Monthly Archives: October 2017

Understanding Underride VI: Maintenance of Underride Equipment

Truck Safety,

Recently, I reviewed proposed language for the “Maintenance Section” of the STOP Underrides! legislation [previously known as the Roya, AnnaLeah & Mary Comprehensive Underride Protection Act of 2017]. Working to accurately spell out what was important to include in requirements for proper maintenance of rear underride guards made me realize how imperative it is that the basic problem of underride be better understood.

A true appreciation of the fundamental underride issue could, in fact, lead to a better grasp of what is at stake if an underride guard is not properly maintained. So that is what I hope to foster here. Because this is not a simple matter of keeping a machine functioning so it can continue to drive down the road; it is a matter of maintaining the integrity of a piece of equipment which can, hopefully, prevent sure death or debilitating injury.

Where does maintenance come into the picture? If you have a piece of equipment which is supposed to guard against deadly underride  — if designed in a particular way (and that includes how it is attached to body of the truck), then it would need to be maintained in such a way that it would continue to provide that same strength.

Herein lies the problem. The current rear underride guards on existing trucks might do what they are supposed to in some collisions and successfully prevent underride. However, if the guards (and their attachments to the trucks) are not properly maintained in like-new condition, then their integrity will be compromised and their strength will be weakened. Underride will be even more likely to occur, and people will die as a result.

And this is the reality for the millions of existing large trucks on the road today. As far as I can see, from simple observation when driving on the highways, many of the rear underride guards are not being properly maintained. Of course, this will be important for the newer, stronger guards, too, as they begin to be installed on new trucks or retrofitted to existing trucks.

Read more here: Proper Maintenance of Underride Guards Can Spell the Difference Between L-i-f-e & D-e-a-t-h

A real-life crash between a semi-trailer & 2 cars shows the life & death difference which underride makes.

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A real life crash, where two cars collided with a semi-trailer, occurred in the Chicago area on October 16, 2017. One driver died; the other driver survived.

The 38-year-old driver of the Jaguar and the 27-year-old driver of the semi-tractor were each transported to area hospitals with non-life threatening injuries. The driver of the Envoy was pronounced deceased at the scene. 2 Dead, 1 Critically Injured in Aurora Crash Involving Semi

I don’t have proof yet, but it appears to me that the driver who survived may have done so because his car (the white Jaguar) hit the trailer tires, which activated the crush zone of the car and prevented underride ( or Passenger Compartment Intrusion = PCI). The driver of the other car was not so fortunate, the first point of impact was probably in his occupant space.

Underride Briefing on The Hill; Video Excerpts of Panel Discussion on October 12

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On October 12, 2017, staff from Congressional Offices gathered to hear presentations from five experts on the topic of truck underride. The presentations were followed by a question & answer period as legislative staff sought to understand the problem and solutions of deadly but preventable underride crashes.

The STOP Underrides! Act of 2017 has been drafted by Senator Kirsten Gillibrand. She is working with Congressman Steve Cohen, who will be drafting a House Companion Measure.  They are both seeking Republican co-leads for this long-overdue, life-saving legislation.

The videos below cover the individual presentations but, unfortunately, the question period was not recorded. Questions about any of the topics covered can be directed to marianne@annaleahmary.com, for follow-up with these and other experts nationally and internationally.

This video includes all five presentations:

Malcolm Deighton, engineer with Hydro (formerly Sapa), discusses their aluminum rear underride guard — successfully crash tested at 40 mph:

Jason Levine, Director of the Center for Auto Safety, discusses the flaws in the cost/benefit analysis of truck underride protection:

Robert Lane, VP of Product Engineering at Wabash National — a trailer manufacturer, discusses their commitment to development of rear and side underride protective devices for the prevention of underride deaths and debilitating injuries:

Matt Brumbelow, a research engineer at the Insurance Institute for Highway Safety (IIHS), discusses the problem of truck underride and the research which IIHS has done to study rear and side underride protection:

Keith Friedman, Friedman Research Corporation, discusses Front Underride Protection:

Further information on truck underride can be found at:

Hosted by Lois Durso (https://stopunderrides.org/) and Marianne Karth (https://annaleahmary.com) who are working to STOP Underrides! in memory of their daughters — Roya Sadigh and sisters AnnaLeah & Mary Karth.

Large trailer manufacturers built 340,000 in 2015. How many purchased in 2017 will have strong rear guards?

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Some of the trailer manufacturers are offering the new stronger rear underride guard as standard to their customers on their new trailers. Some are not. Why is that? If the new guards have been proven to be safer, why still sell trailers with the weaker, ineffective rear guards which — if involved in a crash — could so easily lead to Death by Underride?

I wonder how many trailers have been sold with the newer guards which meet the IIHS ToughGuard award standards. I know that one transport company, J.B. Hunt, ordered 4,000 of the improved Wabash trailers in January 2016. But the stronger guard is not yet standard on Wabash trailers. So, what percentage of the total new purchases is that?

According to Trailer Body Builders, “THE 25 largest trailer manufacturers in North America built some 340,000 truck-trailers and container chassis in 2015, a 16.6 percent increase over the preceding year.” So J.B. Hunt’s order would have been 1.2% of the total truck-trailer and container chassis purchases for that year.

What about the other 336,000 trucks potentially purchased last year? Did they have safer rear underride guards? (And how long will they stay in the fleet?) I know that they did not have side guards. And that is not even mentioning the millions of existing trucks on the road which are Death by Underride waiting to happen — especially because many of them are not properly maintained.

If only the industry would voluntarily take the initiative to make it right and correct their defectively-designed products by making sure that every truck on the road had the best possible underride protection. New and existing.

I find it interesting that at least some in the industry are thinking comprehensively about some aspects of safety technology. . .

Powell said his first advice when talking with fleet customers (Velociti specalizes in “technology deployment services”) is to suggest they “synergize” their technology adoption efforts in order to make them more complete and easier to handle. For example, he said, if your fleet is looking at putting collision avoidance systems on your trucks, why not put them on your yard tractors and forklifts at the same time?

Likewise, instead of dividing the tasks of putting different safety systems on vehicles such as electronic logging devices, in-cab camera systems, and lane-departure warning systems, treat all those initiatives as a single, unified action plan. Fleets Share Best Practices on Implementing New Technologies Looking at technology as a problem-solver first can go a long way toward its successful deployment in real-world fleet operations.

See, the industry understands the logic of approaching safety technology with a COMPREHENSIVE strategy! Now if only they would apply that by including comprehensive underride protection in the Super Truck Project!

Perfect Opportunity to Transform SuperTruck Into An ESV To Advance Underride Protection; DOT & DOE?

How many more people have to die from Death by Underride before “we” do something about it?!

Truck Safety,

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.
  • Of those, 722 (16.7%) were occupants of large trucks and 10.8% were nonoccupants.
  • 72.4% of the truck crash fatalities were occupants of other vehicles, or 3,125.5 (Do I round that up to 3126? Now that really bothers me because this is about people who died in a crash with a truck last year and not merely statistics!)

If you look at NHTSA’s press release, here is their summary:

The 2016 national data shows that:

  • Distraction-related deaths (3,450 fatalities) decreased by 2.2 percent;
  • Drowsy-driving deaths (803 fatalities) decreased by 3.5 percent;
  • Drunk-driving deaths (10,497 fatalities) increased by 1.7 per­cent;
  • Speeding-related deaths (10,111 fatalities) increased by 4.0 percent;
  • Unbelted deaths (10,428 fatalities) increased by 4.6 percent;
  • Motorcyclist deaths (5,286 fatalities – the largest number of motorcyclist fatalities since 2008) increased by 5.1 percent;
  • Pedestrian deaths (5,987 fatalities – the highest number since 1990) increased by 9.0 percent; and
  • Bicyclist deaths (840 fatalities – the highest number since 1991) increased by 1.3 percent.

Do you see the 4,317 truck crash fatalities mentioned there? I don’t! Yet they accounted for 11.5% of the total traffic fatalities.

Is that indicative of what I continue to observe year after year — that truck crash fatalities are considered merely a transportation issue and left to the trucking industry to solve? And so potential lives saved always lose out in any cost/benefit analysis because “CBA is weighted in favor of the regulated industry and against health, safety and environmental protections”.

And we all know who ends up paying the price for this unresolved public health & safety crisis.

“Even if cost-benefit analysis is theoretically a neutral tool. . . it is biased against strong public protections.”

Truck Safety, , ,

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.
  • Of those, 722 (16.7%) were occupants of large trucks and 10.8% were nonoccupants
  • 72.4% of the truck crash fatalities were occupants of other vehicles, or 3,125.5 (Do I round that up to 3126? Now that really bothers me because this is about people who died in a crash with a truck last year and not merely statistics!)

If you look at NHTSA’s press release, here is their summary:

The 2016 national data shows that:

  • Distraction-related deaths (3,450 fatalities) decreased by 2.2 percent;
  • Drowsy-driving deaths (803 fatalities) decreased by 3.5 percent;
  • Drunk-driving deaths (10,497 fatalities) increased by 1.7 per­cent;
  • Speeding-related deaths (10,111 fatalities) increased by 4.0 percent;
  • Unbelted deaths (10,428 fatalities) increased by 4.6 percent;
  • Motorcyclist deaths (5,286 fatalities – the largest number of motorcyclist fatalities since 2008) increased by 5.1 percent;
  • Pedestrian deaths (5,987 fatalities – the highest number since 1990) increased by 9.0 percent; and
  • Bicyclist deaths (840 fatalities – the highest number since 1991) increased by 1.3 percent.

Do you see the 4,317 truck crash fatalities mentioned there? I don’t! Yet they accounted for 11.5% of the total traffic fatalities.

Is that indicative of what I tend to observe — the truck crash fatalities are considered a transportation issue and left to the trucking industry to solve? And so potential lives saved always lose out in any cost/benefit analysis, and we all know who ends up paying the price for this unresolved public health & safety crisis.

Along that line, check out this interesting read about cost/benefit analysis (which agencies have to do in rulemaking) related to safety regulations. . . https://www.foreffectivegov.org/node/2332

Even given the many uncertainties of cost-benefit analysis, proponents still argue that it acts as a neutral tool. Yet, as David Driesen points out, “if CBA only makes regulation weaker, and never strengthens overly weak regulation, it cannot improve priority setting and consistency in the manner its proponents envision.” Driesen lays to rest the argument of CBA’s neutrality by dissecting the use of CBA both in practice and theory. Driesen finds that both in OMB’s implementation of cost-benefit analysis as well as in the assumptions of the cost-benefit analysis itself, CBA is weighted in favor of the regulated industry and against health, safety and environmental protections.
 
Driesen focuses his look at cost-benefit analysis on the role of the Office of Information and Regulatory Affairs (OIRA), a subagency of the Office of Management and Budget (OMB) charged with carrying out cost-benefit analysis through Executive Order 12866. According to a Government Accountability Office (GAO) report, between June of 2001 and July of 2002, OMB “significantly affected 25” environmental, health and safety regulations. If cost-benefit analysis is in practice a neutral tool, then OIRA’s use of cost-benefit analysis to review regulation would sometimes strengthen protections and sometimes weaken them. Driesen found that none of OIRA’s changes made environmental, health or safety protections more stringent, and 24 out of the 25 weakened protections. Even if cost-benefit analysis is theoretically a neutral tool, in the hands of this administration, it is certainly biased against strong public protections.
 
 OMB tends to see cost-benefit analysis as a criterion under which the cost of implementing a regulation can never exceed the benefit. Another option is that cost-benefit analysis is used as a criterion under which cost must always equal benefit, optimizing the efficiency of the regulation. Driesen shows that in each case cost-benefit is not a neutral tool and will always favor the regulated community over the health, safety and environmental regulation.
 
Previous posts on this issue:

Lawmaker first to publicly back truck underride bill written by grieving moms

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Thank you, Congressman Mark DeSaulnier, for your strong commitment to ending truck underride tragedies.

Senator Gillibrand Directs Pointed Questions on Underride to Federal Highway Administration Nominee

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Senator Gillibrand asked Paul Trombino — in his nomination hearing for the position of Administrator of the Federal Highway Administration (FHWA) — some pointed questions about the underride problem. Her questions to him included asking whether he was aware that the IIHS had successfully crash tested a side guard at 40 mph in August and whether he would commit to studying the issue and responding to her within three months if he was appointed to that position.

Go, Senator Gillibrand! Thank you for drawing attention to this and asking for tangible action.

 

Video Links from the Second Underride Roundtable at the IIHS on August 29, 2017

Truck Safety, , , ,

The Insurance Institute for Highway Safety once again did a fantastic job of hosting the Underride Roundtable. They have now provided us with links to the Second Underride Roundtable held at the IIHS Vehicle Research Center in Ruckersville, Virginia, on August 29, 2017. Here is the agenda, followed by the videos:

Truck Underride Roundtable 2 – Morning Session, Part 1:

 

Truck Underride Roundtable 2 – Morning Session, Part 2:

 

Truck Underride Roundtable 2 – Side Guard Panel:

 

Truck Underride Roundtable 2 – Industry Response and Crash Avoidance Panel:

 

Side Guard Crash Test at 40 mph on August 29, 2017:

 

Side Underride & Side Guard Crash Tests at 35 mph at IIHS on March 30 & 31, 2017:

 

 

Debunking the Myth That Safety Countermeasures Over-Regulate the Trucking Industry

Truck Safety,

We have worked hard ever since we lost AnnaLeah (17) and Mary (13) on May 4, 2013, in a senseless and preventable truck underride crash. We have set out to make sure that effective protection is on every defective area of every truck to prevent future underride tragedies.

The problem is that we keep coming against all of the excuses and mistaken beliefs which stand in the way of our moving forward with creative solutions to this public health & safety problem. So my goal now is to debunk the myth that safety countermeasures — like a comprehensive underride protection rule  — are unnecessary and will over-regulate the trucking industry.

First of all, let’s make it very clear that truck underride is not a new problem or even a newly-discovered problem. No, in fact, we have found an 1896 patent for a side underride protective device for a street car and a U.S. patent filed in 1913 for a safety device for the side of motor vehicles. In 1969, the Department of Transportation acknowledged the side underride problem in the Federal Register when they indicated that they intended to extend underride protection to the sides of large trucks.

Second, if the industry was going to solve this problem all by itself, then it would have done so by now. It has not. And I am convinced that, despite the signs of progress which we have seen, there will never be complete and comprehensive underride protection without regulation.

There are too many layers of responsibility in this process; each one involved can point the finger of blame at someone else and the end result is that this problem has fallen between the cracks. I, for one, will not let that continue on my watch.

Next week, we are hosting an Underride Briefing in the Capitol Visitor Center, Room 215, from 2:30 – 4:00 p.m. We are hoping for good attendance from legislative offices so that they are accurately informed about the Stop Underrides Bill — enabling them to wholeheartedly jump on board for this Win/Win solution.

The Senate Commerce Committee had a mark-up today of the AV Start Act.

Here’s hoping that there will be a similar call for safer trucks to be rolling out to deliver goods. And let’s learn from Wabash National’s approach to innovation:

Wabash was first introduced to the possibility of using composites in the trailer by Structural Composites, a Melbourne, Fla.-based company that was using unique composite technology for shock-mitigating Navy boats. Wabash assessed performance and economic metrics, then benchmarked how the technology might apply to trailers.

Wabash opted to use composites, however the project came with a steep learning curve for everyone involved. “We had a lot to learn about semi-trailers and refrigerated truck bodies and what kind of loads they go through,” says Scott Lewit, president of Structural Composites. “And they had to learn from us about what composites can do.” Yeagy encouraged the team to push the boundaries and not be afraid to fail, recalls Lewit. “This approach allowed us to learn and innovate from failure and to rapidly develop and deploy new technology,” he says.  The Trailblazing Trailer, Composites Manufacturing, Evan Milberg , July 5, 2017