Category Archives: Safety Advocacy

Consensus Side Guard Standard

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On April 17, 2020, over 40 people participated in a virtual meeting of a volunteer Underride Protection Committee’s “Side Guard Task Force.” This included two engineers from trailer manufacturers. As a follow-up, several subcommittees began to hold virtual meetings, including an Underride Engineering Subcommittee.

The engineering subcommittee met at least monthly and sometimes every other week from May through November. At the outset, the VP of Engineering of one of the trailer manufacturers provided valuable input. Subcommittee members also participated in a Virtual Briefing for Senate Commerce Committee transportation staffers on August 19, 2020.

The goal of the Underride Engineering Subcommittee was to create a Consensus Side Guard Standard which would provide additional insight for the development of a side guard regulation and industry standard. Lengthy conversation and exchange of information has led this group to submit the following recommendation:

A side underride guard shall be considered to meet the performance standard if it is able to provide vehicle crash compatibility with a midsize car, to prevent intrusion into the occupant survival space, when it is struck at any location, at any angle, and at any speed up to and including 40 mph.

The subcommittee members are in agreement as to the details shaping this long-overdue standard, which they anticipate will lead to the saving of countless lives in the days and years to come. The following group of individuals participated in the Underride Engineering Subcommittee and are willing to continue to provide input.

Jared Bryson

Malcolm Deighton

Keith Friedman

Aaron Kiefer

Garrett Mattos

Perry Ponder

NOTE: It should be mentioned that this standard has, in fact, been evaluated through research conducted by the Insurance Institute for Highway Safety when they crashed a car at 40 m.p.h. into the side of a tractor-trailer equipped with AngelWings side guards on August 29, 2017, during the Second Underride Roundtable at their Ruckersville, Virginia, testing facility.

There was no underride, no Passenger Compartment Intrusion (PCI), and the crash dummy data showed that it was survivable. In other words, this standard is not pie-in-the-sky; it has been proven that the Consensus Side Guard Standard is attainable.

Crash test at 40 mph into AngelWings side guards, August 29, 2017, during the Second Underride Roundtable at the Insurance Institute for Highway Safety

UPDATE: Protecting Passenger Vehicles from Side Underride with Heavy Trucks More research on side underride was published by SAE International in April 2021 — following a presentation by Garrett Mattos of the Friedman Research Center at a SAE Conference. Hopefully, the Department of Transportation now has enough research to make good on their March 19, 1969 intention to add underride protection to the sides of large vehicles.

Utility Trailers Encourages Retrofit of Rear Impact Guards To Prevent Underride

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Last evening, I received some amazing news! Utility Trailer Manufacturing has announced that their improved Rear Impact Guard (RIG) will be offered at a discount.

Utility “is pleased to announce its dry vans, refrigerated vans and flatbeds produced after 2002 can be retrofitted with Utility’s standard 7” deep horizontal Interstate Commerce Commission (I.C.C.) bumper. . .

“Utility strongly recommends their 7” deep horizontal bumper for horizontal bumper replacement on new or older Utility trailer models that were built after 2002 in order to exceed all rear trailer guard safety regulations. Utility will discount the new bumpers as an incentive to replace the old bumpers with the new upgraded 7” deep bumper. . .

“. . .is also I.I.H.S. certified and TUFF Guard awarded. TUFF Guard awards trailers with guards that prevent underride in all three of the institute’s rear underride tests . . . Utility Implements Standard 7’’ Rear Impact Guard on All Trailer Models

We are hopeful that this bold move will pave the way for all trailer manufacturers to follow suit. These retrofit kits will be available to replace not only damaged RIGs but the RIGs on millions of trailers on the road today which have rear underride guards which are TOO WEAK to stop underride all across the back of the trailer.

Thankfully, there are many RIG retrofit solutions available. This is what I know:

This just goes to show you that, by working together, we can STOP underrides. I’m hoping that 2021 will bring significant progress in underride protection!

FMCSA Proposed Rule For Inspection of Rear Underride Guards

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A red letter day: The Federal Motor Carrier Safety Administration (FMCSA) at long last has proposed a rule to add rear underride guards to Appendix G. What does that mean? It means that rear underride guards will be required to be in good condition in order to pass an annual vehicle inspection. Once the rule is actually issued.

The Public can comment on this proposed rule through March 1, 2021, by going here.

This describes the current status of rear guard inspection requirements, according to FMCSA:

While the FMCSRs have required rear impact guards for more than 65 years, they are not included on the list of components in Appendix G that must be inspected during the annual CMV inspection. This means that a vehicle can pass an annual inspection with a missing or damaged rear impact guard. https://public-inspection.federalregister.gov/2020-27502.pdf

Imagine!

In response to petitions from the CVSA and Jerry and Marianne Karth (“the Karths”1 ); a recommendation included in GAO Report GAO-19-264, “Truck Underride Guards: Improved Data Collection, Inspections, and Research Needed;”2 and Congressional correspondence,3 this rulemaking proposes to amend the FMCSRs to include rear impact guards on the list of items that must be examined as part of the required annual inspection for each CMV.

I have not yet read the whole document, but I am getting ready to do so now in order to make an informed and practical comment. I will definitely recommend that damaged guards be replaced with ones which meet the Insurance Institute for Highway Safety (IIHS) TOUGHGuard level of strength to STOP deadly underride — not merely with an older model which has been proven to be too weak.

Over one hurdle. On to the next.

Proper Maintenance of Underride Guards Can Spell the Difference Between L-i-f-e & D-e-a-t-h

“Chattanoga crash that killed 5 underscores bill to add protective barriers to semi trucks”

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Related post: Retrofit Solutions for Rear Impact Guards to Prevent Deadly Underride

“Chattanoga crash that killed 5 underscores bill to add protective barriers to semi trucks”

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Let’s make truck crashes more survivable!

Related post:Retrofit Solutions for Rear Impact Guards to Prevent Deadly Underride

Retrofit Solutions for Rear Impact Guards to Prevent Deadly Underride

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It is to their credit that nine U.S. trailer manufacturers have improved their rear underride guard design to meet the IIHS TOUGHGuard standard and seven of them are putting it on all new trailers as Standard. What that means is that they have surpassed the current federal standard and have been crash tested to show that they are more likely to prevent underride and catastrophic Passenger Compartment Intrusion (PCI) — thereby more likely to save lives when passenger vehicles rear end tractor-trailers.

See the difference between a too weak and a stronger guard:

Read more here: Recognizing good rear underride protection

Unfortunately, that does not help underride victims who crash into older models with too weak rear underride guards. Until the entire fleet has this stronger protection, people will continue to die from an engineering problem that has already been solved.

Underride Crash Memorials (the tip of the iceberg)

Thankfully, there are retrofit solutions available. This is what I know:

Note: When I called a local truck part company, the person with whom I talked knew nothing about improved rear guard retrofit parts. They were still selling the old model of generic horizontal bumper tubes. In other words, despite the availability of improved guards, many trucking companies are replacing damaged guards with the old model which can’t stop a car in an offset crash.

Save Lives by Lighting up Tractor-Trailers & Tanker Trucks

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Truck drivers can play an important role in making sure that the trailers which they haul are as visible as possible to other drivers on the road — especially at nighttime. On October 15, 2018, Leslie and Sophie Rosenberg lost their lives when they collided with the side of a tanker late at night.

Family members are appealing to the trucking industry — including truck owners and drivers — to install additional lights for improved visibility and to make sure that the required lighting and retroreflective tape are kept clean and properly maintained. It could mean the difference between life and death.

“A tanker truck pulled onto the unlit highway from a side road, crossing three lanes of traffic.  My sister – driving in the rightmost lane – in a mini van plowed into the underside of the tanker … There were no skid marks.  The reason for there being no skid marks is simple:  my sister never saw the tanker. She never saw the tanker because it was painted dark blue and had no lights on the sides that were clean and clearly visible. . .” Forman writes.

Forman goes on to argue that if the tanker had been painted silver and had “lights illuminating the entire outline of the tanker” the crash could have been avoided. Family petitions for more lights, no ‘dark colors’ on big rigs following fatal crash

Read more about their story and petition here:

The family’s petition goes into detail about why it is so important to make large trucks as visible as possible especially at nighttime:

In 2018, 96% of vehicle occupants killed in two-vehicle crashes involving a passenger vehicle and a large truck were occupants of the passenger vehicles. (IIHS, 2019) (Source: https://driving-tests.org/driving-statistics/

In 2018, 37% of all fatal crashes, involving large trucks occurred at night (6:00 pm to 6:00 am). (FMCSA, 2016) (Source: https://driving-tests.org/driving-statistics/

“The main factor related to the driver’s ability to see a crossing truck is target conspicuity, or how well an object stands out from its background. Target conspicuity relies largely on contrast characteristics such as color, movement, brightness, shape and size.

“Most commonly with trucks, the misconception is that their large size by itself makes them conspicuous. At night the size of the trailer by itself will not make it conspicuous since other contrast problems will make the trailer virtually invisible. Without any close-in lighting reflecting off the painted surface of the trailer, it will appear black against the black background. Then an approaching driver will have to rely on the side marker lights for his only cue to the presence of the trailer. However, even with the legal placement of marker lights on the sides of the trailer, approaching drivers will still often not perceive the trailer as an obstruction blocking their path.

“Marker lights are small and can be spaced as far as 26 feet apart on the side of a trailer, not providing on-coming drivers with enough information to determine that what they are looking at is a trailer. Marker lights can be misleading, and without an external light source, trailers are often not identified until the headlights of oncoming vehicles directly illuminate them. When their headlights illuminate the trailer, on-coming drivers will only be 100 to 200 feet away, and unable to stop at higher speeds.”

“Retroreflective tape is very effective in making trailers visually –stand out. However, a truck driver should never assume that the presence of this tape on a trailer will automatically guarantee that the trailer will be seen. If the tape is dirty, badly worn, or if the truck is at a steep angle to traffic, oncoming drivers may not be alerted to the presence of the trailer. The underride hazard is still present. Therefore Lights all around the sides are a much better alternative.”

An in-depth discussion of causes of underride collisions can be found at: crashforensics.com: Truck Underride Collision Analysis

NOTE: This is a very important issue. Having more warning that a collision is imminent will mean that the driver of the passenger vehicle will be more likely to brake and reduce the vehicle speed upon collision. However, this is not an either/or situation. Without adequate underride protection, even at speeds as low as 15 mph, a passenger vehicle can go under the truck — causing catastrophic underride and Passenger Compartment Intrusion injuries.

With both adequate truck conspicuity and underride protection, many lives will be saved.

Truck Driver Mistakes Don’t Excuse Industry & Government Negligence To Solve Underride Problem

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Thanksgiving Eve, another apparent underride victim lost her life: A truck driver is being investigated for his role in a deadly crash Wednesday night at a rural Fresno County intersection, according to the California Highway Patrol. . . The driver of a sedan was eastbound on Lincoln when the truck driver appeared to fail to see the car approaching and entered the intersection directly in the sedan’s path, according to CHP. . . The sedan struck the left side of the big rig’s trailer and the driver of the car was pronounced dead at the scene. She was identified Thursday as Lorene Negrete, 57. . .

The driver of the truck, 29-year-old Pardeep Kumar of Fremont, has cooperated with the investigation but likely will face a charge of vehicular manslaughter, according to the CHP. Update: Truck driver may face manslaughter charge in deadly Fresno County crash, CHP says

Though the truck driver may have made a mistake, not all the blame rests with him for a crash which might have had a different outcome with effective underride protection. Carriers, trailer manufacturers, DOT, & Congress can make these kinds of truck crashes more survivable.

A fully-guarded trailer hits the road – ready to STOP underride!

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Engineering ingenuity and a lot of hard work went into the research, development, and installation of this fully-guarded trailer system. This week, a small carrier in North Carolina became part of our pilot program. We are thankful that they have agreed to provide us feedback on this #SaferTruck as they drive it on the road to carry out their transport business.

What does fully-guarded mean? It means that every part of the trailer — at the rear and both sides — is covered by equipment which has been installed to prevent a car (or pedestrian, biker, or motorcyclist) from going under the trailer in the event of a collision.

This “hybrid” safety system combines devices which have been crash tested to prevent a car from riding under, including an AngelWing metal side guard installed behind the landing gear, a SafetySkirt polyester webbing where the AngelWing ends and extending over the rear axle — fastening to the Rear Impact Guard (RIG) Retrofit attachment, which reinforces and strengthens the existing rear underride guard (otherwise known as a Rear Impact Guard or RIG, ICC Bumper, or Mansfield Bar).

Oh, and did I mention that this system includes a side skirt for fuel savings?

This retrofitted trailer proudly displays the #SaferTruckAward decals:

Underride Crash Victim Memorial Posts

Fully-guarded trailer
View from under the trailer of SafetySkirt attached to Rear Impact Guard Retrofit
RIG Retrofit plus SafetySkirt

AngelWing side guard in action:

Memorials of Underride Crash Victims

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Because the bottom of a truck is higher than the bumper of passenger vehicles, when there is a collision the smaller vehicle easily slides under the truck and the first point of impact is the windshield — resulting in underride and passenger compartment intrusion (PCI). Seatbelts, airbags, and car crumple zones do not function as intended in underride crashes — front, side, and rear — leaving passenger vehicle occupants vulnerable to life-threatening injuries.

This geometric mismatch has been misunderstood for decades. Reports on truck crashes generally focus on the cause of the crash and not what caused the deaths. So underride is undercounted. I know this from firsthand experience having been in a truck crash (but not in the part of the car which went under the truck) and lost two daughters because of underride (one of whom was not reported as such in DOT data).

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. 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.

Basic Underride Information

Certified Letters Alert 200 Carriers of Underride Dangers & Solutions