Take advantage of the opportunity to comment on FMCSA’s rulemaking — extended through July 8, 2016, on this Advanced Notice of Proposed Rulemaking:
Make a comment here: Federal Register: regulations.gov on sleep apnea & truck drivers
Take advantage of the opportunity to comment on FMCSA’s rulemaking — extended through July 8, 2016, on this Advanced Notice of Proposed Rulemaking:
Make a comment here: Federal Register: regulations.gov on sleep apnea & truck drivers
Detlef Alwes, an engineer from Germany, suggested to me that the U.S. should discuss underride protection with the World Forum for Harmonization of Vehicle Regulations. I had never heard of it before. Apparently, the U.S. has not had much involvement with it in the past–at least not as far as underride protection.
But doesn’t it make sense to collaborate with other countries and come up with the safest possible vehicle regulations?
Most countries, even if not formally participating in the 1958 agreement, recognise the UN Regulations and either mirror the UN Regulations’ content in their own national requirements, or permit the import, registration, and use of UN type-approved vehicles, or both. The United States and Canada are the two significant exceptions; their UN regulations are generally not recognised and UN-compliant vehicles and equipment are not authorised for import, sale, or use in the US, unless they are tested to be compliant with US car safety laws, or for limited non driving use (e.g. car show displays).[4]
“The World Forum for Harmonization of Vehicle Regulations is a working party (WP.29)[1] of the Inland Transport Division of the United Nations Economic Commission for Europe (UNECE). It is tasked with creating a uniform system of regulations, called UN Regulations, for vehicle design to facilitate international trade.
WP.29 was established on June 1952 as “Working party of experts on technical requirement of vehicles”; the current name was adopted in 2000.
The forum works on regulations covering vehicle safety, environmental protection, energy efficiency and theft-resistance.” World Forum for Harmonization of Vehicle Regulations
Other links:
Dear Care for Crash Victims Community Members:
Achievements
Last year, Clarence Ditlow reported the achievements since publication of Unsafe at Any Speed to include the saving of an estimated 3.5 million lives (many millions more Americans were saved from suffering serious injuries). See
http://www.thenation.com/
Honor
As we walked through Battle Park on January 21, 2013, Mary took many pictures with her camera. I recently made a Youtube video with her photos. Not until I watched that video just now did I look more closely to read what was written on one of the headstones which we passed by:
Blessed are the early dead
Oh, Mary! I wonder what you were thinking when you saw that. Tenderhearted girl.
I am glad to see that the federal rulemaking has become more open to participation by those upon whom it has the most impact. I only hope that our Vision Zero goals will be genuinely considered and implemented to the benefit of us all.
Along that line, I just found this interesting article from 2013 which outlines the history of participation in the federal rulemaking process.
As a policymaking process, rulemaking is a civic paradox in two senses:
1. It often has substantial direct effects not only on industry but also on individuals (including small business owners), state and local government entities, and non-governmental organizations. Yet relatively few people know about rulemaking, and even fewer understand how it works.
2. Rulemaking’s formal legal structure is an open government ideal: it has broader transparency requirements and public participation rights than any other form of federal decision-making. Yet only a limited range of stakeholders—principally, large corporations and trade and professional associations—take advantage of their right to review the information on which an agency is making its decision, or effectively exercise their right to comment on the merit of the proposed rule.
Rulemaking 2.0: Understanding What Better Public Participation Means, And Doing What It Take to Get It1 by Cynthia R. Farina2 & CeRI3, March 1, 2013
And I am looking forward to the upcoming publication of the article on Visual Rulemaking by two law professors, with the inclusion of the story of AnnaLeah and Mary and our efforts to impact truck safety rulemaking. Elizabeth Porter & Kathryn Watts, Visualizing Rulemaking, N.Y.U. L. Rev. (forthcoming 2016).
Mary loved to capture every moment on her camera–from the mundane to the amazing. That included our walk on the trails of Battle Park on a beautiful day in January 2013 in her new home of Rocky Mount, North Carolina.
Mary’s photo story of the walk with her sister, AnnaLeah, dad, and mom is set to Horatio Spafford’s well-known hymn, “It Is Well With My Soul.” Fitting in so many ways. Peace like a river attendeth my soul.
Photography by Mary Lydia Karth (with a few by her mom as well):
We have scheduled a follow-up meeting to the Underride Roundtable on Friday, June 24, at 10:00 a.m. at the IIHS offices in Arlington, VA. Further details will be shared when available.
We will mainly be discussing the proposed Australian underride rule with a presentation by Raphael Grzebieta from Australia. It is our hope that this will help the United States assess the relevancy of Australia’s progressive work to the future of underride rulemaking for improved protection in our country.
News of this proposed rule:
Other topics — relevant to our goal of reducing underride crashes, fatalities, and severe injuries — will be addressed to some extent, including side and front underride/override, retrofitting, SUTs/exempt trucks, conspicuity, parking. Future meetings are anticipated in order to continue working on the preventable underride problem.
In addition to the underride rule from Australia, comments from Detlef Alwes of Germany should be carefully reviewed by anyone who holds responsibility for advancing underride protection. This is the most important point which he has made to me over & over in his communication with me via email:
Real energy absorbing underrun protection crash structures or deformation zones on commercial vehicles should become standard, as they have been on passenger cars for decades.
Here is a presentation on underride protection prepared by Detlef: Proposal for an Energy Absorbing Underrun Protection System for Commercial Vehicles
After observing the webcast of the Underride Roundtable, Detlef also made the following recommendations which he would like shared with interested parties in the United States who bear responsibility for the advancement of underride protection.
Detlef’s last recommendation should be given serious consideration, as underride protection is not unique to one country or another. Saving lives is saving lives.
The UN/ECE level (WP29) aims for worldwide technical harmonization of vehicles: The worldwide technical harmonisation of vehicles is governed by two international agreements – the 1958 Agreement and the 1998 parallel Agreement. These agreements establish harmonised requirements at global level to ensure high levels of safety, environmental protection, energy efficiency, and theft protection. Both agreements help eliminate existing technical barriers to trade and prevent the creation of new ones. The involvement of the EU enables easy access to non-EU markets for manufacturers.
This is Detlef’s experience with this kind of collaborative process:
This suggestion is based on my experience in another field: I was the German representative in an international committee for space debris mitigation (IADC: Inter-Agency Space Debris Coordination Committee). The 11 members of the space leading nations have developed the so-called ‘Space Debris Mitigation Guidelines’.
These Guidelines have been presented to the UN, to the Scientific Subcommittee of UNCOPUOS (UN Committee on the Peaceful Uses of Outer Space). In this Committee the UN Guidelines for Space Debris Mitigation have been worked out and ratified. It was confirmed by the Committee that this process was very effective and very fast – exemplary. The initiative was started by US (NASA), Europe (ESA) and Russia.
It would be great, if we could establish also such an international committee to develop underrun protection guidelines, which we present to the UN/ECE WP 29. The Proposal to the WP 29 can be put on the agenda by the heads of delegation of the represented nations. Maybe such a process can be started by the initiative of you, the IIHS, the NHTSA and others. According my experience, the German governmental authorities will not be initiative to start. They will follow if it works no longer differently.
His reaction to the Virginia Tech team was this:
Yes, I followed this presentation. At the beginning, I thought that there are good concepts but than I was a little bit disappointed about the chosen reference concept, which is near the conventional barriers with small energy absorbing struts. It is a pity that a more effective underride protection system is owed the opinion that it gets too expensive. My suggestion is to start with a realistic energy absorbing underride protection system, and when effective, one can continue with mass and cost saving measures.
I asked Detlef what he thought of crash testing at higher speeds:
Me: I don’t know if you noticed in the webcast, but I raised the question multiple times about why we were not testing at higher speeds and could we please do so.
Detlef: Yes, I noticed that, and I fully agree. I am wondering that the ADAC in Germany is testing also at 56 km/h, corresponding to 35 mph. That is not very realistic, just were in Germany on most highways is no speed limitation, and therefore in most cases the collision velocities are much higher, although if a braking action in the last moment has been taken.
Detlef: Some organisations require higher proof loads, to which bumpers have to withstand. This means that the bumpers of the trucks become stiffer and stiffer. Actual bumpers have to withstand these static dot-like proof loads in longitudinal direction and may break if they are exceeded. This should not be the intention for a crash compatible partnership between the trucks and passenger cars. Decades of discussions in international committees have failed to develop bumper technology beyond what it was in the 1950s. The message should be: Energy absorbing underrun protection structures on commercial vehicles should become standard, as they are on passenger cars for decades.
Detlef watched the Underride Roundtable livestreaming and had submitted a question about oblique impact to the panel discussion:
I hope the sketch will express what I mean. In the case of an oblique impact on the reaqr side of a truck, the lateral test loads/forces are not defined, only the longitudinal loads/forces in P1, P2 and P3. The damage in the case of an oblique impact can be higher than in the case of an impact in the direction of the longitudinal axes.
Oblique Impact Drawing Detlef Alwes
Offset tests show that the passenger car is turning due to the offset of the Center of Gravities of both cars. But also in this case, the lateral loads/forces are not considered in the regulations.
Underride is a decades-old problem. I look forward to a future less plagued by such preventable tragedies.
The Truck Safety Coalition has pointed out a disturbing trend:
We wanted to bring to your attention several disturbing crashes that have occurred recently. There are several contributing factors that caused these crashes, such as double tractor-trailers, fatigue, and failure to stop in time. But all of these crashes share one thing in common – a FedEx truck was involved.
Pennsylvania: FedEx truck hits Wayne Valley H.S. school bus on class trip to Dorney Park. . . http://newjersey.news12.com/news/fedex-truck-hits-wayne-valley-h-s-school-bus-on-class-trip-to-dorney-park-1.11886818
Texas: I-30 Reopens After FedEx Truck Crashes, Spills Fuel. . . http://www.nbcdfw.com/news/local/FedEx-Truck-Crashes-Shuts-Down-I-30-in-Dallas-381080171.html
Mississippi: FedEx [double trailer] truck involved in Highway 78 crash. . . http://www.wdam.com/story/31961768/fedex-truck-involved-in-highway-78-crash
California: CHP Details Deadly Big Rig Crash on I-10 in Cabazon (FedEx double tractor trailer). . . http://patch.com/california/banning-beaumont/least-one-killed-cabazon-big-rig-crash-i-10-chp-0
Tennessee: FedEx [double tractor trailer] driver issued fatigue citation after 8-vehicle crash on I-24. . . http://wkrn.com/2016/05/05/crash-on-i-24-w-near-ohb-causing-significant-delays/
Texas: 18-wheeler crash shuts down I-35 in Salado (FedEx double tractor-trailer). . . http://www.newswest9.com/story/31556016/18-wheeler-crash-shuts-down-i-35-in-salado
Tennessee: Answers sought after FedEx [double trailer] truck captured swerving for 60 miles on I-40 (no crash, but watch video). . . http://wkrn.com/2016/06/08/answers-sought-after-fedex-truck-captured-swerving-for-60-miles-on-i-40/
The recent widespread discussion in social media about the actions of a young man after partying has triggered my distress at the thought of the regrettable actions by drunk, drugged, distracted, and drowsy drivers every day.
Do we really grasp the way that these things impair us and change our ability to act sensibly, responsibly–the way we might if we were “in our right mind”?
What does it lead to (whether intended or not)? Out-of-control. Regrettable actions. Broken lives. Irreversible tragedies.
Surely there are better ways for us to deal with the stress, pain, fear, frustration, and boredom in our lives. I mean, what are we doing to ourselves? Has it become socially acceptable to mess up our own lives as well as those around us?
What can I do about it? What can you do about it? Surely we can work together to find ways to end these senseless, preventable tragedies–on and off the road.