Recent months have brought progress in the right direction to solve the truck underride problem. A PBS/Frontline documentary focused on underride will be aired on Tuesday, June 13, 10/9 Central. See the trailer here, America’s Dangerous Trucks. Spread the word! Breakout stories and articles:
We are launching a new online petition to take advantage of the national attention this broadcast will bring to the hidden problem of underride. Please sign & share:Secretary Pete, It’s Past Time To End Death By Underride! These signatures & comments will be submitted to NHTSA.
In April, the National Highway Traffic Safety Administration (NHTSA) announced members of the Advisory Committee on Underride Protection. The first ACUP meeting was on May 25. This diverse group, with both industry and safety advocates represented, will be making recommendations to Secretary Pete/NHTSA about how to end Death By Underride.
At the same time, NHTSA published an Advance Notice of Proposed Rulemaking (ANPRM) for a potential side guard regulation. Add your voice to our message. Submit a Public Comment (by July 20) here in support of requiring side guards on all new trucks. Help us to bring this long-overdue rule across the finish line.
On a Friday afternoon — February 26, 2021 — over 50 people met via Zoom to discuss comprehensive underride protection. The purpose of the meeting was to report on progress which has been made by several subcommittees since an earlier meeting in 2020 — including Industry Engagement, Research, and Engineering Subcommittees.
The goal of the Underride Engineering Subcommittee — to which trailer manufacturers were invited — was to create a Consensus Side Guard Standard which would provide additional insight for the development of a side guard regulation. 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 Task Force went so far as to suggest that the Truck Trailers Manufacturers Association (TTMA) discuss the Consensus Side Guard Standard at their upcoming annual meeting in San Antonio, April 7-10, 2021. We encouraged them to come together in a Joint Agreement to adopt or improve the Consensus Side Guard Standard, as an association, and fast track the manufacturing of side guards by their 80th Anniversary in 2022.
Accept the standard; build a guard.
Sean O’Malley, Senior Test Coordinator at the Insurance Institute for Highway Safety (IIHS), gave a presentation at the Side Guard Task Force. He stated that, “Everything we do here, we do to save lives. I wasn’t kidding when I said the rear underride program (ToughGuard) is what I’m most proud of. ” Trailer manufacturers responded to the IIHS creation of a safety marketplace for improved rear underride guards by working to meet the TOUGHGuardAward level of protection at the rear of tractor-trailers. Why then would they not do the same to meet the Consensus Side Guard Standard of protection at the sides of tractor-trailers — particularly since the IIHS supports it with their 40 m.p.h. test?
Underride is underride no matter with what part of the truck you collide — because the bottom of large trucks sit up higher from the ground than the bumpers of passenger vehicles. All the way around.
So now what do we do? Will we wait another 100 years? How many more lives will be sacrificed?
Trucking companies could demand trailers with side underride guards. Trailer manufacturers could supply trailers with side underride guards. Or the government could mandate side underride guards — ideally with the support of industry because a government law or regulation will place all manufacturers on a level playing field.
Families of underride victims and engineers appealed to trailer manufacturers to take the bull by the horn, embrace the Consensus Side Guard Standard, and move forward with developing and installing side underride guards ahead of government requirements.
Today, I was reflecting on the Side Guard Task Force meeting and a strategy for action going forward. As I was looking up information on an engineer from one of the manufacturers, whom I’d met several years ago, I noticed that the manufacturer is making plans to hire an engineering intern for the Summer of 2021. Beautiful! Brilliant! How about we show this young intern how engineers can save lives.
Imagine engineering students from universities around the nation spending the coming year doing internships or senior capstone projects at trailer manufacturing companies working alongside industry engineers on side underride guard development. Collaboration could take place and serve to more rapidly bring about the development and implementation of long-overdue, life-saving technology.
Note: The Side Guard Task Force meeting on February 26, 2021, was a follow-up to an earlier meeting. 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.
After listening to Andy Young interview Eric Hein about the loss of his son, Riley, in a side underride, participants viewed a photo memorial slideshow of some of the countless underride victims:
Some of the many individuals and organizations who have made contributions to the work on underride protection were celebrated in this Underride Hero Hall of Fame video:
Note: the video of the complete meeting is an unedited Zoom recording. As excerpts from the agenda are created, Youtube video links will be added.
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.
Perhaps your political leanings favor self-regulation rather than imposing regulations upon industry. But what do you do if that industry has opposed life-saving measures for fifty years and thousands of people die as a result?
Like a UK Committee argued about the tax industry, might you conclude that, “Government needs to take a more active role in regulating the [trucking] industry, as it evidently cannot be trusted to regulate itself”?
The House Transportation & Infrastructure Highways & Transit Subcommittee held a hearing this morning entitled, “Every Life Counts: Improving Safety on our Nation’s Roadways.” A question was asked about Commercial Truck Safety. Note the comment made here which reflects the commonly-held belief that it is inevitable that a large truck will win out in any collision with a smaller entity.
Would Congress pass the STOP Underrides Act if they realized that truck crashes could become more survivable with the installation of comprehensive underride protection?
We are thankful to Cool Breeze Studio for creating this recently-released underride documentary — telling the stories of underride victims to shed light on this preventable problem.
We are asking for 100,000 Americans to sign our new petition on WhiteHouse petition site. Once we get 150 signatures, it will become searchable on their website.
If we are able to get 100,000 signatures in 30 days — by July 31, then the White House has promised that they will respond to our new petition, which calls on President Obama to appoint a National Traffic Safety Ombudsman, who will be an Advocate for Safer Roads.
PLEASE NOTE: If you sign the petition, be sure to go to your email. We the People will send you an email which you have to reply to in order to confirm your signature is valid.
What the Traffic Safety Ombudsman Petition says:
Every average day in the U.S., 100 of our loved ones die in crashes and 400 more suffer serious crash injuries–along with $2 Billion in crash losses.
We propose that the President establish an independent Office of National Traffic Safety Ombudsman to be an advocate to eliminate preventable crash deaths and serious injuries.
We need someone who has a mandate to advocate on behalf of the victims, someone who is not compromised by competing interests. We call on the President to take this action to protect our families and loved ones from one of the leading causes of preventable death.
Traffic Safety has not been a national priority. Without this Presidential action, too many lives will continue to be lost to vehicle violence.
Please SIGN the Petition: https://wh.gov/i6kUj. Then, SHARE this post. We have to get 100,000 in 30 days! July 31 is the target date.
Read more about how a Traffic Safety Ombudsman could help us move more quickly toward ending tragic and preventable crash fatalities and life-altering crash injuries:
When steps are taken to make roads safer, the impact can mean many lives saved globally.
Vision Zero is all about moving towards zero crash fatalities and serious injuries. If we would view road safety as a public health challenge, then we might begin to grasp the immensity of this problem.
When I attempted to find the source of his quote, I stumbled upon this article by another public health expert, Dr. Arshini Daytan. I did a mental double-take when I read her quote from David Jernigan (John Hopkins) on the strategies of large corporations who actively seek to make us unhealthy:
“Associate Professor David Jernigan from Johns Hopkins Bloomberg School of Public Health gave the Basil Hetzel Oration and highlighted the significant influence large multinational corporations had on shaping the environment in which people make health decisions and the need for public health to understand these organisations. He proceeded to explain how these organisations, for example alcohol companies, operate to influence the debates around their products and why we need to know this in terms of public health advocacy. He went through the 10 principles outlined in the book ‘Lethal but Legal – Corporations, Consumption, and Protecting Public Health’ by Nicholas Freudenberg.
1. Make disease promoting products ubiquitous
2. Encourage retailers to promote their products
3. Supersize products
4. Target marketing to vulnerable populations
5. Price unhealthy products to promote sale and use
6. Create monopolies that reduce bargaining power of consumers and government
7. Support candidates who oppose public health policies
8. Lobby against laws that protect public health
9. Threaten to take jobs out of communities that oppose their policies
How did you react when you heard our crash story? I have been thinking about that a lot this week.
On Saturday, we heard other crash stories at Truck Safety Coalition’s Sorrow to Strength conference in Arlington, Virginia. It is hard to hear the same problems with truck safety over and over again and know that too many things are not getting any better. Yes, we heard of the successes over the years. But some of these families have been advocating for safer roads for over 20 years–including for safer underride guards.
On Monday morning, Isaac and I met with Russ Rader at the Insurance Institute for Highway Safety’s DC office. We discussed some of the details for the Underride Roundtable that we are planning with them for May 2016 at their Ruckersville, Virginia, conference & crash testing center. I am getting excited as it is getting closer to becoming a reality.
We arrived early for our meeting and, while we were waiting to start, we sat in the reception area, drank some water, and watched the video loop which they show on a wall monitor. I have seen many of their crash test videos before but learned many new things. It had my attention.
Later that afternoon, Isaac and I joined other Truck Safety Coalition volunteers for meetings at DOT with FMCSA and NHTSA. As we got off the elevator, Scott Darling, FMCSA Administrator, pointed out the framed photo collage of truck safety victims (a fraction of the total number) which was presented to them in 2009. FMCSA staff see it every day as they pass by on their way to work.
The next morning, when I woke up, an idea came to me: create a video loop (which could be updated) of crash victim stories and raise money to put it on monitors throughout DOT. I told Isaac about my idea and he said that it should be on The Hill as well.
Then, as we headed for our meetings on The Hill, we encountered rush hour traffic at the Metro. People piled into the first train that stopped and it was so full that they were packed like sardines and the door couldn’t even shut until the riders pushed themselves closer together.
The woman just in front of me, who was a regular Metro commuter, commented that one time she had seen someone’s backpack get stuck in the door. We continued to talk and, after getting on the next train, eventually got a seat next to each other some stops later.
She asked me about the buttons on my lanyard:
When I told her that two of my daughters were killed in a truck crash, she had tears in her eyes and held my hand. Imagine the power of our story and the impact it could have on the future of highway safety.
I want the faces and voices of once-alive truck crash victims and their surviving families to be seen and heard daily throughout Washington, DC. And then just maybe we will have their attention so that, armed with facts and figures and reasonable solutions, we will be able to bring about dialogue to solve trucking safety problems which take into account the needs of the industry without unnecessarily sacrificing the lives of our families.
I have spoken and corresponded with George Rechnitzer and Raphael Grzebieta from the Transport and Road Safety (TARS) Research Centre in Sydney. I have also written about their work on underride protection in Australia.
Yesterday, I received from them a copy of their submission to the Public Comments on the Underride Protection of Single Unit Trucks. It is worth a read to find out what is being said in other countries about this vital issue.
Whilst there are force based design rules, e.g. in USA, Canada and Europe, it is apparent that these rules are inadequate. In our submission we strongly recommend crash test based performance requirements for under-run protection catering for both centred and off-set impact. Around 10 people per year on average are killed in Australia in rear under-run crashes resulting in horrific injuries such as decapitation.13 Yet the Regulation Impact Statement (RIS)14 for Underrun Protection publish by the Vehicle Safety Standards Branch at the Department of Infrastructure, Transport, Regional Development and Local Government in July 2009 recommended that only front under-run protection be applied to all rigid and articulated trucks. Their conclusion was that the cost-benefit ratio for frontal under-run barriers was greater than one whereas for side and rear under-run the benefit was negative, and hence such protection should not be mandated in an Australian Design Rule. Yet despite these numerous calls for changes over the past three decades, we continue to consistently kill people in such crashes, ignoring the fact that practical low cost effective under-run barriers can be fitted. That is the real unforgivable tragedy.
The Vison Zero and Safe System approach adopted by most of the world now and on which Towards Zero Deaths is anchored, boldly moves away from the economic- rationalist ‘cost-benefit’ models (cited in this Docket as still being used by NHTSA), to a humanistic more rational model. The important aspect of a ‘Vision Zero’ principle is that it introduces ‘ethical rules’ to guide the system designers. In other words: • Life and health can never be exchanged for other benefits within the society • Whenever someone is killed or seriously injured, necessary steps must be taken to avoid similar events.
The Authors of this submission would further point out to those at NHTSA considering how the Rear Impact Protection for Single Unit Trucks should be revised; they should consider placing themselves in the position of the gentleman being asked in the following Australian Government advertisement: https://www.youtube.com/watch?v=bsyvrkEjoXI&feature=youtu.be. This advertisement was commissioned and paid for by the Victorian State Government in Australia. We would ask the NHTSA staff responsible for this NPRM which members of their family would they allocate to die that would be acceptable to them and would meet the NHTSA cost benefit ratios being considered?
To break the impasse between safety stakeholders and regulators, the Authors of this submission have proposed to incorporate into the revision of the ASNZS3845.2 Australian Road Safety Barrier Systems and Devices a crash test performance requirement for rear under-run barriers for heavy trucks, shortly to be released for public comment. In that standard test requirements for under-ride barriers, called Truck Under-run Barriers (TUBs), has been developed and now included. We hope that this standard will be approved by committee members (members include Australian State Government regulators) and hopefully will be published in early 2016. The tests requirements are in part based on the US Manual for Assessing Road Hardware (MASH) and are presented below. We would strongly recommend that NHTSA consider such dynamic performance tests when they deliberate their development of the Federal Motor Vehicle Safety Standard for under-ride barriers.
TUB’s are designed to prevent a vehicle impacting the rear of a stationary truck under-riding the back of the truck in a manner where the truck structure intrudes into the impacting vehicle’s occupant compartment. The TUB’s main function is to protect the occupants in the impacting vehicle.
If the car is designed to such ANCAP and IIHS test protocols with the maximum crashworthiness rating, it is likely that the occupants would not sustain serious injuries in a vehicle impacting such a TUB in the configurations shown in Figure 1.
The manufacturers of such TUBs and operators of heavy vehicles are encouraged to explore the application of energy absorbing systems for TUBs including rear air bags mounted on the rear of trucks.
This latter recommendation is relevant to our goal of seeking research money to provide to Dean Sicking whose proposal intends to do just that: explore the application of the SAFER Barrier — an energy absorbying system — to the prevention of truck underride tragedies.
As soon as their Public Comment is published, I will post a link so that you can read the entire document online for a better understanding of their detailed analysis and proposal for crash test based performance requirements for truck underride protection, for both centred and off-set impact, in contrast to the force based design rules in the current U. S. federal underride standards. The Australian recommendations are based on 30 years of research and experience. (Note: the document in its entirety can be accessed at the top of this post.)
The formal period for submission of Public Comments ends today, September 21, 2015. Upon the request of several groups, I made a request that the period be extended for a short time. That request is under consideration by the agency. All published Public Comments can be found at this site, which is updated as submissions are made: http://www.regulations.gov/#!docketDetail;dct=FR+PR+N+O+SR;rpp=10;po=0;D=NHTSA-2015-0070
George Rechnitzer and Raphael Grzebieta have, unfortunately, faced similar challenges in Australia in trying to persuade the powers that be to make rules which would prevent unnecessary and horrific deaths and injuries. However, they are encouraged by potential upcoming changes in their country:
To break the impasse between safety stakeholders and regulators, the Authors of this submission have proposed to incorporate into the revision of the ASNZS3845.2 Australian Road Safety Barrier Systems and Devices a crash test performance requirement for rear under-run barriers for heavy trucks, shortly to be released for public comment. In that standard test requirements for under-ride barriers, called Truck Under-run Barriers (TUBs), has been developed and now included. We hope that this standard will be approved by committee members (members include Australian State Government regulators) and hopefully will be published in early 2016.
We look forward to working with George and Raphael at the Underride Roundtable in the Spring of 2016 and know that our country can greatly benefit from their expertise.