Tag Archives: cost benefit analysis

Mary would have turned 18 today; but underride protection isn’t “cost-effective.”

Truck Safety, , ,

Controversy surrounds the cost/benefit analysis undergone to determine whether a safety solution — proven to save lives — is cost effective. In other words, does the total cost to the industry required to implement the solution

divided by

the supposed number of lives saved (and by some formula the number of injuries prevented)

equal a $ figure

less than or equal to the Value of a Statistical Life (VSL) at that point in time [currently $9.6 million]?

If the cost is greater than that VSL, the safety countermeasure is deemed too costly and the rulemaking is ditched. In the case of underride protection, no mandate is thereafter issued to the industry requiring them to install equipment which could save lives.

Here is an example. Single Unit Trucks (SUTs) are not currently required to have rear underride guards which meet the same standard as for tractor-trailers. We petitioned NHTSA in May 2014 to require them. In response, NHTSA issued an Advanced Notice of Proposed Rulemaking (ANPRM) in July 2015. Their preliminary regulatory cost benefit analysis came to this conclusion (p. 26):

Guidance from the U.S. Department of Transportation identifies $9.1 million as the value of a statistical life (VSL) to be used for Department of Transportation analyses assessing the benefits of preventing fatalities for the base year of 2012. Per this guidance, VSL in 2014 is $9.2 million.
While not directly comparable, the preliminary estimates for rear impact guards on SUTs
(minimum of $106.7 million per equivalent lives saved) is a strong indicator that these systems will not be cost effective (current VSL $9.2 million).

Yet, here is an April 2017 fatality in Florida from an underride crash involving a Single Unit Truck: Crash kills 2 on I-75 in Bonita Springs

Apparently these lives were not worth saving.

Fairly soon after our crash, after a year or so of taking part in truck safety advocacy efforts, I became aware of the stranglehold which the cost/benefit analysis had on the likelihood of being able to get proven safety solutions actually required. That’s when I launched our Vision Zero Petition which got 20,000+ signatures. That’s when I also found that President Clinton’s Executive Order 12866 was what spelled out the specifications for that regulatory analysis for which the Office of Management & Budget had become the gatekeeper for safety regulations.

Many people made comments on the ANPRM for underride guards on Single Unit Trucks, as well as the NPRM for improved rear underride guards on tractor-trailers to the point that costs were overstated and benefits (saved lives) were understated. In fact, Lois Durso and I recently shared with many people on The Hill, as well as DOT, the proof that our two underride crashes were not even accurately listed as underride crashes with PCI (Passenger Compartment Intrusion) in the NHTSA FARS reports of truck crash fatalities. How many other underride deaths might also be inaccurately reported?

We are convinced that underride deaths are grossly undercounted. In fact, we would go so far as to say that every one of the 4,000 (on average) truck crash deaths each year should be considered an underride death unless otherwise proven (compared to the 200 to 600 annual deaths currently attributed to underride). After all, when a passenger vehicle collides with a large truck, it will be with some portion of that truck. If that part of the truck does not have any/adequate underride protection, then some degree of underride is, of course, likely to occur — which means that the truck is likely to intrude into the passenger occupant space. PCI then occurs with death and/or catastrophic injuries.

It is not necessarily the truck crash per se that causes the horrific deaths and injuries but rather the underride of the truck into the passenger occupant space. But this is not the current thinking in FARS data collection and regulatory analysis.

But even if we found a better way to report these deaths and every single one was included in the count, could someone find a loophole in the formula and still declare that comprehensive underride protection was not cost-effective and these lives were not worth saving?

When we were in DC a few weeks ago and met with DOT, I had a glimmer of hope because we were told that there had been recent discussions of the fact that the achievement of Zero Deaths in the airline industry was in stark contrast to the 35,000 annual deaths on the roadways. There was apparently realization that something had to be changed in how DOT is addressing this major public health problem — including the consideration of studying “near misses.” After all, DOT has publicly stated that their strategic plan is to move Toward Zero Deaths. I say, Let’s hold them to it!

Might we see a shift away from cost/benefit analysis that devalues human life to a cost-effectiveness approach that considers what is the most effective way (with the least cost) to save every life possible? What would it take to bring that about? Would President Trump be willing to sign an Executive Order authorizing Vision Zero Rulemaking?

If our truck crash had been less complicated — if I had rear-ended the tractor-trailer ahead of us instead of another truck hitting us and causing us to go backward into the tractor-trailer ahead of us — I would not be a truck crash survivor. I would have experienced Death by Underride and, quite likely — being in the back seat — AnnaLeah and Mary would have survived.

Mary would have lived to celebrate her 18th birthday today. She would have become an adult. She would have had the chance to live out her dreams and hopes. She would have continued to fill the world with her joie de vivre.

That is why I am unwilling to compromise and why I will continue to insist on underride protection that is comprehensive and effective to the fullest extent technologically possible in concert with the crashworthiness of cars. If that had been so on May 4, 2013, then AnnaLeah and I, along with our whole family, would have been able to wish Mary a very happy 18th birthday.

 

WUSA9 Truck Underride Series: Part 2, Special Assignment Unit: Cost of a Life

Truck Safety,

Part 2 of the truck underride series aired on Friday, July 14, on WUSA9:  Special Assignment Unit: Cost of a Life

Here is the accompanying article on their website:  How much is your life worth?

Video for Parts 1 & 2 can be found here: Mothers fight for tougher tractor trailer laws after daughters die in underride crash

WUSA9 Truck Underride Series, Part 1: 3 young girls lives cut short in truck underride crashes

Truck Safety, ,

Last night, Eric Flack, investigative reporter with WUSA9 in Washington, D.C., began the first part of a series of broadcasts on truck underride. Part 2 will air Friday night, July 14, at 11 p.m.

See last night’s broadcast here: 3 Young girls lives cut short in truck underride crashes

Facebook Livestream Introduction last night:  https://www.facebook.com/WUSA9/videos/10156426907094778/

After looking at some of the comments on the WUSA9 Facebook page, I realized that there were many truck drivers who were complaining about the fact that many car drivers aren’t paying attention or driving safely around trucks. While that may be true, it bothered me that they don’t seem to get that we are not talking about who caused the crash. We are talking about preventing a collision from turning into an underride tragedy.

The problem is that, possibly due to their perception of the issue, the truck drivers get upset because they fear the loss of their livelihood as a result of the cost of installing safety devices. Then they lobby Congress who worries about their campaign contributions and re-election. On top of that, the cost/benefit analysis is skewed and the protection does not get put on decade after decade.

There seems to be an inadequate grasp of the concept that we are not talking here about blame for the collision itself. We are talking about what Dr. Haddon called the “Second Collision”  — what the body collides with after the initial collision — in this case because the underride causes the truck to enter the passenger occupant space (known as Passenger Compartment Intrusion or PCI), leading to catastrophic injuries.

 Underride protective devices can be compared to airbags and seat belts — all of them being passive restraint devices/systems. Should we make the decision to not use airbags and seat belts because, really, people just need to pay more attention and drive better?

A Passive Restraint System is defined in one of the following ways:

  • A system that is constantly operating while a driver sits inside the automobile and the vehicle is in motion
  • A system that restrains the individuals within from moving if a collision occurs
  • A system which deploys automatically without any intentional action having to be undertaken by any of the individual(s) inside of the vehicle

Comprehensive Underride Protection is designed to prevent the Second Collision of the body with the truck. Without the CUP, the crush zone of the car and the other passive restraint devices (airbags and seat belts) don’t have a chance to go to work for us.

Yesterday, I posted these thoughts in response to industry concerns (costs) about underride legislation: Should the trucking industry be concerned about underride legislation?

Recent article in support of adding side guards: Underride crashes aren’t new. Hollywood starlet Jayne Mansfield famously died in such a crash a half-century ago (June 28, 1967 to be exact). And the technology to prevent them, including side underrides, is now well proven. The only real obstacle is whether the nation’s elected leaders in Washington are willing to require the safety upgrade despite trucking industry opposition. Truck trailers can (easily) be made safer, Baltimore Sun, July 14, 2017

The truth of the matter is that the trucking industry and the government have been well aware of these problems for decades and yet have not relentlessly pursued an effective solution. Can we hope that this will change? If not, shame on them.

How many people have to die before they do something?

The Roya, AnnaLeah & Mary Comprehensive Underride Protection Act of 2017:  RAMCUP Draft 15 with Cover

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

Truck Safety, , , ,

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

DOT & OMB: Are you using CEA or CBA rulemaking? Road to Zero requires Vision Zero Rulemaking

Safety Advocacy, Truck Safety, ,

I have a simple request for the Department of Transportation and the Office of Management & Budget/OIRA:

  1. Please let me know if you are using Cost Effectiveness Analysis or Cost Benefit Analysis.
  2. And, please be transparent by telling me what your formula is. What are your parameters?
  3. And, please sit down with us and have a face to face conversation about this.

Unless you use truly Vision Zero rulemaking, the Road to Zero Coalition’s goal will most probably fall short.

Cost.Benefit Analysis

“Money At Root of Takata’s Tragic History”

Safety Advocacy, , , ,

Talking about SAFETY becomes meaningless when no one really values human life over making a profit. When will we get that and say that we have had enough?

Latest email from Lou Lombardo:

Dear Care for Crash Victims Community Members:

NY Times publishes an excellent article on victims of vehicle violence due to air bag defects known for more than a decade.

“In the late 1990s, General Motors got an unexpected and enticing offer. A little-known Japanese supplier, Takata, had designed a much cheaper automotive airbag.

G.M. turned to its airbag supplier — the Swedish-American company Autoliv — and asked it to match the cheaper design or risk losing the automaker’s business, according to Linda Rink, who was a senior scientist at Autoliv assigned to the G.M. account at the time.

But when Autoliv’s scientists studied the Takata airbag, they found that it relied on a dangerously volatile compound in its inflater, a critical part that causes the airbag to expand.

“We just said, ‘No, we can’t do it. We’re not going to use it,’” said Robert Taylor, Autoliv’s head chemist until 2010.

Today, that compound is at the heart of the largest automotive safety recall in history. At least 14 people have been killed and more than 100 have been injured by faulty inflaters made by Takata. More than 100 million of its airbags have been installed in cars in the United States by General Motors and 16 other automakers.

Details of G.M.’s decision-making process almost 20 years ago, which has not been reported previously, suggest that a quest for savings of just a few dollars per airbag compromised a critical safety device, resulting in passenger deaths. The findings also indicate that automakers played a far more active role in the prelude to the crisis: Rather than being the victims of Takata’s missteps, automakers pressed their suppliers to put cost before all else.”

NY Times also publishes a useful article on what consumers can and should know and do.

“Defective airbags made by Takata have been tied to at least 14 deaths and more than 100 injuries. The ensuing recall — the largest in automotive history — has turned out to be messy, confusing and frustrating for car owners.”

http://www.nytimes.com/interactive/2016/business/takata-airbag-recall-guide.html

These stories need to be widely shared.  They give us all useful information on the root of vehicle violence: money.

Lou
Life & Death11wjd2
What can the American people do about this?
Safety is not a priority 002

Truck Underride Tragedies Need to End; Enough is enough!

Truck Safety, , , ,

I recently asked DOT for a breakdown of truck underride deaths by type: front, side, and rear. Yesterday, they sent a chart of Underride Fatalities from the Fatality Analysis Reporting System (FARS)–taken from crash reports submitted to DOT:

From 1994 to 2014, this is the breakdown of Deaths by Underride:

Collision at Front of the Truck: 625

Collision at Side of the Truck: 1534

Collision at Rear of the Truck: 1715

Collision Site Unknown: 132

Total Underride Deaths Reported: 4,006

Truck Underride Deaths by TYPE 1994-2014

Of course, we need to remember that these figures do not include all underride deaths, as it is well-known that they are commonly under-reported. In fact, this chart does not include underride crashes which happened when the truck was parked. When we include those types of crashes, the FARS records yield 5,081 underride deaths in that same time period.

Truck Underride Fatalities, 1994-2014

I have known for some time that there are many deaths due to side underride crashes. But to find out that there are almost as many deaths from side underride as rear underride?! How can NHTSA require rear underride guards and yet not mandate side underride guards? How can they possibly justify that? (Some kind of convoluted cost/benefit analysis, I suppose.) And why are trucks even sold without side guards?

The question must be asked: Whom shall we hold responsible for those 4,006+ deaths (and those not reported as underride deaths), along with the people who died before 1994? The government? The trucking industry? Ourselves for letting it happen in our ignorance or apathy? All of us?

And what about now–today? Will we hold those, who have the authority to act, accountable to do the right thing? Will we demand that they move ahead quickly to correct this tragic and unimaginable situation? Will we make sure that all trucks have the best possible underride protection?

Well?!

Mangled

our mangled Crown Vic on May 4, 2013

Life & DeathIf only

Sign our petition to NHTSA to initiate rulemaking on side guards: Mandate Side Guards On Large Trucks To End Deadly Side Underride Crashes

Demand that we act compassionately to preserve human life rather than protect profit. Otherwise, if we knowingly allow this to continue unabated, will we all be accessories to murder?

Two of the thousands we have lost:

 

Who has the right to block efforts to end Preventable Death by Underride?

Safety Advocacy, Truck Safety, , , ,

I just got back from an errand. Something triggered a memory of AnnaLeah & Mary. I think that it was driving by a park here in Rocky Mount to which Mary and AnnaLeah never got to go. We had lived here less than a year before the crash.

It made me wonder (as I do so often) what they might be doing right now. How  might their lives have unfolded?

All my anger poured out, about how they have been cheated and how wrong it all is. I was yelling in my car, “Who gave power to the trucking industry over life & death matters?  Who has the right to block efforts to end Preventable Death by Underride?”

And that is only one of the many safety issues involved.

Yesterday I was frustrated with the whole side guard issue and the well-known under-reporting of side underride fatalities (in fact, of all types of underride). As far as I can tell, it has contributed to more underride victims as a direct result of the inaccurate cost/benefit analysis that has taken place.

Of course — in case you didn’t already know — I think that the whole cost/benefit analysis basis of safety rulemaking is flawed and unethical and needs to be re-examined. I have clearly laid out my thoughts on this in a drafted Vision Zero Executive Order.

Two more areas which make me concerned — because they do not seem to be taking into account the whole picture — are:

  1. Hours of Service (Have truckers been asked what they think would work best?) and
  2. Speed Limiters (What will truckers do when they need to speed up to get around someone but their speed limiter technology will not allow it? And speed limiters will not change situations where drivers cause crashes because they are driving “too fast for conditions.”)

One trucker, Jeff Halling, recently said to me (regarding speed limiters),

“Can you imagine how this will affect the Move Over Law? I’m running down the interstate stuck at 65 cars are running 80 and 85 miles an hour. An emergency vehicle is on the shoulder in front of me. What do I do? If I move over, it’s guaranteed rear-end crash. If I slow down to 40 miles an hour, which is what they recommend, another possibility of rear-end crash. Just not a good idea. I can say this though, If this law does pass we definitely need to get stronger rear end guards on trailers. Because rear-end crashes will go up ten-fold.”

Both of these situations — in my mind — need someone to facilitate rulemaking who has only safety in mind. Such as a Traffic Safety Ombudsman.

And, one more thing. . .  the pervasive idea in this country has to be confronted that it is an inevitable and acceptable risk you take when you drive on the roads, instead of understanding that there are so many things which could be done to prevent crash deaths.

Who has the power

How can this country continue to turn a cold shoulder to preventable crash deaths?

Safety Advocacy, Truck Safety, , , ,

How can this country continue to turn a cold shoulder to preventable crash deaths? It is so easy to point the finger of blame and not participate in solving the problem ourselves. And it is equally easy to act like it is just a risk that travelers take — and there is nothing that can be done about the problem!

This is a recent comment from a reader (which I did NOT approve to be published on our website) on a post which I wrote related to the Tesla side underride fatal crash:

“This Proves that the Autonomous vehicles are not ready for use. Only an Imbecile would have made millions of truck owners spend thousands to millions because a few Idiots refuse to be Attentive drivers . The time for the Autonomous car is not here ,and the Whole idea needs to be SCRAPED”

And here is another:

“Here’s a novel idea. Require drivers of cars to PAY ATTENTION TO THE ROAD! Ban self driving cars or anything else. The autopilot system failed. It did not recognize the white side of the trailer. It failed to distinguish between the trailer and the sky. Stop trying to put extra burden on the trucking industry. Learn to actually drive. Take a defensive driving course . Don’t rely solely on technology . Relearn to use your brain.”

Either orCar Safety Wars

How can my daughters be gone. . . how did it come to this, that innocent lives would be required to pay the price for this travesty?

CBA Victim

Cost Benefit Analysis Victim

I am thankful that there are many who are working on the problem of preventable crash deaths and I pray that we can make tangible progress — despite the evidence that opposition continues.

Traffic Safety Ombudsman Petition: End Preventable Crash Fatalities: Appoint a National Traffic Safety Ombudsman

When Will We Tackle Underride? – The Hidden Dangers in Trucks

Is it ethical to not use safety technology which could save human lives?

“Stifled Grief: How the West Has It Wrong”

AnnaLeah and Mary, Safety Advocacy, , ,

Stifled Grief: How the West Has It Wrong Huff Post (Common Grief) Michelle E. Steinke Founder/CEO – One Fit Widow, My 1 Fit Life,

It is my grief — my ongoing heartfelt loss —  which compels me to ask these questions.

CBA Victim Cost Benefit Analysis Victim

Is Cost/Benefit Analysis Appropriate for Life & Death Matters? Were their lives worth saving?