Category Archives: Truck Safety

Should the trucking industry be concerned about underride legislation?

Truck Safety

After a phone call with a congressman’s office the other day, I thought that it would be a good idea to put the question out on the table for some honest conversation: What is it going to cost the trucking industry to install effective comprehensive underride protection?

Without going into the exact cost/truck, here are some of my observations about the impact of a comprehensive underride protection mandate:

  1. Fuel savings from combining side skirt and side guard can be significant. The AngelWing side guard has already had SmartWay testing.
  2. Current weight of AngelWing is 800 lbs. and a very small percentage of 80,000 lb. limit–1%. They plan on working to decrease that weight. http://airflowdeflector.com/home/airflow-2/
  3. Aaron Kiefer’s TrailerGuard system weighs closer to 300 lbs (.375% of 80,000 lbs.).: https://www.collisionsafetyconsulting.com/
  4. In an off the record phone conversation with a trailer manufacturer CEO  a month or so ago, he told me that he (as a trailer manufacturer) will welcome a mandate because it will take the burden off of the manufacturer to have to persuade their customers to put on underride safety equipment.
  5. When we met with a congressman a few weeks ago (who also holds a CDL), he suggested a possible credit at weigh stations for extra weight of side guards.
  6. In the Truck Trailer Manufacturers Association TTMA letter to NHTSA on May 13, 2016

    I was 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 Simms, President

    https://annaleahmary.com/2016/05/truck-trailer-manufacturers-assn-reminds-nhtsa-side-guards-are-not-cost-effective-says-who/:  TTMA_Side_Impact_Main_Comment_2016-05-13TTMA_Side_impact_Exhibits_A-D_2016-05-13

  7. IIHS just tested the 6th major manufacturer’s improved rear guard. They have offered to test manufacturer’s side guards. Two have said they are working on a design.
  8. The industry is responding, but pressure is still needed to address the problem decisively, comprehensively, and quickly. Time is of the essence to save lives. And that includes retrofitting of existing trucks.
  9. Fuel savings from trucks with side skirts/guards. Could be $20,000/yr.  https://annaleahmary.com/2017/02/perfect-opportunity-to-transform-supertruck-into-an-esv-to-advance-underride-protection-dot-doe/ and https://annaleahmary.com/2017/02/doe-pours-millions-into-supertruck-fuel-savings-research-projects-0-devoted-to-side-underride-protection/
  10. Some have estimated a 2 yr. ROI for side guards.
  11. Congressman LaMalfa proposed a tax repeal for purchase of new trucks. This could help offset the costs:  the 12-percent Federal retail excise tax routinely adds between $12,000 and $22,000 to the cost of a heavy truck, tractor, or trailer. Read about it here: http://www.truckinginfo.com/channel/fleet-management/news/story/2017/06/house-bill-would-repeal-heavy-truck-federal-excise-tax.aspx and https://annaleahmary.com/2017/06/would-this-truck-tax-savings-cover-cost-of-comprehensive-underride-protection-for-a-winwin-solution/
  12. With proven effective side guards, there will be a new de facto standard. If trucking companies experience a collision with an underride death, the liability could put smaller companies out of business. Effective comprehensive underride protection can prevent these catastrophic outcomes to many truck crashes which end in life-changing tragedies for more than just the victim.
  13. Effective underride protection is more likely to result in a truck which can be used more quickly after a collision.
  14. Stoughton Trailers was able to produce a more effective rear guard on new trucks with no added cost or weight penalty to their customers.
  15. What about a tax credit for early adopters of underride technology before the compliance date?
  16. Truck Underride 101: Part IV Win/Win

Sounds to me like comprehensive underride protection would be a win/win situation. What do you think?

The Roya, AnnaLeah & Mary Comprehensive Underride Protection Act of 2017:  RAMCUP Draft 15 with Cover

 

 

 

Underride crash in NY this week kills 4; Ball’s in your court, Congress, to end these preventable tragedies.

Truck Safety, , ,

Yet another tragic side underride crash occurred in New York this week. Could crash avoidance technology have prevented the collisions of two cars into the side of a jack-knifed milk tanker? Perhaps.

Could comprehensive underride protection — including side guards — have prevented the tragic outcome of 4 lives abruptly ended? Probably.

When will we take action to mandate and install effective underride protection around every part of large trucks to end these preventable tragedies? The ball’s in your court, Congress.

Let’s get The Roya, AnnaLeah and Mary Comprehensive Underride Protection Act of 2017 introduced and passed. Post haste. No more of this senseless highway carnage.

Ready-to-introduce bill:  RAMCUP Draft 15 with Cover

 

 

Just How Far Have We Come In The 50 Years Since Jayne Mansfield’s Death By Truck Underride?

Truck Safety, , , , ,

June 29 marked the 50th anniversary of Jayne Mansfield’s death by underride. The world knew in 1967 — if it didn’t know it before — about the terrible geometric mismatch between a car and a truck which allowed a car to ride under a truck upon collision.

In those 50 years, how many technological problems have we solved? And yet why have we been unable to solve the problem of truck underride and stem the tide of preventable, horrific, and senseless underride tragedies?

Sure we have made some headway — six trailer manufacturers have upgraded their rear underride guards and there are promising side guard solutions with one of them recently tested by the IIHS. Some manufacturers even have retrofit kits available to replace weak rear guards on existing trailers.

Yet it is well known that more could be done, but hasn’t. And why is that? Why have we been so slow to solve this problem? There are many reasons which could be cited. But the facts are the facts. People are still dying (or suffering catastrophic injuries) at an alarming rate from underride and we are seemingly content to let it continue or address it at a snail’s pace.

Not me. I am not content to take it slow and easy — not when the result is that more people will die because we didn’t act sooner. When we could have.

Take front underride or override for example. Front underride protection is one of the components we are asking for in the Roya, AnnaLeah & Mary Comprehensive Underride Protection Act of 2017 (RAMCUP). People are dying due to lack of adequate front underride protection — just like they are on the sides and rear of trucks.

In Europe, they have requirements to protect against this. Not in the U.S. So what are we waiting for? Well, that’s a good question.

Do we wait until we can reinvent the wheel here and figure it out for ourselves with years of research? Or do we speed up the process by learning from others and encouraging collaboration among relevant stakeholders?

Do we include it in the congressional mandate to the Department of Transportation and ask them to figure it out sooner rather than later? Or do we ask them to solve the side guard problem now and then later on, down the road at some unspecified time in the future, we’ll address the need for front protection?

Well, Lois Durso and I took the bull by the horn and said: We’re sick & tired of waiting. People are dying from underride no matter what part of the truck they are unfortunate enough to collide with. We need to solve every kind of underride problem and we are going to include it all in one big comprehensive piece of legislation. Because it is needed. Because it is long-overdue.

Previous posts on Front Underride Protection:

Don’t re-invent the wheel; establish a formal Committee On Underride Protection (COUP) to oversee the development of recommendations for NHTSA underride regulations.

See the history of underride rulemaking as compiled by IIHS and displayed at the first Underride Roundtable on May 5, 2016, held at the IIHS Vehicle Research Center:

From the RAMCUP bill: 

(d) UNDERRIDE PROTECTION ON THE FRONT OF LARGE TRUCKS
Include front override protection in conformance with the following
specifications:
(1) An EU requirement was introduced in 2000 based on ECE Regulation
93 requiring mandatory rigid front underrun protection defining a rigid
front underrun protection system for trucks with a gross weight over 3.5
tonnes Directive 2000/40/EEC. Studies performed by EEVC WG 14 have
shown that passenger cars can ‘survive’ a frontal truck collision with a
relative speed of 75 km/h if the truck is equipped with an energy absorbing               underrun protection system. Furthermore, these systems could reduce
about 1,176 deaths and 23,660 seriously injured car occupants in Europe
per year. Research shows that the benefits of a mandatory specification for
energy absorbing front underrun protection would exceed the costs, even if
the safety effect of these measures was as low as 5%. European
Commission; Front Underrun Protection Systems [Note: 75 kmh = 46.6028
mph]
(2) Front guards must have 3 levels of resistance; soft front for pedestrians
and cyclists, middle area must be softer than the partner vehicle in crashes
and able to absorb energy such as through crush, and rear area must be
strong and stiff enough to resist underride and rotate high-speed vehicles
away from the truck. Extend the front guard from the truck 600 mm (2 feet) to
give room for a 500 mm (1.6 feet) radius curve to deflect crash partners
including VRU and cars. The extra 600 mm should give 102 km/h or (63 mph)
of protection which would exceed a general goal of 60 mph (100 km/h) — an
average speed for highway crashes in the real world.
(3) NHTSA shall immediately issue an RFP to identify the appropriate
requirements for a front underrun protection standard.

ECE No. 93 FRONT UNDERRUN PROTECTION

Design and Optimization of Front Underrun Protection Device

https://ec.europa.eu/transport/road_safety/specialist/knowledge/vehicle/safety_design_needs/heavy_goods_vehicles_en

Don’t you think that enough is enough?! Let’s make it a priority to tackle the whole underride problem post haste! If we don’t (knowing what we now know), then who should we hold responsible for the thousands of people who will most surely die from preventable underride?

No compromise. Too many have already paid the price for 50 years of compromise.

How Far Have We Come In The 50 Years Since Jayne Mansfield’s Death By Truck Underride?

Truck Safety, , , , , , ,

June 29 marked the 50th anniversary of Jayne Mansfield’s death by underride. The world knew in 1967 — if it didn’t know it before — about the terrible geometric mismatch between a car and a truck which allowed a car to ride under a truck upon collision.

In those 50 years, how many technological problems have we solved? And yet why have we been unable to solve the problem of truck underride and stem the tide of preventable, horrific, and senseless underride tragedies?

Sure we have made some headway — six trailer manufacturers have upgraded their rear underride guards and there are promising side guard solutions with one of them recently tested by the IIHS. Some manufacturers even have retrofit kits available to replace weak rear guards on existing trailers.

Yet it is well known that more could be done, but hasn’t. And why is that? Why have we been so slow to solve this problem? There are many reasons which could be cited. But the facts are the facts. People are still dying (or suffering catastrophic injuries) at an alarming rate from underride and we are seemingly content to let it continue or address it at a snail’s pace.

Not me. I am not content to take it slow and easy — not when the result is that more people will die because we didn’t act sooner. When we could have.

Take front underride or override for example. Front underride protection is one of the components we are asking for in the Roya, AnnaLeah & Mary Comprehensive Underride Protection Act of 2017 (RAMCUP). People are dying due to lack of adequate front underride protection — just like they are on the sides and rear of trucks.

In Europe, they have requirements to protect against this. Not in the U.S. So what are we waiting for? Well, that’s a good question.

Do we wait until we can reinvent the wheel here and figure it out for ourselves with years of research? Or do we speed up the process by learning from others and encouraging collaboration among relevant stakeholders?

Do we include it in the congressional mandate to the Department of Transportation and ask them to figure it out sooner rather than later? Or do we ask them to solve the side guard problem now and then later on, down the road at some unspecified time in the future, we’ll address the need for front protection?

Well, Lois Durso and I took the bull by the horn and said: We’re sick & tired of waiting. People are dying from underride no matter what part of the truck they are unfortunate enough to collide with. We need to solve every kind of underride problem and we are going to include it all in one big comprehensive piece of legislation. Because it is needed. Because it is long-overdue.

Previous posts on Front Underride Protection:

Don’t re-invent the wheel; establish a formal Committee On Underride Protection (COUP) to oversee the development of recommendations for NHTSA underride regulations.

See the history of underride rulemaking as compiled by IIHS:

From the RAMCUP bill: 

(d) UNDERRIDE PROTECTION ON THE FRONT OF LARGE TRUCKS
Include front override protection in conformance with the following
specifications:
(1) An EU requirement was introduced in 2000 based on ECE Regulation
93 requiring mandatory rigid front underrun protection defining a rigid
front underrun protection system for trucks with a gross weight over 3.5
tonnes Directive 2000/40/EEC. Studies performed by EEVC WG 14 have
shown that passenger cars can ‘survive’ a frontal truck collision with a
relative speed of 75 km/h if the truck is equipped with an energy absorbing               underrun protection system. Furthermore, these systems could reduce
about 1,176 deaths and 23,660 seriously injured car occupants in Europe
per year. Research shows that the benefits of a mandatory specification for
energy absorbing front underrun protection would exceed the costs, even if
the safety effect of these measures was as low as 5%. European
Commission; Front Underrun Protection Systems [Note: 75 kmh = 46.6028
mph]
(2) Front guards must have 3 levels of resistance; soft front for pedestrians
and cyclists, middle area must be softer than the partner vehicle in crashes
and able to absorb energy such as through crush, and rear area must be
strong and stiff enough to resist underride and rotate high-speed vehicles
away from the truck. Extend the front guard from the truck 600 mm (2 feet) to
give room for a 500 mm (1.6 feet) radius curve to deflect crash partners
including VRU and cars. The extra 600 mm should give 102 km/h or (63 mph)
of protection which would exceed a general goal of 60 mph (100 km/h) — an
average speed for highway crashes in the real world.
(3) NHTSA shall immediately issue an RFP to identify the appropriate
requirements for a front underrun protection standard.

ECE No. 93 FRONT UNDERRUN PROTECTION

Design and Optimization of Front Underrun Protection Device

https://ec.europa.eu/transport/road_safety/specialist/knowledge/vehicle/safety_design_needs/heavy_goods_vehicles_en

Don’t you think that enough is enough?! Let’s make it a priority to tackle the whole underride problem post haste! If we don’t (knowing what we now know), then who should we hold responsible for the thousands of people who will most surely die from preventable underride?

No compromise. Too many have already paid the price for 50 years of compromise.

Animated Illustration of Airflow Deflector’s AngelWing Side Guard

Truck Safety, ,

Check out this animated illustration of Airflow Deflector’s Angel Wing side guard. . .

I Survived Because Of Stoughton: An improved rear underride guard saved this man from an underride death

Truck Safety, , ,

Stoughton Trailers sent me a copy of their flyer which they will be sharing publicly over the next few months — announcing the wonderful news that Terry Rivet and his passenger, Mark Robinson, survived a truck crash, on March 2, 2017 in New York, because the improved rear underride guard on the new Stoughton trailer stopped their car from going under the trailer, thus preventing an underride tragedy!

At least 3 people injured in pileup on NYS Thruway in Warners, By Samantha House | shouse@syracuse.com , on March 02, 2017 at 1:46 PM, updated March 02, 2017 at 4:38 PM

I Survived Because Of Stoughton

Would this truck tax savings cover cost of comprehensive underride protection for a Win/Win solution?

Truck Safety, ,

Congressman LaMalfa, a member of the House Transportation & Infrastructure Committee, “. . . introduced a bill Tuesday to repeal a 12 percent federal excise tax on heavy trucks originally designed to help pay the cost of fighting World War I a century ago.”

Would this tax savings cover all of the costs of comprehensive underride protection? Just sayin’. . . a Win/Win solution.

A Republican congressman from California introduced a bill Tuesday to repeal a 12 percent federal excise tax on heavy trucks originally designed to help pay the cost of fighting World War I a century ago.

The bill by Rep. Doug LaMalfa, H.R. 2946, called the Heavy Truck, Tractor and Trailer Retail Federal Excise Tax Repeal Act of 2017, now heads to the House Ways and Means Committee for review.

The tax “adds tens of thousands of dollars to truck purchases and directly impacts the cost of food, consumer goods and other products Americans need,” LaMalfa said. “Even worse, truck owners large and small pay this tax whether a truck is driven 100,000 miles or never driven at all, forcing them to pay taxes on an investment that may not be generating any revenue.”  Bill Seeks to Repeal Federal Excise Tax on Heavy-Duty Trucks

Truck Underride 101: Part V. Bipartisan Discussion of Legislative Strategy

Truck Underride 101: Part V. Bipartisan Discussion of Legislative Strategy

Truck Safety, , ,

WHY IS THIS SO IMPORTANT? Because it is not necessarily always the collision of a passenger vehicle with a large truck which causes horrific deaths and injuries but rather the collision of the truck with the passenger occupant space in the SECOND COLLISION which occurs with truck underride. This is what we aim to end.

Becoming educated about underride was not a direction I had planned on going with my life and time. But I have gained a great deal of knowledge related to the fact that AnnaLeah’s and Mary’s deaths (and Roya’s, too, along with countless other individual loved ones) might have been prevented had adequate underride protection been on the truck, into which our sturdy Crown Vic crashed — along with the fact that many more countless, unknown individuals will die unless this country takes decisive action.

This information, along with my unresolved grief due to the frustration of knowing that years have gone by without effective protection, fuels my efforts to work collaboratively to bring about widespread and significant change. It is now my aim to equip everyone with the same information — without the accompanying unwanted grief.

It has actually been encouraging for Lois Durso and I to see the extent of interest from the trucking industry, NTSB, DOT, and Congressional leaders — including both the Senate Commerce, Science & Transportation Committee members and the House Transportation & Infrastructure Committee members. And our meetings and discussions have included both Republican and Democratic Offices.

We have appreciated the degree of engagement in discussion and the enlightenment taking place as we share detailed information about the underride problem and its promising solutions. We are excited to see the needle moving as we continue to push for bipartisan collaboration to get a stand-alone bill introduced and passed in order to end this decades-old public health problem.

V. Bipartisan Discussion of Legislative Strategy

  1. Legislative Process and Discussion Handouts: Bipartisan Discussion RAMCUP Handouts FOR RAMCUP Draft 15 with Cover (knowing that our draft will be fine-tuned to be the best legislative package to achieve our objective); See more information here: 2 Moms, Sick & Tired of Waiting, Draft Truck Underride Legislation 

  2. Non-negotiables for RAMCUP: 

    a. Keep it comprehensive; don’t divide it up into separate bills or amendments or rulemaking.

    b. Mandate the establishment of a committee to oversee underride protection (COUP) rulemaking (include at least two victim advocates).

    c. Specific deadlines for rulemaking timeline (due to The Glacial Pace of Truck Underride Improvements (along with countless other safety issues) )

    d. Research $ to determine the outer limits of underride protection.

    e. Strongly encourage the development of a voluntary truck safety certification program to include certification of underride protection (COUP).

  3. COUP/COUP: Upon reflection, it is my belief that the system for arriving at regulations has been working harder to protect the industry from liability than to protect road users from harm. Furthermore, this has led to a non-transparent process for arriving at appropriate and effective safety measures.
    In stark contrast, the crafting of this bill, the Roya, AnnaLeah & Mary Comprehensive Underride Protection Act of 2017, was based upon extensive research and the gathering of experts and interested parties over the last four years,
    · first of all, at the Underride Roundtable at IIHS on May 5, 2016;
    · secondly, through a follow-up meeting at IIHS on June 24, 2016, to hammer out details of the Rear Underride Guard specifications then submitted to NHTSA on August 8, 2016, and IIHS Underride Test Protocol submitted to NHTSA on December 23, 2016;
    · and third, through a continued discussion among engineering experts which led to the Comprehensive Underride Consensus Petition presented to Secretary Foxx on September 23, 2016 (see attached) — upon which this Bill is based.
    These discussions involved trucking industry representatives, including Ted Scott, VP of Engineering for the American Trucking Associations (ATA), and Gary Fenton, who is VP of Engineering for Stoughton Trailers and Chairman of the Engineering Committee for the Truck Trailer Manufacturers Association (TTMA). Participants also have included engineering experts from universities, international experts in truck underride, and two engineers who have designed side guards which have
    recently been successfully tested.
    In my humble opinion, the interests of this country would best be served if this group would be formally recognized and commissioned to work with NHTSA and to develop the specifications for the final comprehensive underride protection rule. Why re-invent the wheel? Why delay the process any longer than necessary? Wasted time translates into more unnecessary death and life-long grief.         AND
    The COUP truck safety certification program (modeled after the Transport for London FORS) could also be integrated into the comprehensive underride protection vision/scenario/strategy/bill:
    COUP (Certification Of Underride Protection). In order to get fully certified, a trucking company would have to get an award in each aspect of underride protection, including:
    1. Rear (Already introduced by the IIHS with their recent presentation of a ToughGuard award to five trailer manufacturers)
    2. Front
    3. Side
    4. Maintenance of underride devices (annual inspection and training in how to do pre-trip inspections of the devices)
    5. Training for drivers in what to do and not do in terms of parking and U-turns
    6. Other (whatever I am forgetting right now)
    This would be required for ALL trucks, including Single Unit Trucks (Straight, Box).
    I plan to add this aspect to the drafted bill, along with a mandate for establishment of a Committee of Experts to Oversee This.

  4. FORS Fleet Operator Recognition Scheme: It is my recommendation that this comprehensive underride protection mandate work hand in hand with a truck safety certification program and I am taking steps to help the ball get rolling on this.

Truck Underride 101: Discussion Topics

I. When Will We Tackle Truck Underride?

Truck Underride 101: I. When Will We Tackle Truck Underride?

II. Why Comprehensive Underride Protection? 

Truck Underride 101: II. Why Comprehensive Underride Protection?

III. Cost Benefit Analysis, Underride Rulemaking, and Vision Zero

 Truck Underride 101: Part III. Cost Benefit Analysis, Underride Rulemaking, and Vision Zero

IV. Win/Win

Truck Underride 101: Part IV Win/Win

V. Bipartisan Discussion of Legislative Strategy

Truck Underride 101: Part V. Bipartisan Discussion of Legislative Strategy

Truck Underride 101: Part IV Win/Win

Truck Safety, , , , ,

Becoming educated about underride was not a direction I had planned on going with my life and time. But I have gained a great deal of knowledge related to the fact that AnnaLeah’s and Mary’s deaths (and Roya’s, too, along with countless other individual loved ones) might have been prevented had adequate underride protection been on the truck, into which our sturdy Crown Vic crashed — along with the fact that many more countless, unknown individuals will die unless this country takes decisive action.

This information, along with my unresolved grief due to the frustration of knowing that years have gone by without effective protection, fuels my efforts to work collaboratively to bring about widespread and significant change. It is now my aim to equip everyone with the same information — without the accompanying unwanted grief.

When you think about it, this should really be a win/win situation. Here is Truck Underride 101: Part IV Win/Win.

IV. Win/Win

  1. Job Creation Quite simply put, a mandate for comprehensive underride protection (which some members of the manufacturing industry have said would take the burden off of them to persuade their customers to install these safety features) would lead to a demand for equipment which would, in effect, create new jobs.

  2. Fuel Savings/Super Truck Project: 

  3. Underride Protection: RETROFIT 

  4. Second Collision: Crash Avoidance/Underride Protection: What is a “Second Collision”? Read about it here: Second Collision and Underride Protection

  5. BOTH/AND and opposing arguments: This post contains numerous links dealing with the issue of crash avoidance vs underride protection: Preventing deadly crashes doesn’t require Either crash avoidance Or underride guards but Both/And.

Truck Underride 101: Discussion Topics

I. When Will We Tackle Truck Underride?

Truck Underride 101: I. When Will We Tackle Truck Underride?

II. Why Comprehensive Underride Protection? 

Truck Underride 101: II. Why Comprehensive Underride Protection?

III. Cost Benefit Analysis, Underride Rulemaking, and Vision Zero

 Truck Underride 101: Part III. Cost Benefit Analysis, Underride Rulemaking, and Vision Zero

IV. Win/Win

V. Bipartisan Discussion of Legislative Strategy

Truck Underride 101: Part III. Cost Benefit Analysis, Underride Rulemaking, and Vision Zero

Truck Safety, , , ,

Becoming educated about underride was not a direction I had planned on going with my life and time. But I have gained a great deal of knowledge related to the fact that AnnaLeah’s and Mary’s deaths (and Roya’s, too, along with countless other individual loved ones) might have been prevented had adequate underride protection been on the truck, into which our sturdy Crown Vic crashed — along with the fact that many more countless, unknown individuals will die unless this country takes decisive action.

This information, along with my unresolved grief due to the frustration of knowing that years have gone by without effective protection, fuels my efforts to work collaboratively to bring about widespread and significant change. It is now my aim to equip everyone with the same information — without the accompanying unwanted grief.

The reason we are devoting our lives to pounding on this door and asking for change is that our daughters may have lost their lives due to the lack of a Vision Zero policy. A decision which concluded that recommended changes would not be cost effective—in other words, that it would supposedly cost more to implement safety measures than the lives saved would be worth—may have led to lax underride guard standards.

If the best possible protection had been pursued when the regulations were last updated (1996), the trucks on the road today (including the one on the road May 4, 2013) might be much safer to be driving around. Mary and AnnaLeah might even still be around.

So, here is Part III of Truck Underride 101.

III. Cost Benefit Analysis, Underride Rulemaking, and Vision Zero

  1. 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/

  2. 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

  3. Underride Statistics 

  4. 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?

  5. 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?

  6. 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

Truck Underride 101: Discussion Topics

I. When Will We Tackle Truck Underride? Truck Underride 101: I. When Will We Tackle Truck Underride?

II. Why Comprehensive Underride Protection? Truck Underride 101: II. Why Comprehensive Underride Protection?

III. Cost Benefit Analysis, Underride Rulemaking, and Vision Zero

IV. Win/Win

V. Bipartisan Discussion of Legislative Strategy