Tag Archives: operational issues

Taking On a Safety Issue: Hazardous Railroad Crossings

I made a Public Comment at the meeting of the Motor Carrier Safety Advisory Committee (MCSAC) on June 6, 2023, related to railway crossing safety. I was motivated to do so by two things.

First of all, I have listened to members of the trucking industry point to the potential of side guards causing an increase in tractor-trailer hang ups on high centered railroad crossings — using it as a basis for opposing a side guard regulation. Yet, in ten years, I have never heard them discuss how they could address this safety problem, which occurs even without side guards.

Secondly, when I was around 26, I worked as a Hospice Pilot Program Analyst for Blue Cross & Blue Shield of Michigan. After some time on the job, one of my coworkers had a baby, who was the delight of her life.  After my family moved away from the Detroit area, we kept in contact mostly through exchanging Christmas cards. One year I received a note from our former boss, who told me that my friend’s now 16 year-old had died when the car in which she was a passenger was hit by a train on her way to her high school. I wrote about her story in a post, Too Often, Too Little, Too Late; A Conspiracy of Silence , in 2015:

Fast forward to 2013, when I, too, experienced the awful devastation of losing a child [make that two] to an unexpected, horrific, potentially-preventable, premature death due to a car crash [this time hit by a truck]. Now I understood what my friend had faced.

Just recently, I tried to reach out to her again–to no avail–after I ran across the news article and the picture of baby “Joy” when going through boxes at our home. I re-read the details of the crash and discovered that there had been no flashers or guard at the fateful railroad crossing–less than a mile from her high school.

As a bereaved-mom-become-safety-advocate, I wanted to know if something had been done to improve safety at the site of that crash 34 years ago. I was encouraged to find out, from the township responsible for that section of roads, that they had bypassed the option of flashers and guards and immediately closed off that particular dirt road where it crossed the tracks.

A good move. Chances are it saved someone. But it was Too Late for Joy.

Why does it Too Often take a death to wake us up to the dangers that were there all along?”

I did not hear from my friend for 40 years because her grief was so intense and it was hard for her to see me with my family of nine living children. In 2020, out of the blue, I received an email from her. Among other things, she shared with me what she and her husband and younger daughter had done following their tragic loss:

[We] took on the State of Michigan after the train crash that killed [Joy and her friend Hope].  After a public hearing, we convinced the state to close the railroad crossing near [the] High School where the crash occurred.  The crossing was at the bottom of a gravel hill and no warning lights or gates were at the site.  State inspectors would park at the top of the hill and walk down to “inspect” it, too concerned to drive down. The site could not be fixed to make it safe for others and the road leading to it is now closed.  No one else will die there.  During our investigation, we found that many other dangerous railroad sites like this exist.  I was too devastated to do anything about those sites in the way you have, and I admire your courage for that.

June 6, 2023

Administrator Hutcheson,

I hope that FMCSA will seriously consider our attached petition and do what is within your power to make railway crossings safer.

Respectfully,

Jerry & Marianne Karth

Here’s our petition to the Federal Motor Carrier Safety Administration: Petition to the FMCSA for Railway Crossing Safety Measures

Here’s our petition a few days earlier to the Federal Railroad Administration: Petition to the FRA for Railway Crossing Safety Measures

Relevant Resources On This Topic:

What can we learn about industry concerns regarding a potential side guard regulation?

Should we be concerned about side guards getting hung up on railroad tracks?

I keep hearing members of the trucking industry bring up the possibility of side guards on trailers getting hung-up on railroad tracks. They point to it as a reason to not require side guards on all new trucks. Is that a valid concern? And where is their documentation?

So, who could oppose the idea? The American Trucking Associations. Dan Horvath, vice president for safety policy, told me that the guards would be an expensive burden that would divert investment from better safety improvements and possibly cause trucks to get hung up at railroad crossings. Car Collisions With Big Rigs Don’t Have To Be So Deadly

When someone voices a concern, I immediately investigate the truth of the matter. On this issue, I received information, in 2019, from someone who had looked into this potential problem extensively. This is what he told me:

It may be a deeper dive into the weeds than you care to make, but attached is a compilation of all railroad grade crossing accidents compiled by the Federal Railroad Administration for the past 5 years.

2014-2018 RR Crossing Data (2)

. . . I see, in the last five years, for the population of trailers we currently have including the  lowboys, car haulers, cattle haulers, beverage trailers, etc there have been ZERO fatalities coded as truck-trailer stuck on track.  

Even if one were to assume a side guard at 18 inches high would create more hang-ups and accidents – and the standards on grade crossings say they won’t – it is just not a statistically frequent fatal or injurious event in comparison to side underrides. Maybe this is why the NTSB, the one responsible for investigating significant rail transport accidents, still recommended side guards for trailers.

Here is a federal database of railroad crossings. How could a trucking company and their drivers use this information to plan their route to avoid potentially hazardous hang-ups? Highway/Rail Crossing Database Files

This 2002 West Virginia University provides useful information for this discussion. Low-Clearance Vehicles at Rail-Highway Grade Crossings: An Overview of the Problem and Potential Solutions

“It is interesting to note that ground clearances as low as 2 in. were identified. Although not included in the data base, it was reported to the researchers that some low-boy trailers operate with as few as 3 in. of ground clearance for a 47-ft wheelbase.

. . . a truck with a wheelbase of 30 ft and 6 in. of ground clearance will still experience problems; however, the magnitude of the problem is not as severe”

Two things are interesting about that: (1) the CMVs with that very low ground clearance would not need a side guard and (2) side guards do not go so low as the vehicles mentioned, which are the ones with the severe hang-up problems.

More thoughts on that research: A 2002 Study by the West Virginia University showed that trailers and trucks must be much lower to the ground than an underride guard to hang up on regulation railroad crossings and driveway and dock slopes.  One need look no further than how low semi-tractors are to the ground, or low-boy trailers. or car hauling trailers, to dispel the notion an underride guard at 16 to 18 inches from the ground cannot operate safely over the road. Perry Ponder

Here are some suggestions for truck drivers:

P L A N N I N G A S A F E R O U T E When possible in planning your route, select a route that contains the fewest highway-rail grade crossings. When it is necessary to cross tracks, select the safest crossings—those that offer the best sight distance (no obstructions to your clear line of vision down the tracks). Select crossings that offer you enough containment or storage area for you to stop at a stop sign or stoplight directly across the tracks. Allow enough space for your truck to fit on the other side without overhang onto the tracks. Be especially careful at passive crossings (those without gates, flashing lights, bells). At these crossings it will be up to you to judge if a train is coming without the assistance of electronic equipment.

If your truck does gets stuck on a crossing, you need to take two actions: 1. Get out of your truck IMMEDIATELY. The quicker you act, the more likely you’ll be able to alert the railroad to avert a tragedy. 2. The Emergency Notification Sign you noted on your review of the crossing contains a phone number to the railroad. Call it. Explain your location, including the DOT number listed on the sign. If there is no sign, call the local authorities or 911. RailroadCrossingSafetyforCommercialMotorVehicles

And here’s some Low Ground Clearance Signage. Let’s not act like problems aren’t there to be solved! Engineers love to solve problems!

Oh, by the way, check out the feedback from four trucking companies who have pioneered the use of side guards on their trucks. Have they had problems getting hung-up on railroad tracks?

Transport Companies Provide Feedback on Side Guard Operational Issues

I asked these companies to let me know how they deal with the railroad crossing problem. Late last night, I received a reply:

“If you can cross a railroad with any modern aerodynamic truck with side fairings and rubber skirts, you can cross it with a truck with side underride protection! I never had a problem!
 
You plan your route with trucking GPS and drive with common sense, and there is no problem!
 
Car haulers are low and have railroad crossing problems; underride protection is not a problem! It does not reduce ground clearance more than frequently used spare tire carriers and toolboxes, pallet storage etc.
 
Livestock and moving company trailers, step deck trailers are way lower than underride protection.” Ferdinand Heres, Heres Transport
 

In the end: What is worse than Death By Underride?

UPDATE, May 21, 2021: Don’t blame side guards when trailers get hung up.

Tractor-trailer stuck on railroad tracks along Route 2

UPDATE, March 16, 2022: “They say that tractor-trailers should not cross there because they have the possibility of getting stuck.” In other words, in general, tractor-trailers should avoid such crossings. Don’t use this as an excuse to stand in the way of a side guard mandate. Side guards save lives.

Tractor-trailer stuck at railroad crossing in Dunbar

Transport Companies Provide Feedback on Side Guard Operational Issues

We know that the trucking industry has expressed concern about potential operational issues which could occur when side guards are installed on large trucks. In order to address those concerns, we asked several trucking companies to give us feedback about their experience after installing side guards on their tractor-trailers.

This is what they told us:

Letter from Glenn Berry, Thomas Transport

Letter from Ferdinand Heres, Heres Transport

Letter from Richard Camden, Prest XsPress

Audio interview of Chris Brock, leasing a fully guarded trailer

Operational Issues with AngelWing Side Guard

Members of the trucking industry have expressed concern about potential operational issues which might occur with long-term use of the AngelWing side guards. Last week, we received an email with feedback from Glen Berry, COO of Thomas Transport Delivery, Inc., a transport company which installed the AngelWing side guards, in August 2017, on one of their trailers which goes back and forth between Ohio and Texas every week.

Marianne/Andy,

As requested…We now have 305,000 miles of Angel Wing use. There has not been a single issue with the structural integrity of the trailer since its installation. My initial concerns, of the Angel Wing System making the trailer frame rails excessively rigid, have dissipated. Because of the bracing structures design characteristics being very stout, to serve their purpose of course, I was worried they may cause frame rail stress, resulting in cracks or other compromises. This has not been the case. Again, I have had zero issues. I am very happy to inform everyone involved…The Angel Wing Test has been an outstanding safety project to be a part of.

Thank you.

Glen Berry

Update on January 28, 2021: Here is an August 12, 2020 Public Comment to NHTSA related to operational & cost issues of underride protection.

Here’s another happy owner of an AngelWing side guard system:

Here’s a crash test of a car into the side of a flatbed trailer at 47.2 mph:

Regarding cost of production of AngelWing:  Not all 11 million trailers would require side or rear guards based on their height relative to the ground, and many trailers are wheels-back trailers (see page below).  And using a $2,900 price for a single aftermarket guard is clearly not where the price would end up.  If a 13,000 lb trailer sells for no more than $30k or $2.3/lb then a side guard is gonna end up an absolute max of $1,300, but likely way less due to its simplicity relative the rest of the trailer.  I have designs and costs estimates from trailer makers showing it would be far less. (Perry Ponder, email, 9/18/2019)

AngelWing installed on a flatbed trailer:

Strick Trailers was motivated briefly to design side guards for their trailers after the Maravilla verdict back in ’00.  Anyway this 700ish pound side guard was estimated to cost them $328 materials and labor to make at that time.  A straight inflation conversion takes that to $450 in 2019 dollars… (Perry Ponder, email, 9/18/2019)

Remember the UVW study about length of trailer, wheelbase length and the height of trailer’s lower edge.  It showed that a trailer would have to be much lower than the AW makes it to hang up on in-spec RR crossings and driveway transitions (see diagram below from that study).
But the RR crossing argument is another red herring.  Google “semi trailer hits overpass” and you’ll see more instances of the height of a trailer causing problems than low trailers at RR crossings…is anyone in the industry arguing for lowered trailer roofs?
(Perry Ponder, email, 10/16/18)

Backing a trailer with the SafetySkirt side guard across a raised median:

Update on January 28, 2021: August 12, 2020 Public Comment to NHTSA related to operational & cost issues of underride protection.

Pros & cons of Super Single Tires

Ignoring Underride Problem Discards Years of Automotive Crashworthiness Efforts

Jerry Karth poses these questions to the trucking industry and to Secretary of Transportation nominee, Pete Buttigieg:

  • Are you aware that AngelWing was successfully tested when a mid-size car was crashed into the side of a tractor trailer at both 35 and 40 MPH at the Insurance Institute for Highway Safety with no Passenger Compartment Intrusion?
  • Are you aware that DOT administrators were invited to view crash testing of side guards less than a mile from the D.C. DOT Offices on March 26, 2019? (at least one FMCSA official attended)
  • Are you aware that AngelWing has been in commercial use for over 8 years?
  • Are you aware that AngelWing has over 800,000 miles in commercial use on the U.S. highways?
  • Are you aware that AngelWing has been durability tested?
  • Are you aware that AngelWing has shown no operational issues (such as loading docks and railroad crossings)?
  • Are you aware that AngelWing has shown no stress or damage on the trailer frame?
  • Are you aware that AngelWing is being commercially used and one route is from Cleveland, Ohio to San Antonio, Texas round trip every week over 3,000 miles per week without any issues — since August 2017?
  • Are you aware that AngelWing and a side skirt increase MPG for a tractor trailer?