Appendix G | AnnaLeah & Mary

FMCSA has issued a Final Rule, effective December 9, 2021, requiring Rear Impact Guards to be inspected as part of commercial motor vehicle inspections on those trucks which must have them installed. This is good because a guard weakened by cuts, tears, rust, bends, or loose connections is going to be less likely to prevent a car from going under a truck.

If a truck fails the inspection, the violation could cost a motor carrier a maximum of $15,876 and a truck driver $3,969. This could lead to the replacement of many rear underride guards — hopefully, with guards that meet the TOUGHGuard level of strength proven possible by the Insurance Institute for Highway Safety and now on many new trailers.

This is what I know about the availability of replacement equipment:

Great Dane Trailers has a retrofit solution.
Stoughton Trailers has a retrofit kit.
Utility Trailers aftermarket sells only the current production horizontal bumper as a replacement for any damaged Utility bumper.
Vanguard Trailers and Manac Trailers have the improved guard available for sale.
I don’t have information about retrofit options for the other trailer manufacturers.
TrailerGuards offers a generic Rear Impact Guard (RIG) Retrofit out of aluminum which can be installed on most any model of trailer. See it crash tested here at 38 mph:

Retrofit Solutions for Rear Impact Guards to Prevent Deadly Underride

Examples of poorly-maintained guards:

Proper Maintenance of Underride Guards Can Spell the Difference Between L-i-f-e & D-e-a-t-h

A red letter day: The Federal Motor Carrier Safety Administration (FMCSA) at long last has proposed a rule to add rear underride guards to Appendix G. What does that mean? It means that rear underride guards will be required to be in good condition in order to pass an annual vehicle inspection. Once the rule is actually issued.

The Public can comment on this proposed rule through March 1, 2021, by going here.

This describes the current status of rear guard inspection requirements, according to FMCSA:

While the FMCSRs have required rear impact guards for more than 65 years, they are not included on the list of components in Appendix G that must be inspected during the annual CMV inspection. This means that a vehicle can pass an annual inspection with a missing or damaged rear impact guard. https://public-inspection.federalregister.gov/2020-27502.pdf

Imagine!

In response to petitions from the CVSA and Jerry and Marianne Karth (“the Karths”1 ); a recommendation included in GAO Report GAO-19-264, “Truck Underride Guards: Improved Data Collection, Inspections, and Research Needed;”2 and Congressional correspondence,3 this rulemaking proposes to amend the FMCSRs to include rear impact guards on the list of items that must be examined as part of the required annual inspection for each CMV.

I have not yet read the whole document, but I am getting ready to do so now in order to make an informed and practical comment. I will definitely recommend that damaged guards be replaced with ones which meet the Insurance Institute for Highway Safety (IIHS) TOUGHGuard level of strength to STOP deadly underride — not merely with an older model which has been proven to be too weak.

Over one hurdle. On to the next.