Tag Archives: IIHS

Can Conflicting Conclusions in Side Underride Guard CBAs BOTH Be Correct?

Safety Advocacy, Truck Safety, , , , , , , , ,

What will Congress and NHTSA do with conflicting conclusions from two side underride guard cost benefit analyses? After all, they can’t both be correct, can they? The answer matters for thousands of road users who may otherwise lose their lives in future collisions with the sides of tractor-trailers.

In 2023, NHTSA issued an Advanced Notice of Proposed Rulemaking (ANPRM) for side impact (underride) guards. The cost benefit analysis, which was not externally peer-reviewed, concluded that 17.2 lives would be saved per year, that the annual discounted cost would be between $970 million and $1.2 billion, with a resulting cost per equivalent life saved ranging between $73.5 million to $103.7 million. They therefore determined that a side impact guard regulation would not be cost-effective.

In contrast, Eric Hein, a retired federal scientist, published a double-blind, peer-reviewed cost benefit analysis study in the Journal of Progress in Safety & Security on May 15, 2026, titled, Cost-benefit analysis of side underride guards for new semitrailers in the United States. Hein concludes,

In every modeled scenario, preventing 50 to 150 fatalities and comparable numbers of serious injuries produces positive present value net economic benefits. Estimated net benefits range from $0.137 billion to $2.8 billion and consistently exceed the combined costs of side underride guard installation and the fuel penalty attributable to added weight.

These two one-pagers, created by Hein, summarize the results of his study:

Side Underrride CBA Policy Brief

Side Underride Hidden Legal Costs

NHTSA requested comments on their 2023 Side Impact Guard ANPRM Regulatory Analysis:

The agency requests comments that would help NHTSA assess and make judgments on the benefits, costs, and other impacts of side underride guards to increase protection for occupants of passenger vehicles in crashes into the sides of trailers and semitrailers. This ANPRM summarizes NHTSA’s research and requests comment on the accuracy of the estimated benefits, costs, and other impacts of requiring side underride guards on heavy trailers and semitrailers.

In response to NHTSA’s request for Public Comments, numerous individuals and organizations questioned the accuracy of NHTSA’s conclusions. That included this excerpt from a comment submitted by the Insurance Institute for Highway Safety:

The Insurance Institute for Highway Safety (IIHS) believes NHTSA’s analysis suffers from several fundamental flaws that reduce its benefit estimates for side underride guards. Specifically, we estimate the number of lives that could be saved by a side underride guard standard is up to ten times the number reported by NHTSA. . .

The LTCCS-derived estimates for relevant fatalities are roughly 9-13 times the 17.2 lives NHTSA
estimated could be saved by a standard. Interestingly, the agency estimated the costs of a rule to be “6-9 times as large as the corresponding estimated safety benefits.” Establishing how many of these crashes may overwhelm side guard designs and still allow fatal underride would require higher speed crash testing of different potential designs and a better estimate of real-world crash severity in side underride crashes, including a reasonable distribution of impact angles. Even after applying a realistic upper severity limit for guard effectiveness, the available EDR data suggest a side underride guard regulation would be close to the cost effectiveness threshold established by NHTSA using passenger vehicle occupants alone. The true benefits will only be larger once the agency accounts for the number of pedestrians, bicyclists, and motorcyclists whose lives could be saved by side underride guards.

In conclusion, IIHS believes side underride guards have the potential to save many more lives than NHTSA has estimated in its cost-benefit analysis. We urge the agency to perform a more thorough analysis that does not depend on multiple assumptions that guards will provide no benefit outside a narrow range of conditions. Large truck side underride crashes result in hundreds of lost lives and debilitating injuries each year. Equipping trailers with side underride guards would immediately and significantly reduce this unacceptable toll.

Now that NHTSA has received multiple public comments questioning the accuracy of their cost benefit analysis, what are they going to do? Will they pay heed to the Public Comment submitted to NHTSA in 2016 by the Truck Trailer Manufacturers Association (TTMA) in response to a 2014 petition for underride rulemaking? TTMA President Jeff Sims concludes that comment with this commitment,

TTMA would support the implementation of side impact 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.

Hein referenced his study in a recent opinion piece published on June 4 in The Hill, Federal regulators know exactly how to prevent side underride deaths. Hein concludes with a reminder and recommendation to Congress regarding its role in ending preventable underride tragedies.

In 2021, the Infrastructure Investment and Jobs Act directed National Highway Traffic Safety Administration to assess the feasibility, benefits and costs of side underride guards and determine whether performance requirements were warranted. The agency issued an advance notice of proposed rulemaking in April 2023, but its analysis left out major categories of preventable harm. It did not count side underride deaths involving pedestrians, bicyclists and motorcyclists, and it excluded crashes above 40 miles per hour, even though the government’s own research shows side guards can be effective up to 50 miles per hour. 

Congress required a decision, not endless review. More than three years later, the agency has not finished the job, still stuck reviewing comments. The rulemaking has not advanced. 

Since the 1970s, the National Transportation Safety Board has urged the agency to address underride protection. Its Advisory Committee on Underride Protection recently reached a similar conclusion, reporting that “in the last 50 years no substantial progress has been made by [The Department of Transportation] to prevent these horrific crash fatalities and injuries.” Yet the National Highway Traffic Safety Administration continues to delay while families keep losing loved ones in crashes that can be prevented. 

The agency does not need perfect data to act. Federal safety regulation often proceeds under uncertainty when the risk is severe, the countermeasure is feasible and the evidence supports action. 

The trucking industry has often said side underride guards should be required only if they are technologically feasible and economically justified. Those conditions have now been met. Crash tests and real-world deployments show the technology can work. 

Congress should include the Stop Underrides Act in the next surface transportation reauthorization and finally require side underride guards on new semitrailers.

Side impact guards have been shown to be both technologically feasible and cost-justified. What are we waiting for?

Stoughton Successfully Completes 40 MPH Rear Impact Guard Crash Test

Truck Safety, , , ,

Thank you, Stoughton Trailers, for leading the way in safety. At no added cost or weight to your customers.

Stoughton Trailers is proud to announce that it has successfully met the Insurance Institute for Highway Safety (IIHS) TOUGHGUARD® requirements at an elevated speed of 40 MPH, surpassing the 35-mph standard IIHS previously set for the van trailer industry.

Read more here: Stoughton Trailers Press Release

As I said in 2017, Stoughton Underride Guard Earns Kudos from Crash Survivor, Insurance Institute:

Upon learning of Stoughton’s decision to make this improved protection available on all of their new trailers, Karth said, “Stoughton’s cooperative efforts to improve the performance of its rear impact guard demonstrates a genuine commitment to safety. Stoughton is to be commended for taking a significant leadership role in design and safety. In my opinion, many lives will be saved as a result of Stoughton’s efforts.” 

  • Thanks to STOUGHTON’s improved Rear Impact Guard, Terry Rivet survived a truck crash in March 2017.
  • Stoughton Press Conference at TMC 2017 Conference
  • Speaking at Stoughton’s Press Conference in 2017
  • Stoughton’s Engineering Innovation won’t bring AnnaLeah & Mary back, but it will save others.

Other Stoughton achievements include the IIHS TOUGHGUARD Award in 2025 for their intermodal chassis: Insurance group approves first container chassis crash guard

Video from 2016 Crash Test: In this toughest IIHS underride guard test, 30 percent of the front of a midsize car strikes a parked Stoughton trailer at its outermost corner at 35 mph. Underride guards are weakest at the outer edges of a trailer.

Oh, by the way, Stoughton also has a side guard patent. Will they lead the way in fully guarding their trailers from underride and lethal passenger compartment intrusion?

Critique of NHTSA-Contracted Elemance Rear Impact Guard Research

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Secretary Duffy,

The Department of Transportation (DOT) engaged Elemance LLC in 2022 to evaluate three current designs of rear impact guards. Unfortunately, Elemance conducted Finite Element analysis of two obsolete rear underride guards that were not current designs at the time of the contract. In fact, both of those designs had been proven a decade earlier to be crash-deficient. The two manufacturers — Great Dane and Wabash — have developed designs with safer, stronger rear-guard designs. Elemance compounded that error by employing an erroneous definition of Passenger Compartment Intrusion. Elemance’s research findings, Heavy-Truck Rear-Impact-Guard Finite Element Simulation and Analysis, are flawed and backwards-looking rather than helpful to the Department and Congress in evaluating current and future rear underride guard performance and regulatory standards.

Please find attached a detailed critique by engineers who are well-acquainted with the underride problem and solutions. This is what the engineers concluded about the NHTSA-contracted research:

In view of the defects in the Elemance report, a follow up study should be commissioned to evaluate examples of current state of the art rear impact guards that have been in service since 2016 and 2017 respectively. The study should utilize the correct definition of PCI and more accurately assess injury risk.

The Department should act promptly to address the flaws in this federal research in order to fulfill its mission to reduce roadway injuries and deaths.

Jerry and Marianne Karth

Note: This critique was submitted as a Public Comment on September 3, 2025, to the U.S. Department of Transportation in response to their Request for Comments on priorities for the 2026 Surface Transportation Reauthorization.

This video created by the Insurance Institute for Highway Safety twelve years ago explains their Rear Impact Guard crash testing research and how the federal standard is failing to protect road users:

This video is a compilation of IIHS Rear Impact Guard crash tests with old and new guard designs for many of the major trailer manufacturers:

This video demonstrates the night & day difference between old and new designs by one manufacturer:

Good News: Stoughton extends IIHS-award-winning underride protection to container shipping

Safety Advocacy, Truck Safety, , , , ,

Good news on underride protection: IIHS has given the TOUGHGUARD Award for rear impact underride protection on intermodal chassis trailers to Stoughton Trailers — the first trailer manufacturer to earn it and one of the largest chassis manufacturers in North America. Should this lead to speculations about what engineering ingenuity could actually produce — despite industry grumblings about the operational issues regarding underride protection, particularly at the sides of intermodal chassis trailers?

Underride guards that meet the Toughguard criteria are substantially more likely to withstand an impact, reducing the severity of the crash. Until now, only dry van, refrigerated and flatbed trailers have qualified. But with the growing importance of shipping containers in global trade, more and more freight is being transported using intermodal chassis.

Chassis-type trailers present a unique challenge when it comes to underride protection. The frame of a dry van, refrigerated or flatbed trailer extends across its entire wheelbase, supporting the underride guard for its full width. In contrast, an intermodal chassis is a ladderlike structure that lies between the trailer’s wheels to support the removable container.

For that reason, the underride guard required a completely new design. Instead of a vertical support attached to the trailer deck, the chassis guard features long, diagonal supports running from the guard’s outboard ends to the chassis rails. Stoughton Intermodal Chassis Earns Underride Guard Award

I’m grateful for Stoughton Trailers’ continued commitment to safety. Unfortunately, not every trailer manufacturer is equally safety-minded. And NHTSA has not shown an inclination to send a strong message to industry; in fact, they declined to include Stoughton’s dry van RIG solution in their regulatory analysis for a 2022 update of the rear guard rule. Decades of government and industry inaction means that there are still far too many (almost ALL of them) trucks on the road which do not have adequate underride protection.

Engineers know how to creatively solve problems. Give them a green light to SAVE LIVES!

May 4, 2013 seems like just yesterday; has anything changed?

AnnaLeah and Mary, Safety Advocacy, Truck Safety, , , , , , , ,

There’s no easy way to get through that time of year when we remember how AnnaLeah & Mary were suddenly snatched from this earthly life. How can it have been ten years ago? May 4, 2013 seems like just yesterday.

Read this post all the way through to find out what advances have come about, or skip to the end to find out how you can help. Despite our loud voices continuously raising awareness and pushing for change, progress has been painfully slow. But these are some actions which the USDOT has taken:

  • Rear underride guards are now on the annual commercial motor vehicle inspection checklist (rule issued by FMCSA in December 2021). This is important because poorly-maintained rear guards increase the chance of crash severity.
  • After beginning work on an improved rear guard rule in December 2015, in response to our 2013/2014 petitions, the National Highway Traffic Safety Administration (NHTSA) finally issued an improved rule in July 2022. Incredibly, it fell short of requiring that the guards had the full strength already proven possible by the IIHS testing of nine major trailer manufacturers! We have petitioned NHTSA to reconsider this ill-advised decision.
  • NHTSA began taking applications for membership on an Advisory Committee on Underride Protection (ACUP) in July 2022. They finally announced the selected committee members in April 2023. The first ACUP meeting will take place virtually on May 25. I’m thankful that I will, at last, be able to sit “around the table” with a diverse group of stakeholders to hammer out reasonable solutions to this century-old problem.
  • Simultaneously with the ACUP announcement, and in advance of receiving any recommendations from the Advisory Committee, NHTSA published an Advanced Notice of Proposed Rulemaking (ANPRM) for a potential side guard regulation. Their cost benefit analysis is based on questionable data and concludes that a side guard regulation would not be cost effective. We are working hard to provide more accurate information in order to correct the CBA in favor of saving lives.

“How can I help?” I thought you’d never ask!

  • Pray for the ACUP members and for this process to produce meaningful outcomes.
  • Only 17 states have an UNDERRIDE FIELD on their state crash report form. This contributes to underreporting of these deaths. By 5:00 p.m. EST on MAY 3, submit a simple, brief Public Comment here. Tell NHTSA you want them to require (not merely suggest) that states have an Underride Field (and which indicates whether it was front, side, or rear) on their crash report form.
  • By June 20, submit a Public Comment on the side guard ANPRM here. Tell them why you think that there should be a side guard regulation (simple reason: To Save Lives).
  • Tens of thousands of underride victims have been a nameless group whose senseless deaths have been swept under the rug for decades despite the ingenuity of engineers to prevent horrific underride. No more. We would like to remember these Precious Ones Gone Too Soon in a special way. We hope to receive permission from the USDOT to install a Commemorative Bell of Hope at their office building in Washington, D.C. We will be organizing a day In Memory of Underride Victims — to ring the bell and call out the names of individuals who lost their lives to underride. We do not know every name, but we will include as many as possible. If you would like to contribute to the purchase of this bell or participate in this event, please let me know by writing to me at marianne@annaleahmary.com.
Side Guard Crash Test in Raleigh, September 2022
To remember how AnnaLeah & Mary lived — full of love & laughter — not merely how they died.

Someday, Seeing Side Guards & Strong Rear Underride Guards Will No Longer Surprise Me

Safety Advocacy, Truck Safety, , , ,

On the way home from our recent side guard crash test in Raleigh, I saw a Carolina Trucking Academy tractor-trailer turn the corner — with side guards! The ones that Jerry helped install not too long ago. Such a good feeling.

Another Side Guard On The Road

And today, on my way home from getting groceries, I saw a tractor-trailer with a rear #underride guard which met the strength of an Insurance Institute for Highway Safety TOUGHGuard Award. I knew it for sure because it had a sticker saying so — like the one we saw on our recent trip North.

I hope that, someday soon, I won’t be so surprised to see these things because they will be commonplace and known for saving lives. I might not get so excited, but I’ll still be grateful.

Five Years Have Passed Since the Historic IIHS Side Guard Crash Test

Truck Safety, , , , ,

The Insurance Institute for Highway Safety (IIHS) conducted an important crash test on March 30, 2017. They crashed a car at 35 mph into the side of a trailer equipped with AngelWing side guards. This crash test was later repeated successfully at 40 mph at the Second Underride Roundtable on August 29, 2017. It was official. Deadly side underride tragedies could be prevented.

What seemed perhaps even more significant was the fact that the following day, March 31, 2017, the IIHS conducted a second crash test into the side of a trailer — only this time, there was no side guard. The stark contrast of the two crashes was captured on film for all to see. Who could argue the benefit of this feasible feat of engineering technology?

Apparently it has not been enough to convince everyone, as we are still struggling to bring this uphill battle to an end five years later. Pray that Pete Buttigieg, the Secretary of Transportation, who is tasked by Congress with making a determination this year, will conclude that saving lives is worth the cost to require trailer manufacturers to equip new trailers with side guards. Otherwise, the inaction of industry and government will allow the senseless, violent slaughter of unprotected road users to continue day after day, year after year — while engineering solutions sit on the shelf gathering dust.

Back of the Envelope Math: How many side underride deaths since March 19, 1969?

Guided Tour of the Truck Underride Exhibit at the IIHS:

IIHS Research Provides Foundation for Traffic Safety Legislation – Including Underride

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This week, the Insurance Institute for Highway Safety (IIHS) justifiably pointed out how their amazing safety research has led to much of the bipartisan traffic safety legislation which the Senate and House recently passed — likely to see final confirmation in the coming weeks. Thankfully, this legislation includes underride provisions — for an updated rear guard standard and further research on side underride.

Years of work by IIHS-HLDI paved way for safety provisions in infrastructure bill, August 25, 2021

What the IIHS did not mention was how long it has taken for that legislation to come about — decades. Further, they didn’t stress, as strongly as I would have, how frustrating it is that the IIHS research — coupled with recommendations from the NTSB — still doesn’t seem to be enough to warrant a straight-out mandate for side guards.

On top of that, the IIHS did not mention the missing components of the underride legislation; the infrastructure bill does not include even a hint of research regarding protection of the traveling public from deadly underride under Single Unit Trucks (otherwise known as straight or box trucks) or at the front of large trucks. And we’re talking not only about passenger vehicle occupants but, also, Vulnerable Road Users — pedestrians, cyclists, and motorcyclists. Yet, IIHS and FMCSA have published reports about those safety hazards:

IIHS Status Report, August 26, 1989

If NHTSA is truly data-driven, then shouldn’t the fact that 61% of the two-vehicle truck crash fatalities in 2019 occurred with first impact at the front of large trucks spur significant research into front underride protection? Shouldn’t we at least consider the potential for proven technology — already installed by major international truck manufacturers on their products in other countries — to make truck crashes more survivable?

Will we, instead, continue to ignore the preventable deaths which occur year after year? Perhaps might we, at least, engage in meaningful, collaborative conversation about potential solutions — active and passive — to end these tragedies? Other countries have done so.

Volvo Trucks Safety – FUPS crash test, published 2009
Front Underride Protection Panel
Engineers, Trucking Industry, & Victim Advocates Collaborate at Side Guard Task Force February 2021
Front Underride Protection Presentation at a Congressional Staff Briefing, by Friedman Research Center

What is wrong with US? Dare I hope that we might finally come to our senses and pursue significant change?

Will DOT Respond to Petition for Underride Rulemaking on Single Unit Trucks?

Petition for Underride Rulemaking on Single Unit Trucks (sign here)

Engineers, Trucking Industry, & Victim Advocates Collaborate at Side Guard Task Force

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On a Friday afternoon — February 26, 2021 — over 50 people met via Zoom to discuss comprehensive underride protection. The purpose of the meeting was to report on progress which has been made by several subcommittees since an earlier meeting in 2020 — including Industry Engagement, Research, and Engineering Subcommittees.

The goal of the Underride Engineering Subcommittee — to which trailer manufacturers were invited — was to create a Consensus Side Guard Standard which would provide additional insight for the development of a side guard regulation. Lengthy conversation and exchange of information has led this group to submit the following recommendation:

A side underride guard shall be considered to meet the performance standard if it is able to provide vehicle crash compatibility with a midsize car, to prevent intrusion into the occupant survival space, when it is struck at any location, at any angle, and at any speed up to and including 40 mph.

The Task Force went so far as to suggest that the Truck Trailers Manufacturers Association (TTMA) discuss the Consensus Side Guard Standard at their upcoming annual meeting in San Antonio, April 7-10, 2021. We encouraged them to come together in a Joint Agreement to adopt or improve the Consensus Side Guard Standard, as an association, and fast track the manufacturing of side guards by their 80th Anniversary in 2022.

Accept the standard; build a guard.

IIHS successful 40 mph AngelWing side guard crash test, 8/29/17
Zoom Video Recording of the Side Guard Task Force Meeting on February 26, 2021
NOTE: The meeting begins at around 7:00 minutes into the video.

Sean O’Malley, Senior Test Coordinator at the Insurance Institute for Highway Safety (IIHS), gave a presentation at the Side Guard Task Force. He stated that, “Everything we do here, we do to save lives. I wasn’t kidding when I said the rear underride program (ToughGuard) is what I’m most proud of. ” Trailer manufacturers responded to the IIHS creation of a safety marketplace for improved rear underride guards by working to meet the TOUGHGuard Award level of protection at the rear of tractor-trailers. Why then would they not do the same to meet the Consensus Side Guard Standard of protection at the sides of tractor-trailers — particularly since the IIHS supports it with their 40 m.p.h. test?

Underride is underride no matter with what part of the truck you collide — because the bottom of large trucks sit up higher from the ground than the bumpers of passenger vehicles. All the way around.

So now what do we do? Will we wait another 100 years? How many more lives will be sacrificed?

This compelling video will show you why Death By Underride, though unnatural & preventable, still continues.

Trucking companies could demand trailers with side underride guards. Trailer manufacturers could supply trailers with side underride guards. Or the government could mandate side underride guards — ideally with the support of industry because a government law or regulation will place all manufacturers on a level playing field.

Families of underride victims and engineers appealed to trailer manufacturers to take the bull by the horn, embrace the Consensus Side Guard Standard, and move forward with developing and installing side underride guards ahead of government requirements.

Today, I was reflecting on the Side Guard Task Force meeting and a strategy for action going forward. As I was looking up information on an engineer from one of the manufacturers, whom I’d met several years ago, I noticed that the manufacturer is making plans to hire an engineering intern for the Summer of 2021. Beautiful! Brilliant! How about we show this young intern how engineers can save lives.

Imagine engineering students from universities around the nation spending the coming year doing internships or senior capstone projects at trailer manufacturing companies working alongside industry engineers on side underride guard development. Collaboration could take place and serve to more rapidly bring about the development and implementation of long-overdue, life-saving technology.

MEETING RESOURCES:

Note: The Side Guard Task Force meeting on February 26, 2021, was a follow-up to an earlier meeting. On April 17, 2020, over 40 people participated in a virtual meeting of a volunteer Underride Protection Committee’s “Side Guard Task Force.” This included two engineers from trailer manufacturers. As a follow-up, several subcommittees began to hold virtual meetings, including an Underride Engineering Subcommittee.

After listening to Andy Young interview Eric Hein about the loss of his son, Riley, in a side underride, participants viewed a photo memorial slideshow of some of the countless underride victims:

Underride Victim Photo Memorial – The Tip of the Iceberg

Some of the many individuals and organizations who have made contributions to the work on underride protection were celebrated in this Underride Hero Hall of Fame video:

Underride Hero Hall of Fame

Note: the video of the complete meeting is an unedited Zoom recording. As excerpts from the agenda are created, Youtube video links will be added.

What Will Come Next in the Timeline of Underride Regulatory History?

Safety Advocacy, Truck Safety, , ,

People have died under trucks since passenger vehicles and trucks have shared the road. What changes have we seen in underride protection? Here is a Timeline put together by the Insurance Institute of Highway Safety for the first Underride Roundtable on May 5, 2016.

What’s next? What will the future hold for underride rulemaking? More of the same or significant progress in preventing underride tragedies?

Underride-timeline