NHTSA’s Proposed Rule for Pedestrian Head Protection
NHTSA is currently seeking public comment on its proposed rule to create a new Federal Motor Vehicle Safety Standard (FMVSS) that would ensure that passenger vehicles, including large pickups and SUVs, are designed to reduce the risk of serious to fatal child and adult head injury in pedestrian crashes. I read through much of the 238-page(!) docket providing background for the rule and submitted the following comments. I’ve included them here in case they can help inform your thoughts and comments. In brief, I emphasized my support for the rule and the need to:
Go further to include testing for frontover risk,
Mandate the testing for shorter and flat hoods, and
Mandate the testing at higher impact speeds than are currently planned.
If you have expertise in vehicle design, I hope you will review the docket and add further insights in your comments. My comments to the docket follow below.
~ Rebecca
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Thank you for your work to improve pedestrian safety and the opportunity to comment on Docket No. NHTSA-NHTSA-2024-0057. I support this rule to establish test procedures simulating a head-to-hood impact and performance requirements to minimize the risk of head injury, and to require the use of human-like headforms for both a child and a smaller adult to measure the head-to-hood impact. I urge NHTSA to go further in this rule and require testing frontover risk to further quantify the risk of varying hood shapes and heights to people outside of the car.
In the docket, NHTSA likely understates the danger of higher, flatter/boxier hoods to pedestrians by citing statistics about injuries as a whole group rather than focusing on fatal and severe injuries. In the Safe System Approach promoted by FHWA and considered to be global best practice, we seek to eliminate fatal and serious injuries and do not focus as much on moderate and minor injuries. In this case, IIHS research has demonstrated that pedestrians are significantly more likely to experience a severe injury when in a crash with a vehicle that has a taller, boxier hood than a lower vehicle with a sloped hood. As the electric car industry continues to evolve, the time is right to mandate this testing -- and safer hood design and body size overall, which this rule currently does not mandate -- to prevent additional fatal and life-altering injuries to people outside of the vehicle. Along these lines, I support requiring shorter or flat hoods to be subjected to this same type of pedestrian safety testing, as discussed on p. 37 of Docket No. NHTSA-NHTSA-2024-0057.
I also urge NHTSA to require this testing to be conducted at speeds greater than 25 mph. The text makes much of the new requirements for AEB, which I greatly appreciate. However, IIHS research has shown that AEB is not as proven in darkness (https://www.iihs.org/news/detail/few-vehicles-excel-in-new-nighttime-test-of-pedestrian-autobrake) -- the lighting condition under which 75% of pedestrian fatalities have occurred over the last several years. When drivers cannot see at night, which is particularly the case at higher speeds, it may seem like a pedestrian "came out of nowhere" when, in fact, they were already crossing the roadway. It may also be the case that the pedestrian stepped off the curb midblock. Either way, we need to accept the reality that AEB might not be effective enough to slow vehicles to 25 mph when they strike a pedestrian. As such, using 25 mph as the impact speed for these tests may lead to significantly underperforming hoods in real world conditions. It would be far preferable -- and reflect a data-driven analysis of the relationship between fatal and severe pedestrian injuries and speeds -- to require testing and performance requirements at 35 mph. Additionally, 35 mph still fits within your definition of practicability as described on pp. 47-48 of Docket No. NHTSA-NHTSA-2024-0057. In a Safe System that accounts for the significant limitation to human eyesight in darkness, we need extra care to ensure that we have the resilience needed to prevent fatal and severe injuries.