 
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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