Tag Archives: SUTs

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.

Trip North May 2015 033underride guards trip to RDU 007

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

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

Public Comments Updated for Underride Guards on Single Unit Trucks

New comments were added yesterday to the Public Comments on the ANPRM for Underride Protection on Single Unit Trucks.

DOCUMENT ID:    NHTSA-2015-0070-0049 (http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0049)
DOCUMENT TYPE:  PUBLIC SUBMISSIONS
POSTED DATE:    09/28/2015
DOCUMENT TITLE: District Department of Transportation – Comments

DOCUMENT ID:    NHTSA-2015-0070-0050 (http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0050)
DOCUMENT TYPE:  PUBLIC SUBMISSIONS
POSTED DATE:    09/28/2015
DOCUMENT TITLE: New York City Department of Transportation – Comment

DOCUMENT ID:    NHTSA-2015-0070-0051 (http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0051)
DOCUMENT TYPE:  PUBLIC SUBMISSIONS
POSTED DATE:    09/28/2015
DOCUMENT TITLE: Anonymous

DOCUMENT ID:    NHTSA-2015-0070-0052 (http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0052)
DOCUMENT TYPE:  PUBLIC SUBMISSIONS
POSTED DATE:    09/28/2015
DOCUMENT TITLE: Tom Maguire – Comment

DOCUMENT ID:    NHTSA-2015-0070-0053 (http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0053)
DOCUMENT TYPE:  PUBLIC SUBMISSIONS
POSTED DATE:    09/28/2015
DOCUMENT TITLE: Kit Keller – Comment

DOCUMENT ID:    NHTSA-2015-0070-0054 (http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0054)
DOCUMENT TYPE:  PUBLIC SUBMISSIONS
POSTED DATE:    09/28/2015
DOCUMENT TITLE: Brendan Kearney – Comment

DOCUMENT ID:    NHTSA-2015-0070-0055 (http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0055)
DOCUMENT TYPE:  PUBLIC SUBMISSIONS
POSTED DATE:    09/28/2015
DOCUMENT TITLE: Seven Hills Engineering, LLC – Comment

DOCUMENT ID:    NHTSA-2015-0070-0056 (http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0056)
DOCUMENT TYPE:  PUBLIC SUBMISSIONS
POSTED DATE:    09/28/2015
DOCUMENT TITLE: National Propane Gas Association – Comment

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/

Underride Research Meme

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Donate online now through AnnaLeah & Mary for Truck Safety at:  https://www.fortrucksafety.com/

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.

Donate now & support Underride Research to Prevent Underride and Save Lives:  https://www.fortrucksafety.com/

Harvard School of Public Health posts comments in support of improved truck underride protection

Latest post in The Federal Register for Public Comments on the Advanced Notice of Proposed Rule Making for underride protection on Single Unit Trucks (SUTS) includes comments on suggestions for side guards to protect cyclists:

http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0010

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

Public Comment Period ends September 21 for ANPRM on underride protection for Single Unit Trucks (SUTS)

There have been some comments added to the Public Comments on the Federal Register for the Advanced Notice of Proposed Rule Making on rear underride protection for Single Unit Trucks (SUTS).

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

The Public Comment period is currently scheduled to end on September 21, 2015. We encourage you to add your comment to this process to indicate support for the inclusion of Single Unit Trucks in the requirements for underride protection.

Here are some suggestions on writing comments:  http://annaleahmary.com/2015/08/thoughts-on-making-a-public-comment-on-rulemaking-for-single-unit-truck-underride-protection-ends-september-21/

Also, please consider donating to our underride research effort.

Donate & Spread the Word using our new website for AnnaLeah & Mary for Truck Safety:  https://www.fortrucksafety.com/

Underride Research Meme

Thoughts on making a Public Comment on rulemaking for Single Unit Truck underride protection (Ends September 21)

DOT is studying whether or not they should require “single unit (or straight)” trucks to be safer, i.e., be built so that–when a vehicle rear-ends them–the smaller vehicle does not slide underneath the larger truck. And they are asking people to let them know what they think about this.

What might you say about the proposed rulemaking for underride protection on these trucks? (Examples of SUTs are dump trucks, garbage haulers, concrete mixers, tank trucks, trash trucks, and local delivery trucks.)

What I would suggest is that you point out the fact that people die every year when their vehicle hits the back of single unit trucks so that the truck actually enters the passenger vehicle in the area where people are sitting. And, if manufacturing companies were required to provide adequate underride protection on these trucks, many of those deaths could be prevented.

Sure, it will cost some money to provide that protection. And that cost will have to be passed on to someone–whether it be the manufacturing company, the company which purchases the truck, the consumer of the trucking industry services, etc. Are we willing to bear that cost as a society, or would we rather keep our costs as low as possible–at the price of human life?

Good news: The 11,000+ AnnaLeah & Mary for Truck Safety Petition signers have been added to the Public Comments for the ANPRM Underride Protection for Single Unit Trucks.

To see all of the signatures/comments from the Petition, go to this link:  http://www.regulations.gov/#!docketBrowser;rpp=25;po=0;D=NHTSA-2015-0070

At that site, click on Karth Family/Care 2 Petition. Then click on Supporting Documents. There is a PDF and an XLS spreadsheet. The PDF can be read better by magnifying the chart.

You are allowed to add your own comments to the ANPRM–even if you signed the Petition. You can do so by clicking the COMMENT NOW button on that website. Please take the time to express your thoughts on this vital issue.

I am grateful for the countless people across the earth who care about these life and death matters and are willing to stand up and ask for safer roads.
Please note: Public Comments Period ends September 21, 2015.
Rebekah photo of crash

11,000+ AnnaLeah & Mary for Truck Safety Petition signers added to Public Comments for the ANPRM Underride Protection for Single Unit Trucks.

Good news: The 11,000+ AnnaLeah & Mary for Truck Safety Petition signers have been added to the Public Comments for the ANPRM Underride Protection for Single Unit Trucks.
To see all of the signatures/comments from the Petition, go to this link:

http://www.regulations.gov/#!docketBrowser;rpp=25;po=0;D=NHTSA-2015-0070

At that site, click on Karth Family/Care 2 Petition. Then Click on Supporting Documents. There is a PDF and an XLS spreadsheet. The PDF can be read better by magnifying.the chart.
You are allowed to add your own comments to the ANPRM–even if you signed the Petition. You can do so on the Comments Now button on that website.
I am grateful for the countless people across the earth who care about these life and death matters and are willing to stand up and ask for safer roads.
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