May 4, 2013 seems like just yesterday; has anything changed?

There’s no easy way to get through that time of year when we remember how AnnaLeah & Mary were suddenly snatched from this earthly life. How can it have been ten years ago? May 4, 2013 seems like just yesterday.

Read this post all the way through to find out what advances have come about, or skip to the end to find out how you can help. Despite our loud voices continuously raising awareness and pushing for change, progress has been painfully slow. But these are some actions which the USDOT has taken:

  • Rear underride guards are now on the annual commercial motor vehicle inspection checklist (rule issued by FMCSA in December 2021). This is important because poorly-maintained rear guards increase the chance of crash severity.
  • After beginning work on an improved rear guard rule in December 2015, in response to our 2013/2014 petitions, the National Highway Traffic Safety Administration (NHTSA) finally issued an improved rule in July 2022. Incredibly, it fell short of requiring that the guards had the full strength already proven possible by the IIHS testing of nine major trailer manufacturers! We have petitioned NHTSA to reconsider this ill-advised decision.
  • NHTSA began taking applications for membership on an Advisory Committee on Underride Protection (ACUP) in July 2022. They finally announced the selected committee members in April 2023. The first ACUP meeting will take place virtually on May 25. I’m thankful that I will, at last, be able to sit “around the table” with a diverse group of stakeholders to hammer out reasonable solutions to this century-old problem.
  • Simultaneously with the ACUP announcement, and in advance of receiving any recommendations from the Advisory Committee, NHTSA published an Advanced Notice of Proposed Rulemaking (ANPRM) for a potential side guard regulation. Their cost benefit analysis is based on questionable data and concludes that a side guard regulation would not be cost effective. We are working hard to provide more accurate information in order to correct the CBA in favor of saving lives.

“How can I help?” I thought you’d never ask!

  • Pray for the ACUP members and for this process to produce meaningful outcomes.
  • Only 17 states have an UNDERRIDE FIELD on their state crash report form. This contributes to underreporting of these deaths. By 5:00 p.m. EST on MAY 3, submit a simple, brief Public Comment here. Tell NHTSA you want them to require (not merely suggest) that states have an Underride Field (and which indicates whether it was front, side, or rear) on their crash report form.
  • By June 20, submit a Public Comment on the side guard ANPRM here. Tell them why you think that there should be a side guard regulation (simple reason: To Save Lives).
  • Tens of thousands of underride victims have been a nameless group whose senseless deaths have been swept under the rug for decades despite the ingenuity of engineers to prevent horrific underride. No more. We would like to remember these Precious Ones Gone Too Soon in a special way. We hope to receive permission from the USDOT to install a Commemorative Bell of Hope at their office building in Washington, D.C. We will be organizing a day In Memory of Underride Victims — to ring the bell and call out the names of individuals who lost their lives to underride. We do not know every name, but we will include as many as possible. If you would like to contribute to the purchase of this bell or participate in this event, please let me know by writing to me at marianne@annaleahmary.com.
Side Guard Crash Test in Raleigh, September 2022
To remember how AnnaLeah & Mary lived — full of love & laughter — not merely how they died.

What Do Baseball & Truck Underride Have In Common?

Now, I’m only a Cubs fan by marriage. Early on in that marriage, I learned what a die-hard fan is and joined the club. But I’m not as familiar with historical details as my husband. Like, what’s with the 1969 Cubs?

However, I have become acquainted with truck underride history and know that, in 1969, our U.S. Department of Transportation was working on rear underride guard rulemaking — though it never became law until 1996 — and said that they intended to add side underride protection on trucks. Never happened.

After losing AnnaLeah and Mary in 2013 due to rear underride, I was, of course, very interested in the updated rear underride guard rule in July 2022. In fact, I was quite disturbed to learn that NHTSA blew an opportunity to require a level of underride protection proven possible by the Insurance Institute for Highway Safety and nine trailer manufacturers, who were given the TOUGHGUARD award — further evidenced as technically feasible by the survivor of a 2017 rear end truck crash.

Imagine my further consternation when I learned that at least part of the basis for that July 2022 Rear Impact Guard Rule was a NHTSA “engineering judgement concern” for “potential rotation outboard.” What that means is that if the rear guard were stronger at the outer edges of the tractor trailer, that is strong enough to prevent underride, then the car upon collision might rotate or spin out into traffic and collide with another vehicle causing a secondary collision — what the industry dubs “unintended consequences.”

Rear Retrofit Crash Test

Ha! The reality is that a secondary crash such as that would be so much more likely to allow the crashworthiness features (crumple zone, airbags, seat belt tensioners) of the involved vehicles to protect the occupants as intended. Was that really their rationale? Allow people to die under a trailer so that some other fender bender, i.e., non life threatening crash, wouldn’t occur?

I asked an engineer at a university to weigh in on this concern during a February 24, 2023, Friday brown bag lunch TEAM Underride Zoom discussion. Here are the rather garbled notes I jotted down: . . . fear that it would go out into the traffic; misplaced fear; projecting less inertia as it is deflected out from hitting truck — missing the fact that there is no catching equipment on a trailer — energy absorption — the trailer does not catch the car. If it collides at the rear corner, With or without guard it will rotate. The reason rotation takes place. . . because it is the 30% offset. Unintended Consequences.

I asked him to write up his thoughts for me to share and Jared Bryson, Smart Road Operations and Mechanical Systems Innovation Director at Virginia Tech, graciously and creatively obliged.

Baseball & Underride

I’d say that well-thought out explanation should be taken into consideration during a careful review of the July 15, 2022 rear underride guard rule and the questionable (my words) NHTSA decision to decline from requiring life-preserving underride protection at the outer edges of the guard. It’s guaranteed to mean the difference between life & death for more than one person in the days ahead.

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

FARS Coding of a Sample of Rear Underride Crashes

FARS Coding of a Sample of Rear Underride Crashes

In August 2022, we submitted a petition to the National Highway Safety Administration (NHTSA) Office of Defects Investigation (ODI) requesting that they investigate the potential safety defect of tractor trailers which do not have Rear Impact Guards (RIG) with the Insurance Institute of Highway Safety’s TOUGHGuard level of underride protection. In response, on January 20, 2023, we received a “Defect Petition Acknowledgement Letter” and Opening Resume related to investigation DP22-004.

The Opening Resume includes a chart indicating that the ODI had received zero Safety Complaints related to Rear Impact Guards. More specifically, they listed zero for the following categories:

  • Complaints
  • Crashes/Fires
  • Injury Incidents
  • Number of Injuries
  • Fatality Incidents
  • Number of Fatalities.

Having lost two daughters due to a rear underride crash on May 4, 2013, I knew that this was most certainly not an accurate representation of the extent of preventable rear underride tragedies, but rather the failure of the process to identify an unreasonable safety risk without the submission of formal complaints. I took it upon myself to immediately rectify that unfortunate situation.

Based on a daily Google Alert email notification of truck crashes, memorial website posts on annaleahmary.com record crashes which appear to involve underride. Those memorial posts include not only rear underride crashes but side underride and front override, as well. So I made a list of all the posts which appeared to involve underride crashes and deaths at the rear of large trucks.

Then I made a pdf of each memorial post, as well as a pdf of a related media article, which either contained a photo or narrative indicating that it was quite probably a rear underride. I numbered each of the crashes and ended up with 176 which appeared to me to be rear underride crashes. I recently discovered that one of those was a side underride, so I have taken that one out of the set.

I proceeded to print each of the memorial posts and media articles — adding, when I could, obituaries and photos of the underride victim. I put these documents in a binder and mailed it to the NHTSA Office of Defects Investigation at the Department of Transportation in Washington, D.C. Additionally, upon their request, I provided the ODI with digital copies of each document.

My next step was to begin a search for these crashes in the NHTSA Fatality Analysis Reporting System (FARS) data query tool. The FARS data comes from fatal crash reports written by investigating officers and submitted to State FARS Analysts. We have learned that FARS Analysts are trained to strictly adhere to what they see in the crash report. If the investigating officer marks an underride field checkbox or indicates in the report narrative that underride occurred, then the FARS Analyst can code the crash as Underride.

Unfortunately, at present, only 17 states have an Underride Field on their state crash report forms. In addition, it appears that there is not adequate training for the investigating officers to know how to properly report an underride crash. The result is that these preventable deaths are vastly undercounted. Consequently, underride regulatory analysis by NHTSA, the federal highway safety agency, determines that effective underride regulations are “not cost effective” and available underride protective devices gather dust on the shelf.

The majority of the 175 rear underride memorial posts were for crashes which occurred in 2021 and 2022 and had, therefore, not yet been recorded in FARS. Thus, I was left with 38 crashes which could be searched for with the NHTSA FARS data query tool by a team of families of underride victims. The following table summarizes the results of that search.

mwk 4/1/2023

Clearly, underride is vastly underreported, as has been previously documented in many reports and studies (Braver, et al, 1997, 1998; Brumbelow; GAO Truck Underride Report; Karth). However, it is not enough to lament about the lack of accurate data. What should we do? For starters. . .

  • Improve training of law enforcement on investigating and reporting underride crashes.
  • Improve training of FARS Analysts on reporting underride crashes.
  • Require states to include an Underride Field on their state (and local) crash report forms.
  • Reassess and amend the Rear Impact Guard Rule, published on July 15, 2022, which falls far short in its protection of vulnerable motorists and other road users with proven and available technology.

In Memory of Precious Ones Gone Too Soon

LPD+ Saves Lives; But what’s an LPD+?

Words have power. Words convey meaning. Let’s choose words which will enhance understanding and catalyze life preserving action.

Take the word #underride for example. How many people realize that an underride guard is a “simple” engineering device which — if properly designed and installed — can prevent a passenger vehicle, as well as pedestrians, bicyclists, and motorcyclists, from ending up under a truck in the event of a collision?

For over a century now, despite industry and government awareness of the problem, underride tragedies have been allowed, for the most part, to go unchecked. Amazingly, a 1915 patent for a safety device to prevent side underride predates the first patent for a traffic signal filed in 1922:

Safety Device for Motor Vehicle” to prevent side underride, 1915 Patent

Unfortunately, there has been too much confusion about the gaping space below a truck’s floor which leads to horrifying injuries when there are collisions with the front, side, or rear of a large truck — not to mention too little action taken to correct that dangerous design. One misunderstanding that I’d like to clear up relates to side underride.

Lateral Protection Device (LPD) is a term coined for equipment installed on the side of a truck to prevent Vulnerable Road Users (pedestrians, bicyclists, and motorcyclists) from being swept under. It is not designed to stop a passenger vehicle from going under. A Side Skirt is a relatively flimsy device, which is designed to improve aerodynamics and save fuel; it is not designed to prevent underride. A Side Underride Guard (SUG) or Side Impact Guard (SIG), on the other hand, is designed to prevent a passenger vehicle from going under a truck. Thankfully, it will also protect Vulnerable Road Users from being killed under a truck. And, by the way, it adds to the fuel savings of side skirts.

That is why a SUG or SIG can rightfully be called a LPD+; it does what an LPD is meant to do — and so much more. Why on earth would we require or install equipment on the U.S. fleet which is less effective than a LPD+ that is designed to protect All Road Users? *

Unbelievably, all we have at present is a patchwork quilt of underride standards, or lack thereof, in this country. It’s high time that our nation’s highway traffic safety agency step up to the plate. @NHTSAgov, make wise and timely use of the Advisory Committee on Underride Protection to provide guidance which appropriately defines and regulates underride devices — thus fulfilling your mission to reduce emissions and save lives. Otherwise, we can expect more of the same: Death By Underride day after day, year after year.

Underride Guards Save Lives

* The term LPD+ was suggested by Garrett Mattos on December 2, 2022, during a Zoom discussion among underride experts and advocates collaborating together as TEAM Underride to advance the implementation of engineering devices to prevent Death By Underride for All Road Users.

The Making of a Very Special Memorial Bench

This is a record of the creation of a very special bench in memory of two sisters who are no more — AnnaLeah and Mary Lydia Karth.

#madewithheart by Carole, a chainsaw wood carver, CC Carving: https://www.facebook.com/profile.php?... https://www.etsy.com/shop/cccarving?f…

I have fought the good fight, I have finished the course, I have kept the faith;

in the future there is laid up for me the crown of righteousness,

which the Lord, the righteous Judge, will award to me on that day;

and not only to me, but also to all who have loved His appearing. (2 Timothy 4: 7-8)

To God be the glory — their Creator and Redeemer.

too often, it’s hard, I know

to find a space where one can recall

not how they died

but how they lived & who they were

a place for grateful reflections

As Hard as It Is, It’s Important to Remember Our Lost Loved Ones

Background Music: “May It Be” Music: Enya Lyrics: Roma Ryan Recorded: Aigle Studios, Dublin

Released: 2001 for the movie Lord Of The Rings: The Fellowship Of The Ring

“May It Be” is both a blessing song and a prayer, written by Enya in collaboration with Nicky and Roma Ryan specifically for Peter Jackson’s film Lord of the Rings: Fellowship of the Ring at the request of soundtrack composer Howard Shore. It was composed in a style intended to evoke the cultural feeling of J.R.R. Tolkien’s world, in particular that of Tolkien’s elves.

Peter Jackson in Part One: From Book to Vision: “May It Be” is a blessing sung for those who choose to walk the long road, in defense of all that is good in life, no matter the odds. Honoring one’s commitment to what is true, loving and good, with perseverance even in the face of total hopelessness, is a continual theme appearing throughout all of Tolkien’s work. (Paraphrased) https://genius.com/Enya-may-it-be-lyrics

“Economism Is Out Of Control” In Life & Death Regulatory Analysis

I’d like to see an overhaul of the current federal guidelines for evaluating the cost-effectiveness of safety countermeasures. And it probably needs to start with an Executive Order. Without such a decisive action, we are likely to see a continuation of compromise which will pile up more senseless and preventable traffic-related deaths.

In the aftermath of a horrific truck crash on May 4, 2013, which I survived, I discovered that the major factor which stole my daughters’ lives — underride — was, is, and probably will continue to be woefully underreported. In fact, recent searching, of the NHTSA Fatality Analysis Reporting System (FARS) files on truck crashes, has revealed the shocking extent of the agency’s failure to record underride deaths as such. Yet, the known-to-be-undercounted data on underride deaths is heavily factored into the formula for underride regulatory analysis.

Executive Order 12866, issued by President Clinton in 1993, sets out the requirements for approval of new federal rules by the Office of Information and Regulatory Affairs (OIRA), which is a part of the White House Office of Management and Budget (OMB). Circular A-4 spells out the specific guidelines for federal agencies to follow when preparing regulatory analysis.

Order 12866 requires agencies to conduct an analysis of the benefits and costs of rules and, to the extent permitted by law, directs that regulatory action shall only proceed on the basis of a reasoned determination that the benefits of a regulation justify the costs.  President Obama issued Executive Order 13563 “Improving Regulation and Regulatory Review,” on January 18, 2011, to reaffirm and supplement Executive Order 12866 to further improve rulemaking and regulatory review. About OIRA

Of great relevance is a recent article in The New Republic by Timothy Noah, May God Save Us From Economists. Noah starts his piece out by describing the gruesome underride death of actress Jayne Mansfield on June 29, 1967, and then he says this:

The federal government took 28 years and three months to get its underride guard rule out the door. By then, nearly 9,000 more people had died the same way Mansfield had, by sliding under a big semi.

Why was three decades’ deliberation necessary to impose such a commonsense safety precaution? Because Mansfield met her fate just as the economics profession was advancing, like an occupying army, into noneconomic agencies of the federal government. The result was a mindset—an ideology, really—that dominates public policymaking to this day. The Marxists (of whom I am not one) have an excellent term for this ideology: Economism. At a time of extreme political polarization, an Economicist bias (pronounced eh-co-nom-i-sist) is practically the only belief that Democrats and Republicans share.

Brilliant observation. Of course, the stranglehold on underride rulemaking is much worse than he realizes (and I told him so via Twitter).

Noah follows that opening with a very lengthy discussion of how this mindset has affected many issues we face today. Then he closes off his comments by returning to the topic of underride:

Because Economism is out of control. Those Mansfield bars? In 2015, NHTSA proposed a regulation requiring that underride guards meet a higher standard of strength and energy absorption, because every year more than 200 people die, on average, the same way Jayne Mansfield did more than half a century ago. Still. The final rule came out this past July, but only after New York Democratic Senator Kirsten Gillibrand inserted into the infrastructure bill language telling NHTSA to get off the dime.

It’s progress of a sort to wait seven years for a safety regulation instead of 28 years, and 1,400 deaths is fewer than 9,000. But when the new regulation was finally published, Joan Claybrook, who was NHTSA administrator in the 1970s, said it was wholly inadequate—“an affront to the families of underride victims.” Other safety advocates seemed to agree. Why wasn’t the Mansfield bar rule stronger? Because, the economists tell us, a human life is worth only so much.

Where will we go from here? Can we hope that the present Administration will issue a new Executive Order that takes a different approach to regulatory analysis? Or should we plan on more of the same — somebody getting away with murder? Rest assured, countless lives depend on this.

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

Driver Fatigue

Drowsy driving is one of many driving hazards which renders drivers less capable of responding appropriately to prevent a crash. Distracted, drugged, and drunk driving likewise cause preventable tragedies.

Article on Vehicle Technology to Detect Microsleep in a Driver: Sleepy Behind the Wheel? Some Cars Can Tell, By ERIC A. TAUB MARCH 16, 2017, NY Times

Drowsiness Alert This feature may alert you if you’re drowsy and suggest you take a break when it’s safe to do so.MyCarDoesWhat.com

Read this January 2017 article on DISTRACTED DRIVING: The Unimaginable Grief of Distracted Driving Deaths How road safety advocates are tackling a public health problem head on.

October 31, 2016, Update on ELDs: ELD mandate survives court challenge “A federal mandate requiring nearly all U.S. truck operators to use electronic logging devices to track duty status has been upheld in court, meaning the December 18, 2017, compliance date remains effective.” I still am hoping to get a Tired Trucker Roundtable organized because ELDs are only a part of the solution.

UPDATE on Electronic Logging Devices: In lawsuit Court date set for ELD lawsuit The federal court overseeing the lawsuit challenging the U.S. DOT’s electronic logging device mandate has scheduled oral arguments for the case to be heard in court on Sept. 13, where the owner-operator plaintiffs in the case hope to convince the court to strike down the U.S. DOT’s ELD mandate. The DOT, meanwhile, hopes to convince the court to uphold its mandate.

UPDATE, May 21, 2016: I propose a Tired Trucker Roundtable to more comprehensively address driver fatigue crashes.

UPDATE August 3, 2016: Tired Trucker Roundtable: If we plan it, they will come. Can we pull it off?

After the truck crash which killed AnnaLeah and Mary, we never saw the truck driver’s paper log books and he was not able to tell us why he hit us. We suspect that drowsy driving may well have played a part. But it is a very difficult thing to prove.

I can’t go back and re-do that day and make sure that truck driver is fully alert throughout his entire work day on the road–especially that stretch of I-20 in Georgia near Exit 130. But I can advocate for the widespread public health problem of driver fatigue to be recognized and tackled.

See my ideas here for a Tired Trucker Roundtable (and, as Lou Lombardo has said, it could also impact drowsy driving by any driver on the road): I propose a Tired Trucker Roundtable to more comprehensively address driver fatigue crashes.

Tired Trucker Roundtable

Congress, let DOT do their job to stop tired truckers. Make saving lives the priority and not saving corporate dollars. See what DOT Secretary Foxx says about trucker Hours of Service: Why We Care About Truck Driver Fatigue.

More than 20,000 people are calling for Vision Zero. That means that the people want this country to make SAVING LIVES The Priority: Save Lives Not Dollars: Urge DOT to Adopt a Vision Zero Policy

For that matter, any form of Distracted or Impaired Driving needs to be addressed in a comprehensive way in this nation (and, of course, globally): Do it, President Obama, for We the People of this United States of America! #VisionZero.

Update, February 10, 2016:   NTSB Finds Fatigue, High-Risk Motor Carrier Led to Fatal 2014 Multi-Vehicle Collision

Update, December 10, 2015, The Electronic Logging Device Rule is now final. Read more here: https://annaleahmary.com/2015/12/fmcsa-finally-releases-the-electronic-logging-devices-rule-to-track-trucker-hours/

December 14, 2015: Gadget to stop Drivers Nodding Off at the Wheel Could Become Compulsory in new European regulations.  My goodness, if this can be done & would Save Lives, why would we NOT do it, America?! http://www.telegraph.co.uk/news/12048267/Gadget-to-stop-drivers-nodding-off-at-the-wheel-could-become-compulsory.html

DWF = Driving While Fatigued (or Drowsy Driving)

Driver fatigue can affect any driver–you included, or the driver of a vehicle in which you are a passenger.

“…Driving while fatigued is comparable to driving drunk, only there is not the same social stigma attached. Like alcohol, fatigue affects our ability to drive by slowing reaction time, decreasing awareness and impairing judgment. Driving while sleep impaired is a significant issue, and is no longer tolerated. Legislation {in Canada} is beginning to change by handling collisions cause by a fatigued driver as seriously as alcohol-impaired crashes.” https://canadasafetycouncil.org/safety-canada-online/article/driver-fatigue-falling-asleep-wheel

Interesting facts about sleephttp://www.vox.com/2015/2/10/8008005/sleep-facts

and about Drowsy Driving:  http://drowsydriving.org/about/facts-and-stats/

IMG_4462

This is our crash, which may have been caused by a drowsy truck driver–killing AnnaLeah (17) and Mary (13).

Fatigue is an ongoing problem among truck drivers. There are many factors, some of them beyond a driver’s control, which contribute to fatigue. Unfortunately, their fatigue too often contributes to a greater likelihood of a crash.

Currently, there are inadequate means to 1) prevent truck drivers from driving fatigued and 2) prove that it was a causal factor when accidents occur.

See posts on this website regarding driver fatigue:  https://annaleahmary.com/tag/driver-fatigue/

Driver Fatigue in Relationship to Driver Pay: http://www.fullyloaded.com.au/industry-news/1009/truck-drivers-pushed-to-the-limit

On Driver Fatigue from Brake Road Safety in the UK:  http://www.brake.org.uk/wake-up/15-facts-a-resources/facts/485-driver-tiredness

See posts on this website regarding electronic logging devices:  https://annaleahmary.com/tag/electronic-logging-devices/

How drowsy driving affected one family:

https://www.youtube.com/embed/vbipLMqmp1c
Check out these links for more information related to driver fatigue:

Truck Safety Coalition on fatigue: http://trucksafety.org/category/trucksafety-issues/fatigue-category/

How to fill out Trucker Log Books: http://www.thetruckersreport.com/how-to-fill-out-a-truck-driver-log-book/

Electronic Logging Devices have been mandated by legislation and the DOT rule which requires them has passed an important milestone. Here is a summary of its progress:

 “So, to break down the EOBR / ELD mandate process so far:

The road to the ELD mandate began when Congress passed MAP-21 in June 2012.

The president signed MAP-21 shortly thereafter, requiring the FMCSA to write a rule requiring use of electronic logging devices, or EOBRs, for all drivers that keep a Record Of Duty Status—about 3.1 million trucks and 3.4 million drivers today.

The FMCSA developed a Supplemental Notice of Proposed Rulemaking (SNPRM) that was sent to the Office of the Secretary, who approved it and sent it back to the FMCSA in July 2013.

From there, the rule moved over to OMB, where it cleared today, March 12, 2014.

The FMCSA will keep the rule for the next two weeks, eventually publishing the SNPRM for public comment.

A comment period will then take place, published as 60 days, giving anyone a chance to add their feedback.

The FMCSA will take those public comments and revise the rule, a process that can take between six and nine months.

According to these time frames, we can estimate a final rule to be published in the first calendar quarter of 2015.

Based on MAP-21 requirements, fleets will have two years to comply with these rules—meaning you will be required to implement an EOBR for an Electronic Logging Device by January 2017 at the latest.”

Taken from: http://eobr.com/eobr-news/eobr-mandate/eld-mandate-clears-omb/#more-849

We are thankful for the progress which DOT has made thus far with the Electronic Logging Device rule. However, we don’t want the process to drag out any longer than necessary. Lives are at stake!

Here is a link to make public comment on Electronic Logging Devices:  https://www.federalregister.gov/articles/2014/03/28/2014-05827/electronic-logging-devices-and-hours-of-service-supporting-documents

Watch these short informative videos on Electronic Logging Devices: http://trucksafety.org/watch-informative-videos-electronic-logging-devices/

Truck Safety Coalition on Electronic Logging Devices: http://trucksafety.org/category/trucksafety-issues/electronic-logging-devices/

Driver Fatigue Monitoring: http://www.bbc.com/news/technology-22640279

 

Protecting Passenger Vehicles from Side Underride with Heavy Trucks (SAE publication)

At various times, members of the trucking industry have voiced doubt about the ability of side guards to function effectively in “real world” crash scenarios.

“We have yet to see evidence that side underride guards would be an effective safety countermeasure,”  American Trucking Associations   Vice President of Public Affairs and Press Secretary Sean McNally said. “Until these devices can be shown to be reliable outside the test track, we believe Congress and regulators should focus on reducing crashes by addressing aggressive and distracted driving and investing in existing, proven safety technologies, including emerging connected vehicle technology.

ATA also notes that trucking companies have opposed the legislation because it “promotes a solution that is neither data-driven nor proven to be effective in real-world highway settings,” and entails potentially “dangerous” and “unintended” consequences. Congress takes third swing at side underride bill

For this SAE research, Protecting Passenger Vehicles from Side Underride with Heavy Trucks, the authors carried out computer simulation in order to assess how side guards would operate in various conditions. According to Garrett Mattos, the principal author,

  • We simulated angles (0 degrees, 30, 60, and 90 degrees). 
  • We simulated sliding (as if on ice).
  • We simulated both stationary and moving truck. Slightly worse outcomes for moving truck vs stationary truck.

Garrett Mattos presented an overview of the research paper at the Side Guard Task Force Meeting on February 26, 2021. You can see his presentation at 1:46:21 on this YouTube Video:

ABSTRACT

Impacts between passenger vehicles and heavy vehicles are uniquely severe due to the aggressivity of the heavy vehicles; a function of the difference in their geometry and mass. Side crashes with heavy vehicles are a particularly severe crash type due to the mismatch in bumper/structure height that often results in underride and extensive intrusion of the passenger compartment. Underride occurs when a portion of one vehicle, usually the smaller vehicle, moves under another, rendering many of the passenger vehicle safety systems ineffective.

Heavy vehicles in the US, including single-unit trucks, truck tractors, semi-trailers, and full trailers, are currently not required to have side underride protection devices. The NTSB, among other groups, has recommended that side underride performance standards be developed and that heavy vehicles be equipped with side underride protection systems that meet those standards.

The work presented used virtual testing to evaluate the relative performance of example side underride devices compared with a baseline. Crash test results were utilized for validation purposes. A tractor-trailer, with and without side impact underride protection, was impacted by a passenger car and SUV under a range of impact conditions. Passenger vehicle intrusion metrics were calculated to provide an indication of relative risk for each impact condition. The results can support the development of side underride protection recommended practices.

DISCUSSION

The results of the analysis indicate that available side underride guards are effective at reducing passenger compartment intrusion (PCI) substantially in what are often fatal side underride crashes. Nearly all passenger compartment intrusion above the beltline was mitigated other than in the purely lateral impact conditions. When intrusion did extend above the beltline, e.g. in the purely lateral sliding condition, the amount of PCI was similar to the intrusion generated in a 56 km/h side impact of a 5-star rated vehicle. Further, the average amount of PCI in the above tests was similar to the amount resulting from small overlap tests of the same vehicle. These results demonstrate that an underride guard can provide a sufficient reaction surface to allow for the vehicle’s passive and active safety systems to protect the occupant. The underride guard also causes the location of PCI to move from near the occupant’s head and torso to the lower extremities which reduces the likelihood of serious or fatal injury.

In general, the results suggest that impacts with a moving truck/trailer combination are more severe than when the truck is stationary. The added velocity of the truck/trailer combination results in greater intrusion of the bullet vehicle firewall as well as slightly higher peak accelerations. Impact severity was also increased when the size of the gap between the end of the underride guard and the rear tires was increased. The increased gap size allowed the bullet vehicle to interact more with the rear tires. In the impacts with a large gap the trailer tires very nearly engaged the driver side door. These results can help to define a comprehensive test plan that can be used to assess the performance of an underride guard.

The acceleration pulses for all impacts were within the range of frontal and side impact crash test pulses generated in similar tests of vehicles that exhibit 5-star safety ratings. This indicates that these impacts were all survivable. The most severe impact scenario was a 56 km/h sideways slide into the trailer with an underride guard.

As shown, there is an 80% or greater reduction in PCI for impacts with an underride guard compared to the baseline condition. Additionally, the location of PCI in the underride guard impacts was generally found to be at the outer firewall area rather than at or above the belt line as in the baseline case. Reducing the PCI and moving the location of PCI away from the occupant’s head and torso both significantly reduce the likelihood of serious injury. No adverse effects were observed as a result of the underride guard.

These results indicate that tests used to evaluate the performance of underride guards should incorporate a moving truck/trailer combination as this was found to increase the severity of the impact. Additionally, the location and size of gaps between an underride guard and the trailer tires and/or landing gear should also be considered as this was found to affect the results. The results demonstrate, along with other work in the literature, that Finite Element analysis can enhance physical tests to expand the number of impact scenarios in a cost-effective and time-efficient manner. While additional impact conditions and test cases can be analyzed, the results are expected to further demonstrate the importance of trailer side underride guards in reducing passenger compartment intrusion under these crash conditions.

Side underride guards integrated into the trailer structure may further enhance the safety benefits associated with preventing trailer underride and limit added weight. Exploration of these design alternatives should be explored in the future in conjunction with additional crash vehicles and configurations.

Partners in the STOP Underrides Crash Test Tour

We are thankful for The Law Firm for Truck Safety, who graciously offered to match all donations up to $25,000 for the STOP Underrides Crash Test Tour. We welcome contributions of any size and wish to recognize all of our Business Partners and TEAM Underride Partners here.

Note: This is a work in progress; partners will be added as they join — although I might fall behind in getting them recorded! If you don’t see your name, or don’t receive a receipt, please let me know at marianne@annaleahmary.com.

How You Can Help TEAM Underride:

  • Contact us at marianne@annaleahmary.com, if you would like to become involved in planning and/or participating in the Tour.
  • For instructions on how you can donate to AnnaLeah & Mary for Truck Safety, a 501(c)(3) non-profit organization, contact us at: marianne@annaleahmary.com.
  • Donations can also be made on Facebook HERE.

Business Partners

Learn about the companies that have donated expertise, facilities, financial support,  and materials to this project for the saving of many lives.

      Academy of Truck Accident Attorneys       

 Maverick MetalWorks    AngelWingSkirts.com    TrailerGuards.com   

  Institute for Safer Trucking         StopUnderrides.org      Swenson & Shelley, PLLC

TEAM Underride Partners

Lois Durso-Hawkins and Mark Hawkins

In Loving Memory of Roya Sadigh

Aaron Kiefer

Trista Jean

Peggy Kiefer

Anthony Mastriano

Daniel Michel

Reshard Alexander

STOP Underrides Crash Test Tour

AnnaLeah & Mary for Truck Safety (ALMFTS) is collaborating with State Highway Patrols & safety groups to demonstrate engineering solutions at 2-day Underride Crash Test Events in at least 4 regions of the U.S.

Each Regional Event will include multiple crash tests — including one with & one without a side guard — as well as a keynote speaker & panel discussion to educate first responders, crash investigators, insurers, regulators, & the trucking industry on the deadly underride problem and solutions.

Organizers:

The STOP Underrides Crash Test Tour is a collaborative TEAM Underride effort of ALMFTSStopUnderrides.orgTrailerGuards.comAngelWingSkirts.comInstitute for Safer TruckingThe Law Firm for Truck Safety, and many other organizations and individuals, including families of underride victims. Go, Team, Go!

Crash Test Tour Event Sites:

As plans develop, information will be provided here on the schedule and locations where Crash Test Events will take place during 2023. Potential sites under consideration include Florida, Georgia, Massachusetts, South Carolina, Indiana, New York, and New Mexico. Subject to change.

Donors:

We are thankful for The Law Firm for Truck Safety, who graciously offered to match all donations up to $25,000. They were later joined by the Academy of Trucking Accident Attorneys (ATAA), who have added another $25,000 to our matching challenge. We welcome contributions of any size and wish to recognize all of our Business Partners and TEAM Underride Partners here.

How You Can Help TEAM Underride:

  • Contact us at marianne@annaleahmary.com, if you would like to become involved in planning and/or participating in the Tour.
  • For instructions on how you can donate to AnnaLeah & Mary for Truck Safety, a 501(c)(3) non-profit organization, contact us at: marianne@annaleahmary.com.
  • Donations can also be made on Facebook HERE.

STOP Underrides Crash Test Tour – Demonstrating Solutions:

Many Underride Stories – Tip of the Iceberg – Precious Loved Ones, Gone Too Soon:

One Underride Story: