Tag Archives: single unit trucks

Additional Public Comments on Underride Protection for Single Unit Trucks

Truck Safety, , ,

Here is the complete list of comments:  http://www.regulations.gov/#!docketBrowser;rpp=25;po=0;dct=PS;D=NHTSA-2015-0070

Here are the most recent comments added to the ANPRM for Underride Protection of Single Unit Trucks after the Public Comment Period was extended for 30 days until November 5, 2015.

Not sure how this is going to prevent people from driving into the rear of a truck… Maybe more money should be spent on educating drivers when they get their…”
View Comment

Submitter Name: Anonymous
Posted: 10/08/2015
ID: NHTSA-2015-0070-0061
I am not apposed to putting on reflective tape on the side rails or boxes of straight trucks, but as for the rear guard what is going to be the rule for…”
View Comment

Submitter Name: Johnson, Paul
Posted: 10/08/2015
ID: NHTSA-2015-0070-0059
As a long-time transportation industry professional, it is my opinion that CMVs should not be exempt from “bumper height” or any other safety regulations. The…”
View Comment

Submitter Name: Gislason, John
Posted: 10/08/2015
ID: NHTSA-2015-0070-0060
Re: Conspicuity Rules. When the rules for class 8 vehicles were implemented, I operated a private fleet operating, primarily, east of the Mississippi river…”
View Comment

Submitter Name: Schafer, Robert
Posted: 10/08/2015
ID: NHTSA-2015-0070-0058
September 21, 2015 Docket Management Facility, M-30 U.S. Department of Transportation West Building Ground Floor, Room W12-140 1200 New Jersey Avenue SE…”
View Comment

Submitter Name: Kearney, Brendan
Posted: 09/28/2015
ID: NHTSA-2015-0070-0054

 

Rear Impact Guards for Single Unit Trucks: Public Comment Period Reopened for 30 days

Truck Safety, ,

NHTSA has re-opened the Public Comments period on the Advanced Notice of Proposed Rulemaking for Underride Protection on Single Unit Trucks. For 30 days until 11/5/2015.

So, if you have not yet made a Public Comment on this important issue, you now have an opportunity to do so.

https://www.federalregister.gov/articles/2015/10/06/2015-25377/federal-motor-vehicle-safety-standards-rear-impact-protection-lamps-reflective-devices-and

“This document reopens the comment period for a July 23, 2015 advance notice of proposed rulemaking (ANPRM) that NHTSA issued in response to a petition for rulemaking from Ms. Marianne Karth and the Truck Safety Coalition relating to rear impact (underride) guards. The original comment period closed September 21, 2015. The agency is reopening the comment period for 30 days.”

“Reopening of Comment Period

NHTSA is reopening the comment period for the ANPRM for 30 days. (2) NHTSA believes that a 30 day period is sufficient and balances the interests of encouraging public participation in the rulemaking process with the desire to not unnecessarily delay key decisions by NHTSA about the rulemaking and attainment of the potential societal benefits associated with a final rule.

Accordingly, the public comment closing dates for DOT Docket No. NHTSA-2015-0070 (RIN 2127-AL57) is reopened for 30 days as indicated in theDATESsection of this document. NHTSA notes that the 30 day period is in addition to the time that has passed since the original September 21 comment closing date until today. Thus, all in all, more than 30 days has been provided. It is further noted that the agency will consider late comments to the extent possible.

Authority

49 U.S.C. 322, 30111, 30115, 30117 and 30166; delegation of authority at 49 CFR 1.95.

Raymond R. Posten,
Associate Administrator for Rulemaking.
[FR Doc. 2015-25377 Filed 10-5-15; 8:45 am]
BILLING CODE 4910-59-P

Footnotes

(1) As noted in the ANPRM (80 FR at 43664), in the near future NHTSA will be issuing a notice of proposed rulemaking on improving the standards’ performance requirements for guards on all vehicles subject to the standards.”

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Comments on the Federal Register can be seen here: http://www.regulations.gov/#!docketDetail;dct=FR+PR+N+O+SR;rpp=10;po=0;D=NHTSA-2015-0070

You can also see the Public Comments on these posts: https://annaleahmary.com/tag/suts/

 

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

AnnaLeah and Mary, Truck Safety, , , , , , ,

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/

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

AnnaLeah and Mary, Truck Safety, , , , , ,

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.

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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/

Thoughts on making a Public Comment on rulemaking for Single Unit Truck underride protection (Ends September 21)

AnnaLeah and Mary, Truck Safety, , ,

DOT is studying whether or not they should require “single unit (or straight)” trucks to be safer, i.e., be built so that–when a vehicle rear-ends them–the smaller vehicle does not slide underneath the larger truck. And they are asking people to let them know what they think about this.

What might you say about the proposed rulemaking for underride protection on these trucks? (Examples of SUTs are dump trucks, garbage haulers, concrete mixers, tank trucks, trash trucks, and local delivery trucks.)

What I would suggest is that you point out the fact that people die every year when their vehicle hits the back of single unit trucks so that the truck actually enters the passenger vehicle in the area where people are sitting. And, if manufacturing companies were required to provide adequate underride protection on these trucks, many of those deaths could be prevented.

Sure, it will cost some money to provide that protection. And that cost will have to be passed on to someone–whether it be the manufacturing company, the company which purchases the truck, the consumer of the trucking industry services, etc. Are we willing to bear that cost as a society, or would we rather keep our costs as low as possible–at the price of human life?

Good news: The 11,000+ AnnaLeah & Mary for Truck Safety Petition signers have been added to the Public Comments for the ANPRM Underride Protection for Single Unit Trucks.

To see all of the signatures/comments from the Petition, go to this link:  http://www.regulations.gov/#!docketBrowser;rpp=25;po=0;D=NHTSA-2015-0070

At that site, click on Karth Family/Care 2 Petition. Then click on Supporting Documents. There is a PDF and an XLS spreadsheet. The PDF can be read better by magnifying the chart.

You are allowed to add your own comments to the ANPRM–even if you signed the Petition. You can do so by clicking the COMMENT NOW button on that website. Please take the time to express your thoughts on this vital issue.

I am grateful for the countless people across the earth who care about these life and death matters and are willing to stand up and ask for safer roads.
Please note: Public Comments Period ends September 21, 2015.
Rebekah photo of crash

Some Facts on Single Unit Truck Underride Crashes from the NTSB

Truck Safety, , ,

Here is some information on single unit trucks (SUTs) crash statistics from the National Transportation Board:

” Although single-unit trucks comprise three percent of registered motor vehicles and four percent of miles traveled, they are involved in nine percent of fatalities among passenger vehicle occupants in multivehicle crashes. Crashes involving single-unit trucks and passenger vehicles pose a hazard to passenger vehicle occupants due to differences in weight, bumper height, and vehicle stiffness. . .

“Many studies of truck safety have examined fatalities as the sole outcome of interest. Tractor-trailers result in a larger proportion of fatal injuries from large truck crashes, which is one reason why some truck safety regulations have been limited to tractor-trailers and trailers. However, this study shows that there are substantial societal impacts resulting from non-fatal injuries arising from single-unit truck crashes. Emergency department visits, inpatient hospitalizations,3 and hospital costs4 that result from the crashes provide measures of the adverse effect of non-fatal injuries on the public.

“This study also shows that federal and state databases frequently misclassify single-unit trucks and thus undercount the total number of fatalities resulting from single-unit truck crashes by approximately 20 percent.”

http://www.ntsb.gov/_layouts/ntsb.recsearch/Recommendation.aspx?Rec=H-13-013

underride guards trip to RDU 006

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

AnnaLeah and Mary, Truck Safety, , , , ,

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.

 

 

Truck Drivers: Please make sure your underride (rear impact) guards are in good shape!

AnnaLeah and Mary, Truck Safety, , ,

An underride guard–adequately designed, installed, and maintained–can mean the difference between life and death.

This JJ Keller Annual Vehicle Inspection Form does NOT list underride guards as an item for inspection. But, truck drivers, please make sure that your underride guard is in good condition!

annual vehicle inspection form

Rebekah photo of crash

Jerry and I recently went on a road trip and I could not resist photographing a few of the underride guards we saw en route!
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This single unit truck is not currently required by DOT to have an underride guard. But look at what it does have at the back: a piece of metal that is highly unlikely to prevent a car from riding under it upon impact.

We have petitioned Secretary Foxx to require this kind of truck to have a rear impact guard.
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