Tag Archives: underride guards

Stoughton Trailers values safety & provides improved rear underride protection at no additional cost.

Safety Advocacy, Truck Safety

ccjdigital reports on Stoughton Trailers upgraded rear underride guard.

The article discusses Stoughton’s new rear underride guard, which was tested at IIHS on May 5, 2016, as part of the Underride Roundtable and performed well in the 30% offset crash at 35 mph. I would like to see them tested at higher speeds to see how they perform under more severe conditions.

An excerpt from the article:

“After thorough testing, we are confident that this design will set the new standard for rear underride safety in our industry,” said Stoughton Trailers President and CEO Bob Wahlin. “We place such a high value on the safety of both our customers and the driving public that we have chosen to provide this improved level of safety and performance as a standard feature — and at no additional cost.”

The company also said the underride guard design complies with all U.S. and Canadian regulations. In December, the National Highway Traffic Safety Administration proposed a rule that would require underride guards on the back of all trailers. Most trailers sold in the U.S. – 93 percent according to NHTSA – already comply with the proposed rulemaking.

I appreciate Stoughton’s stated commitment to safety and their ability to provide greater protection at “no additional cost.” I hope that that serves as a powerful precedent.

But can they meet the conditions of the Australian proposed underride rule which we will be discussing at the follow-up meeting on June 24 at IIHS in Arlington from 10:00 a.m. to 2:00 p.m.? That’s what I would like to know.
Raphael Grzebieta from Australia will be making a presentation so that we can determine whether Australian proposed standards would make sense for the U.S. Gary Fenton, from Stoughton, will be participating in that meeting. Should be interesting. . .
Additionally there will be other underride issues to consider as well, including side and front underride/override, conspicuity (adequate marking for visibility), parking of tractor-trailers (leading to greater likelihood of crashes), maintenance, and enforcement. Resolution of each of these issues could lead to additional saved lives.
Underride Roundtable May 5, 2016 148Underride Roundtable May 5, 2016 168
Jerry’s letter to Stoughton’s CEO, Bob Wahlin, in January 2014, in which he asked for improved guards:  Stoughton trailer manufacturer letter

World Forum for Harmonization of Vehicle Regulations

Safety Advocacy, Truck Safety,

Detlef Alwes, an engineer from Germany, suggested to me that the U.S. should discuss underride protection with the World Forum for Harmonization of Vehicle Regulations. I had never heard of it before. Apparently, the U.S. has not had much involvement with it in the past–at least not as far as underride protection.

But doesn’t it make sense to collaborate with other countries and come up with the safest possible vehicle regulations?

Most countries, even if not formally participating in the 1958 agreement, recognise the UN Regulations and either mirror the UN Regulations’ content in their own national requirements, or permit the import, registration, and use of UN type-approved vehicles, or both. The United States and Canada are the two significant exceptions; their UN regulations are generally not recognised and UN-compliant vehicles and equipment are not authorised for import, sale, or use in the US, unless they are tested to be compliant with US car safety laws, or for limited non driving use (e.g. car show displays).[4]

“The World Forum for Harmonization of Vehicle Regulations is a working party (WP.29)[1] of the Inland Transport Division of the United Nations Economic Commission for Europe (UNECE). It is tasked with creating a uniform system of regulations, called UN Regulations, for vehicle design to facilitate international trade.

WP.29 was established on June 1952 as “Working party of experts on technical requirement of vehicles”; the current name was adopted in 2000.

The forum works on regulations covering vehicle safety, environmental protection, energy efficiency and theft-resistance.”  World Forum for Harmonization of Vehicle Regulations

Other links:

Negotiated Rulemaking

Important Follow-up to the Underride Roundtable, June 24 at IIHS: The Work Continues

Safety Advocacy, Truck Safety, , ,

We have scheduled a follow-up meeting to the Underride Roundtable on Friday, June 24, at 10:00 a.m. at the IIHS offices in Arlington, VA. Further details will be shared when available.

We will mainly be discussing the proposed Australian underride rule with a presentation by Raphael Grzebieta from Australia. It is our hope that this will help the United States assess the relevancy of Australia’s progressive work to the future of underride rulemaking for improved protection in our country.

News of this proposed rule:

Other topics — relevant to our goal of reducing underride crashes, fatalities, and severe injuries — will be addressed to some extent, including side and front underride/override, retrofitting, SUTs/exempt trucks, conspicuity, parking.  Future meetings are anticipated in order to continue working on the preventable underride problem.

In addition to the underride rule from Australia, comments from Detlef Alwes of Germany should be carefully reviewed by anyone who holds responsibility for advancing underride protection. This is the most important point which he has made to me over & over in his communication with me via email:

Real energy absorbing underrun protection crash structures or deformation zones on commercial vehicles should become standard, as they have been on passenger cars for decades.

Here is a presentation on underride protection prepared by Detlef: Proposal for an Energy Absorbing Underrun Protection System for Commercial Vehicles

After observing the webcast of the Underride Roundtable, Detlef also made the following recommendations which he would like shared with interested parties in the United States who bear responsibility for the advancement of underride protection.

“In my opinion the following points should be addressed for rulemaking:
  • real energy absorbing underrun protection system design (the current UP systems are rigid structures to be avoided).
  • lateral proof loads to be considered in design and testing.
  • instead of dot-like test loads, the test loads should be defined area-like distributed.
  • the test collision speed should be higher (just in Germany, the collision velocities are much higher than these of the current crash tests because most highways have no speed limitation).
  • the ‘Follow-up Underride Roundtable’ should develop Underrun Protection Guidelines and discuss them on UN/ECE level (WP29). “

Detlef’s last recommendation should be given serious consideration, as underride protection is not unique to one country or another. Saving lives is saving lives.

The UN/ECE level (WP29) aims for worldwide technical harmonization of vehicles: The worldwide technical harmonisation of vehicles is governed by two international agreements – the 1958 Agreement and the 1998 parallel Agreement. These agreements establish harmonised requirements at global level to ensure high levels of safety, environmental protection, energy efficiency, and theft protection. Both agreements help eliminate existing technical barriers to trade and prevent the creation of new ones. The involvement of the EU enables easy access to non-EU markets for manufacturers.

This is Detlef’s experience with this kind of collaborative process:

This suggestion is based on my experience in another field: I was the German representative in an international committee for space debris mitigation (IADC: Inter-Agency Space Debris Coordination Committee). The 11 members of the space leading nations have developed the so-called ‘Space Debris Mitigation Guidelines’.

These Guidelines have been presented to the UN, to the Scientific Subcommittee of UNCOPUOS (UN Committee on the Peaceful Uses of Outer Space). In this Committee the UN Guidelines for Space Debris Mitigation have been worked out and ratified. It was confirmed by the Committee that this process was very effective and very fast – exemplary. The initiative was started by US (NASA), Europe (ESA) and Russia.

It would be great, if we could establish also such an international committee to develop underrun protection guidelines, which we present to the UN/ECE WP 29. The Proposal to the WP 29 can be put on the agenda by the heads of delegation of the represented nations. Maybe such a process can be started by the initiative of you, the IIHS, the NHTSA and others. According my experience, the German governmental authorities will not be initiative to start. They will follow if it works no longer differently.

His reaction to the Virginia Tech team was this:

Yes, I followed this presentation. At the beginning, I thought that there are good concepts but than I was a little bit disappointed about the chosen reference concept, which is near the conventional barriers with small energy absorbing struts. It is a pity that a more effective underride protection system is owed the opinion that it gets too expensive. My suggestion is to start with a realistic energy absorbing underride protection system, and when effective, one can continue with mass and cost saving measures.

I asked Detlef what he thought of crash testing at higher speeds:

Me: I don’t know if you noticed in the webcast, but I raised the question multiple times about why we were not testing at higher speeds and could we please do so. 

Detlef: Yes, I noticed that, and I fully agree. I am wondering that the ADAC in Germany is testing also at 56 km/h, corresponding to 35 mph. That is not very realistic,  just were in Germany on most highways is no speed limitation, and therefore in most cases the collision velocities are much higher, although if a braking action in the last moment has been taken.

Detlef: Some organisations require higher proof loads, to which bumpers have to withstand. This means that the bumpers of the trucks become stiffer and stiffer. Actual bumpers have to withstand these static dot-like proof loads in longitudinal direction and may break if they are exceeded. This should not be the intention for a crash compatible partnership between the trucks and passenger cars. Decades of discussions in international committees have failed to develop bumper technology beyond what it was in the 1950s. The message should be: Energy absorbing underrun protection structures on commercial vehicles should become standard, as they are on passenger cars for decades.

Detlef watched the Underride Roundtable livestreaming and had submitted a question about oblique impact to the panel discussion:

 

I hope the sketch will express what I mean. In the case of an oblique impact on the reaqr side of a truck, the lateral test loads/forces are not defined, only the longitudinal loads/forces in P1, P2 and P3. The damage in the case of an oblique impact can be higher than in the case of an impact in the direction of the longitudinal axes.

Oblique Impact Drawing Detlef Alwes

Offset tests show that the passenger car is turning due to the offset of the Center of Gravities of both cars. But also in this case, the lateral loads/forces are not considered in the regulations.

Underride is a decades-old problem. I look forward to a future less plagued by such preventable tragedies.

Underride Roundtable May 5, 2016 034 Underride Roundtable May 5, 2016 080Underride Roundtable May 5, 2016 032 Underride Roundtable May 5, 2016 024

Underride Roundtable Timeline Victim families by Underride Timeline Underride Roundtable May 5, 2016 169 Underride Roundtable May 5, 2016 141 Underride Roundtable May 5, 2016 008 Roundtable Display Table Nurenberg, Paris, Heller & McCarthy ALMFTS facebook banner

Annual Motor Vehicle Inspection Form: Are underride guards adequately inspected?

Safety Advocacy, Truck Safety, , ,

While we were getting set up for a side guard crash test this morning, I was taking photos of the tractor-trailer that was part of the test. I noticed an Annual Motor Vehicle Inspection form on the trailer. I looked it over trying very hard to find a line item by which the inspector and truck owner/driver would be reminded to check the condition of the rear underride guard which is required by law to be installed and maintained.

Side Guard Crash Test May 2016 032

I could not find anything  listed about underride guards.

Actually, I had picked one of these forms up in a truck stop previously and couldn’t find anything related to inspection of underride guards in the past. Just thought I would check again.

Scan

There is something not right about this picture.

Side Guard Crash Test #3: Successful Prevention of Truck Underride Once Again!

Safety Advocacy, Truck Safety, , ,

This Saturday morning found us helping out at Aaron Kiefer’s third crash test of his side guard prototype. We managed to complete two crash tests–both successful with no Passenger Compartment Intrusion (PCI). People in the car would probably have survived.

  1. The first crash resulted in the car bouncing back with no part of the vehicle going under the truck. We concluded that the car being in neutral allowed it to be sent backward after the collision. If the car had been in gear, then it probably would not have done that. Because the hood was bent, we took off the broken front bumper to get the hood up in order to charge the battery on the car to prepare it for the second test.
  2. The second crash still had no PCI but the side guard tore at two points–quite likely from sharp parts of the car where the bumper had been taken off. Because the guard tore, it allowed the car to go under the truck up to the point of the A-pillar–although still leaving the passenger compartment totally intact.

Another successful crash test day with promising results for future underride protection which can be manufactured for trailers and single unit trucks. Aaron envisions kits for retrofitting existing trucks, at around 200 pounds for maybe $1,000/truck.

The biggest failing of the day was my crash test video on the first crash; I held my camera at the wrong angle so you’ll have to tip your head to view it properly (audio also seemed to be muted at some points). Thankfully, my bloopers had no impact on the success of the underride prevention technology!

Photo Album from the Crash Test Day:  https://www.facebook.com/AnnaLeahandMaryforTruckSafety/posts/15529895183376422

Here is a video of the preparation and aftermath analysis:

Side Guard Crash Test May 2016 030 Side Guard Crash Test May 2016 018

Previous crash testing of Aaron Kiefer’s side guard prototype (March and April 2016: Witnessed safety defect in action at underride crash tests; this is what snuffed out my daughters’ lives.

Reflections from a bereaved dad on the Underride Roundtable & what that means for rulemaking

Safety Advocacy, Truck Safety, , ,

Jerry Karth submitted some additional comments on the proposed underride rule–with reflections on what was learned through the Underride Roundtable. These comments have now been posted on the Federal Register: Additional Comments on Underride Rulemaking by Jerry Karth, May 19, 2016

He included the following important points:

After participating in the Underride Roundtable, I would like to offer these additional comments (also attached as pdf with clickable links):

1. When the Karth family petitioned Secretary Foxx on May 5, 2014, we requested an upgrade in rear underride guards. At the time, we requested that the U.S. guards meet or exceed the Canadian standard. Since that time, having done extensive online research, we have come in contact with researchers who have shown that much more is possible given existing or proposed underride research.

2. One of the questions raised at the Underride Roundtable was whether underride protection could be produced to prevent underride at higher speeds. In the Preliminary Regulatory Evaluation of the NPRM, NHTSA requested information about underride guard crash tests at higher speeds (than the 35 mph currently being proposed). In fact, underride research has been conducted for decades which has demonstrated that it is possible to prevent underride crashes at higher speeds. It is research which has been available and known to regulators and the industry. For example, the Monash University Accident Research Centre (MUARC) in Australia tested energy-absorbing guards to 75 km/h or 47 mph in the early 1990s. http://www.monash.edu/__data/assets/pdf_file/0006/216924/muarc026.pdf

3. The image of a MUARC energy-absorbing underride guard can be seen in the attachment.

4. The U.S. final underride rule should, at minimum, copy the new Australian/New Zealand proposed rule published in April 2016 as the next underride guard rule rather than the present Canadian rule which is 11 years old. The Australian rule mentions test speeds under the heading Test Requirements on p. 60, Clause G7.3: “Current vehicle crashworthiness technology indicates that occupants will not suffer serous injury in an equivalent frontal impact speed of up to around 64 km/h into a deformable barrier if the car is a modern five star Australian New Car Assessment (ANCAP) vehicle. . . The development of effective energy absorbing TUBs [Truck Underrun Barrier] would both reduce the serious injury to vehicle occupants and increase the effect frontal impact speed DeltaV above the 70 km/h test speed compared with a rigid TUB.”

5. It is technically feasible to develop an improved underride guard in less than a year, as the VA Tech Students demonstrated.

6. The consumers of the trailers have requested and received, from 4 of the trailer manufacturers (Wabash, Manac, Vanguard, Stoughton) improved underride guards.
7. Four of the major trailer manufacturers were more than willing to step up and provide a better underride guard (successfully tested at 35 mph for a 30% offset crash).

8. It is cost-effective to design and build a better underride guard.

9. The Cost/Benefit Analysis (CBA ) used in this rulemaking is faulty as clearly demonstrated by some of the manufacturers’ willingness to step up and provide a better underride guardeven without regulation. (Truck Safety Marketplace)

10. It is possible to bring all of the parties involved into the process, to have meaningful conversation, and to make progress.

These attachments were included:

Jerry submitted his original public comment regarding the proposed underride rulemaking on February 16, 2016. A Bereaved Dad Takes a Close Look at the Flaws in Underride Regulatory Cost/Benefit Analysis

Underride Roundtable Timeline74 gertie 2314PetitionHeader_option2Underride Roundtable May 5, 2016 141

Imagine an Executive Order propelling us toward zero crash deaths. What are we waiting for?

Safety Advocacy, Truck Safety, , ,
When I read Lou Lombardo’s Care for Crash Victims email this morning, it reminded me of what I keep thinking about the proposed underride rule. . . the regulatory analysis needs to include the cost of the lives lost (and injuries sustained) in the past — all the years of too-weak or non-existent guards even when they knew that better could be made — and all the lives which could be saved into the future.
What conclusions would the analysts then draw? Would they deem spilled blood too great a price to pay?

Dear Care For Crash Victims Community Members:

As we think about Benefits and Costs we need to think about Who gets the Benefits and Who gets the Costs.  People’s lives vs. Corporate monies.

 

Think about the power of Presidents and their responsibilities as OMB is a key arm of government in the White House.
 

See OMB Draft Report at

Imagine an Executive Order directing the Justice Department to require all settlement agreements to include payments to the government commensurate with the costs in lives lost in the past and projected into the future – and the benefits of sentencing executives to the elimination of vehicle violence forevermore – Vision Zero. 
 
Lou
Thanks, Lou, for your always-thoughtful questions and comments.
Adopt a Vision Zero Policy 047

A Bereaved Dad Takes a Close Look at the Flaws in Underride Regulatory Cost/Benefit Analysis

Safety Advocacy, Truck Safety, , , ,

Jerry Karth submitted some additional comments on the proposed underride rule–with reflections on what was learned through the Underride Roundtable. These comments have now been posted on the Federal Register: Additional Comments on Underride Rulemaking by Jerry Karth, May 19, 2016

Jerry submitted his original public comment regarding the proposed underride rulemaking on February 16, 2016. Here is an excerpt from that which addresses NHTSA’s preliminary cost/benefit analysis:

I would like to respond to the utilitarian logic approach that NHTSA has appeared to have applied to this issue. Their utilization of a cost/benefit analysis (called for by Executive Order 12866) is sadly lacking moral and ethical depth on the benefits side.

This type of logic was applied in 2000 by the Philip Morris Company in the Czech Republic when they funded a research study on the costs/benefits of smoking in the Czech Republic. http://www.mindfully.org/Industry/Philip-Morris-Czech-Study.htm The study concluded that it would be more beneficial for the people of the Czech Republic to smoke than not. What was this startling conclusion based on? A cost/benefit analysis.

The results are summarized in Figure 1:

Figure 1: The public finance balance of smoking in the Czech Republic in 1999 is estimated at +5,815 mil. CZK

Income and positive external effects 21,463 mil CZK
  Savings on housing for elderly 28,mil CZK
  Pension & soc. expenses savings due to early mortality 196 mil CZK
  Health care costs savings due to early mortality 968 mil CZK
  Customs duty 354 mil CZK
  Corporate income tax 747 mil CZK
  VAT 3,521 mil CZK
  Excise tax 15,648 mil CZK
Smoking related public finance costs 15,647 mil CZK
  Fire induced costs 49 mil CZK
  Lost income tax due to higher mortality 1,367 mil CZK
  Days out of work related public finance costs 1,667 mil CZK
  ETS related health care costs 1,142 mil CZK
  Smoking (first hand) related health care costs 11,422 mil CZK
NET BALANCE +5,815 mil. CZK

The study concluded that $1,227 was saved in pensions, health care, and housing every time a smoker dies. [Photo and caption from http://www.mindfully.org/Industry/Philip-Morris-Czech-Study.htm ]

$1,227 ?

That’s how much a study sponsored by Philip Morris said the Czech Republic saves on health care, pensions and housing every time a smoker dies.

photo: American Cancer Society full-page SF Chronicle advertisement 2aug01


In comparison, let’s look at how this approach could be applied to the underride issue. This type of cost/benefit analysis could lead us to conclude that it is not beneficial to require stronger underride guards because the benefits of keeping weak and ineffective standards for underride guards are greater than the cost of upgrading them to the best possible protection. What might those benefits be?

  1. Save the trucking industry money by holding down manufacturing and installation costs.
  2. Save the consumer money by holding down shipping costs.
  3. Reduce medical costs by killing people at a younger age (and avoiding costly medical costs of the elderly population).
  4. Preserve the Social Security fund by decreasing the number of people who draw from their account due to early Death by Motor Vehicle.
  5. Improve the job market due to the decrease in the workforce from the elimination of workers through Death by Motor Vehicle.

In both cases, the conclusions lack common sense. I hope that we can agree upon that.

In other words, this kind of analysis could potentially require that we decide whether we are willing to fork over money to protect people from Death by Motor Vehicle. It forces us to choose between saving a life or saving costs. When that life is one of your loved ones, what would you choose?

In contrast, a cost-effectiveness approach may be a better solution because it compares the relative costs and outcomes (effects) of two or more courses of action. “Cost-effectiveness analysis is distinct from cost-benefit analysis, which assigns a monetary value to the measure of effect.” https://en.wikipedia.org/wiki/Cost-effectiveness_analysis In this situation, the desired outcome of both courses of action would be an underride guard which did not fail upon collision with a vehicle. The two solutions could be compared based upon cost, but a performance standard of a successful crash test would guarantee that lives would be saved.

Cost.Benefit Analysis

Avoid an impasse: Follow-up Underride Roundtable with Negotiated Rulemaking Meeting

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

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.

I am willing to do the organizing necessary to bring this meeting about. First of all, we need a location for the meeting and therefore I am asking if anyone would like to step forward and host this Negotiated Rulemaking Underride Roundtable. Once that is arranged, then we can proceed with selecting a date, developing an agenda, and sending out the notice.

After our family was 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.

Earlier this week, I wrote a post explaining why I think that a negotiated rulemaking process could be important in overcoming compromise and a possible stalemate (“a situation in which further action or progress by opposing or competing parties seems impossible.”): Is Cost/Benefit Analysis Appropriate for Life & Death Matters? Were their lives worth saving?

The participants, of the May 5, 2016, Underride Roundtable at IIHS, would be qualified to help meet the mandate given to NHTSA to prepare a thorough Cost Effectiveness Analysis (CEA) of the underride issue: The Office of Management and Budget (OMB) recently issued Circular A-4 guidance on regulatory analyses, requiring federal agencies to “prepare a CEA for all major rulemakings for which the primary benefits are improved public health and safety to the extent that a valid effectiveness measure can be developed to represent expected health and safety outcomes.”  Appendix G–Health Based Cost Effectiveness Analysis.pdf

A Negotiated Rulemaking Underride Roundtable could provide a format for development of a more effective and comprehensive underride rule, which would cover all the bases with existing and proposed technology to save as many lives as is humanly possible. 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?

Now that the formal comment period is over for the NPRM on Rear Underride on Trailers, the next step is for NHTSA to review the comments and develop a final rule. Let’s strike while the iron is hot and present them with a unified recommendation to enhance their efforts. Before it’s too late.

Let’s send the message to NHTSA that we are all willing to do the work to bring about an acceptable, all-inclusive underride rule.

VA Tech guard installed
Virginia Tech underride guard installed by Senior Design Team, April 2016

See other posts related to the Underride Roundtable here: Tag Archives: Underride Roundtable

AnnaLeah & Mary for Truck Safety is ready to roll. How about you?

8 Picture 657LOGO AnnaLeah & Mary for Truck Safety

Other Research Which Should Not Be Ignored in Current Underride Rulemaking

Safety Advocacy, Truck Safety, , , ,

NHTSA, in the Preliminary Regulatory Evaluation of the NPRM issued in December 2015 for Rear Underride on Trailers, requested information about underride guard crash tests at higher speeds (than the 35 mph currently being proposed). This is what they said,

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) . See: NPRM Rear Impact Guards, Rear Impact Protection December 2015 document; A Summary of Some of the Highlights

Here are some additional links to underride research around the world which should be taken into consideration when developing improved underride designs and standards.

  1. Evaluation of Energy Absorbing Pliers Underride Guards for Rear and Sides of Large Trucks
  2. DEVELOPMENT OF NEW UNDERRIDE GUARDS FOR ENHANCEMENT OF COMPATIBILITY BETWEEN TRUCKS AND CARS
  3. NHTSA NCAP #00248 Truck Underride Guard (Quinton Hazell Guard)

These links supplement the more lengthy list of underride research, which I posted previously here: Underride Roundtable To Consider Underride Research From Around the Globe.