Reviving the topic of LATCH weight limits

snowbird25ca

Moderator - CPST Instructor
It's been awhile since I've looked through the Transport Canada research testing and today I was looking through the ff'ing info.

There is very specific discussion regarding lower anchor forces and whether they failed at different speeds and different weight dummies.

Some of the tests were done with the 10yr old dummy - 77lbs, in a regent. Out of 10 tests - some of which included no top tether in order to see if the lower anchors on their own could withstand the forces, there was 1 failure. That 1 failure happened in a vehicle where the seat was installed in a center position using borrowed anchors where borrowing wasn't allowed and also was influenced by the top tether slipping in to the split in the seat and leading to a sudden side shift during the test.

I've done a ton of research in the last few months on the amount of force that lower anchors are required to take and compared to things like the amount of release force that a seatbelt buckle is required to take. (To help give perspective on what the force means that lower anchors are required to withstand, lower anchors are tested to over 2/3 the force that a seatbelt buckle is required to withstand without releasing. If we are to believe that lower anchors can fail starting at 65lbs, then that means that seatbelts can fail starting with an adult who weighs 100lbs - we know that seatbelts don't fail regularly even with occupants over 200lbs - so how can we believe lower anchors are able to withstand so much less weight despite the force they're tested to?)

There is in vehicle research testing with high weight dummies at relatively high speeds that show an absence of failure. I'm not in the US and not in a position to push for the facts that NHTSA is apparently using to try and justify the 2014 rule. But I'd really really encourage those of you in the US to push for the facts and challenge these rules instead of just accepting them and passing out the new limits.

There are also some comments on this page about the difference between seatbelt and UAS install (which is the Canadian term for lower anchors,) and the amount of distance the seat came forward in a crash. This is a specific concern that was part of NHTSA's financial assessment prior to deciding to implement LATCH in the US.

There were reasons beyond ease of use for the implementation of LATCH, and the ridiculous limitations that this ruling is imposing could make kids less safe or result in kids being prematurely boostered. I care about what is happening down in the US on this because it has created a spillover of concern and questions in Canada and based on everything I've dug up, there is no evidence or data to support the move. (I've read FMVSS, I've contacted car seat manufacturers, and I've also contacted crash test facilities.)

So I guess this is me saying to all the techs and advocates out there - you are the voice that needs to be heard. I've seen so much focus on disseminating the changes and only a limited amount of questioning the data - if enough people challenge NHTSA, and push Safety Belt Safe to also challenge NHTSA, maybe there will be pressure put on the auto manufacturers - maybe the whole issue will be dropped, or a more reasonable limit put on things. This ruling isn't about increasing the safety of kids, it's bureaucracy. And when bureaucracy has the potential to decrease safety, advocates and techs need to question and challenge it. You are the voices for the kids and your fellow techs and advocates.

For everyone's reading, here is the link to the summary on the ff'ing tests. http://www.tc.gc.ca/eng/roadsafety/safedrivers-childsafety-programs-testing-harness-report-923.htm

Picking on the Radian because it's one of the heaviest seats - it was only tested with the 6yr old, but that dummy is 51lbs. It was also tested at 56km/hr in many tests (higher than standards require and higher than what most collisions are,) and there were zero tether and lower anchor failures. (This was also pre-superlatch, and in the case of the Nissan Murano, the lower anchors on it would've been tested to the previous lower anchor standard which required the lower anchors to be tested to a lower force than what they've had to meet since 2005. So this case is significant overall in that regard that there was no failure even when the anchor minimum strength was lower.)

I still have hope that techs and advocates can create enough questions that the whole 2014 rule might be stopped in regards to lower anchor limits - or that the weight might be revised. Give me a total weight of 105lbs and I could support that as more reasonable. It would also mean that the majority of seats would be able to be used with UAS as long as the child fit the seat. Just because the vehicle manufacturers have more power when it comes to lobbying doesn't mean that they should get final say when it's the government who ultimately makes the rules that they have to meet.

Thanks for reading if you've gotten through this. I feel strongly about this because things like this often eventually spill in to Canada. I'm prepared to fight it and get a strong group together up here should similar legislation eventually show up here, but it would sure be easier for everyone if the initial legislation gets revised in the US first. :thumbsup:
 
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ketchupqueen

CPST and ketchup snob
Staff member
I just wanted to assure you that we HAVE spoken up against it.

SBS and SRN both contacted the LATCH Working Group and NHTSA during the comment period and I can double check but I'm fairly certain the TC data was brought up. The cr manufacturers also fought this. Unfortunately, on the other side, many vehicle manufacturers (Toyota, fyi, not among them) pushed for stricter limits. I'm not sure what happened but somehow we went from 65 lbs child weight to 65 total weight from the proposed to final rule. Part of why more strongly worded challenges weren't initially made- SBS was initially focused on making sure TAs weren't included in the rule-is that 65 lbs child weight sounded pretty reasonable to everyone... I've talked to others about this and we all aren't sure how the change happened.
 

LISmama810

Admin - CPS Technician
Yeah, I don't think anyone really believes in the need to have the limit at 65 lbs, and it absolutely is a bureaucratic decision, not a practical one.

I, personally, am not speaking out against it to SafeKids/NHTSA, because the one time I tried to do that on the CPS List (about top tether limits, I believe), I (and others) were chastised by a NHTSA person about how the automobile working group's decision stands and basically saying that we're not to express dissent. :rolleyes:

I do have confidence that SBS and others with more power are working behind the scenes to address the issue, and I'm happy to back them up if needed, but IME, it's pretty clear that no one at the government level is interested in hearing from lowly techs.
 

ketchupqueen

CPST and ketchup snob
Staff member
Unfortunately, from what I gather, much larger/more ”powerful” groups are now being told essentially the same answer- the rule stands, stop arguing. Not that they'll stop agitating for a more reasonable rule but it needs to be done diplomatically.
 

LISmama810

Admin - CPS Technician
Are the larger, more powerful groups going direct with NHTSA, or are they working on Congresspeople?
 

snowbird25ca

Moderator - CPST Instructor
Yeah, I don't think anyone really believes in the need to have the limit at 65 lbs, and it absolutely is a bureaucratic decision, not a practical one.

I, personally, am not speaking out against it to SafeKids/NHTSA, because the one time I tried to do that on the CPS List (about top tether limits, I believe), I (and others) were chastised by a NHTSA person about how the automobile working group's decision stands and basically saying that we're not to express dissent. :rolleyes:

I do have confidence that SBS and others with more power are working behind the scenes to address the issue, and I'm happy to back them up if needed, but IME, it's pretty clear that no one at the government level is interested in hearing from lowly techs.

Just because they're not interested in hearing, doesn't mean that if enough people make comments they're not going to eventually have to respond.

It's unfortunate that that is the air that has been created though that people feel that they aren't allowed to speak up or that it's pointless. Maybe if techs contacted SBS etc so that they had the ability to say "85% of our 35,000 members have expressed concerns that this ruling reduces the safety of children" there would be something there.

KQ - that's interesting that somehow along the way that 65lbs morphed from child weight to total weight. Are there documents reflecting when it was intended to be child weight? Could those be brought forward to raise questions about the change from child weight to total weight?

I am quite ok with 65lb child weight because it really won't affect the majority of kids in the US (and would only affect special needs restraints up here if it did transfer.)

I wonder if it might be as simple as something getting transferred wrong from one document to another?

I know that the JPMA (I think that's the right initials,) amongst other groups are lobbying NHTSA, but I'm guessing they are lobbying from a different point. I'm not sure that anyone is looking at the numbers and demanding answers... it was the comparison between lower anchor newtons and seatbelt release newtons that really put things in perspective for me... (I get that they're separate systems and different kinds of force being placed on them - but there is still a giant discrepancy there...)

So on a semi-related topic - lets say that the final rule does get changed. My understanding had been that the data in the LATCH manual was changed because the manual is only updated every 2yrs and they wanted it ready for 2014. If the final rule is changed, then that makes the LATCH manual just as wrong as if it hadn't been updated and the final rule wasn't changed... In the meantime parents and techs have been placed in a quandary of having to deal with something when things still could change. The whole thing is just really frustrating to me.

eta: KQ is very right about the need to be diplomatic and I'm not advocating to be a rude PITB - the same content can be delivered in multiple ways.
 
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ketchupqueen

CPST and ketchup snob
Staff member
The rule is already final. There is not a large likelihood of it not going into effect.

I don't think concern from techs means squat at this point. I believe political as well as bureaucratic channels are being used but this isn't a political priority right now.

What I do anticipate is public uproar when this becomes a thing on the labels of child seats next year and all of a sudden they vary all over the place. I suspect THAT is the time when ”call your senator” campaigns could become effective.

Of note, the vehicle manufacturers have changed their limits, they didn't have to. Deferring to the cr would have been enough. I think it's telling of which ones were behind the agitation, which manufacturers changed limits (though that's just a suspicion.)

The way the government archives stuff I'm betting you could find the 65 lbs thing somewhere.
 

SafeDad

CPSDarren - Admin
Staff member
Are the larger, more powerful groups going direct with NHTSA, or are they working on Congresspeople?

Yes. The auto makers are one of the largest lobbying groups in the USA and have always had strong influence with NHTSA and other organizations as well. Consider that it's cheaper to pay one lobbyist $100,000 a year than to put an improved part that costs even just $1 into millions of vehicles.

I suspect this may not even amount to a whimper when 2014 arrives, at least beyond a few community forums and Facebook, anyway. The vast majority of parents don't know or care about any of this and have never had any interest keeping their kids in a 5-point harness beyond a few years of age. Without any major published studies showing the adverse effects in terms of fatalities or economic factors, I doubt there will be much to force a change:-(

I (and others) were chastised by a NHTSA person about how the automobile working group's decision stands and basically saying that we're not to express dissent.

I do hope there is more discussion, of course, and I also think that everyone should be free to speak their opinion on the subject, for or against. While we may all have to accept any "rules" on best practice from NHTSA and our certifying body when it comes to educating parents, they certainly should not be telling anyone that they can't have a dissenting opinion on the rules themselves. That type of enforcement is well beyond the scope of these organizations, not to mention being very un-American and contrary to the first amendment.

For me, the worst part is that this makes it easy for the auto manufacturers to self-impose the same limits on the top tether anchors. I can live without high weight limits on lower anchors, but some kids won't live without top tether anchors.
 

LISmama810

Admin - CPS Technician
What I do anticipate is public uproar when this becomes a thing on the labels of child seats next year and all of a sudden they vary all over the place. I suspect THAT is the time when ”call your senator” campaigns could become effective.

Agreed.
 

LISmama810

Admin - CPS Technician
Yes. The auto makers are one of the largest lobbying groups in the USA and have always had strong influence with NHTSA and other organizations as well. Consider that it's cheaper to pay one lobbyist $100,000 a year than to put an improved part that costs even just $1 into millions of vehicles.

I was referring to SBS, et. al. when I asked about the "more powerful" groups, as I meant they're more powerful than me :) But yes, that's an important point I was just about to touch on: Money talks, and one auto manufacturer has a lot more money to throw around than all the advocacy groups combined. It's pretty clear where these directives are coming from.

I do hope there is more discussion, of course, and I also think that everyone should be free to speak their opinion on the subject, for or against. While we may all have to accept any "rules" on best practice from NHTSA and our certifying body when it comes to educating parents, they certainly should not be telling anyone that they can't have a dissenting opinion on the rules themselves. That type of enforcement is well beyond the scope of these organizations, not to mention being very un-American and contrary to the first amendment.

It wasn't so much that we CAN'T speak against it--more that they made it clear they don't want to hear it and won't listen.
 

snowbird25ca

Moderator - CPST Instructor
The rule is already final. There is not a large likelihood of it not going into effect.

I don't think concern from techs means squat at this point. I believe political as well as bureaucratic channels are being used but this isn't a political priority right now.

What I do anticipate is public uproar when this becomes a thing on the labels of child seats next year and all of a sudden they vary all over the place. I suspect THAT is the time when ”call your senator” campaigns could become effective.

Of note, the vehicle manufacturers have changed their limits, they didn't have to. Deferring to the cr would have been enough. I think it's telling of which ones were behind the agitation, which manufacturers changed limits (though that's just a suspicion.)

The way the government archives stuff I'm betting you could find the 65 lbs thing somewhere.

I'd be interested in knowing if the vehicle manufacturers that changed limits are the same ones who originally opposed the type of LATCH system that vehicles have. That group was swayed over from different variables to the current system by facts that showed it wouldn't be as expensive as they thought and that it would probably be more beneficial safety wise.

Back when the updated standards came in to effect in Canada, there ended up being a 1 year delay given at the last minute - literally the month before everyone was supposed to be compliant to the updated standards. I guess I have a small sliver of hope that things could be changed, but I will admit that I don't understand the processes etc that NHTSA has vs. how things happened with TC. And ultimately our standards didn't get revised again despite some manufacturers wanting that - they just gave a 1yr delay in implementig them... I still have to hope that there is a way to have an impact before the widespread confusion hits...
 

SafeDad

CPSDarren - Admin
Staff member

No imagine the outrage if the auto makers had been required to attach some sort of obvious label on the seat next to the anchors stating that the lower anchors were dangerous to use beyond a combined weight of 65 pounds. After all, if some automakers are admitting they can't stand behind the strength of their anchors, then the label should be on their cars, rather than the carseat, right?

THAT might have raised some ire among the public. Plus, auto companies who make better anchorages wouldn't have to apply the label, giving them a competitive advantage. But, No. We had to force carseat manufacturer to add yet one more label. As it is, so few parents read labels on carseats that most won't know any difference.
 

CTPDMom

Ambassador - CPS Technician
It wasn't so much that we CAN'T speak against it--more that they made it clear they don't want to hear it and won't listen.

Knowing how many techs do not participate in CSO, but how many DO subscribe to the CPSP list and other local lists that the CPSP emails often get cross-posted too (at least here in CT), those questions you're asking are REALLY important. Because often that's the only way some techs know about things.

I just asked one of the 2 officer/CPSTs this morning about this and he looked at me blank faced...hadn't heard a word about it. :cool:

So keep asking the questions, regardless of whether you get a 'cold' answer back from some people. :)

I personally believe as Darren does. I think no one (parents) will really notice or care. I think the majority of parents have no clue there is a LATCH limit now.
 

SafeDad

CPSDarren - Admin
Staff member
I'd be interested in knowing if the vehicle manufacturers that changed limits are the same ones who originally opposed the type of LATCH system that vehicles have. That group was swayed over from different variables to the current system by facts that showed it wouldn't be as expensive as they thought and that it would probably be more beneficial safety wise.

I do know flexible LATCH was allowed, at least in part because it was felt that imposing rigid LATCH would be too much of a financial burden on carseat manufacturers. Seems like the ones in Europe managed somehow!

You can be sure where there are costs involved on adding something to millions of products, money sometimes trumps ease-of-use and sometimes even safety.
 

LISmama810

Admin - CPS Technician
No imagine the outrage if the auto makers had been required to attach some sort of obvious label on the seat next to the anchors stating that the lower anchors were dangerous to use beyond a combined weight of 65 pounds. After all, if some automakers are admitting they can't stand behind the strength of their anchors, then the label should be on the their cars rather than the carseat, right?

THAT might have raised some ire among the public. Plus, auto companies who make better anchorages wouldn't have to apply the label, giving them a competitive advantage. But, not, we had to force carseat manufacturer to add yet one more label. As it is, so few parents read labels on carseats that most won't know any difference.

That's a really good point. If the "problem" lies with the anchors, why has the burden been shifted to the car seats? (Rhetorical question there.)

Knowing how many techs do not participate in CSO, but how many DO subscribe to the CPSP list and other local lists that the CPSP emails often get cross-posted too (at least here in CT), those questions you're asking are REALLY important. Because often that's the only way some techs know about things.

I just asked one of the 2 officer/CPSTs this morning about this and he looked at me blank faced...hadn't heard a word about it. :cool:

So keep asking the questions, regardless of whether you get a 'cold' answer back from some people. :)

I personally believe as Darren does. I think no one (parents) will really notice or care. I think the majority of parents have no clue there is a LATCH limit now.

The CPSP list is intimidating because "important" people are on it. I tried talking there, got shot down, now I read only.
 

cantabdad

New member
The rule is already final. There is not a large likelihood of it not going into effect.

I don't think concern from techs means squat at this point. I believe political as well as bureaucratic channels are being used but this isn't a political priority right now.

[...]
The way the government archives stuff I'm betting you could find the 65 lbs thing somewhere.

For anyone interested, the docket is archived here:
http://www.regulations.gov/#!docketDetail;D=NHTSA-2010-0158

Reading through the final rule, it is clear that NHTSA relied heavily on concerns from "the Alliance" (i.e. Alliance of Automobile Manufacturers) on this issue of combined child+CRS weight, rather than comments from the CPS community.

That being said, as far as I can tell, no one ever countered the Alliance's assertion that the actual lower anchor loading requirements were based on a _combined_ 65 lb. weight.

Some of the heavy hitters on "our" side, such as the American Academy of Pediatrics, also just called for the confusion to be addressed through clear labelling, without coming down one or the other about whether it should be the weight of the child or the combined weight.

As such, it is easy to see how a risk-averse bureaucracy like NHTSA decided to change course and move to this awkward compromise of the "combined weight" standard. However, it was the wrong decision and will only contribute to increased confusion about LATCH and (sadly) to the possibility of additional preventable injuries.

Political pressure would be the only way to go here, I think. It's an awfully technical / obscure issue for most folks in Congress, but some are interested. In fact, the big transportation bill that passed this July (MAP-21) contains a provision requiring NHTSA to pursue a rulemaking that will "improve the ease of use for [LATCH]" (Section 31502).

I have asked around about this, but have not heard any specifics about what Congress intended or how NHTSA plans to respond.
 

LISmama810

Admin - CPS Technician

alwayzmyself

New member
(This was also pre-superlatch, and in the case of the Nissan Murano, the lower anchors on it would've been tested to the previous lower anchor standard which required the lower anchors to be tested to a lower force than what they've had to meet since 2005. So this case is significant overall in that regard that there was no failure even when the anchor minimum strength was lower.)

I know I'm getting off topic here, but had a curious question for you. I was trying to search on Google to find the weight limits for the lower latch anchors on my 2005 Nissan Murano. I checked the manual, but it didn't give an answer.
When I Google searched, it brought up this thread as a result and I'm just curious since you specifically mentioned the Nissan Murano... what's the deal with it? Are the anchors known to fail at lower weights that what the "norm" would be?

We have a 2005 Nissan Murano - My son just turned three last week and is pretty skinny; 38in tall and around 33-35lbs. He sits rear-facing in a Graco MyRide 65 with Safety Surround (15lbs weight). So the total weight between him and the car seat is roughly 50lbs. I was trying to find whether I should stop securing his seat using the LATCH system or if I should begin securing his seat using the vehicles safety belts. Any ideas? Again, I'm sorry that I'm getting off topic here - it just raised a red flag for me seeing the Nissan Murano specifically mentioned.
 

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