NHTSA's Benefit Model in the Proposed FMVSS 216 Roof Strength Standard

As part of a comprehensive plan to reduce the risk of death and serious injury in rollover crashes, NHTSA has proposed upgrading the roof crush resistance standard, FMVSS 216. To evaluate the benefit of this proposal, the agency examined real-world data on injuries and fatalities that would be prevented by the proposed rulemaking. This paper provides a detailed discussion of the statistical and engineering approaches used to derive benefit estimates on fatalities calculated by NHTSA for the proposed upgrade. It concludes the NHTSA estimate of 13-44 lives saved annually is not reliable due to extreme sensitivity of the benefit calculation to the paucity of field data and questionable engineering assumptions.