I am glad to see that there is an investigation of the problem of “chameleon carriers.” When a trucking company with a history of safety issues transforms itself into a new company in order to keep doing business, guess what is likely to happen?
You guessed it: their safety problems go with them!
Read about it here: WRAL INVESTIGATES ‘Chameleon carriers’ create danger on roads
No surprise to us! We uncovered so many issues in the aftermath of our crash: Our Crash Was Not An Accident
Jerry, Isaac, and I are taking over 19,000 Vision Zero Petitions to Washington, D.C., next week. This time we are not taking them in individual envelopes. Instead, we have compiled a printed book (designed by Isaac) with the 16,516 signatures which we had on February 12–along with:
We will also be making a pdf of the book available. And Care2 (ThePetitionSite) will be printing off all of the petition signatures, as of next week, and delivering them to us in a binder to take to Secretary Foxx.
On March 3 and 4, we have multiple meetings scheduled in Washington to discuss our requests and petition our country’s leaders to take decisive action.
We have also arranged to have a Petition Book delivered to President Obama. When my granddaughter, Vanessa (6), saw the stack of books in my bedroom, she asked why they were still there. I explained that we were going to Washington next week and about the meetings and all of the people to whom we were going to be giving books.
Vanessa remembered going with us to deliver the first petition in May 2014. At 4, she sat quietly and “took notes.” Yesterday, she decided that she wanted to write a letter to the president to tell him that she missed Aunt Mary and Aunt AnnaLeah. So we will be taking that as well.
With the formal Public Comment period on the rear underride rulemaking for trailers now closed, recently-submitted comments have been posted and can be viewed at these links:
Notifications from Regulations.gov
———————————-
The link to the Proposed Rule is here:
DOCKET: NHTSA-2015-0118 (http://www.regulations.gov/#!docketDetail;dct=FR+PR+N+O+SR;rpp=10;po=0;D=NHTSA-2015-0118)
NOTIFICATION NAME:
FREQUENCY: Daily
EXPIRES: 01/11/2017
NUM DOCUMENTS: 9
The most recently-posted comments are individually listed here:
DOCUMENT ID: NHTSA-2015-0118-0022 (http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0118-0022)
DOCUMENT TYPE: PUBLIC SUBMISSIONS
POSTED DATE: 02/22/2016
DOCUMENT TITLE: Comment from Seven Hills Engineering, LLC.
DOCUMENT ID: NHTSA-2015-0118-0023 (http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0118-0023)
DOCUMENT TYPE: PUBLIC SUBMISSIONS
POSTED DATE: 02/22/2016
DOCUMENT TITLE: Comment from Randy Gates
DOCUMENT ID: NHTSA-2015-0118-0024 (http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0118-0024)
DOCUMENT TYPE: PUBLIC SUBMISSIONS
POSTED DATE: 02/22/2016
DOCUMENT TITLE: Comment from Jerry Karth
DOCUMENT ID: NHTSA-2015-0118-0025 (http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0118-0025)
DOCUMENT TYPE: PUBLIC SUBMISSIONS
POSTED DATE: 02/22/2016
DOCUMENT TITLE: Comment from Courtney Wood
DOCUMENT ID: NHTSA-2015-0118-0026 (http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0118-0026)
DOCUMENT TYPE: PUBLIC SUBMISSIONS
POSTED DATE: 02/22/2016
DOCUMENT TITLE: Comment from Marianne Karth
DOCUMENT ID: NHTSA-2015-0118-0027 (http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0118-0027)
DOCUMENT TYPE: PUBLIC SUBMISSIONS
POSTED DATE: 02/22/2016
DOCUMENT TITLE: Comment from Brian Vires
DOCUMENT ID: NHTSA-2015-0118-0028 (http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0118-0028)
DOCUMENT TYPE: PUBLIC SUBMISSIONS
POSTED DATE: 02/22/2016
DOCUMENT TITLE: Comment from Andy Young
DOCUMENT ID: NHTSA-2015-0118-0029 (http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0118-0029)
DOCUMENT TYPE: PUBLIC SUBMISSIONS
POSTED DATE: 02/22/2016
DOCUMENT TITLE: Comment from Erin Roth
DOCUMENT ID: NHTSA-2015-0118-0030 (http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0118-0030)
DOCUMENT TYPE: PUBLIC SUBMISSIONS
POSTED DATE: 02/22/2016
DOCUMENT TITLE: Comment from Peter Kurdock
We are grateful that Wabash has taken the initiative to improve rear underride protection on the trailers which they manufacture, as seen on their website: RIG-16 REAR UNDERRIDE GUARD SYSTEM
For the past three years, Wabash National has spent considerable time, capital and facility resources in R&D specifically focused on enhancing rear impact guard performance. As part of these efforts, we conducted numerous crash tests, and consulted and worked with some of the premiere testing facilities in the country. The new RIG-16 system is designed to:
Key Design Features
To achieve our performance objectives, our engineering and product development teams incorporated a number of design enhancements that are engineered to work together, as a system, to better absorb energy and deflect impact.
U.S. Patent Application Publication No. 2015/0258951 and other patents pending
See more about this great underride story here: An unexpected phone call from a trailer buyer with good news on underride guards
It is warmer out today and Oscar The Cat was back on the deck. When I stopped to say hello to him, I was reminded of how much Mary & AnnaLeah lavished love on him.
Wishing it had never happened. . .
The following is a post on The Underride Network by Stephen Hadley who lost his wife in a side underride crash twenty years ago. He expressed his concern about side underride protection and about how Bill Clinton’s Executive Order 12866 has made it difficult to pass effective government agency rules.
When I learned about Executive Order 12866 last year, I was motivated to draft a new Executive Order for Obama to sign which would override the negative effects of EO 12866. This is what we are taking to Washington on March 4: Executive Order Draft 2 Application of Vision Zero Principles to Highway Safety Regulatory Review.
Tag Archives: Vision Zero Executive Order
Here is Steve Hadley’s recent post on this topic:
Two life-long best friends each had little sisters that were also life-long friends. I and my best friend were riding in the back seat of a drivers education car when we crashed into someone’s front yard. My best friend’s big brother married the little sister driving that car, a few years later, she died underneath the side of a truck trailer. My wife Tamara Hadley, the other little sister died underneath the rear of an illegally parked truck trailer with a Clinton rear underride guard.
President Bill Clinton updated Ronald Reagan’s Executive orders establishing cost-benefit analysis with Executive Order 12866. These orders limiting corporate costs of safety regulations have made it almost impossible to pass effective government agency rules for over twenty years. . .
. . . NHTSA wants to just legalize the guards already on the road as did the Clinton Administration twenty years ago. Studies could not find statistical improvement in lives saved by these guards. We estimate at least 6,000 extra Americans died because the administration blocked better guards that had been tested at higher speeds. We call these rear guards of the last twenty years the Clinton guillotine guards. If the new regulation by the Obama Administration is approved as presented to just legalize existing guards, they will now be known as Obama guillotine guards. . .
. . . We have fought for Vision Zero regulatory safeguards to replace Clinton cost-benefit rules for twenty years to save thousands of lives. Destroying the meaning of Vision Zero and the meaning of side guards will cripple our efforts for national rules and regulations. Cost-benefit analysis has killed tens of thousands of Americans and given us corporate control of our government and portions of our economy. . .
Total truck related fatalities in 2013 were 3,964, 338 were pedestrians and 78 were bicyclists or about 10.5% were vulnerable road users. 585 or 15% of total fatal crashes were to the side of the truck in cars in 2013. Most fatal victims die in crashes to the front of the truck. If we design side skirts that only save vulnerable road users we will only save a small percentage of victims leaving most victims including many children to die in car crashes. Many of my friends lost their children in these crashes. . .
Vision Zero means stop killing the children! Even those unworthy souls in cars too! Work with us to save lives, not against us. Over a million Americans have been killed and injured in crashes with trucks. A bad law in America can kill tens or hundreds of thousands overseas as our regulations are copied or not exceeded around the globe. Easily, the Clinton guards in the last twenty years killed a hundred thousand extra souls around the world which would have been saved with available stronger rear guards.
Read the full article here: NYC Vision Zero and phony side guards will wreck national safety efforts
http://www.underridenetwork.
http://ntl.bts.gov/lib/54000/
http://www.reginfo.gov/public/
Aaron Kiefer’s prototype of an innovative retrofitting side/rear underride guard
In our efforts to not only improve regulatory federal standards on underride guards but, also, to catalyze voluntary industry improvement, we heard back from several companies to whom we had written, including:
Chad England committed his company to looking into the matter seriously. (CR England) And Dean Engelage (Great Dane) invited Jerry and I to visit their Research & Design Center in Savannah in June 2014:
We’re looking forward to hosting you and your wife next week. I thought we would start the day off with an 8:30 am breakfast at a local favorite, J. Christopher’s which is near the hotel 122 E Liberty Street. Brandie Fuller, our VP of Marketing, will join us. Parking for the restaurant is street-side at a meter.
This is what we learned from the Great Dane visit: Underride Guards: Can we “sit down at the table together” and work this out?
In addition, we received a letter from Brent Hudson at Extra Mile Transportation:
I am in receipt of your letter and packet dated 17 Feb 14.
First, let me offer you my most sincere condolences on the loss of your beautiful daughters. I have a daughter who is two months shy of her 18th birthday, so I do not even want to imagine the heartache associated with this tragedy. I can only offer you my most sincere respect in working to turn such a tragedy into something good.
Extra Mile Transportation is a non-asset based, third party freight broker. That means that we don’t own any equipment, we contract out for everything we move. However, we are in a position to exert some influence on this matter. By copy of this email, I am requesting our Director of Logistical Solutions incorporate this awareness campaign into some of his efforts. I will be meeting with him to go over this issue and we’ll see what impact we may have.
I wish you only the best for the times you share with your other children and hope that your memories of Mary and AnnaLeah continue to have a positive impact on our safety.
My warmest personal regards,
Brent Hudson, Vice President
Extra Mile Transportation
For more details of our efforts in reaching out to the trucking industry and, in particular, the encouraging response from J. B. Hunt, see: An unexpected phone call from a trailer buyer with good news on underride guards
All in all, we are hopeful that the combination of calling for both more appropriate regulations through Vision Zero rulemaking and, at the same time, voluntary action will yield the desired result–SAVED LIVES. Together, we can do this!
Taking the Vision Zero Petition to DC on March 3 & 4! Sign & Share: Save Lives Not Dollars: Urge DOT to Adopt a Vision Zero Policy
Louis Lombardo does important work by watching out for timely news in the realm of traffic safety and sends out regular emails to keep others informed. If you would like to get his regular updates, you can sign up here: “Care for Crash Victims”
Here is information from the Home Page to let you know what it is about:
Introduction
This web site named “Care for Crash Victims” is a project of a small business public benefit enterprise, Louis V. Lombardo, LLC. The mission is to improve care for crash victims before, during, and after a crash. We are all crash victims — past, present, and future — as individuals, families, friends and society. All of us are impacted by crashes as consumers, insurance premium payers, and tax payers.
Vision
The vision is to advance the prevention, treatment, and rehabilitation of serious crash injuries. Currently in the U.S. each day nearly 100 people die of crash injuries — more than half die without transport to a medical treatment facility — and another estimated 400 people suffer serious injuries. U.S. DOT dollar values for preventing such losses currently amount to about $2 Billion each day.
Since 1978 in the U.S., more people have died and suffered serious crash injuries than died or were wounded in all wars since 1776.
This work continues 45 years of research, writing, and public interest advocacy described and documented to some extent on this web site — along with some key historic publications.
And here is a sample of Lou’s informative emails–from this morning . . . it touches, among other things, on the issue of “the nondisclosure of safety defects by a car company,”
– See more at: http://www.atlantamagazine.com/great-reads/no-accident-inside-gms-deadly-ignition-switch-scandal/#sthash.lTahNcLx.dpuf
Dear Care for Crash Victims Community Members:
The shocking history of discovery of countless tragedies – so far – is well described at http://www.atlantamagazine.
The latest legal maneuvers and the wrangling over money are reported by Automotive News. GM quote suggests the fix continues:
“In a statement, GM spokesman Jim Cain said the company believed the current plan “remains the best process to inform settlement value for the remaining cases.””
See http://www.autonews.com/
Imagine an image of a blindfolded Justice holding scales with lives on the lighter side and money on the heavier side with a tear coming out from under the blindfold.
The Public Comment Period closed on February 16, but not all of the submitted comments have been posted yet. The proposed rear underride rule can be seen here along with all of the posted comments: NPRM Upgrade Underide
On the question of whether used trailers should be retrofitted in order to make them safer (better able to protect against deadly underride crashes), here is an opinion from one person who recently submitted a public comment. . .
Decision not to require used trailers to be retrofitted (end of Section 7, page 32):
“You state that your analysis indicates such a retrofitting requirement would be very costly without sufficient safety benefits. If more lives would be saved and more injuries would be prevented by requiring new trailers to meet the new standards, then logic dictates that more lives would be saved and more injuries would be prevented by requiring used trailers to be retrofitted.
“Indeed, the crash tests cited for new trailers of different manufacturers tested on a Chevy Malibu suggest substantial disparities. It can be expected that the disparities would be magnified if tests were conducted on some of the used equipment in the nation’s fleet. If it is not worth the cost to retrofit an old trailer (in which case it should be scrapped), that should be the decision of its owner rather than the decision of NHTSA.” See more of his comments here: Comment from D. J. Young, III
Here is one innovative side/rear guard design which will be tested soon and could be a possibility for retrofit: Innovative combined side & rear guard promises better underride protection.
Jerry was pleasantly surprised tonight by a phone call from Greer Woodruff, Vice President of Safety & Security at J.B. Hunt. J. B. Hunt Transport Services, Inc. is a trucking and transportation company that was founded by Johnnie Bryan Hunt, and based in the Northwest Arkansas city of Lowell.
Greer was calling to let Jerry know that Wabash National, a trailer manufacturer, had redesigned their rear underride guard to provide better protection at the outer edges of the guard. And he also wanted us to know that J.B. Hunt was the first to purchase the new trailers–having ordered 4,000 of them in January.
We had already heard about that yesterday morning. Thank you, Wabash, for creating a safer truck rear underride guard!
But then Greer went on to say that he had wanted to be sure and tell us about it and thank us for the letters, which Jerry wrote to J.B. Hunt–along with the major trailer manufacturers and many other trailer buyers, back in 2014 before we launched our first petition. Those letters, he said, had raised their awareness about the underride problem and spurred them on to talk to the trailer manufacturers about producing safer trailers.
That brought a smile to Jerry’s face.
We look forward to finding out more details about its design features and what level of protection it provides. Also, we hope to see additional attention given to side and front underride protection and retrofitting existing trailers as well.
Meanwhile, we are encouraged to see that progress is being made in moving toward the best possible protection with both voluntary and regulatory action. The Vision Zero Petition Book has arrived!
First set of letters which Jerry sent to trailer buyers in February 2014 (a variation of this went to trailer manufacturers):
One of the letters which went out to trailer manufacturers in February 2014:
A second set of letters went out in March 2014 to clarify our role/position:
Another letter went out asking for support to our petition request for stronger underride guards:
And then Jerry sent a follow-up letter in the fall of 2014, including with it copies of the IIHS Status Reports which had articles on underride guards:
IIHS Status Reports with articles on underride guards, which we included with the letters to the trucking companies:
Finally, after setting up our non-profit, AnnaLeah & Mary for Truck Safety, in the summer of 2015, we wrote to all of the truck companies again–asking for their help to voluntarily find safer underride guard designs:
Also, sometime after our letter writing, we were discussing our efforts with John Lannen at the Truck Safety Coalition. He asked for our list and said, “Thanks – I’ll follow up with Greer since I know him well. What reaction did you get?”
In our efforts to not only improve regulatory federal standards on underride guards but, also, to catalyze voluntary industry improvement, we heard back from several other companies to whom we had written, including:
For more details on the response we got from them, see: Additional response from trucking industry to our request for voluntary action on underride problem.
Photo Album of Jerry and his girls: With Dad. . . Family Man Jerry prays for his children every morning (lifting them before their heavenly Father/Abba). He is proud of them, teases them, enjoys spending time with them, and treasures each of his special children.
Jerry shares our story at the Fall 2015 Sorrow to Strength conference in DC hosted by the Truck Safety Coalition:
