A Mom’s Knee-Jerk Reaction to NHTSA’s Proposed Rule to Improve Rear Underride Protection

First of all, let me say that I am grateful for the work which NHTSA has done on this problem and their willingness to address it at this time. Then, I have to admit that I am not an engineer. So it’s a good thing that we don’t have to depend on me to be the one to provide a thorough analysis of the recently released proposed rule for the improvement of tractor trailer rear impact protection standards and all of its technical pros and cons.

But I can provide a summary of the highlights included in the NPRM, along with some of my knee-jerk reactions as a mom of two girls, who perished due to a truck underride crash, and as an advocate for better underride protection.

These are my general reactions. . .

While this proposed rear underride rule is definitely a much-needed improvement to the existing standards, it does not appear to embrace a Vision Zero policy approach which would seek to reduce crash deaths and injuries whenever and however possible.

Many of the trailer manufacturers are already meeting Canadian standards, but IIHS research has shown that this is still not adequate to prevent underride in many crash scenarios–particularly offset crashes. http://www.iihs.org/ externaldata/srdata/docs/ sr4907.pdf

Also, when I look at what NHTSA is predicting in terms of lives saved by this proposed rule–1 out of the 125 annual reported PCI underride crash fatalities–I have to ask, “What about the other 124?!” And our daughters, AnnaLeah and Mary, were not even counted in the 2013 FARS crash data for PCI crash fatalities because our crash was listed as “Passenger Compartment Intrusion Unknown“!!!

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(Note: See our FARS crash report in my Public Comment on the Single Unit Truck rear impact protection ANPRM and a discussion of the problem of underride crash fatality UNDERREPORTING  and how it might impact the count of potential saved lives. . .  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0018)

In addition, there are many engineers around the globe who have come up with improved designs for underride protection, and there are many who are even now working on solutions that are stronger than the Canadian standards. They just have not yet been widely implemented or required.

It is, undoubtedly, an enormously significant step for NHTSA to acknowledge the need for stronger guards and to propose an improved guard. However, we do not want them to base the final rule merely on what will provide a “cost-effective” solution if, in fact, technology could be utilized which would save additional lives and prevent additional injuries.

One of our big concerns has been the apparently more vulnerable crash scenario when the smaller passenger vehicle hits the rear of the truck at the outer edges of the rear of the trailer. When Jerry and I visited Great Dane’s Research & Design Center in Savannah in June 2014, they pointed out that the company, Manac, which passed the 30% offset crash test had proven to be more vulnerable (although it still withstood the crash) at the 100% overlap test.

I reported on that in a previous blogpost in June 2014: “Great Dane, one of the major trailer manufacturers, observed that they passed all but one of the quasi-static crash tests—the narrow overlap. Great Dane also noted that their guard appeared to perform better on the full overlap test than Manac’s (which was the only company to pass all three tests in 2013). So Great Dane does not want to make a change which will strengthen one section of their guard but weaken another section. That’s understandable.”   http://annaleahmary.com/2014/06/underride-guards-can-we-sit-down-at-the-table-together-and-work-this-out/

NHTSA’s comments in the NPRM indicate that they do not want to compromise safety in the more common crash scenario and so have proposed to concentrate on making that area of the trailer safer and do nothing, at least at this stage in the game, about the other weaker area where crashes are reportedly less common. (See p. 44, ” NHTSA is not convinced that improved protection in the less frequent 30 percent overlap crashes should come at the cost of adequate protection in the more common 50 and 100 percent overlap crashes.”)

I just have to ask, Is it really an Either/Or situation? Are we sure that we cannot reasonably address both problems?

We are hoping and working toward the possibility that the Public Comments which will be submitted, the underride research both underway and proposed, and the Underride Roundtable which will be taking place at the IIHS Vehicle Research Center on May 5, 2016, will help to refine this rule so that it results in the best possible protection.

Here is the complete NPRM document: NPRM-underride.Dec2015

And here is the press release announcing the proposed rule:  https://www.transportation.gov/briefing-room/usdot-issues-nprm-improved-rear-impact-trailers-semitrailers#sthash.j6eu5DN1.dpuf

As I reviewed the NPRM document for rear impact protection on tractor-trailers, I created my own 9-page document by copying and pasting some of the highlights of the proposed rule (page numbers are indicated in case you want to go to the original document for further details). You can read my summary of the proposed rule here:  Highlights of the NPRM Rear Impact Guards, Rear Impact Protection December 2015 document

On December 10, I was interviewed by Atlanta investigative reporter, Jim Strickland:  http://www.wsbtv.com/news/news/local/new-rules-proposed-help-keep-you-safer-behind-big-/npgzd/.

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