Tag Archives: comprehensive underride protection

Does DOT Want to Reach Toward Zero Deaths? Or not?

In the process of writing a post on Mary’s would-have-been 18th birthday, I discovered a link to a DOT webpage on Toward Zero Deaths.

Here’s that post: Mary would have turned 18 today; but underride protection isn’t “cost-effective.”

And here is the link: Federal Highway Administration: Toward Zero Deaths .

The Department of Transportation is saying that the,

FHWA is committed to the vision of eliminating fatalities and serious injuries on our Nation’s roadways. This approach echoes the Department of Transportation’s Strategic Plan, which articulates the goal of “working toward no fatalities across all modes of travel“; the FHWA’s strategic goal of ensuring the “nation’s highway system provides safe, reliable, effective, and sustainable mobility for all users”; and the emphasis on safety that FHWA renews every year in our strategic implementation efforts.

The zero deaths vision is a way of clearly and succinctly describing how an organization, or an individual, is going to approach safety – even one death on our transportation system is unacceptable. This idea was first adopted in Sweden in 1997 as “Vision Zero” and since then has evolved across the country and across the world. A growing number of states and cities have adopted zero deaths visions under different brandings.

The zero deaths approach uses a data-driven, interdisciplinary approach that FHWA has been promoting for many years. The approach targets areas for improvement and employs proven countermeasures, integrating application of education, enforcement, engineering, and emergency medical and trauma services (the “4Es”). A combination of strategies from different focus areas will be necessary to achieve the zero deaths vision.

If that is truly the Department’s vision, then their lack of appropriate action to issue underride rulemaking falls far short of that mission. And why is that? Could it be that safety is no longer truly their priority? Are they unable to be an uncompromised voice for the victims of vehicle violence — whether there be 400 or 4,000 underride deaths/year?

Who then will advocate for safer roads?

Congress should act responsibly and pass the Roya, AnnaLeah & Mary Comprehensive Underride Protection Act. President Trump should sign an Executive Order to authorize Vision Zero Rulemaking and the Office of Management & Budget should revise their guidelines to allow agencies to conduct regulatory analysis which properly values the preservation of human health & life.

Otherwise, the Department of Transportation’s public commitment to a vision of Toward Zero Deaths is a farce. May it not be so.

 

Remembering Mary when she would have been 18.

Mary Lydia Karth, August 6, 1999 – May 8, 2013

Oh, and before you go, read this previous post: If Sec. Foxx & DOT are embracing Vision Zero, why do we have to fight to get a strong Underride Rule?

What If the Insurance Industry Gave Trucking Companies a Discount for Safety Equipment?

I have asked the question before: Who should pay for truck safety? This question is burning within me because I know all too well the answer to another question: Who pays for the lack of truck safety?

When I checked to see what posts I have written on the topic, I discovered that I have written quite a few. Is that so surprising when I observe that, year after year, not too much changes along that line?

Like I said, I have already written volumes on this topic. What more is there to say? Well, plenty. . . and specifically I have written about this question related to the deadly problem of preventable truck underride. In fact, I made a laundry list of ways that installing comprehensive underride protection could actually be considered a Win/Win situation — if we make an effort to creatively address it to the benefit of all:

Should the trucking industry be concerned about underride legislation?

One thing I didn’t include on that list, however, is the idea of the insurance industry providing a discount to trucking companies on their liability insurance for the installation of safety equipment — like side guards, front underride/override protection, and improved rear underride guards.

Well, why not? I’m serious; I don’t really think that’s just an absurd hypothetical question. And I think it deserves a serious answer.

 

Thanks @SenMarkey for pausing on the sidewalk to hear our stories.

On the way from a meeting in the House to a meeting in the Senate, we had a chance encounter with Senator Edward Markey (D-MA). Lois Durso shared how she had lost her daughter Roya (26) twelve years ago in a truck side underride crash. I shared how I had lost my youngest two daughters, AnnaLeah (17) and Mary (13), in a rear underride crash four years ago. And Senator Markey shared how he was in a car crash when he was 5.

That crash from his childhood clearly made an impression on him. So when we told him that we were looking for support for an underride bill which we had drafted, he told us that he has worked to bring about safety and that we should contact his legislative staff.

We walked away laughing and smiling at yet one more chance encounter orchestrated by the hand of God in this exhausting but exciting quest to pass the Roya, AnnaLeah & Mary Comprehensive Underride Protection Act of 2017 (RAMCUP).

“Powerful Senator joins calls for stronger semi-trailer underride guard laws”

WUSA9 reports that Senator Schumer has joined our call for stronger underride laws.

WASHINGTON, DC (WUSA9) – Senate Minority Leader Charles Schumer, (D-N.Y.) is launching a major effort to improve critical safety features on semi-trailers that could save hundreds of lives on U.S. highways.

The WUSA9 Special Assignment Unit has reported on the issue for weeks.

On Friday, Sen. Schumer called on the federal government to update and upgrade safety standards by requiring trucks be equipped with energy-absorbing rear underride guards.

Schumer is also calling on the National Highway Traffic Safety Administration (NHTSA) to require trucks be equipped with side underride guards. He also asks for new research into front underride guard standards. . . 

Watch their news report here: Powerful Senator joins calls for stronger semi-trailer underride guard laws

After learning of yet another terrible side underride tragedy earlier this month in New York, we reached out to NY legislators asking them to support this cause.

How sad it is that it takes tragedies like these to bring about change. How hopeful I am that we are moving quickly to seeing comprehensive underride protection become a reality. Let’s do this!

Underride crash in NY this week kills 4; Ball’s in your court, Congress, to end these preventable tragedies.

Yet another tragic side underride crash occurred in New York this week. Could crash avoidance technology have prevented the collisions of two cars into the side of a jack-knifed milk tanker? Perhaps.

Could comprehensive underride protection — including side guards — have prevented the tragic outcome of 4 lives abruptly ended? Probably.

When will we take action to mandate and install effective underride protection around every part of large trucks to end these preventable tragedies? The ball’s in your court, Congress.

Let’s get The Roya, AnnaLeah and Mary Comprehensive Underride Protection Act of 2017 introduced and passed. Post haste. No more of this senseless highway carnage.

Ready-to-introduce bill:  RAMCUP Draft 15 with Cover

 

 

Just How Far Have We Come In The 50 Years Since Jayne Mansfield’s Death By Truck Underride?

June 29 marked the 50th anniversary of Jayne Mansfield’s death by underride. The world knew in 1967 — if it didn’t know it before — about the terrible geometric mismatch between a car and a truck which allowed a car to ride under a truck upon collision.

In those 50 years, how many technological problems have we solved? And yet why have we been unable to solve the problem of truck underride and stem the tide of preventable, horrific, and senseless underride tragedies?

Sure we have made some headway — six trailer manufacturers have upgraded their rear underride guards and there are promising side guard solutions with one of them recently tested by the IIHS. Some manufacturers even have retrofit kits available to replace weak rear guards on existing trailers.

Yet it is well known that more could be done, but hasn’t. And why is that? Why have we been so slow to solve this problem? There are many reasons which could be cited. But the facts are the facts. People are still dying (or suffering catastrophic injuries) at an alarming rate from underride and we are seemingly content to let it continue or address it at a snail’s pace.

Not me. I am not content to take it slow and easy — not when the result is that more people will die because we didn’t act sooner. When we could have.

Take front underride or override for example. Front underride protection is one of the components we are asking for in the Roya, AnnaLeah & Mary Comprehensive Underride Protection Act of 2017 (RAMCUP). People are dying due to lack of adequate front underride protection — just like they are on the sides and rear of trucks.

In Europe, they have requirements to protect against this. Not in the U.S. So what are we waiting for? Well, that’s a good question.

Do we wait until we can reinvent the wheel here and figure it out for ourselves with years of research? Or do we speed up the process by learning from others and encouraging collaboration among relevant stakeholders?

Do we include it in the congressional mandate to the Department of Transportation and ask them to figure it out sooner rather than later? Or do we ask them to solve the side guard problem now and then later on, down the road at some unspecified time in the future, we’ll address the need for front protection?

Well, Lois Durso and I took the bull by the horn and said: We’re sick & tired of waiting. People are dying from underride no matter what part of the truck they are unfortunate enough to collide with. We need to solve every kind of underride problem and we are going to include it all in one big comprehensive piece of legislation. Because it is needed. Because it is long-overdue.

Previous posts on Front Underride Protection:

Don’t re-invent the wheel; establish a formal Committee On Underride Protection (COUP) to oversee the development of recommendations for NHTSA underride regulations.

See the history of underride rulemaking as compiled by IIHS and displayed at the first Underride Roundtable on May 5, 2016, held at the IIHS Vehicle Research Center:

From the RAMCUP bill: 

(d) UNDERRIDE PROTECTION ON THE FRONT OF LARGE TRUCKS
Include front override protection in conformance with the following
specifications:
(1) An EU requirement was introduced in 2000 based on ECE Regulation
93 requiring mandatory rigid front underrun protection defining a rigid
front underrun protection system for trucks with a gross weight over 3.5
tonnes Directive 2000/40/EEC. Studies performed by EEVC WG 14 have
shown that passenger cars can ‘survive’ a frontal truck collision with a
relative speed of 75 km/h if the truck is equipped with an energy absorbing               underrun protection system. Furthermore, these systems could reduce
about 1,176 deaths and 23,660 seriously injured car occupants in Europe
per year. Research shows that the benefits of a mandatory specification for
energy absorbing front underrun protection would exceed the costs, even if
the safety effect of these measures was as low as 5%. European
Commission; Front Underrun Protection Systems [Note: 75 kmh = 46.6028
mph]
(2) Front guards must have 3 levels of resistance; soft front for pedestrians
and cyclists, middle area must be softer than the partner vehicle in crashes
and able to absorb energy such as through crush, and rear area must be
strong and stiff enough to resist underride and rotate high-speed vehicles
away from the truck. Extend the front guard from the truck 600 mm (2 feet) to
give room for a 500 mm (1.6 feet) radius curve to deflect crash partners
including VRU and cars. The extra 600 mm should give 102 km/h or (63 mph)
of protection which would exceed a general goal of 60 mph (100 km/h) — an
average speed for highway crashes in the real world.
(3) NHTSA shall immediately issue an RFP to identify the appropriate
requirements for a front underrun protection standard.

ECE No. 93 FRONT UNDERRUN PROTECTION

Design and Optimization of Front Underrun Protection Device

https://ec.europa.eu/transport/road_safety/specialist/knowledge/vehicle/safety_design_needs/heavy_goods_vehicles_en

Don’t you think that enough is enough?! Let’s make it a priority to tackle the whole underride problem post haste! If we don’t (knowing what we now know), then who should we hold responsible for the thousands of people who will most surely die from preventable underride?

No compromise. Too many have already paid the price for 50 years of compromise.

How Far Have We Come In The 50 Years Since Jayne Mansfield’s Death By Truck Underride?

June 29 marked the 50th anniversary of Jayne Mansfield’s death by underride. The world knew in 1967 — if it didn’t know it before — about the terrible geometric mismatch between a car and a truck which allowed a car to ride under a truck upon collision.

In those 50 years, how many technological problems have we solved? And yet why have we been unable to solve the problem of truck underride and stem the tide of preventable, horrific, and senseless underride tragedies?

Sure we have made some headway — six trailer manufacturers have upgraded their rear underride guards and there are promising side guard solutions with one of them recently tested by the IIHS. Some manufacturers even have retrofit kits available to replace weak rear guards on existing trailers.

Yet it is well known that more could be done, but hasn’t. And why is that? Why have we been so slow to solve this problem? There are many reasons which could be cited. But the facts are the facts. People are still dying (or suffering catastrophic injuries) at an alarming rate from underride and we are seemingly content to let it continue or address it at a snail’s pace.

Not me. I am not content to take it slow and easy — not when the result is that more people will die because we didn’t act sooner. When we could have.

Take front underride or override for example. Front underride protection is one of the components we are asking for in the Roya, AnnaLeah & Mary Comprehensive Underride Protection Act of 2017 (RAMCUP). People are dying due to lack of adequate front underride protection — just like they are on the sides and rear of trucks.

In Europe, they have requirements to protect against this. Not in the U.S. So what are we waiting for? Well, that’s a good question.

Do we wait until we can reinvent the wheel here and figure it out for ourselves with years of research? Or do we speed up the process by learning from others and encouraging collaboration among relevant stakeholders?

Do we include it in the congressional mandate to the Department of Transportation and ask them to figure it out sooner rather than later? Or do we ask them to solve the side guard problem now and then later on, down the road at some unspecified time in the future, we’ll address the need for front protection?

Well, Lois Durso and I took the bull by the horn and said: We’re sick & tired of waiting. People are dying from underride no matter what part of the truck they are unfortunate enough to collide with. We need to solve every kind of underride problem and we are going to include it all in one big comprehensive piece of legislation. Because it is needed. Because it is long-overdue.

Previous posts on Front Underride Protection:

Don’t re-invent the wheel; establish a formal Committee On Underride Protection (COUP) to oversee the development of recommendations for NHTSA underride regulations.

See the history of underride rulemaking as compiled by IIHS:

From the RAMCUP bill: 

(d) UNDERRIDE PROTECTION ON THE FRONT OF LARGE TRUCKS
Include front override protection in conformance with the following
specifications:
(1) An EU requirement was introduced in 2000 based on ECE Regulation
93 requiring mandatory rigid front underrun protection defining a rigid
front underrun protection system for trucks with a gross weight over 3.5
tonnes Directive 2000/40/EEC. Studies performed by EEVC WG 14 have
shown that passenger cars can ‘survive’ a frontal truck collision with a
relative speed of 75 km/h if the truck is equipped with an energy absorbing               underrun protection system. Furthermore, these systems could reduce
about 1,176 deaths and 23,660 seriously injured car occupants in Europe
per year. Research shows that the benefits of a mandatory specification for
energy absorbing front underrun protection would exceed the costs, even if
the safety effect of these measures was as low as 5%. European
Commission; Front Underrun Protection Systems [Note: 75 kmh = 46.6028
mph]
(2) Front guards must have 3 levels of resistance; soft front for pedestrians
and cyclists, middle area must be softer than the partner vehicle in crashes
and able to absorb energy such as through crush, and rear area must be
strong and stiff enough to resist underride and rotate high-speed vehicles
away from the truck. Extend the front guard from the truck 600 mm (2 feet) to
give room for a 500 mm (1.6 feet) radius curve to deflect crash partners
including VRU and cars. The extra 600 mm should give 102 km/h or (63 mph)
of protection which would exceed a general goal of 60 mph (100 km/h) — an
average speed for highway crashes in the real world.
(3) NHTSA shall immediately issue an RFP to identify the appropriate
requirements for a front underrun protection standard.

ECE No. 93 FRONT UNDERRUN PROTECTION

Design and Optimization of Front Underrun Protection Device

https://ec.europa.eu/transport/road_safety/specialist/knowledge/vehicle/safety_design_needs/heavy_goods_vehicles_en

Don’t you think that enough is enough?! Let’s make it a priority to tackle the whole underride problem post haste! If we don’t (knowing what we now know), then who should we hold responsible for the thousands of people who will most surely die from preventable underride?

No compromise. Too many have already paid the price for 50 years of compromise.

Would this truck tax savings cover cost of comprehensive underride protection for a Win/Win solution?

Congressman LaMalfa, a member of the House Transportation & Infrastructure Committee, “. . . introduced a bill Tuesday to repeal a 12 percent federal excise tax on heavy trucks originally designed to help pay the cost of fighting World War I a century ago.”

Would this tax savings cover all of the costs of comprehensive underride protection? Just sayin’. . . a Win/Win solution.

A Republican congressman from California introduced a bill Tuesday to repeal a 12 percent federal excise tax on heavy trucks originally designed to help pay the cost of fighting World War I a century ago.

The bill by Rep. Doug LaMalfa, H.R. 2946, called the Heavy Truck, Tractor and Trailer Retail Federal Excise Tax Repeal Act of 2017, now heads to the House Ways and Means Committee for review.

The tax “adds tens of thousands of dollars to truck purchases and directly impacts the cost of food, consumer goods and other products Americans need,” LaMalfa said. “Even worse, truck owners large and small pay this tax whether a truck is driven 100,000 miles or never driven at all, forcing them to pay taxes on an investment that may not be generating any revenue.”  Bill Seeks to Repeal Federal Excise Tax on Heavy-Duty Trucks

Truck Underride 101: Part V. Bipartisan Discussion of Legislative Strategy

Truck Underride 101: Part III. Cost Benefit Analysis, Underride Rulemaking, and Vision Zero

Becoming educated about underride was not a direction I had planned on going with my life and time. But I have gained a great deal of knowledge related to the fact that AnnaLeah’s and Mary’s deaths (and Roya’s, too, along with countless other individual loved ones) might have been prevented had adequate underride protection been on the truck, into which our sturdy Crown Vic crashed — along with the fact that many more countless, unknown individuals will die unless this country takes decisive action.

This information, along with my unresolved grief due to the frustration of knowing that years have gone by without effective protection, fuels my efforts to work collaboratively to bring about widespread and significant change. It is now my aim to equip everyone with the same information — without the accompanying unwanted grief.

The reason we are devoting our lives to pounding on this door and asking for change is that our daughters may have lost their lives due to the lack of a Vision Zero policy. A decision which concluded that recommended changes would not be cost effective—in other words, that it would supposedly cost more to implement safety measures than the lives saved would be worth—may have led to lax underride guard standards.

If the best possible protection had been pursued when the regulations were last updated (1996), the trucks on the road today (including the one on the road May 4, 2013) might be much safer to be driving around. Mary and AnnaLeah might even still be around.

So, here is Part III of Truck Underride 101.

III. Cost Benefit Analysis, Underride Rulemaking, and Vision Zero

  1. Public Comments on Underrride Rulemaking & Cost/Benefit Analysis: Public Comments Re: Cost/Benefit Analysis in NHTSA Proposed Underride Rulemaking on Rear Guards for Tractor-Trailers & for Single Unit Trucks and       Current NHTSA #Underride Rulemaking (Cost/Benefit Analysis): Summary of Public Comments and https://annaleahmary.com/2016/10/dot-omb-are-you-using-cea-or-cba-rulemaking-road-to-zero-requires-vision-zero-rulemaking/

  2. Jerry Karth’s Public Comments on Underride Rulemaking: Comments on the NPRM for Rear Underride Guards on Trailers and Reflections from a bereaved dad on the Underride Roundtable & what that means for rulemaking

  3. Underride Statistics 

  4. The Future of Trucking: Who pays for the costs of safer roads?

    I thought about all of this, on a recent trip “back home”, as I reflected on the plight of small trucking companies and independent owner-operator truck drivers. Are the costs of owning a company and the pressure to drive many miles creating a situation where they won’t be able to stay in business?

    Frequently, I hear that changes of one kind or another in the trucking industry–in order to improve safety (i.e., reduce crashes, injuries and deaths)–will result in increased costs for the trucking companies. I hear that it will put them out of business.

    Is this true? According to whom and based on what information? If it is true, then does something need to change in the trucking industry itself in order to allow for the beneficial work, which trucking provides, to continue but to also allow for truckers to make a decent living wage–without jeopardizing their health and the safety of travelers on the roads? . . .  Read more here: The Future of Trucking; Who pays for the costs of safer roads?

  5. Whose lives are you going to sacrifice? If decisive action is not taken to end these preventable deaths, then who should we hold responsible? Whose lives are we thereby choosing to sacrifice?

  6. TTMA: Truck Trailer Manufacturers Association Reminds NHTSA Why Side Guards Are Not Cost Effective, May 18, 2016 post:

    Yesterday morning, I checked my email and saw that there was a new Public Comment posted on the Federal Register regarding the Notice of Proposed Rulemaking on Underride Guards.

    I quickly went to the site and saw that the Truck Trailer Manufacturers Association had posted a comment (see their comments in the PDFs below). Apparently our Underride Roundtable two weeks ago at IIHS has spurred them to spell out the steps which have been taken over the years to squash side guards from being mandated and manufactured to prevent smaller passenger vehicles from riding under trucks upon collision with the side of the larger vehicle.

    TTMA_Side_Impact_Main_Comment_2016-05-13

    TTMA_Side_impact_Exhibits_A-D_2016-05-13

    Their rationale: Cost/Benefit Analysis shows that adding side guard to trucks is “not cost-effective”. From this post: Truck Trailer Manufacturers Ass’n “Reminds” NHTSA: Side Guards Are “Not Cost-Effective” Says Who? 

    I am encouraged by the closing paragraph of the TTMA letter to NHTSA:

    TTMA would support the implementation of side guards if they ever become justified and technologically feasible. We continue to support the NHTSA review of Petitioners’ requests and stand ready to partner in the development of justified and feasible designs if they possibly emerge. Jeff Sims, President

Truck Underride 101: Discussion Topics

I. When Will We Tackle Truck Underride? Truck Underride 101: I. When Will We Tackle Truck Underride?

II. Why Comprehensive Underride Protection? Truck Underride 101: II. Why Comprehensive Underride Protection?

III. Cost Benefit Analysis, Underride Rulemaking, and Vision Zero

IV. Win/Win

V. Bipartisan Discussion of Legislative Strategy

Truck Underride 101: II. Why Comprehensive Underride Protection?

Becoming educated about underride was not a direction I had planned on going with my life and time. But I have gained a great deal of knowledge related to the fact that AnnaLeah’s and Mary’s deaths (and Roya’s, too, along with countless other individual loved ones) might have been prevented had adequate underride protection been on the truck, into which our sturdy Crown Vic crashed — along with the fact that many more countless, unknown individuals will die unless this country takes decisive action.

This information, along with my unresolved grief due to the frustration of knowing that years have gone by without effective protection, fuels my efforts to work collaboratively to bring about widespread and significant change. It is now my aim to equip everyone with the same information — without the accompanying unwanted grief.

So, here is Part II of Truck Underride 101.

II. Why Comprehensive Underride Protection?

Why, you might ask, would we write a piece of legislation calling for a comprehensive underride protection rule? Why not have separate bills for side underride and rear underride and front underride and Single Unit Trucks (SUTs), et cetera?

I am convinced of the importance of this strategy and want to share some of my thoughts here.

RAM CUP: A DIFFERENT STRATEGY
TO ACHIEVE UNDERRIDE PROTECTION
For Such A Time As This

What can we discover from past attitudes or strategies to address underride deaths? Read more hereWhy COMPREHENSIVE Underride Protection Legislation?

  1. International Research and the Underride Roundtable: On May 5, 2016, over 65 representatives from the trucking industry, government, safety advocates, engineers, crash reconstructionists, attorneys, and media will be on hand at the Insurance Institute for Highway Safety’s Vehicle Research Center to discuss and demonstrate truck underride crashes.

    In order to prepare for that, I am going to highlight some past and current underride research papers and efforts here. It will, of course, not cover everything and others are welcome to send additional information my way, which I would be more than happy to add to the list.

    Although most of the research below will not appear as a presentation on the agenda, I am hopeful that the information will be considered by all as recommendations for underride protection are discussed and proposed.

    I had actually wanted to put together a packet of this kind of information to hand out to participants. Then I thought that it might be more useful to provide it to a wider audience by posting it on our website. So here it is. . .  Underride Roundtable To Consider Underride Research From Around the Globe

  2. Media Coverage of the first Truck Underride Roundtable held at IIHS on May 5, 2016You will find multiple links below reporting on the Underride Roundtable, which took place on May 5, 2016 at the Insurance Institute for Highway Safety’s Vehicle Research Center in Ruckersville Center, co-hosted by them with the Truck Safety Coalition, and our family (AnnaLeah & Mary for Truck Safety).Please note: If you are visiting this site for the first time, please be aware that the reason this Underride Roundtable was organized was because the CURRENT DOT/NHTSA underride standards are TOO WEAK. In way too many cases, even new trucks with underride guards meeting current rules (not just corroded ones) fail and allow underride by a passenger vehicle colliding with them. People die from these kinds of crashes and it has been proven that stronger guards (if required and manufactured) could stop this deadly underride!I know about this because my two youngest daughters, AnnaLeah (17) and Mary (13), died because of this kind of crash on May 4, 2013. I was driving. A truck hit us–spinning us around so that we went backwards into the tractor-trailer ahead of us. AnnaLeah and Mary were in the back seat which went under the truck. They died. I did not. . .

    Knights of the Roundtable: 

  3. Rear Guard Consensus Specifications submitted to NHTSA: Underride Roundtable Led to Recommendations Submitted as a Consensus Public Comment to NHTSA, August 9, 2016

  4. Comprehensive Underride Consensus Petition Letter to Secretary Foxx: 

    In fact, the development of a COMPREHENSIVE approach to taking care of the truck underride problem was probably first planted in my mind at the Underride Roundtable on May 5, 2016, with the suggestion of a member of the trucking industry.

    Read about that here, including the subsequent actions that resulted in a Comprehensive Underride Consensus Petition which a group of us submitted to Secretary Foxx at DOT on September 23, 2016, and upon which the Roya, AnnaLeah & Mary Comprehensive Underride Protection Act of 2017 is based.

  5. The RAMCUP/Roya, AnnaLeah & Mary Comprehensive Underride Protection Act of 2017 was based upon the months and years of research and collaboration preceding its development: