Category Archives: Truck Safety

Side Guard Cost Benefit Analysis Presentation

Safety Advocacy, Truck Safety, , , , ,

A detailed cost benefit analysis of truck side guards was presented on August 26 at a TEAM Underride Zoom meeting. Eric Hein, father of 2015 side underride victim Riley Hein, originally completed this report in May 2021 and submitted it to NHTSA. In May 2022, he updated the analysis and report and again submitted it to NHTSA for consideration. See it here:

A cost-benefit analysis provides estimates of the anticipated benefits that are expected to accrue over a specified period and compares them to the anticipated costs. USDOT guidance ensures that the economic costs and benefits of road safety measures can be monetized and compared, leading to informed decision making. Delve into this cost benefit analysis to see how Eric arrives at these conclusions:

  • Over 15 years of phasing in, SUGs on new semi-trailers would save at least 3,560 lives and prevent 35,598 serious injuries.
  • An SUG with an aerodynamic skirt would offset their entire cost in the first year.
  • A SUG regulation is cost effective because the benefits of side underride guards substantially outweigh the costs.

Then answer the question: Should Secretary Buttigieg be able to determine that a side guard regulation would be cost-effective and therefore is “warranted”?

Unguarded and Unsafe: Death by Underride

Hein V. Utility Trailer Manufacturing Company: Jury Sends a Message to Trailer Manufacturers About Side Underride

Update on Underride Protection Progress

Safety Advocacy, Truck Safety, , , , , , ,

In July 2022, eight years after our original petition was delivered to the Department of Transportation, the National Highway Traffic Safety Administration (NHTSA), whose mission it is to save lives, prevent injuries, and reduce economic costs due to road traffic crashes, through education, research, safety standards, and enforcement, took the following actions related to underride protection:

In this crash test video, the top test shows what IIHS has proven possible, the bottom test shows what the 2022 rule will require:

By refusing to revise the December 2015 NPRM to the TOUGHGuard proven level of strength, NHTSA has demonstrated an unwillingness to require that all manufacturers install these stronger guards as Standard on new trailers. To state the obvious, the result is that manufacturers may continue to offer these guards as an Option, thereby allowing the ongoing production of trailers — into the future — with guards having a known unreasonable risk of Death By Underride. How do they sleep at night knowing that their meaningless rhetoric and regulatory malpractice means many more innocent people will needlessly die?

This is nothing less than a reckless disregard for human life.

Why are we working so hard to get weak rear underride guards replaced?

Launching a Campaign To Flood NHTSA With Underride Complaint Reports

Safety Advocacy, Truck Safety, , ,

Safety defect investigations are based upon complaints. That’s why we’re calling on people to help us submit UNDERRIDE Safety Problem Reports to NHTSA.

In response to our Petition for Investigation of Trailers Without Side Guards submitted to the US DOT on September 14, 2021, the Office of Defects Investigation (ODI) at the National Highway Traffic Safety Administration (NHTSA) in Washington, DC, indicated that they had only received three complaints — besides our petition — about the safety hazard posed by tractor-trailers without side guards. They subsequently denied our petition on June 22, 2022.

Of course, we know that there have been many more than three side underride deaths and serious injuries. However, we are making plans to make sure that the ODI knows this as well and are launching a campaign for submission of underride complaints of all kinds to NHTSA — side, rear, front, tractor-trailer, Single Unit Trucks, and those involving not only passenger vehicle occupants but also pedestrians, cyclists, and motorcyclists.

We are asking that people send us crash reports for collisions with trucks which they suspect involved underride. Send them to marianne@annaleahmary.com. We will submit these as complaints to ODI.

People who would like to make their own submission can do so by following this procedure:

Instructions for Submitting an Underride Complaint to ODI

Note: Please submit a written complaint even if you are unable to obtain a VIN.

We are thankful for all who have participated, and will participate, in the efforts of Team Underride — for the saving of many lives.

“A Safety Rule, A Fatal Flaw”; Industry Discussed Underride Rules in 2000

Truck Safety, , ,

This week, I discovered a U.S. News & World Report article, published on October 2, 2000, entitled, “A Safety Rule, A Fatal Flaw.” I find it enlightening that the trailer manufacturers conceded twenty-two years ago, “underride guards can save lives.” They further admitted that if they had some guidance on technical specifications from the National Highway Traffic Safety Administration (NHTSA), then they could add side guards to trailers. But the manufacturers were unwilling to spend money doing so unless they were required to install them.

How many lives could have been saved if the U.S. Department of Transportation had acted decisively at that time and initiated side guard rulemaking? Perhaps more to the point, I’d like to know if Secretary Buttigieg will act boldly now to end these senseless, preventable deaths by determining that a side guard regulation is warranted?

Back of the Envelope Math: How many side underride deaths since March 19, 1969?

Another Side Guard On The Road

Safety Advocacy, Truck Safety, , , ,

It is not often that you get the opportunity to work with a great crew of people (Aaron Kiefer, Marcus Gainer, Quentin Beverly, Robert and James Gilmore, and Hyle Herwick) to accomplish something that is so meaningful, and life-saving. But I was truly blessed today to have that happen. 

The Carolina Trucking Academy, owned by Charlie and Donna Gray, has been one of the biggest supporters of our efforts on this journey we have been on for years in helping prevent death by underride. Today we were able to place an AngelWing side guard on one of the Academy’s trailers.

It was, once again, an engineering challenge as the trailer was shorter than the normal 53-foot trailers we normally work with. But Aaron Kiefer — as always — came up with the modifications which were required.

Marcus went to work on the Academy trailer — cutting the holes required in the cross members for fitting the support beams in place. Meanwhile, the rest of us started the process of removing the AngelWing from the underride research/storage trailer and preparing it for its new home on the Academy trailer. Each section of the guard was carefully removed, with every bolt, nut, and washer lined up in readiness for the installation.

With dedicated teamwork, we were able to complete the installation of the AngelWing side guard on the Academy’s trailer. So now this life-saving device will be on the highways and byways in and around North Carolina –demonstrating not only great driver training but also the commitment of Charlie and Donna to have the safest equipment on the road.

Jerry Karth

Basic Underride Information

Safety Advocacy, Truck Safety

This post provides basic underride information, as well as a running list of recent relevant posts.

  1. Petition: STOP Senseless Roadway Deaths: Give Victims a Voice
  2. Petition: Secretary Pete, It’s Past Time To End Death By Underride!
  3. Underride Crash Memorials These are posts in memory of a few of the thousands of underride victims. The tip of the iceberg of senseless, preventable deaths. I will slowly be adding more.
  4. Important Videos: Basics of Underride; Front Underride Protection crash test; Side Guard crash test; Rear Guard crash test; Rear Retrofit crash test; Safetyskirt SIG.R Crash Test 2023, 35 mph T-Bone Behind Axles; SafetySkirt Crash Testing Videos; Unguarded Crash Test 2023, 37.5 mph, 45 Degree Angle Crash
  5. STOP Underrides! YouTube Channel Truck Underride Video Playlist
  6. $462M Jury Verdict Over Rear Impact Guard Design
  7. What Don’t They Want to See? DOT Declines to Send Observer to Underride Crash Test… AGAIN!
  8. Industry Response to ACUP Report; Enough of the Bellyaching Already!
  9. NHTSA Defends Itself to Congress – Woulda, Coulda, Shoulda
  10. Advisory Committee on Underride Protection Reports to Congress & DOT Secretary
  11. DOT Victim & Survivor Advocate Act Introduced To Give Victims A Voice
  12. Senior Agency Officials Suppressed Side Guard Research — Impacting Regulatory Analysis
  13. Underride Crash Memorials
  14. Advisory Committee on Underride Protection, April 24, 2024 Meeting Record
  15. Advisory Committee on Underride Protection, April 24 Meeting Video Playlist
  16. How To Make Crashes With The Front Of A Truck More Survivable
  17. Register for April 24 Meeting of Advisory Committee on Underride Protection
  18. Advisory Committee on Underride Protection, February 8, 2024 Meeting Record
  19. Front Impact Guard Webinar – April 17
  20. Truck Impact Guards = Underride Protection
  21. Upcoming Underride Advisory Committee Meeting Schedule
  22. Underride Made #1 on ‘FRONTLINE Dispatch’ Podcast Episodes of 2023
  23. Unsung Underride Prevention Heroes
  24. My Reactions to Comments on Inside Edition Underride Investigative Report
  25. Weak Rear Underride Guards Are Still Killing People
  26. Video of Speakers at Underride Victim Vigil
  27. A Record of Those Remembered in the Underride Victim Vigil
  28. Media Coverage of DC Underride Victim Vigil & Press Conference
  29. A day in the life of an underride crash test crew; A Photographer’s Perspective
  30. Underride Victim Vigil & Press Conference on DOT Steps in DC
  31. Simply Mary. . . August 6, 1999 – May 8, 2013
  32. Video from STOP Underrides Crash Test Event
  33. Public Comments on the Side Guard ANPRM (Advance Notice of Proposed Rulemaking)
  34. Still Time to Submit a Public Comment on Side Guard Rule (July 20)
  35. STOP Senseless Roadway Deaths: Give Victims a Voice
  36. So, what did you think of the PBS/Frontline Underride Documentary?
  37. PBS/Frontline Underride Documentary & Petition to Secretary Pete
  38. Commemorative Bell for Roadway Safety Victims
  39. Taking On a Safety Issue: Hazardous Railroad Crossings
  40. Upcoming PBS/Frontline Documentary: “America’s Dangerous Trucks”
  41. Global Underride Discussion
  42. 10 years after trucking crash killed 2 girls, mother sees hope for change
  43. May 4, 2013 seems like just yesterday; has anything changed?
  44. What Do Baseball & Truck Underride Have In Common?
  45. FARS Coding of a Sample of Rear Underride Crashes
  46. LPD+ Saves Lives; But what’s an LPD+?
  47. STOP Underrides Crash Test Tour
  48. “Economism Is Out Of Control” In Life & Death Regulatory Analysis
  49. Remembering AnnaLeah & Mary
  50. Someday, Seeing Side Guards & Strong Rear Underride Guards Will No Longer Surprise Me
  51. Successful Side Guard Crash Test in Raleigh
  52. NHTSA Failing To Educate Stakeholders On Underride
  53. Side Guard Cost Benefit Analysis Presentation to TEAM Underride
  54. Update on Underride Protection Progress
  55. Side Guard Cost Benefit Analysis
  56. Launching a Campaign To Flood NHTSA With Underride Complaint Reports
  57. “A Safety Rule, A Fatal Flaw”; Industry Discussed Underride Rules in 2000
  58. Another Side Guard On The Road
  59. Too Many Lives Forever Changed
  60. Cohen, Gillibrand Call on DOT to Act Expeditiously & Implement Provisions from Their Stop Underrides Act Included in the Bipartisan Infrastructure Package
  61. Five Years Have Passed Since the Historic IIHS Side Guard Crash Test
  62. Back of the Envelope Math: How many side underride deaths since March 19, 1969?
  63. 53 Years or 19,358 days
  64. When it comes to underride, where do you stand?
  65. DOT Announced A National Roadway Safety Strategy; Now It’s Time To Talk About What That Means
  66. Timeline Of Research & Collaborative Efforts To Create A Consensus Side Guard Standard
  67. Can the Insurance Industry Help End the Unfair Fight of Truck Underride Tragedies?
  68. Why are we working so hard to get weak rear underride guards replaced?
  69. @SecretaryPete, Will you fix flawed underride analysis or let deaths continue?
  70. Families glad new infrastructure law will address underride crashes, WRTV, November 18, 2021
  71. First responders train to save lives during underride crashes, WRTV, November 23, 2021
  72. Raleigh Mom: Infrastructure Bill Will Prevent Crashes Like the One That Killed My Girls , Raleigh News&Observer, November 18, 2021
  73. Rear impact guard now part of annual truck inspection, CCJ, November 15, 2021
  74. FMCSA Issues Final Rule: Rear Underride Guards To Be Part Of Annual Inspections, November 20, 2021
  75. Thoughts on Landmark Underride Legislation
  76. AAJ Supports Trailer Safety Recall Petition: “NHTSA is well within its authority to issue a recall”
  77. Unguarded & Unsafe: Death By Underride by Eric Hein, July 15, 2021
  78. STOP Underrides Petition can be found here.
  79. A Timeline of Underride Safety
  80. Certified Letters Alert 200 Carriers of Underride Dangers & Solutions
  81. History of Underride Research & Reports: 1896-2019
  82. Petition for NHTSA To Recall Semitrailers Due To Lack Of Side Underride Guards
  83. Will DOT Respond to Petition for Underride Rulemaking on Single Unit Trucks?
  84. Side Guard Costs Likely To Decrease With Higher Deployment Volumes
  85. Protecting Passenger Vehicles from Side Underride with Heavy Trucks More research on side underride has just been published by SAE International following a presentation by Garrett Mattos of the Friedman Research Center at a SAE Conference. Hopefully, the Department of Transportation now has enough research to make good on their March 19, 1969 intention to add underride protection to the sides of large vehicles.
  86. IIHS Research Provides Foundation for Traffic Safety Legislation – Including Underride
  87. What will it take to get UNDERRIDE on DOT Regulatory Agenda? We’ve been waiting 52+ years for DOT to move forward with side guards on large trucks — not to mention improving rear guard regulations and adding front underride protection. After numerous petitions, comprehensive underride rulemaking still has not made it the onto the DOT Unified Regulatory Agenda.
  88. Collaborative Discussion of Side Guard Challenges on Specialty Trucks I was very pleased with the collaborative discussion which took place via Zoom on Monday, March 29, 2021, regarding the challenges of adding side guard safety technology to specialty trucks. Participants included primarily engineers and small companies who have been working on researching, designing, and/or marketing solutions to the underride problem. The meeting was also quietly observed by families of underride victims and administrative officials from the Federal Motor Carrier Safety Administration (FMCSA).
  89. The March Madness of Competing Traffic Safety Interests What is it like to compete for the attention of government leaders in order to get traction on the traffic safety problem which took your loved one’s life? Envision a press conference on a hot topic where a cacophony of reporters can be heard shouting out — vying for the opportunity to have their question be the one that gets answered.
  90. Time for a National Traffic Safety Ombudsman Almost five years ago, after delivering a Vision Zero Petition to leaders in Washington, D.C., I realized that we need something more than a White House Vision Zero Task Force and a National Vision Zero Goal. We need a National Traffic Safety Ombudsman to be at the helm of a nationwide network of community traffic safety advocates. Someone who will have a place at the federal table — with the authority to take ongoing action on behalf of vulnerable victims of vehicle violence.
  91. Will NHTSA & NTSB Address Side Underride Factor In Latest Tesla Crash Investigation? I have again requested that NHTSA and NTSB address the side underride factor in their investigation of yet another Tesla side underride crash.
  92. Truck Underride Victims & Families Host News Conference for STOP Underrides Act Introduction On Monday, March 8, 2021, truck crash victims’ families hosted a news conference to discuss their stories and the recent introduction of the STOP Underrides Act of 2021 — on March 4, 2021 in the Senate and March 8 in the House.
  93. Engineers, Trucking Industry, & Victim Advocates Collaborate at Side Guard Task Force On a Friday afternoon — February 26, 2021 — over 50 people met via Zoom to discuss comprehensive underride protection. The purpose of the meeting was to report on progress which has been made by several subcommittees since an earlier meeting in 2020 — including Industry Engagement, Research, and Engineering Subcommittees.
  94. Should we be concerned about side guards getting hung up on railroad tracks? I keep hearing members of the trucking industry bring up the possibility of side guards on trailers getting hung-up on railroad tracks. They point to it as a reason to not require side guards on all new trucks. Is that a valid concern? And where is their documentation?
  95. Transport Companies Provide Feedback on Side Guard Operational Issues We know that the trucking industry has expressed concern about potential operational issues which could occur when side guards are installed on large trucks. In order to address those concerns, we asked several trucking companies to give us feedback about their experience after installing side guards on their tractor-trailers.
  96. Consensus Side Guard Standard On April 17, 2020, over 40 people participated in a virtual meeting of a volunteer Underride Protection Committee’s “Side Guard Task Force.” This included two engineers from trailer manufacturers. As a follow-up, several subcommittees began to hold virtual meetings, including an Underride Engineering Subcommittee.
  97. Utility Trailers Encourages Retrofit of Rear Impact Guards To Prevent Underride Last evening, I received some amazing news! Utility Trailer Manufacturing has announced that their improved Rear Impact Guard (RIG) will be offered at a discount.
  98. FMCSA Proposed Rule For Inspection of Rear Underride Guards A red letter day: The Federal Motor Carrier Safety Administration (FMCSA) at long last has proposed a rule to add rear underride guards to Appendix G. What does that mean? It means that rear underride guards will be required to be in good condition in order to pass an annual vehicle inspection. Once the rule is actually issued.
  99. “Chattanoga crash that killed 5 underscores bill to add protective barriers to semi trucks”
  100. Retrofit Solutions for Rear Impact Guards to Prevent Deadly Underride It is to their credit that nine U.S. trailer manufacturers have improved their rear underride guard design to meet the IIHS TOUGHGuard standard and seven of them are putting it on all new trailers as Standard. What that means is that they have surpassed the current federal standard and have been crash tested to show that they are more likely to prevent underride and catastrophic Passenger Compartment Intrusion (PCI) — thereby more likely to save lives when passenger vehicles rear end tractor-trailers.
  101. Save Lives by Lighting up Tractor-Trailers & Tanker Trucks Truck drivers can play an important role in making sure that the trailers which they haul are as visible as possible to other drivers on the road — especially at nighttime. On October 15, 2018, Leslie and Sophie Rosenberg lost their lives when they collided with the side of a tanker late at night.
  102. Truck Driver Mistakes Don’t Excuse Industry & Government Negligence To Solve Underride Problem Thanksgiving Eve, another apparent underride victim lost her life: Though the truck driver may have made a mistake, not all the blame rests with him for a crash which might have had a different outcome with effective underride protection. Carriers, trailer manufacturers, DOT, & Congress can make these kinds of truck crashes more survivable.
  103. A fully-guarded trailer hits the road – ready to STOP underride! Engineering ingenuity and a lot of hard work went into the research, development, and installation of this fully-guarded trailer system. This week, a small carrier in North Carolina became part of our pilot program. We are thankful that they have agreed to provide us feedback on this #SaferTruck as they drive it on the road to carry out their transport business.
  104. On August 19, we hosted another Underride Staff Briefing — this time via Zoom. We are providing Congressional Offices with the PowerPoint pdf from that presentation, including comments from engineers with expertise in underride as well as underride families: Underride Briefing PowerPoint pdf (inc. links to resources & video)
  105. Crash Tests of Rear Underride Guard Reinforcement Attachments, 2016 & 2020
  106. Media Reports & Video Footage Unveil Highlights of the Successful D.C. Underride Crash Test Event Read more here.
  107. Comparison Chart of Underride Provisions in Various Bills
  108. A quick look at some of the more recent efforts to STOP underride tragedies: Update on Underride News
  109. SOCIAL MEDIA: #STOPunderrides Tweets & Facebook Pages: STOP Underrides Act of 2019 and Save Lives/Stop Underrides., AnnaLeah&MaryforTruckSafety , stopunderrides.org
  110. Underride Crash Memorials These are posts in memory of a few of the thousands of underride victims. The tip of the iceberg of senseless, preventable deaths. I will slowly be adding more.

RAMCUP. Roya, AnnaLeah & Mary Comprehensive Underride Protection. They paid the price:

Cohen, Gillibrand Call on DOT to Act Expeditiously & Implement Provisions from Their Stop Underrides Act Included in the Bipartisan Infrastructure Package

Safety Advocacy, Truck Safety, , , ,

The American people, whether they know it or not, have already waited too long for DOT to take decisive action to stop underride tragedies. That’s why it’s encouraging to see Congress putting DOT on notice to move forward with the Underride Mandate. Yesterday, they sent a letter to Secretary Buttigieg:

Congressman Steve Cohen (TN-09) and Senator Kirsten Gillibrand led 25 of their colleagues in a letter urging Department of Transportation (DOT) Secretary Pete Buttigieg to swiftly execute the provisions from their Stop Underrides Act, which passed in the Infrastructure Investment and Jobs Act. press release

The letter encourages DOT to act swiftly to release the Final Rear Underride Guard rule with IIHS TOUGHGuard strength and issue an Advanced Notice of Proposed Rulemaking (ANPRM) in order to allow the Public to comment on side guards, as well as urging them to, “expeditiously establish the Advisory Committee on Underride Protection and to complete the life-saving side guard research which we hope will lead to a proposed rule on side guards. Together these provisions will help save lives and aim to prevent passenger compartment intrusion from crashes with trucks.”

Senator Gillibrand summarized it well, “Every day we don’t act, we are losing an opportunity to save the lives of innocent Americans.”

Read the Press Release here.

Read the DOT Underrides Implementation Letter here.

Five Years Have Passed Since the Historic IIHS Side Guard Crash Test

Truck Safety, , , , ,

The Insurance Institute for Highway Safety (IIHS) conducted an important crash test on March 30, 2017. They crashed a car at 35 mph into the side of a trailer equipped with AngelWing side guards. This crash test was later repeated successfully at 40 mph at the Second Underride Roundtable on August 29, 2017. It was official. Deadly side underride tragedies could be prevented.

What seemed perhaps even more significant was the fact that the following day, March 31, 2017, the IIHS conducted a second crash test into the side of a trailer — only this time, there was no side guard. The stark contrast of the two crashes was captured on film for all to see. Who could argue the benefit of this feasible feat of engineering technology?

Apparently it has not been enough to convince everyone, as we are still struggling to bring this uphill battle to an end five years later. Pray that Pete Buttigieg, the Secretary of Transportation, who is tasked by Congress with making a determination this year, will conclude that saving lives is worth the cost to require trailer manufacturers to equip new trailers with side guards. Otherwise, the inaction of industry and government will allow the senseless, violent slaughter of unprotected road users to continue day after day, year after year — while engineering solutions sit on the shelf gathering dust.

Back of the Envelope Math: How many side underride deaths since March 19, 1969?

Guided Tour of the Truck Underride Exhibit at the IIHS:

Back of the Envelope Math: How many side underride deaths since March 19, 1969?

Truck Safety, , , ,

If you had to guess how many people have died from truck underride, or more specifically from side underride, since DOT talked about side guards on March 19, 1969, what would you say? Well, nobody can say for sure, but I did some Back of the Envelope Math today — using the National Highway Traffic Safety Administration (NHTSA) Fatality Analysis Reporting System (FARS) undercounted underride death data.

Here’s what I came up with: Back of the Envelope Math — Estimated Underride Deaths 3/19/69 – 3/19/22

Why would we equip some trucks to prevent rear underride but not side or front? And why not equip ALL large trucks with available underride prevention technology?

It might not be exact, but it certainly is revealing.

53 Years or 19,358 days

Truck Safety, , , , ,

Fifty-three years ago, the Department of Transportation published their intention to add underride protection to the sides of large vehicles after the completion of technical studies. That was on March 19, 1969. In less than a week, 19,358 days will have passed. Surely there’s been enough time to complete research on this long-overdue rulemaking.

So I’m thinking that it isn’t unreasonable to expect NHTSA to make the Underride Initiative a high priority — especially since President Biden signed a bill on November 15, 2021, which included a requirement for the Secretary of Transportation to complete side guard research within a year and then to make a determination as to whether a side guard regulation is warranted.

It might even be a good idea for NHTSA to issue a Request for Comments (RFC) right away — to give the Public a chance to comment on the costs and benefits of adding side underride protection to large trucks. Shouldn’t Secretary Buttigieg want access to as much information as possible when he makes his decision by November 15, 2022? It is, after all, a matter of life & death.

“In both tests, a midsize car struck the center of a 53-­foot-­long dry van trailer. In the AngelWing test, the underride guard bent but didn’t allow the car to go underneath the trailer, so the car’s airbags and safety belt could properly restrain the test dummy in the driver seat. In the test with no underride guard for protection, the car ran into the trailer and kept going. The impact sheared off part of the roof, and the sedan became wedged beneath the trailer. In a real-­world crash like this, any occupants in the car would likely sustain fatal injuries.“ March 2017 IIHS Side Crash Tests at 35 mph; 8/29/17 40 mph crash test

Underride Victim Photo Memorial: The Tip of the Iceberg

How many people have died from side underride in 19,358 days?