Tag Archives: straight trucks

Will DOT Respond to Petition for Underride Rulemaking on Single Unit Trucks?

Safety Advocacy, Truck Safety, , , , ,

Dear Secretary Buttigieg,

We are petitioning the U.S. Department of Transportation to take specific immediate action towards the goal of ending traffic deaths by including Single Unit Trucks (SUTS) and vulnerable road users in the scope of mandated and studied comprehensive underride protection, as called for in the STOP Underrides Bill. SUTs outnumber tractor-trailers and, in fact, comprehensive underride protection on them has already been recommended by the NTSB and the IIHS. Yet SUTs are not included in the Underride Sections of the recently passed Senate and House Infrastructure legislation.

Therefore, we are asking that you expedite work on the 2014 Karth Family petition for underride protection on Single Unit Trucks by taking the following actions:

  • Establish the Advisory Committee On Underride Protection, as called for in the STOP Underrides Bill and the Infrastructure Legislation in both the House and Senate.
  • Proceed immediately to issue a Notice of Proposed Rulemaking (NPRM) for comprehensive underride protection on Single Unit Trucks – front, side, and rear.
  • Add language explicitly stating that all mandated and studied comprehensive underride guards are to protect all road users, including Vulnerable Road Users (pedestrians, cyclists, & motorcyclists).

Respectfully submitted,

Marianne & Jerry Karth
AnnaLeah & Mary for Truck Safety

Petition for Underride Rulemaking on Single Unit Trucks (sign here)

If people die from riding under Single Unit Trucks, why aren’t they required to have underride protection?

Truck Safety, , , ,

Today I saw another example of why I think that this planet needs comprehensive underride protection on trucks — including on Single Unit Trucks (SUTs), otherwise known as straight trucks, box trucks, work trucks.

Currently, those kinds of trucks are not required to have underride protection. Some of them have voluntarily added some kind of wimpy thing that tries to pass as a rear underride guard. But looking at this one, I wonder whether they even understand the purpose of an underride guard.

If people die from riding under Single Unit Trucks, why aren’t they required to have underride protection?

Why COMPREHENSIVE Underride Protection Legislation?

Why put rear underride protection on trailers but not Single Unit Trucks? Any underride is deadly.

Truck Safety, , ,

I ran across a study on underride fatality crashes this morning. I’d read it before but took a lot at it again. +

Then, this afternoon, while in city traffic, I saw an almost-side underride-crash between a car and Single Unit Truck (SUT). And when I arrived at a parking lot later, I saw a wimpy rear underride guard on a SUT.

So, why do we put rear underride guards on trailers but don’t require them on SUTs? (Not even mentioning that the current rear guard requirement is ineffective as written.) And why don’t we require side underride guards on any large trucks?

Truck underride is deadly no matter the truck size or portion of the truck the smaller vehicle rides under.

Trip North May 2015 033underride guards trip to RDU 007

SUT Underride guard Great Dane trip 061

+ For SUTs, the study showed that, “Considering all degrees of underride, trucks with a guard suffered slightly more underride than trucks with no rear-end protection, 69.5% to 66.7%. . . This result is counter to what would be expected, although it may be due to small, sample sizes and a host of other complicating factors. The severity threshold of the TIFA file may serve to decrease variation in the amount of underride by rear-end structure, since a fatality must occur for the crash to be included in the file. It could be that many of the collisions are beyond the design limits of the guards, and so the guards have no effect.” Underride in rear-end fatal truck crashes, Submitted to National Highway Traffic Safety Administration, prepared by Daniel Blower Kenneth L. Campbell, The University of Michigan Transportation Research Institute, October 1999

In other words, the wimpy guards aren’t effective anyway, so even if a SUT has one, the guard usually doesn’t do what it’s supposed to do — which is to prevent deadly underride.

Current rulemaking on underride protection for SUTs is in limbo at NHTSA: ANPRM Underride Protection of Single Unit Trucks

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.