OBLIGATION TO FIT ISOFIX ANCHORAGES. (Discussion paper)
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1 111th Session of the MOTOR VEHICLE WORKING GROUP 5 July 2006 OBLIGATION TO FIT ISOFIX ANCHORAGES (Discussion paper) 1. INTRODUCTION CARS 21 has stated in its findings that failure to wear a seat belt or a crash helmet is a serious aggravating factor in accidents and approximately lives could be saved through improved use (to the best international rate). Recommendation No 12 includes the use of Isofix child seats as an improvement measure in favour of halving the number of road victims by CARS 21 has adopted its report on 12 th December Since then Council Directive 91/671/EEC 1 as amended 2 has made mandatory not only the use of safety belts but also the use of child restraint systems in vehicles. These prescriptions are of mandatory application since 9th May this year. The main points of this legislation are described here below M 1, N 1, N 2 and N 3 vehicles Children less than 150 cm in height occupying M 1, N 1, N 2 and N 3 vehicles fitted with safety systems must be restrained by an integral or non-integral child restraint system suitable for the child's mass between zero and 36 Kgs. In practice, child restraint systems must be able to be fitted to the front or to the other rows of seats. Children may not be transported using a rearward-facing child restraint system in a passenger seat protected by a front air bag, unless the air bag has been deactivated (even in cases where the air bag is automatically deactivated in a sufficient manner). Where a child-restraint system is used, it must be approved to the standards of the United Nations Economic Commission for Europe (UN-ECE) Regulation 44/03 or Directive 77/541/EEC, or any other subsequent adaptation thereto. However, until 9 May 2008 Member States may permit the use of child restraint systems approved in accordance with their national standards applicable on the date of installation of the restraint system or with national standards equivalent to Regulation 44/03 or to Directive 75/541/EEC. 1 2 Council Directive 91/671/EEC of 16 December 1991 on the approximation of the laws of the Member States relating to compulsory use of safety belts in vehicles of less than 3,5 tonnes Official Journal L 373, 31/12/1991 P. 26. Directive 2003/20/EC of the European Parliament and of the Council of 8 April 2003 amending Council Directive 91/671/EEC on the approximation of the laws of the Member States relating to compulsory use of safety belts in vehicles of less than 3,5 tonnes Official Journal L 115, 09/05/2003 P
2 1.2. M2 and M3 vehicles All occupants (including children), aged three and over, of M 2 and M 3 vehicles must use the safety systems provided while they are seated. Child restraints shall be approved in accordance with the aforementioned rules in paragraph ISOFIX AND SAFETY RESTRAINT SYSTEMS IN ROAD VEHICLES The Isofix system has been developed for the connection of child restraint systems (child seats) to vehicles. Whilst this system is theoretically applicable to all vehicle categories, it applies commonly to M 1 vehicles 3. The Isofix system is covered by an ISO Standard, the aim of which is to avoid the misfitting of universal child seats when installed in vehicles, thus reducing the risk of injury in the event of a collision. The Isofix system creates a rigid link between the child seat and the vehicle. As well as this extra solidity, it also removes the risk of slack installation which is one of the key misuse areas with child seats are installed using an adult seat-belt. The rigid linking system also makes installation of the seat quicker than when using a seat-belt. Non-negligible is the fact that the same child seat fitted with Isofix connectors may be used in different models of vehicles 4, which is an important feature for a family having two or more vehicles. However, the main objection against the extension of the Isofix system to all vehicles is the fact that it will have a large effect on the market for child restraint systems, thus obliging new parents to buy child seats fitted with Isofix connectors whilst the European fleet is mainly made up of vehicles fitted only with diagonal and lap belts. To compensate for this disadvantage, child-seat manufacturers should be encouraged to market specific seats which can be used in vehicles fitted either with Isofix anchorages or without, as many consumers have two or more cars, of which only one may have Isofix anchorage points. Such seats (called dual or duo) can be installed using the regular lap and diagonal seat-belt assembly or the Isofix anchorage. 3. ISO STANDARDS As said above, Isofix systems are covered by an ISO Standard. This standard has been divided into three constituent parts. The two main parts are ISO Anchorages in vehicles and attachments to anchorages for child restraint systems - Part 1, relating to seat bight anchorages and attachments and ISO Anchorages in vehicles and attachments to anchorages for child restraint systems - Part 2, relating to top tether anchorages and attachments. 3 4 In the currently available UN/ECE legislation, light duty trucks (N 1 vehicles) are concerned in so far as Isofix anchorages, if fitted, have to comply with the technical specifications of the relevant legislation. On condition that they are fitted with the necessary Isofix anchorages.
3 A third part to Standard ISO is currently under development to cover the dimensions and space to be provided in a vehicle to correctly fit the child restraint system. Actually, it has to be ensured that the child seat back, which has to be secured to the top tether anchorage, must lean correctly against the vehicle seat, which implies that there exists a sufficient space to fit the top tether webbing strap. The ISO standards relating to Isofix systems have been adopted by manufacturers worldwide. However, there still exist controversial points, in particular with respect to the top tether anchorage. In this instance, the National Highway Traffic Safety Administration is still questioning the force to be used for test purposes. At the present time many new models of passenger cars introduced recently on the European market are fitted with Isofix anchorages conforming to ISO MAIN CONSTRUCTION FEATURES OF ISOFIX SYSTEMS Isofix systems are made of two specific lower anchorages, which are designed for attaching a compatible child restraint system in conjunction with an anti-rotation device. The lower anchorages are two six mm diameter rigid round horizontal bars, extending from vehicle or seat structure to accept Isofix attachments (the connectors), fulfilling the requirements of UN/ECE Regulation No 44, extending from the Isofix child restraint frame structure The anti-rotation device consists of a top tether anchorage (such as a bar), located in a well-defined zone, designed to accept an Isofix top tether strap connector and to transfer its restraint force to the vehicle structure. The top tether connector is intended to be attached to the top tether anchorage by means of a webbing strap (or equivalent) which extends from the top of the child restraint system to the top tether anchorage, and which is equipped with a tensionrelieving device. A significant issue is that not all passenger cars on the market are capable of accommodating the largest child restraint systems. The correct fitting of the child restraint system requires that the design of the seat back has been adapted in relation to the fitting of Isofix and that it allows sufficient space taking account of the head restraints and other construction features. The use of a standardised gauge is necessary to ascertain that a vehicle type can accommodate the child restraint system. A sufficient transitional period is therefore necessary to allow manufacturers to adapt the current production models to the new requirements. 5. MAIN FEATURES REGARDING COMPATIBLE ISOFIX CHILD RESTRAINT SYSTEMS Child restraint systems ( CRS s ) are safety devices which must satisfy severe approval test conditions in order to provide children with high-level protection and comfort.
4 Currently, they must be type-approved in accordance with the provisions of regulation No 44 as amended by the 03 series of amendments. Today, such CRS s must be fitted to a vehicle type by using the seat belts provided with the host vehicle, thus offering multiple possibilities for misuse. Isofix systems would require that, in the future, all child restraint systems are Isofix compatible. In the practice, that means that seats would have to be fitted with specific attachments. There exist two family of attachments : the rigid Isofix connectors (Fig. A) the latch connectors (Fig. B) In principle, latch connectors will be used during a transitional period but will be replaced by rigid connectors, significantly more easy to use. Fig. A. ISO connectors Fig. B Latch connectors 6. ISOFIX SYSTEMS AND THE LEGISLATION 6.1. UN/ECE Regulations All relevant features of the Isofix systems, which are contained in the relevant ISO standards, have been included in UN/ECE Regulations No 14, 16 and 44. This methodology has generated unnecessary overlaps in the legislation. The UN/ECE legislation has been enforced and is now binding for the Contracting Parties applying these regulations for national type-approval. Whilst the relevant ISO standards apply to all vehicles irrespective of their category, the technical provisions regarding Isofix systems included in UN/ECE regulations relate only to M 1 vehicles and N 1 vehicles (for the latter only at the discretion of the vehicle manufacturer).
5 The provisions regarding Isofix systems apply in accordance to the rules laid down in the revised 1958 Agreement, that means on a semi-optional basis : In this instance (i.e. anchorages Reg 14) : As from 2 years after the enter into force of the 06 series of amendments to this Regulation [= ], Contracting parties applying this Regulation [=14] shall grant ECE type-approvals only if the requirements of this Regulation, as amended by the 06 series of amendments, are satisfied [i.e. if fitted with Isofix anchorages]. As from 7 years after the enter into force of the 06 series of amendments to this Regulation [= ], Contracting parties applying this Regulation [=14] may refuse to recognise approvals which were not granted in accordance with the 06 series of amendments to this Regulation [i.e. if not fitted with Isofix anchorages]. 26 February 2006 is an important date. From that date, when a new vehicle type (as regard Regulation 14) has to be type-approved with respect to this regulation it has to be fitted with isofix anchorages EC Directives The relevant directive concerning child restraint systems is Directive 77/541/EEC which refers explicitly to UN/ECE Regulation 44 including the 03 series of amendments 5 with respect to technical prescriptions. Directive 76/115/EEC concerns safety belt anchorages but refers exclusively to anchorages intended for adults. Lastly, Directive 74/408/EEC regarding seats and head restraints is not directly concerned by the fitting of child restraint systems in vehicles Making Isofix mandatory in the Community To make the fitting of Isofix anchorages compulsory in the Community, the technical annexes of Directives 76/115/EEC and 77/541/EEC would have to be respectively amended at the same time and in the same way so as to ensure the consistency of the whole set of technical provisions and harmonised application of the legislation. In any case, the technical provisions to be included in these Directives should refer to the largest extent to the corresponding UN/ECE regulations. However, some legal aspects are interfering with this principle and oblige the Commission services to opt for a direct reference to ISO technical prescriptions. In addition, the question arises whether the scope of Directive 77/541/EEC should not be modified to take into account of the compulsory use of child restraint systems in vehicles, required by Directive 91/671/EEC. 7. PROPOSALS IN RESPECT OF INSTALLATION PRESCRIPTIONS The following principles will apply when preparing the legislation on Isofix systems : 5 See for reference Annex XVII of Directive 77/541/EEC.
6 only child restraint systems to be installed in forward- or rearward-facing positions are allowed (lateral facing are not permitted - whilst foreseen in UN/ECE Regulation 14); the fitting of a top tether anchorage 6 is mandatory ; air bag located in front of an Isofix position must be designed as to be deactivated automatically when a universal or semi-universal CRS is connected to the anchorages. A transitional period of three years should be provided and the requirement should apply to new vehicle types only. M 1 and M 2 vehicles (these where no standees are permitted) must be fitted with two Isofix positions, one of them for the front row of seats. Convertible M 1 vehicles (it is meant here vehicles with only one row of seats) must be fitted with only one single Isofix position. M 3 vehicles (these where no standees are permitted) must be fitted with at least [four] Isofix positions. N 1 vehicles (with a bodywork categorised van ) must be fitted with two isofix positions, one of them for the front row of seats. Vehicles with only one row of seats must have only one Isofix position. N 2 and N 3 vehicles are not required to be fitted with Isofix positions. When Isofix positions are not required, any fitting of them must comply with the technical provisions of the Directive as amended. Ambulances and hearses are exempted from the obligation to fit Isofix positions. Tests on the anchorages must be performed using the S-FAD (Static Force Application Device) with application of a 800 dan horizontal force and a 500 dan oblique force as in Regulation 14. Whilst the force is reduced by 50 % for M 2 and N 2 and by 66 % for M 3 and N 3 7 with respect to the traction forces used for adult occupants, it is proposed to use a single set of requirements for all vehicle categories for the testing of the Isofix anchorage points. This is justified by the fact that all Isofix anchorages will have the same design in all vehicle categories. JP DELNEUFCOURT ENTR/F The vehicle dashboard or a support leg are also considered as anti-rotation device but not in the context of fitting of anchorages. Respectively (by configuration) 675 dan and 450 dan.
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