"The Government operates the largest fleet of motor vehicles. As a consumer then, its leadership in requiring safety devices will be most influential.

"The purpose the council seeks is to get people to demand the installation and to use those proven safety devices that reduce the dangers of serious injury in the event they are involved in a traffic accident. The council believes that leadership on the part of the Federal Government in recognizing the value of such devices by having them installed in Government vehicles will contribute substantially to the council's purpose, and the council urges that the Government take such leadership."

This position of the council was in direct opposition to several automobile company vice presidents who testified against the bill.

Mr. Nader says: "In view of the odds against the success of Roberts' efforts, H.R. 1341 was a stroke of legislative genius." To counteract his attack on us, we mention that Mr. Johnson actively assisted Congressman Roberts in the original development of the concept of H.R. 1341. This hardly detracts from Roberts' fine leadership.

1960. In making reference to the action program for highway safety, Mr. Nader says, * * * the program has been unchanged since 1949 * * *.” He's wrong. It was thoroughly revised in 1960, and two new sections were added, in 1963 and 1965.

A strong role was played by the council in the 1960 revision of the action program for highway safety, adding a vehicle engineering section which remains the best single policy guide today. Mr. Pyle was Chairman of the Advisory Council of the President's Committee at the time.

A full reading of the section is recommended, but a few excerpts regarding design are pertinent:

Page 57 (first page of this subsection): "Despite the importance of past accomplishments, industry's future contribution to highway safety may be even greater. Fields requiring concentrated attention are vehicle handling, truck vibration and riding qualities, and the protection of vehicle occupants."

Page 58: "Vehicle response to either control or distrubance should be within the capabilities of the driver."

Page 65: "A major challenge to vehicle lighting engineers has been to provide the night driver with a satisfactory view of the roadway and traffic environment under all conditions of weather, at normal driving speeds.

"Just as critical is the need for lights which will communicate at all times the whereabouts of the vehicle in the traffic stream, and the intention of the driver to change speed or direction.

"Also needed is an indication of whether the vehicle is stopped or moving only very slowly, or is disabled.

"For the future, a sizable research effort must be directed to the communication problem by the motor vehicle industry and others appropriately concerned with this aspect of traffic safety."

Page 67: "There is general satisfaction with the performance of passenger car brakes, but there is still some tendency for vehicles to swerve out of the traveled lane and for brakes to fade during stops from high speeds. These deficiencies appear to involve both design and poor maintenance."

Pages 68 and 69: “Well-known engineering principles are applicable to all current and proposed methods of minimizing crash injuries. The integration of these principles into vehicle design would substantially reduce the number of fatalities and extent of injuries in vehicle accidents. These principles include:

"1. Providing a structure that will absorb energy by controlled deformation and at the same time prevent major deformation of the passenger compartment.

"2. Providing occupants with appropriate restraint to prevent uncontrolled body motion.

"3. Preventing ejection of occupants from vehicle.

"4. Minimizing application of concentrated forces on occupants due to body impact with interior elements.

"5. Reducing likelihood of fire."

Page 69: "Seat belts and even shoulder harnesses are recognized as interim or incomplete solutions. They do not provide all the types of restraint that are felt to be desirable. Their particular lack is that they do not offer head restraint to minimize neck injuries in both head-on and rear end collisions."

49-959-66-pt. 3- -19

Pages 69 and 70: "Rollover strength of current designs is not always sufficient to prevent major structural deformation but is generally sufficient to prevent collapse. Planned structural deformation of the body structure to absorb energy in collisions and to distribute impact forces should become a primary design consideration."

Pages 7 7and 78 (summary): "20. The automotive industry should continue its efforts to improve all elements of vehicle design having a bearing on safety. The relative importance of proposed vehicle changes should be assessed to insure that the items of greatest potential benefit are kept under attention. Greater effort is needed in

"(a) Developing more rugged and effective equipment for defrosting and cleaning windshields and rear windows under severe weather conditions. "(b) Standardizing the placement of instruments and controls, and advancing their functional design.

"(c) Implementing basic safety design concepts, particularly those related to restraining devices, dissipation of impact energy, and the lessening of structural deformation in the passenger compartment.

"(d) Conducting collision research to establish criteria for structural design and to determine the effect of the forces involved on both restrained and unrestrained occupants.

"(e) Evaluating the safety aspects of various types of automatic controls. "(f) Determining causes of commercial vehicle fires and means for alleviating these through vehicle design and operating procedures.

"21. Driver fatigue should be reduced and comfort improved by the functional design of passenger car bodies and truck cabs to provide more adequate seating, by the reduction of truck cab noise and virbation, and by the provision of more durable exhaust systems.

"22. Research on vehicle handling should be intensified with respect to— "(a) Provision of maximum maneuverability compatible with driverreaction and vehicle-response times.

"(b) Improving traction on low-friction surfaces.

"(c) Reducing vehicle response to road and aerodynamic disturbances. "23. Industry, highway-user groups, and the Government should intensify their research and development on brakes, to the end that

"(a) The performance of truck brakes may more nearly approach that of passenger car brakes.

"(b) Practical antilocking devices of special benefit on slippery surfaces may be developed.

"(c) Metering devices may be produced to keep braking forces proportional to the load carried on each axle, whether the vehicle is loaded or unloaded.

"(d) In the event of partial brake failure on single unit vehicles, brakes may still operate on one axle.

"(e) Adequate braking or retarding capacity may be available for the descent of long grades and for stopping from high speeds.

"24. Industry and public officials should cooperate in working out vehicle performance requirements that will insure for commercial vehicles the proper relationship between capacities of vehicle components and the gross loads as operated."

1960: General Stewart reiterated Council testimony on H.R. 1341 before the Senate Subcommittee on Surface Transportation of the Committee on Interstate and Foreign Commerce.

1962: When Ford openly bolted the speed advertising and racing resolution of 1957, the Council's president, Howard Pyle, voiced the Council's emphatic disapproval, urged reinstatement of the policy, and sent to the manufacturers a detailed analysis of the Council's views on the effects of speed-thrill advertising.

The following quotations summarize those views:

"The Council strongly believes that advertising and promotion which emphasize the speed-thrill aspects of motoring have the undesirable potential: "1. To adversely influence driver behavior and foster unsafe actions.

"2. To promote unsound concepts of motor vehicle use. "3. To undermine national speed control policies.

"4. To promote driving practices inconsistent with modern traffic requirements.

"5. To inhibit acceptance of safety devices.

"6. To counteract employee safety programs.

"7. To impair, or even destroy, public and legislative acceptance of compre hensive traffic control programs.

"8. To establish an unsound basis for a motor vehicle economy.

"9. To foster governmental regulation of aspects of traffic safety previously subject to voluntary controls."

1963. A new research section of the action program, edited by Dr. Murray Blumenthal, manager of the Council's Research Department, established some policy guides as to the importance and character of vehicle design research. Some excerpts follow:

Page 11: "While we can describe the characteristics of the driver without reference to his vehicle or his environment, it is obvious that anything said about him must be qualified by his relationship to these factors. A faulty vehicle can defy the efforts of the best driver * **

"Emphasis has been placed on the role of the driver as a factor in accidents because of his responsibility for dealing with the relatively inflexible characteristics of his vehicle and the environment."

Page 16: "Head injuries are involved in almost half of all dangerous injuries and more than half of all fatalities. Ejection from the automobile, and impact with the steering assembly, instrument panel, and windshield (in order of frequency), produce most of the dangerous and fatal injuries.

"As a result of extensive studies of motor vehicle injuries, the idea of 'packaging' the occupants of the vehicle has been advanced. This means providing a compartment for the occupants that is designed to protect them in a crash. Since each year approximately 1 car in 5 is in an accident and 1 car in 50 in an injury-producing accident, the necessity for built-in crash protection is obvious.

"Packaging includes securing the occupants with seat belts. In the event of an accident in which the vehicle is rapidly decelerated, the belts restrain the occupants from continuing forward at the original speed of the vehicle, and thus prevent them from smashing into the steering wheel, dashboard, windshield, or windshield header.

"It is important to keep the occupants within the compartment, since ejection through crash-sprung doors has been established as a major cause of injury. Ejection injuries are virtually eliminated by the wearing of seat belts, and are also reduced by improved door latches.

"Another aspect of packaging involves the elimination of knobs and decorations which could contribute to laceration and fracture of a rapidly moving body, and substituting energy-absorbing surfaces and structures such as padded dashboards for the conventional nonyielding materials. Hydraulic bumpers are also being developed for the safe reduction of impact forces. Future findings of research, economic factors, and the disposition of legislatures to require additional safety equipment of this nature will affect the schedule for its appearance in standard passenger cars."

Page 19: "** * fundamental principle of safety engineering: Anticipate every type of accident which may occur because of machine or human failure and then establish safeguards to eliminate the hazard or minimize the injury when failure occurs."

Page 21, Under research needs, the vehicle: "In applying the safety engineering concept to the vehicle, questions like the following can be asked: To what extent should lighting and signaling systems be standardized? What kind and how much 'feedback' from the road surface will assist the driver? Are drivercontrolled variations in steering ratio and brake pressure desirable? How can intervehicle communication be increased? How can headlight systems be improved? What additional safeguards can be built into tires? In what ways can the efficiency and reliability of braking systems be increased? How can vehicles be designed to absorb substantial portions of the impact forces generated in collisions? Additional questions are raised in part IV of the 'Engineering' section of the action program for highway safety."

1963. Rex M. Whitton, Federal Highway Administrator and then the council's vice president for traffic, in a keynote speech opening the National Safety Congress, the council's annual convention, said:

"I am concerned about the great amount of energy being devoted to ‘hard sell' efforts to reform the driver. *** I believe that because of these attacks, our attention is being distracted and our energy is being diverted from the essential things we could and should be doing to reduce the traffic accident toll." (Transactions, 1963, annual meeting of members; also, "Traffic Safety," January 1964.) 1964. The council launched a traffic accident data project to develop basic accident investigation and reporting systems to pinpoint, among other fators, vehicle and equipment failures.

1964. The council's "Metropolitan Life Award" of $1,000 was given to D. M. Severy, of UCLA, for his research report, "Automobile Side-Impact Collision Series II."

1965. The council's analysis of speed-thrill promotion (see 1962) was furnished to the Federal Trade Commission in connection with its inquiry into auto advertising.

1966. One thousand dollars "Metropolitan Life Award" was given to John J. Swearingen, of Civil Aeromedical Research Institute, Oklahoma City, for his report, "Tolerances of the Human Face to Crash Impact."

A $500 award made to L. M. Patrick, of Biomechanics Research Center, Wayne State University, Detroit, for his report, "Comparison of Standard and Experimental Windshields."

1966. The council will very shortly print its 11-year Guide to Traffic Safety Literature, cumulating annual guides published during the past 10 years. The new guide contains 190 entries under the heading "Motor Vehicle Design." D. The "powerful support" that is supposed to effectively gag the council's criticism of auto industry safety performance consists of a little more than 14 percent of the $2,960,000 the council spent in 1965 for programs aimed at traffic accidents, and about 6 percent of its total income. The remaining 86 percent spent on traffic consists of employer-purchased fleet safety services, plus money diverted from the general funds derived primarily from occupational safety services, with the consent of the members who recognize the council's broad charter responsibilities to combat accidents wherever they occur.

The 14 percent, or $422,950, in grant money was contributed by the auto and auto-related industries ($254,950) and by the insurance industry ($168,000). Vital as this money is to the council's activities in field services, the traffic inventory, accident data and research correlation, and driver education in schools, credulity is taxed when it is described as powerful support that could stifle criticism, and the amount is paltry in the light of traffic safety's needs. In fact, at the present time the council has a petition before the Automobile Manufacturers Association for a total of $924,000 annually to expand and improve council traffic programs.

Another source of domination, Mr. Nader intimates, is that "the automobile manufacturers and their safety organizations are heavily represented on the [council] board." Of the 201 members of the board, 13 are directly employed by auto manufacturers. Six of the thirteen are engaged in employee safety programs for their companies, and one is a farm equipment engineer.

Another group of 14 might be described as auto related if you include tire and oil people, a trailer manufacturer, a Georgia auto finance company, and two men from Du Pont because their company once controlled GM and undoubtedly still sells them things such as paint and glass laminates.

The author would have the public believe that these groups control the remaining 87 percent of the board, which is made up of representatives of government, insurance, labor, education, farm groups, youth, religion, public information media, and many other areas of American life.

E. Miscellaneous:

1. Mr. Nader says that a draft of the Secretary of Commerce's 1959 report, "Federal Role in Highway Safety," was reviewed by the National Safety Council before publication. This is not true.

2. Mr. Nader quotes NSC opposition to Congressman Roberts' "National Accident Prevention Center" bill without mentioning the following quotation from

Mr. Johnson's extensive testimony on behalf of U.S. Public Health Service research programs:

"*** it should be amply clear that the National Safety Council believes that a contribution to safety will be made by creating within the Accident Prevention Division a U.S. Public Health Service Accident Prevention Research Center devoted to intramural research programs in the medical, clinical, and behavioral sciences."

Further, NSC opposition to an "overpowering center" was partly on behalf of the need for a similar engineer-oriented center in the Bureau of Public Roads (and perhaps other appropriate centers in other agencies) a goal now widely supported in the Congress.

3. The statistics department's January 29, 1966, memo, "Accident Statistics and Records" (attachment 2), has already been placed in the Ribicoff committee record. It analyzes a variety of common statistical failings in the 1965 testimony, including that of people quoted by Mr. Nader. Mr. Moynihan's testimony is analyzed, both its strong and weak points. The memo also describes the special effort we initiated several years ago to improve accident records.

4. The research statement (attachment 3) we prepared at the request of Senator Ribicoff should serve to answer Mr. Nader's allegations regarding NSC's research role.

5. Although the council has pushed the entire action program, including its vehicle engineering section, Mr. Nader feels the council blames the driver rather than the vehicle. We can cite our basic statement on the roles of highway, vehicle and driver (attachment 4) plus excerpts from the mass communications symposium (attachment 5). In any immediate preholiday period, or at any other given moment, the driver must cope with vehicle or road conditions as he finds them. There is a difference between short-range and long-range goals in public education.

6. Mr. Nader questions the validity of the action program. The degree of proof of the validity of action program recommendations varies widely from section to section. The engineering portions are heavily supported by research and demonstration. Other sections such as education and public information draw upon the pertinent sciences but need additional research. Such a section as organized citizen support represents application of the general political science literature plus case histories. The National Safety Council is just completing a multiple correlation study of program and nonprogram factors as related to accident rates. The multiple correlation study was discussed in appendix 3, item 3, of our Ribicoff presentation. Further, numerous references to traffic safety literature supporting various elements of the action program were in appendix 5, the systems approach.

7. A misleading and major flaw in Mr. Nader's rationale in his failure to discuss actual use of seat belts as a vital precondition for full effectiveness of vehicle design improvements. Promoting seat belt use will continue to be a primary goal of the council's public education efforts aimed at the driver, all the while emphasizing need for the comprehensive action program.

EXHIBIT 111

NATIONAL SAFETY COUNCIL

A GENERAL STATEMENT ON FACTORS IN TRAFFIC ACCIDENTS

Almost every traffic accident is likely to involve one or more deficiencies of drivers, and pedestrians, and vehicles, and the road.

At any given moment, improved driver performance and adequate vehicle maintenance can help drivers cope with traffic conditions as they are drivers can drive in such a way as to avoid accidents despite adverse conditions and actions of pedestrians and other drivers. This is called defensive driving.

However, consumer acceptance and demand for safer vehicles, and public support for governmental road, vehicle, and driver improvement programs is essential to attainment of minimum accident rates.

The automobile industry has the responsibility for manufacturing vehicles which are progressively easier to operate safely and minimize injury potential. Public officials responsible for governmental programs must propose sound and adequate official action and administer authorized programs efficiently.