Tag Archives: Vision Zero rulemaking

Understanding Underride VII: Cost/Benefit Analysis

A panel of experts discuss underride at a Briefing on The Hill, October 12, 2017, to bring greater understanding of the problem and solutions of deadly but preventable truck underride. Jason Levine, Director of the Center for Auto Safety, discusses the flaws in the cost/benefit analysis of truck underride protection.

For more information on the STOP Underrides! Act of 2017, go to http://annaleahmary.com/ and/or https://stopunderrides.org/

Here are some further thoughts on cost benefit analysis related to underride protection:

  1. “Even if cost-benefit analysis is theoretically a neutral tool. . . it is biased against strong public protections.”Recently, NHTSA announced statistics for 2016 traffic fatalities:
    • 37,461 people killed in crashes on U.S. roadways in 2016
    • Up 5.6% from 2015
    • Tucked in the back of the report, if you look for it, you will see that there were 4,317 fatalities in crashes involving large trucks — up 5.4% from 2015, the highest since 2007. . .
  2. Public Comments on Underrride Rulemaking & Cost/Benefit Analysis: Public Comments Re: Cost/Benefit Analysis in NHTSA Proposed Underride Rulemaking on Rear Guards for Tractor-Trailers & for Single Unit Trucks and       Current NHTSA #Underride Rulemaking (Cost/Benefit Analysis): Summary of Public Comments and http://annaleahmary.com/2016/10/dot-omb-are-you-using-cea-or-cba-rulemaking-road-to-zero-requires-vision-zero-rulemaking/

  3. Jerry Karth’s Public Comments on Underride Rulemaking: Comments on the NPRM for Rear Underride Guards on Trailers and Reflections from a bereaved dad on the Underride Roundtable & what that means for rulemaking

  4. Stoughton improved underride guards–standard “at no cost or weight penalty.”
  5. Underride Statistics 

  6. The Future of Trucking: Who pays for the costs of safer roads?

    I thought about all of this, on a recent trip “back home”, as I reflected on the plight of small trucking companies and independent owner-operator truck drivers. Are the costs of owning a company and the pressure to drive many miles creating a situation where they won’t be able to stay in business?

    Frequently, I hear that changes of one kind or another in the trucking industry–in order to improve safety (i.e., reduce crashes, injuries and deaths)–will result in increased costs for the trucking companies. I hear that it will put them out of business.

    Is this true? According to whom and based on what information? If it is true, then does something need to change in the trucking industry itself in order to allow for the beneficial work, which trucking provides, to continue but to also allow for truckers to make a decent living wage–without jeopardizing their health and the safety of travelers on the roads? . . .  Read more here: The Future of Trucking; Who pays for the costs of safer roads?

  7. Whose lives are you going to sacrifice? If decisive action is not taken to end these preventable deaths, then who should we hold responsible? Whose lives are we thereby choosing to sacrifice?

  8. TTMA: Truck Trailer Manufacturers Association Reminds NHTSA Why Side Guards Are Not Cost Effective, May 18, 2016 post:

    Yesterday morning, I checked my email and saw that there was a new Public Comment posted on the Federal Register regarding the Notice of Proposed Rulemaking on Underride Guards.

    I quickly went to the site and saw that the Truck Trailer Manufacturers Association had posted a comment (see their comments in the PDFs below). Apparently our Underride Roundtable two weeks ago at IIHS has spurred them to spell out the steps which have been taken over the years to squash side guards from being mandated and manufactured to prevent smaller passenger vehicles from riding under trucks upon collision with the side of the larger vehicle.

    TTMA_Side_Impact_Main_Comment_2016-05-13

    TTMA_Side_impact_Exhibits_A-D_2016-05-13

    Their rationaleCost/Benefit Analysis shows that adding side guard to trucks is “not cost-effective”. From this post: Truck Trailer Manufacturers Ass’n “Reminds” NHTSA: Side Guards Are “Not Cost-Effective” Says Who? 

    I am encouraged by the closing paragraph of the TTMA letter to NHTSA:

    TTMA would support the implementation of side guards if they ever become justified and technologically feasible. We continue to support the NHTSA review of Petitioners’ requests and stand ready to partner in the development of justified and feasible designs if they possibly emerge. Jeff Sims, President

  9. How can we possibly justify allowing Death by Underride to continue when solutions exist to prevent it?, As I allow myself to remember the joy and laughter and love and creativity and grumpiness and irritability and silliness of my daughters, AnnaLeah and Mary, I also remember why I am working tirelessly to bring an end to Death by Underride — which snatched AnnaLeah from this earthly life on May 4, 2013, and Mary on May 8, 2013. I was in that horrific truck crash four years ago today. I survived but they did not because of Death by Underride. . .
  10. Mandates take burden off manufacturers. Crash tests in labs better than crash tests occurring in real world., Lou Lombardo has written a thought-provoking opinion piece, Creating a Demand for Crash Testing (CTTI, September 2011). It holds great value in confirming the need for comprehensive underride protection legislation to be introduced and passed in a timely manner. . .
  11. They fought the good fight, they finished the race. . .
  12. Every Day’s A Holiday With Mary; Joyful Memories of Mary
  13. Amazing Grace Goodbye, AnnaLeah & Mary, With Love From Grandpa
  14. Truck Industry Leaders: “Clarity is probably the biggest need we have so we can plan accordingly.”
  15. AnnaLeah Karth. May 15, 1995 – May 4, 2013. Death by Underride.

Does DOT Want to Reach Toward Zero Deaths? Or not?

In the process of writing a post on Mary’s would-have-been 18th birthday, I discovered a link to a DOT webpage on Toward Zero Deaths.

Here’s that post: Mary would have turned 18 today; but underride protection isn’t “cost-effective.”

And here is the link: Federal Highway Administration: Toward Zero Deaths .

The Department of Transportation is saying that the,

FHWA is committed to the vision of eliminating fatalities and serious injuries on our Nation’s roadways. This approach echoes the Department of Transportation’s Strategic Plan, which articulates the goal of “working toward no fatalities across all modes of travel“; the FHWA’s strategic goal of ensuring the “nation’s highway system provides safe, reliable, effective, and sustainable mobility for all users”; and the emphasis on safety that FHWA renews every year in our strategic implementation efforts.

The zero deaths vision is a way of clearly and succinctly describing how an organization, or an individual, is going to approach safety – even one death on our transportation system is unacceptable. This idea was first adopted in Sweden in 1997 as “Vision Zero” and since then has evolved across the country and across the world. A growing number of states and cities have adopted zero deaths visions under different brandings.

The zero deaths approach uses a data-driven, interdisciplinary approach that FHWA has been promoting for many years. The approach targets areas for improvement and employs proven countermeasures, integrating application of education, enforcement, engineering, and emergency medical and trauma services (the “4Es”). A combination of strategies from different focus areas will be necessary to achieve the zero deaths vision.

If that is truly the Department’s vision, then their lack of appropriate action to issue underride rulemaking falls far short of that mission. And why is that? Could it be that safety is no longer truly their priority? Are they unable to be an uncompromised voice for the victims of vehicle violence — whether there be 400 or 4,000 underride deaths/year?

Who then will advocate for safer roads?

Congress should act responsibly and pass the Roya, AnnaLeah & Mary Comprehensive Underride Protection Act. President Trump should sign an Executive Order to authorize Vision Zero Rulemaking and the Office of Management & Budget should revise their guidelines to allow agencies to conduct regulatory analysis which properly values the preservation of human health & life.

Otherwise, the Department of Transportation’s public commitment to a vision of Toward Zero Deaths is a farce. May it not be so.

 

Remembering Mary when she would have been 18.

Mary Lydia Karth, August 6, 1999 – May 8, 2013

Oh, and before you go, read this previous post: If Sec. Foxx & DOT are embracing Vision Zero, why do we have to fight to get a strong Underride Rule?

Mary would have turned 18 today; but underride protection isn’t “cost-effective.”

Controversy surrounds the cost/benefit analysis undergone to determine whether a safety solution — proven to save lives — is cost effective. In other words, does the total cost to the industry required to implement the solution

divided by

the supposed number of lives saved (and by some formula the number of injuries prevented)

equal a $ figure

less than or equal to the Value of a Statistical Life (VSL) at that point in time [currently $9.6 million]?

If the cost is greater than that VSL, the safety countermeasure is deemed too costly and the rulemaking is ditched. In the case of underride protection, no mandate is thereafter issued to the industry requiring them to install equipment which could save lives.

Here is an example. Single Unit Trucks (SUTs) are not currently required to have rear underride guards which meet the same standard as for tractor-trailers. We petitioned NHTSA in May 2014 to require them. In response, NHTSA issued an Advanced Notice of Proposed Rulemaking (ANPRM) in July 2015. Their preliminary regulatory cost benefit analysis came to this conclusion (p. 26):

Guidance from the U.S. Department of Transportation identifies $9.1 million as the value of a statistical life (VSL) to be used for Department of Transportation analyses assessing the benefits of preventing fatalities for the base year of 2012. Per this guidance, VSL in 2014 is $9.2 million.
While not directly comparable, the preliminary estimates for rear impact guards on SUTs
(minimum of $106.7 million per equivalent lives saved) is a strong indicator that these systems will not be cost effective (current VSL $9.2 million).

Yet, here is an April 2017 fatality in Florida from an underride crash involving a Single Unit TruckCrash kills 2 on I-75 in Bonita Springs

Apparently these lives were not worth saving.

Fairly soon after our crash, after a year or so of taking part in truck safety advocacy efforts, I became aware of the stranglehold which the cost/benefit analysis had on the likelihood of being able to get proven safety solutions actually required. That’s when I launched our Vision Zero Petition which got 20,000+ signatures. That’s when I also found that President Clinton’s Executive Order 12866 was what spelled out the specifications for that regulatory analysis for which the Office of Management & Budget had become the gatekeeper for safety regulations.

Many people made comments on the ANPRM for underride guards on Single Unit Trucks, as well as the NPRM for improved rear underride guards on tractor-trailers to the point that costs were overstated and benefits (saved lives) were understated. In fact, Lois Durso and I recently shared with many people on The Hill, as well as DOT, the proof that our two underride crashes were not even accurately listed as underride crashes with PCI (Passenger Compartment Intrusion) in the NHTSA FARS reports of truck crash fatalities. How many other underride deaths might also be inaccurately reported?

We are convinced that underride deaths are grossly undercounted. In fact, we would go so far as to say that every one of the 4,000 (on average) truck crash deaths each year should be considered an underride death unless otherwise proven (compared to the 200 to 600 annual deaths currently attributed to underride). After all, when a passenger vehicle collides with a large truck, it will be with some portion of that truck. If that part of the truck does not have any/adequate underride protection, then some degree of underride is, of course, likely to occur — which means that the truck is likely to intrude into the passenger occupant space. PCI then occurs with death and/or catastrophic injuries.

It is not necessarily the truck crash per se that causes the horrific deaths and injuries but rather the underride of the truck into the passenger occupant space. But this is not the current thinking in FARS data collection and regulatory analysis.

But even if we found a better way to report these deaths and every single one was included in the count, could someone find a loophole in the formula and still declare that comprehensive underride protection was not cost-effective and these lives were not worth saving?

When we were in DC a few weeks ago and met with DOT, I had a glimmer of hope because we were told that there had been recent discussions of the fact that the achievement of Zero Deaths in the airline industry was in stark contrast to the 35,000 annual deaths on the roadways. There was apparently realization that something had to be changed in how DOT is addressing this major public health problem — including the consideration of studying “near misses.” After all, DOT has publicly stated that their strategic plan is to move Toward Zero Deaths. I say, Let’s hold them to it!

Might we see a shift away from cost/benefit analysis that devalues human life to a cost-effectiveness approach that considers what is the most effective way (with the least cost) to save every life possible? What would it take to bring that about? Would President Trump be willing to sign an Executive Order authorizing Vision Zero Rulemaking?

If our truck crash had been less complicated — if I had rear-ended the tractor-trailer ahead of us instead of another truck hitting us and causing us to go backward into the tractor-trailer ahead of us — I would not be a truck crash survivor. I would have experienced Death by Underride and, quite likely — being in the back seat — AnnaLeah and Mary would have survived.

Mary would have lived to celebrate her 18th birthday today. She would have become an adult. She would have had the chance to live out her dreams and hopes. She would have continued to fill the world with her joie de vivre.

That is why I am unwilling to compromise and why I will continue to insist on underride protection that is comprehensive and effective to the fullest extent technologically possible in concert with the crashworthiness of cars. If that had been so on May 4, 2013, then AnnaLeah and I, along with our whole family, would have been able to wish Mary a very happy 18th birthday.

 

FMCSA will withdraw rule to raise truck min. liability ins. Who is responsible & who will pay the price?

Please pray for us to have wisdom on how to respond to the upcoming action (on Monday, June 5, 2017) by the DOT/FMCSA to WITHDRAW RULEMAKING on trucking minimum liability insurance  — which has not been raised in over 30 years.

This issue is one of the three #trucksafety issues which we included in our 2014 AnnaLeah & Mary Stand Up For Truck Safety Petition. FMCSA responded with rulemaking in November 2014. The 11,000+ petition signatures were added to the Public Comments for this Proposed Rule.

The AnnaLeah & Mary Stand Up For Truck Safety Petition: http://www.thepetitionsite.com/957/501/869/stand-up-for-truck-safety/

The signtures were posted on the Federal Register hereThe is a Comment on the Federal Motor Carrier Safety Administration (FMCSA) Proposed Rule: Financial Responsibility for Motor Carriers, Freight Forwarders and Brokers: AnnaLeah and Mary Karth – Comments

Articles on this upcoming action:

  1. FMCSA Yanks Minimum Insurance Rulemaking, Heavy Duty Trucking, Truckinginfo.com, David Cullen, June 2, 2017
  2. FMCSA officially nixes rule on increasing minimum liability insurance required for carriers, Overdrive|June 02, 2017
  3. FMCSA Drops Plans to Study Raising Insurance Minimums for Motor Carriers, Brokers  This article even mentions that our 11,366 petition signatures were included in the Public Comments considered by FMCSA .
Who bears responsibility for this decades-long delay?
  1. The trucking industry for acting to delay progress on this important issue.
  2. FMCSA for not using their authority to subpoena the insurance industry to provide the necessary information for the required cost/benefit analysis.
  3. The insurance industry for not providing the requested information.
  4. The Secretary of Transportation for not using his/her authority to sign in an increase — as was originally intended.
  5. Congress for not acting to make sure that this issue is properly addressed.
  6. The President for not signing a Vision Zero Executive Order to ensure that safety rules are not delayed or diluted by cost/benefit analysis that does not give appropriate value to the preservation of human life and health.

See the April 2014 FMCSA Report on this issue: https://www.fmcsa.dot.gov/sites/fmcsa.dot.gov/files/docs/Financial-Responsibility-Requirements-Report-Enclosure-FINAL-April%202014.pdf

Read more about this issue here:

Fortunately we plan on submitting a public comment to the upcoming FMCSA Motor Carrier Safety Advisory Committee public meeting on June 12 in D.C.

Despite our requests for Congress to hold a hearing to force the insurance industry to provide the necessary financial information, no one has been willing to do this. As Jerry says, it is a very one-sided situation: The FMCSA is apparently accepting the information that the rates will sky-rocket and trucking companies will go out of business  — although no one has been able to offer proof of this. At the same time, the FMCSA is apparently not accepting the proof that the current liability level is not adequate to cover the costs to society of these truck crashes.

Furthermore, this issue not only impacts the compensation for truck crash tragedies to the victims and the cost to society, but it also limits the ability of the market to ensure that trucking companies are held accountable for their safety practices.

 What will break through this roadblock?

Senators’ Concern About OSHA Change In Direction Points To Need For Vision Zero Rulemaking

According to a recent Fair Warning article, there has been a change in procedures at the OSHA which could result in diluted rulemaking and standards —  leading to more lax safety practices in the workplace:

In the four months since President Trump took office, the federal Occupational Safety and Health Administration has issued four news releases announcing penalties for job safety violations.

By the end of May last year, it had issued 199.

The recent reticence has spurred six U.S. senators, all Democrats, to ask what’s up at OSHA. In a letter to OSHA’s parent agency, the Department of Labor, the six lawmakers are demanding a review of the agency’s “decision to cease public notification of major findings.”

Under previous Democratic and Republican administration, OSHA has used announcements of major enforcement actions, and the threat of bad publicity, to combat health and safety hazards. . . U.S. Senators Ask: What’s Up at OSHA?, Fair Warning, Paul Feldman, May 30, 2017

Should this concern us? Will this negatively impact the health and safety of American workplaces?

The Democratic lawmakers say in their letter that the spotlight on violators during the Obama administration rankled some employers, who viewed it as unfair public shaming. “Lobbyists for trade groups and large employers have opposed these disclosures, claiming that the data will be ‘distorted’ or ‘misconstrued,’” the senators wrote.

But, they added, “public communication regarding these findings is important for OSHA to fulfill its mission.’

Labor advocates say highlighting abuses is a crucial tool to deter bad employers because OSHA is so thinly staffed that, according to union researchers, it would take the agency 145 years working at its normal pace to inspect every workplace under its jurisdiction just once. . .

Is this one more example, along with traffic safety issues, of the need for Vision Zero Rulemaking?

Vision Zero Petition Book

President Trump: Sign a Vision Zero Executive Order which will make protecting life & health the highest priority by empowering all federal agencies to apply Vision Zero principles to rulemaking.

Save Lives Not Dollars: Urge DOT to Adopt a Vision Zero Policy

Trump’s EO allows for regulations related to “health, safety, financial or national security matters”

I could be wrong, but if what I just read is true, then President Trump is leaving the way open for regulations which would make us safer on the road.

President Trump issued Friday an order to executive agencies directing them to freeze all new regulations pending further review by Trump and his team. It’s unclear, however, whether this rule will affect any coming trucking regulations, especially since the administration’s memo, circulated by Trump’s Chief of Staff Reince Priebus, allows for regulations related to “health, safety, financial or national security matters” to continue.  http://www.overdriveonline.com/unclear-how-trumps-freeze-on-regs-obamacare-relaxer-will-impact-trucking/

Now all we need is for public health and safety to be given the consideration it needs by means of Vision Zero rulemaking.

Equal Justice For All, Legal Reader, artist Neal Angeles
Equal Justice For All, Legal Reader, artist Neal Angeles

Ongoing Tired Trucker (HOS) Controversy on The Hill Proves Need for Vision Zero Rulemaking

It didn’t take me long — after our family’s tragic truck crash — to grasp the futility of lobbying on The Hill as a truck safety advocate in an attempt to push for safer roads through safer regulations.

And then I learned a secret (shh). . . DOT’s safety agencies have their hands tied by an Executive Order (12866) which requires stringent cost/benefit analysis during rulemaking that too often undervalues human life & health and effectually allows industry lobbyists to sabotage and snuff out regulations which could make our roads more safe to travel on.

In case you hadn’t noticed, the DOT agencies which were meant to be our protectors — the FMCSA (Federal Motor Carrier SAFETY Administration) & NHTSA (National Highway Traffic SAFETY Administration) — have not proven to be consistently effective voices for our SAFETY.

That revelation — in combination with my own experience in wasted lobbying hours and my realization that others had tried unsuccessfully for decades before me to push for truck safety rules which might have saved my daughters — spurred me on to launch the Vision Zero Petition in 2015. It garnered over 20,000 signatures online in support of our requests for:

  1. A National Vision Zero Goal.
  2. A White House Vision Zero Task Force.
  3. A Vision Zero Executive Order to authorize Vision Zero Rulemaking (which would favor saving LIVES over saving PROFIT).
  4. An Office of National Traffic Safety Ombudsman (an independent but influential and vigilant voice for vulnerable victims of vehicle violence who could facilitate these goals).
  5. A nationwide network of Vision Zero/Traffic Safety community action/advocacy groups.

Although we took this Petition to DC in March 2016, we have not yet received a response to our requests. And, as I expected, the month of December 2016 has presented us with one more example of the need for this essential strategy: a resurrection of the Tired Trucker hours of service tug-of-war.

All of this, and more — most especially my daughters’ truck crash deaths which might have been prevented had all of this nonsense been addressed appropriately — has led to my efforts to work with others to organize a successful Truck Underride Roundtable and an upcoming Tired Trucker Roundtable.

And I really do keep hoping that a national traffic safety advocate will be appointed and Vision Zero Rulemaking will become a thing. . .

1a85et

Good read on the essential elements of Sweden’s Vision Zero strategy. US could learn & act.

If you think you know what Vision Zero is all about or if you’re not really sure what it is, check out this article whose author interviewed Matt-Ake Belin from Sweden:

What were the main barriers that had to be overcome in initially adopting Sweden’s Vision Zero strategy?

I would say that the main problems that we had in the beginning were not really political, they were more on the expert side. The largest resistance we got to the idea about Vision Zero was from those political economists that have built their whole career on cost-benefit analysis. For them it is very difficult to buy into “zero.” Because in their economic models, you have costs and benefits, and although they might not say it explicitly, the idea is that there is an optimum number of fatalities. A price that you have to pay for transport.

The problem is the whole transport sector is quite influenced by the whole utilitarianist mindset. Now we’re bringing in the idea that it’s not acceptable to be killed or seriously injured when you’re transporting. It’s more a civil-rights thing that you bring into the policy.

The other group that had trouble with Vision Zero was our friends, our expert friends. Because most of the people in the safety community had invested in the idea that safety work is about changing human behavior. Vision Zero says instead that people make mistakes, they have a certain tolerance for external violence, let’s create a system for the humans instead of trying to adjust the humans to the system.

Read more hereThe Swedish Approach to Road Safety: ‘The Accident Is Not the Major Problem’

And there you have it, folks. . . some of the stumbling blocks in our country’s approach to traffic/road/highway safety. And that is why I am adamant in my push for a major change in our rulemaking process, in fact in our entire approach to road safety. It is why I keep bugging the powers-that-be to do something about it. . . because they can.

And if they don’t heed my pleas, and people continue to die from vehicle violence which might have been prevented had they acted upon my petitions, then who should will hold responsible?

Lame Duck Actions Could Reverse the Tide of Highway Carnage

september-2013-069

Please, Secretary Foxx, act now before it is too late for you to pave the way for genuine Vision Zero Rulemaking. Set my case before President Obama.

Pres. Obama, sign this Exec. Order–while you still can–to protect people from violent vehicle deaths!

 

Pres. Obama, sign this Exec. Order–while you still can–to protect people from violent vehicle deaths!

Dear President Obama,

A Canadian mom came to visit me at my home in North Carolina last weekend. We connected quickly on many levels because we have both lost daughters in truck underride tragedies. Tragedies which could have been prevented if Vision Zero Rulemaking had been in place before their deaths to pave the way for life-saving measures to be mandated. . .

You cannot bring Jessica, Mary, and AnnaLeah back to us. But you can prevent other families from suffering similar heart-wrenching, horrific, and unnecessary grief. You can do this by taking action on the Vision Zero strategy which we spelled out for you at great length. In fact, over 20,000 people have joined with us to ask for Vision Zero action:

  1. Set a National Vision Zero Goal.
  2. Establish a White House Vision Zero Task Force.
  3. Sign a Vision Zero Executive Order to authorize Vision Zero Rulemaking by DOT. Unless this is done, people will continue to die needlessly because technologically-feasible life-saving measures will be blocked or delayed because the current rulemaking process will deem them unworthy (too costly) to save!
  4. Establish a National Office of Traffic Safety Ombudsman to oversee this strategy as an independent and influential voice for vulnerable victims of vehicle violence.

My meeting with Jeannette Holman-Price on Saturday reminded me of what I have already painfully learned about one specific but simple example of the impact of the GM Nod where no one takes responsibility for doing anything about this tragic loss of life.

  1. Truck underride is the deadly result of a geometric mis-match between a smaller passenger vehicle and a larger commercial vehicle (truck).
  2. There are effective solutions to prevent this problem but the industry does not use them because the government does not require them and the government will not require them until there are proven products available to the industry to use but the industry does not put the money out to research, design, and manufacture these products [which engineers have shown will work] [and why should they if they are not legally required to do so?] and the people like Jeannette & I (who have lost loved ones) and Aaron Kiefer and Perry Ponder and Bruce Enz (engineers who have invented solutions) do not readily have the money to get these life-saving products on the market.
  3. As one person said in a conference call which Jeannette and I recently joined in to discuss underride solutions, many of the Single Unit Trucks — which are currently exempt from federal underride standards — actually have a “guard-looking thing” hanging down from the back of their truck. So it is perfectly logical to assume that they could easily have a genuine, more-effective underride guard installed instead. And why don’t they? Because they are not required to! As another person on that phone call said, “It is lazy and criminal!”

President Obama, I do not want more heartfelt condolences from you. I want you to do what no one else can: Sign the Vision Zero Executive Order and appoint a Traffic Safety Ombudsman!

Be my hero.

Respectfully and boldly and desperately,

Marianne Karth

p.s. Unfortunately, unless you act, the needless sabotage and/or delay of countless life-saving measures will continue to go on and on — as it has for so many years — and more innocent blood will be spilled on our roads. Who will be held accountable? And who will pay the price?

do-it-president-obama

 

With Road to Zero, DOT commits $3 million; compare that to $9.6 million Value of a Statistical Life

I should be jumping up and down for joy about the recent launch of the Road to Zero Coalition by the US DOT and the National Safety Council. So it doesn’t feel great to be one of those voices who are saying negative things about this great project.

I do look forward to watching how they coordinate the efforts of many organizations around this country who work to save lives. But I have some concerns about the process:

  1. Will they make any significant change in the strategies used to address the disturbing public health problem of 35,200+ Deaths by Vehicle Violence each year?
  2. Will they harness the energy and motivation of survivors/families of victims of vehicle violence?
  3. Will they mobilize citizens to be a significant part of the solution?
  4. Will they have a powerful voice to speak on behalf of the vulnerable victims who cannot speak for themselves?
  5. Will they take steps to address the imbalance of priority in rulemaking of profit over people?

Let’s just consider the last question. One thing which I have learned, after my life was catastrophically up-ended by my two youngest daughters’ deaths from a truck underride crash, is that there appears to be a hesitancy (to put it mildly) to put a meaningful monetary value on the cost of saving human lives.

To begin with, there is the difficulty of getting safety measures to pass the stringent test of the cost/benefit analysis required in federal rulemaking which, in my mind, inordinately favors the cost to industry vs benefit of preventing deaths and serious injuries. This is also reflected in the opposition to increasing the minimum liability insurance for truckers which was set at $750,000 in 1980 and has not been raised since then — despite the current Value of a Statistical Life (VSL) set by DOT at $9.6 million for 2016.

Value of a Statistical Life-guidance-2016

If you have read much of what I write, you might realize that I am in favor of reshaping the rulemaking process to ensure that it properly values human life. But aside from that, let’s just use that $9.6 million and do a little math.

The US DOT announced with the launch of the Road to Zero Coalition that it was committing $1 million/year for three years for grants to non-profit organizations that propose initiatives to save lives. Sounds great, right? But then I took out pen and paper (to get the hands-on sense of the calculation) and worked out the Value of the Statistical Lives of the 35,200 people who died on our roads in 2015 — keeping in mind that it was probably undercounted and does not include the cost of serious injuries.

$9.6 million X 35,200 = $337, 920,000,000 or almost $338 billion in one year alone

Then I decided to take it one step further and calculate the cost of the traffic fatalities over the next 30 years of the Road to Zero strategy to save lives — without taking into account the probable increase in the VSL.

$337,920,000,000  X 30 = $10,137,600,000,000 or over $10 trillion (which includes the cost to society)

And how much is DOT dedicating to this project to try and put a dent on the estimated 1,056,000 Deaths by Vehicle Violence? $3 million (of taxpayer money) — not even 1/3  the supposed value of a person’s life. Why, my two daughters alone were supposedly worth $18.2 million combined in 2013. Two immeasurably precious ones gone far too soon.

$3,000,000 vs $10,137,600,000,000

Now I had trouble even typing those numbers in accurately, so it is entirely possible that I made a mathematical error (didn’t use a calculator). So, please, do the math yourself. And then let me know if you think that we, as a country, are making a truly meaningful effort to do something new to stem the tide of bloodshed.

IMG_4464

 

CBA Victim Cost Benefit Analysis Victim

Car Safety WarsPetition