Category Archives: Truck Safety

Major truck manufacturers have Front Underride Protection designs which can work on American trucks.

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Europe and Australia have underride protection on the front of large trucks. Yet, here in the U.S., there is not much talk about installing front underride protection to stop the horrific devastation which occurs when the front of a truck goes over the top of a car. Why is that?

Well, for one thing, it is not mandated by law in the U.S. whereas it is in Australia and European countries. And because it is not required, the trucking industry is not particularly motivated to use it since they don’t directly benefit from it — although they might change their mind if they look at the whole picture.

And the other thing is that front underride is a vastly misunderstood problem. The general attitude seems to be that it’s not something we can do anything about. Of course, a truck is so much bigger than a smaller passenger vehicle. So if a truck hits your car, you don’t stand a chance. The only thing we can do is try to stop the collision in the first place. Is that true?

Front Underride Protection Brochure 6

As with rear and side underride, we continue to discover appalling facts about the problem of front underrride and how it, too, has been swept under the rug despite available research and technology. Supposedly, there has not been much research done to solve this problem. I’m finding that that’s not the case, after all. Let’s start with these links:

  1. Update on November 23, 2018: Found this pdf from the expert from the European Commission. . . a draft amendment to update the Frontal Underrun Protection regulation. “The amendment is proposed in particular to allow more rounded shape of the cab in light of better aerodynamic performance.”   https://www.unece.org/fileadmin/DAM/trans/doc/2018/wp29grsg/GRSG-115-25e.pdf
  2. IIHS Status Report, August 26, 1989: Front End, Energy-Absorbing Truck Guards Reduce the Risks for Motorists
  3. Australian FUP signed into law on September 16, 2009. Of note are some of the comments in a press release: a) FUP involves an impact barrier of prescribed strength and dimensions that catches or deflects a light vehicle during a collision to stop it sliding under a heavy truck. b) It can either be built in to the structure of the truck, or added on – in some cases replacing the function of a bull bar at the same time. c) By catching or deflecting the light vehicle, its occupant protection systems are then able to work effectively, mitigating injury to the light vehicle occupants. d) The international regulation (United Nations Economic Commission for Europe – UNECE – R 93) that the ADR is based on has been adopted in Europe. It will be adopted by Japan in 2012. It has not been adopted by the United States. e) In 2007, the Department of Infrastructure, Transport, Regional Development and Local Government invited public comment on a Regulatory Impact Statement (RIS) for Underrun Protection. A draft ADR was then developed that took into account local requirements.It is estimated that FUP will provide benefits of over $20 million a year (including lives saved and injuries reduced and averted), once fully implemented.  http://anthonyalbanese.com.au/new-truck-safety-rule-to-save-lives-2
  4. We should be very concerned about the fact that, in a collision, when the FRONT of a truck hits a smaller passenger vehicle — either in a head-on collision or when a truck rear-ends a car — the lack of a front underride protection system (FUPS) means that we are very vulnerable to that truck going over the top of our car. FUPS can change the outcome.
  5. Sapa Front Underride Presentation (international aluminum extrusion company has made FUP in Europe): Sapa Front Underride Presentation

  6. “Fred Andersky, director, customer solutions, controls with Bendix, said at the North American Commercial Vehicle show that every 15 minutes in the U.S., a large truck rear-ends a passenger car.”  https://www.trucknews.com/equipment/bendix-developing-next-gen-safety-systems/1003081127/

    That means there is a potential front override 96 times/day, 672 times/week, 2,912 times/month, and 34,944 times/year! So, tell me why we would not want to have Front Underride Protection (FUP) on trucks in this country!!!

  7. And there are countless head-on collisions every year. I’m not sure how many of those are even being counted as truck underride fatalities.
  8. Andreas Ratzek, a German crash test manager with ADAC, shared this information with us: United Nations Economic Commission for Europe (UNECE) Front Underride Protection Standard from 1993:   http://www.unece.org/fileadmin/DAM/trans/main/wp29/wp29regs/R093e.pdf
  9. EUR-Lex: Access to European Union Law
  10. a link to VC-compat, a European research project that also covers FUP
  11. Raphael Grzebieta shared with us the Australian FUP Standard: Vehicle Standard (Australian Design Rule 84/00 – Front Underrun Impact Protection) 2009
  12. Abstract, “Improvements to highway safety are in continual demand. One of the most severe instances of vehicle collision occurs as a result of vehicle weight and sizing mismatch. The fitment of Front Underride Protection Devices (FUPDs) upon tractor-trailers is studied as a method to improve crash compatibility between passenger vehicles and tractor-trailers involved in head-on highway crashes. While some countries require the use of FUPDs, no such regulation exists in North America. North America’s use of Conventional Tractors also presents a variation to Cab-over Engine Tractors popular in Europe. The distinction presents variations to FUPD design boundary conditions. A three tier design strategy is proposed and implemented in an effort to guide development of FUPDs for improved performance and robustness. Extensive testing is undertaken in establishing guidelines for further development and testing of Front Underride Protection Devices.” from a Canadian Thesis on Front Underride Presentation on Front Underride Protection: https://ir.library.dc-uoit.ca/xmlui/handle/10155/413?show=full
  13. Although Europe has a different design for their Semi-Trucks, we discovered this weekend that Australia has a combination of trucks such as are found in Europe and those manufactured in the U.S. But because they are all required to have FUPS, major truck manufacturers, such as Kenworth, Freightliner, Mack, Mercedes-Benz, etc., have all developed FUPS designs which would work on North American trucks (Canada and the U.S.).
  14. George Rechnitzer, Australian professor shared this with us: “The analysis of FUP requirements has been done decades ago in Great Britain and Europe,  and in our studies in Australia (e.g see my 1993 MUARC report “Truck Involved Crash Study: Fatal and Injury Crashes of Cars and Other Road Users with the Front and Sides of Heavy Vehicles Monash University Accident Research Centre – Report #35 – 1993, download from here: https://www.monash.edu/muarc/our-publications/muarc035. Of course such findings and recommendations could be improved nowadays including the design and use of “large airbags on the front of trucks” – this would clearly need design, crash testing etc. But this should not stop the USA from adopting existing well established FUP designs and principles from Europe, Australia and elsewhere.”
  15. Kenworth Trucks brochure, Kenworth, Safety By Design, August 2019, mentions Front Underride Protection (https://www.kenworth.com.au/wp-content/uploads/2018/08/Kenworth-Safety-Brochure-Aug-2018-Web-Version.pdf): FRONT UNDERRUN PROTECTION SYSTEM (FUPS)
    Designed to prevent a car from being trapped underneath the truck
    in the event of a frontal collision, factory fit FUPS are standard on
    all Kenworth models.
    FUPS also helps to protect against any damage to the truck’s
    steering, thus enabling the truck driver to stay in control.
  16. Notice that last sentence: FUPS also helps to protect against any damage to the truck’s steering. That means not only is the passenger vehicle occupants protected but the truck’s steering is also protected and the truck driver is more likely to be able to stay in control when there is a collision. Win/Win!
  17. I found that same good news in another document shared with us this weekend by George Rechnitzer. The Australian underride regulatory review (which unfortunately does a cost/benefit analysis unfavorable to side underride protection and improved rear protection) approved FUPS (front underride protection system): Aust Regulation Impact Statement for Underrun Protection 2009
  18. From the Nature of the Problem section of that Australian document, p. 13: When an underrun crash between vehicles occurs, there are two noticeable outcomes. The
    first, as described above, is the trauma from the exposure of the smaller vehicle’s occupants to impacts with the interior compartment of their vehicle, occupant protection measures in the smaller vehicle being unlikely to engage. The second is the likelihood of further collisions arising from the loss of control of the heavy vehicle. This follows from damage to the steering or braking components of the heavy vehicle by the smaller vehicle. 
  19. Oh, look! Remember what the Kenworth Trucks brochure said about that: FUPS also helps to protect against any damage to the truck’s steering, thus enabling the truck driver to stay in control.
  20. Then I noticed the crash test manager mention that very thing in the Volvo Youtube video of FUPS crash testing:

  1. Also, Volvo is the first vehicle manufacturer to fit this type of underrun protection system to buses.
  2. From the Background of that Australian document, p. 11: In terms of traffic safety, issues relating to heavy commercial vehicles have drawn considerable attention from policy makers, road safety engineers and the general public.
    For the purposes of this Regulatory Impact Statement (RIS), a heavy commercial vehicle is defined as a goods carrying vehicle with a Gross Vehicle Mass (GVM) greater than 3.5 tonnes. Heavy commercial vehicles have many unique operating characteristics that have an effect on crash severity, such as high gross mass, long vehicle length and relatively long stopping distances. Aggregate data and previous research has shown that crashes involving trucks colliding with passenger cars, motorcycles, bicycles and pedestrians have an increased likelihood of producing a severe injury or fatality. This increase is in large part due to the incompatibility between vehicles due to geometric and mass differences. The compatibility of a vehicle is a combination of its crashworthiness and its aggressivity when
    involved in crashes with vehicles in the fleet. While crashworthiness focuses on the
    capability of a vehicle to protect its occupants in a collision, aggressivity is measured in terms of the casualties to occupants of the other vehicle involved in the collision.
    Crashworthiness is sometimes referred to as self-protection while aggressivity is sometimes referred to as partner-protection.
    Crash incompatibility is of concern in all vehicle-to-vehicle collisions. Heavy commercial vehicle-to-car collisions are one specific aspect of this problem but another one relates to heavy commercial vehicle-to-vulnerable road user collisions, such as motorcycles, bicycles and non-vehicles (ie pedestrians).
    This RIS addresses a particular type of crash event, which is a subset of heavy commercial vehicle crashes and referred to as a “heavy vehicle underrun crash”. A heavy vehicle underrun crash occurs when a passenger car, motorcycle, bicycle or pedestrian slides underneath the front, side, or rear end of a heavy commercial vehicle. 
  3. The terms aggressivity & partner protection, which I have not seen discussed at length in U.S. literature, reminds me of the 2002 American Trucking Associations/Technology Maintenance Council prediction of underride regulations by 2006 — including, Frontal aggressivity regulations (tractors) (estimated). Imagine! The trucking industry has been well aware of the great need to do something about this preventable cause of death.
  4. From the Summary of that Australian document, p. 6: The objective of the Australian Government is to reduce the cost of underrun trauma. To this end, heavy commercial vehicle Underrun Protection (UP) has been investigated since the 1980s in various countries and is now mandatory in the European Union (EU) for commercial vehicles exceeding a GVM of 3.5 tonnes.
    While the heavy commercial vehicle manufacturer or operator would bear the cost of fitting UP, the principal beneficiaries would be other road users and the community generally (through the reduction in the severity of injuries). Therefore, existing market arrangements are not likely to respond to the problem and government intervention of a non-regulatory or regulatory type may be needed. Eight options, both non-regulatory (Options 1-5) and regulatory (Options 6-8), were investigated.
    The provision of Underrun Protection (UP) by self-regulation (Option 1) could be a low cost option and yet is unlikely to generate the high application rate required for new vehicles if underrun trauma is to reduce significantly. This is due to the competitive nature of the industry and because the costs of the option would be borne in the main by the vehicle manufacturer, and subsequently passed onto the operator and consumer, while a significant portion of the benefits would be received by the wider community. 
  5. Also, from the Abstract document, p. 3: The aim of this Regulation Impact Statement (RIS) is to examine whether there is a need for government intervention, to be directed towards new vehicle construction, in order to reduce the trauma from road crashes involving heavy commercial vehicle underrun. These crashes are often severe, because of the incompatibility in both mass and geometry of heavy vehicles and other road users such as passenger cars, motorcycles, bicycles and pedestrians.
    The need for some type of Underrun Protection (UP) was identified. Costs and benefits were estimated for eight possible non-regulatory and regulatory options to introduce UP.  Although self-regulation is very much on the agenda of the road freight transport industry, it was concluded that the level of competition within the industry and the externality of any benefits achieved would not make this an effective option. 
  6. Energy Absorbing Front Underrun Protection for Trucks: Developing a test procedure By Iain Knight
  7. Photo of an Isuzu FUPS: Our front axles now come with FUPS (Front Under-run Protection System) meaning you can safely carry up to 6.5 tonnes over the front axle.
  8. The front underrun protection prevents smaller vehicles in frontal crashes from being dragged under the body of a large truck. In its function as a high-strength steel abutment, it activates the energy-absorbing areas of the body of the advancing vehicle (crumple zones) so that the energy of the collision can be dissipated. See a photo of an FUP by Kirchoff Automotive (Germany): https://www.kirchhoff-automotive.com/products/commercial-vehicles/front-underrun-protection/ 
  9. The Influence of Recent Legislation for Heavy Vehicles on the Risk of Underrun Collisions: Axel Malczyk, Unfallforschung der Versicherer, Berlin
  10. VOLVO’s motto of safety:

    The Volvo brand is the brand that is most linked to safety. The reason is that since its founding in 1927 one of the most important goals of the company has been to make motor vehicles as safe as possible in traffic.

    Many of the safety solutions in use today were first introduced by Volvo. Thanks to the scale of the combined resources of the Volvo Group and Volvo Car Corporation, the companies can invest heavily in research and development on traffic safety.

    Two years ago, Volvo Buses was the first to launch FIP (Front Impact Protection), a reinforced front that increases protection for the driver and guide in a front-end collision. Currently, there are no EU requirements regarding the amount of energy the front of a bus must withstand. However, there is a standard for trucks and Volvo Buses’ FIP withstands energy amounts that exceed the truck requirement by 50%. VOLVOS COACHES FIRST WITH A FRONT UNDERRUN PROTECTION SYSTEM, 2006

  11. So, why did Volvo publicly state at the Road to Zero Coalition, in March 2018, that they would not put Front Underride Protection on trucks unless the government mandates that they do so?!
  12. Here is the STOP Underrides! Bill text for FUP:   https://www.congress.gov/bill/115th-congress/senate-bill/2219/text“(5) ‘front underride guard’ means a device installed on or near the front of a motor vehicle that limits the distance that a vehicle struck in the rear by the vehicle with the device will slide under the front of the striking vehicle.”;

    “(c) Front Underride Guards.—

    “(1) RULE REQUIRED.—Not later than 2 years after the date of the enactment of this section, the Secretary shall issue a final rule requiring all commercial motor vehicles with a gross vehicle weight rating of more than 10,000 pounds manufactured on or after the effective date of the rule to be equipped with front underride guards.

    “(2) REPORT.—Not later than 1 year after the date of enactment of this section, the Secretary shall—

    “(A) complete research on equipping commercial motor vehicles with a gross weight rating of more than 10,000 pounds with a front underride guard to prevent trucks from overriding the passenger vehicle; and

    “(B) submit to the Committee on Commerce, Science, and Transportation of the Senate and the Committees on Transportation and Infrastructure and Energy and Commerce of the House of Representatives a report on the research described in subparagraph (A).

    “(3) RETROFIT REQUIREMENTS.—Not later than 3 years after the date of the enactment of this section, the Secretary shall issue a rule requiring all commercial motor vehicles with a gross vehicle weight rating of more than 10,000 pounds to be equipped with a front underride guard.

    “(4) COMPLIANCE DATES.—

    “(A) IN GENERAL.—Except as provided in subparagraph (B), compliance with each of the rules issued by the Secretary under paragraphs (1) and (3) shall be required beginning on the date that is 1 year after the respective issuance date of each such rule.

    “(B) PHASE-IN.—The Secretary may permit a phase-in period (not to exceed 3 years) pursuant to paragraph (3) for the installation of front underride guards on commercial motor vehicles.

  13. National Transportation Safety Board (NTSB) Front Underride/Override Crash Investigation and underride safety recommendations. See crash photos here and the report here: NTSB Recommended FRONT OVERRIDE PROTECTION In 2010 after Truck OVERRODE 3 vehicles
  14. NHTSA FARS data on front underride deaths (remember, this is an under-reported problem): https://annaleahmary.com/2016/08/truck-underride-deaths-by-type-from-dot-fatality-analysis-reporting-system-fars-1994-2014/
  15. Really, what NHTSA could do is adopt the UNECE 93, FUPS Standard. Novel idea.
  16. annaleahmary.com posts on FUP: https://annaleahmary.com/2017/10/understanding-underride-v-front-underride/and https://annaleahmary.com/tag/front-underride/

21st Century Truck Partnership Third Report mentions front override but not front override protection.

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Just found a 21st Century Truck Partnership Third Report in which SAFETY is mentioned. Front override is also mentioned! I have not yet read every single word, but I see little mention of Front Underride/Override Protection (only crash avoidance technologies).
Here is Chapter 7 from that report. It is entitled, “Safety” (21st Century Truck Partnership — Third Report, 2015).
Please read it with the STOP Underrides Bill in mind (in which Front Underride Protection would be mandated by Congress).
(Note: How is it that I brought up the 21st Century Truck Partnership with NHTSA officials in 2017 but they did not once mention this report!)
p.s. Some quotes:
The review of LTCC cases produced evidence that front override and side underride are significant problems in serious crashes between heavy trucks and light vehicles. Front override and side underride were found in most of the crashes examined. Preliminary estimates from this review are that override occurs in almost three-quarters of crashes involving the front of the truck and in over half of the crashes when the sides of the trucks were struck (Blower and Woodrooffe, 2012).
 
FINDINGS AND RECOMMENDATIONS Finding 7-1. Many safety technologies could be effectively evaluated and demonstrated in a safety-focused program— for example, a Safety SuperTruck similar to the DOE fuel consumption reduction SuperTruck program. 
 
Recommendation 7-1. DOT should consider implementing a Safety SuperTruck program to develop, integrate, and evaluate safety technologies such as cab structural integrity, side curtain airbags, advanced forward warning and collision mitigating systems to help industry attain a more integrated and complete safety package with a view to generating greater purchaser acceptance of safety technology not mandated by law.
 
My posts last year on this:

Mary Barra: “If it’s a safety issue, there should not be a business case calculated.” What about underride?

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I have been wrestling with the question: Does NHTSA do a cost/benefit analysis before issuing a recall on an auto safety defect which has been shown to cause deaths? And if not, then why do they do a cost/benefit analysis to determine whether or not to require underride protection be put on trucks to prevent deadly underride?

And, in general, is the cost/benefit analysis which they have done on underride been flawed? Cost Benefit Public Comments on Underride Rulemaking

 

The Price Of Human Life, According To GM

Cost benefit analysis of safety recalls cspan video footage of GM Ignition Recall Senate Hearing, Mary Barra, CEO at GM

Mary Barra at 0:25: “If there is a safety defect, there is not a calculation done on business case or cost. It’s how quickly we can get the repair. . .whatever needs to be done to make sure the vehicles are safe that our customers are driving.”

Mary Barra at 3:21: “Again, if it’s a safety issue, there should not be a business case calculated.”

The difference is that underride is not about an auto safety defect. It is not about occupant protection on a car, and it is not about occupant protection on a truck. It is about equipment on a truck to protect those who might collide with it. No man’s land in terms of perceived responsibility.

See this description of that dilemma from a Transportation Research Board report titled, The Domain of Truck and Bus Safety Research, May 2017, p. 135:

An added complication for safety technologies is that the beneficiaries of heavy-truck safety are primarily other drivers, not the owners or drivers of the trucks. In a highly competitive business atmosphere, truck buyers are not easily motivated to purchase new technologies solely for the public good. Added equipment must also contribute to their company’s profitability in some way and thereby enable them to compete with other companies that have not purchased the same technologies. For this reason, many new safety technologies that are developed and demonstrated are very slow to be deployed. Those safety devices that do gain widespread acceptance generally have secondary-ancillary functions or capabilities that offer a short-term payback to the buyer.

Given these realities, the federal government plays an important role in the process of introducing new safety technologies into the commercial market. Large demonstration programs, involving broad involvement of all the suppliers of a given technology and all the medium-to heavy-truck manufacturers are essential to creating both a sufficient body of data and evidence that a product or technology performs well, in addition to a sense within the industry that the product will be cost-effective and, therefore, worth buying. It is a difficult task to create this critical mass and one that often only the government can accomplish.

In some cases, regulation may be the only way to achieve significant deployment. Even when there is a general consensus that the total benefits of introduction of a new safety technology would outweigh the total costs, there is still the problem of convincing individual vehicle buyers to pay for societal benefits. A regulatory requirement would level the playing field by requiring all companies to buy the equipment and thus eliminate the competitive financial disparity. Regulations are always controversial. It is extremely difficult to quantify the benefits of a technology before the fact. The Domain of Truck and Bus Safety Research

Another interesting read: The Hidden Benefits of Regulation: Disclosing the Auto Safety Payoff, 1985, Joan Claybrook and David Bollier

What do you think?

@SenatorBurr, the underride problem clearly has not gone away since we discussed it with you 5 years ago.

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We are hoping for another meeting with our senator, Richard Burr. Clearly the underride problem has not gone away since our family met with him five years ago — just a few months after our crash.

Our TV interview, including Senator Burr, on August 13, 2013: https://tinyurl.com/y7ynscpr

Recent underride crashes which have occurred just in the last few days (there may well be more that I have not yet heard about):

Indiana: https://www.wndu.com/content/news/Deadly-crash-on-US-30-in-Kosciusko-County-slows-traffic-498880541.html

Kansas: https://www.kansas.com/news/local/article220852645.html

Michigan: https://wincountry.com/news/articles/2018/oct/30/cass-county-woman-injured-in-crash-with-semi/

Texas: https://www.wcmessenger.com/2018/news/1-killed-in-wreck-on-287-2/

Idaho: https://www.dailyrepublic.com/all-dr-news/solano-news/vallejo/idaho-man-dies-when-car-hits-parked-tractor-trailer-in-vallejo/

Maine: http://www.sunjournal.com/jay-woman-injured-after-running-into-tractor-trailer-in-wilton/

Good News for Traveling Public: “All major trailer makers earn IIHS award for good underride protection”

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The Insurance Institute for Highway Safety announced this week that all eight major trailer manufacturers have now improved their rear underride guards. This is good news for the traveling public.

ARLINGTON, Va. — Seven years after the Insurance Institute for Highway Safety found serious shortcomings in the rear underride guards of most semitrailers, the eight largest North American manufacturers are now making rear guards capable of preventing deadly underride in a range of scenarios. All eight companies earn the IIHS TOUGHGUARD award.

The companies — Great Dane LLC, Hyundai Translead, Manac Inc., Stoughton Trailers LLC, Strick Trailers LLC, Utility Trailer Manufacturing Co., Vanguard National Trailer Corp. and Wabash National Corp. — represent approximately 80 percent of the trailers on the road in the U.S. All but one of them, Manac, had to make changes to its underride guard before they were able to pass the three IIHS tests.

“We’re pleased that all the major manufacturers responded positively to our underride tests,” says David Zuby, IIHS chief research officer. “By improving their guards, these companies have demonstrated a commitment to the safety of passenger vehicle occupants who share the road with their trailers.” . . .

By the time IIHS announced the TOUGHGUARD award last year, 5 of the 8 guards met the criteria.

Since then, Hyundai Translead and Utility have earned the award. Strick now joins them, thanks to a new underride guard that completes the industry’s effort to improve protection against rear underride. . .

See the complete IIHS report here: All major trailer makers earn IIHS award for good underride protection

This is great news, and I am glad for the trailer manufacturers commitment to meet the TOUGHGuard award. But I would have phrased it a little differently myself because I don’t think that this “completes” the industry’s efforts on rear underride.  Still to be done, in my mind:

1. TOUGHGuard rear underride protection become standard on all new trailers — not merely an option.

2. Test the guards to see if they are effective at speeds higher than 35 mph. After all, an aluminum extrusion company has produced a rear underride guard which has been officially and successfully tested at 40 mph.

3. Make retrofit kits available for all trailers at least 10 years back.

4. Install effective rear underride protection on single unit trucks.

5. Enforce the requirement for rear underride guards to be kept in like-new condition because a weakened guard is less likely to perform as needed upon collision.

That is, if we want to prevent rear underride tragedies no matter what truck someone might collide with on the road today or in the years to come. . .

And oh, by the way, the STOP Underrides! Bill would mandate every one of those steps to end preventable underride.

Crash cars from previous crash tests  — one with & one without effective underride protection.