Statement on New Rule Improving Child Passenger Safety and Proposed Rule on the Operation of Event Data Recorders (EDR)

  • June 22, 2022
150 150 Advocates for Highway and Auto Safety
CONTACT: Pete Daniels / / 301-442-2249 (C)


Statement of Cathy Chase, President, Advocates for Highway and Auto Safety (Advocates), on New Rule Improving Child Passenger Safety and Proposed Rule on the Operation of Event Data Recorders (EDR)


Today the National Highway Traffic Safety Administration (NHTSA) took the commendable steps of issuing a Final Rule on side impact protection for children seated in child restraints and a Notice of Proposed Rulemaking (NPRM) on the operation of event data recorders (EDR), devices that provide invaluable information about motor vehicle crashes.  Advocates for Highway and Auto Safety (Advocates) urges the agency to continue working to address the existing backlog of overdue congressionally mandated vehicle safety rules and move forward expeditiously on vehicle safety directives in the Infrastructure Investment and Jobs Act (IIJA, Pub. L. 117-58).

Child Passenger Safety Seat Testing
Motor vehicle crashes are among the leading causes of death for children aged one to 14, according to the Centers for Disease Control and Prevention (CDC).  One thousand three hundred seventy-nine (1,379) children age 16 and younger were killed in crashes in 2021, a six percent increase from the previous year.  An estimated 139,042 children age 14 and younger were injured in traffic crashes in 2020, the most recent year for which data is available.

Front and side impact crashes account for most child occupant fatalities.  Side impacts affecting the passenger area are especially dangerous because of a lack of energy-absorbing structures compared to front or rear-end crashes.

NHTSA’s final rule, which was required in the Moving Ahead for Progress in the 21st Century Act (MAP-21, Pub. L. 112-141) and due six years ago, would make our most vulnerable passengers safer by adding a side impact test using child-sized anthropomorphic test devices, also referred to as crash test dummies.  However, the rule only applies to child seats designed for children weighing up to 40 pounds or up to 43.3 inches tall.  Previously, child restraints were only tested in a frontal crash scenario.

According to NHTSA, the rule will save nearly four lives and prevent 41 injuries each year and will produce net economic benefits of $145 million – $162 million per year.  Advocates’ analysis of this rule is ongoing, and we urge NHTSA to ensure that this Final Rule is not the final word on efforts to better protect all child passengers.

Event Data Recorders (EDR)
EDRs installed in motor vehicles record technical vehicle and occupant information for a brief period of time before, during and after crashes.  NHTSA’s NPRM on EDRs requires 20 seconds of pre-crash data to be collected at a rate of 10 samples per second.  This would be an improvement over the existing rule, which requires data collection five seconds prior to a crash at a rate of two samples per second.

Unlike Europe,* vehicles in the U.S. are not required to be equipped with EDRs, despite a recommendation by the National Transportation Safety Board (NTSB) that dates back more than three decades.  Most vehicles sold in the U.S. today have EDRs, but they are not providing enough information about crashes.  The insufficient requirement regarding voluntarily installed EDRs does not ensure that important facts about vehicle performance and crashes are collected.

Advocates lauds NHTSA Administrator Dr. Steven Cliff and his team for these safety steps forward and continues to urge additional action on proven lifesaving solutions including advanced driver assistance systems (ADAS), impaired driving prevention technology and pediatric “hot car” detection and alert technology in new vehicles.  With crash deaths skyrocketing over the last two years and 100 people being killed on our nation’s roads every day, there is no time to spare.

* The regulation requiring EDRs in Europe begins taking effect in July.


Advocates for Highway and Auto Safety is an alliance of consumer, medical, public health, law enforcement and safety groups and insurance companies and agents working together to make America’s roads safer.  Advocates’ mission is the adoption of federal and state laws, policies and programs that prevent motor vehicle crashes, save lives, reduce injuries, and contain costs.