Tag Archives: underride guards

“Responsibility in Engineering: Toward a New Role for Engineering Ethicists”

Safety Advocacy, Truck Safety, ,

Responsibility in Engineering: Toward a New Role for Engineering Ethicists

Traditionally, the management of technology has focused on the stages before or after development of technology. In this approach the technology itself is conceived as the result of a deterministic enterprise; a result that is to be either rejected or embraced. However, recent insights from Science and Technology Studies (STS) have shown that there is ample room to modulate technology during development. This requires technology managers and engineering ethicists to become more involved in the technological research rather than assessing it from an outsider perspective. Instead of focusing on the question whether or not to authorize, approve, or adopt a certain technology or on the question of who is to blame for potential mistakes, the guiding question in this new approach is how research is to be carried out.

Responsibility in Engineering: Toward a New Role for Engineering Ethicists by Neelke Doorn, Delft University of Technology, Delft, The Netherlands, n.doorn{at}tudelft.nl
and Jessica Nihlén Fahlquist, Delft University of Technology, Delft, The Netherlands, Royal Institute of Technology, Stockholm, Sweden

doi: 10.1177/0270467610372112
Bulletin of Science Technology Society June 2010 vol. 30 no. 3 222-230

Negotiated Rulemaking

Underride Roundtable led to Consensus Underride Recommendations for Submission to NHTSA

Safety Advocacy, Truck Safety, ,

Following the successful Underride Roundtable on May 5, 2016, a group of thirteen people pulled together a Consensus Comment for submission to NHTSA for their consideration.

Today, I emailed this document to the nearly 100 people who attended the roundtable — inviting them to read and sign this set of recommendations for the current rear underride rulemaking on semi-trailers.

Thank you again for participating in the Underride Roundtable hosted by the IIHS on May 5, 2016.

As a follow-up to that successful event, a subsequent meeting, to which you all were invited, took place on June 24 at the IIHS offices in Arlington, Virginia. A smaller group participated in that meeting and were able to put together a Consensus Document which we will be submitted to NHTSA as a Public Comment.

Here is a post with a report on that meeting: Knights of the Underride Roundtable: Finding Some Common Ground to Protect Travelers!

NHTSA has indicated to me that they, “look forward to your recommendations and encourage your continued submissions to the public dockets on NHTSA’s rulemakings on truck underride safety, specifically Docket No. NHTSA-2015-0070 for NHTSA’s rear underride protection for single-unit trucks. . . and Docket No. NHTSA-2015-0118 for NHTSA’s rear underride protection for semi-trailers. . . As with all of our public proceedings, we will give all comments full consideration to help inform our next actions.”

The Consensus Document specifically addresses the NPRM for semi-trailers. Please review the attached document and, if you agree with the Consensus Recommendations and would like to add your name to this document, please let me know by August 6, 2016. I will be submitting this as a Public Comment at the end of that day.

I look forward to continued positive communication among us all.
Marianne

p.s. Please read the attached Consensus Comment document, as well as the press release which is referred to in the document: Press Release: J.B. Hunt Transport Services, Inc. Orders 4,000 Trailers with New Rear Impact Guard Design

NOTE to non-engineers: This would make the NHTSA’s proposed rule stronger — yielding underride guards which should be able to withstand crashes at the outer edges of the trucks. Translation = Save More Lives

Here is the Consensus Document: Consensus Comment NPRM_ Docket No

I will welcome all signatures — whether you were able to participate in the Underride Roundtable or not.

Car Safety WarsMichigan 60 party and cemetery 039IMG_4465If only

Mary would have turned 17 on August 6.

Adopting needed safety technology should not have to be such a battle. Why is it then?

Safety Advocacy, Truck Safety, ,

The Best Possible Protection

Studies have been done which show that trucks, even if they are equipped with rear underride guards, do not pass all of the crash tests. In fact, out of 8 truck companies tested, only one, Manac, passed all of the tests: http://www.iihs.org/news/rss/pr031413.html .

So, it may be a true statement, according to The American Trucking Association, “that many manufacturers are producing trucks with better than required safety underride guards.”http://myfox8.com/2013/08/13/families-push-for-tractor-trailer-regulations/ Nonetheless, the bottomline is that there are many trucks which are NOT equipped with the best possible protection, which means that someone somewhere sometime might crash with one of those trucks and not live to know it.

Why would there be resistance to providing the best possible protection? Is it money? Quite possibly… Yet, according to Manac President Charles Dutil, the Manac underride guard “doesn’t weigh 200 pounds more than anybody else’s; it doesn’t cost $200 more,” estimating the difference to be at most 20 pounds and $20.

“If trailer manufacturers can make guards that do a better job of protecting passenger vehicle occupants while also promising lower repair costs for their customers, that’s a win-win,” says David Zuby, the Insurance Institute for Highway Safety’s chief research officer. https://www.youtube.com/watch?v=OhQdYSSEJO8

What I want most of all, in this situation, is to help reduce the number of families who open their mail to find a death certificate for a family member because of a preventable death.

death certificate envelopes

NOTE: I wrote the above as a facebook post just a few months (August 14, 2013) after the crash which took AnnaLeah and Mary from us. Since then, almost three years later, three more trailer manufacturers have voluntarily improved their rear underride protection.

But there are four major manufacturers who have not and federal underride standards have not yet been improved. And then there are side guards and exempt single unit (straight, box) trucks which still need to be addressed. Not to mention the 12 million existing trucks on the road which probably won’t be required to be retrofitted with improvements.

Meanwhile people continue to die. Needlessly.

The Best Possible Protection

Adopting needed safety technology should not have to be such a battle. Why is it then?

Too Often, Too Little, Too Late; A Conspiracy of Silence

 

Preventing deadly crashes doesn’t require Either crash avoidance Or underride guards but Both/And.

Safety Advocacy, Truck Safety, , , ,

If we can take away anything immediately (while waiting for an in-depth investigative report) from Joshua Brown’s fatal crash with his Tesla, I hope it is the understanding that preventing Death by Underride cannot depend solely on crash avoidance technology. What we should be going for is not either/or but both/and.

The Tesla did not prevent the crash because the side of the truck was too high up to engage/connect with any of the safety technology. Had a side guard — which is not a federal requirement — been on the truck, there might have been no crash or at least no underride. Joshua Brown might still be alive.

This is a clear case where even the most-advanced crash avoidance technology was not able to prevent a tragic underride death. If side guards had been mandated and installed, perhaps the outcome would have been quite different.

There are too many factors and conditions which can result in a collision between a large truck and a smaller passenger vehicle. And without adequate underride protection, the smaller vehicle is going to end up under the larger, too-high truck so that the crashworthy features of the car do not function as intended. The truck then comes into the occupant space [Passenger Compartment Intrusion = PCI] — causing horrific death or serious injuries.

My goodness, it makes me mad just to re-read the posts which I have written over the last three years since our deadly (for those who experienced underride) crash and recall the ongoing attitude of non-responsibility of some parts of the trucking industry to do their part in helping to solve this solvable problem!

I have included the links to those posts along with the beginning paragraphs:

  1. Clarifying the ATA Position on Underride Guards After last week’s announcement by NHTSA of their initiation of the rulemaking process for underride guards, I have had four interviews. So far, I have seen two of the articles and both of them included a statement, obtained from the American Trucking Associations (ATA), which disturbed me when I read them. I posted about it and you can read my thoughts here. . .
  2. The Passion of This Safety Advocate It gets really tiresome to hear the trucking industry come up with the same statements time after time after time. Nearly every time I read an article written about our crash, there are the obligatory responses from the trucking industry. Invariably, they try to shift the responsibility off of themselves to make the changes sought after and, instead, bring up some alternative solution to the “problem.” . . .
  3. Truck Underride Roundtable is one week away! May it be sehr gut! On June 25, 2014, after a tour of the research & design center of a truck trailer manufacturer in Georgia, I wrote down these perplexing thoughts about the too-long unresolved underride problem: Now, it is understandable, amid the multitude of demands and the tyranny of the urgent, that—without a ready solution, in fact, one which would require time and money to develop—this problem has not been given much attention. But, if those who bear responsibility for making sure that this problem gets solved (one way or another) had lost two of their beloved children—or any other loved one—I can guarantee you that they would have moved heaven and earth to find a way to prevent underride. . .
  4. UMTRI Reviews Opposition to Proposed & Proven Truck Underride Prevention Measures Back in 1989, the University of Michigan Transportation Research Institute examined features proposed for improving truck safety. In other words, they reviewed NHTSA underride rulemaking from years past. What they discovered was that a proposed underride rule in 1977 was opposed by practically “the entire trucking industry – both manufacturers and haulers.” The authors of this study noted “that failure to implement a rule on underride guards took place despite extensive research indicating their expected effectiveness.” .  .
  5. Tesla crash fatality could have been stopped by side guards. Tell NHTSA to require them on trucks. The U.S. has been talking about the tragedies of side underride and the possibility of using side guards on trucks since 1969. The recent Tesla S underride crash fatality could quite likely have been prevented if there had been a side guard on the tractor-trailer it collided with.So why is NHTSA still not requiring side guards on trucks? Why is the trailer manufacturing industry still opposing them? Why have so many years gone by with needless, preventable deaths continuing to occur? . . .

When we met with DOT in March 2016 to deliver our 20,000+ Vision Zero Petition signatures, Blair Anderson (NHTSA Deputy Administrator at the time,  now US DOT Undersecretary for Policy) smiled when I made the point about not either/or but both/and. He indicated that the Director had just been talking with staff about that very thing.

Let’s hope that this logical line of reasoning is widely understood and serves the purpose of moving both rulemaking and voluntary industry safety advancement full steam ahead.

Both And

When it comes to safety, is compromise our only option?

Safety Advocacy, Truck Safety, ,

Deadly underride can happen to anyone at any time. Even to the best driver in the safest car.

According to the American Trucking Associations, there are currently 12 million trucks on the road. Most of those trucks have weak and ineffective underride guards. Hopefully, government regulators and the trucking industry will take steps to make future trucks safer to be around.

But they aren’t likely to do anything about the 12 million trucks already on the road–even though there is safety technology to do so. You’ll just have to take your chance that you won’t be at the wrong place at the wrong time.

So, why is it that we are powerless to do anything except agree to whatever the trucking industry is willing to do? Whose lives are we willing to give up to pay the price by settling for less than the best?

Is compromise our only option?

If only

instead of like this: IMG_4464

Current NHTSA #Underride Rulemaking (Cost/Benefit Analysis): Summary of Public Comments

Safety Advocacy, Truck Safety,

I originally set out to highlight comments relative to the flaws in NHTSA cost/benefit analysis. While the document which I put together does that, it actually has much more as it has a link to each of the Public Comments on the currrent underride rulemaking — with some of the highlights copied and pasted from the Federal Register.

It is an incomplete document and could have been done better but it took forever as it is and I hope that it will prove useful to someone.

These are the links to the rulemaking documents themselves:

Here is the Summary Document of the Public Comments: Summary of Public Comments on Underride Rulemaking.

UPDATED, July 22, 2016. Here is the above document revised with links that are clickable! Cost Benefit Public Comments on Underride Rulemaking

If only

Instead of like this:

IMG_4465

UMTRI Reviews Opposition to Proposed & Proven Truck Underride Prevention Measures

Safety Advocacy, Truck Safety, ,

Back in 1989, the University of Michigan Transportation Research Institute examined features proposed for improving truck safety. In other words, they reviewed NHTSA underride rulemaking from years past.

What they discovered was that a proposed underride rule in 1977 was opposed by practically “the entire trucking industry – both manufacturers and haulers.” The authors of this study noted “that failure to implement a rule on underride guards took place despite extensive research indicating their expected effectiveness.”

Like they still do today, the industry tried to turn “the discussion around by stating that underride avoidance should be looking at other measures”–ones that they would not be required to implement. “In particular it called for improving and modifying auto front ends to increase their energy absorbing capacity ‘. . . and protect them when they strike bridges, trees, other cars, and other objects, as well as trucks.'”

Today they are still raising the same sort of objections to improving underride protection:

“The trucking industry and manufacturers are not sure stricter federal regulations are needed – especially since many are voluntarily using tougher underride guards.

‘Underride guards are helpful in reducing the impact of cars crashing into trucks. We would however much prefer to see NHTSA focus on providing automobiles with the capability of preventing cars crashing into trucks,’ said Ted Scott, director of engineering for the American Trucking Associations, Inc. ‘Crash or collision avoidance technology can go a long [ways] in helping to eliminate rear end crashes. Educating automobile drivers on how to share the road with a truck is also very helpful in reducing rear end collisions.’ 

Today, I was discussing that article with my husband. Jerry commented that the Tesla underride crash clearly causes that argument to go out the window. A car with the most advanced collision avoidance technology still could not avoid a deadly side underride.

Note: I appreciate the progress made in underride prevention by at least 4 major trailer manufacturers. And I appreciate the involvement in our Underride Roundtable by many members of the trucking industry. Ted Scott was the first one to say that he would participate in one when it was still just an idea in my head and is also participating in the follow-up efforts to reach a unified consensus recommendation to NHTSA.

But that does not mean that I will stop seeking further action (even when it requires standing firm against controversy) when so much more can be done to save lives.

17hxmi

17hxhyTruck Underride Kills

SIGN  & SHARE the TRAFFIC SAFETY OMBUDSMAN Petition:  End Preventable Crash Fatalities: Appoint a National Traffic Safety Ombudsman

FedEx denies request for underride safety research donation of decommissioned 53′ trailer

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The trucking industry needs to answer the same question which Senator Robert Kennedy posed to GM in 1965: “What was your profit in 2015? And how much money did you spend on safety research in 2015?”

GM’s answer was a safety expenditure figure that was below 1% of their total profit. Which, in my book, makes “safety” a meaningless word.

Yesterday, I received a reply from FedEx, after following their procedure for requesting a donation. Our non-profit, AnnaLeah & Mary for Truck Safety, completed a FedEx charitable assistance application in which we asked them to donate a used, decommissioned 53′ trailer to be used for underride research.

Like in the research undertaken this spring by Aaron Kiefer to crash test his innovative side/rear underride guard protection system. Like the kind of safety measure which could have prevented Joshua Brown from being killed when his Tesla underrode the side of a trailer.

They denied our request. What was FedEx’s reason for denying our request? FedEx email denying safety research trailer donation request

Good day Marianne,

Thank you again for contacting FedEx Freight for charitable assistance. We applaud the work AnnaLeah & Mary for Truck Safety is doing.

After careful review, unfortunately, we must decline your request for the donation of a 53′ trailer.

FedEx Freight works directly with manufacturers and national organizations to support road safety for both our team members and the motoring public.

We wish you success with future endeavors.

Sincerely,

Iris

Iris Coetzee, Senior Communications Specialist

Bah humbug! I would like to know exactly how they work directly with manufacturers and national organizations to support road safety. Spell it out for me. Tell me exactly:

  • How much money they spend on safety.
  • and what percentage that amount is of their total profit.
  • and exactly what that money actually goes for.

I would like to know that information about the whole trucking industry which has opposed and resisted improved underride protection for decades resulting in countless dead people who didn’t have to die if only the trucking industry had acted in a timely and responsible way. And not just for 2015, but for every year since the underride problem was discovered.

I put together a chart for recording that kind of information juxtapositioned against some of the major life events which occurred for me during all of the years when — for the most part as far as I can see the trucking industry did practically nothing “to support road safety for both our team members and the motoring public” — at least in the area of underride prevention. And when they did, it was because we put pressure on their pocketbook.

I’d like to see some investigative reporter dig up this kind of information because I doubt that the industry would give it to me.

11wjd2

 

 

Call has gone out for engineering students & prof’ls to develop innovative truck underride designs.

Safety Advocacy, Truck Safety,

SAE just posted our request for engineering students and professionals to take on the pursuit of solving the deadly underride problem. Last year at this time, similar efforts led to connecting with Aaron Kiefer, crash reconstructionist/inventor, and Jared Bryson with his Virginia Tech Senior Underride Design Dream Team.

Underride Roundtable May 5, 2016 153 Underride Roundtable May 5, 2016 103VA Tech Team with installed guard on rigVirginia Tech Dream Team 2016 PhotoUnderride guard design by Aaron Kiefer 011Underride guard design by Aaron Kiefer 059

Letter from NHTSA re: our truck underride rulemaking efforts

Safety Advocacy, Truck Safety, , ,

I have been reading and sending emails this week to the group which met at IIHS on June 24 to discuss recommendations to NHTSA on the underride rulemaking. It has been encouraging to see that the process is proving more helpful than anything that has been accomplished in the past to gain cooperation through collaborative communication. But it has also been discouraging to see evidence that compromise is being considered.

Then, I opened my email and saw that I had received a letter from NHTSA today — letting me know that they regretted not being able to accept our invitation to attend our Underride Roundtable follow-up meeting at IIHS on June 24, 2016.

They also said that they look forward to our recommendations and encourage our continued submissions to the public dockets for NHTSA’s rulemakings on truck underride safety.

They thanked us for our leadership and for partnering with them to improve roadway safety.

Letter from Ryan Posten, NHTSA, July 6, 2016

Letter from NHTSA July 6, 2016

Thank you

Keep truckin’ — one step at a time.

SIGN  & SHARE the TRAFFIC SAFETY OMBUDSMAN Petition:  https://wh.gov/i6kUj

PLEASE NOTE: If you sign the petition, be sure to go to your email. We the People will send you an email which you have to reply to in order to confirm your signature is valid.