Here’s a little side note on the cost/benefit analysis (CBA) debate from around the globe in Australia:
The fallacy behind the Australian Federal Government’s CBA is that the cost to the tax payer is minimal to introduce a new mandatory standard requiring crashworthy underrun barriers.
The cost is in effect born by the truck manufacturers which the industry accepts.
That’s the irony of the situation.
At most it might add a fraction of a cent to the cost of your Corn Flakes which I am sure if presented to consumers, they would gladly pay if it saved lives.
The disgusting truth to the Australian Federal Regulator’s CBA is that a ‘virtual’ cost has been added by them, i.e. cost to the industry.
That is being touted by the Federal Government as being more important than the well-being or life of a human being.
After we were instrumental in getting underride rulemaking initiated in July 2014, I realized that, though we had made it over one hurdle, in reality the battle had only begun. I became concerned that the cost/benefit analysis which had so often compromised past underride rulemaking was still a very real threat. It was then that I surmised that a Vision Zero Executive Order to modify the regulatory analysis process might well be necessary. Thus the Vision Zero Petition was birthed.
Some of the warning signs that the Cost/Benefit Analysis (CBA) bugaboo might be lurking around the corner can be seen in the Preliminary Cost/Benefit Analysis for the current underride rulemaking:
To avoid making this post too-lengthy, I will provide the link to my initial reactions when the proposed rule was published in December 2015: A Mom’s Knee-Jerk Reaction to NHTSA’s Proposed Rule to Improve Rear Underride Protection with an excerpt here–“NHTSA’s comments in the NPRM indicate that they do not want to compromise safety in the more common crash scenario and so have proposed to concentrate on making that area of the trailer safer and do nothing, at least at this stage in the game, about the other weaker area where crashes are reportedly less common. (See p. 44, ” NHTSA is not convinced that improved protection in the less frequent 30 percent overlap crashes should come at the cost of adequate protection in the more common 50 and 100 percent overlap crashes.”)I just have to ask, Is it really an Either/Or situation? Are we sure that we cannot reasonably address both problems?”
Hey, I forgot about this: They are asking for information about higher (than 35 mph) speeds. We recognize, however, that benefits may accrue from underride crashes at speeds higher than 56 km/h (35 mph), if, e.g., a vehicle’s guard exceeded the minimum performance requirements of the FMVSS. NHTSA requests information that would assist the agency in quantifying the possible benefits of CMVSS No. 223 rear impact guards in crashes with speeds higher than 56 km/h (35 mph) . What are we waiting for?!
Based on their proposed requirements, their CBA comes up with a figure which is very close to the current Value of a Statistical Life (VSL), $9.4 million–which tells me that if more improvements were added to the proposed rule, that figure would go up and they would then say that such a counter-measure was “not cost-effective.” Get it? p. 55 The agency estimates that the net cost per equivalent lives saved is $9.1 million and $9.5 million discounted at 3 percent and 7 percent, respectively.
See what I mean? p. 55 “We have tentatively decided not to require used trailers be retrofitted with CMVSS No. 223 compliant rear impact guards. Our analysis indicates such a retrofitting requirement would be very costly without sufficient safety benefits.
Of course, they aren’t figuring in (that I can see) the additional lives which would be saved with better protection or adequately considering undercounted lives–like AnnaLeah and Mary. Our FARS report said, “Compartment Intrusion Unknown.”
Why on earth, anyway, are they playing God and deciding that it isn’t worth it to save a certain number of lives? Besides, have they taken into account the fact that the underride victims are not the consumer of the product (improved guards on trailers)? The consumer is the trailer buyer who has already shown a willingness to seek safer trailers. And the manufacturers have responded to that by producing safer trailers (to a degree). See my recent comment on the Federal Register: Public Comment on the NPRM by Marianne Karth
When it gets right down to it, I want to just throw the cost/benefit analysis out the window. It is downright unethical and considers profit over people. Jerry says that the Cost Effectiveness Analysis would be more appropriate and is, in fact, mentioned in OMB Circular A-4 as a regulatory requirement. Circular A-4, “Regulatory Impact Analysis: A Primer”
It is my hope that we can pursue a recommendation, made by a participant of the Underride Roundtable during the afternoon panel discussion, and organize a group of affected individuals and organizations/companies to meet together and develop a proposal to take to NHTSA in order to bring about a comprehensive negotiated rulemaking. The result could more quickly bring about a more effective underride rule which would cover all the bases to save as many lives as is humanly possible through improved technology. It would also get the manufacturing companies out of limbo so that they can make long-term plans and move forward with designing and producing safer products. Win/Win. N’est-ce pas?
Last night, I decided to find out if anyone agrees with my opinion that cost/benefit analysis is inappropriate for rulemaking related to traffic safety matters of life and death. Here is what I am finding:
“Cost-Benefit Analysis: An Inadequate Basis for Health, Safety, and Environmental Regulatory Decisionmaking”* Michael S Baram ** “INTRODUCTION The use of cost-benefit analysis in agency decisionmaking has been hailed as the cure for numerous dissatisfactions with governmental regulation. Using this form of economic analysis arguably promotes rational decisionmaking and prevents health, safety, and environmental regulations from having inflationary and other adverse economic impacts. Closer analysis, however, reveals that the cost-benefit approach to regulatory decisionmaking suffers from major methodological limitations and institutional abuses. In practice, regulatory uses of cost-benefit analysis stifle and obstruct the achievement of legislated health, safety, and environmental goals. The Article concludes that if the health, safety, and environmental regulators continue to use cost-benefit analysis, procedural reforms are needed to promote greater accountability and public participation in the decisionmaking process. Further, to the extent that economic factors are permissible considerations under enabling statutes, agencies should conduct cost-effectiveness analysis, which aids in determining the least costly means to designated goals, rather than cost-benefit analysis, which improperly determines regulatory ends as well as means.” Cost-Benefit Analysis: An Inadequate Basis for Health, Safety, and Environmental Regulatory Decisionmaking*
“Since 1981, the Office of Information and Regulatory Affairs (OIRA) in the White House has reviewed significant proposed and final regulations for conformity with cost-benefit tests.3 Under a series of executive orders, OIRA has performed this role through Republican and Democratic presidencies.4 These policy reviews are controversial: Some claim that OIRA promotes the use of sound social-scientific reasoning; others see it as a front for business interests and a triumph of cold and heartless economic reasoning.” Putting Cost-Benefit Analysis in Its Place: Rethinking Regulatory Review p. 2 by Susan Rose-Ackerman
“President Barak Obama has continued the practice of regulatory review under the executive order originally issued by President Bill Clinton and kept in place by President George W. Bush. However, in January 2009, the Administration expressed an interest in revising the executive order. OIRA opened a comment period and received a broad response from the policy community.6 So far, nothing has happened. The comments seem to have fallen into a black hole. OIRA has not attempted a full-blown reconsideration of the executive order. It has concentrated instead on increasing the transparency of government, and especially, on the ease of access to regulatory information and data sets. Otherwise, it is “business as usual”—with the staff reviewing proposed and final rules with only an occasional flare-up over controversial issues, such as whether or not to designate coal ash as a hazardous waste.7 The failure to rethink the executive order is unfortunate—especially given the global trend to institutionalize something called impact assessment (IA).” Putting Cost-Benefit Analysis in Its Place: Rethinking Regulatory Review p. 3
“With no change in the executive order, CBA will continue to be enshrined as the ideal standard for regulation in the United States. Even if the actual cost-benefit studies performed by U.S. government agencies are highly variable in quality and often lack key components, the technique remains a benchmark for analysis.10 I seek to challenge the hegemony of CBA on two grounds. First, cost-benefit analysis should be used to evaluate only a limited class of regulatory policies, and even then it should be supplemented with value choices not dictated by welfare economics. Second, CBA presents an impoverished normative framework for policy choices that do not fall into this first category.” Putting Cost-Benefit Analysis in Its Place: Rethinking Regulatory Review p.4
“Here, the main problems are measurement difficulties that are sometimes so fundamental that better analysis or consultation with experts cannot solve them. I am thinking mainly of debates over the proper discount rate for future benefits and costs; efforts to incorporate attitudes toward risk; and the vexing problems of measuring the value of human life, of aesthetic and cultural benefits, and of harm to the natural world. Disputes over these issues turn on deep philosophical questions—for example, valuing future generations versus” Putting Cost-Benefit Analysis in Its Place: Rethinking Regulatory Review p. 5
“These issues do not have “right” answers within economics. They should not be obscured by efforts to put them under the rubric of a CBA. Politically responsible officials in the agencies and the White House should resolve them in a transparent way. ” Putting Cost-Benefit Analysis in Its Place: Rethinking Regulatory Review p. 6
“I review the limitations of CBA as a policy criterion and use my critique as a ground for proposing a revised executive order to the Obama Administration. The new executive order should continue to require both up-front consultation on the regulatory agenda and ongoing review of major regulations above some minimum level of importance. As Revesz and Livermore recommend, OIRA could play a larger role in overall agenda setting and policy coordination across agencies.13 Such review serves the interest of any president seeking to influence the overall regulatory environment. Hence, both consultation and review should be mandatory for core executive agencies, but, under my proposed framework, the executive order would only require agencies to carry out formal CBAs for a subset of regulations.” Putting Cost-Benefit Analysis in Its Place: Rethinking Regulatory Review p. 7
“To avoid conflicts with the political pressures facing the President, an advisory body independent of the White House should provide expert analytic advice to agency policy analysts and to OIRA. In this, I build on Stephen Breyer, who urges the creation of a separate expert agency with the mission of rationalizing regulatory policy across programs that regulate risk.14 Bruce Ackerman also recommends the creation of an integrity branch, concerned with transparency and limiting corruption, and a regulatory branch insulated from day-to-day political influences but required to justify its actions publicly.15 Either OIRA, or this new advisory body, should create a library of innovative tools for achieving regulatory goals that go beyond the much criticized command-and-control model. Agency policymakers could access this library as they look for innovative ways to achieve goals, as could those contemplating amendments to existing laws” Putting Cost-Benefit Analysis in Its Place: Rethinking Regulatory Review p. 7-8
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.
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!
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.
Strick Trailer is recalling certain single-axle 28-foot van trailers for a rear-impact guard issue, according to a National Highway Traffic Safety Administration document.
More specifically, 2005-2009 van trailers manufactured July 25, 2004, to Feb. 3, 2009, and equipped with rear-impact guards using gussets 55997 and 55998 are affected. Gussets on affected trucks can increase the chances of injury during a crash, thereby violating Federal Motor Vehicle Safety Standard No. 223, “Rear Impact Guards.”
In March 2014, Strick discovered that the gussets may not have been verified using prescribed test procedures, according to the NHTSA document. Tests conducted in April 2014 confirmed that the gussets violated FMVSS 223.
Owners will be notified by Strick to have reinforcements installed to the rear-impact guards at no cost. For more information, contact Strick’s customer service at 260-692-6121. The recall will begin on June 17.
Okay, I am glad that this is being taken care of, but I only hope that it will be done thoroughly and completely and without delay. And, by the way, if the problem was discovered in March 2014, why is the recall only beginning on June 17, 2016? What took so long?
As I was contemplating whether to go next week to Ralph Nader’s Breaking Through Power: A Historic Civic Mobilization, 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 underride guards from being mandated and manufactured.
The rationale: Cost/Benefit Analysis shows that adding side guard protection from underride of trucks by passenger vehicles 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: 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!!!
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!
Meanwhile, people will continue to needlessly die — like AnnaLeah and Mary — and people like me will undergo tremendously traumatic 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.
And, no, I cannot imagine that it would have to weigh the 750 pounds which they claim it will (which the NHTSA cost/benefit analysis is based upon, by the way). I helped roll up the side guard designed by Aaron Kiefer last month and it did not weigh that much. I just talked to Aaron 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 204 pounds.
And, by the way, look at this crash test of Aaron’s side guard, which I witnessed in North Carolina less than a month ago:
Somebody, please get me an audience with President Obama next week (now I have to go to that conference). 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 him, 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 not do so, TTMA has clearly shown us that nothing will be any different and any new underride rule issued will likely continue to be 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?!
Ever since I received a phone call in May 2013 from Brie Handgraaf, a reporter with The Rocky Mount Telegram, she has been covering our story and caring about our family and our journey of safety advocacy.
Almost a year ago, I was developing a couple of ideas: 1) an Underride Roundtable and a Student Underride Design Project. I was looking in my email archives tonight and found a June 24, 2015, email addressing those two projects. I realized then how much was accomplished in less than a year with the organizing of the Underride Roundtable on May 5, 2016, and the presentation by the Virginia Tech Senior Underride Design Team at that event.
I have pasted that June 24, 2015, email at the end of this post.
And now I would like to publicly thank the Virginia Tech Senior Underride Design Dream Team. . .
Dear Wayne Carter, Daniel Carrasco, Andrew Pitt, Sean Gardner, Kristine Adriano. and Brian Smith,
You did a fine thing by taking on the Underride Guard problem for your Senior Design Project. And then you did a fantastic job of working as a team to address the underride problem and come up with a really cool, outside-the-box design solution.
I think that we were all impressed by your presentation at the Underride Roundtable. I hope that someone will make good use of your design work and use your ideas to create a safer guard. And I hope that what you have experienced this last year will continue to impact your ability to creatively engineer meaningful change.
I know that AnnaLeah, who would have been about your age now (she would have turned 21 on May 15), would have been impressed. And Mary would have definitely thought it cool and awesome–what you all have done to make a difference!
I was so glad to meet you at the Underride Roundtable at IIHS. I hope that you will keep track of the underride issue as you each go your separate ways upon graduation. And I hope to hear from you.
I know that your Virginia Tech advisors, Jared Bryson and Robin Ott, are very proud of you. And I am thankful for their work in supporting you.
I will be forever grateful,
Marianne Karth
Here’s the email which I mentioned from June 24, 2015, which got the ball rolling:
I wanted to update you all on some things which have developed following our phone conversation.
A year ago (June 2014), I became convinced that, if only engineers around the globe put their mind to it, better underride protection could be developed:
I began communicating with Mark Rosekind about the topic and John Lannen and I periodically discussed the possibilities.
After we began the planning for an Underride Roundtable, I heard about Dean Sicking’s success in making NASCAR raceways safer with his SAFER BARRIER: http://www.uab.edu/sicking/dean-sicking . I contacted him and asked if he would be interested in participating in the Roundtable. He responded positively and, in fact, began describing how he thought that he could apply some things which he has learned and design a more effective underride prevention system. I continued corresponding with him and asked him to prepare a project proposal, including a budget.
I have attached his proposal for your review. He cannot guarantee that it will work but is quite confident. It would take about $138,040 for his research team at UA-Birmingham to do the complete project including crash testing, with design & simulation about $61,048, and with design, simulation and building of the prototype about $88,000. IIHS has told me that if they thought the prototype showed promise, they could crash test it “on our dime.” And Dean thinks that he could have the project completed in time to report on it at the Roundtable.
Our family has just filed articles of incorporation to set up a non-profit, AnnaLeah & Mary for Truck Safety, in order to be able to receive tax-deductible contributions for this project. We are making plans to raise funds–including letters to about 60 trucking companies and social media “crowd funding.”
In addition, last week, I received an email from David Zuby at IIHS. He said that he had been thinking about the email which I sent out last winter about the idea of a college student competition for underride design. He had thought that it was a good idea at the time and had been talking with Bob Sechler at SAE (Society for Automotive Engineers). He said that Bob didn’t really think that it fit in with their usual projects but was willing to listen to the idea. I emailed Bob last week–who was out of town–and heard back from him yesterday afternoon. He is willing to have SAE (after approved by his committee) promote the idea of senior design project to the faculty and students in their contact list. He said that if they were to do a competition, then a reward would be appropriate and might take longer to get underway.
Prior to speaking with him, on Monday morning, I had googled some terms when naming our non-profit and ran across Virginia Tech’s truck research activities. So I emailed Rich Hanowski there and he referred me to Jared Bryson, Senior Researcher Mechanical Systems Group Leader. I emailed Jared and he immediately had lots of ideas about it and said that if he contacted his department now and we could have a general plan by August 24, then he could pitch it as a topic for a student to select for the 2015/16 school year at Virginia Tech as a Senior Design Project. He said that April would be better as a time for the Roundtable if we wanted to be able to have the student present their paper at the Roundtable.
Bob Sechler said that if we want him to promote the student design project (across the country) then we need to get him a proposal with background information and requirements. Jared had wondered if we want to do rear and side. I said rear this year because of the current rulemaking. There is always next year. He also wondered about whether to have them look at the side of the trailer behind the back axle.
I had also emailed Ted Scott at ATA last week to let him know that we are working on the Roundtable and about the student competition idea. He suggested that I contact Brenda Lantz at the Upper Great Plains Transportation Research Institute. I spoke with her and she was going to be talking with her Transportation Board, Apparently, if they decided to do something like that, then they could widely advertise it. I still have not heard back from her on that.
This is what I need to know about how to proceed:
I need help developing a proposal for the student design project–especially what we are asking them to build, project requirements.
Would we like them to present their papers at the Roundtable?
Can any money be provided to help them attend the Roundtable?
Or would we put out a request for papers and select 1 or more for presentation (and pay for them to attend)?
Is it crazy to have multiple organizations promoting the idea to students?
Who should be the ones to judge the papers if we go that way?
Could we somehow fund one or more to be developed into a prototype?
Could we have someone like IIHS then crash test any prototypes?
What are your thoughts on all of these possibilities?
In addition, in my conversation with David Friedman, I came away with the impression that any research presented to NHTSA in the coming year would be seriously reviewed and could have impact on strengthening the rules if there is data and evidence to justify it–particularly if there is any kind of peer review and/or verification of the results, e.g., through crash testing by someone else like IIHS.
Please get back to me as soon as possible on all of this. As Bob Sechler mentioned, we need to move quickly on this in order to catch the interest of engineering seniors. He suggested that we appeal to them by inviting them to work on a project which would be interesting, challenging, and valuable: they could make a difference.
Rather than wait for a stronger underride rule to be proposed, Jerry Karth, in early 2014, determined to challenge the truck industry to voluntarily step up and strengthen underride protection on trucks.
He wrote letters, first of all, to the major trailer manufacturers — some of whom had been tested earlier by IIHS. He told them about our crash story — how AnnaLeah (17) and Mary (13) through no fault of their own were killed by truck underride which might have been prevented if the truck they collided with had had better underride guards.
Then, soon after those letters were out the door, Jerry had several more lists of trucking companies, who either purchased or leased trailers. He proceeded to write letters to those companies — again telling them our crash story and making sure that they understood the inadequacy of guards designed to satisfy the current U.S. underride standard, or even the Canadian one for that matter.
Jerry asked them to look into the matter — even providing them with copies of the IIHS Status Reports which had articles on the underride issue. He asked them to make sure that they were getting their trailers from manufacturers which provided the best protection possible. He received letters, emails, and phone calls indicating that the companies were appreciative of the information provided to them.
Then, several months ago, Jerry got a call from Greer Woodruff, VP of Safety, Security, & Driver Personnel at J.B. Hunt a transport company. Greer was calling to tell Jerry that JB Hunt had purchased 4,000 new trailers in January 2016 from Wabash who had recently manufactured safer underride guards–having passed the IIHS 30% overlap crash test.
See my posts with exciting developments on this front:
And later, during the afternoon panel discussion at the Underride Roundtable at IIHS on May 5, Jerry asked Mark Roush from Vanguard (a trailer manufacturer) what had motivated them to produce their recently-strengthened underride guards. This was what he found out:
“We had no idea if there would be a safety marketplace for large trucks when we began our crash tests,” Matthew Brumbelow, an IIHS senior research engineer who has extensively studied truck underride crashes, shared with the audience. “We at the Institute have been really encouraged by the response from trailer manufacturers.”
Mark Roush, vice president of engineering with Vanguard, participated in the afternoon panel discussion. Vanguard is one of the trailer manufacturers that voluntarily improved their underride guards. Roush credited IIHS research and the Karth family’s advocacy for raising awareness of the underride problem and ways to address it.
“As far as we knew we were producing trailers to what we thought was the highest regulatory standard, and then the IIHS test came in and made us aware of what was happening,” Roush said. “Three of our largest customers forwarded letters from you [Karth] asking us to do more.” The Karths personally wrote the largest trailer makers seeking their help in building better rear guards.
David Zuby, IIHS executive vice president and chief research officer, wrapped up the day with a call for continued cooperation and research.
“The one thing I hope everyone takes away from this is that there has been a lot of progress in recent years on underride crashes, and there will be more ahead. We heard from Virginia Tech students who are about to graduate and are already thinking about how to make underride guards better. And you heard from Matt Brumbelow about how guards are being designed to prevent types of underride crashes that weren’t addressed before. We are optimistic that we can solve this problem working together.” See more at: IIHS: Truck underride roundtable addresses problem of deadly crashes
It needs to be said, as I have stated before, that the positive progress made by the trailer manufacturers voluntarily — though it should be appreciated — should, nevertheless, not be allowed to stand as the end of the line. Unless they pass crash tests at higher speeds, the manufacturers need to get back to the drawing board and find ways to make their trucks safer all around (including on the sides and at the front) and at higher speeds.
And, unless trucks currently on the road are retrofitted and Single Unit Trucks become included in underride standards, way too many people will continue to die on our roads from preventable underride.
I think that it would make Mary & AnnaLeah smile to think that their lives were the impetus for saving others from an untimely end and untold heartache.
I have been taking care of family needs (not to mention facing the challenges of this hard time of year) since the Underride Roundtable. There is so much which I want to write as a result of the Roundtable. But I want to get it right and make it clear.
Mostly, I am overwhelmed by both gratefulness that so many people came together to face the problem of truck underride together and, at the same time, the awareness that we aren’t done yet.
One of the topics which I want to address is the issue which came up of whether to test and design for higher crash speeds than 35 mph. I asked about it at least two times. And, at one point, someone from the trucking industry raised the concern about deceleration forces causing injury at higher speeds.
This is an issue which pushes my button and I have written about it in the past. It was bothering me after the Underride Roundtable, and I emailed some people about it. This is what I sent to them:
I would like cleared up, once and for all, the misconception — if it is one — that deceleration forces would cause unintended injuries if the guards were made too strong. It pushes my button when I hear someone authoritatively say it — when I’m not sure that they are basing it on anything other than hearsay. I appreciated what Aaron Kiefer said in response to the comment made at the Roundtable about this and I would like it addressed so that it does not remain as one of the obstacles to more effective protection.
I had asked several people in the public health/injury prevention fields to attend but mostly they thought that underride was not their area of expertise. I, on the other hand, am convinced that we need the public health/medical people providing input.
As I have said many times, what people in the industry are saying does not make sense to me on many levels, including the fact that I survived a horrific truck crash and did so, as far as I am concerned, because I did not experience PCI/underride myself. I had many months of limping and leg cramps at night and painful neck and back tension probably due to whiplash and traumatic muscle memory. But that is all gone now and physically I am in great shape.
If your eyes are glazing over from my endless posts on truck safety, this one is a little different. Dawn King, president of the Truck Safety Coalition, lost her dad in a truck crash. She talks here about what she saw and experienced at the amazing Underride Roundtable on May 5, 2016. Thanks for sharing, Dawn.
