Interpretation ID: nht75-6.31

DATE: 07/16/75

FROM: WILLIAM T. COLEMAN -- SECRETARY OF TRANSPORTATION

TO: B. J. CAMPBELL -- CHAIRMAN, NATIONAL MOTOR VEHICLE SAFETY ADVISORY COUNCIL DEPARTMENT OF TRANSPORTATION

TITLE: NONE

TEXT: Dear Dr. Campbell:

As you and the many members present at the Council's last meeting will recall, Dr. Gregory asked the Council to consider two important questions facing NHTSA's motor vehicle safety program. I would like to formally reiterate that request and emphasize the importance of obtaining the Council's collective advice on them.

The first concerns the way NHTSA does business. As a regulatory agency, NHTSA establishes motor vehicle safety standards under the Administrative Procedure Act. Similarly, there are administrative procedures for ensuring industry compliance with those standards. In addition, NHTSA is responsible for monitoring the safety defects of motor vehicles on the highways and has established procedures for carrying out that task.

We are constantly in the process of reviewing, revising, and expanding these procedures. I ask that the Council look at them and determine whether NHTSA is being fair to all involved and at the same time responsive to the requirements of public safety and the mandates of Congress. Are these procedures timely, logical and equitable? Can they be improved?

The second important question concerns the role of cost/benefit studies in our safety standards process. Dr. Gregory and I have taken the position that cost/benefit analysis is important and should always be considered when developing a new or reviewing an existing safety standard. But the cost/benefit factors can be only one input. For example, in the transportation of school children we have a public that demands the safest possible ride on school buses, cost/benefit ratios notwithstanding. On the other hand, we clearly want to avoid a situation of rapidly rising costs with no or little increase in benefits. The question is -- how do we handle this in relation to public values and industry demands? Dr. Gregory and I believe that in any regulatory program standards should be set at a level where the cost -- in terms of dollars, inconvenience, or whatever -- is modest in proportion to the increase in safety benefits. I realize that the Council's Fourth International Congress on Automotive Safety is in large part directed at this question. I hope the information presented there and the ensuing discussions will aid the Council in tackling this important issue.

I've asked Dr. Gregory to make available background material and briefings to aid the Council in deliberating these questions, and I look forward to receiving the Council's advice.

Sincerely,