Tag Archives: maintenance

FMCSA Proposed Rule For Inspection of Rear Underride Guards

December 29, 2020Safety Advocacy, Truck SafetyAppendix G, CVSA, enforcement, FMCSA, ICC Bar, inspection, maintenance, Mansfield Bar, rear impact guard, rear underride guard, RIG, underrideMarianne

A red letter day: The Federal Motor Carrier Safety Administration (FMCSA) at long last has proposed a rule to add rear underride guards to Appendix G. What does that mean? It means that rear underride guards will be required to be in good condition in order to pass an annual vehicle inspection. Once the rule is actually issued.

The Public can comment on this proposed rule through March 1, 2021, by going here.

This describes the current status of rear guard inspection requirements, according to FMCSA:

While the FMCSRs have required rear impact guards for more than 65 years, they are not included on the list of components in Appendix G that must be inspected during the annual CMV inspection. This means that a vehicle can pass an annual inspection with a missing or damaged rear impact guard. https://public-inspection.federalregister.gov/2020-27502.pdf

Imagine!

In response to petitions from the CVSA and Jerry and Marianne Karth (“the Karths”1 ); a recommendation included in GAO Report GAO-19-264, “Truck Underride Guards: Improved Data Collection, Inspections, and Research Needed;”2 and Congressional correspondence,3 this rulemaking proposes to amend the FMCSRs to include rear impact guards on the list of items that must be examined as part of the required annual inspection for each CMV.

I have not yet read the whole document, but I am getting ready to do so now in order to make an informed and practical comment. I will definitely recommend that damaged guards be replaced with ones which meet the Insurance Institute for Highway Safety (IIHS) TOUGHGuard level of strength to STOP deadly underride — not merely with an older model which has been proven to be too weak.

Over one hurdle. On to the next.

Proper Maintenance of Underride Guards Can Spell the Difference Between L-i-f-e & D-e-a-t-h

Unexpected adventure: mom rustles up a truck part to repair a damaged underride guard!

January 13, 2017Truck Safetymaintenance, side guardMarianne

When the used trailer got delivered to Aaron Kiefer for his crash test, he noticed that the rear underride guard was damaged. As soon as he told me that, and that after the test he might rent the trailer out to drivers, I said, “I don’t want that trailer out on the road unless the guard is repaired!” No way do I want to knowingly put someone at risk!

Of course, that meant that I was about to embark that morning on an unexpected adventure. . .

Never in a million years did I expect to be 61 years old and driving around Raleigh to a truck parts store where, for $125, I purchased a “bumper tube” — they didn’t know what I meant when I asked for a horizontal bar for a rear underride guard for a trailer. I guess, many in the industry (like the driving public) don’t realize that the “bumper” on the back of a semi-trailer isn’t just to protect the truck from bumping into loading docks.

No, that replacement tube/bar has a label which clearly says:

Failure to comply with Federal Motor Vehicle Safety Act Standards FMVSS 223/224 (US) or FMVSS 223 (Canada) could result in injury to occupants of another vehicle in the event of a rear end collision with the trailer which, if not avoided, could result in death or serious injury.

Yet, how many trailers are out on the road with rear underride guards in a state of disrepair — like this one was — and not adhering to the FMVSS requirement to keep the guard in a like-new condition so that it is not weakened and lead to an untimely death or life-altering injury?

Enforcement of Proper Maintenance of Truck Underride Guards.pdf

And, by the way, why on earth doesn’t the replacement bar come with the reflective tape on it which they are required by law to have on the guard (so that other vehicles have a better chance of noticing them)?

Here’s the damaged guard:

Here it is after Aaron replaced the horizontal bar with the new bumper tube which I picked up in my Yukon and delivered to where the crash test trailer is awaiting the installation of a side guard for its January 20, 2017, crash test:

As it is, the current federal rear underride guard federal standard only requires a weaker-than-technologically-possible protective device. Couldn’t the industry at least maintain the existing guards in the best possible condition?

And, if they would please — when they do repair their guards — take the time to add Aaron’s newly-developed rear attachment to the outer edges to make their existing guard as strong as possible, I would really appreciate it!

Partner With Us To Protect Vulnerable Victims of Underride Crashes Partner with us to bring about a crash test of Aaron Kiefer’s life-saving and innovative truck side/rear guard on January 20, 2017. We have thought of a way that you could participate in the production & testing of his latest professional-grade prototype.

Annual Motor Vehicle Inspection Form: Are underride guards adequately inspected?

May 29, 2016Safety Advocacy, Truck Safetyannual vehicle inspection, maintenance, preventive maintenance, underride guardsMarianne

While we were getting set up for a side guard crash test this morning, I was taking photos of the tractor-trailer that was part of the test. I noticed an Annual Motor Vehicle Inspection form on the trailer. I looked it over trying very hard to find a line item by which the inspector and truck owner/driver would be reminded to check the condition of the rear underride guard which is required by law to be installed and maintained.

I could not find anything listed about underride guards.

Actually, I had picked one of these forms up in a truck stop previously and couldn’t find anything related to inspection of underride guards in the past. Just thought I would check again.