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 https://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 https://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 

   • NHTSA Underride Statistics 1994-2014 Truck Underride Fatalities Chart from the FARS, 1994-2014

   • NHTSA Underride Statistics By TYPE (Front, Side, Rear): The side guard research has the potential to save 1,534 lives in the next ten years. (Per the NHTSA Truck Underride Statistics Chart, 1994-2014: Truck Underride Tragedies Need to End; Enough is enough!     and  https://annaleahmary.com/wordpress/wp-content/uploads/2016/08/Truck-Underride-Deaths-by-TYPE-1994-2014.pdf)

   • More recent statistics from IIHS (May 10, 2017): IIHS tests show benefits of side underride guards for semitrailers

   • NTSB 2014 Recommendations on Underride Protection: National Transportation Safety Board Washington, DC 20594 Safety Recommendations, April 2, 2014
   • March Historically a Momentous Month for Truck Underride Safety Advocacy; Beware the Ides of March! — including  a March 19, 1969, Federal Highway Administration underride rulemaking document on the Federal Register which indicated that their intent was to extend underride protection to the sides of large vehicles! Eight years before my wedding day, when I was 13 years-old, DOT was intending to call for stronger underride protection. And yet, 44 years later, when my daughter Mary was 13 and AnnaLeah was 17, we still had not gotten it right! That’s just wrong!
   • Thanks to Clarence Ditlow Review of 1981 Underride Rule Sheds Light on Current Rulemaking Concerns
   • Cost/Benefit Analysis: Or, How to Put a Price Tag on a Person’s Life
   • With Road to Zero, DOT commits $3 million; compare that to $9.6 million Value of a Statistical Life
   • Let’s remember that we are not merely talking about statistics but about people who unexpectedly and preventably lose their lives and leave shattered families behind. Memorable Moments: Here Today, Gone Tomorrow

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 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 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.