Insightful Public Comment from a Canadian road safety expert on the NPRM for upgrade of Rear Underride:
Regarding the above noted proposed rulemaking, I support fully a new rear guard standard that exceeds the Canadian standard, which was developed some time ago and that current research shows does not provide adequate passenger compartment protection in all crash scenarios. I also support fully that the new standard apply to all trucks including single unit ones. I believe the NHTSA has overestimated the costs and underestimated the benefits of such changes. More importantly, however, we must modernize the very way we think about road safety in the United States and Canada. We need to make the default design for every car, truck and bus to be one that simply minimizes all levels of human harm.
The use of a cost-benefit analysis for motor vehicle design and upgrades represents outdated thinking. The air, marine and rail industries have a much more forward approach when it comes to safety and more often works to ensure that these modes are safe for all persons. We must do the same with motor vehicles as the use of cost-benefit analysis involves assigning a monetary value to a human life and it is unethical and crass to do that.
Thank you for considering my comments on this important matter.