Advisory Committee on Underride Protection Reports to Congress & DOT Secretary

On June 28, 2024, the Advisory Committee on Underride Protection (ACUP) completed a scathing critique of the Department of Transportation. In a 410-page report, it documented a long history of agency reluctance to regulate the trucking industry’s safety practices, exposed allegations of misconduct by senior officials, and called for the reversal of recent rulemaking that the committee believed made “no substantial progress” to improving public safety.

In its Biennial Report, commissioned by Congress in the Infrastructure Investment and Jobs Act of 2021, the committee contended that fatalities from underride crashes, in which large commercial trucks cause severe injuries to occupants of passenger vehicles, as well as pedestrians, bicyclists or motorcyclists, are largely preventable. But the committee found that, for over 50 years, the Department has not required manufacturers to install guards under the open sides of trailers, due to pressure from the industry.

The report exposed allegations from a whistleblower of serious misconduct. According to a former project manager at the Department in the agency that enforces rules for the trucking industry, senior Department officials in the Trump administration suppressed taxpayer-funded research into the cost-effectiveness of regulations requiring side guards on trucks. Trucking company lobbyists reportedly were angered by the research findings and pressed the Department to alter them. Officials in the Biden administration commenced a rulemaking process that ignored the key findings of the suppressed research. The report called upon the Biden administration to reverse course and start the rulemaking process over again, this time by counting the benefits it previously ignored. Advocates have asked the Inspector General to investigate.

Many of the ACUP’s critiques and recommendations were adopted over the objections of the trucking industry, which lacked the ability to veto the committee’s actions. They published their dissent in a minority report authored by the CEO of Utility Trailer Manufacturing Corporation, which recently was found negligent for the fiery death of a 16 year-old boy in a side underride crash. Utility’s share of the punitive damages was $18.9 million.

The committee, which was composed of engineers, emergency medical professionals, victims, safety advocates, law enforcement, and the trucking industry, sent its Report via NHTSA to Congress and the Secretary of Transportation on July 2, 2024. 

Below are links to the complete ACUP Biennial Report, the Majority Report, a Minority Report, and Appendices, including the statements of concurrence or dissent from ACUP members:

Other useful information to help you dig deeper into the work of the Advisory Committee on Underride Protection:

DOT Victim & Survivor Advocate Act Introduced To Give Victims A Voice

On average, 42,075 people die on our roads every year, while 170,280 people are injured. Industry opposition. Regulatory capture. A lack of a sense of urgency or personal responsibility. These and other factors occur simultaneously — resulting in Too Little being done Too Late to prevent an unimaginable number of irreversible tragedies for those people and their loved ones.

It’s time to give vulnerable victims of vehicle violence a vigilant voice at the table. It’s time for a National Roadway Safety Advocate to serve the public’s best interests at the Department of Transportation. That’s why Senator Ben Ray Lujan (on May 9, 2024), and Congressman Steve Cohen (on May 10, 2024) introduced the DOT Victim & Survivor Advocate Act of 2024 — as a first step to provide safety advocates with a tangible means of bringing about meaningful change in a timely manner.

Find out more here:

You can help make this happen:

Hear Families Share Victim Stories — It’s time for a National Roadway Safety Advocate!

Senior Agency Officials Suppressed Side Guard Research — Impacting Regulatory Analysis

All road users are vulnerable to deadly collisions with large trucks. Truck underride guards can reduce the severity of injuries which occur when a passenger vehicle, pedestrian, bicyclist, or motorcyclist goes under a truck.

Advocate efforts to bring about federal underride regulations have been blocked for decades. Recent testimony from a whistleblower revealed that senior agency officials suppressed vital research — hiding the fact that side underride guards would be cost-effective. Key documents are provided here:

  • A slide presentation by Mr. Kwan to safety advocates and researchers on April 22, 2024, explaining the suppressed research — pdf and video;
  • Exhibit A — the Statement of Work for contract number SA9PAI. FMCSA contracted with the Volpe National Transportation Systems Center for these deliverables to fulfill the research project entitled, Truck Side Guards to Reduce Vulnerable Road User Fatalities
  • Exhibit BThe Suppressed ResearchTruck Side Guards and Skirts to Reduce Vulnerable Road User Fatalities: Final Report on Net Benefits and Recommendations, the final report received from the Volpe Center, meeting all the requirements of the Statement of Work. Among other things, this final report found that it was cost effective to require tractor-trailers and single-unit trucks to be equipped with lifesaving side impact guards. The cost-benefit analysis and most of the rest of this final report were suppressed from the published report by U.S. DOT; and 
  • Exhibit C — email communications obtained through the Freedom of Information Act which document that meetings and discussions concerning the Volpe Center report occurred among senior officials at DOT, NHTSA, and FMCSA in 2019 and 2020 without Mr. Kwan’s participation.

Sign this PETITION:

If this suppression of research goes unchecked, people will continue to be killed senselessly from preventable Death By Underride. Tell President Biden to take immediate action in order to undo the damage done by this misrepresentation of the costs and benefits of truck underride protection:

  1. Direct the Secretary of Transportation to withdraw the erroneous Side Impact Guard rulemaking and then do it right in a new one by counting all preventable deaths as a benefit to society;
  2. Appoint a Presidential Advisory Committee on Integrity of Underride Research to review and ensure the scientific integrity of all underride-related research and rulemaking; and
  3. Establish the Office of National Roadway Safety Advocate in the Office of the Secretary of Transportation proposed by members of Congress.
  4. Amend the July 2022 Rear Impact Guard Rule – bring it up to the TOUGHGUARD strength, as directed by Congress (Appropriations).

Can we expect the Department to adhere to its scientific integrity policy published in January 2024, or is it simply meaningless rhetoric?

Require that agency officials, including public affairs officers, shall neither ask nor direct nor
suggest that agency scientists and technology experts alter the presentation of their
scientific findings in a manner that may compromise the objectivity or accurate
representation of those findings.
Scientific Integrity Policy of the United States Department of Transportation, p.11

Can we count on them to mend the broken trust and act with a sense of urgency to fulfill their mission to reduce roadway deaths and injuries?

Media Coverage

How To Make Crashes With The Front Of A Truck More Survivable

Researchers, safety advocates, and underride victim survivors gathered on April 17 to discuss how to make crashes with the front of a truck more survivable. Experts from around the globe shared their expertise and answered questions:

Front Impact Guard Webinar – April 17

Video Coverage of Speaker Presentations:

Presenter Slides & Papers:

Hopefully, the information shared and learned during this discussion will be but the beginning of a collaborative global conversation leading to the reduction of preventable truck crash fatalities — one life at a time.

Posts on Front Underride Protection

Truck Impact Guards = Underride Protection!

Register for April 24 Meeting of Advisory Committee on Underride Protection

The National Highway Traffic Safety Administration (NHTSA) has announced that registration is open for the next meeting of the Advisory Committee on Underride Protection (ACUP):

  • April 24, 12:30 – 4:30 p.m. ET; Topics: Side Underride and Front Override

Register here to observe via Zoom.

April 24 will be the fifth public meeting of the committee, which was established to provide advice and recommendations to the Secretary of Transportation on safety regulations to reduce underride crashes and fatalities relating to underride crashes.

Basic Underride Information

This post provides basic underride information, as well as a running list of recent relevant posts.

  1. Petition: STOP Senseless Roadway Deaths: Give Victims a Voice
  2. Petition: Secretary Pete, It’s Past Time To End Death By Underride!
  3. Underride Crash Memorials These are posts in memory of a few of the thousands of underride victims. The tip of the iceberg of senseless, preventable deaths. I will slowly be adding more.
  4. Important Videos: Basics of UnderrideFront Underride Protection crash testSide Guard crash testRear Guard crash testRear Retrofit crash test; Safetyskirt SIG.R Crash Test 2023, 35 mph T-Bone Behind Axles; SafetySkirt Crash Testing Videos; Unguarded Crash Test 2023, 37.5 mph, 45 Degree Angle Crash
  5. STOP Underrides! YouTube Channel Truck Underride Video Playlist
  6. Register for April 24 Meeting of Advisory Committee on Underride Protection
  7. Advisory Committee on Underride Protection, February 8, 2024 Meeting Record
  8. Front Impact Guard Webinar – April 17
  9. Truck Impact Guards = Underride Protection
  10. What is Front Underride Protection? (Find out on April 17)
  11. Lateral Protection Device+ Performance Standard = Prevention of Side Underride Tragedies
  12. Upcoming Underride Advisory Committee Meeting Schedule
  13. Underride Made #1 on ‘FRONTLINE Dispatch’ Podcast Episodes of 2023
  14. Unsung Underride Prevention Heroes
  15. My Reactions to Comments on Inside Edition Underride Investigative Report
  16. Weak Rear Underride Guards Are Still Killing People
  17. Video of Speakers at Underride Victim Vigil
  18. A Record of Those Remembered in the Underride Victim Vigil
  19. Media Coverage of DC Underride Victim Vigil & Press Conference
  20. A day in the life of an underride crash test crew; A Photographer’s Perspective
  21. Underride Victim Vigil & Press Conference on DOT Steps in DC
  22. Simply Mary. . . August 6, 1999 – May 8, 2013
  23. Video from STOP Underrides Crash Test Event
  24. Public Comments on the Side Guard ANPRM (Advance Notice of Proposed Rulemaking)
  25. Still Time to Submit a Public Comment on Side Guard Rule (July 20)
  26. STOP Senseless Roadway Deaths: Give Victims a Voice
  27. So, what did you think of the PBS/Frontline Underride Documentary?
  28. PBS/Frontline Underride Documentary & Petition to Secretary Pete
  29. Commemorative Bell for Roadway Safety Victims
  30. Taking On a Safety Issue: Hazardous Railroad Crossings
  31. Upcoming PBS/Frontline Documentary: “America’s Dangerous Trucks”
  32. Global Underride Discussion
  33. 10 years after trucking crash killed 2 girls, mother sees hope for change
  34. May 4, 2013 seems like just yesterday; has anything changed?
  35. What Do Baseball & Truck Underride Have In Common?
  36. FARS Coding of a Sample of Rear Underride Crashes
  37. LPD+ Saves Lives; But what’s an LPD+?
  38. STOP Underrides Crash Test Tour
  39. “Economism Is Out Of Control” In Life & Death Regulatory Analysis
  40. Remembering AnnaLeah & Mary
  41. Someday, Seeing Side Guards & Strong Rear Underride Guards Will No Longer Surprise Me
  42. Successful Side Guard Crash Test in Raleigh
  43. NHTSA Failing To Educate Stakeholders On Underride
  44. Side Guard Cost Benefit Analysis Presentation to TEAM Underride
  45. Update on Underride Protection Progress
  46. Side Guard Cost Benefit Analysis
  47. Launching a Campaign To Flood NHTSA With Underride Complaint Reports
  48. “A Safety Rule, A Fatal Flaw”; Industry Discussed Underride Rules in 2000
  49. Another Side Guard On The Road
  50. Too Many Lives Forever Changed
  51. Cohen, Gillibrand Call on DOT to Act Expeditiously & Implement Provisions from Their Stop Underrides Act Included in the Bipartisan Infrastructure Package
  52. Five Years Have Passed Since the Historic IIHS Side Guard Crash Test
  53. Back of the Envelope Math: How many side underride deaths since March 19, 1969?
  54. 53 Years or 19,358 days
  55. When it comes to underride, where do you stand?
  56. DOT Announced A National Roadway Safety Strategy; Now It’s Time To Talk About What That Means
  57. Timeline Of Research & Collaborative Efforts To Create A Consensus Side Guard Standard
  58. Can the Insurance Industry Help End the Unfair Fight of Truck Underride Tragedies?
  59. Why are we working so hard to get weak rear underride guards replaced?
  60. @SecretaryPete, Will you fix flawed underride analysis or let deaths continue?
  61. Families glad new infrastructure law will address underride crashes, WRTV, November 18, 2021
  62. First responders train to save lives during underride crashes, WRTV, November 23, 2021
  63. Raleigh Mom: Infrastructure Bill Will Prevent Crashes Like the One That Killed My Girls , Raleigh News&Observer, November 18, 2021
  64. Rear impact guard now part of annual truck inspection, CCJ, November 15, 2021
  65. FMCSA Issues Final Rule: Rear Underride Guards To Be Part Of Annual Inspections, November 20, 2021
  66. Thoughts on Landmark Underride Legislation
  67. AAJ Supports Trailer Safety Recall Petition: “NHTSA is well within its authority to issue a recall”
  68. Unguarded & Unsafe: Death By Underride by Eric Hein, July 15, 2021
  69. STOP Underrides Petition can be found here.
  70. A Timeline of Underride Safety
  71. Certified Letters Alert 200 Carriers of Underride Dangers & Solutions
  72. History of Underride Research & Reports: 1896-2019
  73. Petition for NHTSA To Recall Semitrailers Due To Lack Of Side Underride Guards
  74. Will DOT Respond to Petition for Underride Rulemaking on Single Unit Trucks?
  75. Side Guard Costs Likely To Decrease With Higher Deployment Volumes
  76. Protecting Passenger Vehicles from Side Underride with Heavy Trucks More research on side underride has just been published by SAE International following a presentation by Garrett Mattos of the Friedman Research Center at a SAE Conference. Hopefully, the Department of Transportation now has enough research to make good on their March 19, 1969 intention to add underride protection to the sides of large vehicles.
  77. IIHS Research Provides Foundation for Traffic Safety Legislation – Including Underride
  78. What will it take to get UNDERRIDE on DOT Regulatory Agenda? We’ve been waiting 52+ years for DOT to move forward with side guards on large trucks — not to mention improving rear guard regulations and adding front underride protection. After numerous petitions, comprehensive underride rulemaking still has not made it the onto the DOT Unified Regulatory Agenda.
  79. Collaborative Discussion of Side Guard Challenges on Specialty Trucks I was very pleased with the collaborative discussion which took place via Zoom on Monday, March 29, 2021, regarding the challenges of adding side guard safety technology to specialty trucks. Participants included primarily engineers and small companies who have been working on researching, designing, and/or marketing solutions to the underride problem. The meeting was also quietly observed by families of underride victims and administrative officials from the Federal Motor Carrier Safety Administration (FMCSA).
  80. The March Madness of Competing Traffic Safety Interests What is it like to compete for the attention of government leaders in order to get traction on the traffic safety problem which took your loved one’s life? Envision a press conference on a hot topic where a cacophony of reporters can be heard shouting out — vying for the opportunity to have their question be the one that gets answered.
  81. Time for a National Traffic Safety Ombudsman Almost five years ago, after delivering a Vision Zero Petition to leaders in Washington, D.C., I realized that we need something more than a White House Vision Zero Task Force and a National Vision Zero Goal. We need a National Traffic Safety Ombudsman to be at the helm of a nationwide network of community traffic safety advocates. Someone who will have a place at the federal table — with the authority to take ongoing action on behalf of vulnerable victims of vehicle violence.
  82. Will NHTSA & NTSB Address Side Underride Factor In Latest Tesla Crash Investigation? I have again requested that NHTSA and NTSB address the side underride factor in their investigation of yet another Tesla side underride crash.
  83. Truck Underride Victims & Families Host News Conference for STOP Underrides Act Introduction On Monday, March 8, 2021, truck crash victims’ families hosted a news conference to discuss their stories and the recent introduction of the STOP Underrides Act of 2021 — on March 4, 2021 in the Senate and March 8 in the House.
  84. Engineers, Trucking Industry, & Victim Advocates Collaborate at Side Guard Task Force On a Friday afternoon — February 26, 2021 — over 50 people met via Zoom to discuss comprehensive underride protection. The purpose of the meeting was to report on progress which has been made by several subcommittees since an earlier meeting in 2020 — including Industry Engagement, Research, and Engineering Subcommittees.
  85. Should we be concerned about side guards getting hung up on railroad tracks? I keep hearing members of the trucking industry bring up the possibility of side guards on trailers getting hung-up on railroad tracks. They point to it as a reason to not require side guards on all new trucks. Is that a valid concern? And where is their documentation?
  86. Transport Companies Provide Feedback on Side Guard Operational Issues We know that the trucking industry has expressed concern about potential operational issues which could occur when side guards are installed on large trucks. In order to address those concerns, we asked several trucking companies to give us feedback about their experience after installing side guards on their tractor-trailers.
  87. Consensus Side Guard Standard On April 17, 2020, over 40 people participated in a virtual meeting of a volunteer Underride Protection Committee’s “Side Guard Task Force.” This included two engineers from trailer manufacturers. As a follow-up, several subcommittees began to hold virtual meetings, including an Underride Engineering Subcommittee.
  88. Utility Trailers Encourages Retrofit of Rear Impact Guards To Prevent Underride Last evening, I received some amazing news! Utility Trailer Manufacturing has announced that their improved Rear Impact Guard (RIG) will be offered at a discount.
  89. FMCSA Proposed Rule For Inspection of Rear Underride Guards A red letter day: The Federal Motor Carrier Safety Administration (FMCSA) at long last has proposed a rule to add rear underride guards to Appendix G. What does that mean? It means that rear underride guards will be required to be in good condition in order to pass an annual vehicle inspection. Once the rule is actually issued.
  90. “Chattanoga crash that killed 5 underscores bill to add protective barriers to semi trucks”
  91. Retrofit Solutions for Rear Impact Guards to Prevent Deadly Underride It is to their credit that nine U.S. trailer manufacturers have improved their rear underride guard design to meet the IIHS TOUGHGuard standard and seven of them are putting it on all new trailers as Standard. What that means is that they have surpassed the current federal standard and have been crash tested to show that they are more likely to prevent underride and catastrophic Passenger Compartment Intrusion (PCI) — thereby more likely to save lives when passenger vehicles rear end tractor-trailers.
  92. Save Lives by Lighting up Tractor-Trailers & Tanker Trucks Truck drivers can play an important role in making sure that the trailers which they haul are as visible as possible to other drivers on the road — especially at nighttime. On October 15, 2018, Leslie and Sophie Rosenberg lost their lives when they collided with the side of a tanker late at night.
  93. Truck Driver Mistakes Don’t Excuse Industry & Government Negligence To Solve Underride Problem Thanksgiving Eve, another apparent underride victim lost her life: Though the truck driver may have made a mistake, not all the blame rests with him for a crash which might have had a different outcome with effective underride protection. Carriers, trailer manufacturers, DOT, & Congress can make these kinds of truck crashes more survivable.
  94. A fully-guarded trailer hits the road – ready to STOP underride! Engineering ingenuity and a lot of hard work went into the research, development, and installation of this fully-guarded trailer system. This week, a small carrier in North Carolina became part of our pilot program. We are thankful that they have agreed to provide us feedback on this #SaferTruck as they drive it on the road to carry out their transport business.
  95. On August 19, we hosted another Underride Staff Briefing — this time via Zoom. We are providing Congressional Offices with the PowerPoint pdf from that presentation, including comments from engineers with expertise in underride as well as underride families: Underride Briefing PowerPoint pdf (inc. links to resources & video)
  96. Crash Tests of Rear Underride Guard Reinforcement Attachments, 2016 & 2020
  97. Media Reports & Video Footage Unveil Highlights of the Successful D.C. Underride Crash Test Event Read more here.
  98. Comparison Chart of Underride Provisions in Various Bills
  99. A quick look at some of the more recent efforts to STOP underride tragedies: Update on Underride News
  100. SOCIAL MEDIA: #STOPunderrides Tweets & Facebook Pages: STOP Underrides Act of 2019 and Save Lives/Stop Underrides., AnnaLeah&MaryforTruckSafety , stopunderrides.org
  101. Underride Crash Memorials These are posts in memory of a few of the thousands of underride victims. The tip of the iceberg of senseless, preventable deaths. I will slowly be adding more.

RAMCUP. Roya, AnnaLeah & Mary Comprehensive Underride Protection. They paid the price:

Underride Crash Memorials

Because the bottom of a truck is higher than the bumper of passenger vehicles, when there is a collision the smaller vehicle easily slides under the truck and the first point of impact is the windshield — resulting in underride and passenger compartment intrusion (PCI). Seatbelts, airbags, and car crumple zones do not function as intended in underride crashes — front, side, and rear — leaving passenger vehicle occupants vulnerable to life-threatening injuries.

This geometric mismatch has been misunderstood for decades. Reports on truck crashes generally focus on the cause of the crash and not what caused the deaths. So underride is undercounted. I know this from firsthand experience having been in a truck crash (but not in the part of the car which went under the truck) and lost two daughters because of underride (one of whom was not reported as such in DOT data).

In order to raise awareness and preserve the memories of underride victims — precious ones gone too soon — I have been writing memorial posts on what appear to me to be underride crashes. I am not a crash reconstructionist, and I do not have all the facts on these crashes; but underride should be investigated as a potential factor in truck crash injuries and deaths.

This is not an exhaustive list — merely the tip of the iceberg. But I hope that it serves to demonstrate the ongoing nature of a preventable public safety problem.

You can find these Underride Crash Memorial posts here.

Basic Underride Information

Certified Letters Alert 200 Carriers of Underride Dangers & Solutions

Advisory Committee on Underride Protection, April 24, 2024 Meeting Record

The NHTSA Advisory Committee on Underride Protection held its fifth meeting on April 24, 2024, via Zoom. The main agenda items were side and front underride. Presentations and discussions from the meeting can be viewed by using the YouTube video links below.

ACUP April 24, 2024, Meeting Segment Video Links
NHTSA ACUP Meeting – Welcome & Call to Order, Advisory Committee on Underride Protection (ACUP)
NHTSA ACUP Meeting – Side Underride Data and Analyses, Eric Hein of the Institute for Safer Trucking
NHTSA ACUP Meeting – Missed Opportunities to Prevent Side Underride Fatalities, with Marianne Karth
 NHTSA ACUP Meeting – Front Underride, with Marianne Karth of AnnaLeah & Mary for Truck Safety
 NHTSA ACUP Meeting – Concrete Barriers Then and Now, with Doug Smith of the Ralph Smith Company
 NHTSA ACUP Meeting – Front Override, Keith Friedman of the Friedman Research Corporation
NHTSA ACUP Meeting – Side Underride Guards and Intermodal Chassis, with Dennis Lombardi of the IICL
NHTSA ACUP Meeting – Motions and Discussion, the Advisory Committee on Underride Protection (ACUP)
Full YouTube Playlist of Meeting Videos
Advisory Committee on Underride Protection, April 24 Meeting Video Playlist POST

Advisory Committee on Underride Protection, April 24 Meeting Video Playlist

The NHTSA Advisory Committee on Underride Protection (ACUP) held its fifth meeting on April 24, 2024, via Zoom. The main agenda items were side and front underride. Presentations and discussions from the meeting can be viewed by using the YouTube video playlist link here.

The next (and last currently scheduled) ACUP meeting will be held via Zoom on May 22, 2024. The ACUP’s two-year charter is due to expire by the end of June.

Front Impact Guard Webinar – April 17

What is Front Underride or Override Protection?

Find out by joining this webinar

On April 17, 2024 via Zoom, 8:00 a.m. – 10:00 a.m. (Eastern)

AGENDA

  1. Welcome
  2. Current RegulationIain Knight, Director & Principal Engineer at Apollo Vehicle Safety, UK
  3. Original Equipment Manufacturer (OEM) ViewReimert Sjoblom,  Expert Engineer Passive Safety with the Scania Group
  4. Crash Data & Future NeedsRikard Fredriksson, Senior Advisor at the Swedish Transport Administration, Professor at University of Chalmers, Euro NCAP Board
  5. New Countermeasures & Test MethodsRob Thomson, Professor of Vehicle Safety at the Chalmers University of Technology (Sweden)
  6. Wrap up with Opportunity for Q&A and Discussion of What This Means for US

If you’d like to know more about front underride protection, join a Zoom presentation/discussion on April 17, 8:00 – 10:00 a.m. (EST). I know it’s going to be early, but we’ll be hearing from FUP experts located in the UK and Sweden. To receive a Zoom link, send your request to: marianne@annaleahmary.com.

What is Front Underride Protection? (Find out on April 17)

Truck Impact Guards = Underride Protection

Advisory Committee on Underride Protection, February 8, 2024 Meeting Record

The NHTSA Advisory Committee on Underride Protection held its third meeting on February 8, 2024, via Zoom. The main agenda item was rear underride. Presentations and discussions from the meeting can be viewed by using the YouTube video links below.

Meeting Segment
ACUP Welcome & Call to Order
Rulemaking Process – Lina Vallivullah (NHTSA)
A History of Trailer Rear Impact Guards from Utility’s Perspective; Jeff Bennett (Utility Trailers)
Truck Rear Underride; Matt Brumbelow (IIHS) 
Hydro Concept Rear Impact Guard (RIG); Malcolm Deighton (Hydro Aluminum Extrusions) 
Crash Avoidance Technology; Wolfgang Hahn (ZF CV Systems North America) 
Rear Underride Guard Report Recommendations & References; Lee Jackson & Jennifer Tierney (Truck Safety Coalition) 
A Historical Overview of Rear Underride Research, Recommendations, & Rulemaking; Marianne Karth (AnnaLeah & Mary for Truck Safety)
Rear Underride Prevention – Creating Crash Compatibility: Rear Guard Standards; Rear Guard Weight; Rear Guard Retrofit; Aaron Kiefer (Collision Safety Consulting) 
ACUP Member Discussion of Past & Present Motions – NHTSA Response to Information Requests, Assessment, & Recommendations, as well as ACUP communications

Truck Impact Guards = Underride Protection

So, you ask, what are Truck Impact Guards? To borrow from NHTSA terminology, Rear Impact Guards are devices attached to Commercial Motor Vehicles in order to GUARD against deadly underride and intrusion into the occupant survival space of a passenger vehicle when there is a collision or IMPACT [an impinging or striking especially of one body against another, Merriam Webster] at the REAR of a large truck.

The difference a well-designed rear impact guard can make

Although NHTSA does not yet require them, a Side Impact Guard is, likewise, a device attached to a large truck to GUARD against deadly underride and intrusion into the occupant survival space of a passenger vehicle when there is a collision or IMPACT at the SIDE of a large truck.

Underride Crash Tests – Without & With Side Impact Guards

Thus, it stands to reason, even though NHTSA apparently has no plans at present to require this life-saving device, a Front Impact Guard is a device attached to a large truck to GUARD against deadly underride and intrusion into the occupant survival space of a passenger vehicle when there is a collision or IMPACT at the FRONT of a large truck.

Volvo Trucks Safety – Front Impact Guard crash test

Truck Impact Guards do not prevent crashes. But, they do compensate for the lack of crash compatibility, which exists due to the geometric mismatch between the “bumpers” of two colliding vehicles that allows one to slide UNDER the other. Effective impact guards ensure that the passenger vehicle’s crashworthiness features — air bags, crumple zones, bumpers, seat belt tensioners — operate as intended to preserve the occupant survival space. This improved crash compatibility can, therefore, serve to make truck crashes more survivable.

These engineer-designed devices can also GUARD Vulnerable Road Users (VRUs) — pedestrians, bicyclists, and motorcyclists — reducing the likelihood of catastrophic injuries during collisions with large trucks.

What is Front Underride Protection? (Find out on April 17)