Tag Archives: IIHS

Government Accountability Office (GAO) Truck Underride Report Published After a Year-Long Investigation

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After the STOP Underrides Bill was first introduced on December 12, 2017, several members of Congress –Senators Thune, Rubio, Burr, and Gillibrand — requested that the Government Accountability Office prepare a report on truck underride guards. That report was published today and can be found here.

The online report is organized into sections, including Fast Facts, Highlights, and Recommendations. The GAO Recommendations are:

  1. Recommendation: The Administrator of the National Highway Traffic Safety Administration should recommend to the expert panel of the Model Minimum Uniform Crash Criteria to update the Criteria to provide a standardized definition of underride crashes and to include underride as a recommended data field.
  2. Recommendation: The Administrator of the National Highway Traffic Safety Administration should provide information to state and local police departments on how to identify and record underride crashes.
  3. Recommendation: The Administrator of the Federal Motor Carrier Safety Administration should revise Appendix G of the agency’s regulations to require that rear guards are inspected during commercial vehicle annual inspections.
  4. Recommendation: The Administrator of the National Highway Traffic Safety Administration should conduct additional research on side underride guards to better understand the overall effectiveness and cost associated with these guards and, if warranted, develop standards for their implementation.

Here is a 46-page pdf of the Full Report.

I’m curious what Members of Congress along with the Department of Transportation and the trucking industry were anticipating to come out of the report. What did they expect to be uncovered that we have not already been talking and writing about and demonstrating for all to see at the D.C. Underride Crash Test on March 26, 2019 — not to mention, more importantly, with the lost lives of countless underride victims?

In a nutshell, the GAO team told the National Highway Safety Administration (NHTSA) that  Improved Data Collection, Inspections, and Research were needed. In fact, we already knew that, in order to get an accurate count of underride deaths (and injuries), better collection was needed. We have been talking about the need for rear underride guards to be added to the Vehicle Inspection Checklist.  And the STOP Underrides Bill calls for research to find the outer limits of underride protection.

But what the STOP Underrides Bill does not do is say to wait until better data collection has been collected before issuing a mandate to install proven underride protection. That would be like saying: Wait for 14 more years of underride deaths until you have improved collection of how many people are dying and then start using equipment (that was already available) so you know how many people you could have kept alive!

The GAO Report recommends that NHTSA take steps to add underride to the Model Minimum Uniform Crash Criteria (MMUCC) — a guideline to states to use for their crash report forms. However, the next version will not be issued until 2022.

If NHTSA uses this recommendation to justify holding off on underride rulemaking, then they will set us all up for a continuation of same old, same old. NHTSA might sooner or later (in 2022 when the updated MMUCC comes out) START urging states to improve their underride data collection. But then how many years of improved data will they insist that they need before they can proceed with rulemaking (which itself takes 3 or more years before it gets to the implementation phase)?
 
This is what I foresee, if NHTSA is left to their own devices (unless something else intervenes):
2022     New MMUCC
2024     States are ready for better underride data collection
2028     FARS underride data has maybe improved
2029     NHTSA issues an ANPRM to test the waters
2030     NHTSA issues a NPRM side underride rulemaking (what about the rest?)
2033     Implementation of side guard rule begins for new trucks

2043    The whole fleet will have them on (maybe).

Conservative estimate of 300 underride deaths/year x 14 years (2033) = 4,200 more needless deaths (plus catastrophic injuries) if Congress does not mandate that the Department of Transportation move forward with comprehensive underride rulemaking immediately.

What GAO recommends to NHTSA are good actions, but they fall short of an acknowledgement that people have, are, and will continue to die from truck underride unless we act decisively as a nation to mandate that the industry install equipment to prevent it.

The GAO report acknowledges that the trucking industry is waiting for a mandate before it will act. The report also illustrates how NHTSA has been less than diligent to address the underride problem. So, why would we expect that a mere recommendation to NHTSA (when they have received multiple underride safety recommendations from NTSB and multiple petitions from IIHS and others over the years) would cause them to act in a timely and effective manner to fulfill their safety mission and protect the people of this country from deadly underride?

The fourth GAO recommendation is this: The Administrator of the National Highway Traffic Safety Administration should conduct additional research on side underride guards to better understand the overall effectiveness and cost associated with these guards and, if warranted, develop standards for their implementation.

What more would NHTSA need to know — than what they already know, along with what would come about through the process of issuing a Notice of Proposed Rulemaking, and what they would learn through working with knowledgeable members of the Committee On Underride Protection (or COUP, as mandated in the STOP Underrides Bill), who could help them identify and understand the effectiveness and costs of underride protection?

It seems clear to me that even the under-reported 219 underride deaths, on average each year documented by NHTSA in the FARS data, do indeed warrant the development of standards for implementation of comprehensive underride protection. The side guard crash testing by IIHS and others have proven that this technology is effective at preventing underride. Therefore, I would interpret the fourth GAO recommendation as supporting the need for Congress to mandate that DOT proceed with the rulemaking outlined in the STOP Underrides! Bill. DOT has demonstrated that they have no intention of issuing rulemaking without a mandate which would force them to do so.

In my mind, the GAO Truck Underride Guards Report only confirms and strengthens my opinion that it is high time for Congress to pass the STOP Underrides Bill and get NHTSA and FMCSA started on a rulemaking process for comprehensive underride protection, which we petitioned them to do on May 5, 2014.  After years of inaction on that petition, on April 4, 2018, we submitted another petition (for supplemental comprehensive underride rulemaking) to Secretary Chao — still with no tangible action taken.

Congress, the ball is in your court.

If you want to go beyond a cursory understanding of the GAO Truck Underride Report, please read this lengthy analysis of the GAO Underride Report: Karth Cliff Notes on the GAO Truck Underride Report.

“AEB that reliably detects trucks could prevent underride crashes.” Meanwhile, what should we do?

Truck Safety, , , , , ,

Automatic emergency braking (AEB) on passenger vehicles is a good thing. It’s purpose is to reduce the chance of a rear-end collision or decrease the severity of the impact if it does occur. But does it function as intended when the vehicle in front of a car is a large truck?

A recent report from the Insurance Institute for Highway Safety (IIHS) implies that it does not reliably do so:

When it comes to preventing typical front-to-rear crashes, automatic emergency braking is a proven winner. Extending its functionality to address less-common types of rear-end crashes involving turning, changing lanes or striking heavy trucks or motorcycles, for instance, would help maximize autobrake’s benefits, a new IIHS study indicates. . .

Autobrake systems that reliably detect large trucks could prevent underride crashes. Twelve percent of U.S. passenger vehicle occupant deaths in 2017 were in crashes with large trucks, and 1 in 5 of these deaths occurred when a passenger vehicle struck the rear of a large truck.

Autobrake is good, but it could be better, IIHS, Status Report, Vol. 54, No. 2, February 21, 2019

If I am interpreting this correctly, this means that, currently, AEB on many vehicles do not reliably detect large trucks in order to prevent underride crashes. This is no surprise as there is almost 4 feet from the bottom of most trucks to the ground; the sensors are apparently not located in such a way as to be able to detect the truck body. No threat is recognized.

Therefore, it appears to me that we cannot rely on the current collision avoidance technology to prevent rear-end collisions of cars into trucks. If we want to more reliably prevent deadly underride and gruesome passenger compartment intrusion, why then would we not install effective comprehensive underride protection on all large trucks?

See what happens when collision does occur into the rear of a truck which is and is not equipped with an effective rear underride guard:

By the way, the same is, of course, true for the sides of large trucks where there is nothing but open space — nothing for the car’s sensors to detect. What will we do about that?

Download this video file to view a recent crash test by Aaron Kiefer into the side of a trailer equipped with the latest version of his SafetySkirt: Video Feb 24, 2 24 45 PM

AngelWing Crash Test at IIHS, March 30, 2017

Myth: Significant differences in vehicle mass responsible for truck crash severity. #STOPunderrides

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Two days ago, I found an Insurance Institute for Highway Safety (IIHS) Status Report from August 26, 1989. It had two articles about front underride protection which clearly demonstrated the benefit of installing that kind of technology on large trucks to reduce the severity of collision injuries.

“Front End, Energy-Absorbing Truck Guards Reduce the Risks for Motorists”, 8/26/89, IIHS Status Report

Here’s another report which I found the next day. It is a NTSB Safety Recommendation from May 8, 2006, which clearly explains the benefits of front underride protection. Thirteen years ago. And I find myself to be the only one in the country talking about this at any level of insistence that we do something about this. Now.

https://www.ntsb.gov/…/safety-recs/recletters/H06_16.pdf

I found it interesting that NHTSA stated in June 2000 that, “the common belief is that not much can be done to diminish the consequences of crashes between smaller vehicles and large trucks because of the significant differences in vehicle mass.

[I know this to be a MYTH both because I know that underride protection can significantly change the outcome and because I am a truck crash survivor of a horrific crash due to the fact that the truck did not come into my part of the car.]

“However, research has shown that geometric height differences and a lack of forgiving front truck structures CAN be modified to help reduce heavy truck aggressivity and to mitigate the severity of these types of accidents. Examples of these modifications, often referred to as ‘front underride protection systems’–which can result in reduced intrusion or occupant injury–include energy-absorbing front structures to offset the weight differences between two impacting vehicles, as well as bumpers designed to deflect the impacted vehicle away from the front of the truck, thereby reducing the total change in velocity of the smaller vehicle.”

This added information stirs up anger in me at what could have been done well before our crash — in which a truck hit us (front underride protection) and in which we collided with the back of a second trailer (rear underride protection). Fortunately, it also stirs up in me renewed energy and zeal to bring down the walls of Jericho and an end to this senseless loss of lives.

Good News for Traveling Public: “All major trailer makers earn IIHS award for good underride protection”

Truck Safety, , ,

The Insurance Institute for Highway Safety announced this week that all eight major trailer manufacturers have now improved their rear underride guards. This is good news for the traveling public.

ARLINGTON, Va. — Seven years after the Insurance Institute for Highway Safety found serious shortcomings in the rear underride guards of most semitrailers, the eight largest North American manufacturers are now making rear guards capable of preventing deadly underride in a range of scenarios. All eight companies earn the IIHS TOUGHGUARD award.

The companies — Great Dane LLC, Hyundai Translead, Manac Inc., Stoughton Trailers LLC, Strick Trailers LLC, Utility Trailer Manufacturing Co., Vanguard National Trailer Corp. and Wabash National Corp. — represent approximately 80 percent of the trailers on the road in the U.S. All but one of them, Manac, had to make changes to its underride guard before they were able to pass the three IIHS tests.

“We’re pleased that all the major manufacturers responded positively to our underride tests,” says David Zuby, IIHS chief research officer. “By improving their guards, these companies have demonstrated a commitment to the safety of passenger vehicle occupants who share the road with their trailers.” . . .

By the time IIHS announced the TOUGHGUARD award last year, 5 of the 8 guards met the criteria.

Since then, Hyundai Translead and Utility have earned the award. Strick now joins them, thanks to a new underride guard that completes the industry’s effort to improve protection against rear underride. . .

See the complete IIHS report here: All major trailer makers earn IIHS award for good underride protection

This is great news, and I am glad for the trailer manufacturers commitment to meet the TOUGHGuard award. But I would have phrased it a little differently myself because I don’t think that this “completes” the industry’s efforts on rear underride.  Still to be done, in my mind:

1. TOUGHGuard rear underride protection become standard on all new trailers — not merely an option.

2. Test the guards to see if they are effective at speeds higher than 35 mph. After all, an aluminum extrusion company has produced a rear underride guard which has been officially and successfully tested at 40 mph.

3. Make retrofit kits available for all trailers at least 10 years back.

4. Install effective rear underride protection on single unit trucks.

5. Enforce the requirement for rear underride guards to be kept in like-new condition because a weakened guard is less likely to perform as needed upon collision.

That is, if we want to prevent rear underride tragedies no matter what truck someone might collide with on the road today or in the years to come. . .

And oh, by the way, the STOP Underrides! Bill would mandate every one of those steps to end preventable underride.

Crash cars from previous crash tests  — one with & one without effective underride protection.