On January 15, 2004, CAS petitioned the National Highway Traffic Safety Administration to reconsider a final rule issued December 1, 2003, regarding Federal Motor Vehicle Safety Standard No. 301, "Fuel Systems Integrity." The CAS petition cited a number of inadequacies in the new rule, and made recommendations for changes that would truly protect occupants from fire-related trauma. In the petition, CAS noted the following:
1. Though the new rule is commonly referred to as an "upgrade" of the current standard, the rule’s test procedures are pitifully insufficient. In fact, they are so poorly formulated that General Motors’ C/K pickup passes muster, even though it is the motor vehicle responsible for the most fire-related crash deaths in history.
2. The rule is based on inadequate data regarding the number of fatalities caused by fire crashes, and does not appropriately take into account the social and economic impacts of burn injuries, excluding and dismissing the benefits that a reduction in these incidents would represent.
3. Test regimens that would significantly strengthen FMVSS 301 have been extensively researched and developed, and if implemented would represent a true upgrade of the standard.
4. CAS stressed that the fuel system integrity goal of NHTSA and the industry should be to match occupant survival from crash forces with occupant survival from fire, i.e. if an occupant survives the trauma of a crash, he or she should not die by fire.
Click here to read the CAS Petition for Reconsideration
Click here to view the petition in .pdf format.