The Public Comment Period closed on February 16, but not all of the submitted comments have been posted yet. The proposed rear underride rule can be seen here along with all of the posted comments: NPRM Upgrade Underide
On the question of whether used trailers should be retrofitted in order to make them safer (better able to protect against deadly underride crashes), here is an opinion from one person who recently submitted a public comment. . .
Decision not to require used trailers to be retrofitted (end of Section 7, page 32):
“You state that your analysis indicates such a retrofitting requirement would be very costly without sufficient safety benefits. If more lives would be saved and more injuries would be prevented by requiring new trailers to meet the new standards, then logic dictates that more lives would be saved and more injuries would be prevented by requiring used trailers to be retrofitted.
“Indeed, the crash tests cited for new trailers of different manufacturers tested on a Chevy Malibu suggest substantial disparities. It can be expected that the disparities would be magnified if tests were conducted on some of the used equipment in the nation’s fleet. If it is not worth the cost to retrofit an old trailer (in which case it should be scrapped), that should be the decision of its owner rather than the decision of NHTSA.” See more of his comments here: Comment from D. J. Young, III
Jerry was pleasantly surprised tonight by a phone call from Greer Woodruff, Vice President of Safety & Security at J.B. Hunt. J. B. Hunt Transport Services, Inc. is a trucking and transportation company that was founded by Johnnie Bryan Hunt, and based in the Northwest Arkansas city of Lowell.
Greer was calling to let Jerry know that Wabash National, a trailer manufacturer, had redesigned their rear underride guard to provide better protection at the outer edges of the guard. And he also wanted us to know that J.B. Hunt was the first to purchase the new trailers–having ordered 4,000 of them in January.
But then Greer went on to say that he had wanted to be sure and tell us about it and thank us for the letters, which Jerry wrote to J.B. Hunt–along with the major trailer manufacturers and many other trailer buyers, back in 2014 before we launched our first petition. Those letters, he said, had raised their awareness about the underride problem and spurred them on to talk to the trailer manufacturers about producing safer trailers.
That brought a smile to Jerry’s face.
We look forward to finding out more details about its design features and what level of protection it provides. Also, we hope to see additional attention given to side and front underride protection and retrofitting existing trailers as well.
Meanwhile, we are encouraged to see that progress is being made in moving toward the best possible protection with both voluntary and regulatory action. The Vision Zero Petition Book has arrived!
First set of letters which Jerry sent to trailer buyers in February 2014 (a variation of this went to trailer manufacturers):
One of the letters which went out to trailer manufacturers in February 2014:
A second set of letters went out in March 2014 to clarify our role/position:
Another letter went out asking for support to our petition request for stronger underride guards:
And then Jerry sent a follow-up letter in the fall of 2014, including with it copies of the IIHS Status Reports which had articles on underride guards:
IIHS Status Reports with articles on underride guards, which we included with the letters to the trucking companies:
Finally, after setting up our non-profit, AnnaLeah & Mary for Truck Safety, in the summer of 2015, we wrote to all of the truck companies again–asking for their help to voluntarily find safer underride guard designs:
Also, sometime after our letter writing, we were discussing our efforts with JohnLannen at the Truck Safety Coalition. He asked for our list and said, “Thanks – I’ll follow up with Greer since I know him well. What reaction did you get?”
In our efforts to not only improve regulatory federal standards on underride guards but, also, to catalyze voluntary industry improvement, we heard back from several other companies to whom we had written, including:
Photo Album of Jerry and his girls: With Dad. . . Family Man Jerry prays for his children every morning (lifting them before their heavenly Father/Abba). He is proud of them, teases them, enjoys spending time with them, and treasures each of his special children.
Jerry shares our story at the Fall 2015 Sorrow to Strength conference in DC hosted by the Truck Safety Coalition:
On May 5, 2014, we delivered 11,000 AnnaLeah & Mary Stand Up for Truck Safety petition envelopes to DOT in Washington, DC.
This time around, thanks to Jerry’s brainstorm, we are delivering the petitions in a bound copy ofThe Vision Zero Petition Book. All of the first 16, 516 signatures (and any comments which they made) will be in the book, along with the letters to President Obama and Secretary Foxx and a whole lot of other information which I compiled to spell out how we are asking them to implement our Vision Zero petition requests–creatively arranged by Isaac.
Two weeks from today, on March 4, we will be delivering the book to DOT and to various legislators as well as dropping off a copy at The White House. In addition, Care2 will be printing a binder with all of the signatures–up to printing time–and get it to us on February 29; we will take that along to deliver to DOT.
Five boxes of the book arrived today! Excited to see what will come about!
We have been members of the Home School Legal Defense Association (HSLDA) throughout our homeschooling years ever since the oldest of our nine started learning to read. This week I received a postcard from them wondering if we wanted to renew our membership because we had missed the annual date.
So I needed to call and tell them that we didn’t need to renew because Mary, our youngest who would have been sweet sixteen, was never going to finish high school.
A simple but excruciating phone call which had me hard put to verbalize the facts and weeping before it was over. . .
Should we be concerned that NHTSA is leaning toward accepting voluntary standards to be written by the automotive industry regarding automatic braking systems for cars rather than developing federal standards?
Safety advocates are raising concerns about this:
The technology automatically applies brakes to prevent or mitigate collisions, rather than waiting for the driver to act. It’s the most important safety technology available today that’s not already required in cars.
Such systems should be standard in all new cars, says the National Highway Traffic Safety Administration. But instead of mandating it, the government is trying to work out a voluntary agreement with automakers in hopes of getting it in cars more quickly.
But safety advocates say voluntary agreements aren’t enforceable and are likely to contain weaker standards and longer timelines than if the government had issued rules. Safety groups want braking mandate
Voluntary industry standards, in any industry, have the reputation of often being weak standards. They are enforceable only through publicity and public awareness, not by government action. The level of such voluntary standards, set by industry committees with limited public participation, can be that demanded by the weakest company, the one with the tightest profit margins. Voluntary standards are ‘consensus’ standards, based on agreement of all industry participants. In dealing with the lives and safety of so many people, safety standards, are, and were then, matters not of consensus but of public importance. (Lemov, p. 94) Congress, Please give NHTSA the authority & resources to do their job and keep us safe on the road!
I’m all for getting safety solutions implemented as quickly as possible. But what is the most realistic and comprehensive means of getting this accomplished in a way that will have far-reaching and enforceable results? That’s what I want to know.
Ted Scott, from the American Trucking Association, just emailed me with the news about the new rear underride guard design announced yesterday by Wabash (a trailer manufacturer).
The new rear impact guard is constructed of advanced high-strength steel. Its patent-pending design features two additional vertical posts and a longer, reinforced bumper tube, all of which are engineered to work together to absorb energy better and deflect rear impact at any point along the bumper. In addition, the new guard is fully galvanized to resist corrosion.Wabash Debuts Rear Impact Guard Design for its Dry Van Trailers
Thank you, Wabash, for your commitment to safer trucks.
“Our work on the rear impact guard, and trailer performance in general, isn’t finished,” added Giromini. “Innovation is ongoing at Wabash National. We’re continually looking at ways to optimize total performance through engineering and the use of advanced materials in ways that make sense for our customers.”
I hope that means that they will also be looking at side guard and retrofitting solutions as well.
And thank you, J.B. Hunt, for already ordering 4,000 new trailers with the improved underride protection to put on our roads.
“The National Highway Traffic Safety Administration (NHTSA) is announcing a meeting that will be held in Washington, DC on March 10-11, 2016 to explore ways to promote evidence-based behavior change in a traffic safety setting.
“The Driving Behavioral Change in Traffic Safety workshop will include presentations and discussions on a number of topics including analysis and feasibility of using different approaches to changing behavior; exploring promising untested strategies; identifying long-term pathways to eliminate fatalities; and considering how evidence-based behavior change strategies can be used in the broader policy discussion.
“Attendance at the meeting is limited to invited participants because of space limitations of the DOT Conference Center. However, the meeting will be available for live public viewing on the NHTSA Web site (www.nhtsa.gov).” Meetings: Driving Behavioral Change in Traffic Safety
Sounds promising. . . I hope to see meaningful results which can be widely-dispersed. And focused on while also addressing environmental and vehicular causes of traffic deaths.
Note: While taking classes at the University of Michigan in 1979 for my Master of Public Health degree in Health Behavior & Health Education, one of the things I learned, which has stuck with me, is that fear is not always the best motivator for changing behavior. In other words, knowing that something you do could end your life or that of someone else doesn’t necessarily change our actions. It doesn’t always sink in.
That needs to be kept in mind as we attempt to encourage better driving behavior.
The question was brought to my attention as to whether truck side guards, if they were strong enough to prevent passenger vehicle underride (i.e., probable death or severe injury), would be more harmful to pedestrians and cyclists (Vulnerable Road Users–VRU).
I didn’t know. So I asked the experts with whom I am acquainted, and this is what I found out:
Hi MarianneWell-designed rear, side, front underride protection on trucks, will not make it more dangerous for pedestrians and cyclists, but potentially make it safer for peds and cyclists.
Adjunct Assoc. Professor George Rechnitzer, Transport and Road Safety (TARS) Research, University of New South Wales (UNSW), Web: http://www.tars.unsw.edu.au/
The other feedback, which I received from a crash reconstructionist friend who sees the aftermath of lots of crashes firsthand, was more short and to the point: “I think that stronger side skirts will save lives no matter what vehicle is in play. Would you, as a cyclist, rather bump your head on a resilient skirt (or a flexible one like mine for that matter) or slide underneath a trailer and end up looking like a pancake?”
Goodness, I sure hope that we can help shed light on issues such as these at the Underride Roundtable on May 5, 2016. Delays resulting from endless debate and/or stalling on problem-solving has already led to too many needless and preventable deaths.
After launching the Vision Zero Petition online, I waited a bit before I signed myself. I took a moment to decide what comment to make.
596: Marianne Karth, Rocky Mount, North Carolina,
United States
There is no one that this does not potentially impact in some way. We
are asking for bold and decisive action to reduce tragic, preventable crash
fatalities. Don’t wait until it touches you personally to move heaven &
earth to identify and require the best possible protection. Once a loved
one becomes a motor vehicle crash statistic, it will be too late–they will
not come back to you.
Kind people have said to me, ‘She is with God.’ In one sense that is most certain. . . But I find that this question, however important it may be in itself, is not after all very important in relation to grief. . . You tell me, ‘she goes on.’ But my heart and body are crying out, come back, come back. Be a circle, touching my circle on the plane of Nature. But I know this is impossible. I know that the thing I want is exactly the thing I can never get….It is a part of the past. And the past is the past and that is what time means, and time itself is one more name for death, and Heaven itself is a state where ‘the former things have passed away.’ (pp. 24-25)
Reality never repeats. The exact same thing is never taken away and given back. . .For that is what we should all like. The happy past restored. And that, just that, is what I cry out for, with mad, midnight endearments and entreaties spoken into the empty air. (p. 26)
