I just read an interesting Public Comment on the Underride Rulemaking: Comment from 7-E Seven Hills Engineering, LLC – Transport Canada

Perry Ponder also commented on the Single Unit Truck Underride Rulemaking last fall: Comment from 7-E Seven Hills Engineering, LLC – Transport Canada

Of special interest to me was the information in both of his Comments on 1969 rulemaking:

“I will begin by pointing out that continuing to allow truck and trailer induced PCI to occur at otherwise survivable crash speeds (delta-V’s of 45mph and beyond) discards years of crashworthiness efforts and wastes the safety benefits we have come to expect and pay for in our cars.

From an engineering perspective the need for vehicle crash compatibility in the form of adequate heavy truck underride guarding is apparent in order to protect against the hazard of PCI which exposes the vulnerable head and neck region to severe, potentially fatal or crippling injury.

This hazard – easily remedied by readily available materials and simple structural analysis – is present also on the sides of heavy trailers and trucks. The FMVSS standard should be broadened to include guarding for the sides and rear of heavy straight trucks, as well as the sides of heavy trailers. This was the original intent of NHTSA rulemakers in the 1969 NPRM, Docket No. 1-11; Notice 2.”

I need to find out more about that Notice.