"A massive government bureaucracy has come into being, most of it of a low order of efficiency, much of it given to harassment of the citizenry." —Daniel P. Moynihan
Prof. Moynihan's comment occurred more than five years prior to the passage of the monolithic National Traffic and Motor Vehicle Safety Act of 1966. But enactment of this bill, and the vehicle safety standards which quickly followed, gave new meaning to the terms "harassment" and "bureaucracy." Since the Act's passage 10 years ago, over 50 vehicle design standards have been issued, in the government's never-ending drive to crash-proof the automobile. The feds claim the resulting automobile is safer than its pre-Washington counterpart, but on what basis, no one is sure. In reality, only a handful of the 50 standards are of any net benefit.
One of these standards looms large, not for its life-saving contribution, but for typifying that "…low order of efficiency," we have come to expect from massive government bureaucracies. Standard 215 on Exterior Protection—"crash bumpers"—is destined to become the biggest bust in the history of the automobile.
Standard 215—Exterior Protection—Passenger Cars, with Inclusion on 214 Side Door Strength, and 216 Roof Crush Resistance
Standard 215 stands as the ultimate example of gross government inefficiency, special interest meddling, and wasted resources. It has already cost billions of dollars and will continue to plague vehicle owners with residual expenses for years to come. Although this standard was conceived during the early 1970s' gasoline shortages and was issued at the height of the energy crisis, it continues to be enforced with full knowledge that it contributes to increased fuel consumption! As if this were not enough, the bumpers themselves are virtually ineffective in their intended function.
We must distinguish here between two basic types of highway crash losses and their countermeasures:
1. Primary highway losses are those associated with injuries and fatalities. These are the central focus of the Federal Motor Vehicle Safety Standards (FMVSS), authorized by the Federal Motor Vehicle Safety Act of 1966.
2. Secondary highway losses are purely economic in nature, and result from property damage.
Although vehicle damage can occur at all collision speeds, the safety/collision damage interface is generally accepted as 10 mph. Occupant injuries rarely occur below this speed. Standard 215, since it is part of the FMVSS, can regulate only vehicle components that affect safety. Thus it was ostensibly designed only to protect "safety related systems" in low-speed impacts.
Yet another bill dealing with auto safety features was given life by Congress six years later: The Motor Vehicle Information and Cost Savings Act of 1972. This law deals specifically with the second category of crash loss—damageability. As a result, we have two laws dealing concurrently with the same item, crash bumpers, from different directions: Standard 215 relating to crash safety and the 1972 law pertaining to property damage.
Two titles of the 1972 Act deal specifically with damageability:
• Title 1, effective after 1973, directs the Secretary of Transportation to promulgate a bumper performance standard with "no damage" requirements. This puts the Department of Transportation (DOT) in the property loss business, and effectively in the employ of the Insurance Institute for Highway Safety (IIHS), a powerful Washington lobby.
• Title 2, which ran from 1973 through 1975, required a feasibility study of vehicle crashworthiness, damage susceptibility, and repairability, with the information made available to the general public. Calculations of differences in insurance costs were specifically required.
The impetus for all this federal activity emanated from—you guessed it—the insurance lobby. Since the 1969 model year the IIHS has crash tested certain vehicles into barriers and other cars in various configurations. Extensive repair cost data were eventually developed from these tests and utilized to "substantiate" condemnation of the automobile industry for "making cars more fragile." IIHS failed to mention what this fragility was being compared with.
After thorough analysis of the IIHS data, a Society of Automotive Engineers research team completely refuted this allegation. The 1973 SAE report concluded, "No constant repair cost trends are apparent.…Therefore, despite the high cost of repairs, it certainly does not appear that the manufacturers were guilty of designing increasingly fragile vehicles."
Unfortunately, though, the allegation had been made, the groundwork was carefully laid, and the mandate was devised on a multiple framework. The public, not yet exposed to the seatbelt interlock, was unaware of the tightening noose, and the bills became law with little protest. The SAE study was not undertaken until the following year, and when released, it did not receive mass exposure. Thus, the unwary consumer became ensnared by yet another costly federal experiment.
Standard 215 was devised with the intent that passenger cars be made to withstand "specified low speed impacts at the front and rear without damage to lighting, fuel, exhaust, cooling or latching systems." To meet this requirement, a vehicle must be built to withstand a laboratory test, in which a specially constructed pendulum hits both bumpers. In the pendulum test, which is repeated three times, a precisely configured block is used as a striker with the requirement that only a particular projecting ridge on the block may contact the vehicle. This is the primary reason for the strange shapes of the bumpers you've seen on recent model cars.
The National Highway Traffic Safety Administration (NHTSA) implemented the standard in two phases. Phase I, starting with the 1973 model year, utilized only a fixed barrier test, to allow manufacturers some leeway on bumper configuration. Speed of impact into the barrier was established by NHTSA at 5 mph front and 2-1/2 mph rear. Phase II upgraded the requirement to pendulum tests at 5 mph front and 4 mph rear, effective with the 1974 cars. A later amendment increased the rear impact to 5 mph on 1975 and later models and added corner protection to 3 mph in 1976.
From the beginning, the intent of the standard was twofold:
1. To require bumpers to withstand specified impacts front and rear, for the protection "of safety related systems." 2. To standardize the height of bumpers of all passenger cars, to assure alignment and prevent override or underride. This was intended to minimize the likelihood of damage.
To this end the legislation preempted the manufacturer's option on the design height of bumpers. Henceforth, bumpers would be standardized to a height of 16 to 20 inches from the ground surface, NHTSA initially established the height range as between 14 and 20 inches. This meant that the point of pendulum impact was, at their option, anywhere between these limits. Since the manufacturers were uncertain where the test impact would be made, they would have been forced to design a six-inch high bumper that could withstand the impact at any point along its face. After massive company protests, NHTSA reconsidered and reduced the range to four inches. Without this modification, bumpers would now weight about 200 lbs. more than their present overweight.
Even the four-inch range played havoc with the design of sports cars and other limited production vehicles, whose bumpers had always been an integral part of the vehicle design—often a continuation of the aerodynamic shape of the front of the vehicle. Sports car makers were forced to hang on ugly, bulky, heavy frames that not only clashed with the car's aesthetics, but added excess weight at its extreme ends. Cars that were previously lightweight vehicles suddenly became 10 percent heavier at their extreme ends! This change in weight distribution reduces the vehicle's inherent dynamic stability. This reduces its road-holding characteristics, the very factors which contribute to accident avoidance.
Since two entirely separate bodies of legislation now control bumper configuration, it is unclear whether the new bumper is intended to meet safety or economic needs. Perhaps it is intended to address both. Unfortunately, as we shall see, these are not totally compatible goals.
The Cost of Crashes
In considering the issue of vehicle damageability and cost, it appears that NHTSA ignored real-world data. A recent study of over 50,000 insurance collision claims by the Auto Club of Southern California (ACSC) found that higher speed collision claims (over $250 damage) accounted for not only 57.5 percent of claim volume, but 89.6 percent of the insured costs! A major automotive concern reached essentially the same conclusion. They studied 8.58 million front-end crashes and concluded that 83.4 percent of the dollars are paid out for collisions above the protection range of not only the present, but any proposed new bumper system!
In other words, 80 to 90 percent of collision repair costs are incurred in crashes over the protective limit of current bumpers. Simply from an economic standpoint, how can these devices have a significant effect on vehicle damage reduction, when, even if functioning properly, they can influence only 10 percent of collision costs?
The insurance lobby emphasizes that, in return for the "slight additional cost" of crash bumpers, the consumer will reap the benefits of collision premium discounts on cars that meet the 1973 and later bumper standards. This has taken place in some instances, with savings typically being about 10 percent. In 1973 ACSC calculated the so-called savings to the consumer:
If we consider the incremental costs of the 1973 bumper system to be $50 and the average collision insurance premium to be $60 (typical for California) with a 10 percent annual discount allowed, assuming a 10 year vehicle life, the net savings to the vehicle owner [over its life] would be $10.
The ACSC's figures are quite conservative. Upgrading of the standard and subsequent inflation have brought the incremental cost of crash bumpers closer to $200. At this rate it would take over 33 years to recoup the additional cost in premium discounts!
Congress also overlooked the residual costs of crash bumpers. In any collision over the speeds for which they are intended, the bumper will be destroyed. The device, with all its associated hardware, will then have to be replaced. Repair manual figures show that these costs will be radically higher than for earlier models. Replacement part prices for the front bumpers of 1973 domestic automobiles averaged 43 percent more than those of 1971 models. And installation time increased 29 percent. Later models and the added effect of inflation have escalated these figures.
With these kinds of increases are the insurance companies likely to continue offering collision premium discounts? ACSC doesn't think so. In their view, "…the entire increased cost of replacement will have to be assumed by insurance companies because total damage in these cases will exceed the average $100 deductible applied to collision insurance. Therefore, if a significant number of new vehicles are involved in collisions at higher speeds and they require replacement of the costly new bumper systems, insurers may be hard pressed to justify increases in collision premium discounts for the upcoming improved bumper systems."
It comes as no surprise that the current movement among insurance carriers is to eliminate the $100 deductible coverage and make $200 the minimum deductible. This is a move to reduce the pressure that the insurance lobby itself created! And guess who eventually absorbs the cost? But read on—the worst is yet to come!
So what if it costs us a few billion dollars. It's all worth it for safety, right? Maybe, but the reality is that the new bumpers have made a very poor showing here, also. It should be emphasized that Standard 215, Exterior Protection—Passenger Cars, was originally devised to eliminate damage to safety-related systems in low-speed impacts. Only with the passage of the 1972 Act did Congress add the economic constraint through damageability limits.
Recall that bumpers are tested in the NHTSA laboratory using a pendulum with the vehicle in the static position. The standard sets bumper height between 16 and 20 inches from ground level to assure alignment and thereby minimize the likelihood of bumper mismatch, NHTSA itself recognized that mismatch can detract from bumper effectiveness. Mismatch is caused by the front of the vehicle diving and the rear of the vehicle elevating during deceleration. The vehicle is "pitched" in what is commonly referred to as "brake dive." But vehicle dynamics are totally ignored in the standard. Bumpers are tested only in the static position, as though they existed in complete isolation. This is to be expected; if the dynamic factors were considered, the standard, as such, could not exist!
The effect of vehicle dynamics has been studied by the Engineering and Technical Service Div ion of ACSC. In a 1974 SAE research paper, they presented the results of tests performed on 39 1974 model cars that fully complied with Standard 215.
ACSC engineers attached a height measuring device to each bumper. The tests were performed on various paved, relatively flat surfaces, measuring bumper heights with the vehicles at rest, and then braked from 5 to 0 mph. With both vehicles at rest, mismatch was essentially zero. When the rear vehicle was braked from 5 to 0 mph and the front one was at rest, mismatch reached 21 percent. The real revelation occurred when both front and rear vehicles were braked from 5 to 0 mph as happens in many emergencies. Under these conditions, completely within the range of the standard, bumper mismatch was 97 percent! This means that out of 1520 tests, 1474 resulted in either over- or underride.
Was safety improved by the mandate of Standard 215? After considering the test results, the researchers concluded the following:
Pending publication of compliance test results (by NHTSA), it may be assumed that safety-related items listed by the standard are protected. However, the vehicle dynamic pitch in the braking mode described in the results of this paper may be sufficient to allow a colliding vehicle front bumper to contact the vulnerable "underbelly" gas tank area. Therefore, in collisions at speeds higher than the requirements of FMVSS 215, the recognized underride/override effect will occur. When this happens, the main load bearing/energy absorbing structure of the vehicles can be mismatched, providing the condition for gross penetration of the vehicle envelope.
Bumper mismatch also causes other safety problems, one of which is non-activation of the upcoming air cushion restraints (which depend on a bumper-mounted actuator). Seven vehicles equipped with air bags were included in the study. Five of the seven showed complete bumper mismatch, and the remaining two mismatched with approximately 50 percent of all others when both were being braked. The researchers were impressed enough by this deficiency to state, "This mismatch of bumpers could cause non-inflation—or delay inflation of air bags and increase occupant injury risk especially in the absence of the availability of active restraint [seat belt] systems. (Emphasis added)
Further safety problems have been traced to Standard 215. To begin with, the bumpers are considerably heavier than conventional ones, intensifying high-speed collisions through the addition of sheer weight. The heavier the vehicle, the more energy there is to manage in a collision.
Other internal vehicle systems have been found to suffer damage as a result of collision tests, ACSC subjected a modified 1972 Ford to barrier impacts at successively greater speeds until the vehicle sustained damage. This occurred at 8.2 mph. There was no evidence of exterior sheet metal or trim damage, but, on further examination, both front and rear engine mounts revealed extensive cracking. Also, the energy-absorbing steering column was displaced sufficiently to require replacement! So much for protection of safety-related systems and property damage.
Other shortcomings are more mundane. The complex bumper systems require service and maintenance, which add more upkeep expenses to the consumer burden. Some systems have experienced leakage of hydraulic fluid.
Standard 215—so straightforward and simple on the surface—is actually far-reaching in its effects. They are merely "safety" bumpers, says NHTSA, but these cumbersome, weighty items not only contribute nothing to safety but in some way affect every facet of vehicle performance. Some experts are even convinced that the bumpers can contribute to occupant injury.
In early 1971 the Center for Auto Safety and the Ford Motor Company, in response to a notice of proposed rulemaking, petitioned NHTSA on the subject of increased occupant acceleration as a result of the standard on impact bumpers, NHTSA, in its classically omnipotent style, avoided the queries with: "Although review of the available information does not indicate that occupant accelerations will be significantly increased in vehicles conforming to the standard, the NHTSA is aware of the issue and will consider further rulemaking on the subject if subsequent data reveals a problem." Not surprisingly, data on this problem were never published.
What Ford and the Center for Auto Safety were talking about involves the placement of the bumpers and their relationship to vehicle crash characteristics. As a result of auto crash tests performed for many years at UCLA and other test facilities, much is known about how vehicle structures deform during a crash. Using this information, manufacturers have learned to design their vehicles with "progressive crush" characteristics both front and rear, to protect the occupants during collisions. The body structure at both ends collapses gradually, thereby itself absorbing the energy of the impact while the passenger enclosure remains intact.
But rigid impact bumpers interfere with the progressive crush action in otherwise well-designed safety vehicles. The bumpers, by design, extend several inches beyond the front and rear extremities and thus present the initial point of contact with the colliding vehicle. Although some of the bumpers are mounted on hydraulic devices, these are essentially unyielding up to and somewhat beyond their design impact range.
Thus the initial impact in low speed collisions is with a rigid front, since the device must by design protect lamps, including headlights, hood, trunk, doors, fuel, cooling and exhaust systems, propulsion, suspension, steering, and braking mechanisms. In collisions above 5 mph, for which the sophisticated progressive crash pattern becomes effective, first contact is the same rigid device. Rather than compressing gradually, and absorbing the impact energy, the initial effect is extreme acceleration of occupants. This dangerous shifting of passengers takes place before the crush zones can begin to yield and cushion the impact. The crash bumpers effectively cancel out much of the higher speed safety which vehicle crush dynamics provide.
The list of negatives associated with these monstrous devices seems endless. Not only are they ugly, ineffective, and costly, but their added weight creates its own chain reaction of dysfunctional attributes. General Motors confirms that the federally mandated bumpers alone add approximately 250 lbs. to the weight of a full-sized Chevrolet and 150 lbs. to a compact Vega.
Added weight, especially excess and unnecessary poundage, generates vehicle changes that are generally unknown to the consumer. When gross weight is increased, demands are placed on every supportive vehicle system. Brakes, steering, and suspension components must all be strengthened to compensate for the added loads. In a never ending cycle, the strengthening itself generates new demands through its own weight increases, once again raising gross weight! General Motors research shows that a direct increase of 100 lbs. can easily generate 100 lbs. of additional changes to maintain the performance, function, and durability of all other car components. Is it any wonder that the curb weight of a typical mid-size American passenger car of the mid-1960's increased from 3600 to 4400 lbs. or over 22 percent, during the past decade of federal intervention in highway safety?
Increased weight worsens handling, and deteriorates acceleration and passing ability which reduce the margin of safety in overtaking and highway maneuvers. Safety experts have for years recognized pick-up and passing capability as extremely valuable for the vehicle's "active" safety. The federal government has long required that this information be provided in the original vehicle owner's manual. Unfortunately, they have also been contributing to its deterioration.
A typical mid-size vehicle of the sixties could accelerate to 60 mph in around seven seconds. Today, the same size vehicle takes at least 13 seconds. To be sure, some of this loss is due to ever-tightening emission standards, but excess vehicle weight due to bumper standards has claimed its share.
One means of salvaging performance is to increase engine size. Unfortunately, the substitution of a larger engine where there was once a smaller one introduces a whole new set of problems. One is the old bugaboo, weight, again. A 450 cubic inch displacement engine weighs about 150 lbs. more than a 350 cubic inch powerplant, installed with all related accessories. The never ending cycle of weight-begets-more-weight begins again. The larger engine requires a heavier suspension drive train, and related components, which adds even more weight. What began as a 100 lb. addition may end up adding 400 to 500 lbs. A larger engine itself contributes its own share to increased fuel consumption.
We come now to what may be the single most damaging effect of the past decade of federal meddling in vehicle design. By placing demands on auto makers for the inclusion of "safety" devices which have added appreciably to vehicle weight, our own government increased the seriousness of the "energy crisis." The combination of radical increases in weight and ever-tightening emission standards led to progressively greater fuel consumption in an era that might otherwise have witnessed much dedication to energy conservation! From all evidence, the government's auto safety program was totally uncoordinated with its energy program.
The American automobile makers have performed considerable research on auto energy consumption. General Motors recently published a paper outlining how these various factors interrelate. One of the principal factors contributing to increased fuel consumption is increased vehicle weight. The paper analyzed a recent Chevrolet Impala as a typical example of the effects of the FMVSS on vehicle weight.
The three vehicle standards which contribute most to overall weight increase are 214, 215, and 216: side door strength, exterior protection (crash bumpers), and roof crush resistance. Together, these three standards add approximately 490 lbs. to the weight of a full-size car. The recently mandated air bags will join as the fourth major offender, adding approximately 110 lbs. more, GM states that for every 100 lbs. of vehicle weight, seven gallons of fuel are consumed per 10,000 miles. However, this increase does not account for the fact that as vehicle weight increases, acceleration performance suffers, GM researchers have performed extensive fuel consumption studies, and maintain that, "Valid comparisons of fuel economy potential can only be made between cars with equal performance. For a given car design, regaining acceleration performance always causes a sacrifice of fuel economy." To regain this lost performance, engine size or rear axle ratio must be changed, which nearly doubles the fuel consumption penalty to a level of 16 gallons per 100 lbs. of car weight per 10,000 miles driven!
This is, unfortunately, not the end of the overweight cycle. As previously stated, a direct increase of 100 lbs. can easily generate 100 lbs. of additional changes to maintain performance, function, and durability of all other car components. "This magnifies the significance of each pound added and makes the fuel consumption penalty grow to 32 gallons per car year (10,000 miles) for each 100 lbs. of direct weight added."
The three principal safety standards have already added approximately 500 lbs. to the weight of full-size cars and 400 to compacts. At this rate 760 million additional gallons of gasoline were burned for each of the first four years these standards have been effective, or 3.1 billion gallons through 1976. In other words, motorists have burned 3.1 billion gallons more gasoline at a cost of approximately $2.1 billion to satisfy the federal government's demands for impact bumpers, door beams and rollover protection, whose contribution to safety is marginal at best! Even more significant is the fact that no change in any of these standards is planned by any government agency. The manufacturers are now having to spend hundreds of millions of dollars down-sizing their cars, in order to reduce excessive weight and fuel consumption.
IIHS Wins Again
In January 1975, apparently recognizing its mistake in making overly stringent demands in Standard 215, NHTSA proposed reducing the bumper test speeds from the present 5 mph barrier and pendulum requirements to 2-1/2 mph for 1976, 1977, and 1978 models, with damage allowed only to the bumper system, NHTSA, enthusiastically supported by the US auto industry, contended that the costs of the protective bumpers were greater than the consequential savings to car owners. But two months later, under heavy pressure from the Insurance Institute for Highway Safety, NHTSA revoked their January proposal. The IIHS conjured up some impressive statistics to support their trick case, which was essentially that damage-repair costs on later model cars are significantly reduced over pre-crash bumper models. Obviously, no data were presented on the endless lists of problems created by the standard: added weight, reduced performance, more maintenance, increased fuel consumption, and radically higher costs for parts and repair resulting from high-speed collisions.
Once again, the government was purchased by the highest bidder, and the consumer takes the boot. That the IIHS data bear little resemblance to reality is firmly supported by a General Motors statement in response to the federal action: "According to GM studies, the series of barrier and pendulum impact tests, conducted in a laboratory environment, bears little relationship to the wide range of accidents that occur in the real world."
Recently, there have been outcries over the rapid escalation in the cost of crash parts—fenders, doors, bumpers and grilles. The insurance lobby has made its usual accusations of the automobile industry, charging that the big four artificially support the high cost with their unique distribution system. The costs have risen so fast that auto theft, for the sole purpose of parts salvage, has become a billion dollar underworld business.
In typical fashion, IIHS refuses to examine its own house first. Standard 215 for impact protection grew out of the FMVSS interpreted by NHTSA. However, the push to strengthen the requirements to ridiculous limits came from the insurance lobby, through the Motor Vehicle Information and Cost Savings Act of 1972. This act mandated no damage beyond the bumper, and had little if any, relationship to vehicular safety. The entire motivation was provided by the auto insurance companies to reduce their escalating claims costs. Now that they have had their way, they are once again crying for help, and pointing the finger at everyone but themselves. It's amazing to find the auto insurers surprised that complex, heavy bumpers are more expensive to replace and repair than the older "flimsy" ones. It is high time that this lobby, with its apparently unlimited power, be forced to live with the consequences of its own creations.
The impact bumper remains a monument to inefficiency, waste, shortsightedness, and lack of planning by special interest groups bent on meddling, not only in the workings of private industry, but in the everyday activities of the public. The impact bumper is a clumsy, ugly device foisted on the public at the insistence of the automobile insurance lobby under the guise of consumer savings.
The true effect, as always, has been just the reverse. It costs the motorist additional premium dollars because it is complex and expensive to repair. The added repair costs from high-speed crashes will far outweigh the meager savings in reduced premiums, should these in fact ever materialize. Impact bumpers provide few, if any, safety benefits, and waste precious fuel. To say the least, they are a bust.
Once again, the consumer has been victimized in the name of consumer protection. By imposing its safety ideas on everyone, the government has thwarted the market mechanism and produced a billion-dollar boondoggle. How many more examples will it take before our Washington benefactors realize that the best protection they can offer consumers is to leave them free to make their own choices?
Jack Solomon holds engineering and business degrees from UCLA and USC, and works as a management systems consultant. This article Is adapted from his forthcoming book, The Billion Dollar Bumper Bust, and is a copyright © 1978 by the author.