Imagine an underride guard on a truck which combines protection on the rear of the truck with protection on the side. Sound good?
We have an opportunity to raise money to crash test this innovative underride guard–designed by Aaron Kiefer, a forensic engineer/crash reconstructionist in North Carolina, who after seeing horrific crashes wanted to design better protection to prevent people from dying.
See Aaron’s Public Comment on single unit truck underride rulemaking: http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0013 “. . . side impact regulations should be considered for straight trucks but more importantly for semitrailers.
Many lives can be saved through side impact protection that is capable of redirecting passenger vehicles, pedestrians, and bicyclists from moving beneath a straight truck or semitrailer.”
We need to raise $20,000 for a crash test to test Aaron’s design at the Insurance Institute for Highway Safety (IIHS) Vehicle Research Center. So far, we have raised $4,500 to cover the costs of a 2010 Chevy Malibu and a tractor-trailer into which the car will crash.
I received a wonderful email this morning with the Mid-Semester Progress Report from the 6-student team of engineering students at Virginia Tech who took on the creation of a better rear underride guard design as their senior capstone project.
In their words, “our team must strive to achieve the perfect design with respect to each specification, ensuring the absolute best final product.” (Sweet words to this mother’s heart!)
We look forward to seeing them in person at the IIHS Vehicle Research Center on May 5, 2016, as they share the results of their dedicated and innovative efforts at the Underride Roundtable.
I will be praying for the team everyday, including Wayne Carter (Team Facilitator), Daniel Carrasco, Kristine Adriano, Sean Gardner, Andrew Pitt, and Brian Smith–along with Jared Bryson (their Sponsor) and Robin Ott (their Project Advisor).
I remember our trip back from visiting a research & design center in June 2014 and thinking that surely a group of engineers could get together and design better underride protection. It is amazing to watch this unfold.
After a great deal of thinking and talking and preliminary planning, we now have a host facility–the Insurance Institute for Highway Safety’s Vehicle Research Center–and a date, Thursday, May 5, 2016, for our Underride Roundtable.
We will be reaching out to engineers, manufacturers, trucking industry representatives, regulatory officials, safety advocates, and others–inviting them to join us in a collaborative effort to bring about the best possible underride protection.
(Just a note: It doesn’t matter who is at fault in these kinds of crashes of a smaller vehicle into a larger truck; if the underride guards could prevent the smaller vehicle from riding under the truck, the tragedy of death and horrific injury could be avoided.)
“Ten automakers have committed to the government [NHTSA] and a private safety group [IIHS] that they will include automatic emergency braking in all new cars, a step transportation officials say could significantly reduce traffic deaths and injuries.”
But I am glad to see that those “watchdogs” plan on pursuing regulations for that technology. http://tinyurl.com/oc4cqy2
Michael R. Lemov in his book, Car Safety Wars, describes the impact of the passing of the Motor Vehicle Safety Act and the Highway Safety Act in 1966:
“Detroit had lost its bid to prevent federal regulation of the safety of motor vehicles and highways. The companies promised to ‘live with the bill.’ But the industry continued its efforts to weaken key safety standards under the new act. It had only temporarily lost its political clout. It raised objections to the first standards issued by NHTSA in 1968 and later, to most things the safety agency proposed. Manufacturers sent their chief executives to the White House and to President Nixon. They pressed Secretaries of Transportation. They lobbied administrators of NHTSA. They argued, often successfully, to the House and Senate Appropriations committees for restrictions on the safety agency’s funding. The car safety wars did not end.
The enactment of strong federal motor vehicle and highway safety laws marked the single biggest milestone in the century-long fight for safer cars and roads. But the long struggle against death and injury on the highways was really just beginning.” p. 106
It is important for verbal commitment to safety to be followed up with regulatory provisions to ensure that it, in fact, becomes a reality.
The Insurance Institute for Highway Safety has just released a report on recent crash testing for one trailer manufacturer’s improved design for their rear underride guard. Vanguard has now passed the 50% overlap test–with testing still needed for the more narrow overlap test at the edges of the trailer’s guard.
Additional companies have plans to get their guards tested in the future.
Our story is featured in this fall’s edition of the organization’s Status Report. We are thankful for their efforts to research and report on this vital truck safety issue. Their previous reports helped us to better understand the weakness of the current federal regulations for underride guards.
While they provided a good summary of the history of underride guard regulation, I would like to note that they apparently overlooked NHTSA’s mention of an underride guard petition from the Insurance Institute for Highway Safety (IIHS) in the Footnotes of the Federal Register announcement.
The thoughts below are also expressed in this YouTube video:
I find myself in the unenviable position of speaking up on behalf of all travelers on the road who are vulnerable and could—when they least expect it—become the next victim of an underride crash.
Jerry and I had the opportunity, on June 25, to tour the Research & Design Center of Great Dane, a trailer manufacturer. As their guests, we were able to spend the entire morning hearing about what they are doing with regard to quality control and safety, including underride guards which they voluntarily produce to meet or even exceed Canadian standards—thus surpassing current U.S. federal standards. We were able to ask questions and share our concerns about the inadequate federal standards for underride guards (otherwise known as rear impact guards).
We are perhaps better suited to ask those questions than just about anyone. After all, we had two daughters die because the car they were in rode under the back of a semitrailer.
It was an informative day. And we heard what seemed to be genuine comments that, “Cost is not a factor,” and, “Safety is important to us,” and, “We are not competitive about safety.” But what we did not see was a tangible plan to carry out their verbal commitment to create the best possible underride protection.
Now, it is understandable, amid the multitude of demands and the tyranny of the urgent, that—without a ready solution, in fact, one which would require time and money to develop—this problem has not been given much attention. But, if those who bear responsibility for making sure that this problem gets solved (one way or another) had lost two of their beloved children—or any other loved one—I can guarantee you that they would have moved heaven and earth to find a way to prevent underride.
What makes it even more distressing is that there are many individuals and organizations, who truly seem concerned about safety, including the National Highway Traffic Safety Administration (NHTSA), the Insurance Institute for Highway Safety (IIHS), and the trailer manufacturers. Yet, from what I can see, very little communication has taken place to move this problem forward from point A (guards that fail and result in death and/or horrific injuries) to Point B (coming up with a better design that will provide the best protection possible).
Great Dane, one of the major trailer manufacturers, observed that they passed all but one of the quasi-static crash tests—the narrow overlap. Great Dane also noted that their guard appeared to perform better on the full overlap test than Manac’s (which was the only company to pass all three tests in 2013). So Great Dane does not want to make a change which will strengthen one section of their guard but weaken another section. That’s understandable.
So, tell me: Why aren’t we getting anywhere? What will it take for an improved design to be researched and developed?
IIHS has done extensive quasi-static crash tests as well as analysis of Large Truck Crash information, and they are, in fact, champing at the bit—hoping to do further testing as improvements are made. Yet, we are told, Great Dane has not yet seen the details of their previous crash test results.
Great Dane, one of the major trailer manufacturers, tells us that safety is a priority to them. They even told us that they want to know how they can petition NHTSA to improve the underride guard standards. But the unfortunate reality is that there is not yet a new design; there is no improved guard. And Great Dane represents perhaps 12% of the market. What about the rest of the trailer manufacturers; when will they have a design which will produce safer guards?
On our trip home from Savannah to Rocky Mount, North Carolina, Jerry and I rehashed the morning’s events. We spent considerable time observing the many trailers which we saw on the road, and I took numerous photos of the various designs and conditions of the underride guards.
While at Great Dane, Jerry had made a few suggestions for improving the guard design. He suggested putting foam in the hollow horizontal bar. Another idea he put forth was to install panels with airbags to the existing guard—providing an additional barrier/energy absorption solution. Whether with these ideas or something else, surely, a more effective design can be created.
So, in trying to process what we learned at the meeting, I kept thinking over and over: Could an independent work group of qualified individuals, such as an engineering school, take on the challenge of creating such a design—which could then be tested by IHHS, proposed to NHTSA to aid in defining improved rear impact guard specifications, and provided to all trailer manufacturers? Could we do some kind of crowd funding or grant proposal to obtain the necessary funds to support such an endeavor? Could we perhaps even approach the Truck Trailer Manufacturers Association (TTMA) and ask them to seek contributions from their members for such a project?
Is cost truly not a factor? Is safety really a priority and not a competitive matter? Is it possible to improve the communication necessary to prevent more unnecessary deaths? Can we “sit down at the table together” and work this out?
Marianne Karth, June 26, 2014
(Note: I thought it was interesting that, in the photo above, a circle appeared around the very area of underride guard weakness about which we are concerned.)
See the testimony in May 2009 by the Insurance Institute for Highway Safety, in which they call for tougher underride guard standards and with an attachment of the history of federal rulemaking on underride guards (pasted below): http://tinyurl.com/phlaqon
The history of Federal rulemaking on truck underride guards:
1953 Interstate Commerce Commission adopts rule requiring rear underride guards on trucks and trailers but sets no strength requirements.
1967 National Highway Safety Bureau (NHSB), predecessor to the National Highway Traffic Safety Administration (NHTSA), indicates it will develop a standard for truck underride guards.
1969 NHSB indicates it will conduct research on heavy vehicle underride guard configurations to provide data for the preparation of a standard. In the same year the Federal Highway Administration publishes a proposal to require trailers and trucks to have strong rear-end structures extending to within 18 inches of the road surface.
1970 NHSB says it would be “impracticable” for manufacturers to engineer improved underride protectors into new vehicles before 1972. The agency considers an effective date of January 1, 1974 for requiring underride guards with energy-absorbing features as opposed to rigid barriers.
1971 National Transportation Safety Board (NTSB) recommends that NHTSA require energy-absorbing underride and override barriers on trucks, buses, and trailers. Later in the same year NHTSA abandons its underride rulemaking, saying it has “no control over the vehicles after they are sold” and “it can only be assumed that certain operators will remove the underride guard.” The Bureau of Motor Carrier Safety (BMCS), predecessor to the Federal Motor Carrier Safety Administration, considers a regulatory change that would prohibit alteration of manufacturer-installed equipment. This would nullify the major reason NHTSA cited for abandoning the proposed underride standard.
1972 NTSB urges NHTSA to renew the abandoned underride proposal.
1974 US Secretary of Transportation says deaths in cars that underride trucks would have to quadruple before underride protection would be considered cost beneficial.
1977 IIHS testifies before the Consumer Subcommittee of the US Senate Commerce Committee, noting that devices to stop underride have been technologically available for years. IIHS tests demonstrate that a crash at less than 30 mph of a subcompact car into a guard meeting current requirements results in severe underride. IIHS also demonstrates the feasibility of effective underride guards that do not add significant weight to trucks. IIHS petitions NHTSA to initiate rulemaking to establish a rear underride standard. The agency agrees to reassess the need for such a standard and later in the year announces plans to require more effective rear underride protection. BMCS publishes a new but weak proposal regarding underride protection.
1981 NHTSA issues a proposal to require upgraded underride protection.
1986 IIHS study reveals that rear guards designed to prevent cars from underriding trucks appear to be working well on British rigs.
1987 European underride standard is shown to reduce deaths caused by underride crashes.
1996 NHTSA finally issues a new standard, effective 1998.
It has recently come to our attention that our petition to the Department of Transportation regarding underride guards will not have been the first one to address this vital issue.
On February 28, 2011, the Insurance Institute for Highway Safety (IIHS)* sent a letter to David Strickland, the then-Administrator of the National Highway Traffic Safety Administration (NHTSA), titled “Petition for Rulemaking; 49 CFR Part 571 Federal Motor Vehicle Safety Standards; Rear Impact Guards; Rear Impact Protection.” (http://www.iihs.org/iihs/topics/t/large-trucks/reg-documents, #3 in 2011)
The IIHS letter concludes as follows, “In summary, IIHS provides analyses and test results showing that NHTSA could greatly reduce the likelihood of rear truck underride by reopening rulemaking on FMVSS 223 and 224 to:
1. Substantially increase the quasi-static force requirements, at least to levels that would guarantee all guards are as strong as the Wabash;
2. Move the P1 test location farther outboard to improve offset crash protection;
3. Require that attachment hardware remains intact throughout the tests;
4. Require guards be certified while attached to the trailers for which they are designed;
5. Investigate whether the maximum guard ground clearance can be reduced; and
6. Reduce the number of exempt truck and trailer types.
“IIHS urges NHTSA to begin such rulemaking as soon as possible to reduce the preventable injuries and deaths occurring when passenger vehicles strike the rears of large trucks at speeds the passenger vehicles are clearly designed to handle in the absence of underride.”
On April 3, 2014, the National Safety Transportation Board (NSTB) released a document which made Seven Safety Recommendations for Tractor-Trailers to NHTSA—including improvement of standards for rear underride guards. The document made mention of the 2011 petition from IIHS to NHTSA and commented that, “As of December 2013, NHTSA has not formally responded to IIHS’s petition, but the agency has sponsored additional research on rear underride.”
It is clearly past time for action to be taken on this important issue. How many more lives will be unnecessarily lost before those accountable for instigating change will act decisively and make it happen?
“The Insurance Institute for Highway Safety (IIHS) is an independent, nonprofit scientific and educational organization dedicated to reducing the losses — deaths, injuries and property damage — from crashes on the nation’s roads.
The Highway Loss Data Institute (HLDI) shares and supports this mission through scientific studies of insurance data representing the human and economic losses resulting from the ownership and operation of different types of vehicles and by publishing insurance loss results by vehicle make and model.
Both organizations are wholly supported by auto insurers and insurance associations.”
Marianne Karth 
IIHS
