Pedestrian Safety: NHTSA Needs to Decide Whether to Include Pedestrian Safety Tests in Its New Car Assessment Program

In 2018, about 6,300 pedestrians—17 per day—died in collisions with motor vehicles in the United States, up from about 4,400 in 2008. Many factors influence pedestrian fatalities, including driver and pedestrian behavior. Vehicle characteristics are also a factor. NHTSA tests and rates new vehicles for safety and reports the results to the public through its NCAP. Currently, pedestrian safety tests are not included in NCAP.

This report examines: (1) what is known about the relationship between vehicle characteristics and pedestrian fatalities and injuries, (2) approaches automakers have taken to address pedestrian safety, and (3) actions NHTSA has taken to assess whether pedestrian safety tests should be included in NCAP. GAO analyzed data on pedestrian fatalities and injuries from 2008 through 2018 (the most recent available data); reviewed NHTSA reports; and interviewed NHTSA officials. GAO also obtained information about pedestrian safety features from 13 automakers that represented about 70 percent of new vehicle sales in the United States in 2018, and compared NHTSA's actions with leading program management practices.

National Highway Traffic Safety Administration (NHTSA) data show that certain vehicle characteristics related to age, body type, and the speed of the vehicle at the time of the crash are associated with increases in pedestrian fatalities from 2008 to 2018. Specifically, the number of pedestrian fatalities during this time period increased more for crashes involving vehicles that were:

11 years old or older compared to newer vehicles,

sport utility vehicles compared to other passenger vehicles, and

traveling over 30 miles per hour compared to vehicles traveling at lower speeds.

GAO also found that NHTSA does not consistently collect detailed data on the type and severity of pedestrian injuries, but began a pilot program in 2018 to improve its data collection efforts. NHTSA, however, lacks an evaluation plan with criteria to assess whether to expand the pilot program, as called for in leading practices. As a result, NHTSA lacks information to determine how and whether it should expand the pilot to meet the agency's data needs.

Automakers offer a range of approaches to address pedestrian safety. For example, pedestrian crash avoidance technologies use cameras or radar to detect an imminent crash with a pedestrian and engage a vehicle's brakes to avoid a crash. GAO found that about 60 percent of the model year 2019 vehicles offered in the United States by 13 automakers had pedestrian crash avoidance technologies as standard or optional equipment.

In 2015 NHTSA proposed pedestrian safety tests for its New Car Assessment Program (NCAP), but NHTSA has not decided whether it will include such tests in the program. NHTSA has reported that crash avoidance technologies could lead to a decrease in pedestrian fatalities. Nine automakers that GAO interviewed reported that NHTSA's lack of communication about pedestrian safety tests creates challenges for new product development. NHTSA has also not documented a clear process for updating NCAP with milestones for decisions. NHTSA officials said that updating NCAP involves many actions and can take years. However, absent a final decision on whether to include pedestrian safety tests in NCAP and a documented process for making such decisions, the public lacks clarity on NHTSA's efforts to address safety risks.

GAO is recommending that NHTSA (1) develop an evaluation plan with criteria for expanding its pilot program, (2) make and communicate a decision about whether to include pedestrian safety tests in NCAP, and (3) document the process for making changes to NCAP. The Department of Transportation concurred with our recommendations.

The number of pedestrians killed annually in motor vehicle crashes in the  United States has increased from about 4,400 in 2008 to almost 6,300 in  2018—a roughly 43 percent increase. On average, 17 pedestrians a day  died in motor vehicle crashes in 2018, up from 12 a day in 2008. At the  same time, overall fatalities on the nation’s roadways have generally been  decreasing. Many factors can affect pedestrian fatalities and injuries,  including driver and pedestrian behavior, distraction, and roadway and  vehicle design. U.S. Department of Transportation (DOT) officials told us  vehicle size class is also a contributing factor, and an increasing share of  sport utility vehicles (SUVs) in the U.S. vehicle fleet may be responsible  for some of the increases in pedestrian fatalities. For example, in May  2018 the Insurance Institute for Highway Safety (IIHS), an independent  nonprofit scientific and educational organization sponsored by the auto  insurance industry, reported that pedestrian fatalities associated with  SUVs had increased substantially in recent years and that crashes are  increasingly more likely to involve SUVs and higher horsepower  vehicles.

The National Highway Traffic Safety Administration (NHTSA) within DOT  is the federal agency responsible for motor vehicle policy, regulation, and  safety enforcement. The agency’s mission is to save lives, prevent  injuries, and reduce the economic costs associated with road traffic  crashes; NHTSA seeks to accomplish this mission through education,  research, safety standards, and enforcement activity. NHTSA’s New Car  Assessment Program (NCAP) provides consumers with comparative  information on the safety of new vehicles to assist in vehicle purchasing  decisions and NCAP encourages motor vehicle manufacturers to make  vehicle safety improvements through testing and rating of new vehicles.

You asked that we review issues related to pedestrian safety and motor  vehicles. This report: (1) Examines what is known about the relationship  between motor vehicles’ characteristics and pedestrian fatalities and  injuries; (2) Describes approaches automakers have taken to address  pedestrian safety and discusses stakeholder perspectives on these  approaches; and (3) Evaluates actions NHTSA has taken to assess  whether pedestrian safety testing should be incorporated into the NCAP.

To examine what is known about the relationship between motor vehicles’  characteristics and pedestrian fatalities and injuries, we analyzed data  from three NHTSA databases for the period of 2008 through 2018 (the  most recent complete year of data at the time of our review). These  include: (1) Fatality Analysis Reporting System (FARS); (2) Crash Report  Sampling Systems (CRSS); and (3) National Automotive Sampling  System/General Estimates System (NASS/GES). FARS data are derived  from a census of fatal motor vehicle traffic crashes within the 50 states,  Puerto Rico, and the District of Columbia. CRSS is a sample of police- reported motor vehicle crashes that involve all types of motor vehicles,  pedestrians, and cyclists and that is used to develop national estimates of  the number of injuries associated with motor vehicle crashes, among  other things. NASS/GES preceded CRSS and similarly obtained its data  from a nationally representative probability sample of police accident  reports. Additional information about these databases is included in  appendix I. We interviewed NHTSA officials about pedestrian safety data.  We also interviewed selected academic researchers with expertise in  human-vehicle interaction and selected automakers about pedestrian  safety and data needs. We discuss the selection of automakers below.  We reviewed documents related to a pilot program NHTSA recently  initiated to assess data collection for pedestrian injuries and discussed  this program with NHTSA officials. We assessed this program using  criteria for designing successful pilot programs developed in prior GAO  work.

To describe how automakers are addressing pedestrian safety and to  discuss stakeholder perspectives on these approaches, we obtained  information from 13 automakers that sold vehicles in the United States.  The 13 automakers represented about 70 percent of new vehicles sold in  the United States in 2018. We used a semi-structured interview format to  obtain information from the 13 automakers about the pedestrian safety  features included on their model year 2019 vehicles sold in the United  States and the benefits and challenges of these features. We did not  assess the effectiveness of these features. Results of these interviews  are not generalizable to the universe of automakers that may sell vehicles  in the United States. We also interviewed representatives of five  companies identified by an auto industry trade association that supply  pedestrian safety related equipment, as well as officials from auto  industry trade associations, and NHTSA. Finally, we reviewed relevant  federal motor vehicle regulations related to pedestrian safety.

To evaluate NHTSA’s actions related to pedestrian safety and NCAP, we  reviewed applicable federal laws and regulations, requests for comments  published in the Federal Register on proposed NCAP changes, and  NHTSA NCAP program documents. We reviewed studies and  presentations on NHTSA’s work related to pedestrian safety, including  potential pedestrian safety tests and their applicability to the U.S. vehicle  fleet, the use of various test tools, and the potential safety effects  associated with technologies intended to avoid crashes with pedestrians.  We also visited NHTSA’s Vehicle Research and Test Center in East  Liberty, Ohio, and the IIHS Vehicle Research Center in Ruckersville,  Virginia, and interviewed NHTSA and IIHS officials, respectively, at those  locations. Further, we interviewed NHTSA officials about NHTSA’s  process for making changes to NCAP and communicating decisions to  stakeholders. We also interviewed the automakers and auto industry  equipment suppliers discussed above, and IIHS officials about  incorporating pedestrian safety tests into NCAP. We evaluated NHTSA’s  process for deciding whether to make changes to NCAP using practices  in the Project Management Institute, Inc., The Standard for Program  Management, and GAO’s Standards for Internal Control in the Federal  Government. Appendix I provides a detailed discussion of our scope and  methodology.

We conducted our work from February 2019 to April 2020 in accordance  with generally accepted government auditing standards. Those standards  require that we plan and perform the audit to obtain sufficient, appropriate  evidence to provide a reasonable basis for our findings and conclusions  based on our audit objectives. We believe that the evidence obtained  provides a reasonable basis for our findings and conclusions based on  our audit objectives.

Since 2008, both the number of pedestrian fatalities and the share of  pedestrian fatalities as a percentage of overall highway fatalities have  increased (see fig. 1). In 2008, pedestrian fatalities represented about 12  percent of overall highway fatalities, while in 2018 they represented about  17 percent. In addition to fatalities, the estimated number of pedestrians  injured in crashes has increased from about 71,000 in 2008 to about  79,800 in 2018.

A range of factors can influence pedestrian fatalities including exposure of  pedestrians to crashes, roadway characteristics, and driver and  pedestrian behavior. According to DOT officials, there is little nationwide  information about pedestrian exposure to potential crashes and that data  may be more available on the state or local level. Some national data,  however, shows that there may have been some change in people  walking. For example, the U.S. Census Bureau’s American Community  Survey estimated that in 2018, 4 million people reported walking to work  compared with an estimated 3.8 million people in 2010. Regarding  roadways, in 2018 the National Transportation Safety Board (NTSB)  reported that most pedestrian fatalities occur in urban areas on principal  arterial roads that carry high volumes of traffic, traveling at the highest speeds. In 2015, we noted that behavior such as distracted driving,  walking, and cycling may contribute to pedestrian and cyclist fatalities.  When drivers and pedestrians use cell phones or are otherwise  distracted, they may be less aware of their surroundings and more likely  to be involved in a crash. Finally, NHTSA data shows that most  pedestrian fatalities occurred after dark and at places other than  intersections. Specifically, in 2018, of the 6,300 reported fatalities, over  4,700 pedestrians (about 75 percent) were killed after dark and about  4,600 pedestrians (about 73 percent) were killed at non-intersection  locations. See appendix II for additional information on pedestrian  fatalities from 2008 through 2018.

Automakers have developed vehicle features intended to avoid  pedestrian crashes and mitigate the extent of injury to pedestrians. Crash  avoidance features (also known as “active” safety features) rely on  cameras, radar, and other devices to detect a pedestrian and then act to  alert a driver to take action, or automatically apply a vehicle’s brakes to  slow or stop the vehicle to avoid striking a pedestrian (see fig. 2). One  pedestrian crash avoidance system is referred to as pedestrian automatic  emergency braking, which uses a camera, radar, or a combination, to  automatically apply brakes to avoid a collision.

Crash mitigation features (also known as “passive” safety features)  generally involve the use of pedestrian-friendly vehicle components that  are designed to reduce the severity of injuries should a pedestrian be hit.  Passive safety features can include energy absorbing bumper material,  hoods that provide space between the hood and the hard components in  the engine compartment, and contoured vehicle front-ends intended to  reduce harm to pedestrians (see fig. 3).

In executing its mission, NHTSA administers NCAP and issues federal  motor vehicle safety standards (FMVSS) and the federal bumper  standard, among other things. In general, NCAP tests supplement safety  standards established in law or regulation.

NCAP. Created in 1978, this program tests new vehicles to determine  how well they protect drivers and passengers during a crash (front  and side) and how well vehicles resist rollovers. NHTSA tests and  rates vehicles using a five-star safety rating system with five stars  being the highest safety rating and one star the lowest. NHTSA  communicates the results of its vehicle tests through window labels on  new vehicles and on its website. In 2010, NHTSA also began  recommending various safety technologies for consumers to consider  when purchasing vehicles. Recommended technologies include such  things as forward collision warning (an alert that warns drivers to  brake or steer to avoid a crash if they are too close to a car in front of  them); lane departure warning (an alert that warns drivers of  unintentional lane shifts); and automatic emergency braking, which  can automatically activate a vehicle’s brakes if a driver takes no action  to avoid an imminent crash with a preceding vehicle. NHTSA has not  yet included pedestrian automatic emergency braking systems as  recommended technologies. Recommended technologies are not  included in star ratings, but rather are features NHTSA believes  consumers may wish to look for in new vehicles. Pedestrian safety  tests are not currently part of NCAP.

FMVSS. These are minimum performance standards established in  regulation for new motor vehicles and items of motor vehicle  equipment. According to NHTSA officials, FMVSS have test  procedures and performance criteria with minimum thresholds for  motor vehicles and motor vehicle equipment, such as minimum light  intensity requirements for headlamps.

Bumper standard. In addition, while not in the FMVSS, NHTSA’s  bumper standard prescribes performance requirements in regulation  for passenger cars in low-speed front-end and rear collisions.  According to NHTSA officials, the bumper standard is intended to  prevent damage to the car body and safety related equipment at  speeds equivalent to a 5 miles-per-hour (mph) crash into a parked  vehicle of the same weight. The standard applies to front and rear  bumpers on passenger cars, but not to other multipurpose passenger  vehicles, such as SUVs, minivans, or pickup trucks.

The United States is also involved with pedestrian safety internationally.  In June 1998, the United States signed an international agreement  administered by the United Nations concerning the establishment of  global technical regulations for motor and other wheeled vehicles. The  purpose of the agreement was to establish a global process for jointly  developing technical regulations regarding such things as safety,  environmental protection, and energy efficiency of vehicles. As part of this  agreement, in 2008, Global Technical Regulation No. 9 was established  to improve pedestrian safety by requiring vehicle hoods and bumpers to  absorb energy more efficiently when impacted in a vehicle-to-pedestrian  collision. This international standard has two sets of performance  criteria: head impact requirements that ensure vehicle hoods provide  protection to a pedestrian’s head when impacted; and leg protection  requirements for the front bumper that would require bumpers to subject  pedestrians to lower impact forces. According to NHTSA, as a signatory  to the 1998 agreement, the United States is obligated to consider  adopting global technical regulations, but is not obligated to adopt them.  NHTSA officials told us the agency has not yet initiated the rulemaking  process for Global Technical Regulation No. 9.

Although pedestrian safety testing is not currently a part of the U.S.  NCAP, it is a part of similarly established new car assessment programs  in other countries. For example, since 2016 both the European New Car  Assessment Programme (Euro NCAP) and a program in Japan (known  as the Japan New Car Assessment Program (JNCAP)) have tested  vehicle pedestrian crash avoidance systems using a variety of scenarios  and vehicle speeds. Euro NCAP tests include an adult dummy walking  or running perpendicular to a test vehicle and walking parallel to a  vehicle. Tests are also conducted with a child dummy running out from  parked cars (see fig. 4). Euro NCAP tests are also conducted in daylight  and at night. In the United States, two nongovernmental organizations  have also conducted pedestrian safety testing. IIHS began a program to  test pedestrian crash avoidance systems on 2018 and 2019 vehicles, and  in 2020 began using the results to help determine its Top Safety Pick  awards. The American Automobile Association (AAA) also recently  conducted tests of crash avoidance systems.

Moreover, crash mitigation tests that measure the potential for head and  leg injuries resulting from pedestrian-motor vehicle crashes have been in  place for many years in Europe and Japan. Euro NCAP began head and  leg testing in 1997 and Japan began pedestrian head protection testing in  2003 and pedestrian leg protection testing in 2011. In general, these tests  launch projectiles designed to simulate a person’s legs or head into  various locations on a vehicle’s hood and bumper to assess the  effectiveness in limiting pedestrian injury (see fig. 5).

Vehicle Age, Body Type, and Speed Are Associated with Pedestrian Fatalities, But Gaps Remain in NHTSA’s Pedestrian Injury Data

We found that several vehicle characteristics including the age and body  type of the vehicle and the speed at which the vehicle was being driven at  the time of the crash are associated with the increase in pedestrian  fatalities from 2008 through 2018. However, NHTSA lacks complete data  on the relationship between vehicle characteristics and pedestrian  injuries, including detailed information on injury type and severity.  Although NHTSA initiated a pilot program to improve its data collection  protocol for pedestrian injuries, NHTSA lacks a plan for this program to  evaluate its results and determine whether and how it should be  expanded.

The Number of Reported Pedestrian Fatalities Increased for Crashes Involving Older Vehicles, SUVs, and Vehicles Traveling at Higher Speeds

Through FARS, NHTSA annually collects and analyzes data on all  crashes involving pedestrian fatalities, including vehicle-related  characteristics. Based on these data and relevant research, we analyzed  the relationship between pedestrian fatalities and the age, body type, and  speed of vehicles. Our analysis of FARS data shows that from 2008  through 2018, the number of pedestrian fatalities increased more for  crashes involving vehicles that were:

11 years old or older (123 percent increase) compared with newer  vehicles (9 percent increase);

SUVs (68 percent increase) compared with other light trucks (25  percent increase), and passenger cars (47 percent increase); and  traveling at reported speeds 31 mph and above (45 percent increase),  compared to vehicles traveling at lower speeds (28 percent  increase).

The number of pedestrians struck and killed by vehicles 11 years old or  older (older vehicles) increased more relative to the number of  pedestrians struck and killed by vehicles 10 years old or newer (newer  vehicles). In 2008, 1,139 pedestrian fatalities involved older vehicles,  which represented about a quarter (26 percent) of reported pedestrian  fatalities (see fig. 6). By 2018, that number more than doubled to 2,537  pedestrian fatalities, or 40 percent of reported pedestrian fatalities. Over  that same time period, the number of pedestrian fatalities involving newer  vehicles also increased from 2,800 in 2008 to 3,044 in 2018. However,  this increase was less than fatalities involving older vehicles, and the  overall share of pedestrian fatalities involving newer vehicles decreased  from 63 to 48 percent over that period.

The rise in the number of older vehicles involved in pedestrian fatalities  may reflect the rise in the average age of vehicles in operation.  According to data from DOT’s Bureau of Transportation Statistics, the  average age of all vehicles in operation in the United States increased by  about 1.5 years from 10.1 years old in 2008 to 11.7 years old in 2018. In  comparison, the average age of passenger vehicles that struck and killed  pedestrians increased by roughly 2 years from 8.1 years in 2008 to 10  years in 2018. Another possible contributing factor to the increased share  of pedestrian fatalities resulting from crashes with older vehicles may be  the prevalence of safety features in newer vehicles compared with older  vehicles. As discussed below, vehicle manufacturers are offering new  vehicles with pedestrian safety features such as pedestrian crash  avoidance and crash mitigation systems, which may reduce pedestrian  injuries and fatalities.

The number of pedestrian fatalities where passenger cars, SUVs, or other  light trucks were reported as striking vehicles all increased from 2008 to  2018 (see table 1). However, the number of SUVs involved in fatal  pedestrian crashes increased by a higher percentage than passenger  cars and other light trucks. As table 1 shows, pedestrian fatalities  involving SUVs increased by about 68 percent, while pedestrian fatalities  involving passenger cars increased by 47 percent and light trucks and  vans increased by 25 percent. Additionally, although the number of SUVs  involved in pedestrian fatalities increased the most in this timeframe,  passenger cars still accounted for the largest share of fatalities.

Data on the growth of SUVs within the U.S. vehicle fleet and academic  research identify potential contributing factors as to why the number of  SUVs involved in pedestrian fatalities increased between 2008 and 2018:  Increasing SUV market share. SUVs represent a growing share of  the total U.S. vehicle fleet. According to the Highway Loss Data  Institute, the share of new vehicles in the United States that were  SUVs grew from 30 percent in model year 2008 to 48 percent in  model year 2018. In addition, 11 of the 13 auto manufacturers we  interviewed stated that SUV sales, either market-wide or at their  company, increased relative to passenger car sales in the United  States since 2008.

Increased risk of injuries based on vehicle size and weight.  Research suggests that if a pedestrian is struck by a vehicle with  greater mass the crash is more likely to result in serious injuries or a  fatality than if the pedestrian is struck by a lower-mass vehicle. For  example, one study we reviewed that cited work from five other  studies found that the chief determinants for the severity of injuries in  motor vehicle collisions are vehicle size and weight. According to  one NHTSA-funded study, which used information from NHTSA’s  Pedestrian Crash Data Study, researchers found that the probability  of death for pedestrians struck by light trucks (including SUVs) was  3.4 times higher than for pedestrians struck by passenger cars.

Between 2008 and 2018, the number of pedestrian fatalities involving  higher speeds (31 mph and above) at the time of the crash increased  more sharply than the number involving lower speeds (30 mph and  below). Although vehicle speed was missing or not reported for 62  percent of pedestrian fatalities (as discussed below), our analysis of  FARS data showed that when speed data are recorded, the number of  pedestrian fatalities involving vehicles reportedly travelling at higher  speeds increased from 1,315 to 1,912 (45 percent) between 2008 and  2018 (see fig. 7). The number of pedestrian fatalities involving vehicles  reportedly traveling at lower speeds also increased, but at a smaller  percentage (28 percent) than vehicles at higher-speed. During this time  period, about 79 percent of pedestrian fatalities involved vehicles  travelling 31 mph and above, and about 21 percent involved vehicles  traveling at lower speeds.

Multiple studies have found that when vehicles travel at higher speeds  and strike pedestrians, they are more likely to kill or severely injure the  pedestrian. For example, the NTSB reported in 2018 that the relationship  between speed and the severity of injuries is consistent and direct— higher crash speeds result in injuries that are more severe. The NTSB  added that the effect of speed is especially critical for pedestrians  because they lack protection. In addition, according to a 2019 report from  the National Cooperative Highway Research Program, a pedestrian’s risk  of fatality is 90 percent when struck by vehicles travelling between 54 and  63 mph compared with a 10 percent risk of fatality between 24 and 33  mph.

We also found that between 2008 and 2018, the speed of the striking  vehicle was not reported for about 62 percent of pedestrian fatalities. This  omission is likely because it is difficult for police officers to determine a  vehicle’s speed after a crash occurs. Further, some organizations we  spoke with told us that low speed collisions were typically underreported.  According to NHTSA officials, the speed recorded is generally up to the  discretion of the responding police officer.

NHTSA Lacks Complete Data on the Relationship between Vehicle Characteristics and Pedestrian Injuries

NHTSA officials and other stakeholders we interviewed identified  limitations in NHTSA’s data on the relationship between vehicle  characteristics and pedestrian injuries. These include (1) incomplete and  inconsistent injury designations, (2) crash and vehicle information not  linked to medical data, and (3) outdated pedestrian crash investigation  data.

Incomplete and inconsistent injury information. Within CRSS,  NHTSA relies on information provided in police reports to determine  national estimates of injured pedestrians. According to NHTSA  officials, data from the police reports are typically after-the-fact  descriptions of events and NHTSA conducts little, or no, follow up  investigations of these reports. As a result, CRSS data may not  include the cause of crashes or pedestrian injuries, and for some  crashes it may be missing detailed information on specific  characteristics of the striking vehicle. In addition, there may be  inconsistencies in pedestrian injury information. NHTSA’s injury  severity data rely on reporting from states and localities, which may  define injury severity differently, year-to-year. As we have reported,  NHTSA standardized the injury severity definitions nationally in April  2019; however, it will take time for states to adopt this standard.

Crash and vehicle data are not linked to medical records.

According to NTSB and some researchers we spoke with, the five  point injury severity scale used on police crash reports does not  effectively capture injury severity or actual injury outcomes because  NHTSA does not link crash data with medical and hospital records.  Without crash and vehicle information linked to medical records,  researchers cannot crosscheck injury severity designations with  actual injury outcomes or identify specific injury types. NHTSA  previously sponsored a program to help link crash data with injury  data contained in medical records, but federal funding for the program  was discontinued in 2013.

Outdated pedestrian crash investigation data. NHTSA last  collected detailed data on pedestrian crash and injury characteristics  from 1994 to 1998. The Pedestrian Crash Data Study collected  information from over 500 pedestrian crashes, including data on  pedestrian injury types, severity, and potential causation. The study  also reported the vehicle’s type and the part of the vehicle that caused  the injury, such as the front bumper. In its 2018 report, NTSB stated  that while this study was the most complete set of pedestrian crash  data available in the United States, the data are over 20 years old.  NTSB recommended that NHTSA develop a detailed and current  pedestrian crash data set for local and state analysis and to model  and simulate pedestrian collision avoidance systems. As of February  2020, however, NHTSA had not fully implemented the  recommendation. Some automakers and equipment suppliers we  spoke with noted that improved real world injury data would help them  better develop pedestrian safety features.

NHTSA has recognized that it needs to collect more detailed and  complete data on pedestrian injuries. For example, in a 2011 report to  Congress on the agency’s data gaps, NHTSA noted that internal  stakeholders (those within NHTSA) requested an updated Pedestrian  Crash Data Study with crashes involving late-model-year vehicles and  detailed injury data on the body region impacted rather than the vehicle’s  point of contact. Further, in its 2016 to 2020 strategic plan, NHTSA  stated that it would work to improve the quality, timeliness and relevance  of safety data collected.

NHTSA Has Begun a Pilot Program to Improve Its Data Collection Protocol for Pedestrian Injuries, but Lacks a Plan to Evaluate Results

In 2018, NHTSA initiated a pilot program to evaluate existing and new  protocols for collecting pedestrian crash and injury data as part of its  Crash Injury Research and Engineering Network (CIREN). The purpose  of this pilot program is to develop a data collection protocol and collect  preliminary data for pedestrian-motor vehicle crashes, including analysis  on injury causation. Further, NHTSA stated that it intends to use this  protocol and data as the foundation for subsequent pedestrian crash  studies such as research related to injury trends and testing tools.  NHTSA officials also told us that the pilot will help update and build upon  the data collection and analysis protocols for pedestrian-motor vehicle  crashes used in the 1990s in the Pedestrian Crash Data Study. According  to NHTSA officials, the pilot will collect data on nine cases from two  hospitals. A third hospital will provide engineering support. NHTSA  officials stated that they limited the pilot study to nine cases so they would  be able to act quickly on the pilot to determine if a full project was worth  pursuing and to avoid delays. According to NHTSA officials, they expect  initial results to be available by fall 2020.

We have reported that a well-developed and documented pilot program  can help ensure that agency assessments produce information needed to  make effective program and policy decisions. Well-designed pilot  programs use five leading practices including:  1.  establishing clear, appropriate, and measurable objectives;  2.  articulating an assessment methodology and data gathering strategy;  3.  developing a data analysis and evaluation plan to track pilot  4.  identifying criteria for determining whether and how to scale the pilot  and integrate it into overall efforts; and  5.  ensuring two-way stakeholder communication through the pilot  program.

Through our review of the CIREN pedestrian pilot program  documentation, we determined that NHTSA met most of the criteria for a  well-developed pilot program, but not all. Specifically, NHTSA  documented clear, appropriate, and measureable project objectives;  identified an assessment methodology and data gathering strategy;  developed a data analysis plan; and communicated with stakeholders.  NHTSA, however, did not establish an evaluation plan that includes  criteria to determine if the pilot program’s data collection and analysis  protocol should or could be continued or expanded, once the data have  been collected from the nine cases. Although NHTSA officials reported  that they had a plan to review and evaluate individual cases, NHTSA  does not have an evaluation plan for the pilot program that includes  criteria or standards for identifying lessons learned or determining  whether the new data collection and analysis procedures would satisfy  data needs related to pedestrian’s injuries.

NHTSA officials told us that they did not develop an evaluation plan or  criteria for determining the success or scalability of the pedestrian pilot  program because they were not required to create one. They also said  they did not have enough information to tell if the pilot program should be  integrated into overall efforts, although they expect the tools developed by  the pilot to be incorporated into later efforts to increase the number of  pedestrian crashes reviewed under the CIREN program.

Automakers Reported That Various Pedestrian Safety Features Are Commonly Available in New Vehicle Models and That All Features Have Benefits and Challenges

Most Automakers Reported Offering Pedestrian Crash Avoidance or Mitigation Safety Features

Pedestrian crash avoidance and crash mitigation safety features are  commonly available on many 2019 model year vehicles offered in the  United States, according to the 13 automakers we interviewed. As  previously discussed, crash avoidance features rely on cameras or radar  or both to detect a pedestrian and take action to avoid a crash. Crash  mitigation generally involves use of pedestrian-friendly vehicle  components (such as energy absorbing bumper components or hoods)  that are designed to reduce the severity of injuries should a pedestrian be  hit.

The 13 automakers we interviewed responded that they, collectively,  offered 262 model year 2019 vehicles for sale in the United States. Of  those vehicle models, almost 60 percent included pedestrian automatic  emergency braking as either a standard or an optional feature (see fig. 8).  About 62 percent of their model year 2019 vehicles had some type of  standard pedestrian crash mitigation feature. In total, 12 of 13  automakers that we interviewed responded that they offered one or more  2019 model year vehicles with pedestrian automatic emergency braking  as either a standard or optional feature; similarly, 12 of 13 automakers  told us they offered crash mitigation features in at least one of their 2019  model year vehicles.

Some stakeholders we interviewed told us that a combination of crash  avoidance and crash mitigation features can be effective in minimizing  pedestrian injury. For example, NHTSA officials told us that crash  avoidance features, such as pedestrian automatic emergency braking can  slow a vehicle to a speed where it will be less damaging to a pedestrian  once struck, and if the vehicle also has crash mitigation features the  impact of the crash can be further mitigated. We found that almost half of  2019 vehicle models had some combination of both pedestrian automatic  emergency braking and crash mitigation features. For example, about 47  percent of 2019 vehicle models had pedestrian automatic emergency  braking as either standard or optional equipment along with crash  mitigation features, such as softer hoods. However, 24 percent of vehicle  models had neither of these (see fig. 9).

Officials from the 13 automakers we interviewed identified a variety of  factors that influenced their decisions to offer vehicles with pedestrian  safety features in the United States. These include a desire to achieve  high safety ratings for their vehicles, as well as the following:

New car assessment programs: New car assessment programs in  the United States and other countries also influence why automakers  may offer pedestrian safety features. For example, officials from nine  of 10 automakers that responded to this question in our interview  replied that Euro NCAP was a major factor to them in providing  pedestrian safety features, while seven of 10 automakers responded  that JNCAP was a major factor. In contrast, three of 11 automakers  responded that the U.S. NCAP was a major factor in their decisions to  offer vehicles with pedestrian safety features. As previously  discussed, the United States, unlike the European Union and Japan,  does not incorporate pedestrian safety tests into its NCAP.

Independent safety testing: Independent safety testing was also a  factor in why automakers may offer pedestrian safety features on  vehicles. For example, officials from five automakers said that they  considered IIHS safety ratings to be a major factor in their company’s  decision to offer pedestrian safety features on vehicles sold in the  United States. As previously discussed, IIHS began testing  pedestrian crash avoidance systems on 2018 and 2019 vehicles.  These tests are known as pedestrian automatic emergency braking  tests and in 2020 IIHS began using the results to help determine their  Top Safety Pick awards. Officials from two automakers said a  company’s goal is to earn an IIHS top safety-pick rating for each of  their models.

Cost: Cost appeared to be less of a factor influencing whether  pedestrian safety features were offered on vehicles. Officials from  seven of eight automakers who responded to this question replied that  costs either were a minor factor, or did not apply, in their decisions to  offer vehicles with pedestrian safety features. However, officials from  four automakers told us that, in general, while customers want safer  vehicles, automakers have to consider what safety features could be  included without increasing the overall cost. Further, one automaker’s  representative said that as more manufacturers and customers are  buying crash avoidance systems the costs are decreasing.

The future availability of crash avoidance features may depend on several  factors. Specifically, in 2016, 20 automakers voluntarily committed to  making automatic emergency braking systems standard in vehicles sold  in the United States by 2022. Officials from three automakers said that  they planned to incorporate pedestrian automatic emergency braking into  their vehicles’ automatic emergency braking systems as part of this  commitment.

Another factor is customer demand. One automaker said that the number  of models that include pedestrian safety features in the future would  depend on consumer demand or changes in regulation. Officials from  another automaker said their customers often ask for features they see in  Europe and ask why such features are available there but not in the  United States.

Auto Industry Officials Cited Various Benefits and Challenges of Commonly Available Pedestrian Safety Features

The auto industry officials we interviewed identified benefits and  challenges with commonly available pedestrian safety features. Benefits  of crash avoidance systems include the potential of eliminating or  reducing car-to-pedestrian accidents. For example, officials from six  automakers said that crash avoidance features were more effective than  crash mitigation features because the purpose of crash avoidance  features is to prevent the collision from occurring in the first place. Almost  half of the automakers we interviewed (six of 13), however, reported that  a primary challenge with a camera-based pedestrian automatic  emergency braking system was the camera’s ability to work in low lighting  or poor weather. Recently issued research has raised questions about the  overall effectiveness of crash avoidance systems. In October 2019, AAA  reported that based on its own assessment, some vehicles’ pedestrian  safety systems were inconsistent at either slowing down or stopping a  vehicle to avoid hitting a pedestrian. Specifically, the association  reported that none of the crash avoidance systems on the four vehicles  they tested worked in dark conditions.

Auto industry officials also identified benefits and challenges with  pedestrian crash mitigation features. For example, 12 of 13 automakers  reported that crash mitigation features have the overall benefit of reducing  the risk or severity of pedestrian injuries. Officials from eight automakers,  however, said that the current federal bumper standard created  challenges to offering softer, more pedestrian-friendly bumpers in the  United States. Officials from the eight automakers said they offered  softer bumpers in Europe or elsewhere—where there is no similar  bumper standard—but do not offer softer bumpers in the United States.  NHTSA officials told us the current bumper standard is primarily a cost  savings standard in that it is intended to reduce repair costs and not  necessarily to offer safety protection for vehicle occupants. NHTSA  officials told us trade-offs are required to establish a bumper standard that  addresses pedestrian safety, yet minimizes bumper damage and repair  costs. NHTSA officials told us they are in the process of reevaluating the  bumper damageability standard, as part of a Notice of Proposed  Rulemaking, which they expect to publish in 2020.

Appendix III discusses the benefits and challenges of commonly available  pedestrian safety features.

NHTSA Has Proposed Pedestrian Safety Tests for NCAP, but Lacks a Clear Process for Updating the Program and Has Yet to Make or Communicate a Decision

NHTSA Has Conducted Research and Proposed Pedestrian Safety Tests over the Last 10 Years

NHTSA has considered pedestrian safety for many years by conducting  research, considering implementation of global regulations for pedestrian  crash mitigation tests, and proposing pedestrian crash avoidance and  mitigation tests for NCAP (see fig. 10). NHTSA’s last substantial update  of NCAP was in July 2008 (with changes effective for model year 2011  vehicles). This update established additional crash tests and technical  standards to protect vehicle occupants, but did not include pedestrian  safety tests.

Since NCAP Was Last Updated, NHTSA Contributed to Developing Global Pedestrian Regulations and Conducted Research

In the past 10 years, NHTSA has considered but has not yet initiated a  rulemaking process related to international standards for crash mitigation  tests, among other actions. For example, in 2008, the United States along  with other countries approved a United Nation’s international standard for  pedestrian crash mitigation tests. This international standard, if  implemented in the United States in a domestic regulation, would require  U.S. vehicles to meet minimum performance requirements in pedestrian  crash mitigation tests. The United States approved the international  standard in 2008; however, NHTSA has yet to initiate a rulemaking to  implement it either as part of the FMVSS or adopt it as a testing protocol  through NCAP. According to NHTSA officials, implementation of the  standard would require NHTSA to initiate a regulatory proceeding.  Although the United States formally agreed to the standard more than 10  years ago, NHTSA officials told us that the rulemaking initiative is  classified as a long-term action and that there is no timeline for such a  rulemaking to implement pedestrian crash mitigation requirements.

NHTSA has also conducted a range of research on pedestrian crash  avoidance and mitigation tests. Specifically, NHTSA has published,  contributed to, or sponsored over 55 studies and presentations on  pedestrian safety issues since 2008, and NHTSA officials provided  information stating that NHTSA has spent over $8.4 million to research  pedestrian safety, including pedestrian automatic emergency braking and  passive safety features from 2008 through 2019. In addition, officials  stated that NHTSA has conducted a number of additional studies related  to pedestrian safety, studies that NHTSA is currently reviewing for final  publication, though officials did not provide expected publication dates.  NHTSA officials told us this research serves as a body of work that  supports and facilitates agency decisions and policies with respect to  pedestrian safety.

NHTSA’s pedestrian safety research has focused on several key issues,  including developing objective test protocols and reliable test instruments  for inclusion in NCAP and assessing the potential safety benefits. NHTSA  officials told us there are three important elements associated with any  safety tests (including pedestrian safety tests). These elements are (1)  creating test protocols that measure a vehicle’s safety performance  objectively, (2) validating test instruments that measure human injury, and  (3) estimating the potential safety benefit of the tests. NHTSA’s  pedestrian safety research includes work related to all three of these  elements, as follows:

Objective Test Protocols. One NHTSA study developed objective  test protocols to evaluate the effectiveness of pedestrian crash  avoidance systems based on analyses of crash scenarios from real- world crash data. Another NHTSA study applied pedestrian crash  mitigation test protocols used by Euro NCAP to the U.S. vehicle fleet.

NHTSA found that the European protocols could be used to assess  the pedestrian safety performance of vehicles in the United States,  but that the performance of different U.S. vehicle types could vary.  Specifically, NHTSA found that “global platform” vehicles (i.e., models  that include a U.S. and European variant of the same vehicle) offered  more pedestrian safety than vehicles that are only marketed in the  United States.

Valid Test Instruments. NHTSA has been a key contributor in the  development of pedestrian test instruments. For example, NHTSA has  presented information on mannequins for evaluating the repeatability  and accuracy of pedestrian crash avoidance systems, concluding that  mannequins should be durable, realistic, and comparable in size and  movement to humans. In addition, NHTSA found there are  instruments that produce repeatable and reproducible measurements  of pedestrian head, upper leg, and lower leg injuries on tests.

Potential Safety Benefits. NHTSA has studied the potential benefits  of pedestrian crash avoidance, and estimated that these technologies  could reduce the number of annual vehicle-pedestrian crashes by  between 620 and 5,000, and reduce the number of annual fatal  vehicle-pedestrian crashes by between 110 and 810. NHTSA has  also reported that Europe and Japan have responded to the high  proportion of pedestrian fatalities compared to all traffic fatalities by  including pedestrian protection in their respective NCAPs and  requiring pedestrian protection through regulation. According to  NHTSA, these actions have likely contributed to a downward trend in  pedestrian fatalities in Europe and Japan.

Further, an international study found that including pedestrian safety  testing in consumer testing programs has real world benefits by reducing  pedestrian fatalities and injuries. For example, a European study  concluded that vehicles that score well in Euro NCAP pedestrian crash  mitigation tests are less likely to severely injure pedestrians. As  previously noted, Euro NCAP and JNCAP have included pedestrian crash  mitigation tests since 1997 and 2003, respectively, and both Euro NCAP  and JNCAP incorporated pedestrian crash avoidance tests in 2016.

NHTSA Proposed Pedestrian Safety Tests in 2015 and Has Since Requested Comments

In December 2015, NHTSA proposed pedestrian crash avoidance and  mitigation safety tests for NCAP by publishing a Request for Comments  notice in the Federal Register. In the 2015 Request for Comments,  NHTSA indicated that including these tests in NCAP could lead to a  decrease in vehicle-pedestrian crashes and resulting pedestrian injuries  and fatalities. In this request, NHTSA also reported that it believed the  greatest gains in highway safety in coming years would result from  widespread application of crash avoidance technologies and that its  proposed safety tests for crash avoidance technologies, including  pedestrian detection and automatic emergency braking, met NHTSA’s  four prerequisites for updating NCAP. Those four prerequisites include  that: a safety need is known or capable of being estimated;  vehicle and equipment designs exist (or are anticipated in prototype  design) that are capable of mitigating the safety need; a safety benefit is estimated based on the anticipated performance of  the existing or prototype design; and a performance-based, objective test procedure exists to measure the  ability of the vehicle technology to mitigate the safety issue.

With regard to crash mitigation tests, NHTSA reported that it intended to  use the Euro NCAP test procedures rather than those used in Japan  because the European fleet make-up, including vehicle sizes and classes,  is more similar to the U.S. fleet. NHTSA also reported in its 2015  Request for Comments that including pedestrian crash mitigation tests in  NCAP is necessary to stimulate improvements in pedestrian  crashworthiness in new vehicles sold in the United States. NHTSA,  however, did not state in its 2015 Request for Comments whether the  proposed crash mitigation tests met NHTSA’s prerequisites for updating  NCAP, as it had for the crash avoidance tests. The proposed changes in  the 2015 Request for Comment were to take effect for model year 2019  vehicles.

In response to the 2015 Request for Comment, NHTSA officials told us  they received 290 comments, 31 of which addressed pedestrian safety.  According to the officials, the comments received were generally  supportive of including pedestrian safety testing in NCAP, and  commenters proposed that the U.S. tests should be consistent, or  harmonized, with the tests already conducted by Euro NCAP. NHTSA  officials also noted that some commenters expressed concern with test  tools and proposed test scenarios.

Since the 2015 proposal to include pedestrian tests in NCAP, NHTSA has  continued to solicit updated information in additional Requests for  Comments. Most recently, in October 2019 NHTSA announced it would seek comment on NCAP updates in 2020, and in November 2019,  NHTSA requested comments on draft research test procedures for  forward and rear pedestrian crash avoidance, among other technologies.  However, NHTSA stated that its draft test procedures were developed for  research purposes only, and the fact that it was soliciting comments on  these procedures was not an indication that it would then, or at any time  in the future, initiate a rulemaking related to that technology or include  that technology in NCAP.

NHTSA Lacks a Clear Process for Updating NCAP and Has Not Made or Communicated a Decision for Including Pedestrian Safety in NCAP to Stakeholders

NHTSA officials told us there are many actions that go into their decision- making on whether to update NCAP and that this decision-making  process can take years. These actions include such things as reviewing  data, ensuring the reliability and repeatability of proposed tests by  validating protocols at multiple independent test laboratories, and  conducting market research to obtain consumer input. In addition,  NHTSA officials told us that it also uses its four prerequisites for updating  NCAP, and while these prerequisites are not required by law, they  represent good governance practices and are in consumers’ best interest.  However, since NCAP is considered a consumer testing information  program and not a regulation, there are no particular requirements for  when or how final decisions would be made as to whether pedestrian  safety should or should not be included in NCAP. NHTSA officials told us  that ultimately the NHTSA Administrator decides whether to go forward  with changes to NCAP.

Although NHTSA officials told us NCAP is not a regulation, they said  NHTSA generally follows the processes in the Administrative Procedure  Act for informal rulemaking to update NCAP. This process includes a  notice, comment, and decision process in the Federal Register for  transparency. NHTSA, however, has not used this process to  communicate to stakeholders the additional steps that it must take before  it can make its decision on NCAP testing. In addition, although NHTSA  requested and received numerous comments on including pedestrian  safety tests in NCAP in 2015, as of April 2020, it has yet to respond to  those comments.

Leading practices for program management emphasize the importance of  milestones and decision points, documentation, and clearly  communicating to external stakeholders. The Project Management  Institute, Inc., The Standard for Program Management stresses the  importance of program management plans that align with organizational  goals and objectives. Elements of such plans are to provide a roadmap  that identifies such things as milestones and decision points to guide  programs forward. In addition, Standards for Internal Control in the  Federal Government, state that entities should externally communicate  the necessary quality information to achieve the entity’s objectives. In  particular, entities should communicate to external stakeholders  significant matters related to risks or changes. These standards also state  that documentation is necessary for design, implementation, and  operating effectiveness.

Compared to these leading practices, NHTSA’s process does not provide  documentation of the process, decision points, or milestones to guide the  program. For example, NHTSA officials could not provide us with  documentation as to how it determined that the pedestrian crash  avoidance tests proposed in 2015 met the four prerequisites, or how the  proposed crash mitigation tests compared to the prerequisites. Other  NCAPs have used various methods for documenting their process for  updating their testing. For example, Euro NCAP uses a roadmap to  communicate to stakeholders the planned changes for NCAP tests, the  timeline of steps toward the changes, and when those changes will be  effective. Officials from Euro NCAP told us the test and assessment  protocols are developed in conjunction with working groups made up of  automakers, equipment suppliers, test facilities, and Euro NCAP member  organizations. Further, officials told us the working groups and roadmaps  provide automakers with the opportunity to provide real-time input and  obtain information to support their investment decisions.

The lack of a documented overall process for updating NCAP affects  NHTSA’s ability to achieve NCAP’s goals to provide manufacturers an  incentive to improve the safety performance of new vehicles and to assist  consumers with their vehicle purchasing decisions. Specifically, without a  transparent process for NHTSA’s decision-making on NCAP, automakers  lack information on NHTSA’s progress in evaluating proposed changes— such as those offered in the 2015 Request for Comment—and the timing  of the implementation of any specific testing procedures. This is  particularly important because automakers need quality information to  make investments to support the development and deployment of new  technologies and equipment in their product lines to meet testing  requirements. For example, representatives from one automaker told us  that vehicle design is a 6 to 8 year product cycle and that if NHTSA  decides to implement certain tests in the middle of that cycle, it would be  difficult and costly to make changes. Without a clearly documented  process for making changes to NCAP, including established criteria and  milestones for decisions, automakers and the public lack clarity on  NHTSA’s plans for improving vehicle safety to inform investment and  purchasing decisions.

Decision on Pedestrian Safety Testing in NCAP

NHTSA has yet to make or communicate a decision as to whether it  intends to include pedestrian safety tests in NCAP. As discussed above,  NHTSA has conducted extensive research and requested comments on  pedestrian crash avoidance and mitigation tests in 2013 and 2015.  Although NHTSA reported in 2015 that these tests could lead to a  decrease in vehicle-pedestrian crashes and resulting pedestrian injuries  and fatalities, it has yet to make or communicate a decision about the  future of NCAP in relation to pedestrian safety to stakeholders. Nine of 13  automakers we interviewed told us that a lack of communication from  NHTSA on its plan for addressing pedestrian safety issues has presented  a challenge to them, often because they require long lead times to  develop, test, and launch new technologies.

Leading practices for program management also stress the importance of  communication with stakeholders and that effective stakeholder  communications are key to executing program endeavors, addressing  risks, and, ultimately, delivering benefits. Specifically:

The Project Management Institute, Inc., The Standard for Program  Management stresses the importance of managing external  communications, stating that communication provides critical links for  successful decision making. It also stresses the importance of  providing decision-making stakeholders with adequate information to  make the right decisions at the right time in order to move programs  forward.

Standards for Internal Control in the Federal Government states that  entities should identify, analyze, and respond to risks related to  achieving the defined objectives and should externally communicate  the necessary quality information to achieve the entity’s objectives.  As discussed above, these standards also state that management  should externally communicate quality information to external  stakeholders significant matters related to risks or changes.

Further, the statute underlying NCAP requires NHTSA to communicate  certain vehicle safety information to the public. Specifically, DOT is to  provide the public with information on crash avoidance, crashworthiness,  and damage susceptibility. Such information is to be provided in a  simple and understandable form to allow comparison among vehicles to  assist a consumer in buying a new car.

NHTSA officials told us that it has not made or communicated a decision  as to whether it will include pedestrian safety testing in NCAP because  administration priorities have shifted since publication of the 2015  Request for Comments. Specifically, NHTSA officials told us that the  agency drafted technical specifications and testing protocols for  pedestrian safety tests for NCAP and posted those tests to its public web  site in January 2017. After the administration changed, however, those  specifications were withdrawn and not published in the Federal Register.  NHTSA officials told us that, since that time, the agency has sought to  conduct additional review before final decisions could be made.

Although the policy decision as to whether to include pedestrian safety  tests in NCAP ultimately resides within NHTSA’s discretion, NHTSA’s  lack of a decision and its related rationale limits NHTSA’s ability to  address emerging safety risks and to meet its strategic objectives.  Specifically, in the Department of Transportation’s Enterprise Risk Profile  for 2019, NHTSA recognized that increases in roadway fatalities in  general—and pedestrian fatalities in particular—represent one of the top  strategic risk areas for the Department. The document states that to  meet its objectives, NHTSA must focus on areas where there have been  increases in road deaths, including pedestrian fatalities, and advance  crash avoidance and mitigation technology to prevent crashes from  occurring. NHTSA also recognized the importance of using a data-driven  and systematic approach that is timely and complete when making  decisions. In the absence of a decision on whether to include pedestrian  safety testing in NCAP, and the rationale for that decision, stakeholders  lack clarity on whether NHTSA is using all of the policy tools at its  disposal to address emerging safety risks and to achieve its strategic  objectives.

The design of vehicles and the safety features they offer can play an  important role in reducing the frequency and severity of pedestrian  crashes. NHTSA’s pedestrian pilot program is an important step toward  addressing data gaps on the relationship between vehicle characteristics  and pedestrian injuries. Without an evaluation plan that includes criteria  for assessing the scalability of the pilot program, however, NHTSA lacks  the tools necessary to assess whether and how the pilot should be  expanded into a more robust effort to inform NHTSA’s understanding of  pedestrian injury mitigation efforts.

Although NHTSA has recognized that the increase in pedestrian fatalities  presents a risk to the safety of the nation’s roadways, it is not well  positioned to address this risk through NCAP because NHTSA does not  have a clear process for making changes to the program. Documenting  and communicating the process for updating NCAP, with clear criteria  and decision points, would enhance NHTSA’s accountability to key  stakeholders—including Congress, automakers, and consumers—and  help NHTSA communicate the important policy decision as to whether to  include pedestrian safety tests in NCAP. Making and communicating a  decision regarding pedestrian safety testing would give automakers clarity  on whether NHTSA intends to establish performance standards and tests  to evaluate the pedestrian safety features that are commonly available on  new vehicle models. Communicating a decision and the rationale for that  decision would provide transparency and accountability to the public.

We are making the following three recommendations to NHTSA.

The Administrator of NHTSA should document an evaluation plan for the  Crash Injury Research and Engineering Network pedestrian pilot program  that includes criteria for determining whether and how to scale the pilot  program to ensure that the piloted data-collection and analysis  procedures will address NHTSA’s data needs related to pedestrian  injuries and vehicle characteristics. (Recommendation 1)

The Administrator of NHTSA should document the overall process for  making changes to NCAP, including established criteria and milestones  for decisions, and share this process with external stakeholders.  (Recommendation 2)

The Administrator of NHTSA should decide whether to include pedestrian  safety tests in NCAP and NHTSA should communicate this decision and  rationale to relevant stakeholders and the public. (Recommendation 3)

We provided a draft of this report to the Department of Transportation for  review and comment. The department provided a written response, which  is reprinted in appendix IV, and technical comments that we incorporated  as appropriate in the report. The department concurred with all three of  our recommendations. It described various activities NHTSA has  underway related to pedestrian safety, including the CIREN study, a  special study initiated this year to gather detailed data on a selection of  fatal pedestrian crashes, and continuing research on pedestrian crash  test procedures.

Regarding Recommendation 2, the department stated that it has made its  procedures to change NCAP transparent and inclusive of the public.  Specifically, the department stated it has published and requested  comment on its proposals in the Federal Register, as we described in this  report. However, the department agreed that documenting the overall  process on its website would generate increased public awareness of  NCAP as a consumer safety tool. While such a step could increase public  awareness of NCAP, we continue to believe that any steps taken to  document the overall process for making changes to NCAP should also  include established criteria and milestones for decisions to enhance  NHTSA’s accountability to Congress, automakers, and consumers.

We are sending copies of this report to the appropriate congressional  committees, the Secretary of Transportation, and the Administrator of the  National Highway Traffic Safety Administration. In addition, we will make  copies available to others upon request, and the report will be available at  no charge on the GAO website at http://www.gao.gov.

If you or your staff have any questions about this report, please contact  me at (202) 512-2834, or vonaha@gao.gov. Contact points for our Offices  of Congressional Relations and Public Affairs may be found on the last  page of this report. GAO staff who made key contributions to this report  are listed in appendix V.

Appendix I: Objectives, Scope, and Methodology

This report: (1) examines what is known about the relationship between  motor vehicle characteristics and pedestrian injuries and fatalities, (2)  describes approaches automakers have taken to address pedestrians’  safety and discusses stakeholders’ perspectives on these approaches,  and (3) evaluates actions the National Highway Traffic Safety  Administration (NHTSA) has taken to assess whether pedestrian safety  testing should be included in its New Car Assessment Program (NCAP).

For all of our objectives we reviewed pertinent federal statutes and  regulations and applicable program documents. Our work covered the  2008 through 2018 timeframe, with 2018 being the most recent data  available at the time of our analysis. We focused on motor vehicles as  opposed to infrastructure (e.g., roadway design, highway lighting) or  driver/pedestrian behavior. Although infrastructure and behavior may also  contribute to pedestrian fatalities and injuries, the scope of this report was  to assess motor vehicles and their role in pedestrian safety. We defined  motor vehicles as passenger cars, sport utility vehicles, and light trucks  and vans that were offered for sale in the United States. We excluded  commercial vehicles, motorcycles, and buses. The intent was to include  those vehicles that a typical consumer would purchase and the  pedestrian safety features that may or may not be offered on such  vehicles.

Our scope also included gaining an understanding of pedestrian safety  testing activities in Europe (European New Car Assessment Programme  (Euro NCAP)) and Japan (Japan New Car Assessment Program  (JNCAP)). We selected these programs since pedestrian safety testing is  part of their NCAPs and some auto industry stakeholders identified them  as being in the forefront of this type of testing. Both Europe and Japan  began testing crash avoidance systems as part of their NCAPs in 2016.  We interviewed officials with Euro NCAP, received a written response to  questions from JNCAP, and obtained information on pedestrian safety  testing from both organizations.

To examine what is known about the relationship between vehicle  characteristics and pedestrian injuries and fatalities, we analyzed data  from three NHTSA databases for the period of 2008 through 2018: (1)  Fatality Analysis Reporting System (FARS); (2) Crash Report Sampling  Systems (CRSS); and (3) National Automotive Sampling System/General  Estimates System (NASS/GES). To ensure the accuracy of our analysis  we reviewed agency technical documentation related to these databases  and ensured that our figures matched publicly available injury and fatality  data contained in NHTSA publications such as its annual Traffic Safety  Fact Sheets. FARS data are derived from a census of all fatal motor  vehicle traffic crashes within the 50 states, Puerto Rico, and the District of  Columbia and provide uniformly coded, national data on police reported  fatalities. We analyzed FARS data to determine the total number of  pedestrian fatalities each year as well as the number of pedestrian  fatalities by vehicle age, vehicle body type, and vehicle travelling speed  (speed just prior to the crash). These variables were selected based on  our interviews of NHTSA officials and a review of relevant research about  the relationship between pedestrian fatalities and motor vehicle  characteristics. We also analyzed FARS data on the number of  pedestrian fatalities by environmental characteristics such as type of  roadway, light condition, and relationship to intersection, selecting these  characteristics based on our interviews and research.

CRSS is a sample of police reported motor vehicle crashes involving all  types of motor vehicles, pedestrians, and cyclists that is used to develop  national estimates of the number of injuries associated with motor vehicle  crashes, among other things. The CRSS police crash report sample is  selected in multiple stages to produce a nationally representative  probability sample, and the target annual sample size is 50,000 police  accident reports. We analyzed CRSS data from 2016 through 2018, the  only years CRSS data were available, to better understand the estimated  total number of pedestrian crashes as well as the estimated number of  pedestrian crashes by vehicle age, vehicle body type, vehicle speed, and  level of pedestrian injury severity. Similar to our analysis of FARS data,  these variables were selected based on our interviews with NHTSA  officials and a review of relevant research about the relationship between  motor vehicle characteristics and pedestrian crashes. NASS/GES  preceded CRSS and obtained its data from a nationally representative  probability sample of police accident reports. We analyzed NASS/GES  data from 2008 through 2015, the most recent years available within the  database, to better understand historical trend data on the variables we  analyzed in CRSS. Although NHTSA collected similar variables in CRSS  and NASS/GES, differences in the sampling methodologies of each may contribute to differences in the estimated number of pedestrian crashes  between 2008 through 2015 and 2016 through 2018 timeframes.

We used agency technical documentation for CRSS and NASS/GES as  well as guidance from NHTSA statisticians to estimate the sampling error  associated with our estimates derived from CRSS and NASS/GES data.  We express confidence levels of estimates derived from CRSS and  NASS/GES data at the 95 percent confidence interval. This level means  that we are 95 percent confident that the actual population values are  within this interval. Additionally, for our analysis, we used CRSS and  NASS/GES variables that included imputed values for items missing  data on the estimated number of pedestrian crashes by vehicle age,  vehicle body type, and pedestrian injury severity. We reviewed and  assessed NHTSA technical documentation for their statistical imputation  methodology and determined it was sufficiently reliable for us to make  use of the vehicle age, body type, and injury severity variables with  imputed data.

In addition to analyzing NHTSA databases, we analyzed data from the  Highway Loss Data Institute (HLDI), an organization affiliated with the  Insurance Institute for Highway Safety (IIHS), to better understand how  the U.S. vehicle fleet has changed, specifically between 2008 and 2018.  HLDI collected and decoded vehicle identification numbers (VINs) for  each model year between 1983 and 2018. For HLDI’s analysis, it used  VINs from its member companies, among other sources, and information  encoded in the VIN to determine the body styles for these VINs.  According to HLDI, passenger cars include regular two-door models,  regular four-door models, station wagons, minivans, sports models and  luxury models, while SUVs are vehicles with conventional front-end  constructions and large passenger and cargo areas which can be built on  either heavy-duty chassis capable of off-road use or passenger car  platforms. HLDI definitions for vehicle body type classifications differ from  those used by NHTSA. According to HLDI officials, however, the  classifications are comparable. For our analysis, we used these data to  calculate the proportion of vehicles that were passenger cars, light trucks,  or SUVs from 2008 through 2018.

We also conducted interviews with federal government and non- governmental organizations about the relationship between vehicle  related characteristics and pedestrian injuries and fatalities, as well as  issues related to NHTSA’s pedestrian safety data and potential data gaps  and limitations. To discuss NHTSA’s pedestrian safety data, we spoke  with NHTSA officials from the Data Reporting and Information Division,  Mathematical Analysis Division, and Vehicle Research and Test Center.  We also spoke with officials from the National Transportation Safety  Board, which conducts independent accident investigations and  advocates for safety improvements, including those related to pedestrian  safety and motor vehicles. Non-governmental organizations we spoke  with included IIHS and major auto industry trade associations, such as  the Alliance of Automobile Manufacturers, Association of Global  Automakers, the Motor and Equipment Manufacturers Association, and  the Automotive Safety Council. We also spoke with vehicle safety  advocates, such as the Governors Highway Safety Association. These  organizations were selected based on their relationship to the auto  industry, referrals from other interviewees, and recent publications on  pedestrian-motor vehicle safety issues. We also identified and reviewed  studies either published or referenced by these organizations to better  understand research related to pedestrian injuries and fatalities and motor  vehicle characteristics. Where appropriate, we conducted a  methodological review of these studies.

Further, we spoke with academic researchers from six research centers  across four universities with expertise in human-vehicle interaction and  pedestrian-motor vehicle safety, including injury biomechanics and auto  industry data analysis. These researchers were selected based on  referrals from other interviewees and reviews of their organization’s  websites to ensure that their research would be informative for our  purposes. Although these organizations had, or have, relationships with  NHTSA or the auto industry, we included them based on their expertise  with issues related to our work. Based on these criteria we interviewed  officials at the University of Virginia (Center for Applied Biomechanics);  the Ohio State University (Center for Automotive Research; Injury  Biomechanics Research Center); the University of North Carolina  (Highway Safety Research Center), and the University of Michigan  (University of Michigan Transportation Research Institute; International  Center for Automotive Medicine). We conducted interviews with these  researchers to better understand general information on the relationship  between vehicle-related characteristics and pedestrian injuries and  fatalities, uses and limitations of NHTSA data, and potential areas for  further research. Results of our interviews are not generalizable to the  universe of non-governmental organizations or researchers studying  pedestrian-motor vehicle safety. We also spoke with automakers and  equipment suppliers about pedestrian safety and data needs. The  automakers and equipment suppliers were the same as those contacted  about how automakers are addressing pedestrian safety (discussed  below).

Finally, we reviewed documents and interviewed NHTSA officials about  the Crash Injury Research and Engineering Network (CIREN) and the  associated CIREN pedestrian pilot program NHTSA recently initiated.  This pilot will assess data collection approaches and methodologies for  pedestrian injuries resulting from motor vehicle crashes. Specifically, we  reviewed CIREN contract and methodology documents such as the 2016  CIREN Request for Proposal, 2018 CIREN Pedestrian Pilot Study  Request for Proposal, Task Orders for CIREN centers participating in the  pedestrian pilot study, CIREN Pedestrian Crash Process and Coding  Manual, and the Pedestrian Crash Inclusion Criteria. We also interviewed  NHTSA officials responsible for managing the CIREN program and the  pedestrian pilot study. We assessed this program using criteria for  designing successful pilot programs developed during prior GAO work.

To describe the approaches automakers have taken to address  pedestrian-motor vehicle safety and discuss stakeholder perspectives on  these approaches, we contacted automakers that sell new vehicles in the  United States. Specifically, NHTSA provided us with a list of 17  automakers that participated in the 2018 New Car Assessment Program.  NHTSA officials told us they do not necessarily include automakers with  low sales volumes in NCAP testing. As a result, to better ensure that we  had a complete list of automakers that sell vehicles in the United States  we compared the names on NHTSA’s listing to the membership lists of  the Alliance for Automobile Manufacturers and the Association of Global  Automakers—two major trade associations of the auto industry. Officials  told us that between the two organizations we would account for most, if  not all, of the automakers that sell new vehicles in the United States.  Finally, we compared our list with 2018 market share data from Ward’s Automotive to identify the automakers with the highest U.S. sales. Based  on our analysis, we identified 17 automakers to include in our work.  However, during our contacts with automakers, we determined that one of  the 17 automakers—Porsche—was part of the Volkswagen Group. Thus,  our final review resulted in a total of 16 automakers to contact as part of  our study (see table 2). Thirteen of the 16 automakers responded to our  request for information.

We developed a semi-structured interview instrument to collect  information from the automakers. This instrument focused on the  approaches that automakers took to address pedestrian-motor vehicle  safety. The semi-structured interview instrument was peer reviewed by an  independent survey specialist and pretested with two automakers before  we began collecting data. Based upon on their responses, we revised and  clarified the semi-structured interview instrument. In total, 13 of 16  automakers completed and submitted the semi-structured interview  instrument. Those 13 automakers represented approximately 70 percent  of new vehicle sales in the United States for 2018. The interview  instrument asked automakers to identify pedestrian safety features on  their 2019 model year vehicles, as these vehicles would have the most  recent pedestrian safety features available at the time of our work.  Although 12 of the 13 automakers did not respond in full to all the  questions on the semi-structured interview instrument, we obtained  additional information through telephone and in-person interviews  conducted from May 2019 through October 2019. The results of these  interviews are not generalizable to the universe of automakers that may  sell vehicles in the United States. Upon completion of all the interviews, a  GAO methodologist compiled the individual responses from each of the  13 automakers into a database. We used this database to perform a  qualitative content analysis to identify common themes and the frequency  with which the automakers identified certain issues related to pedestrian  safety. A GAO analyst independently verified the themes and certain  other information we received from the automakers to ensure accuracy  and completeness.

We also used semi-structured interview instruments to obtain information  on stakeholders’ perspectives on the approaches automakers have taken  to pedestrian safety. For purposes of this report, we define stakeholders  as automakers, auto equipment suppliers, and auto industry trade  associations. These organizations develop or deploy pedestrian safety  technology in motor vehicles, or, in the case of the trade associations, are  knowledgeable about the legal and regulatory issues related to pedestrian  safety and the auto industry. In addition to interviewing 13 automakers,  we interviewed officials from five auto equipment suppliers and four auto  industry trade associations (see table 3). The five auto equipment  suppliers included in our work were identified with the assistance of the  Motor and Equipment Manufacturers Association, a trade association for  auto industry suppliers. The organization provided us the names of seven  equipment suppliers, five of which agreed to participate in our semi- structured interviews. In general, these equipment suppliers develop or  produce equipment used in motor vehicle crash avoidance or crash  mitigation systems. The semi-structured interview instrument asked  questions about such things as crash avoidance and crash mitigation  technology and the benefits and challenges of this technology. We did not  assess the effectiveness of these features. Additionally, we interviewed  officials from four auto industry trade associations. We conducted  telephone and in-person interviews with these stakeholders from March  2019 through September 2019.

In addition to automakers, equipment suppliers, and auto industry trade  associations, we also interviewed NHTSA and IIHS about crash  avoidance and crash mitigation technology and reviewed applicable  federal regulations related to pedestrian safety. These include federal  headlight and bumper standards. We also reviewed an October 2018  Notice of Proposed Rulemaking in which NHTSA agreed to evaluate  proposed amendments to current federal motor vehicle headlight  requirements. We discussed with NHTSA the federal headlight and  bumper standards and how these relate to pedestrian safety, as well as  any potential changes to these standards to better accommodate  pedestrian safety. Lastly, we reviewed an October 2019 IIHS press  release and an October 2019 American Automobile Association study  discussing the results of pedestrian crash avoidance tests each  organization performed.

To assess NHTSA’s actions related to pedestrian safety and NCAP, we  reviewed applicable federal laws and regulations related to vehicle safety  as well as documents published in the Federal Register, such as  Requests for Comments, soliciting comments on proposed NCAP  changes related to pedestrian safety. NHTSA provided a high-level  summary of comments received from Requests for Comments issued in  2015 and 2018 that we reviewed. We reviewed selected comments and  supporting documents submitted to NHTSA as part of the docket in  support of the Requests for Comment, such as those provided by auto  industry trade associations, automakers, and auto equipment suppliers.  We also reviewed program documents discussing how NHTSA assesses  new car safety, performs NCAP safety tests, and reports the results to the  public. Further, we reviewed over 55 studies and presentations on the  agency’s work related to pedestrian safety. NHTSA highlighted 22 of  these reports and presentations as being representative of the body of  research that supported and facilitated agency decisions and policies with  respect to pedestrian safety, including the 2015 and 2018 Requests for  Comments. We reviewed the 22 reports and presentations and  determined that 14 met our inclusion criteria, in that the reports and  presentations were focused on potential pedestrian safety tests and their  applicability to the U.S. vehicle fleet, the use of various test instruments,  and the potential safety effects associated with technologies intended to  avoid and mitigate crashes. Where appropriate, we conducted a  methodological review of these studies. In addition, NHTSA officials  provided additional studies after our interviews, which we also reviewed.

To better understand pedestrian safety testing and issues related to  incorporating such testing into NCAP, we visited NHTSA’s Vehicle  Research and Test Center in East Liberty, Ohio. We interviewed officials  there about NHTSA pedestrian safety research and how it supported  NHTSA’s proposed pedestrian safety tests for NCAP. We also discussed  the applicability of pedestrian safety tests to the U.S. vehicle fleet,  including tests used by Euro NCAP. During our visit, we observed  examples of a pedestrian crash mitigation test for lower leg injury and a  rear-facing pedestrian crash avoidance test. We reviewed NHTSA’s  budget documentation on pedestrian safety research from fiscal year  2008 to 2019, the most recent year for which data were available. We  also visited and discussed pedestrian safety issues with officials of IIHS’  Vehicle Research Center in Ruckersville, Virginia. We observed a  forward-facing pedestrian crash avoidance test. Further, we interviewed  NHTSA officials about such things as the process for making changes to  NCAP and activities associated with this process, documentation of this  process, how NCAP changes are communicated to stakeholders, and  NHTSA plans for determining whether to incorporate pedestrian safety  tests in NCAP. Finally, we interviewed automakers, auto industry  equipment suppliers, and IIHS about incorporating pedestrian safety tests  into NCAP.

To understand how other NCAPs address pedestrian safety, we  interviewed officials from Euro NCAP and received written responses  from JNCAP to a set of questions we sent them. We also reviewed  supporting documents from both Euro NCAP and JNCAP on pedestrian  crash avoidance and mitigation tests they perform and how such tests are  scored when determining star ratings. Further, we discussed with Euro  NCAP how it works with the auto industry to test vehicles and to develop  future changes to Euro NCAP, including the Euro NCAP roadmap. We  also reviewed selected international studies related to the real-world  benefits of pedestrian safety testing performed by Euro NCAP. We  determined those studies to be sufficiently reliable for our purposes.

To assess how NHTSA’s process for making changes to NCAP compares  to leading practices, we reviewed the Project Management Institute, Inc.,  The Standard for Program Management, and GAO’s Standards for  Internal Control in the Federal Government. The Project Management  Institute’s standards are utilized worldwide and provide guidance on how  to manage various aspects of projects, programs, and portfolios. In  particular, according to The Standard for Program Management, this  standard provides guidance that is generally recognized to support good  program-management practices for most programs, most of the time.

We conducted our work from February 2019 to April 2020 in accordance  with generally accepted government auditing standards. Those standards  require that we plan and perform the audit to obtain sufficient, appropriate  evidence to provide a reasonable basis for our findings and conclusions  based on our audit objectives. We believe that the evidence obtained  provides a reasonable basis for our findings and conclusions based on  our audit objectives.

Appendix II: Additional Data on Pedestrian Crashes in the United States, 2008 through 2018

This appendix contains additional information on pedestrian fatalities and  the estimated number of pedestrians injured from 2008 through 2018.

Although we included much of our pedestrian fatality analysis in the  report, this appendix includes data on the number of pedestrian fatalities  involving particular light conditions and relationships to intersections— environmental factors relevant to pedestrian crashes—as well as data on  vehicle body types (see fig. 11, 12, and 13). We used data from the  National Highway Traffic Safety Administration’s (NHTSA) Fatality  Analysis Reporting System (FARS) to compile information on pedestrian  fatalities.

The following figures show information about the estimated number of  pedestrians injured from 2008 through 2018 (see figs. 14, 15, 16, 17, and  18). These figures show pedestrians injured by age of the striking vehicle,  body type of vehicle, reported speed of the vehicles, and estimated  number of pedestrians with serious or fatal injuries. We used data from  NHTSA’s Crash Report Sampling System (CRSS) for years 2016 through  2018, and National Automotive Sampling System/General Estimates  Survey (NASS/GES) for years 2008 through 2015 to compile information  on pedestrians injured. Within CRSS and NASS/GES databases, we  specifically analyzed data on pedestrians injured by vehicle related  characteristics such as the age, body type, and speed of vehicles that  struck and injured pedestrians, as well as the estimated number of severe  and fatal pedestrians injured.

Appendix III: Benefits and Challenges of Pedestrian-Motor-Vehicle Safety Features

As part of our analysis on how automakers are addressing pedestrian  safety through crash avoidance and crash mitigation technologies, we  obtained the views of 13 automakers and five auto equipment suppliers.  As discussed below, auto industry officials provided their views on the  benefits and challenges of commonly available crash avoidance and  crash mitigation technologies.

Automaker and auto equipment supplier officials identified various  benefits and challenges with pedestrian crash avoidance features. For  example, 12 of 13 automakers reported and two of five auto equipment  suppliers said that crash avoidance features have the overall potential  benefit of eliminating or reducing car-to-pedestrian accidents. The  Highway Loss Data Institute reported in 2017 that one automaker’s  pedestrian automatic emergency braking system reduced pedestrian- related bodily injury liability claims by 35 percent compared to other  vehicles manufactured by that automaker. In addition, the automaker  itself found that, in Japan, its vehicles equipped with the system  experienced 60 percent fewer accidents with injury compared to its  vehicles without the system.

Officials from automakers and auto equipment suppliers we interviewed  also identified challenges with pedestrian crash avoidance technologies.  Specifically, stakeholders cited some distinctions between the  performance of camera-based and radar-based pedestrian automatic  emergency breaking systems. Almost half of the automakers we  interviewed (six of 13) reported that a primary challenge with a camera- based pedestrian automatic emergency braking system was the camera’s  ability to work in low lighting and poor weather. As previously noted in this  report, about 75 percent of all reported pedestrian fatalities occurred in  2018 after dark.

In contrast, several automakers stated that radar based pedestrian  detection systems are not dependent on light to function, but that they are  less effective at identifying pedestrians than camera-based systems.  Officials from another automaker said manufacturers have attempted to  offset the challenges of cameras and radar by developing “fusion”  systems (combination of camera and radar). These officials said,  however, these systems add complexity and processing time to the  technology because the system must manage two separate functions that  must be processed together to identify a pedestrian. Officials from  automakers said that a challenge affecting both camera- and radar-based  systems was limiting the occurrence of false positives, or the activation of  these systems when they are not required.

Recently issued research has raised questions about the overall  effectiveness of crash avoidance systems. In October 2019, the American  Automobile Association (AAA) reported that, based on its own  assessment, some vehicles’ pedestrian safety systems were inconsistent  at either slowing down or stopping a vehicle to avoid hitting a pedestrian.  For example, AAA reported that dark conditions could affect the  effectiveness of available pedestrian detection systems and that none of  the crash avoidance systems on the four vehicles they tested worked in  dark conditions.

Automaker officials told us that the performance of crash avoidance  systems could be improved through updates to current vehicle headlight  standards. Specifically, officials from four automakers indicated that the  National Highway Traffic Safety Administration (NHTSA) should update  federal standards for headlights to permit the use of adaptive driving  beam headlights on new vehicles. Adaptive driving beam headlights are  currently in use in European and other countries, and are different from  the combination high- and low-beam systems used in the United States.  In general, adaptive driving beam headlights use advanced sensors and  computing technology to shape the headlamp beams to provide  enhanced illumination of unoccupied portions of the road and avoid  glaring other vehicles.

In October 2018, NHTSA published a Notice of Proposed Rulemaking in  which it tentatively concluded that federal standards for headlights do not  permit adaptive driving beam systems because those systems would not  comply with some of the standards. NHTSA, however, has said adaptive  driving beam headlights have the potential to create significant safety  benefits in avoiding collisions with pedestrians, cyclists, animals, and  roadside objects by providing additional front-end illumination. Five  automakers we interviewed said that they offer adaptive driving beam  headlamps as a crash avoidance technology on their vehicles sold in  other countries. In its October 2018 Notice of Proposed Rulemaking,  NHTSA sought public comment on amending federal standards to allow  the use of adaptive driving beam systems in response to a petition from  an automaker. NHTSA officials said that it is in the process of developing  a final rule but did not have a period for when it would be issued.

Another challenge for crash avoidance systems is the federal standard for  bumpers. As previously discussed in this report, this standard requires  that vehicles, including their bumpers, meet specified damage criteria  when bumpers are hit at 2.5 miles-per-hour (mph). Officials from five  automakers said that this standard presented challenges with the  placement of crash avoidance sensors. On some vehicles, crash  avoidance sensors are placed in the same area where the vehicles are  tested for compliance with the bumper standard. As a result, the test  could damage or destroy the crash avoidance sensor. Two automaker  officials told us that they have addressed this challenge by relocating the  sensors to another part of the vehicle to avoid conflicts with the bumper  standard. NHTSA officials told us they are in the process of reevaluating  the bumper damageability standard, including the placement of sensors,  as part of a Notice of Proposed Rulemaking, which they expect to publish  in early 2020.

Crash Mitigation Benefits and Challenges

Officials from automakers and auto equipment suppliers we interviewed  identified benefits and challenges for pedestrian crash mitigation features.  For example, 12 of 13 automakers reported and one of five auto  equipment suppliers said that pedestrian crash mitigation features have  the overall benefit of reducing the risk or severity of pedestrian injuries.  Officials from four automakers, however, said that crash mitigation  features do not protect pedestrians from the secondary impact of an  accident, such as the residual injuries from hitting the pavement.  Additionally, officials from six automakers said that crash avoidance  features were more effective than crash mitigation features because the  purpose of crash avoidance features is to prevent the collision from  occurring in the first place.

Similar to crash avoidance, the federal bumper standard may also affect  crash mitigation systems. Officials from eight automakers said that the  bumper standard created challenges to offering additional crash  mitigation features in the United States, such as softer, more pedestrian  friendly bumpers. Officials from the eight automakers said they offered  softer bumpers in Europe or elsewhere—where there is no similar  bumper standard—but do not offer softer bumpers in the United States.  Some stakeholders told us the current bumper standard runs counter to  pedestrian safety, and softer bumpers would help mitigate the severity of  pedestrian injuries. Similarly, NHTSA officials told us the current bumper  standard is primarily a cost savings standard in that it is intended to  reduce repair costs and not necessarily to offer safety protection for  vehicle occupants. NHTSA officials told us that establishing a bumper  standard that addresses pedestrian safety, yet minimizes bumper  damage and repair costs requires tradeoffs. The officials told us as part of  the Notice of Proposed Rulemaking it is reviewing the broader  damageability requirement.

Appendix IV: Comments from the U.S. Department of Transportation

Appendix V: GAO Contact and Staff Acknowledgments

Andrew Von Ah, Director, (202) 512- 2834 or vonaha@gao.gov  In addition to the contact named above, Matt Barranca (Assistant  Director), Richard Jorgenson (Analyst-in-Charge), Carl Barden, Namita  Bhatia-Sabharwal, Melissa Bodeau, Breanne Cave, Michelle Everett,  Susan Fleming, Geoff Hamilton, Hannah Laufe, Regina Morrison, Joshua  Ormond, Terry Richardson, and Michael Steinberg made significant  contributions to this report.

On average, 17 pedestrians died each day in 2018 as a result of vehicle crashes—up 43% from 2008. Automakers offer safety features on many new cars to help protect pedestrians. For example, crash avoidance technologies use cameras or radar to detect pedestrians and warn drivers or automatically slow or stop the car.

The National Highway Traffic Safety Administration has researched pedestrian safety and developed procedures to test new cars. In 2015, NHTSA proposed including these tests in its new car assessment program, but hasn’t made a decision on how to move forward or set a timeline for that to happen. We recommended they decide.