Over the past several years, Carbuilders have been developing car designs that utilize Crash Energy Management (CEM) as an alternative means to demonstrate compliance with carbody structural strength requirements. With the onset of CEM designs, the CFR has been amended to include requirements for alternative compliance to carbody structure requirements (see Docket No. FRA-2013-0060, Notice No. 3, [the Final Rule]) [14]. CEM designs often utilize crush zones with the overall goal of protecting occupant volume. These designs also change the structural behavior of the car during an accident, resulting in different acceleration responses than conventional car designs. This paper seeks to compare and contrast the interior fitting strength requirements between conventional car designs and a generic CEM design. The methodology utilizes simple mathematical simulations, modeling a conventional car design and a CEM design, with outputs of the simulation consisting of car response and behavior. Results indicate that alternative compliance requirements for all tiers of CEM-designed passenger equipment should be considered for interior fixtures.

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