Issues for Consideration During Harmonization Process

5. Issues for Consideration During Harmonization Process

The goal of this section is to briefly present problems/issues which have not been focused on previously in this report and which may be necessary to overcome to achieve the goal of harmonization. These issues are, in the short term, obstacles to a determination of functional equivalence and, in the long term, obstacles to the creation of an unified standard.

Although both the U.S. and EU standards have dynamic requirements with similar approaches, the U.S. standard also has an additional static requirement. This requirement involves loading the door of a given vehicle with a metallic cylinder and measuring the door's resistance to specific quantities of intrusion. The EU regulation does not have such a static requirement which NHTSA believes provides a level of protection in side crashes with poles and trees. The U.S. regulation will also apply to light trucks and vans (LTVs) beginning in 1998 while the EU regulation will only apply to passenger cars. Currently, in the U.S. market, LTVs constitute about 50 percent of new passenger vehicle sales and form a significant segment of the current vehicle fleet.
Although EUROSID-1 has relatively advanced measurement capabilities, it may have mechanical deficiencies that need to be resolved as was indicated by past NHTSA research [10 pg.15] and recent experiences of U.S. automobile manufacturers [12]. One example is the possible binding of rib modules that results in incorrect injury measurements. There are also questions relative to the variability of the EUROSID-1 chest deflection measurements.
The two regulations have very different injury criteria. It is not apparent which standard's criteria are more stringent and how to assess and compare the resulting relative safety benefits in terms of real world injuries. In addition, there are currently questions in the scientific community on how to relate the EU chest and abdominal injury criteria to real world human injuries.
The European moving barrier is specified by its performance in the EU regulation and does not have design specifications as does the barrier in the U.S. standard. This has led to different designs depending on the suppliers. Recent EU test experience by both European and U.S. automobile manufacturers show that the same vehicle typically provides varying results when tested using European barriers from different suppliers. Additionally, recent changes in EUROSID-1, which have been characterized as cosmetic, may have changed the dummy's performance characteristics. Therefore, results from past industry and government testing, although extensive, may not be comparable to more recent tests. However, the latest studies by the Canadian, Australian, and Japanese governments and certain manufacturers may provide consistent data sets for comparison of the two standards.
Additional sled and full vehicle test data may be needed to address the EUROSID-1 durability, repeatability and reproducibility, and to address the EU test procedure repeatability before NHTSA can consider the European dummy in a U.S. regulation.
Development of a representative harmonized moving barrier may not be feasible because of the differences in fleet composition in the U.S. and European markets.
The U.S. standard requires both a front and a rear seated dummy, representing the driver and rear seated passenger. The EU standard only specifies a front seated dummy representing the driver. As such the EU does not require protection for a rear passenger.
Currently, international technical experts have in place a working item through the International Standards Organization (ISO) to develop a worldwide side impact dummy. This was based on their assessment that none of the existing side impact dummies provide sufficiently human like response and do not provide adequate measurements for side impact crash testing. Such a dummy, when built, and the corresponding injury criteria probably would provide a major component of a harmonized side impact regulation.
The European common market countries have a type-approval vehicle certification process which tends to be generally specified. The EU test procedure is lacking in specificity and NHTSA will need to define a number of areas such as the EUROSID-1 seating procedure. The level of detail and specificity to be tolerated by the European community may be a major harmonization issue.
Development and adoption of a harmonized European standard may be a lengthy process given that many countries and several bodies are involved in the European regulatory process. This also presupposes that the European Market countries are willing to participate in the harmonization process and are willing to upgrade their dummy, if necessary. It is anticipated that some European countries, whose automobile manufacturers have little or no market share in the U.S., would have reservations about participating in developing a new or hybrid harmonized standard given that such a standard would increase competition to their native manufacturers in their own markets.
Development of a harmonized standard could require considerable resources to create a test procedure, to upgrade one of the existing dummies or develop a new one, to assess the common safety needs, and to perform safety and benefit studies in several vehicle markets. This would necessitate active participation by the European community and additional NHTSA funding to conduct and coordinate the needed wide scope studies.