Category Archives: Truck Safety

Thanks to Clarence Ditlow Review of 1981 Underride Rule Sheds Light on Current Rulemaking Concerns

In June 2016, I received a link from Clarence Ditlow to a regulations.gov Federal Register 1981 proposed truck underride rule. As I was reflecting on Clarence’s recent death and his life as a car safety advocate, I remembered that email.

When I was able to locate the email, I realized that I had not fully read the proposed rule, so I took some time this morning to do so and have recorded highlights of that document below. Points or questions not in quotes are my own thoughts.

Because this was a lengthy summary, I am going to include a link for the reader:                “Old Underride Petition”; Highlights of a 1981 Rear Underride Rule

Federal Register Docket and Full Proposed Rule pdf can be found here: Rear Impact Guards/Protection: Docket ID: NHTSA-1996-1827

What I would like to know is whether NHTSA will be reviewing prior documents and research (such as this represents) as well as take into account the impact that advances in technology and knowledge when preparing future underride rulemaking? Just for example, would the crashworthiness of “modern” passenger vehicles (e.g., the installation of air bags) change the conclusions drawn in this document?

I would also like to know what the actual cost/benefit analysis formula was which they used in this document as well as in the current underride rulemaking. Does it take a Vision Zero/Road to Zero approach? And would they think that my daughters were worth saving?

Some of the key points of this 1981 proposed underride rule include:

  1. “The agency had tentatively determined that a better regulation was needed because of the continuing problem of fatalities and serious injuries occurring in accidents involving excessive underride, and because of the absence of efforts by the vehicle manufacturers generally to go sufficiently beyond the BMCS requirement.”

  2. “In 1971, after evaluating cost and accident data and reviewing all information received in response to the notices, NHTSA terminated those rulemaking efforts. The Administrator of the agency concluded that the safety benefits achievable with the particular type of underride guard then contemplated would not be commensurate with the cost of implementing the standard.”

  3. “The agency had estimated that the proposed rule would save 50-100 lives per year at an annual cost to the consumer of $500,000,000 .”

  4. “Most of the implementation costs estimated by NHTSA were related to the increase in guard weight which it thought was necessary to meet the proposed requirements.”

  5. “Efforts to improve underride protection resumed in 1977, after the Auto-Truck Crash Safety Hearing was held by Senator Wendell H. Ford. This hearing was the direct result of a program conducted by the Insurance Institute for Highway Safety (IIHS) in 1976.”

  6. “This program focused on the problem of preventing excessive underride. IIHS performed five tests in which passengers car were crashed into the rear of a typical semi-trailer van.

  7. “In addition, the TTI program tested a hydraulic energy-absorbing guard manufactured by Quinton-Hazell Automotive Ltd. (Quinton-Hazell). (An energy-absorbing guard is one that dissipates the energy of the impact in a controlled manner.)”

  8. “The Quinton-Hazell device was very effective both at preventing excessive underride, reducing occupant injury responses, and reducing damage to the colliding vehicle.”

  9. “Despite their apparent advantages, NHTSA will not mandate the use of energy-absorbing underride devices at this time because the agency feels that they are heavy and costly to use.”
  10. “NHTSA encourages the use of energy absorbing guards in light of their ability to mitigate injuries, as evidenced by the testing and the risk analysis.”
  11. “NHTSA stresses that the requirements set forth in the proposed rule are minimum requirements. If adopted truck and trailer manufacturers and owners would be able to place any type of underride guard — rigid, energy-absorbing, moderate strength, etc. — on their vehicle that meets the requirements of the rule.”
  12. “In light of the results of the risk analysis, however, the agency suggests that manufacturers interested in guards stronger than moderate load design consider using hydraulics or other means to absorb energy rather than merely making the guards more rigid.”
  13. “NHTSA estimates that the proposed requirements could have prevented as many as 80 fatal injuries per year if they had been fully implemented in the period from 1977 to 1979. An even greater number of serious injuries would have been prevented.”

Read the other 80 points here: old-underride-petition

How do you interpret those statements? What does it look like to you? Am I the only one who is appalled at their apparent “washing of their hands” of responsibility for the lives lost due to their negligence in mandating the best possible underride protection?

Even if I were willing to overlook their actions in the past, I am not willing to settle for a future rule to continue this kind of travesty. In conjunction with voluntary improvement in underride protection which we are beginning to see, I want to see effective underride protection installed all around trucks because I know it is possible.

I am convinced that this kind of protection will be near to impossible to attain until this country understands and demands Vision Zero Rulemaking as an essential component of its Road to Zero Coalition strategy.

do-it-president-obamaCar Safety Wars

CBA Victim Cost Benefit Analysis Victim

What will President Trump and the next Secretary of Transportation do about this?

Wondering whether new Sec. of Transportation will have a genuine & effective safety focus

The current Secretary of Transportation, Anthony Foxx, was my first experience with the challenges of making SAFETY truly a priority. His words to us on September 12, 2013, “I promise you will see tangible progress on these issues in a short period of time,” was the springboard for our AnnaLeah & Mary Stand Up For Truck Safety Petition delivered to Washington in May 2014 — one year after our tragic truck crash.

  1. https://www.facebook.com/permalink.php?story_fbid=497001560382363&id=464993830249803 
  2. http://www.wral.com/on-anniversary-of-daughters-deaths-mom-pushes-for-tougher-truck-safety-rules/13615053/
  3. https://www.facebook.com/464993830249803/photos/a.465869083495611.1073741828.464993830249803/514036842012168/?type=1&theater
  4. https://www.facebook.com/464993830249803/photos/a.465869083495611.1073741828.464993830249803/510268305722355/?type=1&theater

I wonder whether the next Secretary of Transportation will be motivated and allowed to have a genuine and effective SAFETY focus.

september-2013-069september-2013-070

Will the next Secretary of Transportation be authorized to carry out Vision Zero Rulemaking?

“Crash Analysis of Front UnderRun Protection Device using Finite Element Analysis” research from India

Truck Front Underrun Protection Research from India:

Crash Analysis of Front under Run Protection Device using Finite Element Analysis, IOSR Journal of Mechanical and Civil Engineering (IOSR-JMCE) e-ISSN: 2278-1684,p-ISSN: 2320-334X, Volume 9, Issue 1 (Sep. – Oct. 2013), PP 49-56 www.iosrjournals.org, Santosh Pandimukkula.,Venkata Narayana Yenugula 1 (Mechanical Departmen,Sreenidhi Institute of Science and Technology/JNTUH, INDIA) 2 (Mechanical Departmen,Sreenidhi Institute of Science and Technology/JNTUH, INDIA)

I. INTRODUCTION

In head-on collisions of bonnet-type cars (sedans, wagons, hatchbacks, etc., here after referred to simply as cars) and heavy trucks, the car often under runs the front of the truck, and the car crew received the serious or fatal injuries. The crash safety performance of the car depends on the way its structural parts interact with the structural parts of the truck. FUPD equipment that prevents the car from under running the truck is obligatory in India. The required strength and ground clearance of FUPDs are specified in the relevant regulations used in India. Accidents between cars and trucks are among the most fatal accidents because of the car under running. This phenomenon leads to serious and fatal injuries for car occupants because of intrusion of the car structure into the passenger compartment. . .

IV. Conclusion

1. Head on collision contribute significant amount of serious accidents due to lack of FUPD in heavy trucks.

2. As per Indian standard IS 14812:2005 regulation the Front Under-run Protection Device is designed using Nx8.0 software and analysed by commercial finite element software and found satisfactory results.

3. The maximum displacement, Von mises stresses and strains under impact load of FUPD bar in different cases are studied to meet the requirements as per IS 14812:2005, and this results are to be compared with experimental results.

4. With the above used CAE tools we can reduce the time and increase the productivity of the design and avoid the costly experimental testing.

5. As per above three results second model is safe, strength and low weight model.

6. We can suggest to automobile industries to keep this type of FUPD to car, gypsy, truck, busses…Etc. which saves the life of passenger with less injury.

Best Protection

Tribute to Clarence Ditlow. . . long-time car safety advocate to whom we owe our gratitude

Fair Warning has provided us with yet another tribute to Clarence Ditlow. . . long-time car safety advocate to whom we owe our gratitude.

The Loss of a Consumer Champion, November 15, 2016

I had very little contact with Clarence. But I did have some correspondence with him this year as I was preparing for the Underride Roundtable and also for the Consensus Document which came out of that.  He shared that he was unable to take on that battle due to some major health issues which he was dealing with at that time.

I received this email from Clarence in June:

We are cleaning  up old NHTSA  rulemaking dockets for which we have paper files. At some point in time after 1995, regs.gov became the official repository for federal agency rulemaking dockets including NHTSA’s.   We are taking a sample of regs.gov dockets each year from 1996 going forward until we are sure we have the point in time at which regs.gov became 100% reliable & we can throw away our paper files from that point.

We stumbled across this docket in our sample & sent it to you & Ben as a courtesy to people with a greater interest in and ability to pursue truck underride than the Center.

I have the belief that if I come across something that may be of interest to others, I send it to them.

Clarence

I replied:

Thank you for carrying out your belief.

Marianne

Thank you, Clarence. For everything.

Thank you

If amber signals are noticed before red ones & could prevent more crashes, why aren’t they standard?

A trucker friend posted on facebook that he is trying to figure out ways to increase the visibility on his truck’s turn signals. He mentioned that studies show that people see the amber lights before the red ones.

So he and his wife (a trucker team) are having the shop install custom Amber strobes hooked into the turn signals. Thank you, Jeff and Linda, for going way beyond compliance to make the roads safer!

https://www.facebook.com/jeff.halling/posts/1076123542508557

How many are doing this? Would it help? If so, why isn’t it standard? Because this simple safety measure, if mandated, could SAVE LIVES.

Read the commentaries below on this issue and then tell me why you think Vision Zero Rulemaking and a National Traffic Safety Ombudsman are not really important to make sure that things like this get addressed in a timely fashion and thus ensure that SAFETY is really the priority!

There has been support for amber signals in America since the 1960s; indeed, in 1963, amber frontturn signals were adopted, replacing white signals, because amber is quickly discerned from the white headlights and reflections of sunlight off chrome. But automakers rejected amber rear signals as “not cost effective.” Preventing crashes with amber turn signals

Imagine that!

Studies show that amber turn signals reduce accidents, yet most signal lamps on the rear ends of North American automobiles, trucks and trailers are red. Why? Because amber’s not legally required, and it’s simpler and cheaper to use red for all rear-facing lamps.

Stern, the automotive writer, is perplexed that NHTSA doesn’t require amber rear turn signals. Amber Rear Turn Signals Are Safer Than Red, But Few Use Them

Both And

Hopeful news despite post-election blues: Working together to make a difference despite differences

The day after the election, I participated in a conference call to plan the Second Underride Roundtable. You see the election results have not stopped a group of people who care about making trucks safer. We are moving forward to again bring together another diverse set of people and organizations in a politics-free attempt to provide better underride protection on trucks.

Of course, that does not mean that we are all on the exact same page with precisely the same goals. But the fact remains that we will be gathering together around the table to discuss real problems and tangible solutions.

And then the day after that, I had the privilege of joining my daughter, Rebekah Chojnacki, via webcam as we presented our family’s crash story and safety advocacy efforts to an undergraduate class at the University of Texas in Arlington. They are learning about what public health is and, on Thursday, they were introduced to a real-life public health problem — truck underride injuries and horrific deaths — and a public health strategy to prevent such tragedies. And along with that, we talked about the public health problem of driver fatigue as well as the stressful life of a truck driver.

I don’t know if this group of students will catch the vision of becoming a pilot project Vision Zero/Traffic Safety community action/advocacy group which could serve as a model for students and citizens nationwide becoming active together in a positive way to make a difference and work to move us toward zero crash deaths and serious injuries.

And I don’t know if UTA will become my host facility to help me organize a Tired Trucker Roundtable. But they might be. Or this might be the inspiration for some other city or university or student or citizen group to take on these goals.

But I do know that my daughter told me that many of them were crying because our story touched them in a deep way. And I do know that many of them asked very relevant and appropriate questions. They got it and after only a simple half-hour presentation.

And if only our country will learn to work with one another — not simply waiting around for someone else to solve the problems — we could make a significant impact.

Here is what I shared with that class: presentation-to-uta-public-health-class

Roads Safer

Well, that felt good to tell about those hopeful things. It became a positive channel of the anger and frustration which I have been feeling increasingly of late toward those who did not take responsibility in a way that could have prevented my daughters’ deaths and, even more, who continue to point the finger of blame at someone else or simply shrug off their part in this quest to prevent ever more unnecessary tragedies.

How To Maneuver Around A Truck Safely; Tips from prof’l truck drivers via FMCSA

Check out these tips for how to maneuver around a truck safely:

How to Maneuver Around a Truck Safely

10.52 a.m. Crown Vic May 4 2013

New rear underride guard is std. at one trailer manufacturer; 4 manufacturers have passed IIHS test

Four trailer manufacturers have passed the IIHS offset crash test with their new rear underride guard designs. Here is a recent article about one of those manufacturers who has made it standard on their newly-manufactured trailers:

Stoughton engineers were challenged to design a guard based on the recommendations of the Insurance Institute for Highway Safety (IIHS). The challenge was met without adding weight, without negatively affecting aerodynamics, and without reducing the robustness of the undercarriage and rear structure. Better yet, the guard is one of only three on the market to pass the difficult 30-degree offset crash test.

Read more here: New under-ride guard is standard

Roads Safer

Read more here:

Lifelong Republican questions party support of industry profit vs bipartisan solutions to save lives

As a lifelong Republican and mom of two who were the innocent victims of Vehicle Safety Wars, I have observed the “Republican” support of Industry Profit rather than Preservation of Human Life.

Republicans generally oppose government involvement and regulation. The problem I have with that is the reality which I have painfully discovered that “safety is not an accident” — it doesn’t just happen by itself. Without rules and regulations and enforcement and justice and requirements, chaos and injury and death are more likely to occur.

I have previously written posts on this topic. . .

Face-to-face with our congressman, George Holding, to discuss truck safety concerns :

I shared with Congressman Holding that I had grown up as a Republican and was quite surprised after our crash to find out that, in general, the Republican party line related to truck safety legislation consistently appeared to be pro-trucking industry and anti-safety. I am puzzled why there cannot be bipartisan solutions to these issues.

https://annaleahmary.com/2014/07/truck-safety-needs-bipartisan-support-protecting-its-citizens-is-one-of-the-basic-purposes-of-government/ [I would have to say that I prefer smaller government. But I do think that protecting its citizens is one of the basic purposes of government. “Truck safety” is, for the most part, about protecting travelers on the road. It is a public health problem and should get bipartisan support. http://www.laissez-fairerepublic.com/benson.htm]

His response — a typical one — was that Republicans generally oppose government involvement and regulation. The problem I have with that is the reality which I have painfully discovered that “safety is not an accident” — it doesn’t just happen by itself. Without rules and regulations and enforcement and justice and requirements, chaos and injury and death are more likely to occur.

At least I have not seen a better alternative. Have you? . . 

Delivery of a Vision Zero Petition to Washington; What I have learned in our battle for safer roads:

Due to the complexity of the issue, no one is currently held accountable, responsible, or liable for preventing these deaths which occur upon collision of a passenger vehicle with a larger commercial motor vehicle. Remember, we are not talking here about who was to blame for the collision occurring in the first place.

Can we possibly find our way to work together in our great nation through the Executive, Legislative, and Judicial branches of our government–in a cooperative, concerted effort with private industry, research engineers, safety advocates, and the insurance industry– to bring about the best possible protection for We the People?

Can we agree to share the costs of what the solution will require so that the burden of the problem is shifted from the victims, who experience life needlessly cut short or devastatingly changed by horrific injuries, and their families who are faced with unexpected, traumatic, too-often-bitter, and unending grief?

Right this minute, I must admit, I am discouraged right along with the many others who have tried to bring about change for decades. Nonetheless, I choose to remain hopeful that this is not insurmountable and that we are well on our way to victory as we continue to shed light on traffic safety problems and call for truth, justice, and mercy to prevail. . .

1a85etUnsafe Trucks

How I came to be a presenter on underride research at the TRB 1st Int’l Roadside Safety Conference

How is it that I came to be a presenter at the Transportation Research Board’s First International Roadside Safety Conference, June 12-15, 2017, in San Francisco?

  1. Well, of course, first off I was in a horrific truck underride crash that took the lives of my two daughters, AnnaLeah (17) and Mary (13) on May 4, 2013.
  2. IMG_4465Car Safety Wars
  3. Then, I learned that underride guards are terribly ineffective and all sorts of other unbelievable information about the state of safety on our roads.
  4. I also came in contact with many other people who are trying like me to improve underride protection in order to prevent other people from dying like my girls did.
  5. Then, my family and I gathered thousands of petition signatures calling for improvement and worked with other organizations to plan an Underride Roundtable on May 5, 2016, at the Insurance Institute for Highway Safety.
  6. So, then, in June 2016, after preparing an Underride Consensus document to present to DOT, I serendipitously found out about an upcoming roadside safety conference.
  7. I was copied (by mistake) on an email sent to some PhD students, reminding them of a deadline to submit an abstract to be considered for possible presentation at this conference.
  8. So, after checking with the email sender to see if underride was appropriate for this conference, I prepared an abstract and submitted it on June 28, 2016.
  9. I then got busy doing many other things including preparing a Comprehensive Underride Consensus Petition and forgot about the conference.
  10. Lo, and behold, I received another email on September 2, 2016,                                   Dear Marianne, Congratulations!The Planning Group for TRB’s First International Roadside Safety Conference appreciates your submission of the abstract entitled Promising Research for Improved Heavy Vehicle Underride Prevention Structures and Data to Demonstrate Boundaries of Occupant Survivability in Collisions Between Large Trucks and Passenger Vehicles. We are pleased to inform you that we have selected your abstract for Presentation and Publication.

     In order to proceed with the conference planning in a timely manner, the planning group asks that you upload your files no later than November 1, 2016.

  11. Well, I was amazed and not sure whether it made sense to proceed. It is not exactly the target audience to whom I would have imagined making a presentation. But if their focus is roadside safety, then I will take the opportunity to raise awareness about the underride problem and solutions.
  12. So, on November 1, 2016, I uploaded my revised abstract and underride research presentation paper.
  13. May the Lord bless this endeavor and work mightily to improve underride protection internationally.
  14. If He wills, San Francisco, here I come
  15. Best ProtectionRoads Safer