Category Archives: Truck Safety

Understanding Underride VII: Cost/Benefit Analysis

Truck Safety, , , ,

A panel of experts discuss underride at a Briefing on The Hill, October 12, 2017, to bring greater understanding of the problem and solutions of deadly but preventable truck underride. Jason Levine, Director of the Center for Auto Safety, discusses the flaws in the cost/benefit analysis of truck underride protection.

For more information on the STOP Underrides! Act of 2017, go to https://annaleahmary.com/ and/or https://stopunderrides.org/

Here are some further thoughts on cost benefit analysis related to underride protection:

  1. “Even if cost-benefit analysis is theoretically a neutral tool. . . it is biased against strong public protections.”Recently, NHTSA announced statistics for 2016 traffic fatalities:
    • 37,461 people killed in crashes on U.S. roadways in 2016
    • Up 5.6% from 2015
    • Tucked in the back of the report, if you look for it, you will see that there were 4,317 fatalities in crashes involving large trucks — up 5.4% from 2015, the highest since 2007. . .

  2. Public Comments on Underrride Rulemaking & Cost/Benefit Analysis: Public Comments Re: Cost/Benefit Analysis in NHTSA Proposed Underride Rulemaking on Rear Guards for Tractor-Trailers & for Single Unit Trucks and       Current NHTSA #Underride Rulemaking (Cost/Benefit Analysis): Summary of Public Comments and https://annaleahmary.com/2016/10/dot-omb-are-you-using-cea-or-cba-rulemaking-road-to-zero-requires-vision-zero-rulemaking/

  3. Jerry Karth’s Public Comments on Underride Rulemaking: Comments on the NPRM for Rear Underride Guards on Trailers and Reflections from a bereaved dad on the Underride Roundtable & what that means for rulemaking

  4. Stoughton improved underride guards–standard “at no cost or weight penalty.”

  5. Underride Statistics 

  6. The Future of Trucking: Who pays for the costs of safer roads?

    I thought about all of this, on a recent trip “back home”, as I reflected on the plight of small trucking companies and independent owner-operator truck drivers. Are the costs of owning a company and the pressure to drive many miles creating a situation where they won’t be able to stay in business?

    Frequently, I hear that changes of one kind or another in the trucking industry–in order to improve safety (i.e., reduce crashes, injuries and deaths)–will result in increased costs for the trucking companies. I hear that it will put them out of business.

    Is this true? According to whom and based on what information? If it is true, then does something need to change in the trucking industry itself in order to allow for the beneficial work, which trucking provides, to continue but to also allow for truckers to make a decent living wage–without jeopardizing their health and the safety of travelers on the roads? . . .  Read more here: The Future of Trucking; Who pays for the costs of safer roads?

  7. Whose lives are you going to sacrifice? If decisive action is not taken to end these preventable deaths, then who should we hold responsible? Whose lives are we thereby choosing to sacrifice?

  8. TTMA: Truck Trailer Manufacturers Association Reminds NHTSA Why Side Guards Are Not Cost Effective, May 18, 2016 post:

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

    I am encouraged by the closing paragraph of the TTMA letter to NHTSA:

    TTMA would support the implementation of side guards if they ever become justified and technologically feasible. We continue to support the NHTSA review of Petitioners’ requests and stand ready to partner in the development of justified and feasible designs if they possibly emerge. Jeff Sims, President

  9. How can we possibly justify allowing Death by Underride to continue when solutions exist to prevent it?, As I allow myself to remember the joy and laughter and love and creativity and grumpiness and irritability and silliness of my daughters, AnnaLeah and Mary, I also remember why I am working tirelessly to bring an end to Death by Underride — which snatched AnnaLeah from this earthly life on May 4, 2013, and Mary on May 8, 2013. I was in that horrific truck crash four years ago today. I survived but they did not because of Death by Underride. . .
  10. Mandates take burden off manufacturers. Crash tests in labs better than crash tests occurring in real world., Lou Lombardo has written a thought-provoking opinion piece, Creating a Demand for Crash Testing (CTTI, September 2011). It holds great value in confirming the need for comprehensive underride protection legislation to be introduced and passed in a timely manner. . .
  11. They fought the good fight, they finished the race. . .
  12. Every Day’s A Holiday With Mary; Joyful Memories of Mary
  13. Amazing Grace Goodbye, AnnaLeah & Mary, With Love From Grandpa
  14. Truck Industry Leaders: “Clarity is probably the biggest need we have so we can plan accordingly.”
  15. AnnaLeah Karth. May 15, 1995 – May 4, 2013. Death by Underride.

Understanding Underride VI: Maintenance of Underride Equipment

Truck Safety,

Recently, I reviewed proposed language for the “Maintenance Section” of the STOP Underrides! legislation [previously known as the Roya, AnnaLeah & Mary Comprehensive Underride Protection Act of 2017]. Working to accurately spell out what was important to include in requirements for proper maintenance of rear underride guards made me realize how imperative it is that the basic problem of underride be better understood.

A true appreciation of the fundamental underride issue could, in fact, lead to a better grasp of what is at stake if an underride guard is not properly maintained. So that is what I hope to foster here. Because this is not a simple matter of keeping a machine functioning so it can continue to drive down the road; it is a matter of maintaining the integrity of a piece of equipment which can, hopefully, prevent sure death or debilitating injury.

Where does maintenance come into the picture? If you have a piece of equipment which is supposed to guard against deadly underride  — if designed in a particular way (and that includes how it is attached to body of the truck), then it would need to be maintained in such a way that it would continue to provide that same strength.

Herein lies the problem. The current rear underride guards on existing trucks might do what they are supposed to in some collisions and successfully prevent underride. However, if the guards (and their attachments to the trucks) are not properly maintained in like-new condition, then their integrity will be compromised and their strength will be weakened. Underride will be even more likely to occur, and people will die as a result.

And this is the reality for the millions of existing large trucks on the road today. As far as I can see, from simple observation when driving on the highways, many of the rear underride guards are not being properly maintained. Of course, this will be important for the newer, stronger guards, too, as they begin to be installed on new trucks or retrofitted to existing trucks.

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

A real-life crash between a semi-trailer & 2 cars shows the life & death difference which underride makes.

Truck Safety, , ,

A real life crash, where two cars collided with a semi-trailer, occurred in the Chicago area on October 16, 2017. One driver died; the other driver survived.

The 38-year-old driver of the Jaguar and the 27-year-old driver of the semi-tractor were each transported to area hospitals with non-life threatening injuries. The driver of the Envoy was pronounced deceased at the scene. 2 Dead, 1 Critically Injured in Aurora Crash Involving Semi

I don’t have proof yet, but it appears to me that the driver who survived may have done so because his car (the white Jaguar) hit the trailer tires, which activated the crush zone of the car and prevented underride ( or Passenger Compartment Intrusion = PCI). The driver of the other car was not so fortunate, the first point of impact was probably in his occupant space.

Underride Briefing on The Hill; Video Excerpts of Panel Discussion on October 12

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On October 12, 2017, staff from Congressional Offices gathered to hear presentations from five experts on the topic of truck underride. The presentations were followed by a question & answer period as legislative staff sought to understand the problem and solutions of deadly but preventable underride crashes.

The STOP Underrides! Act of 2017 has been drafted by Senator Kirsten Gillibrand. She is working with Congressman Steve Cohen, who will be drafting a House Companion Measure.  They are both seeking Republican co-leads for this long-overdue, life-saving legislation.

The videos below cover the individual presentations but, unfortunately, the question period was not recorded. Questions about any of the topics covered can be directed to marianne@annaleahmary.com, for follow-up with these and other experts nationally and internationally.

This video includes all five presentations:

Malcolm Deighton, engineer with Hydro (formerly Sapa), discusses their aluminum rear underride guard — successfully crash tested at 40 mph:

Jason Levine, Director of the Center for Auto Safety, discusses the flaws in the cost/benefit analysis of truck underride protection:

Robert Lane, VP of Product Engineering at Wabash National — a trailer manufacturer, discusses their commitment to development of rear and side underride protective devices for the prevention of underride deaths and debilitating injuries:

Matt Brumbelow, a research engineer at the Insurance Institute for Highway Safety (IIHS), discusses the problem of truck underride and the research which IIHS has done to study rear and side underride protection:

Keith Friedman, Friedman Research Corporation, discusses Front Underride Protection:

Further information on truck underride can be found at:

Hosted by Lois Durso (https://stopunderrides.org/) and Marianne Karth (https://annaleahmary.com) who are working to STOP Underrides! in memory of their daughters — Roya Sadigh and sisters AnnaLeah & Mary Karth.

Large trailer manufacturers built 340,000 in 2015. How many purchased in 2017 will have strong rear guards?

Truck Safety, , ,

Some of the trailer manufacturers are offering the new stronger rear underride guard as standard to their customers on their new trailers. Some are not. Why is that? If the new guards have been proven to be safer, why still sell trailers with the weaker, ineffective rear guards which — if involved in a crash — could so easily lead to Death by Underride?

I wonder how many trailers have been sold with the newer guards which meet the IIHS ToughGuard award standards. I know that one transport company, J.B. Hunt, ordered 4,000 of the improved Wabash trailers in January 2016. But the stronger guard is not yet standard on Wabash trailers. So, what percentage of the total new purchases is that?

According to Trailer Body Builders, “THE 25 largest trailer manufacturers in North America built some 340,000 truck-trailers and container chassis in 2015, a 16.6 percent increase over the preceding year.” So J.B. Hunt’s order would have been 1.2% of the total truck-trailer and container chassis purchases for that year.

What about the other 336,000 trucks potentially purchased last year? Did they have safer rear underride guards? (And how long will they stay in the fleet?) I know that they did not have side guards. And that is not even mentioning the millions of existing trucks on the road which are Death by Underride waiting to happen — especially because many of them are not properly maintained.

If only the industry would voluntarily take the initiative to make it right and correct their defectively-designed products by making sure that every truck on the road had the best possible underride protection. New and existing.

I find it interesting that at least some in the industry are thinking comprehensively about some aspects of safety technology. . .

Powell said his first advice when talking with fleet customers (Velociti specalizes in “technology deployment services”) is to suggest they “synergize” their technology adoption efforts in order to make them more complete and easier to handle. For example, he said, if your fleet is looking at putting collision avoidance systems on your trucks, why not put them on your yard tractors and forklifts at the same time?

Likewise, instead of dividing the tasks of putting different safety systems on vehicles such as electronic logging devices, in-cab camera systems, and lane-departure warning systems, treat all those initiatives as a single, unified action plan. Fleets Share Best Practices on Implementing New Technologies Looking at technology as a problem-solver first can go a long way toward its successful deployment in real-world fleet operations.

See, the industry understands the logic of approaching safety technology with a COMPREHENSIVE strategy! Now if only they would apply that by including comprehensive underride protection in the Super Truck Project!

Perfect Opportunity to Transform SuperTruck Into An ESV To Advance Underride Protection; DOT & DOE?

How many more people have to die from Death by Underride before “we” do something about it?!

Truck Safety,

Recently, NHTSA announced statistics for 2016 traffic fatalities:

  • 37,461 people killed in crashes on U.S. roadways in 2016
  • Up 5.6% from 2015
  • Tucked in the back of the report, if you look for it, you will see that there were 4,317 fatalities in crashes involving large trucks — up 5.4% from 2015, the highest since 2007.
  • Of those, 722 (16.7%) were occupants of large trucks and 10.8% were nonoccupants.
  • 72.4% of the truck crash fatalities were occupants of other vehicles, or 3,125.5 (Do I round that up to 3126? Now that really bothers me because this is about people who died in a crash with a truck last year and not merely statistics!)

If you look at NHTSA’s press release, here is their summary:

The 2016 national data shows that:

  • Distraction-related deaths (3,450 fatalities) decreased by 2.2 percent;
  • Drowsy-driving deaths (803 fatalities) decreased by 3.5 percent;
  • Drunk-driving deaths (10,497 fatalities) increased by 1.7 per­cent;
  • Speeding-related deaths (10,111 fatalities) increased by 4.0 percent;
  • Unbelted deaths (10,428 fatalities) increased by 4.6 percent;
  • Motorcyclist deaths (5,286 fatalities – the largest number of motorcyclist fatalities since 2008) increased by 5.1 percent;
  • Pedestrian deaths (5,987 fatalities – the highest number since 1990) increased by 9.0 percent; and
  • Bicyclist deaths (840 fatalities – the highest number since 1991) increased by 1.3 percent.

Do you see the 4,317 truck crash fatalities mentioned there? I don’t! Yet they accounted for 11.5% of the total traffic fatalities.

Is that indicative of what I continue to observe year after year — that truck crash fatalities are considered merely a transportation issue and left to the trucking industry to solve? And so potential lives saved always lose out in any cost/benefit analysis because “CBA is weighted in favor of the regulated industry and against health, safety and environmental protections”.

And we all know who ends up paying the price for this unresolved public health & safety crisis.

“Even if cost-benefit analysis is theoretically a neutral tool. . . it is biased against strong public protections.”

Truck Safety, , ,

Recently, NHTSA announced statistics for 2016 traffic fatalities:

  • 37,461 people killed in crashes on U.S. roadways in 2016
  • Up 5.6% from 2015
  • Tucked in the back of the report, if you look for it, you will see that there were 4,317 fatalities in crashes involving large trucks — up 5.4% from 2015, the highest since 2007.
  • Of those, 722 (16.7%) were occupants of large trucks and 10.8% were nonoccupants
  • 72.4% of the truck crash fatalities were occupants of other vehicles, or 3,125.5 (Do I round that up to 3126? Now that really bothers me because this is about people who died in a crash with a truck last year and not merely statistics!)

If you look at NHTSA’s press release, here is their summary:

The 2016 national data shows that:

  • Distraction-related deaths (3,450 fatalities) decreased by 2.2 percent;
  • Drowsy-driving deaths (803 fatalities) decreased by 3.5 percent;
  • Drunk-driving deaths (10,497 fatalities) increased by 1.7 per­cent;
  • Speeding-related deaths (10,111 fatalities) increased by 4.0 percent;
  • Unbelted deaths (10,428 fatalities) increased by 4.6 percent;
  • Motorcyclist deaths (5,286 fatalities – the largest number of motorcyclist fatalities since 2008) increased by 5.1 percent;
  • Pedestrian deaths (5,987 fatalities – the highest number since 1990) increased by 9.0 percent; and
  • Bicyclist deaths (840 fatalities – the highest number since 1991) increased by 1.3 percent.

Do you see the 4,317 truck crash fatalities mentioned there? I don’t! Yet they accounted for 11.5% of the total traffic fatalities.

Is that indicative of what I tend to observe — the truck crash fatalities are considered a transportation issue and left to the trucking industry to solve? And so potential lives saved always lose out in any cost/benefit analysis, and we all know who ends up paying the price for this unresolved public health & safety crisis.

Along that line, check out this interesting read about cost/benefit analysis (which agencies have to do in rulemaking) related to safety regulations. . . https://www.foreffectivegov.org/node/2332

Even given the many uncertainties of cost-benefit analysis, proponents still argue that it acts as a neutral tool. Yet, as David Driesen points out, “if CBA only makes regulation weaker, and never strengthens overly weak regulation, it cannot improve priority setting and consistency in the manner its proponents envision.” Driesen lays to rest the argument of CBA’s neutrality by dissecting the use of CBA both in practice and theory. Driesen finds that both in OMB’s implementation of cost-benefit analysis as well as in the assumptions of the cost-benefit analysis itself, CBA is weighted in favor of the regulated industry and against health, safety and environmental protections.
 
Driesen focuses his look at cost-benefit analysis on the role of the Office of Information and Regulatory Affairs (OIRA), a subagency of the Office of Management and Budget (OMB) charged with carrying out cost-benefit analysis through Executive Order 12866. According to a Government Accountability Office (GAO) report, between June of 2001 and July of 2002, OMB “significantly affected 25” environmental, health and safety regulations. If cost-benefit analysis is in practice a neutral tool, then OIRA’s use of cost-benefit analysis to review regulation would sometimes strengthen protections and sometimes weaken them. Driesen found that none of OIRA’s changes made environmental, health or safety protections more stringent, and 24 out of the 25 weakened protections. Even if cost-benefit analysis is theoretically a neutral tool, in the hands of this administration, it is certainly biased against strong public protections.
 
 OMB tends to see cost-benefit analysis as a criterion under which the cost of implementing a regulation can never exceed the benefit. Another option is that cost-benefit analysis is used as a criterion under which cost must always equal benefit, optimizing the efficiency of the regulation. Driesen shows that in each case cost-benefit is not a neutral tool and will always favor the regulated community over the health, safety and environmental regulation.
 
Previous posts on this issue:

Lawmaker first to publicly back truck underride bill written by grieving moms

Truck Safety, , , , ,

Thank you, Congressman Mark DeSaulnier, for your strong commitment to ending truck underride tragedies.

Senator Gillibrand Directs Pointed Questions on Underride to Federal Highway Administration Nominee

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Senator Gillibrand asked Paul Trombino — in his nomination hearing for the position of Administrator of the Federal Highway Administration (FHWA) — some pointed questions about the underride problem. Her questions to him included asking whether he was aware that the IIHS had successfully crash tested a side guard at 40 mph in August and whether he would commit to studying the issue and responding to her within three months if he was appointed to that position.

Go, Senator Gillibrand! Thank you for drawing attention to this and asking for tangible action.

 

Video Links from the Second Underride Roundtable at the IIHS on August 29, 2017

Truck Safety, , , ,

The Insurance Institute for Highway Safety once again did a fantastic job of hosting the Underride Roundtable. They have now provided us with links to the Second Underride Roundtable held at the IIHS Vehicle Research Center in Ruckersville, Virginia, on August 29, 2017. Here is the agenda, followed by the videos:

Truck Underride Roundtable 2 – Morning Session, Part 1:

 

Truck Underride Roundtable 2 – Morning Session, Part 2:

 

Truck Underride Roundtable 2 – Side Guard Panel:

 

Truck Underride Roundtable 2 – Industry Response and Crash Avoidance Panel:

 

Side Guard Crash Test at 40 mph on August 29, 2017:

 

Side Underride & Side Guard Crash Tests at 35 mph at IIHS on March 30 & 31, 2017: