NAS/TRB Committee For The Study Of A Motor Vehicle Rollover Rating System: Comments On Consumer Information Issues

NAS/TRB COMMITTEE FOR THE STUDY OF A
MOTOR VEHICLE ROLLOVER RATING SYSTEM

Comments on Consumer Information Issues

Presented by
R. David Pittle, Ph.D.
Senior Vice-President & Technical Director
Consumers Union
April 11, 2001

INTRODUCTION

On behalf of Consumers Union (CU), we want to express our appreciation for the opportunity to address the Committee on the difficult questions presently before it. CU is the nation's leading independent, non-profit product testing organization. Consumer Reports magazine and its companion website, Consumer Reports Online, have approximately 4.5 million monthly subscribers.

Based on our decades of automotive testing experience, we recognize that the issues are complex and that, unfortunately, there may not yet be a single test that answers perfectly all of the questions that could conceivably be raised regarding rollover. However, the consuming public has an urgent need for progress in this vital safety area. Progress in designing tests that empowers consumers to select vehicles that are less likely to roll over, even if not perfect or total, must be made so that lives can be saved and serious injuries lessened each year.

You have heard the representatives from NHTSA describe their history with developing methods to evaluate rollover propensity and presenting that information to consumers. In keeping with the agenda, we would like to present here our views on two aspects of the task before you: 1) effective ways to provide safety information to consumers and 2) the appropriateness of using SSF as the sole measure of rollover propensity. Tomorrow, we will offer our opinion on the critical elements of dynamic testing and on alternatives to SSF.

As a starting point, we all agree that the factors affecting automobile crashes and related injuries are numerous, including vehicle design, the presence of vehicle safety features, driver behavior, road conditions, weather conditions, the behavior of other motorists, and the time of day. We are all focused on crash avoidance and injury prevention-i.e., focused on how to reduce the likelihood of having a crash or being injured in a crash, in light of what is technologically and economically feasible. With such a focus, we have a good chance of making progress in reducing the 10,000 deaths that occur annually from rollover.

From our reading of the congressional mandate, this committee's charge deals primarily with vehicle design and safety features. For essential guidance here, we turn to page one of the NAS report titled Shopping for Safety:

"The dominance of the human factor in crash causation does not diminish the important effect of vehicle design and safety features on crash likelihood or, in particular, on crash outcomes. Drivers cannot change their age or control the driving behavior of others, but they can decide which vehicle to buy and attempt to select the safest vehicle that will meet their needs and minimize crash likelihood and injury potential."

CONSUMERS WANT AUTO SAFETY INFORMATION

Consumers Union has been an independent evaluator of consumer products, including automobiles, for more than 65 years. As many of you may already know, we accept no gifts, grants, test samples, or anything else of value from any commercial entity. We are supported almost entirely by the sale of our publications to consumers. We buy all the products we test on the open market anonymously at retail with cash. For our next auto test program, we will spend over $1 million for the purchase of some 40 new motor vehicles.

Whether we are testing cars, lawnmowers, electric heaters, or baby cribs, our focus includes how the product will perform when used in the same manner the consumer is likely to use it. Our engineers and scientists, each expert in their own special area of product evaluation, use existing tests developed both by industry and by government as well as tests developed within CU's laboratories. Our goal is to evaluate product performance, reliability, value, and safety.

We place a high priority on product safety-and so do our readers. From their mail and our subscriber surveys, we have learned that they have a deep concern for their personal safety and the safety of their families. That concern ranges from food safety to toy safety to auto safety. Indeed, one of the most frequent questions we receive from our subscribers is "What is the safest car?"

And our subscribers are not atypical. For example, a 1998 Harris survey reported that 62 percent of those polled said they would find information about a vehicle's likelihood of rolling over in a crash to be "highly useful." (27% said "somewhat useful". Only 9% said "not very useful at all.")

Not only would information comparing rollover propensity be useful for improving the efficacy of individual consumer choice, CU also believes that providing such information on rollover risk would likely stimulate improved vehicle design-as has happened with NCAP crash testing-and thereby help reduce the numbers of injuries and fatalities.

The manner in which safety information is presented is of great importance. If I may quote from Shopping for Safety once more:

"To be most effective, consumer information should be based on a systematic understanding of what consumers know about vehicle safety and how they go about obtaining and using information in making automobile purchase decisions. …

"Once the context and content of the information are more clearly defined, determining how best to communicate and disseminate it is also a matter of empirical study. Information is likely to be considered if it is simple to acquire and use and is provided at the appropriate time. … early in the process-not just at the point of sale."

I have brought copies of the April issue of Consumer Reports, which is our annual auto issue. It illustrates our latest and best thinking on how to communicate complex auto information in a form that is easily and quickly grasped by the reader. Over the years, we have learned that part or all of the message can be lost if the effort required "to get it" is too burdensome. We have learned that graphical presentations can be immensely successful, especially when they are direct and focused. We have learned that too much text or too much information can lead to "MEGO (Mine Eyes Glaze Over)." We have learned that multi-faceted or layered messages that require interpretation can be frustrating to the reader-the simplest possible overall assessment is often the most useful.

PROVIDING CONSUMER INFORMATION THROUGH NCAP

NHTSA's New Car Assessment Program (NCAP) currently enjoys great popularity and use with the car-buying public. The NCAP website gets some one million hits per year. The frontal- and side-crash information NHTSA currently provides through NCAP meets an important need. As it has in the past, CU continues to support the NCAP program and the information it provides to consumers. But we had hoped that through the NCAP program, consumers at this point in history would be able to get comparative information about rollover based on government-sponsored dynamic rollover testing, in the same way they are able to get access via the Internet to crash testing information.

PROVIDING INFORMATION AT POINT OF PURCHASE

In addition to NHTSA's valuable NCAP program, CU would like to see an expansion of the availability of NCAP program that would allow consumers to get access to information beyond the agency's website. We see no reason why that information should not also be provided at the places consumers buy their cars. It seems needlessly restrictive, in our view, to argue that the labeling of vehicles "with one safety attribute to the exclusion of others may be misleading"-especially within a program intended to provide consumer information. The best way to address this concern, we think, is for NHTSA to require that all NCAP information, including frontal and side-crash testing scores-and someday soon rollover propensity-be available in some manner at point-of-sale, say in brochures and on window stickers.

Referring again to Shopping for Safety, which recommended point-of-sale safety information, based on surveys that asked consumers what kinds of car safety information they would find most useful.

"… Because of the amount of information already provided on vehicle window stickers-price, fuel economy, vehicle features-a separate label is desirable for all vehicle safety-related information. It may be necessary to display the summary safety information in some other prominent location because of limitations on window space for some vehicles and concerns about visibility in driving test vehicles. An accompanying brochure would contain more detailed explanation of the summary measures, the assumptions used in their calculation, and their key components such as vehicle size and weight. A handbook would provide complete comparisons among vehicles. These materials should be developed, tested and refined with groups of typical users."

Currently, many consumers can go on line and access NCAP information. But what about less computer-savvy or lower income consumers who don't have or cannot afford internet access? They are effectively denied this fundamental safety information because the information is not made available at point-of-sale or at some other readily accessible place.

The fact that NHTSA's NCAP section receives so much consumer traffic tells us that much important safety information is disseminated through NHTSA's website. But we would strongly urge that NTHSA require manufacturers to include the rollover safety information in a clear manner at point-of-sale, as well, and to include other NCAP safety information at the same time.

CU's CONTINUING CONCERN ABOUT VEHICLE ROLLOVER

I would like now to summarize our views on NHTSA's use of SSF as a measure of vehicle stability. CU has been providing consumers with information about emergency handling since 1973 when it developed a double lane change avoidance-maneuver test. CU has made emergency handling tests a regular part of every new vehicle's test program, evaluating well over 1,000 vehicles since 1973.

CU has had a long and continuing concern about vehicle stability. More recently, CU petitioned NHTSA in 1996 to commence the development of a dynamic test that would produce meaningful comparative data on the emergency-handling characteristics of different makes and models of SUVs. CU also asked NHTSA to make the information from that test readily available to consumers. As we have done consistently, we noted in our petition that we focused on SUV stability because, as a class, SUVs are less stable than conventional passenger cars and exhibit a greater involvement in rollover crashes.

In 1997, NHTSA's press release announcing the granting of CU's petition, called CU a "welcome partner," and noted that CU has "focused the public's attention on rollover and provided a wealth of consumer information to the car-buying public." In granting CU's petition, NHTSA promised to concentrate on whether it could develop a "practicable, repeatable and appropriate dynamic emergency handling test that assesses, among other issues, a vehicle's propensity for involvement in an on-road, untripped rollover crash."

NHTSA commenced research to develop a dynamic test program, and indeed, published interim results indicating the progress of their work in the Federal Register. NHTSA's decision last year to use Static Stability Factor as the basis for the long awaited consumer information program about rollover was a surprise. There is no doubt about the important roles that track width and center of gravity height play in rollover stability. All other things being equal, a vehicle with a wider track and a lower center of gravity should be more stable and less likely to tip up or roll over in both untripped and tripped emergencies. But, as a general rule, all other things are not equal, whether comparing vehicles within a class or between classes. If two vehicles have similar dimensions-or even similar ratios of dimensions-they will receive the same SSF score. Yet, the design and performance of such critical systems as the suspension system are not accounted for. Below we have cited some of the benefits of dynamic testing, and some of the shortcomings we see with using SSF as the sole measure of rollover propensity:

· Dynamic testing would evaluate the whole vehicle's performance as a complete system, which integrates many more important and critical variables than simply track width and center of gravity height.
· Dynamic testing better reflects the stability of the specific vehicle in real-world driving situations.
· Dynamic testing takes into account the slip angle and the vehicle's suspension, which an index or static formula cannot.
· Dynamic testing effectively evaluates the tires and suspension systems in transitional maneuvers. As NHTSA recently learned during the Bridgestone/Firestone recall, tires can play a substantial role in a vehicle's rollover propensity.
· Dynamic testing rewards active stability control systems that help prevent the vehicle from getting into a situation where it can more easily roll over. These systems are found currently in some luxury vehicles, but are likely to be standard equipment in many more vehicles in the future, as demonstrated by Toyota, which made these systems standard or optional on all of its SUVs except the RAV4.

Problems with SSF

· SSF includes only two factors on the vehicle: center of gravity and track width, T/2H (H being height above the ground of center of gravity and T being the track width).
· SSF doesn't take into account the tires or suspension system on the vehicle.
· SSF alone doesn't adequately reflect performance in real world driving maneuvers.
· SSF does not take into account the new stability control systems technology in some vehicles currently that is intended to prevent rollover.
· SSF is too coarse a measurement to accurately differentiate between vehicles within the same class.

In summary, based on our current knowledge, we believe using SSF alone could actually put misinformation into the hands of consumers. However, while we strongly believe that SSF is not sufficiently strong to stand alone as a comparative measure, we do believe that SSF could be useful as an adjunct to or an integral component of an overall assessment that included one or more dynamic handling tests.

We look forward to your questions. Thank you again for the opportunity to share our views with you.

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