Tag Archives: underride crash

Why use the term collision MITIGATION rather than AVOIDANCE?

The American Trucking Association says that they prefer that DOT would focus on collision avoidance technology rather than things like improved underride guards:  https://annaleahmary.com/2014/12/the-passion-of-this-safety-advocate/

I now have a new response to that tiresome attitude toward vital truck safety measures–thanks to this Truckinginfo.com article:  http://www.truckinginfo.com/article/story/2015/10/behind-ups-decision-to-make-collision-mitigation-standard.aspx

“The National Transportation Safety Board recently recommended that all passenger and commercial vehicles use collision avoidance technology. The suppliers of the technology prefer the term ‘collision mitigation,’ because it’s impossible to avoid all accidents, but it can lessen the severity.”

In other words, because we know that we cannot prevent all crashes, it is unimaginable to me that we would not do everything that we could to make those crashes survivable!  https://annaleahmary.com/2015/10/rear-ending-a-truck-should-be-a-survivable-crash-why-isnt-it/

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Mechanical Engineering Student Makes a Good Case for Preventing Underride Crash Fatalities

Here is another good case for improvement in truck underride regulation and manufacture–this time from a mechanical engineering student:  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0078

It’s all good so be sure and read it, but here are some excerpts:

“Let us consider the future instead of the present for just a moment. A scary revelation is that passenger vehicles used by the commuting public are being designed to be smaller, lighter and built of lightweight composite materials. This engineering is done to improve fuel economy, handling, suspension, and improving the drivers experience. The key is to strive for an increase in safety at the same time. On the polar opposite side of the spectrum, the trucking industry has been trying to increase the size and maximum load of their CMVs to increase revenue for a number of years.

I believe the trucking industry should follow in the footsteps of Emilio Lopez, UPS’ Global Fleet Safety Manager, who was recently quoted in an article by Truckinginfo as saying, “It’s hard to put a ROI (return of investment) on saving someone’s life.” After reviewing recent studies on underride, researching previous studies, looking over police scene photographs and sketches, it can be noted that primarily, rear underride accidents occur at night where the driver of a small passenger vehicle cannot perceive a stopped vehicle.

My biggest issue with the NHTSA ANPRM Docket No.: NHTSA-2015-0070 is the following quote, “Among the 122 fatalities examined in this review, 49 (40 percent) were exceedingly severe crashes that were not survivable.” What if we stop believing traffic fatalities are inevitable and start believing that every traffic fatality is preventable? It may be a rather colossal way of thinking. Innovation can be accomplished by thinking big and starting small. Small steps are what eventually climbs the mountain. Introduce increased regulations on SUT in which the rear guard is stronger than FMVSS Nos. 223 and 224, potentially CMVSS No. 223 compliant guards. Use these regulations to collect real-world data from the increased structural rigidity to determine if the problem lies in the fact that the FMVSS Nos. 223 and 224 guards are not strong enough to begin with.”

Trip North May 2015 031We Rescue Jesus Saves 018

Sign & share Vision Zero Petition: http://www.thepetitionsite.com/417/742/234/save-lives-not-dollars-urge-dot-to-adopt-vision-zero-policy/

See how AnnaLeah & Mary for Truck Safety is raising money for underride research and planning an Underride Roundtable at IIHS on May 5, 2016:  https://www.fortrucksafety.com/ and https://annaleahmary.com/2015/10/underride-roundtable-save-the-date-may-5-2016/

 

Powerful & Informative Case Made for Underride Guard Improvement by Trucker/Attorney

Even if you think that you know all there is to know about truck underride, you’ll want to read the comments by this truck driver/truck crash attorney. He provides an in-depth understanding of how underride occurs and the horrific results.

With the extended Public Comment period coming to a close for Rear Underride Protection on Single Unit Trucks, there are some additional comments just posted on The Federal Register at regulations.gov.  http://www.regulations.gov/#!docketDetail;dct=FR+PR+N+O+SR;rpp=10;po=0;D=NHTSA-2015-0070

Of particular note is a very informative and powerful comment recently posted by Andy Young, a husband, father, truck owner, Class A CDL driver, truck accident attorney and a trial attorney: http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0075 . The remainder of this post contains his public comment on that website:

“I bring a unique and varied perspective to the very issue under consideration. Not only does my background and experience provide me with credibility to make the within comments, but I have also researched issues regarding rear underride guards, lateral protection devices, and front override prevention. My research has even taken me overseas to see how other countries are handling some of the very issues raised in the comments submitted by original equipment manufacturers and by those who are part of the commercial trucking industry. Due to both my practical experience and research, I comment as a proponent in favor of the advance notice of proposed rulemaking (ANPRM).

Underride Crashes = The Eight Figure Jury Verdict

“The automotive industry spends millions, if not billions, in research and development. This research and development is specific to improving a vehicle’s safety features (energy absorbing bumpers, crumple zones, air bags, seat belts, etc.) all designed to keep the vehicle occupants safe. The engineering behind these safety features can mean the difference between a minor injury and a tragic fatality. No matter how safe the car may actually be, the safety features are only effective if there is good structural interaction (crash compatibility) between collision partners. This means there is a geometrical match up of the crush structure of both the striking vehicle and the vehicle being struck.

“A two vehicle collision involving a single-unit, commercial motor vehicle (CMV) and a light passenger vehicle frequently results in a mismatch of structural components at the first point of impact. The crash incompatibility is in large part due to the height of the CMV. This often results in an “underride” collision. The lower profile passenger vehicle physically goes underneath the higher profile CMV. The first point of impact is beyond the hood and into the glass windshield. The second point of impact then literally becomes the heads, faces, and chest of the lower profile vehicle’s occupants.

“Air bags do not deploy because the lower profile vehicle’s bumpers and air bag sensors are not triggered. Energy absorbing bumpers and crumple zones, all designed to keep the passenger compartment intact, become irrelevant. The load path from the crash results in energy that does not initially strike the intended engineered crush structure of the passenger vehicle. With no air bag and the vehicle traveling underneath the opposing vehicle, the occupant compartment is pierced resulting in a passenger compartment intrusion.

Thereafter, the seat belts restraining the occupants fail to prevent catastrophic injury or deadly consequences as the energy from the collision is absorbed directly by the human body. The car’s occupants then suffer the most horrific crash consequences: death by blunt trauma; decapitation; open skull fractures; traumatic brain injuries; degloving of the face; spinal cord injuries; paraplegia; or quadriplegia.

“The truck driver then suffers with a career-ending criminal vehicular homicide and/or criminal vehicular assault charges. At the very least, the truck driver suffers the psychological trauma associated with being an integral part of such a horrific crash. The truck company then likely encounters a civil lawsuit. The fatalities and catastrophic injuries associated with underride crashes typically produce seven figure to eight figure verdicts, all exceeding minimum insurance requirements. Smaller truck companies are saddled with paying the judgments in excess of insurance coverage. These companies then must sell assets and/or end up filing for bankruptcy.

“Everyone loses in an underride truck crash, the truck company and truck driver included. The typical argument that energy absorbing underride guards would increase weight and costs associated with that increase, simply do not equal the costs associated with the potential of a seven to eight figure jury verdict. My question to those in opposition to this measure is: if you are concerned about saving weight, then why not the same level of concern for saving lives?

Underride Lawsuit Example

“Underride crashes resulting in these devastating injuries and fatal results can even occur at lower speeds. A verdict was recently achieved in an underride collision involving a dump truck and a Honda sedan (Kiara E. Torres and Joshua Rojas vs. Concrete Designs, Inc., et al., Cuyahoga County, Case No. CV 12 795422 & 795474). The first point of impact was the windshield and “A Pillar” of the Honda’s front passenger side coming into contact with the back left corner of the dump truck’s cargo bed. The Honda’s front bumper and hood traveled underneath the dump truck’s steel cargo bed without damage. The geometrical mismatch of the collisions’ two partners caused the corner of the dump truck cargo bed to cut through the Honda’s windshield and into the skull of the right front seat passenger. This young man miraculously survived, but suffered an open skull fracture, a traumatic brain injury, and substantial physical limitations – all requiring a prohibitively expensive life care plan. Unfortunately, the Honda had three other passengers and this young man was not the only one exposed to the passenger compartment intrusion.

“The passenger compartment intrusion continued along the right side length of the Honda. The right backseat passenger succumbed to the load forces and also suffered a traumatic brain injury. Intriguingly and not atypical of collisions piercing into the passenger compartment, the two occupants on the left side of the Honda (the driver and the passenger behind the driver) walked away from the accident with minor injuries. The dump truck driver was also uninjured. Frequently, occupants not effected by the passenger compartment intrusion (particularly at lower speeds) can suffer no injury at all while those effected by the PCI can end up with injuries that result in substantial verdicts. The Jury returned a verdict in favor of the front seat passenger in the amount of $34,600,000.00 and the back seat right passenger in the amount of $7,800,000.00. 100% of the fault was apportioned against the dump truck driver. The total verdict for this underride crash was $42,400,000.00.

Over 62 Years Since Rear Underride Guard Requirement Update On SUTs

“The first standard for rear underride guards on CMVs was issued in 1953 by the Bureau of Motor Carriers. On June 29, 1967, national attention was brought to the issue of rear underride guard protection and vehicle crash compatibility when Jayne Mansfield, American actress, was killed as a front seat passenger in a 1966 Buick Electra. In spite of the 1953 rear guard requirement, this Buick hit the back of a tractor-trailer resulting in beyond the windshield passenger compartment intrusion. Three adults and three children were involved in the crash. The three adults seated in the front seat, Jayne Mansfield, her companion Attorney Sam Brody, and the car driver, Ronald B. Harrison were all killed. The actress’ three children (eight-year-old Mickey, six-year-old Zoltan, and three-year-old Marie) all survived and were claimed to have been in the back seat of the car. Early media reports wrongly believed Ms. Mansfield to have been decapitated.

“In 1969 and 1977, the NHTSA proposed an advance notice of rule making. Both regulatory attempts failed. Forty-five years after the 1953 rule requiring rear underride guards, the NHTSA promulgated an updated rear underride guard standard that became effective in 1998. The new mandate was for combination tractor-trailers only. They did not include single unit trucks (SUTs). The new rule required the following: rear guard ground clearance to be no more than 22 inches; rear wheel setbacks of no more than 12 inches from the cargo bed; and strength testing requirements. To date, the NHTSA has not updated rear underride guard requirements for SUTs. It is hoped that this ANPRM will succeed to regulatory mandate.

“In a letter dated April 3, 2014, the National Transportation Safety Board (NTSB) urged the NHTSA to take action regarding underride guards. The NTSB letter asked for a number of items regarding rear and side underride protections systems all “designed to prevent accidents and save lives” (Hersman, Deborah A.P., Chair, National Transportation Safety Board, Safety Recommendations, H-14-001 through -007, letter to The Honorable David J. Friedman, Acting Administrator, National Highway Transportation Safety Administration, page 14). On July 10, 2014, the NHTSA granted a petition for rule making submitted by Ms. Marianne Karth and the Truck Safety Coalition requesting the agency improve the safety of rear underride guards on trailers and SUTs (DOT, NHTSA, “Grant of Petition for Rulemaking; 49 CFR Part 571 FMVSS, Rear Impact Guards; Rear Impact Protection”). The Petitioners also made a request to improve side underride guards and front override protection.

Comments Against Need To Be Met With Skepticism

“Industry equipment manufacturers state that rear guards cannot be placed on various construction related vehicles. These statements need to be met with skepticism. Many European CMVs already have rear-underride guard protection on trucks, like dump trucks or box trucks with lift gates. Please see the following photographs I took while I attended the Commercial Vehicle Show in Birmingham, England this past April, 2014.

Note: The Public Comment can be accessed here to see the indicated photos.  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0075

“As evidenced by the photographs above, the U.S. lags behind other developed nations in providing meaningful rear impact protection. The photos above are just two examples of numerous applications allowing for rear impact protection and a lift gate or dump application. The argument that many SUTs need to have “good off-road mobility at construction sites” or “hitch connections” and therefore cannot have rear impact protection is likewise out-of-date thinking. Below, please see photographs from one vendor at the Commercial Motor Vehicle Show in Birmingham, England.

“While it is not readily apparent by these photographs, the vendor demonstrated how the rear impact protection guard can be adjusted up and down, as needed. Technology exists that debunk the argument that the rear impact guard would interfere with the work that the truck must perform.

Conclusion

“In this magnificent country of ours it is difficult to accept the fact that as a nation we are decades behind protecting our motorists from underride and/or override crash scenarios. The NHTSA has been slow to meaningfully regulate underride guard protection. As such, local governments, such as the City of Boston are passing ordinances requiring lateral protection devices on SUTs. Even the University of Washington announced that it is installing side guards on its campus fleet of SUTs. I implore the NHTSA to seriously consider meaningful passage of the pending proposal. We need to make sure that our citizens have the same protection as those in other nations. Sixty-two years is too long to wait to pass regulatory requirements that afford rear impact protection and other safety devices on single unit trucks.

“If you have any questions, I can be reached at 216-789-4832. My email is andytatransport@gmail.com. My Twitter account is @SafeDriveHome”

Note: Additional information can be gained by an article on underride by the same author: http://www.nphm.com/wp-content/uploads/2014/10/Piercing-The-Passenger-Compartment1.pdf?fd9d09 .

See my Public Comment as a firsthand example of the horrific, fatal injuries which too often occur in underride crashes: Marianne Karth – Comment  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0018

Underride Research Meme

Learn how AnnaLeah & Mary for Truck Safety is raising $ for Underride Research–a timely and life-saving effort:  https://www.fortrucksafety.com/

Our Vision Zero Petition seeks to bring about practical solutions to the problem of motor vehicle crash fatalities & injuries: http://www.thepetitionsite.com/417/742/234/save-lives-not-dollars-urge-dot-to-adopt-vision-zero-policy/

Mother of Underride Crash Victims Demanding Tougher Truck Safety Rules

When Isaac and I were in Washington, DC, to talk with our senators and congressmen, as well as administrative officials at NHTSA and FMCSA (DOT), we were interviewed by Geoff Bennett, Washington Reporter for Time Warner Cable.

His report is airing October 30 – November 1.  We appreciate the opportunity to share our story with a wider audience and invite them to support our underride research and join the thousands who have already signed our Vision Zero Petition.

Read the article here: http://www.ny1.com/nyc/all-boroughs/news/2015/10/30/us-dot-reconsiders-standards-for-rear-impact-safety-guards-on-tractor-trailers.html

Sign & share the petition: http://www.thepetitionsite.com/417/742/234/save-lives-not-dollars-urge-dot-to-adopt-vision-zero-policy/

Support Underride Research: https://www.fortrucksafety.com/

 

Blindsided By Unexpected Loss; The many facets of grief

I recently returned from a trip to DC where Jerry, Isaac, and I joined with other families who had experienced unexpected loss by way of devastating truck crashes. At the Truck Safety Coalition’s Sorrow to Strength Conference we shared our stories with one another, attended workshops to learn more about truck safety issues and how to advocate for change, as well as participated in meetings on The Hill.

One of the workshops was on the topic of grief and I had made the comment that what we all experienced in our horrific, tragic losses made the grief more complicated because of the anger and frustration we all too often feel when too little is done too late to save (other) lives. It is sometimes hard to move on fully with, as they say, “a new normal” when you witness the seemingly calloused and indifferent attitude toward what should be preventable deaths.

Supposedly its a risk you take when you choose to get on the road, you know. Or, changes would not be “cost effective.”

In any case, I wanted to share an article which I read last year. It helped me process my feelings of grief at the unexpected loss I have felt after discovering in 2010 that many of our family members face challenges we had never anticipated with a progressive hereditary peripheral neuropathy (Charcot Marie Tooth or CMT). What they tell us is that it is not life-threatening, but it is a life-changer.

I had searched online and found this interesting article about the grieving of parents with disabled children, which could be helpful for any grieving person–no matter what their loss, The Impact of Childhood Disability: The Parent’s Struggle, by Ken Moses, Ph.D.:
http://www.pent.ca.gov/beh/dis/parentstruggle_DK.pdf

I just now re-read it and noticed this statement by the author:  After working with parents of the impaired for many years, I have come to believe that I was given bad advice. I have come to believe that pain is the solution, not the problem.

That reminded me of something my 5 year-old granddaughter said earlier this year:

One day, Vanessa asked me (out of the blue), “Does pain fix sadness?

Me: “Well. . .?”

Vanessa: Runs off to play. . .

I don’t know. Will the pain which I am going through eventually “fix” my sadness? Is the pain a process–or at least a signal or indication that a process of healing is taking place? If I were not feeling the pain, would it be harder to complete that process? Will the pain ever lessen?

I have also known real peace in this season. It also comes and goes–seeming elusive. Comes mostly when I am focused on the promises of God–in word or song–like the song I sang at their funeral, In Christ Alone. I really believed it then and I believe it now. It just seems in stiff competition with the real pain.

Read more in that post, Real Pain, Real Peacehttps://annaleahmary.com/2015/03/real-pain-real-peace/

I was glad to see that Jerry and Isaac had an opportunity to tell our story themselves for the preparation of videos which I just discovered are now posted on the Truck Safety Coalition’s website:

 

Other families share their truck crash stories here: http://trucksafety.org/get-involved/personal-stories/ .

Just yesterday, I read a facebook post and comments by some of the TSC family members. They were commenting on how hard it was to get back into things after the conference in DC and how they struggled anew with the grief and sadness. It reminded me of how thankful I was for the comment made several times at the conference that we will not tell each other, “Get over it.” It is such a complicated grief; we will never fully get over it.

But, with hope, we will carry on because we know that someday we will see their face again:

https://annaleahmary.com/2015/05/how-a-truck-crash-changed-the-month-of-may-or-what-happens-when-nobody-takes-responsibility/

Underride Roundtable: Save the Date, May 5, 2016

After a great deal of thinking and talking and preliminary planning, we now have a host facility–the Insurance Institute for Highway Safety’s Vehicle Research Center–and a date, Thursday, May 5, 2016, for our Underride Roundtable.

IIHS Vehicle Research Center http://www.iihs.org/iihs/about-us/vrc

We will be reaching out to engineers, manufacturers, trucking industry representatives, regulatory officials, safety advocates, and others–inviting them to join us in a collaborative effort to bring about the best possible underride protection.

Excited. Encouraged.

Save the date. May 5, 2016

Save the Date Underride Roundtable

Underride Research: https://www.fortrucksafety.com/

The latest Public Comments on the ANPRM for Underride Protection of Single Unit Trucks

Here are new comments posted on the Federal Register for

ANPRM for Underride Protection of Single Unit Trucks

See attached file(s) 
View Comment

Submitter Name: Lackore, Roger
Posted: 10/20/2015
ID: NHTSA-2015-0070-0062
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
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
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
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

http://www.regulations.gov/#!docketDetail;dct=FR+PR+N+O+SR;rpp=10;po=0;D=NHTSA-2015-0070

Rear-ending a truck should be a survivable crash. Why isn’t it?

I survived a truck underride crash. My daughters did not. Why not? Because we were sent backward into the back of the truck and AnnaLeah and Mary were in the backseat. The weak and ineffective underride guard gave way and the back of the truck broke their bodies.

The Insurance Institute for Highway Safety has shown through crash testing that the current federal standards for underride guards are not strong enough to withstand most crashes but that it is possible to make stronger ones.  http://www.iihs.org/externaldata/srdata/docs/sr4907.pdf

We are promoting underride research https://www.fortrucksafety.com/ and organizing a national Underride Roundtable ALMFTS Underride Guard Research Brochure.

We have also launched a Vision Zero Petition online because we believe that, unless rulemaking policy changes, when the rubber meets the road Saving Lives will not be the criteria used for making highway safety regulations as effective as humanly possible.Unnecessary compromise will occur and preventable deaths will be the result. Profit will win out over the best possible protection.

We know that rear-ending a truck should be a survivable crash and we are devoting our lives to making it a reality.

Sign & share our Vision Zero Petition: http://www.thepetitionsite.com/417/742/234/save-lives-not-dollars-urge-dot-to-adopt-vision-zero-policy/

Read more here: https://annaleahmary.com/tag/vision-zero/ and https://annaleahmary.com/underride-guards/

Underride Research Meme

Tools For Getting Your Local Media On Board With Vision Zero & Underride Research

In the aftermath of our crash, we have found ourselves walking a path we had not anticipated–safety advocacy. We have discovered the importance of raising awareness and gaining support in order to bring about life-saving changes.

After all, we had no idea about what truck underride guards were before May 4, 2013. How could we expect anyone else to know about them and understand what we were talking about unless we found every way imaginable to inform and motivate them to care about this issue–thankfully, never as much as we do.

So what I would like to talk about here is what you can do about it once you (the reader) better understand the ideas and importance behind our quest for Vision Zero, underride guards, and crash avoidance technology.

Specifically, what you can do is:

  1. Become informed about what we are talking about so incessantly.
  2. Read our Vision Zero Petition.  http://www.thepetitionsite.com/417/742/234/save-lives-not-dollars-urge-dot-to-adopt-vision-zero-policy/
  3. Read even more about Vision Zero:

    For more information on Vision Zero: https://annaleahmary.com/tag/vision-zero//

    “Towards Zero – There’s no one someone won’t miss.” https://youtu.be/bsyvrkEjoXI

  4. Sign our Vision Zero Petition. (Never doubt the power of 1.)
  5. Share our Vision Zero Petition through talking to people about it, emailing, using whatever social media with which you are comfortable. (There are Sharing icons on The Petition Site.)
  6. Read our new website, AnnaLeah & Mary for Truck Safety, which is dedicated to informing about underride guards and raising money for underride research and an Underride Roundtable to bring about the best underride protection by bringing together engineers, industry representatives, government officials, safety advocates, insurance companies, victims & their families, and the media.  https://www.fortrucksafety.com/ and https://annaleahmary.com/underride-guards/
  7. Donate to the research. (Every $1 counts.)
  8. Share the website with others.
  9. Share both of these projects with your local media.
  • When possible, look up your local media and make direct contact with them through a phone call, email, or through an online Contact Form.
  • This site has a lot of tools for reaching local media, including a map of the U.S. which allows you to click on your state and then your city and find local media.  http://sparkaction.org/act/media
  • Click on COMPOSE MESSAGE on that site.
  • Once you locate who you can contact in your community, I have written a couple of press releases for you to share with them: Press Release from ALMFTS Vision Zero and Underride Research and Press Release for the Underride Research Fundraising Campaign . These can be copied and pasted into the form provided online on that site.
  • Be sure to let them know how important this is to you and your community as well.
  • Consider making a follow-up phone call.
  • For whatever you are able to do, thank you! And I’d love to hear about it.

We have made numerous contacts with the media as our story has been shared. But we cannot be in your community. Next week there will be an article in our local Rocky Mount newspaper. I will share the link for that with you and you can pass that along to your local media as well.  We are asking you to be an extension of our national plea for the best possible protection.

Note–The news story has now been published online:  https://www.rockymounttelegram.com/news/advocates-garnering-signatures-3009111

This is not just some freak problem that will never affect you or someone you love. In fact, a Vision Zero policy in DOT rulemaking could make a big impact in not just truck safety but auto safety as well. Decisions about safety should not be led by profit. Cost/benefit analysis can never adequately measure the value of human life and health.

And, once we establish that our Vision is to reduce crash deaths one life at a time, then we can better hold corporate and government officials accountable. No longer will they be able to sweep unpleasant information about the results of defects and flaws under the rug. No longer can they justify decisions and actions which lead to unnecessary tragedy and/or deny that human life was the cost that was paid.

 

gertie 2947

Gertie reaching for Mary ...Susanna's film

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

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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