Public Comments on the Side Guard ANPRM (Advance Notice of Proposed Rulemaking)

NHTSA closed the Public Comment Period on the Advance Notice of Proposed Rulemaking (ANPRM) for side underride guards on July 20, 2023. NHTSA asked commenters to respond to these nine questions. Here’s where the comments are posted: Advance Notice of Proposed Rulemaking for Side Underride Guards. To make it easier to read through the thousands of comments, I’m providing pdfs and/or links to many of them — although it’s not an exhaustive compilation.

Links to Many of the Public Comments on the Side Guard ANPRM

Public Comments on the Side Guard ANPRM – As of June 16, 2023 (119)

The majority of comments (over 1,000) posted from June 16 through June 23 were from individuals and organizations which support the requests in the Public Comment from the League of American Bicyclists – calling for pedestrians and bicyclists to be included in the data for side guard regulatory analysis. (Motorcyclists are vulnerable to underride as well.)

Some-of-the-Public-Comments-on-the-Side-Guard-ANPRM-June-24-July-22-2023.pdf

The Following are Links to Individual Public Comments (which were submitted as or with attachments):

Eric Hein

Institute for Safer Trucking IST-Comment-on-Side-Underride-PC-Final.pdf

Truck Safety Coalition TSC-Comment-on-ANPRM.pdf

Perry Ponder/Seven Hills Engineering

Wabash National (Trailer Manufacturer) Wabash-comment-on-ANPRM.pdf

Werner Enterprises Wermer-Enterprises-Comment-on-ANPRM.pdf

Safety Research & Strategies Safety-Research-Strategies-Comment-on-ANPRM.pdf

National Waste & Recycling Association Waste-and-Recycling-Comment-on-ANPRM.pdf

Lois Durso Lois-Durso-Comment-on-ANPRM.pdf

Mark Hawkins Mark-Hawkins-Comment-on-ANPRM.pdf

American Trucking Associations (ATA) ATA-Comment-on-ANPRM.pdf

Owner Operator Independent Drivers Association (OOIDA) OOIDA-Comment-on-ANPRM.pdf

Chicago Department of Transportation Chicago-DOT-Comment-on-ANPRM-1.pdf

Fortier/PHSS

Coalition of Intermodal Associations Intermodal-Association-Comment-on-ANPRM.pdf

Andy Young Andy-Young-Comment-on-ANPRM.pdf

Consumer Reports Consumer-Reports-Comment-on-ANPRM.pdf

Elisa Braver Elisa-Braver-Comment-on-ANPRM.pdf

Aaron Kiefer/Collision Safety Consulting 

American Truck Dealers American-Truck-Dealers-Comment-on-ANPRM.pdf

Insurance Institute for Highway Safety (Matt Brumbelow) IIHS-Comment-on-ANPRM.pdf

National Association of Mutual Insurance Companies (NAMIC) NAMIC-Comment-on-ANPRM.pdf

Advocates for Highway & Auto Safety Advocates-for-Highway-Auto-Safety-ANPRM-FINAL.pdf

Truck Sail Truck-Sail-Comment-on-ANPRM.pdf

Association of Pedestrian & Bicycle Professionals Association-of-Pedestrian-and-Bicycle-Professionals-Comment-on-ANPRM.pdf

Jay Hightman The-Robyn-Hightman-Foundation-Comment-on-ANPRM.pdf

City of Boston Transportation Cabinet City-of-Boston-Transportation-Cabinet-Comment-on-ANPRM.pdf

Montgomery County Families for Safe Streets Montgomery-County-Families-for-Safe-Streets-Comment-on-ANPRM.pdf

Association of Pedestrian & Bicycle Professionals Association-of-Pedestrian-and-Bicycle-Professionals-Comment-on-ANPRM.pdf

Massachusetts Vision Zero Coalition Massachusetts-Vision-Zero-Coalition-Comment-on-ANPRM.pdf

National Association of Trailer Manufacturers National-Assn-of-Trailer-Mfrs-Comment-on-ANPRM.pdf

Jerry Karth Jerry-Karth-Comment-ANPRM.pdf

Comment from Jerry & Marianne Karthattachments:

According to the federal rulemaking process, the next step is for NHTSA (and that will include the Advisory Committee on Underride Protection)to begin reviewing and evaluating the comments which have been submitted from the public. Now is the time for the development of a recommendation to the Secretary of Transportation as to whether a side guard regulation would be cost effective.

In other words, now is the time to finally determine that safety is an acceptable cost of doing business and Death By Underride is an unacceptable, unreasonable, and preventable risk for all road users. At least, that’s what I think.

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