Tag Archives: Toughguard

Critique of NHTSA-Contracted Elemance Rear Impact Guard Research

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Secretary Duffy,

The Department of Transportation (DOT) engaged Elemance LLC in 2022 to evaluate three current designs of rear impact guards. Unfortunately, Elemance conducted Finite Element analysis of two obsolete rear underride guards that were not current designs at the time of the contract. In fact, both of those designs had been proven a decade earlier to be crash-deficient. The two manufacturers — Great Dane and Wabash — have developed designs with safer, stronger rear-guard designs. Elemance compounded that error by employing an erroneous definition of Passenger Compartment Intrusion. Elemance’s research findings, Heavy-Truck Rear-Impact-Guard Finite Element Simulation and Analysis, are flawed and backwards-looking rather than helpful to the Department and Congress in evaluating current and future rear underride guard performance and regulatory standards.

Please find attached a detailed critique by engineers who are well-acquainted with the underride problem and solutions. This is what the engineers concluded about the NHTSA-contracted research:

In view of the defects in the Elemance report, a follow up study should be commissioned to evaluate examples of current state of the art rear impact guards that have been in service since 2016 and 2017 respectively. The study should utilize the correct definition of PCI and more accurately assess injury risk.

The Department should act promptly to address the flaws in this federal research in order to fulfill its mission to reduce roadway injuries and deaths.

Jerry and Marianne Karth

Note: This critique was submitted as a Public Comment on September 3, 2025, to the U.S. Department of Transportation in response to their Request for Comments on priorities for the 2026 Surface Transportation Reauthorization.

This video created by the Insurance Institute for Highway Safety twelve years ago explains their Rear Impact Guard crash testing research and how the federal standard is failing to protect road users:

This video is a compilation of IIHS Rear Impact Guard crash tests with old and new guard designs for many of the major trailer manufacturers:

This video demonstrates the night & day difference between old and new designs by one manufacturer:

Good News: Stoughton extends IIHS-award-winning underride protection to container shipping

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Good news on underride protection: IIHS has given the TOUGHGUARD Award for rear impact underride protection on intermodal chassis trailers to Stoughton Trailers — the first trailer manufacturer to earn it and one of the largest chassis manufacturers in North America. Should this lead to speculations about what engineering ingenuity could actually produce — despite industry grumblings about the operational issues regarding underride protection, particularly at the sides of intermodal chassis trailers?

Underride guards that meet the Toughguard criteria are substantially more likely to withstand an impact, reducing the severity of the crash. Until now, only dry van, refrigerated and flatbed trailers have qualified. But with the growing importance of shipping containers in global trade, more and more freight is being transported using intermodal chassis.

Chassis-type trailers present a unique challenge when it comes to underride protection. The frame of a dry van, refrigerated or flatbed trailer extends across its entire wheelbase, supporting the underride guard for its full width. In contrast, an intermodal chassis is a ladderlike structure that lies between the trailer’s wheels to support the removable container.

For that reason, the underride guard required a completely new design. Instead of a vertical support attached to the trailer deck, the chassis guard features long, diagonal supports running from the guard’s outboard ends to the chassis rails. Stoughton Intermodal Chassis Earns Underride Guard Award

I’m grateful for Stoughton Trailers’ continued commitment to safety. Unfortunately, not every trailer manufacturer is equally safety-minded. And NHTSA has not shown an inclination to send a strong message to industry; in fact, they declined to include Stoughton’s dry van RIG solution in their regulatory analysis for a 2022 update of the rear guard rule. Decades of government and industry inaction means that there are still far too many (almost ALL of them) trucks on the road which do not have adequate underride protection.

Engineers know how to creatively solve problems. Give them a green light to SAVE LIVES!

Retrofit Solutions for Rear Impact Guards to Prevent Deadly Underride

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It is to their credit that nine U.S. trailer manufacturers have improved their rear underride guard design to meet the IIHS TOUGHGuard standard 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:

Read more here: Recognizing good rear underride protection

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 (June 2, 2025): And the weak rear guard, as seen on the 2013 Utility trailer crash test above, is still allowed to be sold under NHTSA’s 2022 revised Rear Impact Guard rule. For more on this travesty, read here: New federal rule on truck underride protection does not go far enough.

Underride Crash Memorials (the tip of the iceberg)

Thankfully, there are retrofit solutions available. This is what I know:

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.

A fully-guarded trailer hits the road – ready to STOP underride!

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Engineering ingenuity and a lot of hard work went into the research, development, and installation of this fully-guarded trailer system. This week, a small carrier in North Carolina became part of our pilot program. We are thankful that they have agreed to provide us feedback on this #SaferTruck as they drive it on the road to carry out their transport business.

What does fully-guarded mean? It means that every part of the trailer — at the rear and both sides — is covered by equipment which has been installed to prevent a car (or pedestrian, biker, or motorcyclist) from going under the trailer in the event of a collision.

This “hybrid” safety system combines devices which have been crash tested to prevent a car from riding under, including an AngelWing metal side guard installed behind the landing gear, a SafetySkirt polyester webbing where the AngelWing ends and extending over the rear axle — fastening to the Rear Impact Guard (RIG) Retrofit attachment, which reinforces and strengthens the existing rear underride guard (otherwise known as a Rear Impact Guard or RIG, ICC Bumper, or Mansfield Bar).

Oh, and did I mention that this system includes a side skirt for fuel savings?

This retrofitted trailer proudly displays the #SaferTruckAward decals:

Underride Crash Victim Memorial Posts

Fully-guarded trailer
View from under the trailer of SafetySkirt attached to Rear Impact Guard Retrofit
RIG Retrofit plus SafetySkirt

AngelWing side guard in action:

Eighth Major Trailer Manufacturer To Have Improved Rear Underride Guard Crash Tested at IIHS on July 10

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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 Underride Guard Earns Kudos from Crash Survivor, Insurance Institute

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):

Stoughton® Trailers New Rear Underride Guard Lauded Important for Safety

“Great Dane receives TOUGHGUARD award for under-ride safety guards”

Truck Safety,

Great Dane is one of the 5 trailer manufacturers which has voluntarily upgraded its rear underride guard: Great Dane receives TOUGHGUARD award for under-ride safety guards

The new guard is designed to help stop vehicles from sliding beneath a trailer in a rear-impact crash, and that can help prevent injuries, he said.

To ensure a higher level of safety for all Great Dane reefers, dry vans and platform trailers, Great Dane will include the new rear impact guard as standard equipment on all of its trailer models beginning later this year.

In addition, because of the new rear impact guard’s bolt-on design, Great Dane will offer a retrofit option to upgraded rear impact guards on 2007 and later models. The retrofit can be installed easily at any authorized Great Dane service center.

This is important because:

Here’s hoping that research will continue until we have discovered the outer limits of truck underride protection.

Great Dane Trailer Crash Test at IIHS; Receives Toughguard Award For Improved Rear Underride Guard

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I have seen quite a few underride guard crash tests in the last two years. It’s not something I ever planned to do and it is never easy.  Some of them ended in severe underride and it always shakes me up at how quickly life can change forever. In a matter of seconds.

The crash test I viewed at IIHS on January 19, 2017, was particularly hard to watch. It was a test of Great Dane’s newly designed rear underride guard. A Great Dane trailer was what our Crown Vic collided with on May 4, 2013 — with tragic results.

Demonstration of Improvement in Rear Underride Guard; Great Dane Trailers Crash Test at IIHS, January 19, 2017:

They have proven that creative minds can come up with better underride protection. The cars are damaged from the crash, but underride and Passenger Compartment Intrusion (PCI) are prevented. Lives are preserved.

Here is a Youtube video, posted by Cars-Trucks TV, which demonstrates the effectiveness of the improved rear underride guards designed by five of the major trailer manufacturers — Great Dane, Manac, Stoughton, Vanguard, and Wabash — from 2013 to 2017. They received a Toughguard award from IIHS — as announced on March 1, 2017.

Last year, about this time, I posted this: March Historically a Momentous Month for Truck Underride Safety Advocacy; Beware the Ides of March!

Here is an excerpt:  It is my fervent hope that, when March 2017 rolls around, we will be celebrating a vastly improved federal standard–enthusiastically and immediately adopted by the trucking industry–for all-around-the-truck underride protection at higher speeds, including now-exempt single unit trucks as well as retrofitted to existing trucks and trailers.

If this seems like a costly venture, try comparing it to the price paid by thousands upon thousands of individuals and families during the past decades of ineffective underride protection–added to the countless precious people who will be saved in the years to come from tragic, preventable death by underride.

We aren’t finished yet, but we have come a long ways!

Crash Test Videos of Semi Trailers Earning New IIHS Toughguard Award

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Here is a Youtube video, posted by Cars-Trucks TV, which demonstrates the effectiveness of the improved rear underride guards designed by five of the major trailer manufacturers — Great Dane, Manac, Stoughton, Vanguard, and Wabash — from 2013 to 2017. They received a Toughguard award from IIHS.
 

They have proven that creative minds can come up with better underride protection. The cars are damaged from the crash, but underride is prevented and lives are preserved.

 

Stoughton Offers Retrofit Kit For New Rear Impact Guard

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I just received an email from Stoughton Trailers’ Product Brand Manager.  She has begun advertising their new rear impact guard Retrofit Kit (at about $500-$600) and is already getting inquiries.

http://www.stoughtontrailers.com/parts-sales/news/id/64/retrofit-rear-underride-guard

Think of the lives which could be saved by this! It has brought tears to my eyes.

IIHS Presents Toughguard Award to 5 Trailer Manufacturers For Voluntary Upgrade of Rear Underride Guard

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On March 1, 2017, IIHS announced a new award, Toughguard, given to trailer manufacturers which have passed the IIHS rear underride guard crash testing:

Five North American semitrailer manufacturers earn the Insurance Institute for Highway Safety’s new TOUGHGUARD award recognizing rear underride guards that are designed to prevent a range of deadly underride crashes. Semitrailers from Great Dane LLC, Manac Inc., Stoughton Trailers LLC, Vanguard National Trailer Corp. and Wabash National Corp. earn the accolade. IIHS recognizes semitrailers with good underride guards

Other articles covering this story:

  1. Trucks.com article: Insurance Institute Launches New Safety Ranking of Truck Trailers
  2. Today’s Trucking article on the Stoughton Press Conference: Activist applauds Stoughton for tougher guards
  3. Trucknews.com: Stoughton improves rear impact guard
  4. Fleetowner.com: New refrigerated model on the way from Stoughton Trailers
  5. Truckinginfo.com: Stoughton Underride Guard Earns Kudos from Crash Survivor, Insurance Institute

Thank you, IIHS for your commitment to this crash testing project, which has highlighted the continuing underride problem and guided the way to a solution. Thank you, as well, to the trailer manufacturers who have voluntarily improved the rear underride protection on the trailers which they produce and sell (and/or lease).