However, after reading the many and varied comments on the YouTube video of the broadcast, I decided to respond in detail by posting my thoughts here. I hope that, no matter how much you know about underride, you’ll take some time to hear what I have to say:
Progress has been made in reducing underride deaths. But we’re not done yet; we’ve got a lot more work to do.
For example, seven trailer manufacturers are installing stronger rear underride guards as Standard on all new trailers. However, two trailer manufacturers, who have also designed a stronger rear underride guard, are merely offering it as an Option and are, in fact, still selling tens of thousands of new trailers every year with a too-weak rear underride guard — putting road users at risk of Death By Underride.
Not only that, despite the availability of Rear Impact Guard (RIG) retrofit solutions, millions of trailers on the road still pose a known unreasonable risk. It certainly doesn’t help that NHTSA recently issued a new RIG Rule but failed to require that these safety devices meet a technically feasible level of strength proven possible by nine manufacturers.
Families of underride victims gathered on September 14, 2023, in front of the U.S. Department of Transportation at 1200 New Jersey Ave SE in Washington, DC — with crash test cars from the Insurance Institute for Highway Safety 2017 side underride research in the background — to remember loved ones, who lost their lives due to truck underride.
The families rang a commemorative bell for over 750 victims, primarily from the last few years, and called upon the Department to re-evaluate publicly available data, end their decades of inaction, and issue strong underride regulations. Their message was this: Delay = Death.
Thanks to Sarah Haedrich, Vision Zero Coalition Coordinator for the Washington Area Bicyclist Association (WABA), we have video footage of some of the speakers at this event:
Families of underride victims gathered on September 14, 2023, in front of the U.S. Department of Transportation at 1200 New Jersey Ave SE in Washington, DC — with crash test cars from the Insurance Institute for Highway Safety 2017 side underride research in the background — to remember loved ones, who lost their lives due to truck underride. The families rang a commemorative bell for over 750 victims, primarily from the last few years, and called upon the Department to re-evaluate publicly available data, end their decades of inaction, and issue strong underride regulations.
Their message was this: Delay = Death.
The names, included in this solemn event, were taken from a combination of sources, including victims from families known to me and memorial posts on this website. In order to raise awareness and preserve the memories of underride victims — precious ones gone too soon — I have been writing memorial posts on what appear to me to be underride crashes, from daily Google Alerts which I receive on truck crashes. I am not a crash reconstructionist, and I do not have all the facts on these crashes; but underride should be investigated as a potential factor in truck crash injuries and deaths.
This is not an exhaustive list — merely the tip of the iceberg. But I hope that it serves to demonstrate the ongoing nature of a preventable public safety problem. You can find these Underride Crash Memorial posts here. The 750+ victims of preventable truck underride (front, side, and rear, involving tractor-trailers and Single Unit Trucks, as well as pedestrians and cyclists), whom we specifically remembered on September 14, can be found here:
Families of underride victims gathered on September 14, 2023, in front of the U.S. Department of Transportation at 1200 New Jersey Ave SE in Washington, DC — with crash test cars from the Insurance Institute for Highway Safety 2017 side underride research in the background — to remember loved ones, who lost their lives due to truck underride. The families rang a commemorative bell for over 750 victims, primarily from the last few years, and called upon the Department to re-evaluate publicly available data, end their decades of inaction, and issue strong underride regulations.
Dr. Elisa Braver, epidemiologist and safety researcher
Andy Young, The Law Firm for Truck Safety
Barry Davis, father of underride victim Ally Davis
Lois Durso, mother of underride victim Roya Sadigh
Congresswoman Jan Schakowsky (D-IL)
Sean O’Malley, Insurance Institute for Highway Safety
Abbie Bingham Endicott, cousin of underride victim Sylvia Bingham
Daniel Langenkamp (husband of underride victim Sarah Langenkamp) read a statement from Stephen Bingham, father of underride victim Sylvia Bingham
Nancy Avis, cousin of underride victim Carling Mott
Harry Adler, Institute for Safer Trucking
Jerry and Marianne Karth, parents of underride victims AnnaLeah & Mary Karth
“Underride crashes, which occur when a car slides underneath the body of a truck, have tragically become all too common on our highways. These crashes are preventable. Underride guards on large trucks save lives. I urge @NHTSAgov to implement stronger protections without delay,” said Congresswoman Jan Schakowsky. “I would be remiss if I did not mention all the survivors and family members who are turning their personal tragedy into advocacy. We could not do this without you.”
A local photographer became part of the all-volunteer TEAM Underride — offering his skills to capture a day in the life of an underride crash test crew at the Raleigh Underride Crash Test Event on August 3 at the North Carolina State Highway Patrol training facility. Here’s a glimpse of that day from a photographer’s perspective: Team Underride Crash Test Event.
Note: Adam Trevillian provided these photos for TEAM Underride to use. If outside sources would like to use these photos (for publications, etc.), please contact Adam so that he can handle those requests: adam@adamtrevillian.com.
On September 14, from 1:00 to 2:30 p.m., families of victims of horrifying truck underride crashes will be standing vigil in front of the Department of Transportation in Washington, DC. We will be ringing a bell to memorialize the victims and sound an alarm. We will hold a press conference calling upon the Department of Transportation to require truck underride guards which will protect pedestrians, cyclists, and the motoring public from these violent and preventable deaths.
Participants will be invited to ring the bell for their own loved ones or for truck crash victims remembered in these underride crash memorialposts — the tip of the iceberg of precious loved ones gone too soon.
When there is no strong physical barrier under a truck bed, Death By Underride becomes a known unreasonable risk. Fortunately, engineers have developed effective physical barriers or underride protection – although it is not required by law. With that in mind, a group of engineers carried out R&D crash testing on August 3 at the Raleigh Underride Crash Test Event.
Four side crash tests were conducted into semitrailers:
Ford Fiesta into an AngelWing side guard from a 45 degree angle (39 mph)
Chevy Malibu into an unguarded trailer from a 45 degree angle (38 mph)
Chevy Impala into a SafetySkirt side guard in the rear area behind forward positioned trailer axles from a 90 degree angle (36 mph)
Chevy Malibu into a SafetySkirt side guard from a 90 degree angle (43 mph)
Crashed trailers were each ballasted with approximately 28,000 pounds in water tanks. Video footage in this LinkedIn post by Forensic Rock, highlights two of the crash tests:
We love working with passionate people in the AR field. And Aaron Kiefer is one of those super-passionate people we absolutely love working with.
We were lucky enough to help him and his great #StopUnderrides group collect data for an awesome test series they were running in North Carolina. His goal was to demonstrate the collision mitigation of different trailer guards on side underride collisions with lower-profile sedans.
This compilation video compares an unguarded 53′ van trailer to Aaron’s SafetySkirt design. Two Chevrolet Malibu’s were used in this test series.
The speed at impact in the unguarded test was 37.5 mph; the speed at impact for Aaron’s SafetySkirt test was 43.4 mph.
We won’t spoil it for you, but Aaron certainly knows what he is doing.
NHTSA closed the Public Comment Period on the Advance Notice of Proposed Rulemaking (ANPRM) for side underride guards on July 20, 2023. NHTSA asked commenters to respond to these nine questions. Here’s where the comments are posted: Advance Notice of Proposed Rulemaking for Side Underride Guards. To make it easier to read through the thousands of comments, I’m providing pdfs and/or links to many of them — although it’s not an exhaustive compilation.
The majority of comments (over 1,000) posted from June 16 through June 23 were from individuals and organizations which support the requests in the Public Comment from the League of American Bicyclists – calling for pedestrians and bicyclists to be included in the data for side guard regulatory analysis. (Motorcyclists are vulnerable to underride as well.)
According to the federal rulemaking process, the next step is for NHTSA (and that will include the Advisory Committee on Underride Protection)to begin reviewing and evaluating the comments which have been submitted from the public. Now is the time for the development of a recommendation to the Secretary of Transportation as to whether a side guard regulation would be cost effective.
In other words, now is the time to finally determine that safety is an acceptable cost of doing business and Death By Underride is an unacceptable, unreasonable, and preventable risk for all road users. At least, that’s what I think.