Tag Archives: side guards

Underride Retrofit; or, What is an acceptable number of underride deaths?

Safety Advocacy, Truck Safety, , , , , , , , ,

If there are people dying from an automotive defect, would we want those cars to be fixed or left as is? If there are people dying from a dangerous truck design, would we want those trucks to be fixed or left as is — knowing that if we leave the millions of trucks on the roads as is, we are sentencing countless people to death by underride?

Is there any precedent for issuing a recall on unsafe trucks, in other words, doing a retrofit of safety equipment on an existing truck? I’m glad you asked. Yes, there is.

The first one I’ll mention is conspicuity or reflective tape. NHTSA issued a mandate for retro reflective tape to be installed on trucks and trailers to increase their visibility to nearby motorists. FMCSA issued a mandate for retrofitting of existing trucks and trailers with this safety countermeasure.

These requirements were set up by the FMCSA to help improve visibility in low light conditions and help reduce potentially fatal motor vehicle crashes into the sides or back of stopped or parked trucks and tractor trailers at night or in poor visibility.

On December 10, 1992, the National Highway Traffic Safety Administration or NHTSA published a final rule requiring that trailers manufactured on or after December 1, 1993, which have an overall width of 80 inches or more and a gross vehicle weight rating (GVWR) of more than 10,000 pounds, (with the exception of pole trailers and trailers designed exclusively for living or office use) be equipped on the sides and rear with a means for making them more visible on the road. The NHTSA ruling allows trailer manufacturers to install either red and white retro reflective tape or sheeting or reflex reflectors. This tape is commonly referred to as DOT C2 reflective tape and is thus marked for easy identification. https://ifloortape.com/requirements-for-conspicuity-dot-c2-reflective-tape-for-trucks-tractor-trailers-to-meet-federal-dot-fmcsa-nhtsa-regulations/

RETROFIT requirement for retro reflective tape on tractor trailers: Under federal requirements, trailers and semi-trailers manufactured prior to December 1, 1993 must be retrofitted with retroreflective tape or an array of reflex reflectors. The final date for compliance is June 1, 2001. . . Trailers built after the 1993 date are delivered from the factory with reflective tape and do not need to be retrofitted. Bulk Transporter, March 22, 2001, Deadline Approaches for Reflective Tape Retrofit

Another example of a retrofit involving tractor trailers, or in this case a recall, is the Strick Trailers recall of faulty rear impact guards in 2016:

Strick Trailers is recalling certain single-axle 28-foot van trailers for a rear-impact guard issue, according to a National Highway Traffic Safety Administration document. More specifically, 2005-2009 van trailers manufactured July 25, 2004, to Feb. 3, 2009, and equipped with rear-impact guards using gussets 55997 and 55998 are affected. Gussets on affected trailers can increase the chances of injury during a crash, thereby violating Federal Motor Vehicle Safety Standard No. 223, “Rear Impact Guards.” Owners will be notified by Strick to have reinforcements installed to the rear-impact guards at no cost. For more information, contact Strick’s customer service at 260-692-6121. The recall was set to begin on June 17.

Side by side with the notice of the Strick recall in the Landline Magazine in May 2016 was another notice announcing that the FMCSA had issued a safety advisory for one manufacturer’s tankers due to “inadequate accident damage protection:”

Affected TYTAL tankers are unauthorized, according to the FMCSA, until repairs and testing have been completed. Effective June 1, enforcement and fines will be given to owners and drivers operating any of the above tankers that have not made necessary repairs. TYTAL has notified known customers, and repairs have begun free of charge.

It seems to me that these examples demonstrate the existence of a precedent for recalls and retrofitting rules to correct dangerous designs in Commercial Motor Vehicles which could, if uncorrected, result in death and/or injury in the event of a crash.

Clearly, a truck that does not have effective and comprehensive underride protection is a safety concern. After all, the warning label which is found on the horizontal bar of a rear underride guard specifically says so:

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.

Who will pay for the cost of the retrofitting? The ATA made the assertion, in their Letter of Opposition, that if Congress mandated the STOP Underrides Act — which includes a retrofitting requirement — then the trucking industry would be put out of business and the U.S. economy would be adversely affected:

Equipping the estimated 12 million trailers with a side underride guard, identified in Mr. Young’s testimony as costing approximately $2,900 including shipping, would equate to approximately $34.8 billion spent on underride guards. That staggering figure would result in what is likely the largest unfunded mandate on a private sector industry in U.S. history. Furthermore, when combined with the expected cost of labor in installing these guards, would exceed the industry’s annual net revenue, essentially putting trucking out of business, and grinding our economy to a screeching halt.

ATA Stop Underrides Act Follow Up Opposition Letter 6.19.19

RESPONSE to ATA Stop Underrides Opposition Letter

On what basis (what facts and formula) do they make such an exaggerated claim? The fact is that mass production will bring the costs down from the current price of retrofit kits (now at very low voluntary production). Furthermore, the industry should be well aware that adjustments can be made to spread the cost over multiple parties and multiple years.

Take as an example the increased manufacturing costs of trailers due to the tarriff on aluminum and steel and the ability of the manufacturers to share those costs with their customers.

Besides which, there are numerous other reasons to expect that this mandate provides many benefits to the trucking industry and the U.S. economy, including protecting the livelihood of truck drivers. Side guards will add additional fuel savings to that provided by side skirts. Production and installation of this technology will create jobs. Liability risk will go down. IRS Section 179 allows for tax deduction for equipment.

In the end, if we do not retrofit, there will continue to be many underride deaths for years to come. We then have to face the question, What is the acceptable number of underride deaths? And, who should decide that question? Congress, the ball is in your court.


Underride Legislation Discussed at T&I Hearing on The State of Trucking In America

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At last, truck underride was brought to the table at the June 12, 2019, Transportation & Infrastructure Hearing entitled, Under Pressure: The State of Trucking in America.

Congresswoman Eleanor Holmes Norton, Chair of the Highways & Transit Subcommittee, mentioned underride in her opening remarks (at 6:59 in this video):

Truck safety advocate, Andy Young, also talked about underride in both his written and verbal testimony to the Subcommittee members.

In this video excerpt, Chris Spear (ATA) makes a statement (at 1:09.48) in the hearing about his understanding that side guards have only been tested at 35 mph (not true):

Andy Young corrects that information (at 3:22.15 in the hearing video) and mentions that the AngelWing side guards have been successfully tested at the Second Underride Roundtable on August 29, 2017, at the Insurance Institute for Highway Safety (IIHS) at 40 mph:

The AngelWing side guards have also been successfully tested elsewhere at 47.2 mph:

Congressman Steve Cohen, who led the way in the House when he re-introduced the STOP Underrides Act on March 5, 2019, also spoke about underride:


The truth about truck underride should speak for itself. For too many decades, the facts have been hidden; motorists and vulnerable road users have not been adequately protected from becoming underride victims.

Enough is enough! Congress, the ball is in your court. It’s time to act.


NTSB Published a Preliminary Report on the March 2019 Tesla Side Underride Fatal Crash

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The National Transportation Safety Board, on May 16, 2019, released a Preliminary Report on the March 1, 2019, Tesla side underride fatal crash. Read it here: Highway Preliminary Report: HWY19FH008

In summary, the report says:

The National Transportation Safety Board (NTSB) continues to gather information on the operation of the Tesla’s ADAS and the Tesla driver’s actions leading up to the crash. The investigation will also examine the driver of the combination vehicle, the motor carrier, highway factors, and survival factors. All aspects of the crash remain under investigation as the NTSB determines the probable cause, with the intent of issuing safety recommendations to prevent similar crashes. The NTSB is working in partnership with the Palm Beach County Sheriff’s Office during the investigation.

Previous posts on this website related to Tesla side underride crashes:

D.C. Side Underride Crash Tests, March 26, 2019 — with and without side guards:

More D.C. crash test videos can be seen here.

The STOP Underrides! Act mandates comprehensive underride protection on all large trucks. This will make truck crashes more survivable.

As a mom of two daughters, AnnaLeah (17) and Mary (13), who died from a truck underride crash in Georgia on May 4, 2013,  I know the life & death difference that strong underride guards can make (but only if they are installed on the millions of trucks on our roads) — as demonstrated by these crash test videos: The difference a well-designed rear underride guard can make and Benefits of side underride guards for semitrailers and Truck Front Underrun Protection System Crash.

People have died from truck underride for decades and will continue to do so if we do not take decisive action to make trucks safer to be around.

Government Accountability Office (GAO) Truck Underride Report Published After a Year-Long Investigation

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After the STOP Underrides Bill was first introduced on December 12, 2017, several members of Congress –Senators Thune, Rubio, Burr, and Gillibrand — requested that the Government Accountability Office prepare a report on truck underride guards. That report was published today and can be found here.

The online report is organized into sections, including Fast Facts, Highlights, and Recommendations. The GAO Recommendations are:

  1. Recommendation: The Administrator of the National Highway Traffic Safety Administration should recommend to the expert panel of the Model Minimum Uniform Crash Criteria to update the Criteria to provide a standardized definition of underride crashes and to include underride as a recommended data field.
  2. Recommendation: The Administrator of the National Highway Traffic Safety Administration should provide information to state and local police departments on how to identify and record underride crashes.
  3. Recommendation: The Administrator of the Federal Motor Carrier Safety Administration should revise Appendix G of the agency’s regulations to require that rear guards are inspected during commercial vehicle annual inspections.
  4. Recommendation: The Administrator of the National Highway Traffic Safety Administration should conduct additional research on side underride guards to better understand the overall effectiveness and cost associated with these guards and, if warranted, develop standards for their implementation.

Here is a 46-page pdf of the Full Report.

I’m curious what Members of Congress along with the Department of Transportation and the trucking industry were anticipating to come out of the report. What did they expect to be uncovered that we have not already been talking and writing about and demonstrating for all to see at the D.C. Underride Crash Test on March 26, 2019 — not to mention, more importantly, with the lost lives of countless underride victims?

In a nutshell, the GAO team told the National Highway Safety Administration (NHTSA) that  Improved Data Collection, Inspections, and Research were needed. In fact, we already knew that, in order to get an accurate count of underride deaths (and injuries), better collection was needed. We have been talking about the need for rear underride guards to be added to the Vehicle Inspection Checklist.  And the STOP Underrides Bill calls for research to find the outer limits of underride protection.

But what the STOP Underrides Bill does not do is say to wait until better data collection has been collected before issuing a mandate to install proven underride protection. That would be like saying: Wait for 14 more years of underride deaths until you have improved collection of how many people are dying and then start using equipment (that was already available) so you know how many people you could have kept alive!

The GAO Report recommends that NHTSA take steps to add underride to the Model Minimum Uniform Crash Criteria (MMUCC) — a guideline to states to use for their crash report forms. However, the next version will not be issued until 2022.

If NHTSA uses this recommendation to justify holding off on underride rulemaking, then they will set us all up for a continuation of same old, same old. NHTSA might sooner or later (in 2022 when the updated MMUCC comes out) START urging states to improve their underride data collection. But then how many years of improved data will they insist that they need before they can proceed with rulemaking (which itself takes 3 or more years before it gets to the implementation phase)?
 
This is what I foresee, if NHTSA is left to their own devices (unless something else intervenes):
2022     New MMUCC
2024     States are ready for better underride data collection
2028     FARS underride data has maybe improved
2029     NHTSA issues an ANPRM to test the waters
2030     NHTSA issues a NPRM side underride rulemaking (what about the rest?)
2033     Implementation of side guard rule begins for new trucks

2043    The whole fleet will have them on (maybe).

Conservative estimate of 300 underride deaths/year x 14 years (2033) = 4,200 more needless deaths (plus catastrophic injuries) if Congress does not mandate that the Department of Transportation move forward with comprehensive underride rulemaking immediately.

What GAO recommends to NHTSA are good actions, but they fall short of an acknowledgement that people have, are, and will continue to die from truck underride unless we act decisively as a nation to mandate that the industry install equipment to prevent it.

The GAO report acknowledges that the trucking industry is waiting for a mandate before it will act. The report also illustrates how NHTSA has been less than diligent to address the underride problem. So, why would we expect that a mere recommendation to NHTSA (when they have received multiple underride safety recommendations from NTSB and multiple petitions from IIHS and others over the years) would cause them to act in a timely and effective manner to fulfill their safety mission and protect the people of this country from deadly underride?

The fourth GAO recommendation is this: The Administrator of the National Highway Traffic Safety Administration should conduct additional research on side underride guards to better understand the overall effectiveness and cost associated with these guards and, if warranted, develop standards for their implementation.

What more would NHTSA need to know — than what they already know, along with what would come about through the process of issuing a Notice of Proposed Rulemaking, and what they would learn through working with knowledgeable members of the Committee On Underride Protection (or COUP, as mandated in the STOP Underrides Bill), who could help them identify and understand the effectiveness and costs of underride protection?

It seems clear to me that even the under-reported 219 underride deaths, on average each year documented by NHTSA in the FARS data, do indeed warrant the development of standards for implementation of comprehensive underride protection. The side guard crash testing by IIHS and others have proven that this technology is effective at preventing underride. Therefore, I would interpret the fourth GAO recommendation as supporting the need for Congress to mandate that DOT proceed with the rulemaking outlined in the STOP Underrides! Bill. DOT has demonstrated that they have no intention of issuing rulemaking without a mandate which would force them to do so.

In my mind, the GAO Truck Underride Guards Report only confirms and strengthens my opinion that it is high time for Congress to pass the STOP Underrides Bill and get NHTSA and FMCSA started on a rulemaking process for comprehensive underride protection, which we petitioned them to do on May 5, 2014.  After years of inaction on that petition, on April 4, 2018, we submitted another petition (for supplemental comprehensive underride rulemaking) to Secretary Chao — still with no tangible action taken.

Congress, the ball is in your court.

If you want to go beyond a cursory understanding of the GAO Truck Underride Report, please read this lengthy analysis of the GAO Underride Report: Karth Cliff Notes on the GAO Truck Underride Report.

Video of the Underride Panel Discussion at the D.C. Underride Crash Test Event, March 26, 2019

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Safety engineers and professionals share their knowledge and thoughts in a Panel Discussion on the underride issue at the D.C. Underride Crash Test Event on March 26, 2019:

  • David Friedman, Consumer Reports, VP, Advocacy, formerly the CR Director of Cars and Product Policy and Analysis, former NHTSA Acting Administrator
  • Malcolm Deighton, engineer with Hydro, which supplies aluminum for manufacturing underride protective devices and trailer parts and which produces comprehensive underride protection technology in Europe
  • Glen Berry, Safety Director for Thomas Transport Delivery, AngelWing installed since 2017, truck driver
  • Perry Ponder, inventor of AngelWing, engineer with an accident reconstruction engineering company
  • David Dorrity, worked for Stevens Transport for years and testifies all over the country on safe trucking practices.
  • Aaron Kiefer, forensic engineer & crash reconstructionist, inventor of SafetySkirt

Moderated by Andy Young, truck litigation attorney and CDL holder.

The discussion can be viewed in four consecutive videos below.

Part 1:

Part 2:

Part 3:

Part 4:

Thank you, Perry, David, Malcolm, Aaron, Glen, David, and Andy, for taking the time to share your knowledge and thoughts on the underride problem and solutions to this deadly but preventable traffic tragedy.

Note: Video of the crash tests are available here.

Media Reports & Video Footage Unveil Highlights of the Successful D.C. Underride Crash Test Event

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If you were not able to witness the Underride Crash Tests in D.C. in person on March 26, then the next best thing is to see the media coverage of this important event and to view the video footage of all three tests of a car colliding at approximately 30 mph with the side of a tractor-trailer:

  1. The first crash test was into a trailer with an AngelWing side guard — SUCCESSFUL because it prevented underride and Passenger Compartment Intrusion (PCI).
  2. The second crash test was into a trailer with a SafetySkirt side guard — SUCCESSFUL because it prevented underride and Passenger Compartment Intrusion (PCI).
  3. The third crash test was into a trailer with NO side guard (as is the situation with 99.9% of the trucks on the road today) — SUCCESSFUL in that the devastating underride which occurred clearly showed what it is that the other two tests so importantly prevented.

VIDEO FOOTAGE from MGA Research of all three crash tests can be seen here:

First test into AngelWing:

Second test into SafetySkirt:

Third test with NO side underride protection:

Compilation of all three crash tests, including aerial views & views from inside the car:

Here is some of the media coverage of the D.C. Underride Crash Test Event:

MGA Research brought their high speed cameras to capture this video footage. Links to additional video will be shared when their creative team completes their work. WUSA9 had a GoPro camera inside the crash car.

Video of the Underride Panel discussion at the event can be viewed here.

  • David Friedman, Consumer Reports, VP, Advocacy, formerly the CR Director of Cars and Product Policy and Analysis, former NHTSA Acting Administrator
  • Malcolm Deighton, engineer with Hydro, which supplies aluminum for manufacturing underride protective devices and trailer parts and which produces comprehensive underride protection technology in Europe
  • Glen Berry, Safety Director for Thomas Transport Delivery, AngelWing installed since 2017, truck driver
  • Perry Ponder, inventor of AngelWing, engineer with an accident reconstruction engineering company
  • David Dorrity, worked for Stevens Transport for years and testifies all over the country on safe trucking practices.
  • Aaron Kiefer, forensic engineer & crash reconstructionist, inventor of SafetySkirt

Unsung hero of the event: Last year, on May 15, 2018 (what would have been the day my daughter AnnaLeah turned 24), after a hard day of hitting our heads against the wall in trying to convince legislative staffers to move the STOP Underrides! Act forward, I texted my son and said, “How are we going to get them to move?!” He texted back, “Hold a crash test at a field hearing.” I said, “What?!” It was a brilliant idea to let the leaders of this country, who can take action to end these preventable tragedies, witness crash testing in person!

Well, we couldn’t bring about a Field Hearing, but we quickly began the overwhelming process of organizing an Underride Crash Test Event right there in D.C.  — less than 2 miles from The Hill and 1 mile from the Department of Transportation.

Lois Durso and I, along with our families, friends and other underride victim families, want to thank the multitude of individuals, organizations, and companies (both named & unnamed) who have helped us as we work to pass the STOP Underrides! Act (S.665 & HR.1511) and bring about this amazing and totally volunteer-organized event:

Contributors to the STOP Underrides Initiative

Contributors to STOP Underrides! & DC Underride Crash Test

And I want to especially thank the skilled and dedicated Team Underride Crash Test Crew:

We also want to thank Akridge and ImPark for allowing us to use their D.C. parking lot (not an easy thing to find!), Northern Neck Auto Parts for providing the crash cars, and Sunbelt Rentals for providing safety barriers and equipment helpful in moving around the many vehicles to make the three crash tests go smoothly in such a short space of time. MGA Research captured amazing video footage, Mister Video ran the sound system, Andy Young served seamlessly as MC,  and Aaron Kiefer masterfully orchestrated the crash test crew in order to help us all see the clear-cut life & death difference which underride protection can make.

AngelWing crash car: 

SafetySkirt crash car: 

Unguarded crash car: 

We hope that this event will continue to raise awareness and that our message to Congress will grow stronger as people sign & share this petition: Congress, Act Now To End Deadly Truck Underride!

This event was brought about in memory of countless underride victims and in hopes of helping countless others walk away from truck crashes and live to tell about it. . .

@NTSB & @NHTSAgov didn’t call for side guards after 2016 Tesla underride fatality; will they after a 2nd?

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NHTSA investigated the May 2016 side underride crash of Joshua Brown’s Tesla. Here is the report which they published in January 2018.

Special Crash Investigations:
On-Site Automated Driver Assistance
System Crash Investigation of the
2015 Tesla Model S 70D 812481

Read this description of the injuries which the driver suffered as a result of Passenger Compartment Intrusion (PCI) from truck underride:

The front plane of the Tesla underrode the mid-aspect of the semi-trailer in the intersection, and the first crash event occurred as the base of the windshield and both A-pillars of the Tesla impacted and engaged the sill/frame of the semi-trailer’s right plane/undercarriage. Directions of force were in the 12 o’clock sector for the Tesla and the 3 o’clock sector for the UTI semitrailer. The Tesla maintained its momentum and completely underrode the semi-trailer, which sheared the entire greenhouse and roof structure from the Tesla.

During the underride impact, the driver’s face and head contacted multiple intruding components. These contacts produced fatal injuries to the driver. Intruding components and the semi-trailer also contacted and deformed both front row seatbacks and all of the Tesla’s structural pillars. The sheared roof and tailgate/hatch of the Tesla were captured by the right plane of the semi-trailer as the vehicle continued beneath it, and became deposited in the roadway at the location of the impact.

Please explain to me why NHTSA did not suggest that side guards might have changed the outcome of the crash and, furthermore, took no action to initiate rulemaking to mandate side underride protection.

NTSB also investigated the May 2016 Tesla crash and made no side guard recommendations.

Another Tesla Side Underride Tragedy Points to Need for Truck Side Guard Mandate

Congress, Act Now To End Deadly Truck Underride!

Another Tesla Side Underride Tragedy Points to Need for Truck Side Guard Mandate

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Late yesterday afternoon, I heard the news that another man has lost his life when his Tesla went under the side of a tractor trailer in Florida. No matter how it actually came about, doesn’t it seem tragic that we didn’t learn our lesson from Joshua Brown’s tragic death going under the side of a tractor trailer in a Tesla in May 2016?

Earlier today, a Tesla Model 3 owner died in a tragic accident with a semi truck. The Model 3 went under the truck’s trailer resulting “in the roof being sheared off as it passed underneath,” which is known as a “side underride” accident. Tesla Model 3 driver again dies in crash with trailer, Autopilot not yet ruled out

NTSB is sending a team to investigate this crash

Earlier this week, I wrote about the disturbing documentation that current Automatic Emergency Braking (AEB) technology on passenger vehicles is not reliably detecting large trucks: “AEB that reliably detects trucks could prevent underride crashes.” Meanwhile, what should we do? Yet, many of the voices opposing the STOP Underrides! Bill point to Collision Avoidance technology as the better route to prevent underride crashes.

Clearly, collision avoidance technology is not ready to prevent truck underride tragedies at this point in time. In contrast, comprehensive underride protection technology is ready to go — awaiting a mandate to get the ball rolling to save lives.

Here are two practical, viable solutions offered by engineers to prevent the gruesome, deadly passenger compartment intrusion (PCI) which occurs with side underride:

Download this video file to view a recent crash test by Aaron Kiefer into the side of a trailer equipped with the latest version of his SafetySkirt: Video Feb 24, 2 24 45 PM

AngelWing side guard successfully tested at the IIHS at 35 and 40 mph in 2017:

We cannot wait for the trucking industry to handle it themselves and the automotive industry is not prepared to prevent collision with large vehicles. Congress should feel proud to be the ones to make sure that this happens. Unless they want people to die!

STOP Underrides! Petition

D. C. Underride Crash Test, March 26, 2019

From the May 2016, Joshua Brown Tesla side underride crash: Witnesses reveal new details behind deadly Tesla accident in Florida

The police report indicated that Brown’s Model S collided with a tractor trailer that was perpendicular to it and continued to travel underneath it after having its windshield and roof sheared off. Because the vehicle was in Autopilot at the time, the vehicle continued to travel before veering off the road, careening through two fences, and finally coming to a rest after striking a utility pole approximately 100 feet south of the road.

Tesla released a statement on their blog:

“What we know is that the vehicle was on a divided highway with Autopilot engaged when a tractor trailer drove across the highway perpendicular to the Model S. Neither Autopilot nor the driver noticed the white side of the tractor trailer against a brightly lit sky, so the brake was not applied. The high ride height of the trailer combined with its positioning across the road and the extremely rare circumstances of the impact caused the Model S to pass under the trailer, with the bottom of the trailer impacting the windshield of the Model S.”

By the way, these are not “extremely rare circumstances.” Hundreds of vehicles collide with the sides of large trucks every year. Furthermore, both of these crashes clearly involved side underride. Why is this not being acknowledged and addressed?

“AEB that reliably detects trucks could prevent underride crashes.” Meanwhile, what should we do?

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Automatic emergency braking (AEB) on passenger vehicles is a good thing. It’s purpose is to reduce the chance of a rear-end collision or decrease the severity of the impact if it does occur. But does it function as intended when the vehicle in front of a car is a large truck?

A recent report from the Insurance Institute for Highway Safety (IIHS) implies that it does not reliably do so:

When it comes to preventing typical front-to-rear crashes, automatic emergency braking is a proven winner. Extending its functionality to address less-common types of rear-end crashes involving turning, changing lanes or striking heavy trucks or motorcycles, for instance, would help maximize autobrake’s benefits, a new IIHS study indicates. . .

Autobrake systems that reliably detect large trucks could prevent underride crashes. Twelve percent of U.S. passenger vehicle occupant deaths in 2017 were in crashes with large trucks, and 1 in 5 of these deaths occurred when a passenger vehicle struck the rear of a large truck.

Autobrake is good, but it could be better, IIHS, Status Report, Vol. 54, No. 2, February 21, 2019

If I am interpreting this correctly, this means that, currently, AEB on many vehicles do not reliably detect large trucks in order to prevent underride crashes. This is no surprise as there is almost 4 feet from the bottom of most trucks to the ground; the sensors are apparently not located in such a way as to be able to detect the truck body. No threat is recognized.

Therefore, it appears to me that we cannot rely on the current collision avoidance technology to prevent rear-end collisions of cars into trucks. If we want to more reliably prevent deadly underride and gruesome passenger compartment intrusion, why then would we not install effective comprehensive underride protection on all large trucks?

See what happens when collision does occur into the rear of a truck which is and is not equipped with an effective rear underride guard:

By the way, the same is, of course, true for the sides of large trucks where there is nothing but open space — nothing for the car’s sensors to detect. What will we do about that?

Download this video file to view a recent crash test by Aaron Kiefer into the side of a trailer equipped with the latest version of his SafetySkirt: Video Feb 24, 2 24 45 PM

AngelWing Crash Test at IIHS, March 30, 2017

How Imp’t Is It To Know Exactly How Many People Die From Underride Before Taking Action To Prevent It?

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We know from experience and reading studies that truck underride is vastly undercounted. But how important is it to know precisely how many people are impacted by this before taking decisive action to end these preventable tragedies?

Because of the requirement to do cost/benefit analysis when doing federal rulemaking, some people refuse to budge until they get more information than we have already provided. Isn’t the spilled blood we are already aware of enough? Especially coupled with the convincing crash testing which proves that the outcome of collisions could be completely changed!

Here’s another study on estimating side underride fatalities:  Estimating Side Underride Fatalities Using Field Data. I was a little hesitant to post it but asked the opinion of Matt Brumbelow, Senior Research Engineer at the IIHS. He says,

While I do have a few concerns with the methodology, the results actually support the conclusion that side underride guards would be greatly beneficial.  Specifically, she found that FARS underestimates the occurrence of side underride: over half (52%) of the cases coded as “no underride” actually did have side underride.  When you include the crashes that are coded as underride in FARS, they find that 61% of all side impact crashes with a tractor-trailer resulted in underride with PCI.  In other words, around 180 fatalities per year (61% of 300) could potentially be prevented with sufficient side underride protection.

While this 61% figure is still smaller than estimates we’ve made, I don’t see how it could lead anyone to think that the benefit of side guards would be small.

For goodness sake, what are we waiting for?!

Every Month Passing of the STOP Underrides! Bill Is Delayed Means More Unnecessary, Preventable Deaths