Tag Archives: underride crash fatalities

More information on Underride & the World Forum for Harmonization of Vehicle Regulations

That’s exciting. I woke up to a comment on our website related to my post about the World Forum for Harmonization of Vehicle Regulations.

Here’s the comment:

The United States has been involved with WP.29 since its inception; however, the Forum originally focused on developing standards for Europe. It has only been a truly global effort since the late 1990’s. The US (NHTSA and the EPA) has been a major contributor to international research and development efforts, but when it comes to specific regulations, the US legal system operates under different principles from Europe.

The US was the first nation to set up a regulatory system for vehicle safety. Ralph Nader and others saw the issue as one of consumer protection and product liability while Europe later addressed safety more as an engineering and product certification issue. As a result, we have two main approaches (self-certification and type approval) and there are two international agreements (1958 and 1998) to allow for uniform regulations. Under the 1998 Agreement, WP.29 establishes Global Technical Regulations (GTR) that can be used under any system. (UN Regulations can only be used under a type approval system.) So at the international level, a state-of-the-art standard for rear underrun protection would involve looking at the current regulations in use around the world to see if the harmonization of requirements through a GTR would be practicable and beneficial. John Creamer, globalautoregs.com

John Creamer is the founder of GlobalAutoRegs.com and a partner in The Potomac Alliance, a Washington-based international regulatory affairs consultancy. In his client advisory role, Mr. Creamer is regularly involved with meetings of the UN World Forum for the Harmonization of Vehicle Regulations (WP.29). Previously, he has held positions with the US International Trade Commission and the Motor & Equipment Manufacturers Association (representing the US automotive supplier industry), as the representative of the US auto parts industry in Japan, and with TRW Inc. (a leading global automotive safety systems supplier).

I just emailed John to see what else I can find out from him about this possibility for world-wide collaboration on improving protection against deadly underride. Stay tuned.

(Just so long as it does not get in the way of forward progress meanwhile!)

Negotiated Rulemaking

In memory of AnnaLeah and Mary (and so many others). . .

Never forgotten

From 1994-2014, 5,081 truck underride deaths (on average, 4/week) recorded by NHTSA.

April 19, 2016

Dear Care for Crash Victims Community Members:


Marianne Karth asked NHTSA for information on Truck Underride Deaths.


NHTSA provided a revealing and disturbing set of data.


For twenty years about 4 people every average week an American motorist died of their injuries according to NHTSA’s FARS data.  From 1994-2014 the total amounting to 5,081 deaths were recorded by NHTSA.  See attached.


Year after tragic year the number has remained almost constant at more than 200 deaths each year.

See http://annaleahmary.com/2016/04/truck-underride-fatalities-chart-from-the-fars-1994-2014/

Investigative Reporters and Editors (IRE) have access to such data, so why don’t we see more stories?  See DOT and NHTSA databases available at IRE at


Let’s get the media focusing on our clear and present dangers here at home in the U.S.A. today.


Let’s get the media to produce change for the better with news we can use.



Why Front Underride or Front Underrun is Important (Deadly yet preventable?)

We included a request to address front underride in our AnnaLeah and Mary Stand Up For Truck Safety Petition. The response was that they would issue a separate decision on it at a future time:

Grant Of Petition For Rulemaking.
By initiating rulemaking to consider enhancing related safety standards, this notice grants the part of the petition for rulemaking submitted by Ms. Marianne Karth and the Truck Safety Coalition (Petitioners) requesting that the agency improve the safety of rear impact (underride) guards on trailers and single unit trucks. Based on the petition, available information, and the agency’s analysis in progress, NHTSA has decided that the Petitioners’ request related to rear impact guards merits further consideration. Therefore, the agency grants the Petitioners’ request to initiate rulemaking on rear impact guards. NHTSA is planning on issuing two separate notices—an advanced notice of proposed rulemaking pertaining to rear impact guards and other safety strategies for single unit trucks, and a notice of proposed rulemaking focusing on rear impact guards on trailers and semitrailers. NHTSA is still evaluating the Petitioners’ request to improve side guards and front override guards and will issue a separate decision on those aspects of the petition at a later date.


Steve Hadley, Underride Network, has posted on this issue. He says that,

“Front low-speed crashes with VRU (Vulnerable Road Users) are quite survivable with proper design.”

Read more about this issue here: http://www.underridenetwork.org/why-front-underride-or-underrun-is-important/

Front underride 002


A Mom’s Knee-Jerk Reaction to NHTSA’s Proposed Rule to Improve Rear Underride Protection

First of all, let me say that I am grateful for the work which NHTSA has done on this problem and their willingness to address it at this time. Then, I have to admit that I am not an engineer. So it’s a good thing that we don’t have to depend on me to be the one to provide a thorough analysis of the recently released proposed rule for the improvement of tractor trailer rear impact protection standards and all of its technical pros and cons.

But I can provide a summary of the highlights included in the NPRM, along with some of my knee-jerk reactions as a mom of two girls, who perished due to a truck underride crash, and as an advocate for better underride protection.

These are my general reactions. . .

While this proposed rear underride rule is definitely a much-needed improvement to the existing standards, it does not appear to embrace a Vision Zero policy approach which would seek to reduce crash deaths and injuries whenever and however possible.

Many of the trailer manufacturers are already meeting Canadian standards, but IIHS research has shown that this is still not adequate to prevent underride in many crash scenarios–particularly offset crashes. http://www.iihs.org/ externaldata/srdata/docs/ sr4907.pdf

Also, when I look at what NHTSA is predicting in terms of lives saved by this proposed rule–1 out of the 125 annual reported PCI underride crash fatalities–I have to ask, “What about the other 124?!” And our daughters, AnnaLeah and Mary, were not even counted in the 2013 FARS crash data for PCI crash fatalities because our crash was listed as “Passenger Compartment Intrusion Unknown“!!!


(Note: See our FARS crash report in my Public Comment on the Single Unit Truck rear impact protection ANPRM and a discussion of the problem of underride crash fatality UNDERREPORTING  and how it might impact the count of potential saved lives. . .  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0018)

In addition, there are many engineers around the globe who have come up with improved designs for underride protection, and there are many who are even now working on solutions that are stronger than the Canadian standards. They just have not yet been widely implemented or required.

It is, undoubtedly, an enormously significant step for NHTSA to acknowledge the need for stronger guards and to propose an improved guard. However, we do not want them to base the final rule merely on what will provide a “cost-effective” solution if, in fact, technology could be utilized which would save additional lives and prevent additional injuries.

One of our big concerns has been the apparently more vulnerable crash scenario when the smaller passenger vehicle hits the rear of the truck at the outer edges of the rear of the trailer. When Jerry and I visited Great Dane’s Research & Design Center in Savannah in June 2014, they pointed out that the company, Manac, which passed the 30% offset crash test had proven to be more vulnerable (although it still withstood the crash) at the 100% overlap test.

I reported on that in a previous blogpost in June 2014: “Great Dane, one of the major trailer manufacturers, observed that they passed all but one of the quasi-static crash tests—the narrow overlap. Great Dane also noted that their guard appeared to perform better on the full overlap test than Manac’s (which was the only company to pass all three tests in 2013). So Great Dane does not want to make a change which will strengthen one section of their guard but weaken another section. That’s understandable.”   http://annaleahmary.com/2014/06/underride-guards-can-we-sit-down-at-the-table-together-and-work-this-out/

NHTSA’s comments in the NPRM indicate that they do not want to compromise safety in the more common crash scenario and so have proposed to concentrate on making that area of the trailer safer and do nothing, at least at this stage in the game, about the other weaker area where crashes are reportedly less common. (See p. 44, ” NHTSA is not convinced that improved protection in the less frequent 30 percent overlap crashes should come at the cost of adequate protection in the more common 50 and 100 percent overlap crashes.”)

I just have to ask, Is it really an Either/Or situation? Are we sure that we cannot reasonably address both problems?

We are hoping and working toward the possibility that the Public Comments which will be submitted, the underride research both underway and proposed, and the Underride Roundtable which will be taking place at the IIHS Vehicle Research Center on May 5, 2016, will help to refine this rule so that it results in the best possible protection.

Here is the complete NPRM document: NPRM-underride.Dec2015

And here is the press release announcing the proposed rule:  https://www.transportation.gov/briefing-room/usdot-issues-nprm-improved-rear-impact-trailers-semitrailers#sthash.j6eu5DN1.dpuf

As I reviewed the NPRM document for rear impact protection on tractor-trailers, I created my own 9-page document by copying and pasting some of the highlights of the proposed rule (page numbers are indicated in case you want to go to the original document for further details). You can read my summary of the proposed rule here:  Highlights of the NPRM Rear Impact Guards, Rear Impact Protection December 2015 document

On December 10, I was interviewed by Atlanta investigative reporter, Jim Strickland:  http://www.wsbtv.com/news/news/local/new-rules-proposed-help-keep-you-safer-behind-big-/npgzd/.

“Our grandma wants to make the roads safer.” Remembering 2 girls in the aftermath of a truck crash

Marcus & Vanessa were particularly close to their aunts–having spent countless hours with them from birth until AnnaLeah & Mary moved away from Texas in 2012 when Marcus was 6 and Vanessa was 3. So the tragic truck underride crash, which killed AnnaLeah (17) and Mary (13) on May 4, 2013, was especially devastating for Marcus and Vanessa.

The other day, I thought about the idea of “interviewing” Marcus and Vanessa about their memories of AnnaLeah and Mary and what they thought could make underride guards stronger. After asking their mom and dad about the idea, I bought a toy big rig and a car and sat down with Marcus and Vanessa to talk.

Vanessa, her mom said, gets frustrated because she can’t remember very much. But I thought that it was important for her to talk about it. Marcus, on the other hand, says that he remembers them clearly.

After talking in generalities and moving to specifics, it got harder for Marcus to talk about it all. So, when my camera memory got full, it was just as well. I took Marcus on my lap, and we cried together–wishing that they were with us “right now.” These are some of the things which Marcus shared off camera:

  • Why did they have to die?
  • I wish that they could be here now and I could be doing things with them. I don’t know what we’d be doing. But I wouldn’t be crying.
  • I thought Mary was going to be fine when I found out she was at the hospital. I was sure. But it happened anyway.
  • Aunt Mary was my favorite person in the family.
  • Aunt AnnaLeah was a bookworm so I did more things with Aunt Mary. . . but I want both of them to be here!

Marcus and Vanessa both had some ideas about how trucks could be made safer so that cars wouldn’t go under them and people wouldn’t get hurt and die. Out of the mouths of babes. . .

Marcus & Vanessa talk about AnnaLeah & Mary and about how underride guards could be stronger:

A longer version of the interview with Marcus and Vanessa: 

Facebook Photo Album of Marcus & Vanessa with AnnaLeah & Mary:  https://www.facebook.com/media/set/?set=a.480711025344750.1073741852.464993830249803&type=3

Marcus & Vanessa’s mom talks about their loss:  https://www.facebook.com/permalink.php?story_fbid=577896972292821&id=464993830249803 & http://annaleahmary.com/2015/05/a-familys-joys-sorrows/

Underride Research:  https://www.fortrucksafety.com/ & http://annaleahmary.com/2015/10/underride-roundtable-save-the-date-may-5-2016/

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

Virginia Tech Senior Design Project is Addressing the Need for Stronger Underride Guards; Mid-Semester Progress Report

I received a wonderful email this morning with the Mid-Semester Progress Report from the 6-student team of engineering students at Virginia Tech who took on the creation of a better rear underride guard design as their senior capstone project.

In their words, “our team must strive to achieve the perfect design with respect to each specification, ensuring the absolute best final product.” (Sweet words to this mother’s heart!)

We look forward to seeing them in person at the IIHS Vehicle Research Center on May 5, 2016, as they share the results of their dedicated and innovative efforts at the Underride Roundtable.

Here is their 30-page progress report:  Virginia Tech Semi-Trailer Bumper Design Mid Semester Progress Report .


1 gertie 2782

I will be praying for the team everyday, including Wayne Carter (Team Facilitator), Daniel Carrasco, Kristine Adriano, Sean Gardner, Andrew Pitt, and Brian Smith–along with Jared Bryson (their Sponsor) and Robin Ott (their Project Advisor).

Save the Date Underride Roundtable

AnnaLeah & Mary for Truck Safety is raising money to support Underride Research efforts:  https://www.fortrucksafety.com/

I remember our trip back from visiting a research & design center in June 2014 and thinking that surely a group of engineers could get together and design better underride protection. It is amazing to watch this unfold.

Join thousands of other people in calling for a move towards zero crash deaths. Sign our Vision Zero Petitionhttp://www.thepetitionsite.com/417/742/234/save-lives-not-dollars-urge-dot-to-adopt-vision-zero-policy/

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

Support Vital Underride Research

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

Some Facts on Single Unit Truck Underride Crashes from the NTSB

Here is some information on single unit trucks (SUTs) crash statistics from the National Transportation Board:

” Although single-unit trucks comprise three percent of registered motor vehicles and four percent of miles traveled, they are involved in nine percent of fatalities among passenger vehicle occupants in multivehicle crashes. Crashes involving single-unit trucks and passenger vehicles pose a hazard to passenger vehicle occupants due to differences in weight, bumper height, and vehicle stiffness. . .

“Many studies of truck safety have examined fatalities as the sole outcome of interest. Tractor-trailers result in a larger proportion of fatal injuries from large truck crashes, which is one reason why some truck safety regulations have been limited to tractor-trailers and trailers. However, this study shows that there are substantial societal impacts resulting from non-fatal injuries arising from single-unit truck crashes. Emergency department visits, inpatient hospitalizations,3 and hospital costs4 that result from the crashes provide measures of the adverse effect of non-fatal injuries on the public.

“This study also shows that federal and state databases frequently misclassify single-unit trucks and thus undercount the total number of fatalities resulting from single-unit truck crashes by approximately 20 percent.”


underride guards trip to RDU 006