Category Archives: Truck Safety

Underride Roundtable Led to Recommendations Submitted as a Consensus Public Comment to NHTSA

August 9, 2016AnnaLeah and Mary, Safety Advocacy, Truck SafetyNHTSA rulemaking, underride guards, underride roundtableMarianne

The Underride Roundtable at the Insurance Institute for Highway Safety on May 5, 2016, has led to a Consensus Document outlining recommendations for improvement in the federal standards for rear underride guards on semi-trailers. The following Public Comment was posted on regulations.gov/The Federal Register on August 8, 2016:

August 6, 2016

The Honorable Mark R. Rosekind, Ph.D. Administrator
National Highway Traffic Safety Administration
1200 New Jersey Avenue, SE
Washington, DC 20590

Federal Motor Vehicle Safety Standards 49 CFR Part 571, Rear Impact Guards, Rear Impact Protection; Notice of Proposed Rulemaking; Docket No. NHTSA-2015-0118

Dear Administrator Rosekind:

On May 5, 2016, almost 100 people participated in an Underride Roundtable hosted by the Insurance Institute for Highway Safety at their Vehicle Research Center in Ruckersville, Virginia, with co-sponsors Truck Safety Coalition and AnnaLeah & Mary for Truck Safety. Participants included researchers, safety advocacy groups, the trucking industry, truck trailer manufacturers and government officials, including members of NHTSA staff. Discussions during the meeting ranged from descriptions of the nature and magnitude of the underride problem to potential solutions including better conspicuity, new rear underride guard designs and the potential for side guards to prevent run-overs of pedestrians and cyclists in urban environments. The information shared during our meeting clearly illustrated the need to do more to address underride crashes as well as the possibility of doing so.

During the meeting IIHS conducted a 35 mph 30 percent overlap frontal crash test of a midsize car into the new and improved rear underride guard available on trailers manufactured by Stoughton. The guard prevented underride and occupant compartment intrusion thereby becoming the 4th major trailer manufacturer to offer guards capable of preventing underride at 35 mph in all 3 configurations tested by IIHS – full overlap, 50 percent overlap and 30 percent overlap (press release). These 4 manufacturers – Manac, Stoughton, Vanguard and Wabash – represent nearly 40 percent of the truck trailer market in the United States. IIHS crash tests indicate that a higher level of underride protection is possible and the March announcement (press release) that J.B. Hunt Transport Services, Inc. ordered 4,000 trailers with the new Wabash RIG-16 Rear Underride Guard System indicate that better guards are not an impediment to the service trailers provide.

Subsequent to the Underride Roundtable, all participants were invited to attend a follow-up meeting at the IIHS office in Arlington, Virginia. On June 24, 2016, thirteen people representing different points of view met to formulate updated recommendations for NHTSA’s consideration as it deliberates the proposed upgrade of FMVSS 223. Adopting the Canadian Motor Vehicle Safety Standard 223 will do little to advance underride protection because trailer manufacturers already are fitting guards that meet this standard and IIHS testing illustrates that greater levels of strength are needed to address the full range of potential impact zones between the vehicle and rear of the trailer. We believe that incorporating the following recommendations in its final rule will help prevent the senseless loss of lives associated with crashes into the rear of heavy trucks.

* * * * * * * * * * * * * * * * * * * * * * *

1. The revised FMVSS 223 should require guards that are strong enough to allow the inherent crashworthiness of modern passenger vehicles to be realized. Specifically, guards should prevent underride and occupant compartment intrusion when struck by a typical passenger vehicle at 35 mph with overlaps ranging from 30 percent of the passenger vehicle’s width to full overlap between passenger vehicle and truck trailer. Tests of trailers from Manac, Stoughton, Vanguard, and Wabash illustrate the practicability of providing the level of underride protection described above.

2. It should be possible to prescribe a regulatory test procedure based on quasi-static loading and minimum force levels that will lead to guards capable of providing the same or better level of underride protection as demonstrated by guards on Manac, Stoughton, Vanguard and Wabash trailers.

3. The underride guard and trailer structure are a system. As such, compliance testing of rear impact guard strength should be conducted with the guard attached to the trailers and/or a portion of it that includes all structures to which the guard attaches.

This consensus document was signed by the following individuals:

Respectfully submitted,
David Zuby, Chief Research Officer
Insurance Institute for Highway Safety

Gary Fenton, VP of Engineering
Stoughton Trailers

Aaron Kiefer, Consulting Engineer
Accident Research Specialists

Paul Hutson,
ECU engineering student & intern with Aaron Kiefer

Jared Bryson, SR Mechanical Systems Group Leader
Virginia Tech, Center for Technology Development

Perry Ponder, President
Seven Hills Engineering

Raphael Grzebieta, Professor of Road Safety & Australian Naturalistic Driver Study
Lead Chief Investigator (Maintains that dynamic crash testing is preferable to quasi-static testing)

Andy Young, Attorney
Nurenberg, Paris, Heller & McCarthy Law Firm

Jerry Karth, AnnaLeah & Mary for Truck Safety
Father of Underride Victims AnnaLeah & Mary Karth

Isaac Karth, AnnaLeah & Mary for Truck Safety
Brother of Underride Victims AnnaLeah & Mary Karth

Marianne Karth, AnnaLeah & Mary for Truck Safety
Mother of Underride Victims AnnaLeah & Mary Karth

Robert Martineau,
Airflow Deflector

Roy Crawford, PE, Forensic Engineer
Father of Underride Victim Guy Crawford

Stephen A. Batzer, Ph.D., P.E.
Batzer Engineering

Bruce E. Enz
Injury & Crash Analysis, LLC

Ashley McMillan
Girlfriend of Underride Victim Michael Higginbotham

Randy and Laurie Higginbotham
Parents of Underride Victim Michael Higginbotham

Tamara Brininger, Paralegal & Community Initiatives Coordinator
Nurenberg, Paris, Heller & McCarthy

Austin Brininger, Engineering Student

Louis Lombardo
Care for Crash Victims

See a pdf of the recommendations here: Underride Roundtable Consensus Comment NPRM_ Docket No. NHTSA-2015-0118

Here is a link to the Underride Consensus Public Document on regulations.gov: Consensus Comment on the National Highway Traffic Safety Administration (NHTSA) Proposed Rule: Rear Impact Guards, Rear Impact Protection

One more very important thing, please sign the just-launched petition requesting NHTSA to mandate SIDE GUARDS on large trucks: http://www.thepetitionsite.com/104/026/213/mandate-side-guards-on-large-trucks-to-end-deadly-side-underride-crashes/

” Start-Up Otto in Fast Lane to Test Self-Driving Trucking by Year’s End”

August 9, 2016Truck Safetyautonomous vehicles, self-driving trucksMarianne

Every time I turn around, there is more news about “self-driving” or autonomous vehicles. I hope that there is effective communication and collaboration among all the players involved to bring these latest and greatest technologies safely to the road.

Self-driving trucking start-up Otto is poised to put its software in the hands of long-haul truckers by the end of this year for testing, its co-founders said on Thursday.

Otto, co-founded by Google car and map project veterans Anthony Levandowski and Lior Ron, will also begin testing five retrofitted Volvo trucks at Northern California’s autonomous vehicle testing grounds, GoMentum Station, in coming weeks.

By the end of the year, small owner-operators and larger commercial partners will begin using Otto’s self-driving kit, Levandowski told Reuters at the facility in Concord, north of San Francisco, adding the company has a target of “thousands” of testers by 2017.

Otto has not yet announced when the technology will be ready for sale. . .

Read more here: Start-Up Otto in Fast Lane to Test Self-Driving Trucking by Year’s End, Insurance Journal, Alexandria Sage, August 8, 2016

IIHS does valuable work to advance vehicle safety through crash test ratings. Large trucks included.

August 8, 2016Truck Safety5-star crash rating, auto safety, IIHS, Insurance Institute for Highway Safety, seatback failure, underride guardsMarianne

Here’s a recent article on the value of IIHS challenges to automotive companies: Safety institute seeks balance in frontal crash tests

The challenge mentioned here is for car companies to address the need for occupant protection on the passenger side as well as the driver side in frontal crashes. Duh!

As a mom of nine — although they are now grown — it seems commonsense to me to provide occupant protection throughout the entire vehicle! Including protection for passengers from seatback failures.

I am thankful for the valuable work which the Insurance Institute for Highway Safety does to advance vehicle safety through their crash test ratings. That includes large trucks.

I hope to see a 5-star crash rating system for the underride protection system on large trucks soon. It could mean the difference between life and death for someone.

“Economics Will Push Adoption of Self-Driving, Electric Trucks” Trucks.com

August 8, 2016Truck Safetyautonomous vehicles, electric trucks, self-driving trucksMarianne

“Economics Will Push Adoption of Self-Driving, Electric Trucks”

Look for semi-trucks to become more intelligent and electric.

That’s the assessment of Morgan Stanley Research analyst Ravi Shanker.

While there are hurdles, Shanker argues in a recent report to investors that powerful economic and regulatory forces will push the trucking industry toward electric, self-driving trucks.

Look for autonomous trucks to be introduced in 2020, “around the time we expect to see the launch of electric semis, right as the new fuel economy and emissions regulations for commercial trucks gather steam,” Shanker said.

Established truck manufacturers and start-ups are already moving in that direction. . .

https://www.trucks.com/2016/08/08/self-driving-electric-truck-economics/

Petitions & Collaborative Efforts Are Making Progress In Ending Preventable Crash Deaths

August 7, 2016Safety Advocacy, Truck SafetySide Guard Petition, side guards, traffic safety, Traffic Safety Ombudsman Petition, Vision ZeroMarianne

I am thankful for the progress which has been made in traffic safety and underride protection. And I am asking you all to hang in there with us and keep pushing for more.

Please sign and share these two petitions:

Just launched this petition directed to NHTSA calling on them to mandate side guards on trucks; they have been talking about it since 1969. Technology is available. Let’s get at it! Mandate Side Guards On Large Trucks To End Deadly Side Underride Crashes http://www.thepetitionsite.com/104/026/213/mandate-side-guards-on-large-trucks-to-end-deadly-side-underride-crashes/
Traffic Safety Ombudsman Petition: We propose that the United States establish an independent Office of National Traffic Safety Ombudsman to be an advocate to eliminate preventable crash deaths and serious injuries. http://www.thepetitionsite.com/384/321/600/end-preventable-crash-fatalities-appoint-a-national-traffic-safety-ombudsman/

Reports on Past Petitions:

Collaborative Effort: Media Coverage of the first Truck Underride Roundtable held at IIHS on May 5, 2016

Together, we are indeed making the roads safer — one step at a time. Thank you.

A Very Mary Birthday: What Mary would have done & what I did without her on her birthday

August 7, 2016AnnaLeah and Mary, Safety Advocacy, Truck Safetybittersweet memories, complicated grief, enduring grief, grief, joie de vivre, side guardsMarianne

How would Mary have celebrated her 17th birthday today? Well, I don’t know for sure. But I know that she would have enjoyed making her own homemade pizza with us tonight. (Or would she have chosen something else for her birthday meal?)

I know that she would have been glued to the TV or her computer watching the Olympics. She loved watching the 2012 Summer Olympics!

Mary would have played with her dog which she was going to get when we moved into our new house three summers ago. She loved dogs!

Video of Mary with Django (October 2012, Warsaw Indiana): https://www.facebook.com/464993830249803/videos/574678849281300/

Whatever she would have chosen to do on her special day, Mary would have made the most of it because “every day’s a holiday with Mary” and she knew how to live joyfully — when she wasn’t grumpy, that is.

I just discovered that the photos below were ones that Mary took on August 6, 2012 — the day she became a teenager and the last birthday she would ever celebrate:

I also just noticed from these photos from her camera that Mary gave her beloved Gertie a bath on her 13th birthday (the beloved stuffed toy given to her by AnnaLeah so many birthdays before).

Notice the photos Mary took that same day of some of her favorite books (probably her birthday presents from AnnaLeah, whom I can’t ask to be sure) — including an American Girl one about a gymnast!

Mary had put 2012 Olympics gymnast Gabby Douglas’ December birthday on the 2013 calendar.

Mary would have held Oscar today.

A birthday post from Mary’s sister Rebekah

Mary’s dad shares a birthday post

Photo Album: Mary’s First Year of Life

Photo Album: Mistress Mary Quite Contrary by Susanna

Photo Album: Mary on Film by Susanna

I know that Mary would not have read my post from yesterday because I would have had no reason to post it:

New on the Market: Angel Wing Side Guard Solution To Prevent Truck Underride Deaths & Injuries

And Mary would not have checked to see how many people had signed the Traffic Safety Ombudsman Petition because I would not have launched it:

End Preventable Crash Fatalities: Appoint a National Traffic Safety Ombudsman

I would not have spent Mary’s birthday getting ready to post an Underride Roundtable Consensus as a Public Comment to NHTSA’s underride rulemaking at 11:59 p.m. on her birthday. (Link to it on the Federal Register)

And I most definitely would not have launched a new petition on Mary’s birthday to ask NHTSA to mandate SIDE GUARDS on trucks so people wouldn’t die from going underneath the sides of trucks:

Mandate Side Guards On Large Trucks To End Deadly Side Underride Crashes

Please sign & share these two petitions in memory of AnnaLeah and Mary, whom we miss more than we could ever say.

New on the Market: Angel Wing Side Guard Solution To Prevent Truck Underride Deaths & Injuries

August 5, 2016Safety Advocacy, Truck Safetysafety technology, side guards, underride guardsMarianne

Good news for those of us who travel on the roads. . . There will soon be a safety product on the market: a side guard to prevent passenger vehicles — as well as pedestrians, cyclists, and motorcycle riders — from riding under the sides of large trucks upon collision.

Airflow Deflector already supplies a line of truck side guards — aimed mainly at pedestrians, cyclists, and motorcycle riders — and has been installing them on city-owned trucks in Boston and New York, two cities committed to Vision Zero.

As a result of opportunities to network with others at the May 5 Underride Roundtable, Robert Martineau has teamed up with Perry Ponder of Seven Hills Engineering to manufacture and market his side guard invention, Angel Wing. Robert recently shared this good news with me:

” . . . we will be bringing Angel WIng to market. If you go to our site (http://airflowdeflector.com/angelwing_underride/) you can see our new post and video.

“We are excited to launch this product which will be ready for market by the early fall. We will be communicating with different people as to get it tested, certified and tried on trucks as part of a fleet valuation. Still some details to work out but we are now in production.

“We believe this is a very good start and will fit the business model that the transportation industry knows and understands as it does address the issues that face the transportation market both from an economization of fuel and underride safety.“

Another side guard designer, Aaron Kiefer, continues to develop his invention with the goal of making it a viable alternative for protecting people from the deadly side underride which he sees in his work as a crash reconstructionist. His guard actually attaches to the rear guard on trucks thereby strengthening the underride protection for collisions at the back of the truck as well as providing protection on the sides.

Given the vast number of trucks without side guards and the potential for horrific underride deaths and injuries just waiting to happen, I am encouraged to see this progress and look forward to more of the same.

Now what we need is a federal mandate for side underride protection on all large trucks. (Stay tuned for an online petition for Side Guards.)

August 7, 2016 UPDATE We just launched an online petition at Care2 petition site calliing on NHTSA to Mandate Side Guards On Large Trucks To End Deadly Side Underride Crashes.

Please sign & share: http://www.thepetitionsite.com/104/026/213/mandate-side-guards-on-large-trucks-to-end-deadly-side-underride-crashes/

“Truck Parking Shortage Exposes Drivers to Crime, Other Danger”

August 5, 2016Truck SafetyTired Truck Roundtable, truck parkingMarianne

Yes, parking for trucks is a problem that needs to be addressed. And I am recommending that it be included in the agenda at a Tired Trucker Roundtable.

Truck Parking Shortage Exposes Drivers to Crime, Other Danger

TTMA Engineering Committee provides rulemaking input at the annual TTMA meeting in July.

August 4, 2016Truck SafetyTTMA, underride guardsMarianne

The Truck Trailer Manufacturers Association (TTMA) held their annual summer meeting July 26 — 28.

The TTMA Engineering Committee reviewed several key regulatory actions during the TTMA convention.

Among the regulatory items:

• The National Highway Traffic Safety Administration is at work on revisions to its rear underride guard regulations. Engineering Committee provide rulemaking input

I look forward to hearing more about the TTMA Annual Summer Meeting.

Tired Trucker Roundtable: If we plan it, they will come. Can we pull it off?

August 3, 2016Safety Advocacy, Truck Safetydriver fatigue, drowsy driving, DWF, microsleep, Tired Trucker Roundtable, truck driver compensationMarianne

Even though our efforts to improve underride protection are far from being finished, I would like to also tackle the project of organizing a Tired Trucker Roundtable. The only problem is that I have not yet identified any sponsoring organizations or potential facilities for holding such an important event.

The Insurance Institute for Highway Safety and the Truck Safety Coalition were the co-sponsors with AnnaLeah & Mary for Truck Safety of the Underride Roundtable on May 5, 2016. However, at this time, they are not in a position to participate in a similar fashion with a Tired Trucker Roundtable.

Exactly what am I envisioning with this Tired Trucker Roundtable? Let me try to summarize the highlights:

Over and over, truck crash tragedies occur which seem to involve tired truckers.
Of course, it is harder to measure driver fatigue than DUI — after the fact.
Some of the solutions to this problem have included logging driver hours in paper log books (too often unreliable and, in our crash, never seen by us or our attorney or DA) and more recently rulemaking (currently in a lawsuit) has been issued to require electronic log books.
These log books are to be connected to the official Hours of Service (HOS) requirements for truck drivers regulated by DOT’s Federal Motor Carrier Safety Administration (FMCSA).
There has, of course, been ongoing debate about what is appropriate for the details of these HOS. A virtual and ongoing political tug-of-war which leaves the truck drivers in a confusing muddle and truck crash victims in the grave.
I have read comments from and had “discussions with” many truck drivers who are convinced that these HOS rules need to have the input of truck drivers who are experienced with what works for them.
Of course, the problem that should probably involve other players than DOT agencies — like the Department of Labor and the Department of Health & Human Services (CDC/Public Health) — is that it is to a great extent a problem of how truck drivers are normally compensated (by the mile) and their great difficulty in making a living wage without a great toll on their health.
And it must definitely include various sectors of the trucking industry–carriers, shippers, brokers, independent owner-operators.
Government regulators.
Sleep apnea may also be a factor for many.
In general, their occupation involves long hours of monotonous driving which can lead to not just falling asleep but microsleep which can be as bad or worse than driving DUI.
Trucks take longer to brake but are traveling along with the rest of the traffic — posing a hazard to us all, especially when you add in the factor of the geometric mismatch (not merely a weight difference) of the height of the crush zone of the front of passenger vehicles vs the height of the lower edge of trucks. Underride protection (even what is currently legislated) is too weak and ineffective.
And really, driver fatigue is not just a trucker problem — now is it?
Fatigue, of course, is not the only problem; distracted behavior needs to be discussed as well, and other factors of what might make a truck driver inattentive and not ready to react in a timely manner to avoid tragedies.
Let’s not forget the road system and things like electronic signs to alert drivers of upcoming traffic back-ups or law enforcement actions to divert traffic or teaching drivers how to respond, etc.
And, of course, safety technology — to alert drivers when they are in microsleep or crash avoidance systems (but still, then the driver has to react to the surrounding circumstances) and DON’T FORGET underride protection, parking for truck drivers who do need to take breaks but so they don’t create hazards in their parking location, conspicuity, side mirrors.
Lack of truck parking options causes a big problem.
I’m sure that I have forgotten something; but I hope that you get the idea!

Now all I need is for some others (in addition to truck drivers) to catch the vision and help me out with planning this thing — finding sponsors, a facility, speakers, resources, etc.

Let’s collaborate together. Let’s make it happen. Let’s be amazed at the results.