I have spoken and corresponded with George Rechnitzer and Raphael Grzebieta from the Transport and Road Safety (TARS) Research Centre in Sydney. I have also written about their work on underride protection in Australia.

Yesterday, I received from them a copy of their submission to the Public Comments on the Underride Protection of Single Unit Trucks. It is worth a read to find out what is being said in other countries about this vital issue.

NHTSA-Docket-Submission-Grzebieta&Rechnitzer 20 Sept 2015

Here are some highlights:

• Whilst there are force based design rules, e.g. in USA, Canada and Europe, it is apparent that these rules are inadequate. In our submission we strongly recommend crash test based performance requirements for under-run protection catering for both centred and off-set impact.
  Around 10 people per year on average are killed in Australia in rear under-run crashes resulting in horrific injuries such as decapitation.13 Yet the Regulation Impact Statement (RIS)14 for Underrun Protection publish by the Vehicle Safety Standards Branch at the Department of Infrastructure, Transport, Regional Development and Local Government in July 2009 recommended that only front under-run protection be applied to all rigid and articulated trucks. Their conclusion was that the cost-benefit ratio for frontal under-run barriers was greater than one whereas for side and rear under-run the benefit was negative, and hence such protection should not be mandated in an Australian Design Rule. Yet despite these numerous calls for changes over the past three decades, we continue to consistently kill people in such crashes, ignoring the fact that practical low cost effective under-run barriers can be fitted. That is the real unforgivable tragedy.
• The Vison Zero and Safe System approach adopted by most of the world now and on which Towards Zero Deaths is anchored, boldly moves away from the economic- rationalist ‘cost-benefit’ models (cited in this Docket as still being used by NHTSA), to a humanistic more rational model. The important aspect of a ‘Vision Zero’ principle is that it introduces ‘ethical rules’ to guide the system designers. In other words:
  • Life and health can never be exchanged for other benefits within the society
  • Whenever someone is killed or seriously injured, necessary steps must be taken to avoid similar events.
• The Authors of this submission would further point out to those at NHTSA considering how the Rear Impact Protection for Single Unit Trucks should be revised; they should consider placing themselves in the position of the gentleman being asked in the following Australian Government advertisement: https://www.youtube.com/watch?v=bsyvrkEjoXI&feature=youtu.be. This advertisement was commissioned and paid for by the Victorian State Government in Australia. We would ask the NHTSA staff responsible for this NPRM which members of their family would they allocate to die that would be acceptable to them and would meet the NHTSA cost benefit ratios being considered?

• To break the impasse between safety stakeholders and regulators, the Authors of this submission have proposed to incorporate into the revision of the ASNZS3845.2 Australian Road Safety Barrier Systems and Devices a crash test performance requirement for rear under-run barriers for heavy trucks, shortly to be released for public comment. In that standard test requirements for under-ride barriers, called Truck Under-run Barriers (TUBs), has been developed and now included. We hope that this standard will be approved by committee members (members include Australian State Government regulators) and hopefully will be published in early 2016. The tests requirements are in part based on the US Manual for Assessing Road Hardware (MASH) and are presented below.
  We would strongly recommend that NHTSA consider such dynamic performance tests when they deliberate their development of the Federal Motor Vehicle Safety Standard for under-ride barriers.
• TUB’s are designed to prevent a vehicle impacting the rear of a stationary truck under-riding the back of the truck in a manner where the truck structure intrudes into the impacting vehicle’s occupant compartment. The TUB’s main function is to protect the occupants in the impacting vehicle.
• If the car is designed to such ANCAP and IIHS test protocols with the maximum crashworthiness rating, it is likely that the occupants would not sustain serious injuries in a vehicle impacting such a TUB in the configurations shown in Figure 1.
• The manufacturers of such TUBs and operators of heavy vehicles are encouraged to explore the application of energy absorbing systems for TUBs including rear air bags mounted on the rear of trucks.

This latter recommendation is relevant to our goal of seeking research money to provide to Dean Sicking whose proposal intends to do just that: explore the application of the SAFER Barrier — an energy absorbying system — to the prevention of truck underride tragedies.

Dean Sicking’s Research Proposal: Development of Trailer Underride Preventive Measures

As soon as their Public Comment is published, I will post a link so that you can read the entire document online for a better understanding of their detailed analysis and proposal for crash test based performance requirements for truck underride protection, for both centred and off-set impact, in contrast to the force based design rules in the current U. S. federal underride standards. The Australian recommendations are based on 30 years of research and experience. (Note: the document in its entirety can be accessed at the top of this post.)

The formal period for submission of Public Comments ends today, September 21, 2015. Upon the request of several groups, I made a request that the period be extended for a short time. That request is under consideration by the agency. All published Public Comments can be found at this site, which is updated as submissions are made:  http://www.regulations.gov/#!docketDetail;dct=FR+PR+N+O+SR;rpp=10;po=0;D=NHTSA-2015-0070

George Rechnitzer and Raphael Grzebieta have, unfortunately, faced similar challenges in Australia in trying to persuade the powers that be to make rules which would prevent unnecessary and horrific deaths and injuries. However, they  are encouraged by potential upcoming changes in their country:

To break the impasse between safety stakeholders and regulators, the Authors of this submission have proposed to incorporate into the revision of the ASNZS3845.2 Australian Road Safety Barrier Systems and Devices a crash test performance requirement for rear under-run barriers for heavy trucks, shortly to be released for public comment. In that standard test requirements for under-ride barriers, called Truck Under-run Barriers (TUBs), has been developed and now included. We hope that this standard will be approved by committee members (members include Australian State Government regulators) and hopefully will be published in early 2016.

Other posts on their work include:

• https://annaleahmary.com/2015/06/truck-underride-prevention-research-too-long-neglected-how-long-will-this-highway-carnage-continue/
• https://annaleahmary.com/2015/06/the-future-of-underride-prevention-a-conversation-with-underride-researcher-from-australia/
• https://annaleahmary.com/2015/06/crocodile-tears-costbenefit-analysis-vision-zero-goal-of-no-crash-fatalities/
• https://annaleahmary.com/2015/07/the-second-collision-does-not-have-to-be-so-prevalent-we-can-do-better-at-preventing-death-horrific-injuries/

We look forward to working with George and Raphael at the Underride Roundtable in the Spring of 2016 and know that our country can greatly benefit from their expertise.

Donate toward the  Underride Roundtable & Research Now: https://www.fortrucksafety.com/

Be a part of this timely push to prevent unnecessary deaths.

It could save someone you love.