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Subaru – CPS Pet Crash Study Fails the Test Print

  • June 9, 2016

Pets have taken on an increasingly important role in our lives and their photos and exploits dominate the social media sites Facebook and Instagram. However, it is hard to imagine a $60 billion industry as lightly regulated as the pet product industry.

From food to leashes to toys, little testing is done, yet alone made available to the public. Treats made from animal jerky and even sweet potatoes have caused kidney failure and death in many dogs. Snaps and latches fail on leads and collars at the worst possible moment. Cute toys on display at the pet store later become choking or digestive hazards. While there are some loose standards on the food side, producers often keep contents and nutrition profiles on a tighter need to know basis than code word intelligence from the CIA.

Pet parents (owners, if you are old fashioned) long for information of any kind that can help them make good decisions about the products they bring home for their furry friends. This has spawned an explosion of pet advice websites, most authored by lay persons with a minority presence of actual veterinarians. While all are well intended, some sites will recite hearsay as fact and authors often lack the time or training to apply truly critical thinking to the available public information.

Enter the Center for Pet Safety, a non-profit organization with a goal of developing standards for safe pet products and determining which make the grade after performance testing. CPS has made their initial focus on pet travel and recently released a study on travel crates. CPS has also received funding from automaker Subaru as part of their “Subaru Loves Pets” initiative. The combination of video of crash test “dogs” flying about, a large corporate sponsor and a laudable mission has brought considerable print and TV attention to CPS and their testing.

Unfortunately, the CPS testing methodology is a failure. Perhaps more shocking is that Subaru would participate in and further the media attention to a study they certainly knew, or should have known, was flawed from the start.

CPS places considerable importance on two points in their testing: that the dog remain contained by the crate and the crate remain anchored to the test sled. Their reasoning for the latter criteria is to minimize the risk of a seatback becoming damaged or broken during a crash.

The CPS test sled and seatback is longer than the cargo area with seats down of all but the largest of SUVs (think Escalade or Suburban). In their first test run, CPS positions a crate in the center of the sled, leaving 20″ or more to the simulated seatback. This is not a real world scenario and also runs counter to the requirements of a European standard they claim to follow (ECE R-17, used for crash testing seatbacks with cargo). The second test run positions the crate directly behind the seatback.

In both runs, the crate is tied down to d-rings mounted on the test sled with straps provided by the crate manufacturer. CPS makes clear in their report that it is critical, in their opinion, the straps not break free during the crash test so that the crate stays in place.

It was at this point that a Subaru engineer should have stepped in and politely pointed out that the d-rings used by CPS were not at all reflective of those available in a consumer vehicle. The photo below shows this quite clear.

Why is this such a critical problem with the CPS test? Let’s take a recent Subaru Outback as an example. In the owner manual, Subaru states that the cargo tie down points are rated at 110 lb and should only be used for securing light cargos.

Even considering typical safety margins, those moorings will be grossly overmatched by the collision forces of a crated dog. End result — a crate on the loose. But in the CPS test, the anchor and d-ring are so secure that all a manufacture need do to “pass” the test is use a strap rated for large loads (high forces). There is no need to be concerned that the d-ring and anchor will break free.

In fact, CPS was well aware of this, going so far as to place a warning about car tie downs elsewhere on their website. CPS chose to completely ignore this risk in the design of their crash test. In their final analysis, CPS awarded a “top performer” to a crate whose only claim was remaining anchored to the test sled by the use of extra strength 2,500 lb straps. Had the straps been attached to actual car tie downs, the crate would not have remained attached.

In the same breath, CPS did not give a performance award to a crate uniquely designed to crumple in a crash. Why? Because the crate became detached from the sled. All other criteria were met — the test “dog” was contained and all doors remained functional. The crate, though partially collapsed as per its design, retained its structural integrity and did not place the occupant at risk from bent or broken parts.

So in effect, CPS has given a recommendation to pet parents that the “safe” thing to do is to purchase a crate that really was not tested at all while simultaneously steering them away from a crate that survived the rigors of a simulated crash. CPS thus manages to commit not just a type I error but also a type II error in the same test.

It should also be pointed out that CPS never indicates whether those crates that did impact a seatback caused any meaningful damage. Was there ever a risk to a human occupant? Did CPS even monitor this? Given their extreme focus on preventing such an impact in the first place, it seems reasonable they would. Is the silence on this point an indication that none of the crates caused significant damage? If so, what does this say about their recommendation on where to place the travel crate in the cargo area?

A web search will turn up countless links to TV news reports, blog posts, magazine copy and Subaru press releases touting the goals and results of the CPS crate test. In every single case, the test methodology and “results” are never questioned and simply taken as prima facie evidence of safety.

A feel good story with what looks like scientific backing — a dangerous combination — is easily accepted by ordinary people. They are understandably not in a position to spend the time and may lack the requisite knowledge to question crash testing of pet crates or any other consumer good. That is somebody else’s job, right?

In bygone days, journalists might have made some effort to question and vet such testing before trumpeting study results. Unfortunately, declining readership, profits and attention spans has ravaged investigative journalism.

The sad reality of our current age is that the only party in a position to question such research are the sponsors themselves. And that is indeed troubling when their sponsorship is simply a marketing tool to achieve more sales and higher profits.

Subaru, we’re looking at you.

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