If you wonder what some of us do we do when not teaching, here is an example of a letter just sent off to NHTSA-DOT regarding side impact protection.

If you agree with my response, please respond to the questions which must be rec'd in Washington by 11/16/00. I realize this is short notice, I rec'd them only two days ago, I feel this is an important issue for all responders.

By using EPG, it will give the responder more options at a crash and my reduce the over time it will take to perform an extrication.

You will not have the glass beads to hamper or cause soft tissue injury, while laminated glass does produce fragments, the overall benifits out weight the negative which is far less than the tempered glass seen on most side and rear windows. Roll it down, leave it in place or remove a required. Think about it, if you didn't have to remove the glass would it save time, injury from cuts, please respond!

This is something you all can help to improve the way we perform extrication. Now is the time to stand up and be counted, it only takes a few minutes to copy and print some of my text if you choose not to write your own letter.

Regards,
Ron Shaw


Send your replies to:

Docket Management
Docket Number NHTSA-2000-7066
Room PL-401
400 Seventh Street, SW
Washington, DC 20590


Extrication.Com
Vehicle Extrication Specialists
19 Baldwin Circle
Plymouth, MA 02360 USA
http:/www.extrication.com

Ronald E. Shaw, Fire Service Instructor
Phone: 508.747.0860
Fax: 508.747.7975
Email: rshaw@extrication.com


Dear Sir or Madam:

This letter is in response to your questionnaire regarding Federal Register/Vol. 65, No. 139. Docket No. NHTSA-2000-7066

In response to the following public questions, which I feel appropriate for a emergency responder to answer:

3.) Are there any know disadvantages of encapsulation and modified doorframe design in vehicles with inflatable side impact air bags?

As with any airbag designed, no hard product should come between the rescuer or patient and the active airbag. If a responder were to cut a hole through a laminated glass, then position a limb or other body part through the opening and an accidental deployment of the side impact curtain or other supplemental restraint device should occur, as a result of extrication process, a severe injury may result. This can be regardless of the type glazing material installed.

However, this could be prevented through proper training or the use of a pyrotechnic battery cable cutter or similar device disabling the supplemental restraint system currently being developed by the airbag manufacturers. The same hazard exists now with a partially open window made out of tempered safety glass. Should a responder position a body part; head, hand arms or torso through the opening and an accidental deployment occur, a severe injury could occur with the current glazing material.

There is no greater hazard with laminated or enhanced protective glass (EPG) as compared to tempered safety glass. The overwhelming advantage with regards to extrication considerations out weighs any disadvantage, which already exists with the current glazing available from the automobile industry.

4.) Are there any known safety disadvantages of the encapsulation of glazing and modified door frame design such as entrapment?

At this point in time, the only known disadvantage is lack of responder awareness for patient access due to the dissimilar proprieties of laminated glass or polycarbonate glazing. Responders attempting to gain patient access during the glass removal phase of extrication may be confused using normal techniques commonly practiced with tempered safety glass. Common techniques used on tempered safety glass, will not work with a laminated or polycarbonate window.

However, that is not to say that the responder cannot accomplish quick and efficient removal of the glazing. Proper training showing the responders how to identify, cope and adjust techniques for glazing removal will resolve any confusion while confronting the new types of glazing.

The key point in extrication is the delay of patient care, while it may be quicker to clear a window made of tempered safety glass, there are more disadvantages with this process. Such as, when tempered glass is broken, hundreds of sharp glass pellets shattering into the occupant cabin, which may cut both the patient and rescue personnel causing soft tissue injuries. With EPG and polycarbonate, there is less fragments if any, and the rescuer may elect to leave the glazing in place. Which common practice is to remove tempered glass under control breakage prevent soft tissue injures. For an example, injuries to the eyes of patient or the unsuspecting rescuer should the glass break while displacing metal body parts such as a door.

Leaving the glass in tact in a stationary window can add stability for a vehicle inverted. Movable windows can simply be rolled down or left in place, this alone will can save critical minutes by reducing the pre-hospital time.

11.) Are side head airbags an alternative solution of reducing occupant ejection out of a window?

In this given text, I would have to say no, only in conjunction with worn seatbelts do side impact airbags offer protection in a rollover situation. This is according to any published information by the industry including data available on the NHTSA web site or handout material.

12.) Would side head airbags provide any benefits that would not be derived from by advance glazing?

Due to the nature of a crash, there are always situations where the side impact protection will not deploy. A vehicle can have a secondary crash or side impact and not activate the deployment of the side impact airbags. The occupant(s) could be thrown forward or to the side with out deployment of the side impact airbags. The use of both supplemental restraint system (SRS) and the new glazing offers the optimum occupant protection.

There may be a situation where neither restraint will be of value, such as if the crash did not fall into the parameters of the sensor activation or if the windows were to be rolled down. However, with two safety features installed in a vehicle one passive (glazing) the other active (SRS), there is an increased safety protection and less chance of occupants being injured.


13.) What benefits would advanced glazings offer that would not be derived from side head air bags?

The windshield is considered to be the primary restraint within a vehicle, not the seatbelts, not the supplemental restraint system. Why then is laminated or polycarbonate side window glazing not considered to be a primary restraint for side impact protection? Would it be because tempered safety glass will shatter, EPG and polycarbonate window glazings will not.

Rollover tests have shown that polycarbonate glazing does not break or release under the most severe conditions. EPG has the exact properties that laminated windshield glazing has. If this is true, why then would this new form of side window glazing not be considered a primary restraint device during side impact protection. As stated before, there are always situations where neither product will function during a crash, however in conjunction with both glazings and SRS, the industry will provide the best occupant protection.

15.) Should the agency be working on both the advanced glazing and inflatable head restraint systems as viable, complementary technologies to solve the window ejection problem.

Yes, I personally feel that improved occupant safety should be the goal of the industry. However, while improving safety within the vehicle, the industry should also consider the millions of emergency responders who perform extrications. Development and testing should also include extrication specialists in the fire service to render their expertise to increase safety to the responder and at the same time improve techniques to patient access.

One of the greatest disadvantages to the emergency responder is the lack of knowledge of new safety products/hazards prior to the introduction on the streets. This can cause delay, injury and possible death to those that we try to rescue or that of our own. If the industry as a whole will not volunteer to work with extrication specialists, perhaps the federal government should.

Enclosed with my response is a copy of a recent submission that will be published in Fire Engineering Magazine, a periodical targeted for chief officers, training officers and instructors within the fire service. This should help to support my response to your questions. I was also involved in a fire service field test to evaluate the responder effectiveness while performing the glass breaking phase of patient access during an extrication. The tests were performed at the Indian Orchard facilities of the Solutia Company, West Springfield MA. Documentation of the tests is included in this packet in the form of a videotape. Please feel free to contact me with any concerns or questions on this matter.

Regards,


Ronald E. Shaw


RES



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Ron Shaw
http://www.extrication.com