Tag Archives: safety regulations

Consensus Side Guard Standard

On April 17, 2020, over 40 people participated in a virtual meeting of a volunteer Underride Protection Committee’s “Side Guard Task Force.” This included two engineers from trailer manufacturers. As a follow-up, several subcommittees began to hold virtual meetings, including an Underride Engineering Subcommittee.

The engineering subcommittee met at least monthly and sometimes every other week from May through November. At the outset, the VP of Engineering of one of the trailer manufacturers provided valuable input. Subcommittee members also participated in a Virtual Briefing for Senate Commerce Committee transportation staffers on August 19, 2020.

The goal of the Underride Engineering Subcommittee was to create a Consensus Side Guard Standard which would provide additional insight for the development of a side guard regulation and industry standard. Lengthy conversation and exchange of information has led this group to submit the following recommendation:

A side underride guard shall be considered to meet the performance standard if it is able to provide vehicle crash compatibility with a midsize car, to prevent intrusion into the occupant survival space, when it is struck at any location, at any angle, and at any speed up to and including 40 mph.

The subcommittee members are in agreement as to the details shaping this long-overdue standard, which they anticipate will lead to the saving of countless lives in the days and years to come. The following group of individuals participated in the Underride Engineering Subcommittee and are willing to continue to provide input.

Jared Bryson

Malcolm Deighton

Keith Friedman

Aaron Kiefer

Garrett Mattos

Perry Ponder

NOTE: It should be mentioned that this standard has, in fact, been evaluated through research conducted by the Insurance Institute for Highway Safety when they crashed a car at 40 m.p.h. into the side of a tractor-trailer equipped with AngelWings side guards on August 29, 2017, during the Second Underride Roundtable at their Ruckersville, Virginia, testing facility.

There was no underride, no Passenger Compartment Intrusion (PCI), and the crash dummy data showed that it was survivable. In other words, this standard is not pie-in-the-sky; it has been proven that the Consensus Side Guard Standard is attainable.

Crash test at 40 mph into AngelWings side guards, August 29, 2017, during the Second Underride Roundtable at the Insurance Institute for Highway Safety

UPDATE: Protecting Passenger Vehicles from Side Underride with Heavy Trucks More research on side underride was published by SAE International in April 2021 — following a presentation by Garrett Mattos of the Friedman Research Center at a SAE Conference. Hopefully, the Department of Transportation now has enough research to make good on their March 19, 1969 intention to add underride protection to the sides of large vehicles.

Ramblings About the State of Underride

  1. Award-winning WUSA9 Underride Series
  2. What do Heidi King’s responses tell us about the need for the STOP Underrides! Bill to insist that NHTSA move forward with underride rulemaking? Do we expect that they will do it without the encouragement of a law telling them (and authorizing them) to do so? NHTSA’s Heidi King Responds to Senator Nelson’s Questions For The Record on Truck Underride
  3. Perhaps 700-1002 people may have died from underride since the bill was introduced on December 12, 2017, until this day: Every Month Passing of the STOP Underrides! Bill Is Delayed Means More Unnecessary, Preventable Deaths
  4. Underride report language is in the Appropriations Bill:  FY18 omnibus report language,  Truck underride safety researchThe Committee notes that NHTSA’s proposed rulemaking in December 2015 to update truck rear impact guard requirements cited 362 annual fatalities associated with light vehicle crashes into the rear of trucks. The Committee encourages NHTSA to move forward with this rulemaking and continue working with relevant experts and stakeholders, including researchers, engineers, and safety advocates, and the trucking industry, to facilitate the deployment and adoption of rear and side underride protection devices.
  5. Front Underride Protection (FUP) is not talked about as much, yet many people die from lack of protection there as well: https://www.youtube.com/watch?time_continue=56&v=iNRpiRmlBEc and https://www.youtube.com/watch?time_continue=1&v=SXZnHq1PUPU
  6. Retrofitting is included in the Bill because there are millions of existing trailers on the road which will still be death traps otherwise. See IIHS video if you don’t believe me. After watching it, ask yourself if you would want to collide with one of the trucks on the road which was not retrofitted with effective and comprehensive (all around the truck) underride protection: https://www.facebook.com/iihs.org/videos/412706855872750/
  7. To continue that theme of To Retrofit OR Not. . . in February 2018, a man died when his car lodged under the rear of a 2005 Great Dane trailer (one of the older weak rear guards). Our car lodged under the back of a 2007 Great Dane trailer (one of the older weak rear guards). How long do you suppose that we will continue to have those older (more dangerous) trucks on the road? Jessup man dead after slamming car into tractor-trailer on Beltway
  8. President Carter made a point of saying that safety should not be a part of Trucking Deregulation:  Trucking Industry Deregulation Message to the Congress Transmitting Proposed Legislation. 
    June 21, 1979, To the Congress of the United States:I am today transmitting to the Congress legislation to reduce substantially Federal economic regulation over the trucking industry.The trucking industry today is subject to perhaps more complex, detailed, and burdensome Federal regulation than any other industry in our Nation. . . 

    SAFETY

    Reforms in safety enforcement are necessary because present levels of safety are unsatisfactory, and because authority to monitor safety practices and to sanction safety violations should be strengthened. These provisions are distinct from the economic reforms and are not made necessary by them.

    The bill I propose places new emphasis on the existing fitness test which guarantees that all new entrants into the industry are safe. It also consolidates the safety authority in the Department of Transportation, and gives the Secretary of Transportation broader and more effective authority to deal with safety violations. . .

    So I don’t want to hear anybody whine, “Oh, no, not another regulation!” This is a matter of protecting public health and safety — not restricting the freedoms of the trucking industry! If market forces were going to solve the problem, they would have done so decades ago. We apparently need a law to protect us.

With Hope, We Carry On: https://www.youtube.com/watch?v=Kp7acA3CI34

Debunking the Myth That Safety Countermeasures Over-Regulate the Trucking Industry

We have worked hard ever since we lost AnnaLeah (17) and Mary (13) on May 4, 2013, in a senseless and preventable truck underride crash. We have set out to make sure that effective protection is on every defective area of every truck to prevent future underride tragedies.

The problem is that we keep coming against all of the excuses and mistaken beliefs which stand in the way of our moving forward with creative solutions to this public health & safety problem. So my goal now is to debunk the myth that safety countermeasures — like a comprehensive underride protection rule  — are unnecessary and will over-regulate the trucking industry.

First of all, let’s make it very clear that truck underride is not a new problem or even a newly-discovered problem. No, in fact, we have found an 1896 patent for a side underride protective device for a street car and a U.S. patent filed in 1913 for a safety device for the side of motor vehicles. In 1969, the Department of Transportation acknowledged the side underride problem in the Federal Register when they indicated that they intended to extend underride protection to the sides of large trucks.

Second, if the industry was going to solve this problem all by itself, then it would have done so by now. It has not. And I am convinced that, despite the signs of progress which we have seen, there will never be complete and comprehensive underride protection without regulation.

There are too many layers of responsibility in this process; each one involved can point the finger of blame at someone else and the end result is that this problem has fallen between the cracks. I, for one, will not let that continue on my watch.

Next week, we are hosting an Underride Briefing in the Capitol Visitor Center, Room 215, from 2:30 – 4:00 p.m. We are hoping for good attendance from legislative offices so that they are accurately informed about the Stop Underrides Bill — enabling them to wholeheartedly jump on board for this Win/Win solution.

The Senate Commerce Committee had a mark-up today of the AV Start Act.

Here’s hoping that there will be a similar call for safer trucks to be rolling out to deliver goods. And let’s learn from Wabash National’s approach to innovation:

Wabash was first introduced to the possibility of using composites in the trailer by Structural Composites, a Melbourne, Fla.-based company that was using unique composite technology for shock-mitigating Navy boats. Wabash assessed performance and economic metrics, then benchmarked how the technology might apply to trailers.

Wabash opted to use composites, however the project came with a steep learning curve for everyone involved. “We had a lot to learn about semi-trailers and refrigerated truck bodies and what kind of loads they go through,” says Scott Lewit, president of Structural Composites. “And they had to learn from us about what composites can do.” Yeagy encouraged the team to push the boundaries and not be afraid to fail, recalls Lewit. “This approach allowed us to learn and innovate from failure and to rapidly develop and deploy new technology,” he says.  The Trailblazing Trailer, Composites Manufacturing, Evan Milberg , July 5, 2017