IIHS comment to NHTSA concerning backover crashes

May 1, 2009 Stephen R. Kratzke Associate Administrator for Rulemaking National Highway Traffic Safety Administration 1200 New Jersey Avenue, SE, West Building Washington, DC 20590 Advance Notice of Proposed Rulemaking; 49 CFR Part 571 Federal Motor Vehicle Safety Standards, Rearview Mirrors; Docket No. NHTSA-2009-0041 Dear Mr. Kratzke: The Insurance Institute for Highway Safety (IIHS) welcomes the opportunity to comment on the National Highway Traffic Safety Administration’s (NHTSA) advance notice of proposed rulemaking (ANPRM) regarding modification of Federal Motor Vehicle Safety Standard 111 Rearview Mirrors to address the problem of backover crashes. IIHS agrees with NHTSA that the magnitude of the problem — 228 deaths and 17,000 injuries caused by passenger vehicle backover crashes every year — justifies an appropriate response from the agency. Although these numbers are a small percentage of the overall problem of motor vehicle crash injuries, they frequently are especially tragic due to familial involvement, and they seem largely preventable by techniques that enhance driver awareness of objects to the rear of a vehicle. In general, IIHS supports NHTSA’s proposed strategy of specifying a minimum blind spot area, including a minimum distance from the rear of a vehicle that must be visible to the driver either directly or with the aid of mirrors or other vision aids. We have the following additional comments addressing specific ...