On the way home from our recent side guard crash test in Raleigh, I saw a Carolina Trucking Academy tractor-trailer turn the corner — with side guards! The ones that Jerry helped install not too long ago. Such a good feeling.
And today, on my way home from getting groceries, I saw a tractor-trailer with a rear #underride guard which met the strength of an Insurance Institute for Highway Safety TOUGHGuard Award. I knew it for sure because it had a sticker saying so — like the one we saw on our recent trip North.
I hope that, someday soon, I won’t be so surprised to see these things because they will be commonplace and known for saving lives. I might not get so excited, but I’ll still be grateful.
Not only have we lost two daughters due to a weak rear underride guard, but we continue to see countless loved ones lost to other families in a similar way. Senseless deaths. Solutions are available — developed by innovative engineers but too often left on the shelf while people continue to die.
I get Google Alert notifications of truck crashes every day. Here are the rear underride fatalities which I have found in the last few months:
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.
It is to their credit that nine U.S. trailer manufacturers have improved their rear underride guard design to meet the IIHS TOUGHGuardstandard and seven of them are putting it on all new trailers as Standard. What that means is that they have surpassed the current federal standard and have been crash tested to show that they are more likely to prevent underride and catastrophic Passenger Compartment Intrusion (PCI) — thereby more likely to save lives when passenger vehicles rear end tractor-trailers.
See the difference between a too weak and a stronger guard:
Unfortunately, that does not help underride victims who crash into older models with too weak rear underride guards. Until the entire fleet has this stronger protection, people will continue to die from an engineering problem that has already been solved.
Note: When I called a local truck part company, the person with whom I talked knew nothing about improved rear guard retrofit parts. They were still selling the old model of generic horizontal bumper tubes. In other words, despite the availability of improved guards, many trucking companies are replacing damaged guards with the old model which can’t stop a car in an offset crash.
In 2016, Aaron’s team conducted a full overlap rear crash test at approximately 35 mph closure. This test, which was conducted on a reinforced trailer that had already suffered significant rear collision damage. The lightly reinforced rear guard wasn’t able to prevent underride. (TrailerGuards.com)
Aaron’s team has continued to develop trailer underride guards. Recently, they crashed a reinforced trailer with a 2012 Chevy Impala at 38 mph and approximately 25% overlap. This test illustrated that bolt on reinforcements can prevent deadly underride and passenger compartment intrusion (PCI).
Video of Crash Test into a 2005 Vanguard Trailer with a reinforced rear underride guard at 38 mph on January 25, 2020:
Compare that to a crash test by IIHS of a Vanguard 2013 trailer with a weak rear underride guard at 35 mph — at 8:28 on this video:
Crash car after the 38 mph collision into the rear of a tractor trailer: No Passenger Compartment Intrusion (PCI) Hallelujah!!!
Compare that to the initial design of the Rear Reinforcement Attachments on March 12, 2016:
Now that we have proof that these lightweight aluminum plates can prevent deadly underride, should we simply encourage voluntary adoption of this life-saving safety solution? Or should we require every truck in the U.S. to install safety equipment which can meet that level of performance?
In other words, are we going to make it the law to install equipment which can prevent underride when passenger vehicles collide with the rear of large trucks?
Crash testing is always unnerving: Will it work — successfully preventing underride and Passenger Compartment Intrusion (PCI)? Or will it fail — providing some useful information but sending the enthusiastic engineer back to the drawing board?
Either way, the adrenaline of anticipation followed by the jarring crash invariably leave me unsettled.
Aaron Kiefer readies his Rear Reinforcement Attachment, an aluminum device installed at the outer edges of a trailer’s rear underride guard to strengthen it — preventing underride to make truck crashes more survivable & save lives.
Making plans for an upcoming crash test in North Carolina. Stay tuned as we work hard to #STOPunderrides!
Why is this needed? See the difference between a weak and strong rear underride guard:
The current federal standard for rear impact guards has specifications for preventing underride at impact speeds of 30 mph (though not requiring a crash test).
The proposed standard in limbo at NHTSA now would upgrade it to 35 mph to meet the Canadian standard (although most manufacturers are already meeting the Canadian standard). However, the NPRM and the Canadian standard do not require that the guards stop a vehicle for the full width of the guard. That’s what the IIHS has proven with their crash testing program.
The IIHS has tested the new designs of the 8 major trailer manufacturers and given them each a TOUGHGuard Award for being able to pass a crash test at 35 mph across the full width of the back of the trailer.
These stronger guards are being sold on new trailers — some as a standard feature and some as an Option.
There are retrofit kits which can be installed on existing trailers to provide TOUGHGuard quality underride protection at the rear of trailers. There have been very few of these sold — a mere drop in the bucket compared to the 11 million+ trailers on the road which have the older, too weak rear guards.
Additionally, Sapa Extrusions (now Hydro), an aluminum extrusion company, has designed an aluminum rear underride guard which has been successfully tested at 40 mph. Since this is now known to be possible, why would we not mandate a standard which would require this amount of protection at minimum?
The STOP Underrides! Bill calls for research to be completed to ascertain the outer limits of underride protection — so we know what level of protection can reasonably be required.
The STOP Underrides! Bill also calls for establishment of a Committee On Underride Protection to facilitate collaborative and effective discussion among all stakeholders.
For several years before our underride crash, the IIHS had been doing crash testing into rear underride guards on trailers from eight major trailer manufacturers. Their research showed that even though these guards were designed to meet the current federal standard, they were too weak and failed to stop cars from going under upon collision.
We are grateful that seven of those manufacturers have designed improved rear guards as confirmed by crash testing at the IIHS Vehicle Research Center at 35 mph — receiving a TOUGHGUARD Award for their efforts. Here is an example of one of those seven:
While we are thankful, we know that the work isn’t over yet. Still needed:
The eighth manufacturer, Strick Trailers, will have their newly-designed rear underride guard tested on July 10.
Research is needed to demonstrate whether these improved guards are also successful at speeds higher than 35 mph. (We know that a guard developed by an aluminum extrusions company has been tested successfully at 40 mph and perhaps higher.)
Some manufacturers are selling these improved rear guards as Standard on all new trailers, while others are actually selling them as an Option (thus weak guards are still being sold and going on the road). Can you believe it?!
As the bill indicates, there are still millions of trucks on the road which will be hazardous to drive around until they are retrofitted with effective underride protection. For example, I bet that the trailer with which we collided is still on the road and likely still has a weak rear underride guard and so could kill someone else.
Stoughton’s improved rear guard was successfully crash tested at 35 mph at the first Underride Roundtable at the IIHS on May 5, 2016 (3 years after our crash). They were the fourth manufacturer to do so (preceded by Manac, Vanguard, and Wabash — and later followed by Great Dane, Utility, and Hyundai):
