Underride Briefing on The Hill; Video Excerpts of Panel Discussion on October 12

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On October 12, 2017, staff from Congressional Offices gathered to hear presentations from five experts on the topic of truck underride. The presentations were followed by a question & answer period as legislative staff sought to understand the problem and solutions of deadly but preventable underride crashes.

The STOP Underrides! Act of 2017 has been drafted by Senator Kirsten Gillibrand. She is working with Congressman Steve Cohen, who will be drafting a House Companion Measure.  They are both seeking Republican co-leads for this long-overdue, life-saving legislation.

The videos below cover the individual presentations but, unfortunately, the question period was not recorded. Questions about any of the topics covered can be directed to marianne@annaleahmary.com, for follow-up with these and other experts nationally and internationally.

This video includes all five presentations:

Malcolm Deighton, engineer with Hydro (formerly Sapa), discusses their aluminum rear underride guard — successfully crash tested at 40 mph:

Jason Levine, Director of the Center for Auto Safety, discusses the flaws in the cost/benefit analysis of truck underride protection:

Robert Lane, VP of Product Engineering at Wabash National — a trailer manufacturer, discusses their commitment to development of rear and side underride protective devices for the prevention of underride deaths and debilitating injuries:

Matt Brumbelow, a research engineer at the Insurance Institute for Highway Safety (IIHS), discusses the problem of truck underride and the research which IIHS has done to study rear and side underride protection:

Keith Friedman, Friedman Research Corporation, discusses Front Underride Protection:

Further information on truck underride can be found at:

Hosted by Lois Durso (https://stopunderrides.org/) and Marianne Karth (https://annaleahmary.com) who are working to STOP Underrides! in memory of their daughters — Roya Sadigh and sisters AnnaLeah & Mary Karth.

Large trailer manufacturers built 340,000 in 2015. How many purchased in 2017 will have strong rear guards?

Truck Safety, , ,

Some of the trailer manufacturers are offering the new stronger rear underride guard as standard to their customers on their new trailers. Some are not. Why is that? If the new guards have been proven to be safer, why still sell trailers with the weaker, ineffective rear guards which — if involved in a crash — could so easily lead to Death by Underride?

I wonder how many trailers have been sold with the newer guards which meet the IIHS ToughGuard award standards. I know that one transport company, J.B. Hunt, ordered 4,000 of the improved Wabash trailers in January 2016. But the stronger guard is not yet standard on Wabash trailers. So, what percentage of the total new purchases is that?

According to Trailer Body Builders, “THE 25 largest trailer manufacturers in North America built some 340,000 truck-trailers and container chassis in 2015, a 16.6 percent increase over the preceding year.” So J.B. Hunt’s order would have been 1.2% of the total truck-trailer and container chassis purchases for that year.

What about the other 336,000 trucks potentially purchased last year? Did they have safer rear underride guards? (And how long will they stay in the fleet?) I know that they did not have side guards. And that is not even mentioning the millions of existing trucks on the road which are Death by Underride waiting to happen — especially because many of them are not properly maintained.

If only the industry would voluntarily take the initiative to make it right and correct their defectively-designed products by making sure that every truck on the road had the best possible underride protection. New and existing.

I find it interesting that at least some in the industry are thinking comprehensively about some aspects of safety technology. . .

Powell said his first advice when talking with fleet customers (Velociti specalizes in “technology deployment services”) is to suggest they “synergize” their technology adoption efforts in order to make them more complete and easier to handle. For example, he said, if your fleet is looking at putting collision avoidance systems on your trucks, why not put them on your yard tractors and forklifts at the same time?

Likewise, instead of dividing the tasks of putting different safety systems on vehicles such as electronic logging devices, in-cab camera systems, and lane-departure warning systems, treat all those initiatives as a single, unified action plan. Fleets Share Best Practices on Implementing New Technologies Looking at technology as a problem-solver first can go a long way toward its successful deployment in real-world fleet operations.

See, the industry understands the logic of approaching safety technology with a COMPREHENSIVE strategy! Now if only they would apply that by including comprehensive underride protection in the Super Truck Project!

Perfect Opportunity to Transform SuperTruck Into An ESV To Advance Underride Protection; DOT & DOE?

How many more people have to die from Death by Underride before “we” do something about it?!

Truck Safety,

Recently, NHTSA announced statistics for 2016 traffic fatalities:

  • 37,461 people killed in crashes on U.S. roadways in 2016
  • Up 5.6% from 2015
  • Tucked in the back of the report, if you look for it, you will see that there were 4,317 fatalities in crashes involving large trucks — up 5.4% from 2015, the highest since 2007.
  • Of those, 722 (16.7%) were occupants of large trucks and 10.8% were nonoccupants.
  • 72.4% of the truck crash fatalities were occupants of other vehicles, or 3,125.5 (Do I round that up to 3126? Now that really bothers me because this is about people who died in a crash with a truck last year and not merely statistics!)

If you look at NHTSA’s press release, here is their summary:

The 2016 national data shows that:

  • Distraction-related deaths (3,450 fatalities) decreased by 2.2 percent;
  • Drowsy-driving deaths (803 fatalities) decreased by 3.5 percent;
  • Drunk-driving deaths (10,497 fatalities) increased by 1.7 per­cent;
  • Speeding-related deaths (10,111 fatalities) increased by 4.0 percent;
  • Unbelted deaths (10,428 fatalities) increased by 4.6 percent;
  • Motorcyclist deaths (5,286 fatalities – the largest number of motorcyclist fatalities since 2008) increased by 5.1 percent;
  • Pedestrian deaths (5,987 fatalities – the highest number since 1990) increased by 9.0 percent; and
  • Bicyclist deaths (840 fatalities – the highest number since 1991) increased by 1.3 percent.

Do you see the 4,317 truck crash fatalities mentioned there? I don’t! Yet they accounted for 11.5% of the total traffic fatalities.

Is that indicative of what I continue to observe year after year — that truck crash fatalities are considered merely a transportation issue and left to the trucking industry to solve? And so potential lives saved always lose out in any cost/benefit analysis because “CBA is weighted in favor of the regulated industry and against health, safety and environmental protections”.

And we all know who ends up paying the price for this unresolved public health & safety crisis.

“Even if cost-benefit analysis is theoretically a neutral tool. . . it is biased against strong public protections.”

Truck Safety, , ,

Recently, NHTSA announced statistics for 2016 traffic fatalities:

  • 37,461 people killed in crashes on U.S. roadways in 2016
  • Up 5.6% from 2015
  • Tucked in the back of the report, if you look for it, you will see that there were 4,317 fatalities in crashes involving large trucks — up 5.4% from 2015, the highest since 2007.
  • Of those, 722 (16.7%) were occupants of large trucks and 10.8% were nonoccupants
  • 72.4% of the truck crash fatalities were occupants of other vehicles, or 3,125.5 (Do I round that up to 3126? Now that really bothers me because this is about people who died in a crash with a truck last year and not merely statistics!)

If you look at NHTSA’s press release, here is their summary:

The 2016 national data shows that:

  • Distraction-related deaths (3,450 fatalities) decreased by 2.2 percent;
  • Drowsy-driving deaths (803 fatalities) decreased by 3.5 percent;
  • Drunk-driving deaths (10,497 fatalities) increased by 1.7 per­cent;
  • Speeding-related deaths (10,111 fatalities) increased by 4.0 percent;
  • Unbelted deaths (10,428 fatalities) increased by 4.6 percent;
  • Motorcyclist deaths (5,286 fatalities – the largest number of motorcyclist fatalities since 2008) increased by 5.1 percent;
  • Pedestrian deaths (5,987 fatalities – the highest number since 1990) increased by 9.0 percent; and
  • Bicyclist deaths (840 fatalities – the highest number since 1991) increased by 1.3 percent.

Do you see the 4,317 truck crash fatalities mentioned there? I don’t! Yet they accounted for 11.5% of the total traffic fatalities.

Is that indicative of what I tend to observe — the truck crash fatalities are considered a transportation issue and left to the trucking industry to solve? And so potential lives saved always lose out in any cost/benefit analysis, and we all know who ends up paying the price for this unresolved public health & safety crisis.

Along that line, check out this interesting read about cost/benefit analysis (which agencies have to do in rulemaking) related to safety regulations. . . https://www.foreffectivegov.org/node/2332

Even given the many uncertainties of cost-benefit analysis, proponents still argue that it acts as a neutral tool. Yet, as David Driesen points out, “if CBA only makes regulation weaker, and never strengthens overly weak regulation, it cannot improve priority setting and consistency in the manner its proponents envision.” Driesen lays to rest the argument of CBA’s neutrality by dissecting the use of CBA both in practice and theory. Driesen finds that both in OMB’s implementation of cost-benefit analysis as well as in the assumptions of the cost-benefit analysis itself, CBA is weighted in favor of the regulated industry and against health, safety and environmental protections.
 
Driesen focuses his look at cost-benefit analysis on the role of the Office of Information and Regulatory Affairs (OIRA), a subagency of the Office of Management and Budget (OMB) charged with carrying out cost-benefit analysis through Executive Order 12866. According to a Government Accountability Office (GAO) report, between June of 2001 and July of 2002, OMB “significantly affected 25” environmental, health and safety regulations. If cost-benefit analysis is in practice a neutral tool, then OIRA’s use of cost-benefit analysis to review regulation would sometimes strengthen protections and sometimes weaken them. Driesen found that none of OIRA’s changes made environmental, health or safety protections more stringent, and 24 out of the 25 weakened protections. Even if cost-benefit analysis is theoretically a neutral tool, in the hands of this administration, it is certainly biased against strong public protections.
 
 OMB tends to see cost-benefit analysis as a criterion under which the cost of implementing a regulation can never exceed the benefit. Another option is that cost-benefit analysis is used as a criterion under which cost must always equal benefit, optimizing the efficiency of the regulation. Driesen shows that in each case cost-benefit is not a neutral tool and will always favor the regulated community over the health, safety and environmental regulation.
 
Previous posts on this issue:

Lawmaker first to publicly back truck underride bill written by grieving moms

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Thank you, Congressman Mark DeSaulnier, for your strong commitment to ending truck underride tragedies.

Senator Gillibrand Directs Pointed Questions on Underride to Federal Highway Administration Nominee

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Senator Gillibrand asked Paul Trombino — in his nomination hearing for the position of Administrator of the Federal Highway Administration (FHWA) — some pointed questions about the underride problem. Her questions to him included asking whether he was aware that the IIHS had successfully crash tested a side guard at 40 mph in August and whether he would commit to studying the issue and responding to her within three months if he was appointed to that position.

Go, Senator Gillibrand! Thank you for drawing attention to this and asking for tangible action.

 

Video Links from the Second Underride Roundtable at the IIHS on August 29, 2017

Truck Safety, , , ,

The Insurance Institute for Highway Safety once again did a fantastic job of hosting the Underride Roundtable. They have now provided us with links to the Second Underride Roundtable held at the IIHS Vehicle Research Center in Ruckersville, Virginia, on August 29, 2017. Here is the agenda, followed by the videos:

Truck Underride Roundtable 2 – Morning Session, Part 1:

 

Truck Underride Roundtable 2 – Morning Session, Part 2:

 

Truck Underride Roundtable 2 – Side Guard Panel:

 

Truck Underride Roundtable 2 – Industry Response and Crash Avoidance Panel:

 

Side Guard Crash Test at 40 mph on August 29, 2017:

 

Side Underride & Side Guard Crash Tests at 35 mph at IIHS on March 30 & 31, 2017:

 

 

Debunking the Myth That Safety Countermeasures Over-Regulate the Trucking Industry

Truck Safety,

We have worked hard ever since we lost AnnaLeah (17) and Mary (13) on May 4, 2013, in a senseless and preventable truck underride crash. We have set out to make sure that effective protection is on every defective area of every truck to prevent future underride tragedies.

The problem is that we keep coming against all of the excuses and mistaken beliefs which stand in the way of our moving forward with creative solutions to this public health & safety problem. So my goal now is to debunk the myth that safety countermeasures — like a comprehensive underride protection rule  — are unnecessary and will over-regulate the trucking industry.

First of all, let’s make it very clear that truck underride is not a new problem or even a newly-discovered problem. No, in fact, we have found an 1896 patent for a side underride protective device for a street car and a U.S. patent filed in 1913 for a safety device for the side of motor vehicles. In 1969, the Department of Transportation acknowledged the side underride problem in the Federal Register when they indicated that they intended to extend underride protection to the sides of large trucks.

Second, if the industry was going to solve this problem all by itself, then it would have done so by now. It has not. And I am convinced that, despite the signs of progress which we have seen, there will never be complete and comprehensive underride protection without regulation.

There are too many layers of responsibility in this process; each one involved can point the finger of blame at someone else and the end result is that this problem has fallen between the cracks. I, for one, will not let that continue on my watch.

Next week, we are hosting an Underride Briefing in the Capitol Visitor Center, Room 215, from 2:30 – 4:00 p.m. We are hoping for good attendance from legislative offices so that they are accurately informed about the Stop Underrides Bill — enabling them to wholeheartedly jump on board for this Win/Win solution.

The Senate Commerce Committee had a mark-up today of the AV Start Act.

Here’s hoping that there will be a similar call for safer trucks to be rolling out to deliver goods. And let’s learn from Wabash National’s approach to innovation:

Wabash was first introduced to the possibility of using composites in the trailer by Structural Composites, a Melbourne, Fla.-based company that was using unique composite technology for shock-mitigating Navy boats. Wabash assessed performance and economic metrics, then benchmarked how the technology might apply to trailers.

Wabash opted to use composites, however the project came with a steep learning curve for everyone involved. “We had a lot to learn about semi-trailers and refrigerated truck bodies and what kind of loads they go through,” says Scott Lewit, president of Structural Composites. “And they had to learn from us about what composites can do.” Yeagy encouraged the team to push the boundaries and not be afraid to fail, recalls Lewit. “This approach allowed us to learn and innovate from failure and to rapidly develop and deploy new technology,” he says.  The Trailblazing Trailer, Composites Manufacturing, Evan Milberg , July 5, 2017

Front Underride Protection Research; Why don’t we have FUP in the U.S.?

Truck Safety, , ,

People die, on a regular basis, when their car goes under the front of a large truck. Europe has a Front Underride Protection standard for large trucks. Here is some research on this topic to help inform U.S. lawmakers, regulators, and industry leaders on how we can bring this added level of protection to our roads.

  1. Heavy Truck Front Underride Protection Devices Design Principles, International Journal of Vehicle Systems Modelling & Testing, Vol. 6, No. 2, 2011
  2. Heavy truck front-end deployable system opportunities for crash compatibility with passenger vehicles, Keith Friedman, D. Mihora, & J. Hutchinson, Pages 1-12 | Received 07 Aug 2015, Accepted 31 Jan 2017, Published online: 22 Feb 2017,  ABSTRACT
    By 2030, substantial increases in the number of heavy trucks are expected to be on roadways throughout the United States. Currently, 3000 to 5000 occupant fatalities occur in the vehicles impacted by heavy trucks. A significant portion of these engage with the front end of the heavy truck. The use of radar systems has been shown to significantly mitigate many of these rear-end crashes. In this study, the use of deployable front-end airbags is evaluated in terms of the potential effects on passenger vehicles when they are struck in the front or rear by the front of a heavy truck. A virtual testing methodology for the evaluation of various designs under impact conditions is described. The study reports on the potential effects of radar-activated, heavy-truck, front-end airbag systems on crash mitigation in front- and rear-end impacts.
  3.  Rear underride crashes are easier to address than front or side ones, IIHS Status Report, Status Report, Vol. 48, No. 2 | March 14, 2013, Front underride guards, which are required in the EU to protect vehicle occupants in crashes with combined speeds of about 35 mph, also might prevent some deaths. An earlier Institute study of fatal truck crashes in Indiana found that 9 out of 44 front underride crashes might have been survivable in the absence of underride (see “FARS undercounts fatal large truck-car underride crashes,” Feb. 15, 1997).
  4. SuperTruck project for fuel efficiency might also provide better front underrun protection with tractor design. In trucking today, it seems nothing is off the table when it comes to enhancing vehicle fuel efficiencies. Old technologies are being reexamined, while new ones are studied and tested. A new era of ultra-clean, ultra-efficient trucks is just around the corner, likely putting old-style, long-nosed, slab-grilled rigs out to pasture once and for all. See SuperTruck tractor photos here: Fuel Smarts The Future of Fuel Economy, Truckinginfo.com, by Jack Roberts, June 2016
  5.   Design of a Tractor for Optimised Safety and Fuel Consumption 3.4 Future Design Concept Trucks
    The EC funded integrated project Advanced PROtection SYStems “APROSYS” is one of the most important projects for this study because it is intended to start this project based on these results. In the APROSYS project a safety concept for commercial vehicles which is able to deflect a vulnerable road user (VRU: pedestrians and cyclists) sideways in case of an accident by using the impact impulse was developed. The achieved deflection reduces the risk of a run over. A tapered truck front has been designed and analysed that allows additional deformation space for frontal collisions. Such a front shape can be realised by an add-on structure mountable to the front or by a fully integrated concept as shown in Fig. 3-13. In this project the integrated concept will be scaled to a 40 t-HGV truck.                                                                                                             During the development phase of the new front structure in APROSYS a large number of design versions were generated and assessed. The resulting final principal shape was compared to the basic truck in various numerical simulations with different accident scenarios, pedestrian models and parameter settings. Due to the deflection principle, which is used in the rounded front design for the weakest traffic participants, the structure underneath can be designed mainly for protecting the heavy vehicle’s occupants and integrating partner protection relating to passenger vehicles (improved compatibility). The deflection is not only a solution for the protection of pedestrians, but also reduces the impact energy introduced into the heavy vehicle and the passenger car in a HGV-to-car-accident.
    Such a convex truck front can significantly reduce the risk of a run over for VRU and also deflect passenger cars. In addition, it provides a crush zone for energy absorption. The enhanced passive safety could be shown in avoiding serious rollover accidents by 87.5 % of the simulated cases in APROSYS [FAS08].
    Another concept truck shown in Fig. 3-14 was presented at the IAA Commercial Vehicles
    2002 in Hannover. The Aero Safety Truck is a semi-trailer tractor for long-distance transport.
  6.  NHTSA – THE HEAVY GOODS VEHICLE AGGRESSIVITY INDEX

    http://www-nrd.nhtsa.dot.gov/pdf/esv/esv21/09-0323.pdf  Currently the structural AI is addressing the primary
    contact only (the contact with the truck front).
    However, numerical studies and experiments [14]
    have shown the severity of the secondary impact
    makes it a highly relevant aspect for future
    consideration. Studies of the “nose cone” [6]
    indicated not only a reduced likelihood for run-over,
    but also a reduced severity of the secondary impact
    (prevent forward-projection of pedestrian).
    Existing test methods for passenger cars are
    continually under development, such as the research
    into rotational acceleration as an assessment method
    The concept was developed in the innovation and design centre of the vehicle manufacturer Hymer. The improved aerodynamics lead to a reduction in fuel consumption of up to 3 l/100 km. An improvement of safety is realised by an extremely stiff safety cage [LAS03, HYM02]                                                                                                              The DAF Xtreme Future Concept (XFC), which can be seen in Fig. 3-15, was presented at the IAA Commercial Vehicles in 2002. The improved aerodynamic concept reduces fuel consumption and the danger of overrunning other road users by a deflecting frontend. The cabin is designed to be based on an aluminium space frame [EAA02].                                                                                                                                                    The Scania Concept illustrated in Fig. 3-16, was also presented on the IAA Commercial
    Vehicles in 2002 as a bonnet truck concept for the future. The targets are to identify the market interest for this concept and to optimise aerodynamics. In 2003 an additional concept was presented with the Scania Crash Zone Concept. It has an added structure of 600 mm at the front that absorbs more energy than that of a conventional truck. Therefore the survivable collision speed rises from 56 to 90 km/h. It has potential to reduce the number of fatalities in car to truck collisions. The extra weight for nose concept amounts to 250 kg [SCA02, HAH03].                                                                                         In 2008 MAN presented the Bionic Truck with the body form of a dolphin shown in Fig. 3-19. The design of the truck leads to a reduction of fuel consumption up to 25 % according to the manufacturer’s declaration. Therefore the cabin needs to be lengthened by 70 cm and the trailer by about 50 cm. So over all, the truck is 1.2 m longer than a conventional truck.
    Furthermore comprehensive design changes are carried out at the tractor and at the trailer. The trailer has a much rounder front shape. The trailer has a tear drop shape with a tapered rear part and its wheels are covered. For these reasons the truck has a cD value of 0.29 [SCH08].

  7.  Investigating the extent to which UNECE Regulation 93 constrains the ability of Europe to permit longer trucks to improve environmental and safety benefits By Iain Knight
  8. Piercing the Passenger Compartment — Voluntary Efforts to Stop the Horrors of Underride Truck Crashes by Andy Young

Other posts on Front Underride Protection:

How Wabash Prototype Side Guard Could Impact Truck Underride Innovation, Technology, & Regulation

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After hearing some great news Friday night, I want to put it into perspective and bring up for discussion what it might mean to the future of underride protection. Last week, Wabash Trailers revealed their prototype side impact guard at the North American Commercial Vehicle Show in Atlanta: Such exciting news! Wabash Trailers has taken initiative to save lives with prototype side guard!

Other interesting recent posts and news includes:

We lost AnnaLeah and Mary in an underride crash on May 4, 2013. As we began to discover things about underride in the months after our crash, we determined to help bring about change. But by June 2014, when we had met with DOT and toured Great Dane’s Research & Design Center in Savannah, we realized that there was very little communication and collaboration going on among the various stakeholders — government, manufacturers, engineers, researchers, safety advocates, etc. That’s when we thought about the idea of an Underride Roundtable.

We figured that if someone, who could do something about underride, lost a loved one in an underride crash, then they would move heaven & earth to solve the problem. Not willing to wait, we began to take action ourselves to try and bring about the best possible underride protection. By the time the first Underride Roundtable took place at the IIHS on May 5, 2016, we had made many contacts and had begun to see meaningful progress in underride protection.

But we knew that that was still not enough when, on March 14, 2017, Lois Durso and I attended the Senate Commerce Committee Hearing at which an update on Truck Safety was given. We were disturbed that side underride was not even mentioned — having already witnessed successful side guard crash testing of Aaron Kiefer’s TrailerGuard System and knowing that we would, in a few weeks, see crash testing of Perry Ponder’s AngelWing side guard.

That was when we decided that we were sick & tired of waiting for someone else to do something about it and began drafting the Roya, AnnaLeah & Mary Comprehensive Underride Protection (RAM CUP) Act of 2017 ourselves. Since that day, we have been talking and writing about this important legislation ceaselessly with all of the stakeholders, including many legislative offices both Republican and Democrat.

So you can perhaps imagine our excitement when we got a call in July from Senator Gillibrand’s staff with the news that the Senator wanted to work with us to introduce this bill. Not only that, but her plan was to wait and introduce it with Republican support to enable it to move forward. And that is where we are at, hoping to hear soon that a Republican from each House will soon join Senator Gillibrand and Congressman Cohen to set the ball rolling on a mandate which will result in comprehensive underride protection on all trucks.

While we, like anyone else, want to see the advancement of crash avoidance technology, we think that it is also vital to act to make crashes, which do occur, more survivable. Both/and not either/or. Thus we wait expectantly for the introduction of the Stop Underrides Bill as a truly bipartisan effort to bring about a long-overdue solution to a ubiquitous public health and safety problem.

A few days ago, after posting about the fantastic news from Wabash — and after earlier in the week posting about Stoughton’s announcement of stronger rear guards being standard on their new refrigerated trailers — I ran across this post which I wrote in May (be sure to pay attention to what industry leaders have said about innovation, technology, and regulation, and think about how it applies to the underride issue): Truck Industry Leaders: “Clarity is probably the biggest need we have so we can plan accordingly.”

Mandates take burden off manufacturers. Crash tests in labs better than crash tests occurring in real world.

Clearly, we have begun to see effective communication and collaboration taking place. We are thankful for the efforts of so many and encouraged at how the industry is making great strides. We know that it will continue to require a multi-prong strategy and that a comprehensive underride regulation can create a framework for us all going forward. It is for that reason that we included in the Stop Underrides Bill a requirement for a Committee On Underride Protection (COUP) because we want to ensure that the collaboration will not be just an idea but a reality.

We hope that we can count on the support of everyone involved to persevere in this process. And we want to end with this final thought:  We know that rear underride guards have been known at times as Mansfield Bars, and we think that Roya, AnnaLeah and Mary would have been tickled pink if side guards — or the entire comprehensive underride protection system — would become known as Roya, AnnaLeah & Mary Guards — or more simply, RAM Guards.

Jerry and Marianne Karth

Lois Durso

Stay Tuned for an Upcoming Underride Briefing in the Capitol Visitors Center, Room 215, October 12, 2017, 2:30 – 4:00 p.m. Experts will be available to answer questions about the underride problem & solutions.