On Monday, March 8, truck crash victims’ families hosted a news conference to discuss their stories and the recent introduction of the STOP Underrides Act of 2021 — on March 4, 2021 in the Senate and March 8 in the House.
If you missed this important event, here are some useful underride links & resources:
It is a well-known fact that underride crashes (and, therefore, underride deaths and injuries) are undercounted. Investigating officers & reporters can help to improve reporting on underride crashes and deaths. Here are some tips, which we’d like you to consider: Truck Crash Investigation Underride Evaluation Checklist (2021)
We know that the trucking industry has expressed concern about potential operational issues which could occur when side guards are installed on large trucks. In order to address those concerns, we asked several trucking companies to give us feedback about their experience after installing side guards on their tractor-trailers. This is what they told us:
On a Friday afternoon — February 26, 2021 — over 50 people met via Zoom to discuss comprehensive underride protection. The purpose of the meeting was to report on progress which has been made by several subcommittees since an earlier meeting in 2020 — including Industry Engagement, Research, and Engineering Subcommittees.
The goal of the Underride Engineering Subcommittee — to which trailer manufacturers were invited — was to create a Consensus Side Guard Standard which would provide additional insight for the development of a side guard regulation. 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 Task Force went so far as to suggest that the Truck Trailers Manufacturers Association (TTMA) discuss the Consensus Side Guard Standard at their upcoming annual meeting in San Antonio, April 7-10, 2021. We encouraged them to come together in a Joint Agreement to adopt or improve the Consensus Side Guard Standard, as an association, and fast track the manufacturing of side guards by their 80th Anniversary in 2022.
Accept the standard; build a guard.
IIHS successful 40 mph AngelWing side guard crash test, 8/29/17
Zoom Video Recording of the Side Guard Task Force Meeting on February 26, 2021 NOTE: The meeting begins at around 7:00 minutes into the video.
Sean O’Malley, Senior Test Coordinator at the Insurance Institute for Highway Safety (IIHS), gave a presentation at the Side Guard Task Force. He stated that, “Everything we do here, we do to save lives. I wasn’t kidding when I said the rear underride program (ToughGuard) is what I’m most proud of. ” Trailer manufacturers responded to the IIHS creation of a safety marketplace for improved rear underride guards by working to meet the TOUGHGuardAward level of protection at the rear of tractor-trailers. Why then would they not do the same to meet the Consensus Side Guard Standard of protection at the sides of tractor-trailers — particularly since the IIHS supports it with their 40 m.p.h. test?
Underride is underride no matter with what part of the truck you collide — because the bottom of large trucks sit up higher from the ground than the bumpers of passenger vehicles. All the way around.
So now what do we do? Will we wait another 100 years? How many more lives will be sacrificed?
This compelling video will show you why Death By Underride, though unnatural & preventable, still continues.
Trucking companies could demand trailers with side underride guards. Trailer manufacturers could supply trailers with side underride guards. Or the government could mandate side underride guards — ideally with the support of industry because a government law or regulation will place all manufacturers on a level playing field.
Families of underride victims and engineers appealed to trailer manufacturers to take the bull by the horn, embrace the Consensus Side Guard Standard, and move forward with developing and installing side underride guards ahead of government requirements.
Today, I was reflecting on the Side Guard Task Force meeting and a strategy for action going forward. As I was looking up information on an engineer from one of the manufacturers, whom I’d met several years ago, I noticed that the manufacturer is making plans to hire an engineering intern for the Summer of 2021. Beautiful! Brilliant! How about we show this young intern how engineers can save lives.
Imagine engineering students from universities around the nation spending the coming year doing internships or senior capstone projects at trailer manufacturing companies working alongside industry engineers on side underride guard development. Collaboration could take place and serve to more rapidly bring about the development and implementation of long-overdue, life-saving technology.
Note: The Side Guard Task Force meeting on February 26, 2021, was a follow-up to an earlier meeting. 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.
After listening to Andy Young interview Eric Hein about the loss of his son, Riley, in a side underride, participants viewed a photo memorial slideshow of some of the countless underride victims:
Underride Victim Photo Memorial – The Tip of the Iceberg
Some of the many individuals and organizations who have made contributions to the work on underride protection were celebrated in this Underride Hero Hall of Fame video:
Underride Hero Hall of Fame
Note: the video of the complete meeting is an unedited Zoom recording. As excerpts from the agenda are created, Youtube video links will be added.
We know that the trucking industry has expressed concern about potential operational issues which could occur when side guards are installed on large trucks. In order to address those concerns, we asked several trucking companies to give us feedback about their experience after installing side guards on their tractor-trailers.
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.
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
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. . .
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.
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!
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.
It is to their credit that nine U.S. trailer manufacturers have improved their rear underride guard design to meet the IIHS TOUGHGuardstandard 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:
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.
Note (June 2, 2025): And the weak rear guard, as seen on the 2013 Utility trailer crash test above, is still allowed to be sold under NHTSA’s 2022 revised Rear Impact Guard rule. For more on this travesty, read here: New federal rule on truck underride protection does not go far enough.
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.
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.
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/
“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.”
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.
