EUROPEAN COMMISSION

Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs

Industrial Transformation and Advanced Value Chains

Automotive and Mobility Industries

Brussels, 12.07.2016
Grow.ddg1.c.dir(2016)3880469

Subject: TTIP – Car Safety Analysis in the EU and US in relation to US and

EU Regulatory Standards on Crash Testing

1. BACKGROUND
In the context of the Transatlantic Trade and Investment Partnership (TTIP), the
Automotive and Mobility Industries unit in DG Growth of the European Commission has
been vigilantly investigating whether there is opportunity and justification to work on a
possible mutual recognition of passenger car regulatory standards between the United
States of America and the European Union.

In an early phase of this work it became evident that, on the one hand, the regulatory
standards in the US and EU covering car safety in general differ to such great extent that
it would not be possible to make a meaningful comparison on single subject-to-subject
basis. On the other hand, initial analysis also hinted that the real-world safety offered by
US and EU compliant passenger cars seemed to be on a comparable level1.

This seemed to support the hypothesis that there is an important degree of equivalence in
the respective regulatory approaches in the EU and US. However, such hypothesis
required demonstration, based on specific and reproducible data.

Taking real-world safety as a basis, and considering the performance of interacting

systems of vehicles rather than the comparison of detailed prescriptions on subject-to-
subject level, there appeared to be merit in comparing US and EU real-world car safety
performances for broader regulatory areas (e.g. lighting and vision / to see and to be seen,
and crashworthiness / protection of occupants in case of car accidents).

This scientific basis has therefore been proposed by the EU for developing a
methodology to assess the equivalence, if any, of the regulatory frameworks in the EU
and US of these interacting vehicle safety systems.

Following the outlined approach, the assessment methodology was applied in three Test
Cases prepared by the European Commission with assistance of TRL (Transport
Research Laboratory of the UK)2. These three Test Cases have been discussed between
the EU and US during several trade negotiation rounds.

1
Comparison of 2010 and 2011 US and EU fatality rates per billion km and per million vehicles,
source: OECD/IRTAD, DOT/RITA, DG MOVE/CARE
2
http://www.trl.co.uk/media/750140/trl-spring-news-low-aw.pdf#page=2
Commission européenne, B-1049 Bruxelles / Europese Commissie, B-1049 Brussel - Belgium. Telephone: (32-2) 299 11 11.
Office: BREY 10/043. Telephone: direct line (32-2) 2994933. Fax: (32-2) 2969637. E-mail: [email protected]
2. FIRST AND SECOND TEST CASES
The first Test Case – Proposed Methodology for Automotive Regulatory Equivalence3
validated the proposed methodology with the second Test Case – Recognition of
Equivalence in relation to US and EU Lighting and Vision Standards4 building upon it.

Apart from the confirmation of approach, the other main finding of the exercise was that
despite the identification of clear regulatory areas with equivalent levels of protection in
the real-world, there is a need to safeguard certain specific unique requirements for
obvious and justified safety reasons that are valid predominantly in the EU or vice versa
in the US. Thus, an adapted comparative concept was introduced, based on general
equivalence of requirements but adding region specific regulations and/or requiring slight
modifications to vehicle parts. This concept has been referred to as the “equivalency-
plus” approach.

3. THE EU’S THIRD TEST CASE, COVERING THE REGULATORY AREA ON CRASH
SAFETY

The third Test Case on passenger car crash safety, being the most economically
significant subject in the context of TTIP, closely follows the adapted concept approach
outlined above.

The scientific analysis5 laid out in this Test Case supports that, in broad terms, the level
of protection offered to occupants of EU and US cars currently on the market is
comparable, specifically for the crash safety cluster. It also highlights that for very
specific regulatory areas, notably where regulations exist only in the EU or the US, the
real-world safety analysis supports that such specific areas must continue to be regulated
in the respective territories. This is specifically the case with respect to two main
regulatory areas of pedestrian safety in the EU and roll-over protection in the US which
appear to be of such significance that they should be kept in place, and therefore
equivalence could not be justified.

This would mean that no full EU compliant car would just be able to be exported into the
US and vice versa, without further adaptations. A passenger car coming into the EU from
the US, complying with all US rules, would for instance always have to be supplemented
with at least the EU specific pedestrian safety provisions that would remain to be
required. For the US, full EU compliant vehicles would also at least still have to meet the
specific US roll-over protection requirements. It should be noted that given certain
constraints of the performed analysis, specific regulatory issues will need further scrutiny
to assess whether or not regional specificities need to be maintained for justifiable safety
reasons.

The research analysis indicates that both front crash safety and side crash safety of cars in
the marketplace in the US and EU today are equivalent in broad terms, based on their
real-world safety performance.

3
http://trade.ec.europa.eu/doclib/docs/2015/january/tradoc_153023.pdf
4
http://trade.ec.europa.eu/doclib/docs/2015/february/tradoc_153168.4.9 Vehicles paper second test case.pdf
5
The third Test Case is carried out with reference and limited to the EU-wide CARE database (broad
safety data), US-wide FARS and SDS databases (covering broad and in depth data) as well as the
GIDAS German and RAIDS/CCIS Great Britain accident databases (both covering in depth). EU
results are therefore shown in statistics displaying both German and Great Britain data, which is
deemed representative of the overall EU situation, for comparison with US data.

2
Based on this evidence, the analysis therefore hints at a possible recognition of
equivalence in specific areas. Namely, it could be understood that some of the usual
vehicle modifications and design changes that are to be made by car manufacturers, in
order to meet either EU or US front and side impact regulations alone, would no longer
be necessary, potentially leading to significant economic savings.

It must be made clear however that this analysis is strictly based on real-world
performance of cars and that these cars generally outperform the EU and US regulatory
standards by a significant margin. The analysis should therefore not be understood as
supporting, as such, the assumption that our regulatory standards are equivalent whilst
leading to very similar safety outcomes despite differences.

We finally also note that these findings reflect the present situation of passenger cars on
the EU and US markets and that it is not possible to accurately predict the vehicle fleet
trends. In any case, the third Test Case clearly supports that we should work towards
harmonization of diverging rules applied today.

4. RECOGNITION OF EQUIVALENCE AND HARMONIZED RULES IN THE EU/US

REGULATORY SYSTEMS

In terms of vehicle construction and safety requirements, passenger cars in the US have
to fulfil a set of pre-defined Federal Motor Vehicle Safety Standards (FMVSS).
Normally, compliance is based on self-testing and self-certification by vehicle
manufacturers wishing to sell their cars on the US market. The manufacturer is
responsible for ensuring that vehicles comply at all times. Compliance of products in the
market is regularly checked through market surveillance activities by the US regulators.

For the EU, vehicles have to undergo third-party inspections of a pre-defined set of EU
rules consisting of specific EU and United Nations Economic Commission for Europe
(UNECE) regulations, after which an EU whole vehicle type-approval can be granted.
This approval is required before the vehicle manufacturer can place its car on the EU
market. Regular conformity of production checks carried out by the manufacturer are an
essential element of the type-approval concept. Market surveillance is subsequently
carried out by Member States.

The suggested approach could be made to be compatible with the regulatory systems in
place in the EU and the US. For EU compliance, third party inspections and Member
State type-approval authorization would still be foreseen for US cars coming to the EU.
Specific provisions could be integrated in the EU vehicle type-approval system to
regulate the compliance assessment based on accepted US standards for cars produced in
the US. Likewise, EU manufacturers placing vehicles on the US market would continue
self-certifying compliance with the accepted EU rules. Therefore, the EU type-approval
system, EU and US market surveillance provisions and the US self-certification system
would all not be affected.

5. CONCLUSIONS
The evidence of the third test case supports the conclusion that most cars in the EU and
US today are already exceeding the regulatory prescriptions by a wide margin. In the
context of TTIP, the analysis carried out by the European Commission points to a
solution in which equivalence of some safety regulations can be accepted by the EU and
US. However, it is underlined that a straightforward broad equivalence between EU
compliant and US compliant cars cannot be justified in regulatory terms. Crucial safety

3
adaptations to cars will still be necessary to overcome the differences in safety
performances that are essential for the EU and US situations on specific aspects.

For those areas where the recognition of equivalency is not prevalent, the detailed
analysis and in depth regulatory comparison and scrutiny of individual provision as
included in the Test Cases also provide for a convenient and solid basis for
harmonization of car safety rules.

4
 17 July 2015
TECHNICAL NON-PAPER

THIRD TEST CASE ON RECOGNITION OF EQUIVALENCE IN RELATION TO

US AND EU CRASHWORTHINESS STANDARDS

EXECUTIVE SUMMARY

With the first Test Case on safety-belt anchorages and the second Test Case on lighting
and vision standards, the EU has proposed a sensible approach for allowing the
recognition of alternative standards in the context of recognition of equivalence between
US and EU standards based on real-world safety performance of vehicle systems and
passenger cars as a whole. This third Test Case concerns the broad package of vehicle
crashworthiness and is consistent with the aforementioned overall assessment approach.

The protection of car occupants and other road users that are involved in vehicle crashes
are regulated by a large number of prescriptions, on both the EU and US side. Some of
these measures target very specific full-scale vehicle crash scenarios, while others put
life-saving technologies through their paces on system level. However, the individual
safety systems and technologies thus found in cars on the EU and US marketplace today,
whether they are fitted by virtue of technology prescriptive or outcome oriented
regulations, function together as a whole and are therefore assessed in this Test Case
following the cluster approach.

Given the short timeframe in which this work has been completed and given certain
specific differences between the broad high-level as well as in depth accident data
available in the US and EU, the analysis in this Test Case is carried out with reference
and limited to the EU-wide CARE database (broad safety data), US-wide FARS and
NASS CDS databases (covering broad and in depth data) as well as the GIDAS German
and RAIDS/CCIS Great Britain (both covering in depth) accident databases. The results
are therefore shown in statistics displaying both German and Great Britain data, of which
we are of the opinion that it is representative of the EU situation for the purpose of this
exercise, in comparison to the relevant US data.

In the course of carrying out this analysis, it also became evident that a particular aspect
needed to be addressed in a very specific manner. Namely, this concerns the fact that in
principle no single passenger car model is designed and constructed in a way that it just
barely meets the regulatory prescriptions. In fact, vehicle manufacturers all seem to take
precautions to ensure that specific targets are exceeded by a large safety margin. This
approach is common in the US and in the EU and such ‘over-performing’ cars are thus
common in the marketplace. In addition, some of the regulatory areas and subsequent
vehicle performances are also highly influenced by what is commonly referred to as
‘consumer testing’. This is in particular the case for full-scale vehicle crash ‘new car
assessment programs’ and the relevant 5-star rating schemes (i.e. US NCAP, IIHS and
Euro NCAP). In both the US and the EU, the real-world accident statistics that have been
taken on-board this research work, seem to be equally (positively) influenced by vehicles
that thus exceed the regulatory standards by some margin. We wish to highlight that no
evidence was found that in relation to the regions that have been queried for accident
statistics, namely Germany, Great Britain and the United States, there is an
overrepresentation of safer-than-average cars for the EU or US situation. This means that
the influence of ‘exceeding the regulatory standards’ is homogenous for the EU and US
Commission européenne, B-1049 Bruxelles / Europese Commissie, B-1049 Brussel - Belgium. Telephone: (32-2) 299 11 11.
Office: BREY 10/043. Telephone: direct line (32-2) 2994933. Fax: (32-2) 2969637.

E-mail: [email protected]
regions and therefore defines the de-facto average level of safety resulting from the
regulatory prescriptions with these other factors combined.

The accident data analysis and the review of the wider evidence have identified that cars
in both regions outperform the crashworthiness regulations. However, a limitation of this
assessment is the lack of harmonization with respect to national and in-depth accident
data in the EU and US. Work by the University of Michigan (UMTRI) investigated the
‘hypothesis that passenger vehicles meeting EU safety standards would perform
equivalently to US-regulated passenger vehicles in the US driving environment, and that
vehicles meeting US safety standards would perform equivalently to EU-regulated
vehicles in the EU driving environment’. The UMTRI work also identified that future
work would greatly benefit from the availability of harmonized accident data. The report
found that the likelihood of injury in front and side impacts was lower in EU cars
compared to US ones. This does not agree with the analysis within this report, which
found that they were approximately equivalent. However, the UMTRI report authors urge
caution in interpreting the significance tests and confidence intervals of the results
underpinning their conclusions. In particular, they mention that further work should be
performed to investigate the potential effect of the substantially greater share of SUVs
and pickup trucks in the US population compared to the EU. An effect related to this is
likely to explain the discrepancy mentioned above.

We could clearly identify in the analysis that passenger cars in both the US and the EU
outperform the regulatory prescriptions in terms of crash safety. Cars are (a lot) safer
than can be expected solely on the basis of EU and UNECE or FMVSS standards.
However, it is neither realistic nor appropriate to disregard the findings of this analysis
on that basis, as this concerns the real-world situation with the current EU and US
vehicle fleet and this forms a valid basis for the exercise for recognition of equivalence.

We have considered finding the lowest-performing cars on the EU and US markets and
attempting to test them in a variety of real-world scenarios for the purpose of this
exercise. However, we found this not to be realistic, as such testing would still have to be
done under laboratory conditions and would therefore not truly reflect their real-world
performance. We also took into consideration that two (old) specific vehicle models were
identified of which we suspect that the structural properties and on-board equipment did
not differ significantly for the EU and US versions, that were subjected to US and EU
consumer testing (in 1999), that both scored similarly and significantly below average
(i.e. poorly), yet that were fully compliant with FMVSS and EU mandatory standards.
We also note that as far as we are currently aware, there are no longer any EU or US
vehicle manufacturers that produce car types that have scored poorly in consumer testing
in more recent past.

As regards the consideration of clusters, the approach considering interacting vehicle

systems is still highly relevant for the proposed methodology to assess recognition of
equivalence, and this also counts for the crashworthiness analysis that has been carried
out. Taking all elements on board, we arrive at the following conclusions from the
exhaustive analysis in the report.
Suggested recognition of alternatives or equivalence between EU and US regulatory
prescriptions:

Main Crash Safety Cluster

- Frontal impact including

o Frontal impact crash tests (EU and US)
o Windshield zone intrusion assessment (US)
o Windshield mounting assessment (US)
o Impact from steering control testing (EU and US)
o Seat belts and restraint systems testing (EU and US)
o Seat belt anchorages strength and dimension tests (EU and US)
o Interior fittings assessment (EU and US)
o Bumper testing (US)
- Side impact including
o Side impact crash tests (EU and US)
o Interior impact (EU and US)
o Door locks and latches strength testing (EU and US)
- Rear impact including
o Rear impact crash test fuel tank integrity (US)
o System level testing fuel tank integrity (EU)
o Seat strength and head restraint testing (EU and US)
- Tyre pressure monitoring systems
o TPMS safety functionality testing (EU and US)
- Crash safety cluster “equivalency-plus” items including
o EU and US unique in-vehicle warning labels and placards
o EU and US unique child restraint fitting and anchorages legislation

Safety areas that should continue to be regulated separately:

Rollover safety

- Rollover including
o Roof crush resistance (US)
o Ejection mitigation (US)

Vulnerable road users

- Pedestrian safety including

o Front bumper testing (EU)
o Headform to bonnet testing (EU)
o Brake-Assist system testing (EU)

We note that in some specific cases, for reasons of scope, maximum vehicle mass and/or
height of seats, certain vehicles may be exempted from certain tests as regulated in one of
the regions. In such a case the recognition of equivalence is not supported.

We further note that the front bumper testing in the US concerns not safety, but rather
mitigation of repair costs. In this context we also note that the countermeasures that have
to be put in place on cars to comply with the US bumper requirements are often found to
be detrimental to the level of safety that could be provided to pedestrians hit by such US
compliant front bumper. Given the fact that pedestrian-safe front EU bumpers provide for
a significant benefit in terms of the situation for pedestrians hit by a car, we suggest that
the US front bumper requirements are waived in lieu of pedestrian-safety-compliant EU
vehicles.

Suggested way forward, next steps for consideration:

With reference to the above, we conclude that the identified standards and regulations
may be suggested for recognition as alternatives. We highlight the fact that the situation
as analysed concerns the current vehicle fleet. The findings reflect the situation of
passenger cars on the EU and US markets at this time. Especially within the scope of this
Test Case, it is not possible to accurately predict the vehicle fleet trends following a
successful TTIP conclusion on cars in line with the EU’s suggestions. As the EU and US
fleet may change over time, possibly also influenced by a possible agreement, we
recommend that the EU and US could consider to follow the “equivalency-plus”
approach as outlined, and to limit this to a specific timeframe, namely the short to
medium term.

In general, consumer safety testing is based on regulatory prescriptions taken as a

baseline. The linked rating schemes are subsequently devised to strongly encourage car
makers to excel in terms of safety. The EU or US could act in a manner to simply
strengthen its requirements to make them tougher than those found for the rating
schemes. However, this would then be without appropriate regard for cost-effectiveness
aspects, and would be against the principles of better regulation. Instead, the US and EU
could rather consider to harmonize prescriptions in the medium to long term, and to gear
them towards the levels currently seen for EU and US vehicles in the market as they are
proven to be effective in terms of the safety level that is offered. This normalization of
the safety level is then achieved without unacceptable burden for the EU and US as they
de-facto already meet the proposed harmonized requirements. It may furthermore
improve the situation for cars not produced in the EU and US.

Hence, the suggested way forward following this Test Case is:

 Short to medium term – recognition of alternatives for a specified duration of

time, according to the “equivalence-plus” principle.
 Medium to long term – achieving harmonization reflecting the present status of
vehicles on the EU and US market.
TABLE OF CONTENTS

Executive summary ............................................................................................................. 1

1. Introduction ................................................................................................................. 6
2. Methodology ............................................................................................................... 7
2.1 General approach ............................................................................................... 7
2.2 Vehicle selection ............................................................................................... 7
2.3 Literature survey.............................................................................................. 11
2.3.1 Introduction and rationale.................................................................. 11
2.3.2 Process overview ............................................................................... 12
2.3.3 Research Questions ........................................................................... 12
2.3.4 Search Strategy and Article Selection Criteria .................................. 13
2.4 Accident analysis ............................................................................................. 15
2.4.1 Sources of in-depth accident data ...................................................... 15
2.4.2 Inclusion criteria ................................................................................ 16
2.4.3 Accident analysis variables ............................................................... 16
2.4.4 Accident analysis research questions ................................................ 18
2.4.5 Accident data weightings .................................................................. 18
3. Consumer information testing ................................................................................... 19
3.1 Overview of consumer crashworthiness tests and influence on vehicle
design ............................................................................................................... 19
3.2 Consumer tests and real world crashworthiness performance ........................ 21
4. Characteristics of road casualties in the EU and US ................................................. 23
4.1 Background...................................................................................................... 23
4.2 Overview of EU and US accident taxonomy .................................................. 24
4.2.1 Comparing EU and US road casualties, populations and
vehicle fleets ...................................................................................... 24
4.2.2 Passenger car user characteristics ...................................................... 28
4.2.3 Passenger car collision characteristics ............................................... 31
4.2.4 Summary of EU and US accident taxonomy ..................................... 32
4.3 In depth investigation of EU and US car collision characteristics .................. 32
4.3.1 Overview of EU and US car collision characteristics ....................... 32
4.3.2 Car collision characteristics ............................................................... 33
4.3.3 Car user characteristics ...................................................................... 35
4.3.3.1 Seat belted occupants ........................................................ 35
4.3.3.2 Unbelted occupants ........................................................... 37
4.3.3.3 Occupant position and seat belt use................................... 38
4.3.3.4 Occupant gender ................................................................ 40
4.3.3.5 Occupant age ..................................................................... 42
4.3.4 Overview of EU and US car frontal collisions .................................. 44
4.3.4.1 Direction of Force ............................................................. 44
4.3.4.2 Change in speed on impact ................................................ 45
4.3.4.3 Impact partner.................................................................... 49

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 4.3.4.4 Overlap .............................................................................. 52
4.3.5 Overview of EU and US car side collisions ...................................... 55
4.3.5.1 Direction of force .............................................................. 55
4.3.5.2 Damage location ................................................................ 57
4.3.5.3 Impact partner.................................................................... 59
4.3.5.4 Delta-V .............................................................................. 60
4.3.6 Overview of EU and US car rollovers ............................................... 61
4.3.6.1 Type of rollover ................................................................. 61
4.3.6.2 Seat belt use ....................................................................... 62
4.3.6.3 Occupant ejection .............................................................. 64
4.3.6.4 Direction of rollover .......................................................... 65
5. Assessment of the real world benefits of secondary safety improvements ............... 67
5.1 Estimate of the impact of secondary safety in Great Britain ........................... 67
5.1.1 Introduction ....................................................................................... 67
5.1.2 Changes in accident severity over time ............................................. 67
5.1.3 Modelling method ............................................................................. 68
5.1.4 Modelling results ............................................................................... 70
5.1.4.1 Car driver casualties .......................................................... 70
5.1.4.2 Pedestrian casualties hit by cars ........................................ 76
5.2 Estimated car user casualty benefits of EuroNCAP ........................................ 79
5.3 Review of lives saved by vehicle safety technologies and associated
FMVSS in US .................................................................................................. 80
5.4 Review of UMTRI report “comparing motor-vehicle crash risk of EU
and US vehicles” ............................................................................................. 81
6. Frontal impact............................................................................................................ 83
6.1 Comparison of EU regulations and US standards ........................................... 83
6.1.1 Background........................................................................................ 85
6.1.1.1 Frontal impact crash tests (including OOP) ...................... 85
6.1.1.2 Seat-belts and restraint systems ......................................... 87
6.1.2 Frontal impact crash tests (including OOP tests) .............................. 87
6.1.2.1 In-position crash tests ........................................................ 87
6.1.2.2 Out-of-Position (OOP) tests .............................................. 92
6.1.3 Windshield mounting and windshield zone intrusion ....................... 92
6.1.4 Impact from steering control ............................................................. 93
6.1.5 Seat belts and restraint systems ......................................................... 94
6.1.6 Bumper .............................................................................................. 95
6.1.7 Summary of main notable differences ............................................... 95
6.2 Consumer information testing ......................................................................... 97
6.2.1 Frontal full-width............................................................................... 97
6.2.1.1 Effects on legislative notable differences .......................... 99
6.2.2 Frontal medium overlap .................................................................... 99
6.2.2.1 Effects on legislative notable differences ........................ 101

2
 6.2.3 Frontal low overlap.......................................................................... 101
6.2.3.1 Effects on legislative notable differences ........................ 102
6.2.4 Summary of influence of consumer testing on legislative
differences ....................................................................................... 103
6.3 Discussion of real-world implications of legislative differences .................. 105
6.3.1 Summary of legislative differences and effect of consumer
testing .............................................................................................. 105
6.3.2 Literature review - included articles ................................................ 107
6.3.3 Frontal impact crash tests (including OOP) .................................... 108
6.3.4 Windshield mounting and windshield zone intrusion ..................... 121
6.3.5 Seat belts and restraint systems ....................................................... 121
6.3.6 Bumper ............................................................................................ 124
6.3.7 Influence of EU frontal offset deformable barrier test on other
crash configurations......................................................................... 124
7. Side impact .............................................................................................................. 125
7.1 Comparison of EU regulations and US standards ......................................... 125
7.1.1 Background...................................................................................... 126
7.1.2 Side impact barrier crash tests ......................................................... 126
7.1.2.1 Background ..................................................................... 126
7.1.2.2 Comparison of the legislation.......................................... 127
7.1.2.3 Dummies, Performance Criteria and Limits .................... 130
7.1.2.4 Electric Vehicles .............................................................. 131
7.1.2.5 Discussion ....................................................................... 132
7.1.2.6 Summary of main notable differences ............................. 132
7.1.3 Side impact pole crash tests ............................................................. 132
7.1.3.1 Background ..................................................................... 132
7.1.3.2 Comparison of the legislation.......................................... 133
7.1.3.3 Discussion ....................................................................... 134
7.1.4 Interior fittings / impact ................................................................... 135
7.1.4.1 Background ..................................................................... 135
7.1.4.2 Comparison of the legislation.......................................... 135
7.1.5 Door locks and latches..................................................................... 138
7.1.5.1 Background ..................................................................... 138
7.1.5.2 Comparison of the legislation.......................................... 138
7.1.6 Door crush resistance ...................................................................... 139
7.1.6.1 Background ..................................................................... 139
7.1.6.2 Comparison of the legislation.......................................... 139
7.1.6.3 Discussion ....................................................................... 140
7.1.6.4 Summary of main notable differences ............................. 140
7.1.7 Summary of main notable differences ............................................. 140
7.2 Consumer information testing ....................................................................... 142
7.2.1 Barrier side impact .......................................................................... 143

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 7.2.1.1 Effects on legislative notable differences ........................ 145
7.2.2 Pole side impact ............................................................................... 145
7.2.2.1 Effects on legislative notable differences ........................ 146
7.2.3 Summary of influence of consumer testing on legislative
differences ....................................................................................... 146
7.3 Discussion of real-world implications of legislative differences .................. 147
7.3.1 Summary of legislative differences and effect of consumer
testing .............................................................................................. 147
7.3.2 Literature review and accident analysis .......................................... 148
7.3.2.1 Literature review - included articles ................................ 149
7.3.2.2 Information from Accident analysis ................................ 149
7.3.2.3 Information from Literature ............................................ 154
8. Rollover ................................................................................................................... 157
8.1 Comparison of EU regulations and US standards ......................................... 157
8.1.1 Roof strength ................................................................................... 157
8.1.2 Ejection mitigation .......................................................................... 159
8.1.3 Summary of notable differences ...................................................... 161
8.2 Consumer information testing ....................................................................... 162
8.3 Discussion of real-world implications ........................................................... 162
8.3.1 Literature review - included articles ................................................ 163
8.3.2 Rollover testing ............................................................................... 164
8.3.3 Ejection mitigation testing ............................................................... 167
8.3.4 Roof strength testing........................................................................ 169
9. Rear impact.............................................................................................................. 171
9.1 Comparison of EU regulations and US standards ......................................... 171
9.1.1 Rear impact ...................................................................................... 171
9.1.1.1 Background ..................................................................... 172
9.1.1.2 Rear impact test configurations ....................................... 172
9.1.2 Head restraints ................................................................................. 174
9.1.2.1 Background ..................................................................... 175
9.1.2.2 Head restraint tests .......................................................... 175
9.1.3 Bumpers ........................................................................................... 184
9.1.3.1 Background ..................................................................... 184
9.1.3.2 Bumper testing ................................................................ 184
9.1.4 Summary of notable differences ...................................................... 188
9.2 Consumer testing ........................................................................................... 189
9.2.1 Head Restraints ................................................................................ 189
9.3 Influence of consumer testing on legislative notable differences ................. 190
9.4 Discussion of real world implications ........................................................... 191
9.5 Included articles............................................................................................. 192
9.5.1 Rear impact testing .......................................................................... 193
9.5.2 Head restraint testing ....................................................................... 196

4
 9.5.3 Bumper testing................................................................................. 198
10. Pedestrian ................................................................................................................ 199
10.1 Comparison of EU regulations and US standards ......................................... 199
10.1.1 Notable Differences ......................................................................... 202
10.2 Consumer testing ........................................................................................... 202
10.3 Comparison with legislation .......................................................................... 205
10.3.1 Euro NCAP and legislation overlap ................................................ 205
10.3.2 Noticeable differences between the European legislation and
Euro NCAP ...................................................................................... 205
10.3.3 Effective enhancements to European legislation ............................. 205
10.4 Discussion of real-world implications ........................................................... 206
10.4.1 Literature review ............................................................................. 206
10.4.1.1 Included articles .............................................................. 206
11. Tyre Pressure Monitoring ........................................................................................ 212
11.1 Background.................................................................................................... 212
11.2 Comparison of EU regulations and US standards ......................................... 213
11.2.1 Notable Differences ......................................................................... 214
11.2.2 Discussion of real-world implications ............................................. 214
12. References ............................................................................................................... 218
Glossary ........................................................................................................................... 231
Annex 1 : Comparison tables for EU regulations and US standards – frontal
impact ...................................................................................................................... 233
Annex 2 : Comparison tables for included literature review articles – frontal
impact ...................................................................................................................... 282
Annex 3 : Comparison tables for EU regulations and US standards – side impact ........ 312
Annex 4 : Comparison tables for EU regulations and US standards – Rollover............. 374
Annex 5 : Comparison tables for EU regulations and US standards – Rear impact ....... 405
Annex 6 Comparison tables for EU regulations and US standards – Pedestrian ............ 432
Annex 7 : Comparison tables for EU regulations and US standards – Tyre
Pressure Monitoring ................................................................................................ 507
Annex 8 : Accident data analysis .................................................................................... 515
Annex 8.1 Road Accident In-Depth Studies (RAIDS) - UK ............................ 515
Annex 8.2 German In-depth Accident Study (GIDAS) – Germany ................. 520
Annex 8.3 National Automotive Sampling System – Crashworthiness
Data System (NASS - CDS) – USA .............................................................. 527

5
1. INTRODUCTION

As part of the Transatlantic Trade and Investment Partnership (TTIP), a possible approach for
assessing equivalence between EU and US motor vehicle regulations has been proposed.
While, indeed, it is widely understood that there are differences with regard to individual
technical requirements on motor vehicle safety in both regions, the overall level of safety in
each of the regions can generally be regarded as equivalent.

In this context, the EU has provided two Test Cases on the Recognition of Equivalence with a
proposed methodology for automotive regulations. The first test case considered seat-belt
anchorage points. The analysis was based on accidentology data in combination with other
relevant sources, research and experiments. It was presented in a non-paper1 and discussed in
the 7th negotiation round held in Washington in autumn 2014. The second Test Case
considered the legislation regarding lighting, direct visibility and indirect visibility. It defined
the main areas in which the US and EU technical requirements differ. Published literature
was used to provide an assessment of real-world safety effects, if any, of these differences. It
was presented in another non-paper 2 and discussed in the 8th negotiation round held in
Brussels in February 2015.

This third test case considers crashworthiness which includes the following topic areas:

- Frontal impact including:

o Frontal impact crash tests
o Windshield zone intrusion
o Windshield mounting
o Impact from steering control
o Seat belts and restraint systems (front)
o Seat belt anchorages (test case 1) (front)
- Side impact including
o Side impact crash tests
o Interior impact
o Door locks and latches
- Rollover including
o Roof crush resistance
o Ejection mitigation
o Rollover test (in FMVSS 208)
- Rear impact including
o Seat strength and head restraints (rear)
- Pedestrian protection
- Tyre pressure monitoring

1
http://trade.ec.europa.eu/doclib/docs/2015/january/tradoc_153023.pdf
2
http://trade.ec.europa.eu/doclib/docs/2015/february/tradoc_153168.4.9%20Vehicles%20paper%20second%20t
est%20case.pdf

6
2. METHODOLOGY

2.1 GENERAL APPROACH

The comparison of US and EU crashworthiness legislation forms the basis of this Test Case.

The evidence collated within this report was gathered through:

 Literature survey: The aim is to identify previous research that considered the effects
of differences in regulatory requirements between the US and EU, and whether these
explained, either partly or fully, any differences or effects observed in the respective
casualty populations.

 Accident analysis: The aim is to describe, as far as practicable, the nature of passenger
car occupant casualties in each region. The real world crashworthiness performance of
pertinent vehicles in the EU and US is assessed to determine how they compare.

 Comparison of EU Regulations and US FMVSS: An in-depth review of the respective

region’s regulations (frontal, side, rollover, rear, pedestrian and tyre pressure
monitoring), where notable differences were highlighted. These differences were
selected based on their likelihood to effect real world safety.

 Review of consumer information testing programmes: Passenger cars are designed to

meet legislation and to score highly in full-scale vehicle crash ‘new car assessment
programmes’. This Test Case considers the relevant 5-star rating schemes (i.e. US
NCAP, IIHS and Euro NCAP) in both the US and the EU. Consideration is given to
how these schemes enhance minimum legislative standards and in some cases ‘plug’
gaps between differences between the EU and US

 Stakeholder engagement: A small number of OEMs and Tier 1 suppliers were

interviewed and their opinions sought with regard to the practical implications of
conflicts or notable differences between EU and US crashworthiness legislation.

The report collates all the information above.

2.2 VEHICLE SELECTION

In order to be able to compare the potential effect of mutual recognition of vehicle

regulations, one essential parameter to consider is the definition of vehicle categories. In the
EU, a distinction is made between passenger vehicles and goods vehicles based on the
technical specifications of each vehicle. In the US, the vehicle categories have a more
qualitative definition. This is noted in the preamble to UN Special Resolution No.1 (UN,
2005):

There were distinct philosophy differences in vehicle definitions among the

regulations of European Union, Japan and the United States of America. As an
example, the distinctions between passenger cars and trucks made by Japanese
and European Union regulations are based on the quantitative comparisons
between the relative accommodations for passengers and cargo in a given
vehicle (e.g., comparisons of passenger mass to cargo mass or passenger space
7
 to cargo space). The distinctions between passenger cars and trucks made in the
regulations of the United States of America are based on qualitative definitions
(e.g., for "transportation of property or special purpose equipment or
constructed on a truck chassis or with special features for occasional off-road
use").

In the EU, category M1 vehicles are ‘passenger cars’, which is defined in EC Directive
2007/46/EC (known as the ‘Framework Directive’, consolidated to Regulation (EU) No
2015/166) as follows (Annex II, Part A: Criteria for vehicle categorisation – Section 1:
Vehicle categories):

Category M

Motor vehicles designed and constructed primarily for the carriage of

persons and their luggage.

Category M1

Vehicles of category M, comprising not more than eight seating positions

in addition to the driver’s seating position.

Vehicles belonging to category M1 shall have no space for standing

passengers.

The number of seating positions may be restricted to one (i.e. the driver’s
seating position).

In contrast, Category N vehicles are ‘goods vehicles’, defined as follows:

Category N

Motor vehicles designed and constructed primarily for the carriage of

goods.

Category N1

Vehicles of category N having a maximum mass not exceeding 3,5 tonnes.

Part A, Section 3 of the Framework Directive defines criteria for determining whether a
vehicle can be categorised as category N, based on the technical features of the vehicle. In
summary, this includes:

 The compartment(s) where all the seating positions are located shall be completely
separated from the loading area, or the loading area shall be provided with load
securing devices designed to protect occupants against the displacement of the load
during driving, including severe braking and cornering (i.e. meeting Sections 3 and 4
of ISO 27956:2009)

8
  Vehicles shall show a goods-carrying capacity equal or higher than the person-
carrying capacity expressed in kg (using a specified equation to calculate the
capacities)

Furthermore, to be categorised as N1, numerous additional criteria must be met and failure to
meet any of the criteria explicitly means that the vehicle shall be categorised as M1. These
criteria include:

 Specifications of goods loading apertures (i.e. doors and tailgates)

 A generally flat cargo area, of at least 40% of the wheelbase for vehicles with one row
of seats and 30% of the wheelbase for vehicles with two or more rows of seats

In the US legislation, vehicles that would be categorised as M1 in the EU are categorised as

either ‘passenger cars’ or ‘multipurpose passenger vehicles’. (Other categories are defined for
e.g. large goods vehicles). CFR 49 Part 571.3 (GPO, 2015) defines a passenger car as:

A motor vehicle with motive power, except a low-speed vehicle, multipurpose

passenger vehicle, motorcycle, or trailer, designed for carrying 10 persons or
less.

A ‘low-speed vehicle’ has a maximum speed of 40 km/h, while a ‘multipurpose passenger

vehicle’ is defined as:

A motor vehicle with motive power, except a low-speed vehicle or trailer,

designed to carry 10 persons or less which is constructed either on a truck
chassis or with special features for occasional off-road operation.

In practice, this seems to mean that conventional cars (saloons/sedans, estates/station wagons,
hatchbacks and convertibles) are considered to be passenger cars, while other M1 vehicles
(SUVs, crossovers, MPVs/people carriers/minivans) would be considered to be multipurpose
passenger vehicles. The distinction is important, because in some cases the legislative
requirements differ for passenger cars and multipurpose passenger vehicles, or the dates of
application of legislation may be different. It would appear that the distinction arose due to
the different construction methods for the two groups of vehicles, with the multipurpose
passenger vehicles originally having a truck-like body-on-frame / ladder chassis construction,
and passenger cars having a unibody / monocoque construction. However, many
multipurpose passenger vehicles now have a unibody construction, often sharing a platform
with passenger cars from the same manufacturer.

Many of the US crash requirements for multipurpose passenger vehicles and for ‘trucks’
weighing less than 4,530 kg are the same, where truck is defined as:

A motor vehicle with motive power, except a trailer, designed primarily for the
transportation of property or special purpose equipment.

While specific examples are not given in the US legislative text (nor are examples given in
EU legislation), some guidance on the vehicles that would be included in each category can
be derived from the photographs of vehicle certification labels that are included in NHTSA
crash test reports and from the examples given for different vehicle types in the NASS-CDS
coding manual (DOT, 2014). For example, the Audi Q5 and Q7, Chrysler Voyager, Land
9
Rover Discovery, Lexus RX-300, Range Rover, Renault Espace, Toyota Rav4, and Volvo
XC60 and XC90 are all certified as multipurpose passenger vehicles, not as passenger cars.
The Audi Q5, for example, shares a platform with the Audi A4 saloon, which is certified as a
passenger car.

The following vehicles are certified as a ‘truck’ in the US, and would be a Category N1
vehicle in the EU: Ford F150, Ford Ranger, Nissan Navara/NP300/Frontier. In the US the
legislative safety requirements for these vehicles would be similar to those for multipurpose
passenger vehicles such as SUVs and crossovers, whereas in the EU the trucks would have
different legislative safety requirements. For example, in the US trucks would be subject to
the same frontal impact crash test requirements as passenger cars, whereas in the EU the
frontal offset crash test in Regulation 94 would only apply to passenger cars (with a mass not
exceeding 2.5 tonnes) and would not apply to trucks (which would be classified as N1
vehicles).

EU legislation also includes exemptions for ‘small series’, ‘off-road’ and ‘special purpose’
vehicles:

Small series: vehicle types manufactured in volumes not exceeding 1000 per year

M1/N1 off road: with driven front and rear axles, able to climb a 25% gradient, with
defined approach, ramp and departure angles, and defined ground clearances

Special purpose: including motor caravans (RVs), armoured vehicles, ambulances,

hearses, and wheelchair accessible vehicles

Similarly, US legislation includes exemptions e.g. for campers, walk-in vans, vehicles
manufactured for operation by persons with disabilities, and vehicles manufactured
exclusively to be sold to the US Postal Office.

For the purposes of the literature review and accident analysis, the following vehicle
classifications were selected:

Table 1: Definition of passenger cars

EU US

M1 Passenger cars and multipurpose passenger vehicles (not including passenger car
derivatives such as car-derived pickups/vans, stretched chassis limousines or
large vans, which would be likely to be classifies as M2 or N1 vehicles in the
EU depending on the body type and intended function)

For the analysis of US accident data, the above classifications were approximated using the
following ‘BODYTYPE’ codes:

10
 Table 2: US selected vehicles (from accident data descriptions)

Code Description

01 Convertible

02 2-door sedan, hardtop, coupe

03 3-door/2-door hatchback

04 4-door sedan, hardtop

05 4-door/5-door hatchback

06 Station wagon (excluding van and truck based)

07 Hatchback, number of doors unknown

08 Other automobile type (specify)

09 Unknown automobile type

14 Compact utility vehicle (e.g. Audi Q5, Ford Explorer, Jeep Wrangler, Land
Rover Discovery, Lexus RX-300, Toyota Rav4, and Volvo XC60 and XC90)

15 Large utility vehicle (e.g. Chevrolet Tahoe, Ford Expedition, Range Rover,
Toyota Landcruiser)

16 Utility station wagon (e.g. Chevrolet Suburban, Ford Excursion)

17 3-door coupe

19 Utility vehicle, body type unknown

20 Minivan (e.g. Chrysler Grand Voyager, Mazda MPV, Toyota Previa)

It should be noted that it is likely that there will be a small number of vehicles in the NASS-
CDS using these body codes that would be classified as category N1 in the EU.

2.3 LITERATURE SURVEY

2.3.1 INTRODUCTION AND RATIONALE

An important component of this work was to review literature for each crashworthiness topic
considered by this test case. The aim of this was to identify previous research that considered
the effects of differences in regulatory requirements between the US and Europe, and whether
these explained, either partly or fully, any differences or effects observed in the respective
casualty populations.

11
Prior to commencing the review, it was known that a considerable body of research existed
on these crashworthiness topics. The literature review process was therefore designed to
systematically identify and appraise available abstracts that were focussed on particular
regulatory differences and their casualty outcomes. In overview, this comprised forming a
research question based on notable differences in regulation and the associated outcome, and
designing a literature search on each research question. This included a defined grading
exercise which meant only the key references identified were used in the review of literature.

This approach meant that the literature for each crashworthiness topic used a structured and
consistent approach that:

 used the same systematic approach to define research questions based on regulatory
differences that had been identified between the EU and US;
 used the same assessment procedure and grading approach to select the full versions
of the sources for final review and inclusion in the review;
 carried out the search using identical databases and data sources.

2.3.2 PROCESS OVERVIEW

The literature review comprised three approaches. The main literature search was
complemented by a search using Google Scholar and also a search of key online databases.
The Google Scholar search used the same approach as the main literature search and used
specific research questions to construct a logical search.

The key databases searched were as follows:

 NHTSA - http://www.nhtsa.gov/Research
 UMTRI - http://www.umtri.umich.edu/our-results/publications
 Cordis - http://cordis.europa.eu/projects/home_en.html
 ESV (years 2011 onward) -
http://www.nhtsa.gov/Research/Enhanced+Safety+of+Vehicles+(ESV)/ESV+Proceed
ings
 Federal Register https://www.federalregister.gov/articles/search#advanced (Accepts
Boolean logic – search for Rules and Proposed Rules)
These were searched using Boolean search terms where this facility was available for the data
source in question. Where this was not available ‘scope’ keyword terms were used to identify
any relevant literature.

2.3.3 RESEARCH QUESTIONS

For each crashworthiness topic, the first task undertaken was to review and compare
regulation (and consumer testing programmes) in the EU and US. This process led to the
identification of notable differences. These were assessed in terms of their hypothesised
effect on casualty outcome and research questions designed to query the literature and locate
relevant research.

The research questions used a modified version of the PICO (Population, Intervention,
Comparator and Outcome) approach, namely: Scope (S), Difference (D), Outcome (O). This
structure was used to formulate each research question. For example:
12
“Do car passengers in frontal impacts [S], when unbelted [D] experience more severe injury
[O]?”

For each of ‘Scope’, ‘Difference’ and ‘Outcome’, keywords were generated that described
each aspect. For the example provided here, these might be:

 Scope: “frontal impact” “frontal crash” “frontal collision”…etc.

 Difference: “belted” “unbelted” “belt use”...
 Outcome: “injury” “injury severity” “KSI” “injury severity”…

Once the full list of descriptors for each aspect of ‘Scope’, ‘Difference’, and ‘Outcome’ was
finalised, these were transferred in to a query with the following logical structure:

(“A” or “B” or “C”) AND (“D” or “E” or “F”) AND (“G” or “H” or “I”)

Where A, B, C are ‘Scope; keywords, D, E, F are ‘Difference’ keywords, and G, H, I are

‘Outcome’ keywords.

Exclusion criteria for publication year were included in the final research questions such that
all sources with a publication year prior to the year 2000 were excluded. This step was to
ensure that research included was contemporary, although in some cases this included data
from before 2000; this was accounted for when the full source texts were reviewed.

2.3.4 SEARCH STRATEGY AND ARTICLE SELECTION CRITERIA

The search logic for each crashworthiness topic was passed to the TRL Library and
Information Centre; which provides archiving and records management services for TRL
projects and publishing support. The following data sources were searched using the search
strategy outlined in Section 2.3.3 above.

TRID (Transport Research International Documentation) TRID is a new database that

combines ITRD (OECD’s International Transport Research Documentation database) and the
US-based database TRIS (Transport Research Information Service). Together they form one
of the most comprehensive transport research databases available today. http://trid.trb.org/

Science Direct ScienceDirect is a leading full-text scientific database offering journal articles
and book chapters from more than 2,500 peer-reviewed journals and more than 11,000 books.
http://www.sciencedirect.com/

ITRP Transport Research Portal ITRP is portal for accessing information from databases
of past and ongoing research projects worldwide. This portal is an international collaborative
project funded by the European Commission FP7 programme. Its aim is to foster a closer and
more effective communication between researchers working in the field of transport
technologies, both in the EU and internationally. It seeks to do this by facilitating exchange
of information and developing a framework for long term collaboration.
http://www.intransport.eu/search/index.php

13
ARRB Knowledge Base The ARRB knowledge base a free full text searchable resource of
ARRB publications from 1962 to the present, including conference papers, reports and
bulletins. There are over 5,000 items in the resource with more being added as they are
scanned. http://arrbknowledge.com

PubMed Is a public version of MEDLINE, arguably the world’s largest medical database. Its
records contain many levels of medical research from meta-analyses and systematic reviews
to case studies. Includes accident studies, safety, human factors, psychology, and so on.
http://www.ncbi.nlm.nih.gov/pubmed/

TRIP (formerly the Transport Research Knowledge Centre) TRIP gives you an overview of
in-progress and completed transport research activities at European and national levels, based
around the EU research framework funding programme. http://www.transport-
research.info/web/index.cfm

Google Scholar is a freely accessible web search engine that indexes the full text or metadata
of scholarly literature across an array of publishing formats and disciplines. Released in beta
in November 2004, the Google Scholar index includes most peer-reviewed online journals of
Europe and America's largest scholarly publishers, plus scholarly books and other non-peer
reviewed journals.

This review attempted to identify all English language articles published after December 31st
1999 which met the defined research question logic (see Section 2.3.3).

All duplicate articles, editorial letters, animal studies, and studies which used outdated (e.g.
1980s or earlier) data were excluded. Article titles and abstracts were screened for relevance,
with identified articles included for the detailed review of the full manuscript. Finally,
alongside the specific searches, the bibliographies of all studies selected for full text review
were recursively searched.

Literature was graded by assigning the scope of the study to one of the following categories:

 Accident data based on human epidemiological studies

 Anthropometric Test Devices
 Post Mortem Human Surrogates
 Modelling studies
Appraisal procedures were performed using a standardised appraisal form; studies were
classified by level of relevance. For those sources categorised as ‘Accident data based on
human epidemiological studies’ a scale of 0 to 3 was assigned to each of the aspects “Scope”,
“Difference”, and “Outcome” defined in each research question, where 0 was ‘not relevant’
and 3 ‘very relevant’. Using this method, the relevance of each source was rated:

 Low if rating <=3

 Medium if rating: 4-6
 High if rating: 7-9

Full versions of all medium and high rated sources were subsequently requested. Studies
were further classified by methodological quality of evidence. This was achieved by listing
14
potential confounders. The source was rated ‘Low’ if the methodology had flaws and ≥3
potential confounders, ‘Medium’ if there were between 1-2 potential confounders, and ‘High’
if the method was found to have no confounders. For the literature review, the ‘Medium’ and
‘High’ quality sources were included, with remaining sources disregarded at this stage.

For each crashworthiness topic, the results of the literature review for each research question
are presented in the ‘real-world implications of legislative differences’ sub-sections of the
main sections, e.g. for frontal impact, Section, 6.3.

2.4 ACCIDENT ANALYSIS

The accident data analysis provides a high level overview of the road casualties in the EU28
and the US. Further in-depth analysis then examines the characteristics of passenger car
collisions in Great Britain, Germany and US.

2.4.1 SOURCES OF IN-DEPTH ACCIDENT DATA

The US is a single country, and national crash datasets are made available to the general
public free of charge. There are three major national datasets of crashes: 1) the Fatality
Analysis Reporting System (FARS); 2) the National Automotive Sampling System—
Crashworthiness Data System (NASS-CDS or CDS); and 3) the National Automotive
Sampling System—General Estimates System (NASS-GES or GES).

FARS is a census of fatal crashes on public roads in the US. CDS is an annual probability
sample of approximately 3500-4500 tow-away crashes involving light duty vehicles. The
CDS data collection includes in-depth crash investigation and estimation of Delta-V using the
software WinSmash (an enhanced and updated version of the accident reconstruction
software CRASH3), as well as details on injury outcome. Finally, GES is an annual
probability sample of approximately 50,000 police reported crashes. The basis for the data in
GES is information contained in state police crash reports, but the data elements are coded to
a national standard. To perform estimates of injury risk for occupants of US vehicles, the
CDS dataset was used because it contains measures of crash severity and injury level. GES
and FARS were used for analysis of crash avoidance.

The German In-Depth Accident Study (GIDAS) is the largest database of its kind in Europe.
Data collection commenced in 1999 and was initiated by the German Federal Highway
Research Institute (BASt) and the German Association for Research on Automotive
Technology (FAT). Currently, GIDAS has 16 sponsors who have exclusive access to the
database. Crash data is collected by two teams, one at the Hannover Medical School (MHH)
and one at the Traffic Accident Research Institute (VUFO) of Technische Universität
Dresden (TU Dresden). A statistically developed sampling plan defines the work shifts for
the teams, which covers 12 hours per day. If an accident occurs with at least one injured
person suspected, the GIDAS team is notified directly by the local police or rescue service
via radio communication. Sample criteria for the GIDAS database are that at least one
accident participant has been injured and the accident occurs within the shifts and the
specified regions. After 15 years of continuous data collection, the database includes over
28,000 injury crashes (i.e. crashes in which at least one person was injured) investigated in-
depth. Delta-V values are reconstructed using a method based on the conservation of
momentum in the crash, predominantly with the software PC-Crash.

15
The Road Accident In Depth Studies (RAIDS) programme {formerly called the Cooperative
Crash Injury Study (CCIS)} is a major crash database in Great Britain in which data
collection, funded by the UK Department for Transport and industrial partners, started in
1983. The database contains more than 15,000 crashes. Crash events are collected according
to a stratified sampling procedure, which favours cars containing fatal or seriously injured
occupants. More specifically, the inclusion criteria in RAIDS require that at least one
passenger car, which is younger than 7 years has been involved in the crash and towed from
the scene and that at least one crash-involved occupant was injured, according to the police
report. For this study, data were collected retrospectively (several days after the crash) by
teams of investigators from Birmingham Automotive Safety Centre (BASC) based at the
University of Birmingham, Vehicle Safety Research Centre (VSRC) based at Loughborough
University, Transport Research Laboratory (TRL) and Vehicle Operations and Standards
Agency (VOSA) from various locations in England. Delta-V reconstruction in RAIDS is
damage-based, using the software AI-Damage which is, similar to WinSmash, based on the
CRASH3 algorithm. Collisions up to 2010 were included.

2.4.2 INCLUSION CRITERIA

The accident data sample was based on the inclusion criteria that were applied to each
participating database. In this case, the inclusion criteria for the data to be included in the
analysis were as follows:
1. Collision occurred on or after January 2004
2. M1 vehicles (passenger cars) only as described in Section 2.2, excluding car derived
vans (CDVs)
3. Year of manufacture on or after 2004 (except where specific analyses state any year
of manufacture was allowed)
4. Occupant severity and Maximum Abbreviated Injury Score (MAIS) were known
(those who were known to be fatal with MAIS 9 were also included)
5. Occupant position in the vehicle was known
6. Occupant age was known
7. Occupant gender was known
8. Someone injured in the crash (MAIS 1+ or police reported injury)
9. At least one vehicle towed
Where the information for the inclusion criteria was missing or unknown the occupant was
excluded from the analysis.

2.4.3 ACCIDENT ANALYSIS VARIABLES

A range of data fields were extracted for each casualty record from the in-depth accident
databases in Germany, the UK and the US, and these were then analysed and compared:
 MAIS: 0 to 6 (AIS 1990 with 1998 revision)
 Occupant severity: Uninjured, slight, serious, fatal
 Position: Driver, Front seat passenger, Rear occupant, 3rd row occupant
16
  Belt used: Yes, No, Unknown
 Gender: Male, Female (unknowns were excluded)
 Age: 0-4, 5-7, 8-11, 12-15, 16-19, 20-24, 25-29, 30-39, 40-49, 50-59, 60-69, 70+
(unknowns were excluded)
 Year of manufacture: year the vehicle was manufactured
 Collision type: Frontal, Side, Rear, Other, Multiple, Rollover
o Frontal: Number of impacts = 1, no rollover, CDC side = F
o Side: Number of impacts = 1, no rollover, CDC side = R or L
o Rear: Number of impacts = 1, no rollover, CDC side = B
o Other: Number of impacts = 1, no rollover, CDC side = T, U or 9
o Multiple: Number of impacts > 2, no rollover, (most severe impact was used
or the first impact if they were low severity (CDC extent ≤ 2)
o Rollover: Number of rolls ≥ 0.25
Collision type was then broken down into specific characteristics to describe the type of
collision:
 Front and side impact characteristics:
o Object hit: Car, Two-wheeler, MPV/LGV, HGV/PSV, Narrow object (<41cm
diameter), Wide object (≥ 41cm diameter), Pedestrian, Other, Animal,
Unknown
o PDOF: 1 to 12 clock ray
o Overlap: 0 to 100%
o Damage pattern: CDC damage pattern
o Structural loading: describes longitudinal and engine loading; OS, NS, Engine,
NS + Engine, OS + Engine, OS + Engine + NS, OS + NS, Unknown
o Crush extent: CDC extent
o Delta-V: 0-10, 11-20, 21-30, 31-40, 41-50, 51-60, 61-70, 71-80, 81+
o Airbag activation: Frontal present, Frontal deployed, Side present, Side
deployed, None present/deployed

 Rollover characteristics:
o Belt type: Lap and diagonal static, Lap and diagonal auto, Lap belt, Full
harness, Wheelchair restraint, None fitted, Other, Unknown, No belt
o Ejection type: Full, partial, not ejected
o Ejection route: Windscreen, Side window, Rear window, Side door,
Hatch/estate door, Sunroof, Other, Unknown, Not ejected
o Roll direction: To O/S, to N/S, Rear over front, Front over rear, Unknown,
None
17
 o Roll initiation: Kerb, Gradient down (ditch), Grass/ earth or soft surface,
Tarmac / hard surface, Other vehicle, Safety barrier / similar low structure,
Fence / similar high structure, Sharp turning or spinning of the vehicle,
Unknown, Other, None

2.4.4 ACCIDENT ANALYSIS RESEARCH QUESTIONS

For front, side and rollover collisions, the review and comparison of regulation (and
consumer testing programmes) in the US and EU led to the identification of notable
differences. These were assessed in terms of their hypothesised effect on casualty outcome
and research questions designed to query the accident data to evaluate if real world injury
outcome was affected.

2.4.5 ACCIDENT DATA WEIGHTINGS

All of the accident data presented in this report was weighted to the relevant country’s
national level. A detailed methodology for how each dataset was weighted can be found in
Annex 8.

18
3. CONSUMER INFORMATION TESTING

3.1 OVERVIEW OF CONSUMER CRASHWORTHINESS TESTS AND INFLUENCE ON VEHICLE

DESIGN

The crashworthiness of passenger cars has improved greatly over the past 20 years. This has
been driven by legislative requirements and the response of vehicle manufacturers to
assessment programmes which supply consumers with vehicle safety rating information. The
overall aims of these programmes are to:

 Provide consumers with a measure of the relative safety potential of cars, so that they
can identify the safest vehicle for their needs
 To establish market forces to encourage vehicle manufacturers to design a higher
level of safety into their vehicles than that required by legislation

The following programmes exist in Europe and the USA:

Europe:

The European New Car Assessment Programme (Euro NCAP), which is sponsored by
governments and safety related organisations and was launched in December 1996.

 Currently, Euro NCAP rates vehicles from zero to five stars based on performance in
four areas: Adult occupant protection (for the driver and passenger); Child occupant
protection; Pedestrian protection; and Safety Assist technologies. Individual scores for
each areas and further breakdowns are available also.

USA:

The United States New Car Assessment Programme (US NCAP), which is funded by
NHTSA and started testing in 1978.

 Currently, US NCAP rates vehicles from zero to five stars based on performance in
frontal, side and rollover tests. Star ratings are also given for each of these tests. In
addition, it is also reported whether or not the vehicle is fitted with recommended
advanced safety features such as forward collision warning.

The Insurance Institute for Highway Safety (IIHS) and Highway Loss Data Institute safety
awards which is self-funded and was launched around the mid-1990’s.

 Currently, IIHS rates vehicles good, acceptable, marginal or poor, based on

performance in five tests: moderate overlap front, small overlap front, side, roof
strength and head restraints. In the area of crash avoidance and mitigation, IIHS
assigns vehicles with available front crash prevention systems ratings of basic,
advanced or superior, based on the type of system and performance in track tests.

The effect of these assessment programmes is substantial and is illustrated by the following:

 Vehicles achieving four or five stars (max = five) in US-NCAP increased from less
than 30% in 1979 to greater than 98% in 2007 (NHTSA, 2008)(NHTSA 2008).

19
  Vehicles rated “good” by IIHS have increased from less than 50% in 1995 to 91% in
2009 (Sherwood et al., 2009).

However, it should be noted that legislative requirements were also updated throughout this
period and therefore will likely also have contributed to the improved performance observed,
although to what extent, it is not possible to determine.

The relationship between these assessment programmes and injury outcomes in real-world
crashes is illustrated by the following:

 Kullgren et al. found a good correlation between Euro NCAP test results and real-
world injury outcomes (Kullgren et al., 2010). The largest difference in injury risk
between 2- and 5-star rated cars in Euro NCAP was found for risk of fatality,
confirming that car manufacturers have focused their safety performance on serious
crash outcomes. In addition, Euro NCAP crash tests were shown to be highly
correlated with serious crash performance, confirming their relevance for evaluating
real-world crash performance.
 Farmer examined the relationship between the IIHS frontal offset safety ratings and
real-world fatality rates and showed that there was a clear trend for better-rated
vehicles to have lower driver fatality risk, although the correlation was not uniform
across all vehicle groups or statistically significant in all cases (Farmer, 2005).

From the above, it can be seen that consumer information test programmes have, to a large
extent, achieved their aim to establish market forces to encourage vehicle manufacturers to
design a higher level of safety into their vehicles than that required by legislation. Therefore,
they now have a very large effect on a vehicle’s crashworthiness safety performance.
Compared to the effect of legislation, this effect can be categorised into the following two
parts:

 Enhancement of the legislation by assessing a vehicle’s safety performance using

similar methods (tests) to those used in the legislation, but with more stringent
performance limits and /or (small) changes to the test configuration.
o E.g. The Euro NCAP frontal impact test is similar to the UN Regulation 94
test but is performed at a higher test speed (64 km/h compared to 56 km/h) and
has ‘green’ performance rating limits that are far in excess of the legislative
ones (e.g. chest deflection 22 mm compared to 50 mm for Regulation 94,
which represents a much lower risk of injury 5% risk of injury ≥ AIS
3compared to 50% risk of injury ≥ AIS 3).
 Enhancement of the legislation by assessing a vehicle’s safety performance using
different methods to those used in the legislation. In some cases these assessments
may use similar methods to those used by the legislation in another jurisdiction. In
these cases the consumer testing can be seen to plug (fill) a difference between the
legislations.
o E.g. In the US legislation, there is no high speed frontal ODB test to assess
and control a vehicle’s frontal impact crashworthiness. . However, the IIHS

20
 use a high speed frontal ODB test to assess a vehicle’s occupant protection, in
particular its structural performance.
o Vice-versa in the EU legislation, there is no full width test to assess and
control a vehicle’s frontal impact crashworthiness. However, since the
beginning of 2015, Euro NCAP use a full width test to assess a vehicle’s
occupant protection, in particular the performance of the restraint system.

If the safety requirements for a vehicle are considered from a vehicle manufacturer’s design
point of view, they can be divided into three categories as shown in Figure 1 below.

Figure 1: Categorisation of Vehicle manufacturer (VM) crashworthiness design

requirements.

All manufacturers are obliged to meet the legislative requirements. Most manufacturers aim
to achieve good ratings in consumer assessment programmes, which demand a safety
performance over and above that required by the legislation. A few manufacturers, who
generally have a safety as a major part of their brand, also have further requirements which
aim to improve safety in areas they have identified individually and may not be assessed by
consumer rating programmes.

3.2 CONSUMER TESTS AND REAL WORLD CRASHWORTHINESS PERFORMANCE

An overall five star Euro NCAP rating is now very common amongst cars tested 3. Recent
work by TRL (Wallbank et al., 2015) showed the average overall star rating, weighted by

3
http://www.euroncap.com/en/ratings-rewards/latest-safety-ratings

21
traffic for cars in London, to be close to 5 stars. Similarly five star safety ratings achieved
under NHTSA are also now very common4.

This high level of performance has not always been the case for EU and US compliant cars.
Both Euro NCAP and IIHS have tested EU and US compliant versions of the same ‘twin’
cars represented by the Chrysler Voyager for EU and Dodge Caravan for US in 19995, as
well as the Opel/Vauxhall Sintra for EU and Pontiac Trans Sport for US, also in 19996

Consumer testing programmes in the EU and US have evolved over time and they continue to
develop and introduce new requirements, typically at a rate much quicker than legislation can
feasibly achieve. The public’s desire and the motor manufacturers’ acceptance and
cooperation with these programmes has resulted in four or five star cars dominating the
market place, such vehicles are now prevalent within the EU and US fleets. Obtaining a good
consumer test rating generally requires a car to meet more stringent crashworthiness criteria
than is required by the minimum mandatory measures stipulated in EU Regulations or the
Federal Motor Vehicle Safety Standards. Therefore, the influence of consumer testing on the
real world safety performance of modern vehicles in the EU and US is a significant factor to
consider.

It is difficult to differentiate between the effect of legislation and the effect of consumer
testing programmes. However, the legislation is essential, as it provides the base upon which
further tests and safety design improvements can be based. This argument is further
complicated because many manufacturers increasingly design and build ‘world vehicles’ and
seek to harmonise as much of the design as practicable to maximise efficiency.

Therefore, a car maker planning to sell a vehicle in more than one world region, must meet
all the relevant international vehicle legislation; and to help support their reputation and aid
sales, they generally aim to score at least 4 or more commonly 5 stars in the local consumer
testing programmes. This means that manufacturers are adept at meeting different standards
and designing and building cars for international markets. There are some conflicting criteria
between the EU and US regions, and therefore changes are required for vehicles to be sold in
each area, but standardisation is an increasing factor within the global market place.

This all means that comparing the crash performance of cars based on the legislative
requirements in different regions is complicated, because the vehicle design is also influenced
by international consumer testing programmes, other world region legislation and in-house
manufacturer testing standards. The quantification of this is discussed further in Sections 4
and 5.

4
http://www.safercar.gov/Vehicle+Shoppers/5-Star+Safety+Ratings
5
http://www.euroncap.com/en/results/chrysler/voyager/15497 -
http://www.iihs.org/iihs/ratings/vehicle/v/dodge/grand-caravan-minivan/1999
6
http://www.euroncap.com/en/results/opel/vauxhall/sintra/15505 -
http://www.iihs.org/iihs/ratings/vehicle/v/pontiac/trans-sport-montana-minivan/1999

22
4. CHARACTERISTICS OF ROAD CASUALTIES IN THE EU AND US

4.1 BACKGROUND

According to the World Health Organisation (WHO), there were approximately 1.24 million
road traffic deaths globally in 2010. Males account for 77% of the fatalities and middle-
income countries have the highest burden and the highest road traffic death rates.

In 2012 there were 28,177 and 33,782 road deaths in the EU28 and the US respectively,
which combined represents 5% of the world’s road traffic fatalities. There are a variety of
different ways of quantifying the relative effect or harm of road traffic accidents compared to
other sources of injury or disease. One harm measure calculates the “years of life lost”, by
determining the difference between the age at death, and the life expectancy for a person at
that age. A variation of this is the “years of working life lost”, which provides a simple way
of ranking causes of death by their economic effect.

Table 3 shows the top 10 causes of death in England and Wales in 2006, sorted by the years
of working life lost due to these causes. The data for the table were obtained from the Office
for National Statistics (ONS) “Mortality Statistics” publications (Office for National
Statistics 2008). The years of working life lost were calculated by summing the number of
years lost between the ages of 15 and 64.

Table 3: Causes of death in England and Wales in 2006, ranked by ‘Years of working life
lost’

Years of working life lost

Cause Number of deaths (2006) (thousands)

Ischaemic heart diseases 82,619 99

Land transport accidents 2,990 78

Diseases of the liver 7,281 69

Intentional self-harm 3,331 64

Malignant neoplasm of trachea,

bronchus and lung 29,332 49

Malignant neoplasm of breast 11,011 43

Cerebrovascular diseases 48,389 36

Accidental poisoning by and

exposure to noxious substances 1,072 26

Malignant neoplasm of colon,

rectum and anus 14,022 25

Malignant neoplasm of brain 3,112 24

All causes, all ages 502,599 1,262

23
The Table shows that road traffic accidents were rated as the second cause of death in
England and Wales in 2006, when ranking by “years of working life lost”. This finding is
witnessed across the world because younger people are disproportionally involved in road
traffic collisions.

4.2 OVERVIEW OF EU AND US ACCIDENT TAXONOMY

4.2.1 COMPARING EU AND US ROAD CASUALTIES, POPULATIONS AND VEHICLE FLEETS

In the past fourteen years there have been significant improvements with regard to the
number of people killed in road traffic accidents in the EU and US. The EU experienced the
largest reduction in this time period, but in recent years the decline appears to have stalled in
both regions, with a levelling of annual fatalities in 2013 to about 26,000 and 33,000 in the
EU and US respectively (Figure 2)

60,000
EU28
50,000
US
40,000

30,000

20,000

10,000

0
2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

Figure 2: Number of road fatalities in the EU28 and US by year

In 2014, 25,845 road fatalities were reported in the EU28; at the time of writing casualty data
were not available for the US for this year. In 2013, there were 32,719 fatalities in the US, 55%
of which occurred in rural areas, 54% of the EU’s fatalities occurred on rural roads.

Figure 3 provides a breakdown of the number of people killed on the roads of the EU28 and
US, by their road user type. In 2013, there were 11,887 and 11,977 passenger car users killed
in traffic accidents in the EU28 and US respectively. In 2012, passenger car occupants
accounted for 45% of all road users killed in the EU28 and 37% in the US.

Table 5 provides high level details with respect to the population characteristics in each
region. The EU has a larger population and a significantly higher population density
compared to the US. There are also differences with respect to the age distribution, with a
24
greater proportion of children in the US, and greater proportion of elderly people (65 years
and older) in the EU.

The EU has approximately twice as many registered cars and four times as many motorcycles
as the US (Table 6). The EU has far fewer trucks than the US, which has a comparatively
large fleet of ‘Light trucks’. The ‘Light truck’ category includes pickups, vans (full-size and
mini), utility-type vehicles, as well as other vehicles (panel trucks and delivery vans generally
of 10,000 pounds (4,536 kg) or less gross vehicle weight).

In contrast 28% of road deaths in the US were occupants of light trucks compared to 3% in
the EU28. Vulnerable Road Users (VRU), namely motorcyclists, pedestrians and pedal
cyclists, accounted for 46% of the deaths in the EU28, and 31% in the US.

25
 16000

14000

12000 US Passenger Car

US Light Truck
US Large Truck
10000 US Motorcyclists
US Pedestrian
US Pedal Cyclists
8000 US Other/Not Known
EU Passenger Car
EU Light Truck
6000 EU Large Truck
EU Motorcyclists
EU Pedestrian
4000 EU Pedal Cyclists
EU Other/Not Known

2000

0
2010 2011 2012 2013

Figure 3: Number of road fatalities in the EU28 and US, by road user type, by year

Table 5 provides high level details with respect to the population characteristics in each
region. The EU has a larger population and a significantly higher population density
compared to the US. There are also differences with respect to the age distribution, with a
greater proportion of children in the US, and greater proportion of elderly people (65 years
and older) in the EU.

The EU has approximately twice as many registered cars and four times as many motorcycles
as the US (Table 6). The EU has far fewer trucks than the US, which has a comparatively
large fleet of ‘Light trucks’. The ‘Light truck’ category includes pickups, vans (full-size and
mini), utility-type vehicles, as well as other vehicles (panel trucks and delivery vans generally
of 10,000 pounds (4,536 kg) or less gross vehicle weight).

26
 Table 4: Proportion of motor vehicle occupants, motorcyclists and non-occupants killed in
the EU28 and US (2012)7

Road users Percentage fatalities

EU28 US

Passenger Cars 45.48% 36.59%

Light Trucks 2.52% 27.88%

Large Trucks 1.58% 2.06%

Motorcycles 17.63% 14.76%

Pedestrians 20.85% 14.26%

Pedal Cyclists 7.57% 2.17%

Other/Unknown 4.37% 2.27%

Total 28,177 33,782

Table 5: Population characteristics (2012)

EU28 US

Population (10^3) 504,228 310,384

Area (10^3 km^2) 4,381.4 9,629.1

Population Density (inhabitants per km^2) 115.1 32.2

Age group % 0-14 years 15.6 20

15-64 years 66.5 67

65+ years 17.9 13

7
US data from ‘FARS Data Tables’ (2012), http://www-fars.nhtsa.dot.gov/. EU data from CARE (2013),
http://ec.europa.eu/transport/road_safety/specialist/statistics/index_en.htm ; accessed on 12th June.

27
 Table 6: Registered vehicle characteristics (2012)

EU28 US

Registered Passenger Car 246,343 111,289.9

Vehicles Bus/Coach 816.1 764.5

(10^3) Truck 34,251.7 133,130

Motorbike 34,516.7 8,454.9

Total 315,927.5 253,639.4

Passenger Car (10^9 passenger km) 4,613 4,612.5

In 2012, the passenger car fatality rate, per billion passenger kilometers driven was 2.8 in the
EU28 and 2.7 in the US (Table 7). Therefore, at a population level, the risk of a car user
being killed, per passenger km driven, is very similar in each region. There are notable
differences between the regions, including vehicle fleet characteristics, road types,
environments and journey lengths.

Table 7: Passenger car fatality rates by region (2012)

EU US

Passenger car fatalities 12,815 12,361

per million people 25.4 39.8

per million vehicles (Passengers cars) 52 111

per billion passenger car passenger km 2.8 2.7

4.2.2 PASSENGER CAR USER CHARACTERISTICS

Approximately 70% of all car user fatalities in both regions are drivers, but proportionally
there are more passengers killed in the EU (Table 8). There are significantly more female
passenger car users killed, as a proportion of all passenger car fatalities, in the US (39%)
compared to the EU (28%) (Table 9).

28
 Table 8: Percentage of Fatalities by seating position, by region and vehicle type
Driver Passenger Total

N % N %

US Passenger Car (2012)8 8,891 72.46% 3,352 27.32% 12,271

US Light Truck (2012) 6,876 73.18% 2,491 26.51% 9,396

EU Passenger Car (2013) 8,135 68.44% 3,752 31.56% 11,887

Table 9: Percentage of Fatalities by sex, by region and vehicle type

Male Female Total

N % N %

US Passenger Car (2012) 7,480 60.96% 4,786 39.00% 12,271

US Light Truck (2012) 6,658 70.86% 2,735 29.11% 9,396

EU Passenger Car (2009)9 11,488 72.25% 4,407 27.72% 15,900

A person’s age and their sex are related to the likelihood of a car user suffering serious injury
or death in the event of a collision. Figure 4 compares the age distribution of driver fatalities
between the EU24 (Dacota, 2009) and the US (2013), where all drivers (male and female)
sum to 100% for each region (EU or US). The US data relates to 2013 and includes 15,530
fatalities (100%); the EU data is from 2009 and includes 10,746 fatalities (100%).

The available data for the US combine passenger cars and light trucks, whereas the EU data
are for passenger cars only. Over 80% of the EU driver fatalities were male compared to 70%
for the US. For male and female drivers, in both regions, the age group 25 to 49 years old was
the most frequently fatally injured. Around 6% of the EU driver fatalities were women over
49 years old, compared to nearly 13% in the US.

8
US data from ‘FARS Data Tables’ (2012), accessed on 12 th June; http://www-fars.nhtsa.dot.gov/People/: Note
slight difference in total fatalities between Tables 7,8 and 9, which is due to different FARS reference tables.
9
EU24, Dacota fact sheet; http://www.dacota-project.eu/deliverables.html

29
 40.00%
US Male (70%)
35.00% EU Male (81%)

30.00% US Female (30%)

EU Female (19%)
25.00%

20.00%

15.00%

10.00%

5.00%

0.00%
< 25 25-49 50-64 65+

Figure 4: Distribution of driver age by sex, for US passenger vehicles (cars and light trucks)
and EU passenger cars (US Drivers, 2013, N=15,530; EU Drivers, 2009, N=10,746).

Figure 5 compares the age distribution of passenger fatalities between the EU24 (Dacota,
2009) and the US (2013), where all drivers (male and female) sum to 100% for each region
(EU or US). The US data relates to 2013 and includes 5,738 fatalities (100%); the EU data is
from 2009 and includes 5,154 fatalities (100%).

The available data for the US combine passenger cars and light trucks, whereas the EU data
are for passenger cars only. For both regions, approximately half of the passenger fatalities
were female and the age distribution was significantly different than the driver fatalities. In
the EU 13% of passenger fatalities were female and over 65 years old compared to 12% in
the US. Approximately one quarter of the passenger fatalities were young males (< 25 years
old) in both regions.

In the EU, 15% of the passenger fatalities were young women (< 25 years old); nearly 19% of
the US passenger fatalities were young women (< 25 years old).

30
 30.00%
US Male (51%)
EU Male (54%)
25.00%
US Female (49%)
20.00% EU Female (46%)

15.00%

10.00%

5.00%

0.00%
< 25 25-49 50-64 65+

Figure 5: Distribution of passenger age by sex, for US passenger vehicles (cars and light
trucks) and EU passenger cars (US Drivers, 2013, N=5,738; EU Drivers, 2009, N=5,154).

4.2.3 PASSENGER CAR COLLISION CHARACTERISTICS

The type of collision is a fundamental factor with regard to the risk of car user serious injury
or death. In the US, the Fatal Accident Reporting System (FARS) collates information that
describes the collision circumstances. In Europe, at the time of writing, the CARE database
does not capture information that describes the side of the vehicle that was impacted. For this
assessment, data from the British STATS19 police reported road casualty reporting system
have been used. This is not intended to represent Europe as a whole.

Table 10: Passenger car impact type for fatal accidents

Type of impact US (2012) GB (2011-13)

N % N %

Front 6,421 52.33% 1,201 48.80%

Side 3,762 30.66% 647 26.29%

Rear 669 5.45% 93 3.78%

Other 1,419 11.56% 520 21.13%

Total 12,271 100.00% 2,461 100.00%

Rollover 3,009 24.52% 486 19.75%

31
The incidence of rollover is not mutually exclusive from the ‘Type of impact’ for the US,
where over 3,000 of the 12,271 car user fatalities suffered a rollover.

In GB between 2011 and 2013, there were 486 car user fatalities where their car overturned
or rolled over. These are all coded in the upper part of Table 10 under ‘Other’.

4.2.4 SUMMARY OF EU AND US ACCIDENT TAXONOMY

 In 2013, the EU and US had a similar number of passenger car user fatalities.
 The EU has far fewer Light truck occupant fatalities than the US.
 The EU has more pedestrian and roughly four times more pedal cyclist fatalities than
the US.
 In 2012, the passenger car fatality rate, per billion passenger kilometers driven was
2.8 in the EU28 and 2.7 in the US. Therefore, at a population level, the risk of a car
user being killed, per passenger km driven, is very similar in each region.
 There are notable differences between the regions, including vehicle fleet
characteristics, road types, environments and journey lengths.
 There are some differences with respect to the demographics (age and sex) of
fatalities between the EU and the US.

4.3 IN DEPTH INVESTIGATION OF EU AND US CAR COLLISION CHARACTERISTICS

4.3.1 OVERVIEW OF EU AND US CAR COLLISION CHARACTERISTICS

An analysis of in-depth accident databases from the EU and US has been completed to
describe the characteristics of collisions and the number of injured occupants that occur in the
two regions.

The NASS CDS database collates in-depth investigations to nationally reported injury
collisions so they can be scaled to provide a representative sample for the US. In-depth
accident databases in the EU are currently conducted by individual countries and the only
databases with enough statistical power for this analysis were RAIDS from Great Britain and
GIDAS from Germany (DE). These two databases were used in the following analysis to
provide an indication of typical collisions that occur in the EU and are not intended to be
representative of the EU. Therefore, collisions from the Britain and Germany have been
presented separately alongside the US for analysis. All three in-depth databases have
sufficient detail recorded to allow meaningful comparisons to be made.

This section of the report initially compares the three countries with respect to the
characteristics of the casualties and their collisions, with regard to frequency of occurrence.
Then, where practicable, comparisons are made based on the proportion of serious and fatal
(MAIS 2+) passenger car casualties, who experienced similar collisions; for example,
quantifying the percentage of seat belted drivers in each geographical region who
experienced a frontal impact and suffered MAIS 3+ injury.

32
4.3.2 CAR COLLISION CHARACTERISTICS
The risk of injury to car occupants is largely dependent on the type of collision the vehicle
experiences. The in-depth databases were used to show the distribution of collision types for
the casualties.

Figure 6 shows that the distribution of injured occupants as a percentage of total casualties is
broadly similar between all three regions. A notable difference is GB’s slightly larger
proportion of injured occupants in frontal collisions compared to Germany and the US. The
number of injured occupants in the US that experienced a multiple impact collision is greater
than the EU regions. This accounts for the smaller proportion of injured occupants in the US
classified as frontal, side, rear, and, to an extent, rollover collisions, as they are grouped into
the multiple impacts. This could also be related to different in-country data coding systems.

Figure 7 highlights the distribution of total injuries and the proportion of each injury severity.
The distribution of injury severities is also largely similar between the three regions. Great
Britain appears to have a slightly smaller proportion of serious and fatal casualties in multiple
impact collisions and rollovers compared to Germany and the US.

Figure 8 uses the same data as Figure 7, but controls for frequency by stacking each column
to 100% and demonstrates how vehicles from the three regions perform in relation to
occupant injury severity. In other words, if you are involved in a frontal collision in GB,
approximately 90% suffer slight injuries and 10% are seriously injured or killed.

GB generally has a smaller proportion of serious casualties across all of the collision types,
but has a large proportion of fatal casualties in rollovers compared to Germany and the US.
The US also has a large proportion of fatal casualties occurring in rollovers and a much larger
proportion of serious casualties compared to the EU regions.

33
Figure 6: Percentage of total casualties for each region by collision type (e.g. all UK
casualties = 100%)

Figure 7: Percentage of each injury severity for each region by collision type (e.g. all UK
casualties = 100%)
34
Figure 8: Proportion of each injury severity for each collision type by region.

4.3.3 CAR USER CHARACTERISTICS

4.3.3.1 SEAT BELTED OCCUPANTS

The majority of occupants in all three regions are seat belted during the collision and so the
distribution of injury severity for belted occupants broadly follows that of all occupants by
collision type and is largely comparable across the three regions (Figure 9 and Figure 10).

35
Figure 9: Percentage of MAIS groups for belted occupants in each region by collision type
(e.g. all UK casualties = 100%)

Figure 10: Proportion of each MAIS group for belted occupants by collision type, by region

36
4.3.3.2 UNBELTED OCCUPANTS
Unbelted car occupants show consistently greater proportions of seriously injured and fatal
occupants (MAIS 3+ and fatal) compared to seat belted occupants, across all regions and are
comparable. Most MAIS 2+ casualties in the Germany occur in frontal impacts (Figure 11).
However, the relative distribution of these casualties when stacked to 100% in Figure 12 is
smaller than the US.

Although relatively few unbelted casualties occur in side impacts and rollovers in GB, the
proportion of MAIS 2+ casualties is far greater than those from Germany and the US. This
may be affected by the small sample that was used to weight the data. Comparatively,
Germany appears to have no MAIS 2 casualties and a smaller proportion of MAIS 3+ and
fatal casualties than the US during rollovers. However, it is worth noting that the sample size
for GB and Germany for rear impacts and rollovers are very small (n < 10).

Figure 11: Percentage of MAIS groups for unbelted occupants in each region by collision
type (e.g. all UK casualties = 100%)

37
Figure 12: Proportion of each MAIS group for unbelted occupants by collision type, by
region.

4.3.3.3 OCCUPANT POSITION AND SEAT BELT USE

Figure 13 shows the majority of all casualties in all regions are belted drivers. Furthermore,
the majority of all casualties appear to be belted regardless of seating position in the vehicle.

Figure 14 shows the proportion of serious and fatally injured belted drivers is substantially
lower in GB compared to Germany and the US in all vehicle positions and that Germany has
a higher proportion of serious and fatal casualties in all three belted categories. It also appears
that unbelted drivers in the US make up a far larger proportion of casualties than the EU
regions.

Seating position in the passenger car is abbreviated to:

 Driver – DRV
 Front seat passenger – FSP
 Rear seat passenger - RSP

38
Figure 13: Percentage distribution of each injury severity for each region by occupant
position in the vehicle and belt use.

Figure 14: Proportion of each injury severity by seating position, by belt use, by region.

39
4.3.3.4 OCCUPANT GENDER
The majority of injured belted drivers in the US are female; in the EU regions the majority of
injured belted drivers are male. However, the proportions of casualties with respect to gender
for the three regions are largely comparable.

The distribution of injury severity for males largely follows that for all occupants as expected
with the majority of serious and fatal injuries occurring to belted drivers. Figure 16 shows
again that the three regions are broadly comparable for belted drivers with little difference in
the proportion of injury severities. GB generally has a smaller proportion of seriously injured
and fatal occupants irrespective of seating position and seat belt use.

Figure 15: Percentage distribution of gender for each region by occupant position in the
vehicle and belt use.

40
Figure 16: Percentage of injury severity for male occupants in each region by occupant
position in the vehicle and belt use.

Figure 17: Percentage of injury severity for female occupants in each region by occupant
position in the vehicle and belt use.
41
Table 18 highlights the greater problem with unbelted casualties in the US compared to GB
and Germany. Males are more frequently unbelted than females in all three regions.

Table 18 Percentage injury severity distribution for each region by gender and belt use.

Percentage
Total
Fatal Serious Slight
M F M F M F M F
GB

Seat belt
60 76 74 81 75 77 75 77
used

Seat belt
26 15 15 11 5 4 6 4
not used

Seat belt
14 10 10 8 19 19 19 19
use n/k

Total 100 100 100 100 100 100 100 100

DE

Seat belt
43 100 88 93 93 94 91 94
used

Seat belt
43 0 10 3 4 2 6 2
not used

Seat belt
15 0 2 4 3 4 3 4
use n/k

Total 100 100 100 100 100 100 100 100

US

Seat belt
44 47 62 74 80 88 78 84
used

Seat belt
41 37 32 19 16 10 17 13
not used

Seat belt
16 16 6 7 4 2 5 4
use n/k

Total 100 100 100 100 100 100 100 100

4.3.3.5 OCCUPANT AGE

Figure 19 shows that Germany has the highest proportion of casualties occurring in older age
groups followed by the US and then GB. Germany and the US both have correspondingly
42
higher proportions of seriously injured and fatal occupants in older age groups compared to
GB However, it is also apparent that Germany has a higher proportion of seriously injured
and fatal casualties in lower age groups compared to the US and GB (Figure 20).

Figure 19: Percentage injury severity distribution for each region by age group.

Figure 20: Proportion of each injury severity by age group by region

43
4.3.4 OVERVIEW OF EU AND US CAR FRONTAL COLLISIONS

4.3.4.1 DIRECTION OF FORCE

4.3.4.1.1 FREQUENCY OF INJURIES

Most injuries from frontal impacts are from collisions with a primary direction of force along
the axis of the car (referred to as 12 o’clock) and in over 90% of cases, in all regions, the
primary direction of force is within a cone 45° either side of 12 o’clock (Figure 21).

Figure 21: Breakdown of injuries in frontal impacts by primary direction of force

4.3.4.1.2 PROPORTION OF SERIOUS INJURIES AND FATALITIES

Figure 22 shows the injury breakdown for occupants in frontal collisions for each primary
direction of force. This gives a top level overview of the relative injury severity in such
impacts and highlights that the proportion of seriously injured and killed occupants in crashes
in which the primary direction of force was 11, 12 or 1 o’clock is similar between the regions.

The differences shown for 9, 10, 2 and 3 o’clock are not robustly representative of real world
performance, given the small number of incidents on which these breakdowns are based (for
example there is no breakdown of injury severity for frontal impacts with a primary direction
of force of 9 o’clock for GB because none were recorded in RAIDS).

44
Figure 22: Breakdown of injury severity for frontal impacts with a given primary direction of
force

4.3.4.2 CHANGE IN SPEED ON IMPACT

4.3.4.2.1 FREQUENCY OF INJURIES

Overall, occupant injuries occur at slightly lower speed reductions on impact (delta-V) in the
US but all three regions exhibit a similar trend, see Figure 23. In the European countries 70%
of all occupant injuries in frontal collisions occur below 30 km/h and in the US this figure is
nearly 80%.

Figure 24 shows some exaggeration of these differences when considering the proportions of
seriously injured or killed occupants involved in crashes at different values of delta-V. For
example, nearly two thirds of US MAIS 3+ and fatal injuries occur below a delta-V of 40
km/h compared to half for GB and under one third for Germany. This trend is largely
replicated when considering belted drivers only, see Figure 25. Both graphs show that a
smaller proportion of MAIS 3+ and fatal injuries occur above a delta-V of 60 km/h for GB
than in the other regions.

45
Figure 23: All occupants. Distribution of all injuries, for each region, by Delta-V

Figure 24: All occupants. Distribution of MAIS 3+ and fatal injuries, for each region, by
Delta-V

46
Figure 25: Belted drivers. Distribution of MAIS 3+ and fatal injuries, for each region, by
Delta-V

4.3.4.2.2 PROPORTION OF SERIOUS INJURIES AND FATALITIES

In contrast to the differences in the frequency of injuries occurring at different values of

delta-V shown above, the differences in the MAIS distribution for all injuries for crashes
grouped by delta-V (above and below 40 km/h) are somewhat small, see Figure 26 to Figure
28. This implies that the relatively high proportion of serious injury below 40 km/h in the US
is a result of the relative number of such incidents rather than the performance of the cars in
protecting their occupants.

Figure 27 and Figure 28 highlight the marked increase in injury severity, for all regions, for
both high speed incidents and unbelted occupants.

47
Figure 26: All occupants. MAIS distribution as a percentage of all injuries above and below
a delta-V of 40 kmh.

Figure 27: Belted occupants. MAIS distribution as a percentage of all injuries above and
below a delta-V of 40 kmh.

48
Figure 28: Unbelted occupants. MAIS distribution as a percentage of all injuries above and
below a delta-V of 40 kmh.

4.3.4.3 IMPACT PARTNER

4.3.4.3.1 FREQUENCY OF INJURIES

Injuries in frontal crashes are most likely to come from car-to-car impacts, in all regions, in
terms of object hit. In the US a larger proportion of the occupant injuries from frontal crashes
for cars are with LGVs and wide objects than in the European countries while Germany has a
relatively larger proportion of injuries from frontal crashes involving narrow objects, see
Figure 29.

Figure 30 shows a near identical trend, with respect to occupant injuries split by impact
partner, for belted occupants.

49
Figure 29: All occupants (belted + unbelted). Percentage distribution of each injury severity,
for each region, by object hit (i.e. all UK fatalities = 100%)

Figure 30: Belted occupants only. Percentage distribution of each injury severity, for each
region, by object hit (i.e. all UK fatalities = 100%)

50
4.3.4.3.2 PROPORTION OF SERIOUS INJURIES AND FATALITIES

Considering the injury severity of occupants in frontal crashes split by impact partner
regardless of their frequency it is clear that, for the most common impact partners, injury
severity is similar across the regions, see Figure 31. The data for the less common impact
partners should be treated with caution since the number of crashes upon which they are
based is small. Figure 32 shows very similar trends when the data set is limited to belted
drivers.

Figure 31: All occupants. Breakdown of injury severity for frontal impacts with a given
impact partner

Figure 32: Belted drivers. Breakdown of injury severity for frontal impacts with a given
impact partner

51
4.3.4.4 OVERLAP

4.3.4.4.1 FREQUENCY OF INJURIES

Figure 33 shows that injuries from high overlap collisions are the most common with respect
to frontal impacts across all regions, accounting for between 20 and 25% of frontal impact
injuries, and that injuries from low overlap collisions are slightly more common in Germany
than in GB or the US.

Figure 34 presents a similar trend for belted driver injuries.

Figure 33: All occupants (belted + unbelted). Percentage distribution of injuries, for each
region, by percentage overlap

52
Figure 34: Belted drivers. Percentage distribution of injuries, for each region, by percentage
overlap

4.3.4.4.2 PROPORTION OF SERIOUS INJURIES AND FATALITIES

For a given level of overlap the injury severity breakdown of occupants in frontal crashes is
similar across the regions, see Figure 35. There is a slightly higher proportion of serious
injury in some of the low overlap conditions, particularly in US, but overall Figure 35 (and
Figure 36 for belted drivers) show that, in all regions, around 10-15% of injured occupants in
frontal crashes are seriously injured or killed.

Figure 37 summarises the injury severity breakdown in low to medium (50%) and high
overlap conditions for belted drivers and while the proportion of serious injury is slightly
higher in the US all regions show similar trends.

53
Figure 35: All occupants (belted + unbelted). Percentage distribution of each injury severity,
for each region, for a given percentage overlap

Figure 36: Belted drivers. Percentage distribution of each injury severity, for each region,
for a given percentage overlap

54
Figure 37: Belted drivers. Percentage distribution of each injury severity, for each region,
for low and high overlap crashes

4.3.5 OVERVIEW OF EU AND US CAR SIDE COLLISIONS

4.3.5.1 DIRECTION OF FORCE

4.3.5.1.1 FREQUENCY OF INJURIES

The primary direction of force (PDOF) in side impact collisions is defined in terms of a clock
face overlaid on a plan view of the vehicle with 12 o’clock pointing towards the front of the
vehicle. Therefore drivers would typically be hit with a PDOF of 3 o’clock in GB and 9
o’clock in Germany and the US. Figure 38 shows that most injuries occur in collisions where
the car is struck at an oblique angle opposing the forward direction (i.e. 1, 2, 10 and 11
o’clock).

55
Figure 38: Breakdown of injuries in side impacts by primary direction of force

4.3.5.1.2 PROPORTION OF SERIOUS INJURIES AND FATALITIES

The proportion of injured occupants in side impact collisions by primary direction of force is
shown in Figure 39. The differences between GB and Germany are generally as large as the
differences between these countries and the US implying there is no noticeable difference in
injury severity between the regions in side impacts although overall the data suggest a smaller
proportion of serious injury in GB.

56
Figure 39: Breakdown of injury severity for side impacts with a given primary direction of
force

4.3.5.2 DAMAGE LOCATION

The following graphs describe the area of the vehicle that was damaged in the collision using
the Collision Deformation Classification (CDC) code:

Figure 40: CDC horizontal damage location code

57
4.3.5.2.1 FREQUENCY OF INJURIES

Figure 41: MAIS distribution by CDC horizontal damage location

4.3.5.2.2 PROPORTION OF SERIOUS INJURIES AND FATALITIES

For a given damage location the proportion of seriously injured occupants is shown in Figure
42. These data do not reveal any clear trend between the European countries and the US.

Figure 42: MAIS distribution for given CDC horizontal damage location

58
4.3.5.3 IMPACT PARTNER

4.3.5.3.1 FREQUENCY OF INJURIES

Figure 43 shows the distribution of injuries in side impacts with respect to object hit. The
trends are similar for each of the regions with injuries from car-to-car side impacts by far the
most common, although there are relatively more impacts with LGVs in the US and impacts
with wide objects in GB compared to the other countries.

Figure 43: Percentage MAIS distribution by object hit.

4.3.5.3.2 PROPORTION OF SERIOUS INJURIES AND FATALITIES

Considering the injury severity of the impacts with respect to a given impact partner, as
shown in Figure 44, the fraction of injured occupants in side impacts who are seriously
injured or killed is similar across the regions. Similarly there are no clear differences between
the regions for other impact partners and in these cases the number of crashes on which the
breakdown of injury severity is based is small and these results should be treated with caution.

59
Figure 44: MAIS distribution for given impact partner

4.3.5.4 DELTA-V

4.3.5.4.1 FREQUENCY OF INJURIES

Serious occupant injuries in side impacts occur at slightly lower speed reductions on impact
(delta-V) in the UK, but all three regions exhibit a similar trend, see Figure 45.

Figure 45: All occupants. Cumulative frequency of MAIS 3+ & Fatal injury risk by delta-V.
60
4.3.6 OVERVIEW OF EU AND US CAR ROLLOVERS

4.3.6.1 TYPE OF ROLLOVER

The most common types of rollover inducing injuries differ between the three regions with
the simple rollovers occurring most commonly in the US; rollovers preceded by impacts in
GB and rollovers followed by impacts in Germany. Rollovers are generally complex
collisions and this difference may be due to differences in how these collisions are coded in
the three databases.

In Figure 47 the proportions of each MAIS severity show that the US consistently has a
greater proportion of MAIS 2, MAIS + and fatal casualties than the EU regions in all types of
rollover.

4.3.6.1.1 FREQUENCY OF INJURIES

Figure 46: Breakdown of injuries in rollover by rollover type

61
4.3.6.1.2 PROPORTION OF SERIOUS INJURIES AND FATALITIES

Figure 47: Breakdown of injury severity for rollover for a given rollover type

4.3.6.2 SEAT BELT USE

Breaking the injury distribution down by occupant seat belt use (Figure 48) shows that the
majority of casualties are belted as expected. The most common types of rollover in each
region have very similar distributions of MAIS severities.

Figure 49 shows that the proportion of occupants with a severe injury outcome is consistently
greater for unbelted occupants in all types of rollover. Apart from rollovers followed by
impacts in GB, the US still shows a consistently greater proportion of severe MAIS levels in
all rollover types and belt use than the EU regions. However, it should be noted that the
sample sizes for the unbelted occupants in the EU regions are small.

62
4.3.6.2.1 FREQUENCY OF INJURIES

Figure 48: Breakdown of injuries in rollover by rollover type and belt use

4.3.6.2.2 PROPORTION OF SERIOUS INJURIES AND FATALITIES

Figure 49: Breakdown of injury severity by rollover type by belt use

63
4.3.6.3 OCCUPANT EJECTION

Figure 50 shows that occupant ejection during a rollover is a rare event in all three regions.
However, when it does occur the consequences are typically severe injury outcomes. The
sample sizes for full and partial ejection are very small for GB and there were no recorded
ejections in the German dataset.

4.3.6.3.1 FREQUENCY OF INJURIES

Figure 50: Breakdown of injuries in rollover by occupant ejection

64
4.3.6.3.2 PROPORTION OF SERIOUS INJURIES AND FATALITIES

Figure 51: Breakdown of injury severities for rollover by occupant ejection

4.3.6.4 DIRECTION OF ROLLOVER

GIDAS does not record the direction the vehicle rolled over, so this data is not available in
the following graphs.

Vehicles in GB and the US tend not to roll end over end. However, vehicles in GB appear to
roll more frequently to the driver’s side, where the opposite is true for vehicles in the US. The
direction the vehicle rolls has very little effect on the injury outcome of occupants from either
region as shown in Figure 53.

65
4.3.6.4.1 FREQUENCY OF INJURIES

Figure 52:Breakdown of injuries in rollover by the direction the vehicle rolled

4.3.6.4.2 PROPORTION OF SERIOUS INJURIES AND FATALITIES

Figure 53:Breakdown of injury severities for rollovers by direction the vehicle rolled

66
5. ASSESSMENT OF THE REAL WORLD BENEFITS OF SECONDARY SAFETY IMPROVEMENTS

5.1 ESTIMATE OF THE IMPACT OF SECONDARY SAFETY IN GREAT BRITAIN

5.1.1 INTRODUCTION

The following section examines how car secondary safety for drivers and pedestrian
casualties has improved in Great Britain in recent decades. Statistical modelling was used to
predict the number of casualties which would have occurred if secondary safety had not
improved.
The models use data from the British STATS19 database to model the proportion of
casualties killed or seriously injured in road accidents. The following variables will be
included in the models:
 Registration year of the vehicle
 Accident year
 Age and sex of the casualty
 Vehicle type of striking car
 Road type

5.1.2 CHANGES IN ACCIDENT SEVERITY OVER TIME

Figure 54 shows that the proportion of car driver casualties killed or seriously injured
decreased from 1989 to 2013 on both built-up (BU) and non-built-up (NBU) roads. Figure 55
uses the same data spilt by registration year instead of accident year to demonstrate how the
proportion of car driver casualties who were killed or seriously injured (KSI) decreases as
registration year of the vehicle increases.

Figure 54: Proportion of car driver casualties killed or seriously injured by accident year

67
Figure 55: Proportion of car driver casualties killed or seriously injured by registration year
Newer cars have secondary safety features which improve the protection offered to occupants
of the vehicle in a collision. Figure 55 demonstrates that secondary safety has improved in
Great Britain over the past two decades, but how much of this improvement is due to
secondary safety features and how much due to changes in the conditions in which vehicles
are driven, for example due to improvements to the road system or changes in the weather, or
the way in which they are driven is difficult to define. Statistical modelling is required to
disaggregate these effects.

5.1.3 MODELLING METHOD

The statistical modelling uses data from police reported injury accidents (from the British
STATS19 accident database) occurring between 198910 and 2013. These data are analysed
using logistic regression models fitted to the severity proportions:
 P1 the proportion of car driver casualties who were killed
 P2 the proportion of car driver casualties who were killed or seriously injured (KSI)
Car registration year is used to estimate the reduction in the severity of drivers’ injuries
linked to changes in succeeding ‘cohorts’ in the car fleet. Note that cars sharing the same
registration year can be at very different stages in the product cycle. At any particular time,
some will have just entered production and represent the “state of the art” of car design, while
others entered production several years earlier. Consequently, an advance in design technique
will only gradually affect these secondary safety results by registration year.
The variables included in the model are:

10
1989 was the first year in which the vehicle enhanced data (including the year of registration and make/model
of the vehicle) were included in the STATS19 database.

68
  Year of accident: accounts for the fact that other road safety measures and conditions
will have affected the road system.
 Age/sex: as it is known that older drivers tend to be more seriously injured than
younger drivers for physiological reasons and they are also more likely to drive older
cars. The inclusion of this variable also gives the opportunity to examine whether
developments in car secondary safety have benefited some age/sex groups more than
others.
 Size of car: the driver casualty rate falls markedly with size of car; larger cars tend to
protect their occupants more than smaller vehicles.
 BU and NBU roads: Previous research has shown that the injury severity is also
influenced by the speed at which the accident occurs. The impact speeds of vehicles
involved in injury accidents is not recorded in STATS19 but the speed limit of the
road will be used as a proxy.
The modelling predicts the number of casualties which would have occurred if secondary
safety had not improved. This calculation assumes that improving car secondary safety
cannot prevent occupants from being injured in an accident, but can reduce the severity of the
injuries suffered. As a result, this model is likely to underestimate the actual benefit as some
car occupants who would previously have been slightly, or even seriously injured, may now
not be injured. DfT estimates for the value of prevention of a casualty 11 will be used to
estimate how much money improvements to secondary safety have saved Great Britain over
the past decade or so.
The effect of secondary safety improvements for pedestrian casualties hit by cars will also be
examined within a separate model (Lloyd et al., 2012). Similar explanatory variables will be
incorporated into the model:
 Registration year of the striking car
 Accident year
 Age and sex of the pedestrian casualty
 Vehicle type of striking car
For the pedestrian model ‘road type’ (built-up or non-built-up) was not included as only
relatively small proportion (approximately 9%) of pedestrians were injured on non-built-up
roads. As a result, the pedestrian casualty counts in the non-built-up group are too small to
give robust results.
Two models are fitted to each dataset: the first uses registration year as a factor in the model
i.e. the coefficients for each registration year are calculated separately, the second uses
registration year as a covariate i.e. the coefficients for each registration year are assumed to
be linearly related. For some of the models presented a break-point in the linear trend was
required. This breakpoint usually occurred around the 1990-91 registered vehicles; it is

11
Average value of prevention per reported casualty from Table RAS60001, GB 2012

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/244913/rrcgb2012-02.pdf

69
 suggested that this is due to the impact of manufacturers starting to consider the impact of
possible regulations on the car industry.

5.1.4 MODELLING RESULTS

5.1.4.1 CAR DRIVER CASUALTIES

In total, 2,802,648 car driver casualties were injured in accidents recorded in STATS19
between 1989 and 2013. Table 11 shows the number of car driver casualties with known
values for registration year, vehicle type, casualty age, sex and road type.
Table 11: Number of car driver casualties used for the modelling
Count (% of
all driver Comments
casualties)

2,802,648
Car driver casualties (1989-2013)
(100%)

excludes drivers of vehicles with unknown

Car driver casualties with valid vehicle 2,435,061
registration year or where the registration year >
registration year (87%)
accident year

accident involved vehicles matched to vehicle type

Car driver casualties with valid vehicle 2,353,809 classification - excludes drivers of cars with
registration year and vehicle type (84%) unknown vehicle type or where the vehicle type is
recorded as ‘van’ or ‘motorcycle’

Car driver casualties aged 17+ with

2,329,397 excludes drivers with unknown age and/or sex and
valid vehicle registration year and
(83%) underage drivers (i.e. those under 17 years old)
vehicle type

Car driver casualties aged 17+ with

2,329,293 excludes accidents where the speed limit is
valid vehicle registration year, vehicle
(83%) unknown
type and speed limit

The year of registration was known for 87% of the cars involved in injury accidents between
1989 and 2013. Excluding driver casualties on the basis of missing information for the other
key variables, leaves 83% of the total number of driver casualties for use in the modelling. It
will be assumed that excluding those vehicles where the data is unknown does not bias the
results of the model; however it is worth noting that that the casualty estimates presented will
be an underestimate of the actual number of lives saved.
For car driver casualties, two models are used: one for built-up roads and one for non-built-up
roads. The number of car driver casualties split by road type and severity is shown in Table
12.

70
 Table 12: Car driver casualties by road type and severity (1989-2013)
Road Type Killed KSI Total

BU road (≤40mph) 3,296 76,569 1,175,209

NBU road
18,140 159,539 1,154,084
(>40mph)

Total 21,436 236,108 2,329,293

Overall casualty numbers were comparable between built-up and non-built-up roads;
however a higher proportion of the casualties on non-built-up roads were killed or seriously
injured (14% compared to 7%).

o Modelling results
Figure 56 shows the proportion of male 25-59 year old small family car driver casualties
killed by registration year in 2013 on built up and non-built up roads. The blue dots show the
result of the model when year of registration is included as a factor, and the red line shows
the model results when a linear trend is assumed for the improvements to secondary safety. A
break-point in the linear trend occurred in 1990-91 registered vehicles on both built-up and
non-built-up roads.

71
 Figure 56: Modelled fatality proportion by registration year for car drivers (males 25-59,
small family cars, 2013)
Figure 57 shows the proportion of male 25-59 year old small family car driver casualties
killed or seriously injured by registration year in 2013 on built up and non-built up roads. As
with the killed models shown in Figure 56, a break-point in the linear trend occurred in 1990-
91 registered vehicles on non-built-up roads, possibly because manufacturers started to
consider the impact of possible regulations on the car industry.

72
Figure 57: Modelled KSI proportion by registration year for car drivers (males 25-59, small
family cars, 2013)

Figure 56 and Figure 57 indicate that, for accidents on built-up and non-built-up roads, since
1990-91 improvements to secondary safety for car occupants have improved more rapidly
than pre-1990.
The models can also be used to examine how the secondary safety of vehicles registered in a
given year change as accident year increases (Table 13).

73
 Table 13: Modelled fatality proportion for car drivers in 1990-91 registered vehicles by
accident year (BU roads, males 25-59, small family cars)
Accident % of drivers
Year killed

1990 0.28%

2000 0.33%

2010 0.47%

In 1990, the model indicates that 0.28% of casualties were killed in newly registered vehicles
(i.e. those registered in 1990-91). By 2000 it is likely that some of the vehicles registered in
1990-91 will have been scrapped, but some still remain and the model indicates that the
proportion of casualties killed had increased to 0.33% in these vehicles. By 2010, this
proportion had increased again to 0.47%.
The structural design of vehicles registered in 1990-91 did not change during the period 1990
to 2010, however the decrease in car drivers killed could have been due to changes to the
vehicles in which the 1990-91 registered vehicles collide with: as (Lloyd et al., 2012)
demonstrates the car fleet is diverging in size with more larger and smaller vehicles.
One other possible explanation for this increase is a change to the level of underreporting in
STATS19. If slight and/or serious casualties were being reported less over time, but the level
of fatality reporting remained the same then the proportion of casualties killed would appear
to increase. In June 2006, the Department for Transport commissioned some work to match
STAT19 data to hospital data in an attempt to determine levels of underreporting (Broughton
and Keigan, 2010); however the conclusions are hard to draw out and the trend over time was
not investigated. However, assuming there is no bias in the underreporting by age of vehicle,
changes to reporting rate over time should not influence the key results relating to registration
year.

o Estimated casualty benefits

Following the methodology outlined in (Broughton, 2003), the models described above can
be used to estimate the number of lives that have been saved (or the number of KSI casualties
eliminated) by improvements to the secondary safety of cars. For example, it is possible to
determine if the safety of cars had remained at the level of the 1990-91 registered cars how
many additional fatalities and KSI car driver casualties would have occurred in 2010.
These calculations assume that the total number of collisions remains unchanged, but that
more drivers would have been killed or seriously injured because of the lower secondary
safety. The model is used to adjust the severity proportions of the modern cars to match with
those registered in 1990-91. Casualties in cars registered before 1990-91 are assumed to
remain unaffected.

74
Improvements to secondary safety are likely to have reduced the total number of
casualties as some casualties who would have previously been slightly injured in the
collision are not injured in more modern cars. As a result, the casualty estimates
presented in Table 14 are an underestimate for the actual casualty benefit.
Table 14: Actual and estimated car driver casualty numbers in 2010 if secondary safety
had remained at level of 1990-91 registered vehicles

Actual casualty numbers Estimated casualty Reduction in casualties

numbers if secondary due to secondary safety
Accident Casualty
safety had not improved improvements
Year severity
BU NBU Total BU NBU Total BU NBU Total

Fatalities 90 478 568 198 844 1,042 108 366 474

2010
KSI 2,107 4,312 6,419 2,966 6,306 9,272 859 1,994 2,853

The overall effectiveness of secondary safety can be estimated by calculating the

proportion of the potential number of casualties that were saved by the improvements
i.e.
𝑒𝑠𝑡𝑖𝑚𝑎𝑡𝑒𝑑 𝑟𝑒𝑑𝑢𝑐𝑡𝑖𝑜𝑛 𝑖𝑛 𝑓𝑎𝑡𝑎𝑙𝑖𝑡𝑖𝑒𝑠
𝑃𝑟𝑜𝑝𝑜𝑟𝑡𝑖𝑜𝑛 𝑜𝑓 𝑙𝑖𝑣𝑒𝑠 𝑠𝑎𝑣𝑒𝑑 = .
𝑒𝑠𝑡𝑖𝑚𝑎𝑡𝑒𝑑 𝑟𝑒𝑑𝑢𝑐𝑡𝑖𝑜𝑛 𝑖𝑛 𝑓𝑎𝑡𝑎𝑙𝑖𝑡𝑖𝑒𝑠+𝑎𝑐𝑡𝑢𝑎𝑙 𝑛𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑓𝑎𝑡𝑎𝑙𝑖𝑡𝑖𝑒𝑠

Hence, in 2010 the estimated effectiveness of improvements in secondary safety since

1990-91 registered vehicles was 45% for car driver fatalities and 31% for KSI car driver
casualties. Figure 58 shows how this proportion changes from 1990 to 2010 for car driver
fatalities as older cars are scrapped and newer models introduced.

Figure 58: Proportion of lives saved by improvements to secondary safety since 1990-91
registered vehicles by accident year

75
5.1.4.2 PEDESTRIAN CASUALTIES HIT BY CARS

In total, 793,326 pedestrian casualties were recorded as injured when struck by a car in
STATS19 between 1989 and 2013. Table 15 shows the number of pedestrian casualties
with known values for registration year, vehicle type and casualty age and sex.
Table 15: Number of pedestrian casualties hit by cars used for the modelling

Count (% of all
pedestrian Comments
casualties)

Pedestrian casualties hit by cars (1989-

793,326 (100%)
2013)

Pedestrian casualties hit by cars with excludes pedestrian casualties hit by cars
613,652 (77%)
valid vehicle registration year with unknown registration year

accident involved vehicles matched to

vehicle type classification - excludes
Pedestrian casualties hit by cars with
pedestrian casualties hit by cars with
valid vehicle registration year and 590,691 (74%)
unknown vehicle type or where the
vehicle type
vehicle type is recorded as ‘van’ or
‘motorcycle’

Pedestrian casualties hit by cars with

excludes pedestrian casualties with
valid vehicle registration year, vehicle 576,246 (73%)
unknown age and/or sex
type and age/sex

The year of registration was known for 77% of the cars involved in injury accidents
between 1989 and 2013. This proportion is much lower than for car driver casualties
were 87% had a valid registration year. Excluding pedestrian casualties on the basis of
missing information for the other key variables, leaves 73% of the total number of
pedestrian casualties for use in the modelling. It will be assumed that excluding those
vehicles where the data is unknown does not bias the results of the model; however it is
worth noting that that the casualty estimates presented will be an underestimate of the
actual number of lives saved.

5.1.4.2.1 MODELLING RESULTS

Figure 59 shows the proportion of male 16-59 year old pedestrian casualties hit by small
family cars killed by registration year in 2013. The blue dots show the result of the model
when year of registration is included as a factor, and the red line shows the model results
when a linear trend is assumed for the improvements to secondary safety.

76
 Figure 59: Modelled fatality proportion by registration year for pedestrians hit by cars
(males 16-59, small family cars, 2013)

Figure 60 shows the proportion of male 16-59 year old pedestrian casualties hit by small
family cars killed or seriously injured by registration year in 2013.

Figure 60: Modelled KSI proportion by registration year for pedestrians hit by cars
(males 16-59, small family cars, 2013)

Figure 59 implies that secondary safety has not improved for pedestrian casualties hit in
the most severe accidents over the period studies. In contrast, Figure 60 indicates that
improvements to the pedestrian protection offered by cars has had some effect on the
proportion of seriously injured casualties; a smaller proportion of pedestrians are
seriously injured when hit by cars registered in 2012-13 compared to those hit by cars
registered before 1976.
The models can also be used to examine how the secondary safety of vehicles registered
in a given year change as accident year increases (Table 16).
77
 Table 16: Modelled fatality proportion for pedestrians hit by 1990-91 registered vehicles
by accident year (males 16-59, small family cars)

% of
Accident pedestrians
Year killed
1990 3.15%
2000 2.57%
2010 1.89%

In 1990, the model indicates that 3.15% of pedestrian casualties hit by newly registered
vehicles (i.e. those registered in 1990-91) were killed. By 2000 it is likely that some of
the vehicles registered in 1990-91 will have been scrapped, but some still remain and the
model indicates that the proportion of casualties killed had decreased to 2.57% in these
vehicles. By 2010, this proportion had decreased again to 1.89%.
This trend is the opposite direction to the trend for car driver casualties (Table 13). Since
the structural design of vehicles registered in 1990-91 did not change during the period
1990 to 2010, the reason for this trend is not known.

5.1.4.2.2 ESTIMATED CASUALTY BENEFITS

As for the car driver casualties the models can be used to estimate the number of lives
saved by improvements to secondary safety of cars. The question asked here is: if the
safety of cars had remained at the level of the 1990-91 registered cars how many
additional fatalities and KSI pedestrian casualties would have occurred in 2010? Table 17
shows the actual and estimated fatalities and people who were killed or seriously injured
(KSIs) in 2010.
Table 17: Actual and estimated pedestrian casualty numbers in 2010 if secondary safety
had remained at level of 1990-91 registered vehicles

Estimated casualty
numbers if secondary Reduction in casualties
Accident Casualty Actual casualty safety had not due to secondary safety
Year severity numbers improved improvements
Fatalities 268 268 0
2010
KSI 4,260 4,754 394

In 2010 the estimated effectiveness of improvements in secondary safety since 1990-91

registered vehicles was <0.1% for pedestrian fatalities and 8% for KSI pedestrian
casualties.
These casualty benefits are substantially lower than those obtained for the car driver
casualties (see Section 5.1.4.1) which demonstrates that although improvements to
secondary safety have benefitted car occupants there has been little effect with respect to
the proportion of KSI injury of pedestrians who are struck by the vehicles.
It is possible that the design changes made to the front of cars to protect pedestrians are
having positive effects. For example, there could be a reduction in the number and
78
severity of the serious injuries pedestrian’s experience, but their overall injury severity
remains classified as ‘serious’ based on the police definitions. This is not known and is
only hypothesised as this time as the model used for this study would not identify
changes in serious injury mechanisms and epidemiology. However, it is notable that
reductions in car occupant KSI proportions can be attributed to secondary safety design
improvements and this is not the case for pedestrians. Further evaluation is needed to
understand the reasons behind these findings and to ensure future collision and injury
mitigation strategies for VRUs are effective.

5.2 ESTIMATED CAR USER CASUALTY BENEFITS OF EURONCAP

Following the methodology outlined in Broughton (2003), the models described above
can be used to estimate the number of lives that have been saved by improvements to the
secondary safety of cars. For example, it is possible to determine if the safety of cars had
remained at the level of the 2004-05 registered cars how many additional fatalities would
have occurred up to 2013.
These calculations assume that the total number of collisions remains unchanged, but that
more drivers would have been killed because of the lower secondary safety. The model is
used to adjust the severity proportions of the modern cars to match with those registered
in 2004-05. Casualties in cars registered before 2004-05 are assumed to remain
unaffected.
Improvements to secondary safety are likely to have reduced the total number of
casualties as some casualties who would have previously been slightly injured in the
collision are not injured in more modern cars. As a result, the casualty estimates
presented in Table 15 are an underestimate for the actual casualty benefit. The total
figure shown in Table 15 is based on modelled data to smooth out variability in the trend
due to random variation.

Table 18: Actual and estimated car driver fatality numbers in 2007, 2010, 2013 if
secondary safety had remained at level of 2004-05 registered vehicles
Accident year Actual Estimated Reduction in Proportional
fatality fatality fatalities due to reduction due to
numbers numbers if secondary safety secondary safety
secondary improvements
safety had
not
improved
2007 934 990 56 5.7%
2010 568 583 15 2.5%
2013 543 602 59 9.8%
Total (modelled) 6,874 7,176 302 4.2%
2005-2013

Hence, between 2005 and 2013 the estimated effectiveness of improvements in

secondary safety since 2004-05 registered vehicles was 4.2% for car driver fatalities.
That is, 4.2% fewer car drivers died between 2005 and 2013 due to improvements in
secondary safety in cars.

79
5.3 REVIEW OF LIVES SAVED BY VEHICLE SAFETY TECHNOLOGIES AND ASSOCIATED
FMVSS IN US

In 1975, NHTSA began to evaluate the effectiveness of vehicle safety technologies

associated with the Federal Motor Vehicle Safety Standards. In January 2015, (Kahane,
2015) published a comprehensive report which evaluates the effectiveness of a
significant number of life-saving technologies introduced in passenger cars, pickup
trucks, SUVs, and vans from about 1960 to about 2010. A statistical model was used to
estimate the number of lives saved from 1960 to 2012 by the combination of these life-
saving technologies

The Fatality Analysis Reporting System (FARS) data for 1975 to 2012 documents the
actual crash fatalities in vehicles that, especially in recent years, include many safety
technologies. The (Kahane, 2015) report (DOT HS 812 069) uses NHTSA’s published
injury reduction effectiveness estimates to model and quantify estimates with respect to
how many people would have died if the vehicles had not been equipped with any of the
safety technologies. Figure 61 provides a summary of the lives saved by vehicle
technologies for passenger car users in 2012.

0 2000 4000 6000

208: Seat belts - all types, all seating positions 7169

208: Frontal air bags 1738

FMVSS Standard for occupant protection

203/204: Energy-absorbing steering assemblies 1323

214: Side impact protection and curtain air bags 1196

201: Instrument panel improvements and head

778
impact protection

206: Improved door locks 486

216: Roof crush resistance (eliminate true

122
hardtops)

301: Fuel system integrity - rear impact upgrade 5

226: Curtains that deploy during rollovers 3

Estimates of lives saved by safety technologies for car occupants in 2012

Figure 61: Estimates of car occupant lives saved by FMVSS standard

80
5.4 REVIEW OF UMTRI REPORT “COMPARING MOTOR-VEHICLE CRASH RISK OF EU
AND US VEHICLES”

The UMTRI report (Flannagan et al., 2015) presents statistical methodologies which
investigate the hypothesis that:

‘(passenger) vehicles meeting EU safety standards perform similarily to US-regulated

vehicles in the US driving environment and vice-versa’.

The methods used separate risk from exposure, to account for the different environments
used by EU and US drivers, where risk is the probability of injury given a particular set
of circumstances and exposure is the particular collection of those circumstances.

The summary of the crashworthiness conclusions for cars users are reproduced below:

 The EU and US injury risk models are different for both front/side crashes and
rollovers.
 Overall risk across the US front-side crash population (given the selection
criteria for this study) is likely lower for EU vehicles. Though the range of
estimates is wide, the best estimate of the risk difference is ‐0.012.
 Overall risk across the EU front‐side crash population (given the selection
criteria for this study) is likely lower for EU vehicles. Though the range of
estimates is wide, the best estimate of the risk difference is ‐0.013.
 Overall risk across both EU and US rollover crash populations is lower for US
vehicles. The best estimate of the risk difference for the US population is 0.057.
The best estimate of the risk difference for the EU population is 0.036.
 Risk differences in front/side crashes are largest for near‐side crashes, middle
occupant ages (31 ‐ 70), unbelted occupants, and higher Delta‐Vs. In rollovers,
risk differences were highest for unbelted occupants and ejected occupants.
“

In short, an interpretation of these conclusions is that US-regulated passenger vehicles

are not as safe in front and side impacts as EU ones and vice-versa for rollover accidents.
This is in contradiction to the accident analysis work reported above, which indicates that
the safety of EU and US passenger cars (M1) are approximately equivalent in front and
side impacts.

However, before much emphasis is placed on this ‘discrepancy’ it should be noted that
Flannagan et al. caution the reader in interpreting the significance tests and confidence
intervals of the results underpinning their conclusions. In particular, they mention that
further work should be performed to investigate the potential effect of the substantially
greater share of SUVs and pickup trucks in the US population compared to the EU.

Indeed, this effect could explain the discrepancy seen in the results as follows:

The in-depth accident analysis within this report (Section 4.3) selected passenger cars in
the US so that they were equivalent to M1 (passenger cars) in the EU (Tables 1 and 2).
Like-by-like comparisons were then perfomed which reported injury proportions (i.e.
injury risk) to be broadly similar for EU and US passenger cars in front and side impacts.
The outcome of this was that many SUVs, pickups, etc were not included in the US
accident data sample for this work.
81
The UMTRI work selected passenger vehicles based on the number of seating positions,
six or fewer, or seven or more seating positions. Crash partners were selected as
passenger vehicles, wide objects (including HGVs and buses), and narrow objects and
other. The outcome of this was that SUVs and pickups were included in the UMTRI
accident data sample because of the number of seating positions and defined as passenger
vehicles, both as struck vehicles, but more importantly as striking vehicles too.

If we now consider passenger car to passenger car impacts, the UMTRI analysis includes
SUVs and pickups impacting passenger cars. SUVs and pickups are more aggressive
partners in front and side impacts compared to conventional cars, because of a number of
factors, including their mass / stiffness and their geometry. The UMTRI work fits models
to the accident data to determine the relationship between risk of injury and accident
parameters. Whilst these models contain coefficients, such as delta-V, which will
probably take into account the mass / stiffness aggressivity factor of the SUVs and
pickups, they do not contain coefficients to take into account their geometrical
aggressivity.

The inclusion of the SUV and pickup vehicles as impact partners in the UMTRI work is
likely to explain why the US vehicles have a higher injury risk than EU ones in front-
front and front-side collisions. The UMTRI models do not account for all of the effects of
regional vehicle fleet differences.

For the accident data analysis within this report the accident data samples are more
similar in terms of the numbers of SUVs and pickups, because the approach was to
compare like-for-like crashes, and hence the issue described above with the UMTRI
work does not arise.

The UMTRI report is, to our knowledge, the first side-by-side comparison of predicted
risk for EU-regulated and US-regulated vehicles, but further work is required before any
differences in crashworthiness performance in the real world can be quantified. Therefore,
the conclusions of this work have been carefully reviewed, but on balance the evidence
within the report and the statistical model results are not strong enough to categorically
state that EU or US vehicles have a lower risk in the real-world.

Considering future vehicle design and technologies, it is important to aim for better and
more harmonized real world accident data collection in both regions. This will allow
more reliable and robust evaluations to be made earlier and the best safety designs and
technologies to be identified and promoted more efficiently, which will ultimately
prevent more injuries, arguably in all world regions.

82
6. FRONTAL IMPACT

6.1 COMPARISON OF EU REGULATIONS AND US STANDARDS

Frontal impact requirements for the EU and the US are specified in the regulatory acts
and federal standards, respectively, shown in Table 19 below.

It should be noted that:

 The item ‘seat-belt anchorages’ are not included in this table because they were
covered in the first test case non-paper12. However, child restraint anchorages are
included under ‘seat-belts and restraint systems’ because they were not covered in
the first test case.
 The item, ‘safety glazing materials and their installation on vehicles’ and
associated legislative requirements of UN Regulation 43, FMVSS 205 and GTR 6
are not included in this table because they were covered in the second case test
non-paper in the direct vision section13.
 The item ‘interior fittings / impact protection’ and associated legislative
requirements of UN Regulation 21 and FMVSS 201 are not included in this table
although interior impact is relevant to frontal impact. However, a comparison of
them is included in Section 7 ’Side Impact’.
 The ‘bumper’ item is described in Section 9, ‘Rear impact’. It is important for
low speed and pedestrian impact.

12
Technical non-paper: EU Position Paper: Test case on functional equivalence – proposed methodology
for automotive regulatory equivalence.
http://trade.ec.europa.eu/doclib/docs/2015/january/tradoc_153023.pdf
13
Technical non-paper: Second test case on recognition of equivalence in relation to US and EU Lighting
and Vision standards.
http://trade.ec.europa.eu/doclib/docs/2015/february/tradoc_153168.4.9%20Vehicles%20paper%20second
%20test%20case.pdf

83
 Table 19: Regulatory Acts and federal standards that specify frontal impact related
requirements for the EU and the US, respectively

No. Item EU USA

Regulatory Description Federal Description
Act (Framework Standard
Directive)
1 Frontal UN Reg 94 53A: Protection FMVSS 208 Occupant crash
impact crash – (ODB 56 of occupants in protection
tests km/h) the event of a FMVSS 301 Fuel system
(including frontal collision integrity
Out of FMVSS 204 Steering
Position Control
(OOP)) Rearward
Displacement
(FMVSS 303, (Fuel system
integrity,
compressed
natural gas
vehicles.
FMVSS 305) Electric
powered
vehicles:
electrolyte
spillage and
electrical shock
protection)
2 Windshield None FMVSS 212 Windshield
mounting mounting
and FMVSS 219 Windshield
windshield zone intrusion
zone
intrusion
3 Impact from UN Reg 12 14A: Protection FMVSS 203 Impact
steering of the driver Protection for
control against the the Driver from
steering the Steering
mechanism in Control System
the event of an
impact
4 Seat-belts UN Reg 16 31A: Safety FMVSS 208 Occupant crash
and restraint belts, restraint protection
systems systems, CRS FMVSS 209 Seat-belt
and ISOFIX assemblies
CRS FMVSS 225 Child restraint
anchorage
systems
6 Bumper (UN Reg Not required in Part 581 Bumper
42) framework standard
Directive

84
This section continues to give some background. This is followed by comparisons of the
legislations in each region for each item in Table 19 and finally a summary of the notable
differences between the legislations.

6.1.1 BACKGROUND

The main items in Table 19 that control a vehicle’s frontal impact protection are the
‘Frontal impact crash tests’ and ‘Seat-belts and restraint systems’, which are discussed in
separate sub-sections below. The items ‘Impact from steering wheel control’ and
‘Windshield mounting and windshield zone intrusion’ are not as significant as the
‘frontal impact crash tests’ and to some extent are believed to be retained due to
historical reasons. Indeed, the requirements for ‘Impact from steering wheel control’ (EU:
UN Regulation 12; US: FMVSS 203) are deemed to be met if appropriate parts of the
‘frontal impact crash tests’ are fulfilled. It is interesting to note the historical reasons for
these items:

 Impact from steering wheel control: This helped improve the design of steering
wheels to offer better protection for people impacting it in a crash. It is now
largely superfluous with the advent of driver airbags.
 Windshield mounting (FMVSS 212): This helped improve the design of
windshields to ensure that they remained in place in a crash and therefore could
prevent occupant ejection. It is now largely superfluous with bonded windscreens
which easily meet the requirements of this standard.
 Windshield penetration zone (FMVSS 219): In the past bonnets (hoods) would
break off at the hinges and penetrate the windshield. This legislation helped
improve the design of bonnets and their attachment to prevent this happening. It
is now part of standard design practice and therefore to a certain extent FMVSS
219 is superfluous.

Further background is given on the items ‘frontal impact crash tests’ and ‘seat-belts and
restraint systems’ in the sub-sections below.

6.1.1.1 FRONTAL IMPACT CRASH TESTS (INCLUDING OOP)

Regulation 94

The frontal impact Offset Deformable Barrier (ODB) test procedure and associated
performance requirements used in Regulation 94 were developed by EEVC Working
Group 11 (Lowne 1996). At this time, accident studies indicated the importance of
occupant compartment intrusion in the causation of fatal and serious injuries and
demonstrated the importance of replicating, in a dynamic test, the dynamics of structural
deformations occurring in accidents. To achieve this, EEVC WG11 developed a test
consisting of an offset impact into a deformable barrier. The most appropriate design of
deformable barrier was found to consist of a block of aluminium honeycomb of crush
strength 0.342 MPa of depth 450 mm with a smaller piece of 1.711 MPa honeycomb
attached along the bottom edge of its front surface to act as a nominal ‘bumper’. The
barrier was mounted 200 mm from the ground with its top surface at 850 mm. A test
speed of 56 km/h with a 40% overlap was recommended. This configuration was found
to replicate car to car tests between similar cars with a 50% overlap and a closing speed
of 100 km/h (each car travelling at 50 km/h). It was recommended that 50th percentile
Hybrid III dummies should be used in the driver and front seat positions. The
performance requirements recommended were mainly dummy based with limits
appropriate for the reduction for the risk of fatal and serious injuries. However, some
85
vehicle response requirements, such as steering wheel displacement and dummy
extraction, were also recommended to supplement the dummy requirements and increase
the robustness of the test. Also, it was recommended that separate tests (regulations) for
steering wheel impact, seat and seat attachment, and seatbelts and anchorages should be
maintained because these may not be assessed adequately in the ODB test.

The ODB test, in the form of Directive 96/79/EC, was made mandatory in the EU for M1
vehicles with a total permissible vehicle mass less than 2.5 tonnes, for new types from
1998 and for all new vehicles from 2003 and has remained largely unchanged to this day,
with the exception of amendments for items such as airbag warning labelling and
requirements for electric vehicles related to protection against electric shock and battery
retention. It is interesting to note that, in 2001, EEVC reviewed Directive 96/79/EC and
recommended that the test speed should be increased to 64 km/h (Edwards et al., 2001).
However, this recommendation was not implemented because of concerns that it may
encourage heavier vehicles to become stiffer (assuming their crush length was not
increased) and exacerbate compatibility problems (Edwards et al., 2003).

FMVSS 208

In 1984 NHTSA amended FMVSS 208 to phase in automatic protection such as airbags
or automatic belts for the front outboard seats of passenger cars. This was achieved with
requirements for crash tests at any speed up to 48 km/h (30mph) into a fixed rigid barrier
perpendicular to the line of travel of the vehicle, and at any angle up to 30 degrees in
either direction from the perpendicular with both belted and unbelted 50th percentile
Hybrid III dummies in driver and right front passenger positions.

Frontal airbags were designed to protect restrained and unrestrained occupants, but in the
early 1990s, it was found that they may cause harm to occupants positioned too close to
the airbag at the time of deployment. By late 1995, it was evident that not only infants,
but also unrestrained children and even some adults were being injured by frontal air
bags. Therefore, NHTSA initiated actions to reduce and eventually eliminate the adverse
effect of frontal air bags for infants, children and other high-risk occupants while
retaining the benefits of air bags for most people. The first of these actions, to facilitate
the introduction of depowered airbags circa 1998-99, was to permit a sled test in lieu of a
barrier impact in FMVSS 208 to certify that airbags would protect an unrestrained
occupant (‘sled certifcation’). This and following actions culminated in “advanced” air
bags that could deploy at a low level of force, depending on the occupant and crash
conditions, or provide the option of suppressed deployment of the passenger air bag.
Advanced air bags were phased into the fleet from September 1, 2003 to September 1,
2006. This was achieved by adding requirements for ‘out-of-position’ tests, a wider
variety of ‘in-position’ crash tests (full frontal, offset frontal) and a larger range of
occupant sizes (5th percentile Hybrid III). Further amendments have increased the
protection at higher speeds for belted occupants (the maximum test speed for belted
occupants increased from 48 km/h to 56 km/h) and added requirements for the different
options for the driver and passenger airbag system (driver – low risk deployment – tests
using 5th percentile Hybrid III; passenger – low risk deployment – tests using 1, 3, and 6
year old child dummies).

Discussion

It is generally agreed that to assess fully a car’s frontal impact crash protection both
offset and full-width tests are required (O'Reilly, 2003). An offset test is required to
assess the car’s intrusion resistance and provide a ‘softer’ deceleration pulse to assess the
86
restraint system, whereas a full-width test is required to provide a ‘hard’ deceleration
pulse to assess the restraint system. The International Harmonisation of Research
Activities (IHRA) frontal impact working group agreed that it would be desirable for two
frontal impact tests to be adopted universally and that this could be achieved most easily
by the universal adoption of the European Offset Deformable Barrier (ODB) test and the
‘restrained/perpendicular’ element of the US full-width test. To date, this IHRA
recommendation has not been implemented in either the EU or the US.

Therefore, at present, to some extent, the focus of the frontal impact crash test in the EU
is on control of the car’s structural performance and intrusion whereas in the US the
focus is on control of the car’s restraint system. Note that the purpose of the 40 km/h
ODB test in the US is to promote improvements in crash sensing and timing of the airbag;
its speed is too low to assess a car’s intrusion resistance. Interestingly, consumer testing
in the two regions can, to some extent, be seen to complement the regulation, in that IIHS
perform a 64 km/h ODB test in the US and Euro NCAP have just introduced (January
2015) a 50 km/h full width test in the EU. Consumer safety information testing is
detailed in Section 0.

6.1.1.2 SEAT-BELTS AND RESTRAINT SYSTEMS

Seat-belts are regarded as a vehicle’s top safety feature. NHTSA have estimated that
seat-belts have saved 12,174 lives in the US in 2012 and nearly 63,000 lives in the period
2008 to 2012 (NHTSA, 2013).

In 1958, Nils Bohlin, a Volvo design engineer patented the three point safety belt. By the
end of the sixities, three point belts were fitted to the front seat positions of most cars in
the US and the EU. Since then, seat-belt technology has advanced a great deal with
locking retractors, pretensioners and webclamps and more recently inflatable belts for
rear-seat occupants. These advances together with airbags helped to make the seat-belt
more effective and less restrictive to wear. Despite the proven advantages that seat-belt
wearing offers, the belt wearing rate is still some way off 100%, so currently seat-belt
reminders are installed in vehicles to encourage car passengers (drivers) to wear their belt.
In the past automatic belt-systems have also been tried in the US but because of their
many disadvantages, in particular that they generally offered inferior crash protection,
they were ultimately unsuccessful and not used today.

6.1.2 FRONTAL IMPACT CRASH TESTS (INCLUDING OOP TESTS)

This section compares the frontal impact crash test requirements including out-of-
position (OOP) for the EU and the US. It starts with a background section which
describes a little of the history of Regulation 94 and FMVSS 208 to set the scene for the
comparison of in-position tests and out-of-position tests made in the following sections.
The final section summarises the notable differences found.

6.1.2.1 IN-POSITION CRASH TESTS

This section compares the EU and US legislative requirements for in-position crash tests.

Scope

EU: Passenger cars (M1) of a total permissible mass ≤ 2.5 tonnes.

USA: Passenger cars, multipurpose passenger vehicles and trucks with Gross Vehicle
Weight Rating ≤ 8,500 lb (3,856 kg) or unloaded vehicle weight ≤ 5,500 lb (2,495 kg)
87
Test configurations

The legislative crash test configurations for each region are shown in Table 20. The EU
has one test, an ODB test at 56 km/h which controls the car’s intrusion resistance and
provides a ‘softer’ deceleration pulse to control the restraint system. In contrast the US
has five tests:
 Belted full-width frontal rigid barrier, ≤56 km/h, 0o±5o, 50th percentile driver and
passenger Hybrid III dummies
o To promote improved restraints for higher impact severities
 Belted full-width frontal rigid barrier, ≤56 km/h, 0o±5o, 5th percentile driver and
passenger Hybrid III dummies
o To promote improved restraints for higher impact severities
 Belted offset deformable barrier, ≤40 km/h, 0o, 5th percentile driver and passenger
Hybrid III dummies
o To promote improvements in crash sensing and timing of the air bag
 Unbelted full-width frontal rigid barrier, 32-40 km/h, 0o±5o, 5th percentile driver
and passenger Hybrid III dummies
o To promote improved occupant sensing and multi-stage inflation
 Unbelted full-width frontal oblique rigid barrier, 32-40 km/h, ±30o, 50th percentile
driver and passenger Hybrid III dummies
o To promote wider airbags

Table 20: Comparison of EU and US frontal impact test configurations

No. EU USA

(Regulation 94) (FMVSS 208)

Offset Deformable Barrier (ODB) tests

1 BELTED BELTED

Seat adjustment: 50th fore/aft mid,

Seat adjustment: fore/aft mid, up/down up/down lowest; 5th fore/aft, forward,
manufacturer defined up/down mid
Reference: R94, S5.2, Annex 3 Reference: F208, S17 & S18

Full-width tests

88
No. EU USA

(Regulation 94) (FMVSS 208)

2 None BELTED

Reference: F208, S14.5.1 & 5.1.1(b)

(1)(2)

3 None BELTED

Reference: F208, S15.1 & S16.1

(a)(1)(2).

89
No. EU USA

(Regulation 94) (FMVSS 208)

4 None UNBELTED

Reference: F208, S14.5.1 & 5.1.1(b)

(1)(2)

5 None UNBELTED

Reference: F208, S15.2 & S16.1(b)

The main differences are:

 No high(er) speed ODB test in US to control performance of vehicle structure

(intrusion resistance).
 No tests in EU to control protection for smaller occupants (5th percentile Hybrid
III).
 No tests in EU to control protection for the unbelted.
 No tests in EU to control protection in high deceleration full-width impacts.

Performance criteria and limits

90
The performance criteria and limits for the EU ODB test and the US tests are shown in
Table 46 in Annex 1. The main differences are:

 Dummy:
o Lower leg / knee: The EU has performance criteria and limits for the knee
and tibia whereas the US does not.
o Chest: The EU has a more stringent performance limit for chest deflection
(50 mm compared to 63 mm). The EU assesses chest Viscous Criterion
(VC) but not chest acceleration and vice-versa for the US.
 Note: In general, the US tests have a harder deceleration pulse then
the EU test because they are full-width whereas the EU test is
offset. This may partially reduce the real-world effects of the
different performance limits because higher chest loads would be
expected in tests with a harder deceleration pulse with a similar
restraint system.
o Neck: The neck injury criteria and limits were similar for R94 and F208
(sled test) until the US introduced the Nij criterion as part of the changes
for the ‘advanced airbags’ interim final rule (NHTSA 2000). Nij was seen
as an improvement over the previous separate limits because it accounts
for the superposition of loads and moments, and the additive effects on
injury risk. Limits were also specified for tension / compression to
independently control these potentially injurious loading modes. In
summary, the US F208 criteria and limits should be improved and slightly
more stringent than the EU R94 ones.
o Head: The EU use HIC36 and the US use HIC15. However, HIC36 of
1000 and HIC15 of 700 are broadly equivalent for long duration pulses,
which is likely to be the case for vehicles that meet the requirements. For
shorter duration pulses (< 25 ms) HIC15 is more stringent, which is likely
to be the case for vehicles close to the limits (NHTSA 2000). Also, EU
have an additional 3 ms acceleration criterion. Overall, head injury criteria
/ limits likely to be broadly equivalent with US slightly more stringent.
 Vehicle structure
o The EU has requirements for evacuation (after test) whereas the US does
not – seat belt mechanism release force and door opening.
 Fuel system integrity
o The US has more stringent post-crash requirements for fuel system
integrity, the main difference being the static roll test requirement in
FMVSS 301 where such a roll is not done in the EU.
o The US has post-crash fuel integrity leak requirements for Compressed
Natural Gas (CNG) vehicles whereas the EU does not. However, the
fitment of an automatic cylinder valve, which cuts off gas when required
by safety reason, is mandatory in the EU.
 Electric Vehicles
o Requirements are broadly similar with the exception that the US has
additional static roll test requirement for electrolyte spillage which the EU
does not.

Other requirements

Warning labels (and information in owner manuals) are required in both the EU and US,
related to the potential danger of airbags, especially the danger of placing babies in rear
facing seats on the front passenger seat.

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6.1.2.2 OUT-OF-POSITION (OOP) TESTS

This section compares the EU and US requirements for out-of-position (OOP) tests. The
EU has no requirements for OOP tests. The OOP test requirements for the US are
detailed in Table 47 in Annex 1. They consist of 4 sets of requirements for:

 OOP small stature female drivers

 Infants in front right passenger seat
 3 year old children in front right passenger seat
 6 year old children in front right passenger seat

For each of these requirement sets there are two options, either suppression of the airbag
or low risk deployment, with one exception. This is the set of test requirements for the
small stature female driver for which there is only one option of low risk deployment.

6.1.3 WINDSHIELD MOUNTING AND WINDSHIELD ZONE INTRUSION

USA requirements

FMVSS 212 ‘Windshield mounting’ and FMVSS 219 ‘Windshield zone intrusion’
effectively add to the requirements of FMVSS 208. Both apply to passenger cars,
multipurpose passenger vehicles, trucks and buses with a Gross Vehicle Weight Rating
(GVWR) less than 4,536 kg. Also, both set requirements must be met in a 48 km/h
perpendicular rigid barrier crash test with driver and front seat passenger Hybrid III 50th
percentile dummies.

FMVSS 212 ‘Windshield mounting’ requires that not less than 50 percent of the portion
of the windshield periphery on each side of the vehicle’s longitudinal centreline shall be
retained. Note this is 75 percent for vehicles not equipped with passive restraints.

FMVSS 219 ‘Windshield zone intrusion’ requires that no part of the vehicle outside the
occupant compartment (except components normally in contact with the windshield)
shall penetrate the protected zone template to a depth of more than 6 mm and no such
part of a vehicle shall penetrate the inner surface of that portion of the windshield, within
the Daylight Opening.

The protected zone is the space enclosed by the following surfaces, as shown in

(a) The outer surface of the windshield in its pre-crash configuration.

(b) The locus of points 76 mm outward along perpendiculars drawn to each point on
the outer surface of the windshield.
(c) The locus of lines forming a 45° angle with the outer surface of the windshield at
each point along the top and side edges of the outer surface of the windshield and
the lower edge of the protected zone, determined by using a 165 mm rigid sphere
with a mass of 6.8 kg, in the plane perpendicular to the edge at that point.

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 Figure 62: Windshield protection zone

EU requirements

There are no requirements for these items in the EU.

6.1.4 IMPACT FROM STEERING CONTROL

The relevant legislation for the EU is UN Regulation 12 and for the US FMVSS 203 and
SAE J944 June 1980. Regulation 12 specifies steering column displacement
requirements, body block test requirements, and protection against electrical shock
requirements whereas FMVSS 203 (and SAE J944) specifies body block test
requirements only. This section focuses on the body block test requirements only because
the steering column displacement requirements and the protection against electrical
shock items are described in Section 6.1.2.1 above. Section 6.1.2.1 contains the
requirements for these items in the description of the main in-position crash tests.

Interestingly, the applicability of both Regulation 12 and FMVSS 203 is similar in that
the requirements are deemed to be met (Regulation 12), or not applicable (FMVSS 203),
if appropriate parts of the main in-position crash test requirements have been met, which
will be the case for virtually all passenger cars under consideration for the current study,
i.e. those produced in unlimited series and fitted with driver airbags. However if
applicable, Regulation 12 only applies to passenger cars of gross mass less than 1,500 kg,
whereas FMVSS 203 applies to passenger cars of gross mass less than 4,536 kg.

The body block tests in Regulation 12 and FMVSS 203 are similar. The body block and
test procedure are the same, but there are some small differences in the requirements, in
particular the EU has additional requirements for acceleration and sharp or rough edges
(see Table 48).

In summary, there are no significant notable differences between EU and US legislative

requirements for protection of the driver against impact with the steering control.

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6.1.5 SEAT BELTS AND RESTRAINT SYSTEMS

The relevant legislation for the EU is UN Regulation 16 and for the US FMVSS 209 with
some of the higher level requirements in FMVSS 208. A comparison of the tests and
associated requirements of the relevant legislations is shown in Table 49.

Whilst there are many detailed differences, the main notable ones are:

 Retractors: Whilst the EU and US both require three-point belts and emergency
locking retractors for all seating positions, (although it is slightly unclear what the
US requirement is for a front centre seat), there are three notable differences:
o EU requires retractor with multiple sensitivity (i.e. sensitive to both
vehicle acceleration and webbing withdrawal) whereas the US does not.
o Locking requirements are significantly different for both vehicle
acceleration and webbing withdrawal and in some cases difficult to
compare directly; e.g. vehicle acceleration: EU lock when vehicle
deceleration ≥ 0.45g, US lock before payout of 25 mm with acceleration
of 0.7g. Interesting to note difference in test setup for webbing withdrawal
assessment: in EU webbing is pulled, in US retractor is moved. EU setup
is necessary because of overlapping requirements of vehicle acceleration
and webbing withdrawal, so not possible to perform both tests by moving
retractor.
o USA allows option of switchable retractors for seats other than front
outboard which is most likely related to the installation of child seats.
 Seat-Belt Reminder (SBR): Whilst the EU and US both require fitment of a SBR
for the driver’s seat, the EU requirements for the warning are greater with both
visual and audible warnings required (USA either one or the other) and two levels
of warning required (USA only one).
 Occupant size: EU does not specify size of occupants that restraint system should
fit whereas US does.
 Dynamic test: EU has a dynamic sled test whereas US does not. However, it
should be noted that the front outboard seated positions are tested dynamically as
part of FMVSS 208 in the US. Therefore, there is only a possible issue for the
rear and front inboard seat positions because the 208 test is of comparable or
greater severity than the EU dynamic sled test. Furthermore, the US has higher
strength requirements for attachments compared to the EU ((22,241 – 49,034N
compared to 14,700N), which will at least compensate partially for the absence of
a dynamic test for some seat positions.

There are also many other less notable differences such as:

 Attachments: Loads for attachment strength test higher for US compared to EU

(22,241 – 49,034N compared to 14,700N). However, EU has dynamic sled test
whereas US does not.
 Compressive load test: The compressive load test for the buckle and rigid
(plastic) parts is significantly different between the EU and US. The EU test is an
impact type test whereas the US one is a compressive quasi-static load; the EU
test on the buckle is at low temperature whereas the US one is at room
temperature; and the EU tests rigid (plastic) parts whereas the US does not.
 Strap conditioning: The EU has low temperature, heat and water conditioning
whereas the US does not. In contrast the US has a micro-organism test for strap
materials that are susceptible to this type of degradation whereas the EU does not.

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6.1.6 BUMPER

USA requirements

In the US, the part 581 ‘bumper standard’ is mandatory. The main purpose of this
standard is to reduce physical damage to the front and rear ends of a passenger motor
vehicle from low speed front and rear collisions (2.5 mph for longitudinal impact, 1.5
mph for corner impact). The standard consists of pendulum impactor tests into the
bumper at a height between 16 and 20 inches and a test of the vehicle into a fixed barrier.
Damage based requirements should be met, such as lamps and reflectors should be free
of cracks and hood, truck and doors should operate as normal. A detailed description of
the requirements of this standard can be found in Section 9 (Rear Impact). It is applicable
to passenger vehicles excluding multipurpose passenger vehicles and low speed vehicles.

EU requirements

There are no mandatory requirements for the bumper in the EU, although UN Regulation
42 does specify requirements somewhat similar to the US Part 581 ones. Further details
of the Regulation 42 requirements and how they compare to the Part 581 ones can be
found in Section 9 (Rear Impact).

6.1.7 SUMMARY OF MAIN NOTABLE DIFFERENCES

In-position crash tests

 No high(er) speed ODB test in US to control performance of vehicle structure

(intrusion resistance).
 No tests in EU to control protection for smaller occupants (5th percentile Hybrid
III).
 No tests in EU to control protection for the unbelted.
 No tests in EU to control protection in high deceleration full-width impacts.
 The EU has a more stringent chest deflection performance limit (50 mm
compared to 63 mm for 50th percentile Hybrid III).
o Note: In general, the US tests have a harder deceleration pulse then the
EU test because they are full-width whereas the EU test is offset. This
may partially reduce the real-world effects of the different performance
limits because higher chest loading would be expected in tests with a
harder deceleration pulse with a similar restraint system.
 The EU has requirements for the knee and the lower leg (tibia) whereas the US
does not.
 The EU assesses the following vehicle structural related parameters whereas the
US does not:
o Occupant evacuation criteria after test, in particular seatbelt mechanism
release force and door opening.
 The US has more stringent post-crash requirements for fuel system integrity,
mainly a static rollover test to assess leakage after the crash test, whereas the EU
assesses leakage only in the end position after the test. However, the EU requires
a tank overturn test as component test for normal use, i.e. test pre-crash.
Note: US also requires a static rollover test following side (MDB and pole) and
rear crash tests and for battery electrolyte spillage for electric vehicles.
o The US has post-crash fuel integrity requirements for CNG vehicles
whereas the EU does not. Note: this is also applicable for side (MDB and
pole) and rear crash tests. However, the fitment of an automatic cylinder
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 valve, which cuts off gas when required by safety reason, is mandatory in
the EU.

 Although warning against somewhat similar dangers, the warning labels (and
information in owner hand manuals) are substantially different.

Out-of-Position (OOP) tests

 No OOP tests in EU to ensure airbag suppression or low risk deployment for:

o Small stature female drivers
o Infants in rear facing seats in front right passenger seat
o 3 and 6 year old children in front right passenger seat

Windshield mounting and windshield zone intrusion

 No windshield mounting requirement in EU – retention of windshield in 48 km/h

full-width rigid barrier test in US.
 No windshield zone intrusion test in EU – no external car components, e.g.
bonnet (hood), penetrate zone close to windshield in 48 km/h full-width rigid
barrier test in US.

Impact from steering control

 No notable differences

Seat belts and restraint systems

 Retractors: Whilst the EU and US both require three point belts and emergency
locking retractors for all seating positions, (although it is slightly unclear what
requirement is in US for a front centre seat), there are three notable differences:
o EU requires retractor with multiple sensitivity (i.e. sensitive to both
vehicle acceleration and webbing withdrawal) whereas the US does not.
o Locking requirements significantly different for both vehicle acceleration
and webbing withdrawal and in some cases difficult to compare directly
e.g. vehicle acceleration EU lock when vehicle deceleration ≥ 0.45g, US
Lock before payout of 25 mm with acceleration of 0.7g. Interesting to
note difference in test setup for webbing withdrawal assessment, in EU
webbing is pulled, in US retractor is moved. EU setup is necessary
because of overlapping requirements of vehicle acceleration and webbing
withdrawal, so not possible to perform both tests by moving retractor.
o USA allows option of switchable retractors for seats other than front
outboard which is most likely related to the installation of child seats.
 Safety Belt Reminder (SBR): Whilst the EU and US both require fitment of a
SBR for the driver’s seat, the EU requirements for the warning are greater with
both visual and audible warnings required (USA either one or the other) and two
levels of warning required (USA only one).
 Occupant size: EU does not specify size of occupants that restraint system should
fit whereas US does.
 Dynamic test: EU has a dynamic sled test whereas US does not. However, it
should be noted that the front outboard seated positions are tested dynamically as
part of FMVSS 208 in the US. Therefore, there is only a possible issue for the
rear and front inboard seat positions as these are thus not tested.

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Bumper

 The US has mandatory requirements for the bumper to minimise vehicle damage
in low speed impacts, whereas the EU does not.

6.2 CONSUMER INFORMATION TESTING

This section describes frontal impact tests performed in the EU and US to provide safety
information for consumers. A summary of the tests performed is given in Table 21
categorised by degree of overlap.

The tests are described and compared in the sections below. Also their effects on the
legislation, and in particular the notable differences detailed in the section above are
discussed in terms of:

 Legislative differences that are effectively plugged (filled).

 Effective enhancement of the legislation.

Table 21: Frontal impact tests for consumer information in the EU and US

Item / Test EU USA

1 Frontal full-width Euro NCAP – Rigid barrier US NCAP Rigid
50 km/h – introduced from barrier 56 km/h
Jan 2015
2 Frontal medium Euro NCAP ODB 64 km/h IIHS – ODB 64 km/h
overlap

3 Frontal low overlap None IIHS low overlap

(25%) 64 km/h –
introduced 2012

6.2.1 FRONTAL FULL-WIDTH

Full-width rigid barrier tests are conducted in both regions by Euro NCAP and US NCAP
as part of respective consumer testing programmes. While the US NCAP test has been in
force for many years, the Euro NCAP test was only recently introduced in 2015. It is yet
to be seen how manufacturers of European vehicles will respond to meet the
requirements of this test.

There are several differences between the test setup adopted in each region. Euro NCAP
carries out the test at 50 km/h while US NCAP uses a higher speed of 56 km/h. Euro
NCAP assesses two 5th percentile Hybrid III dummies; one in the driver position and one
in the rear left position (Table 22). The OEM is requested to provide data for the front
passenger position in the same test setup to demonstrate similar protection levels for this
seating position. In cases where the OEM is not willing or able to provide this data, Euro
NCAP may perform the full-width test with an additional Hybrid III 5th percentile
dummy in the front passenger seat. The US NCAP test assesses a 50th percentile Hybrid
III dummy in the driver position and a 5th percentile Hybrid III dummy in the front seat
passenger position as standard.

97
Table 22: Comparison of test configurations for Euro NCAP (EU) and US NCAP (USA)
frontal full width crash tests for consumer information

No. EU USA

(Euro NCAP) (U.S. NCAP)

Full-width tests

1 BELTED BELTED

Note: Introduced January 2015

Both assessments are based on the dummy injury criteria measurements. Euro NCAP
divides body regions into colours to indicate how well each area is protected. In contrast,
US NCAP awards an overall star rating for the driver and passenger dummy to indicate
how well it was protected.

For Euro NCAP, the vehicle’s performance is evaluated using dummy measurements for
the following body regions: head (HIC15, resultant acceleration), neck (shear, tension,
extension) chest (Compression, Viscous criterion) and femur / pelvis (femur
compression).

A maximum of 4 points are awarded for each body region based on how the dummy
injury criteria compare with upper and lower performance limits taking the criterion that
gives the lowest score. The points are summed to create an overall score. Modifiers are
also applied meaning that points may be deducted for undesirable vehicle performance
(e.g. incorrect airbag deployment). The protection provided for adults for each body region
are presented visually, using coloured segments within body outlines. The colour used is
based on the points awarded for that body region, with green for maximum (4) points, red for
zero points and yellow, orange or brown for between 0 and 4 points. Further details of the
Euro NCAP assessment may be found in Table 52.

For US NCAP, the rating is based on an evaluation of injury risk indicated by the injury
criteria recorded during the test. The risk of an AIS 3+ injury for each body region is
calculated using injury risk curves. The overall risk of serious injury for frontal impact
can then be calculated using:

𝑃𝐽𝑜𝑖𝑛𝑡 = 1 − (1 − 𝑃𝐻𝑒𝑎𝑑 ) × (1 − 𝑃𝑁𝑒𝑐𝑘 ) × (1 − 𝑃𝐶ℎ𝑒𝑠𝑡 ) × (1 − 𝑃𝐹𝑒𝑚𝑢𝑟 )

98
This risk is then compared to a baseline risk of 15%. The ratio is called the relative risk
and is used to determine the star rating.

To compare the US NCAP and FMVSS 208 requirements, US NCAP upper and lower
performance limits were derived by calculating the individual risk value for each body
region which, when put into the equation calculating the overall risk for frontal impact,
produced a total relative risk value that enabled the vehicle to achieve either a five star
rating (upper performance limit) or a one star rating (lower performance limit). It should
be noted that this method assumed that the risk of injury, contributed by each body
region to the final equation, was equal. In practice, OEM’s may achieve higher
performance in some body regions, which can offset lower performance in other regions.
The US NCAP derived performance limits are compared with the FMVSS 208
requirements in Table 51 and show that to obtain a NCAP five star rating a car’s crash
performance needs to exceed that to meet the FMVSS 208 requirements substantially.

6.2.1.1 EFFECTS ON LEGISLATIVE NOTABLE DIFFERENCES

The effects of the Euro NCAP and US NCAP full-width tests on the legislative notable
differences are:

 Legislative differences that are plugged, i.e. filled.

o The Euro NCAP full-width test, to some extent, fills the following
legislative differences for in-position crash tests:
 No tests in EU to control protection for smaller occupants (5th
percentile Hybrid III).
 No tests in EU to control protection in high deceleration full-width
impacts.

However, it should be noted that effects of the Euro NCAP full-width test to date on
the vehicle fleet are likely to be minimal because it was only introduced January 2015.
Also, it is planned that the introduction of a legislative full-width test in the EU will
be voted on in WP29. in November 2015.

 Effective enhancement of the legislation.

o The US NCAP full-width test effectively enhances the effect of the
FMVSS 208 legislative full-width tests in that it encourages greater
occupant protection performance to achieve reduced dummy injury
criteria in all body regions assessed (head, neck, chest and femur). Note
that the US NCAP test setup is no more stringent than that of the higher
speed FMVSS 208 tests with the 50th and 5th percentile dummies.
o The Euro NCAP full-width test assesses the protection of a small adult
occupant in the rear of a vehicle. This effectively enhances the legislation,
although it is not currently required in legislative testing for either region.
However, it should be noted that effects of the Euro NCAP full-width test
to date on the vehicle fleet are likely to be minimal because it was only
introduced January 2015.

6.2.2 FRONTAL MEDIUM OVERLAP

In the EU and the US, medium overlap crash tests to provide consumer information, are
performed by Euro NCAP and the Insurance Institute for Highway Safety (IIHS),
respectively.

99
The test setups are similar, but the Euro NCAP test assesses three more seating positions:
the front passenger for adult protection and the rear seating positions for child protection
(Table 23).

Table 23: Comparison of test configurations for Euro NCAP (EU) and IIHS (USA)
frontal medium overlap crash tests for consumer information

No. EU USA

(Euro NCAP) (IIHS)

Offset Deformable Barrier (ODB) tests

2 BELTED BELTED

The performance assessments for the Euro NCAP and IIHS tests are similar in principle,
but very different in detail. Both assessments are based on the dummy injury criteria
measurements divided into four levels using upper and lower performance limits for each
body region. The assessment is modified if other, generally vehicle performance,
measurements indicate undesirable behaviour. The individual body region assessments
are combined to give, ultimately, an overall assessment for the vehicle. For Euro NCAP,
the vehicle’s performance is evaluated using dummy measurements for each body region.
A number of points are awarded based on how the dummy injury criteria compare with
upper and lower performance limits taking the criterion that gives the lowest score. The
points are summed to create an overall score for adult protection and child protection.
Modifiers are also applied meaning that points may be deducted for undesirable vehicle
performance (e.g. incorrect airbag deployment). For IIHS, a similar process is followed
but as only one dummy is assessed it is simpler.

The Euro NCAP and IIHS assessments are compared in detail in Table 50. It is
interesting to note that many of the lower limit performance values for Euro NCAP are
the same as the performance limit values for UN Regulation 94 frontal impact test. There
are many differences between the injury criteria used for assessment of the body regions
and the upper and lower performance limit values. The most notable is:

100
  The Euro NCAP performance limits for chest deflection (upper 22 mm; lower
42mm) are substantially lower than the IIHS limits (upper 50 mm; lower 75 mm).
In contrast IIHS assesses chest acceleration whereas Euro NCAP does not.

6.2.2.1 EFFECTS ON LEGISLATIVE NOTABLE DIFFERENCES

The effects of the Euro NCAP and IIHS medium overlap tests on the legislative notable
differences are:

 Legislative differences that are plugged, i.e. filled.

o The IIHS medium overlap test, to some extent, fills the following
legislative differences for in-position crash tests:
 No high(er) speed ODB test in US to control performance of
vehicle structure (intrusion resistance).
 The EU has requirements for the knee and the lower leg (tibia)
whereas the US does not.
 Effective enhancement of the legislation.
o The Euro NCAP medium overlap test effectively enhances the effect of
the UN Regulation 94 legislative test in that it encourages vehicle’s to
have a safety performance substantially in excess of that required for
Regulation 94, in particular test speed is higher 64 km/h compared to
56 km/h and performance limits are more stringent, generally the Euro
NCAP lower limit is the limit for Regulation 94 and the upper limit
substantially more stringent, e.g. chest deflection: lower limit 50 mm
which represents 50% risk of injury ≥ AIS 3 14; upper limit 22 mm which
represents 5% risk of injury ≥ AIS 3. However, it should be noted that this
may not be without negative effects. These are that this may encourage
vehicles to be stiffer which could cause higher vehicle decelerations in
lower speed impacts, which in turn could lead to more injury in these
impacts, in particular for more vulnerable elderly occupants (Edwards et
al., 2003), (Johannsen et al., 2013), (O'Reilly, 2003).

6.2.3 FRONTAL LOW OVERLAP

In the US, the IIHS perform a low overlap test to provide information for consumers on a
vehicle’s performance in a low-overlap impact. FMVSS 208 does not require a low
overlap test and no equivalent test exists in the EU either.

During the IIHS low overlap test, a vehicle strikes a rigid barrier with a 25% overlap at
64 km/h. The driver’s seat is occupied by a Hybrid III 50th percentile dummy (Table 24).

14
Mertz H; Horsch J, Horn G and Lowne R (1991). Hybrid III sternal deflection associated with thoracic
injury severities on occupants restrained with force-limiting shoulder belts. SAE paper 910812.

101
 Table 24: Comparison of test configurations for Euro NCAP (EU) and IIHS (USA)
frontal low overlap crash tests for consumer information

No. EU USA

(Euro NCAP) (IIHS)

Low Overlap tests

3 None BELTED

25% overlap

Introduced 2012

The performance assessments for the IIHS test are based on the dummy injury criteria
measurements divided into four levels using upper and lower performance limits for each
body region. The assessment is modified if other, generally vehicle performance,
measurements indicate undesirable behaviour. The individual body region assessments
are combined to give, ultimately, an overall assessment for the vehicle. A rating of
‘good’, ‘acceptable’, ‘marginal or ‘poor’ is awarded for each body region based on how
the dummy injury criteria compare with certain performance limits. The dummy
kinematics and the vehicle structure are also awarded a rating. The overall score is based
on the number of times the vehicle scored each of the ratings. Normally a vehicle
achieves one level above the worst rating achieved. The vehicle rating may also be
downgraded due to undesirable vehicle performance (e.g. incorrect airbag deployment).
The IIHS assessment is described in detail in Table 53.

6.2.3.1 EFFECTS ON LEGISLATIVE NOTABLE DIFFERENCES

The effects of the IIHS small overlap test on the legislative notable differences are:

 Legislative differences that are plugged, i.e. filled.

o None
 Effective enhancement of the legislation.
o The IIHS low overlap test effectively enhances the US legislation by
adding assessment of the protection that a vehicle offers in low overlap
impacts. Because there is no low overlap test in the European legislation,
it also effectively adds to the legislative differences.
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6.2.4 SUMMARY OF INFLUENCE OF CONSUMER TESTING ON LEGISLATIVE
DIFFERENCES

The influence of consumer testing on the legislative notable differences listed above are
summarised in this section. This consists of the following two parts:

 Legislative differences that are plugged by consumer tests.

 Legislative enhancements that are driven by consumer tests.

Full-width tests

 Legislative differences that are plugged.

o The Euro NCAP full-width test, to some extent, fulfils the following
legislative differences for in-position crash tests:
 No tests in EU to control protection for smaller occupants (5th
percentile Hybrid III).
 No tests in EU to control protection in high deceleration full-width
impacts.

However, it should be noted that effects of the Euro NCAP full-width test to date on
the vehicle fleet are likely to be minimal because it was only introduced in January
2015.

 Effective enhancement of the legislation.

o The US NCAP full-width test effectively enhances the effect of the
FMVSS 208 legislative full-width tests in that it encourages greater
occupant protection performance to achieve reduced dummy injury
criteria in all body regions assessed (head, neck, chest and femur). Note
that the US NCAP test setup is no more stringent than that of the higher
speed legislative tests with the 50th and 5th percentile dummies.
o The Euro NCAP full-width test assesses the protection of a small adult
occupant in the rear of a vehicle. This effectively enhances the legislation,
although it is not currently required in legislative testing for either region.
However, it should be noted that effects of the Euro NCAP full-width test
to date on the vehicle fleet are likely to be minimal because it was only
introduced in January 2015.

Medium overlap tests

 Legislative differences that are plugged.

o The IIHS medium overlap test, to some extent, fulfils the following
legislative differences for in-position crash tests:
 No high(er) speed ODB test in US to control performance of
vehicle structure (intrusion resistance).
 The EU has requirements for the knee and the lower leg (tibia)
whereas the US does not.
 Effective enhancement of the legislation.
o The Euro NCAP medium overlap test effectively enhances the effect of
the UN Regulation 94 legislative test in that it encourages vehicles to have
a safety performance substantially in excess of that required for
Regulation 94.

103
 o Euro NCAP assesses the protection of a small adult occupant in the rear of
a vehicle. This is not currently required in regulatory testing for either
region.

Low overlap tests

 Legislative differences that are plugged.

o None
 Effective enhancement of the legislation.
o The IIHS low overlap test effectively enhances the US legislation by
adding assessment of the protection that a vehicle offers in low overlap
impacts. Because there is no low overlap test in the European legislation,
it also effectively adds to the legislative differences.

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6.3 DISCUSSION OF REAL-WORLD IMPLICATIONS OF LEGISLATIVE DIFFERENCES

6.3.1 SUMMARY OF LEGISLATIVE DIFFERENCES AND EFFECT OF CONSUMER TESTING

Frontal impact crash tests (including OOP)

 No high(er) speed ODB test in US to control performance of vehicle structure

(intrusion resistance).
o However, the IIHS medium overlap test does, to some extent, fill this
difference.
o It should be noted that:
 The Euro NCAP medium overlap test effectively enhances the
effect of the UN Regulation 94 legislative test in that it encourages
vehicle’s to have a safety performance substantially in excess of
that required for Regulation 94, in particular test speed is higher 64
km/h compared to 56 km/h and performance limits are more
stringent to achieve any rating better than poor.
 The IIHS medium overlap test encourages vehicle crash
performance in excess of that which Regulation 94 demands, in
terms of an increased test speed (IIHS 64 km/h, R94 56 km/h) and
generally more stringent performance limits.
 The Euro NCAP test has substantially more stringent performance
limits than the IIHS test for chest deflection, Euro NCAP 22 mm -
42 mm; IIHS 50 mm – 75 mm.
 No tests in EU to control protection in high deceleration full-width impacts.
o However, the Euro NCAP full width test introduced in January 2015
should, to some extent, fill this difference in the future, although its
influence to date (and hence relevance to this study) will likely have been
minimal because of the short time that it has been active.
 No tests in EU to control protection for the unbelted.
 No tests in EU to control protection for smaller occupants (5th percentile Hybrid
III).
o However, the Euro NCAP full width test introduced in January 2015
should, to some extent, fill this difference in the future, although its
influence to date (and hence relevance to this study) will likely have been
minimal because of the short time that it has been active.
 The EU has a more stringent chest deflection performance limit (50 mm
compared to 63 mm for 50th percentile Hybrid III).
o Note: In general, the US tests have a harder deceleration pulse then the
EU test because they are full-width whereas the EU test is offset. This
may partially reduce the real-world effects of the different performance
limits because higher chest loading would be expected in tests with a
harder deceleration pulse with a similar restraint system.
 The EU has requirements for the knee and the lower leg (tibia) whereas the US
does not.
o However, the IIHS medium overlap test does, to some extent, fill this
difference.
 The EU assesses the following vehicle structural related parameters, namely
occupant evacuation criteria after test, in particular seatbelt mechanism release
force and door opening, whereas the US does not.
 The US has more stringent requirements for fuel system integrity, mainly a static
rollover test to assess leakage after the crash test, whereas the EU assesses
105
 leakage only in the end position after the test. However, the EU require a tank
overturn test as component test for normal use, i.e. pre-crash test.
Note: US also requires a static rollover test for side (MDB and pole) and rear
crash tests and battery electrolyte spillage for electric vehicles.
 The US has fuel integrity requirements for CNG vehicles whereas the EU does
not. Note: this is also applicable for side (MDB and pole) and rear crash tests.
 Although warning against somewhat similar dangers, the warning labels (and
information in owner hand manuals) are substantially different.

 No OOP tests in EU to ensure airbag suppression or low risk deployment for:

o Small stature female drivers
o Infants in rear facing seats in front right passenger seat
o 3 and 6 year old children in front right passenger seat

Windshield mounting and windshield zone intrusion

 No windshield mounting requirement in EU – retention of windshield in 48 km/h

full-width rigid barrier test.
 No windshield zone intrusion test in EU – no external car components, e.g.
bonnet (hood), penetrate zone close to windshield in 48 km/h full-width rigid
barrier test.

Impact from steering control

 No notable differences

Seat belts and restraint systems

 Retractors: Whilst the EU and US both require three point belts and emergency
locking retractors for all seating positions, (although it is slightly unclear what
requirement is in US for a front centre seat), there are two notable differences:
o EU requires retractors with multiple sensitivity whereas the US does not.
o Locking requirements significantly different for both vehicle acceleration
and webbing withdrawal and in some cases difficult to compare directly
e.g. vehicle accln EU lock when vehicle decel ≥ 0.45g, US Lock before
payout of 25 mm with accel 0.7g. Interesting to note difference in test
setup for webbing withdrawal assessment, in EU webbing is pulled, in US
retractor is moved. EU setup is necessary because of overlapping
requirements of vehicle accln and webbing withdrawal, so not possible to
perform both tests by moving retractor.
o USA allows option of switchable retractors for seats other than front
outboard which is most likely related to the installation of child seats.
 Safety Belt Reminder (SBR): Whilst the EU and US both require fitment of a
SBR for the driver’s seat, the EU requirements for the warning are greater with
both visual and audible warnings required (USA either one or the other) and two
levels of warning required (USA only one).
 Occupant size: EU does not specify size of occupants that restraint system should
fit whereas US does.
 Dynamic test: EU has a dynamic sled test whereas US does not. However, it
should be noted that the front outboard seated positions are tested dynamically as
part of FMVSS 208 in the US. Therefore, there is only a possible issue for the
rear and front inboard seat positions as these are thus not tested.

106
Bumper

 The US has mandatory requirements for the bumper to minimise vehicle damage
in low speed impacts, whereas the EU does not.

6.3.2 LITERATURE REVIEW - INCLUDED ARTICLES

The flow of articles through the literature review selection process is illustrated by a flow
diagram in Figure 63 below. There were 1101 citations retrieved from the original search
of the databases, of which 884 were excluded based on the a priori selection criteria. Of
Number of articles identified Number of articles identified
through database searching through other sources
(n=909) (n=192)
Number of articles identified

Number of articles after duplicates removed

(n=727)

Number of articles screened Number of articles excluded

for relevance (n=331)
(n=548)
Number of articles screened

Number of full text articles Excluded articles (n=168):

assessed for eligibility Failed to meet selection criteria: 92
(n=217) Not highly relevant to RQ: 70
Low quality methodology: 6

Number of studies included

for evidence evaluation
(n=49)

RQ1 RQ3 RQ5 RQ7 RQ9

(n=8) (n=8) (n=8) (n=15) (n=0)

RQ2 RQ4 RQ6 RQ8 RQ10

(n=10) (n=11) (n=14) (n=0) (n=0)

the 217 articles selected for full review, 49 met the selection criteria and were included
for full article evaluation for each Research Question (RQ).

Figure 63: Flow diagram illustrating the flow of articles through the selection process.
(Several articles report on multiple research questions (RQ))

107
6.3.3 FRONTAL IMPACT CRASH TESTS (INCLUDING OOP)

 No high(er) speed ODB test in US to control performance of vehicle

structure (intrusion resistance).
 No tests in EU to control protection in high deceleration full-width impacts.

The research questions used to perform the literature search to address these notable
differences were:
RQ1: In offset frontal passenger car collisions occurring at higher (>40 km/h) impact
speeds and involving front seat occupants [S], do EU and US occupants [D]
experience any difference in injury severity from vehicle intrusion [O]?
RQ2: In full width frontal passenger car collisions involving front seat occupants [S],
do EU and US occupants [D] experience any difference in injury severity [O]?

These two legislative differences were considered together because they are highly
related. As mentioned previously above, it is generally agreed that to assess and control
fully a car’s frontal impact crash protection both offset and full-width tests are required
(O'Reilly, 2003). An offset test is required to assess the car’s intrusion resistance and
provide a ‘softer’ deceleration pulse to assess the restraint system whereas a full-width
test is required to provide a ‘hard’ deceleration pulse to assess the restraint system.

On this bias, an expected outcome of the legislative differences above could be, less
protection and therefore greater proportion of more severe injuries to casualties in offset
crashes in US compared to EU, and vice-versa for full-width crashes.

On review of the literature, no study (from 106 full article reviews) was found to directly
compare the differences in the offset or full width frontal impact injuries experienced by
the EU and US fleets. On further examination, several studies collated epidemiological
data documenting the real-world implications of offset and full width frontal impacts at
the national level. Eight highly-relevant articles (comprised of nine accident databases:
four US, two GB, two German and one Swedish) analysed offset frontal impacts (RQ1,
Annex 2, Table 54), whilst eleven articles (comprised of twelve accident databases: four
US, five GB, one German, one Swedish and one Australian) evaluated full width frontal
impacts (RQ2, Annex 2, Table 55).

From these reviews, however, it is clear that there is wide variation between the studies
extracting real-world accident data. Fundamental differences between these studies such
as accident analysis periods, model years of included vehicles, selection criteria (for
occupants, vehicles and accidents) and statistical analysis methods, makes the analysis of
trends within these studies extremely difficult.

Figure 64 shows an attempt to compare data from these studies. The distribution of all,
MAIS2+ & MAIS3+ injured casualties in frontal impact by overlap is shown for the US
and the EU, specifically Great Britain (GB) – note that data for the EU as a whole could
not be found. The data for the US were obtained from Scullion et al. (Scullion et al.,
2010). They are weighted data for model year 1985+ vehicles from NASS-CDS 1995-
2008 data. The data for GB were obtained from Richards et al. (2010). They are data
from the GB Co-operative Crash Injury Study (CCIS) for Regulation 94 compliant (or
equivalent) cars for crashes collected between June 1998 and August 2009.

108
 60

50

All USA
40
MAIS 2+ USA
Percentage

MAIS 3+ USA
30

All GB
20
MAIS 2+ GB

10 MAIS 3+ GB

0
Low (No rail Offset (Loading Full (Loading of
loading) of one rail) both rails)
Accident Overlap in terms of structural loading

Figure 64: Comparison of the distribution of all, MAIS2+ & MAIS3+ injured casualties
in frontal impact by overlap for the US and GB.

It is seen that there are differences in the injury distributions for the US and GB. For
offset accidents the US has a greater proportion of MAIS3+ injuries compared to all and
MAIS2+ injuries than GB, whereas for full width accidents the US has a smaller
proportion of MAIS3+ injuries compared to all and MAIS2+ injuries than GB. If these
differences were significant and the effect of confounding factors, such as the age and
gender, were removed, this would indicate that the regulatory differences may have real-
world implications, i.e. the lack of a higher speed ODB test in the US leads to a greater
proportion of more severe injuries in offset crashes and similarly the lack of a full width
test in the EU leads to a greater proportion of more severe injuries in full width crashes.
However, it is not known if these differences are significant – they are probably not – and
confounding factors are likely to be present, for example the vehicle age distribution is
different between the samples, therefore no conclusions can be drawn.

Because no conclusions could be drawn from the accident data in the literature, a specific
accident analysis was performed to compare the distribution of injury severity by overlap
for passenger car frontal impacts for the EU (GB and Germany) and the US.

The results showed no significant differences in the distribution of injury severity

between the EU and US for low, medium and high overlap crashes (Figure 65). This
indicates that the protection provided by passenger cars in medium and high overlap
crashes in the EU and US is similar.

109
Figure 65: Belted drivers. Percentage distribution of each injury severity, for each
region, for low (≤ 20%), medium (20 -70%) and high (> 70%) overlap frontal crashes.

Although neither the EU nor US legislation has requirements for low overlap impacts, it
is interesting to note that IIHS introduced tests to encourage improved protection in this
crash configuration in 2009.

The reasoning for this action appears to be underpinned by the results of an accident
analysis performed by Brumbelow and Zuby (2009). They found that a large number of
serious and fatal injuries occur to belted occupants in frontal crashes in cars which
achieve good performance in crashworthiness evaluation programmes. For a significant
proportion of these, compartment intrusion was the main likely contributor factor to the
injury. Compartment intrusion occurred most frequently in small overlap, underride and
high velocity moderate overlap crashes. However, the larger proportion of the injuries
occurred without significant compartment intrusion. Brumbelow and Zuby commented
that a variety of factors may have contributed to the injury risk in these cases, such as
occupants being out of position due to preceding impacts, loading from other occupants,
or restraint misuse. In addition, they commented that restraint systems may be unable to
adequately balance the need for varying restraint forces based on occupant age, size, and
crash severity. They concluded that further research is needed to develop improved
countermeasures that adapt to the occupant and crash circumstances and to determine test
conditions which would allow meaningful evaluation of the countermeasures. They
finally concluded that, until this is complete, it appears more promising to address the
crashes in which compartment intrusion occurs, i.e. the low overlap ones.

 No tests in EU to control protection for the unbelted.

The research questions used to perform the literature search to address this notable
difference were:
RQ3: In frontal passenger car collisions involving unrestrained front seat occupants
[S], do EU and US occupants [D] experience any difference in injury severity
[O]?
RQ4: In frontal passenger car collisions involving restrained (airbag + belted, airbag
only, belted only) front seat occupants [S], do EU and US occupants [D]
experience any difference in injury severity [O]?

110
In the US, since the 1990’s, it has been required that airbags are designed to protect
unbelted occupants. In contrast, in the EU, no similar requirement for protection of the
unbelted has ever existed.
The seat belt use rate has improved enormously in the US in recent years, from around
60 % in the nineties to 87% nowadays (Figure 66).
100

90

80
Percent Seat belt Use

70

60

50

40

30
1994 1999 2004 2009 2014

Figure 66: Percent seat belt wearing rate by year as measured by NHTSA’s National
Occupant Protection Use Survey (NOPUS) (Chen, 2015).

In the EU, seat belt wearing rate data (based on roadside observations) could only be
found for individual countries (WHO, 2009;IRTAD, 2013). These data show that the
wearing rate for passenger cars (M1 vehicles) for front seat passengers varies
substantially by country, e.g. Germany 98%, Italy 69%, United Kingdom 95%. Using
these data a seat belt wearing rate of 90% for EU member countries was calculated by
averaging based on passenger car kilometres travelled in each member country.
Comparing this value with that for the US shows that the seat belt wearing rate is, on
average, approximately the same in the EU and US nowadays, albeit slightly higher in
the EU.

Analyses of accident data from the nineties shows the high effectiveness of airbags in the
US in reducing the fatality risk for unbelted occupants (Table 25 - Airbag alone) noting
that the benefits were derived primarily from frontal crashes (NHTSA, 2001). With the
low seat belt usage rate at this time (about 60%), the benefit of designing airbags to
protect unbelted occupants is clear. However, it should be noted that the same study
showed that the level of effectiveness is far more for the belted occupants, which clearly
shows the benefit of wearing a seat belt.

Table 25: Estimated effectiveness in reducing fatality risk for passenger car drivers in all
crashes by occupant protection system in US.

Occupant protection system Effectiveness

Fatalities
Airbag plus lap-shoulder belt 51%

Airbag alone 14%

Manual lap-shoulder belt 45%

111
It is interesting to note that a similar analysis using accident data from Great Britain
calculated an effectiveness of about 60% for airbag and belt restraint systems compared
to about 40% for a belt only system for driver fatalities (Richards et al., 2008). Broadly,
these values are comparable to those shown above calculated by NHTSA.

The main issue is that some believe that designing airbags (and the car) to protect the
unbelted can reduce the effectiveness of the belt and bag system for belted occupants.
This issue is clearly more important now than it was in the nineties because the seat belt
usage rate has increased from about 60% then, to 87% recently as mentioned above.
However, the evidence for this issue in the literature is scarce. One modelling based
study by Nusholtz et al. (2007) showed that providing protection for unbelted occupants
may have disbenefits for belted occupants. Specifically, the work showed that a vehicle’s
impact response (stiffness) optimized for the unbelted may be counter indicated for the
belted and vice-versa if optimised for the belted.

However, some manufacturers surveyed informed that, although the prime focus was on
protection for belted occupants, they had essentially one restraint solution for both the
US and the EU. This indicates that some protection for unbelted occupants can be
delivered without substantial reduction in protection for belted occupants.

Therefore, on this basis, the expected consequences of the legislative notable difference
may be that US cars have an improved restraint system efficacy for unbelted occupants
compared to EU cars, and in contrast a reduced restraint system efficacy for belted
occupants. On these hypotheses, one would expect to observe a greater comparative risk
of injury for EU unbelted and US belted occupants, when compared to the rest of their
respective populations. This should be particularly evident for frontal crashes with a
delta-V of less than 40 km/h (25 mph), which is the speed up to which protection for
unbelted occupants is required in the US.

The proportions of MAIS 3+ & Fatal, MAIS 2 and MAIS 1 injured occupants in the EU
and US were compared in Section 4.3.4 for a delta-V above and below 40 km/h, the
speed up to which FMVSS 208 requires protection for the unbelted. As a result of this
requirement, for unbelted casualties, one would expect to observe a lower proportion of
more seriously injured casualties in accidents with a delta-V less than 40 km/h in the US.
No significant evidence of this was seen (Figure 67), indicating that protection for the
unbelted in the EU and US is similar.

112
Figure 67: Unbelted occupants. MAIS distribution as a percentage of all injuries above
and below a delta-V of 40 kmh.

On further review of the literature, no study (from 94 full article reviews) was found to
directly compare the differences between the frontal impact injuries experienced by both
belted and unbelted occupants in the EU and US fleets. On further examination, several
studies collated epidemiological data documenting the real-world implications of frontal
impacts for belted and unbelted occupants at the national level. Fifteen articles
(comprised of two meta-analyses and 13 US accident databases) were observed to assess
the relative risks of the various restraint system combinations (airbag and belted, airbag
only, belt only, no restraint) and during frontal impacts (Annex 2, Table 56). Specifically,
eight articles were found to evaluate the relative fatality risks associated with these
restraint systems when compared to unrestrained occupants (RQ3), whilst 11 articles
further compared the risks of fatality between the various restraint systems themselves
(RQ4).

Through a meta-analysis of articles (published prior to 2009) that evaluated the effect of
airbags and seatbelt restraint systems during frontal impacts, Høye (2010) summarised
the efficacy of these systems in reducing driver fatalities and serious injuries. This review
observed that airbags reduced fatalities in frontal collisions by 22% among belted drivers
and by 13% among unbelted drivers, whilst also reducing severe injuries by 18% among
belted drivers. The results also indicated that the effectiveness of airbags was improved
for belted drivers in the US with the 1997 revision of the testing procedures, i.e. sled
certified testing for airbags to facilitate the introduction of depowered airbags. For
unbelted drivers in frontal collisions, however, this revision was observed to be neither
beneficial nor counterproductive and may have even increased the risk of fatalities by 8%
in non-vehicle-to-vehicle scenarios. When comparing the fatality odds ratios of airbags in
the EU and the US, Høye (2010) observed that European airbags (both from GB studies)
resulted in a greater reduction in frontal injuries; however, these results remain
inconclusive due to the greater summary effect of the European studies not being
statistically significant.

113
Importantly, when considering the current (3rd) generation of US certified advanced and
compliant (CAC) airbags (i.e. compliant with FMVSS 208 phase-in 2003-2006), three
articles have attempted to evaluate the relative fatality risks for CAC airbags for front
seat passengers in frontal impacts when compared to sled-certified (2nd generation)
airbags in the US (Braver et al., 2010;Greenwell, 2013;Teoh, 2014). These studies found
no significant overall effect for CAC airbags, when compared to both advanced and non-
advanced sled-certified airbags (Greenwell, 2013), but did observe a statistically
significant increase of 12-22% in the fatality risks associated with CAC airbags for belted
drivers (Braver et al., 2010;Teoh, 2014). This increased risk of fatality may be an
important consideration for importing new US vehicle models (i.e. those fitted with
CAC airbags) to the EU.

Due to this paucity in recent and substantial European studies that evidence the outcomes
of belted and unbelted occupants during frontal impacts, it remains difficult to come to
any conclusion about the real-world implications of the lack of a legislative requirement
to protect unbelted occupants in the EU. To resolve this problem older accident data
containing vehicles not fitted with driver airbags could be used, but this would introduce
confounding factors related to improvements in the vehicle crashworthiness and restraint
performance in the intervening fifteen or so years.

 No tests in EU to control protection for smaller occupants (5th percentile

Hybrid III).

The research question used to perform the literature search to address this notable
difference was:
RQ5: In frontal passenger car collisions involving smaller front seat occupants [S],
do EU and US occupants [D] experience any difference in injury severity [O]?

An expected consequence of this notable difference could be that restraint systems may
not perform as well for smaller stature (mainly female) occupants in the EU compared to
those in the US. On this bias, one would expect to observe a greater comparative risk of
injury for smaller stature (mainly female) occupants compared to rest of the population in
the EU compared to the US.

On review of the literature, only one study (from 25 full article reviews) was observed to
directly compare the differences between frontal impact injuries experienced by smaller
occupants in the EU and US fleets (Mackay and Hassan, 2000). Unfortunately, this study
had several fundamental issues associated with the quality of the methodology adopted
for weighting the data limiting specific comparisons (as noted by the author). This study
was therefore rejected from the literature review on the grounds of poor methodological
quality. On further examination, several studies collated epidemiological data reporting
the real-world implications of frontal impacts for smaller stature female occupants at the
national level. Four highly-relevant articles (comprised of four accident databases: two
GB, one German and one US) analysed the relative injury risks associated with smaller
stature occupants during frontal impacts (RQ3, Annex 2, Table 57), whilst four articles
(comprised of four accident databases: two GB and two US) assessed the relative injury
risks associated with female occupants during frontal impacts (RQ3, Annex 2, Table 57).

To analyse the effects of occupant stature on frontal impact injury outcomes in the EU,
Kirk et al. (2002) and Welsh et al. (2003) utilised CCIS data to assess the probability of
AIS2+ head injuries for smaller stature GB occupants. Kirk et al. (Kirk et al., 2002)
found that, when compared to taller occupants (>1.73 m) in frontal impacts when the
airbag either deployed (3.4%) or failed to deploy (7.5%), smaller occupants had a greater
114
probability of AIS2+ head injury during frontal impacts both when the airbag deployed
(6%, <1.73 m; 6%, <1.61 m) and when the airbag failed to deploy (12%, <1.73 m; 23%,
<1.61 m). This relationship was further found by Welsh et al. (2003) for driver AIS2+
head injuries in airbag fitted and non-fitted vehicles and for driver AIS2+ pelvis and
lower extremity injuries. In frontal impacts, Welsh et al. (2003) found that, in
comparison to taller drivers with (4%, >1.70 m; 7%, >1.85 m) or without (10%, >1.70 m;
15%, >1.85 m) a fitted airbag, smaller drivers had a greater probability of AIS2+ head
injury both with (7%, ≤1.70 m; 8%, ≤1.55 m) and without (14%, ≤1.70 m; 21%, ≤1.55 m)
fitted airbags. This trend was similarly found for driver AIS2+ pelvis and lower
extremity injuries in frontal impacts, with smaller drivers found to have a greater
probability of injury (14%, ≤1.70 m; 23%, ≤1.55 m) than taller occupants (11%, >1.70 m;
9%, ≤1.85 m).

To analyse the effects of occupant stature on the injury outcomes of frontal impacts in the
US, Newgard & McConnell (2008) used NASS CDS data to model the effects of stature
on the probability of AIS3+ injury. Newguard & McConnell (2008) found that both taller
and smaller occupants experienced an increased probability of AIS3+ injuries with airbag
deployment, whilst experiencing a reduction in AIS3+ injuries when the airbag failed to
deploy. Divergence between the two injury mechanisms occurred at <1.55 m for smaller
occupants and >1.90 m for taller occupants, with a significant difference found at statures
of <1.38 m. This data can, in part, be compared to European data from a similar analysis
of AIS2+ head injuries performed by Kirk et al. (2002) using CCIS accident data. Kirk et
al. (2002) also found that both taller and smaller belted drivers experienced an increased
probability of AIS2+ head injuries with airbag deployment, whilst smaller belted drivers
experienced an increase in AIS2+ injuries when the airbag failed to deploy. Divergence
between the two injury mechanisms occurred at <1.65 m for smaller occupants and >1.80
m for taller occupants; however, no significant difference between the injury mechanisms
was found.

With the female population tending to be of smaller stature in general, this review also
sought to evaluate the effect of gender on injury outcomes during frontal impacts. For the
EU, Lenard & Welsh (2001) and Welsh & Lenard (2001) both analysed CCIS data for
GB frontal impacts. Lenard & Welsh (2001) found a significant trend towards a greater
incidence of skeletal thoracic injuries amongst belted female front passengers (53% vs.
31%), whilst no other significant trend in injury outcomes was found by either study. For
the US, Hill and Boyle (2006) observed that, in frontal collisions, females aged 55–74
(OR: 5.27) and ≥75 (OR: 2.33) were significantly more likely to suffer a severe injury in
comparison with other occupants. Carter et al. (2014) expanded this research to establish
that female occupants were more likely to experience AIS3+ thoracic, upper extremity
and lower extremity injuries, whilst this gender effect was found to be modulated by age
as older females were more likely to have AIS3+ thoracic and upper extremity injuries
than older males. Carter et al. (2014) further predicted the potential injury reductions that
would be associated with limiting the population to male only vehicle occupants, finding
that setting gender to male in their model resulted in fewer thoracic (5618, [4212–6272]),
upper extremity (3804 [1781–4803]) and lower extremity (2791, [2216–3256]) injuries in
frontal crashes across the US.

These reviews indicate that smaller stature occupants have a higher risk of severe head
and lower extremity injuries in both regions, whilst female occupants (who are generally
smaller) are at the greatest risk of severe thoracic injuries. From these reviews, however,
it is clear there is wide variation in both the methods used and the measures collected by
the studies extracting real-world accident data. These fundamental differences, between

115
accident analysis periods, selection criteria (for occupants, vehicles and accidents) and
the analyses performed by each study, therefore make the analysis of trends within and
between these studies extremely difficult. Even so, it indicates that protection of smaller
stature and female occupants is still an issue in both the EU and US even though the US
have additional legislation aimed specifically at measures for protection of these
occupant groups.

It is interesting to note that some manufacturers of world cars surveyed informed that
they had essentially one restraint solution for both the US and the EU. This indicates that
for these cars protection for smaller stature occupants is the same in both the US and the
EU.

 The EU has a more stringent chest deflection performance limit (50 mm

compared to 63 mm for 50th percentile Hybrid III), although should be noted
that US tests are more severe, in terms of deceleration pulse and therefore
higher chest deflections should be expected.
 The EU has requirements for the knee and the lower leg (tibia) whereas the
US does not.

The research questions used to perform the literature search to address these two notable
differences were:
RQ6: In frontal passenger car collisions involving front seat occupants [S], do the
thoraces of EU and US occupants [D] experience any difference in injury
severity [O]?
RQ7: In frontal passenger car collisions involving front seat occupants [S], do the
knees and lower limbs of EU and US occupants [D] experience any
difference in injury severity [O]?

The expected consequences of these legislative differences could be that the thorax, knee
and lower leg protection systems installed in the US fleet may not perform at the standard
of those installed in the EU fleet. On this bias, one would expect to observe a reduction in
the severity of thoracic, knee and lower leg injuries for EU restrained occupants, when
compared to US restrained occupants.

On review of the literature, no study (from 75 full article reviews) was found to directly
compare the differences between the thoracic, knee and lower leg injuries experienced by
EU and US occupants during frontal impacts. On further examination, several studies
collated epidemiological data documenting the real-world implications of frontal impacts
on the severity of thoracic, knee and lower leg injuries experienced at the national level.
Fourteen articles (comprised of fifteen accident databases: six US, six GB, two German
and one Australian) were found to assess the severity of thoracic injuries (RQ6, Annex 2,
Table 58), whilst fifteen articles (comprised of sixteen accident databases: nine US, four
GB, two German and one Australian) evaluated the severity of injuries to the knee and
lower leg (RQ7, Annex 2, Table 59).

Similar to the reviews for RQ1 and RQ2, it is clear that there is wide variation between
the studies extracting real-world accident data. These fundamental differences, between
measures such as accident analysis periods, model years of included vehicles, selection
criteria (for occupants, vehicles and accidents), outcome measures and statistical analysis
methods, make the analysis of trends between studies challenging. The following review,
however, provides important context to the real-world effects of these notable differences
between the legislative requirements of the EU and US.
116
In the US, US NCAP encourages lower chest deflection values than those required for
FMVSS 208 compliance, specifically a maximum deflection of 32 mm is allowed for a
five star rating. This will encourage the design of cars which have chest deflections much
lower than required for compliance in FMVSS 208 tests. Also, the IIHS moderate
overlap test, which is more severe than the UN Regulation 94 test (IIHS test speed 64
km/h, R94 56 km/h) and has generally more stringent requirements for the knee and
lower leg (tibia), will encourage the design of cars which can meet the Regulation 94
requirements for knee and lower tibia. Therefore, these consumer information tests will
likely fulfil the above notable legislative differences between the EU and US.

Brumbelow and Farmer (2013) investigated the relationship between the chest deflection
measured in the IIHS moderate (40%) overlap frontal crash test with real-world injury
risk in frontal impacts. They found that restraint systems that reduce peak Hybrid III
sternal deflection in a moderate overlap crash test are beneficial in real-world crashes
with similar or greater overlap but likely have a disbenefit in crashes with small overlap.
They concluded that current restraint systems could be improved by designs that reduce
sternal deflection in moderate and large overlap crashes without increasing occupant
excursion in small overlap crashes.

As part of this work, the chest deflection values recorded in IIHS moderate overlap tests
for model year vehicles since 1995 were reported. These results showed that for all
model year 2002+ vehicles, the chest deflection value measured was below 50 mm with
an average around 32 mm. Considering that the IIHS test has a significantly higher test
speed than the UN Regulation 94 test (IIHS 64 km/h; R94 56 km/h), this is a strong
indication that US cars would meet the Regulation 94 chest deflection performance
limits. However, it is interesting to note that very few of the vehicles tested recorded
chest deflections values low enough to meet the Euro NCAP higher performance limit of
22 mm. This gives some indication that restraint systems are optimised to achieve good
ratings in the consumer information programmes for each region.

For the US, from analysis of NASS CDS data for 2004-08, Hallman et al. (2011) found
that the greatest proportion of belted front seat occupant AIS2+ and AIS3+ large overlap
injuries were experienced by the lower extremities (78% and 66%, respectively) followed
by injuries to the thorax (32% and 62%, respectively). This was further supported by the
analysis of 2000-2006 NASS CDS data (Brumbelow and Zuby, 2009), which found that,
in frontal crashes for vehicles that performed well in IIHS frontal crash tests, belted front
seat occupants sustain AIS3+ injuries to the thorax more often than the head, abdomen,
spine or pelvis. They also found that a large proportion of these thoracic injuries occurred
with little or no compartment intrusion and were primarily associated with either restraint
or occupant (e.g. age, BMI) related factors. The crashes in which compartment collapse
caused AIS 3+ injuries were mostly small overlap, underride and high velocity moderate
overlap crashes. It should be noted that the study sample size was small (n=116) due to
the limitation that occupants were selected from frontal crashes involving vehicles with
good IIHS ratings for frontal crash protection and were injured at the MAIS 3+ level (i.e.
had at least one AIS 3+ injury).

For the EU, Richards et al (2010) analysed CCIS (GB) and GIDAS (Germany) accident
data to find that, for belted drivers of UN Regulation 94 compliant cars in frontal crashes,
the most frequently injured body regions for both MAIS2+ and MAIS3+ injured drivers
were the thorax (GB: 32% and 52%; Germany: 39% and 60%, respectively) followed by
the lower extremities (GB: 33% and 43%; Germany: 12% and 26%, respectively). As in

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the US, a large proportion (37%) of GB MAIS3+ thoracic injuries were primarily related
to the restraint system and occurred with little or no compartment intrusion.

To some extent, the relatively similar body injury distribution patterns described above
confirm that the real-world effects of the above notable legislative differences are not
particularly significant, possibly because they are filled by consumer information testing.
For the chest deflection difference, this explanation is supported further by the chest
deflection measurements recorded in the IIHS moderate overlap test. These show that all
US Model Year 2002+ cars tested by IIHS would meet the UN Regulation 94 chest
deflection requirement. As with the previous Research Questions, there is wide variation
in both the methods used and the measures collected by the studies extracting real-world
accident data. These fundamental differences, between accident analysis periods,
selection criteria (for occupants, vehicles and accidents), the outcome measures collected
and analyses performed by each study, therefore make the analysis of trends within and
between these studies challenging.

 The EU assesses the following vehicle structural related parameters, namely

occupant evacuation criteria after test, in particular seatbelt mechanism
release force and door opening, whereas the US does not.

The research question used to perform the literature search to address this notable
difference was:
RQ8: After a frontal passenger car collision [S], do EU and US occupants
attempting to evacuate their vehicle [D] experience any difference in
injury severity [O]?

The expected consequences of these notable legislative differences could be a reduction

in the incidence of trapped occupants in the EU when compared to the US. On this bias,
one would expect to observe greater injury severities associated with trapped occupants
and trapped occupant rates after frontal collisions in the US fleet when compared to the
EU fleet. Unfortunately, on review of the literature, no articles were found to achieve the
study selection criteria so no full article reviews were performed.

Overall, it is not thought that this notable difference is likely to be significant because:

 No information could be found in the literature on this issue.

 Door opening is related to the vehicle’s structural performance and the IIHS
assess the structural performance of vehicles in their medium overlap test and so
effectively, to some extent, plug this difference between the legislations.

 The US has more stringent requirements for fuel system integrity, mainly a
static rollover test to assess leakage after the crash test, which the EU does
not require. However, the EU requires a tank overturn test as component
test for normal use, i.e. test pre-crash.
Note: US also requires a static rollover test for side (MDB and pole) and rear
crash tests and battery electrolyte spillage for electric vehicles.
 The US has fuel integrity requirements for CNG vehicles whereas the EU
does not. However, the fitment of an automatic cylinder valve, which cuts off
gas when required by safety reason, is mandatory in the EU.
Note: the US also has this requirement for side (MDB and pole) and rear
crash tests.
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The research questions used to perform the literature search to address these two notable
differences were:
RQ9: After a frontal passenger car collision [S], does any difference in the fuel
integrity of EU and US vehicles [D] result in any difference in occupant
injury severity or vehicular damage [O]?
RQ10: After a frontal passenger car collision [S], does any difference in the fuel
integrity of EU and US CNG vehicles [D] result in any difference in
occupant injury severity or vehicular damage [O]?

The expected consequences of these notable legislative differences could be a reduction

in the incidence of vehicular fuel leaks and /or fires in the US when compared to the EU.
Unfortunately, on review of the literature, no study (from 7 full article reviews) was
found to investigate the frontal impact injuries or damage experienced during vehicular
fires in the EU and US fleets.

It is also unlikely that a specific accident analysis would give significant results either.
This is because fire is such a rare event, differences (if any) seen between the incidence
rates in the EU and US would probably be insignificant.

 The warning labels (and information in owner hand manuals) are

substantially different.

Whilst the dangers that are being warned against are somewhat similar and positioning of
the labels are also somewhat similar, the differences between the labels (and information
in owner manuals) are so substantial that they are not appropriate for use in the other
region. For example, the US labels have substantial text on them which is only in
English. This would likely cause problems in many EU member states where the main
language is not English. For this reason the EU have adopted labels that are more
pictogram based. the EU pictogram labels would likely cause problems in the US
because they do not convey as much information as the US ones. Also, the warning
labels (and information in owner manuals) in each region are likely to be related to
information advertisement campaigns. For these reasons and the fact that changing the
warning labels (and information in owner manuals) for each region should not entail a
major cost, it is suggested that these items are not considered equivalent and the
legislated labels (and information in owner manuals) appropriate for each region
are used always.

 No OOP tests in EU to ensure airbag suppression or low risk deployment

for:
o Small stature female drivers
o Infants in rear facing seats in front right passenger seat
o 3 and 6 year old children in front right passenger seat

In the 1990’s in the US, while air bags were saving an increasing number of casualties in
moderate and high speed crashes, they occasionally caused fatalities, especially to
unrestrained, out of position children, in relatively low speed crashes. As of April 1,
2000, NHTSA's Special Crash Investigation (SCI) program had confirmed a total of 158
fatalities induced by the deployment of an airbag. Of that total, 92 were children, 60 were
drivers, and 6 were adult passengers (NHTSA, 2000). Behavioural and technological
changes were made to address this problem. Behavioural changes, such as more children
travelling in the rear seats and short statured drivers seating further away from the
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steering wheel, were encouraged with public education programmes and improved
labelling informing of the dangers of airbags. Technological changes were made through
the depowering of airbags at the end of the 1990’s driven by the introduction of the sled
test option for the certification of second generation airbags into FMVSS 208. The
benefits of these initial behavioural and technological changes were then confirmed by
the SCI program through a reduction in the annual incidence of child and adult airbag
related fatalities from 1.43 fatalities per million registered vehicle years (MRVY) in
1996-1997 (NHTSA, 2000) to less than 0.05 child (and 0.01 adult) fatalities per MRVY
in 2001-2002 (Chidester and Roston, 2001;Kindelberger et al., 2003).

Several studies have since examined the real-world effects of these airbag design changes
on young front seat occupants in frontal collisions. Based on Partners for Child Passenger
Safety (PCPS) dataset, Durbin et al. (2003) determined the relative risks of injuries to
restrained children (aged 3–15 years old) exposed to first-generation passenger air bags
in frontal impacts compared to those in similar crashes with no airbag deployment.
Exposure to the passenger airbag was observed to increase the risk of minor (including
facial and chest abrasions), moderate and serious injuries, particularly head injuries and
upper extremity fractures (Durbin et al., 2003). This trend was confirmed using the
FARS database for both restrained and unrestrained children aged ≤5 years old (Olson et
al., 2006), with a 66% increase in the risk of death when children were exposed to first-
generation airbags. For children aged between 6-12 years old, however, Olsen et al.
(2006) found that first-generation airbags reduced the risks of death, although this was a
non-significant trend. Finally, when comparing first and second-generation airbags using
the PCPS dataset, Arbogast et al. (2005) found that, for belted front seat children aged 3-
15 years old, second-generation airbags resulted in a 41% reduction in AIS2+ injury risk.
This trend was also confirmed by Olsen et al. (2006) for all children aged ≤12 years old,
with a non-significant 21-34% reduction in the risks of death with second-generation
airbags.

When combined with the analyses performed by RQ3-5, the benefits to either supressing
or depowering passenger and driver airbags for smaller and younger occupants are clear.
Regardless of which region you are in, there is clearly an increased risk associated with
driver airbags for smaller stature drivers and passenger airbags for younger front seat
passengers, particularly when these occupants are sat closer to the airbag. From these
reviews, however, it is again clear that there is wide variation in the methods used and
the measures collected by studies extracting real-world accident data. These fundamental
differences, between accident analysis periods, selection criteria (for occupants, vehicles
and accidents) and the analyses performed by each study, therefore make the analysis of
trends between the regions extremely difficult. Further work, particularly within the EU,
is therefore required to determine whether or not protection for smaller and younger front
seat occupants is relatively worse or better in either region.

Regarding the FMVSS 208 OOP test for small stature female drivers, consultation with
vehicle manufacturers revealed that, generally, most modern airbag systems are designed
to deploy in a low risk manner controlled to a large extent by the panel break-out force,
airbag folding and, for the passenger airbag, initial deployment towards the windshield.
On this basis it is likely that a large proportion of driver airbags fitted in European cars
would meet the FMVSS 208 low risk deployment tests for small stature female drivers.

However, regarding the FMVSS 208 OOP test for infant seats, consultation with vehicle
manufacturers revealed that although automatic airbag suppression systems are fitted in
US vehicles for when an infant seat is present in the front passenger seat, only a manual

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airbag on / off switch is fitted in EU vehicles. Part of the reason for this is that the
automatic suppression technology is not believed to be absolutely foolproof, In contrast a
manual switch is, provided it is switched.

6.3.4 WINDSHIELD MOUNTING AND WINDSHIELD ZONE INTRUSION

 No windshield mounting requirement in EU – retention of windshield in 48

km/h full-width rigid barrier test (FMVSS 212).
 No windshield zone intrusion test in EU – no external car components, e.g.
bonnet (hood), penetrate zone close to windshield in 48 km/h full-width rigid
barrier test (FMVSS 219).

With typical bonded windshields fitted to passenger cars nowadays, it is not believed
that a vehicle would fail to meet the windshield mounting requirements of FMVSS
212. No compliance failures with recent vehicles could be found in the literature.
Crash tests carried out by TRL on vehicles that have recently undergone windscreen
replacement confirm that the performance of modern windscreen bonding systems
exceed the strength requirement to comply with FMVSS 212 at one hour after
replacement. This supports the view that fully cured windscreen bonds have strength
considerably greater than that required by FMVSS 212.

Similarly, with bonnets (hoods) fitted to passenger cars nowadays, it is not believed
that a vehicle would fail to meet the windshield zone intrusion requirements of
FMVSS 219.

Vehicle manufacturers consulted in the stakeholder survey agreed that the absence of
legislation in the EU equivalent to FMVSS 212 and FMVSS 219 should not have any
real-world implications because all current car designs should meet the requirements.
However, a stakeholder noted that, hypothetically, the EU pedestrian headform
impactor test requirements could drive the strength of bonnet hinges (weak to deform
when hit by impactor) below that required to meet FMVSS 219 (strong enough to
hold rear of bonnet).

6.3.5 SEAT BELTS AND RESTRAINT SYSTEMS

 Retractors: Whilst the EU and US both require three point belts and
emergency locking retractors for all seating positions, (although it is slightly
unclear what requirement is in US for a front centre seat), there are three
notable differences:
o EU requires retractors with multiple sensitivity (vehicle deceleration and
webbing withdrawal) whereas the US does not.
o Locking requirements significantly different for both vehicle acceleration
and webbing withdrawal and in some cases difficult to compare directly
e.g. vehicle acceleration EU lock when vehicle deceleration ≥ 0.45g, US
Lock before payout of 25 mm with acceleration 0.7g. Interesting to note
difference in test setup for webbing withdrawal assessment, in EU
webbing is pulled, in US retractor is moved. EU setup is necessary
because of overlapping requirements of vehicle acceleration and webbing
withdrawal acceleration, so not possible to perform both tests by moving
retractor.
o USA allows option of switchable retractors for seats other than front
outboard which is most likely related to the installation of child seats.

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Vehicle manufacturers consulted in the stakeholder survey confirmed that one design of
retractor can meet both the EU and US requirements. This indicates that the different
locking requirements for the EU and US must be similar and therefore approximately
equivalent.

This still leaves the possibility of US to EU import vehicles having single sensitivity
retractors (vehicle deceleration or webbing withdrawal) and optional switchable
retractors on rear seats, which could be undesirable.

 Safety Belt Reminder (SBR): Whilst the EU and US both require fitment of a
SBR for the driver’s seat, the EU requirements for the warning are greater
with both visual and audible warnings required (USA either one or the
other) and two levels of warning required (USA only one).

Ford and Honda introduced enhanced SBRs in their passenger cars in 2002 and 2004
respectively. Subsequently, in early studies, belt wearing rates of small groups of drivers
arriving for service at dealerships in the US were observed. For the Ford system, an
increase from 71% to 76% for those with SBR was reported (Williams et al., 2002); for
Honda, an increase from 84% to 90% was reported (Ferguson et al., 2007).

As well as how they influence wearing rates, other studies have looked at the association
between seat belt reminders and driver fatality risk (Farmer and Wells, 2010). This used
records of driver deaths in the US between 2000 and 2007, and the number of driver
deaths per vehicle registration was calculated for vehicles with and without SBR that met
the US standards. The fatality rate was 6% less in vehicles fitted with SBR, which was
unlikely to be due to chance. When these results were adjusted to remove any differences
in vehicle age between the two groups, it was found that the fatality rate was 2% less in
vehicles fitted with SBR, although it was more likely that this was due to chance.

Consumer rating testing in the EU encourages requirements for SBRs far in excess of the
UN Regulation 16 legislative requirements. There are no consumer testing incentives for
SBRs in the US. Euro NCAP awards vehicles with up to three extra points for SBRs (one
point for each of driver’s seat, passenger’s seat or all rear seats) out of a maximum of
10.5 points in the safety assist assessment if the SBR system meets certain criteria. The
safety assist assessment counts towards 20% of the overall star rating, so SBRs have a
significant effect on the overall rating of the car. For front seats, Euro NCAP requires a
“final signal”, which has to be audio-visual and must be presented at the latest 60
seconds after the engine start, after 500 metres of vehicle travel or speeds above 25 km/h.
The final signal must last for a minimum of 90 seconds and consisting of a loud and clear
audible and a visual signal. For the rear seats, Euro NCAP requires a “start signal”,
which may be visual only and starts within 5 seconds of engine start or forward travel at
speeds higher than 10 km/h. This may be delayed by 10 seconds if occupancy detection
is present. The duration of the signal must be at least 30 seconds. If a change in belt
status occurs at speeds above 25 km/h, i.e. a belt gets unbuckled, then an immediate
audible signal must be given. Seat occupancy detection is required for the front
passenger’s seat only, but recommended for the rear seats.

A study by Krafft et al. (2006) observed the seat belt use of 3,000 drivers in cars with
and without SBR in Sweden. It found that in cars without SBR, 82.3 percent of the
drivers used the seat belt, while in cars with SBR, the seat belt use was 98.9 percent. The
difference was significant. In cars with mild reminders, the use was 93.0 percent. This
study was later extended to show the benefit of SBRs throughout the EU (Lie et al.,
2008). Data collected in six major European cities and five Swedish cities showed a
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significant difference in the seat-belt wearing rate for similar types of car with and
without SBRs. For all observations, the total seat belt wearing rate was 97.5% +/− 0.5%
in cars with SBR, while it was 85.8% +/− 0.8% in cars without.

More recently, Kidd (2012) performed a study examined the effects of duty cycle and
duration on seat belt reminder effectiveness and annoyance. It also evaluated the Euro
NCAP duration requirement. Eighty part-time belt users experienced one of four seat belt
reminders during a simulated drive and rated its effectiveness and annoyance every 45
seconds. Overall, enhanced reminders were rated as more effective than a basic reminder
that complied with but did not exceed the U.S. federal requirements. Ratings of reminder
effectiveness did not change significantly as reminder duration increased. Increasing the
duty cycle of the chime and flashing icon in a reminder cycle did not influence system
effectiveness, but it did make the system more annoying. Reducing the duty cycle of
enhanced reminders would be one method of increasing user acceptance while retaining
overall system effectiveness. The variation in duration and duty cycle permitted under
Euro NCAP requirements for seat belt reminders did not affect their perceived
effectiveness.

The above illustrates that the difference in the legislative requirements for SBRs between
the EU and US (details in Annex 1, Table 49, second row) could likely lead to real-world
implications because the EU legislation requires a different type of SBR, which research
shows is more effective in the real-world. Hence, legislative equivalence cannot be
assumed. However, to a large extent, it is Euro NCAP and not the legislation that is
controlling SBRs in the EU, in terms of both warning level and seats fitted to
requirements. This further complicates the issue because if it is assumed that Euro NCAP
will assess and influence the design of US import cars, then legislative equivalence could
perhaps be assumed because it would have minor influence. Alternatively, if it is
assumed that Euro NCAP will not assess and influence the design of US import cars,
then legislative equivalence could not be assumed.

To complicate this issue further, it should be noted that an amendment to the SBR
legislation in the EU is being considered currently. The amendment is likely to propose
compulsory fitment of SBRs to front seat passenger and rear seat positions for M1
vehicles.

 Occupant size: EU does not specify size of occupants that restraint system
should fit whereas US does (FMVSS 208 S4.1 adjustable to fit occupants
from 5th female to 95th male).

Vehicle manufacturers consulted in the stakeholder survey said that all their vehicles,
including those sold in Europe, would meet the FMVSS 208 occupant size fitment
criterion. This indicates strongly that this difference is unlikely to cause an issue
regarding regulatory equivalence.

 Dynamic test: EU has a dynamic sled test whereas US does not. However, it
should be noted that the front outboard seated positions are tested
dynamically as part of FMVSS 208 in the US. Therefore, there is only a
possible issue for the rear and front inboard seat positions. However, the test
is related mainly to the strength of the restraint system. The US has higher
strength requirements for seatbelt attachments.

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 This is not likely to be an issue because, as mentioned above, the US has higher
strength requirements for seatbelt attachments. Stakeholders consulted agreed that
this is not likely to be an issue regarding regulatory equivalence because all their
vehicles would meet both EU and US requirements.

6.3.6 BUMPER

 The US has mandatory requirements for the bumper to minimise vehicle

damage in low speed impacts, whereas the EU does not.

Consultation with vehicle manufacturers revealed that the main real-world issue
regarding the mandatory low speed bumper impact requirements in the US is the conflict
with the pedestrian leg impact requirements in the EU (see Section 10 below). Explained
simply, a stiff bumper, which is not damaged easily, is required to meet the bumper
impact requirements whereas a soft bumper which deforms easily is required to ensure
impact loads are low enough to meet the pedestrian leg impact requirements in EC
78/2009 and EC 631/2009. Because there is no legislation for pedestrian impact
protection in the US, cars sold in the US have a bumper system that meets the US low
speed bumper requirements and not the EU pedestrian leg impact requirements and vice-
versa for cars sold in the EU. This is even the case for ‘world’ cars sold in both regions.
The reason for this is that although it is possible to design a bumper system to meet both
requirements, it would cost significantly more and most likely involve an increase in the
frontal length of the vehicle, which is undesirable from a packaging point of view.

6.3.7 INFLUENCE OF EU FRONTAL OFFSET DEFORMABLE BARRIER TEST ON OTHER

CRASH CONFIGURATIONS

It is worthwhile noting the influence of the frontal offset deformable (ODB) test on the
design of the car for other crash configurations, in particular side impact and rollover.

In order to meet legislative requirements in the EU and obtain good ratings in Euro
NCAP and IIHS tests, good occupant compartment integrity is required. This includes
features such as:

 A strong side structure including well-designed, strong door beams that can
transfer frontal impact loads across the door aperture. Stakeholders indicated that
as a rule of thumb, for a small car, a door beam sufficient to offer good
performance in the Euro NCAP ODB test, will also be sufficient to meet the US
door crush resistance test requirements.
 A strong side structure including a well-designed strong cant rail that can transfer
frontal impact loads along the side of the car. Stakeholders indicated that as a rule
of thumb, for a small (short) car, a cant rail sufficient to offer good performance
in the Euro NCAP ODB test, will also be sufficient to meet the US FMVSS 216a
roof crush requirements.

The above illustrates the intricate nature of the interaction between the large array of
legislative and consumer crashworthiness requirements and that they cannot be
considered in isolation, not even for a particular impact configuration.

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7. SIDE IMPACT

7.1 COMPARISON OF EU REGULATIONS AND US STANDARDS

This section of the report compares the EU and US legislative requirements relevant to
occupant protection in a lateral impact. An overview of the main areas and regulations is
shown in Table 26, with a more detailed breakdown in Table 27. Each legislation type is
reviewed in sub-section 7.1.2 to 7.1.6; each sub-section begins with background
information briefly describing the history of EU and US side impact legislation and then
summarises the variations between the legislative requirements in the two regions,
including the likely real-world implications of these differences in accidents. FMVSS
226 ‘Ejection Mitigation’ is also relevant to occupant outcomes in a side impact, and has
been reviewed in Section 8.

Table 26: Overview of the main areas of legislation relevant to occupant protection in a
side impact

Item / Test Europe USA

1 Side impact barrier test R95 FMVSS 214, 301
2 Side impact pole test None‡ FMVSS 214, 301
3 Interior fittings / impact R21 FMVSS 201
4 Door locks and latches R11, GTR 1 FMVSS 206, GTR 1
5 Door crush resistance None FMVSS 214
‡
NB: GTR 14 on pole side impact was established in the Global Registry 13 November 2013, but
has not been made compulsory in the EU or US to date

Table 27: Regulatory Acts and Federal Standards that specify side impact related
requirements for the EU and the US, respectively

No. Item EU USA

Regulatory Description Federal Description
Act (Framework Standard
Directive)
1 Side impact UN Reg 95 54A: Protection FMVSS 214 Side impact
barrier crash of occupants in protection
tests the event of a
lateral collision
FMVSS 301 Fuel system
integrity
FMVSS 303 Fuel system
integrity
compressed
natural gas
vehicles

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No. Item EU USA
Regulatory Description Federal Description
Act (Framework Standard
Directive)
FMVSS 305 Electric
powered
vehicles:
electrolyte
spillage and
electrical shock
protection
2 Side impact None FMVSS 214 Side impact
pole crash protection
tests
GTR 14 Pole side impact GTR 14 Pole side impact
GTR developed GTR developed
but yet but not adopted
implemented
3 Interior UN Reg 21 12A: Interior FMVSS 201 Occupant
fittings / fittings protection in
impact interior impact
4 Door locks UN Reg 11 6B: Door latches FMVSS 206 Door locks and
and latches and door door retention
retention components
components
GTR 1 Door locks GTR 1 Door locks
5 Door crush None None FMVSS 214 Side impact
resistance protection

7.1.1 BACKGROUND

7.1.2 SIDE IMPACT BARRIER CRASH TESTS

7.1.2.1 BACKGROUND

EU

The side impact mobile deformable barrier (MDB) test procedure and associated
performance requirements using in UN Regulation 94 were developed in the late 1980s
and 1990s by EEVC WG13. The regulation was adopted by the Council and the
Parliament of the EC in May 1996 (Henssler, 1998) as Directive 96/27/EC; it became
mandatory for new types of cars from 1 October 1998 and for all new cars from
1 October 2003.

US

A dynamic side impact MDB test has been required by FMVSS 214 since 1994. The test
primarily provides protection for the thorax and pelvis (Parker, 1994).

For easy reference Figure 68 shows a summary of the timeline for the introduction of
full-scale side impact (MDB and pole) tests.

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 FMVSS 214
FMVSS 214 NHTSA FMVSS 201
NHTSA to MDB test to NHTSA FMVSS 214
include include most NHTSA permit adoption of
dynamic light trucks crabbed deployable IIHS begins oblique pole
(MDB) side (GVWR impact upper interior side impact side impact
impact test ≤2722 kg) testing protection testing test

1990 1995 1996 1997 1998 2001 2002 2003 2010 2015

EC 96/27/EU Euro NCAP Euro NCAP Introduction Euro NCAP Euro NCAP
R95 Lateral introduced introduces of Advanced adopts changes to
Impact (side, front pole side 2000 barrier AE-MDB oblique pole
adopted by EU and impact face to R95 barrier face side impact
pedestrian
impacts)

Figure 68 Timeline for the introduction of full-scale side impact (MDB and pole) tests

7.1.2.2 COMPARISON OF THE LEGISLATION

This section compares the EU and US requirements for side impact crash tests.

Scope

EU: Behaviour of the structure of the passenger compartment of M1 (passenger cars,

maximum 9 seating positions including the driver) and N1 (goods vehicles, maximum
mass 3,500 kg) categories of vehicles where the R-point of the lowest seat is not more
than 700 mm from ground level when the vehicle is in the condition corresponding to the
reference mass.

US: Passenger cars, multipurpose passenger vehicles and trucks with Gross Vehicle
Weight Rating ≤ 2,722 kg (6000 lb).

Test configurations

The crash tests for each region are depicted in Table 28 below. The EU has a side impact
MDB test at a 50 km/h impact speed, whereas the US has a crabbed side impact MDB
test at 53 km/h impact speed.

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 Table 28: Comparison of EU and US side barrier impact test configurations

No. EU USA

Movable Deformable Barrier (MDB) side impact

1

Impactor 90˚ to vehicle Impactor crabbed at 63˚ to vehicle

50M Driver 50M Driver, 5F Passenger

Driver’s seat: mid, mid Driver’s seat: mid, lowest

Reference: Reference:
Speed - R95, Annex 4, 3 Speed - F214, S7
Angle - R95, Annex 4, 2.3 Angle - F214, S8.10

NB: In the EU the Type Approval Authority can opt to test on the side opposite the
driver’s seat if they consider that the structure of the vehicle may make this side perform
less favourably. Furthermore, the Technical Service may require the test to be conducted
with the seat in a different fore-aft adjustment position.

The R.95 MDB uses a 500 x 500 x 1500 mm (h x d x w) aluminium honeycomb barrier
face attached to a wheeled trolley with a combined mass of 950±20 kg. The
trolley/barrier combination simulates a typical European car at the time that the
regulation was developed, which was relatively small and light. The MDB impacts the
side of the car at 90° to the longitudinal axis of the car.

FMVSS 214 uses a 559 x 483 x 1676 mm (h x d x w) aluminium honeycomb barrier face
attached to a wheeled trolley with a combined mass of 1368 kg. The wheels of the trolley
are set at an angle such that the MDB impacts the car at 63° to the longitudinal axis of
the car, as depicted in Table 28. The crabbed impact stance in the US regulation is used
to simulate both vehicles moving, to represent for example an RTA at an intersection.
This tends to force the test vehicle back slightly, applying different force values to the
dummies when compared to the EU regulation. In theory, the US regulation should
favour certain forces over others, such as forward movement of the dummies as well as
sideways movement.

Figure 69 shows a comparison of the R95 and F214 barrier faces relative to ground level.

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 Figure 69 Overlay comparison of EU and FMVSS 214 barrier faces

The US barrier face is slightly larger in size and both barrier faces are mounted at a
similar height. Both have lower “bumper” sections, with the larger section of the US spec
impactor has a uniform crush resistance of 0.342 MPa, and the bumper section having a
uniform crush resistance of 1.711 MPa. The EU barrier has six zones, all of which have
varying resistance to crush pressure, defined by pressure/deflection corridors defined in
the regulation (an example of which is shown in Figure 70).

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 Figure 70 Impact corridor for one section
of EU R95 impactor

The kinetic energy of the MDBs can be seen in Table 29 below. It can be seen that the
energy the US trolley has is significantly larger than its EU counterpart, due to the
difference in trolley mass. Nominally, this means that the US barrier could intrude further
into the passenger compartment, as well as apply higher forces to the dummy occupants –
although this also depends on the stiffness of the barrier face and the degree of
engagement with vehicle structures such as the sill.
Table 29: Comparison of EU and US side barrier impact energies

Regulation Trolley Energy

EU (950 kg at 50 km/h) 92 kJ
US FMVSS (1368 kg at 53 km/h @ 63˚ 148 kJ
(47 km/h @ 90˚))

7.1.2.3 DUMMIES, PERFORMANCE CRITERIA AND LIMITS

The dummy used in the driver’s seat in the EU and US tests is very similar: a variant of
the ES-2 dummy in both cases. The US variant has modifications to the rib structure to
ensure that the seat foam/cover cannot penetrate between the ribs and the spine, which
may artificially limit the chest deflection recorded by the dummy. NB: up until
1 September 2010, FMVSS 214 used the 49 CFR Part 572 Subpart F dummy, known as
SID in the front and rear outboard seating positions. Between 1 September 2010 and
31 August 2014, a proportion of the manufacturer’s production could be certified using
the SID dummy, while an increasing proportion had to meet the ES-2re requirements.
With the SID dummy, performance requirements are only defined for the thorax and
pelvis body regions, whereas for the ES-2 there are requirements for the head, thorax,
abdomen and pelvis.

The seating position for the driver dummy in the EU is mid-position fore-aft, and mid-
position for the height adjustment, although – as noted above – the Technical Service
may choose to test with the seat in any fore-aft position. The US regulation states mid-
position fore-aft and the lowest position for height. Also, the US regulation states in
detail other seat adjustments such as lumbar and separate cushion positions; in the EU
these are set to the manufacturer’s recommended position. However, the seat back angle
for both regulations is the same, at the manufacturer’s stated position, or 25˚. The
adjustment likely to have most effect in tests is the lower seat height specified by the US
regulation. This position will result in each part of the dummy being exposed to a
130
different interaction with the MDB, door and airbags when compared with the EU
regulation, which may affect the test results and the mitigation employed by the vehicle
manufacturer.

The performance criteria and limits for the EU and US MDB tests are shown in Annex 3,
Table 61. The performance criteria for the dummies are very similar, with a notable
difference being the ‘soft tissue criterion’ (viscous criterion, VC) in the EU regulation,
which is not used in the US regulation. The use of this metric in the EU regulation is
intended to reduce the risk of soft tissue injuries such as lung contusions. Also, the US
regulation allows 2 mm more rib deflection than the EU regulation (44 mm and 42 mm
respectively). Both US and EU regulations use a head injury metric (HPC or HIC) with a
limit of 1000; the criterion is calculated identically in both, but the maximum time
duration for the calculation is different, meaning that the EU requirement may be more
stringent in some cases. The regulations also share peak abdominal force limits of
2500 N and peak pubic symphysis forces of 6000 N. Nevertheless, the greater
compliance margin typically targeted by manufacturers for the US requirements may
mean that the US requirements are in effect slightly more stringent.

A major difference between the regulations is the use of a 5F dummy as a struck-side

rear seat passenger within the US regulation. This may provide encouragement for
curtain airbags (because seat-mounted side airbags are not usually used in rear seating
positions) and curtain airbags that offer protection lower down the side of the vehicle
(because the head of the 5F is lower than the head of the 50M and therefore more
exposed to the MDB, although it should be noted that the R-point of rear seats is often
higher than that of front seats).

It is also worth noting that the tolerances on the dummy soak temperatures in the EU
regulation allow a greater temperature range of 8°C (18˚C to 26˚C), whereas the range
allowed by the US regulation is 1.6˚C (20.6˚C to 22.2°C). Crash test dummies are
particularly sensitive to ambient temperature, so a large change in temperature may affect
the performance requirements measured in the test. The US temperature range is
approximately central to the EU range, so there would be no issue with the temperature
of a test performed in the US, but the converse may not be true.

The EU legislation requires that no door shall open during the test, whereas the US
legislation only applies this requirement to non-struck doors. Therefore, there may be a
greater risk of occupant ejection or partial ejection in the US should any second impact
occur. The EU legislation also has numerous requirements for the pre- and post-crash
performance of any automatic door locks that may be fitted, whereas F214 has no
specific requirements.

7.1.2.4 ELECTRIC VEHICLES

Regulations have been made to allow compliance of electric or hybrid vehicles in side
impact crashes. Across the EU and US regulations, the specification is mainly the same.
The most notable difference between the regulations is the presence of a “finger test” in
the EU regulation, to make sure post-crash that no exposed electrically conducting
components can be touched or reached by occupant’s fingers. For further detail on the
comparison, see Annex 3, Table 61.

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7.1.2.5 DISCUSSION

The differing factor with most influence over the vehicle crash test is the MDB and
trolley. It is clear to see that the US trolley will impact the vehicle with more force due to
the mass, and create a different dynamic situation to that of the EU trolley, due to the
crabbing. The slightly larger barrier in F214 may equate to a larger area of the occupant
compartment being deformed; however, the increased surface area of the barrier may also
dissipate energy better, spreading the load over more of the test vehicle’s side, reducing
impact intrusion. The US impactor has a bumper section which is far stiffer than the
section it is mounted on, and has a narrower height than the EU equivalent. This could
concentrate force more to the lower section of the vehicle, but as the barriers are of
similar heights, much of the force of impact on both barrier tests will be
absorbed/distributed by the vehicle’s sill structure.

There is no assessment for rear seated occupants in the MDB EU regulation. It should be
noted however that two child dummies, (Q1.5 and Q3) are used in the Euro NCAP tests,
further discussed in Section 7.2.3.

7.1.2.6 SUMMARY OF MAIN NOTABLE DIFFERENCES

Notable differences:
 Markedly higher impact energy in F214 cf. R95 (148 kJ cf. 98 kJ), primarily
due to the much higher MDB mass in the US legislation cf. the EU (1368 kg
cf. 950 kg)
 Crabbed (63°) MDB impact trajectory in the US cf. 90° in the EU test
 Assessment of smaller (5F) rear seat occupant protection in F214; none in
R95
 Larger MDB in F214 (though by a small margin)
 Different structure to MDB (honeycomb, aluminium type etc.) resulting in
different stiffness and stiffness distribution
 Door opening requirements more stringent in the EU (no door may open
during the test) than the US (no non-struck door may open)
 Numerous automatic door lock requirements are specified in the EU and none
in the US
 Driver’s seat at mid-height in EU; at lowest adjustable height in US
 1.6°C temperature range for the dummies in the US; 8°C temperature range
for the dummy in the EU

7.1.3 SIDE IMPACT POLE CRASH TESTS

7.1.3.1 BACKGROUND

EU

The EU does not currently have any pole side impact crash test legislation, although it is
expected that UN Regulation No. 135, implementing GTR-14, will soon be applied in the
EU. It is also worth noting that a lateral pole side impact test has been conducted by Euro
NCAP since 2000; for earlier phases of Euro NCAP the test was performed only on

132
vehicles that had a side head protection device (typically a side airbag) and that were s
rated as green in the Euro NCAP side impact test.

US

FMVSS 214 has included an oblique pole side impact test procedure since 2010.

7.1.3.2 COMPARISON OF THE LEGISLATION

This section compares the EU and US requirements for side impact crash tests.

Scope

EU: N/A

US: Passenger cars, multipurpose passenger vehicles and trucks with Gross Vehicle
Weight Rating ≤ 3,856 kg (8,500 lb) or unloaded vehicle weight ≤ 2,722 kg (6000 lb).

Test configurations

FMVSS 214 in the US specifies an oblique pole side impact test with either a 50M front
seat occupant or a 5F front seat occupant – either dummy and either outboard seating
position can be used at the regulator’s discretion. Currently, there is no pole side impact
test specified for the EU (see Table 30), but GTR-14 is likely to be published soon as UN
Regulation 135.

Table 30: Comparison of EU and US side pole impact test configurations

No. EU USA

Pole Side Impact

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No. EU USA

1 None

Vehicle speed applied at 75˚ to normal

0-32 km/h (26-32 km/h during phase-in)

50M or 5F driver or FSP

Driver’s seat: mid, lowest

Reference:
Speed - F214 S9.1.2
Angle - F214 S10.11/S10.12.2

GTR-14 adopts the WorldSID 50M dummy in the front seating position and explicitly
mentions a second phase in which a WorldSID 5F dummy could be considered. In the
meantime, the text of the regulation allows that Contracting Parties may continue to
apply any pre-existing domestic pole side impact requirements using a 5F side impact
dummy, e.g. FMVSS 214, to ensure that local safety standards are not degraded. It is
further noted that the US abstained from voting on GTR-14, and will, for the moment,
not implement the GTR.

7.1.3.3 DISCUSSION

Currently, therefore, the legislative comparison is very straightforward, with legislative

requirements defined in the US and none defined in the EU. If GTR-14 is implemented in
both regions then some aspects of pole side impact safety legislation will be harmonised,
i.e. for an average size male driver; however, the GTR will allow Contracting Parties to
continue to apply any pre-existing domestic pole side impact requirements using a small
female dummy (e.g. FMVSS 214 in the US) and may restrict the mass range of vehicles
that the GTR is applied to if it decides that such restriction is appropriate. Neither
allowance presents any difficulty for implementation of GTR-14 in either the EU or the
US, but may require further consideration if mutual recognition of the implementation of
the GTR is considered.

Summary of main notable differences

Notable differences:
 Pole side impact test defined in the US; none defined in EU legislation
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NB: It is likely that GTR-14 will be adopted in the EU (as R135) in the near future:

 GTR-14 explicitly allows options for continued testing with a 5F dummy in

regions that already incorporate this in their legislation, as well as restriction of
the mass range of vehicle to which the GTR applies, so may not represent full
harmonisation even if implemented in both regions

7.1.4 INTERIOR FITTINGS / IMPACT

7.1.4.1 BACKGROUND

EU

UN Regulation No. 21 describes tests and requirements that control the stiffness and
shape of interior components of the vehicle, in order to minimise the risk of injury arising
from contact with these components in a collision. Generally, the regulation applies only
to those components that could be contacted by an adult head (represented by a sphere
with a diameter of 165 mm).

US

FMVSS 201 employs a very similar test to similar interior structures, except the roof and
the roof support pillars which are tested using a free-motion headform (essentially a head
from a crash test dummy head projected at the target location on the vehicle). The
requirements supplement the thorax and pelvis protection developed in FMVSS 214 to
(at least partially) address head protection (Samaha and Elliott, 2005).

The EEVC status report at the 1994 ESV conference indicated that the EEVC was
concerned that the MDB test (see Section 7.1.2) would only evaluate one head contact
location, while accident data indicated the importance of head injuries with the vehicle
interior at many locations in side impacts (Friedel, 1998); therefore, the need for a
supplementary sub-system head impact test was identified. Considerable work was
undertaken by the EEVC to develop a free-motion interior headform test procedure
similar to that used in FMVSS 201 (see e.g. (Roberts et al., 1996)), but it was concluded
that the procedure was not suitable for application in regulation and the work was
stopped (Cesari, 2011).

7.1.4.2 COMPARISON OF THE LEGISLATION

Scope

EU: R21 applies to the interior fittings of vehicles of category M1 with regard to the
interior parts of the passenger compartment other than the rear-view mirror or mirrors;
the arrangement of the controls; the roof or opening roof, and the seat-back and the rear
parts of seats (the latter also covered under R17). R21 also regulates the power operation
of windows, roof panels and partition system, but this is not directly relevant to impact
performance (side, front or rollover) and has not been reviewed further herein.

US: FMVSS 201 applies to passenger cars, multipurpose passenger vehicles and trucks
with a Gross Vehicle Weight Rating ≤ 4,536 kg (with some exclusions for buses with a
GVWR > 3860 kg).

Test configurations
135
An overview of the EU and US interior fittings/impact legislation is given in Table 28
and a detailed comparison of the interior fittings legislation can be found in Annex 3,
Table 64.

Table 31: Comparison of EU and US interior fittings/impact legislation

No. EU (R21) USA (FMVSS 201)

Dangerous Roughness or Sharp Edges

1 Radii of 2.5 – 3.2. mm specified for all No requirements defined
contactable interior fittings. No
dangerous roughness or sharp edges
permitted after headform impact test.
Items that project between 3.2 and 9.5
mm shall have a cross-sectional area
≥2cm2 and rounded edges (min. radius
2.5 mm)
Items that project >9.5 mm shall retract
or detach when a 378 N force is applied
Some detailed specifications apply, e
g. for window winders and handbrake
levers
Guided Impactor Energy Dissipation Tests
2 24.1 km/h; 19.3 km/h if area protected 24 km/h; 19 km/h if area protected by
by an airbag an airbag
Identical head impact location fixture
Same headform diameter and mass;
Headform attached to a rigid pendulum Headform attached to a linear impactor,
or equivalent test procedure rigid pendulum or equivalent test
procedure
Same performance requirement metric (3 ms exceedence of 80 g)
Similar intent to the areas excluded (i.e. those that would not be contacted by the
headform statically; glazing)
Includes roof Does not include roof – tested with
free-motion headform as below
Excludes A-pillar and may exclude See free-motion headform tests
rearmost pillar
Free-motion Upper Interior Headform Tests
3 No requirement Free-motion headform or free-motion
headform to dynamically deployed
upper interior head protection system
[e.g. airbag] (at the manufacturer’s
option)

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No. EU (R21) USA (FMVSS 201)
Adds A-pillar, C/D-pillar (which may
not be tested in R21, depending on the
rear seat positon and inclination

FMVSS 201 applies to a wider range of vehicles than R21, including trucks and buses
with a GVWR ≤ 4,536 kg; R21 applies only to M1 vehicles.

The EU legislation incorporates requirements on the stiffness, sharpness or break-away

force for projections, which are not required in the US legislation.

The EU and US guided impactor tests use very similar test equipment and have identical
‘energy dissipation’ performance requirements. The areas tested are, however, somewhat
different as shown in Annex 3, Table 64, although the intent would seem to be similar.
The biggest differences are that the A-pillar is exempted in the EU test and the ‘upper
zones’ (roof etc.) are tested using a separate interior headform test in the US (part 3 of
Table 31 above). Furthermore, the ‘reference zone’ in which tests are conducted under
R21 can, at the choice of the manufacturer, optionally be defined based on vehicle crash
tests, sled tests or numerical simulation at multiple impact angles and with multiple sizes
of occupant (5F, 50M and 95M).

The exemption of the A-pillars within the EU legislation could have a significant effect
on the injury risk in low-overlap, oblique frontal impacts, particularly an elevated risk of
head injury for front row occupants. However, the US is developing a new low-overlap
oblique frontal full-scale crash test using the THOR dummy, in part to reduce the risk of
head injury which may imply that the interior headform test has not been sufficient to
mitigate this risk adequately.

For the roof and pillars, the US regulation contains a free-motion headform test, where
by a dummy head is fired at a determined angle into selected points on the interior. The
impact velocity is similar to the guided impactor tests (any speed up to 24 km/h, or 19
km/h when in an area of a deployed airbag (during the test the airbag is not deployed),
but the headform mass is lower at 4.54 kg. HIC36(d) with a limit of 1000 is employed as a
performance requirement and a total of 33 target locations are tested.

Summary of main notable differences

Notable differences:
 EU requirements apply only to M1 vehicles; US requirements apply to wider
range of vehicles (comparable vehicles plus trucks and buses with a GVWR ≤
4,536 kg)

 EU has specific requirements on radii and break-away forces for controls and
other projections; US does not.
o Sharp edges can cause disfiguring lacerations or acute blood loss, but
may not be adequately controlled by the headform impactor tests
employed in FMVSS 201
 Very similar energy dissipation tests below roof/pillar level with identical
performance requirements, but with some differences in the structures tested

137
 o A-pillars and (for some vehicles) rearmost pillars excluded in EU
o EU allows alternative methods for identifying potential head contact
test zones; these methods are not allowed in the US
o Lots of detailed differences in how the test regions are defined, but the
intent seems similar
 EU tests the roof and some pillars using the same energy dissipation test as
for other structures; the US uses a completely different free-motion headform
test for these structures

7.1.5 DOOR LOCKS AND LATCHES

7.1.5.1 BACKGROUND

Reg 11/FMVSS 206/GTR 1

EU

The EU defines requirements for door locks, latches and hinges (i.e. door retention
components) in UN Regulation No. 11. The legislation is intended to ensure that doors
do not open in a collision, thereby preventing full or partial ejection of the occupant,
because ejection carries a very high risk of fatal injury. The legislation also defines
requirements that ensure that doors locked by an automatic locking system will be
unlocked after a crash to allow egress from the vehicle.

US

The US defines very similar requirements and test procedures.

7.1.5.2 COMPARISON OF THE LEGISLATION

A summary of the side by side comparisons can be seen in Annex 3, Table 63. Both sets
of legislation are very similar, with essentially identical test procedures and requirements
in most cases. An exception is that child safety locks, which prevent children from
opening the door from the inside of the vehicle, may be used on rear doors under R11,
whereas these are not permitted in FMVSS 206 (see also Docket No. NHTSA–2006–
23882). The US legislation is more specific for testing and compliance of rear doors.

It is worth noting that GTR-1 for door locks and latches shares the same test limits for
door force loading and direction, for hinges as well as latches in both primary and
secondary positions. Also, the inertial load limits of 30 g are the same in all plane
directions.

Summary of main notable differences

Notable differences:
 Child safety locks (to prevent children from opening rear side doors) explicitly
permitted under EU legislation; not permitted under FMVSS 206

138
7.1.6 DOOR CRUSH RESISTANCE

7.1.6.1 BACKGROUND

EU

No requirements defined.

US

The first version of FMVSS 214, issued in 1970, set strength requirements for passenger
car side doors based on a static test of crush resistance. The test gradually forces a rigid
steel cylinder into the door, and a minimum resistance force must be met at various
depths of crush. The test built on work on door beams and static test procedures at GM in
the 1960s, and all US cars were equipped with compliant side door beams by the end of
model year 1973 (Kahane, 2007). The door beams mandated by FMVSS 214 were
intended to minimise the danger caused by intrusion into the occupant compartment and
were found to be effective in single-vehicle side impacts, particularly those with a single
fixed object, where the beams help to deflect the car past the object without excessive
intrusion into the occupant compartment (Kahane, 1982). NHTSA extended the door
crush resistance requirements to LTVs in 1993.

7.1.6.2 COMPARISON OF THE LEGISLATION

Scope

EU

No requirements defined.

US

The door crush resistance requirements apply to passenger cars, and to multipurpose
passenger vehicles, trucks and buses with a gross vehicle weight rating (GVWR)
≤4,536 kg, except for walk-in vans and doors not adjacent to seats.

Test configurations

The door crush resistance test consists of gradually forcing a steel cylinder of 305 mm
diameter into the door at a rate not exceeding 12.7 mm/s up to a distance of 457 mm. The
top of the cylinder must be at least 13 mm above the bottom edge of the window opening,
but not overlapping any structures above this level, and 127 mm above the bottom of the
door, i.e. the cylinder shall load only the door and not any structural elements of the rest
of the vehicle.

At the manufacturer’s option, the test can be performed in one of two ways: with the
seats removed or with the seats in-situ. The requirements for each option are shown
below:

With seats removed, the cylinder must encounter a resistance:

 Averaging at least 10,000 N during the first 152 mm of crush

 Averaging at least 15.569 N during the first 305 mm, and

139
  Reaching a peak of at least 31,138 N or twice the vehicle’s curb weight
(whichever is less) at some point during the first 457 mm of crush.
With seats installed in the vehicle, the cylinder must encounter a resistance

 Averaging at least 10,000 N during the first 152 mm of crush

 Averaging at least 19,460 N during the first 305 mm, and
 Reaching a peak of at least 53,378 N or 3.5 times the vehicle’s curb weight
(whichever is less) at some point during the first 457 mm of crush

7.1.6.3 DISCUSSION

Quasi-static door crush resistance requirements were first implemented in FMVSS 214
45 years ago in order to encourage manufacturers to fit door beams or other mechanisms
to reduce intrusion in a side impact. Door beams have been reported to be most effective
in single-vehicle side-swipe type collisions, where the vehicle is deflected away from a
fixed object without excessive intrusion (Kahane, 1982). Given that barrier side impact
and pole side impact tests have subsequently been introduced to FMVSS 214 in order to
further improve side collision safety, it may be argued that the door crush resistance
requirements have been superseded and are no longer necessary. However, the pole side
impact test, which is the most severe of the newer tests, is only performed at one location
on the vehicle, and the door crush resistance requirements – which are applied to all
doors (with exclusions) – may ensure at least a minimum performance for doors that are
not loaded in the dynamic full-scale crash tests.

7.1.6.4 SUMMARY OF MAIN NOTABLE DIFFERENCES

Notable differences:
 Quasi-static door crush resistance requirements defined in the US; no specific
requirements in the EU

7.1.7 SUMMARY OF MAIN NOTABLE DIFFERENCES

Barrier side impact test:

 Markedly higher impact energy in F214 cf. R95 (148 kJ cf. 98 kJ), primarily
due to the much higher MDB mass in the US legislation cf. the EU (1368 kg
cf. 950 kg)
 Crabbed (63°) MDB impact trajectory in the US cf. 90° in the EU test
 Assessment of smaller (5F) rear seat occupant protection in F214; none in
R95
 Larger MDB in F214 (though by a small margin)
 Different structure to MDB (honeycomb, aluminium type etc.) resulting in
different stiffness and stiffness distribution
 Door opening requirements more stringent in the EU (no door may open
during the test) than the US (no non-struck door may open)
 Numerous automatic door lock requirements are specified in the EU and none
in the US

140
  Driver’s seat at mid-height in EU; at lowest adjustable height in US
 1.6°C temperature range for the dummies in the US; 8°C temperature range
for the dummy in the EU
Pole side impact tests:
 Pole side impact test defined in the US; none defined in EU legislation

NB: It is likely that GTR-14 will be adopted in the EU (as R135) in the near future:

 GTR-14 explicitly allows options for continued testing with a 5F dummy in

regions that already incorporate this in their legislation, as well as restriction of
the mass range of vehicle to which the GTR applies, so may not represent full
harmonisation even if implemented in both regions

Interior fittings/impact:
 EU requirements apply only to M1 vehicles; US requirements apply to wider
range of vehicles (comparable vehicles plus trucks and buses with a GVWR ≤
4,536 kg)

 EU has specific requirements on radii and break-away forces for controls and
other projections; US does not.
o Sharp edges can cause disfiguring lacerations or acute blood loss, but
may not be adequately controlled by the headform impactor tests
employed in FMVSS 201
 Very similar energy dissipation tests below roof/pillar level with identical
performance requirements, but with some differences in the structures tested
o A-pillars and (for some vehicles) rearmost pillars excluded in EU
o EU allows alternative methods for identifying potential head contact
test zones; these methods are not allowed in the US
o Lots of detailed differences in how the test regions are defined, but the
intent seems similar
 EU tests the roof and some pillars using the same energy dissipation test as
for other structures; the US uses a completely different free-motion headform
test for these structures
Door locks and latches:
 Child safety locks (to prevent children from opening rear side doors) explicitly
permitted under EU legislation; not mentioned under FMVSS 206

Door crush resistance

 Quasi-static door crush resistance requirements defined in the US; no specific
requirements in the EU

An overview of the notable differences in the legislative side impact requirements is

shown in Figure 71:

141
 Side Impact

Barrier Interior Ejection

Door Latches Door Crush Pole Impact
Impact Impact Mitigation

EU US US EU US US EU US US

Very similar Barrier Barrier Energy Energy

requirements 9.2 kJ 14.8 kJ Dissipation Dissipation
50 km/h 53 km/h Front Instrument
Would be aligned 950 kg 1368 kg compartment panel, seat
under GTR 14 Rear backs, interior
Impact Impact compartment compartment
Perpendicular Crabbed Roof doors, sun
(90°) (63°) visors and
armrests
Occupant Occupant
Driver Driver & RSP Free Motion
Headform
Upper
compartment

Figure 71 Overview of legislative side impact requirements

7.2 CONSUMER INFORMATION TESTING

This section describes frontal impact tests performed in the EU and US to provide safety
information for consumers. A summary of the tests performed is given in Table 21.

The tests are described and compared in the sections below. Also their effects on the
legislation, and in particular the notable differences detailed in the section above are
discussed in terms of:

 Legislative differences that are effectively plugged (filled)

 Effective enhancement of the legislation

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 Table 32: Frontal impact tests for consumer information in the EU and US

Item / Test EU USA

1 Barrier side Euro NCAP (2015-on) – 1300 kg US NCAP – F214 barrier;
impact barrier; 50 km/h 90°; WorldSID 62 km/h 63°; 50M driver; lowest
50M driver, Q1.5 and Q3 RSPs; seat height
mid seat height if both adjustable
Euro NCAP (1999-2014) – IIHS – tall, 1500 kg barrier;
950 kg R95 barrier; 50 km/h 90°; 50 km/h 90°; 5F driver and RSP;
ES/ES-2 50M driver, P/Q1.5 and UMTRI seat position and seating
P/Q3 RSPs; lowest seat height procedure
2 Pole side Euro NCAP (2015-on) – similar US NCAP – F214 pole; 32 km/h
impact pole to F214; 32 km/h 75°; 75°; SID-IIs 5F driver; lowest
WorldSID 50M driver; lowest seat height
seat height
Euro NCAP (1999-2014) –
similar pole to F214; 29 km/h
90°; ES-2 50M driver; lowest seat
height

7.2.1 BARRIER SIDE IMPACT

Side impact MDB tests are performed by Euro NCAP in the EU and by US NCAP and
IIHS in the US. Until January 2015, the Euro NCAP test was essentially identical to the
R95 test, but with reward for better performance on the dummy injury metrics. Similarly,
the US NCAP MDB test is very similar to the F214 test, but is conducted at a speed of
62 km/h (which is 8 km/h greater than the legislative test) and again rewards dummy
metrics that are better than those required by the legislation.

The IIHS uses a heavier MDB with a much taller barrier face with greater ground
clearance, which is intended to be more representative of the popular SUV pick-up
segments of the US fleet. An overlay of the different barrier faces used in the legislative
and consumer information tests in the EU and US is shown in Figure 72. A photograph
of the IIHS and FMVSS 214 barrier faces is shown in Figure 73; it can be seen that the
head and upper torso is much more exposed to the IIHS barrer face than the FMVSS 214
barrier face. The higher ground clearance of the IIHS barrier face means that it is less
likely to engage the sill of the struck vehicle, particularly if the struck vehicle is a
passenger car, which means that the B-pillar and door structures have to resist a
proportionally greater load.

143
 Figure 72 - Overlay of barrier sizes and positions

Figure 73: IIHS (silver) vs FMVSS 214 (yellow) barrier faces

144
The impact energy of the legislative and consumer information tests is shown in Table
61. It can be seen that the impact energy used in US NCAP is more than twice that used
in R95 and, until this year, in Euro NCAP. The IIHS impact energy is more than 50%
greater than the EU tests and the barrier face is less likely to engage the sill of the struck
vehicle. Both of these differences are likely to mean that the side structures of US market
vehicles have to be stronger than those of EU market, and there may also be differences
in the restraint system. This may lead to a reduced intrusion in equivalent car-to-car or
car-to-fixed obstacle collisions in the US cf. the EU.

Table 33: Comparison of EU and US side barrier impact test energies

Test MDB Energy

EU – 50 km/h at 90°; 950 kg 92 kJ
US FMVSS – 53 km/h at 63˚; 1368 kg 148 kJ
Euro NCAP – 50 km/h at 90°; 950 kg 92 kJ
Euro NCAP (2015-on) – 50 km/h at 90°; 1300 kg 126 kJ
US NCAP – 61.9 km/h at 63˚; 1368 kg 202 kJ
IIHS – 50 km/h at 90°; 1500 kg 145 kJ

7.2.1.1 EFFECTS ON LEGISLATIVE NOTABLE DIFFERENCES

The effects of the Euro NCAP and US NCAP barrier side impact tests on the legislative
notable differences are:

 Legislative differences that are plugged

o Euro NCAP uses 1.5- and 3-year-old child dummy occupants on the rear
seats, which encourages improved RSP protection
 Effecitve enhancement of the legislation
o Both US and Euro NCAP encouarage performance significantly better
than that required by regional legislation, by rewarding the achievement of
much lower dummy injury metrics
o US NCAP is performed at a markedly higher impact energy than F214

7.2.2 POLE SIDE IMPACT

The US NCAP pole side impact test is basically the most severe test option from the
FMVSS 214 pole impact velocity range (0-32 km/h). A 5F driver dummy is used (50M
dummy is an option in FMVSS 214); all other key parameters are per F214. Euro NCAP
has also included a pole side impact test for more than 15 years. Up until this year, the
impact energy in the Euro NCAP test was slightly lower than that in the US NCAP test,
but both tests have strongly encouraged the fitment of curtain side airbags. The US
NCAP test uses a 5F driver dummy, which may encourage manufacturers to provide
protection to a lower height than the 50M dummy used in Euro NCAP.

145
7.2.2.1 EFFECTS ON LEGISLATIVE NOTABLE DIFFERENCES

The effects of the Euro NCAP and US NCAP barrier side impact tests on the legislative
notable differences are:

 Legislative differences that are plugged

o The Euro NCAP pole side impact test substantially compensates for the
lack of a legislative pole side impact test in the EU, for the majority of
vehicles in the fleet
 Effecitve enhancement of the legislation
o US NCAP encourages better side impact protection than that required by
F214

7.2.3 SUMMARY OF INFLUENCE OF CONSUMER TESTING ON LEGISLATIVE

DIFFERENCES

The influence of consumer testing on the legislative notable differences listed above are
summarised in this section. This consists of the following two parts:

 Legislative differences that are plugged by consumer tests.

 Legislative enhancements that are driven by consumer tests.

Barrier side impact tests

 Legislative differences that are plugged

o Euro NCAP uses 1.5- and 3-year-old child dummy occupants on the rear
seats, which encourages improved RSP protection
 Effecitve enhancement of the legislation
o Both US and Euro NCAP encouarage performance significantly better
than that required by regional legislation, by rewarding the achievement of
much lower dummy injury metrics
o US NCAP is performed at a markedly higher impact energy than F214

Pole side impact tests

 Legislative differences that are plugged

o The Euro NCAP pole side impact test substantially compensates for the
lack of a legislative pole side impact test in the EU, for the majority of
vehicles in the fleet
 Effecitve enhancement of the legislation
o US NCAP encourages better side impact protection than that required by
F214

146
7.3 DISCUSSION OF REAL-WORLD IMPLICATIONS OF LEGISLATIVE DIFFERENCES

7.3.1 SUMMARY OF LEGISLATIVE DIFFERENCES AND EFFECT OF CONSUMER TESTING

Barrier side impact test:

 Both Euro NCAP and US NCAP encourage car-to-car side impact protection
that is considerably enhanced (in terms of reduced risk of injury in a collision)
compared to that required by the legislation in each region
o Furthermore, the US NCAP is performed at a higher impact severity
than FMVSS 214
 Markedly higher impact energy in F214 cf. R95 (148 kJ cf. 98 kJ), primarily
due to the much higher MDB mass in the US legislation cf. the EU (1368 kg
cf. 950 kg)
o From January 2015 the impact energy in the Euro NCAP will reduce
the gap between the EU and US testing, but will still be greatly below
that used in US NCAP
 Crabbed (63°) MDB impact trajectory in the US cf. 90° in the EU test
 Assessment of smaller (5F) rear seat occupant protection in F214; none in
R95
o Euro NCAP uses 1.5- and 3-year-old child dummy occupants on the
rear seats, which encourages improved RSP protection in the EU
 Larger MDB in F214 (though by a small margin)
 Different structure to MDB (honeycomb, aluminium type etc.) resulting in
different stiffness and stiffness distribution
 Door opening requirements more stringent in the EU (no door may open
during the test) than the US (no non-struck door may open)
 Numerous automatic door lock requirements are specified in the EU and none
in the US
 Driver’s seat at mid-height in EU; at lowest adjustable height in US
 1.6°C temperature range for the dummies in the US; 8°C temperature range
for the dummy in the EU
Pole side impact tests:
 Pole side impact test defined in the US; none defined in EU legislation
o However, Euro NCAP has included pole side impact tests for many years,
which substantially fills this gap for the majority of the vehicles in the
fleet
o US NCAP encourages better side impact protection than that required by
FMVSS 214
NB: It is likely that GTR-14 will be adopted in the EU (as R135) in the near future:

 GTR-14 explicitly allows options for continued testing with a 5F dummy in

regions that already incorporate this in their legislation, as well as restriction of
the mass range of vehicle to which the GTR applies, so may not represent full
harmonisation even if implemented in both regions
Interior fittings/impact:
147
  EU requirements apply only to M1 vehicles; US requirements apply to wider
range of vehicles (comparable vehicles plus trucks and buses with a GVWR ≤
4,536 kg)

 EU has specific requirements on radii and break-away forces for controls and
other projections; US does not.
o Sharp edges can cause disfiguring lacerations or acute blood loss, but
may not be adequately controlled by the headform impactor tests
employed in FMVSS 201
 Very similar energy dissipation tests below roof/pillar level with identical
performance requirements, but with some differences in the structures tested
o A-pillars and (for some vehicles) rearmost pillars excluded in EU
o EU allows alternative methods for identifying potential head contact
test zones; these methods are not allowed in the US
o Lots of detailed differences in how the test regions are defined, but the
intent seems similar
 EU tests the roof and some pillars using the same energy dissipation test as
for other structures; the US uses a completely different free-motion headform
test for these structures
Door locks and latches:
 Child safety locks (to prevent children from opening rear side doors) explicitly
permitted under EU legislation; not mentioned under FMVSS 206
Door crush resistance
 Quasi-static door crush resistance requirements defined in the US; no specific
requirements in the EU

7.3.2 LITERATURE REVIEW AND ACCIDENT ANALYSIS

The following research questions were identified as being best answered by the accident
analysis being undertaken in the study, rather than by literature review, because few
source were identified that directly compared outcomes in the EU and US:

RQ3: Do occupants in side impact passenger car collisions [S], occurring in the EU
and US [D], experience any difference in injury severity [O]?
RQ4: Do occupants in side impact passenger car collisions [S], occurring in the EU
and US [D], experience any difference in injury severity from intrusion of/by
the struck object into the occupant compartment [O]?
RQ5: In side impact passenger car collisions [S], do EU and US occupants [D]
experience any difference in head injury severity [O]?
RQ6: In side impact passenger car collisions [S], do small stature EU and US front
seat occupants [D] experience any difference in injury severity [O]?
RQ7: In side impact passenger car collisions [S], do rear seat occupants in the EU
and US [D] experience any difference in injury severity [O]?
Evidence related to the remaining research questions was sought via the literature review:

RQ8: In the vehicle fleet [S], does the FMVSS 214 crabbed MDB impact [D] lead to
different occupant protection strategies or outcomes [O]?

148
 RQ9: In side impact passenger car tests [S], does impact trolley mass or velocity [D]
lead to a significant difference in dummy measurements or other assessment of
car safety [O]?
RQ10: In a side impact passenger car test [S], does the stiffer bumper beam in the US
MDB cf. the EU MDB [D] cause a greater intrusion into the occupant
compartment of the struck vehicle [O]?
RQ11: In a side impact passenger car test [S], does the higher barrier face in the EU
MDB cf. the US MDB [D] cause a greater intrusion into the occupant
compartment of the struck vehicle [O]?
RQ12: In the vehicle fleet [S], does the FMVSS 214 door crush resistance test cf. no
push test in the EU [D] lead to a greater incidence or higher specification of
door beams [O]?
RQ13: In side impact occupant protection for passenger cars [S], has legislation or a
change in regulatory requirements [D] led to the introduction of any new side
impact protection technologies [O]?

7.3.2.1 LITERATURE REVIEW - INCLUDED ARTICLES

Number of articles identified Number of articles identified

through database searching through other sources
(n=517) (n=78)
Number of articles identified Number of articles identified
through database searching
(n=426)
Number of full text articles Excluded articles (n=42):
assessed for eligibility Failed to meet selection criteria: 10
(n=47) Not highly relevant to RQ: 32
Low quality methodology: 0

Number of studies included

for evidence evaluation
(n=5)

RQ7 RQ9 RQ11

(n=4) (n=4) (n=1)

RQ6 RQ8 RQ10

(n=4) (n=4) (n=0)

Figure 74: Flow diagram for the side impact literature review

7.3.2.2 INFORMATION FROM ACCIDENT ANALYSIS

To date, data is only available for the UK and US. The injury data for these two regions
relevant to RQ1-5 is shown below:

RQ1: Do occupants in side impact passenger car collisions [S], occurring in the EU
and US [D], experience any difference in injury severity [O]?

149
Figure 75: Cumulative delta-v for all side impacts, MAIS 2 and MAIS 3+ side impacts

Figure 76: Distribution of fatal, serious and slight injured occupants in side impacts

150
Figure 75 indicates that the collision severity for a given risk of receiving a MAIS 2 or
MAIS 3+ injury is greater in the US compared with the UK. The proportion of fatally
and slightly injured occupants is lower in the US data (Figure 76), while the proportion
of seriously injured occupants is higher.

RQ2: Do occupants in side impact passenger car collisions [S], occurring in the EU
and US [D], experience any difference in injury severity from intrusion of/by
the struck object into the occupant compartment [O]?

Figure 77: Distribution of fatal, serious and slight injured occupants in side impacts
with and without significant intrusion into the occupant compartment

Figure 77 shows that for collisions with low intrusion into the occupant compartment,
the proportion of fatal and serious casualties is slightly lower in the UK data compared
with the US data. In contrast, there is a higher proportion of fatal casualties in the UK
(and a lower proportion of serious casualties) when the intrusion exceeds 8-10 cm.

RQ3: In side impact passenger car collisions [S], do EU and US occupants [D]
experience any difference in head injury severity [O]?

151
 Figure 78: MAIS 2 and MAIS 3+ head injury distribution

Figure 79: MAIS 2 and MAIS 3+ head injury distribution with and without a roof rail
airbag
Figure 78 shows a similar proportion of MAIS 3+ head injuries in the UK and US data,
but a markedly different proportion of MAIS 2 head injuries, with a much lower
152
incidence in the UK data. It is not clear why these should be so different: the majority of
AIS 2 head (not including face) injuries that are likely to be coded in either data set are
minor cranium fractures and minor loss of consciousness (or related amnesia or
neurological deficit), but it is not known why these would be either coded or occur at
such different rates.

Figure 79 shows that the absence of a roof rail airbag has little effect on the proportion of
occupants receiving a MAIS 3+ head injury in the US data and seems to be associated
with a reduction in the proportion receiving MAIS 2 head injuries. For the UK data, the
proportion of occupants with serious MAIS 3+ injuries is greater without the roof rail
airbag.

RQ4: In side impact passenger car collisions [S], do small stature EU and US front
seat occupants [D] experience any difference in injury severity [O]?

Figure 80: Occupant injury severity distribution for smaller, medium, and taller
occupants
Figure 80 shows the distribution of fatal, serious and slight injuries for occupants <1.6 m,
1.6-1.8 m and >1.8m tall. For both UK and US, the data are indicative of a greater risk
of fatal injury for the medium-size occupant group (also for serious injuries in the US
data), with a lower risk of fatality for taller and smaller occupants.

RQ5: In side impact passenger car collisions [S], do rear seat occupants in the EU
and US [D] experience any difference in injury severity [O]?

153
 Figure 81: Fatal, serious and slight injury distributions for rear seat occupants
(age >12 years)
This data (Figure 81) indicates that rear seat occupants are better protected in US
vehicles than in UK vehicles, with a lower proportion of fatal and serious injuries in the
US data than the UK data. Nevertheless, rear seat occupant risk is still greater than front
seat: Liu et al. (Liu et al., 2012) showed that occupant injury metrics improved year-on-
year in US NCAP tests. Nevertheless, rear seat occupant head injury risks were much
higher than for front seat occupants, even for newer vehicle models, with the HIC
approximately double for rear seat dummies compared with front seat dummies from
2001 to 2009. The authors recommended that head and thoracic injury countermeasures
be prioritised for rear seating positions.

7.3.2.3 INFORMATION FROM LITERATURE

A number of sources were found giving information on the effect of differences in the
US and EU MDB test characteristics. These are covered in the four RQs below:

RQ6: In the vehicle fleet [S], does the FMVSS 214 crabbed MDB impact [D] lead to
different occupant protection strategies or outcomes [O]?
RQ7: In side impact passenger car tests [S], does impact trolley mass or velocity [D]
lead to a significant difference in dummy measurements or other assessment of
car safety [O]?
RQ8: In a side impact passenger car test [S], does the stiffer bumper beam in the US
MDB cf. the EU MDB [D] cause a greater intrusion into the occupant
compartment of the struck vehicle [O]?
RQ9: In a side impact passenger car test [S], does the higher barrier face in the EU
MDB cf. the US MDB [D] cause a greater intrusion into the occupant
compartment of the struck vehicle [O]?

154
Fildes et al. (1998) explored the possibility of a ‘hybrid’ barrier side impact test
procedure, using the high-mass crabbed trolley from FMVSS 214 with the R95 barrier
face. The hybrid test procedure was found to have greater benefit than either individual
test procedure (F214 or R95). The narrower R95 barrier face did not load the rear seat
occupant as much as the F214 barrier face, but it was more representative of the rear seat
occupant loading in a car-to-car test with the same vehicle. It should be noted that only
one vehicle model was used in this test series, which was an Australian domestic vehicle
designed to meet FMVSS 214.

As shown in Lim et al. (2013), a heavier MDB does not necessarily result in larger
deformations of the vehicle structure; the deformations relate to the stiffness, stiffness
distribution and height of the barrier face and to the size of the vehicle. For example, in
their tests with small to medium size vehicles, the heavier, stiffer 1300 kg and 1500 kg
AE-MDBs gave greater vehicle deformations than the 950 kg R95 MDB. However, when
testing a large car, the vehicle deformation at the pelvis level was larger when testing a
with the R95 MDB than with either the 1300 kg or 1500 kg AE-MDB.

Dakin et al. (2003) showed that, for the IIHS MDB test, mass (1500 or 1900 kg) and
approach angle (crabbed or perpendicular) had less effect on dummy injury measures and
kinematics than impact velocity (48.3 or 50 km/h). On this basis, they selected a 1500 kg
perpendicular impact at 50 km/h for their consumer information testing.

Newland (2005) reported on the progress of the IHRA Side Impact Working Group a the
19th ESV conference. The group undertook a parametric study to examine the effect on
injury risk of the mass, stiffness and geometry of the striking vehicle in side impact,
based on numerical modelling and full-scale crash tests conducted by laboratories in the
UK, Canada, US and Japan. The authors reported that the ground clearance of the
striking vehicle or MDB had the greatest effect, mainly due to a reduction in engagement
of the side sill of the struck vehicle, while increasing the stiffness of the vehicle or MDB
had a lesser effect. Impact velocity had a similar effect as ground clearance. They also
found that perpendicular impacts increased the loading to the driver dummy compared
with crabbed impacts, and that non-homogeneous barrier faces generate more intrusion
than homogensous ones.

RQ10: In side impact occupant protection for passenger cars [S], has legislation or a
change in regulatory requirements [D] led to the introduction of any new side
impact protection technologies [O]?
No literature directly relating to this question was identified.

RQ11: In the vehicle fleet [S], does the FMVSS 214 door crush resistance test cf. no
push test in the EU [D] lead to a greater incidence or higher specification of
door beams [O]?
No literature directly relating to this question was identified. However, Fildes et al.
(2005) noted that design strategies used to improve performance the frontal offset test
condition [as used in R95 and Euro NCAP] include strengthening of the side of the
vehicle. This is done to maintain occupant compartment integrity in the offset frontal
test, but coincidentally improves side impact protection. One of the stakeholders
consulted in the project also noted that door beams have been strengthened due to the
frontal offset test condition used in EU, and that – at least for small cars – this may be
155
sufficient to meet the F214 door crush resistance test. This means that to some extent
the EU frontal impact requirements may offset the absence of a specific test for door
beams in EU legislation.

156
8. ROLLOVER

8.1 COMPARISON OF EU REGULATIONS AND US STANDARDS

Rollover test requirements for the EU and the US are specified in the regulatory acts and
federal standards, respsectively, shown in Table 34_Hlk420395392 below.

It should be noted that:

 The item, ‘interior fittings/impact’ and associated legislative requirements of UN

Regulation 21 and FMVSS 201 are covered in Section 4 ‘Side Impact’.

Table 35: Regulatory Acts and Federal Standards that specify rollover test related
requirements for the EU and the US, respectively.

No. Item EU USA

Regulatory Description Federal Description
Act (Framework Standard
Directive)
1 Roof strength None FMVSS Roof crush
216(a) resistance
2 Ejection None FMVSS 226 Ejection
mitigation mitigation
3 Interior UN Reg 21 12A: Interior FMVSS 201 Occupant
fittings / fittings See side protection in
impact impact interior impact
See side
impact

8.1.1 ROOF STRENGTH

There are no EU regulations concerning roof strength. Therefore, this section describes
the US requirements, namely FMVSS 216 and 216a.

Rollover is defined as an event in which a vehicle overturns onto its roof or side. This
occurs when a vehicle is destabilised by an imbalance of forces acting upon it, due to
factors such as a collision, excessive speed, change in ground friction and excessive
steering inputs. This type of accident can be extremely harmful to occupants. Injuries to
the head and neck, thorax, abdomen, upper limbs and lower limbs are typically observed
due to occupants colliding with structures inside the vehicle (Eichler, 2003). The most
harmful injuries usually occur when occupants are fully or partially ejected from the
vehicle. According to CARE (EU road accidents database) approximately 26,000 people
are killed in road accidents each year and 1.4 million people are injured (CARE, 2014).
Research carried out within 15 Member States of the European Union (EU) between
2002 and 2005 found that rollover accidents account for between 5 and 10 per cent of all
vehicle accidents. However, 10 to 20 per cent of all seriously injured occupants and
fatalities were involved in an accident where the car rolled, demonstrating the potentially
severe consequences of rollover events (Gugler and Steffan, 2006).

The damage to a vehicle during a rollover crash can often include deformation of the roof
and its supporting structures. Strengthening of the roof to a required standard is
suggested as an appropriate countermeasure to help ensure occupant survival space.
157
 FMVSS 216 became effective on September 1st, 1973, and established roof strength
requirements for the roof structure of passenger cars with a Gross Vehicle Weight Rating
(GVWR) ≤ 2722kg. Amendments in 1991 and 1999 expanded its applicability to other
vehicle classes (multipurpose passenger vehicles, trucks and buses) and modified the test
procedure slightly to accommodate vehicles with raised and highly sloped roof structures.

In 2009, FMVSS 216 was amended substantially resulting in FMVSS 216a. This
standard requires significantly stronger roof structures than FMVSS 216. It has a phase in
period with 100% compliance for new vehicles by September 1st, 2015.

The applicability, test configuration and requirements of FMVSS 216 and 216a are
compared in Table 13.

Notes:

 Applicability is for passenger cars, multipurpose passenger vehicles, trucks and

buses except school buses and convertibles with a GVWR as detailed.
 Force is applied using rigid platen measuring 762 mm by 1,829 mm as shown.

Main differences in FMVSS 216a are:

 Increase in scope and strength requirements.
 Test on both driver and passenger sides, rather than just driver or passenger side.
 Allowed platen movement requirement added, namely no load > 222 N should be
applied to headform located at head position of 50th percentile male. This
effectively restricts allowable crush of 127 mm further for vehicles with a roof
close to the occupant’s head.

Table 10: Comparison of FMVSS 216 and 216a roof crush resistance requirements.

FMVSS 216 FMVSS 216a

Applicability (scope) and requirements

GVWR ≤ 2,722kg GVWR ≤ 2,722kg:
Force: 1.5 x UVW x 9.8N Force = 3.0 x UVW x 9.8N
Passenger OR Driver side testing GVWR >2722kg and ≤4536kg:
(Manufacturer choice) Force = 1.5 x UVW x 9.8N
Passenger AND Driver side testing
UVW = Unloaded Vehicle Weight
Test configuration
Passenger OR driver side testing: Passenger AND Driver side testing:
Passenger side testing: Passenger side testing:

158
 FMVSS 216 FMVSS 216a

Driver side testing: Driver side testing:

Notes:
The test device moves in a downward direction perpendicular to the lower surface of the
test device at a rate of not more than 13 millimetres per second until reaching the required
force level. The test is completed within 120 seconds.

8.1.2 EJECTION MITIGATION

There are no EU regulations concerning ejection mitigation. Therefore, this section

describes the US requirements, namely FMVSS 226.

The purpose of FMVSS 226 is to reduce complete and partial ejections of vehicle
occupants through side windows in crashes, particularly rollover crashes. It came into
effect on March 1st, 2011 with phase-in requirements from 1st September 2013 to 31st
August 2018. In order to meet its requirements, it is expected that vehicle manufacturers
will enhance side curtain air bags by making them larger to conceal more of the window
opening, more robust to remain inflated longer, and more innovative to deploy in side
impacts and in rollovers. The curtains will be made not only to cushion but also to be
sufficiently strong to reduce the possibility that an occupant will be fully or partially
ejected through a side window.

Essentially, FMVSS 226 testing consists of propelling a headform impactor at targets on

both the front and rear side daylight openings of the vehicle. The countermeasure (airbag)
should prevent impactor displacement of more than 100 mm past the ‘zero displacement
159
plane’. This plane is determined for each target point by the location of the outer most
surface of the headform pressed lightly (20 N force max) against the closed glazing. Prior
to impact testing, the glazing covering the target location must be removed from the side
daylight opening, fully retracted, or pre-broken. Any side door on the opposite side of the
longitudinal centerline of the vehicle from the target to be impacted may be open or
removed. Any rear hatchback or tailgate may be open or removed for testing any target.
Any other doors, doors, including any rear hatchback or tailgate, are fully closed and
latched but not locked.

Tests are conducted at two impact velocities:

 16km/h ±0.5 after a 6 second time delay of the countermeasure deployment.

 24km/h ±0.5 after a 1.5 second time delay of the countermeasure deployment.

and at target locations as shown in Table 14.

160
 Table 36: Configuration of FMVSS 226 headform impactor tests.

Configuration of FMVSS 226 headform impactor tests

1. 16km/h ±0.5 after a 6 second time delay of the countermeasure
deployment.
4 target locations on each front AND rear side daylight openings

2. 24km/h ±0.5 after a 1.5 second time delay of the countermeasure

deployment.
4 target locations on each front AND rear side daylight openings.

Note windows open, doors closed for testing

8.1.3 SUMMARY OF NOTABLE DIFFERENCES

 No tests in EU to control roof crush resistance.

 No test in EU to control partial or full occupant ejection from the vehicle in the
event of a rollover.
For interior impact see Section 4 ‘Side Impact’.

161
8.2 CONSUMER INFORMATION TESTING

This section describes rollover related tests performed in the EU and US to provide
safety information for consumers.

In the EU, effectively no rollover related tests for consumer information are performed. It
should be noted that the Allgemeiner Deutscher Automobil-Club (ADAC) have
performed some tests, namely corkscrew and trip type rollover tests. However, because
these tests are not conducted often or regularly, it was decided to discount them from this
overview.

In the US, the IIHS perform a roof crush strength test.

Table 14: Rollover related tests for consumer information in the EU and US.

Item / Test EU US
1 Roof Strength Test None IIHS – Roof Strength

IIHS introduced roof strength testing in 2009 to help consumers choose vehicles that will
protect them better in a rollover crash. The test is similar to that outlined in FMVSS 216,
with the exception that the rigid platen is displaced 127 mm and the highest force
sustained measured. From this a strength to weight ratio (SWR) that the vehicle roof can
sustain is calculated. Using this measure, the vehicle’s roof strength rating is rated as
follows:

Good: ≥ 4.00
Acceptable: ≥ 3.25 to < 4.00
Marginal: ≥ 2.5 to < 3.25
Poor: < 2.5
The IIHS test effectively enhances the FMVSS 216a legislative test because it requires a
significantly higher roof SWR to obtain a good rating (FMVSS 216 a 3.0, IIHS good
rating 4.0)

8.3 DISCUSSION OF REAL-WORLD IMPLICATIONS

The US has mandatory legislative roof crush resistance and ejection mitigation. The EU
does not have any legislation regarding these tests. Consumer testing for roof crush
resistance is conducted in the US.

 No test in EU to control partial or full occupant ejection from the vehicle.

 No tests in EU to control roof crush resistance.
o Also, the IIHS consumer information roof crush test effectively
enhances the US legislative requirement by requiring a higher
Strength to Weight Ratio (SWR) for a ‘good’ rating (IIHS good
rating 4.0, FMVSS 216a legislative limit 3.0).

The main effect of this difference may be hypothesised to result in a greater occurrence
of more severe casualty injuries in similar rollover accidents in the EU than in the US.

The research questions used to perform the literature search to address these notable
differences were:
162
RQ1: Comparing rollover incidents in the US and EU is there a difference in
casualty rates per vehicle km?

RQ2: Comparing rollover casualties in the US and EU is there a difference in the

severity of neck, head, spine, abdomen and lower limb injuries?

RQ3: In rollover incidents, does belt use in the US and EU affect the rates of
passenger partial and/or full ejection?

RQ4: In rollover incidents, does belt use in the US and EU affect the distribution of
injuries on the body?

RQ5: In rollover incidents, is roof strength associated with injury outcome when
passengers are belted in the US and EU?

8.3.1 LITERATURE REVIEW - INCLUDED ARTICLES

The flow of articles through the literature review selection process is illustrated by a flow
diagram in Figure 82 below. There were 189 citations from the original search of
databases, of which 92 were excluded based on the a priori selection criteria. Of the 125
articles selected for full review, 15, met the selection criteria and were included for full
article evaluation.

163
 Number of articles identified Number of articles identified
through database searching through other sources
(n = 324) (n = 0)

Number of articles after

duplicates removed
(n = 189)

Number of articles Number of articles

screened for relevance excluded
(n = 97) (n = 92)

Number of full test articles Excluded articles (n=13)

assessed for eleigibility Not highly relevant to RQ: 13
(n = 28 Low quality methodology:
Failed to meet selection criteria:

Number of studies
included for evidence
evaluation
(n = 15)

RQ1 RQ2 RQ3 RQ4 RQ5

(n = 5) (n = 5) (n = 2) (n = 4) (n = 5)

Figure 82:Flow diagram illustrating the flow of articles through the

selection process.

8.3.2 ROLLOVER TESTING

 No test in the EU to control adult driver and passenger safety in rollover

crashes.
 No test in the EU to control infant passenger safety in rollover crashes.
o The US rollover test (FMVSS 208) is conducted on various test
dummies, and therefore a wider range of injury criteria results are
collected. This aids manufacturers in ensuring greater overall vehicle
safety.
 No test in the EU to measure injury criteria in the event of a rollover crash.
 No test in the EU to control occupant safety from hazards that occur as a
result of electrolyte spillage in a rollover crash.
164
  No test in the EU to control occupant safety from electric shocks.

Several research questions used to perform the literature search to address these notable
differences:

RQ1: Comparing rollover incidents in the EU and US, is there a difference in

casualty rates in rollovers?

It could be assumed that these legislative differences, could lead to a higher casualty rate
in (similar) rollovers in the EU than the US (due to mandatory rollover test requirements
in the US). A literature search was conducted based on the research questions above to
identify any evidence to support or oppose these assumptions. Only one study was
identified which directly compared EU and US data:

 Parenteau et al. examined UK and US data to identify factors influencing rollover

occurrence and injury outcome (Parenteau et al., 2001). The US data was
obtained from NASS-CDS (1992-1996) and consisted of 220,576 cases. The UK
pre-roll data (7102 cases) was obtained from the national STATS 19 database for
1996, while the injury information was collected from the Co-operative Crash
Injury Study (CCIS) (1992-1998) database (1600 cases).
 The study found that rollovers represented 9% of all crashes recorded within the
US dataset. However, of the seriously injured occupants involved in a crash, 25%
were injured after a rollover event. The risk for an occupant to be seriously
injured was highest in a rollover event, at 6 per 100 rollovers.
 In the UK sample, rollovers represented 13% of all crashes and involved 21% of
seriously injured occupants. Similar to US data, the risk of serious injury was also
highest in a rollover, at 21 per 100 rollovers.

Overall, the comparison of accident data from each region showed that an occupant
involved in a rollover event in a vehicle sold in the EU was more likely to sustain a
serious injury than an occupant in a vehicle sold in the US. However, the data from this
study is based on vehicles that are much older than the current fleet on EU and US roads
and is less likely to be as representative of the modern fleet. The sample size of each data
set differs greatly meaning that the results of the comparison study cannot be used to
draw any definitive conclusions.

A review of papers examining casualty rates in rollover crashes in either region was
carried out to identify any differences:

 Ryb et al.’s study of motor vehicle collisions analysed cases from the NASS-CDS
for the years 2000 to 2008. Of the 30,514,372 motor vehicle collisions that
occurred in this time frame, 8.4% were characterised as rollover incidents. Of
those occupants involved in rollover incidents, 2.02% sustained fatal injuries
(Ryb et al., 2011).

 Rains and Kanianthra identified that rollover collisions carry a higher risk of
death and serious injury than any other type of motor vehicle crash (Rains and
Kanianthra, 2004). In 2005, there were approximately 11 million motor vehicle
crashes in the US. Amongst these, approximately 2.6% of vehicles rolled over.
Despite this small number, 21% of fatal crashes and 30% of all occupant fatalities
involved a rollover event.

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  Barrios et al. examined in-depth accident data from road accidents in Spain.
Within this database there were 76 rollover crashes. In 16 out of the 76 cases,
serious injuries (AIS 3+) were present; over 20% (Barrios et al., 2005).

However, due to the lack of studies comparing rollover events in both regions, the
literature review did not identify any papers which could provide a definitive conclusion
regarding differences in casualty rates between the EU and the US.

RQ2: Comparing rollover casualties in the US and EU, is there a difference in the
severity of neck, head, spine, abdomen and lower limb injuries?

It could be assumed that these legislative differences, could lead to occupants involved in
a rollover event sustaining higher severity injuries in the EU than the US (due to
mandatory rollover test requirements in the US). Various studies were identified that
examined the difference in injury severity of occupants involved in rollover crashes in
either region. Two studies were found to directly compare rollover casualties based on
data from the US and the UK:

 Padmanaban et al. compared rollover crash characteristics, and injury distribution

and severity in belted occupants (Padmanaban et al., 2005). Real world accident
data was obtained from the NASS data files (1988-2002) in the US, and the CCIS
database (1995-2002) in the UK. Serious injury distribution in the US and UK
was noted and compared by Padmanaban et al.. The data shows that there is a
higher proportion of combined ‘serious head/face/neck’ and ‘serious torso’
injuries in the UK (see Table 37).

Table 37: Proportion of serious injuries (AIS 3-6+) sustained by belted occupants in
rollover incidents using data from NASS (1988-2002) and CCIS (1995-2002).

Injury US UK
(Type and combinations) % %
Serious torso* injuries 40 31
only

Serious head/face/neck 20 18
injuries only

Serious head/face/neck 10 26
AND serious torso*
injuries

*‘Torso’ includes abdomen, thorax, thoracic and lumbar spine, and pelvic hip.

 Parenteau et al.’s study highlights that the risk for a belted driver to sustain a
serious injury was higher in the UK CCIS sample than US NASS-CDS sample, at
12% and 1% respectively, suggesting a lack of occupant protection. This was also
true for unbelted drivers, at 15% for UK and 2% for US drivers (Parenteau et al.,
2001).

The evidence gathered by Padmanaban et al. and Parenteau et al. suggests that vehicles
sold in the EU perform worse at protecting occupants in a rollover event than vehicles
sold in the US. It could be hypothesised that the absence of rollover tests may be
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compromising the safety of vehicle occupants in real-world rollover accidents, although
no definitive conclusion can be reached due to the limitations of both studies (e.g.
differences in samples, numbers of cases and age of data). No further papers were
identified which compared the injury severity of passengers in rollover incidents in the
EU and US.

8.3.3 EJECTION MITIGATION TESTING

 No test in EU to control partial or full occupant ejection from the vehicle.

The research questions used to perform the literature search to address these notable
differences were:

RQ3: In rollover incidents, does belt use in the US and EU affect the rates of
passenger partial and/or full ejection?

RQ4: In rollover incidents, does belt use in the US and EU affect the distribution of
injuries on the body?

Due to the legislative differences, it could be assumed that there is a higher rate of
occupant partial and/or full ejection in the EU than in the US due to the mandatory
ejection mitigation testing carried out in the latter region. For the same reason, it could
also be assumed that the distribution of injuries would be less severe in the US than in
the EU. A literature search was conducted based on the research questions above to
identify any evidence to support or oppose these assumptions. No studies were identified
that examined the ejection rate of belted passengers in rollover incidents in the EU.
However, a few studies examining passenger ejection in rollover crashes in the US
region were identified:

 Eigen analysed data from the NASS-CDS database for the years 1995 to 2001
(Eigen, 2003). A higher number of passengers were entirely ejected from the
vehicle when unrestrained (97% versus 3%). However, the percentages were
similar for partial ejection regardless of wearing a seatbelt or not (49% versus
51%).
 Parenteau and Shah obtained data from NASS-CDS for calendar years 1992 to
1996 (Parenteau and Shah, 2000). Trip-overs were chosen for the analysis as they
accounted for over 50% of rollover crashes in the US at that time. Of the 50,504
unbelted drivers, 27% were completely/partially ejected, while, of the 150,426
belted drivers, less than 1% were ejected.
 Funk et al.’s study on the factors which affect risk in rollover crashes also noted
findings regarding passenger ejection paths (Funk et al., 2012). Side curtain
airbag deployments were found to be 66% effective at preventing partial ejection
in belted occupants, and 67% effective at preventing complete ejection in
unbelted occupants. In the US, there is legislation which ensures ejection
mitigation testing is conducted (FMVSS 226) on vehicles. There is, however, no
such legislation in the EU. By considering this issue, it is assumed that there
would be safety implications if an EU vehicle was to be sold in the US.

The US data conclusively shows that seatbelt use virtually eliminates the risk of complete
ejection in any kind of crash. The studies also showed that seatbelt use also reduces the
risk of partial ejection, although the risk is not eliminated. EU data is required to
determine whether the same effect is observed in the EU.
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Studies were identified that examined the effect of seatbelt use on the distribution of
injuries in a rollover incident. As no studies were found to directly compare US and EU
data, a review of papers examining the effect of seatbelt use on injury distribution in each
region was performed:

 Parenteau and Shah noted that injuries were frequent to the head and thorax in
unbelted drivers in the US. Unbelted occupants were more likely to receive
serious head injuries for a quarter to a half vehicle roll event (Parenteau and Shah,
2000).
 Digges et al. examined NASS-CDS data, from the years 1995 to 2003, to
determine the injury distribution by body region for the most frequently occurring
rollover classifications that result in MAIS 3+ injuries from sources inside the
vehicle. (Digges et al., 2005). The study found that MAIS 3+ injuries are more
likely to be sustained by unbelted front seat passengers in all four ‘ejection types’
examined.
 The same study by Digges et al. also revealed that serious injury is more likely to
occur to the head for unbelted, not-ejected occupants, whereas the other body
regions are all more likely to be seriously injured if the non-ejected occupant is
wearing a belt. Table 38 shows the HARM percentage of each body region which
sustains AIS 3+ injuries in non-ejected belted and unbelted occupants. HARM is
calculated by applying the injury cost weighting factor to each category of AIS
injuries.

Table 38: AIS 3+ HARM percentages for belted and unbelted not ejected relevant
occupants by body region.
Body Region Belted Unbelted
(HARM %) (HARM %)
Head 35 49
Spine 12 9
Trunk 30 25
Extremity 15 11
Unspecified 7 6

 Otte’s study on the severity of injuries sustained in rollover crashes for the years
1994 to 2000, using information from GIDAS, also provided information
regarding belt use and injury distribution (Otte, 2005). Injuries on the body to
belted, non-ejected occupants after a rollover had taken place in three regions:
o 42.5% were injured on the head,
o 26.2% on the thorax, and
o 44.6% on the upper extremities.

 Cuerden et al. examined CCIS data from between December 2002 and September
2008. It was found that occupants, who were either fully or partially ejected from
their cars, were strongly linked to severe injury outcome. Seat belts, used in
conjunction with other restraint devices, were shown to be effective (Cuerden et
al., 2009).

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Various studies concerning belted passenger ejection rates in the US all highlight that
ejection is higher when the occupant is unbelted. Moreover, it has been noted in both US
and EU studies, that more serious injuries are likely to occur when an occupant is ejected
from the vehicle. Therefore, in response to the research questions, seatbelt usage does
effect the rate of ejection and subsequently injury distribution. The differences in ejection
rates and injury distribution of belted and unbelted occupants in the EU and US could not
be directly compared due to differences in each study, meaning that no definitive
conclusions on the effectiveness of US rollover legislation could be reached based on the
literature identified.

8.3.4 ROOF STRENGTH TESTING

 No legislative tests in EU to control roof crush resistance.

o Also, the IIHS consumer information roof crush test effectively
enhances the US legislative requirement by requiring a higher
Strength to Weight Ratio (SWR) for a ‘good’ rating (IIHS good
rating 4.0, FMVSS 216a legislative limit 3.0).

The research question used to perform the literature search to address these notable
differences was:

RQ5: In rollover incidents, is roof strength associated with injury outcome when
passengers are belted in the US and EU?

These legislative differences were considered together as they are highly related. An
expected outcome of the legislative differences is that head injuries of belted occupants
sustained during a rollover event may be of a higher severity if sustained within a vehicle
sold in the EU compared with a vehicle sold in the US. This is due to the fact that the US
region enforces mandatory roof strength testing whereas the EU region does not.

No studies were found that compared the association between roof crush and injury
outcome in the US and EU regions. However, various studies exist which examine this
relationship based on data in the US region:

 Mattos et al. examined the association between the pattern of roof damages and
the incidence of a serious head injury for contained, restrained occupants. NASS-
CDS data for the years 2000 to 2010 was observed. Mattos et al. noted that
serious head injury occurred with comparatively little roof crush (<15cm),
suggesting that injury patterns in a rollover are complex and roof crush is but one
of many exposures to consider (Mattos et al., 2014).

 Dobbertin et al. utilised data from the NASS-CDS for the years 1997 through
2007. The objective of this study was to determine if increased vertical roof crush
was associated with increased odds of head, neck and spine injury. A statistically
significant increase was found in the odds of life-threatening head, neck or spine
injury for each additional 10cm of vertical roof crush. Similarly it was found that
the same increase in vertical roof crush was associated with a significant increase
in the odds of any injury to the head, neck and spine (Dobbertin et al., 2013).

 Mandell et al. analysed NASS-CDS and CIREN data from 1993 to 2006 for
10,921 occupants involved in rollover crashes to evaluate the relationship
between different levels of roof crush and mortality, severe injury to the spine,
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 spinal cord and head injury. The findings revealed that serious (AIS≥3) injuries
and mortality rates increase as the amount of roof crush increases (Mandell et al.,
2010). The findings are listed in Table 39 below:

Table 39: Injury and mortality rates associated with the degree of roof crush.

Degree of Roof Crush Mortality Spine Injury Head Injury

AIS≥3 AIS ≥3
(cm)
(%) (%) (%)
0-3 3.41 1.96 3.82
3-8 2.03 1.92 2.26
8-15 2.64 3.79 4.25
15-30 6.86 4.82 5.69
≥30 18.18 5.09 12.73

 Rains and Kanianthra (2004) conducted a comparative study between 155 belted
rollover occupants who did and did not receive head injuries from roof contact.
Information the NASS and Crashworthiness Data System (CDS) for the years
1988 to 1992 was analysed. Contact with the roof of the vehicle in rollovers has
been associated with head and brain injury. Results showed that headroom was
reduced more in those crashes where the occupant had head injuries than in cases
where there were no head injuries (Rains and Kanianthra, 2004).

 Funk et al. examined data from 1995 to 2008 to identify risk factors for cervical
spine, head, serious (AIS≥3) and fatal injuries. They found that more than 15cm
of roof crush at an occupant’s seat position was associated with a seven fold
increase in the risk of cervical spine injury compared to less than 3cm of roof
crush (Funk et al., 2012).

Each study, except for Mattos et al.’s (2013) study, found that the larger the degree of
roof crush, the greater the risk of serious injury to the head, neck and/or spine. Moreover
there is a greater risk of fatality. No study was found that examined whether roof crush is
associated with injury outcome in the EU.

The literature reviewed supports the notion that a larger degree of roof crush increases
the risk and severity of injury in the US. As no information was found to support this
hypothesis in the EU, it can only be assumed that the same relationship is present. Data
from the EU is required before it can be determined whether injury statistics are more
severe in that region due to the lack of roof crush resistance testing.

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9. REAR IMPACT

9.1 COMPARISON OF EU REGULATIONS AND US STANDARDS

Rear impact requirements for the EU and the USA are specified in the regulatory acts and
federal standards, respectively, shown in Table 40 below:

Table 41: Regulatory Acts and Federal Standards that specify rollover test related
requirements for the EU and the US, respectively.

No. Item EU USA

Regulatory Description Federal Description
Act (Framework Standard
Directive
2007/46)
1 Rear impact UN Reg 34 3A: Prevention FMVSS 301 Fuel system
of fire risks integrity
(liquid fuel
tanks)
UN Reg 32 Note: Not
required in
framework
Directive
2 Head UN Reg 17 15A: Seats, their FMVSS 202 Head restraints
restraints anchorages and
any head
restraints

(GTR 7) Head restraints (GTR 7) Head restraints

(Not transposed (Not transposed
into EU into US
legislation, to legislation, to
date) date)

UN Reg 25 Head restraints,

whether or not
incorporated in
vehicle seats
3 Bumpers UN Reg 42 Bumpers Part 581 Bumper
Note: Not standard
required in
framework
Directive

9.1.1 REAR IMPACT

This section compares the rear impact test requirements for the EU and the US. It begins
with a background section which describes a brief history of Regulation 32, Regulation
34, and FMVSS 301. The following sections include a comparison of rear impact tests
and the notable differences that were found.

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9.1.1.1 BACKGROUND

Regulation 32

Regulation 32 specifies a rear impact test, which is optional in the EU. The test consists
of either a moving barrier or pendulum impactor which contacts the rear end of the
vehicle. The requirements include ensuring that rigid components do not pose a risk of
serious injury, that side doors of the vehicle do not open under impact, and that the
vehicle deformation does not prevent the doors from being opened without the use of
tools, after the impact. Fuel spillage is not assessed.

Regulation 34

Regulation 34 specifies mandatory requirements for the approval of vehicles with regard
to the prevention of fire risk. Regulation 34 contains requirements for liquid fuel tanks as
a separate technical unit and for the installation of the fuel tank on the vehicle, both of
which are mandatory for the EU. The approval of vehicles with regard to the liquid fuel
tank can be met by either tests on the fuel tank or by a rear impact test. Therefore, the
rear impact test is optional for the EU and conducted at the manufacturer’s request,
although a pending amendment to Regulation 34 (03 series amendments) seeks to make it
mandatory. This test is identical to Regulation 32 and consists of either a mobile barrier
or pendulum impactor which contacts the rear end of the vehicle. The purpose of the test
is to simulate the conditions of rear end collision by another vehicle in motion. The
assessment measures fuel spillage, ensures that there is no fire as a result of fuel spillage,
and maintains the position of the battery in the event of a rear impact crash.

FMVSS 301

In the USA, FMVSS 301 was adopted to aid the reduction of deaths and injuries caused
by post-crash fires. This test is mandatory in the USA and applies to passenger cars,
multipurpose passenger vehicles, trucks, and buses with GVWR ≤4536kg and fuel with
boiling point above 0°C. The Standard limits the amount of fuel spillage from fuel
systems of vehicles during applicable frontal, side and rear impact tests and a subsequent
static rollover test. The applicable frontal, side and rear impact tests are specified in
FMVSS208, 214 and 301, respectively.

9.1.1.2 REAR IMPACT TEST CONFIGURATIONS

The main crash test configuration parameters for the rear impact tests in the EU and US
are shown in Table 11.

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 Table 11: Comparison of EU and US rear impact test configurations.

EU (Regulations 32 and 34) US (FMVSS 301)

Note: R32 not part of framework directive,

test currently optional within R34

Moving barrier or pendulum. Moving deformable barrier.

Vehicle Mass:
Unladen kerb weight
Vehicle mass:
Impactor: UVW plus rated cargo and luggage capacity
2500mm x 800mm weight, plus 50th percentile dummies in each
Edge radius: front outboard seating position.
40-50mm clad with 20mm thick plywood
layer Impactor block:
Ground clearance: 1676mm x 559mm x 381mm
175±25mm Ground clearance:
Impactor weight: 229mm
1100±20kg Bumper:
1676mm x 203mm x 102mm
Impact surface: Bumper ground clearance:
Entire width of vehicle 280mm

Impact surface:
70% overlap to either side at impact

The EU rear impact test, which is optional, consists of a moving rigid barrier or
pendulum impacting the rear end of a vehicle. The impact speed is between 35 and 38
km/h. The same test is included in Regulations 32 and 34.

Regulation 32 focuses on the structure of the vehicle. The requirements are as follows:

 No rigid component in passenger compartment shall pose risk of serious injury,

 Side doors of vehicle shall not open under impact,
 Doors shall be opened after impact without use of tools,
 The lengthwise displacement of rearmost seat R-point projection shall not exceed
75mm.
Regulation 34 focuses on the vehicle’s fuel tanks after a rear impact crash. The
requirements are as follows:

 During and after impact, battery shall be kept in position,

 No more than slight leakage of liquid on collision,
 Continuous leakage after collision shall not exceed 30g/min,
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  No fire maintained by fuel shall occur.

The USA has a mandatory rear impact test which is specified in FMVSS 301. The test
configuration is described in Table 11. The requirements are listed below:

 Fuel spillage shall not exceed 28g from impact until vehicle motion has ceased,
 Fuel spillage shall not exceed 142g in following 5 minutes after the rear impact
crash,
 Fuel spillage shall not exceed 28g/min for following 25 minutes after the rear
impact crash.

Further details for the performance criteria and limits for the EU rear impact test (both
Regulations 32 and 34) and the US test (FMVSS 301) are shown in Annex 5, Table 68.

The notable differences are:

 Rear impact tests in the EU are not mandatory (although pending 03 series
amendments may make it so) whereas the US test is mandatory.
o The impact speed is considerably higher in the USA (80km/h) compared
to between 35 and 38 km/h in the EU.
 Pending 03 series amendments require a test speed of between 48
km/h and 52 km/h15
 The test impactor differs significantly in each region in terms of size and material;
the EU barrier is rigid whereas the US barrier is deformable.
 The vehicle undergoes a full width impact in the EU, whereas in the USA the
impact is carried out with a 70% overlap.
 In the EU the vehicle is tested at unladen mass. In the USA the tested vehicle
must carry its rated cargo capacity and 50th percentile dummies in front outboard
seating positions.
 In the USA the vehicle is tested with transmission in neutral and with the parking
brake disengaged, but in EU testing the gears and brakes may be used.
 USA regulation has slightly stricter limits on post-crash fuel system leakage than
Regulation 34.

9.1.2 HEAD RESTRAINTS

Although whiplash injuries can occur in any kind of crash, an occupant’s likelihood of
sustaining this type of injury is greatest in rear end impacts. Rear impact and whiplash
type injury is a severe issue in terms cost to society. The risk of whiplash injury is not
simply related to head restraint position, but is dependent on a contribution of factors
related to both head restraint and seatback design (SafetyNet, 2009).

Whiplash injuries involve the soft tissues of the head, neck, and spine. Symptoms of pain
in the head, neck, shoulders, and arms may be present along with damage to muscles,

15
http://www.unece.org/fileadmin/DAM/trans/doc/2014/wp29/ECE-TRANS-WP29-
2014-65e.pdf

174
ligaments, and vertebrae. Symptoms may be delayed and may only last a few hours;
however, in some cases, the effect of the injury may last for years or even be permanent
(NHTSA, 2004).

The purpose of a head restraint is to prevent whiplash injury in rear impact crashes. It is
widely believed that by reducing the gap between the occupant’s head and the head
restraint, there should be a reduced movement of the head relative to the torso, and thus
result in lower whiplash rates (NHTSA, 2000). The relevant legislation regarding head
restraint testing for the EU is Regulation 17 and Regulation 25. For the USA, it is
FMVSS 202. There is also a Global Technical Regulation (GTR), namely GTR7. Neither
the EU nor the US has transposed GTR 7 into their regional legislation yet.

9.1.2.1 BACKGROUND

Regulation 17

Regulation 17 outlines the testing for head restraints which is implemented in the EU.
The legislation sets limits for seat strength, seat anchorages and head restraints in order to
ensure a safer environment for the occupant in the event of a rear impact crash. The
regulation was brought into effect in the EU on March 24th, 1998.

Regulation 25

Regulation 25 also became effective in the EU on March 24th, 1998. The regulation
outlines a testing procedure for head restraints in the EU. There are certain requirements,
which integrated head restraints, removable head restraints and separate head restraints
have to meet in order to be deemed acceptable.

FMVSS 202

Since January 1st, 1969, passenger cars have been required by FMVSS 202 to have head
restraints in the front outboard seating positions. The standard also applies to light trucks
manufactured after August 31st, 1991. On July 3rd, 2007, FMVSS 202 was amended and
took into consideration various factors. One alteration included specifying that the
backset (the distance between the back of the head and the headrest) is determined by
taking the average of three measurements rather than using a single measurement. The
backset requirement was made less stringent by specifying the backset limit as the
manufacturer’s specified design. Alterations were also made to non-use positions of rear
seat head restraints, requirements for gaps between the head restraint and seat back, and
the backset and height retention tests. The phase-in period for front seats consisted of 80%
compliance by September 1st, 2008, and 100% by September 1st, 2010. For rear seats, 80%
of the vehicles were to comply by September 1st, 2010, and 100% by September 1st, 2011.

GTR 7

GTR 7 specifies requirements for head restraints to reduce the frequency and severity of
neck injury in rear end and other collisions. The proposed GTR will build on elements
from UNECE Regulations 17 and 25, and FMVSS 202.

9.1.2.2 HEAD RESTRAINT TESTS

This section compares the EU and US requirements for head restraint tests.
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Scope

EU:

Regulation 25 - applies to integrated head restraints, removable head restraints and

separate head restraints. It does not apply to head restraint devices which may be fitted to
folding seats or seats facing towards the side or towards the rear.

Regulation 17 - applies to the seat strength, anchorages and head restraints of category
M1 and N vehicles, and to the same areas for vehicles in categories M2 and M3 if not
covered by Regulation 80. It does not apply to vehicles with regard to side facing or
rearward facing seats, or to any head restraint fitted to these seats.

USA: Passenger cars, multipurpose passenger vehicles, small trucks and buses with
GVWR ≤4536kg

GTR 7: 1-1 vehicles, small trucks and buses.

Test configurations

The test configurations for the EU are shown in Table 13. There are two head restraint
tests in the EU, one of which is specified in Regulation 25. The first element of the test is
an energy absorption assessment, where a pendulum impacts both the front and,
subsequently, the rear of the head restraint. The second part consists of a static test in
which a force of 37.3daN is applied to the head restraint using a spherical headform.
Upon completion of this assessment, a strength test procedure is conducted in which the
force applied to the head restraint is increased to 89daN, unless breakage occurs earlier.
The test requirements for EU Regulation 25 can be found in Annex 5, Table 70. These
include the following:

 Energy absorption test

o Deceleration of the headform shall not exceed 80g continuously for more
than 3ms,
o No dangerous edge shall occur during or remain after the test.
 Static test
o Maximum displacement of the head is less than 102mm.
 Strength test
o Head restraint and anchorage shall be strong enough to bear load without
failure.

The test outlined in Regulation 17 is mandatory for all outboard front seats, whereas
other seats with head restraints are approved optionally. This assessment similarly
consists of energy absorption, static and further strength testing. The procedures are all
alike those completed in Regulation 25 in terms of the impactor, impactor speed and
impact zones. The requirements are noted below:

 Energy absorption test

o Deceleration of the headform shall not exceed 80g continuously for more
than 3ms.
 Static test
o Maximum displacement of the head is less than 102mm.
 Strength test
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 o Head restraint and anchorage shall be strong enough to bear load without
failure.

There is one test in the US which focuses on head restraints. The FMVSS 202 test is
mandatory for all outboard seats, and rear outboard seats with head restraints are also
required to be tested. The assessment involves energy absorption, height retention, static,
strength and dynamic testing. The energy absorption test is made up of a hemi-spherical
headform impacting the front surface of the head restraint at a speed of 24.1 km/h, which
is the same speed as for the energy absorption testing is conducted at in UN Regulation
17. The test limits the deceleration of the headform to no more than 80g continuously for
more than 3ms.

The height retention test consists of a cylindrical test device applying force to the head
restraint. The initial reference position is established by applying a downward load of
50±1N at a rate of 250±50N/min for 5.5±0.5s. The load is then increased at a rate of
250±50N/min to at least 500N and maintained for 5.5±0.5s. The load is subsequently
reduced at the same rate until it is completely removed for a maximum of 2±0.5mins.
The load is again increased at the same rate to 50±1N. During the application of the
initial 50N load, the test device must not move downward by more than 25mm. When the
test load is reduced back to 50N, the device must return to within 13mm of the initial
reference position.

A static test is performed in which a spherical headform is used to apply a force to the
head restraint. Initially a force producing a moment of 37±0.7Nm is applied about the h-
point. This is maintained for 5.5±0.5s. The load is increased at 187±37Nm/s up to
373±7.5Nm and is maintained for 5.5±0.5s. The load is then reduced at the same rate
until it is completely removed and is maintained for 5.5±0.5s. The headform shall not be
displaced more than 25mm during the application of the initial reference moment, and
shall not be displaced more than 102mm during the application of 373±7.5Nm moment
about the h-point. The headform shall return to within 13mm of initial reference position
after the load application sequence. Upon completion of the static test, a strength
assessment is conducted. A load is increased at a rate of 250±50N/min to at least 890N
and is maintained for 5.5±0.5s.

Following this, dynamic testing is completed. A Hybrid III dummy is placed in each
designated seating position with a head restraint. The seat, restraint and dummy position
are adjusted to the requirements noted in Annex 5, Table 70. The test platform is
accelerated or decelerated to reach delta V of 17.3±0.6km/h. The angular rotation
between the head and the torso of the test dummy is limited to 12° in all outboard seating
positions. The HIC value is also limited to 500. The set requirements for each test are
noted in Annex 5, Table 70.

The proposed GTR 7 testing is mandatory for all outboard front seats, whilst other seats
with head restraints must also conform to the relevant requirements. The testing
procedure is similar to that in FMVSS 202 in that there are five assessments: energy
absorption, height retention, static, strength and dynamic. However, there are differences
between the test procedures which include:

 the seat position in static and dynamic testing,

 an allowance of +2mm in FMVSS 202 to the diameter of the spherical head form
for static and dynamic testing, and

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  in GTR 7, the force applied to the head restraint in static and dynamic testing
allows for ±0.7Nm in the first test and for ±7.5 Nm in the second.

The energy absorption test consists of a semi-spherical headform which measures

165±2mm in diameter impacting the front of the head restraint at 24.1km/h. The
requirements for this test are the same as those listed in FMVSS 202, namely the
deceleration of the headform shall not exceed 80g continuously for more than 3ms.

The height retention test is also similar. A cylindrical device of the same measurements is
used to apply a downward load of 50±1N at a rate of 250±50N/min for 5s to determine
the initial reference position. The test device load is increased at a rate of 250±50N/min
to at least 550N and is maintained for at least 5s. The load is subsequently reduced until
the load is completely removed for a maximum of 2mins. The load is again increased at
the same rate to 50±1n. The restraint mechanism shall not allow downward movement of
the restraint by more than 25mm.

Static testing is completed by applying a force producing a moment of 37Nm about the r-
point using a 165±2mm diameter spherical headform. The load is increased at 2.5-
37.3Nm/s up to 373Nm and is then upheld for a minimum of 5s. The headform shall not
be displaced more than 25mm during the application of the initial reference moment and
it shall not be displaced more than 102mm during the application of the 373Nm moment
about the r-point. The headform shall also return to within 13mm of the initial reference
position after the load application sequence. Alike FMVSS 202, a strength test follows
the completion of the static testing. The test device load is increased at a rate of 5-
200N/sec to at least 890N. This is retained for a period of 5s.

A dynamic test is performed. The assessment procedure is identical to that in FMVSS

202, except that the ignition has to be running in GTR 7 testing. The performance
requirements and limits are also similar. These are noted in Annex 5, Table 70.

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 Table 13: Comparison of EU and US head restraint test configurations.

No. EU EU USA GTR 7

(Regulation 25) (Regulation 17) (FMVSS 202)

1. Energy absorption test

Front of restraint testing: Front of restraint testing: Front of restraint testing: Front of restraint testing:

Rear of restraint testing: Rear of restraint testing:

Reference: Annex 6 S1.1, Reference: Annex 6 S1.1, Reference: S5.2.5, S5.2.5(a), Reference: Annex 7 S3, S3.1.1,
S1.2.1, S1.4.1.1, S1.4.2. S1.2.1, S1.4.3, S2.3.1. S4.2.5. S3.3.1. Part B S5.2.1

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No. EU EU USA GTR 7

(Regulation 25) (Regulation 17) (FMVSS 202)

2. Height retention test

None None

(assessed in R17 sled test) (assessed in R17 sled test)

Reference: S5.2.6(a), S5.2.6(b), Reference: Annex 8 S2.1, S2.2,

S4.2.6. S5.2.2.

3. Static test

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No. EU EU USA GTR 7

(Regulation 25) (Regulation 17) (FMVSS 202)

First test: First test:

 37Nm  37±0.7Nm
Second Test: Second test:
 373Nm  373±7.5Nm

Reference: S7.4.2.1, S7.4.3, Reference: S5.12, S6.4, S6.4.1. Reference: S5.2.7(a)(1) Reference: Annex 6 S3.1
S6.8.

4. Strength test

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No. EU EU USA GTR 7

(Regulation 25) (Regulation 17) (FMVSS 202)

Increased load: Increased load:

 ≥890N  ≥890N

Remain at this load for a period Remain at this load for a period
of 5s. of 5s.

Reference: S6.9, S7.4.3.7. Reference: S5.13, S6.4.3.6. Reference: S4.2.7(a), S4.2.7(b).

5. Dynamic test

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No. EU EU USA GTR 7

(Regulation 25) (Regulation 17) (FMVSS 202)

No dynamic protocol No dynamic protocol

implemented implemented
Maximum head rest Maximum head rest
displacement measured in displacement measured in
static test of R17 static test of R17

Hybrid III dummies: placed in Hybrid III dummies: placed in

each designated seating position each designated seating position
with head restraint. with head restraint.

Temp: 18-20°C. Temp: 18-20°C.

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Main differences are:

 No energy absorption testing of the rear of head restraints in the USA,

 No height retention testing in the EU at present,
 No dynamic testing in the EU at present.
 The US and the EU do not provide protection for smaller occupants.

Performance criteria and limits

The performance criteria and limits for the EU and US head restraint tests are compared
in Annex 4. The differences include:

 Rear outboard seats with head restraints must be tested in the USA as well as
front outboard seats. In the EU testing of seats other than front outboard is
optional,
 In energy absorption test, EU regulations require the restraint to be tested in the
most unfavourable position but the USA regulation allows for testing in any
position.

9.1.3 BUMPERS

9.1.3.1 BACKGROUND

Regulation 42

This regulation is not mandatory in the EU. It applies to the behaviour of certain parts of
the front and rear structure of passenger cars when involved in a collision at low speed.
Exterior protection is assured by protective devices, which are essentially elements
located at the front and rear ends of vehicles and designed in such a way as to allow
contacts and small shocks to occur without causing any serious damage.

Part 581

Part 581 specifies requirements to minimise damage to the front and rear ends of
passenger cars in low-speed collisions. It is mandatory in the US.

9.1.3.2 BUMPER TESTING

This section compares the EU and US legislations for low speed damage bumper tests.

Scope

EU: Regulation 42 is not mandatory; it is not included in the EU framework directive.

USA: Passenger vehicles excluding multipurpose passenger vehicles and low speed
vehicles.

Test configurations

The EU UN Regulation 42 impact device consists of hardened steel with dimensions as

shown in Figure 83.

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Figure 83: Impact device for US Part 581 bumper standard and UN Regulation 42.

Two longitudinal tests to both the front and rear of the vehicle are performed.

 The first test location is a free choice,

 The second location has to be at least 300mm away from the initial test point,
A corner impact is also executed to both the front and rear of the vehicle. The impact
areas for this test are noted in Table 42.

Post impact vehicle conditions are noted and include ensuring that the lighting and
signalling all work correctly and that the doors, boot lid and bonnet open normally.
Further requirements include confirming that side doors do not open under impact, that
there is no damage or displacement to the exhaust system which prevents normal
functioning, and that propulsion, suspension, steering and braking systems remain
operating normally.

The US Part 581 test impactor is formed of a pendulum with an impact ridge constructed
of hardened steel, identical as for UN Regulation 42. Two frontal longitudinal tests and
one corner test and are performed on the vehicle. One impact longitudinally rearwards of
the vehicle into a fixed collision barrier is also conducted. After testing, certain areas are
checked against set limits on the vehicle to ensure that it has met FMVSS 581 test
requirements. Fuel spillage and the vehicle condition are both examined. The aspects of
the vehicle which are checked are similar to those discussed in Regulation 42. The test
procedures and requirements are detailed further in Annex 5, Table 71.

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 Table 14: Comparison of EU and US bumper test configurations.

EU USA

(Regulation 42) (Part 581)

Frontal longitudinal test

Impact height: 445 mm Impact height: Between 16” and 20”

First impact location: Free choice Impact locations: Must be 2” apart vertically.
Second impact location: 300mm away from
first. Impact speed:
Impact speed: 2.5mph
4(+0.25, -0)km/h
Corner test - front and rear

Front corner impact: Front corner impact:

Rear corner impact: Rear corner impact:

Impact height: 445 mm First impact height: 20”

Second impact height: Between 16” and 20”

Impactor angle: Impactor angle:

60±5° to longitudinal plane of vehicle 60° to longitudinal plane of vehicle.
Impact speed: Impact speed:
2.5(+0.1, -0)km/h 1.5mph
Rear longitudinal test

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EU USA

(Regulation 42) (Part 581)

First impact location: Free choice Impact height: Between 16” and 20”
Second impact location: 300m away from Impact locations: Must be 2” apart vertically.
first. Pendulum impact:
2.5mph

No fixed collision barrier impact. Fixed collision barrier impact:

2.5mph

Reference: Annex 3, S2.3.1, S2.4, S 2.7, S2.8. Reference: S6, S6(b)(1), S7 Figure 1, S7
Annex 4 S2.7.5, S2.8.4. Figure 2.

Main differences are:

 Bumper testing is mandatory in the USA but is not required in the EU

(Regulation 42 not included in framework Directive).
o Optional testing in the EU does not measure fuel leakage post impact.

Other differences include:

 Impact conditions
o Impactor should be of the pendulum type in the USA but may be a
pendulum or moving barrier in the EU.
o In the USA an impact of the vehicle into a fixed collision barrier is
required as well as mobile barrier tests.
o Minor differences in restrictions for impact positions.
 Vehicle conditions
o The vehicle mass in the EU differs to that required in the USA. In the
USA the vehicle is tested at UVW, whereas in the EU one impact is
conducted at unladen running order mass and one at laden mass.
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 o There are no specifications for fluid levels in Part 581 bumper test.
o The USA regulation allows no damage to the vehicle bumper other than
parts that were in direct contact with the impact ridge during impact.
o The USA regulation requires no leakage from the fuel system post-impact.

9.1.4 SUMMARY OF NOTABLE DIFFERENCES

Rear impact testing

 Testing is mandatory in the US on passenger cars. In the EU, the specific rear
impact regulation (UN Reg 32) is not part of the framework directive, whilst the
rear impact testing in the fuel tanks regulation (UN Reg 34) is optional (although
pending 03 series amendments make the rear impact test mandatory).
 The nature of the test impactor in each region differs significantly. In the EU
regulations a full width, moving or pendulum style impactor of rigid steel
construction is used. In the USA, the same moving deformable barrier as is used
in side impact testing is used, but with a smaller ground clearance.
 Impact speed in the US is significantly higher at 80km/h, compared to between 35
and 38km/h in the EU (although the impact speed is increased to 48-52 km/h in
proposed R.34 03 series amendments).
 In the EU the vehicle undergoes a full width impact whereas in the USA the
impact is carried out with a 70% overlap.
 Vehicle is tested at unladen mass in the EU but in the US the tested vehicle must
carry its rated cargo capacity and 50th percentile dummies in front outboard
seating positions.
 Vehicle is tested with transmission in neutral and parking brake disengaged in the
USA but gears and brakes may be used during EU testing.
 USA regulation has slightly stricter limits on post-crash fuel system leakage than
UN Reg 34 (28g/min compared to 30g/min as well as a limit on total leakage after
testing).
 EU regulations have requirements for vehicle condition post-impact but USA
does not.

Head restraints
 Rear outboard seats with head restraints must be tested in the US as well as front
outboard seats. In the EU testing of seats other than front outboard is optional.
 In the energy absorption test, EU regulations require the restraint to be tested in
the most unfavourable position but the USA regulation allows for testing in any
position.
 No energy absorption testing to the rear of head restraints in the US.
 No height retention testing in the EU but height retention test following the same
procedure as the USA is included in GTR 7, which will be transposed into UN
Reg 17.
 No dynamic testing in the EU but like height retention, dynamic testing is
included in GTR 7 following same procedure as in the US.
 The US and the EU do not provide protection for smaller occupants.

Bumpers

 Bumper testing is mandatory in the US but is not required in the EU (Regulation

42 not included in framework Directive).
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 o Optional testing in the EU does not measure fuel leakage post impact.

9.2 CONSUMER TESTING

This section describes the head restraint tests for whiplash performed in the EU and US
to provide safety information for consumers. A summary of the tests performed are given
in Table 15_Hlk419902062. The tests are described and compared in the sections below.
Their effects on the legislation and in particular the notable differences detailed in the
section above are discussed in terms of:

 Legislative differences that are effectively fulfilled.

 Effective enhancement of the legislation.

Table 15: Rear impact tests for consumer information in the EU and the US.

Item / Test Europe USA

1 Head Restraints Euro NCAP – Neck Injury IIHS – Head Restraints
Protection

9.2.1 HEAD RESTRAINTS

Head restraint tests are conducted in both regions by Euro NCAP and IIHS as part of
respective consumer testing programmes. Euro NCAP introduced a rear impact test from
2009 to assess protection against whiplash. IIHS introduced a rear impact test in 2004 to
evaluate head restraints. The tests utilised in each region are somewhat similar however
there are several differences in detail. The same test dummy, BioRID IIg, is applicable in
both tests, although in the Euro NCAP test an additional ‘mould 2’ jacket is used. The
pulse in each test differs also. The IIHS test only provides one single test pulse, whereas
the Euro NCAP test uses three different pulses (see Table 16). These increase in severity.
The main differences between these tests are the limits for both the dynamic and static
assessments. The dynamic assessment in the Euro NCAP test applies limits to NIC, Nkm,
rebound velocity, upper neck shear, upper neck tension, TI acceleration and T-HRC. The
static assessment of the head restraint outlines two performance limits, higher and lower,
that include the height and backset of the head restraint. In the USA, the dynamic
assessment used in the IIHS only sets limits for upper neck shear, upper neck tension, TI
acceleration and T-HRC. The limits for the static assessment are categorised into four
groups (poor, marginal, acceptable and good), and similarly include the height and
backset of the head restraint.

Table 16: Comparison of test configurations for Euro NCAP (EU) and IIHS
(USA) head restraint tests for consumer information.

EU USA

(Euro NCAP) (IIHS)

Head restraint test

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EU USA

(Euro NCAP) (IIHS)

BELTED BELTED
Dummy: BioRID IIg Dummy: BioRID IIg (+ ‘mould 2’ jacket)

Low severity pulse: Single test pulse:

 Velocity change: 16.10±0.8km/h  Accel. at 0ms: -0.25-0.5g
 Mean accel.: 42.35±4.5m/s²  Accel. at 27ms: 9.5-10.5g
 Max accel.: 5±0.5g  Time that accel. reaches 0g: 88-94ms
Medium severity pulse:  Velocity change: 14.8-16.2km/h
 Velocity change: 15.65±0.8km/h
 Mean accel.: 47.85±4m/s²
High severity pulse:
 Velocity change: 24.45±1.2km/h
 Max accel.: 7.5±0.75g

Both the Euro NCAP and IIHS test are based on the dummy injury criteria measurements.
For Euro NCAP assessment the vehicle’s performance is evaluated using dummy
measurements for each body region. Points are awarded based on how the dummy injury
criteria compare with the upper and lower performance limits, taking the criterion that
gives the lowest score. The points are calculated to create an overall score for adult
protection. Modifiers are also applied meaning that points may be deducted for
undesirable performance.

For IIHS, the assessment is also based on dummy injury criteria measurements divided
into four levels using upper and lower performance limits for each body region. A
number of points are awarded based on how the dummy injury criteria compare with
upper and lower performance limits taking the criterion that gives the lowest score. The
points are summed to create an overall score for adult protection.

9.3 INFLUENCE OF CONSUMER TESTING ON LEGISLATIVE NOTABLE DIFFERENCES

 Legislative differences that are addressed

o The Euro NCAP test fulfils the following legislative differences for head
restraint testing:
 No dynamic testing in the EU.
 EU regulations fail to outline dynamic testing for head
restraints. Dynamic testing is conducted by Euro NCAP.
 In the EU testing of seats other than front outboard is optional.
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  The EU regulation states that it is only mandatory for all
outboard front seats to comply with the requirements, and
that other seats with head restraints may be optionally
approved. The Euro NCAP test includes both front and
rear seats.
 Effective enhancement of the legislation
o Euro NCAP effectively enhances the effect of UN Regulations 17 and 25
legislative tests in that it encourages vehicles to have a safety
performance considerably greater than the minimum requirements.
o The seat positioning in the Euro NCAP test is set to a more unfavourable
position than that used in regulation testing, creating a more stringent test
than those used in Regulations 17 and 25.
o The IIHS head restraint test effectively improves the result of the USA’s
FMVSS 202 in that it encourages vehicles to exceed the minimum safety
performance requirements.
o The dynamic performance requirements within FMVSS 202 only set
limits for HIC and the angular rotation between head and torso of the test
dummy. Consumer testing measures and records a wider range of injury
criteria.
o The seat positioning in the IIHS test is similarly set to a more
unfavourable position than that used in regulation testing, again forming a
harsher test than that conducted in FMVSS 202.

9.4 DISCUSSION OF REAL WORLD IMPLICATIONS

The US has mandatory legislative rear impact, head restraint and bumper testing
requirements. The EU currently has optional legislation regarding rear impact tests and a
greater number of optional components for head restraints. The main effect of this
difference may be hypothesised to result in a greater occurrence of rear impact casualties
and more frequent severe injuries in key body regions such as the neck (e.g. whiplash) in
the EU.

The EU does not carry out bumper testing but the focus of this test is on vehicle damage,
rather than injury protection. The requirement for a stiffer front bumper in the US may
have implications for pedestrian protection performance.

The regulations in US and EU have evolved different approaches with respect to fire risk
and fuel tank integrity. In the US, this is addressed with an 80km/h rear impact test. In
the EU, mandatory requirements for the fuel tank are at the component level, with further
mandatory requirements for installation on the vehicle to reduce risk of leaks/fires in rear
impact. The proposed 03 series amendments to the EU rear impact test (in Regulation 34)
seek to make this test mandatory and also to increase the test speed to 48-52 km/h.
Following this, future fire risk protection could therefore be considered comparable
between the regions.

There are consumer tests for head restraints in both the US and the EU. These
assessments are conducted by IIHS and Euro NCAP, and focus on the prevention of
whiplash injury. Specific protection for occupants is encouraged by consumer testing in
both regions. However, consumer testing is limited and does not address rear impact
testing or bumper testing. Whilst real world expectations are for a reduction in casualties,
vehicle damage and fuel leakage due to safety enhancements, these issues will still occur
due to the limitations of regulations and consumer assessments.

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9.5 INCLUDED ARTICLES

The flow of articles through the literature review selection process is illustrated by a flow
diagram in Figure 1 below. There were 91 citations from the original search of databases,
of which 36 were excluded based on the a priori criteria. Of the 36 articles selected for
full review, 18, met the selection criteria and were included for full article evaluation.

Number of articles identified through Number of articles identified through

database searching other sources
(n = 87) (n = 4)

Number of articles after duplicates

removed
(n = 88)

Number of articles screened for Number of articles

relevance excluded
(n = 52) (n = 36)

Number of articles assessed for Excluded articles (n = 18)

eligibility Not highly relevant to RQ: 18
(n = 36) Low quality methodology:
Failed to meet selection criteria:

Number of studies included for

evidence evaluation
(n = 18)

RQ1 RQ2 RQ3

(n=2) (n=4) (n=0)

Figure 1: Flow diagram illustrating the flow of articles through the selection process.

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9.5.1 REAR IMPACT TESTING

 No mandatory test in the EU (but note that 03 series amendments to

Regulation 34 are proposed which would make the rear impact test
mandatory).
 Impact speed in the USA is significantly higher at 80km/h, compared to
between 35 and 38km/h in the EU (but note 03 series amendments seek to
increase test speed to 48-52 km/h).
 In the EU the vehicle undergoes a full width impact whereas in the USA the
impact is carried out with a 70% overlap.
 In the EU regulations a full width, moving or pendulum style impactor of
rigid steel construction is used. In the USA, the same moving deformable
barrier as used in side impact testing is used, but with a smaller ground
clearance.
 Vehicle is tested at unladen mass in the EU but in the USA the tested vehicle
must carry its rated cargo capacity and 50th percentile dummies in the front
outboard seating positions.
 Vehicle is tested with transmission in neutral and parking brake disengaged
in the USA, but gears and brakes may be used during EU testing.
 No test in the USA that focuses on the structure of the vehicle after a rear
impact crash.

A hypothesized outcome of these differences could be a greater proportion of casualties

and fuel leaks / fires in rear impacts in the EU compared to the US due to the lack of rear
impact testing.

The research questions used to perform the literature search to address these notable
differences were:

RQ1: Comparing rear impact accidents in the US and EU is there a difference in

casualty rate per km?

RQ2: For rear impact accidents in the US and EU, is there a difference in the
proportion of accidents with fuel leaks and / or fires?

On evaluation of the literature, no studies (from eighteen full article reviews) were found
that directly compared the differences in the casualty rates per vehicle km for rear impact
accidents in the US and EU. No studies were found to directly compare the proportion of
accidents with fires in the EU and US, either.

There have been a number of cases where the frequency of vehicle fires has received a
lot of media attention. In 2005, Ford introduced automatic extinguishers to their Crown
Victoria Police Interceptor line due to the concern over the number of fire-related
fatalities associated with high-speed rear impacts in stationary Crown Victoria vehicles
(Beall, 2011).

NHTSA are currently investigating Chrysler due to a number of incidents where several
of their Jeep models have caught fire following a rear impact. It is reported that, in its
current location, the fuel tank is highly vulnerable to being punctured in a rear impact
event (George, 2013). Federal regulators have linked 51 deaths to fire due to rear-end
crashes involving Jeep Grand Cherokees (1993 to 1998 model year) and Jeep Liberty
(model year 2002 to 2007) SUVs (Rogers, 2014). It is not yet clear whether the apparent
dangers posed by the fuel system design on these vehicles is related to a limitation of the
193
test procedure or due to the implementation of the test procedure within the self-
certification process used in the US. It should be noted that the EU have mandatory
requirements for the installation of fuel tanks on the vehicle.

One of the most detailed sources of fatality rates from vehicle fire data was collected by
the Swedish Transport Administration between 1998 and 2008. In-depth data was
recorded from fatal crashes involving passenger cars, SUVs, vans and minibuses.
Viklund et al. (2013) summarised the findings of the study relevant to vehicle fires. In
total, 181 fire related deaths caused by 133 separate road crashes were recorded
nationally, which accounted for 5% of all road fatalities that occurred during this period.
Fire and smoke were ruled as the primary cause of death in 55 cases. The source of the
fire was not identified for 61 of the 133 cases. However, of the remaining 72 cases, 16
fires were found to originate from the fuel tank. Two fuel tank fires were found to be
caused by rear end impacts.

Based on the literature identified during this study, the literature identified does not
provide a conclusive view as to whether the risk of fires is better controlled in US or EU.
The regulations in these regions have evolved according to different philosophies, with
US using a rear impact test and EU adopting component testing and installation
requirements. The optional rear impact test in Regulation 34 is proposed to be made
mandatory in the 03 series amendments, at the same time as increasing the test speed to
48-52km/h, making the level protection afforded against fire risks comparable between
US and EU.

On further examination of the literature, two studies collated epidemiological data

documenting rear impact accident statistics. These articles (comprised of two accident
databases: one from Finland and one from Great Britain) analysed the casualty rate of
rear impact accidents. No studies were identified which provided similar data for rear
impact incidents in the US, meaning that no direct comparison could be carried out.
However, some US rear impact statistics, provided by IIHS, were analysed. It is evident
that there is a wide variation between the studies extracting real-world accident data from
either region. These differences, between measures such as accident analysis periods,
selection criteria (for occupants, vehicles and accidents) and statistical analysis methods,
therefore makes the comparison of trends within these studies difficult.

Walter (2006) studied un-survivable accidents involving cars in Great Britain using the
CCIS database. The database contained information for 21,797 car occupants involved in
accidents between the years 1994 and 2004. It is important to note that this figure is
representative of the incidents the CCIS investigation team attended. Of these occupants,
621 (3%) were belted rear impact casualties. Of the accidents attended by the CCIS team,
it is calculated that approximately 62 belted rear impact casualties occur per year.
Kelkka et al. (2009) conducted a study which focused on fatal accidents on Finnish
motorways. In Finland, between the years of 2002 and 2006, a total of 1900 people died
in traffic accidents in accordance with data collated by investigation teams. Of these, 22
(approximately 1%) were a result of rear impact collisions. This is calculated as
approximately 4 fatalities per year. Although differences are evident in the data, it can be
noted that the proportion of rear impact casualties and/or fatalities is similar is terms of
percentage. The percentage is relatively low in comparison to other forms of impact
(frontal for example) in both studies.

In the US, the IIHS records data regarding traffic accidents. The number (and percentage
of occupants in each vehicle type) of occupant deaths in 2013 which were caused by rear
impacts are listed in Table 17. The vehicles included in this data are cars, minivans,
194
 pickups, SUVs and cargo/large passenger vans. As pick-ups and SUVs have become
more popular, the distribution of vehicle types in fatal crashes has changed. Car occupant
deaths have declined 51% since 1975 (compared with 2013 data), while pick-up occupant
deaths have risen 15% and SUV occupant deaths are nearly 9 times as high.

Table 17: Passenger vehicle occupant deaths in single and multiple vehicle crashes by
rear impact (IIHS, 2013).

Vehicle type Number (% of deaths in each

vehicle type)

Car occupants 688 (5%)

Pick-up occupants 152 (4%)

SUV occupants 206 (5%)

Total passenger car occupants 1,066 (5%)

As noted, it is difficult to compare real-life data as there are many differences to

overcome. For example, the US is considerably larger than Great Britain and Finland,
and the time scale in which the data was collected is substantially different.

Most crash tests are conducted at low speeds compared with highway traffic. In the EU,
testing is conducted at speeds between 35 and 38km/h. The speed limit for cars in the EU
is listed in Table 19. The higher speed test of 38km/h is considerably lower than the
majority of speed limits in Europe, except for Gibraltar. In the US, speed limits are set by
each state. A general overview is noted in Table 18. Rear impact testing in the US is
conducted at a significantly higher speed than done so in the EU. Testing is conducted at
a speed of 80km/h. Although testing does not coincide with the highest speeds attained, it
does reach the top end of the lower speed spectrum.

Table 18: General overview of speed limits in the EU and US.

Road Type EU USA

km/h km/h

Built-up area/town 40 – 60 40 - 88
(Gibraltar: 30)

Outside built-up area/dual 50 - 117 105 - 129

carriageway

Motorway/highway 88 - 129 105 - 129

The data recorded in the EU rear impact tests will be lower than that endured in real life
accidents, both low and high speed (‘low speed’ estimated at 40km/h and ‘high’ speed
estimated at 129km/h). US testing will provide data that is lower than high speed
accidents (‘low’ speed estimated at 40km/h and ‘high’ speed estimated at 129km/h). For
low speed accidents, US testing will provide beneficial information. As the legislative
195
US test is more stringent than that performed in the EU, there could be implications if an
EU vehicle was to be sold in the US. However, there are mandatory requirements for the
fuel tank

9.5.2 HEAD RESTRAINT TESTING

 No energy absorption testing to the rear of head restraints in the USA.

o EU regulations for the energy absorption test require the restraint to
be tested in the most unfavourable position, but the USA regulation
allows for testing in any position.
o Consumer testing conducted by both EuroNCAP and IIHS, both
position seats in an unfavourable position.
 No height retention testing in the EU at this moment.
 No dynamic testing in the EU at this moment.
o Dynamic testing is conducted by Euro NCAP.
o Dynamic testing conducted by IIHS measures and records a wider
range of injury criteria.
 The US and the EU do not provide protection for smaller occupants.
 Rear outboard seats with head restraints must be tested in the USA as well as
front outboard seats. In the EU testing of seats other than front outboard is
optional.
o The Euro NCAP test includes both front and rear seats.

The research question used to perform the literature search to address these notable
differences was:

RQ3: For rear impact accidents in the US and EU, is there a difference in the
proportion of accidents with whiplash injury?

These legislative differences were considered together as they are highly related. Based
on the notable differences identified above, it may be hypothesised that there would be a
higher proportion of accidents in the EU where occupants suffer with whiplash injury due
to the lack of legislative and consumer height retention testing.

On review of the literature, no studies (from eighteen full article reviews) were found to
directly compare the differences in the proportion of rear impact accidents with whiplash
injury in the US and EU. On further examination, several studies collated
epidemiological data documenting the real-world implications of rear impacts. Tomasch
et al. determined that seats with whiplash protection systems have shown to vary
considerably in their real world protection performances (Tomasch et al., 2014). Over the
past six decades, much has been done to improve the understanding of specific whiplash
injury mechanisms, patient treatment protocols, and vehicle bumper, seat and head
restraint designs. Yet, even with the voluminous amount of research in the engineering
and medical fields, whiplash injuries in rear crashes have increased since the 1960s
(Kahane, 1982).

It is again evident, as noted for the first research question, that there is a wide disparity
between the studies extracting real-world accident data. Moreover, it is difficult to
compare ‘whiplash’ studies due to regions defining and measuring the term differently,
and to fraudulent claims. A number of studies using claims statistics originating from the
insurance industry indicate that low-speed rear impacts are the cause of a large number of

196
whiplash injuries in the UK, Europe and world-wide. Whiplash injuries have been
estimated to have high costs:

 USA - US$10 billion

 European Union - €10 billion

The word whiplash describes a dynamic movement, but has also become a definition of a
soft tissue injury in the neck. The injury occurs in the fast whiplash motions of the head
in both rear-end and frontal impacts but also in lateral impacts and rollovers. The
symptoms might be several, pain and stiffness in the neck, numbness, headache etc.
These symptoms may occur directly after the crash, within a couple of hours or within
some days after the crash. Whiplash injuries have been classified in a number of ways,
including AIS (all whiplash injuries are rated as AIS 1) and the Quebec Task Force Scale
(WAD 0 to WAD 4).

Table 439: Clinical classification of Whiplash-Associated Disorders by the Quebec Task

Force

Grade Clinical Presentation

0 No complaint about the neck, no physical signs.

I Neck complaint of pain, stiffness, or tenderness.

No physical signs.

II Neck complaint and musculoskeletal signs.

Decreased range of motion or point tenderness.

III Neck complaint and neurological signs.

Decreased or absent tendon reflexes, weakness, and sensory deficits.

IV Neck complaint and fracture or dislocation.

Many publications differentiate between short-term and long-term whiplash symptoms,

and the costs associated with the two may be quite different. Long-term may be defined
as symptoms lasting longer than one month up to symptoms lasting longer than two years
or more. The difference is often due to the differing needs of data owners or researchers.
For instance, the definition of long-term may be based on the length of clinical evaluation
that must be completed before an insurance claim can be processed, whereas it may be
sufficient to use a shorter duration for some research programmes.

For example, in an analysis by Folksam, the occupants were divided in two groups based
on symptom duration and frequency:

 Those not reporting any symptoms and those with symptoms for less than six
months.
 Those with symptoms for more than 6 months and where the symptoms occurred
at least once a week.

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By selecting long-lasting symptoms as being required to qualify as a definite injury for
study, it is usually implied that the claimant has received clinical evaluation of their
injury and that they could have attended several appointments to review their case.
Alternatively, shorter-term injury claims are more reliant on the opinion of the person
making the claim and perhaps an initial review of their symptoms. As a specific injury
and cause of the symptoms can be difficult to diagnose, short-term claims are more prone
to fraudulent claims and are, to a greater extent than long-term injuries, subject to the
‘claims culture’ in the area. For instance, the incidence of whiplash associated disorders
in France was traditionally extremely low, as there was no culture of claiming
compensation for minor neck injuries. By studying injuries with longer-term symptoms
only, fewer transient and fraudulent cases may be included but, it will exclude a
component of the full burden to society associated with whiplash associated disorders.

It is due to these difficulties that a conclusion cannot be reached regarding whiplash

injuries caused by rear impact crashes in the EU and US. Further specific accident
analysis is required to inform on any differences in this area.

9.5.3 BUMPER TESTING

 Bumper testing in the USA is mandatory but the EU it is optional, (it is not
included in the framework directive).
o Optional testing in the EU does not measure fuel leakage post impact.

Consultation with vehicle manufacturers revealed that the main real-world issue
regarding the mandatory low speed bumper impact requirements in the US is the conflict
with the pedestrian leg impact requirements in the EU (see Section 10 below). Explained
simply, a stiff bumper, which is not damaged easily, is required to meet the bumper
impact requirements whereas a soft bumper which deforms easily is required to ensure
impact loads are low enough to meet the pedestrian leg impact requirements. Because
there is no legislation for pedestrian impact protection in the US, cars sold in the US have
a bumper system that meets the US low speed bumper requirements and not the EU
pedestrian leg impact requirements and vice-versa for cars sold in the EU. This is even
the case for ‘world’ cars sold in both regions. The reason for this is that although it is
possible to design a bumper system to meet both requirements, it would cost significantly
more and most likely involve an increase in the frontal length of the vehicle, which is
undesirable from a packaging point of view.

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10. PEDESTRIAN

10.1 COMPARISON OF EU REGULATIONS AND US STANDARDS

The current type-approval regulation in force in Europe is Regulation (EC) No. 78/2009
which sets out the minimum pedestrian protection requirements for M1 vehicles in the
form of tests and minimum performance criteria. Regulation (EC) No. 631/2009 provides
detailed test procedures for each test which must be carried out to gain approval to
Regulation 78/2009. Depending on the date of approval and the vehicle mass, vehicles
must gain a ‘Type A’ or a ‘Type B’ approval which correspond to the stages of
development of the Regulation. A ‘Type B’ approval was introduced later to the
European requirements as an update or second phase to approval and contains more
stringent minimum performance criteria than the ‘Type A’ approval. Both types are
described because the change in requirements happens in the near future, although
currently only Type A approval is required. In all cases, the supplementary fitment of a
Braking-Assist System is mandatory as part of the EU requirements.

All new M1 vehicle types must gain ‘Type A’ approval:

 From February 2013 for vehicles that weigh less than 2.5 tonnes
 From February 2015 for vehicles that weigh more than 2.5 tonnes

All new M1 vehicles must gain ‘Type B’ approval:

 From February 2018 for vehicles that weigh less than 2.5 tonnes
 From August 2019 for vehicles that weigh more than 2.5 tonnes

Other pedestrian protection regulations applicable to European vehicles also exist.

UN Regulation No. 127, (00 Series) has similar approval requirements to (EC) No.
78/2009, and is already applicable in the European Union as an alternative to EC 78/2009.
The 01 Series of amendments to this regulation have entered force since January 2015
and represent an optional alternative to EC 78/2009 testing for type approvals in Europe.
Also, under the 1998 Agreement, the European Union has also given final notification of
their intention to use the transposition of GTR No. 9 (Pedestrian Safety), as contained
within UN Regulation No. 127 (01 Series). Braking-Assist System fitment is still
compulsory under the EU rules, parallel to the equivalent UN Regulation.

In the United States, there is currently no legislation in force addressing the protection of
pedestrians. It should be noted that the US is one of the countries that contributed to the
development of GTR No. 9, but this has not yet been implemented in US legislation.
Currently, the US has only provided the first Status report. However, it seems likely that
GTR9 will become part of US legislation in the future.

Since the US is not one of the signatories to the 1958 agreement, if the country signs up
to GTR No. 9, (EC) No. 78/2009, UN Regulation No. 127 and the GTR must remain
identical in order to achieve harmonisation. Table 44 summarises the current situation for
pedestrian safety legislation in both regions.

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Table 44: Description of the current pedestrian safety legislation in force in both regions

No. Item EU USA

Regulatory Description Federal Description
Act (Framework Standard
Directive)
1 Pedestrian (EC) No. Pedestrian None GTR No. 9 not
protection 78/2009 protection transposed into US
legislation yet (last
GTR No. 9 Pedestrian safety notification
14.11.13, waiting
UN Pedestrian safety for completion of
Regulation performance phase 2 to evaluate
No. 127 alternative leg test
device)

Table 45 shows the tests required and minimum performance criteria specified by current
legislation. Impactors and test speeds are identical for each set of tests.

Table 45: Comparison of performance for current type approval tests within Regulation
(EC) No. 78/2009, UN Regulation No. 127 and GTR No. 9 (prior to the first series of
amendments of UN Regulation No. 127and prior to phase 2 of GTR No. 9)

Type-approval (EC) No. 78/2009 (EC) No. 78/2009 UN Regulation

Requirements Type “A” Type “B” No. 127 and GTR
Approval Approval No. 9
Legform to bumper test
Note: This can be either a lower legform to bumper test or an upper bumper to legform
test depending on the height of the bumper. All test procedures and impactors are
identical.
Maximum knee bending 21º 19º 19º
angle
Maximum dynamic knee 6.0 mm 6.0 mm 6.0 mm
shearing
Acceleration measured 200 g 170 g 170 g
at upper end of the tibia
Upper legform to bumper test

Instantaneous sum of 7.5 kN 7.5 kN 7.5 kN

impact forces with
respect to time
Bending moment of test 510 Nm 510 Nm 510 Nm
impactor
Upper legform to bonnet leading edge
Note: This is carried out for monitoring purposes only
Instantaneous sum of 5 kN 5 kN Not included
impact forces with
respect to time
Bending moment of test 300 Nm 300 Nm Not included
impactor
200
Type-approval (EC) No. 78/2009 (EC) No. 78/2009 UN Regulation
Requirements Type “A” Type “B” No. 127 and GTR
Approval Approval No. 9
Child headform to front structure test

HIC/HPC Shall not exceed: Shall not exceed: Shall not exceed:
 1000 over 2/3  1000 over 1/2  1,000 over half
of the bonnet of the child of the child
test area headform test headform test
 2000 for the area area
remaining 1/3  1000 over 2/3  1,000 over two
of the test area of the thirds of the
combined child combined child
and adult and adult
headform test headform test
areas. areas.
 1700 for the  1700 for the
remaining remaining
areas. areas.
 1,000 over two
thirds of the
test area. In
cases where
there is only a
child headform
test area and
1700 for the
remaining
areas.
Adult headform to front structure test

HIC/HPC No test. Shall not exceed: Shall not exceed:

1000 over 1/2 of 1,000 over a
(Adult headform the child headform minimum of one
is projected into test area half of the child
the windscreen headform test area
rather than the 1000 over 2/3 of 1,000 over two
bonnet structure. the combined child thirds of the
Values recorded and adult combined child and
for monitoring headform test adult headform test
purposes only). areas. areas.
1700 for the
1700 for the remaining areas.
remaining areas.

Table 45 shows that the test configurations and corresponding performance requirements
within (EC) No. 78/2009, UN Regulation No. 127 and UN GTR No. 9 are identical. The
only differences include the upper legform to bonnet leading edge test and the adult
headform to windscreen test encountered within (EC) No. 78/2009. However, these are
carried out for monitoring purposes only and do not contribute to the minimum safety
standard of the vehicle.

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Regulation (EC) No. 78/2009 also contains requirements for the pedestrian protection
should a vehicle be equipped with a type-approved brake assist system. This is not
required by UN Regulation No. 127 or GTR No. 9 alone, but mandatory in the context of
EU type-approval. No similar brake assist system requirements appear to exist within US
legislation, although stakeholders indicated that brake assist is incorporated as standard
in most brake systems these days.

All test procedures and impactors are currently identical between each regulation.
However, it is important to note that there is already an amendment to UN Regulation No.
127 (01 Series of amendments) and an upcoming amendment to GTR No. 9 (phase 2 /
Amendment 1) which changes this situation. The amendments will introduce a different
type of legform impactor (the Flexible Pedestrian Legform Impactor or ‘Flex-PLI’).
Once the amendment of each regulation is in force, the testing requirements of each will
remain identical. There are no plans to introduce Flex-PLI impactors to (EC) No.
78/2009.

The Flex-PLI provides different measurements during the lower legform to bumper test.
Instead of recording the knee bending angle, the dynamic knee shearing and acceleration,
the Flex-PLI records dynamic anterior cruciate ligament and posterior cruciate ligament
elongation and the dynamic bending moments at the tibia. The upper legform to bumper
test is not changed by this amendment.

In summary, there are currently three Regulations that are applicable to M1 vehicles in
the EU that address pedestrian safety. However, no equivalent pedestrian safety standards
are currently applicable to vehicles in the US. If the US signed up to GTR No. 9, this
would align pedestrian protection with that currently in force in the EU. Phase 1 of the
GTR does not, however, contain provisions for the updated Flex-PLI impactor of UN
Regulation No. 127 which is expected to become mandatory for pedestrian safety testing
in Europe in the near future. This change is planned for Phase 2 of the GTR, meaning
that Regulation requirements between each region could be out of step for a period of
time. However, if the US adopted GTR No. 9 now, it would be in line with Regulation
(EC) No. 78/2009 and Regulation (EC) No. 631/2009, both of which specify the older
legform impactor.

10.1.1 NOTABLE DIFFERENCES

There are no pedestrian protection requirements in the US. In contrast, the EU has
mandatory performance requirements for the lower leg and head protection and for brake
assist systems.

10.2 CONSUMER TESTING

In addition to the regulatory requirements, pedestrian safety is also tested in consumer

information schemes. As with the situation with regulation, pedestrian protection is not
considered by US consumer testing but is included in the EU.

In the EU, the Euro NCAP pedestrian component involves a pedestrian protection
assessment of a test vehicle. Mirroring the legislative testing, the assessment comprises
several separate tests to provide consumer information regarding the potential risk of
injury to a pedestrian head, upper and lower leg and pelvis. Currently, there are no
equivalent pedestrian consumer tests conducted in the US.

Euro NCAP carries out the following tests:

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 Lower legform to bumper (Figure 84): This test is carried out when the height
of the lower bumper reference line is low. If the reference line is within certain
height limits, the manufacturer may choose between conducting the test with a
lower or upper legform. The Flex-PLI legform impactor is used.

Figure 84: Lower legform to bumper test

 Upper legform to bumper: This test is carried out when the height of the lower
bumper reference line is high.
 Upper legform to Wrap Around Distance (WAD) 775 mm (Figure 85): An
upper legform impactor is propelled at a selected point on the WAD 775mm line.

Figure 85: Upper legform to WAD775mm test

 Child headform to frontal structure (Figure 86): The child headform is used to
test points in the child headform testing zone.
 Adult headform to frontal structure (Figure 86): The adult headform is used to
test points in the adult headform testing zone
 Child headform to bonnet leading edge (Figure 86): This test is carried out
when the bonnet leading edge reference line is located within a certain region.
The child headform impactor is propelled at a selected point. This test does not
affect the pedestrian protection score but if the results achieved are ‘poor’, Euro
NCAP may choose to comment upon this alongside the pedestrian protection
score.

203
 Figure 86: Headform tests

Each test area is awarded a score based on how well the vehicle performs relative to the
lower and higher performance criteria. The score relates to a colour which indicates the
performance of pedestrian protection for that area. The colour scale ranges from red for
poor scoring points to green for points that score well.

Figure 87: Example of the pedestrian protection area colour scoring results

204
10.3 COMPARISON WITH LEGISLATION

10.3.1 EURO NCAP AND LEGISLATION OVERLAP

Euro NCAP pedestrian testing uses similar procedures and impactors as specified by EU
regulations, apart from the fact that the lower legform test has already switched to use the
Flex-PLI impactor. Furthermore, the nature of the Euro NCAP rating scheme means that
performance over and above the minimum requirement within the Regulation is rewarded.

10.3.2 NOTICEABLE DIFFERENCES BETWEEN THE EUROPEAN LEGISLATION AND EURO

NCAP

The following differences can be identified:

 Euro NCAP headform testing procedures include the windscreen and A-pillars in
the test area. In legislation these areas are not included in the testing.
 Euro NCAP includes a child headform to the bonnet leading edge test for
monitoring purposes only. This or any other assessment of the bonnet leading
edge region is no longer contained in the legislative procedures.
 The Euro NCAP lower legform test uses the Flex-PLI impactor whereas the base
Regulations (EC) 78/2009 and Regulation 127 (00 Series) use the EEVC lower
legform impactor. However, Flex-PLI is expected to be adopted in the near future
via Regulation 127 (01 Series).
 For monitoring purposes, Regulation (EC) 78/2009 included an upper legform to
bonnet leading edge test and Euro NCAP contains an upper legform to
WAD775mm test (these have been the same until recently). Minor differences
exist between the two assessments:
o The test locations differ slightly. One tests the bonnet leading edge and
the other tests at the set wrap around distance of 775 mm.
o The mass of the impactors differ slightly. In Euro NCAP the weight is
10.5 kg. In the Regulation the weight is worked out based on the velocity
and impact energy.
o The velocity at impact differs. Euro NCAP uses a velocity of 11.1 m/s.
The velocity in the Regulation is dependent on the shape of the vehicle
and ranges from 5.56 m/s to 11.1 m/s.

10.3.3 EFFECTIVE ENHANCEMENTS TO EUROPEAN LEGISLATION

 Euro NCAP encourages pedestrian protection performance that is in excess of

that required in the legislation. Generally, the Euro NCAP lower limit is aligned
with the regulated minimum requirement and the Euro NCAP upper limit is
substantially more demanding.
 The Euro NCAP upper legform to WAD775mm can be seen to replace the upper
legform to bonnet leading edge test in Regulation (EC) No. 78/2009:
o The upper legform to bonnet leading edge regulatory test used to be
carried out for monitoring purposes only and did not appear to improve
the pedestrian protection performance at this region.

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10.4 DISCUSSION OF REAL-WORLD IMPLICATIONS

The US has no pedestrian requirements, either in legislation or consumer testing. In

contrast, the EU has requirements in both of these areas. The main effect of this
difference may be hypothesised as a greater frequency of pedestrian casualties per
unit of exposure, and more frequent severe injuries in key body regions such as the
head and leg (particularly the knee and lower leg). The rationale for this is that
protection overall, and specific protection for key body regions, is not regulated or
encouraged by consumer testing in the US.

Side benefits may also exist from the pedestrian protection requirements. For
instance, the chest may be protected in some instances by improvements in the
safety of the bonnet. Also, some pedestrian protection provisions may offer safety
benefits for other vulnerable road users.

Whilst the pedestrian protection strategies enforced or encouraged by the testing in

Europe will improve the initial interaction between a car and pedestrian, they are
unlikely to have a substantial influence on secondary impacts (e.g. with the ground).
Therefore, whilst real world expectations are for a reduction in injuries due to
safety improvements, injuries to the head from secondary contacts will still occur
and limit the potential effectiveness of the safety measures seen on cars in the fleet.

10.4.1 LITERATURE REVIEW

• No pedestrian safety regulations in the US.

The research questions used to perform the literature search to address these notable
differences were:

RQ1: Comparing pedestrian casualties [S] in the US and EU [D] is there a

difference in casualty rates per vehicle km [O]?

RQ2: Comparing pedestrian casualties [S] in the US and EU [D] is there a

difference in the distribution of lower leg and knee or upper leg or head injuries [O]?

10.4.1.1 INCLUDED ARTICLES

The flow of articles through the literature review selection process is illustrated by a flow
diagram in Figure 63, below. There were 107 citations retrieved from the original search
of databases, of which 82 were excluded based on the a priori criteria. Of the 23 articles
selected for full review, 14 met the selection criteria and were included for full article
evaluation.

206
 Number of articles identified Number of articles identified
through database searching through other sources
(n=90) (n=17)
Number of articles identified

Number of articles after duplicates removed

(n=105)

Number of articles screened Number of articles excluded

for relevance (n=82)
(n=105)
Number of articles screened

Number of full text articles Excluded articles (n=9):

assessed for eligibility Not highly relevant to RQ: 8
(n=23) Low quality methodology: 1
Failed to meet selection criteria: 0

Number of studies included

for evidence evaluation
(n=14)

RQ1 RQ2
(n=0) (n=14)

Figure 88: Flow diagram illustrating the flow of articles through the selection process.

Vehicles sold in the EU must meet the requirements within EU type-approval legislation
concerning the protection of pedestrians. However, vehicles sold in the US are not
currently required to meet any pedestrian safety requirements. Therefore, an assumption
could be made that a US car permitted on EU roads may present a greater safety risk to
pedestrians, potentially leading to higher severity pedestrian injuries in the event of a
collision in comparison to an EU vehicle. A literature review was carried out with the
aim of identifying any studies which assess the effectiveness of EU regulations at
improving pedestrian safety or that allude to any potential safety implications of allowing
US cars on EU roads.

Various studies were identified that examined the effect of the adoption of GTR No. 9
(phase 1) on pedestrian safety in the US. Mueller et al. analysed 67 pedestrian crashes
that occurred between 2002 and 2006 (Mueller et al., 2012). The study used data from
the Crash Injury Research and Engineering Network (CIREN) database. Each of the
pedestrians had sustained at least one AIS 2+ injury. The sample contained data from
incidents involving both adults and children.

The findings of the study indicated that the adoption of GTR No. 9 in the United States
may not be effective at reducing pedestrian injury severity, since many of the injuries
sustained were outside of the scope of the GTR:

207
  Of the total of 45 head-injuries, 31 pedestrians were struck by a part of the
vehicle that was outside of the areas specified for testing within GTR No. 9.
 Over half of the lower leg fractures were below the height of the vehicle bumper
and below the instrumented portion of the leg impactor. Therefore, the test may
not be sensitive to a significant portion of the leg injuries.
 Fifty-nine out of 67 (88%) pedestrians sustained injuries to body regions that
were not addressed by GTR No. 9.
 One third of the pedestrians sustained pelvic and thigh injuries. Half of those
were attributable to the bonnet leading edge, which is not tested by the GTR.
 The estimated speed of many of the crash events was found to be higher than the
target speed assessed within the GTR tests.

As the testing requirements of the GTR are currently identical to the regulatory
requirements in Europe, Mueller et al.’s work indicates that the safety effect of the EU
pedestrian protection regulation is low. However, the sample size in this study is very
small. The study also recommended the extension of the headform testing zone to include
the windscreen and A-pillars. For European vehicles the windscreen and A-pillars are
included in the area assessed by Euro NCAP, up to a Wrap-Around-Distance of 2.1 m,
although the grid points on these parts are not tested and are assigned a default rating:
green for the windscreen, red for the pillars. However, the pedestrian protection
performance of vehicles within Europe appears to be improved by consumer testing.
However, reliable methods for testing the windscreen and A-pillars, rather than assigning
default results, should be sought if robust solutions are to be found to address such
additional injuries.

The study by Mueller et al. also noted that the use of the Flex-PLI legform would address
the protection needs for a much greater number of the lower leg injuries encountered.
Studies exist which examine the limitations of the EEVC legform that is currently in use:

 Konosu et al. and Takahashi et al. have identified that there is poor correlation
between the EEVC legform impactor acceleration measurement and the incidence
of leg fractures away from the measurement site (Konosu et al., 2009) (Takahashi
et al., 2012).
 Due to the bending mechanism and profile of the leg it may be expected that
fractures occur away from the point of loading by the main bumper component.
The incidence of fractures away from the bumper contact point could be
exacerbated by the inclusion of a stiff low spoiler which can help to attenuate
other measurements made during testing.

A study of large passenger vehicles conducted by Mallory et al. concluded that the front
ends of these vehicles would require modification in order to meet the headform testing
requirements within GTR No. 9 (Mallory et al., 2007). Eighty-eight pedestrian head
impact tests were conducted upon 11 US vehicles using testing zones defined by the
GTR. The following results were found:

 Three of the 11 vehicles passed all headform tests performed.

 Six of the 11 vehicles required design improvements to certain areas to ensure the
HIC results were below 1,700 in the relaxation zone.
 Two of the 11 vehicles required more widespread design changes to reduce the
HIC results to below 1,700 in the relaxation zone and below 1,000 outside the
relaxation zone.

208
Assuming that GTR No. 9 effectively increases pedestrian protection, the results from
this study indicate that the front ends of large US passenger vehicles present a greater
risk of severe head injury than EU vehicles during a pedestrian impact. However, the
number of vehicles tested represented a small sample of the US vehicle fleet. Further
experiments would be required to provide a more conclusive result. Mallory and
Stammen carried out a similar study examining the performance of US vehicle bumper
systems in comparison to the GTR lower leg requirements (Mallory and Stammen, 2009).
Lower legform to bumper tests were conducted on nine US vehicles using the
EEVC/TRL pedestrian lower legform according to test procedures in the GTR proposal.
The results showed that none of the vehicles tested would have passed the GTR testing
requirements:

 Only five of the 39 test locations met the 170 g tibia acceleration limit. Six of the
vehicles exceeded 400g in at least one test location.
 Only the Honda CR-V achieved results below 6 mm in the sheer displacement
limit test for each of the impact locations.
 Three of the nine vehicles did not pass the sheer displacement requirement in any
of the test locations. The other six passed it in at least one impact location.
 The pass requirement for knee bending angle is 19º. Only 20% of the impacts
achieved scores below this. The majority of failing impacts showed bending
angles in excess of 30º.

Mallory and Stammen concluded that relative to GTR requirements, the pedestrian lower
extremity protection offered by US vehicles tested was poor. Assuming that GTR No. 9
effectively increases pedestrian protection, the results from this study indicate that the
front bumper systems of US passenger vehicles present a greater risk of higher severity
pedestrian lower leg injuries compared to EU vehicles.

Mallory et al. carried out a comparison of US and European crash cases (Mallory et al.,
2012). The study compared data from 933 EU pedestrian collisions (occurring between
1999 and 2008) and 549 US pedestrian collisions (occurring between 1994 and 1998).
The study examined the frequency of injury/source combinations for cases only
involving passenger cars. Serious lower extremity injuries from bumper contact occurred
in 43% of seriously injured pedestrian cases in the US PCDS data and 35% of European
GIDAS cases. Lower-extremity bumper injuries also account for more than 20% of
disability in both datasets. Serious head and face injuries from windshield contact occur
in 27% of PCDS and 15% of GIDAS serious injury cases. Head and face injuries from
windscreen contact, upper extremity and thorax injuries from bonnet contact and lower
extremity injuries from bumper contact were found to be more frequent in the US dataset.
Head & face and thorax injuries from the environment were more common in the
European dataset. The results of this paper indicate that the regions of vehicles which are
tested by EU Regulations have a lower incidence of injury, indicating that US vehicles
are more likely to cause serious injury to pedestrians. Also, the distribution of injuries
suggests that protection strategies for the bonnet and bumper are perhaps contributing to
these parts causing fewer injuries in the European cases compared with the US. However,
the difference in age range of the vehicles included within the two datasets means that the
data is not directly comparable and no definitive conclusions may be reached.

No further papers were identified which compared the pedestrian protection

characteristics of cars sold in the EU and the US. A review of papers examining the
distribution of injuries in either region was also carried to identify any differences in
commonly occurring injury types and severities:

209
  In a study of 1,629 pedestrian accidents involving US children, Woods et al.
found that head and lower limb injuries were the most frequent injuries (Woods et
al., 2003). The frequency of pelvic injuries appeared highest in the youngest and
oldest populations.
 Yang et al. analysed 186 pedestrian accident cases obtained from the GIDAS
database (Yang et al., 2005). The head and the lower extremities were the two
most frequently injured body parts for both children and adults. Head injuries
accounted for 56.4% of AIS2+ injuries for children. This was lower for adults
with head injuries accounting for 30.9% of AIS2+ injuries.
 Kramlich et al. studied 1186 pedestrian injuries from the GDV database. They
found occurrences of life-threatening head injuries for all age groups (Kramlich et
al., 2002). Injuries to the chest, upper extremities and pelvis occur primarily in
adults. The head and the lower leg were the 2 most frequently injured body parts
for adults. However, for children it was the head and the upper leg. The finding
related to leg injuries seems to reflect the fact that in most cases the initial contact
will be higher up the leg for a child compared with a taller adult.
 Fredriksson et al. focused on 161 AIS 3+ injured pedestrians from the GIDAS
database (Fredriksson et al., 2010). Of these; 58% sustained severe injuries to the
legs, 43% to the head and 37% to the chest.

Data from both regions showed that the head and the lower leg are the most frequently
inured body regions. No large difference in injury distribution between both regions was
identified. It is important to note the differences in the fleets of the US and Europe. The
US has a higher proportion of large passenger vehicles and SUVs in their fleet than
Europe. This difference in vehicle size may also have safety implications for pedestrians
if larger US vehicles were permitted on EU roads. Papers studying the effect of vehicle
size on pedestrian injury were examined:

 A study by AlEassa et al. compared injuries caused by small passenger cars and
sport utility vehicles (SUV) in the UAE (AlEassa et al., 2012). The authors
examined a small number of pedestrian collision cases (101) which occurred
between April 2006 and October 2007. Of the cases, eighty pedestrians had been
hit by a small passenger car and 21 hit by an SUV. The study found that there was
no statistically significant difference in anatomical distribution of pedestrian
injuries and their injury severity between small vehicles and SUVs. The lower
extremity was the most frequently injured region followed by the head, face and
upper extremity regions.
 Longhitano et al. carried out a similar study using data from the US Pedestrian
Crash Data Study (PCDS) (Longhitano et al., 2005). The study included 174 cars
and 95 LTV pedestrian impacts. The LTV group included light trucks, vans and
sport utility vehicles. The results showed a higher frequency of AIS3+ injuries
associated with LTVs for all body regions. The frequency of the torso region was
2.5 times higher for LTVs than for cars. The torso injury frequency for LTVs was
higher than the lower extremity injury frequency for both car and LTV. However,
for pedestrian accidents involving cars, the lower extremity injury frequency was
higher than the torso injury frequency. The frequency of AIS2+ injuries was
higher for the LTV group for all body regions.

The conclusions drawn from both papers differed greatly. It is possible that the results
found by Longhitano were influenced by the inclusion of light trucks and vans in the
same category as SUV. However, both sample sizes in both studies (particularly in the

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AlEassa et al. study) are too small to draw any definitive conclusions about the effect of
vehicle size on pedestrian safety.

A review of literature examining the correlation between Euro NCAP pedestrian test
results and real-life accident statistics was also carried out:

 Strandroth et al. conducted separate studies examining 1184 cases from the
Swedish Traffic Accident Data Acquisition (STRADA) system between 2003 and
2014 (Strandroth et al., 2011), (Strandroth et al., 2014). One study found that the
injury severity for pedestrians reduced as the pedestrian Euro NCAP score
increased (Strandroth et al., 2014). Pedestrian injury severities recorded for 2-star
vehicles were found to be significantly lower than for 1-star vehicles except for
AIS3+ injuries (Strandroth et al., 2011). The Risk of Permanent Medical
Impairment (RPMI) and Risk of Serious Consequences (RSC) were found to be
lower for higher scoring cars in both studies.
 Pastor examined 7576 cases from German National Accident Records (Pastor,
2013). The study found that each additional point in the Euro NCAP score led to
a reduction in the probability of fatal injury by as much as 2.5%. The reduction of
serious injury probability is about 1.0%. When comparing a vehicle scoring 5
points with a vehicle scoring 22 points, the probability of a pedestrian being
fatally injured in a collision was reduced by 35%. The probability of serious
injuries was reduced by 16%. Pastor concluded that if every car on German roads
achieved a minimum of 22 Euro NCAP points, fatalities could be reduced by 6%.
The number of seriously injured pedestrians could also be reduced by 9%.

The positive correlation between higher scoring Euro NCAP cars and a reduction in
injury severity suggest that pedestrian safety consumer testing may be having a positive
effect on reducing pedestrian injury severity in Europe. It has been shown that some US
vehicles do not meet the requirements of the GTR, which assesses vehicles against the
lower performance limit of Euro NCAP test procedures. Therefore, with regard to these
assessments of existing vehicles, some US vehicles seem to offer less pedestrian
protection in the tested regions than European vehicles; which have to meet a minimum
level of protection as defined in the legislation.

Based on the literature identified during this study, an assumption could be made that US
vehicles present a greater safety risk to pedestrians than EU vehicles. However, many of
the studies are limited by low sample sizes, older vehicle model years assessed, or a
small number of tests carried out. Therefore, the literature identified does not provide a
definitive view as to whether this is the case. Further testing to examine the effectiveness
of the GTR in a real world context and to assess the pedestrian protection performance of
US vehicles would be required to provide a more definitive view. Until that time, the
concern may remain that the US vehicles offer less pedestrian protection than their
European counterparts.

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11. TYRE PRESSURE MONITORING

Tyre pressure monitoring system requirements for the EU and the US are specified in the
regulatory acts and federal standards, respectively, shown in Table 1 below.

No. Item EU USA

Regulatory Description Federal Description
Act (Framework Standard
Directive)
1 Tyre Pressure UN Reg 46E: FMVSS 138 Tire pressure
Monitoring 64.02 Temporary-use monitoring
spare unit, run- systems
flat tyres/system
and tyre pressure
monitoring
system

11.1 BACKGROUND

UN Regulation 64.02

The United Nations Economic Commission for Europe (UN ECE) requirements on tyre
pressure monitoring systems was published on 10th November 2010. The requirements
have been published as a 02 series of amendments to ECE Regulation No. 64, which now
covers temporary use spare wheels and tyres, run flat tyres and tyre pressure monitoring
systems.

The need for agreed ECE requirements on tyre pressure monitoring systems was
generated by the European Union when they published Regulation (EC) No. 661/2009 on
general safety which mandated the fitment of tyre pressure monitoring systems for M1
category vehicles from 1st November 2012 for new types of vehicle. This mandatory
requirement for tyre pressure monitoring systems was justified on the grounds of both
safety and environmental protection, as the loss of pressure in one or more tyres can
affect both the vehicle's handling characteristics and its fuel consumption/CO2 emissions.

The Initial drafting of tyre pressure monitoring requirements was based on the pre-
existing US legal requirements on tyre pressure monitoring systems contained in FMVSS
138.

The final agreed requirements apply to vehicle categories M1 and N1 and allow
Contracting Parties to mandate compliance with these new requirements from 1st
November 2012 for new types of vehicle and from 1st November 2014 for all new
vehicles.

FMVSS 138

In accordance with the TREAD Act, the objective of the standard is to supplement
regular tyre maintenance on the part of drivers by providing a warning system to alert
them when one or more of a vehicle’s tyres become significantly under-inflated.

FMVSS Standard No. 138 was promulgated previously through a final rule published in
the Federal Register on June 5, 2002 (67 FR 38704). It included two compliance options:
212
  a TPMS with a four-tyre, 25-percent under-inflation detection capability or
 a TPMS with a one-tyre, 30-percent under-inflation detection capability).

However, on August 6, 2003, the U.S. Court of Appeals for the Second Circuit (Second
Circuit) issued its opinion in Public Citizen v. Mineta16, which held that the TREAD Act
requires a TPMS capable of detecting when any combination of tyres, up to all four tyres,
is significantly under-inflated. It vacated FMVSS No. 138 and directed the agency to
conduct further rulemaking. This final rule sets requirements for the TPMS standard in a
manner consistent with the Second Circuits opinion. It also responds to numerous public
comments submitted in response to the agencys September 16, 2004 notice of proposed
rulemaking (NPRM) (69 FR 55896) and is still current today.

The rational for implementing this rule is that the under-inflation of tyres increases the
likelihood of many different types of crashes, including those involving:

 skidding and/or loss of control of the vehicle;

 hydroplaning;
 increases in stopping distance;
 flat tyres and blowouts, and
 overloading of the vehicle.

In the TREAD Act of November 1, 2000, Congress required the National Highway
Traffic Safety Administration (NHTSA) to develop a rule requiring all new light vehicles
to be equipped with a warning system to indicate to the operator when a tyre is
significantly underinflated.

In response to this requirement, NHTSA undertook an evaluation of existing OEM and

aftermarket tyre pressure monitoring systems. In this evaluation NHTSA determined the
capabilities of existing technologies and the methods of warning the driver that were
under consideration by system manufacturers. Based on this evaluation, NHTSA
determined the minimum system performance criteria that were technically feasible and
provide the most useful information to the driver for preventing unsafe conditions. The
final rule re-establishes FMVSS No. 138, Tyre Pressure Monitoring Systems, which
requires installation of a tyre pressure monitoring system in light vehicles, thereby
implementing a mandate in the TREAD Act.

11.2 COMPARISON OF EU REGULATIONS AND US STANDARDS

A detailed comparison of UN Regulation 64.02 and US FMVSS 138 is shown in Annex

7, Table 74. There are five main areas of comparison between the UN R.64.02 and US
FMVSS 138, these are:

Applicable vehicles – UN R.64.02 covers M1 <3500kg and N1 ≤3500kg vehicles.

FMVSS 138 applies to a wider range of vehicles, as it has an upper weight limit of
4536kg making it applicable to light trucks and buses.

16
http://openjurist.org/340/f3d/39/public-citizen-inc-v-mineta.

213
Speed range – UN R.64.02 has a defined speed range at which the TPMS must operate
(40km/h or less and up to the maximum vehicle speed), FMVSS 138 has no speed range
stated; however, the test procedure dictates test speeds of 50 km/h to 100km/h.

Tyre pressure detection - UN R.64.02 requires a warning activation within a timeframe

of 10min for rapid deflation (for one tyre) however, it also has a 60min timeframe for
diffusion (for 2 or more tyres) opposed to 20mins for FMVSS 138 under all conditions.

UN R.64.02 has an activation tolerance of 20% below the vehicle manufacturer's

recommended cold inflation pressure as opposed to 25% for FMVSS 138.

UN R.64.02 has two test criteria for low tyre pressure warning, puncture and slow
deflation. These two criteria have a 10min (puncture) and 60min (slow deflation)
warning activation time. FMVSS 138 does not distinguish between puncture and slow
deflation and therefore, only has one activation timeframe, which is 20mins.

Low tyre pressure warning - This section is equivalent for both Standards and the
symbols used by both Standards are comparable. These are:

and

TPMS malfunction – The time taken for the TPMS malfunction to activate in UN
R.64.02 is 10mins. Time limit for activation in FMVSS 138 is greater at 20mins.

The symbols used (same as for low tyre pressure warnings) by both Standards are
comparable. (See above)

All other functions are comparable.

11.2.1 NOTABLE DIFFERENCES

 Warning activation pressure - 20% for UN R.64.02 and 25% for FMVSS 138
(below the vehicle manufacturer's recommended cold inflation pressure) over a
25psi to 70psi range this difference equates to 1.25psi to 3.5psi greater pressure
loss before a warning is activated. Normal pressure loss (diffusion) can be in the
order of 1psi, per month.
 Maximum time taken to activate warnings - 10mins (puncture)/ 60mins
(diffusion) for UN R.64.02 and 20mins for FMVSS 138.

11.2.2 DISCUSSION OF REAL-WORLD IMPLICATIONS

Technology

There are three technologies that are used for tyre pressure monitoring systems for use on
vehicles; these are either direct, indirect or hybrid. For direct technology the system uses
214
pressure sensors and sometimes temperature sensors located within the tyres. The sensors
are either located on internal surface of the wheel rim, an integral part of the valve
assembly or glued to the internal surface of the tyre. For indirect technology, the system
uses the wheel speed and other vehicle sensors to detect tire pressure loss from the tyres.
The hybrid system uses a combination of the two, the pressure sensors are on two of the
vehicles wheels instead of four, and the wheel speed sensors compare the differences in
speed to these wheels to detect a dip in pressure.

Any tyre pressure monitoring system, irrespective of using direct or indirect technology,
will collect information and transmit data from a range of sensors to an on-board
processor. This processor then interprets the sensor signals then activates a warning to
the driver of the vehicle when the pressure in the tyre reaches a pre-set limit. The
warning is given via a warning light with diagram, the vehicle’s instrument panel.

There are many systems of tyre pressure monitoring on the market, both for OEM’s and
aftermarket fitment, the majority using direct technology sensors, as these detect a
pressure loss condition faster and require less maintenance than indirect systems,
however, direct systems can be more expensive. Sensors are manufactured by
international companies such as Schrader, Alligator, Continental, TRW, Pacific, Lear,
Beru/HUF and others.

As indirect systems use existing sensors that also have other functions they are not
readily available as an aftermarket fitment. Manufacturers include NIRA Dynamics,
(who has fully focussed on them) TRW and SRI/DunlopTech.

Main comparisons

When comparing the EU regulatory acts and US and federal standards, there are two
main areas where they differ, namely the maximum amount time the system can take
before it activates a warning when an incident occurs and the percentage deviation from
the cold tyre pressure value before a warning is activated. The top level aims of a tyre
pressure monitoring system are to improve safety and maintain or improve CO2
performance.

Warning activation pressure

UN R.64.02 sets the warning activation pressure at 20% below the manufacturer’s
recommended cold inflation pressure, while FMVSS 138 sets the pressure threshold at 25%
below the manufacturer’s cold inflation pressure. The typical range of tyre pressures for
M1 and N1 vehicles are: M1 25 to 38 psi and N1 30 to 65 psi. FMVSS 138 vehicle
categories are going to be similar, at 20 to 70 psi. Over the whole range the additional
increase in fuel consumption over UN R.64.02 could be in the range of 0.5% to 1.43%
for the limits set in FMVSS 138.

Both UN R.64.02 and FMVSS 138 would achieve similar benefits with UN R.64.02
offering slightly better performance for CO2 saving.

Could we have tighter limits for warning activation? Probably not, if a technology
neutral solution is required, with all parameters/tolerances considered when setting limits.

 Allowing for varying sensor type, manufacturer and specification +/- 2.2psi
 Allowing for the pressure range for tyres the being measured – dependant on
vehicle load – possible 14 psi difference between upper and lower values

215
  Allowing for temperature changes - 1 psi for every 10 deg C change in
temperature - 2 to 4 psi

What are current system specifications? None could be found other than specialist
aftermarket products.

No real up to date research/specifications found, last comparison done in July 2001 by

NHTSA. Specific pieces of work have done by vehicle manufacturers during the
development of UN R.64.02 (Working Party on Brakes and Running Gear (GRRF) -
Informal working group on Tyre Pressure Monitoring (TPM) 2007/8) to review and
improve the limits that originated in FMVSS 138.

Time taken to activate a low tyre pressure warning

R.64.02 has two criteria by which a warning signal must be activated if there is an issue
with one or more of the tyres on a vehicle fitted with a tyre pressure monitoring system
(TPMS), the time limits for these are 10 minutes (for puncture) and 60 minutes (for
diffusion), while FMVSS 138 has only one criterion, covering up to all four tyres and has
a 20 minute time limit to activate a warning signal.

The different activation times quoted within R.64.02 are derived to address the needs of a
tyre pressure monitoring system that is to improve safety and reduce CO2 from vehicles.
This is achieved by having two time values for activation (10 min for a rapid deflation -
puncture) covers the safety issues and (60 minute for a slow deflation – diffusion) the
CO2 saving issues.

FMVSS 138 limits were based on an evaluation by NHTSA on the technology available
at its introduction (Phase-in from Oct 2005 to Sept 2007) with the limiting factor being
the amount of time required by an indirect system to calibrate itself before it is ready to
detect any pressure loss in the tyres, which was at that time between 5 and 20 minutes.
(Early systems using indirect technology reported numerous false warnings of tyre
pressure loss). The time limit is too long for identification of a rapid deflation (puncture)
and too short to identify slow deflation (diffusion).

Is the 5 to 20 minute calibration time still the case for 2nd generation indirect systems?

It would appear that it is similar.

Could we have tighter limits for the time to activate a warning of low pressure?

The answer is possibly, but only if it were made compulsory (not technology neutral) for
all vehicle manufacturers to fit only ‘direct’ technology tyre pressure monitoring systems,
individual vehicles would then have to be configured to take into account vehicle
loads/tyre sizes (adjustable parameters?). Direct technology currently can have
pressure/temperature sensors updating at between 1Hz and 40Hz depending on the
application (general use or race car telemetry).

The system could then have a shorter time period to detect a rapid pressure loss,
increasing the safety benefits and the system would be able to monitor the actual
pressures within each of the tyres to over a longer time period to inform of a slow
deflation issue more accurately enabling optimisation of the CO2 saving benefits.

216
Direct technology appears to be favoured by the mainstream European and U.S vehicle
manufacturers. However this depends on the model and when it was introduced and or
revised.

Overall, when comparing R.64.02 with FMVSS 138 for safety both will give similar
safety performance with a slight benefit towards R.64.02 due to the tighter limit for
activation under a rapid deflation incident and a slightly lower percentage of pressure
loss before activation. When comparing the environmental aspects of R.64.02 and
FMVSS 138, R.64.02 main difference is that the safety and environmental aspects have
been separated, with consideration as to the limits assigned to each aspect, offering a
slightly better long term environmental benefit.

Therefore R.64.02 should be retained and improved on in the future.

TPM systems were never intended to replace regular tire maintenance and the technology
is nowhere near perfect. It is still important to visually inspect tires and check tire
pressure each month to ensure safe driving, maximized fuel efficiency, and decreased
wear on tires.

217
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GLOSSARY

5F 5th percentile Female – typically the smallest stature of car occupant

and ATD considered for vehicle safety applications

50M 50th percentile Male – the average height and weight of car
occupant; the size of ATD most commonly used in vehicle crash
test regulations and consumer information tests

95M 95th percentile Male – typically the largest stature of car occupant
and ATD considered for vehicle safety applications; this size of
ATD is available, but is not used in any legislative or consumer
information crash tests

AIS Abbreviated Injury Scale – an internationally used tool for ranking

injury severity, with injuries given a score of 1 to 6 (minor to
maximal)

ATD Anthropometric Test Device – also known as a crash test dummy

Euro NCAP European New Car Assessment Programme

FMVSS Federal Motor Vehicle Safety Standard

FWDB Full-Width Deformable Barrier – a rigid crash barrier that is at least

as wide as a car (so that the whole width of the front of the car is
loaded by the barrier); the rigid barrier has a deformable element
(typically aluminium honeycomb) in front of it that is intended to
make the test more representative of a car-to-car crash

FWRB Full-Width Rigid Barrier – a rigid crash barrier that is at least as

wide as a car (so that the whole width of the front of the car is
loaded by the barrier); the barrier is entirely non-deformable and
may include a matrix of load cells to measure the vehicle impact
forces

Hybrid III A family of ATDs covering 5F, 50M and 95M sizes, plus a range of
related child dummies

IIHS Insurance Institute for Highway Safety

NCAP New Car Assessment Programme

NHTSA National Highway Traffic Safety Administration – part of the US

231
 Department of Transportation

ODB Off-set Deformable Barrier

OOP Out of Position

R.94 UN Regulation number 94 (frontal off-set impact)

R.95 UN Regulation number 95 (side impact)

R.13x UN Regulation number 13x – currently in draft form, but expected

to receive a number between 130 and 139

UN United Nations

UNECE United Nations Economic Commission for Europe

232
Annex 1 : COMPARISON TABLES FOR EU REGULATIONS AND US STANDARDS – FRONTAL IMPACT

Table 46: Comparison of performance criteria and limits for frontal impact in-position crash tests for the EU and USA. Note that 5th percentile dummy
references and limits for the USA are in square brackets.

Property / Criteria Unit EU USA Comparison

Item Reference Specification Reference Specification /
/ Limit Limit
Dummy
Head HIC15 None F208, S6.2 700 EU use HIC36 whereas US use HIC15.
[5F [700] However, HIC36 of 1000 and HIC15 of 700 are
S15.3.2] broadly equivalent for long duration pulses
HIC36/HPC36 R94, 1000 None which is likely to be the case for vehicles that
S5.2.1.1 meet the requirements. For shorter duration
Acc 3ms g R94, 80 None pulses (< 25 ms) HIC15 is more stringent which
Exceedence S5.2.1.1 is likely to be the case for vehicles close to the
limits (Reference NHTSA (2000). Advanced
Airbags interim final rule:
http://www.nhtsa.gov/Laws+&+Regulations/Air
+Bags Also, EU have additional 3 ms
acceleration criterion.
Neck Fx (shear) kN R94, 3.1 at 0 ms F208, S6.6 None The neck injury criteria and limits were similar
S5.2.1.2 1.5 at 25-35 [5F for R94 and F208 (sled test) until the USA
ms S15.3.6] introduced the Nij criterion as part of the
1.1 at >= 45 changes for the ‘advanced airbags’ interim final
ms rule (NHTSA 2000). Nij was seen as an
Fz (tension) kN R94, 3.3 at 0 ms 4.17 improvement over the previous separate limits
S5.2.1.2 2.9 at 35 ms [2.62] because it accounts for the superposition of loads
1.1 at >= 60 and moments, and the additive effects on injury
ms risk. Also, specific limits were also specified for
Fz kN F208, S6.6 4 tension / compression to independently control
Property / Criteria Unit EU USA Comparison
Item Reference Specification Reference Specification /
/ Limit Limit
(compression) [5F [2.52] these potentially injurious loading modes. In
S15.3.6] summary, the current USA F208 criteria and
Mocy (flexion Nm R94, 57 None limits should be improved and slightly more
or extension) S5.2.1.3 stringent than the EU R94 ones.
Nij 1 (4)
Chest Deflection mm R94, 50 F208, S6.4 63 Both EU and US assess chest deflection, but EU
S5.2.1.4 [5F [52] has more stringent performance limit. The EU
S15.3.4] assesses chest VC but not chest acceleration and
Viscous m/s R94, 1 None vice-versa for the US.
Criterion (VC) S5.2.1.5
Acc 3ms None F208, S6.3 60
Exceedence [5F [60]
S15.3.3]
Femur Fz kN R94, 9.07 at 0 ms F208, S6.5 10 Same criterion, but EU has slightly more
(compression) S5.2.1.6 7.58 at >10 [5F [6.805] stringent performance limit
ms S15.3.5]

Knee Displacement mm R94, 15 None No assessment of knee in US

(shear) S5.2.1.9
Tibia Tibia Index R94, 1.3 None No assessment of lower leg (tibia) in US
S5.2.1.8
Fz kN R94, 8 None
(compression) S5.2.1.7
Vehicle Structure
Steering Residual mm R94, < 80 upwards F204, S4.2 < 127 horizontal Additional vertical displacement criterion in EU
wheel displacement S5.2.2 vertical rearward – in 48 and more stringent performance limits, if R94
< 100 km/h test applicable, which it is for M1 unlimited

234
Property / Criteria Unit EU USA Comparison
Item Reference Specification Reference Specification /
/ Limit Limit
rearward perpendicular rigid series ECWTA.
horizontal in barrier test only
56 km/h
ODB test
R12, S5.1 If ODB test
not
performed <
127
horizontal
rearward and
< 127
vertical in
48.3 km/h
perpendicular
rigid barrier
test
Door R94, No door shall F208, S6.1 All portions of Different requirements but likely to have similar
opening S5.2.3 open during dummy shall be effect.
during test test contained within
outer surfaces of
vehicle passenger
compartment
Evacuation R94, 1. Possible to None No evacuation requirements for US.
after test S5.2.5 open at least
one door or
move seats /
tilt backrest
for vehicles

235
Property / Criteria Unit EU USA Comparison
Item Reference Specification Reference Specification /
/ Limit Limit
with rigid
roof.
2. Release
dummies
from
restraint,
force < 60 N
Fuel system integrity
Fuel R94, No more than F301, S5.5 In collision before Slightly more stringent requirements for US
system S5.2.7 slight leakage vehicle motion
integrity after stopped fuel
(Crash collision. spillage < 28g.
test) If continuous After collision,
leakage, rate first 5 mins
of leakage < spillage <142g,
30 g/min subsequent 25
mins rate of
spillage < 28g/min
Fuel R34, S6.2 Normal use F301, S6.4, After crash test, No fuel system integrity static roll test
system tank and S5.6 perform static requirement for EU post crash test. Also comm.
integrity associated rollover test. From
(Static fuel system the onset of
rollover component rotational motion,
test) overturn test. fuel spillage shall
Turn 90 deg not exceed a total
for five of 142g for the
minutes, then first 5 minutes of

236
Property / Criteria Unit EU USA Comparison
Item Reference Specification Reference Specification /
/ Limit Limit
turned 90 deg testing at each
further for successive 90°
another five increment. For the
minutes. remaining test
Drip less period, at each
than 30g/min increment of 90°
may be fuel spillage
tolerated. during any 1
minute interval
shall not exceed
28g.
0° increment
(starting position):

90° increment:

180° increment:

237
Property / Criteria Unit EU USA Comparison
Item Reference Specification Reference Specification /
/ Limit Limit

270°increment

Fuel R110, Mandatory F303 For all vehicles, Leak requirements for US only, although fitment
system S8.3.1 fitment of the pressure drop of automatic cylinder valve mandatory in EU
integrity automatic in the high which cuts off gas when required by safety
(CNG) valve on pressure portion of reason.
cylinder, the fuel system,
which cuts expressed in
off gas when kiloPascals (kPa),
required by in any fixed or
safety reason. moving barrier
crash from vehicle
impact through the
60 minute period
following
cessation of
motion shall not

238
Property / Criteria Unit EU USA Comparison
Item Reference Specification Reference Specification /
/ Limit Limit
exceed:
(1) 1062 kPa (154
psi), or (2) 895
(T/VFS);
whichever is
higher [T
temperature in
Kelvin, VFS
Volume of
cylinder / fuel lines
in litres]
Electric Vehicles
Protection R94, One of: F305, S5.3 Absence of high Similar, but EU legislation allows more
against S5.2.8.1 absence of voltage or high options.
electric high voltage, isolation
shock low electrical resistance.
energy,
physical
protection or
high isolation
resistance
Electrolyte R94, No spillage F305, S5.1 Not more than 5.0 Similar except US has additional static roll test
spillage S5.2.8.2 into litres of
from passenger electrolyte from
compartment propulsion
propulsion
From impact batteries shall
batteries to 30 mins < spill outside the
7% passenger
electrotyte compartment, and
spillage no visible trace of

239
Property / Criteria Unit EU USA Comparison
Item Reference Specification Reference Specification /
/ Limit Limit
outside electrolyte shall
compartment spill into the
, except passenger
open type compartment.
traction Spillage is
batteries measured from
outside the time the
compartment vehicle ceases
. For these < motion after a
7% with a barrier impact
maximum of test until 30
5 litres minutes
outside thereafter, and
compartment throughout any
. static rollover
after a barrier
impact test.
Rechargab R94, REESS F305, S5.2 (a) Electric energy Requirements are similar.
le energy S5.2.8.3 located storage/conversio
storage inside n devices shall
passenger remain attached
system
compartment to the vehicle by
(REESS) shall remain at least one
retention in the component
location in anchorage,
which they bracket, or any
are installed structure that
and REESS transfers loads
components from the device to
shall remain the vehicle
within REESS structure, and

240
Property / Criteria Unit EU USA Comparison
Item Reference Specification Reference Specification /
/ Limit Limit
boundaries (b) Electric
energy
storage/conversio
n devices located
outside the
occupant
compartment
shall not enter the
occupant
compartment.

241
 Table 47: US requirements for OOP tests including tests description and injury criteria / performance limits for low risk deployment tests.

Requirements Ref Test description ATD Injury criteria / performance limits

HIC Nij Neck Neck Chest Chest Axial

15 tension compre 3ms deflecti femur
Fz ssion result on force
(kN) Fz (kN) accln (mm) (kN)
(g)
F208, Low risk deployment test carried out in the HIII 700 1.0 2.07 2.52 60 52 6.805
OOP 5th S25, presence of an out-of-position 5th percentile 5% (4)
percentile adult S26 adult female dummy. Two driver positions are female
female in driver tested: 'Chin on the module' and 'chin on the dummy
position rim'. Frontal airbag is deployed and dummy
injury criteria evaluated.
Infants in rear F208, Two test options: CRABI 390 1.0 2.07 2.52 50 *No N/A
facing and S19, (1) Automatic air bag suppression feature test. 12m (4) possibl
convertible S20 The air bag must be suppressed during several e
child restraints static tests with a 12-month-old child dummy measur
and car beds in positioned in a child restraint on the front ement
front passenger passenger seat. The restraints are placed in (other
position several specified positions during the static wise 30
tests. Static tests also carried out with 5th mm)
percentile female dummy to ensure that airbag
is not inappropriately supressed for small-
statured adults.
(2) Low risk deployment test where a vehicle is
required to meet specified injury criteria
performance limits when the passenger air bag
is deployed in the presence of a 12-month-old
CRABI dummy placed in a belted rear-facing
child restraint. Manufacturers must assure
compliance using each child restraint included
in sections B and C of the proposed list of

242
Requirements Ref Test description ATD Injury criteria / performance limits

HIC Nij Neck Neck Chest Chest Axial

15 tension compre 3ms deflecti femur
Fz ssion result on force
(kN) Fz (kN) accln (mm) (kN)
(g)
representative child restraints
OOP 3-year-old F208, Two test options: HIII 3 570 1.0 1.13 1.38 55 34 N/A
children in S21, (1) Testing a feature that suppresses the air y/o (4)
front passenger S22 bag when a child is present, e.g., a weight or
seat size sensor. The air bag must be suppressed
OOP 6-year-old F208, during several static tests using, in the right HIII 6 700 1.0 1.49 1.82 60 40 N/A
children in S23, front passenger seat, a 3-year-old or 6-year-old y/o (4)
front passenger S24 child dummy. The child dummy is placed in
seat several specified positions during the static
tests.
(2) Low risk deployment test involving
deployment of the air bag in the presence of
out-of-position 3-year-old and 6-year-old child
dummies. The test is conducted at two positions
which tend to be "worst case" positions in terms
of injury risk. In one of these positions, the
dummy's chest is on the instrument panel; in
the other, the dummy's head is on the
instrument panel.

243
 Table 48: Comparison of EU and USA legislative requirements for protection against impact with steering control (UN Regulation 12 and FMVSS
203)

Property / Criteria Unit EU USA Comparison

Test Reference Specification Reference Specification /
/ Limit Limit
Body block test
Speed Relative km/ R12, S5.2 24.1 F203, S5.1 24 Virtually identical
impact speed h
Impact Force N R12, S5.2 11,110 F203, S5.1 11,120 3ms Similar requirement for force but EU has
injury exceedence additional requirements for acceleration and
criteria Acceleration g R12, S5.3 80, 3 ms None None sharp or rough edges.
exceedence
120 peak
with CFC
600 filter
Roughness and R12, No sharp or None None
sharp edges on S5.4.1.1 rough edges
steering likely to
control surface increase
directed danger or
towards driver severity of
injuries to
driver
Other
Steering Steering R12, Sharp edges None None Identical requirement for interference with
control control S5.4.1 roughness driver’s clothing but EU has additional
design and roughness and that can be requirement for sharp or rough edges.
contsructio sharp edges on contacted by
n steering 165 mm
control surface sphere,
Property / Criteria Unit EU USA Comparison
Test Reference Specification Reference Specification /
/ Limit Limit
directed radius of
towards driver curvature >
2.5 mm
Interference R12, Designed, F203, S5.2 Constructed so
with driver’s S4.5.2 constructed that no
clothing and fitted as components or
attachments can
not to
catch the driver’s
embody clothing or
components jewellery during
or normal driving
accessories manoeuvres.
capable of
catching in
the driver’s
clothing or
jewellery in
normal
driving
movements

245
 Table 49: Comparison of EU and USA legislative requirements for seatbelts and restraint systems (UN Regulation 16 and FMVSS 209 / 208).

Property / Criteria EU USA Comparison

Test Ref Specification / Limit Ref Specification / Limit

Minimum R16, Annex All front and rear F208, All front and rear outboard and rear Similar with three
requirements 16 for outboard and centre S4.1.5.1(3), centre seating positions. point belts and
for M1vehicles seating positions S4.1.5.5(After Three point belt (type 2), note: rear emergency
configuration (passenger Three point belt Sept 1 2007), centre after Sept 1 2007. locking retractors
of seat-belts cars) Emergency locking S7.1, S7.2 Emergency locking retractor (for lap for all seating
and retractors retractor with portion of belt S7.1.1.3) but with option, positions,
multiple sensitivity, for seats other than front outboard seats, although slightly
i.e. vehicle of manual webbing adjustment device unclear what
acceleration and capable of causing the retractor that requirement is in
webbing withdrawal. adjusts the lap belt to lock when the belt US for front
is buckled (S7.1.1.4). centre seat.
However, two
significant
differences:
1. EU requires
retractor with
multiple
sensitivity
whereas the
USA does
not.
2. USA allows
option of
switchable
retractors for
seats other

246
Property / Criteria EU USA Comparison
Test Ref Specification / Limit Ref Specification / Limit
than front
outboard
which is most
likely related
to the
installation of
child seats.
Safety Belt R16, S8.4 Driver seat reminder F208, S7.3a Driver seat reminder Both EU and
Reminder Visual and audible Either USA require a
warnings easily Activates a continuous or intermittent safety belt
recognisable by audible signal for a period of not less reminder for the
driver. than 4 seconds and not more than 8 driver’s seat.
Visual warning seconds and that activates a continuous However, the EU
readily visible and or flashing warning light visible to the requirements for
continuous or driver displaying the symbol for the seat the warning are
intermittent signal. belt telltale. greater with both
If signal red, then visual and
shall use specific audible warnings
seatbelt symbol as required (USA
defined. Or either one or the
Activates, for a period of not less than 4 other) and two
seconds and not more than 8 seconds levels of warning
(beginning when the vehicle ignition required (USA
Audible warning switch is moved to the “on” or the only one).
continuous or “start” position), a continuous or
intermittent signal or flashing warning light visible to the
vocal. driver, displaying the symbol of the seat
Levels of warning belt telltale.
defined:

247
Property / Criteria EU USA Comparison
Test Ref Specification / Limit Ref Specification / Limit
1. Visual for 4 sec,
when ignition
switch engaged.
2. Visual and
audible for 30 sec,
when thresholds
exceeded:
Distance travelled ≤
500m
Speed excewould
eded ≤ 25 mph

Inspection of R16, S6.1.2, Designed / F209, S4.1d, Free from burrs, sharp edges that may Main difference
restraint S6.1.3, constructed to ensure S4.1e, S4.1g contact webbing, person’s clothing. is that EU does
system S6.2.1.1, satisfactory operation Readily accessible to occupant to permit not specify size
S6.2.2, and reduce injury in his easy and rapid removal from of occupants that
S6.2.3.1, event of accident. assembly. restraint system
S6.3.1.1 Straps not liable to Adjustable to fit occupants from 5th should fit
assume dangerous percentile adult female to 95th percentile whereas USA
configuration. adult male. does.
No sharp edges that Buckle release mechanism designed to
may cause wear of minimise possibility of accidental
straps and preclude release.
any possibility of Only one opening that tongue can be
incorrect use. inserted into.
Adjust automatically
or manual adjusting
device convenient
and easy to use, i.e.

248
Property / Criteria EU USA Comparison
Test Ref Specification / Limit Ref Specification / Limit
adjustable with one
hand.
Strap characteristics
such that pressure on
wearers body even.
Energy absorbing.
Finished salvages that
do not come
unravelled.
Inspection of R16, S6.2.2.2 Easy to use and grasp F209, S4.1e, Designed to minimise possibility of Main differences:
buckle Possible to release S4.3(d) accidental release. 1. Allowed
and engage with Readily accessible to occupant to permit buckle release
simple movement of his easy and rapid removal from force higher
one hand assembly. for USA (EU
Not possible for Only one opening that tongue can be 10N; USA
buckle to be left in inserted into 133 N)
partially closed Buckle release force, not more than 133 2. EU require
condition. N. buckle release
At least 46 mm wide Buckle release - push-button, min area to be coloured
and presented area 452 mm2, min linear size 10 mm red whereas
not less than 20 cm2. USA do not.
(Note: Width
requirement not
needed for harness
belt buckles)
Buckle release force,
not less than 10 N in
any condition
Buckle release; for

249
Property / Criteria EU USA Comparison
Test Ref Specification / Limit Ref Specification / Limit
enclosed buttons, size
min area 450 mm2,
min width 15 mm, for
non-enclosed buttons
min area 250 mm2,
width 10 mm
Buckle release area
coloured red
Buckle R16, Withstand load of F209, S4.4b Withstand load of: On average,
strength test S6.2.2.6, 9,800N, build up not  Pelvic parts: 11,120N similar load
S7.5.1, S7.5.5 specified.  Upper torso parts 6,672N requirements
For buckles having
parts common to two
safety belts withstand
a load of 14,700N
applied
simultaneously to
both straps
Strength test R16, Withstand load of F209, S4.4b Withstand load of: On average,
on adjusting S6.2.3.3, 9,800N, build up not  Pelvic parts: 11,120N similar load
device (and S7.5.1 specified. Retractor  Upper torso parts 6,672N requirements
where locked 450 mm from
necessary end of strap.
retractors)
Strength test R16, S6.2.4, 14,700N applied in F209, S4.3(c), Bolts – used to secure seat-belt assembly Loads for
on attachments S7.5.2 least favourable S5.2(c) 40,034N force with load applied at 45 attachment
(and where conditions (direction) deg, except when ends of two assemblies strength test
necessary likely to occur in use. cannot be attached with single bolt when higher for USA

250
Property / Criteria EU USA Comparison
Test Ref Specification / Limit Ref Specification / Limit
retractors) Not break or become force reduced to 22,241N. compared to EU
detached. Attachment hardware other than bolts (22,241 –
Retractors unwound 26,689N force. 49,034N
completely compared to
14,700N).
However, EU has
dynamic sled test
whereas USA
does not.

(Low R16, Refrigerated at -10±1 F209, S5.2d3 Compressive force of 1779 N applied Compressive load
temperature) S6.2.2.3, deg C for 2 hours. anywhere on a test line that is coincident test on buckle
compressive S7.5.3 After removal from with the centre line of the belt extended performed in both
load test on fridge, mating parts through the buckle or on any line that EU and USA but
buckle of buckle coupled, extends over the centre of the release substantial
and laid on flat rigid mechanism and intersects the extended differences. EU is
steel surface (at - centreline of the belt at an angle of 60°. at low
10±1 deg C, mass at The load shall be applied by using a temperature, US
least 100 kg) and curved cylindrical bar having a cross is not, EU
impacted by dropping section diameter of 19 mm and a radius specifies impact
18 kg impactor 300 of curvature of 152 mm, placed with its load in two
mm under gravity. longitudinal centre line along the test orientations on

251
Property / Criteria EU USA Comparison
Test Ref Specification / Limit Ref Specification / Limit
Impactor face at least line and its centre directly above the two samples,
45 HRC hardness, point or the buckle to which the load will USA specifies
geometry convex be applied. compressive load
surface transverse Three samples tested. in one orientation
radius of 10 mm, on three samples.
longitudinal radius Also, differences
150 mm. Tested in between
two orientations with impactors.
curved bar in line and
perpendicular to
strap.
Two samples tested.
Low R16, Ditto above as for None None No requirement
temperature S6.2.1.4, buckle for compressive
(compressive S7.5.4 (impact) load test
load) test on for rigid
rigid parts (hardware
plastic) parts in
USA.
Ease of R16, Force required to F209, Should have either, an automatic locking Overall, very
adjustment S6.2.3.2, operate manual S4.1(g), retractor, or an emergency locking similar.
(belt adjusting S6.2.3.4, device, i.e. webbing 4.3(e), retractor, or adjustment device within
device) S7.5.6 pull through force, ≤ reach of occupant.
50 N. Shall be capable of adjustment to fit
occupants from 5th percentile female to
95th percentile male.
Adjustment force, i.e. webbing pull
through force ≤ 49N

252
Property / Criteria EU USA Comparison
Test Ref Specification / Limit Ref Specification / Limit
Conditioning / testing of belt or restraint system before dynamic test
Durability of R16, S6.2.2.4 Withstand repeated F209, S4.3(g) Release mechanism moved 200 times More cycles for
buckle operation and before S5.2(g) through maximum possible travel EU, but forces
dynamic test of belt against stops with max force of 133±13 probably higher
assembly undergo N at ≤0.5 Hz. Not fail or gall or wear for USA.
5,000 opening and such that normal latching / unlatching
closing cycles under impaired.
normal conditions of
use
Corrosion R16, Test in mist chamber F209, S4.3(a) EITHER Corrosion test
resistance (of S6.2.1.2, S7.2 at 35 ± 5deg C filled & S5.2(a) Test in mist chamber at 35 ± 5deg C and limit nearly
rigid parts) test with atomised salt filled with atomised salt solution identical, with
solution prepared by prepared by dissolving 5 ±1 parts in 95 higher exposure
dissolving 5 ±1 parts parts of water by mass that has pH 6.5- times for EU for
in 95 parts of water 7.2 using nozzle with air pressure at 70- hardware not
by mass that has pH 170 kN/m2 such that a 80 cm2 area close to floor.
6.5-7.2 using nozzle collects 1.0 to 2.0 ml of solution per Also, US has
with air pressure at hour. additional option
70-170 kN/m2 such Expose for two periods of 24 hrs that specifies if
that a 80 cm2 area followed by 1 hr drying for hardware electroplated to
collects 1.0 to 2.0 ml close to floor. For all other hardware one specified service
of solution per hr. period. At end of test wash and dry at condition, no
Expose for 50 hr room temperature for 24 hours. requirement to
continuously, Limit, free of ferrous corrosion on test.
washed, dry at room significant surfaces
temperature for 24 OR
hours. For hardware near floor electroplated
Requirement is no coated with at least service condition
signs of corrosion level of SC2 and other hardware ditto

253
Property / Criteria EU USA Comparison
Test Ref Specification / Limit Ref Specification / Limit
visible to unaided eye with level of SC1.
or deterioration likely
to impair proper
functioning.
Retractors
Locking R16, Type 4: F209, One of: Main difference
threshold S6.2.5.3.1, Lock when vehicle S4.3(j)(2) 1. Sensitive to veh accel: is that EU
(Emergency S6.2.5.3.3, decel ≥ 0.45g Note: for seat Lock when tilted > 45 deg; requires multiple
locking type 4 S7.6.2 Not lock within 50 belt Not lock when tilted ≤ 15 deg. sensitivity
retractors) mm extraction with assemblies Lock before payout of 25 mm with accel emergency
strap extraction accel manufactured 0.7g, two perpendicular directions. locking retractor
≤ 0.8g on or after 2. Sensitive to webbing withdrawal (vehicle
Not lock when Feb 22nd 2007 Not lock before 51 mm payout when acceleration and
sensing device tilted withdrawal accel ≤ 0.3g webbing
≤ 12 deg from Lock before payout of 25 mm with accel withdrawal)
installation position. 0.7g, one direction whereas the USA
Lock when tilted > 27 requires one or
deg the other.
Lock when strap Also, locking
extraction accel ≥ requirements
3.0g significantly
Strap movement different for both
before locking ≤ 50 vehicle
mm acceleration and
TEST SETUP: webbing
Extraction withdrawal and in
(withdrawal) test some cases
length: At full length difficult to
less 300±3 mm, compare directly

254
Property / Criteria EU USA Comparison
Test Ref Specification / Limit Ref Specification / Limit
required accelerations e.g. vehicle accln
reached before 5 mm EU lock when
of withdrawal vehicle decel ≥
For webbing 0.45g, USA Lock
extraction: before payout of
Acceleration rate ≥ 25 mm with accel
55g/s and ≤ 150g/s 0.7g. Interesting
For vehicle accel: to note difference
Acceleration rate ≥ in test setup for
25g/s and ≤ 150g/s webbing
withdrawal
assessment, in
EU webbing is
pulled, in USA
retractor is
moved. EU setup
is necessary
because of
overlapping
requirements of
vehicle accln and
webbing
withdrawal.
Retracting R16, Lap belt: Not less F209, Force measured (lowest) within ±51 mm Higher retraction
force S6.2.5.3.4, than 7N measured in S4.3(j)(2) of 75% extension. Attached to lap and forces for EU.
S7.6.4 free length between Note: for seat pelvic: ≥ 1N, ≤ 7N.
dummy and retractor belt Attached pelvic only ≥3N
when strap being assemblies Upper torso only ≥ 1N, ≤ 5 N
retracted and just manufactured

255
Property / Criteria EU USA Comparison
Test Ref Specification / Limit Ref Specification / Limit
about to touch on or after
dummy. Feb 22nd 2007
Upper torso: ≥1 N , ≤
7 N measured as
above, with exception
for when tension
reducing device fitted
when may be reduced
to 0.5N.
Corrosion R16, Ditto as for buckle F209, S4.3(a) Ditto as for buckle above. Very similar
S6.2.5.3.5, above. & S5.2(a)
S7.2
Dust R16, S7.6.3 Retractor positioned F209, S5.2(k) Retractor positioned in dust chamber Similar with
in dust test chamber with strap extracted and possible slight
mounted in kept extracted, except for 10 complete difference on dust
orientation similar to cycles of extraction/ retraction after each composition and
that in vehicle. agitation of dust. particle size.
500 mm of strap Chamber consists of cylinder 500 mm
extracted and kept diameter, 500 mm high with 40 deg cone
extracted except for below to hold dust.
10 complete cycles of Test time 5hrs, dust agitated every 20
extraction/ retraction mins for 5 sec using clean dry
after each agitation of compressed air.
dust. 0.9 kg of dry coarse dust (chemically
Chamber consists of ~70% quartz), particle size defined in
cylinder 500 mm SAE J726 Sept79 as:
diameter, 500 mm Particle distribution by weight:
high with 40 deg cone Size Microns %
below to hold dust. 0-5 12±2

256
Property / Criteria EU USA Comparison
Test Ref Specification / Limit Ref Specification / Limit
Test time 5hrs, dust 5-10 12±3
agitated every 20 10-20 14±3
mins for 5 sec using 20-40 23±3
clean dry compressed 40-80 30±3
air. 80-200 9±3
1 kg of dry quartz
dust with given
particle size
distribution as
follows:
Passing 150 μm
aperture 99-100%
Passing 105 μm
aperture 76-86%
Passing 75 μm
aperture 60-70%
Strap
Testing of R16, S6.3.1.2 Width measured at F209, S5.1(a) Type 2 (three point) belt – Width Similar but with
strap width tension of 14.7 kN. measured at tension of 9786±450 N. measurement
Performance limit Type 1 (lap belt only) - Width measured made with higher
≥46 mm at tension ≤ 22 N force for EU.
Limits
≥46 mm.
Strap strength R16, S7.4.2 Grip ends of strap F209, S5.1(b) Ends of webbing placed in split drum Some differences
test (after each (webbing) between grips of tensile testing machine having on details and
conditioning clamps of tensile diameter between 51 and 102 mm. Grip tolerances, but
test below) testing machine. separation between 51 and 102 mm/min. overall very
Clamps designed to Distance between grips at beginning of similar.

257
Property / Criteria EU USA Comparison
Test Ref Specification / Limit Ref Specification / Limit
avoid breakage of test between 102mm and 254 mm. Note that in USA
strap at or near them, Accuracy of testing machine better than there is also an
speed of traverse 1 percent in range of breaking strength. elongation load
about 100 mm/min. (Elongation load test not required if test. However, If
Free length of restraint system equipped with load system is
specimen between limiter). equipped with
clamps at beginning Requirements as noted after load limiter
of test 200±40 mm conditioning tests compliance with
Requirements as elongation
noted after requirements not
conditioning tests required which is
more than likely
to be the case for
systems
considered in this
study. Systems
with load limiters
must comply with
208 frontal
barrier crash test.
Room R16, S6.3.2, Conditioned in F209, S5.1(a), Conditioned for at least 24 hrs in Some difference
conditioning S7.4.1.1, accordance with ISO 4.2(b) atmosphere having relative humidity 48 in conditioning
S7.4.2 139 (2005), which is to 67 percent and temperature 23±2 deg test, but range in
temperature 20±2 deg C. tolerances would
C and relative Requirements allow a
humidity 65±4 % 1. Static breaking load test temperature of 21
until successive Type 2 (3-point belt) Pelvic ≥ 22,241N, deg C and a
weighings (at 2 hr upper torso ≥17,793N humidity of 61-
intervals) show no Note: measure breaking strength load for 67 percent to

258
Property / Criteria EU USA Comparison
Test Ref Specification / Limit Ref Specification / Limit
progressive change in reference meet both
mass greater than (2. Elongation load test requirements, so
0.25%. Type 1 (lap belt only) 20% @ 11,120N; likely difference
Requirements Type 2 (3-point belt) Pelvic 30% @ not that
Static breaking load 11,120 N, Upper torso 40% @ 11,120 significant.
test N.) Higher minimum
≥14.7kN and ≤10% Note: elongation load test not required breaking load
difference between for manual belts with load limiters or requirements for
two samples. those subject to requirements of FMVSS USA, but
Note measure 208, S5.1. breaking loads
breaking strength likely to be at
loads and record least 25% higher
average for reference than EU
minimum (see
heat conditioning
requirements
below), so likely
not a notable
difference.
Also elongation
requirements for
USA but only
energy sbsorbing
specified for EU
– see inspection
of restraint
system above.
Light R16, S6.3.3, Conditioned in F209, S4(e), Webbing lengths of at least 508 mm Somewhat
conditioning S7.4.1.2, accordance to ISO S5.1(e) suspended vertically inside single open different but

259
Property / Criteria EU USA Comparison
Test Ref Specification / Limit Ref Specification / Limit
S7.4.2 105-B-2 flame sunshine carbon-arc light unable to
(1994/Amd2:2000) apparatus (type E) with automatic temp compare directly
which uses a Xenon control and 1rpm of specimen rack. to determine if
arc lamp source to Filter used soda lime glass with equivalent, but
give light on sample transmittance <5% for wavelengths < some items are
of 1.1 W/m2 x 305 nm and ≥90% for wavelengths 375 similar such as
wavelength in to 800 nm. Air temperature 60±2 deg C. wavelength of
nanometers at 420 nm Exposure time 100 hours. Followed by light exposed to.
using filter with room conditioning test above
transmittance at least Requirement
90% between 380 nm Static breaking load test
and 750 nm falling to 1. ≥ 60% of reference breaking load in
0 between 310 nm room conditioning test
and 320 nm for a time 2. Colour retention not less than No. 2
to cause contrast on AATCC Gray scale
equal to Grade 4 on
the grey scale to
standard blue dye no.
7. Followed by room
conditioning above.
Requirement
Static breaking load
test
1. ≥ 75% of
reference
breaking load in
room
conditioning test
2. Static breaking

260
Property / Criteria EU USA Comparison
Test Ref Specification / Limit Ref Specification / Limit
load ≥14.7kN
Low R16, S6.3.3, 1.5 hours on plane None None No low
temperature S7.4.1.3, surface in low temperature
conditioning S7.4.2 temperature chamber conditioning
at -30±5 deg C. Then requirement for
folded and 2 kg USA.
weight also cooled
used to weight fold
for further 30 minutes
in chamber.
Requirement
1. Static breaking
load
≥75% of average load
in room conditioning
test
≥14.7kN
Heat R16, S6.3.3, 3 hrs in a heating None None No heat
conditioning S7.4.1.4, cabinet temperature conditioning
S7.4.2 60±5 deg C, humidity requirement for
65±5 percent USA.
Requirement
1. Static breaking
load
≥75% of average load
in room conditioning
test
≥14.7kN

261
Property / Criteria EU USA Comparison
Test Ref Specification / Limit Ref Specification / Limit
Water R16, S6.3.3, Immersed for 3 hrs in None None No water
conditioning S7.4.1.5, distilled water with a conditioning
S7.4.2 trace of wetting agent requirement for
at temp of 20±5 deg USA.
C
Requirement
1. Static breaking
load
≥75% of average load
in room conditioning
test
≥14.7kN
Micro- Micro- None None F209, S4.2(f), Test not required on webbing made from US has micro-
organism organisms S5.1(f) materials which is inherently resistant to organism
conditioning micro-organisms resistant test for
Soil burial for two weeks webbing
Requirements materials
1. Static breaking load susceptible to it
≥85% of reference load for unexposed whereas EU does
specimens, e.g. measured after room not.
conditioning test – see above.
Micro-slip test R16, Micro-slip test – None None No micro-slip test
S6.2.3.2, S7.3 sample conditioned for belt length
for 24 hrs, temp 20±5 adjusting devices
deg C, humidity 65±5 in USA.
percent. Load one end However, this
of strap 50 N, move type of belt
other end 300±5 mm length adjustment
for 1,000 cycles @0.5 device very

262
Property / Criteria EU USA Comparison
Test Ref Specification / Limit Ref Specification / Limit
Hz. unlikely to form
Requirement part of belt
Two samples tested assembly in
Slip ≤ 25 mm for passenger cars
each adjusting device, considered in this
≤ 40 mm for both study because
devices they are fitted
with three point
belts with
emergency
locking retractors
which are self
adjusting.
Abrasion test R16, S6.4.2, Performed for every F209, 1. Webbing abraded over hexagonal Main difference
S7.4.1.6 device for which the S4.2(d), rod as defined and shown below. is that US has
strap is in contact S5.1(d), additional
with except adjusting S5.3(c) hexagonal bar
devices which allow abrasion test
less than 300 mm slip whereas EU does
and undergo micro- not.
slip test, i.e. devices Also, differences
not supposed to slip. in details, in
Three slightly particular test
different test weight and
procedures for testing number of cycles
different devices, one and stroke length.
for devices with For example for
straight through pull, B-pillar D rings
(stroke 300±20 mm, EU has lower

263
Property / Criteria EU USA Comparison
Test Ref Specification / Limit Ref Specification / Limit
load 25 N, cycles load (weight) and
5,000), one for higher number of
devices with more cycles (EU 0.5
complex belt changes kg, 45,000
of direction (stroke cycles; US 2.35
300±20 mm, load 5 kg, 2,500 cycles).
N, cycles 45,000) and . Stroke length
one for devices where less for device
there is little slip tests (US 203
(load 0-50 N, cycles mm; EU 300
45,000) Also note mm).
that this
procedure doubles as
the microslip test.
Frequency of loading
for all 0.5Hz (30
cycle per minute)
Requirement Mass of weight 2.35±0.05 kg, stroke 330
1. Static breaking mm. Test for 2,500 cycles at 30±1 cycle
load per minute.
≥75% of average Following this room conditioning and
reference load in then static breaking load test.
room test 2. Expose webbing for 4hrs to
≥14.7kN atmosphere humidity 65 percent,
temp 18 deg C. Then, webbing
abraded through each buckle or
adjusting device in seat-belt
assembly for 2,500 cycles with
machine that uses 1.4 kg mass and

264
Property / Criteria EU USA Comparison
Test Ref Specification / Limit Ref Specification / Limit
has stroke length 203 mm.
Requirements
1. Static breaking load
≥75% of following for specified belt
type: Type 1 (lap belt only) ≥ 26, 689N;
Type 2 (3-point belt) Pelvic ≥ 22,241N,
upper torso ≥17,793N
Dynamic R16, S6.4.1, Dynamic(deceleration None None No dynamic sled
(sled) test S7.7 or acceleration) sled test in USA
test with defined
pulse with 50 km/h
velocity change and
corridor defined as
follows:
Time Lower Upper
(ms) (g) (g)
0 - 20
10 0 -
10 15 -
15 20 -
18 - 32
25 26 -
45 26 -
55 20 -
60 0 32
80 - 0

Restraint system
mounted on trolley to

265
Property / Criteria EU USA Comparison
Test Ref Specification / Limit Ref Specification / Limit
rigid frame with rigid
smooth surfaced seat
with defined
dimensions.
Test performed with
well-defined manikin
of mass 75.5 ±1 kg.
Requirements
1. No part of system
shall break or
unlock
2. Forward
displacement of
manikin 80-200
mm at pelvic
level and 100-300
mm at chest level.
Chest
displacement may
be larger if
position protected
by airbag and
speed at this value
does not exceed
24 km/h.
3. Devices to allow
occupant to exit
vehicle should
still operate after

266
Property / Criteria EU USA Comparison
Test Ref Specification / Limit Ref Specification / Limit
test.
Buckle R16, Opening force not F209, S4.3(d) Not more than 133 N USA allows
opening test S6.2.2.5, more than 60 N after higher buckle
S6.2.2.7, S7.8 dynamic test of belt opening forces
assembly with 600 N than EU; USA
force applied on 133 N, EU 60N
straps connected to
buckle.
Retractor R16, Withdraw / retract Corrosion resistance test (see above first Similar,
durability S6.2.5.3.5, 40,000 cycles at ≤ 0.5 row of table).
S7.6.1 Hz with snatch to Followed by withdraw / retract 2,500
lock retractor every cycles.
5th cycle. Followed by temperature resistance test.
Followed by Followed by withdraw / retract 2,500
corrosion test (see cycles.
above 1st row of Followed by dust resistance test (see
table). above, 1st row retractors).
Followed by dust Followed by withdraw / extract 45,000
resistance test (see cycles with locking mechanism actuated
above 1st row at least 10,000 times. 3 retractors
retractors). (samples) tested.
Followed by Performance requirements
Withdraw / retract Correct operation, including locking and
5000 cycles at ≤ 0.5 retraction requirements detailed in the
Hz with snatch to two rows above, with exception that
lock retractor every retraction force shall not be less than
5th cycle. 50% of its original force.
Following this must
meet locking and

267
Property / Criteria EU USA Comparison
Test Ref Specification / Limit Ref Specification / Limit
retraction force
requirements above.
2 samples tested.
Heat None None F209, 24 hrs at 80 deg C over water followed No heat
resistance test S5.2(b), by 24 hrs at 80 deg C in oven resistance
(conditioning) ASTM D756- conditioning for
for non- 78 plastic (non-
metallic parts metallic) parts for
EU.

268
 Table 50: Comparison of EU and USA consumer testing assessments for medium overlap frontal offset deformable barrier (ODB) tests

Body Injury Criteria Euro NCAP Points IIHS Rating Comparison

Region
4 3.99 - 2.66 - 1.32 - 0
2.67 1.33 0.01

Upper limit Lower limit Good Acceptable Marginal Poor

Head HIC15 < 500 > 700 ≤ 560 ≤ 700 ≤ 840 > 840 Similar. Euro
NCAP
encourages a
a3ms < 72g > 80g - - - - slightly lower
HIC15 value than
Head Modifiers Unstable airbag/steering wheel contact (-1) A head/neck rating that is otherwise good will be IIHS. Lower
lowered to acceptable if the neck tension, limit for Euro
compression, or shear (X-direction) forces fall NCAP is classed
Hazardous airbag deployment (-1) outside the force duration corridors specified by as 'acceptable' by
Mertz (1984) (Euro NCAP lower performance IIHS. 3ms Head
Incorrect airbag deployment (-1) limits for neck tension and neck shear). Contact acceleration is
with airbag and steering column assessed during not given an
dummy kinematics assessment (below). individual score
Steering column displacement (-1)
by IIHS.

Neck My,extension < 42 Nm > 57 Nm - - - - Similar values

for neck tension
Fz,tension < 2.7 kN @ 0 ms > 3.3 kN @ 0 ms ≤2.6k ≤ 3.3 kN ≤ 4.0 kN > 4.0 kN and neck shear.
N Bending moment
< 2.3 kN @ 35 ms > 2.9 kN @ 35 ms is incorporated

269
Body Injury Criteria Euro NCAP Points IIHS Rating Comparison
Region
4 3.99 - 2.66 - 1.32 - 0
2.67 1.33 0.01

Upper limit Lower limit Good Acceptable Marginal Poor

< 1.1 kN @ 60 ms > 1.1 kN @ 60 ms into Nij for IIHS

rating. Additional
Fx,shear < 1.9 kN @ 0 ms > 3.1 kN @ 0 ms - - - - 70g head
acceleration
< 1.2 kN @ 35 ms > 1.5 kN @ 35 ms injury criterion is
based on concern
< 1.1 kN @ 60 ms > 1.1 kN @ 60 ms about moderate
and serious
Nij - - ≤ 0.8 ≤ 1.00 ≤ 1.20 > 1.20 injuries (AIS 2-3)
to the face and
Fz,Compression - - ≤ 3.2 ≤ 4.0 kN ≤ 4.8 kN > 4.8 kN
weaker parts of
kN
the skull
ares peak - - Values > 70g result in downgrading (for neck and
head)

Chest Deflection < 22 mm > 42 mm ≤ 50 mm ≤ 60 mm ≤ 75 mm > 75 mm Large differences

in chest
VC < 0.5 m/s > 1.0 m/s ≤ 0.8 m/s ≤ 1.00 ≤ 1.20 > 1.20 deflection limits.

270
Body Injury Criteria Euro NCAP Points IIHS Rating Comparison
Region
4 3.99 - 2.66 - 1.32 - 0
2.67 1.33 0.01

Upper limit Lower limit Good Acceptable Marginal Poor

a3ms - - ≤ 60 ≤ 75 ≤ 90 > 90 Chest deflection

rate and thoracic
Deflection rate - - ≤ 6.6 m/s ≤ 8.2 m/s ≤ 9.8 m/s > 9.8 m/s spine
acceleration not
Chest Modifiers Displacement of the A pillar (-2) assessed by Euro
NCAP.
Passenger compartment integrity (-1)

Steering wheel contact (-1)

Incorrect airbag deployment (-1)

Shoulder belt load > 6kN (-2)

Femur Axial < 3.8 kN > 9.07 kN ≤ 7.3 kN ≤ 9.1 kN ≤ 10.9 kN > 10.9 kN Large difference
Forcecompression @ 0ms @ 0ms @ 0ms @ 0ms between Euro
NCAP higher
performance
> 7.56 kN @ 10 ms ≤ 6.1 kN ≤ 7.6 kN ≤ 9.1 kN @ > 9.1 kN @ limit and good
@ 10ms @ 10ms 10ms 10ms performance
rating by IIHS.
EURO NCAP is
more stringent.

271
Body Injury Criteria Euro NCAP Points IIHS Rating Comparison
Region
4 3.99 - 2.66 - 1.32 - 0
2.67 1.33 0.01

Upper limit Lower limit Good Acceptable Marginal Poor

Knee Displacement < 6 mm > 15 mm ≤ 12 mm ≤ 15 mm ≤ 18 mm > 18 mm Euro NCAP high

performance
Knee Modifiers Variable contact (-1) Two measurement points are taken on the knee limit is a lot
region of the lower instrument panel to calculate lower than IIHS
Concentrated loading (-1) the precrash/postcrash difference. Assessed as part good
of structural performance. performance
Incorrect airbag deployment (-1) limit.

Tibia Tl < 0.4 > 1.3 ≤ 0.8 ≤ 1.00 ≤ 1.20 > 1.20 Euro NCAP high
performance
Axial < 2 kN > 8 kN ≤ 4.0 ≤ 6.0 kN ≤ 8.0 kN ≤ 8.0 kN limits are more
Forcecompression kN stringent than
IIHS.
Tibia Modifiers Upward displacement of the worst Only brake pedal is measured
performing pedal (-1)

Foot Pedal rearward < 100 mm > 200 mm - - - - Different

displacement assessment
methods
Acceleration - - ≤ 150 g ≤ 200 g ≤ 260 g > 260 g

Foot Modifiers Footwell rupture (-1)

Pedal blocking (-1)

272
Body Injury Criteria Euro NCAP Points IIHS Rating Comparison
Region
4 3.99 - 2.66 - 1.32 - 0
2.67 1.33 0.01

Upper limit Lower limit Good Acceptable Marginal Poor

Structural Rating/Modifiers Modifiers are applied to the chest region if Safety cage deformation measurements: Similar
the following occur: Displacement of the A Measurement of 7 points on the vehicle interior measurements
pillar above 100 mm; Door latch or hinge (plus measurement of the closing of distance recorded
failure, unless the door is adequately between the A- and B- pillars. Two points are on
retained by the door frame; Buckling or instrument panel in front of knees, four in the
other failure of the door resulting in severe footwell area and one on the brake pedal. Initial
loss of fore/aft compressive strength; structural rating is based on intrusion
Separation or near separation of the cross measurements in figure XX. However, this may be
facia rail to A pillar joint; Severe loss of downgraded based on additional observations
strength of the door aperture. Pre-test about the structural integrity of the safety cage.
checks are carried out on electric vehicles The final rating is typically not more than one
to ensure there is sufficient protection rating level above the worst measurement.
provided against electrical shock. Significant fuel leaks (above leak rate permitted in
FMVSS 301) or compromised high voltage
systems (which do not meet the electrolyte
spillage, battery retention and electrical isolation
requirements in FMVSS 305) will downgrade
overall rating to poor.

273
Body Injury Criteria Euro NCAP Points IIHS Rating Comparison
Region
4 3.99 - 2.66 - 1.32 - 0
2.67 1.33 0.01

Upper limit Lower limit Good Acceptable Marginal Poor

Dummy kinematics rating Applied to individual dummy regions Evaluation based on dummy movement on high Low speed
speed film plus measurement of steering column bumper testing
movement. The basic characteristics of good also contributes
occupant restraint/dummy kinematics performance to IIHS results.
are: the dummy should move straight forward into Dummy
a fully deployed airbag and then return directly to melting/burning
the seat during rebound. The head and body should not mentioned in
stay behind and within the extended perimeter of Euro NCAP.
the airbag. The head should not approach hard
surfaces of the vehicle interior. The rearward and
upward movement of the steering column should
be minimal (less than 100 mm). The lap belts
should have stable anchorages that allow only
minimal lengthening or spool-out even when
force-limiting devices are used. The vehicle door
must not open during a crash. Frontal airbags must
not deploy during low speed bumper test. Burning
or melting of dummy parts must not occur.

274
 Table 51: Comparison of US regulation FMVSS 208 and US NCAP consumer testing requirements for full width rigid barrier tests. Notes:(1) 5th
percentile dummy performance limits are in square brackets; (2) US NCAP higher and lower performance limits estimated using assumption of even
risk of AIS 3+ injury for all four body regions assessed.
Property / Criterion Unit FMVSS 208 US NCAP Comparison
Item Specification / Limit Higher Lower
Performance Performance
Dummy
Head HIC15 700 404 723 US NCAP score is calculated for each region
[700] [409] [723] using injury risk curves. Star rating is based
on the calculated risk of serious injury. All US
NCAP values in this table are entirely
nominal - OEM can trade less good
performance in one criterion with better
performance in another. The US NCAP star
rating system encourages manufacturers to aim
to achieve a lower HIC15 value.
Neck Fz (tension) kN 4.17 3.08 3.78 US NCAP encourages further protection of the
[2.62] [1.95] [3.78] neck beyond the requirements set out in FMVSS
208.
Fz kN 4 3.08 3.78
(compression) [2.52] [1.95] [3.78]
Nij 1 0.22 0.63
[1] [-0.2] [0.63]
Chest Deflection mm 63 24.7 39.6 US NCAP encourages reduced values of chest
[52] [20.4] [39.6] deflection compared to FMVSS 208.

Acc 3ms g 60
Exceedence [60]
Femur Fz kN 10 4.1 7.32 US NCAP encourages greater protection for the
(compression) [6.805] [2.85] [7.32] Femur compared to FMVSS 208.

275
 Table 52: Euro NCAP consumer testing requirements for full width rigid barrier tests

Property / Item Criterion Euro NCAP

Specification / Limit

Dummy

Head HIC15 < 500

> 700

a3ms < 72 g
> 80 g

Head Modifiers Unstable airbag/steering wheel contact (-1)

Hazardous airbag deployment (-1)

Incorrect airbag deployment (-1)

Steering column displacement (-1)

Exceeding forward excursion line

Neck My,extension < 36 Nm

> 49 Nm

Fz,tension < 1.7 kN

> 2.62 kN

276
 Property / Item Criterion Euro NCAP

Specification / Limit

Fx,shear < 1.2 kN

> 1.95 kN

Chest Deflection < 18 mm

> 42 mm

VC < 0.5 m/s

> 1.0 m/s

Chest Modifiers Steering wheel contact (-1)

Incorrect airbag deployment (-1)

Shoulder belt load > 6 kN (-2)

Femur Axial Forcecompression ≤ 2.6 kN

≤ 6.2 kN

Femur Modifiers Incorrect airbag deployment (-1)

Submarining (-4)

277
 Table 53: US IIHS consumer testing requirements for small overlap barrier (SOB) tests

SOB Assessment Assessment Criteria IIHS Rating

Good Acceptable Marginal Poor

DUMMY INJURY CRITERIA

Head HIC15 ≤ 560 ≤ 700 ≤ 840 > 840
Neck Fz,tension ≤ 2.6 kN ≤ 3.3 kN ≤ 4.0 kN > 4.0 kN

Nij ≤ 0.8 ≤ 1.00 ≤ 1.20 > 1.20

Fz,Compression ≤ 3.2 kN ≤ 4.0 kN ≤ 4.8 kN > 4.8 kN

ares peak Values > 70 g result in downgrading (for neck and head)
Chest Deflection ≤ 50 mm ≤ 60 mm ≤ 75 mm > 75 mm
VC ≤ 0.8 m/s ≤ 1.00 m/s ≤ 1.20 m/s > 1.20 m/s
a3ms ≤ 60 g ≤ 75 g ≤ 90 g > 90 g
Deflection rate ≤ 6.6 m/s ≤ 8.2 m/s ≤ 9.8 m/s > 9.8 m/s
Thigh and Hip KTH injury risk (%) ≤5 ≤ 15 ≤ 25 > 25

278
SOB Assessment Assessment Criteria IIHS Rating

Good Acceptable Marginal Poor

Knee Displacement ≤ 12 mm ≤ 15 mm ≤ 18 mm > 18 mm
Tibia Tl ≤ 0.8 ≤ 1.00 ≤ 1.20 > 1.20
Axial Forcecompression ≤ 4.0 kN ≤ 6.0 kN ≤ 8.0 kN ≤ 8.0 kN

Foot Acceleration ≤ 150 g ≤ 200 g ≤ 260 g > 260 g

VEHICLE STRUCTURE RATING

Lower Occupant Compartment Lower hinge pillar (resultant) ≤ 150 ≤ 225 ≤ 300 > 300
Intrusions (mm)
Footrest (resultant)

Left toepan (resultant)

Brake pedal (resultant)

Parking brake pedal (resultant)

Rocker panel (lateral) ≤ 50 ≤ 100 ≤ 150 > 150

Upper Occupant Compartment Steering column (longitudinal) ≤ 50 ≤ 100 ≤ 150 > 150
Intrusions (mm)
Upper hinge pillar (resultant) ≤ 75 ≤ 125 ≤ 175 > 175
Upper dash (resultant)

Left instrument panel (resultant)

279
SOB Assessment Assessment Criteria IIHS Rating

Good Acceptable Marginal Poor

RESTRAINTS AND DUMMY KINEMATICS RATING (Demerits)

Demerit score ≤1 ≤3 ≤5 >5

Frontal Head Protection Partial frontal airbag interaction 1

Minimal frontal airbag interaction 2

Excessive lateral steering wheel movement (>100 mm) 1
Two or more head contacts with structure 1
Late deployment or non-deployment of frontal airbag Automatic Poor
Lateral Head Protection Side head protection airbag deployment with limited 1
forward coverage

No side head protection airbag deployment 2

Excessive head lateral movement 1
Front Chest Protection Excessive vertical steering wheel movement (>100 mm) 1
Excessive lateral steering wheel movement (>100 mm) 1

Occupant Containment and Excessive occupant forward excursion (>250 mm) 1

Miscellaneous
Occupant burn risk 1

280
SOB Assessment Assessment Criteria IIHS Rating

Good Acceptable Marginal Poor

Seat instability 1
Seat attachment failure Automatic Poor
Vehicle door opening Automatic Poor

281
Annex 2 : COMPARISON TABLES FOR INCLUDED LITERATURE REVIEW ARTICLES – FRONTAL IMPACT

Table 54: Articles included for review of the real-world implications of the higher speed offset deformable barrier test in EU (Research Question 1)

Study Brumbelow Cuerden Eichberger Hallman Lindquist Pintar Richards Richards

(2009) (2007) (2007) (2011) (2006) (2008) (2010) (2010)
Country US UK Germany US Sweden US UK Germany
Database NASS/CDS CCIS GIDAS NASS/CDS (10/00-09/01) CIREN CCIS GIDAS
(2000-2006) (06/98-03/06) (Unspecified) (2004-2008) (2000-2006) (06/98-08/09) (Unspecified)
NASS
(2000-2006)
Additional Good IIHS frontal Belted, Belted, frontal ≥16YO, belted, Fatalities, R94 compliant, R94 compliant,
Selection offset test rated MAIS2+ only, occupants, non-ejected, D belted drivers, belted, all occupants,
Criteria cars only, belted all occupants vehicle-vehicle CDC code non-rollover, belted, non-
only, MY 2000- vehicle-vehicle rollover,
2006, AIS3+ only, vehicle-vehicle
injuries to
extremities
excluded
Total Sample 96 806 1,126 8,425 61 ~35,000 893 534
Offset (Y+Z)*
Moderate - 32% (MAIS2) 54% (MAIS2+) 4.7% (AIS2+) - 26% (All) 50% (MAIS2) -
Severe 24% (AIS3+) 32% (MAIS3+) 63% (MAIS3+) 1.5% (AIS3+) - 31% (AIS3+) 51% (MAIS3+) -
Fatal - 26% - - 20% - 58% -
Offset (Y)*
Moderate - 21% (MAIS2) - - - - 31% (MAIS2) -
Severe - 27% (MAIS3+) - - - - 42% (MAIS3+) -
Fatal - 19% - - 18% - 54% -
Offset (Z)*
Moderate - 11% (MAIS2) - - - - 19% (MAIS2) -
Severe - 5% (MAIS3+) - - - - 9% (MAIS3+) -
Fatal - 7% - - 2% - 4% -
LX Injuries†
Moderate - 29% (AIS2) - 77% (AIS2+) - - 36% (AIS2) 12% (AIS2)
Severe - 53% (AIS3+) - 65% (AIS3+) - - 44% (AIS3+) 27% (AIS3+)
Fatal - 63% - - - - 58% -
Study Brumbelow Cuerden Eichberger Hallman Lindquist Pintar Richards Richards
(2009) (2007) (2007) (2011) (2006) (2008) (2010) (2010)
∆V Occupants - 438 1,126 - - No correlation 779 531
56 kph‡
Moderate - 96% (MAIS2) 82% (All) - - - 96% (MAIS2) 96% (MAIS2)
Severe - 83% (MAIS3+) - - - - 90% (MAIS3+) 83% (MAIS3+)
Fatal - 60% - - - - 45% 45%
40 kph‡
Moderate - 61% (MAIS2) 60% (All) - - - 68% (MAIS2) 81% MAIS2)
Severe - 38% (MAIS3+) - - - - 45% (MAIS3+) 54% (MAIS3+)
Fatal - 28% - - - - 30% 30%

Study Scullion
(2010)
Country US
Database NASS/CDS
(1995-2008)
Additional MY1985+, non-
Selection rollover, non-fire
Criteria
Total Sample 26,162
Offset (Y+Z)*
Moderate 39% (MAIS2+)
Severe 46% (MAIS3+)
Fatal -
Offset (Y)*
Moderate -
Severe -
Fatal -
Offset (Z)*
Moderate -
Severe -
Fatal -
LX Injuries†
Moderate -
Severe -

283
 Study Scullion
(2010)
Fatal -
∆V Occupants -
56 kph‡
Moderate -
Severe -
Fatal -
40 kph‡
Moderate -
Severe -
Fatal -
All data extracted from studies using best available technique. * Brumbelow (2009): AIS3+ injuries experienced for moderate overlap impacts (MOI: interaction with one longitudinal member) as a proportion of all injuries. Cuerden
(2007): Injuries experienced at each severity level for offset frontal impacts (Y/Z) as a proportion of the injuries experienced at each severity level for all frontal impacts (i.e. MAIS2 offset frontal impact injuries as a proportion of all
MAIS2 frontal impact injuries). Eichberger (2007): Injuries experienced at each severity level for offset frontal impacts (≤60% interaction) as a proportion of the injuries experienced at each severity level for all frontal impacts (i.e.
MAIS2+ offset frontal impact injuries as a proportion of all MAIS2+ frontal impact injuries). Hallman (2011): Injuries experienced at each severity level for large overlap impacts (LOI: Y/Z/D) as a proportion of the injuries experienced
for all large overlap impacts (i.e. AIS2+ LOI injuries as a proportion of all LOI injuries). Linquist (2004): Fatalities experienced for offset frontal impacts (Y/Z) as a proportion of the fatalities experienced for all frontal impacts. Pintar
(2008): Injuries experienced at each severity level for offset frontal impacts (Y/Z) as a proportion of the injuries experienced at each severity level for all frontal impacts (i.e. AIS3+ offset frontal impact injuries as a proportion of all
AIS3+ frontal impact injuries). Richards (2010): Injuries experienced at each severity level for offset frontal impacts (OS/NS) as a proportion of the injuries experienced at each severity level for all frontal impacts (i.e. MAIS2 offset
frontal impact injuries as a proportion of all MAIS2 frontal impact injuries). Scullion (2010): Injuries experienced at each severity level for offset and moderate offset frontal impacts as a proportion of the injuries experienced at each
severity level for all frontal impacts (i.e. MAIS2+ offset frontal impact injuries as a proportion of all MAIS2+ frontal impact injuries).† Results provided for front seat occupant lower extremity injuries experienced at each severity level
in frontal impacts as a proportion of all injuries experienced at each severity level for front seat occupants in frontal impacts (i.e. AIS2 frontal impact lower extremity injuries as a proportion of all AIS2 frontal impact injuries). ‡ ∆V
results represent the cumulative proportion of injured occupants at each severity level for all frontal impacts. Abbreviations: Lx, lower extremity; AIS, abbreviated injury score; MAIS, maximum abbreviated injury score; MY, model year.

284
 Table 55: Articles included for review of the real-world implications of the full width rigid barrier test in the US (Research Question 2)

Study Brumbelow Cuerden Cuerden Frampton Hallman Kirk Lindquist Morris

(2009) (2001) (2007) (2000) (2011) (2002) (2004) (2001)
Country US UK UK UK US UK Sweden Australia
Accident NASS/CDS CCIS CCIS CCIS NASS/CDS CCIS (10/00-09/01) MUARC
Database (2000-2006) (1992-2000) (06/98-03/06) (1992-2000) (2004-2008) (1996-2001) (1995-2000)
Additional Good IIHS MY 1989-2000, Belted, Belted ≥16YO, belted, 10-2 o’clock, Fatalities, Matched study
Selection frontal offset single impact, MAIS2+ only, non-ejected, non-rollover belted groups (vehicle
Criteria test rated cars 3-point belted, all occupants Y/Z CDC code kerb-weight &
only, belted 10-2 o’clock ∆V), belted, 10-
only, MY 2000- 2 o’clock
2006, AIS3+
only, injuries to
extremities
excluded
Total Sample 96 2,335 806 5,215 8,425 2195 61 495
Full Width (D)*
Moderate - 40% (MAIS≤1) 44% (MAIS2) - 4.7% (AIS2+) 17% (MAIS2) - -
Severe 6% (AIS3+) 51% (MAIS2+) 49% (MAIS3+) - 1.5% (AIS3+) 11% (MAIS3+) - -
Fatal - - 56% - - - 45% -
Tx Injuries†
Moderate - - 39% (AIS2) 48% (AIS1) 32% (AIS2+) - - 33% (AIS1+)
Severe 67% (AIS3+) - 38% (AIS3+) 40% (AIS2+) 62% (AIS3+) - - 8% (AIS2+)
Fatal - - 81% - - - - -
Head Injuries†
Moderate - - 9% (AIS2) 9% (AIS1) 45% (AIS2+) - - 7% (AIS1+)
Severe 17% (AIS3+) - 8% (AIS3+) 36% (AIS2+) 19% (AIS3+) - - 4% (AIS2+)
Fatal - - 56% - - - - -

Cont’d… Pintar Richards Richards Scullion

(2008) (2010) (2010) (2010)
Country US UK Germany US

285
 Cont’d… Pintar Richards Richards Scullion
(2008) (2010) (2010) (2010)
Accident CIREN CCIS GIDAS NASS/CDS
Database (2000-2006) (06/98-08/09) (Unspecified) (1995-2008)
NASS
(2000-2006)
Additional R94 compliant, R94 compliant, MY1985+, non-
Selection all occupants, all occupants, rollover, non-
Criteria belted, non- belted, non- fire
rollover, rollover,
vehicle-vehicle vehicle-vehicle
Total Sample ~35,000 893 534 26,162
Full Width (D)*
Moderate 42% (All) 39% (MAIS2) - 44% (MAIS2+)
Severe 44% (AIS3+) 38% (MAIS3+) - 34% (MAIS3+)
Fatal - 33% - -
Tx Injuries†
Moderate - 32% (AIS2) 39% (AIS2) -
Severe - 52% (AIS3+) 60% (AIS3+) -
Fatal - 80% - -
Head Injuries†
Moderate - 8% (AIS2) 27% (AIS2) -
Severe - 5% (AIS3+) 27% (AIS3+) -
Fatal - 33% - -
All data extracted from studies using best available technique. * Brumbelow (2009): AIS3+ injuries experienced for full width impacts (FWI: interaction with two longitudinal members) as a proportion of all injuries. Cuerden (2001):
Injuries experienced at each severity level for full width frontal impacts (D) as a proportion of the injuries experienced at each severity level for all frontal impacts (i.e. MAIS2+ full width frontal impact injuries as a proportion of all
MAIS2+ frontal impact injuries). Cuerden (2007): Injuries experienced at each severity level for full width frontal impacts (D) as a proportion of the injuries experienced at each severity level for all frontal impacts (i.e. MAIS2 full width
frontal impact injuries as a proportion of all MAIS2 frontal impact injuries). Hallman (2011): Injuries experienced at each severity level for large overlap impacts (LOI: Y/Z/D) as a proportion of the injuries experienced for all large
overlap impacts (i.e. AIS2+ LOI injuries as a proportion of all LOI injuries). Kirk (2002): Injuries experienced at each severity level for frontal impacts as a proportion of the injuries experienced for all frontal impacts (i.e. MAIS2 frontal
injuries as a proportion of all frontal injuries). Linquist (2004): Fatalities experienced for full width frontal impacts (D) as a proportion of the fatalities experienced for all frontal impacts. Pintar (2008): Injuries experienced at each
severity level for offset frontal impacts (Y/Z) as a proportion of the injuries experienced at each severity level for all frontal impacts (i.e. AIS3+ offset frontal impact injuries as a proportion of all AIS3+ frontal impact injuries). Richards
(2010): Injuries experienced at each severity level for offset frontal impacts (OS/NS) as a proportion of the injuries experienced at each severity level for all frontal impacts (i.e. MAIS2 offset frontal impact injuries as a proportion of all
MAIS2 frontal impact injuries). Scullion (2010): Injuries experienced at each severity level for offset and moderate offset frontal impacts as a proportion of the injuries experienced at each severity level for all frontal impacts (i.e.
MAIS2+ offset frontal impact injuries as a proportion of all MAIS2+ frontal impact injuries). † Results provided for thoracic and head injuries experienced at each severity level for frontal impacts proportional to all injuries experienced
at each severity level for frontal impacts (i.e. AIS2 frontal thoracic extremity injuries as a proportion of all AIS2 frontal impact injuries). Abbreviations: Tx, thorax; AIS, abbreviated injury score; MAIS, maximum abbreviated injury
score; MY, model year.

286
Table 56: Articles included for review of the real-world implications of the belted and unbelted full width rigid barrier test in the US (Research
Questions 3 & 4)

Study Braver Braver Braver Braver Brumbelow Crandall Elvik Greenwell

(2005) (2008a) (2008b) (2010) (2007) (2001) (2009) (2013)
Country US US US US US US US & UK US
Accident FARS FARS FARS FARS FARS FARS Meta-Analysis FARS
Database (2000-2002) (1998-2005) (1998-2004) (2004-2007) (1996-2003) (1992-1997) (1993-2006) (2003-2011)
NASS/GES
(1998-2004)
Additional MY 1997-1999, MY 1994-2005, MY 1998-2004, Matched study Matched study Matched-pair Best estimate Matched-pair
Selection rollover, 12 head on car-car 11-1 o’clock, groups (vehicle groups (vehicle drivers from from included vehicle models
Criteria o’clock, drivers collisions only, seat belt use not structures & structures, ESC vehicle-vehicle studies (pre/post-US 3rd
only, fatalities fatalities, adj. controlled, ESC status), & airbag), 12 collisions only Gen)
for seat-belt, fatalities fatalities o’clock, drivers
age, car size only, fatalities
Total Sample 2,420 437 27,312 4,544 585 19,718 14 studies 5,428
Fatality Ratios*
US 3rd Gen vs. - - - - - - - O: 2.65RRe
All 2nd Gen D: 3.64RRe
FP: -1.82RRe
US 3rd Gen vs. - - - D: 1.10 - - - O: 4.79RRe
Advanced 2nd [0.94,1.28] D: 6.58RRe
Gen Airbag FP: 1.03 FP: -2.88RRe
[0.85,1.26]
US 3rd Gen vs. - - - D: 1.21 - - - -
Advanced 2nd [1.04,1.39]
Gen Airbag
(Belted)
US 3rd Gen vs. - - - D: 0.91 - - - -
Advanced 2nd [0.67,1.22]
Gen Airbag
(Unbelted)
US 3rd Gen vs. - - - - - - - O: -3.22RRe
Non-Advanced D: -4.30RRe
2nd Gen Airbag FP: 2.26RRe

287
Study Braver Braver Braver Braver Brumbelow Crandall Elvik Greenwell
(2005) (2008a) (2008b) (2010) (2007) (2001) (2009) (2013)
US 3rd Gen vs. - - - - - - - -
Non-Advanced
2nd Gen Airbag
(Belted)
US 3rd Gen vs. - - - - - - - -
Non-Advanced
2nd Gen Airbag
(Unbelted)
US Advanced - - - D: 0.84 - - - -
2nd Gen vs. [0.77,0.90]
Non-Advanced FP: 0.83
2nd Gen Airbag [0.68,1.00]
US Advanced - - - D: 0.96 - - - -
2nd Gen vs. [0.84,1.10]
Non-Advanced
2nd Gen Airbag
(Belted)
US Advanced - - - D: 0.68 - - - -
2nd Gen vs. [0.56,0.82]
Non-Advanced
2nd Gen Airbag
(Unbelted)
US 2nd Gen vs. D: 0.94 O: 1.04 D: 0.89RR - - - - -
1st Gen Airbag [0.88,1.01] [0.85,1.29] [0.74,1.08]
FP: 0.89RR
[0.74,1.07]
US 2nd Gen vs. D: 0.92 - - - - - D: -5OR -
1st Gen Airbag [0.81,1.05] [-6,-4]
(Belted) FP: -5OR
[-17,9]
US 2nd Gen vs. D: 0.93 - - - - - D: -1OR -
1st Gen Airbag [0.82,1.05] [-8,7]
(Unbelted) FP: -7OR
[-19,7]

288
Study Braver Braver Braver Braver Brumbelow Crandall Elvik Greenwell
(2005) (2008a) (2008b) (2010) (2007) (2001) (2009) (2013)
Load Limiter - - - - D: 0.82 - - -
vs. None [0.48,1.37]
Load Limiter + - - - - D: 1.36 - - -
2nd Gen Airbag [1.06,1.76]
vs. None
Load Limiter + - - - - D: 1.01 - - -
2nd Gen Airbag [0.79,1.30]
vs. 2nd Gen
Airbag
Tensioner + - - - - D: 1.27 - - -
Load Limiter + [0.74,2.19]
2nd Gen Airbag
vs. None
Any Airbag vs. - - - - - - - -
None
Any Airbag vs. - - - - - - D: -22OR -
None (Belted) [-28,-16]
Any Airbag vs. - - - - - - D: -25OR -
None (Belt Use [-47,5]
Adjusted)
Any Airbag vs. - - - - - - D: -13OR -
None [-18,-7]
(Unbelted)
US 2nd Gen - - - - - - D: -30OR -
Airbag vs. None [-42,-16]
US 2nd Gen - - - - - - - -
Airbag vs. None
(Belted)
US 2nd Gen - - - - - - - -
Airbag vs. None
(Unbelted)
US 1st Gen - - - - - D: 0.71 D: -21OR -
Airbag vs. None [0.58,0.87] [-27,-14]

289
Study Braver Braver Braver Braver Brumbelow Crandall Elvik Greenwell
(2005) (2008a) (2008b) (2010) (2007) (2001) (2009) (2013)
US 1st Gen - - - - - - - -
Airbag vs. None
(Belted)
US 1st Gen - - - - - - - -
Airbag vs. None
(Unbelted)
Any Seat Belt - - - - - D: 0.25 D: -50OR -
vs. None [0.22,0.29] [-55,-45]
FP: -45OR
[-55,-35]
Serious Injury
Ratios*
Any Airbag vs. - - - - - - D: -20OR -
None (Belted) [-25,-14]
FP: -28OR
[-43,-10]
Any Airbag vs. - - - - - - - -
None
(Unbelted)
Any Seat Belt - - - - - - D: -45OR -
vs. None [-50,-40]
FP: -45OR
[-60,-30]
EU Airbag vs. - - - - - - - -
None (Belted)

Cont’d… Høye Kahane MacLennan McGwin NHTSA Olson Teoh

(2010) (2006) (2008) (2003) (2001) (2006) (2014)
Country US, UK, France US US US US US US
& Australia
Accident Meta-Analysis FARS NASS/CDS NASS/CDS FARS FARS FARS
Database (1995-2008) (1994-2004) (1995-2004) (1995-2000) (1987-2001) (1990-2002) (2004-2011)

290
Cont’d… Høye Kahane MacLennan McGwin NHTSA Olson Teoh
(2010) (2006) (2008) (2003) (2001) (2006) (2014)
Additional Summary effect Matched study MY 1987-2005, ∆v ≥15 km/h, Fatalities, 12 MY 1987-2003, MY 1998-2010,
Selection from included groups (vehicle ≥16 YO, airbag 11-1 o’clock, o’clock, non- passenger cars 11-1 o’clock,
Criteria studies structures, ESC deployed, FS adjusted for rollover, driver crashes only, matched study
& airbag), non- occupants, 12 variables with only complete data groups (vehicle
rollover, 11-1 o’clock known effects only, matched structures &
o’clock, ≥13YO occupants, air ESC status),
bag activated, fatalities, ≥15
11-1 o’clock YO
Total Sample 24 studies - 21,329 32,058 >40,000 48,787 -
Fatality Ratios*
US 3rd Gen vs. - - - - - - -
All 2nd Gen
US 3rd Gen vs. - - - - - - D: 1.02
Advanced 2nd [0.95,1.10]
Gen Airbag FP: 1.03
[0.89,1.19]
US 3rd Gen vs. - - - - - - D: 1.12
Advanced 2nd [1.04,1.20]
Gen Airbag
(Belted)
US 3rd Gen vs. - - - - - - D: 0.88
Advanced 2nd [0.74,1.06]
Gen Airbag
(Unbelted)
US 3rd Gen vs. - - - - - - -
Non-Advanced
2nd Gen Airbag
US 3rd Gen vs. - - - - - - -
Non-Advanced
2nd Gen Airbag
(Belted)

291
Cont’d… Høye Kahane MacLennan McGwin NHTSA Olson Teoh
(2010) (2006) (2008) (2003) (2001) (2006) (2014)
US 3rd Gen vs. - - - - - - -
Non-Advanced
2nd Gen Airbag
(Unbelted)
US Advanced - - - - - - D: 0.90
2nd Gen vs. [0.85,0.95]
Non-Advanced FP: 0.84
2nd Gen Airbag [0.75,0.95]
US Advanced - - - - - - D: 1.02
2nd Gen vs. [0.89,1.18]
Non-Advanced
2nd Gen Airbag
(Belted)
US Advanced - - - - - - D: 0.74
2nd Gen vs. [0.63,0.87]
Non-Advanced
2nd Gen Airbag
(Unbelted)
US 2nd Gen vs. - D: 0.2RRe O: 0.64RR - - - -
1st Gen Airbag [-4,5] [0.29,1.41]
FP: 4.6RRe
[-5,13]
US 2nd Gen vs. D: -5OR D: 5RRe - - - D: 0.92RRR -
1st Gen Airbag [-6,-4] FP: 5RRe [0.77,1.10]
(Belted) FP: 0.90RRR
[0.75,1.08]
US 2nd Gen vs. D: -1OR D: -5RRe - - - D: 0.97RRR -
1st Gen Airbag [-8,7] FP: 7RRe [0.81,1.28]
(Unbelted) FP: 0.95RRR
[0.79,1.15]
Load Limiter - - - - - - -
vs. None

292
Cont’d… Høye Kahane MacLennan McGwin NHTSA Olson Teoh
(2010) (2006) (2008) (2003) (2001) (2006) (2014)
Load Limiter + - - - - - - -
2nd Gen Airbag
vs. None
Load Limiter + - - - - - - -
2nd Gen Airbag
vs. 2nd Gen
Airbag
Tensioner + - - - - - - -
Load Limiter +
2nd Gen Airbag
vs. None
Any Airbag vs. - D: -22RRe - - D: 29RRe - -
None [-28,-17] FP: 32RRe
FP: -32RRe
[-21,-41]
Any Airbag vs. D: -13OR - - - D: 21RRe - -
None (Belted) [-20,-5]
Any Airbag vs. D: -8OR - - - - - -
None (Belt Use [-14,-2]
Adjusted)
Any Airbag vs. D: -3OR - - - D: 36RRe - -
None [-11,2]
(Unbelted)
US 2nd Gen - - - - - O: 0.74RR -
Airbag vs. None [0.62,0.87]
US 2nd Gen - - - - - D: 0.71RR -
Airbag vs. None [0.59,0.85]
(Belted) FP: 0.66RR
[0.55,0.80]
US 2nd Gen - - - - - D: 0.82RR -
Airbag vs. None [0.68,0.90]
(Unbelted) FP: 0.77RR
[0.64,0.93]

293
 Cont’d… Høye Kahane MacLennan McGwin NHTSA Olson Teoh
(2010) (2006) (2008) (2003) (2001) (2006) (2014)
US 1st Gen - - - - - O: 0.79RR -
Airbag vs. None [0.75,0.85]
US 1st Gen D: -21OR - - - - D: 0.77RR -
Airbag vs. None [-27,-24] [0.72,0.83]
(Belted) FP: 0.74RR
[0.68,0.80]
US 1st Gen - - - - - D: 0.85RR -
Airbag vs. None [0.79,0.91]
(Unbelted) FP: 0.81RR
[0.75,0.88]
Any Seat Belt - - - - - - -
vs. None
Serious Injury -
Ratios*
Any Airbag vs. - - - O: 1.32RR - - -
None [1.03,1.68]
Any Airbag vs. - - - O: 0.71RR D: 80RRe - -
None (Belted) [0.49,1.02]
Any Airbag vs. - - - O:0.98 D: 49RRe - -
None [0.80,1.19]
(Unbelted)
Any Seat Belt - - - O:0.42 D: 80RRe - -
vs. None [0.36,0.48]
EU Airbag vs. D: -55OR - - - - - -
None (Belted) [-84,28]
All data extracted from studies using best available technique. * All data presented as rate ratios unless otherwise specified. Significant results highlighted with bold and italics. Abbreviations: O, overall front seat occupant results; D,
driver side occupant results; FP, front passenger occupant results; 1st Gen, 1st generation airbag (pre-1997 full powered airbag in the US); 2nd Gen, unspecified 2nd generation airbag (sled-certified airbag); Advanced 2nd Gen, 2nd
generation airbag (sled-certified airbag) with advanced features (such as dual/multistage inflator, seat track position sensor, seat belt use sensor or occupant size/weight sensor); Non-Advanced 2nd Gen, 2nd generation airbag (sled
certified airbag) without advanced features; 3rd Gen, certified advanced and compliant (with FMVSS204) airbag; RR, risk ratio; OR, odds ratio (%); RRe, risk reduction ratio (%); RRR, ratio of risk ratios.

294
Table 57: Articles included for review of the real-world implications of the 5th percentile female Hybrid-III full width rigid barrier tests in the US
(Research Question 5)

Study Carter Hill Kirk Lenard Malczyk Newgard Welsh Welsh

(2014) (2006) (2002) (2001) (2013) (2008) (2001) (2003)
Country US US UK UK Germany US UK UK
Accident NASS/CDS NASS/GES CCIS CCIS GIDAS NASS/CDS CCIS CCIS
Database (2000-2010) (2000) (1996-2001) (1992-2000) (1999-2010) (1995-2006) (1992-2000) (1992-2001)
Additional MY ≥2000, Passenger 10-2 o’clock, Belted only MAIS3+ MY 1990-2006, Belted only Belted only,
Selection three-point vehicles only non-rollover drivers only, aged ≥15 YO, drivers only
Criteria belted and 11-1 o’clock, controlled for
unbelted only, belted only, confounders
aged 16+ YO, non-multi-
front outboard vehicle, non-
occupants only, rollover, ∆v 26-
occupants with 70kph, compact
known height, and subcompact
weight and age vehicles only
only
Total Sample 18,371 >114,000 2195 4,414 19 37,663 1,151 1,470
Occupant
Stature*
AIS2+ head - - 6% (<1.73 m) - - - - -
injuries for 6% (<1.65 m)
small occupants 6% (<1.61 m)
and airbag
deployed
AIS2+ head - - 12% (<1.73 m) - - - - -
injuries for 14% (<1.65 m)
small occupants 23% (<1.61 m)
and no airbag
deployed
AIS2+ head - - - 14%† - - 8% (≤1.55 m)
injuries for (≤1.70 m) 7% (≤1.70 m)
small occupants
and airbag fitted
Study Carter Hill Kirk Lenard Malczyk Newgard Welsh Welsh
(2014) (2006) (2002) (2001) (2013) (2008) (2001) (2003)
AIS2+ head - - - - - - 21% (≤1.55 m)
injuries for 14% (≤1.70 m)
small occupants
and no airbag
fitted
AIS2+ head - - 3.4% (>1.73 m) - - - - -
injuries for tall
occupants and
airbag deployed
AIS2+ head - - 7.5% (>1.73 m) - - - - -
injuries for tall
occupants and
no airbag
deployed
AIS2+ head - - - - 25%† - - 7% (>1.85 m)
injuries for tall (>1.70 m) 4% (>1.70 m)
occupants and
airbag fitted
AIS2+ head - - - - - - - 15% (>1.85 m)
injuries for tall 10% (>1.70 m)
occupants and
no airbag fitted
AIS2+ pelvis - - - - 85%† - - 23% (≤1.55 m)
and lower (≤1.70 m) 14% (≤1.70 m)
extremity
injuries for
small occupants
AIS2+ pelvis - - - - 58%† - - 9% (>1.85 m)
and lower (>1.70 m) 11% (>1.70 m)
extremity
injuries for tall
occupants

296
Study Carter Hill Kirk Lenard Malczyk Newgard Welsh Welsh
(2014) (2006) (2002) (2001) (2013) (2008) (2001) (2003)
Belted AIS2+ - - <1.65 m (small) - - - - -
head injuries >1.8 m (tall)
regression
analysis point of
divergence
between airbag
equipped/non-
equipped
AIS3+ injuries - - - - - <1.55 m (small) - -
regression >1.9 m (tall)
analysis point of
divergence
between airbag
deployed/non-
deployed
Belted AIS2+ - - No significant - - - - -
head injuries difference
significant (p=0.08)
difference in
regression
analyses
between airbag
equipped/non-
equipped
AIS3+ injuries - - - - - <1.38 m (small) - -
significant
difference in
regression
analyses
between airbag
deployed/non-
deployed
Female
Occupants‡

297
Study Carter Hill Kirk Lenard Malczyk Newgard Welsh Welsh
(2014) (2006) (2002) (2001) (2013) (2008) (2001) (2003)
Log. parameter -0.438 - - - - - - -
estimate for all (-1.88,1.01)
female AIS3+
thoracic injuries
Predicted 5618 - - - - - - -
decrease in all (4212,6272)
AIS3+ thoracic
injuries
Log. parameter 2.143 - - - - - - -
estimate for all (1.19,3.10)
female AIS3+
upper extremity
injuries
Predicted 3089 - - - - - - -
decrease in all (832,3755)
AIS3+ upper
extremity
injuries
Log. parameter 0.513 - - - - - - -
estimate for all (0.30,0.72)
female AIS3+
lower extremity
injuries
Predicted 2791 - - - - - - -
decrease in all (2216,3256)
AIS3+ lower
extremity
injuries
Log. parameter - 0.3637 - - - - - -
estimate for all (55-74 YO)
female severe 0.6885
injuries (≥75 YO)

298
Study Carter Hill Kirk Lenard Malczyk Newgard Welsh Welsh
(2014) (2006) (2002) (2001) (2013) (2008) (2001) (2003)
Odds ratios for - 5.27 - - - - - -
likelihood of all (55-74 YO)
female severe 2.33
injuries (≥75 YO)
Driver MAIS1 - - - 66% (Female) - - 61% (Female) -
injuries 66% (Male) 52% (Male)
Driver MAIS2 - - - 21% (Female) - - 20% (Female) -
injuries 22% (Male) 18% (Male)
Driver MAIS3+ - - - 13% (Female) - - 12% (Female) -
injuries 13% (Male) 10% (Male)
Front seat - - - 65% (Female) - - -
passenger 68% (Male)
MAIS1 injuries
Front seat - - - 24% (Female) - - - -
passenger 18% (Male)
MAIS2 injuries
Front seat - - - 11% (Female) - - - -
passenger 13% (Male)
MAIS3+
injuries
Driver thoracic - - - 37% (Female) - - - -
injuries for 34% (Male)
MAIS2
Front seat - - - 53% (Female) - - - -
passenger 31% (Male)
thoracic injuries
for MAIS2
Driver leg - - - 34% (Female) - - - -
injuries for 29% (Male)
MAIS2
Front seat - - - 18% (Female) - - - -
passenger leg 19% (Male)
injuries for
MAIS2

299
 Study Carter Hill Kirk Lenard Malczyk Newgard Welsh Welsh
(2014) (2006) (2002) (2001) (2013) (2008) (2001) (2003)
Driver arm - - - 23% (Female) - - - -
injuries for 26% (Male)
MAIS2
Front seat - - - 29% (Female) - - - -
passenger arm 40% (Male)
injuries for
MAIS2
Driver AIS2 - - - - - - 36% (Female) -
thoracic injuries 34% (Male)
for MAIS2
Driver AIS2 leg - - - - - - 33% (Female) -
injuries for 28% (Male)
MAIS2
Driver AIS2 - - - - - - 22% (Female) -
arm injuries for 26% (Male)
MAIS2
All data extracted from studies using best available technique. * All data presented as probability of injury unless otherwise specified. † Proportion of all AIS2+ injuries for each body region. ‡ Data presented as proportion of injuries
unless otherwise specified. Abbreviations: AIS, abbreviated injury score; MY, model year.

300
Table 58: Articles included for review of the real-world implications of the greater chest deflection performance limit in the US (Research Question 6)

Study Brumbelow Brumbelow Carroll Carter Cuerden Frampton Frampton Hallman

(2009) (2013) (2009) (2014) (2007) (2000) (2006) (2011)
Country US US UK US UK UK UK US
Accident NASS/CDS NASS/CDS CCIS NASS/CDS CCIS CCIS CCIS NASS/CDS
Database (2000-2006) (2000-2010) (2000-2010) (06/98-03/06) (1992-2000) (1997-2005) (2004-2008)
FARS
(200-2010)
Additional Good IIHS 11-1 o’clock, MY 2000+, MY ≥2000, Belted only, Belted only Belted only, ≥16YO, belted,
Selection frontal offset CDC damage non-rollover, three-point MAIS2+ only, MY <7 YO at non-ejected,
Criteria test rated cars extent of 3+, aged 12+ YO, belted and all occupants time of LOI collisions
only, belted belted & airbag known MAIS unbelted only, collision,
only, MY 2000- deployed only, score, belted, aged 16+ YO, fatalities only,
2006, AIS3+ pretensioners, controlled for front outboard non-underrun
only, injuries to force limiters & impact partner, occupants only,
extremities good IIHS rated impact severity, occupants with
excluded cars only, overlap, known height,
drivers only intrusion and weight and age
restraint type only
Total Sample 96 472 (67) 2,148 18,371 806 5,215 72 8,425
All Tx Injuries*
Moderate - - 40% (MAIS2) - 39% (AIS2) 48% (AIS1) - 32% (AIS2+)
Severe 54% (AIS3+) - 21% (MAIS3+) 0.5% (AIS3+) 38% (AIS3+) 40% (AIS2+) 65% (AIS4+) 62% (AIS3+)
Fatal - - - - 81% - - -
Full Width Tx
Injuries*
Moderate - - 43% (MAIS2+) - - - - -
Severe 67% (AIS3+) - - - - - - -
Fatal - - - - - - - -
Moderate
Overlap Tx
Injuries*
Moderate - - 23% (MAIS2+) - - - - -
Severe 53% (AIS3+) - - - - - - -
Fatal - - - - - - - -

301
Study Brumbelow Brumbelow Carroll Carter Cuerden Frampton Frampton Hallman
(2009) (2013) (2009) (2014) (2007) (2000) (2006) (2011)
Tx Restraint
Injuries*
Moderate - - - - - - - -
Severe 44% (AIS3+) - - - - - - -
Fatal - - - - - - - -
Full Width Tx
Injury Rates*
AIS3+ with - 4% - - - - - -
Damage Extent
Forward of
Firewall
AIS3+ with - 3% - - - - - -
Damage Extent
to Firewall
AIS3+ with - 60% - - - - - -
Damage Extent
Rearward of
Firewall
Moderate
Overlap Tx
Injury Rates*
AIS3+ with - 1% - - - - - -
Damage Extent
Forward of
Firewall
AIS3+ with - 12% - - - - - -
Damage Extent
to Firewall
AIS3+ with - 24% - - - - - -
Damage Extent
Rearward of
Firewall

302
Cont’d… Lenard Morris Prasad Richards Richards Richter Zhu
(2001) (2001) (2004) (2010) (2010) (2001) (2010)
Country UK Australia US UK Germany Germany US
Accident CCIS MUARC NASS/CDS CCIS GIDAS MHH NASS/CDS
Database (1992-2000) (1995-2000) (1988-2001) (06/98-08/09) (Unspecified) (1985-1998) (2001-2005)

Additional Belted only Matched study 11-1 o’clock, R94 compliant, R94 compliant, Non-rollover ≥18YO,
Selection groups (vehicle aged 13+ YO, all occupants, all occupants, passenger cars
Criteria kerb-weight & belted only, belted, non- belted, non- and trucks,
∆V), belted, 10- AIS3+ only rollover, rollover, missing data
2 o’clock vehicle-vehicle vehicle-vehicle excluded
Total Sample 4,414 495 1,838,766 (w) 893 534 471 10,941
All Tx Injuries*
Moderate 38% (MAIS2) 33% (AIS1+) - 32% (AIS2) 39% (AIS2) 2.7% (AIS1+) 14% (MAIS1+)
Severe 39% (MAIS3+) 8% (AIS2+) 0.9% (AIS3+) 52% (AIS3+) 60% (AIS3+) - 1% (MAIS3+)
Fatal - - - 80% - - -
Full Width Tx
Injuries*
Moderate - - - - - - -
Severe - - - - - - -
Fatal - - - - - - -
Moderate
Overlap Tx
Injuries*
Moderate - - - - - - -
Severe - - - - - - -
Fatal - - - - - - -
Tx Restraint
Injuries*
Moderate - - - 28% (AIS2) - - -
Severe - - - 38% (AIS3+) - - -
Fatal - - - 14% - - -
Full Width Tx
Injury Rates*

303
 Cont’d… Lenard Morris Prasad Richards Richards Richter Zhu
(2001) (2001) (2004) (2010) (2010) (2001) (2010)
AIS3+ with - - - - - - -
Damage Extent
Forward of
Firewall
AIS3+ with - - - - - - -
Damage Extent
to Firewall
AIS3+ with - - - - - - -
Damage Extent
Rearward of
Firewall
Moderate
Overlap Tx
Injury Rates*
AIS3+ with - - - - - - -
Damage Extent
Forward of
Firewall
AIS3+ with - - - - - - -
Damage Extent
to Firewall
AIS3+ with - - - - - - -
Damage Extent
Rearward of
Firewall
All data extracted from studies using best available technique. * Brumbelow (2009): AIS3+ thoracic injuries experienced for all frontal, full width and moderate overlap impacts (full width: interaction with two longitudinal members;
moderate overlap: interaction with one longitudinal member) and restraint factors as a proportion of all AIS3+ frontal impact injuries. Brumbelow (2013): AIS3+ thoracic injuries experienced for all full width and moderate overlap
impacts and damage extent (loading configurations) as a proportion of all frontal impact injuries at each loading configuration. Carroll (2009): Thoracic injuries experienced at each severity level for all frontal impacts as a proportion of
all killed or seriously injured (KSI) occupants in frontal impacts (i.e. MAIS2+ thoracic frontal impact injuries as a proportion of KSI frontal impact occupants). Carter (2014): AIS3+ thoracic injuries experienced for all frontal impacts as
a proportion of all frontal impact injuries. Cuerden (2001): Thoracic injuries experienced at each severity level for frontal impacts as a proportion of all injuries experienced at each severity level for all frontal impacts (i.e. AIS2+ thoracic
frontal impact injuries as a proportion of all AIS2+ frontal impact injuries). Frampton (2000): Thoracic injuries experienced at each severity level for frontal impacts as a proportion of all injuries experienced at each maximum severity
level for all frontal impacts (i.e. AIS2+ thoracic frontal impact injuries as a proportion of all MAIS2+ frontal impact injuries). Frampton (2006): AIS4+ thoracic injuries experienced for all frontal impacts as a proportion of all AIS4+
frontal impact injuries. Hallman (2011): Thoracic injuries experienced at each severity level for large overlap impacts (LOI: Y/Z/D) as a proportion of the injuries experienced for all large overlap impacts (i.e. AIS2+ LOI thoracic injuries
as a proportion of all AIS 2+ LOI injuries). Lenard (2001): Thoracic injuries experienced as the most severe injury at each severity level for frontal impacts as a proportion of all occupants injured at each severity level for all frontal
impacts (i.e. MAIS2 thoracic frontal impact injuries as a proportion of all MAIS2 frontal impact injured occupants). Morris (2001): Thoracic injuries experienced at each severity level for frontal impacts as a proportion of all injured
occupants (i.e. AIS2+ thoracic frontal impact injuries as a proportion of all frontal impact injured occupants). Prasad (2004): AIS3+ thoracic injuries experienced for all frontal impacts as a proportion of all frontal impact injuries.
Richards (2010): Thoracic injuries experienced at each severity level for all frontal impacts as a proportion of all injuries experienced at each severity level for all frontal impacts (i.e. MAIS2 thoracic frontal impact injuries as a

304
proportion of all MAIS2 frontal impact injuries). Richter (2001): AIS1+ thoracic injuries experienced for all frontal impacts as a proportion of all frontal impact injuries. Zhu (2010): Thoracic injuries experienced at each severity level for
frontal impacts as a proportion of all injured occupants (i.e. AIS3+ thoracic frontal impact injuries as a proportion of all frontal impact injured occupants). Abbreviations: Tx, thorax; AIS, abbreviated injury score; MAIS, maximum
abbreviated injury score; IIHS, insurance institute for highways safety; MY, model year; YO, years old, R94, UNECE regulation 94; w, weighted.

305
Table 59: Articles included for review of the real-world implications of knee and lower leg performance limits in the EU (Research Question 7)

Study Carter Chong Cuerden Frampton Hallman Kuppa Kuppa Lenard

(2014) (2007) (2007) (2000) (2011) (2001) (2006) (2001)
Country US US UK UK US US US UK
Accident NASS/CDS CIREN CCIS CCIS NASS/CDS NASS/CDS NASS/CDS CCIS
Database (2000-2010) (1997-2003) (06/98-03/06) (1992-2000) (2004-2008) (1993-1999) (1993-2001) (1992-2000)
Additional MY ≥2000, Non-rollover, Belted only, Belted only ≥16YO, belted, Airbag Non-rollover, Belted only
Selection three-point non-ejection, 1- MAIS2+ only, non-ejected, equipped 11-1 o’clock or
Criteria belted and 11 o’clock all occupants LOI collisions vehicles, non- 10-2 o’clock
unbelted only, rollover, non- with GAD
aged 16+ YO, ejections, 11-1 forward of A-
front outboard o’clock or 10-2 pillar, aged 15+
occupants only, o’clock with YO, passenger
occupants with GAD forward cars, utility
known height, of A-pillar vehicles and
weight and age LTVs of weight
only <10,000lbs
Total Sample 18,371 336 806 5,215 8,425 - - 4,414
All Lx Injuries†
Moderate - 41% (Fx) 29% (AIS2) 45% (AIS1) 78% (AIS2+) 5% (AIS2+) 4.5% (AIS2+) 27% (MAIS2)
Severe 0.6% (AIS3+) - 53% (AIS3+) 43% (AIS2+) 66% (AIS3+) - - 26% (MAIS3+)
Fatal - - 63% - - - - -
Foot and Ankle
Injuries†
Moderate - 38% (Fx) - - - 0.33% (AIS2+) 2% (AIS2+) -
Severe - - - - - - - -
Fatal - - - - - - - -
All LL Injuries†
Moderate - 12% (Fx) - - - 0.12% (AIS2+) - -
Severe - - - - - - - -
Fatal - - - - - - - -
Knee Injuries†
Moderate - 5% (Fx) - - - 0.34% (AIS2+) - -
Severe - - - - - - - -
Fatal - - - - - - - -

306
Study Carter Chong Cuerden Frampton Hallman Kuppa Kuppa Lenard
(2014) (2007) (2007) (2000) (2011) (2001) (2006) (2001)
Knee Airbag
Injury Risk
AdjRR of Lx - - - - - - - -
Fracture
AdjRR of Foot - - - - - - - -
Fracture
AdjRR of LL - - - - - - - -
Fracture
AdjRR of Knee - - - - - - - -
Fracture

Cont’d… Moran Morris Patel Richards Richards Richter Weaver Zhu

(2003) (2001) (2013) (2010) (2010) (2001) (2013) (2010)
Country US Australia US UK Germany Germany US US
Accident NASS/CDS MUARC NASS/CDS CCIS GIDAS MHH CIREN NASS/CDS
Database (1995-2000) (1995-2000) (2000-2009) (06/98-08/09) (Unspecified) (1973-1996) (collected on (2001-2005)
CIREN 15/08/2011)
(2000-2009)
Additional Aged 13+ YO, Matched study Matched study R94 compliant, R94 compliant, Restrained only, MY <7 YO ≥18YO,
Selection MY <7 YO groups (vehicle groups (age, all occupants, all occupants, 11-1 o’clock from crash, 10- passenger cars
Criteria from crash, kerb-weight & sex, belt use, belted, non- belted, non- 2 o’clock, non- and trucks,
frontal and ∆V), belted, 10- seating position, rollover, rollover, rollover, non- missing data
near-side offset 2 o’clock ∆V, vehicle vehicle-vehicle vehicle-vehicle ejection, excluded
type, sampling matched study
weight) groups (vehicle
types, ∆v, crash
type, belt use,
age, height,
weight)
Total Sample 1,954,760 (w) 495 554 893 534 8053 40 10,941
All Lx Injuries*
Moderate 6% (Fx) 29% (AIS1+) 14% (Fx) 33% (AIS2) 12% (AIS2) - - 19% (MAIS1+)
Severe - 4.5% (AIS2+) - 43% (AIS3+) 26% (AIS3+) - - 1% (MAIS3+)
Fatal - - - 62% - - - -

307
 Cont’d… Moran Morris Patel Richards Richards Richter Weaver Zhu
(2003) (2001) (2013) (2010) (2010) (2001) (2013) (2010)
Foot and Ankle
Injuries*
Moderate - - 4.5% (Fx) - - 2.3% (Fx) - -
Severe - - - - - - - -
Fatal - - - - - - - -
All LL Injuries*
Moderate - - 5.2% (Fx) - - - - -
Severe - - - - - - - -
Fatal - - - - - - - -
Knee Injuries*
Moderate - - 1.1% (Fx) - - - - -
Severe - - - - - - - -
Fatal - - - - - - - -
Knee Airbag
Injury Risk†
Risk of Lx - - 0.87RR - - - -
Fracture [0.51,1.48]
Risk of Foot - - 1.96RR - - - 0.69PD -
Fracture [0.72,5.32]
Risk of LL - - 1.23RR - - - 0.52PD -
Fracture [0.52,2.90]
Risk of Knee - - 1.13RR - - - -0.03 -
Fracture [0.13,9.63]
All data extracted from studies using best available technique. * Carter (2014): AIS3+ lower extremity injuries experienced for all frontal impacts as a proportion of all frontal impact injuries. Chong (2007): Lower extremity, foot and
ankle, lower leg and knee fractures experienced as a proportion of all frontal impact injured occupants. Cuerden (2001): Lower extremity injuries experienced at each severity level for frontal impacts as a proportion of all injuries
experienced at each severity level for frontal impacts (i.e. AIS2+ lower extremity frontal impact injuries as a proportion of all AIS2+ frontal impact injuries). Frampton (2000): Lower extremity injuries experienced at each severity level
for frontal impacts as a proportion of all injuries experienced at each maximum severity level for all frontal impacts (i.e. AIS2+ lower extremity frontal impact injuries as a proportion of all MAIS2+ frontal impact injuries). Hallman
(2011): Lower extremity injuries experienced at each severity level for large overlap impacts (LOI: Y/Z/D) as a proportion of the injuries experienced for all large overlap impacts (i.e. AIS2+ LOI lower extremity injuries as a proportion
of all AIS 2+ LOI injuries). Kuppa (2001): AIS2+ lower extremity, foot and ankle, lower leg and knee injuries experienced as a proportion of all frontal impact injured occupants. Kuppa (2003): AIS2+ lower extremity and lower leg
injuries experienced as a proportion of all frontal impact injured occupants. Lenard (2001): Lower extremity injuries experienced as the most severe injury at each severity level for frontal impacts as a proportion of all occupants injured
at each severity level for all frontal impacts (i.e. MAIS2 lower extremity frontal impact injuries as a proportion of all MAIS2 frontal impact injured occupants). Moran (2003): Lower extremity fractures as a proportion of all frontal
impact injured occupants. Morris (2001): Lower extremity injuries experienced at each severity level for frontal impacts as a proportion of all injured occupants (i.e. AIS2+ lower extremity frontal impact injuries as a proportion of all
frontal impact injured occupants). Patel (2013): Lower extremity, foot, lower leg and knee fractures experienced as a proportion of all frontal impact injured occupants. Richards (2010): Lower extremity injuries experienced at each
severity level for all frontal impacts as a proportion of all injuries experienced at each severity level for all frontal impacts (i.e. MAIS2 thoracic frontal impact injuries as a proportion of all MAIS2 frontal impact injuries). Richter (2001):
Foot fractures as a proportion of all injured occupants. Weaver (2013): Foot and ankle, lower leg and knee fractures experienced as a proportion of all matched-pair frontal impact injured occupants. Zhu (2010): Lower extremity injuries
experienced at each severity level for frontal impacts as a proportion of all injured occupants (i.e. AIS3+ lower extremity frontal impact injuries as a proportion of all frontal impact injured occupants). Abbreviations: Lx, lower extremity;

308
LL, lower leg; AIS, abbreviated injury score; MAIS, maximum abbreviated injury score; Fx, fracture; IIHS, insurance institute for highways safety; MY, model year; YO, years old, R94, UNECE regulation 94; GAD, general area of
damage; LTVs, light trucks/vans; RR, risk ratio; PD, paired difference.

309
Table 60: Articles included for review of the real-world implications of the out-of-position infant and young child frontal impact tests in the US
(Research Question 13)

Study Arbogast Cummings Durbin Newguard Olson

(2005) (2002) (2003) (2005) (2006)
Country US US US US US
Accident PCPS FARS PCPS NASS/CDS FARS
Database (1998-2002) (1992-1998) (1998-2002) (1995-2002) (1990-2002)
Additional MY ≥1990, MY 1989-1997, MY ≥1990, MY 1990-2002, MY 1987-2003,
Selection child aged 3-15 child aged ≤12 child aged 3-15 child aged ≤18 child aged ≤12
Criteria YO, front plane YO, fatalities YO, belted only YO, YO, fatalities,
of vehicle only, passenger car
belted only crashes only,
complete data
only, matched
occupants, air
bag activated,
11-1 o’clock
Total Sample 1,148 90,264 1,243 3,790 48,787
All Injuries*
Moderate - - 86% (AIS1+) - -
Severe 13% (AIS2+) - 14% (AIS2+) 1.6% (AIS3+) -
Fatal - - - - -
PAB Injury
Risks†
2nd Gen Airbag - - - - 0-5: 1.10aRR
vs. No Airbag [0.63,1.93]
6-12: 0.71aRR
[0.48,1.05]
2nd Gen Airbag - - - - 0-5: 1.07aRR
vs. No Airbag [0.61,1.89]
(Restrained) 6-12: 0.68aRR
[0.46,1.01]

310
 Study Arbogast Cummings Durbin Newguard Olson
(2005) (2002) (2003) (2005) (2006)
2nd Gen Airbag - - - - 0-5: 1.22aRR
vs. No Airbag [0.69,2.17]
(Unrestrained) 6-12: 0.78aRR
[0.52,1.16]
2nd Gen Airbag 0.59OR (AIS2+) - - - -
vs. 1st Gen [0.36,0.97]
Airbag
2nd Gen Airbag - - - - 0-5: 0.66aRRR
vs. 1st Gen [0.35,1.24]
Airbag 6-12: 0.75aRRR
(Restrained) [0.49,1.16]
2nd Gen Airbag - - - - 0-5: 0.69aRRR
vs. 1st Gen [0.36,1.31]
Airbag 6-12: 0.79aRRR
(Unrestrained) [0.51,1.23]
1st Gen Airbag - - 0-5: 1.66aRR
vs. No Airbag [1.20,2.30]
6-12: 0.93aRR
[0.74,1.17]
1st Gen Airbag - 1.13aRR 2.0OR (AIS2+) - 0-5: 1.63aRR
vs. No Airbag [0.92,1.40] [1.1-3.7] [1.18,2.26]
(Restrained) 5.3OR (AIS1+) 6-12: 0.91aRR
[2.1-13.4] [0.72,1.14]
1st Gen Airbag - 1.42aRR - - 0-5: 1.77aRR
vs. No Airbag [1.12,1.80] [1.28,2.46]
(Unrestrained) 6-12: 0.98aRR
[0.78,1.24]
All Airbag vs. - - - 0-14: 6.13aOR
No Airbag [0.30,126]
All data extracted from studies using best available technique. * Arbogast (2005): AIS2+ injuries experienced for PAB deployed frontal impacts as a proportion of all PAB deployed frontal impacts. Durbin (2003): Injuries experienced at
each severity level for PAB deployed frontal impacts as a proportion of all PAB deployed frontal impacts (i.e. AIS2+ PAB deployed frontal impact injuries as a proportion of all PAB deployed frontal impacts). Abbreviations: PAB,
passenger airbag; 1st Gen, 1st generation airbag (pre-1997 full powered airbag in the US); 2nd Gen, 2nd generation airbag (sled-certified airbag); AIS, abbreviated injury score; MY, model year; YO, years old; aRR, adjusted risk ratio;
OR, odds ratio; aOR, adjusted odds ratio; aRRR, adjusted ratio of risk ratios.

311
 Annex 3 : COMPARISON TABLES FOR EU REGULATIONS AND US STANDARDS – SIDE IMPACT

Table 61: Comparison of legislative MDB Side Impact requirements in EU (UN Regulation No. 95) and USA (FMVSS 214)

EU (UN Regulations) US (FMVSSs)

Property Comparison
Specification Reference Specification Reference
VEHICLE
Vehicle tested Manufacturer is R95 Any certified EU test may be
entitled to 3.3 production vehicle performed on
present any data may be subject to a prototype or
and results of compliance test incomplete prototype
tests carried out vehicle; performance
which make it of production vehicles
possible to required to be similar
establish that by clauses in R95 by
compliance with R95 separate conformity of
the 3.4.1 production legislation
requirements If performed, US test
can be achieved performed on
on prototype production vehicle
vehicles with a selected at random
sufficient degree
of accuracy
Vehicle need not R95
include all the 7.1
components Controlled by
proper to the CoP
type provided

312
 EU (UN Regulations) US (FMVSSs)
Property Comparison
Specification Reference Specification Reference
that it can be requirements in
shown that the 1958 and 1995
absence of the Agreements
components
omitted has no
detrimental
effect on the
performance
prescribed in the
requirements of
the regulation
Every vehicle
approved under
the regulation
shall be so
manufactured as
to conform to
the type
approved by
meeting the
requirements
(conformity of
production)
Mass and M1 and N1 R95, 1. Passenger cars FMVSS 214 S4, EU regulation applies
dimensions vehicles where (a) to any vehicle 3500

313
 EU (UN Regulations) US (FMVSSs)
Property Comparison
Specification Reference Specification Reference
the R point of MPVs, trucks and (b) kg or less, whereas
the lowest seat buses with a GVWR US regulation side
is ≤700mm from ≤2772 kg impact applies to
ground level 2007/46 EC vehicles of 2772 kg or
when the vehicle Annex II less.
is in the 1.1/1.1.1
reference mass
stage
M - Motor
vehicles
designed and
constructed
primarily for the 2007/46 EC
carriage of Annex II
persons and 1.2/1.2.1
their luggage.
(M1 - not more
than eight
seating positions
in addition to
the driver’s
seating position,
no space for
standing
passengers).
N - Motor

314
 EU (UN Regulations) US (FMVSSs)
Property Comparison
Specification Reference Specification Reference
vehicles
designed and
constructed
primarily for the
carriage of
goods. (N1 -
Vehicles of
category N
having a
maximum mass
not exceeding
3,5 tonnes).
Exclusions Not stated - Motor homes, S5, (4, b, 1) In the EU, Motor
explicitly in R95, ambulances and homes, ambulances
but the following other emergency etc would be classed
would be rescue/medical as either heavier
excluded under vehicles (including vehicles (N2/3 etc)
the adopting EC vehicles with fire- and/or be
legislation: fighting equipment), manufactured in small
Small series vehicles equipped quantities, thus would
(≤1000 per with wheelchair lifts, not be required to
annum) and and vehicles which carry out a side
individually have no doors or S5, (4, b , 2) impact test, although
manufactured exclusively have not stated in
vehicles doors that are regulation. Similar
designed to be easily exclusions are

315
 EU (UN Regulations) US (FMVSSs)
Property Comparison
Specification Reference Specification Reference
‘Special purpose attached or removed included in the US
vehicles’, such so the vehicle can be S5, (4, b , 3) legislation.
as motor operated without
caravans, doors.
ambulances,
hearses and
wheelchair Passenger cars with
accessible a wheelbase ≥130 S5, (4, b , 4)
vehicles inches need not
meet the
requirements of MDB
test as applied to
the rear seat.
Vehicles with side
facing rear seats or
seats that are so
small that they
cannot
accommodate the
dummy when using
the positioning
procedure are
exempt from the
Multi-stage build side impact.
vehicles MPVs, trucks and
numbering <250

316
 EU (UN Regulations) US (FMVSSs)
Property Comparison
Specification Reference Specification Reference
are exempt from buses with a GVWR
impact testing of more than 2,722
(NB: MSB are kg are exempt
often based on Nothing in US reg
larger vehicles with regards to MSB
thus R point
would be higher
than 700mm
from ground
level, exempting
them anyway
IMPACT CONFIGURATION
Impact speed 50 km/h ± R95 53 km/h ± 1km/h FMVSS 214 Speed difference -
1km/h, Annex 4, 3 (equates to 47 km/h S7 1.87mph,
stabilised at @ 90˚ to vehicle) FMVSS 214 - 148 kJ
least 0.5 m EU R95 - 92 kJ
before impact
If test is
performed at
higher speed
and criteria are
met, test is
acceptable
Impact angle Perpendicular R95, Annex 4, Crabbed (63°) S8.10 Crabbed angle in US
(90°) 2.3 regulation to simulate

317
 EU (UN Regulations) US (FMVSSs)
Property Comparison
Specification Reference Specification Reference
both vehicles moving.
VEHICLE STATUS
General spec Representative R95 Determine the FMVSS 214 Doesn’t talk about
of series Annex 4, 4.1 distance between a S8.2 “representative
production, level surface and a vehicle” as such in the
including all standard reference reg. But does talk
equipment point on the test about “vehicle
normally fitted R95 vehicle's body, attitude”. This refers
and shall be in Annex 4, 5.8 directly above each to suspension heights
normal running wheel opening, when etc.
order. R95 Annex 4, the vehicle is in its
Components 5.10 mentions fully loaded
may be omitted ‘vehicle condition at the test
if no test effect attitude’ site, with all tires
can be seen inflated to the
Tyres shall be manufacturer's
inflated to specifications listed
manufacturer’s on the vehicle's tire
recommended placard, and with
settings the vehicle filled to
100% of all fluid
capacities. The “fully
loaded condition” is
the test vehicle
loaded in accordance

318
 EU (UN Regulations) US (FMVSSs)
Property Comparison
Specification Reference Specification Reference
with FMVSS 214
S8.1. The load
placed in the cargo
area is centred over
the longitudinal
centreline of the
vehicle. The pre-test
vehicle attitude is
equal to the fully
loaded attitude ± 10
mm.
Test mass ±1% of R95 Unloaded vehicle FMVSS 214 US reg is a heavier
reference mass Annex 4, 4.3.1 weight + 136 kg of S8.1 vehicle due to added
(Unladen mass 2.10 luggage mass/or luggage mass.
of vehicle rated cargo/luggage
+100 kg (mass capacity (whichever
of dummy and is less) + the weight
its R95 of the dummies
instrumentation) Annex 4, 4.3.4
If the mass of
the measuring
apparatus on
board of the
vehicle exceeds
the 25 kg R95
Annex 4, 4.3.5

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allowed, it may
be offset by
reductions which
have no
noticeable effect
on the results of
the test.
The mass of the
measuring
apparatus shall
not change each
axle reference
load by more
than 5 per cent,
each variation
not exceeding
20 kg.
Fluids/fuel Fuel tank filled R95 Stoddard, between FMVSS 214 EU statement would
volume/mass with water to Annex 4, 4.3.2 92% - 94% of fuel S8.1 be heavier (Stoddard
mass equal to tank’s usable approx. 780 kg/m3,
90% of full fuel capacity stated by water approx.
load ±1% manufacturer. 1000 kg/m3)
R95 Stoddard to be bled
All the other EU has no mention of
Annex 4, 4.3.3 through fuel lines
systems (brake, bleeding through fuel
cooling, etc.) until intake/injectors lines etc.

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 EU (UN Regulations) US (FMVSSs)
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may be empty;
in this case, the
mass of the
liquids shall be
offset.
Adjustable Tested under R95 - - Nothing specified in
height normal Annex 4, 5.10 US regs on adjustable
suspension operating height suspension
conditions of use
at 50km/h
defined by the
manufacturer
DUMMY
Dummy size 50M, front R95 50M, front driver’s FMVSS 214 50M driver dummy
driver’s seat Annex 6, 1.2 seat LHD S11 used Small female
5F rear left rear passenger in US
passenger seat reg

Dummy class ES-2 R95 ES-2re (rib FMVSS 214 Similar dummy used
Annex 7, 2.7 extensions) front, S7.2.2 in driver’s position,
SID II rear female dummy is US
only
Dummy seat Place the R95 ES-2re 50M dummy FMVSS 214 Both situated on
position dummy in the Annex 7, 2.5 (Subpart U) in the S7.2.2 struck side of vehicle.
front seat of the front seat, SID-IIs Extra US detail for

321
 EU (UN Regulations) US (FMVSSs)
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impacted side as 5F dummy (Subpart rear passenger.
described in the V) in the rear seat.
side impact test The test dummies
procedure are placed and
specification positioned in the
front and rear
outboard seating
positions on the
struck side of the
vehicle
Head Impact
Driver Driver
Criterion

The head R95 The HIC shall not FMVSS 214 Both use same
performance 5.2.1.1/Annex exceed 1000 when S7.2.5 (a) HPC/HIC equation and
criterion (HPC) 4 Appendix 1, calculated in limit number, but the
shall be less 1. accordance with the maximum time
than or equal to following formula: interval for the
1000; when calculations is
there is no head different, so the EU
contact, the the requirement may be
The maximum time
HPC shall not be more stringent in
interval for the HIC
measured but be some cases.
calculation shall be
recorded as “no 36 ms. Extra detail in EU reg
head contact”. if no head contact
The maximum occurs.

322
 EU (UN Regulations) US (FMVSSs)
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time interval for
the HPC
calculation is
limited to the
head contact
duration
(likely > 36 ms)
Passenger Passenger
The HIC shall not FMVSS 214 No passenger included
exceed 1000 when S7.2.6 (a) in EU reg
calculated in
- - accordance with the
following formula:

Deflection/force
Driver Driver
measurements
Rib deflection R95 The deflection of any FMVSS 214 2 mm more deflection
criterion 5.2.1.2 (a) of the upper, middle, S7.2.5 (b) allowed in the US reg
≤42 mm and lower ribs, shall
not exceed 44 mm
(1.73 in)
Abdominal Peak R95 The sum of the FMVSS 214 Identical
Force ≤2500 N front, middle and

323
 EU (UN Regulations) US (FMVSSs)
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(= external 5.2.1.4 rear abdominal S7.2.5 (c) EU reg states external
force of 4500 N) forces shall not force as well,
exceed 2500 N (562 otherwise identical
lb)
Pubic Symphysis R95 The pubic symphysis FMVSS 214 Identical
Peak Force 5.2.1.3 force shall not S7.2.5 (c)
≤6000 N exceed 6000 N
(1350 lb)
Soft tissue R95 Not stated in US reg
criterion (VC) 5.2.1.2 (b) - -
≤1.0 m/s
- - Passenger
The resultant lower No passenger in EU
spine acceleration FMVSS 214 reg
- -
shall not exceed 82 S7.2.6 (b)
g
The sum of the FMVSS 214 No passenger in EU
acetabular and iliac S7.2.6 (c) reg
- -
pelvic forces shall
not exceed 5525 N
Temperature Stabilised R95 Stabilised FMVSS 208 1.6°C temperature
temperature of Annex 4, 2.6 temperature of the S8.1.5 range in US; 8°C
dummy at dummy at impact: range in EU

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 EU (UN Regulations) US (FMVSSs)
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impact: 22°C ± between 20.6°C and US range close to
4°C 22.2°C centre of EU range
SEAT ADJUSTMENT
Fore-aft Midway between R95 Midway between the FMVSS 214 Essentially identical,
position the foremost Annex 4 – foremost and S8.3.1.3.3.2 although the EU
and rearmost 5.5.1 rearmost positions, technical service has
positions, or or nearest notch the option to set the
nearest notch R95 towards the rear seat to any fore-aft
towards the rear 5.1.2 adjustment position
NB: The
technical service
may require the
test to be
conducted with
a different fore-
aft position
Height Midway between R95 Lowest height FMVSS 214 Mid height (of fixed
highest and Annex 4 – S8.3.1.3.3.3 height) in EU; lowest
lowest 5.5.4 height in US. This will
adjustment; or make the body
height regions of the dummy
corresponding to lower relative to the
fixed seat if the door and MDB in the
vehicle has a US compared with the

325
 EU (UN Regulations) US (FMVSSs)
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Specification Reference Specification Reference
fixed seat option EU
Seat cushion Position R95 If adjustable: FMVSS 214 Manufacturer’s choice
specified by the Annex 4 – 5.4 rearmost, lowest S8.3.1.3.1 in EU; specified
vehicle position and mid position in US
manufacturer angle
(NB: defined
under ‘comfort’
features)
Seat back angle Angle specified R95 ‘Nominal design FMVSS 214 Identical
by the vehicle Annex 4, 5.5.3 riding position’ S8.3.1.3 /
manufacturer; if specified by the S8.3.2.2
not specified, vehicle
25° from manufacturer; if not
vertical specified, 25° from
vertical
Head restraints Head restraint R95 Head restraint at FMVSS 214 Head restraint
shall be Annex 4, 5.5.2 highest and most S8.3.1.2 adjustment differs
adjusted such forward position (only applies to between regs. Unlikely
that its top 50M ES-2re to make a difference
surface is level driver dummy) unless forward-most
with the CoG of position (US)
the dummy’s interferes with the
head. If not dummy’s head during
possible, upper the test
most position

326
 EU (UN Regulations) US (FMVSSs)
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used
Lumbar support Position R95 Lumbar: lowest, FMVSS 214 Manufacturer’s choice
specified by the Annex 4 – 5.4 retracted or deflated S8.3.1.1 / in EU; specified
vehicle position S8.3.3.1 position in US
manufacturer (applies to 50M
(NB: defined ES-2re driver
under ‘comfort’ dummy and 5F
features) SID-IIs RSP
dummy)
Other All other seat R95 Other seat FMVSS 214 Not stated for male
adjustments adjustments Annex 4, 5.5.4 adjustments: any S8.3.3.2 driver in US reg. EU
shall be mid- adjustable part (only applies to statement applies to
point of providing additional 5F SID-IIs RSP all seating positions
available travel, support at dummy) not previously
or where fixed lowest/non-deployed affected by dummy
seats are an position. Head positioning
option, in the restraint at lowest parameters.
fixed seat and most forward
position. position. A “none
Nearest locking use” position is
points to excluded as a lowest
rearward, position.
downward and
outboard of the
mid-point.

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 EU (UN Regulations) US (FMVSSs)
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STEERING WHEEL AND SEAT-BELTS
Steering wheel If adjustable, all R95 Geometric centre FMVSS 214 Similar positioning, US
adjustments in Annex 4, 5.7 through its full range S8.4 is more specific with
their mid-travel of positions, or regards to latching
locations nearest lower locations
latched location, if
telescopic, Mid
position or nearest
rearward latched
location
Seat-belt / Safety-belts or R95 Restrained using all FMVSS 214 Both regs specify
Restraint other restraint Annex 4, available belt S12.1 safety device to be
systems which 6.2/6.3 systems in all used wherever fitted.
are specified for seating positions US spec does not
the vehicle shall where such belt FMVSS 214 mention use of
be used. Belts restraints are S12.3.1/S12.2.1 approved systems
should be of an provided.
approved type, Place adjustable
conforming to anchorages at
Reg 16 or nominal position for
equivalent a 50M/5F as
requirements, indicated by the
and mounted to vehicle manufacturer
anchorages
conforming to

328
 EU (UN Regulations) US (FMVSSs)
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Reg 14 or
equivalent
requirements.
Fitted to
manufacturer’s
instructions. If
none, height
adjustment shall
be set to
middle/ or lower
position nearest
to middle.
Pedals - - - -
BARRIER FACE
Dimensions Width: 1500 mm R95 Width: 1676 mm FMVSS 214 Both made up of two
± 10 mm Annex 5, 2.1.1 Height: 559 mm Figure 2 sections of various
Height: 500 mm Depth: 381 mm dimension, however
± 5 mm (main section) use different sizes.
Depth: 440 mm Depth: 102 mm EU reg states 6
± 5 mm (3 (bumper section) deformable elements.
elements, top US reg treats the two
row) sections as two whole
Depth: 500 mm sections.
± 5 mm (3
elements,

329
 EU (UN Regulations) US (FMVSSs)
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bottom row)
Height above 300 mm R95 279 mm from FMVSS 214 US impactor 30 mm
ground level Annex 5, 2.1.1 ground to larger Figure 2 higher bumper edge
section, 330 mm than EU reg. Could
from ground to result in bumper
bumper edge missing sill structure
and intruding further
into the passenger
compartment
Pre-crush Shall be R95 - - No “pre-crush” stated
performed on Annex 5, in US reg.
the surface of 2.1.2.1
honeycomb to
which the front
sheets are R95
attached. Annex 5,
Pre-crush shall 2.1.2.2
be performed on
the surface of R9
the honeycomb Annex 5,
to which the
2.1.2.3
front sheets are
attached. Zones
1-3 (bottom
row) crushed by

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 EU (UN Regulations) US (FMVSSs)
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Specification Reference Specification Reference
10 mm to give
depth of 500
mm. Zones 4-6
(top row)
crushed by 10
mm to give
depth of 440
mm.
Aluminium type Upper row: 3003 R95 Main section: 3003 CFR 49 Subpart Both use aluminium
Al Annex 5, Al C 587.14 a)2) structures. EU
Lower row: 5052 2.1.3.2./2.1.3.3 Bumper Section: regulation uses 5052
Al 3003 Al aluminium for lower
row; however, the
CFR 49 Subpart material choice is
C 587.14 b)2) made redundant when
the two are compared
due to the controlled
nature of the crush
behaviour.
Honeycomb The aluminium R95 Main section: Crush CFR 49 587.14, EU regs have defined
structure honeycomb Annex 5, strength 0.342 MPa a)2) strength corridors in
blocks should be 2.1.3.4 ±0-10% (49.6 psi which the materials
processed such ±0-10%) must lie. These are
that the force Bumper section: defined on a
deflection-curve CFR 49 587.14, pressure/displacement
Crush strength

331
 EU (UN Regulations) US (FMVSSs)
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Specification Reference Specification Reference
when statically 1.711 MPa ±0-10% b)2) graph and vary
crushed is within (248 psi ±0-10%) depending on where
the corridors the block is located on
defined for each the MDB.
of the six blocks. US regulation has
specific strengths
defined, with a
tolerance band. No
corridors through
which the material
need comply with.
EU (UN Regulations) US (FMVSS/SAE Standards)
Property Comparison
Specification Reference Specification Reference
MDB
MDB mass Mass: 950 kg R95 Mass: 1368 kg FMVSS 214 No tolerances stated
(trolley + ±20 kg Annex 5, 1.1- CoG: 1123 mm rear Figure 2 on US reg. Neither is
barrier face) CoG: 1.7 of front axle; 7.6 the CoG. US trolley is
Longitudinal mm left of 418 kg heavier than
median plane longitudinal centre EU reg
within 10 mm; line; 500 mm above US Reg: impact
1000 mm ± 30 the ground energy 148 kJ due to
mm behind font slightly higher speed
axle and 500 and heavier MDB
mm ± 30 mm EU Reg: impact

332
 EU (UN Regulations) US (FMVSSs)
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Specification Reference Specification Reference
above the energy 92 kJ due to
ground. 2000 slower 90˚ speed and
mm ± 30 mm lighter MDB
from front of
impactor
Trolley Track width: R95 Track width: FMVSS 214
dimensions 1500 mm Annex 5, 1.1- 1880 mm Figure 2
±10 mm 1.7 Wheelbase:
Wheelbase: 2591 mm
3000 mm Chassis length:
+10 mm 3632 mm
Chassis width:
1251 mm
Total length:
4115 mm (inc.
barrier face)
Angle of Perpendicular to R95 63° to vehicle FMVSS 214 Angle trajectory on US
trajectory the longitudinal Annex 4, 2.3 longitudinal S8.10 reg to simulate motion
median vertical centreline of both vehicles. Will
plane also apply different
forces to impact
dummies
Impact The longitudinal R95 Mark vertical line at FMVSS 214 No tolerance stated on
reference line vertical Annex 4, 2.4 location where S8.11 US reg. EU reg more

333
 EU (UN Regulations) US (FMVSSs)
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Specification Reference Specification Reference
centreline of the impact trolley will detailed on positioning
impact trolley strike vehicle of impact point. US
passes ±25 mm reg states marks for
through the vehicles of a different
vertical plane of wheelbase. (see below
the R point of points)
the front seat of
the side to be
impacted.
Horizontal
median plane
within two
planes ±25 mm
above and below
predetermined
plane
For vehicle with FMVSS 214 US specific centreline
wheelbase of ≤2896 S8.11.1 a) position requirement
- - mm, mark 940 mm
forward of centre of
vehicle’s wheelbase
For vehicle with FMVSS 214 US specific centreline
- - wheelbase of >2896 S8.11.1 b) position requirement
mm, mark 508 mm
rearward of the

334
 EU (UN Regulations) US (FMVSSs)
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centreline of the
vehicle’s front axle
OPENINGS
Door Opening - - Any side door that is FMVSS 214 No statement in EU
struck by the barrier S7.3 a) reg about detachment
shall not separate of doors from vehicle,
totally from the though the below EU
vehicle point could be seen to
cover that
No door shall R95 b)Any door FMVSS 214 Though no doors
open during test 5.3.1 (including rear S7.3 a should open during
hatch/tailgate that is b) either test, the US
not struck by the spec contains more
moving deformable detail on
barrier shall meet latches/mountings
the following etc.
requirements:
1) door shall not
disengage from
latched position
2) latch shall not
separate from
striker, hinge
components shall

335
 EU (UN Regulations) US (FMVSSs)
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Specification Reference Specification Reference
not separate from
each other or from
their attachment to
the vehicle
3) Neither latch nor
hinge systems of the
door shall pull out of
their anchorages
Door Locking With regards to R95 - - No mention of
(Auto locking) automatically 5.3.1.1 automatic door
locking doors locking on US
installed regulations
optionally/can
be de-activated,
verified by one
of two
procedures:
If testing to A4, R95 - - No mention of
5.2.2.1, 5.3.1.1.1 automatic door
demonstrate locking on US
that in the regulations
absence of an
auto
system/system
de-activated, no

336
 EU (UN Regulations) US (FMVSSs)
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door will open in
case of impact
If testing to A4, R95 - - No mention of
5.2.2.2 5.3.1.1.2 automatic door
manufacturer locking on US
shall regulations
demonstrate
that the inertial
load
requirements of
paragraph R11,
6.1.4 are met
for the unlocked
doors on the
non-struck side
After impact, R95 - - No mention of
the side doors 5.3.2 automatic door
on the non- locking on US
struck side shall regulations
be unlocked
With vehicles R95 - No mention of
equipped with 5.3.2.1/Annex automatic door
automatic 5, 5.2.1/5.2.2 locking on US
locking systems, regulations
the doors shall

337
 EU (UN Regulations) US (FMVSSs)
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be locked before
impact, and
unlocked after
impact, at least
on the none
struck side
Door Locking Doors shall be R95 Doors shall be closed FMVSS 214 Identical
closed not Annex 5, 5.2 not latched S8.7
locked
Windows Side windows at R95 Fully closed on FMVSS 214 Identical
least on the Annex 4, 5.1 struck side S8.5
struck side shall
be closed
Convertible Top - - Closed FMVSS 214 Nothing mentioned on
S8.6 convertible vehicles in
EU regulations
TRANSMISSION AND BRAKES
Transmission/ Gear: Neutral R95 Gear: Second gear FMVSS 214 Both regulations
Brakes Parking brake: Annex 4, 5.3 (manual); Neutral S8.8 specify parking brakes
Disengaged (auto) are disengaged, but
Parking brake: EU applies neutral
Disengaged gearing to all
drivetrain categories.
This could be due to

338
 EU (UN Regulations) US (FMVSSs)
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the angled nature of
the US test. The use
of 2nd gear may affect
roll of the vehicle
upon impact, though
it can be assumed the
car (in a real world
scenario) will be
moving with a gear
selected.
FUEL SPILLAGE
Initial fuel If there is R95 Not to exceed 28 g FMVSS 301 US spec more specific
leakage continuous 5.3.6 from impact until S5.5 about periods of
leakage of liquid rest leakage. EU has a flat
from the fuel leakage rate.
feed system,
rate of leakage
shall not exceed
30 g/min
Intermediate - - Shall not exceed 142 FMVSS 301
period g in a 5 minute S5.5
period following
cessation of motion
End period - - Shall not exceed 28 FMVSS 301

339
 EU (UN Regulations) US (FMVSSs)
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g during 1 minute S5.5
periods, for 25
minute total time
ELECTRIC VEHICLES
Spillage In the period Reg 95 Electrolyte spillage FMVSS 305 Same time frame as
from the impact 5.3.7.2 from propulsion S5.1 well as spillage of
until 30 minutes batteries. Not more electrolyte. 5 litres
after no than 5.0 litres of max within a
electrolyte from electrolyte from 30 minute time frame.
the REESS shall propulsion batteries No electrolyte must
spill into the shall spill outside the leak into/within the
passenger passenger passenger
compartment compartment, and compartment.
and no more no visible trace of R95 states 7%
than 7% of electrolyte shall spill electrolyte with 5 litre
electrolyte shall into the passenger max. Percentage
spill from the compartment. relative to battery
REESS except Spillage is measured size.
open type from the time the
traction vehicle ceases
batteries outside motion after a
the passenger barrier impact test
compartment. until 30 minutes
For open type thereafter, and
traction throughout any

340
 EU (UN Regulations) US (FMVSSs)
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batteries no static rollover after a
more than 7% barrier impact test.
with a maximum
of 5.0 litres shall
spill outside the
passenger
compartment.
The
manufacturer
shall
demonstrate
compliance in
accordance with
paragraph 6 of
Annex 9
System REESS located Reg 95 Electric energy FMVSS 305 Similar between
retention inside the 5.3.7.3 storage/conversion S5.2 regulations, nothing to
passenger device retention. become detached,
compartment During and after though F214 states at
shall remain in each test specified in least one bracket
the location in S6 of this standard: minimum to remain.
which they are (a) Electric energy The R95 states
installed and storage/conversion devices used for the
REESS devices shall remain REESS inside the
components attached to the passenger

341
 EU (UN Regulations) US (FMVSSs)
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shall remain vehicle by at least compartment shall not
inside REESS one component become detached,
boundaries. anchorage, bracket, implying anything
No part of any or any structure that detached outside of
REESS that is transfers loads from the passenger
located outside the device to the compartment is
the passenger vehicle structure, acceptable. Also, both
compartment for and state that nothing
electric safety (b) Electric energy used for the electric
assessment storage/conversion drivetrain shall enter
shall enter the devices located the passenger
passenger outside the occupant compartment.
compartment compartment shall
during or after not enter the
the impact test. occupant
The compartment.
manufacturer
shall
demonstrate
compliance in
accordance with
paragraph 7. of
Annex 9 (visual
inspection).
Physical Following the Reg 95 - - No US test for

342
 EU (UN Regulations) US (FMVSSs)
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Specification Reference Specification Reference
protection vehicle impact Annex 9, 4 exposed live objects
test any parts post-crash, EU
surrounding the regulation uses a
high voltage finger space test in
components any gaps that would
shall be, without appear after crash to
the use of tools, assess possible
opened, sources of electric
disassembled or shock from the high
removed. All voltage system.
remaining
surrounding
parts shall be
considered part
of the physical
protection.
The Jointed Test
Finger described
shall be inserted
into any gaps or
openings of the
physical
protection with
a test force of
10 N ±10% for
electrical safety

343
 EU (UN Regulations) US (FMVSSs)
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assessment. If
partial or full
penetration into
the physical
protection by
the Jointed Test
Finger occurs,
the Jointed Test
Finger shall be
placed in every
position as
specified below.
Starting from
the straight
position, both
joints of the test
finger shall be
rotated
progressively
through an
angle of up to
90° with respect
to the axis of
the adjoining
section of the
finger and shall

344
 EU (UN Regulations) US (FMVSSs)
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be placed in
every possible
position.
Internal
electrical
protection
barriers are
considered part
of the enclosure.
If appropriate a
low-voltage
supply (of not
less than 40 V
and not more
than 50 V) in
series with a
suitable lamp
should be
connected,
between the
Jointed Test
Finger and high
voltage live
parts inside the
electrical
protection

345
 EU (UN Regulations) US (FMVSSs)
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barrier or
enclosure.
Electrical safety If the AC high 5.3.7.1.4.1 After each test S5.3 Both regs have
voltage buses specified in S6 of isolation monitoring,
and the DC high this standard, each minimum 100 Ω/V for
voltage buses high voltage source DC and 500 Ω/V for
are galvanically in a vehicle must AC.
isolated from meet the electrical 500 Ω/V for AC alone
each other, isolation 500 Ω/V for DC
isolation requirements of without isolation
resistance subparagraph (a) or monitoring.
between the the voltage level
high voltage bus requirements of For EU reg, if finger
and the subparagraph (b). test is satisfied or if
electrical chassis the AC voltage after
(a) The electrical
(Ri, as defined impact is 30 V or less,
isolation of the high
in paragraph 5. then isolation
voltage source,
of Annex 9) resistance shall be a
determined in
shall have a minimum of 100 Ω/V.
5.3.7.1.4.2 accordance with the
minimum value procedure specified
of 100 Ω/V of in S7.6, must be
the working greater than or
voltage for DC equal to one of the
buses, and a following:
minimum value (1) 500 Ω/V for an
of 500 Ω/V of

346
 EU (UN Regulations) US (FMVSSs)
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Specification Reference Specification Reference
the working AC high voltage
voltage for AC source; or
buses. (2) 500 Ω/V for a DC
If the AC high high voltage source
voltage buses without electrical
and the DC high isolation monitoring
voltage buses during vehicle
are galvanically operation; or
connected (3) 100 Ω/V for a DC
isolation high voltage source
resistance with electrical
between the isolation monitoring,
high voltage bus in accordance with
and the the requirements of
electrical chassis S5.4, during vehicle
(Ri, as defined operation.
in paragraph 5. (b) The voltages V1,
of Annex 9) V2, and Vb of the
shall have a high voltage source,
minimum value measured according
of 500 Ω/V of to the procedure
the working
specified in S7.7,
voltage. must be less than or
However, if the equal to 30 VAC for
protection AC components or
degree IPXXB is

347
 EU (UN Regulations) US (FMVSSs)
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satisfied for all 60 VDC for DC
AC high voltage components.
buses or the AC
voltage is equal
or less than 30
V after the
vehicle impact,
the isolation
resistance
between the
high voltage bus
and the
electrical chassis
(Ri, as defined
in paragraph 5.
of Annex 9)
shall have a
minimum value
of 100 Ω/V of
the working
voltage.

348
Table 62: Comparison of legislative Pole Side Impact requirements in USA (FMVSS 214) and Global Technical Regulation No. 14 (which is likely to
be implemented in EU as UN Regulation No. 135)

US (FMVSS) GTR 14

Property Specification Reference Specification Reference Comparison

FMVSS GTR 14
214
VEHICLE
Vehicle Any certified As defined in local
tested production vehicle implementation of the
may be subject to a GTR
compliance test
Mass and Passenger cars S4 Category 1-1 vehicles 2
dimensions Multipurpose Category 1-2 and 2
passenger vehicles Category 2 vehicles
and trucks with Gross with a Gross Vehicle
Vehicle Weight Rating Mass ≤ 4,500 kg
≤ 4,536 kg (10,000
lb)
Exclusions Motor homes; S5(c) None listed
ambulances; vehicles
with a lowered floor or
raised/modified roof;
vehicles with the
driver’s or FSP’s seat
removed and replace
with wheelchair

349
 US (FMVSS) GTR 14

Property Specification Reference Specification Reference Comparison

FMVSS GTR 14
214
restraints; and
vehicles with
removable or no doors
IMPACT CONFIGURATION
Pole Vertical, rigid, S10.10 Fixed, rigid vertical 2.8 Essentially identical
Structure 254 mm diameter, metal structure, 254
stationary mm ± 6 mm diameter
Start no more than 102
mm above the lowest
point of the tyres on
the impact side of the
vehicle; extend above
the highest point of the
roof of the test vehicle
Impact Any speed up to and S9.1.2 Any speed up to and 7.1 Same maximum speed:
Velocity including 32 km/h including 32 km/h GTR and both US tests
May be reduced to allow any speed up to
26 km/h for vehicles of 32 km/h. GTR allows
width ≤1.5 m derogation on impact
speed for very small
vehicles
Angle of 75° ± 3° S10.11 75° ± 3° 7.3 Identical

350
 US (FMVSS) GTR 14

Property Specification Reference Specification Reference Comparison

FMVSS GTR 14
214
Impact
Impact Impact aligned with S10.11 Impact aligned with the Annex 4, Identical requirement,
Alignment the CoG of the driver S10.12.2 CoG of the driver Figure 4-1 / with tighter tolerance in
dummy’s head dummy’s head Figure 4-2 the GTR
Impact tolerance Impact tolerance
±38 mm ±25 mm
VEHICLE STATUS
Vehicle Determine the S10.2 Test vehicle when 2.5 Similar. GTR shares 136
Attitude distance between a positioned on a level kg additional weight with
level surface and a surface with all tyres the US regulations.
standard reference fitted and inflated as
point on the test recommended by the
vehicle's body, directly vehicle manufacturer
above each wheel and loaded to the laden
opening, when the mass. The test vehicle
vehicle is in its fully is loaded by centrally
loaded condition at positioning 136 kg or
the test site, with all the rated cargo and
tires inflated to the luggage mass
manufacturer's (whichever is less) in
specifications listed on the cargo / luggage
the vehicle's tire carrying area over the
placard, and with the longitudinal centreline

351
 US (FMVSS) GTR 14

Property Specification Reference Specification Reference Comparison

FMVSS GTR 14
214
vehicle filled to 100% of the vehicle. The
of all fluid capacities. mass of the necessary
The “fully loaded S8.1 anthropomorphic test
condition” is the test device is placed on the
vehicle loaded in front-row outboard
accordance with designated seating
FMVSS 214 S8.1. The S8.1 position on the impact
load placed in the side of the vehicle. The
cargo area is centred front-row seat on the
over the longitudinal impact side of the
centreline of the vehicle is positioned in
vehicle. The pre-test accordance with Annex
vehicle attitude is 2.
equal to the fully
loaded attitude ± 10
mm.
Unloaded vehicle
weight + 136 kg of
luggage mass/or rated
cargo/luggage
capacity (whichever is
less) + the weight of
the dummies.
Stoddard, between

352
 US (FMVSS) GTR 14

Property Specification Reference Specification Reference Comparison

FMVSS GTR 14
214
92% - 94% of fuel
tank’s usable capacity
stated by
manufacturer.
Stoddard to be bled
through fuel lines until
intake/injectors
Brakes/Ge Parking brake S10.9 The parking brake shall 5.6.1 GTR states no
aring engaged be engaged. Section E.15 transmission engagement
Auto: Neutral Requirements on is required, as it was
Manual: 2nd gear transmission concluded it would not
engagement were not make a difference to the
included as these test.
appeared inconsistent US regs state 2nd gear
within the requirement selection. All require
and incompatible with handbrake engagement.
some modern vehicle
drivetrains. The group
agreed that
transmission setting
would have no effect on
the result of a test.
SEAT ADJUSTMENT

353
 US (FMVSS) GTR 14

Property Specification Reference Specification Reference Comparison

FMVSS GTR 14
214
Fore-aft Mid S8.3.1.3.3 20 mm rearward of mid Annex 2, GTR-14 slightly rearward
Position 5.11 of F214
Height Lowest S8.3.1.3.2 Lowest Annex 2, 5.9 Identical
Seat Back As specified by the S8.3.1.2 50M design torso angle Annex 2, Very similar
Angle manufacturer; 25˚ if ±1°; or 23°±1° 6.20; 6.21
not specified by the
manufacturer
Lumbar Lowest, retracted or S10.3.2.1 Lowest, retracted or Annex 2, Identical
Support deflated adjustment most deflated 3.1.1.1
position adjustment position
Other Seat Lowest or non- S10.3.2.2 Rearmost or most Annex 2, Identical intent
Adjustment deployed adjustment retracted adjustment 3.1.1.2
s position position
OPENINGS
Doors Closed not locked S10.8 Fully closed and fully 5.5.1 Very similar
latched, but not locked
Roof/Sunro Raised/fully closed S10.8 In the closed passenger 5.4.1 Very similar
of compartment
configuration 5.9.2
Any sunroof(s) shall be
placed in the fully

354
 US (FMVSS) GTR 14

Property Specification Reference Specification Reference Comparison

FMVSS GTR 14
214
closed position
Windows Windows: All raised S10.6/S10. Moveable vehicle 5.9.1 Identical
7 windows and vents
located on the impact
side of the vehicle shall
be placed in the fully
closed position.
DUMMY
Dummy 50M driver S10.4 50M driver 3.3.1 50M driver in both cases
Size 5F RSP No rear seat occupant in
GTR
Dummy ES-2re driver S10.4 WorldSID 3.3.1 GTR uses World SID,
Class SID-IIs RSP Possibility to adopt a 5F FMVSS 214 uses ES2-re
WorldSID in a second and SID-IIs
phase of negotiations
Injury 50M ES2-re 50M WorldSID
Criteria
Head HIC36 1000 S9.2.1(a) HIC36 1000 4.2.2.1 Identical
Shoulders 3.0 kN 4.2.3.1 Additional requirement in
(peak lateral GTR (no equivalent
force) measurement capability

355
 US (FMVSS) GTR 14

Property Specification Reference Specification Reference Comparison

FMVSS GTR 14
214
in ES2-re
Thorax (rib 44 mm S9.2.1(b) 55 mm 4.2.4.1 F214 states a lower
deflection) maximum deflection limit
of 44 mm, cf. 55 mm in
GTR-14 due to differences
in the dummy biofidelity –
the injury risk is intended
to be equal
Abdomen Abdomen force 2.5 kN S9.2.1(c) Lateral deflection: 4.2.5.1 Different instrumentation,
65 mm leading to different
requirements – intention
is that the requirements
are equivalent
Lower spine 75 g (3 ms 4.2.5.2
acceleration exceedence)
Pelvis (pubis 6.0 kN S9.2.1(c) 3.36 kN 4.2.6.1 Different pelvis stiffness,
force) leading to different
requirements
SID-IIs
HIC36 1000 S9.2.2(a)
Lower spine 82 g S9.2.2(b)

356
 US (FMVSS) GTR 14

Property Specification Reference Specification Reference Comparison

FMVSS GTR 14
214
(acceleration
)
Pelvis (sum 5525 N S9.2.2(c)
of acetabular
and iliac
force)
Dummy 20.6-22.2°C S11.3 20.6-22.2°C 6.3 Identical
Temp

357
 Table 63: Comparison of legislative Door Latch requirements in EU (UN Regulation No. 11) and USA (FMVSS 206)

Property EU (UN Regulations) US (FMVSS/SAE Standards) Comparison

Specification Reference Specification Reference
R11 F206
VEHICLE TESTED
Scope M1 and N1 1 Passenger cars, multipurpose S2
passenger vehicles, and
trucks, and buses with a gross
vehicle weight rating
(GVWR) of 4,536 kg or less
Application Vehicle latches and door 1 Vehicle door locks and door S1
retention components such retention components,
as hinges and other including latches, hinges, and
supporting means on doors, other supporting means
which can be used for the All side and back doors, that S4
entry or exit of the lead directly into a
occupants and/or can compartment that contains
present the risk of occupants one or more seating
being thrown from a vehicle accommodations and the
as a result of impact associated door components
All side and back doors 5.1
Exceptions Latches and door retention 5.1 Door components on folding S4 Exception for bus doors in F206
components on folding doors, roll-up doors, would be outside scope for R11
doors, roll-up doors, detachable doors, bus doors anyway
detachable doors, and doors used only for emergency
that are designated to egress purposes and labelled
provide emergency egress accordingly and on bus doors

358
Property EU (UN Regulations) US (FMVSS/SAE Standards) Comparison
to accommodate a
permanently attached
wheelchair lift system
HINGED DOORS
Load Test 1 Each primary and auxiliary 6.1.1 Each primary and auxiliary S4.1.1.1 Identical
latch system when in the latch system when in the fully
fully latched position, shall latched position, shall not
not separate, load of separate, load of 11,000 N
11,000 N applied applied perpendicular to the
perpendicular to the face of face of the latch
the latch In secondary position:
In secondary position: 4,500 N in same direction
4,500 N in same direction
Load Test 2 Each primary and auxiliary 6.1.2 Each primary and auxiliary S4.1.1.2 Identical
latch system when fully latch system when fully
latched, shall not separate latched, shall not separate
when a load of 9,000 N when a load of 9,00 0N
applied in the fork-bolt applied in the fork-bolt
opening direction and opening direction and parallel
parallel to the face of the to the face of the latch
latch In secondary position:
In secondary position: 4,500 N in same direction
4,500 N in same direction
Load Test 3 (Applicable to ALL doors 6.1.3 (Applicable to BACK doors S4.1.1.3 Very similar; however, EU
that open vertically): that open vertically): requirement applies to ALL
Each primary latch system Each primary latch system doors that open vertically and
shall not disengage from the shall not disengage from the US requirement only to BACK

359
Property EU (UN Regulations) US (FMVSS/SAE Standards) Comparison
fully latched position when fully latched position when a doors that open vertically
a vertical load of 9,000 N is load of 9,000 N is applied
applied orthogonally to the directions
previously stated.
Inertial Load Each primary latch shall not 6.1.4 Each primary and auxiliary S4.1.1.4 Identical
disengage from fully latched latch shall not disengage from
position when an inertia fully latched position when
load of 30 g is applied to the an inertia load is applied to
system, including the latch the system, including the
and activation device, in latch and activation device, in
directions parallel to the directions parallel to the
vehicle’s longitudinal and vehicle’s longitudinal and
transverse axes, with the transverse axes, with the lock
lock disengaged disengaged
Vertical inertial load of 30 g Vertical inertial load of 30 g
applied in the case of back applied in the case of back
doors doors
Calculation method can be Calculation method can be
used instead, subjected to a used instead, subjected to a
load of 30 g load of 30 g
DOOR HINGES
Hinges Each door hinge system 6.1.5.1 Each door hinge system shall: S4.1.2 Similar forces applied to hinges.
shall: (a) Support the door US more specific about back
(a) support the door door hinges.
(b) Not separate when a
(b) not separate when a longitudinal load of 11,000 N
longitudinal load of is applied
11,000 N is applied (c) Not separate when a

360
Property EU (UN Regulations) US (FMVSS/SAE Standards) Comparison
(c) not separate when a transverse load of 9,000 N is
transverse load of 9,000 N is applied
applied (d) For back doors
(d) On doors which open in (1) Not separate when a load
a vertical direction, not of 11,000 N is applied
separate when a vertical perpendicular to the hinge
load of 9,000 N is applied face plate (longitudinal load
test) such that the hinge plates
are not compressed against
each other (Load Test One)
(2) Not separate when a load
of 9,000 N is applied
perpendicular to the axis of
the hinge pin and parallel to
the hinge face plate
(transverse load test) such
that the hinge plates are not
compressed against each
other (Load Test Two)
(3) Not separate when a load
of 9,000 N is applied in the
direction of the axis of the
hinge pin (Load Test Three—
only for back doors that open
in a vertical direction)
SLIDING SIDE DOORS
Load Test 1 At least one door latch 6.2.1 At least one door latch system S4.2.1.1 Identical intent – clarification of

361
Property EU (UN Regulations) US (FMVSS/SAE Standards) Comparison
system when in the fully when in the fully latched loading direction in F206
latched position, shall not position, shall not separate
separate when a load of when a load of 11,000 N is
11,000 N is applied applied perpendicular to the
perpendicular to the face of face of the latch such that the
the latch latch and striker anchorage
The primary door latch, are not compressed together
when in the secondary The primary door latch, when
latched position, shall not in the secondary latched
separate when a load of position, shall not separate
4,500 N in same direction when a load of 4,500 N in
same direction
Load Test 2 At least one door latch 6.2.2 At least one door latch system S4.2.1.2 Identical
system when in the fully when in the fully latched
latched position, shall not position, shall not separate
separate when a load of when a load of 9,000 N is
9,000 N is applied in the applied in the fork-bolt
fork-bolt opening direction opening direction and parallel
and parallel to the face of to the face of the latch
the latch The primary door latch, when
The primary door latch, in the secondary latched
when in the secondary position, shall not separate
latched position, shall not when a load of 4,500 N in
separate when a load of same direction
4,500 N in same direction
Inertial Load Each door latch system shall 6.2.3 Each door latch system shall S4.2.1.3 Identical
not disengage from the fully not disengage from the fully
latched position when an latched position when an

362
Property EU (UN Regulations) US (FMVSS/SAE Standards) Comparison
inertia load of 30 g is inertia load of 30 g is applied
applied to the system, to the system, including the
including the latch and latch and activation device, in
activation device, in directions parallel to the
directions parallel to the vehicle’s longitudinal and
vehicle’s longitudinal and transverse axes, with the lock
transverse axes, with the disengaged
lock disengaged Calculation method can be
Calculation method can be used instead, subjected to a
used instead, subjected to a load of 30 g
load of 30 g
Door System The track and slide 6.2.4 The track and slide S4.2.2 Identical
combination while in the combination while in the
closed fully latched closed fully latched position,
position, shall not separate shall not separate from the
from the door frame when a door frame when a force of
force of 18,000 N is applied 18,000 N is applied along the
along the vehicle transverse vehicle transverse axis
axis A failure will occur if a
A failure will occur if a separation permits a sphere of
separation permits a sphere diameter 100 mm to pass
of diameter 100 mm to pass from the interior to the
from the interior to the exterior of the vehicle, or
exterior of the vehicle, or either force application
either force application device displaces 300 mm
device displaces 300 mm
DOOR
LOCKS

363
Property EU (UN Regulations) US (FMVSS/SAE Standards) Comparison
General Each door shall be equipped 6.3.1 Each door shall be equipped S4.3 Identical
with at least one locking with at least one locking
device which, when device which, when engaged,
engaged, prevents operation prevents operation of the
of the exterior door handle exterior door handle and
and which has an internal which has an internal means
means of of engagement/release
engagement/release
Rear Side Each rear side door shall be 6.3.2 Each rear side door shall be S4.3.1 Child safety lock not mentioned
Doors equipped with at least one equipped with at least one in F206
locking device which, when locking device which, when
engaged, prevent operation engaged, prevent operation of
of the interior door handle the interior door handle,
Either a child safety lock or accessible to the driver or
a device accessible to the occupant adjacent to the door
driver or occupant adjacent
to the door
Back Doors Each back door shall be 6.3.3 Each back door shall be Identical
equipped with at least one equipped with at least one
locking device located locking device located within
within the interior of the the interior of the vehicle
vehicle which, when which, when engaged,
engaged, prevent operation prevent operation of the
of the interior door handle interior door handle

364
 Table 64: Comparison of legislative Interior Impact requirements in EU (UN Regulation 21) and US (FMVSS 226)

Property EU (UN Regulations) US (FMVSS/SAE Standards) Comparison

Specification Reference Specification Reference
R21 FMVSS 201
VEHICLE TESTED
Scope M1 1 Passenger cars, multipurpose S2 F201 applies to a wider range of
passenger vehicles, and vehicles than R21
trucks, and buses with a gross
vehicle weight rating
(GVWR) of 4,536 kg or less
Application The interior parts of the 1 Instrument panels, seat backs, S5; S6
passenger compartment interior compartment doors,
other than the rear-view sun visors, and armrests
mirror or mirrors; the Upper interior components –
arrangement of the controls; roof and pillars
the roof or opening roof,
and the seat-back and the
rear parts of seats
Exceptions A-pillars 2.3.3 - -
DANGEROUS ROUGHNESS, PROJECTIONS OR SHARP EDGES

365
Scope Any protruding objects that 5.1/5.2/5.3 - - EU only
can be contacted by a Can be applied to door cards and
165 mm sphere other side interior sections
Seat rails, seat adjustment 5.3.4.1 Applies to everything with an
devices and seat belt reals edge that can be contacted by the
etc. are not subject to sphere
regulation if situated below
the H point
Edge Radii Rounded edges ≥3.2 mm 5.3.2.1/5.3.4.1 Everything must have rounded /
blunted edges
Projections Width of projecting parts 5.3.4.1
shall not be less than the
amount of their downward
projection
Alternatively, projecting 5.2.4.1
parts shall pass the energy-
dissipating test
Control levers and knobs 5.1.5
shall retract or detach under
a forward-acting
longitudinal horizontal force
of 37.8 daN
Window winders may 5.3.2.2
project 35 mm from the
surface of the panel

366
Measuring Using a special apparatus Annex 6, 2.1.2 - - EU has very descriptive
projections consisting of a projection test, using half
hemispherical headform headform and retractable centre
165 mm in diameter in section. The device is placed on
which there is a sliding ram the tested projection, and the ram
of 50 mm diameter pushed in until it stops. The
If the panels and Annex 6, 1.1 value on the index is then noted.
components, etc., are
covered with materials
softer than 50 shore A
hardness, the procedure for
measuring the projections
described above shall apply
only after removal of such
materials.
GUIDED IMPACTOR ENERGY DISSIPATION TESTS
Head Form 165 mm sphere, 6.8 kg, Annex 4, 1.2.1 165 mm sphere. 6.8 kg S5.1 Identical headform size, EU
mounted on pole adjustable mounted on adjustable stick
between 736 mm and pivoting from representative H
840 mm, from H-point point
Impact 24.1 km/h, or in the case of Annex 4, 1.4.2 24 km/h, or 19 km/h where S5.1a/b Similar. EU reg states if a
Velocity components covering an the vehicle meets panel/part if covering an airbag
uninflated airbag: 19.3 km/h requirements for frontal (e.g. passenger dash panel), then
occupant crash by an apply 19 km/h impact speed. US
inflatable restraint system and reg states the vehicle must
of a type 2 SBA. comply with the protection
requirements in FMVSS208 to
apply 19 km/h impact speed.

367
Performance Not to exceed 80 g Annex 4, 2.1 Not to exceed 80 g S5.1b Identical
Requirement continuously for more than continuously for more than
3 ms 3 ms
Test Zones All the non-glazed surfaces Annex 1 Instrument panels, seat backs, S5.1
of the interior of a vehicle interior compartment doors,
above the lowest H-point of sun visors and arm rests
the front seats and capable
of being contacted statically
with a sphere of 165 mm
diameter attached to a rod
continuously adjustable
736-840 mm with its base at
the H-point of the seat
Towards the rear of the 5.3.1
vehicle the test zone is
limited by the torso
reference line of the
rearmost seats
Separate requirements for 5.2
zone below the instrument
panel (excluding pedals)
Exempt Areas The area bounded by the 2.3.1 a) console assemblies S5.1.1 US: more specific areas.
forward horizontal b) areas <125 mm inboard EU excludes A pillars
projection of a circle from juncture of instrument
circumscribing the outer panel to body side inner
limits of the steering structure
control, increased by a c)areas closer to the
peripheral band 127 mm in windshield juncture than
width; bounded below by those statically contactable by

368
 the horizontal plane the head form with the
tangential to the lower edge windshield in place
of the steering control when (d) Areas outboard of any
the latter is in the position point of tangency on the
for driving straight ahead instrument panel of a 165 mm
The part of the instrument 2.3.2 diameter head form tangent to
panel comprised between and inboard of a vertical
the edge of the area longitudinal plane tangent to
specified in paragraph 2.3.1. the inboard edge of the
above and the nearest inner steering wheel; or
side-wall of the vehicle; this (e) Areas below any point at
part of the surface is which a vertical line is
bounded below by the tangent to the rearmost
horizontal plane tangential surface of the panel.
to the lower edge of the Seats in school buses that S5.2.1
steering control comply with F222
The windscreen side pillars 2.3.3

Dynamically Differing from the Annex 8, 1 None defined - EU has options to prove head
determined procedure described in impact zones via various test
head impact Annex 1 (headform stick methods, including numerical
zone mounted test) the applicant method (e.g. computer
may prove, by a procedure simulation). However, that
accepted by the technical method requires being proven
service responsible for via another practical method.
conducting the tests, that a
All tests require the use of a 5F,
dynamically determined
50M, and 95M dummy at
head impact zone is relevant
various impact angles.
for this vehicle type.

369
Procedures may include:
Full-scale crash tests in the Annex 8, 1.2.1
range of ±30° against a
fixed rigid barrier with an
impact speed of at least
48.3 km/h. Normally it will
be sufficient to test at 0°,
+30° and -30° using 5F,
50M and 95M occupant
dummies at the
manufacturer’s design
seating position
Body shell sled tests using Annex 8, 1.2.2
the deceleration pulse
shown in R16 Annex 8
(change of velocity
50 km/h) using 5F, 50M and
95M occupant dummies
Normally it will be
sufficient to test with the
body shell oriented at O°,
+18° and -18°
Simulated impact tests Annex 8, 1.2.3
representing either of the
above

370
FREE-MOTION HEADFORM ENERGY DISSIPATION TESTS

Head Form None defined - Part 572 subpart L free- S3

motion headform (mass
4.54 kg)
Headform is launch towards S8
the target location, headform
vertical and upright at the
time of launch

Impact None defined - Any velocity up to 24 km/h, S6.2

Velocity or any velocity up to 19 km/h
if within a zone covered by
an airbag

Performance None defined - HIC36(d) ≤ 1000 S7

Requirement

Test Zones None defined - A-pillar: 3 target locations S8.13.4

B-pillar: 4 target locations
Other pillars: 2 target
locations
Rearmost pillar: 2 target
locations
Front header: 2 target
locations
Side rail between A- and B-
pillars: 2 target locations

371
Other side rail: 1 target
location
Rear header: 1 target location
Upper roof: 1 target location
(any point on the upper roof –
so whole area must comply)
Sliding door track: 1 target
location
Roll bar: 2 target locations
Stiffener: 2 target locations
Brace: 1 target location
Door frame: 4 target locations
Other door frame: 2 target
locations
Seat belt mounting structure:
3 target locations
Total: 33 target locations
tested. Locations defined to
ensure a minimum
distribution of testing, not to
constrain the location to a
specific site

372
373
 Annex 4 : COMPARISON TABLES FOR EU REGULATIONS AND US STANDARDS – ROLLOVER

Table 65: US roof crush resistance requirements within FMVSS 216/216a

FMVSS 216 Ref. FMVSS 216a Ref. Comparison

Scope

Establishes strength requirement for the S1 Establishes strength requirement for S1

passenger compartment roof. the passenger compartment roof.

Purpose

Reduce death and injuries due to the S2 Reduce death and injuries due to the S2
crushing of the roof into the occupant crushing of the roof into the occupant
compartment in rollover crashes. compartment in rollover crashes.

Applicability

Applicable to: Passenger cars S3 Passenger cars S3.1 The standard is expanded to include vehicles with a
GVWR of up to 4536kg.
Multipurpose passenger vehicles Multipurpose passenger vehicles

Trucks Trucks

Buses with a GVWR of 2722kg or less Buses with a GVWR of 4536kg or less

374
 FMVSS 216 Ref. FMVSS 216a Ref. Comparison

Not applicable to: School buses S3 School buses S3.1

Vehicles that conform to the rollover Vehicles that conform to the rollover
test requirements in Standard No. 208 test requirements of Standard 208.
Convertibles – except for optional Convertibles, except for optional
compliance as an alternative to rollover compliance with the standard as an
test in Standard No. 208 alternative to the rollover test
requirement of Standard 208.
Vehicles certified to comply with
§571.216a Trucks built in 2 or more stages with a
GVWR greater than 2711 kg not built
using a chassis cab or using an
incomplete vehicle with a full exterior
van body.

Compliance: 100% compliance by September 1st,

2015.
Vehicle Conditions

Exterior: Close all windows. The vertical distance between the S7.1
Close and lock all doors. driver side and passenger side sills
Secure any convertible top or must not be more than ± 10 mm
removable roof structures in place over
the occupant compartment. Remove S7.1 Close all windows. S7.1
roof racks and other non-structural Close and lock all doors.
components Secure any convertible top or
removable roof structures in place over
the occupant compartment. Remove
roof racks and other non-structural
components

375
 FMVSS 216 Ref. FMVSS 216a Ref. Comparison

Interior - Manikin: Not applicable. Adjust seats and position the top centre S7.2 Head room maintenance is monitored through the use
of the head form specified in 49 CFR of a head form representing a 50th percentile male
571.201 at the location of the top seated in the front occupant positions.
centre of the Head Restrain
Measurement Device (HRMD)
specified in 49 CFR 571.201a as
follows:

 Position the 3D manikin specified

in SAE J826 JUL95 in accordance
to the seating procedure specified,
except that the length of the lower
leg and thigh segments of the H-
point machine are adjusted to 414
mm and 40 mm respectively
instead of the 50th percentile
values.

 Remove 4 torso weights form the

3D manikin specified in SAE J826
JUL95, replace with 2 HRMD
torso weights and attach and level
the HRMD head form.

 Mark the location of the top centre

of the HRMD in 3D space to
locate the top centre of the head
form

Position: Fix the vehicle rigidly with the sills or S7.1 Support the vehicle off its suspension S7.1
chassis frame of the vehicle on a rigid, and rigidly secure the sills and chassis
horizontal surface. frame on a rigid horizontal surface at a
longitudinal attitude of 0º ± 0.5º.

376
 FMVSS 216 Ref. FMVSS 216a Ref. Comparison

Test Device

Material/ Rigid, steel block Rigid, steel block

Measurements:
Lower surface of the block is a flat Lower surface of the block is a flat
rectangle surface (127mm x rectangle surface (127mm x 1829mm).
1829mm).

Procedure: A force is applied to either the A force is applied to both the driver’s Standard No. 216a sees the force being applied to both
driver’s or passenger’s side of the or passenger’s side of the forward edge sides of the vehicle.
forward edge of the vehicle roof by of the vehicle roof by a rigid, steel
a rigid, steel block. block.

Position: Longitudinal axis is at a forward S7.2 Longitudinal axis is at a forward angle S7.3
angle of 5º below the horizontal, of 5º below the horizontal, and it is
and it is parallel to the vertical parallel to the vertical plane through
plane through the vehicle’s the vehicle’s longitudinal centreline Its
longitudinal centreline Its transverse axis is at an outboard angle,
transverse axis is at an outboard in the front view projection, of 25º
angle, in the front view projection, below the horizontal.
of 25º below the horizontal.

The midpoint of the forward edge The midpoint of the forward edge of
of the lower surface of the test the lower surface of the test device is
device is within 10mm of the S7.3 within 10mm of the transverse vertical S7.4
transverse vertical plane, and plane, and 254mm forward of the
254mm forward of the forward forward most point on the exterior
most point on the exterior surface surface of the roof, including
of the roof, including windshield windshield trim, that lies in the
trim, that lies in the longitudinal longitudinal vertical plane passing
vertical plane passing through the through the vehicles longitudinal
vehicles longitudinal centreline. centreline.

377
 FMVSS 216 Ref. FMVSS 216a Ref. Comparison

Applied Force: 1.5 x the Unloaded Vehicle Weight Vehicles with a GVWR of 2722kg or S5.2 Standard No. 216a states that the maximum applied
of the vehicle (kg) x 9.8 Newtons. less: 3.0 × the unloaded vehicle weight force must equal 3 times the UVW for vehicles with a
of the vehicle (kg) × 9.8 Newtons. GVWR less than 2722kg.

Vehicles with a GVWR greater than In Standard No. 216 the force applied was 1.5 x UVW
2722kg, and less than or equal to of the vehicle (kg) 9.8 Newtons for all vehicle weights.
4536kg: 1.5 × the unloaded vehicle
weight of the vehicle (kg) × 9.8
Newtons.

Apply force so that the test device

moves in a downward direction S7.5
perpendicular to the lower surface of
the test device at a rate of not more
than 13 mm per second.

Test Requirements

378
 FMVSS 216 Ref. FMVSS 216a Ref. Comparison

Requirements: Force applied to either side of the Force applied to both sides of the S5.1 The platen force, displacements, and head form contact
forward edges of the vehicle roof. forwards edges of the vehicle roof – requirements must be met on both sides of the vehicle’s
first to one side and then to the other. roof structure.

The lower surface of the test device The lower surface of the test device
must not move more than 127mm. must not move more than 127mm. S5.1

No load greater than 222 Newtons may

be applied to the head form located at
the head position of a 50th percentile S5.1
adult male in accordance with S7.2 of
this section.

Table 66: US Regulation for ejection mitigation within FMVSS 226

FMVSS 226 Ref.

Purpose

Establishes requirements for ejection mitigation systems to reduce the likelihood of complete and partial S1
ejection of vehicle occupants through side windows during rollovers or side impact events.

Applicability

Applicable to: Passenger cars S2

Multipurpose passenger vehicles

379
 FMVSS 226 Ref.

Trucks

Buses with a gross vehicle weight rating of 4536kg or less

Not applicable to: Walk-in vans S2

Modified roof vehicles

Convertibles

Law enforcement vehicles, correctional institution vehicles, taxis and limousines if they have a fixed security
partition separating the 1st and 2nd, or 2nd and 3rd rows and if they are produced by more than one manufacturer
or are altered.

Vehicle Conditions

Position: The vehicle is placed on a level surface, perpendicular to the test device. S6.1

Measure the sill angle of the driver door sill and mark where the angle is measured.

Mark a point on the vehicle body above the left and right front wheel wheels. Determine the vertical height of
these two points from the level surface.

Support the vehicle off of its suspension such that the driver door sill angle is within ±1° of that measured at
the marked area, and the vertical height difference of the two points marked is within ±5mm of the vertical
height difference.

Side Daylight Openings: The glazing is pre-broken, fully retracted or removed prior to the impact test. S5.4

380
 FMVSS 226 Ref.

Mass: The vehicle is loaded to its UVW in kg. S6.1

General: All tyres are inflated to the manufacturer’s specifications listed on the vehicle’s tyre placard. S6.1

Doors: Doors are fully closed and latched but not locked. S6.2

During testing, any side door on the opposite side of the longitudinal centreline of the vehicle from the target to
be impacts may be open or removed.

Any rear hatchback or tailgate may be open or removed for testing any target.

Interior/exterior components: Steering wheel, steering column, seats, grab handles, and exterior mirrors may be removed from the vehicle or
adjusted to facilitate testing and/or provide an unobstructed path for the head form travel through and beyond
the vehicle.

Temperature/Humidity: Ambient temperature is between 18°C and 29°C.

Humidity between 10% and 70%.
Test Device

381
 FMVSS 226 Ref.

Material/Measurements: Ejection impactor: Consists of an ejection head form attached to a shaft. S7.1

Mass of 18kg ±0.05kg. S7.1

Shaft is parallel to the y axis of the head form. S7.1

Ejection head form dimensions: Dimensions are depicted in Ejection Mitigation Head form Drawing Package, S7.1.1
dated December 2010 (§ 571.5).

Head form: Exposed to S6.5 conditions for a continuous period not less than one hour, prior to the test. S6.5(b)

Target Locations: Each side daylight opening is impacted at four locations.

Initial determination of offset line: project each point of the side daylight opening laterally onto a vehicle S5.2.1.1
vertical longitudinal plane. Move each point by 25±2mm towards the centre of the side daylight opening
projections and perpendicular to a line tangent to the projection at that point, while maintaining the point on a

382
FMVSS 226 Ref.

vehicle vertical longitudinal plane.

Determination of primary target locations: divide the side daylight opening into four quadrants by passing a S5.2.3
vertical line and a horizontal line, in a vehicle vertical longitudinal plane, through the geometric centre of the
side daylight opening.

Front windows: for any side daylight opening forward of the vehicle B-pillar, the primary quadrants are the S5.2.3.1
forward-lower and rearward-upper.

Rear windows: for any side daylight opening rearward of the B-pillar, the primary quadrants are the forward- S5.2.3.2
upper and rearward-lower.

Determination of secondary target locations: measure the horizontal distance between the centres of the S5.2.4
primary targets.

Front windows: Place one secondary target centre rearward of the forward primary target by one-third of the S5.2.4.1
horizontal distance between the primary target centres and tangent with upper portion of the offset-line. Place
another secondary target center rearward of the forward primary target by two-thirds of the horizontal distance
between the primary target centres and tangent with the lower portion of the offset-line.
Rear windows: Place one secondary target centre rearward of the forward primary target by one-third of the S5.2.4.2
horizontal distance between the primary target centres and tangent with lower portion of the offset-line. Place
another secondary target centre rearward of the forward primary target by two-thirds of the horizontal distance
between the primary target centres and tangent with the upper portion of the offset-line.

383
FMVSS 226 Ref.

Front:

Rear:

384
 FMVSS 226 Ref.

Speeds/Times: The test is conducted at two impact velocities. Each target is tested to an impact speed of 16km/h ±0.5 after a 6
second time delay of the countermeasure deployment.

Each target is then tested again to an impact speed of 24km/h ±0.5 after a 1.5 second time delay of the
countermeasure deployment.

Procedure: Ejection mitigation countermeasures that deploy in the event of a rollover must be deployed for the side
daylight opening being tested.

The ejection impactor strikes the countermeasure at the impact target locations, at the specified speeds and
times.
Test Requirements
Requirements: The ejection impactor targeting point must not deflect more than 20mm in the x-z plane when a 981 N ±5 N S7.2
force is applied in a vehicle vertical longitudinal plane, through the y axis of the head form and no more than
5mm rear of the posterior surface of the head form. The force is applied once in each of the following head
form axes: z, −z, x, −x. The static deflection measurement is made with the ejection impactor extended 400
mm outboard of the theoretical point of impact with the countermeasure and attached to the ejection propulsion
mechanism, including any support frame and anchors.

The most outboard surface of the ejection head form must not displace more than 100mm beyond the zero
displacement plane.

385
Table 67: US requirements for electric powered vehicles within FMVSS 305

FMVSS 305 Ref.

Scope

Specifies requirements for limitation of electrolyte spillage, retention of electric energy storage/conversion S1
devices, and protection from harmful electric shock during and after a crash.

Purpose

Reduce deaths and injuries during and after a crash that occurs because of electrolyte spillage from electric S2
energy storage devices, intrusion of electric energy storage/conversion devices into the occupant compartment,
and electrical shock.

Applicability

Applies to: Passenger cars, S3

Multipurpose passenger vehicles,
Trucks, and
Buses with a GVWR of 4536kg or less, that use electric propulsion components with working voltages more than
60 volts direct current (VDC) or 30 volts alternating current (VAC), and whose speed attainable over a distance
of 1.6km on a paved level surface is more than 40km/h.

Vehicle Conditions

Mass: Passenger cars: loaded to UVW plus rated cargo and luggage capacity weight, secured in the luggage area, plus S7.2.3a
the necessary test dummies.

Multipurpose passenger vehicles, trucks, or buses with a GVWR of 4536kg or less: loaded to UVW plus the S7.2.3b
necessary dummies, plus 136kg or its rated cargo and luggage capacity weight, whichever is less.

386
 FMVSS 305 Ref.

Pre-test Requirements: The switch or device that provides power from the electric energy storage/conversion system to the propulsion S8
system is in the activated position or the ready-to-drive position.

Determine the isolation resistance, Ri, of the high voltage source with the electrical isolation monitoring system
using the procedure outlined in S7.6.2 and S7.6.7.

Insert a resistor with resistance Ro equal to or greater than 1/(1/(95x the working voltage of the high voltage
source)-1/Ri) and less than 1/(1/(100x the working voltage of the high voltage source)- 1/Ri) between the
positive terminal of the high voltage source and the electrical chassis.

The electrical isolation monitoring system indicator shall display a warning visible to the driver seated in the
driver’s designated seating position.

Brakes/Transmission: The parking brake is disengaged and the transmission, if any, is in the neutral position. S7.2.1

Energy storage device state-of- a) Maximum state-of-charge in accordance with the vehicle manufacturer’s recommended charging S7.1
charge: procedures, as stated in the vehicle owner’s manual or on a label that is permanently affixed to the
vehicle, or
b) If the manufacturer has made no recommendations for charging procedures in the owner’s manual or on
a label that permanently affixed to the vehicle, at a state-of-charge of not less than 95% of the maximum
capacity of the electric energy storage device, or
c) If the electric energy storage device(s) is/are rechargeable only by an energy source on the vehicle, at
any state-of-charge within the normal operating voltage defined by the vehicle manufacturer.
Seat belts: Passenger Cars: Each dummy is restrained only by means that are installed in the vehicle for protection at its S7.2.3a
seating position.

Multipurpose passenger vehicles, trucks, or buses with a GVWR of 4536kg or less: Each dummy is restrained S7.2.3b
only by means that are installed in the vehicle for protection at its seating position.
Test Device

Static Rollover Test Device: The vehicle is rotated about its longitudinal axis, with the axis kept horizontal, to each successive increment of Standard No.
90°, 180°, and 270° at a uniform rate, with 90° of rotation taking place in any time interval from 1 to 3 minutes. 301 S7.4
After reaching each 90° increment the vehicle is held in that position for 5 minutes.

387
 FMVSS 305 Ref.

Procedure: The vehicle is rotated on its longitudinal axis to each successive increment of 90° after each impact test.

Test Requirements

No more than 5.0 litres of electrolyte from propulsion batteries shall spill outside the passenger compartment, S5.1
and no visible trace of electrolyte shall spill into the passenger compartment. Spillage is measured from the time
the vehicle ceases motion after a barrier impact test until 30 minutes thereafter and throughout any static rollover
after a barrier impact test.

Electric energy storage/conversion devices shall remain attached to the vehicle by at least one component
anchorage, bracket, or any structure that transfers loads from the device to the vehicle structure. Devices that are S5.2a
located outside the occupant compartment shall not enter the occupant compartment.
S5.2b
The electrical isolation of the high voltage source must be greater than or equal to one of the following:
1) 500 ohms/volt for an AC high voltage source, or
2) 500 ohms/volt for a DC high voltage source without electrical isolation monitoring during vehicle S5.3a
operation, or
3) 100 ohms/volt for a DC high voltage source with electrical isolation monitoring during vehicle
operation.

The voltages V1, V2 and Vb of the high voltage source must be less than or equal to 30 VAC for AC components
or 60 VDC for DC components.

Each vehicle must be capable of meeting the requirements of any applicable single barrier crash/static rollover S5.3b
test sequence, without alteration of the vehicle during the test sequence.

S6

388
US Regulations: Occupant Crash Protection

FMVSS 208 Ref.

Scope

Specifies performance requirements for the protection of vehicle occupants in crashes. S1

Purpose

To reduce the number of deaths in vehicle occupants, the severity of injuries, by specifying vehicle S2
crashworthiness requirements in terms of forces and accelerations measured on anthropomorphic dummies in test
crashes.

Applicability

Applies to: Passenger cars S3

Multipurpose passenger vehicles
Trucks
Buses
Pressure vessels and explosive devices

The rollover test is optional

Vehicle Conditions

General Requirements: ‘As delivered’ Condition: S8.1.1d

100% of all fluid capacities.
All tyres inflated to the manufacturer’s specifications as listed on the vehicle’s tyre placard.

‘Fully-loaded’ Condition:
Vehicle loaded in accordance with S8.1.1a or S8.1.1b as applicable.
The load placed in the cargo area shall be centre over the longitudinal centreline of the vehicle.

389
 FMVSS 208 Ref.

Mass: Passenger Car: Vehicle loaded to its UVW plus its rated cargo and luggage capacity weight, secured in the S8.1.1a
luggage area, plus the weight of the necessary anthropomorphic test devices.

Multipurpose passenger vehicles, trucks and buses: Vehicle loaded to its UVW plus 300 pounds or its rated cargo S8.1.1b
and luggage capacity weight, whichever is less, secured in the load carrying area and distributed as nearly as
possible in proportion to its gross axle weight rating, plus the weight of the necessary anthropomorphic test
devices.

Vehicles are tested to a maximum UVW of 5500 pounds.

Adjustable Seats: Seats are in the adjustment position midway between the forward-most and rear-most positions. S8.1.2

If separately adjustable in a vertical direction, seats are at the lowest position.

If an adjustment position does not exist midway between the forward-most and rear-most positions, the closest
adjustment position to the rear of the midpoint is used.

Adjustable Seat Backs: Seat backs are in the manufacturer’s nominal design riding position in the manner specified by the manufacturer. S8.1.3

Place any adjustable anchorages at the manufacturer’s nominal design position for a 50 th percentile adult male
occupant.

Each head restraint is placed in its highest adjustment position.

Adjustable lumbar supports are positioned so that the lumbar support is in its lowest adjustment position.

Steering: Adjustable steering controls are adjusted so that the steering wheel hub is at the geometric centre of the locus is S8.1.4
describes when it is moved through its full range of driving positions.

Windows/Vents: Placed in fully closed position, unless the vehicle manufacturer chooses to specify a different adjustment position S8.1.5
prior to the time it certifies the vehicle.

Convertibles: Convertibles and open body top type vehicles have the top, if any, in place in the closed passenger compartment S8.1.6
configuration.

390
 FMVSS 208 Ref.

Doors: Doors are fully closed and latched but not locked. S8.1.7

Brakes/Transmission: Disengaged and neutral. S8.3.2

Seat Belts: Any manual seat belt shall be designed to maintain of the following three seat belt parts on top of or above the seat S7.4.6.1
cushion under normal conditions; the seat belt latch plate, the buckle, or the seat belt webbing.

Test Device

Anthropomorphic Test Dummy:

Material/Measurements: A Hybrid III test dummy is placed in the front outboard designated seating position on the vehicle's lower side as S7.1.4
mounted on the test platform

Each test dummy is clothed in a form fitting cotton stretch short sleeve shirt with above-the-elbow sleeves and
above-the-knee length pants. The weight of the shirt or pants shall not exceed 0.25 pounds each.

Each foot of the test dummy is equipped with a size 11XW shoe which meets the configuration size, sole, and heel
thickness specification of MIL-S-13192 change “P” and whose weight is 1.25 ±0 pounds. S8.1.8.2

S8.1.8.2
Temperature: The stabilised test temperature of the test dummy is at any temperature level between 69°F and 72°F. S8.1.8.5

Position:

391
 FMVSS 208 Ref.

Head: The transverse instrumentation platform of the head shall be level with 0.5°. To level the head of the test dummy, S10.1
the following sequences must be followed. First, adjust the H point within the limits set in S10.4.2.1 to level the
transverse instrumentation platform of the head of the test dummy. If the transverse instrumentation platform of
the head is still not level, then adjust the pelvic angle of the test dummy within the limits specified in S10.4.2.2 of
this standard. If the transverse instrumentation platform of the head is still not level, then adjust the neck bracket
of the dummy the minimum amount necessary form the adjust “0” setting to ensure that the transverse
instrumentation platform of the head is horizontal within 0.5°. The test dummy shall remain within the limits
specified in S10.4.2.1 and S10.4.2.2, after any adjustment of the neck bracket.

Upper Arms: The driver’s upper arms shall be adjacent to the torso with the centrelines as close to a vertical plane as possible. S10.2.1

The passenger’s upper arms shall be in contact with the seat back and the side of the torso. S10.2.2

Hands: The palms of the driver’s test dummy shall be in contact with the outer part of the steering wheel rim at the rim’s S10.3.1
horizontal centreline. The thumbs shall be over the steering wheel rim and shall be lightly taped to the steering
wheel rims so that if the hand of the test dummy is pushed upward by a force of not less than 2 pounds and not
more than 5 pounds, the tape shall release the hand from the steering wheel rim.
The palms of the passenger test dummy shall be in contact with the outside of the thigh. The little finger shall be in S10.3.2
contact with the seat cushion.

392
 FMVSS 208 Ref.

Torso: Upper Torso: S10.4.1.1

In vehicles equipped with bench seats, the upper torso of the driver and passenger test dummies shall rest against
the seat back. The midsagittal plane of the driver dummy shall be vertical and parallel to the vehicle’s longitudinal
centreline, and pass through the centre of the steering wheel rim. The midsagittal plane of the passenger dummy
shall be vertical and parallel to the vehicle’s longitudinal centreline and the same distance from the vehicle’s
longitudinal centreline as the midsagittal plane of the driver dummy.

In vehicles equipped with bucket seats, the upper torso of the driver and the passenger test dummies shall rest S10.4.1.2
against the seat back. The midsagittal plane of the driver and the passenger dummy shall be vertical and shall
coincide with the longitudinal centreline of the bucket seat.

Lower Torso:
H-Point: The H-points of the driver and passenger test dummies shall coincide within 0.5inches in the vertical
dimension and 0.5inches in the horizontal dimension of a point 0.25inches below the position of the H-point S10.4.2.1
determined by using the equipment and procedures specified in SAE J826 (APR 1980) except that the length of
the lower leg and thigh segments of the H-point machine shall be adjusted to 16.3 and 15.8inches, respectively,
instead of the 50th percentile values.

Pelvic Angle: As determined using the pelvic angle gage which is inserted into the H-point gaging hole of the S10.4.2.2
dummy, the angle measured from the horizontal on the three inch flat surface of the gage shall be 22.5° ±2.5°.

Legs: The upper legs of the driver and passenger test dummies shall rest against the seat cushion to the extent permitted S10.5
by placement of the feet. The initial distance between the outboard knee clevis flange surfaces shall be 10.6inches.
To the extent practicable, the left leg of the driver dummy and both legs of the passenger dummy shall be in
vertical longitudinal planes. To the extent practicable, the right leg of the driver dummy shall be in a vertical
plane. Final adjustment to accommodate the placement of feet in accordance with S10.6 for various passenger
compartment configurations is permitted.

393
 FMVSS 208 Ref.

Feet: Driver’s Position:

If the vehicle has an adjustable accelerator pedal, adjust it to the full forward position. Rest the right foot of the S10.6.1.1
test dummy on the undepressed accelerator pedal with the rearmost point of the heel on the floor pan in the plane
of the pedal. If the foot cannot be placed on the accelerator pedal, set it initially perpendicular to the lower leg and
then place it as far forward as possible in the direction of the pedal centreline with the rearmost point of the heel
rest on the floor pan. If the vehicle has an adjustable accelerator pedal and the right foot is not touching the
accelerator pedal when positioned as above, move the pedal rearward until it touches the right foot. If the
accelerator pedal still does not touch the foot in the full rearward position, leave the pedal in that position.

Place the left foot on the toeboard with the rearmost point of the heel resting on the floor pan as close as possible S10.6.1.2
to the point of intersection of the planes described by the toeboard and the floor pan and not on the wheel-well
projection. If the foot cannot be positioned on the toeboard, set it initially perpendicular to the lower leg and place
it as far forward as possible with the heel resting on the floor pan. If necessary to avoid contact with the vehicle’s
brake or clutch pedal, rotate the test dummy’s left foot about the lower leg. If there is still pedal interference, rotate
the left leg outboard about the hip the minimum distance necessary to avoid the pedal interference. For vehicles
with a foot rest that does not elevate the left foot above the level of the right foot, place the left foot on the foot rest
so that the upper and lower leg centrelines fall in a vertical plane.

Passenger’s Position:
Vehicle’s with a flat floor pan/toeboard: Place the right and left feet on the vehicle’s toeboard with the heels S10.6.2.1
resting on the floor pan as close as possible to the intersection point with the toeboard. If the feet cannot be placed
flat on the toeboard, set them perpendicular to the lower leg centrelines and place them as far forward as possible
with the heels resting on the floor pan.

Vehicle’s with wheelhouse projections in passenger compartment: Place the rght and left feet in the well of the
floor pan/toeboard and not on the wheelhouse projection. If the feet cannot be placed flat on the toeboard, initially
set them perpendicular to the lower leg centrelines and then place them as far forward as possible with the heels
resting on the floor pan.

Test dummy positioning for Pull the belt webbing 3inches from the test dummy’s chest and release until the webbing is within 1inch of the test S10.8
belt contact force: dummy’s chest and measure the belt contact force.

394
 FMVSS 208 Ref.

Manual belt adjustment for Remove all slack from the lap belt portion/ Pull the upper torso webbing out of the retractor and allow it to retract; S10.9
dynamic testing: repeat this four times. Apply a 2 to 4 pound tension load to the lap belt. If the belt system if equipped with a
tension-relieving device, introduce the maximum amount of slack into the upper torso belt that is recommended by
the vehicle manufacturer in the vehicle’s owner’s manual. If the belt system is not equipped with a tension
relieving device, allow the excess webbing in the upper torso belt to be retracted by the retractive force of the
retractor.
Sled:
Measurements and Position The vehicle is placed on a sled fixed with a rigid, angled platform positioned 9 inches from the ground and 23° S8.3.3
of Sled: from the horizontal.

The driver’s side tyres rest alongside a 4 inch lip at the forward edge of the test platform.

395
 FMVSS 208 Ref.

Procedure: The vehicle and sled are accelerated along a straight path perpendicular to the longitudinal axis of the vehicle, for S8.3.5
a sufficient period of time for the vehicle to become motionless relative to the platform.

The sled is then decelerated rapidly, without change of direction and without transverse or rotational movement S8.3.6
during the deceleration of the platform and the departure of the vehicle.

This procedure results in vehicle trip and subsequent rollover.

Velocity and Distance: Acceleration: The sled is accelerated at a constant speed of 30mph. S8.3.5

Deceleration: The sled is decelerated rapidly from 30mph to 0mph in a distance of no more than 3 feet. S8.3.6

Test Requirements

Anthropomorphic Test Dummy:

All portions of the test dummy shall be contained within the outer surfaces of the vehicle passenger compartment. S6.1

396
 FMVSS 208 Ref.

Head Injury Criteria: For any two points in time 𝑡1 and 𝑡2 during the event which are separated by not more than a 36ms time interval S6.2(a)(1)
and where 𝑡1 is less than 𝑡2 , the head injury criterion ( HIC36 ) shall be determined using the resultant head
acceleration at the centre of gravity of the dummy head, 𝑎𝑟 , expressed as a multiple of g (the acceleration of
gravity) and shall be calculated using the expression:

The maximum calculated HIC36 value shall not exceed 1000. S6.2(a)(2)

For any two points in time 𝑡1 and 𝑡2 during the event which are separated by not more than a 15ms time interval S6.2(b)(1)
and where 𝑡1 is less than 𝑡2 , the head injury criterion ( HIC15 ) shall be determined using the resultant head
acceleration at the centre of gravity of the dummy head, 𝑎𝑟 , expressed as a multiple of g (the acceleration of
gravity) and shall be calculated using the expression:

The maximum calculated HIC15 value shall not exceed 700.

S6.2.2
Chest: The resultant acceleration calculated from the output of the thoracic instrumentation shall not exceed 60g’s, except S6.3
for intervals whose cumulative duration is not more than 3ms.

Compressive deflection of the sternum relative to the spine shall not exceed 76mm. S6.4(a)
Compressive deflection of the sternum relative to the spine shall not exceed 63mm. S6.4(b)

Leg: The force transmitted axially through each upper leg shall not exceed 2250 pounds. S6.5

397
 FMVSS 208 Ref.

Neck Injury Criterion: Normalised Neck Injury Criterion (Nij) S6.6(a)

The shear force (𝐹𝑥 ), axial force (𝐹𝑧 ), and bending moment (My) shall be measured by the dummy upper neck load S6.6(a)(1)
cell for the duration of the crash event. Shear force, axial force and bending moment shall be filtered for Njj
purposes at SAE Recommended Practice J211/1MAR95.

During the event, the axial force can be either in tension or compression while the occipital condyle bending S6.6(a)(2)
moment (Mocy) can be in either flexion or extension. This results in four possible loading conditions for Nij:
tension-extension (Nte), tension-flexion (Ntf), compression-extension (Nce), or compression-flexion (Ncf).

At each point in time, only one of the four loading conditions occurs and the Nij value corresponding to that
loading condition is computed and the three remaining loading modes shall be considered a value of zero. The S6.6(a)(4)
expression for calculating each Nij loading condition is given by:

Nij = (Fz/Fzc) + (Mocy/Myc)

Fzc = 6806N (1530lbf) when Fz is in tension. S6.6(a)(3)(i)

Fzc = 6160N (1385lbf) when Fz is in compression. S6.6(a)(3)(ii)
Myc = 310Nm (229lbf-ft) when a flexion moment exists at the occipital condyle. S6.6(a)(3)(iii)
Myc = 135Nm (100lbf-ft) when an extension moment exists at the occipital condyle. S6.6(a)(3)(iv)

None of the four Nij values shall exceed 1.0 at any time during the event. S6.6(a)(5)
Tension force measured at the upper neck load cell shall not exceed 4000N (899lbf) at any time. S6.6(b)

398
 IIHS Roof Strength Test - USA

Test: Metal plate is pushed against one side of the vehicle at a slow but constant speed.

Safety ratings are based on the vehicle’s UVW and maximum force measured
before 127mm of travel.

Applicable to:

Force applied: Relative to the vehicle’s weight – strength-to-weight ratio.

Requirements: Good: Strength-to-weight ratio of 4 (must withstand force of atleast 4 times the
vehicle’s weight before the plate crushes the roof by 5 inches).

Acceptable: 3.25

Marginal: 2.5

Poor: <2.5

Crush Limit: 127mm

Test Surface: Place vehicle on a level surface

Test Procedure: Measure the on-road pitch angle at the front door sill on both sides of the
vehicle.

399
 IIHS Roof Strength Test - USA

Vehicle Conditions: All roof racks and other non-structural items that may be contacted during the
test are removed from the vehicle’s roof unless the manufacturer requests
otherwise.

Any trim or other components are removed if they interfere with supporting the
vehicle along its rocker panels.

For vehicles with vertical pinch weld flanges on the bottom of the rocker panels,
the vehicle support system consists of one I-beam for each rocker panel, with
two lengths of angle iron welded to the top of the I-beam. The angle iron on the
outboard side of the vehicle is drilled and tapped to accommodate bolts with cup
or cone pointed tips. Once the vehicle’s rocker panel is supported by the angle
iron, the bolts are tightened against the pinch weld to clamp the system in place.

When the punch weld flange has a bend that prevents supporting the sill with one
I=beam, more than one I-beam can be used on each side of the vehicle.

For vehicles with no pinch weld flange, or with a non-vertical flange angle that
precludes clamping, mounting by another method may be necessary.

All windows are closed and doors are locked.

Full tank of fuel.

Seat position: Prior to test, the front row seatback on the side being tested is reclined to prevent
interaction with the crushing roof.

Rear seats are latched in their upright position.

400
 IIHS Roof Strength Test - USA

Test Device Quasi-static test system.

Upright assembly and attached loading head that can be fixed at varying heights
from the ground as well as at pitch angles ranging from -5 to +5 degrees to
accommodate testing on the driver or passenger side.

The roll angle is permanently fixed at 25 degrees.

Four hydraulic actuators control the movement of the platen along two linear
guides.

The entire system is mounted on a T-slot bed plate anchored to the floor of the
test facility.

Two HR A-36 W10x88 I-beams are mounted on the bed plate perpendicular to
the longitudinal axis of the platen.

The vehicle is adjusted so that:

1. The longitudinal centreline for the platen is within 10mm of initial roof
contact points.
2. The yaw angle of the vehicle relative to longitudinal axis of the platen is
0± 0.5 degrees.
3. The midpoints of the platen’s forward edge is 254 ± 10mm forward of
the most forward point of the roof (including windshield trim if it
overlaps the roof) lying on the vehicle’s longitudinal centreline.
4. The pitch angle of the vehicle matches the on-road angle, while also
accounting for any difference between the platen’s pitch angle and the
nominal -5 degrees. The maximum combined difference of the vehicle
and platen pitch angles from their targets is ±.5 degrees. If necessary to
achieve this angle, shims are inserted between the rocker panel supports
and the W10x88 I-beams attached to the bed plate.

401
IIHS Roof Strength Test - USA

Rocker panel supports are clamped to the two perpendicular I-beams, and the
beams are marked to allow confirmation that the vehicle position is maintained
during the test.

For body-on-frame vehicles, the frame is supported to prevent the weight of the
chassis from stressing the body at the body mounts.

The roof is crushed to a minimum displacement of 127mm at a nominal rate of

5mm/second.

Some tests are conducted to a greater displacement to collect additional strength

data for research purposes.

Force data are recorded from five load cells attached to the loading platen.

Displacement data are recorded from four linear variable displacement

transducers integrated into the hydraulic actuators.

Force and displacement data are collected with a National Instruments USB-
6210 data acquisition system and reported at 100 Hz.

The displacement-time histories from the LVDTs are compared to verify that the
platen’s roll angle and pitch angle (relative to the vehicle’s on-road pitch) were
maintained at 25 ± 0.5 degrees and -5 ± 0.5 degrees, respectively.

The precrash and postcrash conditions of each test vehicle are documented with
still photographs. The position of the vehicle in the test fixture also is recorded.
Motion picture photography is made of the test with real-time video cameras.

402
 IIHS Roof Strength Test - USA

Calculation of SWR Force and displacement data are recorded for 5 seconds prior to each test, while
Rating the test system holds the loading platen at initial roof contact. The data recorded
from 1 to 4 seconds of this hold time are averaged for each channel to produce a
measurement offset that is subtracted from the data recorded during the crushing
of the roof. After removing the offset for each channel, the force-displacement
curve is plotted using the summed output from the five load cells and the average
displacement from the four LVDTs.

The maximum force prior to 127 mm of platen displacement is divided by the

measured curb weight to obtain the SWR. Both force and curb weight are
rounded to the nearest pound prior to performing the calculation, and the
resulting SWR is rounded to the nearest one-hundredth of a unit. Displacement is
rounded to the nearest 0.1 mm. (The maximum displacement where the load can
be used for the vehicle rating is 126.9 mm.) The vehicle’s rating is assigned
based on the boundaries listed in Table 1.

All trim levels sharing the tested vehicle’s body type and roof structure are
assigned the same rating as the typically equipped trim level, provided their curb
weights do not exceed 110 percent of the selected vehicle’s weight. Based on
published curb weights from multiple sources, any trim levels that may exceed
this weight are identified and weighed. If the weight does exceed 110 percent of
the weight of the selected vehicle, a unique SWR is calculated for that trim level.
If this SWR results in a lower rating, both ratings are reported for the model,
with a split according to trim level. If a trim level weighs more than 110 percent
of the typically equipped model, but the lower SWR does not fall in a lower
rating band, only the original SWR and rating are reported for the model.

403
 IIHS Roof Strength Test - USA

Difference to FMVSS Roof strength evaluations consist of a quasi-static test conducted on a vehicle’s
216 roof in a manner similar to tests used to judge compliance with Federal Motor
Vehicle Safety Standard 216 (Office of the Federal Register, 2009). The main
differences between the procedure specified by the Insurance Institute for
Highway Safety (IIHS) and that specified by the US federal government are that
the IIHS procedure:
• Specifies testing one side of a vehicle’s roof,
• Does not include a headroom criterion,
• Specifies testing to a given displacement instead of a given force level, and
• Specifies setting the vehicle’s pitch angle during testing based on the measured
on-road pitch angle.
An overall rating is assigned based on the peak strength-to-weight ratio (SWR)
measured within 127 mm of plate displacement.

404
 Annex 5 : COMPARISON TABLES FOR EU REGULATIONS AND US STANDARDS – REAR IMPACT

Table 68: Comparison of rear impact legislative requirements for EU (Regulation 32 and Regulation 34) and US (FMVSS 301).

FMVSS 301 (Fuel System

UN R32 (Rear Impact) UN R34 (Fuel Tanks)
Integrity)
Property Comparison
Specification Reference Specification Reference Specification Reference

Passenger cars,
Rear impact test
MPVs trucks &
section of reg is US regulation is mandatory. UN
Not part of buses with GVWR Standard
Applicability optional optional regs 32 and 34 are optional for
framework directive of ≤ 4536kg and 301, S3.
(Part I or II must rear impact testing.
fuel with boiling
be satisfied)
point above 0°C

Impactor

FMVSS 301 specifies mobile

Moving
Moving barrier or Annex 4, Moving barrier or Standard deformable barrier. UNECE regs
Type Annex 4, 2.3. deformable
pendulum 2.3. pendulum 301, S6.2 (b) offer choice of either mobile
barrier
impactor or pendulum impactor.

Aluminium UN Regs use hardened steel rigid

honeycomb block Standard barriers whereas FMVSS 301 uses
Steel rigid Annex 4, Steel rigid Annex 4,
Material and bumper with 214, Figure deformable aluminium honeycomb
construction 2.2.1. construction 2.2.1.
aluminium sheet 2. same asFMVSS 214 side impact
faces test impactor.

Flat surface Flat surface According to

Standard UN Regs 32 and 34 have the
2500mm wide Annex 4, 2500mm wide Annex 4, diagram in
301, S7.3. largest impactors as the impact
800mm high 2.2.2. 800mm high 2.2.2. Standard 214.
must cover the entire width of the
Dimensions edge radius 40- edge radius 40-
Standard rear of the vehicle.
50mm Annex 4, 50mm Annex 4, Block:
214, Figure
clad with 20mm thick 2.2.3.4. clad with 20mm 2.2.3.4. 1676mm wide
2. FMVSS 301 impactor the same as
plywood layer thick plywood 559mm high
side impact impactor other than
layer 381mm deep

405
 FMVSS 301 (Fuel System
UN R32 (Rear Impact) UN R34 (Fuel Tanks)
Integrity)
Property Comparison
Specification Reference Specification Reference Specification Reference

ground clearance of 229mm ground slight drop in ground clearance.

impacting surface ground clearance clearance
175±25mm of impacting
surface bumper:
175±25mm 1676mm wide
203mm high
102mm deep
280mm ground
clearance

Annex 4, Annex 4,
2.4.3. 2.4.3.
3,015 lbs (1,367 Weight of FMVSS301 impactor 267
Weight 1100±20kg 1100±20kg Part 587
kg) kg greater than R32/34 impactor
Annex 4 Annex 4
2.5.6. 2.5.6.

Impact
conditions

Annex 4, between 35 and Annex 4,

2.4.2 38 km/h 2.4.2 Standard
between 35 and 38 Much higher speed in FMVSS 301
Speed (between 48-52 80±1 km/h 301, S7.3.
km/h than in UN R32 and R34.
Annex 4, km/h in series 03 Annex 4, (b) (3)
2.5.4. amendment) 2.5.4.

406
 FMVSS 301 (Fuel System
UN R32 (Rear Impact) UN R34 (Fuel Tanks)
Integrity)
Property Comparison
Specification Reference Specification Reference Specification Reference

Impacting surface
Impacting surface
perpendicular to
perpendicular to
longitudinal plane
longitudinal plane of Line of travel
of vehicle with
vehicle with not more parallel to
not more than
than 300mm lateral longitudinal Standard Full overlap impact in UN R32 and
Annex 4, 300mm lateral Annex 4,
Position deviation. centre of vehicle 301, S7.3. R34 compared to 70% overlap in
2.2.3. deviation. 2.2.3.
and 70% overlap (b) (4) FMVSS 301.
Impacting surface to either side at
Impacting surface
shall extend over impact.
shall extend over
entire width of
entire width of
vehicle.
vehicle.

Vehicle
Conditions

Unloaded vehicle
weight, plus rated
cargo and
luggage capacity Standard FMVSS 301 likely to be largest
Annex 4, Unladen kerb Annex 4,
Mass Unladen kerb weight weight, plus 50th 301, S7.1.6. vehicle mass due to luggage and
2.7.1. weight 2.7.1.
percentile (a) cargo loading.
dummies in each
front outboard
seating position

Tank filled 90-

Similar fuel tank filling level
90% of fuel tank 90% of fuel tank 95%.
Standard requirements in FMVSS 301 and
capacity with liquid of Annex 4, capacity with Annex 4,
Fluid levels 301, S7.1.1., UN R32 and R34. No requirements
similar density to 2.7.2. liquid of similar 2.7.2. Fuel system filled
S7.1.2. on fluid levels in fuel system in UN
fuel. density to fuel. to normal
R32 and R34.
operating level.

407
 FMVSS 301 (Fuel System
UN R32 (Rear Impact) UN R34 (Fuel Tanks)
Integrity)
Property Comparison
Specification Reference Specification Reference Specification Reference

UN R32 and R34 allow for gears to

Annex 4, Gear may be Annex 4, Standard
Transmission Gear may be engaged Neutral be engaged on vehicle during test
2.7.3. engaged 2.7.3. 301, S7.1.4.
whereas FMVSS301 does not.

UN R32 and R34 allow for brakes

Brakes may be Annex 4, Brakes may be Annex 4, Parking brake Standard
Brakes to be engaged on vehicle during
applied 2.7.3. applied 2.7.3. disengaged 301, S7.1.4.
test whereas FMVSS301 does not.

Post Impact
Requirements

Not to exceed 28g

No more than
from impact until
slight leakage of
vehicle motion
liquid on collision.
has ceased.
Continuous
Not to excede Only FMVSS 301 and R34 have
leakage after Standard
Fuel spillage 142g in following fuel leakage requirements as they
collision shall not 301, S5.5.
5 minutes. are fuel system safety regulations.
exceed 30g/min
Not to excede
No fire
28g/min for
maintained by
following 25
fuel shall occur
minutes

408
 FMVSS 301 (Fuel System
UN R32 (Rear Impact) UN R34 (Fuel Tanks)
Integrity)
Property Comparison
Specification Reference Specification Reference Specification Reference

No rigid component in
passenger
compartment shall
No post impact vehicle condition
pose risk of serious
requirements in FMVSS301.
injury.
During and after
Vehicle impact, battery R32 requires doors to be useable
Side doors of vehicle
condition shall be kept in post impact.
shall not open under
position.
impact.
R34 has a specific requirement for
battery mounting post impact.
Doors shall be
openable without use
of tools.

Lengthwise R32 has a specific requirement on

displacement of the displacement of the vehicle R-
Vehicle
rearmost seat R-point point following the impact. No
Movement
projection shall not such requirement in other
exceed 75mm. regulations.

409
 Table 69: Comparison of fuel tank legislative requirements for EU (Regulation 34)

US requirements with respect to fuel system integrity are addressed by FMVSS 301 (see previous table)

UN R34 (Fuel Tanks)

Property
Specification Reference

Part I (Approval of vehicles with regard to their fuel tanks) or Part II (see previous table) are
Applicability Section 4
mandatory

The tank is filled with a non-flammable liquid (water, for example) and the pressure
Hydraulic increased, to a relative internal pressure equal to double the working pressure ( not less than
Section 6.1
test an excess pressure of 30 kPa (0.3) bar), which shall be maintained for one minute. During
this time the tank shell shall not crack or leak.

This test is carried out with the tank orientated in the same way as fitted in the car. While
90% full, the tank is turned from 90° to the right and held at least five minutes. The tank is
Overturn test then turned another 90° until inverted and held for at least another five minutes. The tank is Section 6.2
then rotated back to its starting position. The rotation is then carried out in the opposite
direction. Requirements on leakage are contained in Part III.

Applicability Part III. Approval of tanks for liquid fuel as separate technical units is mandatory Section 10

Various
technical Tanks must be corrosion-resistant and be fitted with devices to cope with excess pressure Section5.1
requirements

Resistance to
Must meet the Hydraulic test requirements Section 5.2
pressure

410
 UN R34 (Fuel Tanks)
Property
Specification Reference

Fuel shall not leak from tank cap or pressure devices during “foreseeable course of operation
Fuel leakage Section 5.9
of vehicle.” Leak must not exceed 30g/min when tested to the overturn test

Fire
Tanks must fire-resistant 5.12
resistance

Part IV. Approval of a vehicle with regard to the installation of an approved fuel tank(s) is
Applicability
mandatory

Requirements for vents to be designed to reduce fire risk by channelling any leakage away
Vents Section 5.4
from exhaust system and onto ground.

Tank shall not be situated in, or from, a surface (floor, wall, bulkhead) of the passenger
compartment or other compartment integral with it. Partitions shall separate occupant
compartments from the tank. Requirement for tank to be securely fixed and placed so any
Tank siting Section 5.5, 5.6, 5.7, 5.10, 5.11
leak escapes to the ground. Tanks shall be sited such that they are protected from rear
impact and there shall not be any protruding parts. Tanks shall also be protected from any
ignition hazards.

Filler hole Requirement that this must not be sited in the occupant, luggage, or engine compartments Section 5.8

411
 Table 70: Comparison of EU (Regulation 25 and 17) and US (FMVSS 202) head restraint tests.

UN R25 (head restraints) UN R17 (seats, anchorages) GTR 7 (head restraints) FMVSS 202 (head restraints)
Property Comparison
Specification Reference Specification Reference Specification Reference Specification Reference

UNECE R25 component

level only but all others
Compulsory for M1
1-1 vehicles, small apply to normal
Applicability Component level vehicles in framework Part B, 2. 2.91+ S2.
trucks and buses passenger vehicles.
directive
R17 and FMVSS202
compulsory.

N/A for R25 at

component level.
Other Regs require
testing for all outboard
front seats. R17 makes
Mandatory for all Mandatory for all
Mandatory for all testing optional for
outboard front seats. outboard front seats.
outboard front seats. other seats with head
Restraints Other seats with head Rear outboard seats
N/A Other seats with head 5.4.1. Part B, 4. S4.1. restraints. GTR 7 states
required restraints must with head restraints
restraints may be that all other seats
conform to relevant must conform to
approved optionally. with head restraints
requirements. requirements.
must be tested.
FMVSS202 requires
rear outboard seats
with head restraints to
be tested.

Dimensions of
restraint

412
 UN R25 (head restraints) UN R17 (seats, anchorages) GTR 7 (head restraints) FMVSS 202 (head restraints)
Property Comparison
Specification Reference Specification Reference Specification Reference Specification Reference

Front seats:
Front seats:
minimum 800mm for
minimum 800mm in at
at least one position of
Not less than 800mm Not less than 800mm least one position of
adjustment, min. Part B, Same requirements for
Height for front seats and 6.4. for front seats and 5.6. adjustment. S4.2.1.
750mm in any position. 5.1.1. each reg.
750mm for others. 750mm for others.
Other seats:
Other seats:
minimum 750mm
minimum 750 mm

FMVSS202 gives
65 ±3mm below the
slightly more flexibility
Restraint shall cover Restraint shall cover Width of head restraint top of the head
by stating minimum
minimum 85mm to minimum 85mm to shall be minimum Part B, restraint, the lateral
Width 6.7. 5.11 S4.2.2. width at a specific level
each side of seat plane each side of seat plane 85mm either side of 5.1.2. width of a head
but all specify
of symmetry of symmetry torso line restraint must be not
minimum width of
less than 170mm
170mm.

FMVSS202 prohibits
Gaps in head restraint Gaps in head restraint gaps greater than
Gaps in head restraint
may be over 60mm so may be over 60mm so No gaps greater than 60mm. Other Regs
Gaps within 6.6.2.2. 5.9. may be over 60mm so
long as additional and long as additional and 5.1.3. 60mm within head S4.2.4.1. allow larger gaps so
restraint 6.6.3. 5.10. long as testing
normal testing normal testing restraint. long as the testing
requirements are met.
requirements are met. requirements are met. requirements of the
restraint are met.

No more than 60mm No more than 60mm No more than 60mm No more than 60mm
gap for non adjustable gap for non adjustable gap for non adjustable gap for non adjustable
Gap between
restraints and no more 6.6. restraints and no more restraints and no more Part B, restraints and no more S4.2.4.1. Same requirements for
restraint and 5.8.
than 25mm gap for 6.6.1. than 25mm gap for than 25mm gap for 5.1.4. than 25mm gap for S4.2.4.2. each reg.
seat
adjustable in lowest adjustable in lowest adjustable in lowest adjustable in lowest
position. position. position. position.

413
 UN R25 (head restraints) UN R17 (seats, anchorages) GTR 7 (head restraints) FMVSS 202 (head restraints)
Property Comparison
Specification Reference Specification Reference Specification Reference Specification Reference

Energy
absorption test

R25 and R17 require

restraint to be tested
in most unfavourable
Mounted as normal to
position. GTR 7 states
Mounted as normal to Mounted as normal to seat back/vehicle.
Adjustable head that restraints are
seat back/vehicle and Annex 6, seat back/vehicle and Annex 6, Annex 7, 2.
Restraint set-up restraints in any S5.2.5. measured (tested?) in
in most unfavourable 1.1. in most unfavourable 1.1. Adjustable restraints Annex 7, 3.
position of adjustment any position of
position if adjustable position if adjustable measured in any
adjustment. FMVSS
position of adjustment
allows head restraint
to be tested in any
position of adjustment.

Semispherical head
Pendulum with centre Pendulum with centre form of 165±2mm Semispherical head Same impactor
of percussion mass of of percussion mass of diameter. form 165±2mm headform and mass for
6.8kg and lower Annex 6, 6.8kg and lower Annex 6, Combined mass such Annex 7, diameter. each Reg. R17 and R25
Impactor S5.2.5. (a)
extremity of rigid 1.2.1. extremity of rigid 1.2.1. that at 24.1km/h, 3.1.1. Head form and base specify the use of a
headform 165mm headform 165mm energy of 152 joules is combined mass of pendulum style
diameter diameter reached. (approx 6.8±0.05kg impactor.
6.79kg)

Annex 6, Annex 6, Annex 7, Same test speed for

Impact speed 24.1km/h 24.1km/h 24.1km/h 24.1km/h S4.2.5.
1.4.2. 1.4.3. 3.3.1. each reg

414
 UN R25 (head restraints) UN R17 (seats, anchorages) GTR 7 (head restraints) FMVSS 202 (head restraints)
Property Comparison
Specification Reference Specification Reference Specification Reference Specification Reference

Longitudinal axis of
Impacts shall take Impacts shall take
impactor should be Each Reg specifies that
place at points in the place at points in the
Longitudinal axis of within 2 degrees of impact to front of
impact zone and impact zone and
impactor should be horizontal at time of restraint should be
possibly outside on possibly outside on
within 2 degrees of impact. horizontal.
edges with radius of edges with radius of
horizontal at time of
curvature less than curvature less than
impact. Headform should FMVSS202 specifies
5mm. Annex 6, 5mm. Annex 6,
Impact travel for at least minimum headform
1.4.1, 1.4.2, Annex 7, S5.2.5. (c),
direction and Impact front surface of 25mm before impact. travel prior to impact.
Impact to rear of 1.4.1.1., Impact to rear of 1.4.2.1., 3.3.1. (d), (e)
position restraint at any point
restraint shall be at 1.4.1.2. restraint shall be at 1.4.2.2.
with height more than Impact front surface of No requirementd for
angle of 45 degrees to angle of 45 degrees to
635mm from R point restraint at any point impact to rear of
the vertical. the vertical.
and within 70mm of with height more than restraint in GTR7 and
restraint vertical 635mm from R point FMVSS 202. Rear
Impact to front of Impact to front of
centreline. and within 70mm of impact should be at 45
restraint shall be restraint shall be
restraint vertical degrees to vertical.
horizontal. horizontal.
centreline.

Decelleration of
headform shall not Same decelleration
Decelleration of exceed 80g Decelleration of Decelleration of requirement for each
headform shall not continuously for more headform shall not headform shall not Reg.
Performance Part B, 2
exceed 80g Annex 6, 2. than 3ms. 5.2.3.1. exceed 80g exceed 785m/s (80g) S4.2.5.
requirement 5.2.1.
continuously for more continuously for more continuously for more R17 requires no
than 3ms. No dangerous edge than 3ms. than 3ms. dangerous edges to be
shall occur during or caused by the test.
remain after the test.

Height No height retention

retention test test in R25 and R17.

415
 UN R25 (head restraints) UN R17 (seats, anchorages) GTR 7 (head restraints) FMVSS 202 (head restraints)
Property Comparison
Specification Reference Specification Reference Specification Reference Specification Reference

Restraints should be
tested in highest Restraints should be
position and not less tested in highest
than but closest to: position and not less No testing requirement
than but closest to: for rear centre head
Restraint Annex 8,
800mm for front S5.2.6. (a) restraint in FMVSS 202.
position 2.1.
outboard 800mm for front Otherwise heights are
750mm for rear outboard the same.
outboard and front 750mm for rear
centre outboard
700mm for rear centre

Cylindrical device Cylindrical device

Annex 8, Same impactor in GTR7
Test device 165±2mm diameter 165±2mm diameter S5.2.6. (b)
2.2. and FMVSS202.
and 152mm in length. and 152mm in length.

416
 UN R25 (head restraints) UN R17 (seats, anchorages) GTR 7 (head restraints) FMVSS 202 (head restraints)
Property Comparison
Specification Reference Specification Reference Specification Reference Specification Reference

Orient test device such

that axis of revolution
is horizontal in the Orient test device such
longitudinal vertical that axis of revolution
plane through the is horizontal in the
centre of the restraint. longitudinal vertical
Position midpoint of plane through the
bottom surface of centre of the restraint.
cylinder in contact with Position midpoint of
restraint. bottom surface of
cylinder in contact with Same set up in both
Pre-test set up S5.2.6. (b)
Establish initial restraint. regs
reference position by
applying downward Establish initial
load of 50±1N at rate reference position by
of 250±50N/min for 5 applying downward
seconds. Mark load of 50±1N at rate
reference position and of 250±50N/min for
measure distance 5.5±0.5 secs. Mark
between lowest point reference position.
of restraint and top of
seat back.

417
 UN R25 (head restraints) UN R17 (seats, anchorages) GTR 7 (head restraints) FMVSS 202 (head restraints)
Property Comparison
Specification Reference Specification Reference Specification Reference Specification Reference

Increase test device

load at rate of
250±50N/min to at
Increase test device
least 500N and
load at rate of
maintain for at least 5
250±50N/min to at
secs. Reduce load at
least 500N and
same rate until load is
maintain for 5.5±0.5
completely removed
secs. Reduce load at
and maintain for
same rate until load is
maximum of 2 mins.
completely removed
Increase load at same Same procedure in
Test process and maintain for 2 S5.2.6. (b)
rate again to 50±1N both regs
mins±5secs. Increase
and after 5 secs,
load at same rate again
determine position of
to 50±1N and after
test device with
5.5±0.5 secs,
respect to its initial
determine position of
reference position.
test device with
Repeat measurement
respect to its initial
of distance between
reference position.
lowest point of
restraint and top of
seatback.

418
 UN R25 (head restraints) UN R17 (seats, anchorages) GTR 7 (head restraints) FMVSS 202 (head restraints)
Property Comparison
Specification Reference Specification Reference Specification Reference Specification Reference

During application of
initial 50N reference Neither Reg permits
load, test device must movement of test
Mechanism of restraint not move downward device by more than
shall not fail in such a by more than 25mm. 25mm during load
Performance way as to allow application. FMVSS202
5.2.2. S4.2.6.
requirement downward movement Once test load is also requires restraint
of restraint by more reduced back to 50N to return to within
than 25mm. reference load, test 13mm of initial
device must return to position after load
within 13mm of initial application.
reference position.

Static testing

R25 and GTR7 require

head restraint to be
placed in highest
Adjust restraint so that
position.
its top is at a height
closest to and not less
If adjustable, restraint If adjustable, restraint Adjust head restraint R17 requires restraint
Annex 6, than: S5.2.7. (a)
Restraint set-up shall be set in highest 7.4.2.1. shall be placed in most 6.4.1. to highest position of to be tested in most
3.1. 800mm for front (1)
position. unfavourable position. vertical adjustment. unfavourable position.
outboard seats
750mm for rear
FMVSS202 requires
outboard seats
restraint to be tested
at closest height to
those specified.

419
 UN R25 (head restraints) UN R17 (seats, anchorages) GTR 7 (head restraints) FMVSS 202 (head restraints)
Property Comparison
Specification Reference Specification Reference Specification Reference Specification Reference

Displaced reference
line determined by
applying rearward
Displaced reference
moment of 373±7.5Nm
line determined by
about H point to the
applying rearward
back of h-point
moment of 373±7.5Nm
manikin at a rate of
about R point to the
Displaced reference Displaced reference 187±37Nm/min.
back of h-point
line determined by line determined by
manikin at a rate of
applying rearward applying rearward Use 165±2mm
2.5-37.3Nm/s.
moment of 37.3daNm moment of 37.3daNm diameter spherical
Same force to
about R point to the about R point to the headform to apply a
Use 165±2mm determine initial
back of h-point back of h-point force producing a
diameter spherical reference line in each
manikin. manikin. moment of 37±0.7Nm
headform to apply a reg. FMVSS202 and
about the h-point, at
force producing a GTR7 specify a rate at
Use 165mm diameter Use 165mm diameter right angles to
moment of 37Nm which the load should
spherical headform to spherical headform to displaced reference
about the r-point, at be applied.
apply a force producing apply a force producing line at distance of
right angles to
a moment of a moment of 65±3mm below top of
displaced reference Same headform and
37.3daNM about the r- 37.3daNM about the r- restraint. Maintain
Displacement line at distance of force to be applied in
point, at right angles to 7.4.3. point, at right angles to 6.4. load for 5.5±0.5s,
test procedure 65±3mm below top of each reg but
displaced reference displaced reference measure displacement
restraint. Measure FMVSS202 and GTR7
line at distance of line at distance of of headfrom. Increase
displacement of specify load application
65mm below top of 65mm below top of load at 187±37Nm/min
headfrom during load rate and load duration.
restraint. restraint. up to 373±7.5Nm and
application. Increase
maintain for 5.5±0.5
load at 2.5-37.3Nm/s FMVSS202 requires a
The tangent to the The tangent to the secs.
up to 373Nm and reapplication of load so
headform, parallel to headform, parallel to
maintain for 5 secs that the head restraint
the displaced reference the displaced reference Reduce load at same
minimum. position is measured
line is determined. The line is determined. The rate until completely
under load.
distance between the distance between the removed and maintain
The tangent to the
tangent and displaced tangent and displaced for 2mins ± 5 secs.
headform, parallel to
reference line is reference line is Increase load at same
the displaced reference
measured. measured. rate again to
line is determined and
37±0.7Nm moment
the distance between
about h--point.
the tangent and
Maintain for 5.5±0.5s,
displaced reference
measure posterior
line is420
measured.
deiplacement of
headfrom from initial
position.
 UN R25 (head restraints) UN R17 (seats, anchorages) GTR 7 (head restraints) FMVSS 202 (head restraints)
Property Comparison
Specification Reference Specification Reference Specification Reference Specification Reference

Headform shall: Headform shall:

Not be displaced more Not be displaced more

than 25mm during than 25mm during Same maximum
application of initial application of initial displacement in each
reference moment. reference moment. Reg, GTR7 and
Diplacement Maximum Maximum
Not be displaced more Not be displaced more FMVSS202 specify
test displacement of the displacement of the
6.8. 5.12. than 102mm during than 102mm during limits on movement
performance head is less than head is less than
the application of the the application of the during initial small load
requirements 102mm 102mm
373Nm moment about 373±7.5Nm moment application and
the r-point. about the h-point. difference in position
Return to within 13mm Return to within 13mm after load application.
of initial reference of initial reference
position after the load position after the load
application sequence. application sequence.

All regs specify same

Once load from maximum load for
After displacement After displacement Increase load from displacement test has strength test.
test, increase load test, increase load displacement test at been removed for 2
Strength test applied through applied through rate of 5-200N/sec to mins, inrease load at GTR7 and FMVSS202
7.4.3.7. 6.4.3.6. S4.2.7 (a)
procedure headform to 89daN headform to 89daN at least 890N and rate of 250±50N/min both specify the
unless breakage occurs unless breakage occurs maintain for minimum to at least 890N and loading rate and
earlier. earlier. of 5 secs. maintain for require the load to be
5.5±0.5secs. maintained for a
minimum time period.

421
 UN R25 (head restraints) UN R17 (seats, anchorages) GTR 7 (head restraints) FMVSS 202 (head restraints)
Property Comparison
Specification Reference Specification Reference Specification Reference Specification Reference

All regs require

Load applied to Load applied to restraint to be able to
Head restraint and Head restraint and
Strength test restraint shall reach restraint shall reach withstand 890N load,
anchorage shall be anchorage shall be
performance 6.9. 5.13. 890N and remain at 890N and remain at S4.2.7 (b) GTR7 and FMVSS202
strong enough to bear strong enough to bear
requirements 890N for period of 5 890N for period of 5 require the load to be
load without failure. load without failure.
seconds. seconds. withstood for 5
seconds.

Dynamic
testing

Mount vehicle so that

longitudinal plane is
Mount vehicle so that
parallel to direction of
longitudinal plane is
travel and vehicle
parallel to direction of
cannot move on sled.
travel and vehicle
cannot move on sled.
Remove tires, wheels,
fluids, unsecured
Remove tires, wheels, Same vehicle mounting
components. Rigidly
fluids, unsecured and set up in each reg.
secure engine,
Vehicle set-up components. Rigidly
transmission, axles,
secure engine, Ignition must be on in
exhaust, vehicle frame
transmission, axles, GTR7
and other components.
exhaust, vehicle frame
and other components.
Any moveable
windows should be
Any moveable
fully open.
windows should be
fully open.
All tests performed
with ignition on.

422
 UN R25 (head restraints) UN R17 (seats, anchorages) GTR 7 (head restraints) FMVSS 202 (head restraints)
Property Comparison
Specification Reference Specification Reference Specification Reference Specification Reference

Seat back should be in Seat back should be in

inclination position inclination position
closest to 25° from closest to 25° from
vertical. vertical.
Seat should be at Seat should be at
lowest position and lowest position and
midway between midway between
forward most and forward most and
rearward most rearward most
positions. positions.
If seat cushion is If seat cushion is
adjustable, position adjustable, position
such that highest h- such that highest h-
Seat
point position is point position is Same for both regs
adjustment
achieved with respect achieved with respect
to seat back. to seat back.
If head restraint is If head restraint is
asjustable, adjust top asjustable, adjust top
of restraint to position of restraint to position
midway between midway between
lowest and highest lowest and highest
positions of positions of
adjustment. adjustment.
Adjustable lumbar Adjustable lumbar
supports should be in supports should be in
lowest retracted or lowest retracted or
deflated position. deflated position.

If an upper adjustable If an upper adjustable

Seat belt seat belt turning loop seat belt turning loop
Same for both regs
adjustment exists, place it in the exists, place it in the
adjustment position adjustment position
closest to the mid- closest to the mid-

423
 UN R25 (head restraints) UN R17 (seats, anchorages) GTR 7 (head restraints) FMVSS 202 (head restraints)
Property Comparison
Specification Reference Specification Reference Specification Reference Specification Reference

position. position.

Hybrid III dummy Hybrid III dummy

placed in each placed in each
designated seating designated seating
position with head position with head
restraint. restraint.
Dummy should be Dummy should be
Dummy
clothed in form fitting clothed in form fitting Same for both regs
requirements
cotton short sleeve cotton short sleeve
shirt and above the shirt and above the
knee pants. Each foot knee pants. Each foot
fitted with size 11XW should be fitted with
shoes. Limb joints set size 11XW shoes. Limb
to 1g. joints set to 1g.

Dummy head should Dummy head should

Dummy head
be level within ½ be level within ½ Same for both regs
positioning
degree. degree.

424
 UN R25 (head restraints) UN R17 (seats, anchorages) GTR 7 (head restraints) FMVSS 202 (head restraints)
Property Comparison
Specification Reference Specification Reference Specification Reference Specification Reference

Driver upper arms Driver upper arms

adjacent to torso. adjacent to torso.
Passenger upper arms Passenger upper arms
in contact with seat in contact with seat
back and torso. back and torso.
Driver hands in contact Driver hands in contact
with outer rim of with outer rim of
steering wheel at steering wheel at
horizontal centre. horizontal centre.
Palms of passenger Palms of passenger
hands are in contact hands are in contact
Dummy body
with outside of thigh. with outside of thigh. Same for both regs
positioning
Upper torso of each Upper torso of each
dummy rests against dummy should rest
seat back in central against seat back in a
position. H-point of central position.
driver and passenger H-point of driver and
dummies shall be passenger dummies
within 12.5mm shall be within 12.5mm
vertically, 12.5mm vertically, 12.5mm
horizontally of a point horizontally of a point
6.25mm below the h- 6.25mm below the h-
point of the seat. point of the seat.

425
 UN R25 (head restraints) UN R17 (seats, anchorages) GTR 7 (head restraints) FMVSS 202 (head restraints)
Property Comparison
Specification Reference Specification Reference Specification Reference Specification Reference

Pelvic angle as Pelvic angle as

measured from measured from
horizontal to flat horizontal to flat
surface of gauge is surface of gauge is
22.5±2.5 degrees. 22.5±2.5 degrees.
Upper legs rest on seat Upper legs rest on seat
cushion. Distance cushion. Distance
between knee surfaces between knee surfaces
269mm. Lower left leg 269mm. Lower left leg
of driver and both of driver and both
lower legs of passenger lower legs of passenger
in vertical longitudinal in vertical longitudinal
plane. Right leg of plane. Right leg of
driver in vertical plane. driver in vertical plane.
Driver right foot with Driver right foot with
heel on floor and heel on floor and
Dummy leg and
perpendicular to lower perpendicular to lower Same for both regs
foot positioning
leg with foot resting on leg with foot resting on
or as close to pedal as or as close to pedal as
possible. Driver left possible. Driver left
foot and both foot and both
passenger feet with passenger feet with
heel resting on floor heel resting on floor
and perpendicular to and perpendicular to
lower leg as far lower leg as far
forward as possible or forward as possible or
resting on toeboard. resting on toeboard.
Rear passenger feet Rear passenger feet
flat on floorpan flat on floorpan
beneath front seat as beneath front seat as
far forward as possible far forward as possible
without seat without seat
interference. interference.

426
 UN R25 (head restraints) UN R17 (seats, anchorages) GTR 7 (head restraints) FMVSS 202 (head restraints)
Property Comparison
Specification Reference Specification Reference Specification Reference Specification Reference

All tests conducted at All tests conducted at

Test conditions ambient temperature ambient temperature Same for both regs
of 18-28°C of 18-28°C

Accelerate or Accelerate or
decelerate test decelerate test
Test procedure Same for both regs
platform to reach delta platform to reach delta
V of 17.3±0.6km/h V of 17.3±0.6km/h

Angular rotation Angular rotation

between head and between head and
torso of test dummy torso of test dummy
Performance
limited to 12 degrees limited to 12 degrees Same for both regs
requirements
in all outboard seating in all outboard seating
positions. positions.
Limit HIC value to 500. Limit HIC value to 500.

427
 Table 71: Comparison of EU (UN Regulation 42 – optional) and US (Part 581 – mandatory) bumper requirements.

UN R42 (Bumpers) Part 581 (Bumpers)

Property Comparison
Specification Reference Specification Reference

Applies to passenger vehicles

Optional in EU, not in framework
Applicability excluding MPVs and low speed US regulation is mandatory. UN R.42 is optional in EU.
Directive.
vehicles

Impactor

Annex 3, Standard FMVSS 581 specifies pendulum impactor. UNECE reg offers
Type Moving barrier or pendulum Pendulum
2.4. 581.6 (b) choice of either mobile impactor or pendulum impactor.

Rigid construction, impact contour Annex 3, Standard

Material Impact ridge of hardened steel Same for both regs.
hardened steel 2.3.1. 581.6 (b) (1)

According to diagram in reg. According to diagram in standard.

Standard
610mm wide 24" wide
Annex 3, 581.7,
Dimensions 915mm high 36" tall Same dimensions for impactors but expressed in different units.
2.3.2. Figure 1,
Figure 2
Impact contour centreline at 305mm Impact ridge centreline at 12" with
high, countour height of 114 mm. ridge height of 4.5".

effective mass equal to unladen Annex 4, effective mass equal to mass of Standard
Weight Same for both regs.
weight of tested vehicle 2.3.3. tested vehicle 581.6 (b) (3)

Impact conditions

428
 UN R42 (Bumpers) Part 581 (Bumpers)
Property Comparison
Specification Reference Specification Reference

Annex 4,
longitudinal impact: 2.5mph
longitudinal impact: 4 (+0.25, -0) 2.7.5.
km/h Virtually the same test speeds in each regulation but expressed
Speed Corner impact: 1.5mph
in different units and no tolerances for Part 581.
Corner impact: 2.5 (+0.1, -0) km/h Annex 4,
Barrier test: 2.5mph
2.8.4.

Two longitudinal tests to both front

and rear of vehicle with impactor
impact line at any height between
16 and 20 inches. For each impact,
Two longitudinal tests bounded by Annex 3,
impact line must be at least 2 inches
width of vehicle to both front and 2.7.
away vertically.
rear of vehicle, first test location
Slightly different restrictions on separation of impact positions in
free choice, second location at least
One corner impact to both front and each Reg.
300mm away.
Position rear of vehicle at height of 20" and
one impact between 16 and 20 Part 581 requires vehicle impact into fixed collision barrier as
Corner impact to both front and rear
inches. Impactor shall make angle of well as mobile impactor tests.
of vehicle, impactor shall make angle
60° with vehicle.
of 60±5° to the logitudinal plane of Annex 3,
the vehicle 2.8.
One impact logitudinally rearwards
of vehicle into fixed collision barrier
perpendicular to line of vehicle
travel

Vehicle Conditions

One impact at unladen running

order mass, one impact at laden
Mass running order mass (includes 4.3.1. Unloaded vehicle weight R42 requires an impact at laden vehicle mass as well as unladen.
passenger mass), for both
longitudinal and corner impacts

429
 UN R42 (Bumpers) Part 581 (Bumpers)
Property Comparison
Specification Reference Specification Reference

Fluid levels Running order fluid levels. No specification on fluid levels in Part 581.

Annex 3,
Transmission Neutral Neutral Same for both regs
2.2.4.

Annex 3,
Brakes Brakes disengaged Brakes disengaged Same for both regs
2.2.4.

Post Impact Requirements

No leaks from fuel system and

Fuel spillage sealing devices and caps shall open Requirement for no leakage from fuel system in Part 581.
in normal manner.

430
 UN R42 (Bumpers) Part 581 (Bumpers)
Property Comparison
Specification Reference Specification Reference

Lamps and reflectors shall be free of

crack and operate correctly.
Hood, trunk and doors operate as
normal.
No leaks in vehicle exhaust system.
Propulsion, suspension, steering and
lighting and signalling operate braking systems remain in
correctly. adjustment and operate normally.
Bonnet, boot lid and doors open in Pressure vessels used to absorb
normal manner and side doors do impact energy shall not suffer loss of
not open under impact. gas or fluid or fragment. FMVSS 581 allows no damage to the vehicle bumper other than
Paragraph
Vehicle condition No damage or displacement to Exterior surface shall have no on parts that were in contact with the impact ridge during
6.
exhaust system preventing normal separations of surface materials, impact.
function. paint, coatings or covering materials
Propulsion, suspension, steering and from the surface to which they are
braking systems remain in bonded and no permanent
adjustment and operate normally deviations from their original
contours 30 minutes after
completion of each impact except
where such damage occurs to
bumper face bar.
There shall be no breakage or
release of fasteners or joints.

431
Annex 6 COMPARISON TABLES FOR EU REGULATIONS AND US STANDARDS – PEDESTRIAN

Table 72: Comparison of pedestrian legislative requirements for EU (EC 78/2009, EC 631/2009, UN Reg 127) and GTR 9 (Potential US legislation).

UN Regulation No. 127

Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in GTR No. 9 (Potential US Regulation) Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref

Scope

All of the regulations include passenger

vehicles that carry up to 8 passengers and a
The regulation applies to The regulation applies to vehicles of: driver.
motor vehicles of category M1  category 1-1 with a gross vehicle The GRT No. 9 also includes vehicles that
and N1 and to frontal mass exceeding 500 kg carry more than 8 passengers provided that the
Art 2
protection systems fitted as The regulation applies to  category 1-2 with a gross vehicle gross vehicle mass is between 500 kg and 4500
1.(a),
original equipment to these motor vehicles of 1. mass exceeding 500 kg but not 2. 2.1 kg.
1.(b),
vehicles or supplied as category M1 and N1. exceeding 4500 kg Goods vehicles that have a maximum mass not
1.(c)
separate technical unites that  category 2 with a gross vehicle exceeding 3.5 tonnes are also included in
are intended to be fitted to mass exceeding 500 kg but not Regulation (EC) No. 78/2009 and UN
these vehicles. exceeding 4500 kg Regulation No. 127. Goods vehicles are also
included in GTR No. 9 if the gross mass is
between 500 kg and 4500 kg
Vehicles of category: Vehicles of category: Vehicles of category 1-2 and category
All the regulations allow for the exemption of
 N1;  N1; 2, where the distance, measured
goods vehicles and passenger cars derived
 M1 derived from N1 and of  M1 with a maximum longitudinally on a horizontal plane,
from goods vehicles if the mass is over 2500
maximum mass exceeding mass exceeding 2500 kg between the transverse centre line of
kg from the tests if the driver position ‘R-
2500 kg; that are derived from the front axle and the R-point of the
point’ is either forward of the front axle or
Articl N1; driver's seat is less than 1,100 mm,
longitudinally rearwards of the front axle
Where the driver position ‘R- e2 are exempt from the requirements of
1. 2. 2.1 transverse centreline by a maximum of 1100
point’ is either forward of the 2.(a), Where the driver position this regulation.
mm.
front axle or longitudinally 2.(b) ‘R-point’ is either forward Contracting Parties can also exempt
GTR No. 9 also includes for passenger
rearwards of the front axle of the front axle or category 1-1 vehicles on this basis
vehicles provided that the components of the
transverse centreline by a longitudinally rearwards and it has components of the frontal
front structure are interchangeable with the
maximum if 1100 mm are of the front axle structure that are interchangeable with
other categories of vehicle.
excluded from the tests. transverse centreline by a the above-mentioned category 1-2
(Sections 2 and 3 of Annex 1) maximum if 1100 mm are and category 2 vehicles.

432
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in GTR No. 9 (Potential US Regulation) Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
excluded from the tests.
(Sections 2 and 3 of
Annex 1)

Granting
type-
approval
Vehicles can comply with
either the requirements of
Section 2 or 3 of Annex I.
Compliance with Section 3
gives the vehicle “Type A”
approval. Articl
Compliance with Section 3 e 4 1.
Vehicles gives the vehicle “Type B” Articl - - - - N/A
approval. e 6 2.
The Regulation includes a (a)
timetable for application to
vehicles, which is phasing out
“Type A” approval. By 2019
all new vehicles must gain
“Type B” approval.
Frontal protection systems that
are either fitted as original
equipment or supplied as
Articl
separate technical units must
Frontal e 4 2.
comply with the requirements
Protection Articl - - - N/A
in Section 5 and 6 of Annex I.
System e 6 2.
They approval letter given is
(b)
dependent on which part of
Annex I Section 5 5.1.1. is
complied with.

Legform to
bumper

433
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in GTR No. 9 (Potential US Regulation) Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
Either lower legform to
Annex
bumper or upper legform to
I 2.1, Test carried out is
bumper test can be carried out.
3.1 dependent on the height
Test carried out is dependent on the
of the lower bumper:
Test carried out is dependent height of the lower bumper:
 _< 425 mm – lower
on the height of the lower  _< 425 mm – lower legform to
legform to bumper test
bumper: bumper test
 425 mm < _ > 500 mm – The legform test that must be carried out is
 _< 425 mm – lower legform  425 mm < _ > 500 mm – choice of
choice of manufacturer 5.1 4.1 height dependant in all of the regulations. The
to bumper test manufacturer to carry out either
to carry out either lower heights are identical in all of the regulations.
 425 mm < _ > 500 mm – lower legform to bumper test or
legform to bumper test or
choice of manufacturer to upper legform to bumper test
upper legform to bumper
carry out either lower legform
Part II  _ > 500 mm – upper legform to
test
to bumper test or upper bumper test
Chapt  _ > 500 mm – upper
legform to bumper test er II legform to bumper test
_ > 500 mm – upper legform
3.2
to bumper test

Lower
legform test
results
Regulation (EC) No. 78/2009 “Type B”
approval, UN Regulation 127 (pre optional
amendment series 01) and GTR No. 9 are
identical.
Regulation (EC) No. 78/2009 “Type A”
Annex
approval is higher, but is being phased out.
Lower I
legform 21.0º 2.1(a)
The optional Series 01 of amendments for UN
maximum 19º 5.1.1 19º 5.1.1
Regulation 127 were introduced in January
knee bending 19.0º Annex
2015. The amendments introduce a different
angle I
lower legform impactor (Flex-PLI), making the
3.1.(a)
requirements that must be met different (see
below).
GTR No. 9 (phase 2) may also introduce the
implementation of the Flex-PLI impactor
which would change the requirements.

434
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in GTR No. 9 (Potential US Regulation) Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
Identical

Lower The optional Series 01 of amendments for UN

legform Regulation 127 were introduced in January
Annex
maximum 2015. The amendments introduce a different
I
dynamic 6.0 mm 6.0 mm 5.1.1 6.0 mm 5.1.1 lower legform impactor (Flex-PLI), making the
2.1(a),
knee requirements that must be met different (see
3.1(a)
shearing below).
displacement GTR No. 9 (phase 2) may also introduce the
implementation of the Flex-PLI impactor
which would change the requirements.
Regulation (EC) No. 78/2009 “Type B”
approval, UN Regulation 127 (pre amendment
series 01) and GTR No. 9 are identical.
Lower Annex
legform I The optional Series 01 of amendments for UN
acceleration Not exceeding 200 g 2.1(a) Regulation 127 were introduced in January
measured at 170 g 5.1.1 170 g 5.1.1 2015. The amendments introduce a different
the upper Not exceeding 170 g Annex lower legform impactor (Flex-PLI), making the
end of the I requirements that must be met different (see
tibia 3.1(a) below).
GTR No. 9 (phase 2) may also introduce the
implementation of the Flex-PLI impactor
which would change the requirements.
In addition, the Regulation (EC) No. 78/2009 “Type B”
manufacturer may approval, UN Regulation 127 (pre amendment
nominate bumper test series 01) and GTR No. 9 are identical.
In addition, the manufacturer widths of up to 264 mm
In addition, the manufacturer may
may nominate bumper test in total where the The optional Series 01 of amendments for UN
Annex nominate bumper test widths of up to
widths of up to 264 mm in acceleration measured at Regulation 127 were introduced in January
I 5.1.1 264 mm in total where the 5.1.1
total where the acceleration the upper end of the tibia 2015. The amendments introduce a different
3.1(a) acceleration measured at the upper
measured at the upper end of shall not exceed 250 g lower legform impactor (Flex-PLI), making the
end of the tibia shall not exceed 250 g
the tibia shall not exceed 250 g requirements that must be met different (see
In addition, the below).
manufacturer may GTR No. 9 (phase 2) may also introduce the
nominate bumper test implementation of the Flex-PLI impactor

435
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in GTR No. 9 (Potential US Regulation) Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
widths up to a maximum which would change the requirements.
of 264 mm in total where
the absolute value of the
tibia bending moment
shall not exceed 380 Nm
The optional Series 01 of amendments for UN
Regulation 127 were introduced in January
Maximum 2015. The amendments introduce a different
dynamic lower legform impactor (Flex-PLI).
medial These are the new test requirements that must
collateral - - 22 mm 5.1.1 - - be met according to the optional amendments.
ligament GTR No. 9 (phase 2) may also introduce the
elongation at implementation of the Flex-PLI impactor and
the knee would be likely to introduce the same test
requirements.

Maximum
dynamic
anterior
cruciate
ligament and - - 13 mm 5.1.1 - -
posterior
cruciate
ligament
elongation
Absolute
value of
dynamic
- - 340 Nm 5.1.1 - -
bending
moments at
the tibia
Lower
legform test
procedures

436
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in GTR No. 9 (Potential US Regulation) Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
Annex
1
40 km/h 2.1(a), Annex
3.1(a) 5 1.12
Impact
11.1 ± 0.2 m/s 11.1 ± 0.2 m/s Identical
velocity
Part II Annex
11.1 ± 0.2 m/s Chapt 5 1.12
er II
4.4
Minimum of three tests, one
each to the middle and outer In the bumper test area. Annex
thirds at positions most likely 5 1.4
UN Regulation 127 (Series 00) and Regulation
to cause injury. Minimum of three tests,
(EC) No 78/2009 are almost identical.
Tests shall be performed to Part II one each to the middle
Regulation (EC) No 78/2009 includes the extra
different types of structure Chapt and outer thirds.
Measuring In the bumper test area. provision that different types of structure must
where they vary throughout er II Measuring points a 7.1.1.1
points be tested.
the area to be assessed. 3.3 minimum of 132 mm Annex
Measuring points a minimum apart horizontally and a 5 1.5
GTR No. 9 gives far less details, only that the
of 132 mm apart horizontally minimum of 66 mm
test must be in the bumper area.
and a minimum of 66 mm inside defined corners of
inside defined corners of bumper
bumper
Horizontal plane and Annex
Direction of Horizontal plane and parallel Part II Horizontal plane and parallel to the
parallel to the longitudinal 5 1.6
impact to the longitudinal vertical Chapt longitudinal vertical plane of the
vertical plane of the 7.1.1.2 Identical
velocity plane of the vehicle. er II vehicle.
vehicle. Annex
vector Tolerance of ± 2º. 4.4 Tolerance of ± 2º.
Tolerance of ± 2º. 5 1.6
Bottom of impactor 25
mm above the ground Identical
Annex
reference plane
Bottom of impactor 25 mm Part II 5 1.7
Tolerance of ± 10 mm. Bottom of impactor 25 mm above the The Series 01 of amendments for UN
Height of above the ground reference Chapt
ground reference plane 7.1.1.3 Regulation 127 changes the height of the
impactor plane er II
Bottom of impactor 75 Tolerance of ± 10 mm impactor. The amendments require the bottom
Tolerance of ± 10 mm. 4.6 Annex
mm above the ground of the impactor to be higher above the ground
5 1.7
reference plane reference plane.
Tolerance of ± 10 mm.

437
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in GTR No. 9 (Potential US Regulation) Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
Annex
Part II
Impactor must be in free 5 1.8
Impactor must be in free flight Chapt Impactor must be in free flight at the
flight at the time of 7.1.1.3.1 Identical
at the time of impact. er II time of impact.
impact. Annex
2.1
5 1.8
Part II Annex
At impact the centre line must Horizontal and vertical
Chapt 5 1.10 Horizontal and vertical impact
be within ± 10 mm tolerance impact tolerance of ± 10 7.1.1.3.3 Identical
er II Annex tolerance of ± 10 mm
to the selected impact location mm
4.7 5 1.10
At first contact the
At first contact the impactor
impactor must have Annex At first contact the impactor must
must have intended orientation Part II
intended orientation about 5 1.9 have intended orientation about the
about the vertical axis for the Chapt
the vertical axis for the vertical axis for the correct operation 7.1.1.3.2 Identical
correct operation of the knee er II
correct operation of the Annex of the knee joint.
joint. 4.6
knee joint. 5 1.9 Tolerance of ± 5º.
Tolerance of ± 5º.
Tolerance of ± 5º.
The axis of the impactor
The axis of the impactor must shall be perpendicular to
Part II
be perpendicular to the the horizontal plane with Regulation (EC) No. 78 and the Series 01 of
Chapt Annex
horizontal plane with a a roll and pitch angle - - amendments for UN Regulation 127 are
er II 5 1.6
tolerance of 2º in the lateral tolerance of ±2° in the identical.
4.5
and longitudinal plane lateral and longitudinal
plane.
Tibia bending moments
shall not exceed +/- 15
Nm within an evaluation Annex
- - - - N/A
interval of 30 ms 5 1.13
immediately prior to
impact.
Lower
legform
impactor
Two foam covered rigid Two foam covered rigid Two foam covered rigid segments, Identical
Part V Annex
segments, representing femur segments, representing representing femur (upper leg) and 6.3.1.1
1.1 4 1.1
(upper leg) and tibia (lower femur (upper leg) and tibia (lower leg), joined by a The Series 01 of amendments for UN

438
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in GTR No. 9 (Potential US Regulation) Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
leg), joined by a deformable, tibia (lower leg), joined deformable, simulated knee joint. Regulation127 introduces a lower legform
simulated knee joint. by a deformable, impactor (Flex-PLI) which is different to the
simulated knee joint. impactor in the other regulations.

Flexible lower legform GTR No. 9 (phase 2) may also introduce the
impactor shall consist of implementation of the Flex-PLI impactor
flesh and skin, flexible which would change the requirements.
long bone segments
(representing femur and
tibia), and a knee joint
Annex
The lower legform impactor introduced in the
432 mm from the centre of the Part V 4
Femur length 339 ± 2 mm - - Series 01 of amendments for UN Regulation
knee 1.1 Figure
127 has a different length femur.
1
Annex
The lower legform impactor introduced in the
494 mm from the centre of the Part V 4
Tibia length 404 ± 2 mm - - Series 01 of amendments for UN Regulation
knee 1.1 Figure
127 has a different length tibia.
1
Annex
4
Knee length 185 ± 1 mm - - N/A
Figure
1
Annex
Regulation (EC) No. 78/2009, UN Regulation
4 1.1
127(Series 00) and GTR No. 9 are identical.
926 ± 5 mm
Overall Part V
926 ± 5 mm Annex 926 ± 5 mm 6.3.1.1
length 1.1 The lower legform impactor introduced in the
928 ± 3 mm 4
Series 01 of amendments for UN Regulation
Figure
127 is a different length.
1
Regulation (EC) No. 78/2009, UN Regulation
127(Series 00) and GTR No. 9 are identical.
70 ± 1 mm
Diameter of 70 ± 1 mm 70 ± 1 mm
Part V Covered in foam flesh Annex
tibia and Covered in foam flesh 25mm Covered in foam flesh 25mm thick 6.3.1.1.1 The diameter of the lower legform impactor
1.2 25mm thick and a skin 4 1.2
femur thick and a skin 6mm thick. and a skin 6mm thick. introduced in the Series 01 of amendments for
6mm thick.
UN Regulation 127 is not mentioned as it
varies from the top to the bottom of the

439
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in GTR No. 9 (Potential US Regulation) Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
legform.

Regulation (EC) No. 78/2009, UN Regulation

127(Series 00) and GTR No. 9 are identical.
8.6 ± 0.1 kg
Part V Annex
Femur mass 8.6 ± 0.1 kg 8.6 ± 0.1 kg 6.3.1.1.3
1.3 4 1.4 The lower legform impactor introduced in the
2.46 ± 0.12 kg
Series 01 of amendments for UN Regulation
127 has a different femur mass.
Regulation (EC) No. 78/2009, UN Regulation
127(Series 00) and GTR No. 9 are identical.
Part V 4.8 ± 0.1 kg Annex
Tibia mass 4.8 ± 0.1 kg 4.8 ± 0.1 kg 6.3.1.1.3
1.3 2.64 ± 0.13 kg 4 1.4 The lower legform impactor introduced in the
Series 01 of amendments for UN Regulation
127 has a different tibia mass.

Knee joint Annex

- 4.28 ± 0.21 kg - - N/A
mass 4 1.4

13.4 ± 0.2 kg
Regulation (EC) No. 78/2009, UN Regulation
127(Series 00) and GTR No. 9 are identical.
13.2 ± 0.4 kg Annex
Part V 6.3.1.1,
Total mass 13.4 ± 0.2 kg Assembled mass of 4 1.1, 13.4 ± 0.2 kg
1.3 6.3.1.1.3 The mass of the lower legform impactor
femur, knee joint and tibia 1.4
introduced in the Series 01 of amendments for
without the flesh and skin
UN Regulation 127 is different.
– 9.38 ± 0.3 kg
Annex Regulation (EC) No. 78/2009, UN Regulation
217 ± 10 mm from the
4 1.4 127(Series 00) and GTR No. 9 are identical.
centre of the knee
Femur centre 217 ± 10 mm from the centre Part V 217 ± 10 mm from the centre of the
Annex 6.3.1.1.3 The centre of gravity for the femur of the
of gravity of the knee 1.1 159 ± 8 mm from the knee
4 lower legform impactor introduced in the
opposite end to the knee
Figure Series 01 of amendments for UN Regulation
joint
1 127 is different.

440
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in GTR No. 9 (Potential US Regulation) Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
Annex Regulation (EC) No. 78/2009, UN Regulation
233 ± 10 mm from the 4 1.4 127(Series 00) and GTR No. 9 are identical.
centre of the knee
Tibia centre 233 ± 10 mm from the centre Part V 233 ± 10 mm from the centre of the
Annex 6.3.1.1.3 The centre of gravity for the tibia of the lower
of gravity of the knee 1.1 knee
202 ± 10 mm from either 4 legform impactor introduced in the Series 01
end Figure of amendments for UN Regulation 127 is
1 different.
0.127 ±0.010 kgm² (about
a horizontal axis through
Regulation (EC) No. 78/2009, UN Regulation
the respective centre of
0.127 ±0.010 kgm² (about a 127(Series 00) and GTR No. 9 are identical.
gravity and perpendicular 0.127 ±0.010 kgm² (about a
Femur horizontal axis through the
Part V to the direction of impact) Annex horizontal axis through the respective
moment of respective centre of gravity 6.3.1.1.3 The moment of inertia for the femur of the
1.4 4 1.4 centre of gravity and perpendicular to
inertia and perpendicular to the lower legform impactor introduced in the
0.0325 ± 0.0016 kgm² the direction of impact)
direction of impact) Series 01 of amendments for UN Regulation
(about the X-axis through
127 is different.
the respective centre of
gravity)
0.120 ±0.010 kgm² (about
a horizontal axis through
Regulation (EC) No. 78/2009, UN Regulation
the respective centre of
0.120 ±0.010 kgm² (about a 127(Series 00) and GTR No. 9 are identical.
gravity and perpendicular 0.120 ±0.010 kgm² (about a
Tibia horizontal axis through the
Part V to the direction of impact) Annex horizontal axis through the respective
moment of respective centre of gravity 6.3.1.1.3 The moment of inertia for the tibia of the lower
1.4 4 1.4 centre of gravity and perpendicular to
inertia and perpendicular to the legform impactor introduced in the Series 01
0.0467 ± 0.0023 kgm² the direction of impact)
direction of impact) of amendments for UN Regulation 127 is
(about the X-axis through
different.
the respective centre of
gravity)
0.0180 kgm²
Knee joint ± 0.0009 kgm² (about the
Annex
moment of - - X-axis through the - N/A
4 1.4
inertia respective centre of
gravity)
Fitted with deformable
Fitted with deformable knee elements
knee elements with the Annex Identical for UN Regulation 127 (Series 00)
Knee joint - - with the same batch as those used in 6.3.1.1.2
same batch as those used 4 1.3 and GTR No. 9.
the certification tests.
in the certification tests.

441
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in GTR No. 9 (Potential US Regulation) Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
Lower
legform
impactor
instrumentati
on
Uniaxial accelerometer
Uniaxial accelerometer
mounted on the non- Uniaxial accelerometer mounted on
mounted on the non-impacted
impacted side of the tibia the non-impacted side of the tibia 66
side of the tibia 66 ± 5 mm Part V Annex Regulation (EC) No. 78/2009, UN Regulation
66 ± 5 mm below the ± 5 mm below the knee joint centre, 6.3.1.1.6.1
below the knee joint centre, 1.5 4 2.1 127(Series 00) and GTR No. 9 are identical.
knee joint centre, with its with its sensitive axis in the direction
with its sensitive axis in the
sensitive axis in the of impact.
direction of impact
direction of impact.
Part V Annex
Damper and tranducers 6.3.1.1.6.2, Regulation (EC) No. 78/2009, UN Regulation
Damper and tranducers fitted. 1.5, 4 2.2, Damper and tranducers fitted.
fitted. 6.3.1.1.6.3 127(Series 00) and GTR No. 9 are identical.
1.6 2.3
4 tranducer in tibia to
measure bending
moments: Annex
The lower legform impactor introduced in the
 134 ± 1 mm 4 2.1,
- - - - Series 01 of amendments for UN Regulation
 214 ± 1 mm Figure
127 uses different instrumentation.
 294 ± 1 mm 3
 374 ± 1 mm
From knee joint centre
3 tranducers in the femur
to measure bending
moments: Annex
The lower legform impactor introduced in the
4 2.1,
- -  137 ± 1 mm - - Series 01 of amendments for UN Regulation
Figure
 217 ± 1 mm 127 uses different instrumentation.
3
 297 ± 1 mm
From knee joint centre
Three transducers in the
Annex
knee joint to measure The lower legform impactor introduced in the
4 2.1,
- - elongations of the Medial - - Series 01 of amendments for UN Regulation
Figure
Collateral Ligament 127 uses different instrumentation.
3
(MCL), Anterior Cruciate

442
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in GTR No. 9 (Potential US Regulation) Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
Ligament (ACL), and
Posterior Cruciate
Ligament (PCL). The
measurement locations of
each transducer are shown
in Figure 3. The
measurement locations
shall be within ±4 mm
along the X-axis from the
knee joint centre.
Annex
Channel 180 4 2.4
Part V
frequency 180 180 6.3.1.1.6.4 Identical
1.7
class 180 Annex
4 2.3
50º for knee bending
angle Regulation (EC) No. 78/2009, UN Regulation
10 mm for shearing 127(Series 00) and GTR No. 9 are identical.
Annex
50º for knee bending angle displacement
CAC 4 2.4 50º for knee bending angle
10 mm for shearing Part V 500 g for acceleration The lower legform impactor introduces in the
response 10 mm for shearing displacement 6.3.1.1.6.4
displacement 1.7 Series 01 of amendments for UN Regulation
values Annex 500 g for acceleration
500 g for acceleration 30 mm for knee ligament 127 uses different instrumentation and takes
4 2.3
elongations different measurements.
400 Nm fot the tibia and
femur bending moments
Lower
legform
impactor
certification
Maximum of 20 impacts Maximum of 20 impacts Maximum of 20 impacts before re-
before re-certification before re-certification certification
Part V Annex
Re-certification if more than Re-certification if more Re-certification if more than 12 6.3.1.1.7.2 Identical
1.9 6 1.1
one year has elapsed since than 12 months has months has elapsed since previous
previous certification elapsed since previous certification
certification

443
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in GTR No. 9 (Potential US Regulation) Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
Re-certified if any impact Re-certified if any impact exceeds the
exceeds the CAC values Re-certified if any impact CAC values
exceeds the CAC values

Upper
legform test
results
Upper
legform
instantaneou Annex
s sum of I
Not exceeding 7.5 kN Not exceeding 7.5 kN 5.1.2 Not exceeding 7.5 kN 5.1.2 Identical
the impact 2.1(b),
forces with 3.1(b)
respect to
time
Upper
Annex
legform
I
bending Not exceeding 510 Nm Not exceeding 510 Nm 5.1.2 Not exceeding 510 Nm 5.1.2 Identical
2.1(b),
moment of
3.1(b)
test impactor
Upper
legform test
procedures
Annex
1
40 km/h 2.1(b),
3.1(b)
Impact Annex
11.1 ± 0.2 m/s 11.1 ± 0.2 m/s Identical
velocity 5 1.12
Part II
11.1 ± 0.2 m/s Chapt
er III
4.5
Minimum of three tests, one Part II In the bumper test area. Annex UN Regulation 127 and Regulation (EC) No
Measuring 5 1.4 In the bumper test area.
each to the middle and outer Chapt 7.1.2.1 78/2009 are almost identical. Regulation (EC)
points
thirds at positions most likely er II Minimum of three tests, No 78/2009 includes the extra provision that

444
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in GTR No. 9 (Potential US Regulation) Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
to cause injury. 3.3 one each to the middle different types of structure must be tested.
Tests shall be performed to and outer thirds.
different types of structure Measuring points a GTR No. 9 gives far less details, only that the
where they vary throughout minimum of 132 mm Annex test must be in the bumper area.
the area to be assessed. apart horizontally and a 5 2.5
Measuring points a minimum minimum of 66 mm
of 132 mm apart horizontally inside defined corners of
and a minimum of 66 mm bumper
inside defined corners of
bumper
Parallel to the longitudinal Horizontal plane and
Direction of Part II Horizontal plane and parallel to the
axis of the vehicle, with the parallel to the longitudinal
impact Chapt Annex longitudinal vertical plane of the
axis of the upper legform vertical plane of the 7.1.2.2 Identical
velocity er III 5 2.6 vehicle.
vertical. vehicle.
vector 4.4 Tolerance of ± 2º.
Tolerance of ± 2º. Tolerance of ± 2º.
At first contact the
At first contact the impactor impactor centre must be
At first contact the impactor centre
centre must be vertically Part II vertically midway
must be vertically midway between
Position of midway between the upper Chapt between the upper Annex
the upper bumper reference line and 7.1.2.2 Identical
impactor bumper reference line and the er III bumper reference line and 5 2.6
the lower bumper reference line.
lower bumper reference line. 4.4 the lower bumper
Tolerance of ± 10mm
Tolerance of ± 10mm reference line.
Tolerance of ± 10mm
The impactor vertical
The impactor vertical centre
Part II centre line must be The impactor vertical centre line must
line must be positioned
Chapt positioned laterally within Annex be positioned laterally within the
laterally within the selected 7.1.2.2 Identical
er III the selected impact 5 2.6 selected impact location
impact location
4.4 location Tolerance of ± 10 mm
Tolerance of ± 10 mm
Tolerance of ± 10 mm
Upper
legform
impactor
Upper legform must be rigid Upper legform must be
Part V Annex Upper legform must be rigid and
and foam covered at the rigid and foam covered at 6.3.1.2 Identical
2.1 4 3.1 foam covered at the impact side
impact side the impact side

445
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in GTR No. 9 (Potential US Regulation) Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
Overall Part V Annex
350 ± 5 mm 350 ± 5 mm 350 ± 5 mm 6.3.1.2 Identical
length 2.1 4 3.1

Part V Annex
Total mass 9.5 ± 0.1 kg 9.5 ± 0.1 kg 9.5 ± 0.1 kg 6.3.1.2.1 Identical
2.4 4 3.2

Total mass
of front
member and
other
components
Part V Annex
in front of 1.95 ± 0.05 kg 1.95 ± 0.05 kg 1.95 ± 0.05 kg 6.3.1.2.2 Identical
2.4 4 3.3
active
element
(excluding
foam and
skin)
Front
Part V Annex
member 50 ± 1 mm 50 ± 1 mm 50 ± 1 mm 6.3.1.2.6 Identical
2.1 4 3.7
diameter
Impactor shall be
Impactor shall be mounted to mounted to the propulsion
the propulsion system by a system by a troque Impactor shall be mounted to the
troque limiting joint and be limiting joint and be propulsion system by a troque
insensitive to off-axis loading. insensitive to off-axis limiting joint and be insensitive to
Part II
It shall move only in the loading. It shall move off-axis loading. It shall move only in
Torque Chapt Annex
specified direction of impact only in the specified the specified direction of impact 6.3.1.2.3 Identical
limiting joint er III 4 3.4
when in contact with the direction of impact when when in contact with the vehicle and
2.1
vehicle and shall be prevented in contact with the vehicle shall be prevented from motion in
from motion in other and shall be prevented other directions including rotation
directions including rotation from motion in other about any axis.
about any axis. directions including
rotation about any axis.

446
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in GTR No. 9 (Potential US Regulation) Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
Longitudinal axis of front Longitudinal axis of front
Torque Longitudinal axis of front member is
member is perpendicular to the Part V member is vertical at the Annex
limiting joint vertical at the time of impact. 6.3.1.2.4 Identical
axis of the guidance system 2.2 time of impact. 4 3.5
setup Tolerance ± 2º.
Tolerance ± 2º. Tolerance ± 2º.

Joint friction Part V Annex

675 ± 25 Nm. 675 ± 25 Nm. 675 ± 25 Nm. 6.3.1.2.4 Identical
torque 2.2 4 3.5

Parts of impactor forward

Parts of impactor forward of
of torque limiting joint Parts of impactor forward of torque
torque limiting joint shall lie
Centre of Part V shall lie on the Annex limiting joint shall lie on the
on the longitudinal centre line 6.3.1.2.5 Identical
gravity 2.3 longitudinal centre line of 4 3.6 longitudinal centre line of impactor
of impactor
impactor Tolerance ± 10 mm
Tolerance ± 10 mm
Tolerance ± 10 mm
Length
between load Part V Annex
310 ± 1 mm 310 ± 1 mm 310 ± 1 mm 6.3.1.2.6 Identical
transducer 2.1 4 3.7
centre lines
Upper
legform
impactor
instrumentati
on
Three strain gauges located on
the impactor to measure the
bending moments of the front Front member must be
Front member must be strain gauged
Strain member. Part V strain gauged to measure Annex
to measure bending moments in three 6.3.1.2.9.1 Identical
gauges Two outer strain gauges 50 ± 1 2.6 bending moments in three 4 4.1
positions.
mm from the symmetrical axis positions.
Middle strain gauge on the
symmetrical axis ± 1 mm
Back of the front member Back of the front member
Strain Two outer strain gauges Two outer strain gauges 50 ± 1 mm
Annex
gauges 50 ± 1 mm from the from the symmetrical axis 6.3.1.2.9.1 Identical
4 4.1
positions symmetrical axis Middle strain gauge on the
Middle strain gauge on symmetrical axis ± 1 mm

447
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in GTR No. 9 (Potential US Regulation) Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
the symmetrical axis ± 1
mm

Two fitted to measure forces Two fitted to measure

Load Part V Annex Two fitted to measure forces applied
applied at either end of the forces applied at either 6.3.1.2.9.2 Identical
tranducers 2.5 4 4.2 at either end of the impactor
impactor end of the impactor
Channel
Part V Annex
frequency 180 180 180 6.3.1.2.9.3 Identical
2.7 4 4.3
class
CAC 10 kN for force tranducers
10 kN for force tranducers Part V Annex 10 kN for force tranducers
response 1000 Nm for bending 6.3.1.2.9.3 Identical
1000 Nm for bending moment 2.7 4 4.3 1000 Nm for bending moment
values moment
Upper
legform
impactor
certification
Maximum of 20 impacts
Maximum of 20 impacts Maximum of 20 impacts before re-
before re-certification
before re-certification certification
Re-certification if more
Re-certification if more than Re-certification if more than 12
Part V than 12 monts has elapsed Annex
one year has elapsed since monts has elapsed since previous 6.3.1.2.10.2 Identical
2.10 since previous 6 2.1
previous certification certification
certification
Re-certified if any impact Re-certified if any impact exceeds the
Re-certified if any impact
exceeds the CAC values CAC values
exceeds the CAC values
Upper
legform to
bonnet
leading edge

Test Results

448
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in GTR No. 9 (Potential US Regulation) Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
Instantaneou
s sum of the
Annex
impact
Not exceeding 5.0 kN I 2.2, - - - - N/A
forces with
3.2
respect
to time
bending
moment on
the test Compared with possible target Annex
impactor of 300 Nm I 2.2
shall be - - - - N/A
recorded and Compared with possible Annex
compared maximum of 300 Nm I 3.2
with the
possible

Test
Procedures

Longitudinal axis of the

Part II
impactor must be parallel to
Chapt
the longitudinal vertical plane - - - - N/A
er IV
of the vehicle to be tested
4.4
Tolerence ±2º
At first contact the centre line
shall be consistent with the Part II
bonnet leading edge reference Chapt
- - - N/A
line and laterally with the er IV
selected impact location 4.4
Tolerence ±10 mm
40 km/h Annex
I 2.2,
Impact Determined by the vehicle 3.2
- - - - N/A
velocity shape. Minimum 5.56 m/s,
maximum 11.1 m/s. Part II
Tolerance ±2% Chapt

449
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in GTR No. 9 (Potential US Regulation) Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
er IV
4.5

Direction of Dependant on the values of

- - - - N/A
impact bonnet leading edge height

Same as impactor for upper Part V

Impactor - - - - N/A
legform to bumper 2

Calculated using M=2E/V2.

Part II
The mass may be adjusted by
Chapt
Weight up to ± 10% provided the - - - - N/A
er IV
velocity is changed to keep the
4.8
same kinetic energy.
Child and
adult
Child and adult headform to
headfroms
bonnet top
to front
structure
Child
headform
impact test
result
Shall not exceed 1000 over 2/3 Shall not exceed 1,000 Shall not exceed 1,000 over a Regulation (EC) No. 78/2009 “Type B”
of the bonnet test area and Annex over a minimum of one 5.2.1 minimum of one half of the child approval, UN Regulation 127 and GTR No. 9
2000 for the remaining 1/3 of I 2.3 half of the child headform headform test area are identical.
the test area test area and 1,000 over two thirds of the UN Regulation 127 and GTR No.9 include an
and 1,000 over two thirds combined child and adult headform extra provision in case there is only a child test
HIC
Shall not exceed 1000 over 1/2 of the combined child and test areas. The HIC for the remaining 5.2.3 area.
recorded
of the child headform test area adult headform test areas. areas shall not exceed 1,700 for both
and in addition shall not The HIC for the headforms. Regulation (EC) No. 78/2009 “Type A”
exceed 1000 over 2/3 of the remaining areas shall not approval has a higher allowance value for 1/3
combined child and adult exceed 1,700 for both 5.2.3 In case there is only a child headform of the test area, but is being phased out.
headform test areas. The HPC Annex headforms. test area, the HIC recorded shall not

450
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in GTR No. 9 (Potential US Regulation) Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
for the remaining areas shall I 3.5 exceed 1,000 over two thirds of the
not exceed 1700 for both In case there is only a test area. For the remaining area the
headforms. child headform test area, HIC shall not exceed 1,700.
the HIC recorded shall not
exceed 1,000 over two
thirds of the test area. For
the remaining area the
HIC shall not exceed
1,700.
Adult
headform
impact test
result
Shall not exceed 1,000
Shall not exceed 1000 over 1/2 over a minimum of one
Shall not exceed 1,000 over a
of the child headform test area half of the child headform
minimum of one half of the child
and in addition shall not Annex test area
headform test area
exceed 1000 over 2/3 of the I 3.5 and 1,000 over two thirds Regulation (EC) No. 78/2009 “Type B”
HIC and 1,000 over two thirds of the
combined child and adult of the combined child and 5.2.1 5.2.3 approval, UN Regulation 127 and GTR No. 9
recorded combined child and adult headform
headform test areas. The HPC adult headform test areas. are identical.
test areas. The HIC for the remaining
for the remaining areas shall The HIC for the
areas shall not exceed 1,700 for both
not exceed 1700 for both remaining areas shall not
headforms.
headforms. exceed 1,700 for both
headforms.
Headform
test
procedures
Part II
Chapt
er V Impactor must be in free Annex
Impactor must be in free flight Impactor must be in free flight at the
2.1, flight at the time of 5 7.2.1 Identical
at the time of impact. time of impact.
Chapt impact. 3.1.1
er VII
2.1

451
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in GTR No. 9 (Potential US Regulation) Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
Part II The impactor must be
The impactor must be released
Chapt released at a distance so The impactor must be released at a
at a distance so that the test
er V that the test results are not Annex distance so that the test results are not
results are not influenced by
2.1, influenced by contact 5 influenced by contact with hte 7.2.1 Identical
contact with hte propulsion
Chapt with hte propulsion 3.1.2 propulsion system during rebound of
system during rebound of the
er VII system during rebound of the impactor.
impactor.
2.1 the impactor.
Measurements or
recordings of the
Measurements or recordings of
following must be taken: Measurements or recordings of the
the following must be taken:
 Velocity of the impact following must be taken:
 Velocity of the impact must Part II must be measured  Velocity of the impact must be
be measured during free Chapt during free flight Annex measured during free flight before
flight before impact. er V before impact. 5 impact.
 Angle of velocity vector at 4.8, 7.2.2, 7.2.3 Identical
 Angle of velocity 3.2.1,  Angle of velocity vector at impcat
impcat Chapt
vector at impcat 3.3.1  Acceleration time histories
 Acceleration time histories er VII
 Acceleration time  HIC calculated
 HIC calculated 4.8
histories  First point of contact (measuring
 First point of contact
 HIC calculated point)
(measuring point)
 First point of contact
(measuring point)
Splitting of
headform
test zones
HIC1000 zone and HIC20000 Part II
zone identified by Chapt
manufacturer and shown on a er V
HIC1000 zone and
drawing shoing it viewed from 3.2.1
HIC1700 zone identified HIC1000 zone and HIC1700 zone
above. Annex
by manufacturer and identified by manufacturer and shown 5.2.4.1,
5 3.1, Identical
shown on a drawing on a drawing shoing it viewed from 5.2.4.2
HIC1000 zone and HIC1700 3.2
shoing it viewed from above.
zone identified by Part II
above.
manufacturer and shown on a Chapt
drawing shoing it viewed from er VII
above. 3.3.2

452
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in GTR No. 9 (Potential US Regulation) Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref

Part II
Chapt
Areas of the zones may
Areas of the zones may consist er V Areas of the zones may consist of
consist of several parts, Annex
of several parts, the number of 3.2.3, several parts, the number of parts not 5.2.4.3 Identical
the number of parts not 5 3.3
parts not being limited. Chapt being limited.
being limited.
er VII
3.3.3
Part II
Chapt Calculation of the surface
Calculation of the surface of Calculation of the surface of the
er V of the bonnet top area and
the bonnet top area and the Annex bonnet top area and the zones must be
3.2.4, the zones must be done on 5.2.4.4 Identical
zones must be done on the 5 3.4 done on the basis of the drawing
Chapt the basis of the drawing
basis of the drawing supplied. supplied.
er VII supplied.
3.3.3

Measuring
points

Minimum of 18 tests carried Part II Minimum of 9 tests; 3

out with the headform Chapt tests each to the middle Annex Regulation (EC) No. 78/2009 “Type B”
impactor. 6 tests each to the er V and outer thirds at 5 4.2. approval and UN Regulation 127 are identical.
middle and outer thirds of the 3.2 positions judged most 5.2 However, UN Regulation 127 contains the
Tests shall be made to the front
bonnet top at positions judged likely to cause injurt. provision that less than 9 tests can be carried
structure within the boundaries as
most likely to cause injury. At 7.3.1 out if the test area is too small.
defined in paragraph 3.12.
least 12 of the 18 must be Less than 9 tests for each
within the HPC1000 zone and impactor may be GTR No. 9 does not include any information
Tests shall be made to the front
6 within the HPC2000 zone performed if a number of about the number of thests that should be
structure within the boundaries as
measuring points have 7.4.1 carried out.
defined in paragraph 3.1.
Minimum of 9 tests carried out been selected in order of Annex
with each headform impactor. Part II potential to cause injury 5 3.5 Regulation (EC) No. 78/2009 “Type A”
3 tests each to the middle and Chapt and the test area approval has a different requirement, but is
outer thirds of the bonnet top er VII remaining is too small to being phased out.
at positions judged most likely 3.1.1 select another measuring

453
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in GTR No. 9 (Potential US Regulation) Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
to cause injury. point while maintaining
the minimum spacing
between points be
performed.
The positions tested by
the laboratories shall be
indicated in the test
report. However, the
technical services
conducting the tests shall
perform as many tests as
necessary to guarantee the
Annex
- - compliance of the vehicle - - N/A
5 3.5
with the head injury
criteria (HIC) limit values
of 1000 for the HIC1000
zone and 1700 for the
HIC1700 zone, especially
in the points near to the
borders between the two
types of zones.
Child
headform
specific test
procedures
Selected measuring points Part II Selected measuring points Selected impact points shall be: Regulation (EC) No. 78/2009 “Type B”
must be: Chapt must be a minimum of  a minimum of 82.5 mm inside the approval, UN Regulation 127 and GTR No. 9
 a minimum of 165 mm apart er V 165 mm apart. defined side reference lines, and, are identical.
 a minimum of 82.5 mm 3.2  forward of the WAD1700 line, or a However, Regulation (EC) No. 28/2009 and
inside the defined side minimum of 82.5 mm forwards of UN Regulation 127 also state the points must
referenc lines the bonnet rear reference line - 7.3.2 be 165 mm apart.
 a minimum of 82.5 mm whichever is most forward at the
forwards of the defined  Front: WAD1000mm or point of measurement, and; Regulation (EC) No. 78/2009 “Type A”
bonnet rear reference line. a line 82.5 mm rearward rearward of the WAD1000 line, or, approval has slightly different requirements,
 A minimum of 165 mm of the bonnet leading  a minimum of 82.5 mm rearwards but is being phased out.
rearwards of the the bonnet edge reference line, of the bonnet leading edge

454
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in GTR No. 9 (Potential US Regulation) Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
leading edge referance line , whichever is most reference line - whichever is most
unless no point in the bonnet rearwards Annex rearward at the point of
leading edge test area within  Rear: WAD1700 or a 5 4.3 measurement.
165 mm laterally would, if line 82.5 mm forward of
chosen for an upper legform the bonnet rear reference
to bonnet leading edge test, line, whichever is most
require a kinetic energy of forward
more than 200 J.  Sides: line 82.5 mm
inside the side reference
Selected measuring points Part II line
must be: Chapt
 a minimum of 165 mm apart er VII
 a minimum of 82.5 mm inside 3.2 2.14
the defined side referenc lines
 a minimum of 82.5 mm
forwards of the defined
bonnet rear reference lineor
forward of a WAD 1700 mm,
whichever is most forward
 a minimum of 82.5 mm
rearward of the bonnet leading
edge referance line or
rearward of the WAD 1000
mm, whichever is more
rearward
35 km/h Annex
I 2.3,
3.3

Part II
Impact Annex
9.7 ± 0.2 m/s Chapt 9.7 ± 0.2 m/s 9.7 ± 0.2 m/s 7.3.4 Identical
velocity 5 4.6
er V
4.6,
Chapt
er VII
4.6

455
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in GTR No. 9 (Potential US Regulation) Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
Part II
In the longitudinal vertical In the longitudinal
Chapt In the longitudinal vertical plane of
plane of the vehicle at an angle vertical plane of the
er V the vehicle at an angle of 50 ± 2 º to
Direction of of 50 ± 2 º to Ground Referenc vehicle at an angle of 50 ± Annex
4.4.1, the horizontal. 7.3.5 Identical
impact Level 2 º to the horizontal. 5 4.7
Chapt The direction must be downward and
The direction must be The direction must be
er VII rearward.
downward and rearward. downward and rearward.
4.4.1

Tests must be within the Annex Identical for UN Regulation 127 and GTR No.
- - Tests must be within the boundaries. 7.3.1
boundaries. 5 4.1 9.

Part II
Chapt The impactor must not
The impactor must not contact The impactor must not contact the
er V contact the windscreen or
the windscreen or A-pillar Annex windscreen or A-pillar before the
4.4, A-pillar before the bonnet 7.3.1 Identical
before the bonnet for tests at 5 4.1 bonnet for tests at the rear area of the
Chapt for tests at the rear area of
the rear area of the bonnet top. bonnet top.
er VII the bonnet top.
4.4
Part II
No point measured that
No point measured that the Chapt
the impactor will have a No point measured that the impactor
impactor will have a glancing er V
glancing blow resulting in Annex will have a glancing blow resulting in
blow resulting in a more 3.2, 7.3.2 Identical
a more severe second 5 4.4 a more severe second impact outside
severe second impact outside Chapt
impact outside the test the test area.
the test area. er
area.
3.3.1
Part II
Chapt
Point of first contact must
Point of first contact must be er V Point of first contact must be within a
be within a ± 10 mm Annex
within a ± 10 mm tolerence of 4.6, ± 10 mm tolerence of the intended 7.3.3 Identical
tolerence of the intended 5 4.5
the intended point Chapt point.
point.
er VII
4.6
Adult
headform
specific test
procedures

456
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in GTR No. 9 (Potential US Regulation) Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
Selected measuring points
Selected measuring points must be a minimum of
must be: 165 mm apart.
 a minimum of 165 mm apart 2.1
 a minimum of 82.5 mm inside  Front: WAD1700mm or
Selected impact points shall be:
the defined side referenc lines Part II a line 82.5 mm rearward
 a minimum of 82.5 mm inside the Regulation (EC) No. 78/2009 “Type B”
 a minimum of 82.5 mm Chapt of the bonnet leading
defined side reference lines, and, approval, UN Regulation 127 and GTR No. 9
forwards of the defined er VII edge reference line,
 forward of the WAD2100 line, or are identical.
bonnet rear reference lineor 3.2 whichever is most
a minimum of 82.5 mm forwards of 7.4.2 However, Regulation (EC) No. 28/2009 and
forward of a WAD 2100 mm, rearwards
the bonnet rear reference line - UN Regulation 127 also state the points must
whichever is most forward  Rear: WAD2100 or a Annex
whichever is most forward at the be 165 mm apart.
 a minimum of 82.5 mm line 82.5 mm forward of 5 5.3
point of measurement, and;
rearward of the bonnet leading the bonnet rear reference
 rearward of the WAD1700 line
edge referance line or line, whichever is most
rearward of the WAD 1700 forward
mm, whichever is more  Sides: line 82.5 mm
rearward inside the side reference
line
35 km/h Annex
I 2.3,
3.3
Impact Annex
9.7 ± 0.2 m/s 9.7 ± 0.2 m/s 7.4.4 Identical
velocity 9.7 ± 0.2 m/s Part II 5 5.6
Chapt
er VII
4.6
In the longitudinal vertical In the longitudinal
In the longitudinal vertical plane of
plane of the vehicle at an angle Part II vertical plane of the
the vehicle at an angle of 65 ± 2 º to
Direction of of 65 ± 2 º to Ground Referenc Chapt vehicle at an angle of 65 ± Annex
the horizontal. 7.4.5 Identical
impact Level er VII 2 º to the horizontal. 5 5.7
The direction must be downward and
The direction must be 4.4.1 The direction must be
rearward.
downward and rearward. downward and rearward.

Tests must be within the Annex Identical for UN Regulation 127 and GTR No.
- - Tests must be within the boundaries. 7.4.1
boundaries. 5 5.1 9.

457
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in GTR No. 9 (Potential US Regulation) Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
The impactor must not
The impactor must not contact Part II The impactor must not contact the
contact the windscreen or
the windscreen or A-pillar Chapt Annex windscreen or A-pillar before the
A-pillar before the bonnet 7.4.1 Identical
before the bonnet for tests at er VII 5 5.1 bonnet for tests on the rear area of the
for tests on the rear area
the rear area of the bonnet top. 4.4 bonnet top.
of the bonnet top.
No point measured that
the impactor will have a No point measured that the impactor
glancing blow resulting in Annex will have a glancing blow resulting in Identical for UN Regulation 127 and GTR No.
- - 7.4.2
a more severe second 5 5.4 a more severe second impact outside 9.
impact outside the test the test area.
area.
Point of first contact must
Point of first contact must be Part II Point of first contact must be within a
be within a ± 10 mm Annex
within a ± 10 mm tolerence of Chapt ± 10 mm tolerence of the intended 7.4.3 Identical
tolerence of the intended 5 5.5
the intended point er 4.6 point.
point.
Child
headform
impactor
Annex
Part V
Material Aluminium Aluminium 5 Aluminium 6.3.2.1 Identical
3.1
5.1.1
Annex
Part V
Shape Spherical Spherical 5 Spherical 6.3.2.1 Identical
3.1
5.1.1
Annex
Part V
Diameter 165 ±1 mm 165 ±1 mm 5 165 ±1 mm 6.3.2.1 Identical
3.1
5.1.1
Annex
I 2.3,
3.5 kg Annex
3.3
Mass 3.5 ± 0.07 kg 5 3.5 ± 0.07 kg 6.3.2.1 Identical,
3.5 ± 0.07 kg 5.1.1
Part V
3.1

458
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in GTR No. 9 (Potential US Regulation) Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
Moment of
inertia about
an axis
through the
Annex
centre of Part V
0.008 to 0.012 kgm2 0.008 to 0.012 kgm2 5 0.008 to 0.012 kgm2 6.3.2.1 Identical
gravity and 3.3
5.1.1
perpendicula
r to the
direction of
impact
Geometric centre of Annex
Centre of Centre of sphere Part V Geometric centre of sphere
sphere 5 6.3.2.1 Identical
Gravity Tolerence ± 2 mm 3.3 Tolerence ± 2 mm
Tolerence ± 2 mm 5.1.1
14 ± 0.5 mm thick synthetic 14 ± 0.5 mm thick Annex
Part V 14 ± 0.5 mm thick synthetic ckin
Skin ckin covering at least half the synthetic ckin covering at 5 6.3.2.1 Identical
3.2 covering at least half the sphere
sphere least half the sphere 5.1.1
Annex
First natural Part V
5000 Hz 5000 Hz 5 5000 Hz 6.3.2.1.2 Identical
frequency 3.7
5.1.2
Adult
headform
impactor
Annex
Part V
Material Aluminium Aluminium 5 Aluminium 6.3.2.2 Identical
4.1
5.3.1
Annex
Part V
Shape Spherical Spherical 5 Spherical 6.3.2.2 Identical
4.1
5.3.1
Annex
Part V
Diameter 165 ±1 mm 165 ±1 mm 5 165 ±1 mm 6.3.2.2 Identical
4.1
5.3.1

459
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in GTR No. 9 (Potential US Regulation) Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
Annex
4.5kg I 3.4 Annex
Mass 4.5 ± 0.1 kg 5 4.5 ± 0.1 kg 6.3.2.2 Identical
4.5 ± 0.1 kg Part V 5.3.1
4.1.2
Moment of
inertia about
an axis
through the
Annex
centre of Part V
0.010 to 0.013 kgm2 0.010 to 0.013 kgm2 5 0.010 to 0.013 kgm2 6.3.2.2 Identical
gravity and 4.3
5.3.1
perpendicula
r to the
direction of
impact
Geometric centre of Annex
Centre of Centre of sphere Part V Geometric centre of sphere
sphere 5 6.3.2.2 Identical
Gravity Tolerence ± 5 mm 4.3 Tolerence ± 5 mm
Tolerence ± 5 mm 5.3.1
14 ± 0.5 mm thick synthetic 14 ± 0.5 mm thick Annex
Part V 14 ± 0.5 mm thick synthetic ckin
Skin ckin covering at least half the synthetic ckin covering at 5 6.3.2.2 Identical
4.2 covering at least half the sphere
sphere least half the sphere 5.3.1
Annex
First natural Part V
5000 Hz 5000 Hz 5 5000 Hz 6.3.2.2.2 Identical
frequency 4.7
5.3.2
 Flat face
 Flat face
 perpendiculat to the
 perpendiculat to the direction of
direction of travel
travel
 perpendiculat to thehe
 perpendiculat to thehe axis of one of
Rear face of axis of one of the Annex Identical for UN Regulation 127 and GTR No.
- - the accelerometers 6.3.2.3
impactors accelerometers 4 5.5 9.
 Capable of providin access to
 Capable of providin
accelerometers
access to accelerometers
 Attachment point for propulsion
 Attachment point for
system
propulsion system

460
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in GTR No. 9 (Potential US Regulation) Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
Child and
adult
headform
impactor
instrumentati
on
Recess in sphere for ine
Recess in sphere for ine
triaxial or three uniaxial
triaxial or three uniaxial Recess in sphere for ine triaxial or
accelerometers. Location;
accelerometers. Location; three uniaxial accelerometers.
 Within ± 10 mm seismic
 Within ± 10 mm seismic Location;
mass location from
mass location from centre of Annex  Within ± 10 mm seismic mass
Part V centre of spehere for the
spehere for the measurement 4 location from centre of spehere for 6.3.2.1.1,
3.4, measurement axis Identical
axis 5.2.1, the measurement axis 6.3.2.2.1
4.4  Within ± 1 mm seismic
 Within ± 1 mm seismic mass 5.4.1  Within ± 1 mm seismic mass
mass location tolerance
location tolerance from the location tolerance from the centre of
from the centre of the
centre of the sphere for the the sphere for the perpendicular
sphere for the
perpendicular direction to the direction to the measurement axis
perpendicular direction
measurement axis
to the measurement axis
If three uniaxle
If three uniaxle accelerometers
accelerometers used, one
used, one of the
of the accelerometers
accelerometers must; If three uniaxle accelerometers used,
must;
 have its sensitive axis one of the accelerometers must;
 have its sensitive axis
perpendicular to the mounting  have its sensitive axis perpendicular
perpendicular to the
face Annex to the mounting face
Part V mounting face
 Seismic mass positioned 4  Seismic mass positioned within a 6.3.2.1.1,
3.4.1,  Seismic mass positioned Identical
within a cylindrical tolerence 5.2.2, cylindrical tolerence field of 1mm 6.3.2.2.1
4.4.1 within a cylindrical
field of 1mm radius and 20 5.4.2 radius and 20 mm length
tolerence field of 1mm
mm length  Centre of tolerence field must
radius and 20 mm length
 Centre of tolerence field must coincide with the centre of the sphere
 Centre of tolerence field
coincide with the centre of the of the headform impactor
must coincide with the
sphere of the headform
centre of the sphere of
impactor
the headform impactor

461
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in GTR No. 9 (Potential US Regulation) Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
The remaining
The remaining accelerometers
accelerometers must;
must;
 Have their sensitive axis The remaining accelerometers must;
 Have their sensitive axis
perpendicular to the  Have their sensitive axis
perpendicular to the mounting
mounting face perpendicular to the mounting face
face Annex
Part V  Seismic mass positioned  Seismic mass positioned within a
 Seismic mass positioned 4 6.3.2.1.1,
3.4.2, within a spherical spherical tolerence field of 10 mm Identical
within a spherical tolerence 5.2.3, 6.3.2.2.1
4.4.2 tolerence field of 10 mm radius
field of 10 mm radius 5.4.3
radius  Centre of tolerence field must
 Centre of tolerence field must
 Centre of tolerence field coincide with the centre of the sphere
coincide with the centre of the
must coincide with the of the headform impactor
sphere of the headform
centre of the sphere of
impactor
the headform impactor
Annex
Part V
4 6.3.2.1.1,
CFC value 1000 3.5, 1000 1000 Identical
5.2.4, 6.3.2.2.1
4.5
5.4.4
Annex
CAC Part V
4 6.3.2.1.1,
response 500g 3.5, 500g 500g Identical
5.2.4, 6.3.2.2.1
value 4.5
5.4.4
Child and
adult
headform
impactor
certification
Maximum of 20 impacts
Maximum of 20 impacts Maximum of 20 impacts before re-
before re-certification
before re-certification certification
Re-certification if more
Re-certification if more than Part V Re-certification if more than 12
than 12 monts has elapsed Annex
12 monts has elapsed since 3.6, monts has elapsed since previous 6.3.2.4 Identical
since previous 6 3,1
previous certification 4.6 certification
certification
Re-certified if any impact Re-certified if any impact exceeds the
Re-certified if any impact
exceeds the CAC values CAC values
exceeds the CAC values

462
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in GTR No. 9 (Potential US Regulation) Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
Adult Regulation (EC) No. 78/2009 “Type A”
headform to (Required for “Type A” approval is being phased out.
windscreen approval) This test was removed in 2014.
test

Test Result

HPC shall be recorded and

compared with the possible
HPC target of 1000. The test shall Annex
- - - - N/A
recorded be completed for monitoring I 2.4
purposes only and the results
shall be fully recorded

Test
Procedure

 82.5 mm inside windscreen

Part II
limits as described in
Chapt
Directive 77/649/EEC N/A
er VI
 82.5 mm forwards of the rear
3.2
windscreen reference line
Part II
Impactor must be in free flight Chapt
- - - - N/A
at the time of impact. er VI
2.1,
The impactor must be released
at a distance so that the test Part II
results are not influenced by Chapt
- - - - N/A
contact with hte propulsion er VI
system during rebound of the 2.1
impactor.
A minimum of 5 tests shall be Part II
Measuring carried out at positions judged Chapt
- - - - N/A
points to be the most likely to cause er VI
injury. 3.2

463
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in GTR No. 9 (Potential US Regulation) Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
In the vertical longitudinal
plane of the vehicle at an angle Part II
Direction of of 35 ± 2 º to Ground Referenc Chapt
- - - - N/A
impact Level er VI
The direction must be 4.4
downward and rearward.
Part II
Point of first contact must be
Chapt
within a ± 10 mm tolerence of - - - - N/A
er VI
the intended point
4.5
Part II
Impact Chapt
9.7 ± 0.2 m/s - - - - N/A
velocity er VI
4.6
Adult
headform
impactor

Part V
Material Aluminium - - - - N/A
4.1

Part V
Shape Spherical - - - - N/A
4.1

Part V
Diameter 165 ±1 mm - - - - N/A
4.1

4.8 kg Annex
I 2.4
Mass - - - - N/A
4.8 ± 0.1 kg Part V
4.1.1

464
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in GTR No. 9 (Potential US Regulation) Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
Moment of
inertia about
an axis
through the
centre of Part V
0.010 to 0.013 kgm2 - - - - N/A
gravity and 4.3
perpendicula
r to the
direction of
impact

Centre of Centre of sphere Part V

- - - - N/A
Gravity Tolerence ± 5 mm 4.3

14 ± 0.5 mm thick synthetic

Part V
Skin ckin covering at least half the - - - - N/A
4.2
sphere

First natural Part V

5000 Hz - - - - N/A
frequency 4.7

Instrumenta
tion

Maximum of 20 impacts
before re-certification

Re-certification if more than

Part V
12 monts has elapsed since - - - - N/A
4.6
previous certification

Re-certified if any impact

exceeds the CAC values

465
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in GTR No. 9 (Potential US Regulation) Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
Brake Assist
System

Vehicles must be equipped

with a type-approved brake
Articl
Requirement assisit system that comply - - - - N/A
e 4 1.
with the test in Annex I
Section 4
Reference test to identify
opertaion point at which the
Annex
anti-lock braking system
I
(ABS) activates.
Sectio
Tests Test to verify the brake assist - - - - N/A
n4
system is correctly triggered
4.1,
so as to apply the maximum
4.2
achievable deceleration
characteristics of the vehicle
Legform to
frontal
protection
system
Either lower legform to FPS or
Annex
upper legform to FPS test can - - - - N/A
I 5.1
be carried out.

Impact 5.1.1,
40 km/h - - - - N/A
velocity 5.1.2

21.0º for fitting to vehicles that Annex

Lower comply with section 2 I
legform 5.1.1.
maximum 19.0º for fitting to vehicles that 1 - - - - N/A
knee bending comply with section 3
angle Annex
24.0º for fitting to vehicles that I

466
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in GTR No. 9 (Potential US Regulation) Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
do not comply with either 5.1.1.
section 2 or 3 2
or
Value not exceeding 90% of Anene
value recorded withought the xI
FPS fitted for fitting to 5.1.1.
vehicles that do not comply 3,
with either section 2 or 3 5.1.1.
3.1

Anene
xI
5.1.1.
3,
5.1.1.
3.2

Annex
I
5.1.1.
6.0 mm for fitting to vehicles 1,
that comply with section 2 or 3 5.1.1.
2
Lower
7.5 mm for fitting to vehicles
legform
that do not comply with either Anene
maximum
section 2 or 3 xI
dynamic - - - - N/A
or 5.1.1.
knee
Value not exceeding 90% of 3,
shearing
value recorded withought the 5.1.1.
displacement
FPS fitted for fitting to 3.1
vehicles that do not comply
with either section 2 or 3
Anene
xI
5.1.1.

467
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in GTR No. 9 (Potential US Regulation) Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
3,
5.1.1.
3.2

Annex
I
5.1.1.
1

200 g for fitting to vehicles Annex

that comply with section 2 I
5.1.1.
170 g for fitting to vehicles 2
Lower that comply with section 3
legform Anene
acceleration 215 g for fitting to vehicles xI
measured at that do not comply with either 5.1.1. - - - - N/A
the upper section 2 or 3 3,
end of the or 5.1.1.
tibia Value not exceeding 90% of 3.1
value recorded without the
FPS fitted for fitting to
vehicles that do not comply Anene
with either section 2 or 3 xI
5.1.1.
3,
5.1.1.
3.2

Upper Not exceeding 7.5 kN for Annex

legform fitting to vehicles that comply I
instantaneou with section 2 or 3 5.1.2.
s sum of 1 - - - - N/A
the impact 9.4 kN for fitting to vehicles
forces with that do not comply with either
respect to section 2 or 3 Annex

468
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in GTR No. 9 (Potential US Regulation) Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
time or I
Value not exceeding 90% of 5.1.2.
value recorded without the 2,
FPS fitted for fitting to 5.1.2.
vehicles that do not comply 2.1
with either section 2 or 3

Annex
I
5.1.2.
2,
5.1.2.
2.2

Annex
I
5.1.2.
1
Not exceeding 510 Nm for
fitting to vehicles that comply
with section 2 or 3 Annex
I
Upper 640 Nm for fitting to vehicles 5.1.2.
legform that do not comply with either 2,
bending section 2 or 3 5.1.2. - - - - N/A
moment of or 2.1
test impactor Value not exceeding 90% of
value recorded without the
FPS fitted for fitting to Annex
vehicles that do not comply I
with either section 2 or 3 5.1.2.
2,
5.1.2.
2.2

469
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in GTR No. 9 (Potential US Regulation) Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
Upper
legform to
frontal
protection
system
leading edge

Impact Annex
40 km/h - - - - N/A
velocity I 5.2

Instantaneou
s sum of the
impact Annex
Not exceeding 5.0 kN - - - - N/A
forces with I 5.2
respect
to time
bending
moment on
the test
impactor
Compared with possible target Annex
shall be - - - - N/A
of 300 Nm I 5.2
recorded and
compared
with the
possible
Child/small
adult
headform to
frontal
protection
system

Impact Annex
35 km/h - - - - N/A
velocity I 5.3

470
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in GTR No. 9 (Potential US Regulation) Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
Impactor Annex
3.5 kg - - - - N/A
weight I 5.3

HPC Annex
Shall not exceed 1000 - - - - N/A
Recorded I 5.3

Constructio
n and
installation
provisions

Details of construction and Annex

- - - - N/A
installation provisions I6

Collision
avoidance
systems
Vehicles equipped with
collision avoidance systems
may not have to fulfil the test
requirements laid down in
section 2 and 3 of Annex I. Articl
Measures proposed shall e 11 1, - - - - N/A
ensure levels of protection 2
which is at least equivalent, in
terms of actual effectiveness,
to those provided by Sections
2 and 3 of Annex I

471
 Table 73: Comparison of pedestrian legislative requirements for EU (EC 78/2009, EC 631/2009, UN Reg 127) and consumer testing (Euro NCAP).

UN Regulation No. 127

Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in Euro NCAP Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref

Scope

The regulation applies to

motor vehicles of category M1
and N1 and to frontal Articl
protection systems fitted as e2 The regulation applies to
original equipment to these 1.(a), motor vehicles of 1.
vehicles or supplied as 1.(b), category M1 and N1.
separate technical unites that 1.(c)
are intended to be fitted to
these vehicles.
Vehicles of category:
 N1;
Vehicles of category:
 N1;  M1 with a maximum
mass exceeding 2500 kg
 M1 derived from N1 and of
that are derived from
maximum mass exceeding
N1;
2500 kg;
Articl Where the driver position
Where the driver position ‘R-
e2 ‘R-point’ is either forward
point’ is either forward of the 1.
2.(a), of the front axle or
front axle or longitudinally 2.(b) longitudinally rearwards
rearwards of the front axle
of the front axle
transverse centreline by a
transverse centreline by a
maximum of 1100 mm are
maximum of 1100 mm
excluded from the tests.
are excluded from the
(Sections 2 and 3 of Annex 1)
tests. (Sections 2 and 3 of
Annex 1)

472
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in Euro NCAP Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
Legform to
bumper

Either lower legform to

Annex
bumper or upper legform to
I 2.1, Test carried out is
bumper test can be carried out.
3.1 dependent on the height Test carried out is dependent on the
of the lower bumper: height of the lower bumper reference
Test carried out is dependent
 _< 425 mm – lower line at the chosen point:
on the height of the lower
legform to bumper test  _< 425 mm – lower legform to
bumper:
 425 mm < _ > 500 mm – bumper test
 _< 425 mm – lower legform 6.1.1, 6.2.1,
choice of manufacturer 5.1  425 mm < _ > 500 mm – choice of Identical
to bumper test 6.2.2
to carry out either lower manufacturer to carry out either
 425 mm < _ > 500 mm –
legform to bumper test or lower legform to bumper test or
choice of manufacturer to
upper legform to bumper upper legform to bumper test
carry out either lower legform
Part II test  _ > 500 mm – upper legform to
to bumper test or upper
Chapt  _ > 500 mm – upper bumper test
legform to bumper test
er II legform to bumper test
_ > 500 mm – upper legform 3.2
to bumper test
 Start at the intersection of the vehicle
centreline and upper bumper
reference line
 Mark grid points every 100mm in
both lateral directions up to the edge
of the bumper test zone
Marking The 100 mm distances are measured
impact area horizontally in a lateral vertical plane 3.12, 3.13
grid points and projected onto the bumper
reference line
 Where the bumper test zone is 50mm
outboard of the outermost grid point,
an additional point will be added
50mm outboard of the last grid point.
 Upper legform grid pints will contain

473
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in Euro NCAP Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
the prefix ‘U’
 Lower legform grid points will
contain the prefix’L’
 Grid points will be marked
sequentially from the centreline
being 0, points to the left will
decrease (-), points to the right will
increase (+)
Lower
legform test
results
Lower legform maximum
knee bending angle:
Lower legform maximum knee
- 19º
bending angle:
- 21.0º Regulation (EC) No. 78/2009 “Type B
Lower legform maximum
- 19.0º 5.1.1 Higher Performance Limit approval and UN Regulation 127
dynamic knee shearing
Tibia bending moment: pre-amendment series 01 (optional) are
displacement:
Lower legform maximum - 282 NM identical. Regulation (EC) No. 78/2009 “Type
- 6.0 mm
dynamic knee shearing MCL Elongation: A” approval is higher, but is being phased out.
displacement: Annex - 19 mm
Lower legform
- 6.0 mm I ACL/PCL Elongation The impactor used in Euro NCAP and the
acceleration measured at
2.1(a) - 10 mm Series 01 of amendments for UN Regulation
the upper end of the tibia:
Lower legform acceleration AP-PP 3.1.3 127 are measuring different things to the
- 170 g
measured at the upper end of Annex Lower Performance Limit impactor used for UN Regulation 127 (Series
In addition, the
the tibia: I Tibia bending moment: 00) and in Regulation (EC) No. 78/2009.
manufacturer may
- Not exceeding 200 g 3.1.(a) - 340 NM
nominate bumper test
- Not exceeding 170 g MCL Elongation: The measurements in Series 01 of amendments
widths of up to 264 mm
In addition, the manufacturer - 22 mm for UN Regulation 127 and the lower
in total where the
may nominate bumper test ACL/PCL Elongation performance limit of Euro NCAP are identical.
acceleration measured at
widths of up to 264 mm in 5.11 - 10 mm
the upper end of the tibia
total where the acceleration
shall not exceed 250
measured at the upper end of
the tibia shall not exceed 250
Maximum dynamic
medial collateral ligament

474
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in Euro NCAP Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
elongation at the knee:
- 22 mm

Maximum dynamic
anterior cruciate ligament
and posterior cruciate
ligament elongation:
- 13 mm

Absolute value of
dynamic bending
moments at the tibia:
- 340 Nm
In addition, the
manufacturer may
nominate bumper test
widths up to a maximum
of 264 mm in total where
the absolute value of the
tibia bending moment
shall not exceed 380 Nm
Lower
legform test
procedures
Annex
1
40 km/h 2.1(a), Annex
3.1(a) 5 1.12
Impact
11.1 ± 0.2 m/s 11.1 ± 0.2 m/s 9.5.8 Identical
velocity
Part II Annex
11.1 ± 0.2 m/s Chapt 5 1.12
er II
4.4

475
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in Euro NCAP Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
Minimum of three tests, one Annex
each to the middle and outer In the bumper test area. 5 1.4
thirds at positions most likely
to cause injury. Minimum of three tests,
The regulations set out the minimum number
Tests shall be performed to Part II one each to the middle Euro NCAP will test “worst case”
of tests that must be carried out and the
different types of structure Chapt and outer thirds. grid points and manufacturers may
Measuring APPP location of these tests. Whereas, Euro NCAP
where they vary throughout er II Measuring points a Annex nominate additional tests to be
points 2 only tests the grid points likely to cause most
the area to be assessed. 3.3 minimum of 132 mm 5 1.5 performed and the results will be
injury and any additional points at the request
Measuring points a minimum apart horizontally and a included in the assessment.
of the manufacturer.
of 132 mm apart horizontally minimum of 66 mm Annex
and a minimum of 66 mm inside defined corners of 5 1.5
inside defined corners of bumper
bumper
Horizontal plane and Annex
Direction of Horizontal plane and parallel Part II Horizontal plane and parallel to the
parallel to the longitudinal 5 1.6
impact to the longitudinal vertical Chapt longitudinal vertical plane of the
vertical plane of the 9.5.9 Identical
velocity plane of the vehicle. er II vehicle.
vehicle. Annex
vector Tolerance of ± 2º. 4.4 Tolerance of ± 2º.
Tolerance of ± 2º. 5 1.6
Bottom of impactor 25 Regulation (EC) No. 78/2009 and UN
mm above the ground Regulation 127 (series 00) are identical.
Annex
reference plane
Bottom of impactor 25 mm Part II 5 1.7
Tolerance of ± 10 mm. Bottom of legform shall be 75 mm The Series 01 of amendments for UN
Height of above the ground reference Chapt
above Ground Reference Level 9.5.3 Regulation 127 changes the height so that the
impactor plane er II
Bottom of impactor 75 Tolerance ± 10 mm. bottom of the impactor is higher above the
Tolerance of ± 10 mm. 4.6 Annex
mm above the ground ground reference level. This height is identical
5 1.7
reference plane to the height specified by Euro NCAP.
Tolerance of ± 10 mm.
Annex
Part II
Impactor must be in free 5 1.8
Impactor must be in free flight Chapt
flight at the time of Impactor must be in free flight 9.3.4, 9.3.8 Identical
at the time of impact. er II
impact. Annex
2.1
5 1.8
Part II Annex
At impact the centre line must Horizontal and vertical Horizontal and vertical impact
Chapt 5 1.10
be within ± 10 mm tolerance impact tolerance of ± 10 tolerance of ± 10 mm of the selected 9.5.12 Identical
er II Annex
to the selected impact location mm impact point
4.7 5 1.10

476
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in Euro NCAP Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
At first contact the
At first contact the impactor
impactor must have Annex At first contact the impactor must
must have intended orientation Part II
intended orientation about 5 1.9 have intended orientation about the The tolerance is lower for Euro NCAP than
about the vertical axis for the Chapt
the vertical axis for the vertical axis for the correct operation 9.5.10 Regulation (EC) No. 78/2009 and UN
correct operation of the knee er II
correct operation of the Annex of the knee joint. Regulation 127.
joint. 4.6
knee joint. 5 1.9 Tolerance of ± 2º.
Tolerance of ± 5º.
Tolerance of ± 5º.
The axis of the impactor
The axis of the impactor must shall be perpendicular to
Part II
be perpendicular to the the horizontal plane with The axis legform should be vertical at
Chapt Annex
horizontal plane with a a roll and pitch angle the time of first contact 9.5.9 Identical
er II 5 1.6
tolerance of 2º in the lateral tolerance of ±2° in the Tolerance of ± 2º.
4.5
and longitudinal plane lateral and longitudinal
plane.
Tibia bending moments
Only Series 01 of amendments for UN
shall not exceed ± 15 Nm
Bending moments should be ± 10.0 Regulation 127 and Euro NCAP contain this
within an evaluation Annex
- - Nm within the 30ms immediately 9.5.11 provision the bending moment allowed before
interval of 30 ms 5 1.13
prior to impact. impact is different.
immediately prior to
impact.
That specified in:
Lower
“UNECE/TRANS/WP.29/GRSP/201
legform
3/26, Annex 4.” which is UN
impactor
Regulation 127.
Two foam covered rigid
segments, representing
femur (upper leg) and
tibia (lower leg), joined
Two foam covered rigid Regulation (EC) No. 78/2009 and UN
by a deformable, Flexible lower legform impactor shall
segments, representing femur Regulation 127 (Series 00) are identical.
Part V simulated knee joint. Annex consist of flesh and skin, flexible long
(upper leg) and tibia (lower Annex 4 1.1
1.1 4 1.1 bone segments (representing femur
leg), joined by a deformable, Series 01 of amendments for UN Regulation
Flexible lower legform and tibia), and a knee joint
simulated knee joint. 127 and Euro NCAP are identical.
impactor shall consist of
flesh and skin, flexible
long bone segments
(representing femur and

477
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in Euro NCAP Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
tibia), and a knee joint

Annex
Series 01 of amendments for UN Regulation
432 mm from the centre of the Part V 4 Annex 4
Femur length 339 ± 2 mm 339 ± 2 mm 127 and Euro NCAP are identical.
knee 1.1 Figure Figure 1
Regulation (EC) No. 78/2009 is different.
1
Annex
Series 01 of amendments for UN Regulation
494 mm from the centre of the Part V 4 Annex 4
Tibia length 404 ± 2 mm 404 ± 2 mm 127 and Euro NCAP are identical.
knee 1.1 Figure Figure 1
Regulation (EC) No. 78/2009 is different.
1
Annex
Series 01 of amendments for UN Regulation
4 Annex 4
Knee length - - 185 ± 1 mm 185 ± 1 mm 127 and Euro NCAP are identical.
Figure Figure 1
Regulation (EC) No. 78/2009 is different.
1
Annex
4 1.1 Regulation (EC) No. 78/2009 and UN
926 ± 5 mm Regulation 127 (Series 00) are identical.
Overall Part V Annex 4
926 ± 5 mm Annex 928 ± 3 mm
length 1.1 Figure 1
928 ± 3 mm 4 Series 01 of amendments for UN Regulation
Figure 127 and Euro NCAP are identical.
1
70 ± 1 mm
Diameter of 70 ± 1 mm
Part V Covered in foam flesh Annex Regulation (EC) No. 78/2009 and UN
tibia and Covered in foam flesh 25mm - -
1.2 25mm thick and a skin 4 1.2 Regulation 127 (Series 00) are identical.
femur thick and a skin 6mm thick.
6mm thick.
Regulation (EC) No. 78/2009 and UN
Regulation 127 (Series 00) are identical.
Part V 8.6 ± 0.1 kg Annex
Femur mass 8.6 ± 0.1 kg 2.46 ± 0.12 kg Annex 4 1.4
1.3 2.46 ± 0.12 kg 4 1.4
Series 01 of amendments for UN Regulation
127 and Euro NCAP are identical.
Regulation (EC) No. 78/2009 and UN
Part V 4.8 ± 0.1 kg Annex Regulation (Series 00) are identical.
Tibia mass 4.8 ± 0.1 kg 2.64 ± 0.13 kg Annex 4 1.4
1.3 2.64 ± 0.13 kg 4 1.4
Series 01 of amendments for UN Regulation

478
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in Euro NCAP Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
127 and Euro NCAP are identical.

Knee joint Annex Series 01 of amendments for UN Regulation

- - 4.28 ± 0.21 kg 4.28 ± 0.21 kg Annex 4 1.4
mass 4 1.4 127 and Euro NCAP are identical.

13.4 ± 0.2 kg
Regulation (EC) No. 78/2009 and UN
13.2 ± 0.4 kg
13.2 ± 0.4 kg Annex Regulation 127 (Series 00) are identical.
Part V Assembled mass of femur, knee joint Annex 4 1.1,
Total mass 13.4 ± 0.2 kg Assembled mass of 4 1.1,
1.3 and tibia without the flesh and skin – 1.4
femur, knee joint and tibia 1.4 Series 01 of amendments for UN Regulation
9.38 ± 0.3 kg
without the flesh and skin 127 and Euro NCAP are identical.
– 9.38 ± 0.3 kg
Annex
217 ± 10 mm from the
4 1.4 Regulation (EC) No. 78/2009 and UN
centre of the knee
Regulation 127 (Series 00) are identical.
Femur centre 217 ± 10 mm from the centre Part V 159 ± 8 mm from the opposite end to Annex 4
Annex
of gravity of the knee 1.1 159 ± 8 mm from the the knee joint Figure 1
4 Series 01 of amendments for UN Regulation
opposite end to the knee
Figure 127 and Euro NCAP are identical.
joint
1
Annex
233 ± 10 mm from the 4 1.4 Regulation (EC) No. 78/2009 and UN
centre of the knee Regulation 127 (Series 00) are identical.
Tibia centre 233 ± 10 mm from the centre Part V Annex 4
Annex 202 ± 10 mm from either end
of gravity of the knee 1.1 Figure 1
202 ± 10 mm from either 4 Series 01 of amendments for UN Regulation
end Figure 127 and Euro NCAP are identical.
1
0.127 ±0.010 kgm² (about
a horizontal axis through
0.127 ±0.010 kgm² (about a Regulation (EC) No. 78/2009 and UN
the respective centre of
Femur horizontal axis through the 0.0325 ± 0.0016 kgm² (about the X- Regulation 127 (Series 00) are identical.
Part V gravity and perpendicular Annex
moment of respective centre of gravity axis through the respective centre of Annex 4 1.4
1.4 to the direction of impact) 4 1.4
inertia and perpendicular to the gravity) Series 01 of amendments for UN Regulation
direction of impact) 127 and Euro NCAP are identical.
0.0325 ± 0.0016 kgm²
(about the X-axis through

479
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in Euro NCAP Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
the respective centre of
gravity)

0.120 ±0.010 kgm² (about

a horizontal axis through
the respective centre of
0.120 ±0.010 kgm² (about a Regulation (EC) No. 78/2009 and UN
gravity and perpendicular
Tibia horizontal axis through the 0.0467 ± 0.0023 kgm² (about the X- Regulation 127 (Series 00) are identical.
Part V to the direction of impact) Annex
moment of respective centre of gravity axis through the respective centre of Annex 4 1.4
1.4 4 1.4
inertia and perpendicular to the gravity) Series 01 of amendments for UN Regulation
0.0467 ± 0.0023 kgm²
direction of impact) 127 and Euro NCAP are identical.
(about the X-axis through
the respective centre of
gravity)
0.0180 kgm²
Knee joint ± 0.0009 kgm² (about the 0.0180 kgm² ± 0.0009 kgm² (about
Annex Series 01 of amendments for UN Regulation
moment of - - X-axis through the the X-axis through the respective Annex 4 1.4
4 1.4 127 and Euro NCAP are identical.
inertia respective centre of centre of gravity)
gravity)
Fitted with deformable
knee elements with the Annex
Knee joint - - - - N/A
same batch as those used 4 1.3
in the certification tests.
Lower
legform
impactor
instrumentati
on
Uniaxial accelerometer
Uniaxial accelerometer
mounted on the non-
mounted on the non-impacted
impacted side of the tibia
side of the tibia 66 ± 5 mm Part V Annex Regulation (EC) No. 78/2009 and UN
66 ± 5 mm below the - -
below the knee joint centre, 1.5 4 2.1 Regulation 127 (Series 00) identical.
knee joint centre, with its
with its sensitive axis in the
sensitive axis in the
direction of impact
direction of impact.

480
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in Euro NCAP Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
Part V Annex
Damper and transducers Regulation (EC) No. 78/2009 and UN
Damper and transducers fitted. 1.5, 4 2.2, - -
fitted. Regulation 127 (Series 00) identical.
1.6 2.3
4 transducers in tibia to
4 transducers in tibia to measure
measure bending
bending moments:
moments: Annex  134 ± 1 mm
 134 ± 1 mm 4 2.1, Annex 4 2.1, Series 01 of amendments for UN Regulation
- -  214 ± 1 mm
 214 ± 1 mm Figure Figure 3 127 and Euro NCAP are identical.
 294 ± 1 mm
 294 ± 1 mm 3
 374 ± 1 mm
 374 ± 1 mm
From knee joint centre
From knee joint centre
3 transducers in the femur
3 transducers in the femur to measure
to measure bending
moments: Annex bending moments:
4 2.1,  137 ± 1 mm Annex 4 2.1, Series 01 of amendments for UN Regulation
- -  137 ± 1 mm
Figure  217 ± 1 mm Figure 3 127 and Euro NCAP are identical.
 217 ± 1 mm
3  297 ± 1 mm
 297 ± 1 mm
From knee joint centre
From knee joint centre
Three transducers in the
knee joint to measure
elongations of the Medial
Three transducers in the knee joint to
Collateral Ligament
measure elongations of the Medial
(MCL), Anterior Cruciate
Collateral Ligament (MCL), Anterior
Ligament (ACL), and
Annex Cruciate Ligament (ACL), and
Posterior Cruciate
4 2.1, Posterior Cruciate Ligament (PCL). Annex 4 2.1, Series 01 of amendments for UN Regulation
- - Ligament (PCL). The
Figure The measurement locations of each Figure 3 127 and Euro NCAP are identical.
measurement locations of
3 transducer are shown in Figure 3. The
each transducer are shown
measurement locations shall be within
in Figure 3. The
±4 mm along the X-axis from the
measurement locations
knee joint centre.
shall be within ±4 mm
along the X-axis from the
knee joint centre.

481
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in Euro NCAP Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
Annex
Channel 180 4 2.4
Part V
frequency 180 180 Hz 9.1.2 Identical
1.7
class 180 Annex
4 2.3
50º for knee bending
angle
Regulation (EC) No. 78/2009 and UN
10 mm for shearing
Annex Regulation 127 (Series 00) are identical.
50º for knee bending angle displacement
CAC 4 2.4 400 Nm for tibia bending
10 mm for shearing Part V 500 g for acceleration
response 300 mm for knee elongation 9.1.2 Series 01 of amendments for UN Regulation
displacement 1.7
values Annex (optional) 500 g for tibia acceleration 127 and Euro NCAP are identical.
500 g for acceleration 30 mm for knee ligament
4 2.3 Euro NCAP also includes and optional CAC
elongations
response value for tibia acceleration
400 Nm fot the tibia and
femur bending moments

Lower Certification procedures are detailed

legform in
6.2.1
impactor UNECE/TRANS/WP.29/GRSP/2013/
certification 26 Annex 6, Chapter 1.4.

Re- certified before each vehicle

Maximum of 20 impacts Maximum of 20 impacts 9.2.2
assessment
before re-certification before re-certification
Re-certified after a maximum of 10
Re-certification if more than Re-certification if more 9.2.3
impacts Euro NCAP requires the impactor to be tested
one year has elapsed since Part V than 12 months has Annex
prior to testing, otherwise the requirements are
previous certification 1.9 elapsed since previous 6 1.1
Re-certified at least once every 12 identical.
certification 9.2.4
months
Re-certified if any impact
exceeds the CAC values Re-certified if any impact
Re-certified if it exceeds any of its
exceeds the CAC values 9.2.5
CACs

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 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in Euro NCAP Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
Upper
legform test
results
Higher performance limit
Upper legform bending Bending moment:
Upper legform bending
moment of test impactor: - 285 Nm
moment of test impactor:
Not exceeding 510 Nm Sum of forces: The bending moment and sum of forces
Not exceeding 510 Nm
Annex - 5.0 kN measurement requirements are higher in
Upper legform instantaneous I Regulation (EC) No. 78/2009 and UN
Upper legform 5.1.2 AP-PP 3.1.2
sum of 2.1(b), Lower performance limit Regulation 127 than both the higher
instantaneous sum of the
the impact forces with respect 3.1(b) Bending moment: performance limit and lower performance limit
impact forces with respect
to time: - 350 Nm in Euro NCAP.
to time:
- Not exceeding 7.5 kN Sum of forces:
- Not exceeding 7.5 kN
- 6.0 kN

Upper
legform test
procedures
Annex
1
40 km/h 2.1(b),
3.1(b)
Impact Annex
11.1 ± 0.2 m/s 11.1 ± 0.2 m/s 10.3.8 Identical
velocity 5 1.12
Part II
11.1 ± 0.2 m/s Chapt
er III
4.5
Minimum of three tests, one In the bumper test area. Annex
each to the middle and outer 5 1.4 The regulations set out the minimum number
Part II Euro NCAP will test “worst case”
thirds at positions most likely Minimum of three tests, of tests that must be carried out and the
Impact Chapt grid points and manufacturers may
to cause injury. one each to the middle APPP location of these tests. Whereas, Euro NCAP
measuring er II nominate additional tests to be
Tests shall be performed to and outer thirds. 2 only tests the grid points likely to cause most
points 3.3 performed and the results will be
different types of structure Measuring points a injury and any additional points at the request
included in the assessment.
where they vary throughout minimum of 132 mm Annex of the manufacturer.
the area to be assessed. apart horizontally and a 5 2.5

483
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in Euro NCAP Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
Measuring points a minimum minimum of 66 mm
of 132 mm apart horizontally inside defined corners of
and a minimum of 66 mm bumper
inside defined corners of
bumper
Parallel to the longitudinal Horizontal plane and
Direction of Part II
axis of the vehicle, with the parallel to the longitudinal
impact Chapt Annex
axis of the upper legform vertical plane of the Parallel to the vehicle centre line ± 2º 10.3.7 Identical
velocity er III 5 2.6
vertical. vehicle.
vector 4.4
Tolerance of ± 2º. Tolerance of ± 2º.
At first contact the
At first contact the impactor impactor centre must be
centre must be vertically Part II vertically midway Midway between the bumper
Position of midway between the upper Chapt between the upper Annex reference line and the impactor centre
10.3.7 Identical
impactor bumper reference line and the er III bumper reference line and 5 2.6 line
lower bumper reference line. 4.4 the lower bumper Tolerance ± 10 mm
Tolerance of ± 10mm reference line.
Tolerance of ± 10mm
The impactor vertical
centre line must be
Laterally with the selected impact
positioned laterally within Annex
- - location 10.3.7 Identical
the selected impact 5 2.6
Tolerance ± 10 mm
location
Tolerance of ± 10 mm

Conform to that specified in

Upper Regulation (EC) 78/2009 of the
10.1.1
legform European Parliament and of the
impactor Council (14th January 2009) and
annexed in R (EC) 631/2009 (22nd
July 2009)
Upper legform must be rigid Upper legform must be
Part V Annex Upper legform must be rigid and Part V
and foam covered at the rigid and foam covered at Identical
2.1 4 3.1 foam covered at the impact side 2.1
impact side the impact side

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 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in Euro NCAP Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
Overall Part V Annex Part V
350 ± 5 mm 350 ± 5 mm 350 ± 5 mm Identical
length 2.1 4 3.1 2.1

9.5 ± 0.1 kg
Mass may be adjusted from this value
10.3.4
by up to ± 1 kg provided the required
Part V Annex
Total mass 9.5 ± 0.1 kg 9.5 ± 0.1 kg impact velocity is also changed using Identical
2.4 4 3.2 Part V
the formula.
2.4
9.5 ± 0.1 kg
Total mass
of front
member and
other
10.3.5
components 1.95 ± 0.05 kg
Part V Annex
in front of 1.95 ± 0.05 kg 1.95 ± 0.05 kg Identical
2.4 4 3.3 Part V
active 1.95 ± 0.05 kg
2.4
element
(excluding
foam and
skin)
Front
Part V Annex Part V
member 50 ± 1 mm 50 ± 1 mm 50 ± 1 mm Identical
2.1 4 3.7 2.1
diameter
Impactor shall be mounted to Impactor shall be
the propulsion system by a mounted to the propulsion Impactor shall be mounted to the
torque limiting joint and be system by a torque propulsion system by a torque
insensitive to off-axis loading. limiting joint and be limiting joint and be insensitive to
Part II
It shall move only in the insensitive to off-axis off-axis loading. It shall move only in Part II
Torque Chapt Annex
specified direction of impact loading. It shall move the specified direction of impact Chapter III Identical
limiting joint er III 4 3.4
when in contact with the only in the specified when in contact with the vehicle and 2.1
2.1
vehicle and shall be prevented direction of impact when shall be prevented from motion in
from motion in other in contact with the vehicle other directions including rotation
directions including rotation and shall be prevented about any axis.
about any axis. from motion in other

485
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in Euro NCAP Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
directions including
rotation about any axis.

Longitudinal axis of front Longitudinal axis of front Longitudinal axis of front member is
Torque
member is perpendicular to the Part V member is vertical at the Annex perpendicular to the axis of the Part V
limiting joint Identical
axis of the guidance system 2.2 time of impact. 4 3.5 guidance system 2.2
setup
Tolerance ± 2º. Tolerance ± 2º. Tolerance ± 2º.

Joint friction Part V Annex Part V

675 ± 25 Nm. 675 ± 25 Nm. 675 ± 25 Nm. Identical
torque 2.2 4 3.5 2.1

Parts of impactor forward

Parts of impactor forward of
of torque limiting joint Parts of impactor forward of torque
torque limiting joint shall lie
Centre of Part V shall lie on the Annex limiting joint shall lie on the Part V
on the longitudinal centre line Identical
gravity 2.3 longitudinal centre line of 4 3.6 longitudinal centre line of impactor 2.3
of impactor
impactor Tolerance ± 10 mm
Tolerance ± 10 mm
Tolerance ± 10 mm
Length
between load Part V Annex Part V
310 ± 1 mm 310 ± 1 mm 310 ± 1 mm Identical
transducer 2.1 4 3.7 2.1
centre lines
Upper
legform
impactor
instrumentati
on
Three strain gauges located on
Three strain gauges located on the
the impactor to measure the
impactor to measure the bending
bending moments of the front Front member must be
moments of the front member.
Strain member. Part V strain gauged to measure Annex Part V
Two outer strain gauges 50 ± 1 mm Identical
gauges Two outer strain gauges 50 ± 1 2.6 bending moments in three 4 4.1 2.6
from the symmetrical axis
mm from the symmetrical axis positions.
Middle strain gauge on the
Middle strain gauge on the
symmetrical axis ± 1 mm
symmetrical axis ± 1 mm

486
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in Euro NCAP Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
Back of the front member
Two outer strain gauges
Strain 50 ± 1 mm from the
Annex
gauges symmetrical axis Identical
4 4.1
positions Middle strain gauge on
the symmetrical axis ± 1
mm
Two fitted to measure forces Two fitted to measure
Load Part V Annex Two fitted to measure forces applied Part V
applied at either end of the forces applied at either Identical
transducers 2.5 4 4.2 at either end of the impactor 2.5
impactor end of the impactor
Channel
Part V Annex
frequency 180 180 180 Hz 10.1.2 Identical
2.7 4 4.3
class
10 kN for force
CAC
10 kN for force transducers Part V transducers Annex 10 kN for force
response 10.1.2 Identical
1000 Nm for bending moment 2.7 1000 Nm for bending 4 4.3 1000 Nm for bending moment
values
moment
Upper
legform Detailed in Regulation (EC) 631/2009
10.2.1
impactor (22nd July 2009).
certification
Maximum of 20 impacts Certified before the test programme 10.2.2
Maximum of 20 impacts
before re-certification
before re-certification
Re-certified after a maximum of 20
Re-certification if more impacts 10.2.4
Re-certification if more than Euro NCAP requires the impactor to be tested
Part V than 12 months has Annex
one year has elapsed since prior to testing, otherwise the requirements are
2.10 elapsed since previous 6 2.1 Re-certified at least once every 12
previous certification identical.
certification months 10.2.5
Re-certified if any impact
Re-certified if any impact Re-certified if it exceeds any of its
exceeds the CAC values
exceeds the CAC values CACs 10.2.6
Upper
legform to
bonnet
leading

487
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in Euro NCAP Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
edge/ Upper
legform to
WAD775
mm
The test was used for monitoring purposes
Annex only for Regulation (EC) No. 78/2009. The test
Test results Monitoring purposes only I 2.2 - - - - was removed from use in 2014.
The test in Euro NCAP is used for the overall
pedestrian score assessment.
Bending moment on the test Annex Higher performance limit
impactor shall be recorded and I 2.2 Bending moment:
compared with the possible: - 285 Nm
The sum of forces in Regulation (EC) No.
- Compared with possible Annex Sum of forces:
78/2009 and the higher performance limit in
target of 300 Nm I 3.2 - 5.0 kN
Euro NCAP are identical.
- Compared with possible
- - AP-PP 3.1.2 The bending moment In Regulation (EC) No.
maximum of 300 Nm Lower performance limit
78/2009 is between the Euro NCAP higher
Bending moment:
performance limit and lower performance
Instantaneous sum of the - 350 Nm
limit.
impact forces with respect Annex Sum of forces:
to time: I 2.2, - 6.0 kN
- Not exceeding 5.0 kN 3.2

Test
procedures

 Start at the intersection of the

centreline and WAD775mm
 Mark grid points every 100 mm in
both lateral directions along the
WAD775 up to the corner reference
- - - - points. 3.11 N/A
The 100 mm distances are measured
horizontally in a lateral vertical plane
and projected onto the WAD775mm.
 Grid points less than 50mm from the
corner reference point shall be

488
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in Euro NCAP Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
deleted.

Longitudinal axis of the upper

legform impactor are in the fore and
Longitudinal axis of the aft vertical plane of the section of
Part II
impactor must be parallel to vehicle to be tested
Chapt 11.4.6
the longitudinal vertical plane - - Tolerance ± 2º Identical
er IV 11.4.7
of the vehicle to be tested Where α<0º, then α=0º. The impact
4.4
Tolerence ±2º will be in the same Y-Z plane as each
grid point.
Tolerance ± 2º
At first contact the centre line
Impactor centreline must be
shall be consistent with the Part II
coincident with the WAD775mm and
bonnet leading edge reference Chapt
- - laterally with the selected impact 11.4.7 Identical
line and laterally with the er IV
location
selected impact location 4.4
Tolerance ± 10 mm
Tolerence ±10 mm
Impact angle α in relation to the
ground at each grid point is
perpendicular to a straight line
Part II
passing through the internal bumper Impactor dependant on the shape of the vehicle
Direction of Dependant on the values of Chapt
- - reference line and WAD 930.mm at 11.3.1 for both Regulation (EC) 78/2009 and Euro
impact bonnet leading edge height er IV
the same lateral position from the NCAP.
4.7
vehicle centreline. Measure and
record the angle at each point to be
tested.
The nominal impactor energy to be
used in the test should be calculated
using the formula:
Nominal 𝐸𝑛 = 0.5 × 𝑚𝑛 × 𝑣𝑐2
impactor - - - - Where: 11.3.2 N/A
energy 𝑚𝑛 = 7.4𝑘𝑔
𝑣𝑐 = 𝑣𝑜 cos(1.2𝛼)
𝑚
𝑣𝑜 = 11.11
𝑠

489
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in Euro NCAP Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref

Annex
40 km/h I 2.2, The velocity shall be adjusted to meet
The impact velocity in Regulation (EC) No.
3.2 the nominal energy by using the
78/2009 is determined by the shape of the
Impact Determined by the vehicle following formula:
- - 11.3.3 vehicle. The impact velocity in Euro NCAP is
velocity shape. Minimum 5.56 m/s, Part II 2𝐸𝑛 determined based on the impact angle and the
maximum 11.1 m/s. Chapt 𝑣𝑡 = √
Tolerance ±2% er IV 10.5𝑘𝑔 impactor energy.
4.5

Conform to that specified in

Same as impactor for upper Part V Regulation (EC) 78/2009 of the Same as impactor as upper legform to bumper
Impactor - -
legform to bumper 2 European Parliament and of the test.
Council (14th January 2009)

Calculated using
𝑀 = 2𝐸/𝑉 2
Where:
M = Mass [kg] Part II Euro NCAP uses a set mass of the impactor.
E = Impact Energy [J] Chapt 10.5 kg Whereas, the mass of the impactor is
Total mass - - 11.4.5
V = Velocity [m/s] er IV Accuracy of better than ± 1% calculated depending on the impact energy and
The mass may be adjusted by 4.8 velocity in Regulation (EC) No. 78/2009.
up to ± 10% provided the
velocity is changed to keep the
same kinetic energy.
Channel
Part V
frequency 180 - - 180 Hz 11.1.2 Identical
2.7
class
CAC
10 kN for force transducers Part V 10 kN for force
response - - 11.1.2 Identical
1000 Nm for bending moment 2.7 1000 Nm for bending moment
values

490
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in Euro NCAP Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
Certified before the test programme 11.2.2
Maximum of 20 impacts
before re-certification
Re-certified after a maximum of 20
Upper impacts 11.2.4
Re-certification if more than Euro NCAP requires the impactor to be tested
legform Part V
one year has elapsed since - - prior to testing, otherwise the requirements are
impactor 2.10 Re-certified at least once every 12
previous certification identical.
certification months 11.2.5
Re-certified if any impact
Re-certified if it exceeds any of its
exceeds the CAC values
CACs 11.2.6
Child and
Manufacturer is required to provide
adult
HIC15 or colour data detailing the
headforms (to bonnet top) 4.1.1
protection offered at all headform
to front
grid locations.
structure
HIC shall not exceed
Annex 1,000 over a minimum of For the headform area, data shall be
I 2.3 one half of the child provided for each grid point
HPC shall not exceed 1000
headform test area according to the following
over 2/3 of the bonnet test area
and 1,000 over two thirds performance criteria:
and 2000 for the remaining 1/3
of the combined child and HIC15 < 650 = Green The regulations have limits which cannot be
of the test area 5.2.1
adult headform test areas. 650 ≤ HIC15 < 1000 = Yellow exceeded, it is a pass/fail criteria. The worst
The HIC for the 1000 ≤ HIC15 < 1350 = Orange performing test criteria (red) for Euro NCAP is
remaining areas shall not 1350 ≤ HIC15 < 1700 = Brown the highest of these limits. Euro NCAP has a
Headform Shall not exceed 1000 over 1/2
Annex exceed 1,700 for both 1700 ≤ HIC15 = Red range of lower values which correspond to
impact test of the child headform test area 4.1.3
I 3.5 headforms. different colours and a points rating below the
result and in addition shall not
limits in the regulations.
exceed 1000 over 2/3 of the
In case there is only a
combined child and adult
child headform test area,
headform test areas. The HPC 5.2.3
the HIC recorded shall not
for the remaining areas shall
exceed 1,000 over two Euro NCAP also includes certain points that
not exceed 1700 for both
thirds of the test area. For are able to be defaulted red on green depending
headforms.
the remaining area the on the location
HIC shall not exceed
1,700.

491
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in Euro NCAP Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
Some grid points shall have a default
red or green rating awarded to them.
These shall be clearly identified as
defaulted in the predicted data.
The only areas to be defaulted are as
follows:
• A-pillars = Default red (unless data is
provided to suggest otherwise, in
which case treated as any other point)
4.1.5, 4.1.6,
• Windscreen glazing = Default green
4.1.7, 4.1.8
except:
- within 165 mm of solid strip
around periphery of windscreen
mounting frame
- where structures are mounted
behind the windscreen
- within 100 mm of any underlying
structures in the windscreen base
area

Headform
test
procedures
Part II
Chapt
er V Impactor must be in free Annex
Impactor must be in free flight
2.1, flight at the time of 5 Impactor should be in free flight 12.3.6 Identical
at the time of impact.
Chapt impact. 3.1.1
er VII
2.1
The impactor must be released Part II The impactor must be
at a distance so that the test Chapt released at a distance so Annex
Regulation (EC) No. 78/2009 and UN
results are not influenced by er V that the test results are not 5 - -
Regulation 127 are identical.
contact with the propulsion 2.1, influenced by contact 3.1.2
system during rebound of the Chapt with the propulsion

492
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in Euro NCAP Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
impactor. er VII system during rebound of
2.1 the impactor.

Measurements or
recordings of the
Measurements or recordings of
following must be taken:
the following must be taken:
 Velocity of the impact
 Velocity of the impact must Part II must be measured
be measured during free Chapt during free flight Annex
flight before impact. er V before impact. 5 Regulation (EC) No. 78/2009 and UN
 Angle of velocity vector at 4.8, - -
 Angle of velocity 3.2.1, Regulation are identical.
impact Chapt
vector at impact 3.3.1
 Acceleration time histories er VII
 Acceleration time
 HIC calculated 4.8
histories
First point of contact
 HIC calculated
(measuring point)
 First point of contact
(measuring point)
 Wrap around distances on centre line
from 100 mm to 2100 mm are marked
at 100 mm intervals.
(for v-shaped front ended vehicles it
may be necessary to mark 2200 mm
and 2300 mm)
 Mark points laterally in both
Marking directions at 100 mm distances from
headform each WAD point on the centre line
- - - - 3.10 N/A
impact area  For A-pillars mark and additional
grid points point at the intersection of the lateral
vertical plane and the side reference
line for each WAD.
 Remove grid points that have a lateral
distance of less than 50mm to the side
reference lines (not including the
points on the A-pillar)
 Remaining grid points are used for

493
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in Euro NCAP Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
the assessment of the vehicle
 Child headform grid points will be
marked with the prefix ‘C’
 Adult headform grid points will be
marked with the prefix ‘A’
 Grid points on the centre line will be
marked 0, grid points to the right will
increase by 1 (+), grid pints to the left
will decrease by 1 (-)
Splitting of
headform
test zones
Part II
HIC1000 zone and HIC20000
Chapt
zone identified by
er V
manufacturer and shown on a
3.2.1 HIC1000 zone and
drawing showing it viewed
HIC1700 zone identified Regulation (EC) No. 78/2009 “Type B”
from above. Annex
by manufacturer and approval and UN Regulation 127 are identical.
5 3.1, - -
shown on a drawing Regulation (EC) No. 78/2009 “Type A”
HIC1000 zone and HIC1700 3.2
Part II showing it viewed from approval is higher but is being phased out.
zone identified by
Chapt above.
manufacturer and shown on a
er VII
drawing showing it viewed
3.3.2
from above.
Part II
Chapt
Areas of the zones may
Areas of the zones may consist er V Regulation (EC) No. 78/2009 and UN
consist of several parts, Annex
of several parts, the number of 3.2.3, - - Regulation 127 are identical.
the number of parts not 5 3.3
parts not being limited. Chapt
being limited.
er VII
3.3.3
Calculation of the surface of Part II Calculation of the surface
Regulation (EC) No. 78/2009 and UN
the bonnet top area and the Chapt of the bonnet top area and Annex
- - Regulation 127 are identical.
zones must be done on the er V the zones must be done on 5 3.4
basis of the drawing supplied. 3.2.4, the basis of the drawing

494
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in Euro NCAP Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
Chapt supplied.
er VII
3.3.3

Measuring
points

Part II Selected measuring points Annex

Chapt must be a minimum of 5 4.3,
er VII 165 mm apart. 5.3
3.2,
Selected measuring points 3.3 Minimum of 9 tests; 3
must be a minimum of 165 tests each to the middle Annex
mm apart. and outer thirds at 5 4.2.
positions judged most 5.2
Minimum of 18 tests carried likely to cause injury.
out with the headform The manufacturer must provide data
How the testing is carried out is very different
impactor. 6 tests each to the Less than 9 tests for each detailing the protection offered by the
between the regulations and Euro NCAP.
middle and outer thirds of the Part II impactor may be vehicle at all grid locations.
Regulation (EC) No. 78/2009 and UN
bonnet top at positions judged Chapt performed if a number of
Regulation 127 have a minimum number of
most likely to cause injury. At er V measuring points have Euro NCAP will test a sample of AAAP
tests that must be carried out and there is a
least 12 of the 18 must be 3.2 been selected in order of Annex randomly selected grid points. The 2.
pass/fail criteria.
within the HPC1000 zone and potential to cause injury 5 3.5 results at these points provide a
Euro NCAP is provided with data which the
6 within the HPC2000 zone and the test area correction factor. The headform score
test results provide a correlation factor to apply
remaining is too small to will be based on the predicted data
to the predictions.
Minimum of 9 tests carried out select another measuring with the correction applied.
with each headform impactor. point while maintaining
3 tests each to the middle and the minimum spacing
outer thirds of the bonnet top between points be
at positions judged most likely Part II performed.
to cause injury. Chapt
er VII
3.1.1

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 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in Euro NCAP Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
The positions tested by
the laboratories shall be
indicated in the test
report. However, the
technical services
conducting the tests shall
perform as many tests as
necessary to guarantee the
Annex
- - compliance of the vehicle - - N/A
5 3.5
with the head injury
criteria (HIC) limit values
of 1000 for the HIC1000
zone and 1700 for the
HIC1700 zone, especially
in the points near to the
borders between the two
types of zones.
Child
headform
specific test
procedures
Selected measuring points Part II Selected measuring Used to test the:
must be: Chapt points must be a Annex  Forward section of the bonnet top
 a minimum of 165 mm apart er V minimum of 165 mm 5 4.3  A-pillars 12.3.4 Regulation (EC) No. 78/2009 and UN
 a minimum of 82.5 mm 3.2 apart  Windscreen Regulation 127 are identical. There are
inside the defined side With test locations lying between differences in the test area between Euro
referenc lines boundaries described by the WAD NCAP and the regulations.
 a minimum of 82.5 mm  Front: WAD1000mm or 1000mm and 1500mm
forwards of the defined a line 82.5 mm rearward Euro NCAP includes the A-pillars and
bonnet rear reference line. of the bonnet leading Points forward of and directly on the windscreen if the points are in the area. The
 A minimum of 165 mm edge reference line, 2.14 bonnet rear reference line will be rear of the area is the rear of the bonnet and so
rearwards of the the bonnet whichever is most assessed using the child impactor. will not include the windscreen or A-pillars in
leading edge referance line , rearwards Where the bonnet rear reference line Regulation (EC) No. 78/2009 and UN
unless no point in the bonnet  Rear: WAD1700 or a is rearward of 1700 mm WAD, the 3.5.9 Regulation 127.
leading edge test area within line 82.5 mm forward of child impactor will be used up to and
165 mm laterally would, if the bonnet rear reference including 1700 mm.

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Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in Euro NCAP Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
chosen for an upper legform line, whichever is most
to bonnet leading edge test, forward
require a kinetic energy of  Sides: line 82.5 mm
more than 200 J. inside the side reference
line
Selected measuring points Part II
must be: Chapt
 a minimum of 165 mm apart er VII
 a minimum of 82.5 mm inside 3.2
the defined side referenc lines
 a minimum of 82.5 mm
forwards of the defined
bonnet rear reference lineor
forward of a WAD 1700 mm,
whichever is most forward
 a minimum of 82.5 mm
rearward of the bonnet leading
edge referance line or
rearward of the WAD 1000
mm, whichever is more
rearward
35 km/h Annex
I 2.3,
3.3

Part II Euro NCAP carried out the impacts at a higher

Impact Annex
9.7 ± 0.2 m/s Chapt 9.7 ± 0.2 m/s 11.1 ± 0.2 m/s 12.3.13 velocity to Regulation (EC) No. 78/2009 and
velocity 5 4.6
er V UN Regulation 127.
4.6,
Chapt
er VII
4.6
In the longitudinal vertical Part II In the longitudinal
Direction of plane of the vehicle at an angle Chapt vertical plane of the Annex Angle of impact shall be 50º ± 2º to
12.3.9 Identical
impact of 50 ± 2 º to Ground er V vehicle at an angle of 50 ± 5 4.7 the ground reference level
Reference Level 4.4.1, 2 º to the horizontal.

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Regulation (EC) No. 78/2009 and
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Optional changes brought in Euro NCAP Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
The direction must be Chapt The direction must be
downward and rearward. er VII downward and rearward.
4.4.1
Part II
Chapt The impactor must not
The impactor must not contact
er V contact the windscreen or
the windscreen or A-pillar Annex Regulation (EC) No. 78/2009 and UN
4.4, A-pillar before the bonnet - -
before the bonnet for tests at 5 4.1 Regulation 127 are identical.
Chapt for tests on the rear area
the rear area of the bonnet top.
er VII of the bonnet top.
4.4
Part II
No point measured that
No point measured that the Chapt
the impactor will have a
impactor will have a glancing er V
glancing blow resulting in Annex Regulation (EC) No. 78/2009 and UN
blow resulting in a more 3.2, - -
a more severe second 5 4.4 Regulation 127 are identical.
severe second impact outside Chapt
impact outside the test
the test area. er
area.
3.3.1
Part II
Chapt
Point of first contact must
Point of first contact must be er V Centreline of the headform impactor
be within a ± 10 mm Annex
within a ± 10 mm tolerance of 4.6, shall be within a ± 10 mm tolerance 12.3.12 Identical
tolerance of the intended 5 4.5
the intended point Chapt to the selected grid point.
point.
er VII
4.6
Adult
headform
specific test
procedures
Selected measuring points Part II Selected measuring 2.1 Used to test the: 12.3.4 Regulation (EC) No. 78/2009 and UN
must be: Chapt points must be a  Rearward section of the bonnet top Regulation 127 are identical. There are
Adult  a minimum of 165 mm apart er VII minimum of 165 mm  A-pillars differences in the test area between Euro
headform  a minimum of 82.5 mm inside 3.2 apart  Windscreen NCAP and the regulations.
test area the defined side referenc lines With test locations lying between
 a minimum of 82.5 mm  Front: WAD1700mm or boundaries described by the WAD Euro NCAP includes the A-pillars and
forwards of the defined a line 82.5 mm rearward 1700mm and 2100mm 3.5.9 windscreen if the points are in the area. The

498
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in Euro NCAP Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
bonnet rear reference lineor of the bonnet leading Annex rear of the area is the rear of the bonnet and so
forward of a WAD 2100 mm, edge reference line, 5 5.3 Points rearward of the bonnet rear will not include the windscreen or A-pillars in
whichever is most forward whichever is most reference line between 1500 mm and Regulation (EC) No. 78/2009 and UN
a minimum of 82.5 mm rearwards 1700 mm WAD will be tested using Regulation 127.
rearward of the bonnet  Rear: WAD2100 or a the adult impactor.
leading edge referance line or line 82.5 mm forward of
rearward of the WAD 1700 the bonnet rear reference
mm, whichever is more line, whichever is most
rearward forward
 Sides: line 82.5 mm
inside the side reference
line
35 km/h Annex
I 2.3,
3.3
Euro NCAP carried out the impacts at a higher
Impact Annex
9.7 ± 0.2 m/s 11.1 ± 0.2 m/s 12.3.13 velocity to Regulation (EC) No. 78/2009 and
velocity 9.7 ± 0.2 m/s Part II 5 5.6
UN Regulation 127.
Chapt
er VII
4.6
In the longitudinal vertical In the longitudinal
plane of the vehicle at an angle Part II vertical plane of the
Direction of of 65 ± 2 º to Ground Chapt vehicle at an angle of 65 ± Annex Angle of impact shall be 65º ± 2º to
12.3.10 Identical
impact Reference Level er VII 2 º to the horizontal. 5 5.7 the ground reference level
The direction must be 4.4.1 The direction must be
downward and rearward. downward and rearward.
The impactor must not
The impactor must not contact Part II
contact the windscreen or
the windscreen or A-pillar Chapt Annex Regulation (EC) No. 78/2009 and UN
A-pillar before the bonnet - -
before the bonnet for tests at er VII 5 5.1 Regulation 127 are identical.
for tests on the rear area
the rear area of the bonnet top. 4.4
of the bonnet top.
No point measured that
the impactor will have a
Annex
- - glancing blow resulting in - - N/A
5 5.4
a more severe second
impact outside the test

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 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
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Optional changes brought in Euro NCAP Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
area.

Point of first contact must

Point of first contact must be Part II Centreline of the headform impactor
be within a ± 10 mm Annex
within a ± 10 mm tolerance of Chapt shall be within a ± 10 mm tolerance 12.3.12 Identical
tolerance of the intended 5 5.5
the intended point er 4.6 to the selected grid point.
point.
Conform to that specified in
Headform Regulation (EC) 78/2009 of the
12.1.1
impactor European Parliament and annexed in
Regulation (EC) 631/2009
Annex
Part V
5 Part V
Material Aluminium 3.1, Aluminium Aluminium Identical
5.1.1, 3.1, 4.1
4.1
5.3.1
Annex
Part V
5 Part V
Shape Spherical 3.1, Spherical Sphere Identical
5.1.1, 3.1, 4.1
4.1
5.3.1
Annex
Part V
5 Part V
Diameter 165 ±1 mm 3.1, 165 ±1 mm 165 ±1 mm Identical
5.1.1, 3.1, 4.1
4.1
5.3.1
Annex
Child I 2.3,
Annex
3.5 kg 3.3
Child 5 Child
3.5 ± 0.07 kg Part V
Child 3.5 ± 0.07 kg 5.1.1 3.5 ± 0.07 kg
3.1
impactor Part V Identical
mass Adult Annex Adult 4.1.2
Adult Annex
4.5 ± 0.1 kg 5 4.5 ± 0.1 kg
4.5kg I 3.4
5.3.1
4.5 ± 0.1 kg Part V
4.1.2

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Regulation (EC) No. 78/2009 and
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Optional changes brought in Euro NCAP Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
Moment of
inertia about
Annex
an axis
Child Child 5 Child
through the
0.008 to 0.012 kgm2 Part V 0.008 to 0.012 kgm2 5.1.1 0.008 to 0.012 kgm2
centre of Part V
3.3, Identical
gravity and 3.3, 4.3
Adult 4.3 Adult Annex Adult
perpendicula
0.010 to 0.013 kgm2 0.010 to 0.013 kgm2 5 0.010 to 0.013 kgm2
r to the
5.3.1
direction of
impact
Geometric centre of Annex
Centre of Centre of sphere Part V sphere 5 Centre of sphere
Part V 3.3 Identical
Gravity Tolerance ± 2 mm 3.3 Child Tolerance ± 2 mm 5.1.1, Tolerance ± 2 mm
Adult Tolerance ± 5 mm 5.3.1
14 ± 0.5 mm thick synthetic 14 ± 0.5 mm thick Annex
Part V 14 ± 0.5 mm thick synthetic skin Part V
Skin skin covering at least half the synthetic skin covering at 5 Identical
3.2 covering at least half the sphere 3.2, 4.2
sphere least half the sphere 5.1.1
Annex
First natural Part V Part V
5000 Hz 5000 Hz 5 5000 Hz Identical
frequency 3.7 3.7, 4.7
5.1.2
 Flat face
 perpendicular to the
direction of travel
 perpendicular to the axis
Rear face of of one of the Annex
- - - - N/A
impactors accelerometers 4 5.5
 Capable of providing
access to accelerometers
 Attachment point for
propulsion system
Child and
adult
headform
impactor
instrumentati

501
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in Euro NCAP Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
on

Recess in sphere for one

Recess in sphere for one
triaxial or three uniaxial
triaxle or three uniaxial Recess in sphere for one triaxial or
accelerometers. Location;
accelerometers. Location; three uniaxial accelerometers.
 Within ± 10 mm seismic
 Within ± 10 mm seismic Location;
mass location from
mass location from centre of Annex  Within ± 10 mm seismic mass
Part V centre of sphere for the
sphere for the measurement 4 location from centre of sphere for the Part V
3.4, measurement axis Identical
axis 5.2.1, measurement axis 3.4, 4.4
4.4  Within ± 1 mm seismic
Within ± 1 mm seismic mass 5.4.1  Within ± 1 mm seismic mass
mass location tolerance
location tolerance from the location tolerance from the centre of
from the centre of the
centre of the sphere for the the sphere for the perpendicular
sphere for the
perpendicular direction to the direction to the measurement axis
perpendicular direction
measurement axis
to the measurement axis
If three uniaxle
If three uniaxle accelerometers
accelerometers used, one
used, one of the
of the accelerometers
accelerometers must; If three uniaxle accelerometers used,
must;
 have its sensitive axis one of the accelerometers must;
 have its sensitive axis
perpendicular to the mounting  have its sensitive axis perpendicular
perpendicular to the
face Annex to the mounting face
Part V mounting face
 Seismic mass positioned 4  Seismic mass positioned within a Part V
3.4.1,  Seismic mass positioned Identical
within a cylindrical tolerance 5.2.2, cylindrical tolerance field of 1mm 3.4.1, 4.4.1
4.4.1 within a cylindrical
field of 1mm radius and 20 5.4.2 radius and 20 mm length
tolerance field of 1mm
mm length  Centre of tolerance field must
radius and 20 mm length
Centre of tolerance field must coincide with the centre of the sphere
 Centre of tolerance field
coincide with the centre of the of the headform impactor
must coincide with the
sphere of the headform
centre of the sphere of
impactor
the headform impactor
The remaining accelerometers The remaining Annex The remaining accelerometers must;
Part V
must; accelerometers must; 4  Have their sensitive axis Part V 3.4.2,
3.4.2, Identical
 Have their sensitive axis  Have their sensitive axis 5.2.3, perpendicular to the mounting face 4.4.2
4.4.2
perpendicular to the mounting perpendicular to the 5.4.3  Seismic mass positioned within a

502
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in Euro NCAP Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
face mounting face spherical tolerance field of 10 mm
 Seismic mass positioned  Seismic mass positioned radius
within a spherical tolerance within a spherical  Centre of tolerance field must
field of 10 mm radius tolerance field of 10 mm coincide with the centre of the sphere
Centre of tolerance field must radius of the headform impactor
coincide with the centre of the  Centre of tolerance field
sphere of the headform must coincide with the
impactor centre of the sphere of
the headform impactor
Annex
Part V
4
CFC value 1000 3.5, 1000 1000 12.1.3 Identical
5.2.4,
4.5
5.4.4
Annex
CAC Part V
4
response 500g 3.5, 500g 500g 12.1.3 Identical
5.2.4,
value 4.5
5.4.4
Child and
adult Detailed in Regulation (EC) 631/2009
headform (22nd July 2009). 12.2.1
impactor
certification
Certified before the test programme 12.2.2
Maximum of 20 impacts
before re-certification Maximum of 20 impacts
Re-certified after a maximum of 20
before re-certification
impacts 12.2.3
Re-certification if more than Part V Euro NCAP requires the impactor to be tested
Annex
12 monts has elapsed since 3.6, Re-certification if more prior to testing, otherwise the requirements are
6 3,1 Re-certified at lead once every 12
previous certification 4.6 than 12 months has identical.
months 12.2.4
elapsed since previous
Re-certified if any impact certification
Re-certified if any of their CACs are
exceeds the CAC values
exceeded 12.2.5
Adult
Regulation (EC) No. 78/2009 “Type A”
headform to (Required for “Type A”
approval is being phased out.
windscreen approval)
This test was removed in 2014.
test

503
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in Euro NCAP Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref

Test Result

HPC shall be recorded and

compared with the possible
HPC target of 1000. The test shall Annex
- - - - N/A
recorded be completed for monitoring I 2.4
purposes only and the results
shall be fully recorded

Test
Procedure

 82.5 mm inside windscreen

Part II
limits as described in
Chapt
Directive 77/649/EEC - - - - N/A
er VI
 82.5 mm forwards of the rear
3.2
windscreen reference line
Part II
Impactor must be in free flight Chapt
- - - - N/A
at the time of impact. er VI
2.1,
The impactor must be released
at a distance so that the test Part II
results are not influenced by Chapt
- - - - N/A
contact with the propulsion er VI
system during rebound of the 2.1
impactor.
A minimum of 5 tests shall be Part II
Measuring carried out at positions judged Chapt
- - - - N/A
points to be the most likely to cause er VI
injury. 3.2
In the vertical longitudinal Part II
Direction of plane of the vehicle at an angle Chapt
- - - - N/A
impact of 35 ± 2 º to Ground er VI
Reference Level 4.4

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 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in Euro NCAP Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
The direction must be
downward and rearward.

Part II
Point of first contact must be
Chapt
within a ± 10 mm tolerance of - - - - N/A
er VI
the intended point
4.5
Part II
Impact Chapt
9.7 ± 0.2 m/s - - - - N/A
velocity er VI
4.6
Same as adult impactor used in
Impactor headform to bonnet top except - - - - N/A
velocity.
4.8 kg Annex
I 2.4
Mass - - - - N/A
4.8 ± 0.1 kg Part V
4.1.1
Headform
to bonnet
leading edge
test

Test Results This test is not present in any of the European

Regulations.
Headform to The test is carried out by Euro NCAP as an
HIC value - - - - Monitored against a HIC value of 650 Bonnet extra measure of pedestrian protection of a
leading Edge vehicle. The result of the test does not affect
Technical the pedestrian protection score or any other
Where a poor test result is achieved, Bulletin part of the overall assessment, but Euro NCAP
Euro NCAP may comment on this may comment on poor results alongside the
- - - - alongside the normal pedestrian normal pedestrian protection score.
protection score. The result is not
reflected in the actual pedestrian

505
 UN Regulation No. 127
Regulation (EC) No. 78/2009 and
Property Regulation (EC) No. 631/2009
Optional changes brought in Euro NCAP Comparison
by series 01 of amendments
Specification Ref Specification Ref Specification Ref
protection score or any other part of
the overall assessment.

Test
procedure

Carried out where the bonnet leading

- - - - edge reference line is located between
WAD 930 mm and WAD 1000 mm.
Intersection of the vertical
Impact - - - - longitudinal plane with the bonnet
leading edge reference line

Impact angle - - - - 20º ± 2º to the ground reference level

Impact
40 km/h
velocity

506
Annex 7 : COMPARISON TABLES FOR EU REGULATIONS AND US STANDARDS – TYRE PRESSURE MONITORING

Table 74: Comparison of performance criteria and limits for tyre pressure monitoring for the EU and US.

Property Criteria Unit EU USA Comparison

/ Item Reference Specification / Limit Reference Specification / Limit
Applicable vehicles
5.3.1 Applies to vehicle S2 Applies to passenger cars, FMVSS 138 applies to a wider range of
category M1 and N1 multipurpose passenger vehicles than ECE 64.02
when equipped with: vehicles, trucks and buses M1 <3500kg
(a.) A temporary use that have a gross vehicle N1 ≤3500kg
spare unit; and /or weight rating of 4536kg
(b.) Run flat tyres and/or (10,000lbs) or less except
run-flat system; and /or those vehicles with dual
(c.) A tyre pressure wheels on an axle,
monitoring system according to the phase-in
schedule specified in S7
of the Standard.
Speed range
5.3.1.3 The system shall operate FMVSS 138 has no speed range stated,
from a speed of 40 km/h however, the test procedure dictates test
or below, up to the speeds of 50 km/h to 100km/h.
vehicle's maximum design
speed.
Tyre pressure detection
For incident 5.3.2.1 The TPMS shall S4.2 The tire pressure ECE 64.02 requires a warning activation
related illuminate the warning monitoring system must: within a shorter timeframe 10min
pressure loss signal described in (a) Illuminate a low tire opposed to 20mins for FMVSS 138.
(puncture paragraph 5.3.5 not more pressure warning tell-tale
test) than 10 minutes after the not more than 20 minutes ECE 64.02 has a tighter activation
in service operating after the inflation pressure tolerance of 20% as opposed to 25% for

507
Property Criteria Unit EU USA Comparison
/ Item Reference Specification / Limit Reference Specification / Limit
pressure in one of the in one or more of the FMVSS 138.
vehicle's tyres has been vehicle's tires, up to a
reduced by 20 per cent or total of four tires, is equal ECE 64.02 has two test criteria for low
it is at a minimum to or less than either the tyre pressure warning, puncture and slow
pressure of 150 kPa, pressure 25 percent below deflation.
whatever is higher. the vehicle manufacturer's
recommended cold FMVSS 138 does not distinguish
Detection 5.3.3.1 The TPMS shall inflation pressure, or the between puncture and slow deflation and
for a tyre illuminate the warning pressure specified in the therefore, only has one activation
pressure signal described in 3rd column of Table 1 of timeframe, which is 20mins.
level paragraph 5.3.5. within this standard for the
significantly not more than 60 minutes corresponding type of tire,
below the of cumulative driving whichever is higher;
recommende time after the in-service (b) Continue to illuminate
d pressure operating pressure in any the low tire pressure
for optimum of the vehicle's tyres, up warning tell-tale as long
performance to a total of four tyres, has as the pressure in any of
including been reduced by 20 per the vehicle's tires is equal
fuel cent. to or less than the
consumption pressure specified in
and safety S4.2(a), and the ignition
(diffusion locking system is in the
test). “On” (“Run”) position,
whether or not the engine
is running, or until
manually reset in
accordance with the
vehicle manufacturer's
instructions.

508
Property Criteria Unit EU USA Comparison
/ Item Reference Specification / Limit Reference Specification / Limit

Low tyre pressure warning

5.3.5.1 The warning indication S4.3.1 Each tire pressure This section is equivalent for both
shall be by means of an monitoring system must Standards.
optical warning signal include a low tire pressure Symbols used by both Standards are
conforming to Regulation warning tell-tale that: comparable
No. 121. (a) Is mounted inside the
occupant compartment in
5.3.5.2 The warning signal shall front of and in clear view
be activated when the of the driver;
ignition (start) switch is in (b) Is identified by one of
the "on" (run) position the symbols shown for the
(bulb check). This “Low Tire Pressure” Tell-
requirement does not tale in Table 1 of
apply to tell-tales shown Standard No. 101 (49
in a common space. CFR 571.101); and
(c) Is illuminated under
5.3.5.3 The warning signal must the conditions specified in
be visible even by S4.2.
daylight; the satisfactory
condition of the signal S4.3.2 In the case of a tell-tale
must be easily verifiable that identifies which
by the driver from the tire(s) is (are) under-
driver's seat. inflated, each tire in the
symbol for that tell-tale
must illuminate when the
tire it represents is under-
inflated to the extent
specified in S4.2.

509
Property Criteria Unit EU USA Comparison
/ Item Reference Specification / Limit Reference Specification / Limit

S4.3.3 (a) Except as provided in

paragraph (b) of this
section, each low tire
pressure warning tell-tale
must illuminate as a check
of lamp function either
when the ignition locking
system is activated to the
“On” (“Run”) position
when the engine is not
running, or when the
ignition locking system is
in a position between
“On” (“Run”) and “Start”
that is designated by the
manufacturer as a check
position.
(b) The low tire pressure
warning tell-tale need not
illuminate when a starter
interlock is in operation.
TPMS malfunction
5.3.4.1 The TPMS shall S4.4 (a) The vehicle shall be Time limit for activation is greater in
illuminate the warning equipped with a tire FMVSS 138, 20mins as opposed to
signal described in pressure monitoring 10mins for ECE 64.02.
paragraph 5.3.5. not more system that includes a
than 10 minutes after the tell-tale that provides a Symbols used by both Standards are
occurrence of a warning to the driver not comparable. (see above)

510
Property Criteria Unit EU USA Comparison
/ Item Reference Specification / Limit Reference Specification / Limit
malfunction that affects more than 20 minutes
the generation or after the occurrence of a All other functions are comparable.
transmission of control or malfunction that affects
response signals in the the generation or
vehicle's tyre pressure transmission of control or
monitoring system. If the response signals in the
system is blocked by vehicle's tire pressure
external influence (e.g. monitoring system. The
radio-frequency noise), vehicle's TPMS
the malfunction detection malfunction indicator
time may be extended. shall meet the
requirements of either
5.3.5.4 The malfunction S4.4(b) or S4.4(c).
indication may be the
same warning signal as (b) Dedicated TPMS
the one used to indicate malfunction tell-tale. The
under-inflation. If the vehicle meets the
warning signal described requirements of S4.4(a)
in paragraph 5.3.5.1. is when equipped with a
used to indicate both dedicated TPMS
under-inflation and a malfunction tell-tale that:
malfunction of the TPMS, (1) Is mounted inside the
the following shall apply: occupant compartment in
with the ignition (start) front of and in clear view
switch in the "on" (run) of the driver;
position the warning (2) Is identified by the
signal shall flash to word “TPMS” as
indicate a malfunction. described under the “Tire
After a short period of Pressure Monitoring

511
Property Criteria Unit EU USA Comparison
/ Item Reference Specification / Limit Reference Specification / Limit
time the warning signal System Malfunction”
shall remain continuously Telltale in Table 1 of
illuminated as long as the Standard No. 101 (49
malfunction exists and the CFR 571.101);
ignition (start) switch is in (3) Continues to
the "on" (run) position. illuminate the TPMS
The flashing and malfunction tell-tale
illumination sequence under the conditions
shall be repeated each specified in S4.4(a) for as
time the ignition (start) long as the malfunction
switch is in the "on" (run) exists, whenever the
position until the ignition locking system is
malfunction has been in the “On” (“Run”)
corrected. position; and
(4) (i) Except as provided
in paragraph (ii), each
dedicated TPMS
malfunction tell-tale must
be activated as a check of
lamp function either when
the ignition locking
system is activated to the
“On” (“Run”) position
when the engine is not
running, or when the
ignition locking system is
in a position between
“On” (“Run”) and “Start”
that is designated by the

512
Property Criteria Unit EU USA Comparison
/ Item Reference Specification / Limit Reference Specification / Limit
manufacturer as a check
position.
(ii) The dedicated TPMS
malfunction tell-tale need
not be activated when a
starter interlock is in
operation.
(c) Combination low tire
pressure/TPMS
malfunction tell-tale. The
vehicle meets the
requirements of S4.4(a)
when equipped with a
combined Low Tire
Pressure/TPMS
malfunction tell-tale that:
(1) Meets the
requirements of S4.2 and
S4.3; and
(2) Flashes for a period of
at least 60 seconds but no
longer than 90 seconds
upon detection of any
condition specified in
S4.4(a) after the ignition
locking system is
activated to the “On”
(“Run”) position. After
each period of prescribed

513
Property Criteria Unit EU USA Comparison
/ Item Reference Specification / Limit Reference Specification / Limit
flashing, the tell-tale must
remain continuously
illuminated as long as a
malfunction exists and the
ignition locking system is
in the “On” (“Run”)
position. This flashing
and illumination sequence
must be repeated each
time the ignition locking
system is placed in the
“On” (“Run”) position
until the situation causing
the malfunction has been
corrected. Multiple
malfunctions occurring
during any ignition cycle
may, but are not required
to, reinitiate the
prescribed flashing
sequence.

514
Annex 8 : ACCIDENT DATA ANALYSIS

Annex 8.1 ROAD ACCIDENT IN-DEPTH STUDIES (RAIDS) - UK

Aims

Data collection commenced in 1983 and collected accident data in various phases up to 2010.
The RAIDS project (formerly CCIS) was an in-depth study where detailed examinations of
accident damaged cars were correlated with the injuries that the car occupants sustained.
The prime objective was to gain an improved understanding of how car occupants are injured
in road traffic accidents; the overall objectives of RAIDS can be summarised as:
 Provide detailed information on the crashworthiness of vehicles.
 Analyse the benefits of countermeasures (such as airbags) in reducing injury.
 Provide the ability to monitor the effectiveness of new safety systems and
countermeasures.
 Identify the needs for improved vehicle safety as changes take place.
 Provide detailed bio-mechanical information.
 Help in the development of improved impact test dummies.
 Support legislation for improved car occupant protection.
Data collection

This was accomplished by collecting in-depth accident data on real accidents occurring in the
UK. Collection teams were based at Birmingham University (Birmingham Automotive
Safety Centre - BASC), Loughborough University (Transport Safety Research Centre -
TSRC), the Vehicle & Operator Services Agency (VOSA; now the Driver and Vehicle
Standards Agency, DVSA) and the Transport Research Laboratory (TRL). The project was
collaboratively funded, with costs being shared by the Department for Transport (DfT) and,
at one time or another, a number of major car and ancillary equipment manufacturers.
Sampling criteria

The sampling criteria for RAIDS comprised of a combination of vehicle age and maximum
occupant injury severity within the vehicle. For an accident to be eligible for inclusion in the
study it had to contain a vehicle which fulfilled ALL of the following criteria:
 The vehicle crashed within the investigation team’s area;
 The vehicle was a car or car derivative (car-based van etc);
 The vehicle was up to seven years old (five years if injury severity was only Slight);
 The vehicle had at least one occupant who was injured (as classified by the Police);
 The vehicle was towed away from the scene of the accident.
All fatal and serious accidents that met the criteria were investigated. Slight accidents were
sampled from those that met the criteria. This meant that RAIDS deliberately targeted the
more severe accidents that occurred within the sampling area.
Data collected and procedures
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Each RAIDS case involved an in-depth examination of the structural damage and residual
crush sustained by the damaged vehicles. Vehicle damage was quantified using the standard
Collision Deformation Classification (CDC) system. Occupant injury data was obtained from
questionnaires sent to survivors, and from hospital records and coroners’ reports.
Database overview

RAIDS data is stored in a comprehensive relational database, containing information on:

• The nature and severity of the damage to the vehicles
• The role of safety systems such as restraints
• Car occupant characteristics (such as age, gender, height and weight)
• Details of the injuries suffered by the vehicle occupants
• Injury causation mechanisms
• Images relating to the vehicles

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Data weighting from RAIDS to STATS19 (UK national level)

Background

RAIDS does not include a weighting variable to allow the raw data to be related to the
national level. However, it was necessary to weight the RAIDS data so that it represented
the United Kingdom.
Methodology

The full RAIDS dataset contains all passenger car occupants casualties recorded in
RAIDS between 2004 and 2010. Cases with unknown injury severity were removed.
Weights were calculated using the full RAIDS dataset (with unknown injury severity
removed).
STATS19 data were extracted (to match with the RAIDS dataset as closely as possible)
using the following criteria:
 Driver and passenger car occupant casualties (all positions) by severity and
impact type (rollover, front, rear, offside, nearside, other unknown/no impact) for
accidents where:
o Accident year is 2004-2010 (inclusive)
o At least one vehicle is <7yrs old and has at least one injured occupant in it
In both RAIDS and STATS19, the definitions for collision type are relative to the vehicle
and not its occupants. Therefore, the collision type used the ‘skidding/overturning’ field
in STATS19 to first classify into rollover/no rollover and then the ‘first point of impact’
field was used to classify the non-rollovers into front, rear, nearside, offside
other/unknown/no impact.
STATS19 does not record uninjured individuals in the accident; however, using the
assumption that every car must have a driver, the number of uninjured car drivers can be
estimated. This number and the proportion of injured casualties that were drivers was
then used to estimate the number of uninjured front and rear seat passengers, using the
assumption that the proportion of injured casualties that were passengers is equivalent to
the proportion of uninjured drivers. This proportion changes across impact type.
For example, there were 1,083 uninjured drivers identified in rollover accidents in
STATS19. 66% of the injured casualties in rollover accidents were drivers; hence it is
estimated that in total there was 1,635 uninjured casualties (drivers and passengers) in
rollover accidents.
STATS19 figures:
Casualty Severity Rollover Frontal Nearside Offside Other17 Total

Fatal 361 808 299 194 95 1,757

Serious 1,913 8,855 1,746 1,116 1,277 14,907

Slight 11,356 85,126 23,754 17,977 62,797 201,010

Uninjured (estimated) 1,635 99,154 17,422 19,784 47,844 185,838

Total 15,265 193,943 43,221 39,071 112,013 403,512

CasSev Rollover Frontal Nearside Offside Other Total

Fatal 0.1% 0.2% 0.1% 0.0% 0.0%

Serious 0.5% 2.2% 0.4% 0.3% 0.3%

Slight 2.8% 21.1% 5.9% 4.5% 15.6%

Uninjured (estimated) 0.4% 24.6% 4.3% 4.9% 11.9%

Total 100.0%

RAIDS figures:
OCSEVCIS Rollover Frontal Nearside Offside Other Total

Fatal 30 41 24 27 23 145

Serious 153 336 50 79 84 702

Slight 244 632 125 208 267 1476

Uninjured 44 184 45 63 48 384

Total 471 1193 244 377 422 2707

OCSEVCIS Rollover Frontal Nearside Offside Other Total

Fatal 1.1% 1.5% 0.9% 1.0% 0.8%

Serious 5.7% 12.4% 1.8% 2.9% 3.1%

Slight 9.0% 23.3% 4.6% 7.7% 9.9%

17
Other includes all impacts classified as rear and other/unknown/no impact from STATS19.

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 Uninjured 1.6% 6.8% 1.7% 2.3% 1.8%

Total 100.0%

Weightings (STATS19/RAIDS):
OCSEVCIS Rollover Frontal Nearside Offside Other

Fatal 0.08 0.13 0.08 0.05 0.03

Serious 0.08 0.18 0.23 0.09 0.10

Slight 0.31 0.90 1.27 0.58 1.58

Uninjured 0.25 3.62 2.60 2.11 6.69

Accident case weighting

The weights calculated above were applied to each occupant in the RAIDS sample based
on their severity and the collision type they were involved in. Note that due to the biased
selection criteria used for the model datasets (as described in Section 1.3), the national
weights calculated above may not be optimum for the subset of data used for the
modelling. However, to avoid a number of different weights being applied to different
subsets of the data used for the different tasks in this project, a decision was made by the
project team to apply the national weights to the model dataset. This is noted as
limitation of the methodology.

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 Annex 8.2 GERMAN IN-DEPTH ACCIDENT STUDY (GIDAS) – GERMANY

Introduction

The basis of this study is the latest database of GIDAS (German In-Depth Accident
Study, Effective December 2014) which contains about 29,500 traffic accidents. Of those
26,220 are fully reconstructed and coded in the database and can therefore be used an
analysis.

The scope of this study is the data analysis for supporting TRL’s TTIP study. The focus
is an overview of available data and the analysis of them regarding occupant injury
severity, MAIS and belt usage depending on the seating positions, gender and age of the
occupant.

To be able to draw representative conclusions from the GIDAS database the data is
weighted towards the German accident scenario. Therefore different weighting factors
(accident site, severity and type) on accident level are used.

Dataset

German In-Depth Accident Study (GIDAS)

GIDAS is a collaborative project of the Federal Highway Research Institute (BASt) of

Germany and The Research Association of Automotive Technology (FAT) of Germany
(Figure 1). It started in 1999 including data of research areas Dresden and Hanover. In
these areas about 2,000 accidents per year are investigated and recorded to the GIDAS
database. Each case is encoded with about 3,400 variables and 150 pictures per accident
on average. Following the documentation, each accident is reconstructed by an
experienced engineer.

Figure 1 – Structure of the GIDAS project

The GIDAS database is adapted for representative statements about German traffic
accident scenario due to high number of recorded accidents, the fact that research areas
represent topographically German average and investigation follows an exact sampling
plan. For further details see [1].
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Documentation of traffic accidents (Limitations)

The selection criteria of traffic accidents are

- at least one injured person

- within investigation time
- within investigation area
- the most current accident.

The investigation areas of the GIDAS project are Dresden and Hanover (Figure 2).The
research area around Dresden is 40 – 45 km and includes the city of Dresden and
surrounding areas. The area of Hanover is with 30 – 35 km a little bit smaller, but
includes also the city and surrounding areas. Dresden has in the north a flat surface and in
the south elevations up to 800 m. The area of Hanover is mostly flat surface. The
investigation areas include all traffic and urban situations like highways, avenues, urban
streets, towns, villages and countryside.

Figure 2 – Investigation areas of the GIDAS project

Accidents are recorded in two six-hour shifts each day. These shifts change every week.
The investigation times are:

First week: 12 a.m. – 6 a.m. and 12 p.m. – 6 p.m.

Next week: 6 a.m. – 12 a.m. and 6 p.m. – 12 p.m.

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All daytimes are covered throughout the year. The shifts take place every day, including
weekends and holidays. Every accident has the same chance of being selected. It is
possible to do extrapolations towards the entire German accident scenario see in chapter
2.3.

The GIDAS investigation contains the technical investigation like general information,
accident sketch, vehicle parameters, road and environment parameters and also the
medical investigation like personal data, injury data and psychological Interviews.

The following figure (Figure 3) gives an overview of the investigated accidents in the
GIDAS database. Note: The given numbers are unweighted data.

Figure 3 – Documentation and reconstruction of accident data (unweighted)

GIDAS Weighting Factors

Following a strict sample plan, GIDAS collects data in selected areas and within
specified shift times. While gathering a large number of accident parameters, GIDAS
contains only a fraction of all accidents occurring in Germany. Such a data sample is
always biased and there are some particular and logical reasons why there is some bias in
the GIDAS data: The investigation teams are not always thoroughly informed about
every aspect of each accident, that is, information about injuries cannot always be
obtained immediately and there may be differences between parts of the investigation
areas. To obtain a more representative result when analyzing GIDAS data, it is
recommended to apply weighting factors in order to compensate these effects. The
GIDAS database is commonly weighted on the basis of three categories: the accident
location, the type of accident, and the accident severity. By combining all values of the

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three categories and calculating a weighting factor for the resulting combination, each
accident in the database gets a weighting factor.

1st Category: Accident Severity

There are three major accident severities in GIDAS:

1. accidents with slight injuries

2. accidents with severe injuries
3. accidents with fatalities

In GIDAS there is a slight bias towards accidents with severe injuries and fatalities. This
bias is a result of the different alarming awareness in the police stations. The accident
research unit is more precisely and immediately informed about accidents with severe
injuries or fatalities than about accidents with minor injuries. It also happens quite often
that a participant is not recognized as injured at first glance, for example in some cases
where the injuries become established some hours or even a day after the accident.
Without applying weighting factors, the GIDAS dataset contains a slightly higher
proportion of accidents with severe injuries and fatalities.

2nd Category: Accident Location

There are two accident locations in GIDAS: “urban” and “rural”. Compared to the
German statistics, GIDAS tends to contain more urban accidents. Thus, accidents in rural
areas are slightly under-represented in GIDAS.

3rd Category: Type of Accident

There are seven major accident types in GIDAS (according to the official definition),
representing the critical situation prior to the crash:

1. Loss of control accident

2. Turn off accident
3. Turn into / cross accident
4. Pedestrian crossing accident
5. Accident in resting traffic
6. Accident in longitudinal traffic
7. Other accident

Weighting categories and weighting factors

Combining these three categories leads to 42 different combinations (weighting

categories). For each weighting category, the number of accidents in GIDAS is compared
to the number of accidents in the corresponding category in the German national statistics.
On the basis of the ratios a weighting factor is calculated for each weighting category. In
general, accidents that are under-represented in GIDAS (e.g. accidents in rural areas with
slightly injured persons) get a weighting factor larger than one, and accidents that are
over-represented get a factor smaller than one.
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Master dataset

The hierarchical structure of the GIDAS database cuts into four levels: the accident level,
the vehicle level, the occupant level and the injury level. Each level consists of several
records which contain the investigated parameters of an accident (figure 3).

Figure 3 – Hierarchy of the GIDAS database

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Creating the Master dataset

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526
 Annex 8.3 NATIONAL AUTOMOTIVE SAMPLING SYSTEM – CRASHWORTHINESS
DATA SYSTEM (NASS - CDS) – USA

Taken from pages 6-10 of the “National Automotive Sampling System –

Crashworthiness Data System 2013 Analytical User Manual” (DOT HS 812 066)
released by the U.S. Department of Transportation, National Highway Traffic Safety
Administration in September 2014:

SECTION 3
THE SAMPLING SYSTEM AND SAMPLE DESIGN

The crashes investigated in NASS CDS are a probability sample of all police reported
crashes in the U.S. A NASS CDS crash must fulfill the following requirements: must be
police reported, must involve a harmful event (property damage and/or personal injury)
resulting from a crash and must involve at least one towed passenger car or light truck or
van in transport on a trafficway. Every crash, which meets these conditions, has a chance
of being selected. This type of sample design makes it possible to compute estimates,
which are representative of the entire country.
The selection of sample crashes in NASS is accomplished in three stages: (1) selection of
Primary Sampling Units (PSU's), (2) selection of police jurisdictions and (3) selection of
crashes.

Stage 1 - Select PSU's

For the first stage of selection, the country was divided into 1195 geographic areas called
PSU's. Each PSU consisted of a central city, a county surrounding a central city, an entire
county or a group of contiguous counties. The PSU's were defined so that their minimum
population was approximately 50,000.
The 1195 PSU's were grouped into 12 strata based on geographic region and type, e.g.,
central cities, suburban counties, and other PSU's. The 24 PSU's to be sampled were
allocated to each stratum roughly proportional to the number of crashes in each stratum.
At least two PSU's were selected from each stratum.

Stage 2 - Select Police Jurisdictions

If every crash in each PSU were investigated, a national estimate could be obtained by
weighting each crash by the inverse of the probability of selecting the PSU. Because it is
uneconomical and impractical to investigate every crash in each sample PSU, a second
and third stage of sampling are performed. Each PSU contains a number of police
jurisdictions which process reports of crashes that occur within the PSU's boundaries.
These police jurisdictions form the frame of the second stage of sampling. Each
jurisdiction is assigned a measure of size based on the number, severity and type of its
crashes. A sample of jurisdictions is selected which oversamples those having a larger
measure of size.

Stage 3 - Select Crashes

The final stage of sampling is the selection of crashes within the sampled jurisdictions.
Each week, the police jurisdictions are contacted and all crashes that qualify for the
NASS CDS for which a police crash report has been filed since the last date that
jurisdiction was contacted are listed. While being listed, each crash is classified into a
stratum based on type of vehicle; most severe police reported injury, disposition of the
injured, tow status of the vehicles and model year of the vehicles. All qualifying crashes
are listed, except in a few of the largest police jurisdictions. In these jurisdictions only
crashes with either an even or an odd police crash report number are listed.

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To select crashes, each team is assigned a fixed number of crashes to investigate each
week. The number of crashes a team selects for investigation is governed by the number
of researchers on a team. Sampling weights for the strata are assigned so that a larger
percentage of the higher severity crashes are selected than of the lower severity crashes.
Also, crashes in the same stratum have the same probability of being selected, regardless
of the PSU.
To select the sample, each crash is assigned a weight equal to the inverse of the
probability of selecting the police jurisdiction in which it was listed.

SAMPLING VARIABLES
The stratification category (1) by type of vehicle is [a] "CDS applicable"---passenger cars,
light trucks and vans and [b] "Non-CDS Applicable vehicles"---all other vehicle types; (2)
by injury is "fatal injury"---K, "serious injury"---A or "minor injury, not injured or
unknown"---B,C,O,U; (3) by disposition of the injured is "transported to a medical
facility" or "not transported"; (4) by hospitalization is "occupant admitted at least
overnight"; (5) by tow status is "towed due to damage" or "not towed"; (6) by model year
of the vehicle is "late model year"---2010 through 2014 or "non-late model year"---2009
or before.

SAMPLING STRATA
The ten PAR sampling Strata used by the CDS are listed below and shown in Table 3-1:

Stratum A-NASS crashes in which at least one occupant of a towed CDS applicable late
model year vehicle had a police reported injury of "K" (fatal injury).

Stratum B-NASS crashes not qualifying for Stratum A in which at least one occupant of
a towed CDS applicable non-late model year vehicle had a police reported injury of "K"
(fatal injury).

Stratum J-NASS crashes not qualifying for Strata A or B in which at least one occupant
of a towed CDS applicable late model year vehicle had a police reported injury of "A"
(incapacitating injury) AND was transported to a treatment facility for treatment AND
was admitted overnight to the hospital. If the crash involved more than one CDS
applicable vehicle, at least two of the CDS applicable vehicles must be towed.

Stratum K-NASS crashes not qualifying for Strata A, B or J in which at least one
occupant of a towed CDS applicable non late model year vehicle had a police reported
injury of "A" (incapacitating injury) AND was transported to a treatment facility for
treatment AND was admitted overnight to the hospital. If the crash involved more than
one CDS applicable vehicle, at least two of the CDS applicable vehicles must be towed.

Stratum C-NASS crashes not qualifying for Strata A, B, J or K in which at least one
occupant of a towed CDS applicable late model year vehicle had a police reported injury
of "A" (incapacitating injury) AND was transported to a treatment facility for treatment.
If the crash involved more than one CDS applicable vehicle, then at least two of the CDS
applicable vehicles must be towed.

Stratum D-NASS crashes not qualifying for Strata A, B, J, K or C in which at least one
occupant of a towed CDS applicable non-late model year vehicle had a police reported
injury of "A" (incapacitating injury) AND was transported to a treatment facility for
treatment. If the crash involved more than one CDS applicable vehicle, then at least two
of the CDS applicable vehicles must be towed.

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Stratum E-NASS crashes not qualifying for Strata A, B, J, K, C or D in which at least
one occupant of a towed CDS applicable late model vehicle was transported from the
scene to a treatment facility for treatment.

Stratum F-NASS crashes not qualifying for Strata A, B, J, K, C, D or E in which at least

one occupant of a towed CDS applicable non-late model vehicle was transported from
the scene to a treatment facility for treatment.

Stratum G-NASS crashes not qualifying for Strata A, B, J, K, C, D, E or F which involve

at least one CDS applicable late model vehicle that was towed, according to the police
report, from the scene due to damage.

Stratum H-NASS crashes not qualifying for Strata A, B, J, K, C, D, E, F or G which

involve at least one CDS applicable non-late model vehicle that was towed, according to
the police report, from the scene due to damage.

Example of Crash Stratification: A CDS applicable non-late model year vehicle and a
bicycle crash. The CDS applicable vehicle is towed with minor injuries to the occupants,
who are not transported. The bicyclist receives a serious injury---"A". The crash is
classified as Stratum H because of the minor injuries to the occupants of the towed CDS
applicable non-late model year vehicle.

Sampling
Because the crashes selected in NASS CDS are a probability sample of all crashes
occurring in the survey year, the data from these crashes are "weighted" to produce
National Estimates. The weights result from the stages of selection, reflecting that crash's
probability of selection. The analysis file contains only one weight.

National Inflation Factor

The National Inflation Factor is the overall sampling weight for each crash selected in the
NASS sample and the inverse of the probability of selection of that crash. It is equal to
product of the PSU Inflation Factor and the inverse of the probability of selection of the
PSU (Stage 1).
The sum of the National Inflation Factors for all sampled NASS crashes in a year is an
unbiased estimate of the total number of crashes, which occurred during the year in the
U.S. If restricted to a crash stratum, the sum is an estimate of the total number of that
type of crash, which occurred in that year. Unbiased estimates of National totals of crash
characteristics can be obtained by multiplying the value of the characteristic for each
crash in the NASS sample by the National Inflation Factor for that crash.

Ratio Inflation Factor

The Ratio Inflation Factor (SAS: RATWGT) is the product of the National Inflation
Factor and a rate, which adjusts for differences between actual and estimated totals. This
ratio is calculated using crash totals from both the sampled and non-sampled police
jurisdictions. The totals for the sampled jurisdictions come from the Stage 3 frame. The
totals for the non-sampled jurisdictions are collected annually. The PSU's are grouped
into predetermined sets. Dividing the total crashes in each stratum and in each set of
PSU's by the estimated total forms ratios. Those estimated totals are sums of the National
Inflation Factors for each crash in the crash strata and set of PSU's.
Estimates of National totals for crash characteristics can be obtained using the Ratio
Inflation Factor (RIF). However, because the RIFs have been adjusted to actual crash

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counts, some of the sampling variation has been removed. Therefore they will produce
more precise estimates than the National Inflation Factor. It is for this reason that the RIF
or Ratio Weight is the only weight on the analysis file. Less than one percent of the cases
have RIFs greater than 5000. This is the result of listing at least twice the number of
expected serious injury crashes on a given sampling day.
Overall (unweighted) counts of records:

Year Crash Records Vehicle Records Occupant Records

2004 5597 10000 12275

2005 4481 7907 9859

2006 4941 8746 10895

2007 4963 8965 10809

2008 5167 9402 10833

2009 5200 9548 11027

2010 4856 8921 10215

2011 4278 7898 8940

2012 3581 6665 7402

2013 3385 6348 7084

Counts (unweighted) of records meeting TRL inclusion criteria (Section 1):

Year Crash Records Vehicle Records Occupant Records

2004 482 490 780

2005 775 803 1180

2006 1249 1326 1944

2007 1746 1906 2849

2008 2064 2276 3342

2009 2238 2497 3706

2010 2162 2417 3596

2011 2078 2378 3492

2012 1776 2046 2899

2013 1839 2157 3080

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