Tag Archives: underride guards

What would a DOT Vision Zero policy look like in actual implementation?

AnnaLeah and Mary, Truck Safety, , , ,

In our petition, we have asked for a paradigm shift in how truck underride guards are regulated. This means that, instead of using a force-based design rule, DOT would require performance-based standards. In other words, when a manufacturer designs an underride protection system for a truck, they would have to crash test it and prove that it could actually withstand a crash.

And we want that to be true for higher speeds than currently required and for impact all along the back of the truck–not just at the center but also at the edges (where the guards currently fail in the majority of crashes). And then, we also want side guards to be a requirement.

A Vision Zero rulemaking policy would mean that Saved Lives would win out over dollars in decisionmaking. In contrast, look at what DOT decided about underride guards in  1974:

  • 1974 US Secretary of Transportation says deaths in cars that underride trucks would have to quadruple before underride protection would be considered cost beneficial.  (History of federal rulemaking on underride guards:  https://annaleahmary.com/underride-guards/ )

In fact, there have been many engineers over the years who have insisted that the guards were weak and ineffective and that stronger guards could be designed. Here are four examples of Vision Zero principles being applied by engineers who are currently hoping to design and/or promote more effective underride protection which would actually save lives:

  1. George Rechnitzer & Raphael Grzebieta, engineers in Australia with whom we have been in contact, have proposed performance-based standards and have done extensive underride research:  NHTSA-Docket-Submission-Grzebieta&Rechnitzer 20 Sept 2015 (or in the Federal Register Public Comments on underride protection for single unit trucks: http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0021)
  2. Dean Sicking, an engineer at the University of Alabama, who designed NASCAR’s SAFER Barrier to save lives and is confident that he could apply those principles to underride protection. Here is the research proposal which he has given to us and for which we are raising money so that he can do it!  Development of Trailer Underride Preventive Measures
  3. Aaron Kiefer, a forensic engineer/crash reconstructionist, who has been motivated by the tragic, preventable crash deaths which he witnesses in his work, to design an innovative underride protection system which combines side & rear guard components. We have met him and were able to go see a prototype of his invention on a semi-trailer.  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0013
  4. IIHS has researched and petitioned for improved underride protection for many years: http://www.iihs.org/externaldata/srdata/docs/sr4907.pdf

For further information about Vision Zero, see these additional posts:  https://annaleahmary.com/tag/vision-zero/

 

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

Petition screenshot 021

 

A Quest for the Best/Support Underride Research: Donate Now  https://www.fortrucksafety.com/

Underride Research Meme

Urge DOT to Adopt a Vision Zero Policy: Save Lives Not Dollars

AnnaLeah and Mary, Truck Safety, , , , ,

On average, 40,000 people die each year in crashes.  Currently, the Department of Transportation makes highway safety rules based upon how much safety measures will cost. We are hoping to change that and promote a Vision Zero safety strategy model with goals of Zero Deaths, Zero Injuries, Zero Fear of Traffic.

MV-TRAFFIC-FATALITIES(1899-2009)

One of the biggest challenges to making change is the cost/benefit analysis. On the one side there are lives to be saved and on the other side there are companies working to make money. The trick is to try and meet everyone’s needs. The solution has to be effective in saving lives while still being affordable for companies so that they can make the changes necessary without a lot of struggle.

The problem comes in when human life and health get the short end of the stick. The result is that many safety measures are stopped because they would cost more to implement than the “worth” of the “small” number of human lives which would be saved. That’s just not right.

After losing two daughters in a truck underride crash on May 4, 2013, our family made a positive impact one year later by taking over 11,000 signatures on our AnnaLeah & Mary Stand Up For Truck Safety Care2 Petition to DOT in Washington, DC. And we have set up a non-profit to promote highway safety research and federal regulations to protect motorists, pedestrians, & cyclists.

Sign our new petition to let DOT Secretary Anthony Foxx know that we want him to:

1. Change rulemaking policy to move away from an economic-rationalist cost/benefit model and adopt a more humanistic, rational Vision Zero safety strategy model. “Vision Zero states that the loss of human life and health is unacceptable and therefore the road transport system should be designed in a way that such events do not occur.” http://tinyurl.com/9uhzyux

2. Apply Vision Zero principles by requiring crash test-based performance standards for truck underride guards rather than force-based design standards along with success at higher speeds—to include rear (both centered and offset) and side guards for both Single Unit Trucks and trailers.

3. Apply Vision Zero principles by requiring NHTSA to initiate rulemaking to require forward collision avoidance and mitigation braking (F-CAM) systems on all new large trucks and buses with a gross vehicle weight rating of 10,000 lbs. or more.

Please sign & share this petition in memory of AnnaLeah & Mary
and make the roads safer for us all:   http://www.thepetitionsite.com/417/742/234/save-lives-not-dollars-urge-dot-to-adopt-vision-zero-policy/

For more information: https://www.fortrucksafety.com/

Public Comments Updated for Underride Guards on Single Unit Trucks

Truck Safety, ,

New comments were added yesterday to the Public Comments on the ANPRM for Underride Protection on Single Unit Trucks.

DOCUMENT ID:    NHTSA-2015-0070-0049 (http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0049)
DOCUMENT TYPE:  PUBLIC SUBMISSIONS
POSTED DATE:    09/28/2015
DOCUMENT TITLE: District Department of Transportation – Comments

DOCUMENT ID:    NHTSA-2015-0070-0050 (http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0050)
DOCUMENT TYPE:  PUBLIC SUBMISSIONS
POSTED DATE:    09/28/2015
DOCUMENT TITLE: New York City Department of Transportation – Comment

DOCUMENT ID:    NHTSA-2015-0070-0051 (http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0051)
DOCUMENT TYPE:  PUBLIC SUBMISSIONS
POSTED DATE:    09/28/2015
DOCUMENT TITLE: Anonymous

DOCUMENT ID:    NHTSA-2015-0070-0052 (http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0052)
DOCUMENT TYPE:  PUBLIC SUBMISSIONS
POSTED DATE:    09/28/2015
DOCUMENT TITLE: Tom Maguire – Comment

DOCUMENT ID:    NHTSA-2015-0070-0053 (http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0053)
DOCUMENT TYPE:  PUBLIC SUBMISSIONS
POSTED DATE:    09/28/2015
DOCUMENT TITLE: Kit Keller – Comment

DOCUMENT ID:    NHTSA-2015-0070-0054 (http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0054)
DOCUMENT TYPE:  PUBLIC SUBMISSIONS
POSTED DATE:    09/28/2015
DOCUMENT TITLE: Brendan Kearney – Comment

DOCUMENT ID:    NHTSA-2015-0070-0055 (http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0055)
DOCUMENT TYPE:  PUBLIC SUBMISSIONS
POSTED DATE:    09/28/2015
DOCUMENT TITLE: Seven Hills Engineering, LLC – Comment

DOCUMENT ID:    NHTSA-2015-0070-0056 (http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0056)
DOCUMENT TYPE:  PUBLIC SUBMISSIONS
POSTED DATE:    09/28/2015
DOCUMENT TITLE: National Propane Gas Association – Comment

Truck industry, engineers & safety advocates comment on Truck Underride Protection for motorists, pedestrians & cyclists

AnnaLeah and Mary, Truck Safety, , ,

The Public Comment Period is Closed now for the Advanced Notice of Proposed Rule Making for Underride Protection of Single Unit Trucks. I appreciate those who took the time to comment and I look forward to in-depth dialogue among these people and organizations at our Spring 2016 Underride Roundtable. You can find their published comments here:  http://www.regulations.gov/#!docketDetail;dct=FR+PR+N+O+SR;rpp=10;po=0;D=NHTSA-2015-0070

These include comments from:

With funds which we raise for underride research, we are hoping to cover the costs of the crash test for the innovative combined side & rear guard designed by this engineer, Aaron J. Kiefer MSME, PE . See his Comment:  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0013

And we have been in correspondence with these two engineers in Australia who have researched solutions to deadly underride for 30 years.  Transport and Road Safety (TARS) Research Centre . See their Comments:  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0021  & my posts on them:  https://annaleahmary.com/2015/09/australian-engineers-champion-the-cause-of-better-truck-underride-  protection/

Contrast their comments to the conclusion of the NTEA: “Based on the published data and expected benefits, there is no justification for requiring rear underride guards on single unit trucks.” Maybe they ought to watch this video from Australia.

Someone in Australia was asked this question: “So last year, 249 people died on our roads. What do you think would be a more acceptable number?”

See what he answered:

IIHS October 2014 Status Report CoverBefore & After Photos

Cover of IIHS Status Report on guards; photos of our car before/after

Support Underride Research to Prevent Unnecessary Deaths & Injuries.

Donate Now: https://www.fortrucksafety.com/

Request for Extension of Public Comment Period on Single Unit Truck Rulemaking Process

AnnaLeah and Mary, Truck Safety, , , , , ,

After hearing that several groups were hoping that they could have more time (beyond the current deadline of September 21) to prepare a Public Comment on the Advanced Notice of Proposed Rule Making (ANPRM) on Underride Protection of Single Unit Trucks, I contacted NHTSA and filed a request to extend the Public Comment period.

The agency replied that they are considering my request. It usually takes at least 10 calendar days for such a process. I hope that this helps with providing useful information but does not lead to unnecessary delay of the needed rulemaking.

Trip North May 2015 035

Photo by me of a Single Unit Truck I saw on the expressway a few months ago.

Note the wimpy rear underride guard.

Donate now & support Underride Research to Prevent Underride and Save Lives:  https://www.fortrucksafety.com/

Innovative combined side & rear guard promises better underride protection

AnnaLeah and Mary, Truck Safety, , , ,

One of our Underride Research funding goals is to cover the costs of crash testing at IIHS ($25,000) of an innovative underride prevention system designed by Aaron Kiefer, a forensic engineer (he does crash reconstructions) here in North Carolina. Jerry and I went to see his prototype a few weeks ago. Very cool. It combines side & rear guard protection.

See his Public Comment on the Advanced Notice of Proposed Rule Making (ANPRM) for underride protection on Single Unit Trucks posted today on the Federal Register:  http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0013

Underride guard design by Aaron Kiefer 059

Donate here to support crash testing to verify the effectiveness of Aaron’s vital invention: https://www.fortrucksafety.com/

Harvard School of Public Health posts comments in support of improved truck underride protection

Truck Safety, , , , ,

Latest post in The Federal Register for Public Comments on the Advanced Notice of Proposed Rule Making for underride protection on Single Unit Trucks (SUTS) includes comments on suggestions for side guards to protect cyclists:

http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0010

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

“One Family’s Quest to Improve Truck Safety” by Kevin Matthews at Care2 The Petition Site

AnnaLeah and Mary, Truck Safety, , ,

After the success of the AnnaLeah & Mary for Truck Safety Petition in 2014 on The Petition Site, we went back to Care2 where it was hosted online and gave them an update on our efforts. They decided to write an article on our safety advocacy efforts.

It was published this morning: http://www.care2.com/causes/one-familys-quest-to-improve-truck-safety.html .

I am thankful for the many people who are working together with us to make our roads safer.  We appreciate each one.

Public Comment Period ends September 21 for ANPRM on underride protection for Single Unit Trucks (SUTS)

AnnaLeah and Mary, Truck Safety, , ,

There have been some comments added to the Public Comments on the Federal Register for the Advanced Notice of Proposed Rule Making on rear underride protection for Single Unit Trucks (SUTS).

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

The Public Comment period is currently scheduled to end on September 21, 2015. We encourage you to add your comment to this process to indicate support for the inclusion of Single Unit Trucks in the requirements for underride protection.

Here are some suggestions on writing comments:  https://annaleahmary.com/2015/08/thoughts-on-making-a-public-comment-on-rulemaking-for-single-unit-truck-underride-protection-ends-september-21/

Also, please consider donating to our underride research effort.

Donate & Spread the Word using our new website for AnnaLeah & Mary for Truck Safety:  https://www.fortrucksafety.com/

Underride Research Meme

Underride Guards: a topic of conversation on TruckingInfo.com

AnnaLeah and Mary, Truck Safety, , , ,

Underride guards have been a topic of conversation over the months (many of them now since our crash) at TruckingInfo.com:

Why Better Underride Guards, and Maybe Other Stuff, Are Worth It
June 3, 2013,  http://www.truckinginfo.com/blog/trailer-talk/story/2013/06/why-better-underride-guards-and-maybe-other-stuff-are-worth-it.aspx

NHTSA to Issue New Rules on Underride Guards
July 11, 2014,  http://www.truckinginfo.com/channel/safety-compliance/news/story/2014/07/nhtsa-to-issue-new-rules-on-underride-guards.aspx

NHTSA to Upgrade Truck Underride and Conspicuity Rules
July 20, 2015,  http://www.truckinginfo.com/channel/fleet-management/news/story/2015/07/nhtsa-initiates-upgrade-of-truck-underride-and-conspicuity-rules.aspx

Crash Argues for Better Impact Guards, and Better Driving
August 14, 2015, http://www.truckinginfo.com/blog/trailer-talk/story/2015/08/rear-end-crash-argues-for-better-impact-guards-and-better-control-of-one-s-car.aspx

(Just a note: It doesn’t matter who is at fault in these kinds of crashes of a smaller vehicle into a larger truck; if the underride guards could prevent the smaller vehicle from riding under the truck, the tragedy of death and horrific injury could be avoided.)

Underride Research MemeSupport Underride Research/Donate Now: https://www.fortrucksafety.com/