JPMA Responds to Consumer Reports' Testing of Infant Car Seats

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JPMA Responds to Consumer Reports' Testing of Infant Car Seats

January 4, 2007

The Juvenile Products Manufacturers Association (JPMA), which represents the
leading manufacturers of infant child restraints in the United States,
questions the forthcoming findings of Consumer Reports magazine about the
performance of infant child restraints in recent crash tests. In the real
world, no product is more effective at reducing fatalities and injuries to
our precious children.

"Child restraints are highly effective safety devices that have saved
thousands of children's lives in car crashes," said Robert Waller, JPMA
President. "Their use is required throughout the nation, because they are so
effective at reducing injury to children. It is irresponsible to suggest
that infant child restraints may not perform well in crashes."

Moreover, the crash test results and protocols have not previously been
shared with the industry or government for proper evaluation. The scientific
validity of Consumer Reports' conclusions is highly questionable. Most
infants and toddlers under 4 years of age are being transported in vehicles
with child restraint seats. Research has proven time and again that these
seats are highly effective at reducing the likelihood of death by more than
70%. These seats are considerably more effective than adult safety belts.
The bigger issue affecting the potential for injury or death is non-use of
such seats. Too many infants and especially older children ride unrestrained
in motor vehicles.

All child restraints sold in the United States are required to satisfy the
rigorous performance standards established by the National Highway Traffic
Safety Administration (NHTSA), and are certified by their manufacturers as
compliant before they can be offered for sale. Manufacturers extensively
test their child restraints, using both in-house and independent test
laboratories, both for the purpose of assuring compliance before marketing
the products and to confirm continuing compliance during production. The
Government also independently tests child restraints every year to ensure
compliance with its standards.

NHTSA has determined that "child restraints are highly effective in reducing
the likelihood of death and or serious injury in motor vehicle crashes." 68
Fed.Reg. 37620, 37622 (June 24, 2003). NHTSA studies show that for infants
(children less than one year old), a child restraint can reduce the risk of
fatality by 71 percent when used in a passenger car and by 58 percent when
used in a light truck, van or SUV. 68 Fed.Reg. at 37622.

NHTSA has noted that an increase in severity of speed would require redesign
of many child restraints and increase their cost and availability "without a
proportionate safety benefit" 68 Fed. Reg. at 37640.

The Insurance Institute for Highway Safety has confirmed that "child
restraints designed to pass the current 30 mph standard are providing very
good protection to children in frontal crashes, and there is no evidence
suggesting that designing child restraints to withstand higher crash forces
could have prevented or mitigated any of the serious or fatal injuries in
cases studied by the Institute". NHTSA Docket 11707, Entry 31.

The University of Michigan Transportation Research Institute (UMTRI) also
advised that the 30 mph sled test is "more severe than approximately 98% of
the frontal impact crashes nationwide." UMTRI cautioned against increasing
the speed of the test, noting:

"Increasing the velocity of the test is not likely to increase safety, but
will increase consumer cost of child restraint systems. In addition,
designing child restraints to pass a test at higher crash severity may lead
to child restraint design changes that make the restraints less effective or
more easily misused at lower severity crashes, which occur much more
frequently." NHTSA Docket 11707, Entry 43.

As noted by these and other experts, there is no evidence that infant child
restraints would protect children better in real world crashes if they were
designed to meet a crash test conducted at higher speed. Moreover, design
changes needed to meet a higher crash speed may result in designs that are
less effective in lower speed collisions, or harder to install properly,
leading to decreased safety in the vast majority of crashes. The fact
remains that child restraints are highly effective at reducing death and
serious injury in the real world. To the extent that the Consumer Reports
story undermines confidence in use of these restraints it does the public a
disservice. Greater use of these demonstrably life saving seats should be
promoted, not discouraged. Ultimately, better performance of vehicles in all
crash situations will provide the greatest commensurate benefit for all
vehicle occupants.