Category Archives: Safety Advocacy

Weak Rear Underride Guards Are Still Killing People

Progress has been made in reducing underride deaths. But we’re not done yet; we’ve got a lot more work to do.

For example, seven trailer manufacturers are installing stronger rear underride guards as Standard on all new trailers. However, two trailer manufacturers, who have also designed a stronger rear underride guard, are merely offering it as an Option and are, in fact, still selling tens of thousands of new trailers every year with a too-weak rear underride guard — putting road users at risk of Death By Underride.

Not only that, despite the availability of Rear Impact Guard (RIG) retrofit solutions, millions of trailers on the road still pose a known unreasonable risk. It certainly doesn’t help that NHTSA recently issued a new RIG Rule but failed to require that these safety devices meet a technically feasible level of strength proven possible by nine manufacturers.

Retrofit Solutions for Rear Impact Guards to Prevent Deadly Underride

RIG Retrofit


RIG Retrofit Crash Test
In January 2020, Aaron Kiefer crash tested a reinforced trailer with a 2012 Chevy Impala at 38 mph. This test illustrated that bolt on reinforcements can prevent deadly underride and passenger compartment intrusion (PCI)

Why are we working so hard to get weak rear underride guards replaced?

What’s wrong with this picture?

10 years after trucking crash killed 2 girls, mother sees hope for change, May 5, 2023, Trucking Dive, by David Taube

Video of Speakers at Underride Victim Vigil

Families of underride victims gathered on September 14, 2023, in front of the U.S. Department of Transportation at 1200 New Jersey Ave SE in Washington, DC — with crash test cars from the Insurance Institute for Highway Safety 2017 side underride research in the background — to remember loved ones, who lost their lives due to truck underride.

The families rang a commemorative bell for over 750 victims, primarily from the last few years, and called upon the Department to re-evaluate publicly available data, end their decades of inaction, and issue strong underride regulations. Their message was this: Delay = Death.

Thanks to Sarah Haedrich, Vision Zero Coalition Coordinator for the Washington Area Bicyclist Association (WABA), we have video footage of some of the speakers at this event:

We are thankful for all who spoke at the Underride Victim Vigil, including:

  • Dr. Elisa Braver, epidemiologist and safety researcher
  • Andy Young, The Law Firm for Truck Safety
  • Barry Davis, father of underride victim Ally Davis
  • Lois Durso, mother of underride victim Roya Sadigh
  • Congresswoman Jan Schakowsky (D-IL)
  • Sean O’Malley, Insurance Institute for Highway Safety
  • Abbie Bingham Endicott, cousin of underride victim Sylvia Bingham
  • Daniel Langenkamp (husband of underride victim Sarah Langenkamp) read a statement from Stephen Bingham, father of underride victim Sylvia Bingham
  • Nancy Avis, cousin of underride victim Carling Mott
  • Harry Adler, Institute for Safer Trucking
  • Jerry and Marianne Karth, parents of underride victims AnnaLeah & Mary Karth

A Record of Those Remembered in the Underride Victim Vigil

Media Coverage of DC Underride Victim Vigil & Press Conference

A Record of Those Remembered in the Underride Victim Vigil

Families of underride victims gathered on September 14, 2023, in front of the U.S. Department of Transportation at 1200 New Jersey Ave SE in Washington, DC — with crash test cars from the Insurance Institute for Highway Safety 2017 side underride research in the background — to remember loved ones, who lost their lives due to truck underride. The families rang a commemorative bell for over 750 victims, primarily from the last few years, and called upon the Department to re-evaluate publicly available data, end their decades of inaction, and issue strong underride regulations.

Their message was this: Delay = Death.

The names, included in this solemn event, were taken from a combination of sources, including victims from families known to me and memorial posts on this website. In order to raise awareness and preserve the memories of underride victims — precious ones gone too soon — I have been writing memorial posts on what appear to me to be underride crashes, from daily Google Alerts which I receive on truck crashes. I am not a crash reconstructionist, and I do not have all the facts on these crashes; but underride should be investigated as a potential factor in truck crash injuries and deaths.

This is not an exhaustive list — merely the tip of the iceberg. But I hope that it serves to demonstrate the ongoing nature of a preventable public safety problem. You can find these Underride Crash Memorial posts here. The 750+ victims of preventable truck underride (front, side, and rear, involving tractor-trailers and Single Unit Trucks, as well as pedestrians and cyclists), whom we specifically remembered on September 14, can be found here:

Names & Photos of Underride Victims Part 1 – The Tip of the Iceberg

Names & Photos of Underride Victims PART 2 – The Tip of the Iceberg

Names & Photos of Underride Victims PART 3 – The Tip of the Iceberg

Media Coverage of DC Underride Victim Vigil & Press Conference

Video of Speakers at Underride Victim Vigil

Media Coverage of DC Underride Victim Vigil & Press Conference

Families of underride victims gathered on September 14, 2023, in front of the U.S. Department of Transportation at 1200 New Jersey Ave SE in Washington, DC — with crash test cars from the Insurance Institute for Highway Safety 2017 side underride research in the background — to remember loved ones, who lost their lives due to truck underride. The families rang a commemorative bell for over 750 victims, primarily from the last few years, and called upon the Department to re-evaluate publicly available data, end their decades of inaction, and issue strong underride regulations.

Their message was this: Delay = Death.

A Record of Those Remembered in the Underride Victim Vigil

Media coverage included:

Grieving families say US Department of Transportation failed victims of tractor-trailer underride crashes

Speakers at the press conference included:

  • Dr. Elisa Braver, epidemiologist and safety researcher
  • Andy Young, The Law Firm for Truck Safety
  • Barry Davis, father of underride victim Ally Davis
  • Lois Durso, mother of underride victim Roya Sadigh
  • Congresswoman Jan Schakowsky (D-IL)
  • Sean O’Malley, Insurance Institute for Highway Safety
  • Abbie Bingham Endicott, cousin of underride victim Sylvia Bingham
  • Daniel Langenkamp (husband of underride victim Sarah Langenkamp) read a statement from Stephen Bingham, father of underride victim Sylvia Bingham
  • Nancy Avis, cousin of underride victim Carling Mott
  • Harry Adler, Institute for Safer Trucking
  • Jerry and Marianne Karth, parents of underride victims AnnaLeah & Mary Karth

“Underride crashes, which occur when a car slides underneath the body of a truck, have tragically become all too common on our highways. These crashes are preventable. Underride guards on large trucks save lives. I urge @NHTSAgov to implement stronger protections without delay,” said Congresswoman Jan Schakowsky. “I would be remiss if I did not mention all the survivors and family members who are turning their personal tragedy into advocacy. We could not do this without you.”

Underride Victim Families Appeal to Secretary Pete Buttigieg

Letter to DOT Office of Inspector General, September 14, 2023

We pray for Secretary Buttigieg

Video of Speakers at Underride Victim Vigil

A day in the life of an underride crash test crew; A Photographer’s Perspective

A local photographer became part of the all-volunteer TEAM Underride — offering his skills to capture a day in the life of an underride crash test crew at the Raleigh Underride Crash Test Event on August 3 at the North Carolina State Highway Patrol training facility. Here’s a glimpse of that day from a photographer’s perspective: Team Underride Crash Test Event.

Note: Adam Trevillian provided these photos for TEAM Underride to use. If outside sources would like to use these photos (for publications, etc.), please contact Adam so that he can handle those requests: adam@adamtrevillian.com.

Underride Victim Vigil & Press Conference on DOT Steps in DC

On September 14, from 1:00 to 2:30 p.m., families of victims of horrifying truck underride crashes will be standing vigil in front of the Department of Transportation in Washington, DC. We will be ringing a bell to memorialize the victims and sound an alarm. We will hold a press conference calling upon the Department of Transportation to require truck underride guards which will protect pedestrians, cyclists, and the motoring public from these violent and preventable deaths.

SAVE THE DATE Underride Victim Vigil & Press Conference FINAL

Participants will be invited to ring the bell for their own loved ones or for truck crash victims remembered in these underride crash memorial posts — the tip of the iceberg of precious loved ones gone too soon.

Underride Victim Memorial Bell

Video from STOP Underrides Crash Test Event

When there is no strong physical barrier under a truck bed, Death By Underride becomes a known unreasonable risk. Fortunately, engineers have developed effective physical barriers or underride protection – although it is not required by law. With that in mind, a group of engineers carried out R&D crash testing on August 3 at the Raleigh Underride Crash Test Event.

Four side crash tests were conducted into semitrailers:

  • Ford Fiesta into an AngelWing side guard from a 45 degree angle (39 mph)
  • Chevy Malibu into an unguarded trailer from a 45 degree angle (38 mph)
  • Chevy Impala into a SafetySkirt side guard in the rear area behind forward positioned trailer axles from a 90 degree angle (36 mph)
  • Chevy Malibu into a SafetySkirt side guard from a 90 degree angle (43 mph)

Crashed trailers were each ballasted with approximately 28,000 pounds in water tanks. Video footage in this LinkedIn post by Forensic Rock, highlights two of the crash tests:

We love working with passionate people in the AR field. And Aaron Kiefer is one of those super-passionate people we absolutely love working with.

We were lucky enough to help him and his great #StopUnderrides group collect data for an awesome test series they were running in North Carolina. His goal was to demonstrate the collision mitigation of different trailer guards on side underride collisions with lower-profile sedans.

This compilation video compares an unguarded 53′ van trailer to Aaron’s SafetySkirt design. Two Chevrolet Malibu’s were used in this test series.

The speed at impact in the unguarded test was 37.5 mph; the speed at impact for Aaron’s SafetySkirt test was 43.4 mph.

We won’t spoil it for you, but Aaron certainly knows what he is doing.

Underride Crash Tests – Unguarded Trailer vs Guarded Trailer

The guards prevented Passenger Compartment Intrusion (PCI) in each guarded test.

Note: More details will be shared in the days ahead as photos, video, and electronic data are compiled.

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.

Still Time to Submit a Public Comment on Side Guard Rule (July 20)

Don’t miss the July 20 deadline (extended from June 20) for submitting a Public Comment to NHTSA on the Advance Notice of Proposed Rulemaking for Side Underride Guards. Here’s how you can do it:

  • Go to this link.
  • Write your comment to let NHTSA know why you want them to proceed with a rule on side guards.
  • If you have specific information to answer NHTSA’s nine questions, you can include it in your comments and/or add attachments.
  • Please note the WARNING:   Do not submit personally identifiable information through this form. Any personally identifiable information (e.g., name, address, phone number) included in the comment form or in an attachment may be publicly disclosed in a docket or on the Internet.
  • Use the drop down box to Select a Comment Category (Rule/Proposed Rule/Final Rule).
  • Provide your email address (won’t be published online) and indicate that you’re an Individual and NOT a Robot.
  • Then, SUBMIT.
  • That’s it. Thank you!

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.

Comment from Jerry & Marianne Karth

STOP Senseless Roadway Deaths: Give Victims a Voice

Inaction by federal traffic safety agencies, who are fiercely and disproportionately influenced by industry pressure, has left all road users at risk. As a follow-up to the PBS/Frontline truck underride documentary, on June 22, ProPublica published an article which has exposed the depth of this regulatory capture and the powerlessness of safety activists to bring about change.

If I hadn’t already been aware of most of the details of this report, I might have had a hard time believing it was for real. I’m curious what you think of it. It’s a long read, but worth it!

  • “The Department of Transportation allowed trucking lobbyists to review an unpublished report recommending a safety device that could save lives by preventing pedestrians and cyclists from getting crushed under large trucks. . .
  • But that recommendation generated intense resistance, both internally, from department officials who challenged their findings, and externally, from trucking industry lobbyists. . .
  • After meeting with trucking industry lobbyists in December, 2018, the DOT supervisor overseeing the project emailed researchers: “PLEASE delete any mention of a recommendation to develop…any regulation.” DOT Researchers Suggested a Way to Make Big Trucks Safer. After Meeting With Lobbyists, Agency Officials Rejected the Idea.

If that disturbs you (and it’s just the tip of the iceberg), please sign the petition for a National Roadway Safety Ombudsman so that this kind of regulatory capture doesn’t continue to happen:

STOP Senseless Roadway Deaths: Give Victims a Voice

It’s time to turn the tide and demand that vulnerable victims of vehicle violence be given a vigilant voice at the table. It’s time for a National Roadway Safety Ombudsman to serve the public’s best interests at the Department of Transportation.

Credit to Ken McLeod