Submission at the Workshop on Risk Assessment in Regulatory Policy Analysis (RIA), Session 8, Mexico, 9-11 June 2014. Further information is available at http://www.oecd.org/gov/regulatory-policy/

1. Identifying
Benefits
–
NHTSA
Prevention
of
Backover
Pedestrian
Accidents
In
2007
the
United
States
Congress
directed
the
National
Highway
Transportation
Safety
Administration
(NHTSA)
to
issue
a
final
rule
amending
the
agency’s
Federal
motor
vehicle
safety
standard
on
rearview
mirrors
to
improve
the
ability
of
a
driver
to
detect
pedestrians
in
the
area
immediately
behind
his
or
her
vehicle
and
thereby
minimize
the
likelihood
of
a
vehicle’s
striking
a
pedestrian
while
its
driver
is
backing
the
vehicle
(a
“backover”
crash).
NHTSA
undertook
a
regulatory
impact
analysis
to
evaluate
alternative
strategies
to
reduce
deaths
and
injuries
from
backover
crashes.
As
the
base
case,
NHTSA
found
that
“available
safety
data
indicates
that
on
average
there
are
292
fatalities
and
18,000
injuries
(3,000
of
which
we
judge
to
be
incapacitating)
resulting
from
backover
crashes
every
year.
Of
those,
228
fatalities
and
17,000
injuries
were
attributed
to
backover
incidents
involving
light
vehicles”
(GVW
<
10,000
pounds).
NHTSA
also
identified
key
attributes
of
the
accidents
including
“many
of
these
incidents
occur
off
public
roadways,
in
areas
such
as
driveways
and
parking
lots
and
involve
parents
(or
caregivers)
accidentally
backing
over
children.
Second,
children
under
five
years
of
age
represent
approximately
44
percent
of
the
1fatalities,
which
we
believe
to
be
a
uniquely
high
percentage
for
a
particular
crash
mode.”
NHTSA
evaluated
the
effectiveness
of
three
currently
available
technologies
(mirrors,
sensors,
and
rearview
video
systems)
to
determine
if
an
individual
was
in
a
10
x
20
foot
zone
directly
behind
the
vehicle
–
presumably
avoiding
a
backover
crash.
They
also
estimated
savings
from
property
damage
when
a
crash
is
avoided.
NHTSA
identified
the
rearview
video
system
as
the
most
effective
option,
saying,
“we
believe
the
annual
fatalities
that
are
occurring
in
backing
crashes
can
be
reduced
by
95
to
112.
Similarly,
injuries
would
be
reduced
by
7,072
to
8,374.”
Rearview
video
is
also
the
most
expensive
option
and
NHTSA
observed
“to
equip
a
16.6
million
new
vehicle
fleet
with
rearview
video
systems
is
estimated
to
be
$1.9
billion
to
$2.7
billion
annually.”
The
final
analysis
suggested
that,
using
“discount
rates
of
3
and
7
percent,
the
net
cost
per
equivalent
life
saved
for
camera
systems
ranged
from
$11.8
to
$19.7
million.
For
sensors,
it
ranged
from
$95.5
to
$192.3
million
per
life
saved.
According
to
our
present
model,
none
of
the
systems
are
cost
effective
based
on
our
comprehensive
cost
estimate
of
the
value
of
a
statistical
life
of
$6.1
million.”
• Is
this
an
example
of
actuarial
or
modeled
risk
information
informing
a
regulatory
impact
analysis?
• Are
there
non-­‐quantifiable
benefits
that
might
have
a
significant
influence
on
judgment
of
the
desirability
of
the
crash
avoidance
options?
Would
they
differ
between
options
• NHTSA
has
proposed
to
require
the
rearview
video
system.
Is
that
a
reasonable
judgment?
1
NHTSA
Proposed
Rule
and
Analysis