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Chronology of 1971 Roof…
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Created: Mon Sep 8 17:58:12 2008
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Chronology of 1971 Roof Strength Standard
33-Year Old Standard Does Not Provide Basic Crashworthiness
Protections for Occupants in Vehicles that Roll Over
September 2008
The auto industry and government have known about the deadly consequences of vehicle roof
crush since the at least the 1960s, yet have never upgraded the 1971 standard.
July 13, 1965 Both General Motors (GM) and Ford highlight the importance of roof strength
in rollovers in testimony before Congress.
April 13, 1966 GM engineering staff memo describes the company's plans to develop a
dynamic roof strength drop test from 5.5 feet.
Aug. 1, 1966 Ford test report describes dynamic roof crush "roof drop test."
Sept. 9, 1966 President Johnson signs the National Traffic and Motor Vehicle Safety Act.
Oct. 11, 1967 The National Highway Traffic Safety Administration (NHTSA)'s predecessor,
the National Traffic Safety Bureau (NTSB) issues an Advanced Notice of
Proposed Rulemaking (ANPRM) on 47 issues, including roof intrusion,
seeking public comment.
Jan. 6, 1971 NHTSA, formerly NTSB, issues a Notice of Proposed Rulemaking (NPRM)
on roof intrusion protection for passenger cars that would statically test both
front sections of the roof on passenger vehicles.
1971 NHTSA issues Federal Motor Vehicle Safety Standard (FMVSS) 208 with
optional dolly rollover test. Most companies use the dolly test internally, but
do not publish results.
April 1971 GM and the Automobile Manufacturers Association (which later became the
Alliance of Automobile Manufacturers) argued in comments to the docket that
testing both sides of the roof was unnecessary. It was later revealed in
litigation that GM had used NHTSA's two-section test on six of its production
model vehicles and that only one vehicle it tested passed. GM nevertheless
argued to NHTSA that only one side should be tested because the roof was
"symmetrical," in addition to pushing for other changes to weaken the test.
Moreover, GM withheld its test results from the agency.
Dec. 8, 1971 NHTSA issues a final rule establishing a roof crush standard for passenger
cars to take effect in 1973. The standard, which is virtually the same today as
in 1973, statically measures the result of pressure to only one side of the
vehicle's roof.
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March 22, 1973 The Center for Auto Safety petitions NHTSA to apply Federal Motor Vehicle
Safety Standards, including the roof crush standard, to light trucks and
multipurpose passenger vehicles (MPVs) with gross vehicle weight rating
(GVWR) of 10,000 pounds or less.
Sept. 1, 1973 Roof Crush Resistance Standard, FMVSS No. 216, takes effect for passenger
cars.
1974 NHTSA contracts with Minicars for development of a research safety vehicle
that protects occupants in serious rollover crashes at 40 miles per hour.
April 30, 1976 Engineer killed during accidental rollover at GM proving grounds during a tire
evaluation test. GM institutes a new policy requiring roll cages on all test
vehicles and all test drivers and test occupants to wear helmets.
April 17, 1991 NHTSA issues a final rule, effective Sept. 1, 1993, extending the application
of FMVSS 216, the existing roof crush resistance standard, to light trucks,
vans, buses and MPVs with GVWR of 6,000 pounds or less, specifically
declining to extend the standard to light trucks, vans, buses and MPVs with a
GVWR up to 10,000 pounds.
Dec. 18, 1991 The Intermodal Surface Transportation Efficiency Act (ISTEA) requires
application of passenger car safety standards to light trucks, vans, buses and
MPVs with GVWR of 6,000 pounds or less. ISTEA also requires issuance of
a standard to improve head impact protection from interior components (roof
rails, pillars and front headers) of passenger cars. ISTEA additionally directs
NHTSA to commence a rulemaking proceeding on a standard to prevent
rollover crashes.
Jan. 3, 1992 NHTSA issues an ANPRM to establish a rollover prevention standard, as
required by ISTEA.
Sept. 23, 1992 NHTSA releases Planning Document for Rollover Prevention and Injury
Mitigation listing alternative actions the agency could take to address the
rollover problem, including research into improved roof crush resistance to
prevent head and spinal injury.
Jan. 22, 1993 NHTSA delays by one year, until Sept. 1, 1994, the effective date for
application of FMVSS 216, the roof crush resistance standard, to light trucks,
vans, buses and MPVs with GVWR of 6,000 pounds or less.
Jun. 23, 1994 NHTSA terminates rulemaking on rollover prevention and stability standard.
In the notice of termination, the agency promises that it will instead address
factors involved in preventing rollover casualties, including roof strength
requirements.
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May 6, 1996 R. Ben Hogan, Smith and Alspaugh, PC, a law firm, petition NHTSA for
rulemaking and request that the agency require roll cages as standard
equipment on passenger cars.
Jan. 8, 1997 NHTSA grants petition requesting rulemaking to require roll cages.
April 27, 1999 FMVSS 216, the roof crush standard procedure, clarified the placement of the
test device to accommodate certain vehicles that have raise and/or highly
sloped roofs. This change in the standard did not address or upgrade
underlying roof crush testing and strength requirements.
Sept. 2000 In the wake of the expose of the Ford/Firestone rollover fatalities, the NHTSA
administrator states that the agency needs to improve roof crush safety
standard for rollover protection in testimony before Congress.
Oct. 22, 2001 NHTSA publishes a notice and request for comments on roof crush resistance,
describing the agency's roof crush research and testing as part of its rollover
protection program over the past 30 years.
2002 "Alternative Roof Crush Resistance Testing with Production and Reinforced
Roof Structures,"i paper discusses the feasibility of a dynamic roof crush test,
stating that "[t]he automotive industry and researchers have used drop testing
for years to evaluate roof strength." In the late 1960s, the Society of
Automotive Engineers (SAE) developed a standardized procedure to perform
full vehicle inverted drop tests. Many domestic and import auto
manufacturers have used the inverted drop test technique since the 1960s and
1970s to evaluate roof strength.
Apr. 2002 NHTSA publishes Characteristics of Fatal Rollover Crashes, which notes that
rollover crashes are more likely to be fatal than other crashes.ii
Sept. 17, 2002 NHTSA Administrator Jeffrey Runge states that roof crush intrusion
potentially contributes to serious or fatal injury in 26 percent of rollover
crashes.iii
Feb. 26, 2003 The Senate Commerce Committee holds a well-publicized hearing on SUV
safety where Senators, auto industry representatives, the NHTSA
administrator and spokespeople from consumer safety groups speak about the
problems of roof crush in SUV rollovers.
Mar. 3, 2003 The Detroit News series "Deadly Driving" highlights the failure of NHTSA to
upgrade its roof strength standard and cites NHTSA data indicating that 1,400
deaths and 2,300 serious injuries could be prevented if the standard were more
rigorous.
3
April 2003 NHTSA publishes Characteristics of Fatal Rollover Crashes and reports the
following:
Rollovers are more likely to result in fatalities than other crashes;
Rollovers constitute about one-fifth of all fatal crashes;
SUVs have the highest rollover fatality rate at 11.06 per 100,000
registered SUVs, followed by pickups at 7.52, vans at 4.09 and cars at
3.48 (for 1999).
June 2003 NHTSA issues Initiatives to Address the Mitigation of Vehicle Rollovers
reporting that rollover mitigation is one of its four major priority areas, but
proposing few concrete actions of deadlines. The other three priority areas
include vehicle compatibility, safety belt use and impaired drivers.
July 15, 2003 National Transportation Safety Board (NTSB) concludes roof crush
contributed to severity of driver injuries and diminished passenger survival
space in the Henrietta, Texas crash of a 15-passenger van that killed four
occupants and seriously injured eight others.
July 2003 NHTSA issues National Motor Vehicle Traffic Crash Injury and Fatality
Estimates: 2002 Annual Report, finding that rollover crashes accounted for 82
percent of the total fatality increase between 2001 and 2002. The report also
reveals that in 2002, 10,666 occupants were killed in rollovers one-third of
occupant highway deaths.
Nov. 25, 2004 NHTSA estimates that 1,339 serious or fatal injuries caused by roof crush
intrusion are suffered by belted occupants each year. NHTSA lists a proposed
rule to upgrade roof crush resistance as a possible 2004 action, and a final rule
as a possible 2005 action, in Vehicle Safety Rulemaking Priorities and
Supporting Research 2003-2006, with little description of the rule's possible
contents.
2003 Jan. Safety researchers at Xprts, in Goleta, California, conduct roof crush dynamic
2004 tests using the Jordan Rollover System (JRS) on Chevrolet Blazers, Chevrolet
Suburbans and Ford Explorers. During the JRS tests, a section of roadbed
surface moves forward along a track, while the vehicle is rotated on a spit.
The tests show that while the current static test measures only the weakness of
the roof, dynamic tests measure occupant injury, safety belt performance,
window glazing, side impact air bags, seatback strength, and door locks and
latches, in addition to roof strength.
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Feb. 12, 2004 Senate passes S. 1072, the Highway Funding Bill, which includes safety
provisions from S. 1978 that would require NHTSA to:
Issue a rollover crashworthiness standard by June 30, 2006, for
passenger vehicles under 10,000 pounds that will consider the
prescription of a dynamic roof strength standard that realistically
duplicates actual crash forces;
Consider improved seat structure and seat belt design (including belt
pretensioners), side impact head protection airbags and roof injury
protection measures.
Aug. 2005 Congress enacts the Safe, Accountable, Flexible, Efficient Transportation
Equity Act: A Legacy for Users (SAFETEA-LU), the federal surface
transportation bill. It includes vehicle safety mandates, including rollover
prevention, ejection mitigation and upgraded roof crush resistance for both
"driver and passenger sides," requiring the agency to evaluate dynamic testing
for the rollover protection rule.
Nov. 21, 2005 The comment period on NHTSA's proposal closes. The agency is widely
criticized by consumer safety advocates because it does not require two-sided
testing as mandated by the law, does not consider dynamic testing and does
not provide adequate information about occupant risk in rollover crashes.
Over 120 documents are submitted to the docket after the close of the
comment period.
Aug. 3, 2006 Public Citizen, Advocates for Highway and Auto Safety and the Center for
Auto Safety submit a joint letter asking for a change to respond to late
industry comments to the docket.
Dec. 13, 2006 Public Citizen, the Center for Auto Safety and the Center for Injury Research
present the results of dynamic rollover tests conducted on the JRS and
encourage the agency to revisit the roof crush proposal. In a letter to the
NHTSA administrator, these groups also requested that NHTSA publish a
supplemental notice of proposed rulemaking (SNPRM).
Feb. 23, 2007 Representatives from NHTSA travel to Goleta, California to see a test
conducted using the Jordan Rollover System (JRS).
Oct. 18, 2007 The Senate Commerce Committee holds an oversight hearing of the
Department of Transportation. The committee wants to know the progress on
the roof crush rulemaking. Transportation Secretary Mary Peters responded
that NHTSA would issue a supplemental notice related to "different types" of
roof strength testing than the agency had used previously.
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Jan. 30, 2008 NHTSA issues an SNPRM for the roof crush rule. The notice includes the
results of 26 two-sided static tests the agency conducted to assess whether
two-sided testing was advisable. NHTSA did not make a specific
recommendation for regulatory action, but requested comments about the use
of two-sided testing and whether it should use a 2.5 or a 3.0 strength-to-weight
ratio.
Mar. 27, 2008 End of formal comment period for 2008 SNPRM on roof crush resistance.
Jun. 6, 2008 A Subcommittee of the Senate Commerce Committee holds an oversight
hearing to investigate the implementation of the roof crush rulemaking,
particularly with respect to the agency's failure to consider dynamic testing,
and the preemption language.
Jul. 1, 2008 Transportation Secretary Peters sends a letter to the committees of
jurisdiction, requesting an extension from July 1, 2008 until Oct. 1, 2008 to
complete the roof crush rule, as permitted under SAFETEA-LU.
i
Herbst, B.; Forrest, S.; Meyer, S.; Hock, D. "Alternative Roof Crush Resistance Testing with Production and
Reinforced Roof Structures." SAE 2002-01-2076.
ii
NCSA, Characteristics of Fatal Rollover Crashes. DOT HS 809 438 (Apr. 2002), at 14, 20; See also "Registration
Data for 1975-2001."
iii
Runge, Jeffrey. Speech to the 3rd Motor Vehicle Safety Symposium, United Nations University, Tokyo, Japan,
Sept. 17, 2002.
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