The Center for Auto Safety is the nation’s premier independent, member driven, non-profit consumer advocacy organization dedicated to improving vehicle safety, quality, and fuel economy on behalf of all drivers, passengers, and pedestrians.




March 7, 2007


 The Center for Auto Safety (CAS) strongly supports effective consumer information programs on auto safety as our cooperative rescue with Jack Gillis of The Car Book shows.  As the most popular consumer publication ever issued by the Federal government, the National Highway Traffic Safety Administration (NHTSA) should consider republishing this invaluable guide to buying a safe new car if it could distribute it as effectively as it did in 1980. 

There are two crucial issues in consumer information — (1) what is effective and useful consumer information and (2) how to get it to the consumer user.  For the consumer who buys and uses a car, i.e., the user of NHTSA’s consumer information, there are two components to NHTSA’s consumer information program.  First, there is information used for buying a safer new vehicle.  Second, there is the information used by the consumer to buy a safer used vehicle and for safe operation of the vehicle.  To date, NHTSA’s programs have concentrated more on the former than the latter. Although NHTSA has a great deal of information on vehicle defects and used car safety which is greatly sought by the driving public, NHTSA has not given any real attention to how to get this information out beyond the safety defect recall notices required under the National Traffic and Motor Vehicle Safety Act. Even those have been watered down in recent years as NHTSA has let auto companies substitute Service Campaigns, Technical Service Bulletins and Geographic Recalls for national safety recalls subject to all the full requirements of the National Traffic and Motor Vehicle Safety Act and implementing regulations including civil fines and criminal penalties.

 Safety Information No Substitute for Safety Standards:  To be effective, consumer information cannot be a substitute for safety standards but must supplement them. The New Car Assessment Program (NCAP) works because it is coupled to a standard (FMVSS 208) which provides a safety floor which all vehicles must meet. NCAP provides a safety elevator which consumers can use to buy cars that are safer than the minimum standard requires.  Manufacturers who wish to succeed in the marketplace produce safer cars and are rewarded with greater sales.  The NCAP safety elevator has resulted in significant safety improvements in cars but these improvements would not have occurred without the baseline standard.

 Safety Information at Point of Sale & On the Vehicle:  Consumer advocates have long stressed the need to require crashworthiness ratings placed on windows as are gas mileage ratings. Point of sale information must be on every new model the moment it hits the showroom floor.To accomplish this, NHTSA must take a page from the U.S. Environmental Protection Agency (EPA) which requires auto companies to test vehicles for both emissions and fuel economy in advance of the model year with gas mileage ratings posted on the every new vehicle as they are sold. EPA does confirmatory testing to ensure that the auto companies do not cheat on the testing.  NHTSA could and should do the same thing with NCAP ratings for vehicles. To supplement the NCAP ratings, NHTSA should post fatality rates based on FARS on its website as an indicator of how specific makes and models perform in the real world. Such information cannot be required for all new models because there may not be adequate vehicle use exposure on which to base ratings.

Present NCAP Ratings Not Effective or Even Fully Implemented: The present star system is outdated and does not adequately distinguish between vehicles on safety performance. NHTSA measures leg and neck injury criteria in its crash tests but does not use them in the NCAP ratings. The agency should do so beginning with the 2007 model year.

Too many models are clustered at the top in a form of starflation, Moreover the vehicles that do get less than four stars do not convey how poor their performance is. Due to star ratings in other areas such as hotels and restaurants, consumers accept one star as acceptable and three stars as pretty good. The ratings should use an A to F rating system to better reflect that the top is very good and the bottom is very bad. The severity of the test should be increased to eliminate starflation and separate the super star safety cars from the not so super star safety cars.  As an immediately feasible first step, the frontal barrier crash test speed should be increased to 40 mph. The side impact test should be run with a 500 pound heavier moving barrier that is at least 3 inches higher to simulate the heavier and higher light trucks on the road today.

Other Tests: New NCAP ratings are badly needed for other safety areas including:

Roof crush Over 10,000 occupants die in rollover crashes every year, up from about 3,000 occupants in the early 1970’s. Occupant deaths in other crash modes have decreased from about 40,000 to about 23,000 per year.  Weak roofs cause at least 27,000 deaths and serious injuries each year by crushing in on occupants and by breaking windows/windshields and distorting their frames to create portals of ejection. Some vehicles such as the Volvo XC90 have strong roofs that dramatically reduce casualties in rollovers but no consumer can tell which vehicles have strong roofs without an upgraded safety standard and an NCAP rating system.

 Far Side Impact Many serious injuries occur to occupants on the far side of a vehicle in a near side impact.  Although NHTSA has an NCAP rating for near side occupant injuries in a near side impact, it has no rating for injury to occupants on the far side.  It needs to develop not only a far side NCAP injury rating but also a far side injury standard.

Bumpers Weak bumpers cost consumers billions of dollars each year in low speed impacts that should cause no damage to the vehicle or bumper itself. When NHTSA rolled back the 5 mph no-damage bumper in 1982, the agency promised to issue a bumper rating system so consumers could find and buy vehicles with stronger bumpers. Twenty-five years later, the public is still waiting for NHTSA to issue a bumper rating system. A quarter of a century is long enough to wait bumper ratings should be put into NCAP.

Pedestrian protection Four to five thousand pedestrians are killed each year yet some manufacturers like Honda have designed pedestrian protection into their vehicles but again there is no rating to tell the consumer which are the pedestrian friendly vehicles.

Rear Impact Seat backs collapse in rear impacts and occupants in the very last row of seats are subject to lethal impacts from intruding vehicles. Yet there is no effective standard to prevent deaths and injuries in rear impacts or NCAP rating to enable consumers to buy vehicles that are more protective in such collisions. 

Head Restraints  The Insurance Institute for Highway Safety has demonstrated there most vehicle do not have good head restraints to protect against whiplash and other injuries. NHTSA could readily test head restraints for their protective ability in rear impact tests.

Aggressivity Consumers care not only about how well their vehicle protects them in crashes but also how well their vehicle does in not injuring occupants of other vehicles in crashes. Every time NHTSA runs a front barrier crash, load cells in the barrier collect data on the force and point of impact that could and should be incorporated into an NCAP aggressivity rating.

NHTSA can learn from its own history of how consumer information and labels alone have not worked.  In 1981, rather than recall 23 million cars and trucks with faulty transmissions Ford sent out warning labels and cautions to owners about the hazards of its automatic transmissions jumping out of "Park" and instructing owners to make sure they turned off their engines, applied the parking brake and took the key out of the ignition after shifting into Park. If anything, the fatality rate increased after the warning labels were sent out. In the rollover area, NHTSA issued a regulation in 1982 that required warning labels on utility vehicles and information in the owner’s manual on their rollover hazards yet this consumer information did not stem the tide of rollover fatalities.

Defect Investigation and Recall Information: NHTSA has expressed an interest in the notice on this hearing on combining recall and crash test information. Presently NHTSA’s website has significant information on safety recalls, defect investigations, Technical Service Bulletin and consumer complaints.  Unfortunately the NHTSA data base is in a total state of disarray  under the make Ford, NHTSA has 237 models with 41 different listings for the Ford F-Series models alone.  Information on a  Ford F-250 Super Duty could be listed under F Series, F-Series, F Super Duty, F-Super Duty Chassis, F-250SD, F-250 Super Duty, F250 Superduty, or F250 Super Duty. To make sure a consumer finds all recalls, investigations, TSBs and complaints, a consumer would have to check every single F-250 Super Duty permutation on the website.  CAS spent countless hours of creating a model sieve to channel the many, many thousands of make/model permutations into the real world model it represent into a vehicle dossier search function on our Website at If NHTSA wants to convey meaningful consumer information through a unified rating system, it has a huge, but necessary task ahead of it.

Beginning in 1995 with the infamous Chrysler tailgate latch defect that resulted in at least 40 deaths, NHTSA accepted Service Campaigns as Safety Recalls even though Service Campaigns are not subject to the provisions of the National Traffic and Motor Vehicle Safety Act or the regulations enacted there under. In many cases, Defect Investigations are opened based on an existing Service Campaign or a Technical Service Bulletin. Sometimes, they are closed based on a Service Campaign or a Technical Service Bulletin (TSB) issued during the investigation. Unlike Safety Recalls or Safety Improvement Campaign, NHTSA does not uniformly provide copies of such documents on its Website. Unless the consumer gets access to the Service Campaign or TSB, the consumer will often not get the repair set forward in the Service Campaign or TSB.

CAS has found that NHTSA has no policy in place to ensure that TSBs or Service Campaigns that are used to justify opening or closing an investigation are placed on the agency’s website. The following are but a few examples of where this has occurred.

EA05-008 (1998-04 Sonoma/S-10 Pickup Tailgate Cable) GM conducted a special policy program, but program details and TSB are not posted on NHTSA’s website.

PE05-053 (2002-03 Mini-Cooper Airbag Warning Light)  BMW agreed to extend existing warranty, investigation was opened and closed based on TSBs, neither of which are posted on NHTSA’s website.

PE05-059 (2002-03 Hyundai Sonata Tire Valve Stem)  Closing of this investigation was based upon Michelin issuing a TSB and TSB is not posted on NHTSA’s website. 

PE05-063 (2005 GM Terraza, Uplander, Montana, Saturn Relay Wiring Harness) Opening and closing of this investigation were based upon GM issuing TSBs, neither of which are posted on NHTSA’s website.

PE05-066 (2003-05 Ford Ranger/Mazda Truck Brake Light Failure)  Investigation was opened based upon both Mazda and Ford issuing TSBs, neither of which are posted on NHTSA’s website.

If NHTSA wants to expand its consumer information program to adequately cover Defect Investigations which result in recalls or which are closed because the manufacturer has issued a TSB or a Service Campaign, then the agency must publish TSBs and Service Campaign on its website arranged by make and model exactly in the same make and model terminology as used in the NCAP crash ratings.