Answering that question means you have an answer to the question of what is happening with the certification of a whole range of aftermarket devices, among which is the RiveMove certification.
The certification of some manufactured road safety devices has become a very controversial topic. It is a very important topic as it concerns the safety of our children. That’s why it is necessary to clear up what is happening with the certification of all accessories within a vehicle, such as RiveMove, and what the key points of this topic are.
Is RiveMove approved or certified?
Firstly, we should make it clear how the term certification is defined and how it differs from the commonly-used term of approval. These terms are usually confused by people who are not familiar with them. We will also analyse other terms such as accreditation or self-certification.
Certification is a process whereby a body completely independent of the manufacturer issues a document to confirm that an organisation, product, process or service meets the requirements specified in one or more technical standards or specifications. In the case by which we are concerned, RiveMove is certified by the Italy-based accredited laboratory CSI-Spa, according to the provisions of the most up-to-date and stringent standard of any that currently apply to Child Restraint Systems, i.e. ECE-R129 aka I-Size.
CSI-Spa is a renowned organisation with sufficient capacity to perform relevant tests under the correct conditions of execution and procedure. It specialises in children’s passive safety and is a member of the now widely-recognised EuroNCAP.
As for approval, it is defined by the Royal Spanish Academy as: “the action of verifying that an object or action fulfils certain specifications or characteristics”. In other words, it is when an official body approves a product or service for marketing purposes, in light of the fact that it has fulfilled a series of specifications. If we take the definition literally, we could say the RiveMove is approved, as the definition of this term and the definition of certification are virtually identical. However, we at RiveKids feel more comfortable making the distinction between Certification and Approval.
What specifications or characteristics is an approved device required to fulfil?
Child Restraint Systems are subject to the specifications set forth in ECE R44 or the new I-Size R129. We would be in the situation of certification. However, Child Restraint Systems have an approval number issued by an independent and accredited laboratory, the same body that issues certification, only in this case each safety seat will have an identification. RiveMove undergoes the same tests at the same site, but at the end of the process it is a certificate and not an identification (as in the case of Child Restrain Systems) that is issued. What happens to RiveMove also happens to any accessory that is intended for the interior of the vehicle, except for the vehicle itself and the child safety seat.
In some cases, the process known as self-certification takes place. It enables the manufacturer to take responsibility for ensuring that its product or service complies with one or more standards, specifications or technical documents, in so far as they apply to the manufacturer’s product or service. This is the most commonly used formula by the various manufacturers of car accessories as it is much more economical than the process involving independent certification.
RiveMove is, of course, subject to a comprehensive quality control procedure which applies both to its materials and its production process; it does not have self-certification but does hold certification. As part of this quality control process, several static tests are carried out to ensure that the resistance of the material used is sufficient and that RiveMove subjects all parts to a number of standards. Moreover, many other parameters are controlled such as energy absorbed, possible forms of rupture, etc.
We then face the uncertainty of whether a product meets the same conditions and is subject to the same tests when it comes to obtaining an approval number or certification.
What is the difference? The answer is simple, the difference is the identification in the form of an orange label which is displayed by products with an approval number, which certified products cannot have. All products certified in accordance with these standards undergo the same tests as approved products in relation to the same standard, with the only difference being that they do not receive a sticker.
RiveMove and RiveKids without approval
We then question why the RiveMove device does not have approval. This cannot be understood without explaining what the approval number is.
The approval number is a code awarded to certain products, in this case Child Restraint Systems, which confirms that approval has been granted in accordance with regulatory requirements. This number is featured on the orange approval labels of the seats. These labels also include the regulation according to which they are approved.
But can all devices obtain this approval number? Who can? Not all products can obtain it. In terms of road safety, it can only be obtained by Child Restraint Systems and the vehicles themselves. No other device is able to obtain an approval number, not even a GPS or a seat belt for pregnant women. RiveMove finds itself in the same boat.
In this capacity, RiveKids does not specify that RiveMove is approved, otherwise it may confuse the consumer. RiveMove cannot obtain an approval number, but our device undergoes the same tests and is subject to the same conditions as any Child Restraint System under the i-Size standard.
The procedure used in the various dynamic and crash tests conducted on the different seat models under CSI Spa is as follows:
- Firstly, the Child Restraint System is fitted in its nominal position in accordance with R-129 in the absence of our device. This identifies the reference biomechanical criteria used for comparison purposes when RiveMove is tested. This test is popularly referred to as a control test and it is not necessary for certification purposes; it is only necessary for researching ways to improve safety.
- After the first test, the device is fitted with the 7-cm movement (the maximum permissible distance). The test is repeated under these conditions and the new biomechanical criteria are obtained. This is referred to as the certification test as it certifies that the child safety seat can be used in conjunction with RiveMove according to regulatory requirements.
- A comprehensive comparison of the biomechanical values obtained during the test with and without RiveMove is subsequently carried out. We do not rest on our laurels if the Child Restraint System meets the minimum requirements established by the regulations. We go further as our objective is to improve the data of the biomechanical values of the test without RiveMove. Especially the biomechanical values of the head.
RiveKids has conducted approximately 100 tests at CSI Spa involving Q10, Q6 and Q3 dummies in safety seats belonging to all groups and approvals.
On that basis, and due to the current confusion between the terms of approval and certification, although subject to the same specifications, in a bid to maintain transparency, no official communication contains the term “approved”.
Approved does not mean safe
Child safety is a major area of concern for families. Although we have previously addressed the differences between approval, approval number and certification, it is necessary to analyse the bearing that these terms have on safety. There are so many unanswered questions in relation to this issue, such as, for instance, whether all approved Child Restraint Systems are safe; whether current standards mandate that all systems must be tested under the same conditions; whether these conditions are restrictive enough, etc.
As we have previously stated, there is no single standard currently in existence in Europe to regulate the manufacture of Child Restrain Systems. There are two different approval systems according to which a Child Restrain System can be approved: ECE R-44, the latest version of which entered into force in 2006 and ECE R-129, aka I-Size, in force since 2013 and co-existing alongside R-44, in principle until 2019; this date has already passed and it will be some time yet before both standards co-exist. This means that some systems are designed in accordance with the specifications of R-44 while others are designed as per the requirements of R-129 I-Size. In other words, some child safety seats comply with requirements which make them safer while others are subject to less restrictive requirements.
There is actually a desire to start regulating all Child Restraint Systems in accordance with I-Size R129 (Regulation no. 129 of the United Nations Economic Commission for Europe) but the reality of the current situation is very different indeed.
It should be noted that the biomechanical values required under these standards are quite different. For instance, R44 does not regulate side impact or the limits for HPC (head performance criterion) in frontal impacts, while the new I-Size standard does regulate side impact and provide HPC limits for every kind of dummy used in the test. Nor does ECE R44 regulate head acceleration in the event of a crash, while R-129 does.
But are the requirements imposed by the standard strict enough to guarantee the safety of our children? At RiveKids, we don’t think they are. We believe they could be much stricter and the standard itself is considering adding further biomechanical values to the limits. The new minimum established by ECE R-129 is much stricter than the one provided by ECE R-44 and, although it is not sufficient, it’s a good start.
Bearing in mind that, as things stand, not all Child Restraint Systems are tested under the same conditions and that the standard is being updated step by step to obtain stricter values, we can state that a “genuinely safe” system” should have values with a margin in respect of the limits of ECE R-129.
The RiveKids device, RiveMove, achieves values which are considerably better than those defined by R-129. Not only is RiveMove safe but it also improves safety and the values obtained by Child Restraint Systems.
In the case of adults who occupy the vehicle’s middle rear seat, part of that seat is occupied by the Child Restraint System if RiveMove is not used; in the event of a frontal impact, despite being restrained by the seat belt, the adult is initially thrown forwards and then backwards. In the backwards movement, the adult will come into contact with the safety seats before reaching the backrest. This involves a risk of whiplash of almost 100%. RiveMove makes sure that their body is stopped by the vehicle’s seat when the adult is thrown backwards.
In the event of a side impact, if a child is travelling in a Child Restraint System in the window seat, the laws of physics and the space existing between the Child Restraint System and the door panel dictate that the child will rotate towards the window, in which case his or her head may collide with the window. RiveMove reduces this space and the door panel itself restricts the rotating effect, meaning that the impact suffered by the child is reduced. This is not an opinion or an assumption, as shown by one of the most comprehensive studies on the matter:
The geometric design and materials of RiveMove also facilitate a progressive controlled deformation of the device, thereby allowing part of the energy generated by the impact to be absorbed.
On the basis of the above, RiveMove reduces up to 20% the Head Performance Criterion (HPC15) and improves the biomechanical values in the event of an accident.
In short, RiveMove does not have an approval number because it is not possible for a system to obtain one, unless of course it is the Child Restraint System or the vehicle itself. RiveMove is certified and tested according to the requirements of the most stringent standard in Europe, and produces results that outperform minimum legal requirements by a connectable margin.
The importance of regulation
However, although official approval is not always a guarantee of safety, we should stress the importance of regulation. Technical standards in industry make a very significant contribution to many aspects of our lives.
Regulation is important because it forces all manufacturers to comply with a number of criteria and to strive to improve the safety of their products. Consequently, consumers and users of products and services in general are protected.
Implementing the new standard ECE R-129
It is also important to distinguish between various aspects related to the implementation of the new standard I-Size.
For instance, the new standard divides Child Retention Systems by weight ranges and height. It also sets out a number of maximum dimensions for child safety seats and minimum dimensions for the seats of vehicles in which they are fitted.
The new standard also specifies that the anchorage systems of seats manufactured under the new standard may “only” be connected to the vehicle via the ISOFIX system in phases 1 and 2. Phase 3 of R129 already allows child safety seats to be fitted with a seat belt. In the opinion of RiveKids, phase 3 is not faithful to the initial spirit of the standard and may face pressure from safety seat manufacturers.
Another important point to note is that this standard applies to manufacturers of Child Restraint Systems and does not mean that, upon its full implementation, citizens may only use safety seats manufactured in accordance with R129. In other words, this standard differs from the legislation that must be respect by all citizens when they are behind the wheel.
The need for child safety research
We, at RiveKids, think that child road safety research is fundamental to the attainment of the objective of “zero victims in road traffic accidents”. RiveMove has undertaken several stages of measures to achieve satisfactory results. These results would not have been possible without a lot of effort and painstaking work.
We conduct this research as we seek to challenge the data at our disposal. At present, 500 children die every day in road traffic accidents and if we want to reduce this figure, further innovation and research are needed. Only by investing in R+D can we change the world. We, at RiveKids, not only want to change the world; we are going to do so based on the strictest research and most stringent developments.
We’ll leave you with a reminder of our motto: “The true journey finishes how it began, happily and innocently”. RiveKids.