Tag Archives: conspicuity

Save Lives by Lighting up Tractor-Trailers & Tanker Trucks

Truck drivers can play an important role in making sure that the trailers which they haul are as visible as possible to other drivers on the road — especially at nighttime. On October 15, 2018, Leslie and Sophie Rosenberg lost their lives when they collided with the side of a tanker late at night.

Family members are appealing to the trucking industry — including truck owners and drivers — to install additional lights for improved visibility and to make sure that the required lighting and retroreflective tape are kept clean and properly maintained. It could mean the difference between life and death.

“A tanker truck pulled onto the unlit highway from a side road, crossing three lanes of traffic.  My sister – driving in the rightmost lane – in a mini van plowed into the underside of the tanker … There were no skid marks.  The reason for there being no skid marks is simple:  my sister never saw the tanker. She never saw the tanker because it was painted dark blue and had no lights on the sides that were clean and clearly visible. . .” Forman writes.

Forman goes on to argue that if the tanker had been painted silver and had “lights illuminating the entire outline of the tanker” the crash could have been avoided. Family petitions for more lights, no ‘dark colors’ on big rigs following fatal crash

Read more about their story and petition here:

The family’s petition goes into detail about why it is so important to make large trucks as visible as possible especially at nighttime:

In 2018, 96% of vehicle occupants killed in two-vehicle crashes involving a passenger vehicle and a large truck were occupants of the passenger vehicles. (IIHS, 2019) (Source: https://driving-tests.org/driving-statistics/

In 2018, 37% of all fatal crashes, involving large trucks occurred at night (6:00 pm to 6:00 am). (FMCSA, 2016) (Source: https://driving-tests.org/driving-statistics/

“The main factor related to the driver’s ability to see a crossing truck is target conspicuity, or how well an object stands out from its background. Target conspicuity relies largely on contrast characteristics such as color, movement, brightness, shape and size.

Most commonly with trucks, the misconception is that their large size by itself makes them conspicuous. At night the size of the trailer by itself will not make it conspicuous since other contrast problems will make the trailer virtually invisible. Without any close-in lighting reflecting off the painted surface of the trailer, it will appear black against the black background. Then an approaching driver will have to rely on the side marker lights for his only cue to the presence of the trailer. However, even with the legal placement of marker lights on the sides of the trailer, approaching drivers will still often not perceive the trailer as an obstruction blocking their path.

“Marker lights are small and can be spaced as far as 26 feet apart on the side of a trailer, not providing on-coming drivers with enough information to determine that what they are looking at is a trailer. Marker lights can be misleading, and without an external light source, trailers are often not identified until the headlights of oncoming vehicles directly illuminate themWhen their headlights illuminate the trailer, on-coming drivers will only be 100 to 200 feet away, and unable to stop at higher speeds.”

“Retroreflective tape is very effective in making trailers visually –stand out. However, a truck driver should never assume that the presence of this tape on a trailer will automatically guarantee that the trailer will be seen. If the tape is dirty, badly worn, or if the truck is at a steep angle to traffic, oncoming drivers may not be alerted to the presence of the trailer. The underride hazard is still present. Therefore Lights all around the sides are a much better alternative.”

An in-depth discussion of causes of underride collisions can be found at: crashforensics.com: Truck Underride Collision Analysis

NOTE: This is a very important issue. Having more warning that a collision is imminent will mean that the driver of the passenger vehicle will be more likely to brake and reduce the vehicle speed upon collision. However, this is not an either/or situation. Without adequate underride protection, even at speeds as low as 15 mph, a passenger vehicle can go under the truck — causing catastrophic underride and Passenger Compartment Intrusion injuries.

With both adequate truck conspicuity and underride protection, many lives will be saved.

Why rely on driver reaction to avoid truck side underride when a side guard could prevent tragedy?

I just read a very detailed explanation for why a driver might not react in time to avoid riding under the side of a semi-trailer — one without a side guard I might add. Well, that is all very interesting and we might learn something useful from it.

But, why on earth would we rely on driver behavior (especially in such an unexpected scenario) when the installation of a side guard could so easily save the driver’s life?!

Save Lives

Of course, taking a comprehensive approach to safety makes the most sense –one which makes other factors important as well, including:

  • Visibility and conspicuity.
  • Adequate parking for trucks.
  • Making it illegal for trucks to make U-turns.

Either or

Celebrating Progress in Underride Guard Rulemaking: Advance Notice of Proposed Rulemaking on Single Unit Trucks (SUTs)

The current federal standards for truck and trailer crash protection do NOT currently include Single Unit Trucks (SUTs). These types of trucks are not required to have any rear underride guards. Yet, research has shown that there are many deaths due to smaller vehicles colliding with the rear end of SUTs.

Examples of SUTs are dump trucks, garbage haulers, concrete mixers, tank trucks, trash trucks, and local delivery trucks.

Today, NHTSA issued an advance notice of proposed rulemaking (ANPRM) for SUTs–the first step of a larger agency initiative to upgrade the standards for truck and trailer underride crash protection. This is very good news!

As soon as it gets published in the Federal Register, we will be asking people to put in their two cents worth online through a 60-day Public Comment Period.

http://www.nhtsa.gov/About+NHTSA/Press+Releases/2015/nhtsa-truck-underride-anprm-july2015

Straight Truck Advance Notice of Proposed Rulemaking nhtsa 3715[1]:

This announcement is about protecting more drivers and passengers,” said U.S. Transportation Secretary Anthony Foxx. “These vehicles are essential to transportation system, and we have a duty to the traveling public to take every opportunity to strengthen truck safety.”

 

This 79 page document spells out the details , ANPRM-underride-SUT-July2015 :

SUMMARY:

NHTSA is issuing this ANPRM following a July 10, 2014 grant of a petition for rulemaking from Ms. Marianne Karth and the Truck Safety Coalition (petitioners) regarding possible amendments to the Federal motor vehicle safety standards (FMVSSs) relating to rear impact (underride) guards. The petitioners request that NHTSA require underride guards on vehicles not currently required by the FMVSSs to have guards, notably, single unit trucks, and improve the standards’ requirements for all guards, including guards now required for heavy trailers and semitrailers.

Today’s ANPRM requests comment on NHTSA’s estimated cost and benefits of requirements for underride guards on single unit trucks, and for retroreflective material on the rear and sides of the vehicles to improve the conspicuity of the vehicles to other motorists. Separately, NHTSA plans to issue a notice of proposed rulemaking proposing to upgrade the requirements for all guards.

DATES: You should submit your comments early enough to ensure that the docket receives them not later than [INSERT DATE 60 DAYS AFTER DATE OF PUBLICATION IN THE FEDERAL REGISTER].

I have been told that it could take a few days, a week, or even longer to get published in the Federal Register. But when it does, we will most certainly inform you and ask you to make a public comment. Instructions will be provided.

Here is a photo of a Single Unit (or Straight) Truck which we saw on the road during one of our road trips recently. Note the rather wimpy (voluntary) underride guard.

Trip North May 2015 035Right now (without a requirement for SUT underride guards), whether they realize it or not, these trucks are “getting away with murder.”* We hope that this is the first step toward bringing that tragic and preventable situation to an end.

*”The killing of another person without justification or excuse, especially the crime of killing a person with malice aforethought or with recklessness manifesting extreme indifference to the value of human life.”(Is it “manifesting extreme indifference to the value of human life” to not do something which in fact could be done to prevent horrific injury or death?)

 http://www.thefreedictionary.com/Getting+Away+with+Murder

“To escape punishment for or detection of an egregiously blameworthy act. http://idioms.thefreedictionary.com/get+away+with+murder

We know all too well what an underride crash can result in:

IMG_4465

June 2013 article on straight trucks: http://www.truckinginfo.com/channel/safety-compliance/news/story/2013/06/ntsb-says-straight-truck-safety-not-receiving-enough-attention.aspx

 

Please note that this is only the beginning of a lengthy rule making process. But we are in this for the LONG HAUL and hope to see this advance in a timely manner to the end goal of safer trucks on the road. Here is a description of the regulatory process:

Regulatory Dashboard  http://www.reginfo.gov/public/jsp/Utilities/faq.jsp#dashboard

Q.    What is Reginfo.gov and the Regulatory dashboard and what information does it display?

A.     Reginfo.gov displays regulatory actions and information collections currently at OIRA for review. The Regulatory dashboard is a component of that site that provides an up-to-date and easy-to-read graphical representation of regulatory actions currently under review. The dashboard displays these regulatory actions by agency, length of review, economic significance, and stage of rulemaking.

Q.    What are the different types of significant regulatory actions currently displayed on the dashboard that undergo OIRA review?

A.    They are:

  • Notice  –  These are documents that announce new programs (such as grant programs) or agency policies.
  • Pre-rule (or advance notice of proposed rulemaking)  –  Agencies undertake this type of action to solicit public comment on whether or not, or how best, to initiate a rulemaking. Such actions occur prior to the proposed rule stage.
  • Proposed rule  –  This is the rulemaking stage in which an agency proposes to add to or change its existing regulations and solicits public comment on this proposal.
  • Final rule  –  This is the last step of the rulemaking process in which the agency responds to public comment on the proposed rule and makes appropriate revisions before publishing the final rule in the Federal Register to become effective.
  • Interim Final Rule  –  These interim rules are typically issued in conformity with statutory provisions allowing agencies to publish a final rule that becomes effective soon after publication, without going through the proposed rule stage. The “good cause” exception in the Administrative Procedure Act allows agencies to bypass public notice and comment on a rule when it would be impracticable, unnecessary, or contrary to the public interest. This process typically allows for public comment after the rule is published so that the agency still has an opportunity to consider public input and revise the rule accordingly.
  • Direct Final Rule  –  These rules are similar to interim final rules, except that there is no comment period after publication, on the ground that they are uncontroversial. Such rules are categorized simply as “final rules” for display purposes on the dashboard.