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.
Utility “is pleased to announce its dry vans, refrigerated vans and flatbeds produced after 2002 can be retrofitted with Utility’s standard 7” deep horizontal Interstate Commerce Commission (I.C.C.) bumper. . .
“Utility strongly recommends their 7” deep horizontal bumper for horizontal bumper replacement on new or older Utility trailer models that were built after 2002 in order to exceed all rear trailer guard safety regulations. Utility will discount the new bumpers as an incentive to replace the old bumpers with the new upgraded 7” deep bumper. . .
We are hopeful that this bold move will pave the way for all trailer manufacturers to follow suit. These retrofit kits will be available to replace not only damaged RIGs but the RIGs on millions of trailers on the road today which have rear underride guards which are TOO WEAK to stop underride all across the back of the trailer.
This just goes to show you that, by working together, we can STOP underrides. I’m hoping that 2021 will bring significant progress in underride protection!
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.
The Public can comment on this proposed rule through March 1, 2021, by going here.
This describes the current status of rear guard inspection requirements, according to FMCSA:
While the FMCSRs have required rear impact guards for more than 65 years, they are not included on the list of components in Appendix G that must be inspected during the annual CMV inspection. This means that a vehicle can pass an annual inspection with a missing or damaged rear impact guard. https://public-inspection.federalregister.gov/2020-27502.pdf
Imagine!
In response to petitions from the CVSA and Jerry and Marianne Karth (“the Karths”1 ); a recommendation included in GAO Report GAO-19-264, “Truck Underride Guards: Improved Data Collection, Inspections, and Research Needed;”2 and Congressional correspondence,3 this rulemaking proposes to amend the FMCSRs to include rear impact guards on the list of items that must be examined as part of the required annual inspection for each CMV.
I have not yet read the whole document, but I am getting ready to do so now in order to make an informed and practical comment. I will definitely recommend that damaged guards be replaced with ones which meet the Insurance Institute for Highway Safety (IIHS) TOUGHGuard level of strength to STOP deadly underride — not merely with an older model which has been proven to be too weak.
It is to their credit that nine U.S. trailer manufacturers have improved their rear underride guard design to meet the IIHS TOUGHGuardstandard 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.
See the difference between a too weak and a stronger guard:
Unfortunately, that does not help underride victims who crash into older models with too weak rear underride guards. Until the entire fleet has this stronger protection, people will continue to die from an engineering problem that has already been solved.
Note: When I called a local truck part company, the person with whom I talked knew nothing about improved rear guard retrofit parts. They were still selling the old model of generic horizontal bumper tubes. In other words, despite the availability of improved guards, many trucking companies are replacing damaged guards with the old model which can’t stop a car in an offset crash.
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.
Family members are appealing to the trucking industry — including truck owners and drivers — to install additional lights for improved visibility and to make sure that the required lighting and retroreflective tape are kept clean and properly maintained. It could mean the difference between life and death.
“A tanker truck pulled onto the unlit highway from a side road, crossing three lanes of traffic. My sister – driving in the rightmost lane – in a mini van plowed into the underside of the tanker … There were no skid marks. The reason for there being no skid marks is simple: my sister never saw the tanker. She never saw the tanker because it was painted dark blue and had no lights on the sides that were clean and clearly visible. . .” Forman writes.
The family’s petition goes into detail about why it is so important to make large trucks as visible as possible especially at nighttime:
In 2018, 96% of vehicle occupants killed in two-vehicle crashes involving a passenger vehicle and a large truck were occupants of the passenger vehicles. (IIHS, 2019) (Source: https://driving-tests.org/driving-statistics/
“The main factor related to the driver’s ability to see a crossing truck is target conspicuity, or how well an object stands out from its background. Target conspicuity relies largely on contrast characteristics such as color, movement, brightness, shape and size.
“Most commonly with trucks, the misconception is that their large size by itself makes them conspicuous. At night the size of the trailer by itself will not make it conspicuous since other contrast problems will make the trailer virtually invisible. Without any close-in lighting reflecting off the painted surface of the trailer, it will appear black against the black background. Then an approaching driver will have to rely on the side marker lights for his only cue to the presence of the trailer. However, even with the legal placement of marker lights on the sides of the trailer, approaching drivers will still often not perceive the trailer as an obstruction blocking their path.
“Marker lights are small and can be spaced as far as 26 feet apart on the side of a trailer, not providing on-coming drivers with enough information to determine that what they are looking at is a trailer. Marker lights can be misleading, and without an external light source, trailers are often not identified until the headlights of oncoming vehicles directly illuminate them. When their headlights illuminate the trailer, on-coming drivers will only be 100 to 200 feet away, and unable to stop at higher speeds.”
“Retroreflective tape is very effective in making trailers visually –stand out. However, a truck driver should never assume that the presence of this tape on a trailer will automatically guarantee that the trailer will be seen. If the tape is dirty, badly worn, or if the truck is at a steep angle to traffic, oncoming drivers may not be alerted to the presence of the trailer. The underride hazard is still present. Therefore Lights all around the sides are a much better alternative.”
NOTE: This is a very important issue. Having more warning that a collision is imminent will mean that the driver of the passenger vehicle will be more likely to brake and reduce the vehicle speed upon collision. However, this is not an either/or situation. Without adequate underride protection, even at speeds as low as 15 mph, a passenger vehicle can go under the truck — causing catastrophic underride and Passenger Compartment Intrusion injuries.
With both adequate truck conspicuity and underride protection, many lives will be saved.
Thanksgiving Eve, another apparent underride victim lost her life: A truck driver is being investigated for his role in a deadly crash Wednesday night at a rural Fresno County intersection, according to the California Highway Patrol. . . The driver of a sedan was eastbound on Lincoln when the truck driver appeared to fail to see the car approaching and entered the intersection directly in the sedan’s path, according to CHP. . . The sedan struck the left side of the big rig’s trailer and the driver of the car was pronounced dead at the scene. She was identified Thursday as Lorene Negrete, 57. . .
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.
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.
What does fully-guarded mean? It means that every part of the trailer — at the rear and both sides — is covered by equipment which has been installed to prevent a car (or pedestrian, biker, or motorcyclist) from going under the trailer in the event of a collision.
Because the bottom of a truck is higher than the bumper of passenger vehicles, when there is a collision the smaller vehicle easily slides under the truck and the first point of impact is the windshield — resulting in underride and passenger compartment intrusion (PCI). Seatbelts, airbags, and car crumple zones do not function as intended in underride crashes — front, side, and rear — leaving passenger vehicle occupants vulnerable to life-threatening injuries.
This geometric mismatch has been misunderstood for decades. Reports on truck crashes generally focus on the cause of the crash and not what caused the deaths. So underride is undercounted. I know this from firsthand experience having been in a truck crash (but not in the part of the car which went under the truck) and lost two daughters because of underride (one of whom was not reported as such in DOT data).
In order to raise awareness and preserve the memories of underride victims — precious ones gone too soon — I have been writing memorial posts on what appear to me to be underride crashes. I am not a crash reconstructionist, and I do not have all the facts on these crashes; but underride should be investigated as a potential factor in truck crash injuries and deaths.
This is not an exhaustive list — merely the tip of the iceberg. But I hope that it serves to demonstrate the ongoing nature of a preventable public safety problem.
You can find these Underride Crash Memorial posts here.
Because the bottom of a truck is higher than the bumper of passenger vehicles, when there is a collision the smaller vehicle easily slides under the truck and the first point of impact is the windshield — resulting in underride and passenger compartment intrusion (PCI). Seatbelts, airbags, and car crumple zones do not function as intended in underride crashes — front, side, and rear — leaving passenger vehicle occupants vulnerable to life-threatening injuries.
This geometric mismatch has been misunderstood for decades. Reports on truck crashes generally focus on the cause of the crash and not what caused the deaths. So underride is undercounted. I know this from firsthand experience having been in a truck crash (but not in the part of the car which went under the truck) and lost two daughters because of underride (one of whom was not reported as such in DOT data).
In order to raise awareness and preserve the memories of underride victims — precious ones gone too soon — I have been writing memorial posts on what appear to me to be underride crashes. I am not a crash reconstructionist, and I do not have all the facts on these crashes; but underride should be investigated as a potential factor in truck crash injuries and deaths.
This is not an exhaustive list — merely the tip of the iceberg. But I hope that it serves to demonstrate the ongoing nature of a preventable public safety problem.
You can find these Underride Crash Memorial posts here.
