In 1997 Mertz, Prasad and Irwin  have described a technique for the development of injury risk curves for measurements made with the CRABI and Hybrid III family of biofidelic child and adult dummies that are used to evaluate restraint systems in frontal collision simulations. They further developed normalized injury risk curves for neck tension, neck extension moment, combined neck tension and extension moment for adults and children.The approach described by Mertz et al , is based on lines of equivalent stress and uses the maximum normal stress theory of failure to impose limits of the risk of injuries. In this paper a complementary approach is described based on the maximum energy of failure and lines of constant energy. A special case of this approach in 1D is used to develop the assessment values obtained by Mertz et al . Limitations and advantages of the energy based approach are described, with especial emphasis on future implementation.