throbber
U.S. Department
`Of Transportation
`National Highway
`Traffic Safety Administration
`
`FINAL REGULATORY EVALUATION
`
`EVENT DATA RECORDERS
`(EDRs)
`
`Office of Regulatory Analysis and Evaluation
`National Center for Statistics and Analysis
`July 2006
`
`People Saving People
`
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`

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`TABLE OF CONTENTS
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`TABLE OF CONTENTS
`
`EXECUTIVE SUMMARY ------------------------------------------------------- E-1
`EXECUTIVE SUMMARY ....................................................... 13-1
`
`I.
`I.
`
`II.
`II.
`
`INTRODUCTION ------------------------------------------------------ I-1
`INTRODUCTION ...................................................... 1-1
`
`REQUIREMENTS OF THE FINAL RULE ------------------------- II-1
`REQUIREMENTS OF THE FINAL RULE ------------------------- II—l
`
`III.
`III.
`
`BENEFITS --------------------------------------------------------------- III-1
`BENEFITS ............................................................... 111-1
`
`IV.
`IV.
`
`COSTS AND LEADTIME -------------------------------------------- IV-1
`COSTS AND LEADTIME ............................................ IV-l
`
`V.
`V.
`
`REGULATORY FLEXIBILITY ACT AND ------------------------ V-1
`REGULATORY FLEXIBILITY ACT AND ------------------------V-1
`UNFUNDED MANDATES REFORM ACT
`UNFUNDED MANDATES REFORM ACT
`
`REFERENCES ----------------------------------------------------------------------- R-1
`REFERENCES ....................................................................... R_1
`
`APPENDIX A: RESPONSE TO COMMENTS ---------------------------------- A-1
`APPENDIX A: RESPONSE TO COMMENTS .................................. A4
`
`APPENDIX B: CHANGES FROM THE NPRM --------------------------------- B-1
`APPENDIX B: CHANGES FROM THE NPRM ................................. 3-1
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`OWNER EX. 2003, page 2
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`E - 1
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`EXECUTIVE SUMMARY
`
`This Final Regulatory Evaluation (FRE) analyzes the potential impacts of the final rule
`
`for voluntarily installed Event Data Recorders (EDRs) in light vehicles. An EDR is a
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`device or function in a vehicle that records a vehicle’s dynamic, time-series data just
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`prior to or during a crash, intended for retrieval after the crash.
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`Final Rule
`
`The final rule requires voluntarily installed EDRs in vehicles with a gross vehicle weight
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`rating (GVWR) of 3,855 kilograms (8,500 pounds) or less to:
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`a. Record 15 essential data elements,
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`b. Record up to 30 additional data elements if the vehicle is equipped to record these
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`elements,
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`c. Record these data elements in a standardized format, with specifications for
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`range, accuracy, resolution, sampling rate, recording duration, and filter class,
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`d. Function after full-scale vehicle crash tests specified in FMVSS Nos. 208 and
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`214, and
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`e. Have the capacity to record two events in a multi-event crash.
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`In addition, the final rule requires vehicle manufacturers to make a retrieval tool for the
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`EDR information commercially available. The rule also requires vehicle manufacturers
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`to include a standardized statement in the owner’s manual indicating that the vehicle is
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`equipped with an EDR and describing its purposes.
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`E - 2
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`Technological Feasibility
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`Currently, about 9.8 million (64 percent) new light vehicles are equipped with some type
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`of EDR. Many of the EDRs already collect the data elements required by the final rule
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`but with slightly different formats. For these EDRs, their software algorithms might
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`require minor modification. For EDRs that do not record all the required essential data
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`elements, their memory chips and computer processors might require upgrades to
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`accommodate the increase in data flow and storage. These EDRs may also require
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`software algorithm redesigns and other improvements for their computer area networks.
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`Benefits
`
`The final rule will standardize and enhance the amount of recorded crash information that
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`is available through EDRs. Safety researchers would utilize the standardized information
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`to better understand crash dynamics and to identify more effective crashworthiness and
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`crash-avoidance countermeasures, thereby helping to improve motor vehicle safety.
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`EDRs meeting with the requirements of the final rule may also provide a more
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`comprehensive and useful set of data for automatic collision notification (ACN) systems,
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`which evaluate the need for and the level of emergency response to traffic crashes.
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`Costs
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`At the current level of usage of EDRs, the estimated costs associated with the rule would
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`be up to $1.7 million (2004 dollars). This aggregate cost figure reflects the need for
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`technology improvements, as well as assembly costs, compliance costs, and paperwork
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`maintenance costs. Technological improvements account for majority of these costs.
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`E - 3
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`The cost of the rule would potentially increase to $5.2 to $8.4 million if future
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`rulemakings (e.g., FMVSS No. 214) make the recording of additional data elements
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`inevitable or if the manufacturers voluntarily design their current EDRs to record all the
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`additional data elements. If all 15.5 million new light vehicles became voluntarily
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`equipped with an EDR, the cost would be rise to $10.9 million for the present final rule
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`and $11.8 to $33.3 million if additional data elements are required due to future
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`rulemakings.
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`Leadtime
`
`The compliance date of the final rule is September 1, 2010. Multi-stage vehicle
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`manufacturers and alterers must comply with the rule beginning on September 1, 2011.
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`The long leadtime should enable vehicle manufacturers to make design changes to their
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`EDRs as they introduce new make/models, which will minimize the compliance costs
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`towards the lower bound of estimates.
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`I - 1
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`CHAPTER I. INTRODUCTION
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`This final regulatory evaluation accompanies the National Highway Traffic Safety
`
`Administration’s (NHTSA) final rule to specify requirements for voluntarily installed
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`Event Data Recorders (EDRs) in light vehicles with a gross vehicle weight rating
`
`(GVWR) not more than 3,855 kg (8,500 pounds). An EDR is a device or function in a
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`vehicle that records vehicle performance characteristics just prior to or during a crash.
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`The final rule’s requirements cover the data elements and their recording formats,
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`compliance tests, survivability and retrievability of the EDR data, disclosure and
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`reporting of EDR information.
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`Background
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`EDRs have been available in various forms in certain vehicles since the 1970s. In 1991
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`the agency, in cooperation with General Motors (GM), began to utilize EDRs as one of
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`the crash investigative tools for the agency’s Special Crash Investigations (SCI) program.
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`Between 1991 and 1997, staff from the SCI program worked with manufacturers to read
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`approximately 40 EDRs in support of its program.
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`In 1997, the National Transportation Safety Board (NTSB) issued Safety
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`Recommendation H-97-18 to NHTSA, recommending that the agency “pursue crash
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`information gathering using EDRs.” In the same year, the National Aeronautics and
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`Space Administration (NASA) Jet Propulsion Laboratory (JPL) recommended that
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`NHTSA "study the feasibility of installing and obtaining crash data for safety analyses
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`I - 2
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`from crash recorders on vehicles.” Later, in 1999, NTSB made additional EDR
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`recommendations, suggesting that EDRs be installed in school buses and motor coaches.
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`In response, NHTSA sponsored two EDR working groups since 1998. The working
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`groups were comprised of members from industry, academia, and other government
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`organizations. The groups’ missions were to facilitate the collection and utilization of
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`collision avoidance and crashworthiness data from on-board EDRs. In August 2001, the
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`first EDR Working Group published a final report on the results of its deliberations1. In
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`May 2002, the second working group, the NHTSA Truck & Bus EDR Working Group,
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`published its final report2. NHTSA also developed a website for highway-based EDRs.
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`This website includes the current development on EDRs. The web address is
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`“http://www-nrd.nhtsa.dot.gov/edr-site/index.html”.
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`Petitions
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`Almost in parallel to the agency’s EDR research, the agency received three rulemaking
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`petitions pertaining to EDRs. Two of the petitions were from private individuals, Mr.
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`Price T. Bingham and Ms. Marie E Birnbaum. The third one was from Dr. Ricardo
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`Martinez, President of Safety Intelligence Systems Corporation.
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`1 Event Data Recorders, Summary of Findings by the NHTSA EDR Working Group, August 2001, Final
`Report. (Docket No. NHTSA-99-5218-9).
`2 Event Data Recorders, Summary of Findings by the NHTSA EDR Working Group, May 2002, Final
`Report, Volume II, Supplemental Findings for Trucks, Motorcoaches, and School Buses (Docket No.
`NHTSA-2000-7699-6).
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`I - 3
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`Mr. Bingham and Ms. Brinbaum both petitioned the agency in late 1990’s. Mr. Bingham
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`asked the agency to initiate rulemaking to require air bag data to be recorded during a
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`crash and to be read later by crash investigators. The second petitioner, Ms. Marie E.
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`Birnbaum, asked the agency to initiate rulemaking to require passenger cars and light
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`trucks to be equipped with “black boxes” (i.e., EDRs) analogous to those found on
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`commercial aircraft.
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`In responding to these two petitions, the agency stated that EDRs could provide valuable
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`information to better understand crashes. The recorded information could be used in a
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`variety of ways to improve motor vehicle safety. Nevertheless, the agency denied these
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`two petitions because the motor vehicle industry was already voluntarily moving in the
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`direction recommended by the petitioners, and because the agency believed "this area
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`presents some issues that are, at least for the present time, best addressed in a non-
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`regulatory context." (63 FR 60270; November 9, 1998 and 64 FR 29616; June 2, 1999.)
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`The third petitioner, Dr. Ricardo Martinez, petitioned the agency in October 2001 to
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`“mandate the collection and storage of onboard vehicle crash event data, in a
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`standardized data and content format and in a way that is retrievable from the vehicle
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`after the crash.” The petitioner reasoned that crash information is the cornerstone of
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`safety decision-making for designing the vehicle, making policy, identifying a potential
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`problem, or evaluating the effectiveness of safety systems. However, the petitioner felt
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`that the industry’s overall response has been “sluggish and disjointed” and that a NHTSA
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`rulemaking on EDRs is necessary. The NHTSA-sponsored Working Group on EDRs, the
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`I - 4
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`Institute of Electrical and Electronics Engineers (IEEE), and the Society of Automotive
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`Engineers (SAE) all had begun to work on guidance for standardizing data sets for EDRs.
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`In addition, the petitioner argued that a rulemaking would greatly accelerate the
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`deployment of automatic crash notification (ACN) since the advent of advanced ACN is
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`dependent upon the standardized collection of crash information in the vehicle.
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`Finally, the petitioner stated that privacy issues could be overcame by ensuring that the
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`vehicle owner is the one who owns the data collected by the EDR and can provide
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`permission for its use and transmission. The EDR data does not have personal identifier
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`information and is only stored in the event of a crash. Current crash information in the
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`form of police reports and insurance claims have much more personal identifying
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`information than EDRs.
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`The petition from Dr. Martinez was submitted shortly after the first NHTSA EDR
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`Working Group had published its final report and while the agency was waiting for the
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`conclusions from the second EDR working group. In October 2002, after the second
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`working group had completed its work, the agency decided to request public comments
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`on the future role the agency should take related to the continued development and
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`installation of EDRs in motor vehicles. After the consideration of the pubic comments,
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`the agency then decided to respond to Dr. Martinez’s petition in a notice for proposed
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`rulemaking (NPRM).
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`I - 5
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`Request for Comments
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`On October 11, 2002, NHTSA published in the Federal Register (67 FR 63493; Docket
`
`No. NHTSA-02-13546), a request for comments concerning EDRs and as to what future
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`role the agency should take related to the continued development and installation of
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`EDRs in motor vehicles.
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`The agency received comments from light and heavy vehicle manufacturers, equipment
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`manufacturers, vehicle users, the medical community, advocacy organizations, safety
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`research organizations, crash investigators, insurance companies, academia, government
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`agencies, and private individuals. Generally, the commenters believed that EDRs will
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`improve vehicle safety by providing necessary and accurate data for crash analysis,
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`information for potential injury prediction, and data for vehicle/roadway design
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`improvement. However, commenters also expressed concern that the complexity of and
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`incompatibility among existing EDRs might prevent the recorded data from being fully
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`utilized for vehicle occupant safety improvements. Thus, the commenters concluded that
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`a standardization of EDR data would be desirable and helpful. Both the SAE and IEEE
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`commented that they are working on drafting standards for use with EDRs (which have
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`since been finalized).
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`As for NHTSA’s role in the future of EDRs, the commenters’ opinions varied. However,
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`most commenters stated that NHTSA should perform research, work with manufacturers
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`to increase the availability of the data, and encourage the development of EDR standards.
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`I - 6
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`After considering these inputs, the agency decided to issue a Notice of Proposed
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`Rulemaking (NPRM) to propose a standardized set of data elements and formats for all
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`voluntarily installed EDRs. The goal of the proposal would be to enhance the use of the
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`recorded data in ACN systems, crash investigation, the evaluation of safety
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`countermeasures, and advanced restraint and safety countermeasure research and
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`development.
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`Notice of Proposed Rulemaking (NPRM)
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`On June 14, 2004, NHTSA published an NPRM for EDRs (69 FR 32932; NHTSA-04-
`
`18029). The NPRM proposed that voluntarily installed EDRs in light vehicles with
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`GVWR no greater than 3,855 kg (8,500 pounds) shall:
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`(1) record a minimum set of 18 specified data elements useful for crash investigations,
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`analysis of the performance of safety equipment, e.g., advanced restraint systems,
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`and automatic collision notification systems;
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`(2) record an additional 24 data elements if light vehicles were equipped with these data
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`elements;
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`(3) specify data format requirements including range, accuracy, precision, sampling rate,
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`recording time duration, and filter class for the required data elements;
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`(4) record up to 3 events in an multi-event crash;
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`(5) increase the survivability of the EDRs and their data by requiring that the EDRs
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`would function during and after the front, side and rear vehicle crash tests specified
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`in Federal Motor Vehicle Safety Standard (FMVSS) Nos. 208, 214, and 301;
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`(cid:50)(cid:58)(cid:49)(cid:40)(cid:53)(cid:3)(cid:40)(cid:91)(cid:17)(cid:3)(cid:21)(cid:19)(cid:19)(cid:22)(cid:15)(cid:3)(cid:83)(cid:68)(cid:74)(cid:72)(cid:3)(cid:20)(cid:20)
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`I - 7
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`(6) require that the EDR data would retrievable at least 30 days after the crash;
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`(7) require vehicle manufacturers to make publicly available information that would
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`enable crash investigators to retrieve data from the EDR; and
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`(8) require vehicle manufacturers to include a brief standardized statement in the owner's
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`manual indicating that the vehicle is equipped with an EDR and describing the
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`purposes of EDRs.
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`The NPRM would allow the agency to better evaluate the performance of advanced
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`restraint systems, allow crash investigators to obtain better crash data for reconstruction
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`purposes, and enhance the development and installation of ACNs. Essentially, with the
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`NPRM, the agency granted partly (i.e., standardization of EDR data) and denied partly
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`(i.e., mandating EDRs) the third petition.
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`Comments on the NPRM
`
`NHTSA received a total of 104 comments to the NPRM. Of these, 61 were from private
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`citizens, and 43 were from 40 various groups, including automotive and EDR
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`manufacturers, insurance companies, safety organizations, government agencies,
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`health/medical institutes, and other small groups. Among the 61 individual responders,
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`54 opposed, 6 supported, and 1 abstained the NHTSA proposal. Invasion of privacy,
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`violation of constitutional rights of the vehicle owners, and ambiguity regarding
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`ownership of the EDR data were the fundamental reasons for their opposition.
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`I - 8
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`Among the 40 various groups (43 comments), 4 groups opposed, 35 groups supported,
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`and 1 group abstained the NPRM proposal. Their 43 comments tended to be more
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`complex than those of individual commenters and covered a variety of issues. Issues of
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`concern included privacy, ownership of the EDR data, accessibility of EDR data, whether
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`EDRs should be mandatory, the authentication of the EDR data, the definition of EDR,
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`the appropriateness of data elements and data formats, the stringency of survivability
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`requirements, low cost estimates, and short leadtime. Of the four groups opposed to the
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`proposal, three were small private research organizations and one was a European
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`automobile manufacturer (Porsche). The three small private groups opposed the proposal
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`with reasons echoing those made by the individual commenters (i.e., privacy,
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`constitutional rights, and ownership). Porsche, on the other hand, opposed the proposed
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`rule by citing that the industry was already moving in this direction and other EDR
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`technical problems.
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`Of the 35 groups supporting the EDR proposal, some of these commenters expressed
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`concern about privacy and ownership issues, and other commented on the “voluntarily”
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`aspect of rule. But, the major shared concerns among these groups were centered on the
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`EDR technical issues: (a) EDR specifications, i.e., appropriateness of the data elements,
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`format, and accuracy requirements, (b) functioning and survivability requirements, and
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`(c) the cost estimates. These commenters argued that the NPRM proposal is excessive.
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`For example, commenters stated that the data format requirements (range, sampling rate,
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`accuracy, resolution, and filter) significantly exceeded the current industry practices, and
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`in some aspects, the sensor technologies for achieving the proposed data format
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`I - 9
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`requirements might not be feasible in the near future. To comply with the NPRM
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`proposal, the commenters argued that the manufacturers would be required to incur a
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`substantially higher cost for updating their sensors/accelerometers, computer processing
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`units (CPUs), and back-up power supplies in order to handle the data flow and comply
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`with the functioning/survivability proposal. The commenters suggested that the total cost
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`per EDR could be up to $500 with the majority of the cost attributable to the need for
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`back-up power supplies.
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`Other concerns raised by the commenters included whether there should be a mandatory
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`requirement for EDRs, exemption of the multi-stage vehicles, preemption of State Law,
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`clarification on the definition of “EDR”, and clarification of the test procedures, and the
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`accessibility of EDR data by EMS responders. Specific comments are available for
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`review in Docket No. NHTSA-04-18029.
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`Meetings With Industry
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`After the comment period, the agency arranged meetings with Ford, GM, Toyota, and
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`Delphi to further discuss the EDR technology and cost issues. Memoranda documenting
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`these meetings are also contained in Docket No. HNTSA-04-18029. The agency gained
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`valuable knowledge and information on current/future EDR designs and their costs from
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`the participant companies.
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`I - 10
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`The Agency’s Response to Public Comments
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`The agency largely agrees with the commenters’ concerns related to the EDR technical
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`issues and cost estimates. After careful consideration of all the comments, the agency
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`acknowledges that the NPRM proposal would impose a much higher cost than estimated
`
`but it would still be significantly less than $150 per vehicle, as suggested by some of the
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`commenters. The manufacturers misinterpreted the NPRM proposed requirements for
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`survivability, which drove up their cost estimates substantially. Nevertheless, to ensure
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`the technology feasibility and to balance the cost and the safety needs, the agency has
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`decided to revise the requirements in this final rule. The revisions make the rule less
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`intrusive and burdensome, while maintaining the integrity of the data requirements and
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`usefulness to ACN, crash investigation, and advanced restraint system research and
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`development. Consequently, the cost estimate is revised accordingly in this FRE. Cost
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`related responses to public comments are summarized in Appendix A. In addition,
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`interested parties may consult the preamble of the final rule for a comprehensive analysis
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`of comments on the NPRM.
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`Organization of the Remaining Analysis
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`Chapter II of this FRE discusses the final rule requirements and it also lists the changes
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`between the NPRM proposal and final rule. Chapter III discusses the benefits of the final
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`rule. Chapter IV estimates the costs of the final rule and discusses leadtime. Finally,
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`Chapter V examines the impacts of the rule on small business entities. Appendix A
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`I - 11
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`details the agency responses to cost- related comments on the NPRM. Appendix B lists
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`the changes in data elements and their formats between the final rule and NPRM.
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`II - 1
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`CHAPTER II. REQUIREMENTS OF THE FINAL RULE
`
`This chapter discussed the requirements of the final rule. The final rule specifies
`
`requirements for voluntarily installed EDRs in light passenger vehicles. An EDR is
`
`defined as “a device or function in a vehicle that captures the vehicle’s dynamic, time-
`
`series data during the time period just prior to a crash event (e.g., vehicle speed vs. time)
`
`or during a crash event (e.g., delta-V vs. time), intended for retrieval after the crash
`
`event.” The recorded data does not include audio and video data. Light vehicles covered
`
`by the rule include passenger cars, multipurpose passenger vehicles, light trucks, and
`
`vans with a GVWR of 3,855 kilograms (8,500 pounds) or less and an unloaded vehicle
`
`weight of 2,495 kg (5,500 lbs) or less with the exception of walk-in type vans or vehicles
`
`that are designated to be sold exclusively to the U.S. Postal Service.
`
`For light vehicles equipped with an EDR, the final rule requires:
`
`1) EDRs to record 15 essential data elements with a standardized data format
`
`including sampling rate, recording time duration, range, accuracy, resolution, and
`
`filter class for each event,
`
`2) EDRs to record up to 30 additional data elements with a standardized data format
`
`(including sampling rate, recording time duration, range, accuracy, resolution, and
`
`filter class for each event), if the vehicle is equipped to record these elements3,
`
`3) EDRs to have the capacity to capture and record the required data elements for
`
`two events in a multi-event crash,
`
`3 “If recorded” means if the data are recorded in non-volatile memory for the purpose of subsequent
`downloading.
`
`(cid:50)(cid:58)(cid:49)(cid:40)(cid:53)(cid:3)(cid:40)(cid:91)(cid:17)(cid:3)(cid:21)(cid:19)(cid:19)(cid:22)(cid:15)(cid:3)(cid:83)(cid:68)(cid:74)(cid:72)(cid:3)(cid:20)(cid:26)
`
`

`

`II - 2
`
`4) EDRs to function during and after the full-scale vehicle crash tests specified in the
`
`FMVSS Nos. 208 and 214. The data elements must be retrievable for at least 10
`
`days after the crash tests,
`
`5) vehicle manufacturers to ensure the availability of download tools for the EDR
`
`dara, and
`
`6)
`
` vehicle manufacturers to include a standardized statement in the owner’s manual
`
`indicating that the vehicle is equipped with an EDR and describing the purposes
`
`of EDRs.
`
`Data Requirements
`
`The final rule requires a voluntarily installed EDR to record 15 essential data elements
`
`with specific formats including recording time, data range, sampling rate, accuracy,
`
`resolution, and filter type. These data elements and their format requirements are listed
`
`in Table II-1. In addition, the final rule requires up to 30 additional data elements to be
`
`recorded if the EDR-equipped vehicles already have on-board technologies to record
`
`these data for later download. Table II-2 lists these 30 additional data elements to be
`
`recorded under specified conditions along with their data formats. Twenty-eight of the
`
`30 additional data elements are required if vehicles were equipped to record these
`
`elements intended for downloading later. The remaining two data elements “Frontal air
`
`bag deployment, time to nth stage, driver” and “Frontal air bag deployment, time to nth
`
`stage, right front passenger” are required if vehicles were equipped with frontal air bags
`
`(cid:50)(cid:58)(cid:49)(cid:40)(cid:53)(cid:3)(cid:40)(cid:91)(cid:17)(cid:3)(cid:21)(cid:19)(cid:19)(cid:22)(cid:15)(cid:3)(cid:83)(cid:68)(cid:74)(cid:72)(cid:3)(cid:20)(cid:27)
`
`

`

`II - 3
`
`with a multi-stage inflator. An EDR is required to record these elements for up to two
`
`events in a multi-event crash.
`
`The following briefly explains the format requirements of the final rule. “Recording
`
`Time” specifies the duration of time relative to the time of crash (time zero) for which an
`
`EDR must record that specific data element. A negative time designation means pre-
`
`crash. “Range” specifies the possible responses of a particular data element. “Accuracy”
`
`specifies the magnitude that the recorded data can deviate from the laboratory test results.
`
`“Resolution” specifies the maximum allowable increment in measurement unit.
`
`For example, for delta-V, longitudinal (essential data element #1), the possible recorded
`
`response of this element is limited between –100 and 100 km/h. The recorded delta-V is
`
`allowed to deviate by a maximum of 5% from the laboratory test measurement. In a case
`
`of a laboratory measurement of 50 km/h, an EDR-recorded delta-V would be 50 + 2.5
`
`km/h. The 1 km/h resolution requirement allows recorded delta-V to be rounded to the
`
`nearest integer. For example, if the EDR measured the delta-V to be 50.7 km/h, the
`
`reported delta-V from the EDR would be 51 km/h.
`
`Data elements such as lateral, longitudinal, and normal accelerations have an additional
`
`filter specification. The time history data to measure these three elements are required to
`
`be filtered using an SAE J211 Class 60 filter. Several data elements are binary (i.e., the
`
`recorded response (or range) is yes/no or on/off). For these elements, occupant size
`
`classification determines the size of an occupant. For the driver side, “yes” means a
`
`(cid:50)(cid:58)(cid:49)(cid:40)(cid:53)(cid:3)(cid:40)(cid:91)(cid:17)(cid:3)(cid:21)(cid:19)(cid:19)(cid:22)(cid:15)(cid:3)(cid:83)(cid:68)(cid:74)(cid:72)(cid:3)(cid:20)(cid:28)
`
`

`

`II - 4
`
`small stature driver. For the front right passenger side, a “yes” indicates that the
`
`passenger is a child. Occupant position classification determines whether the specific
`
`occupant was out-of-position, and is recorded as “yes” indicating out-of-position.
`
`Table II-1
`Required Essential Data Elements and Formats
`Sampling
`Recording
`Time*
`Rate
`0 – 250 ms 100/s
`
`Data Elements
`Delta-V, Longitudinal
`
`Range Accuracy Resolution
`-100 to 100
`+ 5%
`1 km/h
`km/h
`-100 to 100
`km/h
`0 – 300 ms + 3 ms
`
`+ 5%
`
`1 km/h
`
`2.5 ms
`
`Speed, vehicle indicated
`
`Engine throttle, % full (accelerator pedal
`% full)
`Service brake, on/off
`
`-5.0 to 0 s 2/s
`
`-5.0 to 0 s 2/s
`
`-200 to 200
`km/h
`0 – 100%
`
`+ 1 km/h 1 km/h
`
`+ 5%
`
`1%
`
`-5.0 to 0 s 2/s
`
`On/off
`
`N.A.
`
`N.A.
`
`0 – 60,000 + 1 cycle 1 cycle
`
`0 – 60,000 + 1 cycle 1 cycle
`
`On/off
`
`On/off
`
`N.A.
`
`N.A.
`
`On/off
`
`On/off
`
`Maximum delta-V, Longitudinal
`
`0 – 300 ms N.A.
`
`Time, Maximum delta-V, Longitudinal 0 – 300 ms N.A.
`
`Ignition cycle, crash
`
`Ignition cycle, download
`
`Safety belt status, driver
`
`Frontal air bag warning lamp
`
`Frontal air bag deployment time, Driver
`(1st stage, in case of multi-stage air bags)
`Frontal air bag deployment time, RFP
`(1st stage, in case of multi-stage air bags)
`Multi-event, number of events (1 or 2)
`
`-1.0 s
`
`At time of
`download
`-1.0 s
`
`-1.0 s
`
`Event
`
`Event
`
`Event
`
`N.A.
`
`N.A.
`
`N.A.
`
`N.A.
`
`N.A.
`
`N.A.
`
`N.A.
`
`Item
`#
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`Time from event 1 to 2
`
`As needed N.A.
`
`0 - 5.0 s
`
`0 – 250 ms +2 ms
`
`0 – 250 ms +2 ms
`
`1, 2
`
`1 ms
`
`1 ms
`
`1, 2
`
`0.1 s
`
`Yes/no
`
`N.A.
`
`0.1 s
`
`N.A.
`
`15
`
`Complete file recorded (yes or no)
`
`N.A.
`
`Yes/no
`
`After Other
`Data
`s: second; ms: millisecond; km/h: kilometer per hour; RFP: right front passenger; N.A.: not applicable
`* Relative to time zero
`
`(cid:50)(cid:58)(cid:49)(cid:40)(cid:53)(cid:3)(cid:40)(cid:91)(cid:17)(cid:3)(cid:21)(cid:19)(cid:19)(cid:22)(cid:15)(cid:3)(cid:83)(cid:68)(cid:74)(cid:72)(cid:3)(cid:21)(cid:19)
`
`Filter
`N.A.
`
`N.A.
`
`N.A.
`
`N.A.
`
`N.A.
`
`N.A.
`
`N.A.
`
`N.A.
`
`N.A.
`
`N.A.
`
`N.A.
`
`N.A.
`
`N.A.
`
`N.A.
`
`N.A.
`
`

`

`Item
`#
`1
`
`2
`
`3
`
`4
`5
`6
`7
`8
`
`9
`10
`11
`
`12
`13
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`20
`21
`
`22
`
`Delta-V, Lateral
`Maximum delta-V, Lateral
`Time, maximum delta-V, Lateral
`Time, maximum delta-V, resultant
`Engine RPM
`
`0 – 250 ms 100/s
`0 – 300 ms N.A.
`0 – 300 ms N.A.
`0 – 300 ms N.A.
`-5.0 to 0 s 2/s
`
`Vehicle roll angle (degree)
`ABS activity
`
`-1.0 to 5 s 10/s
`-5.0 to 0 s 2/s
`-5.0 to 0 s 2/s.
`
`-5.0 to 0 s 2/s
`-1.0 s
`N.A.
`-1.0 s
`N.A.
`
`Event
`
`Event
`
`Event
`
`Event
`
`Event
`Event
`Event
`
`Event
`
`N.A.
`
`N.A.
`
`N.A.
`
`N.A.
`
`N.A.
`N.A.
`N.A.
`
`N.A.
`
`1 km/h
`(+) 100 km/h +5%
`1 km/h
`(+) 100 km/h +5%
`2.5 ms
`0 – 300 ms + 3 ms
`2.5 ms
`0 – 300 ms + 3 ms
`0 – 10,000
`+ 100 rpm

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