Category Archives: Safety Advocacy

Is Cost/Benefit Analysis Appropriate for Life & Death Matters? Were their lives worth saving?

May 20, 2016AnnaLeah and Mary, Safety Advocacy, Truck Safetycost benefit analysis, cost-effectiveness analysis, Susan Rose-Ackerman, underride guards, Vision Zero, Vision Zero Executive Order, Vision Zero rulemakingMarianne

After we were instrumental in getting underride rulemaking initiated in July 2014, I realized that, though we had made it over one hurdle, in reality the battle had only begun. I became concerned that the cost/benefit analysis which had so often compromised past underride rulemaking was still a very real threat. It was then that I surmised that a Vision Zero Executive Order to modify the regulatory analysis process might well be necessary. Thus the Vision Zero Petition was birthed.

Some of the warning signs that the Cost/Benefit Analysis (CBA) bugaboo might be lurking around the corner can be seen in the Preliminary Cost/Benefit Analysis for the current underride rulemaking:

To avoid making this post too-lengthy, I will provide the link to my initial reactions when the proposed rule was published in December 2015: A Mom’s Knee-Jerk Reaction to NHTSA’s Proposed Rule to Improve Rear Underride Protection with an excerpt here–“NHTSA’s comments in the NPRM indicate that they do not want to compromise safety in the more common crash scenario and so have proposed to concentrate on making that area of the trailer safer and do nothing, at least at this stage in the game, about the other weaker area where crashes are reportedly less common. (See p. 44, ” NHTSA is not convinced that improved protection in the less frequent 30 percent overlap crashes should come at the cost of adequate protection in the more common 50 and 100 percent overlap crashes.”)I just have to ask, Is it really an Either/Or situation? Are we sure that we cannot reasonably address both problems?”
Back in December, I put together a handy-dandy document highlighting important points in the Preliminary Analysis: NPRM Rear Impact Guards, Rear Impact Protection December 2015 document; A Summary of Some of the Highlights
Hey, I forgot about this: They are asking for information about higher (than 35 mph) speeds. We recognize, however, that benefits may accrue from underride crashes at speeds higher than 56 km/h (35 mph), if, e.g., a vehicle’s guard exceeded the minimum performance requirements of the FMVSS. NHTSA requests information that would assist the agency in quantifying the possible benefits of CMVSS No. 223 rear impact guards in crashes with speeds higher than 56 km/h (35 mph) . What are we waiting for?!
Based on their proposed requirements, their CBA comes up with a figure which is very close to the current Value of a Statistical Life (VSL), $9.4 million–which tells me that if more improvements were added to the proposed rule, that figure would go up and they would then say that such a counter-measure was “not cost-effective.” Get it? p. 55 The agency estimates that the net cost per equivalent lives saved is $9.1 million and $9.5 million discounted at 3 percent and 7 percent, respectively.
See what I mean? p. 55 “We have tentatively decided not to require used trailers be retrofitted with CMVSS No. 223 compliant rear impact guards. Our analysis indicates such a retrofitting requirement would be very costly without sufficient safety benefits.
Of course, they aren’t figuring in (that I can see) the additional lives which would be saved with better protection or adequately considering undercounted lives–like AnnaLeah and Mary. Our FARS report said, “Compartment Intrusion Unknown.”
Why on earth, anyway, are they playing God and deciding that it isn’t worth it to save a certain number of lives? Besides, have they taken into account the fact that the underride victims are not the consumer of the product (improved guards on trailers)? The consumer is the trailer buyer who has already shown a willingness to seek safer trailers. And the manufacturers have responded to that by producing safer trailers (to a degree). See my recent comment on the Federal Register: Public Comment on the NPRM by Marianne Karth

When it gets right down to it, I want to just throw the cost/benefit analysis out the window. It is downright unethical and considers profit over people. Jerry says that the Cost Effectiveness Analysis would be more appropriate and is, in fact, mentioned in OMB Circular A-4 as a regulatory requirement. Circular A-4, “Regulatory Impact Analysis: A Primer”

It is my hope that we can pursue a recommendation, made by a participant of the Underride Roundtable during the afternoon panel discussion, and organize a group of affected individuals and organizations/companies to meet together and develop a proposal to take to NHTSA in order to bring about a comprehensive negotiated rulemaking. The result could more quickly bring about a more effective underride rule which would cover all the bases to save as many lives as is humanly possible through improved technology. It would also get the manufacturing companies out of limbo so that they can make long-term plans and move forward with designing and producing safer products. Win/Win. N’est-ce pas?

Side note to Cost/Benefit Analysis Question: The fallacy behind the Australian fed. gov’t’s CBA.

Last night, I decided to find out if anyone agrees with my opinion that cost/benefit analysis is inappropriate for rulemaking related to traffic safety matters of life and death. Here is what I am finding:

“Cost-Benefit Analysis: An Inadequate Basis for Health, Safety, and Environmental Regulatory Decisionmaking”* Michael S Baram ** “INTRODUCTION The use of cost-benefit analysis in agency decisionmaking has been hailed as the cure for numerous dissatisfactions with governmental regulation. Using this form of economic analysis arguably promotes rational decisionmaking and prevents health, safety, and environmental regulations from having inflationary and other adverse economic impacts. Closer analysis, however, reveals that the cost-benefit approach to regulatory decisionmaking suffers from major methodological limitations and institutional abuses. In practice, regulatory uses of cost-benefit analysis stifle and obstruct the achievement of legislated health, safety, and environmental goals. The Article concludes that if the health, safety, and environmental regulators continue to use cost-benefit analysis, procedural reforms are needed to promote greater accountability and public participation in the decisionmaking process. Further, to the extent that economic factors are permissible considerations under enabling statutes, agencies should conduct cost-effectiveness analysis, which aids in determining the least costly means to designated goals, rather than cost-benefit analysis, which improperly determines regulatory ends as well as means.” Cost-Benefit Analysis: An Inadequate Basis for Health, Safety, and Environmental Regulatory Decisionmaking*
“Since 1981, the Office of Information and Regulatory Affairs (OIRA) in the White House has reviewed significant proposed and final regulations for conformity with cost-benefit tests.3 Under a series of executive orders, OIRA has performed this role through Republican and Democratic presidencies.4 These policy reviews are controversial: Some claim that OIRA promotes the use of sound social-scientific reasoning; others see it as a front for business interests and a triumph of cold and heartless economic reasoning.” Putting Cost-Benefit Analysis in Its Place: Rethinking Regulatory Review p. 2 by Susan Rose-Ackerman
“President Barak Obama has continued the practice of regulatory review under the executive order originally issued by President Bill Clinton and kept in place by President George W. Bush. However, in January 2009, the Administration expressed an interest in revising the executive order. OIRA opened a comment period and received a broad response from the policy community.6 So far, nothing has happened. The comments seem to have fallen into a black hole. OIRA has not attempted a full-blown reconsideration of the executive order. It has concentrated instead on increasing the transparency of government, and especially, on the ease of access to regulatory information and data sets. Otherwise, it is “business as usual”—with the staff reviewing proposed and final rules with only an occasional flare-up over controversial issues, such as whether or not to designate coal ash as a hazardous waste.7 The failure to rethink the executive order is unfortunate—especially given the global trend to institutionalize something called impact assessment (IA).” Putting Cost-Benefit Analysis in Its Place: Rethinking Regulatory Review p. 3
“With no change in the executive order, CBA will continue to be enshrined as the ideal standard for regulation in the United States. Even if the actual cost-benefit studies performed by U.S. government agencies are highly variable in quality and often lack key components, the technique remains a benchmark for analysis.10 I seek to challenge the hegemony of CBA on two grounds. First, cost-benefit analysis should be used to evaluate only a limited class of regulatory policies, and even then it should be supplemented with value choices not dictated by welfare economics. Second, CBA presents an impoverished normative framework for policy choices that do not fall into this first category.” Putting Cost-Benefit Analysis in Its Place: Rethinking Regulatory Review p.4
“Here, the main problems are measurement difficulties that are sometimes so fundamental that better analysis or consultation with experts cannot solve them. I am thinking mainly of debates over the proper discount rate for future benefits and costs; efforts to incorporate attitudes toward risk; and the vexing problems of measuring the value of human life, of aesthetic and cultural benefits, and of harm to the natural world. Disputes over these issues turn on deep philosophical questions—for example, valuing future generations versus” Putting Cost-Benefit Analysis in Its Place: Rethinking Regulatory Review p. 5
“These issues do not have “right” answers within economics. They should not be obscured by efforts to put them under the rubric of a CBA. Politically responsible officials in the agencies and the White House should resolve them in a transparent way. ” Putting Cost-Benefit Analysis in Its Place: Rethinking Regulatory Review p. 6
” There is no need to resolve difficult conceptual and philosophical issues if the preferred outcome does not depend on the choice of a discount rate or the value given to human life. ” Putting Cost-Benefit Analysis in Its Place: Rethinking Regulatory Review p. 6
“I review the limitations of CBA as a policy criterion and use my critique as a ground for proposing a revised executive order to the Obama Administration. The new executive order should continue to require both up-front consultation on the regulatory agenda and ongoing review of major regulations above some minimum level of importance. As Revesz and Livermore recommend, OIRA could play a larger role in overall agenda setting and policy coordination across agencies.13 Such review serves the interest of any president seeking to influence the overall regulatory environment. Hence, both consultation and review should be mandatory for core executive agencies, but, under my proposed framework, the executive order would only require agencies to carry out formal CBAs for a subset of regulations.” Putting Cost-Benefit Analysis in Its Place: Rethinking Regulatory Review p. 7
“To avoid conflicts with the political pressures facing the President, an advisory body independent of the White House should provide expert analytic advice to agency policy analysts and to OIRA. In this, I build on Stephen Breyer, who urges the creation of a separate expert agency with the mission of rationalizing regulatory policy across programs that regulate risk.14 Bruce Ackerman also recommends the creation of an integrity branch, concerned with transparency and limiting corruption, and a regulatory branch insulated from day-to-day political influences but required to justify its actions publicly.15 Either OIRA, or this new advisory body, should create a library of innovative tools for achieving regulatory goals that go beyond the much criticized command-and-control model. Agency policymakers could access this library as they look for innovative ways to achieve goals, as could those contemplating amendments to existing laws” Putting Cost-Benefit Analysis in Its Place: Rethinking Regulatory Review p. 7-8

Do it, President Obama, for We the People of this United States of America! #VisionZero

Letter to President Obama from the Karth Family, including the Vision Zero Executive Order

Vision Zero Petition Book 3rd Edition

Is Cost/Benefit Analysis Appropriate for Regulatory Decisions in Life & Death Matters?

May 20, 2016AnnaLeah and Mary, Safety Advocacy, Truck SafetyEO 12866, Vision Zero, Vision Zero Executive Order, Vision Zero rulemakingMarianne

I decided to find out if anyone agrees with my opinion that cost/benefit analysis is inappropriate for rulemaking related to traffic safety matters of life and death.

Here is what I am finding:

Cost-Benefit Analysis: An Inadequate Basis for Health, Safety, and Environmental Regulatory Decisionmaking* Michael S Baram ** “INTRODUCTION The use of cost-benefit analysis in agency decisionmaking has been hailed as the cure for numerous dissatisfactions with governmental regulation. Using this form of economic analysis arguably promotes rational decisionmaking and prevents health, safety, and environmental regulations from having inflationary and other adverse economic impacts. Closer analysis, however, reveals that the cost-benefit approach to regulatory decisionmaking suffers from major methodological limitations and institutional abuses. In practice, regulatory uses of cost-benefit analysis stifle and obstruct the achievement of legislated health, safety, and environmental goals. The Article concludes that if the health, safety, and environmental regulators continue to use cost-benefit analysis, procedural reforms are needed to promote greater accountability and public participation in the decisionmaking process. Further, to the extent that economic factors are permissible considerations under enabling statutes, agencies should conduct cost-effectiveness analysis, which aids in determining the least costly means to designated goals, rather than cost-benefit analysis, which improperly determines regulatory ends as well as means.” Cost-Benefit Analysis: An Inadequate Basis for Health, Safety, and Environmental Regulatory Decisionmaking*
“Since 1981, the Office of Information and Regulatory Affairs (OIRA) in the White House has reviewed significant proposed and final regulations for conformity with cost-benefit tests.3 Under a series of executive orders, OIRA has performed this role through Republican and Democratic presidencies.4 These policy reviews are controversial: Some claim that OIRA promotes the use of sound social-scientific reasoning; others see it as a front for business interests and a triumph of cold and heartless economic reasoning.” Putting Cost-Benefit Analysis in Its Place: Rethinking Regulatory Review p. 2 by Susan Rose-Ackerman
“President Barak Obama has continued the practice of regulatory review under the executive order originally issued by President Bill Clinton and kept in place by President George W. Bush. However, in January 2009, the Administration expressed an interest in revising the executive order. OIRA opened a comment period and received a broad response from the policy community.6 So far, nothing has happened. The comments seem to have fallen into a black hole. OIRA has not attempted a full-blown reconsideration of the executive order. It has concentrated instead on increasing the transparency of government, and especially, on the ease of access to regulatory information and data sets. Otherwise, it is “business as usual”—with the staff reviewing proposed and final rules with only an occasional flare-up over controversial issues, such as whether or not to designate coal ash as a hazardous waste.7 The failure to rethink the executive order is unfortunate—especially given the global trend to institutionalize something called impact assessment (IA).” Putting Cost-Benefit Analysis in Its Place: Rethinking Regulatory Review p. 3
“With no change in the executive order, CBA will continue to be enshrined as the ideal standard for regulation in the United States. Even if the actual cost-benefit studies performed by U.S. government agencies are highly variable in quality and often lack key components, the technique remains a benchmark for analysis.10 I seek to challenge the hegemony of CBA on two grounds. First, cost-benefit analysis should be used to evaluate only a limited class of regulatory policies, and even then it should be supplemented with value choices not dictated by welfare economics. Second, CBA presents an impoverished normative framework for policy choices that do not fall into this first category.” Putting Cost-Benefit Analysis in Its Place: Rethinking Regulatory Review p.4
“Here, the main problems are measurement difficulties that are sometimes so fundamental that better analysis or consultation with experts cannot solve them. I am thinking mainly of debates over the proper discount rate for future benefits and costs; efforts to incorporate attitudes toward risk; and the vexing problems of measuring the value of human life, of aesthetic and cultural benefits, and of harm to the natural world. Disputes over these issues turn on deep philosophical questions—for example, valuing future generations versus” Putting Cost-Benefit Analysis in Its Place: Rethinking Regulatory Review p. 5
“These issues do not have “right” answers within economics. They should not be obscured by efforts to put them under the rubric of a CBA. Politically responsible officials in the agencies and the White House should resolve them in a transparent way. ” Putting Cost-Benefit Analysis in Its Place: Rethinking Regulatory Review p. 6
” There is no need to resolve difficult conceptual and philosophical issues if the preferred outcome does not depend on the choice of a discount rate or the value given to human life. ” Putting Cost-Benefit Analysis in Its Place: Rethinking Regulatory Review p. 6
“I review the limitations of CBA as a policy criterion and use my critique as a ground for proposing a revised executive order to the Obama Administration. The new executive order should continue to require both up-front consultation on the regulatory agenda and ongoing review of major regulations above some minimum level of importance. As Revesz and Livermore recommend, OIRA could play a larger role in overall agenda setting and policy coordination across agencies.13 Such review serves the interest of any president seeking to influence the overall regulatory environment. Hence, both consultation and review should be mandatory for core executive agencies, but, under my proposed framework, the executive order would only require agencies to carry out formal CBAs for a subset of regulations.” Putting Cost-Benefit Analysis in Its Place: Rethinking Regulatory Review p. 7
“To avoid conflicts with the political pressures facing the President, an advisory body independent of the White House should provide expert analytic advice to agency policy analysts and to OIRA. In this, I build on Stephen Breyer, who urges the creation of a separate expert agency with the mission of rationalizing regulatory policy across programs that regulate risk.14 Bruce Ackerman also recommends the creation of an integrity branch, concerned with transparency and limiting corruption, and a regulatory branch insulated from day-to-day political influences but required to justify its actions publicly.15 Either OIRA, or this new advisory body, should create a library of innovative tools for achieving regulatory goals that go beyond the much criticized command-and-control model. Agency policymakers could access this library as they look for innovative ways to achieve goals, as could those contemplating amendments to existing laws” Putting Cost-Benefit Analysis in Its Place: Rethinking Regulatory Review p. 7-8

Do it, President Obama, for We the People of this United States of America! #VisionZero

Letter to President Obama from the Karth Family

Vision Zero Petition Book 3rd Edition

Congress Using Zika To Weaken Truck Safety; Get Life & Death Matters out of political tug-of-war!

May 19, 2016Safety Advocacy, Truck Safetytruck driver fatigue, Vision ZeroMarianne

The newly inserted policy provisions represent a trend over the last three years of the trucking industry using must-pass spending bills to win regulatory concessions that are opposed by most safety advocates and likely could not pass as normal stand-alone bills. In this case, not only do the bills fund major parts of the government, they provide cash to fight Zika.

See more here: Congress Is Using Zika To Weaken Truck Safety

My comment on the article:

Marianne Waldron Karth ·

Truck driver fatigue, along with other deadly traffic safety problems, needs to be addressed in a more comprehensive manner. Traffic Safety is a public health problem and needs to be a National Priority. Contact President Obama here: https://annaleahmary.com/…/tell-obama-you-are-standing…/.

Tell President Obama that you want him to grant the AnnaLeah & Mary Karth Vision Zero Petition to SAVE LIVES. Take life & death matters out of the political tug-of-war arena!

“Safety Advocates Say Fatal Car Seat Failures Are ‘Public Health Crisis’” #VisionZero

May 18, 2016Safety Advocacy, Truck Safetyauto safety defect, manufacturer liability, NHTSA rulemaking, public health crisis, traffic safety, Vision ZeroMarianne

LOS ANGELES (CBSLA.com) — Safety advocates say automakers and regulators have acted with “criminal” negligence in failing to remedy a long-acknowledged auto safety flaw that watchdogs say has played a role in hundreds of deaths, creating a “public health crisis.”

At issue are car seats that malfunction and collapse backward when a car is rear-ended. The impact of the crash and collapsing seat can cripple or kill drivers, as well as passengers in the back seat, in many cases, children. . .

See the entire article and newscast here: Safety Advocates Say Fatal Car Seat Failures Are ‘Public Health Crisis’

In my opinion, a Vision Zero Executive Order, if signed by President Obama, could end the kind of Cost/Benefit Analysis which allows for the excuse that “not enough people die,” from an automotive defect, to justify taking action on deadly automotive defects. See why here:

Sign our Vision Zero Petition here: Save Lives Not Dollars: Urge DOT to Adopt a Vision Zero Policy

Truck Trailer Manufacturers Ass’n “Reminds” NHTSA: Side Guards Are “Not Cost-Effective” Says Who?

May 18, 2016Safety Advocacy, Truck SafetyNHTSA rulemaking, TTMA, underride guards, underride roundtable, Vision ZeroMarianne

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”.

“In its 1991 Preliminary Regulatory Evaluation of proposed guards for rear underride, NHTSA’s Plans and Policy Office of Regulatory Analysis stated: “Combination truck side underride counter-measures have been determined not to be cost-effective.” [Docket I-11; Notice 9; Comment 002, page 15 (emphasis added) {by TTMA}].”

Translate that: Not enough people die from side underride crashes to justify the money it would take to add this safety feature. If this attitude and rulemaking policy is allowed to continue unabated, then innocent, unsuspecting travelers on our road will continue to experience preventable underride crashes and receive a Sentence of Death by Preventable Underride. And no one will be held responsible for that–not the trailer manufacturers, not the trucking companies, not the truck drivers (unless perhaps they were blamed for the collision itself), not the regulators, not the insurers; I repeat, no one!!! No one will be penalized for this despicable, unconscionable action–except, of course, the victims.

And, yes, TTMA is repeating the oft-heard industry argument that the solution is to concentrate on Crash Avoidance Technology instead–as if it were an either/or not a both/and question!

Mom Says $100 Truck Tweak Could Have Saved Her Daughters

Meanwhile, people will continue to needlessly die — like AnnaLeah and Mary — and people like me will undergo tremendously traumatic ongoing grief multiplied exponentially by the anger and frustration of knowing that it might well have been prevented were it not for the endless opposition to implementing solutions which are readily available.

I helped roll up the side guard designed by Aaron Kiefer last month and it did not seem to weigh that much. I talked to Aaron yesterday and he estimates that his side guard, once in mass production, might weigh about 175 pounds. Currently, his prototype, when combining the weight of it on both sides of the truck, weighs in at around 300 pounds. And what percentage of the total allowed 80,000 lbs. is that anyway? (.4%?)

And, by the way, look at this amazing crash test of Aaron’s side guard, which I witnessed in North Carolina less than a month ago (April 30, 2016):

Somebody, please get me an audience with President Obama. I need him to tell me to my face that it is not a matter of life & death for him to adopt a National Vision Zero Goal, to establish a White House Vision Zero Task Force, and to sign a Vision Zero Executive Order which will pave the way for Vision Zero Rulemaking at DOT.

Of course, what I would really like to have happen is to speak with the President, have him catch the vision and promise me that he will actually take those actions. Wouldn’t that be exciting!

However, if President Obama does nothing about the traffic safety travesty, TTMA has clearly shown us what to expect: Continued opposition and resistance to efforts to make trucks safer to drive around.

I truly hope that I am wrong and that the outcome of the Underride Roundtable will have made a huge difference in the future of underride protection. However, it appears that, if TTMA has anything to say about it, we should expect that any new underride rule issued will either be opposed or be unchanged and, therefore, weak and ineffective. When it is Technologically Unnecessary for that to be so.

And then who will be ethically responsible for the continued carnage on the highways of this great country?! That’s what I want to know.

Underride Roundtable To Consider Underride Research From Around the Globe

Media Coverage of the first Truck Underride Roundtable held at IIHS on May 5, 2016

Strick to recall 2005-2009 van trailers for faulty rear impact guard. Discovered in 2014. Recall in 2016.

May 17, 2016Safety Advocacy, Truck SafetyNHTSA, safety defects, underride guardsMarianne

5/13/2016

Strick Trailer is recalling certain single-axle 28-foot van trailers for a rear-impact guard issue, according to a National Highway Traffic Safety Administration document.

More specifically, 2005-2009 van trailers manufactured July 25, 2004, to Feb. 3, 2009, and equipped with rear-impact guards using gussets 55997 and 55998 are affected. Gussets on affected trucks can increase the chances of injury during a crash, thereby violating Federal Motor Vehicle Safety Standard No. 223, “Rear Impact Guards.”

In March 2014, Strick discovered that the gussets may not have been verified using prescribed test procedures, according to the NHTSA document. Tests conducted in April 2014 confirmed that the gussets violated FMVSS 223.

Owners will be notified by Strick to have reinforcements installed to the rear-impact guards at no cost. For more information, contact Strick’s customer service at 260-692-6121. The recall will begin on June 17.

– See more at: http://www.landlinemag.com/Story.aspx?StoryID=31159#.VzsfwfkrK70

Okay, I am glad that this is being taken care of, but I only hope that it will be done thoroughly and completely and without delay. And, by the way, if the problem was discovered in March 2014, why is the recall only beginning on June 17, 2016? What took so long?

Somebody, please get me an audience with President Obama to respond to my Vision Zero Petition!

May 17, 2016AnnaLeah and Mary, Safety AdvocacyNHTSA rulemaking, President Obama, side guards, underride guards, underride roundtable, Vision Zero, Vision Zero PetitionMarianne

As I was contemplating whether to go next week to Ralph Nader’s Breaking Through Power: A Historic Civic Mobilization, 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 underride guards from being mandated and manufactured.

TTMA_Side_impact_Exhibits_A-D_2016-05-13

TTMA_Side_Impact_Main_Comment_2016-05-13

The rationale: Cost/Benefit Analysis shows that adding side guard protection from underride of trucks by passenger vehicles is not cost-effective.

Translate that: If this attitude and rulemaking policy is allowed to continue unabated, then innocent, unsuspecting travelers on our road will continue to experience preventable underride crashes and receive a Sentence of Death by Preventable Underride. And no one will be held responsible for that!!!

And, yes, TTMA is repeating the oft-heard industry argument that the solution is to concentrate on Crash Avoidance Technology instead–as if it were an either/or not a both/and question!

Meanwhile, people will continue to needlessly die — like AnnaLeah and Mary — and people like me will undergo tremendously traumatic grief multiplied exponentially by the anger and frustration of knowing that it might well have been prevented were it not for the endless opposition to implementing solutions which are readily available.

And, no, I cannot imagine that it would have to weigh the 750 pounds which they claim it will (which the NHTSA cost/benefit analysis is based upon, by the way). I helped roll up the side guard designed by Aaron Kiefer last month and it did not weigh that much. I just talked to Aaron and he estimates that his side guard, once in mass production, might weigh about 175 pounds. Currently, his prototype, when combining the weight of it on both sides of the truck, weighs in at 204 pounds.

And, by the way, look at this crash test of Aaron’s side guard, which I witnessed in North Carolina less than a month ago:

Somebody, please get me an audience with President Obama next week (now I have to go to that conference). I need him to tell me to my face that it is not a matter of life & death for him to adopt a National Vision Zero Goal, to establish a White House Vision Zero Task Force, and to sign a Vision Zero Executive Order which will pave the way for Vision Zero Rulemaking at DOT.

Of course, what I would really like to have happen is to speak with him, have him catch the vision and promise me that he will actually take those actions. Wouldn’t that be exciting!

However, if President Obama does not do so, TTMA has clearly shown us that nothing will be any different and any new underride rule issued will likely continue to be weak and ineffective. When it is Technologically Unnecessary for that to be so. And then who will be ethically responsible for the continued carnage on the highways of this great country?!

That’s what I want to know.

Underride Roundtable To Consider Underride Research From Around the Globe

Memorials to remember victims of our country’s traffic crash epidemic

May 16, 2016AnnaLeah and Mary, Safety Advocacy, Truck Safetygrief, photo memorialsMarianne

People who die as a result of traffic crashes usually have no warning and, for the most part, were not doing something intentional to warrant such an untimely end.

Whatever the cause of their death, what is the best way to honor the memories of those hundreds of thousands of loved ones? One way is to share their stories and photos. Another way is to work diligently in their memory to reduce crash deaths so that others do not have to suffer the same tragic end to their earthly life–and putting an end to this traffic crash epidemic.

Here is one Victim Memorial Page: Truck Crash Victim Memorials at Truck Safety Coalition

Here is an idea I had a while ago for making these stories more visible: Digital photo/video montage of the countless people who have had their lives cut short by a tragic crash.

What would you suggest? Email your ideas to me at marianne@annaleahmary.com.

U.S.A. Crash Death Clock

Will we set a National #Vision Zero Goal? Pedestrian Traffic Fatalities by State 2015 Prelim. Data

May 16, 2016Safety Advocacypedestrian traffic fatalities, Vision ZeroMarianne

Let’s work together as communities to reduce all kinds of crash deaths–including pedestrian traffic fatalities. Let’s create a network of Vision Zero Community Action Groups across this nation. With shared vision and resources.

Pedestrian Traffic Fatalities by State 2015 Preliminary Data

I firmly believe that, in order to move as a nation Toward a Vision of Zero Crash Deaths, it will take take a commitment to a National Vision Zero Goal and a coordinated endeavor of government, private industry, workers of every skill imaginable, and informed citizens. Anything short of this will be disjointed and less effective, which translates into — not simply unmet project goals but — people dying. It is not an impossible dream but it will require sacrifice and will be well worth the effort.

Do it, President Obama, for We the People of this United States of America! #VisionZero

See what is being done in Bangladesh, through a community project, to reduce crash fatalities: Community project puts a dent in crash fatality numbers.

Community project puts a dent in crash fatality numbers (Bangladesh)

May 16, 2016Safety AdvocacyVision Zero, Vision Zero community action groupsMarianne

Community involvement has helped to reduce crash deaths in Bangladesh. Could we learn something from their efforts?

Community project puts a dent in crash fatality numbers – See more at: http://www.dhakatribune.com/bangladesh/2016/may/15/community-project-puts-dent-crash-fatality-numbers

What will it take to make a significant reduction in the number of people who die on our roads?

Among other things, I also believe that it will take listening to the hundreds of thousands of families who have lost loved ones due to traffic crashes and apologizing, as a society, for letting them down–for not addressing it as the priority it should be.

Bring a deeper measure of healing and hope by acknowledging their frustration and anger and grief. Let them know that they are being heard and that their petitions for change are being taken seriously.

Set a National Vision Zero Goal and then give these motivated people a voice. Launch a nation-wide network of Vision Zero Traffic Safety Community Action Groups which can channel their zealous energy in positive ways. In concert with a White House Vision Zero Task Force and a Cabinet which is authorized to conduct Vision Zero rulemaking, these groups could work at the local level as a powerful tool for changing the future and moving us more surely Toward Zero Crash Deaths, Serious Injuries, and Fear of Traffic.

Do it, President Obama, for We the People of this United States of America! https://annaleahmary.com/2016/03/do-it-president-obama-for-we-the-people-of-this-united-states-of-america-visionzero/