Tag Archives: Vision Zero

Truck Underride 101: Part III. Cost Benefit Analysis, Underride Rulemaking, and Vision Zero

Becoming educated about underride was not a direction I had planned on going with my life and time. But I have gained a great deal of knowledge related to the fact that AnnaLeah’s and Mary’s deaths (and Roya’s, too, along with countless other individual loved ones) might have been prevented had adequate underride protection been on the truck, into which our sturdy Crown Vic crashed — along with the fact that many more countless, unknown individuals will die unless this country takes decisive action.

This information, along with my unresolved grief due to the frustration of knowing that years have gone by without effective protection, fuels my efforts to work collaboratively to bring about widespread and significant change. It is now my aim to equip everyone with the same information — without the accompanying unwanted grief.

The reason we are devoting our lives to pounding on this door and asking for change is that our daughters may have lost their lives due to the lack of a Vision Zero policy. A decision which concluded that recommended changes would not be cost effective—in other words, that it would supposedly cost more to implement safety measures than the lives saved would be worth—may have led to lax underride guard standards.

If the best possible protection had been pursued when the regulations were last updated (1996), the trucks on the road today (including the one on the road May 4, 2013) might be much safer to be driving around. Mary and AnnaLeah might even still be around.

So, here is Part III of Truck Underride 101.

III. Cost Benefit Analysis, Underride Rulemaking, and Vision Zero

  1. 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/

  2. 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

  3. Underride Statistics 

  4. 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?

  5. 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?

  6. 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 rationale: Cost/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 Simms, President

Truck Underride 101: Discussion Topics

I. When Will We Tackle Truck Underride? Truck Underride 101: I. When Will We Tackle Truck Underride?

II. Why Comprehensive Underride Protection? Truck Underride 101: II. Why Comprehensive Underride Protection?

III. Cost Benefit Analysis, Underride Rulemaking, and Vision Zero

IV. Win/Win

V. Bipartisan Discussion of Legislative Strategy

“Michael Bloomberg: Automakers, developing nations must commit to auto safety”

Michael Bloomberg calls on automakers to do their part to reduce crash deaths globally:

If car crashes were an infectious disease, like malaria or polio, governments, international aid organizations and foundations would pour money and energy into stopping it — as is only right.  If that kind of determination is brought to bear on road crashes, we can save millions of lives and prevent untold amounts of heartache and grief. 

Michael Bloomberg: Automakers, developing nations must commit to auto safety, June 4, 2017, Detroit Free Press

“Blind Spots in Police Reports Hamper Efforts to Curb Deadly Crashes, Study Says”

After our truck crash on May 4, 2013, we waited for months to receive the crash investigation report (SCRTE) from the state highway patrol. It was detailed but left out a lot of important information.

For example, there was no mention of underride in the report (or on the police crash form). Also, we were not able to find out any verification about the truck driver’s hours of service prior to the crash — except for his verbal report on when he had started out that day on his trip.

It is likely that this paucity of information has contributed to decades of delay in effectively solving the issues of truck underride and driver fatigue — among others.

Inadequate crash information is, in fact, the norm. What might we be able to discover and change were this situation to improve? The National Safety Council has raised this question:

The scope of deadly hazards such as texting and drug use by drivers may be underestimated and not adequately addressed because police aren’t collecting enough information at crash scenes, according to a new report.

The report, released today by the National Safety Council, also found that no state systematically records whether crashes involve vehicles with self-driving features, such as collision-avoidance systems.

The group said more attention must be focused on the problem with a shift from an “accident-report mentality” to crash investigation. It is important to know not just what happened, but why it happened, said Deborah Hersman, chief executive of the safety council, a nonprofit group.

“Better data enables us to make better decisions when it comes to our priorities, our investment and our technology,” she told FairWarning. . .

Safety researchers already conduct crash tests and computer simulations trying to determine how well a vehicle will protect its occupants. But detailed information from a crash is important to understand what happens in the real world, said Charles Farmer, the vice president for research at the Insurance Institute for Highway Safety, a research group funded by the insurance industry.

Researchers like Farmer have yearned for that information for at least three decades.

Since 1998, the National Highway Traffic Safety Administration, the federal agency that regulates traffic safety, has been working with the Governors Highway Safety Association trying to get police to collect more detailed and standardized information. Their recommended Model Minimum Uniform Crash Criteria has 110 items.

Every state uses that form “to some degree and most states use most of the data elements,” said Barbara Harsha, former GHSA executive director.

Despite NHTSA and GHSA working on the issue for almost two decades, the safety council report concluded that “no state is adequately capturing the crash data we need to understand why crashes are rising, and form an effective path forward.”

Fair Warning, Blind Spots in Police Reports Hamper Efforts to Curb Deadly Crashes, Study Says By Christopher Jensen on April 25, 2017

Are we truly a country of united states? Can we work together more effectively to solve this issue or do we have such a high need to act independently to take care of it ourselves? Lives are at stake.

National Safety Council important report: Undercounted Is Underinvested; HOW INCOMPLETE CRASH REPORTS IMPACT EFFORTS TO SAVE LIVES

Why on earth don’t we establish National Traffic Safety Standards & require them to be adopted by States?

 

Road Safety Audit (RSA); One way to make our roads safer

It is heartening to know that there are many people working to make the roads safer. This video gives a glimpse of how tribal leaders are trying to protect their people:

What can you do to make the roads safer?

 

Side Underride Problem & Solutions Featured on The Today Show

Ronan Farrow investigated the side underride problem and here is his report on The Today Show, February 7, 2017:

Side Guards: New push to make safety devices on trucks mandatory

NBCNews story on side guards (2/7/17): Side Underride Crashes Kill 200 People a Year. Will Congress Act?

The federal government does not require side guards on large trucks. Trailer manufacturers do not install them on the trailers they produce. Here are 5 ways you can help to change that:

  1. Sign our Side Guard Petition here to let our government & trucking industry leaders know that you want them to act NOW to SAVE LIVES by putting side guards on large trucks.
  2. Write to the 8 major trailer manufacturers. Tell them that you want them to put side guards on the trailers which they make and sell to trucking companies. You can find their contact information here.
  3. Support side guard research projects, which will help get affordable and effective side guards on the market. Donate here.
  4. Contact your legislators here.
  5. Submit a Public Comment to DOT/NHTSA here. After you get to this site, click on the Comment Now button.

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Aaron Kiefer’s underride protection devices: ENHANCING TRUCK SAFETY ​ SAVING LIVES

What Will It Take To Convince US That Side Underride KILLS But Side Guards Save Lives?

February 13, 2017 Update: I just received a notification of a new posting to the Federal Register of a Public Comment from someone asking DOT/NHTSA to mandate side guards! I am assuming that someone responded to my request for people to do so to help bring about change. 🙂 See it here: https://www.regulations.gov/document?D=NHTSA-2015-0118-0049 Actually, a second person also submitted a comment.

You can do it, too! SUBMIT a Public Comment to DOT/NHTSA here: https://www.regulations.gov/docket?D=NHTSA-2015-0118 After you get to this site, click on the COMMENT NOW button.

Side Guard Petition Signatures & Comments: end-deadly-side-underride-crashes-mandate-side-guards-on-large-trucks_022417

 

Unimaginable Grief of Preventable Crash Deaths: advocates tackling a public health problem head on.

Late last year, Neal Pollack interviewed me. He asked about our crash story and our family’s advocacy efforts. Then he proceeded to interview other traffic safety advocates as well. This is what he recently wrote:

The Unimaginable Grief of Distracted Driving Deaths How road safety advocates are tackling a public health problem head on.  BY NEAL POLLACK JANUARY 19, 2017

IMG_4519WarsawINFilmPhotographer_MIMemoria_Film_063 cropped

 

Dwight Eisenhower: Inspirational Crusader for Traffic Safety; Would that he could speak to us today.

I was suitably impressed as I sat on my Amtrak train en route to Washington, D.C., last week and read the words which President Dwight Eisenhower wrote and spoke about traffic safety:

President Dwight D. Eisenhower and the Federal Role in Highway Safety Chapter 2: A Crusade for Safety

I knew that he was responsible for our improved interstate system, but I did not know that he was such a genuinely enthusiastic crusader for traffic safety. Here are a few excerpts among many:

Although President Eisenhower would not become fully engaged in a highway initiative until the Grand Plan speech in 1954, he acted on highway safety in July 1953 when he met in the Cabinet Room of the White House with 28 business leaders. He told the leaders that his goal was to save 17,000 lives and $1.25 billion a year by reducing accidents. According to an account in Transport Topics for August 3, 1953:

 

President Eisenhower told the group . . . he is tired of having three to four times as many persons killed a year on the highways as were killed in Korea. He said the history of efforts to save lives on the highway shows that when something is done on a coordinated basis the accident trend drops sharply.

The president said that something-a truce-had been done about saving lives in Korea and that there is good reason why something should be done about highway accidents. . .

On December 11, 1953, the President wrote to the Nation’s Governors to request their help:

Dear Governor:

The mounting toll of death and injury on our highways long ago reached a point of deep concern to all of us. It stands before America as a great challenge-humanitarian and economic-and must be met by urgent action.

I have examined the “Action Program for Highway Safety” which you and the other Governors have developed in cooperation with interested organizations and public officials having jurisdiction over highway safety. It is a sound and workable program, but effective citizen leadership is needed to help you put this great crusade into organized action on a scale far bigger than ever before.

Accordingly, I have called a Conference on Highway Safety for Washington next February seventeenth, eighteenth and nineteenth. The Conference will serve to focus more public attention on the problem and stimulate active leadership in every community. . .

After noting the privilege of addressing the [White House Conference on Highway Safety], he began:

The purpose of your meeting is one that is essentially local or community in character. But when any particular activity in the United States takes 38,000 American lives in one year, it becomes a national problem of the first importance. Consequently, this meeting was called, and you have accepted the invitation, in an understanding between us that it is not merely a local or community problem. It is a problem for all of us, from the highest echelon of Government to the lowest echelon: a problem for every citizen, no matter what his station or his duty.

I was struck by a statistic that seemed to me shocking. In the last 50 years, the automobile has killed more people in the United States than we have had fatalities in all our wars: on all the battlefields of all the wars of the United States since its founding 177 years ago
He acknowledged that this was a problem that “by its nature has no easy solution.” He did not intend to get into the technicalities of this “many-sided” problem. However, he felt that the key was public opinion. “In a democracy, public opinion is everything.” He explained:

If there were community groups established that could command the respect and the support of every single citizen of that city or that community, so that the traffic policeman, so that everyone else that has a responsibility in this regard, will know that public opinion is behind him. Because I have now arrived at the only point that I think it worthwhile to try to express to you, because in all the technicalities of this thing you know much more than I do.

If, he said, “we can mobilize a sufficient public opinion, this problem, like all of those to which free men fall heir can be solved.”

Hmmm. . . sounds sort of like a National Vision Zero Goal and a Nationwide Network of Community Traffic Safety Action Groups. . .

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On My Way to the Road to Zero Coalition Gathering in DC

I am encouraged by the opportunity to gather with like-minded individuals and organizations to collaborate in a quest for traveling a road toward fewer deaths and serious injuries from preventable vehicle violence.

Road to Zero New Partnership Aims to End Traffic Fatalities Within 30 Years

In memory of AnnaLeah & Mary.

Roads Safer

So, why aren’t we making a bigger dent in tragic crashes? America, we can do better than this!

Every time I hear about a new tragic crash or an ineffective attempt to strengthen safety rules and regulations, my own personal grief at the loss of my two youngest daughters, AnnaLeah (17) and Mary (13), due to a preventable truck underride crash on May 4, 2013, wells up anew.

Take this for example:

Or the latest attempt by some legislators to get the government to do something about the problem of deadly seatback collapse: Lawmakers demand “immediate action” on unsafe car seats.

Unfortunately, I know all too well from experience that raising questions and demanding action are mostly a wasted effort and won’t bring about needed change in time to save countless lives from joining the rank of those gone too soon — when perhaps such tragedies could have been avoided.

In my opinion, we aren’t going to see much progress in many areas of traffic safety until we as a country take vehicle violence seriously. That is why I continue to call for for a more effective and united strategy:

  1. Set a National Vision Zero Goal — make traffic safety a priority; Death by Motor Vehicle is one of the leading causes of preventable death.
  2. Establish a White House Vision Zero Task Force — it is a multifaceted problem, not just a transportation issue.
  3. Adopt Vision Zero Rulemaking.
  4. Appoint an independent National Traffic Safety Ombudsman to serve as a vigilant voice for vulnerable victims of vehicle violence.
  5. Mobilize citizens to be part of the solution through a nationwide network of Vision Zero/Traffic Safety community action groups.

Wake up, America! The Crash Death Clock is ticking away. . .

Mobilize citizens to be part of the solution in the Road to Zero crash deaths.

Roads Safer

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?

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