Tag Archives: underride guards

Speed Limiters: The Controversy of Speed Differentials Between Trucks & Cars

The DOT recently published a proposed rule to require “speed limiters” on trucks — meaning there would be technology on trucks to limit how fast they could run. There is, of course, controversy about this proposed safety measure.

See the proposed rule (NPRM) at this link: U.S. DOT Proposes Speed Limiters For Large Commercial Vehicles

The American Trucking Associations (ATA) supports it. Some major trucking companies already use them.

The Owner-Operator Independent Drivers Association (OOIDA) opposes it:  Among the various concerns the organization has are the possibility that truckers will speed more often in low-speed areas, such as construction zones, to make up time, and the potential for drivers to lose money because they couldn’t drive as many miles in a day. http://ht.ly/e2Hy303DTS0

According to Joel Stocksdale, Autoblog,

NHTSA’s proposal says vehicles with a gross vehicle weight rating of 26,000 pounds or more must be limited to 60, 65 or 68 mph. This would apply to both semi-trucks and buses. NHTSA explains that the amount of force a truck will exert in a crash goes up far more drastically than with cars because of the vehicle’s great mass; hence, a lower speed limit with more seriously impact safety. US Transportation Secretary Anthony Foxx summed it up saying, “This is basic physics.” The organization also said that requiring limiters could also save over $1 billion in fuel each year.

I have corresponded with one independent truck owner-operator, Jeff Halling (and Linda, his wife–a truck driver team), about this safety issue (among others). This is what he says,

  • Personally Linda and I think this is a terrible idea. Not because we want to drive 80 miles an hour but because it totally eliminates our advantage of getting out of a situation if we have to speed up a little bit. Every credible study that has ever been conducted says traffic flows better when everyone is running the same speed. Several states have actually increased the truck speed to coincide with that of cars. Illinois and Arkansas being the most recent. Folks driving cars generally drive anywhere from 5 to 10 to 15 miles an hour above the posted limit. Trucks stuck at 65 will create major rear-end hazards. Not to mention the incredible traffic jams and road rages that will increase dramatically. The only way speed limiters will work is if all vehicles have them and we both know that’ll never happen. Very interested to see what the report says this week.
  • Can you imagine how this will affect the Move Over Law. I’m running down the interstate stuck at 65 cars are running 80 and 85 miles an hour. An emergency vehicle is on the shoulder in front of me what do I do. If I move over it’s guaranteed rear-end crash. If I slow down to 40 miles an hour which is what they recommend another possibility of rear-end crash. Just not a good idea.
  • I can say this though. If this law does pass we definitely need to get stronger rear end guards on trailers. Because rear-end crashes will go up ten fold.

Jeff and his wife (they are a trucking team) recently had a good conversation, about truck safety concerns, with an Idaho DOT vehicle inspector while they were being inspected. This is what he told them:

  • While we never touched on the subject of speed limiters he did say he did not like speed differentials. Although we got the impression he wanted to lower the limit for cars not raise it for trucks. Makes sense everybody drives too damn fast.

In fact, I found a September 2004 Federal Highway Administration (FHWA) article on research related to this topic: The Safety Impacts of Differential Speed Limits on Rural Interstate Highways . They study the impact of Uniform Speed Limits (USL) and Differential Speed Limits (DSDL). Here are a couple of quotes from that article:

  • A 1974 study by Hall and Dickinson showed that speed differences contributed to crashes, primarily rear end and lane change collisions.
  • Table 1 shows that a higher proportion of car-into-truck and truck-into-car crashes occurred in USL States, except for rear end crashes where more car-into truck collisions happened in the DSL group.
  • A study by Garber and Gadiraju conducted in 1991 compared crash rates in the adjacent States of Virginia (DSL) and West Virginia (USL).(3) The increase in the posted speed limit for trucks to 105 km/h (65 mi/h) did not result in a significant increase in fatal, injury, and overall accident rates. There was, however, some evidence that the DSL may increase some types of crash rates while reducing others.

It will be some time before every car is equipped with crash avoidance technology, so cars rear-ending trucks will continue to be a problem and underride deaths will still be a problem until the underride regulation is drastically improved.

And, even with the crash avoidance technology, what will be the result of high speed differentials? Will the cars truly avoid colliding with the truck? Will the trucking industry be required to protect against underride at higher speed collisions than what is currently proposed: 35 mph?

Here is a previous post which I wrote on speed limiters last spring:

See why truckers oppose Speed Limiters & why others promote them #VisionZero strategy needed

How is it that I, as a self-made (Ha! like I had a choice) safety advocate, am waffling on this purported safety measure? Do these things ever get a truly comprehensive discussion around the table?

Talkin together

Yet one more traffic safety issue which could perhaps be more effectively negotiated with the help of a National Traffic Safety Ombudsman. . . just sayin’.

UPDATE, February 26, 2017:

Why would we suppress available technology that could be put to use to protect innocent lives?

Call on the Lord. Trust in Him. Rely on His strength.
41b AnnaLeah armor
The Battle is the LORD’s!
Surely it would be His will for available technology to be put to use to protect innocent lives.
 
Then Asa called to the LORD his God, and said, ‘Lord, there is no one besides Thee to help in the battle between the powerful and those who have no strength; so help us, O LORD our God, for we trust in Thee, and in Thy name have come against this multitude. O LORD, Thou are our God; let not man prevail against Thee.’
2 Chronicles 14:11
Car Safety Wars11wjd2Gertie reaching for Mary ...Susanna's film25 AnnaLeah Jesus Loves Me 052
Trip North May 2015 138IMG_4467

Truck Underride Tragedies Need to End; Enough is enough!

I recently asked DOT for a breakdown of truck underride deaths by type: front, side, and rear. Yesterday, they sent a chart of Underride Fatalities from the Fatality Analysis Reporting System (FARS)–taken from crash reports submitted to DOT:

From 1994 to 2014, this is the breakdown of Deaths by Underride:

Collision at Front of the Truck: 625

Collision at Side of the Truck: 1534

Collision at Rear of the Truck: 1715

Collision Site Unknown: 132

Total Underride Deaths Reported: 4,006

Truck Underride Deaths by TYPE 1994-2014

Of course, we need to remember that these figures do not include all underride deaths, as it is well-known that they are commonly under-reported. In fact, this chart does not include underride crashes which happened when the truck was parked. When we include those types of crashes, the FARS records yield 5,081 underride deaths in that same time period.

Truck Underride Fatalities, 1994-2014

I have known for some time that there are many deaths due to side underride crashes. But to find out that there are almost as many deaths from side underride as rear underride?! How can NHTSA require rear underride guards and yet not mandate side underride guards? How can they possibly justify that? (Some kind of convoluted cost/benefit analysis, I suppose.) And why are trucks even sold without side guards?

The question must be asked: Whom shall we hold responsible for those 4,006+ deaths (and those not reported as underride deaths), along with the people who died before 1994? The government? The trucking industry? Ourselves for letting it happen in our ignorance or apathy? All of us?

And what about now–today? Will we hold those, who have the authority to act, accountable to do the right thing? Will we demand that they move ahead quickly to correct this tragic and unimaginable situation? Will we make sure that all trucks have the best possible underride protection?

Well?!

Mangled

our mangled Crown Vic on May 4, 2013

Life & DeathIf only

Sign our petition to NHTSA to initiate rulemaking on side guards: Mandate Side Guards On Large Trucks To End Deadly Side Underride Crashes

Demand that we act compassionately to preserve human life rather than protect profit. Otherwise, if we knowingly allow this to continue unabated, will we all be accessories to murder?

Two of the thousands we have lost:

 

Truck Underride Deaths (by type) from DOT Fatality Analysis Reporting System (FARS) 1994-2014

I asked DOT for a breakdown of truck underride deaths by type: front, side, and rear. I just received that chart today.

Truck Underride Deaths by TYPE 1994-2014

From 1994 to 2014, this is the breakdown of Deaths by Underride:

Collision at Front of the Truck: 625

Collision at Side of the Truck: 1534

Collision at Rear of the Truck: 1715

Collision Site Unknown: 132

Total Underride Deaths Reported: 4,006

Of course, we need to remember that these figures do not include all underride deaths as it is well-known that they are commonly under-reported.

So why are trucks sold without side guards? (Why on earth would this be an optional feature?!) And why does NHTSA not mandate side guards?

Sign our petition to NHTSA to initiate rulemaking on side guards: Mandate Side Guards On Large Trucks To End Deadly Side Underride Crashes

Save Lives

Posts on Side Underride

Who has the right to block efforts to end Preventable Death by Underride?

I just got back from an errand. Something triggered a memory of AnnaLeah & Mary. I think that it was driving by a park here in Rocky Mount to which Mary and AnnaLeah never got to go. We had lived here less than a year before the crash.

It made me wonder (as I do so often) what they might be doing right now. How  might their lives have unfolded?

All my anger poured out, about how they have been cheated and how wrong it all is. I was yelling in my car, “Who gave power to the trucking industry over life & death matters?  Who has the right to block efforts to end Preventable Death by Underride?”

And that is only one of the many safety issues involved.

Yesterday I was frustrated with the whole side guard issue and the well-known under-reporting of side underride fatalities (in fact, of all types of underride). As far as I can tell, it has contributed to more underride victims as a direct result of the inaccurate cost/benefit analysis that has taken place.

Of course — in case you didn’t already know — I think that the whole cost/benefit analysis basis of safety rulemaking is flawed and unethical and needs to be re-examined. I have clearly laid out my thoughts on this in a drafted Vision Zero Executive Order.

Two more areas which make me concerned — because they do not seem to be taking into account the whole picture — are:

  1. Hours of Service (Have truckers been asked what they think would work best?) and
  2. Speed Limiters (What will truckers do when they need to speed up to get around someone but their speed limiter technology will not allow it? And speed limiters will not change situations where drivers cause crashes because they are driving “too fast for conditions.”)

One trucker, Jeff Halling, recently said to me (regarding speed limiters),

“Can you imagine how this will affect the Move Over Law? I’m running down the interstate stuck at 65 cars are running 80 and 85 miles an hour. An emergency vehicle is on the shoulder in front of me. What do I do? If I move over, it’s guaranteed rear-end crash. If I slow down to 40 miles an hour, which is what they recommend, another possibility of rear-end crash. Just not a good idea. I can say this though, If this law does pass we definitely need to get stronger rear end guards on trailers. Because rear-end crashes will go up ten-fold.”

Both of these situations — in my mind — need someone to facilitate rulemaking who has only safety in mind. Such as a Traffic Safety Ombudsman.

And, one more thing. . .  the pervasive idea in this country has to be confronted that it is an inevitable and acceptable risk you take when you drive on the roads, instead of understanding that there are so many things which could be done to prevent crash deaths.

Who has the power

Front Override Truck/Car Crash Fatalities Need Attention, Too

After hearing about a recent underride crash fatality which appears to be a front override crash, I looked into this underride issue which we still need to address.

Here is the recent crash: Austin Police ID Woman Killed In Wrong-Way Crash

Briefly, here are some things about front override crashes, which is what happens when the front of a truck rides over a car.

Front Override 008

Clearly, front override is another deadly problem which has solutions. What are we waiting for?

Negotiated RulemakingFront underride 002

How can this country continue to turn a cold shoulder to preventable crash deaths?

How can this country continue to turn a cold shoulder to preventable crash deaths? It is so easy to point the finger of blame and not participate in solving the problem ourselves. And it is equally easy to act like it is just a risk that travelers take — and there is nothing that can be done about the problem!

This is a recent comment from a reader (which I did NOT approve to be published on our website) on a post which I wrote related to the Tesla side underride fatal crash:

“This Proves that the Autonomous vehicles are not ready for use. Only an Imbecile would have made millions of truck owners spend thousands to millions because a few Idiots refuse to be Attentive drivers . The time for the Autonomous car is not here ,and the Whole idea needs to be SCRAPED”

And here is another:

“Here’s a novel idea. Require drivers of cars to PAY ATTENTION TO THE ROAD! Ban self driving cars or anything else. The autopilot system failed. It did not recognize the white side of the trailer. It failed to distinguish between the trailer and the sky. Stop trying to put extra burden on the trucking industry. Learn to actually drive. Take a defensive driving course . Don’t rely solely on technology . Relearn to use your brain.”

Either orCar Safety Wars

How can my daughters be gone. . . how did it come to this, that innocent lives would be required to pay the price for this travesty?

CBA Victim

Cost Benefit Analysis Victim

I am thankful that there are many who are working on the problem of preventable crash deaths and I pray that we can make tangible progress — despite the evidence that opposition continues.

Traffic Safety Ombudsman Petition: End Preventable Crash Fatalities: Appoint a National Traffic Safety Ombudsman

When Will We Tackle Underride? – The Hidden Dangers in Trucks

Is it ethical to not use safety technology which could save human lives?

“When Will We Tackle Underride? – The Hidden Dangers in Trucks” Trucks.com Opinion Piece

I enjoyed working with Jerry Hirsch, the editor of Trucks.com, to prepare this fact-based opinion column on the truck underride issue.

When people learned of the recent fatal crash in Florida of a Tesla Model S running in its Autopilot mode, many started questioning the safety of autonomous driving features in the newest cars.

While this is a legitimate topic of debate, for now autonomous driving presents little threat to those on the road. It comes on just a handful of expensive luxury models, and there’s only a small chance that the car driving next to you will have a robot at the controls.

However, the tragic Tesla crash does highlight a real and present highway danger — cars sliding underneath large trucks when vehicles collide. Regardless of who was at fault in the Tesla crash, the driver might have lived if the truck had been required to have side guards that would have prevented the electric sports sedan from wedging underneath the trailer.

I know just how dangerous collisions like this can be.

My youngest daughters, AnnaLeah and Mary, died in 2013 in a truck rear underride crash.

Read more here: https://www.trucks.com/2016/08/10/trucks-underride-hidden-danger/, “When Will We Tackle Underride? – The Hidden Dangers in Trucks” by Marianne Karth, August 10, 2016, Trucks.com

If only

You can help. Sign & share our petition asking DOT to mandate side guards on truckshttp://www.thepetitionsite.com/104/026/213/mandate-side-guards-on-large-trucks-to-end-deadly-side-underride-crashes/

Underride Roundtable Led to Recommendations Submitted as a Consensus Public Comment to NHTSA

The Underride Roundtable at the Insurance Institute for Highway Safety on May 5, 2016, has led to a Consensus Document outlining recommendations for improvement in the federal standards for rear underride guards on semi-trailers. The following Public Comment was posted on regulations.gov/The Federal Register on August 8, 2016:

August 6, 2016

The Honorable Mark R. Rosekind, Ph.D. Administrator
National Highway Traffic Safety Administration
1200 New Jersey Avenue, SE
Washington, DC 20590

Federal Motor Vehicle Safety Standards 49 CFR Part 571, Rear Impact Guards, Rear Impact Protection; Notice of Proposed Rulemaking; Docket No. NHTSA-2015-0118

Dear Administrator Rosekind:

On May 5, 2016, almost 100 people participated in an Underride Roundtable hosted by the Insurance Institute for Highway Safety at their Vehicle Research Center in Ruckersville, Virginia, with co-sponsors Truck Safety Coalition and AnnaLeah & Mary for Truck Safety. Participants included researchers, safety advocacy groups, the trucking industry, truck trailer manufacturers and government officials, including members of NHTSA staff. Discussions during the meeting ranged from descriptions of the nature and magnitude of the underride problem to potential solutions including better conspicuity, new rear underride guard designs and the potential for side guards to prevent run-overs of pedestrians and cyclists in urban environments. The information shared during our meeting clearly illustrated the need to do more to address underride crashes as well as the possibility of doing so.

During the meeting IIHS conducted a 35 mph 30 percent overlap frontal crash test of a midsize car into the new and improved rear underride guard available on trailers manufactured by Stoughton. The guard prevented underride and occupant compartment intrusion thereby becoming the 4th major trailer manufacturer to offer guards capable of preventing underride at 35 mph in all 3 configurations tested by IIHS – full overlap, 50 percent overlap and 30 percent overlap (press release). These 4 manufacturers – Manac, Stoughton, Vanguard and Wabash – represent nearly 40 percent of the truck trailer market in the United States. IIHS crash tests indicate that a higher level of underride protection is possible and the March announcement (press release) that J.B. Hunt Transport Services, Inc. ordered 4,000 trailers with the new Wabash RIG-16 Rear Underride Guard System indicate that better guards are not an impediment to the service trailers provide.

Subsequent to the Underride Roundtable, all participants were invited to attend a follow-up meeting at the IIHS office in Arlington, Virginia. On June 24, 2016, thirteen people representing different points of view met to formulate updated recommendations for NHTSA’s consideration as it deliberates the proposed upgrade of FMVSS 223. Adopting the Canadian Motor Vehicle Safety Standard 223 will do little to advance underride protection because trailer manufacturers already are fitting guards that meet this standard and IIHS testing illustrates that greater levels of strength are needed to address the full range of potential impact zones between the vehicle and rear of the trailer. We believe that incorporating the following recommendations in its final rule will help prevent the senseless loss of lives associated with crashes into the rear of heavy trucks.

*      *      *      *      *      *      *      *      *      *      *      *      *     *     *     *     *     *     *     *     *     *     *

1. The revised FMVSS 223 should require guards that are strong enough to allow the inherent crashworthiness of modern passenger vehicles to be realized. Specifically, guards should prevent underride and occupant compartment intrusion when struck by a typical passenger vehicle at 35 mph with overlaps ranging from 30 percent of the passenger vehicle’s width to full overlap between passenger vehicle and truck trailer. Tests of trailers from Manac, Stoughton, Vanguard, and Wabash illustrate the practicability of providing the level of underride protection described above.

2. It should be possible to prescribe a regulatory test procedure based on quasi-static loading and minimum force levels that will lead to guards capable of providing the same or better level of underride protection as demonstrated by guards on Manac, Stoughton, Vanguard and Wabash trailers.

3. The underride guard and trailer structure are a system. As such, compliance testing of rear impact guard strength should be conducted with the guard attached to the trailers and/or a portion of it that includes all structures to which the guard attaches.

 

This consensus document was signed by the following individuals:

Respectfully submitted,
David Zuby, Chief Research Officer
Insurance Institute for Highway Safety

Gary Fenton, VP of Engineering
Stoughton Trailers

Aaron Kiefer, Consulting Engineer
Accident Research Specialists

Paul Hutson,
ECU engineering student & intern with Aaron Kiefer

Jared Bryson, SR Mechanical Systems Group Leader
Virginia Tech, Center for Technology Development

Perry Ponder, President
Seven Hills Engineering

Raphael Grzebieta, Professor of Road Safety & Australian Naturalistic Driver Study
Lead Chief Investigator (Maintains that dynamic crash testing is preferable to quasi-static testing)

Andy Young, Attorney
Nurenberg, Paris, Heller & McCarthy Law Firm

Jerry Karth, AnnaLeah & Mary for Truck Safety
Father of Underride Victims AnnaLeah & Mary Karth

Isaac Karth, AnnaLeah & Mary for Truck Safety
Brother of Underride Victims AnnaLeah & Mary Karth

Marianne Karth, AnnaLeah & Mary for Truck Safety
Mother of Underride Victims AnnaLeah & Mary Karth

Robert Martineau,
Airflow Deflector

Roy Crawford, PE, Forensic Engineer
Father of Underride Victim Guy Crawford

Stephen A. Batzer, Ph.D., P.E.
Batzer Engineering

Bruce E. Enz
Injury & Crash Analysis, LLC

Ashley McMillan
Girlfriend of Underride Victim Michael Higginbotham

Randy and Laurie Higginbotham
Parents of Underride Victim Michael Higginbotham

Tamara Brininger, Paralegal & Community Initiatives Coordinator
Nurenberg, Paris, Heller & McCarthy

Austin Brininger, Engineering Student

Louis Lombardo
Care for Crash Victims

See a pdf of the recommendations here: Underride Roundtable Consensus Comment NPRM_ Docket No. NHTSA-2015-0118

Here is a link to the Underride Consensus Public Document on regulations.gov: Consensus Comment on the National Highway Traffic Safety Administration (NHTSA) Proposed Rule: Rear Impact Guards, Rear Impact Protection

Roads SaferBest Protection

One more very important thing, please sign the just-launched petition requesting NHTSA to mandate SIDE GUARDS on large trucks: http://www.thepetitionsite.com/104/026/213/mandate-side-guards-on-large-trucks-to-end-deadly-side-underride-crashes/

IIHS does valuable work to advance vehicle safety through crash test ratings. Large trucks included.

Here’s a recent article on the value of IIHS challenges to automotive companies: Safety institute seeks balance in frontal crash tests

The challenge mentioned here is for car companies to address the need for occupant protection on the passenger side as well as the driver side in frontal crashes. Duh!

As a mom of nine — although they are now grown — it seems commonsense to me to provide occupant protection throughout the entire vehicle! Including protection for passengers from seatback failures.

I am thankful for the valuable work which the Insurance Institute for Highway Safety does to advance vehicle safety through their crash test ratings. That includes large trucks.

I hope to see a 5-star crash rating system for the underride protection system on large trucks soon. It could mean the difference between life and death for someone.

IMG_4464If onlyUnderride Roundtable May 5, 2016 008Underride Roundtable May 5, 2016 007Roundtable Display TableUnderride Roundtable May 5, 2016 169Underride Roundtable May 5, 2016 080Underride Roundtable TimelineButterfly girls and birds 013Never forgotten