Past Time for Action


It has recently come to our attention that our petition to the Department of Transportation regarding underride guards will not have been the first one to address this vital issue.

On February 28, 2011, the Insurance Institute for Highway Safety (IIHS)* sent a letter to David Strickland, the then-Administrator of the National Highway Traffic Safety Administration (NHTSA), titled “Petition for Rulemaking; 49 CFR Part 571 Federal Motor Vehicle Safety Standards; Rear Impact Guards; Rear Impact Protection.” (, #3 in 2011)

The IIHS letter concludes as follows, “In summary, IIHS provides analyses and test results showing that NHTSA could greatly reduce the likelihood of rear truck underride by reopening rulemaking on FMVSS 223 and 224 to:

1. Substantially increase the quasi-static force requirements, at least to levels that would guarantee all guards are as strong as the Wabash;

2. Move the P1 test location farther outboard to improve offset crash protection;

3. Require that attachment hardware remains intact throughout the tests;

4. Require guards be certified while attached to the trailers for which they are designed;

5. Investigate whether the maximum guard ground clearance can be reduced; and

6. Reduce the number of exempt truck and trailer types.

“IIHS urges NHTSA to begin such rulemaking as soon as possible to reduce the preventable injuries and deaths occurring when passenger vehicles strike the rears of large trucks at speeds the passenger vehicles are clearly designed to handle in the absence of underride.”

On April 3, 2014, the National Safety Transportation Board (NSTB) released a document which made Seven Safety Recommendations for Tractor-Trailers to NHTSA—including improvement of standards for rear underride guards. The document made mention of the 2011 petition from IIHS to NHTSA and commented that, “As of December 2013, NHTSA has not formally responded to IIHS’s petition, but the agency has sponsored additional research on rear underride.”

It is clearly past time for action to be taken on this important issue. How many more lives will be unnecessarily lost before those accountable for instigating change will act decisively and make it happen?

* Note: The IIHS is a reputable organization ( ):

“The Insurance Institute for Highway Safety (IIHS) is an independent, nonprofit scientific and educational organization dedicated to reducing the losses — deaths, injuries and property damage — from crashes on the nation’s roads.

The Highway Loss Data Institute (HLDI) shares and supports this mission through scientific studies of insurance data representing the human and economic losses resulting from the ownership and operation of different types of vehicles and by publishing insurance loss results by vehicle make and model.

Both organizations are wholly supported by auto insurers and insurance associations.”


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