IIHS comment to NHTSA concerning NASS CDS

July 1, 2009 Ronald Medford Acting Deputy Administrator National Highway Traffic Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 Notice and Request for Comments; Reports, Forms, and Record Keeping Requirements; Agency Information Collection Activity Under OMB Review; Docket No. NHTSA-2009-0106 Dear Acting Deputy Administrator Medford: The Insurance Institute for Highway Safety (IIHS) welcomes the opportunity to comment on the National Highway Traffic Safety Administration’s (NHTSA) notice regarding the information collection program known as the National Automotive Sampling System/Crashworthiness Data System (NASS/CDS). IIHS fully supports NHTSA’s efforts to use NASS/CDS to collect meaningful data, but we also believe it is necessary to expand the scope of data collection, ensure the accuracy and completeness of the information collected, and add new information that currently is not collected. Therefore, IIHS will address specifically NHTSA’s request for comments on ways to enhance the quality, utility, and clarity of the information collected by NASS/CDS. Because NASS/CDS data are critical to understanding crash problems, NHTSA should increase the number of crashes being investigated. Originally scheduled to involve teams investigating an estimated 18,000 crashes at 75 locations, NASS/CDS currently only investigates about 5,000 crashes at 24 locations. This number is inadequate due to the ...