NHTSA Withdraws Rulemaking for Windshield Zone Intrusion
November 30, 2012

by Casey Neeley, cneeley@glass.com

In an article published on the Federal Register yesterday, the National Highway Traffic Safety Administration (NHTSA) has decided to withdraw a rulemaking proposal aimed at repealing the Federal Motor Vehicle Safety Standard (FMVSS) rule No. 219 focused on windshield zone intrusion.

The NHTSA article reads, "The agency has determined that there are two ongoing regulatory developments that could influence vehicle designs by putting a premium on the use of lighter or less rigid materials. These two developments are U.S. fuel economy requirements and a global technical regulation aimed at reducing injuries to pedestrians struck by vehicles. As a result, the agency believes that vehicle designs with regard to the hood and windshield are in a state of change and that the implications of these developments should be better understood before deciding whether to rescind FMVSS No. 219."

The current FMVSS No. 219, which took place on September 1, 1976, states that a vehicle hood must "not enter a defined zone in front of the vehicle's windshield during a full frontal crash test at 48 kilometers per hour (km/h)," or 30 miles per hour (mph), according to the NHTSA. It further explains, "The protected zone is an area encompassing the width of the windshield and that protrudes about 76 millimeters (3 inches) from the outer surface of the windshield."

The standard, which NHTSA claims has not been substantially revised since taking effect, was put into place in an effort to "reduce injuries and fatalities that result from occupant contact with vehicle components, such as the hood, that are displaced into the occupant compartment through the windshield opening or into the zone immediately forward of the windshield aperture during a frontal crash."

On July 7, 2008, the NHTSA proposed a rulemaking change that would rescind FMVSS No. 219 after deeming it a "standard that could possibly be removed as unnecessary," and deciding FMVSS Nos. 208 and 213, standards focused on occupant crash protection and hood latch systems, respectively, already met the standard described in 219.

"Our belief stemmed from the fact that FMVSS No. 219 had succeeded in virtually eliminating the intrusion of vehicle components from outside the occupant compartment into the windshield," reads the NHTSA article, "The agency's analysis of FMVSS compliance and New Car Assessment Program (NCAP) tests indicated there had been no known incidents in which a crash tested vehicle failed to meet the performance requirements in FMVSS No. 219. Furthermore, in a preliminary analysis of crashes in the National Automotive Sampling System (NASS) Crashworthiness Data System (CDS), no hood intrusions into the areas prescribed by FMVSS No. 219 were found among full frontal crashes."

As a result of the ever-changing trends in auto safety and foreign innovations, the NHTSA decided rescinding FMVSS No. 219 now was ill-timed.

"There are relatively new considerations affecting vehicle design, specifically, enhanced corporate average fuel economy standards, and global technical regulations for vehicle hoods that will reduce the severity of injuries sustained by pedestrians that are struck by vehicles. These considerations are likely to stimulate the use of lighter or less stiff materials in vehicles. In addition, we may begin to see new entrants from foreign and domestic manufacturers that have less experience with the FMVSS framework, in comparison to manufacturers that have long been part of the U.S. market. Therefore, the agency has concluded that now is not an appropriate time to rescind FMVSS No. 219."

According to Bob Beranek, editor of Auto Glass Journal and president and founder of Automotive Glass Consultants Inc., maintaining the standard is a smart choice.

"When they decided to rescind the 219 standard they did not think through the ramifications of the new fuel efficiency laws proposed by the new administration-namely the 50 miles per gallon mandate," says Beranek.

"When their engineers looked at history and realized that to attain fuel efficiency, vehicle designers took weight away from the vehicles' structure. If the crash dynamics were not considered and the FMVSS not in place, then the occupants would be the loser due to weakness in structure. So, NHTSA realized that the standard must stay in place to force the engineers to consider safety when increasing fuel efficiency. Their decision to reinstate the 219 standard is the responsible thing to do in my opinion."

Dale Malcolm, technical manager for Dow Automotive Systems aftermarket division, agrees.

"What a shame it would be for somebody to have all of the high tech features like airbags and crash zones then get into an otherwise survivable accident only to have the bottom of the windshield let go and have the windshield wiper stab them in the chest; I think it's a good thing they kept the regulation," says Malcolm.

Though Beranek and Malcolm agree the announcement positively reinforces the status quo, both say if the NHTSA ever decide to proceed with the removal of the standard it may spell trouble for highway safety.

"If it is rescinded then the vehicle manufacturers can interpret the other standards as it wishes," says Beranek. "It could mean less safe vehicles or it could mean that other standards would make up for the absence of 219. However, the [NHTSA] article indicates that smarter heads prevail and that NHTSA understands that the regulation must be in place to assure that the engineers are not pushed away from safety for the sake of profits."

"My concern is you've got a piece of glass that's been tested to do a certain job," says Malcolm. "For the glass to do its job completely, it needs to stay bonded into the car well. I believe the intrusion tests ties somewhat into how the glass stays bonded into the car."

"Having these standards and being able to kind of tell a story full circle reinforces to the average technician why they should care and why they should do the right thing," Malcolm continues. "If you're pulling standards, you start to wonder if you're saying, subliminally, that you're going to send the wrong message that things are getting easier; things aren't quite as strict."

This story is an original story by AGRR™ magazine/glassBYTEs.com™. Subscribe to AGRR™ Magazine.
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