NHTSA's Safety Standards for Child Restraint Systems-Side Impact Protection

April 24, 2014

Sofie E. Miller

Download this Public Interest Comment (PDF)


This public interest comment on the National Highway Traffic Safety Administration’s proposed rule setting side-impact requirements for child restraint systems is part of a new project to evaluate how well agencies are preparing for retrospective review and analysis of regulations, pursuant to Executive Order 13563.

As such, it does not express judgment on the merits of NHTSA’s proposal or whether the proposed objectives are worthwhile, but rather attempts to evaluate whether NHTSA’s proposal incorporates plans for retrospective review, so that it and the public can determine whether those stated objectives are being achieved. In this comment, Miller concludes that after implementation, NHTSA should commit to measuring child injury and fatality rates for side impact crashes through the FARS and NASS-CDS databases every year as new CRSs are being introduced into the market. This information will indicate whether this rule accomplishes the reductions in child fatalities and injuries that NHTSA projects.