Tag Archives: NHTSA rulemaking

Public Comments Updated for Underride Guards on Single Unit Trucks

New comments were added yesterday to the Public Comments on the ANPRM for Underride Protection on Single Unit Trucks.

DOCUMENT ID:    NHTSA-2015-0070-0049 (http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0049)
DOCUMENT TYPE:  PUBLIC SUBMISSIONS
POSTED DATE:    09/28/2015
DOCUMENT TITLE: District Department of Transportation – Comments

DOCUMENT ID:    NHTSA-2015-0070-0050 (http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0050)
DOCUMENT TYPE:  PUBLIC SUBMISSIONS
POSTED DATE:    09/28/2015
DOCUMENT TITLE: New York City Department of Transportation – Comment

DOCUMENT ID:    NHTSA-2015-0070-0051 (http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0051)
DOCUMENT TYPE:  PUBLIC SUBMISSIONS
POSTED DATE:    09/28/2015
DOCUMENT TITLE: Anonymous

DOCUMENT ID:    NHTSA-2015-0070-0052 (http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0052)
DOCUMENT TYPE:  PUBLIC SUBMISSIONS
POSTED DATE:    09/28/2015
DOCUMENT TITLE: Tom Maguire – Comment

DOCUMENT ID:    NHTSA-2015-0070-0053 (http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0053)
DOCUMENT TYPE:  PUBLIC SUBMISSIONS
POSTED DATE:    09/28/2015
DOCUMENT TITLE: Kit Keller – Comment

DOCUMENT ID:    NHTSA-2015-0070-0054 (http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0054)
DOCUMENT TYPE:  PUBLIC SUBMISSIONS
POSTED DATE:    09/28/2015
DOCUMENT TITLE: Brendan Kearney – Comment

DOCUMENT ID:    NHTSA-2015-0070-0055 (http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0055)
DOCUMENT TYPE:  PUBLIC SUBMISSIONS
POSTED DATE:    09/28/2015
DOCUMENT TITLE: Seven Hills Engineering, LLC – Comment

DOCUMENT ID:    NHTSA-2015-0070-0056 (http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0056)
DOCUMENT TYPE:  PUBLIC SUBMISSIONS
POSTED DATE:    09/28/2015
DOCUMENT TITLE: National Propane Gas Association – Comment

Underride Guards for Single Unit Trucks: More Comments Posted on the Federal Register

The Public Comments period has closed for the Advanced Notice of Proposed Rulemaking for Underride Protection on Single Unit Trucks. But there were 21 last-minute comments which have now been added to the Federal Register today.

Read them here:  http://www.regulations.gov/#!docketDetail;dct=FR+PR+N+O+SR;rpp=10;po=0;D=NHTSA-2015-0070

Newly-listed commenters include:

  1. Seven Hills Engineering (Perry Ponder),  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0046
  2. Alliance of Automobile Manufacturers, (Scott Schmidt),  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0032
  3. Boston Public Health Commission BPHC (Lisa Conley),  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0048
  4. Medical Academic and Scientific Community Organization, Inc. MASCO Area Planning and Development (Paul Nelson),  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0043
  5. National Transportation Safety Board (Christopher Hart),  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0030
  6.  3M Traffic & Safety Security Division (Daniel Hickey),  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0022
  7. National Ready Mixed Concrete Association (NRMCA) ( ),  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0026
  8. International Brotherhood of Teamsters (Sam Loesche),  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0047
  9. ORAFOL Americas Inc. (Chris Gaudette),  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0033
  10. Avery Dennison (a leading designer and manufacturer of retroreflective safety materials), http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0037
  11. Transportation Safety Equipment Institute (Christopher Grigorian),  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0044
  12. Truck and Engine Manufacturers Association (EMA) (Timothy Blubaugh),  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0031
  13. General Motors, LLC (Brian Latouf, Director),  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0034
  14. Meehan Boyle Black & Bogdanow, PC,  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0041
  15. Texas Cotton Ginners’ Association (Kelley Green),  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0038
  16. Southeastern Cotton Ginners Association, Inc. (Dennis Findley),  http://www.regulations.gov/#!docketBrowser;rpp=25;po=25;dct=PS;D=NHTSA-2015-0070
  17. National Asphalt Pavement Association (Howard Marks),  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0036
  18. National Cotton Ginners’ Association (W. Harrison Ashley),  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0040
  19. City of Palo Alto-Planning & Community Environment (Joshuah Mello),  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0035
  20. National Waste & Recycling Association (John Haudenshield),  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0042
  21. Advocates for Highway & Auto Safety (Shaun Kildare),  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0039

Note: Previously-posted Public Comments on this issue can be accessed here:  https://annaleahmary.com/2015/09/truck-industry-engineers-safety-advocates-comment-on-truck-underride-protection-for-motorists-pedestrians-cyclists/

Underride Research Meme

Support Vital Underride Research

Donate online now through AnnaLeah & Mary for Truck Safety at:  https://www.fortrucksafety.com/

Truck industry, engineers & safety advocates comment on Truck Underride Protection for motorists, pedestrians & cyclists

The Public Comment Period is Closed now for the Advanced Notice of Proposed Rule Making for Underride Protection of Single Unit Trucks. I appreciate those who took the time to comment and I look forward to in-depth dialogue among these people and organizations at our Spring 2016 Underride Roundtable. You can find their published comments here:  http://www.regulations.gov/#!docketDetail;dct=FR+PR+N+O+SR;rpp=10;po=0;D=NHTSA-2015-0070

These include comments from:

With funds which we raise for underride research, we are hoping to cover the costs of the crash test for the innovative combined side & rear guard designed by this engineer, Aaron J. Kiefer MSME, PE . See his Comment:  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0013

And we have been in correspondence with these two engineers in Australia who have researched solutions to deadly underride for 30 years.  Transport and Road Safety (TARS) Research Centre . See their Comments:  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0021  & my posts on them:  https://annaleahmary.com/2015/09/australian-engineers-champion-the-cause-of-better-truck-underride-  protection/

Contrast their comments to the conclusion of the NTEA: “Based on the published data and expected benefits, there is no justification for requiring rear underride guards on single unit trucks.” Maybe they ought to watch this video from Australia.

Someone in Australia was asked this question: “So last year, 249 people died on our roads. What do you think would be a more acceptable number?”

See what he answered:

IIHS October 2014 Status Report CoverBefore & After Photos

Cover of IIHS Status Report on guards; photos of our car before/after

Support Underride Research to Prevent Unnecessary Deaths & Injuries.

Donate Nowhttps://www.fortrucksafety.com/

Request for Extension of Public Comment Period on Single Unit Truck Rulemaking Process

After hearing that several groups were hoping that they could have more time (beyond the current deadline of September 21) to prepare a Public Comment on the Advanced Notice of Proposed Rule Making (ANPRM) on Underride Protection of Single Unit Trucks, I contacted NHTSA and filed a request to extend the Public Comment period.

The agency replied that they are considering my request. It usually takes at least 10 calendar days for such a process. I hope that this helps with providing useful information but does not lead to unnecessary delay of the needed rulemaking.

Trip North May 2015 035

Photo by me of a Single Unit Truck I saw on the expressway a few months ago.

Note the wimpy rear underride guard.

Donate now & support Underride Research to Prevent Underride and Save Lives:  https://www.fortrucksafety.com/

Public Comment Period ends September 21 for ANPRM on underride protection for Single Unit Trucks (SUTS)

There have been some comments added to the Public Comments on the Federal Register for the Advanced Notice of Proposed Rule Making on rear underride protection for Single Unit Trucks (SUTS).

You can see the comments here:  http://www.regulations.gov/#!docketDetail;dct=FR+PR+N+O+SR;rpp=10;po=0;D=NHTSA-2015-0070

The Public Comment period is currently scheduled to end on September 21, 2015. We encourage you to add your comment to this process to indicate support for the inclusion of Single Unit Trucks in the requirements for underride protection.

Here are some suggestions on writing comments:  https://annaleahmary.com/2015/08/thoughts-on-making-a-public-comment-on-rulemaking-for-single-unit-truck-underride-protection-ends-september-21/

Also, please consider donating to our underride research effort.

Donate & Spread the Word using our new website for AnnaLeah & Mary for Truck Safety:  https://www.fortrucksafety.com/

Underride Research Meme

Congress, Please give NHTSA the authority & resources to do their job and keep us safe on the road!

I don’t know about you, but I am tired of the ongoing battle over highway safety. The opposition, as far as I can tell, to measures designed to protect travelers on the road demand more research. But are they listening to the research already being done?

One specific example is regarding longer trucks (Double 33s):

“The legislation would force states to allow “twin 33s” — trucks that pull two trailers, each 33 feet long. Only 11 states allow them now, and Pennsylvania is not among them. Double trailers here cannot be more than 28 feet, 6 inches, and single trailers can be no more than 53 feet long.

“Supporters say the change would eliminate 6 million trips each year, improve the environment and cut down on crashes. . .

“The former head of the National Highway Traffic Safety Administration likens the massive trucks to “trains on highways” that would damage roads and endanger motorists. Trucks weigh 20 to 30 times more than cars, and they take longer than cars to come to a stop, particularly on wet and slippery roads. A U.S. Department of Transportation study found that the twin 33s require 22 more feet for braking than the current trucks on the road. In 2013, 3,964 people died in crashes involving large trucks.

“Pennsylvania Sen. Bob Casey, a Democrat who is crusading against the change, says longer trucks would cause more than $2 billion in damage to the nation’s roads and bridges.” http://www.post-gazette.com/opinion/editorials/2015/07/26/Bigger-s-not-better-Longer-tractor-trailers-spell-trouble-on-the-road/stories/201507310057

NHTSA has had some weak areas, but then let’s do what we can to improve their ability to do what they were commissioned to do in 1966–not sabotage their efforts. In October 1966, Dr. William Haddon became the first administrator of the new federal safety agency.

“Haddon announced twenty-three proposed standards on November 29, 1966, at the Auto Industry Dinner held at the Detroit Automobile Show. . . Haddon began his speech by reminding the auto executives and others present of the ‘continuing national tragedy’ of nearly three times as many Americans dying ‘on our streets and highways,’ as have died in all America’s wars. ‘As civilized people,’ Haddon said, we can no longer tolerate these fatalities, ‘year after year, like a medieval plague beyond our power of influence.’ America must, he said, ‘manufacture safer automobiles.’

“The infant agency raced against the clock to issue new safety standards within about one year of its creation by early 1968. It was not an easy task. . . Haddon himself worked nights and weekends while building the structure of NHTSA and simultaneously writing the final safety standards. . .

“NHTSA’s twenty-three ‘final’ safety standards were drawn mostly from existing General Service Administration standards, from the Society of Automotive Engineers’ (SAE) voluntary ‘guides,’ and one–banning hubcaps that could become dangerous projectiles–based on a Swedish government standard. They were organized into three categories, paralleling Haddon’s original accident matrix: 100-level standards designed to prevent crashes from occurring; 200-level standards designed to reduce the likelihood of injury when crashes occurred; and 300-level standards designed to reduce the risk of injury after a crash occurred. They were issued on time.

“Once a federal standard was adopted it had real teeth. It became the law of the land and could not be ignored or offered only as an option by car makers selling motor vehicles in the United States. The scope of federal motor vehicle safety standards (FMVSS) started with the initial twenty-three, but it has expanded and now includes more than fifty major standards, covering passenger cars, pickup trucks, vans, SUVs, motorcycles, large trucks, buses, and school buses.

“The initial 1968 standards ranged from relatively modest changes such as uniform and visible labeling of dashboard controls, to ground-breaking rules, such as those requiring front seat shoulder harnesses and seat belts built to the GSA standard. There were standards that represented major improvements, such as common transmission shifting sequences (Park-Reverse-Neutral-Drive-Low), warning lights for braking system failures, improved exterior lighting, front seat head restraints, collapsible, energy-absorbing steering columns, and safer door latches.

“The first NHTSA standards were met with sharp criticism from automobile manufacturers. They derided them as ‘useless,’ ‘inadvisable,’ ‘illegal,’ and ‘impossible to meet.’. . .

“For the first time, the automobile industry was required to follow federal safety rules in the design of much of its cars. The standards established a base level of safety in automobiles sold to Americans. And they demonstrated that a federal agency could, if it was forceful enough, require automobile manufacturers to change their car designs to produce safer vehicles.” (Car Safety Wars; One Hundred Years of Technology, Politics, and Death, by Michael R. Lemov, pp. 115-116, 118)

Fortunately, these standards were made law and not voluntary standards,

“The House proposal gave the manufacturers the right to initially write voluntary standards before the federal government would have the chance and the heavy burden of showing that further action was necessary. Detroit should have grabbed the offer. Voluntary industry standards, in any industry, have the reputation of often being weak standards. They are enforceable only through publicity and public awareness, not by government action. The level of such voluntary standards, set by industry committees with limited public participation, can be that demanded by the weakest company, the one with the tightest profit margins. Voluntary standards are ‘consensus’ standards, based on agreement of all industry participants. In dealing with the lives and safety of so many people, safety standards, are, and were then, matters not of consensus but of public importance.” (Lemov, p. 94)

Just one example of this is the rear underride guard standard for tractor-trailers. The current standard is weak and ineffective and does not prevent many deadly underride crashes. The current rule was implemented in 1998 and, despite research to show that it needs to be strengthened, the industry has done little to voluntarily improve the situation. This is a matter of public importance and it is my sincere hope that industry and government can work together and not in opposition.

FMVSS No. 224: https://www.federalregister.gov/articles/2015/07/23/2015-17973/rear-impact-protection-lamps-reflective-devices-and-associated-equipment-single-unit-trucks

Let’s not cave in to industry pressure at the price of compromising the safety of all who travel on the road. Let’s give them the authority and resources to do the job they were given to do. That includes the Federal Motor Carrier Safety Administration (FMCSA) as well.

I, for one, am thankful and will do all I can to promote thorough research and informed decision-making. Saved lives are well worth the price.

Safety is not a priority 002

Public Comments are Now Requested by NHTSA on Rear Underride Protection for Single Unit Trucks

The Advanced Notice of Proposed Rule Making for rear impact guards and reflective tape on Single Unit (Straight) Trucks (SUTs) is now published in the Federal Register as of today, July 23, 2015.

Public Comments will be accepted on this issue for 60 days (until September 21, 2015).

Please take the time to let the National Highway Traffic Safety Administration (NHTSA) know what you think. To do so, go here:  http://www.regulations.gov/#!documentDetail;D=NHTSA_FRDOC_0001-1478

If you scroll down on that site, it gives very detailed information about what they are proposing and why and upon what they would like comments. In particular, there are instructions for commenting: IV. Request for Comment on Extension of FMVSS No. 224

“NHTSA requests comments that would help the agency assess and make judgments on the benefits, costs and other impacts of requiring SUTs to have underride guards. In providing a comment on a particular matter or in responding to a particular question, interested persons are asked to provide any relevant factual information to support their opinions, including, but not limited to, statistical and cost data and the source of such information. For easy reference, the questions below are numbered consecutively.”

In order to make your viewpoint known about these needed changes to help prevent underride crashes, unnecessary deaths & horrific injuries, please Click on COMMENT NOW! at that site.

We have many posts on this topic–providing you with plenty of opportunity to take a good, hard look at the facts of this matter: https://annaleahmary.com/underride-guards/ and https://annaleahmary.com/tag/underride-guards/.

Also, see this post for a description of SUTs: https://annaleahmary.com/2015/07/celebrating-progress-in-underride-guard-rulemaking-advance-notice-of-proposed-rulemaking-on-single-unit-trucks-suts/

Whether you are able to provide detailed feedback or simply voice your thoughts on the necessity of this proposed rulemaking, please join us in speaking out. Also, please multiply your efforts and share this post using the buttons at the bottom of the post.

This is the first step toward reaching the goal of making effective underride prevention a requirement for Single Unit Trucks. Thank you for helping us to move this along for the safety of us all and in memory of AnnaLeah & Mary Karth–and the countless others who have lost their lives in potentially unnecessary underride crashes.

AnnaLeah, Mary at MuskegonPerhaps you have seen this photo before. . . so let me explain that this was taken in 2010 at the Muskegon Luge in Muskegon, Michigan  Winter Sports Complex, where Olympic hopefuls practice. AnnaLeah & Mary had gone there with siblings off-season and, after “trying out” the luge, were pretending to be the victors–standing on the awards blocks and raising their hands in victory. Their genuine joy in life, and this reminder we have of it, makes me think that they would have celebrated with us every milestone in this battle for safer roads.

 

Celebrating Progress in Underride Guard Rulemaking: Advance Notice of Proposed Rulemaking on Single Unit Trucks (SUTs)

The current federal standards for truck and trailer crash protection do NOT currently include Single Unit Trucks (SUTs). These types of trucks are not required to have any rear underride guards. Yet, research has shown that there are many deaths due to smaller vehicles colliding with the rear end of SUTs.

Examples of SUTs are dump trucks, garbage haulers, concrete mixers, tank trucks, trash trucks, and local delivery trucks.

Today, NHTSA issued an advance notice of proposed rulemaking (ANPRM) for SUTs–the first step of a larger agency initiative to upgrade the standards for truck and trailer underride crash protection. This is very good news!

As soon as it gets published in the Federal Register, we will be asking people to put in their two cents worth online through a 60-day Public Comment Period.

http://www.nhtsa.gov/About+NHTSA/Press+Releases/2015/nhtsa-truck-underride-anprm-july2015

Straight Truck Advance Notice of Proposed Rulemaking nhtsa 3715[1]:

This announcement is about protecting more drivers and passengers,” said U.S. Transportation Secretary Anthony Foxx. “These vehicles are essential to transportation system, and we have a duty to the traveling public to take every opportunity to strengthen truck safety.”

 

This 79 page document spells out the details , ANPRM-underride-SUT-July2015 :

SUMMARY:

NHTSA is issuing this ANPRM following a July 10, 2014 grant of a petition for rulemaking from Ms. Marianne Karth and the Truck Safety Coalition (petitioners) regarding possible amendments to the Federal motor vehicle safety standards (FMVSSs) relating to rear impact (underride) guards. The petitioners request that NHTSA require underride guards on vehicles not currently required by the FMVSSs to have guards, notably, single unit trucks, and improve the standards’ requirements for all guards, including guards now required for heavy trailers and semitrailers.

Today’s ANPRM requests comment on NHTSA’s estimated cost and benefits of requirements for underride guards on single unit trucks, and for retroreflective material on the rear and sides of the vehicles to improve the conspicuity of the vehicles to other motorists. Separately, NHTSA plans to issue a notice of proposed rulemaking proposing to upgrade the requirements for all guards.

DATES: You should submit your comments early enough to ensure that the docket receives them not later than [INSERT DATE 60 DAYS AFTER DATE OF PUBLICATION IN THE FEDERAL REGISTER].

I have been told that it could take a few days, a week, or even longer to get published in the Federal Register. But when it does, we will most certainly inform you and ask you to make a public comment. Instructions will be provided.

Here is a photo of a Single Unit (or Straight) Truck which we saw on the road during one of our road trips recently. Note the rather wimpy (voluntary) underride guard.

Trip North May 2015 035Right now (without a requirement for SUT underride guards), whether they realize it or not, these trucks are “getting away with murder.”* We hope that this is the first step toward bringing that tragic and preventable situation to an end.

*”The killing of another person without justification or excuse, especially the crime of killing a person with malice aforethought or with recklessness manifesting extreme indifference to the value of human life.”(Is it “manifesting extreme indifference to the value of human life” to not do something which in fact could be done to prevent horrific injury or death?)

 http://www.thefreedictionary.com/Getting+Away+with+Murder

“To escape punishment for or detection of an egregiously blameworthy act. http://idioms.thefreedictionary.com/get+away+with+murder

We know all too well what an underride crash can result in:

IMG_4465

June 2013 article on straight trucks: http://www.truckinginfo.com/channel/safety-compliance/news/story/2013/06/ntsb-says-straight-truck-safety-not-receiving-enough-attention.aspx

 

Please note that this is only the beginning of a lengthy rule making process. But we are in this for the LONG HAUL and hope to see this advance in a timely manner to the end goal of safer trucks on the road. Here is a description of the regulatory process:

Regulatory Dashboard  http://www.reginfo.gov/public/jsp/Utilities/faq.jsp#dashboard

Q.    What is Reginfo.gov and the Regulatory dashboard and what information does it display?

A.     Reginfo.gov displays regulatory actions and information collections currently at OIRA for review. The Regulatory dashboard is a component of that site that provides an up-to-date and easy-to-read graphical representation of regulatory actions currently under review. The dashboard displays these regulatory actions by agency, length of review, economic significance, and stage of rulemaking.

Q.    What are the different types of significant regulatory actions currently displayed on the dashboard that undergo OIRA review?

A.    They are:

  • Notice  –  These are documents that announce new programs (such as grant programs) or agency policies.
  • Pre-rule (or advance notice of proposed rulemaking)  –  Agencies undertake this type of action to solicit public comment on whether or not, or how best, to initiate a rulemaking. Such actions occur prior to the proposed rule stage.
  • Proposed rule  –  This is the rulemaking stage in which an agency proposes to add to or change its existing regulations and solicits public comment on this proposal.
  • Final rule  –  This is the last step of the rulemaking process in which the agency responds to public comment on the proposed rule and makes appropriate revisions before publishing the final rule in the Federal Register to become effective.
  • Interim Final Rule  –  These interim rules are typically issued in conformity with statutory provisions allowing agencies to publish a final rule that becomes effective soon after publication, without going through the proposed rule stage. The “good cause” exception in the Administrative Procedure Act allows agencies to bypass public notice and comment on a rule when it would be impracticable, unnecessary, or contrary to the public interest. This process typically allows for public comment after the rule is published so that the agency still has an opportunity to consider public input and revise the rule accordingly.
  • Direct Final Rule  –  These rules are similar to interim final rules, except that there is no comment period after publication, on the ground that they are uncontroversial. Such rules are categorized simply as “final rules” for display purposes on the dashboard.

 

 

Clarifying the ATA Position on Underride Guards

Minolta DSC

After last week’s announcement by NHTSA of their initiation of the rulemaking process for underride guards, I have had four interviews. So far, I have seen two of the articles and both of them included a statement, obtained from the American Trucking Associations (ATA), which disturbed me when I read them. I posted about it and you can read my thoughts here:

 https://annaleahmary.com/2014/07/underride-guards-in-the-news/

Not wanting to misrepresent the trucking industry, yesterday, I decided to call the person who was quoted, Ted Scott, the Director of Engineering Services with ATA. I told him why I was calling, shared our story, and we spent some time discussing underride guards. I then asked if I could send him the article, in which he was quoted, as well as information about our website and links to underride guard information. In my email, I also asked him to write a few sentences to clarify his statement about underride guards.

In response, this morning I received this email from Ted Scott:

 Ted Scott, ATA, email July 2014

 Well, I was excited to have him get back to me on this matter and quickly let him know that I appreciated it:

 Ted Scott, ATA, email July 2014 My Reply

 

From what I have observed, too often, needed changes have been prevented or delayed by resistance or opposition–for whatever reason, whether it be misunderstanding, misinformation, or differing priorities. In my mind, that makes this promise of support and cooperation by the American Trucking Associations super significant!

 Minolta DSC

Yes!

(p.s. I hope that Mary would think that I am making good use of her joie de vivre!)

NHTSA Has Initiated a Rulemaking Process to Evaluate Options for Improving Underride Guards

AnnaLeah, Mary at Muskegon

At 1:01 p.m. today, Jerry and I received an email from David Friedman, Acting Administrator of the National Highway Traffic Safety Administration (NHTSA), as a follow up to our petition for improved underride guards.

David Friedman underride email

Here is ” the “unpublished” version that has been provided for public inspection at https://s3.amazonaws.com/public-inspection.federalregister.gov/2014-16018.pdf.”

Mary would have said, “Awesome!” And AnnaLeah would have found a suitable YouTube video to show her approval.

https://www.youtube.com/watch?v=IUZEtVbJT5c&feature=kp

https://www.youtube.com/watch?v=kbJcQYVtZMo

Picture 275

We are forever grateful to everyone who had any part in this victory.  May there be many more in the days ahead.

Jerry & Marianne