On January 18, 2024, engineers and underride experts gathered via Zoom to expand the Consensus Side Guard Standard, developed by TEAM Underride in 2020, to specifically address the protection of All Road Users — that is, not only the occupants of passenger vehicles but, also, pedestrians, bicyclists, motorcyclists and other Vulnerable Road Users. In 2022, the term, Lateral Protection Device PLUS or LPD+, was coined*, and now the goal was to create language for a performance standard which such a device should meet.
We had gotten a good start on this process in December 2023. We continued that invigorating discussion and wordsmithing, and this is what we came up with to define the requirements for a Lateral Protection Device PLUS, or side impact guard, on a Commercial Motor Vehicle:
A side impact guard shall be considered to meet the performance standard if it is able to:
prevent intrusion into the occupant survival space of a mid-size vehicle when the Commercial Motor Vehicle (CMV) is struck at any location along its side, at any angle, and at any closing speed up to and including 40 mph, and
prevent a Vulnerable Road User (VRU) from passing underneath the CMV in an interaction along its side.
It is our hope that this process will ultimately result in collaborative action among diverse stakeholders, including government and industry, to develop a voluntary consensus standard which can guide rulemaking and catalyze timely, widespread adoption of underride protection on the sides of large vehicles as envisioned by the Department of Transportation in 1969. For the saving of many lives.
* The term LPD+ was suggested by Garrett Mattos on December 2, 2022, during a Zoom discussion among underride experts and advocates collaborating together as TEAM Underride to advance the implementation of engineering devices to prevent Death By Underride for All Road Users.
When there is no strong physical barrier under a truck bed, Death By Underride becomes a known unreasonable risk. Fortunately, engineers have developed effective physical barriers or underride protection – although it is not required by law. With that in mind, a group of engineers carried out R&D crash testing on August 3 at the Raleigh Underride Crash Test Event.
Four side crash tests were conducted into semitrailers:
Ford Fiesta into an AngelWing side guard from a 45 degree angle (39 mph)
Chevy Malibu into an unguarded trailer from a 45 degree angle (38 mph)
Chevy Impala into a SafetySkirt side guard in the rear area behind forward positioned trailer axles from a 90 degree angle (36 mph)
Chevy Malibu into a SafetySkirt side guard from a 90 degree angle (43 mph)
Crashed trailers were each ballasted with approximately 28,000 pounds in water tanks. Video footage in this LinkedIn post by Forensic Rock, highlights two of the crash tests:
We love working with passionate people in the AR field. And Aaron Kiefer is one of those super-passionate people we absolutely love working with.
We were lucky enough to help him and his great #StopUnderrides group collect data for an awesome test series they were running in North Carolina. His goal was to demonstrate the collision mitigation of different trailer guards on side underride collisions with lower-profile sedans.
This compilation video compares an unguarded 53′ van trailer to Aaron’s SafetySkirt design. Two Chevrolet Malibu’s were used in this test series.
The speed at impact in the unguarded test was 37.5 mph; the speed at impact for Aaron’s SafetySkirt test was 43.4 mph.
We won’t spoil it for you, but Aaron certainly knows what he is doing.
Write your comment to let NHTSA know why you want them to proceed with a rule on side guards.
If you have specific information to answer NHTSA’s nine questions, you can include it in your comments and/or add attachments.
Please note the WARNING: Do not submit personally identifiable information through this form. Any personally identifiable information (e.g., name, address, phone number) included in the comment form or in an attachment may be publicly disclosed in a docket or on the Internet.
Use the drop down box to Select a Comment Category (Rule/Proposed Rule/Final Rule).
Provide your email address (won’t be published online) and indicate that you’re an Individual and NOT a Robot.
The majority of comments (over 1,000) posted from June 16 through June 23 were from individuals and organizations which support the requests in the Public Comment from the League of American Bicyclists – calling for pedestrians and bicyclists to be included in the data for side guard regulatory analysis.
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.
On April 17, 2020, over 40 people participated in a virtual meeting of a volunteer Underride Protection Committee’s “Side Guard Task Force.” This included two engineers from trailer manufacturers. As a follow-up, several subcommittees began to hold virtual meetings, including an Underride Engineering Subcommittee.
The engineering subcommittee met at least monthly and sometimes every other week from May through November. At the outset, the VP of Engineering of one of the trailer manufacturers provided valuable input. Subcommittee members also participated in a Virtual Briefing for Senate Commerce Committee transportation staffers on August 19, 2020.
The goal of the Underride Engineering Subcommittee was to create a Consensus Side Guard Standard which would provide additional insight for the development of a side guard regulation and industry standard. Lengthy conversation and exchange of information has led this group to submit the following recommendation:
A side underride guard shall be considered to meet the performance standard if it is able to provide vehicle crash compatibility with a midsize car, to prevent intrusion into the occupant survival space, when it is struck at any location, at any angle, and at any speed up to and including 40 mph.
The subcommittee members are in agreement as to the details shaping this long-overdue standard, which they anticipate will lead to the saving of countless lives in the days and years to come. The following group of individuals participated in the Underride Engineering Subcommittee and are willing to continue to provide input.
NOTE: It should be mentioned that this standard has, in fact, been evaluated through research conducted by the Insurance Institute for Highway Safety when they crashed a car at 40 m.p.h. into the side of a tractor-trailer equipped with AngelWings side guards on August 29, 2017, during the Second Underride Roundtable at their Ruckersville, Virginia, testing facility.
There was no underride, no Passenger Compartment Intrusion (PCI), and the crash dummy data showed that it was survivable. In other words, this standard is not pie-in-the-sky; it has been proven that the Consensus Side Guard Standard is attainable.
Crash test at 40 mph into AngelWings side guards, August 29, 2017, during the Second Underride Roundtable at the Insurance Institute for Highway Safety
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.
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?
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.
Prior to Our Crashon May 4, 2013, our family had become good friends with another family. Their youngest, a pre-schooler at the time, followed Mary (13) around and was sure that he was going to marry her. Last week, his mom shared this with me:
Marianne, a couple of days ago I took [her son, now 8] to WalMart. On the way out of the parking lot, he started YELLING, “Mom! Mom! Mrs. Karth got the law passed, Mrs. Karth got the law passed!!!”
Huh? What on earth was that boy talking about??? I turned around and there was a semi with the guards on the side! I had no idea he knew anything about what we’ve been talking about all these years! 🙂
I wish it were true. . .
Bless his heart!!!!!! 🙂 What he likely saw was a side skirt for fuel savings ($).
I look forward to that day when we can all drive down the road and rejoice at the safer trucks because, finally, saving lives will have become more important than saving $! I will sing & dance & thank the Lord for all that He has done.
I’m sure that Mary & AnnaLeah — were they here — would join me!
Successful side guard crash test at 33-34 mph — one year after we helped Aaron Kiefer with his first one. No Passenger Compartment Intrusion (PCI). If this had been a real-life crash, the people in the car would not have experienced deadly, severe underride of the side of the truck.
Lengthier video shows the construction of the side guard, as well as the prep work and aftermath clean-up by Aaron’s volunteer crew:
Thank you, Aaron, for your confidence that this is a solvable problem — and your commitment to follow this project through to its life-saving goal.
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?
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.
