Yesterday morning, I checked my email and saw that there was a new Public Comment posted on the Federal Register regarding the Notice of Proposed Rulemaking on Underride Guards.
I quickly went to the site and saw that the Truck Trailer Manufacturers Association had posted a comment (see their comments in the PDFs below). Apparently our Underride Roundtable two weeks ago at IIHS has spurred them to spell out the steps which have been taken over the years to squash side guards from being mandated and manufactured to prevent smaller passenger vehicles from riding under trucks upon collision with the side of the larger vehicle.
TTMA_Side_Impact_Main_Comment_2016-05-13
TTMA_Side_impact_Exhibits_A-D_2016-05-13
Their rationale: Cost/Benefit Analysis shows that adding side guard to trucks is “not cost-effective”.
“In its 1991 Preliminary Regulatory Evaluation of proposed guards for rear underride, NHTSA’s Plans and Policy Office of Regulatory Analysis stated: “Combination truck side underride counter-measures have been determined not to be cost-effective.” [Docket I-11; Notice 9; Comment 002, page 15 (emphasis added) {by TTMA}].”
Translate that: Not enough people die from side underride crashes to justify the money it would take to add this safety feature. If this attitude and rulemaking policy is allowed to continue unabated, then innocent, unsuspecting travelers on our road will continue to experience preventable underride crashes and receive a Sentence of Death by Preventable Underride. And no one will be held responsible for that–not the trailer manufacturers, not the trucking companies, not the truck drivers (unless perhaps they were blamed for the collision itself), not the regulators, not the insurers; I repeat, no one!!! No one will be penalized for this despicable, unconscionable action–except, of course, the victims.
And, yes, TTMA is repeating the oft-heard industry argument that the solution is to concentrate on Crash Avoidance Technology instead–as if it were an either/or not a both/and question!
Mom Says $100 Truck Tweak Could Have Saved Her Daughters
Meanwhile, people will continue to needlessly die — like AnnaLeah and Mary — and people like me will undergo tremendously traumatic ongoing grief multiplied exponentially by the anger and frustration of knowing that it might well have been prevented were it not for the endless opposition to implementing solutions which are readily available.
I helped roll up the side guard designed by Aaron Kiefer last month and it did not seem to weigh that much. I talked to Aaron yesterday and he estimates that his side guard, once in mass production, might weigh about 175 pounds. Currently, his prototype, when combining the weight of it on both sides of the truck, weighs in at around 300 pounds. And what percentage of the total allowed 80,000 lbs. is that anyway? (.4%?)
And, by the way, look at this amazing crash test of Aaron’s side guard, which I witnessed in North Carolina less than a month ago (April 30, 2016):
Somebody, please get me an audience with President Obama. I need him to tell me to my face that it is not a matter of life & death for him to adopt a National Vision Zero Goal, to establish a White House Vision Zero Task Force, and to sign a Vision Zero Executive Order which will pave the way for Vision Zero Rulemaking at DOT.
Of course, what I would really like to have happen is to speak with the President, have him catch the vision and promise me that he will actually take those actions. Wouldn’t that be exciting!
However, if President Obama does nothing about the traffic safety travesty, TTMA has clearly shown us what to expect: Continued opposition and resistance to efforts to make trucks safer to drive around.
I truly hope that I am wrong and that the outcome of the Underride Roundtable will have made a huge difference in the future of underride protection. However, it appears that, if TTMA has anything to say about it, we should expect that any new underride rule issued will either be opposed or be unchanged and, therefore, weak and ineffective. When it is Technologically Unnecessary for that to be so.
And then who will be ethically responsible for the continued carnage on the highways of this great country?! That’s what I want to know.
Underride Roundtable To Consider Underride Research From Around the Globe
Media Coverage of the first Truck Underride Roundtable held at IIHS on May 5, 2016
