Tag Archives: conspicuity

Why rely on driver reaction to avoid truck side underride when a side guard could prevent tragedy?

I just read a very detailed explanation for why a driver might not react in time to avoid riding under the side of a semi-trailer — one without a side guard I might add. Well, that is all very interesting and we might learn something useful from it.

But, why on earth would we rely on driver behavior (especially in such an unexpected scenario) when the installation of a side guard could so easily save the driver’s life?!

Save Lives

Of course, taking a comprehensive approach to safety makes the most sense –one which makes other factors important as well, including:

  • Visibility and conspicuity.
  • Adequate parking for trucks.
  • Making it illegal for trucks to make U-turns.

Either or

Celebrating Progress in Underride Guard Rulemaking: Advance Notice of Proposed Rulemaking on Single Unit Trucks (SUTs)

The current federal standards for truck and trailer crash protection do NOT currently include Single Unit Trucks (SUTs). These types of trucks are not required to have any rear underride guards. Yet, research has shown that there are many deaths due to smaller vehicles colliding with the rear end of SUTs.

Examples of SUTs are dump trucks, garbage haulers, concrete mixers, tank trucks, trash trucks, and local delivery trucks.

Today, NHTSA issued an advance notice of proposed rulemaking (ANPRM) for SUTs–the first step of a larger agency initiative to upgrade the standards for truck and trailer underride crash protection. This is very good news!

As soon as it gets published in the Federal Register, we will be asking people to put in their two cents worth online through a 60-day Public Comment Period.


Straight Truck Advance Notice of Proposed Rulemaking nhtsa 3715[1]:

This announcement is about protecting more drivers and passengers,” said U.S. Transportation Secretary Anthony Foxx. “These vehicles are essential to transportation system, and we have a duty to the traveling public to take every opportunity to strengthen truck safety.”


This 79 page document spells out the details , ANPRM-underride-SUT-July2015 :


NHTSA is issuing this ANPRM following a July 10, 2014 grant of a petition for rulemaking from Ms. Marianne Karth and the Truck Safety Coalition (petitioners) regarding possible amendments to the Federal motor vehicle safety standards (FMVSSs) relating to rear impact (underride) guards. The petitioners request that NHTSA require underride guards on vehicles not currently required by the FMVSSs to have guards, notably, single unit trucks, and improve the standards’ requirements for all guards, including guards now required for heavy trailers and semitrailers.

Today’s ANPRM requests comment on NHTSA’s estimated cost and benefits of requirements for underride guards on single unit trucks, and for retroreflective material on the rear and sides of the vehicles to improve the conspicuity of the vehicles to other motorists. Separately, NHTSA plans to issue a notice of proposed rulemaking proposing to upgrade the requirements for all guards.

DATES: You should submit your comments early enough to ensure that the docket receives them not later than [INSERT DATE 60 DAYS AFTER DATE OF PUBLICATION IN THE FEDERAL REGISTER].

I have been told that it could take a few days, a week, or even longer to get published in the Federal Register. But when it does, we will most certainly inform you and ask you to make a public comment. Instructions will be provided.

Here is a photo of a Single Unit (or Straight) Truck which we saw on the road during one of our road trips recently. Note the rather wimpy (voluntary) underride guard.

Trip North May 2015 035Right now (without a requirement for SUT underride guards), whether they realize it or not, these trucks are “getting away with murder.”* We hope that this is the first step toward bringing that tragic and preventable situation to an end.

*”The killing of another person without justification or excuse, especially the crime of killing a person with malice aforethought or with recklessness manifesting extreme indifference to the value of human life.”(Is it “manifesting extreme indifference to the value of human life” to not do something which in fact could be done to prevent horrific injury or death?)


“To escape punishment for or detection of an egregiously blameworthy act. http://idioms.thefreedictionary.com/get+away+with+murder

We know all too well what an underride crash can result in:


June 2013 article on straight trucks: http://www.truckinginfo.com/channel/safety-compliance/news/story/2013/06/ntsb-says-straight-truck-safety-not-receiving-enough-attention.aspx


Please note that this is only the beginning of a lengthy rule making process. But we are in this for the LONG HAUL and hope to see this advance in a timely manner to the end goal of safer trucks on the road. Here is a description of the regulatory process:

Regulatory Dashboard  http://www.reginfo.gov/public/jsp/Utilities/faq.jsp#dashboard

Q.    What is Reginfo.gov and the Regulatory dashboard and what information does it display?

A.     Reginfo.gov displays regulatory actions and information collections currently at OIRA for review. The Regulatory dashboard is a component of that site that provides an up-to-date and easy-to-read graphical representation of regulatory actions currently under review. The dashboard displays these regulatory actions by agency, length of review, economic significance, and stage of rulemaking.

Q.    What are the different types of significant regulatory actions currently displayed on the dashboard that undergo OIRA review?

A.    They are:

  • Notice  –  These are documents that announce new programs (such as grant programs) or agency policies.
  • Pre-rule (or advance notice of proposed rulemaking)  –  Agencies undertake this type of action to solicit public comment on whether or not, or how best, to initiate a rulemaking. Such actions occur prior to the proposed rule stage.
  • Proposed rule  –  This is the rulemaking stage in which an agency proposes to add to or change its existing regulations and solicits public comment on this proposal.
  • Final rule  –  This is the last step of the rulemaking process in which the agency responds to public comment on the proposed rule and makes appropriate revisions before publishing the final rule in the Federal Register to become effective.
  • Interim Final Rule  –  These interim rules are typically issued in conformity with statutory provisions allowing agencies to publish a final rule that becomes effective soon after publication, without going through the proposed rule stage. The “good cause” exception in the Administrative Procedure Act allows agencies to bypass public notice and comment on a rule when it would be impracticable, unnecessary, or contrary to the public interest. This process typically allows for public comment after the rule is published so that the agency still has an opportunity to consider public input and revise the rule accordingly.
  • Direct Final Rule  –  These rules are similar to interim final rules, except that there is no comment period after publication, on the ground that they are uncontroversial. Such rules are categorized simply as “final rules” for display purposes on the dashboard.