Tag Archives: single unit trucks

Just How Far Have We Come In The 50 Years Since Jayne Mansfield’s Death By Truck Underride?

June 29 marked the 50th anniversary of Jayne Mansfield’s death by underride. The world knew in 1967 — if it didn’t know it before — about the terrible geometric mismatch between a car and a truck which allowed a car to ride under a truck upon collision.

In those 50 years, how many technological problems have we solved? And yet why have we been unable to solve the problem of truck underride and stem the tide of preventable, horrific, and senseless underride tragedies?

Sure we have made some headway — six trailer manufacturers have upgraded their rear underride guards and there are promising side guard solutions with one of them recently tested by the IIHS. Some manufacturers even have retrofit kits available to replace weak rear guards on existing trailers.

Yet it is well known that more could be done, but hasn’t. And why is that? Why have we been so slow to solve this problem? There are many reasons which could be cited. But the facts are the facts. People are still dying (or suffering catastrophic injuries) at an alarming rate from underride and we are seemingly content to let it continue or address it at a snail’s pace.

Not me. I am not content to take it slow and easy — not when the result is that more people will die because we didn’t act sooner. When we could have.

Take front underride or override for example. Front underride protection is one of the components we are asking for in the Roya, AnnaLeah & Mary Comprehensive Underride Protection Act of 2017 (RAMCUP). People are dying due to lack of adequate front underride protection — just like they are on the sides and rear of trucks.

In Europe, they have requirements to protect against this. Not in the U.S. So what are we waiting for? Well, that’s a good question.

Do we wait until we can reinvent the wheel here and figure it out for ourselves with years of research? Or do we speed up the process by learning from others and encouraging collaboration among relevant stakeholders?

Do we include it in the congressional mandate to the Department of Transportation and ask them to figure it out sooner rather than later? Or do we ask them to solve the side guard problem now and then later on, down the road at some unspecified time in the future, we’ll address the need for front protection?

Well, Lois Durso and I took the bull by the horn and said: We’re sick & tired of waiting. People are dying from underride no matter what part of the truck they are unfortunate enough to collide with. We need to solve every kind of underride problem and we are going to include it all in one big comprehensive piece of legislation. Because it is needed. Because it is long-overdue.

Previous posts on Front Underride Protection:

Don’t re-invent the wheel; establish a formal Committee On Underride Protection (COUP) to oversee the development of recommendations for NHTSA underride regulations.

See the history of underride rulemaking as compiled by IIHS and displayed at the first Underride Roundtable on May 5, 2016, held at the IIHS Vehicle Research Center:

From the RAMCUP bill: 

(d) UNDERRIDE PROTECTION ON THE FRONT OF LARGE TRUCKS
Include front override protection in conformance with the following
specifications:
(1) An EU requirement was introduced in 2000 based on ECE Regulation
93 requiring mandatory rigid front underrun protection defining a rigid
front underrun protection system for trucks with a gross weight over 3.5
tonnes Directive 2000/40/EEC. Studies performed by EEVC WG 14 have
shown that passenger cars can ‘survive’ a frontal truck collision with a
relative speed of 75 km/h if the truck is equipped with an energy absorbing               underrun protection system. Furthermore, these systems could reduce
about 1,176 deaths and 23,660 seriously injured car occupants in Europe
per year. Research shows that the benefits of a mandatory specification for
energy absorbing front underrun protection would exceed the costs, even if
the safety effect of these measures was as low as 5%. European
Commission; Front Underrun Protection Systems [Note: 75 kmh = 46.6028
mph]
(2) Front guards must have 3 levels of resistance; soft front for pedestrians
and cyclists, middle area must be softer than the partner vehicle in crashes
and able to absorb energy such as through crush, and rear area must be
strong and stiff enough to resist underride and rotate high-speed vehicles
away from the truck. Extend the front guard from the truck 600 mm (2 feet) to
give room for a 500 mm (1.6 feet) radius curve to deflect crash partners
including VRU and cars. The extra 600 mm should give 102 km/h or (63 mph)
of protection which would exceed a general goal of 60 mph (100 km/h) — an
average speed for highway crashes in the real world.
(3) NHTSA shall immediately issue an RFP to identify the appropriate
requirements for a front underrun protection standard.

ECE No. 93 FRONT UNDERRUN PROTECTION

Design and Optimization of Front Underrun Protection Device

https://ec.europa.eu/transport/road_safety/specialist/knowledge/vehicle/safety_design_needs/heavy_goods_vehicles_en

Don’t you think that enough is enough?! Let’s make it a priority to tackle the whole underride problem post haste! If we don’t (knowing what we now know), then who should we hold responsible for the thousands of people who will most surely die from preventable underride?

No compromise. Too many have already paid the price for 50 years of compromise.

If people die from riding under Single Unit Trucks, why aren’t they required to have underride protection?

Today I saw another example of why I think that this planet needs comprehensive underride protection on trucks — including on Single Unit Trucks (SUTs), otherwise known as straight trucks, box trucks, work trucks.

Currently, those kinds of trucks are not required to have underride protection. Some of them have voluntarily added some kind of wimpy thing that tries to pass as a rear underride guard. But looking at this one, I wonder whether they even understand the purpose of an underride guard.

If people die from riding under Single Unit Trucks, why aren’t they required to have underride protection?

Why COMPREHENSIVE Underride Protection Legislation?

Why put rear underride protection on trailers but not Single Unit Trucks? Any underride is deadly.

I ran across a study on underride fatality crashes this morning. I’d read it before but took a lot at it again. +

Then, this afternoon, while in city traffic, I saw an almost-side underride-crash between a car and Single Unit Truck (SUT). And when I arrived at a parking lot later, I saw a wimpy rear underride guard on a SUT.

So, why do we put rear underride guards on trailers but don’t require them on SUTs? (Not even mentioning that the current rear guard requirement is ineffective as written.) And why don’t we require side underride guards on any large trucks?

Truck underride is deadly no matter the truck size or portion of the truck the smaller vehicle rides under.

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SUT Underride guard Great Dane trip 061

+ For SUTs, the study showed that, “Considering all degrees of underride, trucks with a guard suffered slightly more underride than trucks with no rear-end protection, 69.5% to 66.7%. . . This result is counter to what would be expected, although it may be due to small, sample sizes and a host of other complicating factors. The severity threshold of the TIFA file may serve to decrease variation in the amount of underride by rear-end structure, since a fatality must occur for the crash to be included in the file. It could be that many of the collisions are beyond the design limits of the guards, and so the guards have no effect.” Underride in rear-end fatal truck crashes, Submitted to National Highway Traffic Safety Administration, prepared by Daniel Blower Kenneth L. Campbell, The University of Michigan Transportation Research Institute, October 1999

In other words, the wimpy guards aren’t effective anyway, so even if a SUT has one, the guard usually doesn’t do what it’s supposed to do — which is to prevent deadly underride.

Current rulemaking on underride protection for SUTs is in limbo at NHTSA: ANPRM Underride Protection of Single Unit Trucks

Mechanical Engineering Student Makes a Good Case for Preventing Underride Crash Fatalities

Here is another good case for improvement in truck underride regulation and manufacture–this time from a mechanical engineering student:  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0078

It’s all good so be sure and read it, but here are some excerpts:

“Let us consider the future instead of the present for just a moment. A scary revelation is that passenger vehicles used by the commuting public are being designed to be smaller, lighter and built of lightweight composite materials. This engineering is done to improve fuel economy, handling, suspension, and improving the drivers experience. The key is to strive for an increase in safety at the same time. On the polar opposite side of the spectrum, the trucking industry has been trying to increase the size and maximum load of their CMVs to increase revenue for a number of years.

I believe the trucking industry should follow in the footsteps of Emilio Lopez, UPS’ Global Fleet Safety Manager, who was recently quoted in an article by Truckinginfo as saying, “It’s hard to put a ROI (return of investment) on saving someone’s life.” After reviewing recent studies on underride, researching previous studies, looking over police scene photographs and sketches, it can be noted that primarily, rear underride accidents occur at night where the driver of a small passenger vehicle cannot perceive a stopped vehicle.

My biggest issue with the NHTSA ANPRM Docket No.: NHTSA-2015-0070 is the following quote, “Among the 122 fatalities examined in this review, 49 (40 percent) were exceedingly severe crashes that were not survivable.” What if we stop believing traffic fatalities are inevitable and start believing that every traffic fatality is preventable? It may be a rather colossal way of thinking. Innovation can be accomplished by thinking big and starting small. Small steps are what eventually climbs the mountain. Introduce increased regulations on SUT in which the rear guard is stronger than FMVSS Nos. 223 and 224, potentially CMVSS No. 223 compliant guards. Use these regulations to collect real-world data from the increased structural rigidity to determine if the problem lies in the fact that the FMVSS Nos. 223 and 224 guards are not strong enough to begin with.”

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Sign & share Vision Zero Petition: http://www.thepetitionsite.com/417/742/234/save-lives-not-dollars-urge-dot-to-adopt-vision-zero-policy/

See how AnnaLeah & Mary for Truck Safety is raising money for underride research and planning an Underride Roundtable at IIHS on May 5, 2016:  https://www.fortrucksafety.com/ and http://annaleahmary.com/2015/10/underride-roundtable-save-the-date-may-5-2016/

 

Powerful & Informative Case Made for Underride Guard Improvement by Trucker/Attorney

Even if you think that you know all there is to know about truck underride, you’ll want to read the comments by this truck driver/truck crash attorney. He provides an in-depth understanding of how underride occurs and the horrific results.

With the extended Public Comment period coming to a close for Rear Underride Protection on Single Unit Trucks, there are some additional comments just posted on The Federal Register at regulations.gov.  http://www.regulations.gov/#!docketDetail;dct=FR+PR+N+O+SR;rpp=10;po=0;D=NHTSA-2015-0070

Of particular note is a very informative and powerful comment recently posted by Andy Young, a husband, father, truck owner, Class A CDL driver, truck accident attorney and a trial attorney: http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0075 . The remainder of this post contains his public comment on that website:

“I bring a unique and varied perspective to the very issue under consideration. Not only does my background and experience provide me with credibility to make the within comments, but I have also researched issues regarding rear underride guards, lateral protection devices, and front override prevention. My research has even taken me overseas to see how other countries are handling some of the very issues raised in the comments submitted by original equipment manufacturers and by those who are part of the commercial trucking industry. Due to both my practical experience and research, I comment as a proponent in favor of the advance notice of proposed rulemaking (ANPRM).

Underride Crashes = The Eight Figure Jury Verdict

“The automotive industry spends millions, if not billions, in research and development. This research and development is specific to improving a vehicle’s safety features (energy absorbing bumpers, crumple zones, air bags, seat belts, etc.) all designed to keep the vehicle occupants safe. The engineering behind these safety features can mean the difference between a minor injury and a tragic fatality. No matter how safe the car may actually be, the safety features are only effective if there is good structural interaction (crash compatibility) between collision partners. This means there is a geometrical match up of the crush structure of both the striking vehicle and the vehicle being struck.

“A two vehicle collision involving a single-unit, commercial motor vehicle (CMV) and a light passenger vehicle frequently results in a mismatch of structural components at the first point of impact. The crash incompatibility is in large part due to the height of the CMV. This often results in an “underride” collision. The lower profile passenger vehicle physically goes underneath the higher profile CMV. The first point of impact is beyond the hood and into the glass windshield. The second point of impact then literally becomes the heads, faces, and chest of the lower profile vehicle’s occupants.

“Air bags do not deploy because the lower profile vehicle’s bumpers and air bag sensors are not triggered. Energy absorbing bumpers and crumple zones, all designed to keep the passenger compartment intact, become irrelevant. The load path from the crash results in energy that does not initially strike the intended engineered crush structure of the passenger vehicle. With no air bag and the vehicle traveling underneath the opposing vehicle, the occupant compartment is pierced resulting in a passenger compartment intrusion.

Thereafter, the seat belts restraining the occupants fail to prevent catastrophic injury or deadly consequences as the energy from the collision is absorbed directly by the human body. The car’s occupants then suffer the most horrific crash consequences: death by blunt trauma; decapitation; open skull fractures; traumatic brain injuries; degloving of the face; spinal cord injuries; paraplegia; or quadriplegia.

“The truck driver then suffers with a career-ending criminal vehicular homicide and/or criminal vehicular assault charges. At the very least, the truck driver suffers the psychological trauma associated with being an integral part of such a horrific crash. The truck company then likely encounters a civil lawsuit. The fatalities and catastrophic injuries associated with underride crashes typically produce seven figure to eight figure verdicts, all exceeding minimum insurance requirements. Smaller truck companies are saddled with paying the judgments in excess of insurance coverage. These companies then must sell assets and/or end up filing for bankruptcy.

“Everyone loses in an underride truck crash, the truck company and truck driver included. The typical argument that energy absorbing underride guards would increase weight and costs associated with that increase, simply do not equal the costs associated with the potential of a seven to eight figure jury verdict. My question to those in opposition to this measure is: if you are concerned about saving weight, then why not the same level of concern for saving lives?

Underride Lawsuit Example

“Underride crashes resulting in these devastating injuries and fatal results can even occur at lower speeds. A verdict was recently achieved in an underride collision involving a dump truck and a Honda sedan (Kiara E. Torres and Joshua Rojas vs. Concrete Designs, Inc., et al., Cuyahoga County, Case No. CV 12 795422 & 795474). The first point of impact was the windshield and “A Pillar” of the Honda’s front passenger side coming into contact with the back left corner of the dump truck’s cargo bed. The Honda’s front bumper and hood traveled underneath the dump truck’s steel cargo bed without damage. The geometrical mismatch of the collisions’ two partners caused the corner of the dump truck cargo bed to cut through the Honda’s windshield and into the skull of the right front seat passenger. This young man miraculously survived, but suffered an open skull fracture, a traumatic brain injury, and substantial physical limitations – all requiring a prohibitively expensive life care plan. Unfortunately, the Honda had three other passengers and this young man was not the only one exposed to the passenger compartment intrusion.

“The passenger compartment intrusion continued along the right side length of the Honda. The right backseat passenger succumbed to the load forces and also suffered a traumatic brain injury. Intriguingly and not atypical of collisions piercing into the passenger compartment, the two occupants on the left side of the Honda (the driver and the passenger behind the driver) walked away from the accident with minor injuries. The dump truck driver was also uninjured. Frequently, occupants not effected by the passenger compartment intrusion (particularly at lower speeds) can suffer no injury at all while those effected by the PCI can end up with injuries that result in substantial verdicts. The Jury returned a verdict in favor of the front seat passenger in the amount of $34,600,000.00 and the back seat right passenger in the amount of $7,800,000.00. 100% of the fault was apportioned against the dump truck driver. The total verdict for this underride crash was $42,400,000.00.

Over 62 Years Since Rear Underride Guard Requirement Update On SUTs

“The first standard for rear underride guards on CMVs was issued in 1953 by the Bureau of Motor Carriers. On June 29, 1967, national attention was brought to the issue of rear underride guard protection and vehicle crash compatibility when Jayne Mansfield, American actress, was killed as a front seat passenger in a 1966 Buick Electra. In spite of the 1953 rear guard requirement, this Buick hit the back of a tractor-trailer resulting in beyond the windshield passenger compartment intrusion. Three adults and three children were involved in the crash. The three adults seated in the front seat, Jayne Mansfield, her companion Attorney Sam Brody, and the car driver, Ronald B. Harrison were all killed. The actress’ three children (eight-year-old Mickey, six-year-old Zoltan, and three-year-old Marie) all survived and were claimed to have been in the back seat of the car. Early media reports wrongly believed Ms. Mansfield to have been decapitated.

“In 1969 and 1977, the NHTSA proposed an advance notice of rule making. Both regulatory attempts failed. Forty-five years after the 1953 rule requiring rear underride guards, the NHTSA promulgated an updated rear underride guard standard that became effective in 1998. The new mandate was for combination tractor-trailers only. They did not include single unit trucks (SUTs). The new rule required the following: rear guard ground clearance to be no more than 22 inches; rear wheel setbacks of no more than 12 inches from the cargo bed; and strength testing requirements. To date, the NHTSA has not updated rear underride guard requirements for SUTs. It is hoped that this ANPRM will succeed to regulatory mandate.

“In a letter dated April 3, 2014, the National Transportation Safety Board (NTSB) urged the NHTSA to take action regarding underride guards. The NTSB letter asked for a number of items regarding rear and side underride protections systems all “designed to prevent accidents and save lives” (Hersman, Deborah A.P., Chair, National Transportation Safety Board, Safety Recommendations, H-14-001 through -007, letter to The Honorable David J. Friedman, Acting Administrator, National Highway Transportation Safety Administration, page 14). On July 10, 2014, the NHTSA granted a petition for rule making submitted by Ms. Marianne Karth and the Truck Safety Coalition requesting the agency improve the safety of rear underride guards on trailers and SUTs (DOT, NHTSA, “Grant of Petition for Rulemaking; 49 CFR Part 571 FMVSS, Rear Impact Guards; Rear Impact Protection”). The Petitioners also made a request to improve side underride guards and front override protection.

Comments Against Need To Be Met With Skepticism

“Industry equipment manufacturers state that rear guards cannot be placed on various construction related vehicles. These statements need to be met with skepticism. Many European CMVs already have rear-underride guard protection on trucks, like dump trucks or box trucks with lift gates. Please see the following photographs I took while I attended the Commercial Vehicle Show in Birmingham, England this past April, 2014.

Note: The Public Comment can be accessed here to see the indicated photos.  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0075

“As evidenced by the photographs above, the U.S. lags behind other developed nations in providing meaningful rear impact protection. The photos above are just two examples of numerous applications allowing for rear impact protection and a lift gate or dump application. The argument that many SUTs need to have “good off-road mobility at construction sites” or “hitch connections” and therefore cannot have rear impact protection is likewise out-of-date thinking. Below, please see photographs from one vendor at the Commercial Motor Vehicle Show in Birmingham, England.

“While it is not readily apparent by these photographs, the vendor demonstrated how the rear impact protection guard can be adjusted up and down, as needed. Technology exists that debunk the argument that the rear impact guard would interfere with the work that the truck must perform.

Conclusion

“In this magnificent country of ours it is difficult to accept the fact that as a nation we are decades behind protecting our motorists from underride and/or override crash scenarios. The NHTSA has been slow to meaningfully regulate underride guard protection. As such, local governments, such as the City of Boston are passing ordinances requiring lateral protection devices on SUTs. Even the University of Washington announced that it is installing side guards on its campus fleet of SUTs. I implore the NHTSA to seriously consider meaningful passage of the pending proposal. We need to make sure that our citizens have the same protection as those in other nations. Sixty-two years is too long to wait to pass regulatory requirements that afford rear impact protection and other safety devices on single unit trucks.

“If you have any questions, I can be reached at 216-789-4832. My email is andytatransport@gmail.com. My Twitter account is @SafeDriveHome”

Note: Additional information can be gained by an article on underride by the same author: http://www.nphm.com/wp-content/uploads/2014/10/Piercing-The-Passenger-Compartment1.pdf?fd9d09 .

See my Public Comment as a firsthand example of the horrific, fatal injuries which too often occur in underride crashes: Marianne Karth – Comment  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0018

Underride Research Meme

Learn how AnnaLeah & Mary for Truck Safety is raising $ for Underride Research–a timely and life-saving effort:  https://www.fortrucksafety.com/

Our Vision Zero Petition seeks to bring about practical solutions to the problem of motor vehicle crash fatalities & injuries: http://www.thepetitionsite.com/417/742/234/save-lives-not-dollars-urge-dot-to-adopt-vision-zero-policy/

The latest Public Comments on the ANPRM for Underride Protection of Single Unit Trucks

Here are new comments posted on the Federal Register for

ANPRM for Underride Protection of Single Unit Trucks

See attached file(s) 
View Comment

Submitter Name: Lackore, Roger
Posted: 10/20/2015
ID: NHTSA-2015-0070-0062
Not sure how this is going to prevent people from driving into the rear of a truck… Maybe more money should be spent on educating drivers when they get their…
View Comment

Submitter Name: Anonymous
Posted: 10/08/2015
ID: NHTSA-2015-0070-0061
Re: Conspicuity Rules. When the rules for class 8 vehicles were implemented, I operated a private fleet operating, primarily, east of the Mississippi river…
View Comment

Submitter Name: Schafer, Robert
Posted: 10/08/2015
ID: NHTSA-2015-0070-0058
As a long-time transportation industry professional, it is my opinion that CMVs should not be exempt from “bumper height” or any other safety regulations. The…
View Comment

Submitter Name: Gislason, John
Posted: 10/08/2015
ID: NHTSA-2015-0070-0060
I am not apposed to putting on reflective tape on the side rails or boxes of straight trucks, but as for the rear guard what is going to be the rule for…
View Comment

Submitter Name: Johnson, Paul
Posted: 10/08/2015
ID: NHTSA-2015-0070-0059

http://www.regulations.gov/#!docketDetail;dct=FR+PR+N+O+SR;rpp=10;po=0;D=NHTSA-2015-0070

Additional Public Comments on Underride Protection for Single Unit Trucks

Here is the complete list of comments:  http://www.regulations.gov/#!docketBrowser;rpp=25;po=0;dct=PS;D=NHTSA-2015-0070

Here are the most recent comments added to the ANPRM for Underride Protection of Single Unit Trucks after the Public Comment Period was extended for 30 days until November 5, 2015.

Not sure how this is going to prevent people from driving into the rear of a truck… Maybe more money should be spent on educating drivers when they get their…
View Comment

Submitter Name: Anonymous
Posted: 10/08/2015
ID: NHTSA-2015-0070-0061
I am not apposed to putting on reflective tape on the side rails or boxes of straight trucks, but as for the rear guard what is going to be the rule for…
View Comment

Submitter Name: Johnson, Paul
Posted: 10/08/2015
ID: NHTSA-2015-0070-0059
As a long-time transportation industry professional, it is my opinion that CMVs should not be exempt from “bumper height” or any other safety regulations. The…
View Comment

Submitter Name: Gislason, John
Posted: 10/08/2015
ID: NHTSA-2015-0070-0060
Re: Conspicuity Rules. When the rules for class 8 vehicles were implemented, I operated a private fleet operating, primarily, east of the Mississippi river…
View Comment

Submitter Name: Schafer, Robert
Posted: 10/08/2015
ID: NHTSA-2015-0070-0058
September 21, 2015 Docket Management Facility, M-30 U.S. Department of Transportation West Building Ground Floor, Room W12-140 1200 New Jersey Avenue SE…
View Comment

Submitter Name: Kearney, Brendan
Posted: 09/28/2015
ID: NHTSA-2015-0070-0054

 

Rear Impact Guards for Single Unit Trucks: Public Comment Period Reopened for 30 days

NHTSA has re-opened the Public Comments period on the Advanced Notice of Proposed Rulemaking for Underride Protection on Single Unit Trucks. For 30 days until 11/5/2015.

So, if you have not yet made a Public Comment on this important issue, you now have an opportunity to do so.

https://www.federalregister.gov/articles/2015/10/06/2015-25377/federal-motor-vehicle-safety-standards-rear-impact-protection-lamps-reflective-devices-and

“This document reopens the comment period for a July 23, 2015 advance notice of proposed rulemaking (ANPRM) that NHTSA issued in response to a petition for rulemaking from Ms. Marianne Karth and the Truck Safety Coalition relating to rear impact (underride) guards. The original comment period closed September 21, 2015. The agency is reopening the comment period for 30 days.”

Reopening of Comment Period

NHTSA is reopening the comment period for the ANPRM for 30 days. (2) NHTSA believes that a 30 day period is sufficient and balances the interests of encouraging public participation in the rulemaking process with the desire to not unnecessarily delay key decisions by NHTSA about the rulemaking and attainment of the potential societal benefits associated with a final rule.

Accordingly, the public comment closing dates for DOT Docket No. NHTSA-2015-0070 (RIN 2127-AL57) is reopened for 30 days as indicated in theDATESsection of this document. NHTSA notes that the 30 day period is in addition to the time that has passed since the original September 21 comment closing date until today. Thus, all in all, more than 30 days has been provided. It is further noted that the agency will consider late comments to the extent possible.

Authority

49 U.S.C. 322, 30111, 30115, 30117 and 30166; delegation of authority at 49 CFR 1.95.

Raymond R. Posten,
Associate Administrator for Rulemaking.
[FR Doc. 2015-25377 Filed 10-5-15; 8:45 am]
BILLING CODE 4910-59-P

Footnotes

(1) As noted in the ANPRM (80 FR at 43664), in the near future NHTSA will be issuing a notice of proposed rulemaking on improving the standards’ performance requirements for guards on all vehicles subject to the standards.”

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Comments on the Federal Register can be seen here: http://www.regulations.gov/#!docketDetail;dct=FR+PR+N+O+SR;rpp=10;po=0;D=NHTSA-2015-0070

You can also see the Public Comments on these posts: http://annaleahmary.com/tag/suts/

 

Underride Guards for Single Unit Trucks: More Comments Posted on the Federal Register

The Public Comments period has closed for the Advanced Notice of Proposed Rulemaking for Underride Protection on Single Unit Trucks. But there were 21 last-minute comments which have now been added to the Federal Register today.

Read them here:  http://www.regulations.gov/#!docketDetail;dct=FR+PR+N+O+SR;rpp=10;po=0;D=NHTSA-2015-0070

Newly-listed commenters include:

  1. Seven Hills Engineering (Perry Ponder),  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0046
  2. Alliance of Automobile Manufacturers, (Scott Schmidt),  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0032
  3. Boston Public Health Commission BPHC (Lisa Conley),  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0048
  4. Medical Academic and Scientific Community Organization, Inc. MASCO Area Planning and Development (Paul Nelson),  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0043
  5. National Transportation Safety Board (Christopher Hart),  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0030
  6.  3M Traffic & Safety Security Division (Daniel Hickey),  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0022
  7. National Ready Mixed Concrete Association (NRMCA) ( ),  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0026
  8. International Brotherhood of Teamsters (Sam Loesche),  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0047
  9. ORAFOL Americas Inc. (Chris Gaudette),  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0033
  10. Avery Dennison (a leading designer and manufacturer of retroreflective safety materials), http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0037
  11. Transportation Safety Equipment Institute (Christopher Grigorian),  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0044
  12. Truck and Engine Manufacturers Association (EMA) (Timothy Blubaugh),  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0031
  13. General Motors, LLC (Brian Latouf, Director),  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0034
  14. Meehan Boyle Black & Bogdanow, PC,  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0041
  15. Texas Cotton Ginners’ Association (Kelley Green),  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0038
  16. Southeastern Cotton Ginners Association, Inc. (Dennis Findley),  http://www.regulations.gov/#!docketBrowser;rpp=25;po=25;dct=PS;D=NHTSA-2015-0070
  17. National Asphalt Pavement Association (Howard Marks),  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0036
  18. National Cotton Ginners’ Association (W. Harrison Ashley),  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0040
  19. City of Palo Alto-Planning & Community Environment (Joshuah Mello),  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0035
  20. National Waste & Recycling Association (John Haudenshield),  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0042
  21. Advocates for Highway & Auto Safety (Shaun Kildare),  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0039

Note: Previously-posted Public Comments on this issue can be accessed here:  http://annaleahmary.com/2015/09/truck-industry-engineers-safety-advocates-comment-on-truck-underride-protection-for-motorists-pedestrians-cyclists/

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Request for Extension of Public Comment Period on Single Unit Truck Rulemaking Process

After hearing that several groups were hoping that they could have more time (beyond the current deadline of September 21) to prepare a Public Comment on the Advanced Notice of Proposed Rule Making (ANPRM) on Underride Protection of Single Unit Trucks, I contacted NHTSA and filed a request to extend the Public Comment period.

The agency replied that they are considering my request. It usually takes at least 10 calendar days for such a process. I hope that this helps with providing useful information but does not lead to unnecessary delay of the needed rulemaking.

Trip North May 2015 035

Photo by me of a Single Unit Truck I saw on the expressway a few months ago.

Note the wimpy rear underride guard.

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