Tag Archives: underride guards

International Call for Underride Research Re: Injury Prevention & Energy Absorption Issues

Safety Advocacy, Truck Safety, ,

A year ago, I put together a request for underride design proposals.

As a result of that, I came in contact with some awesome underride prevention researchers from around the globe, including:

  • Aaron Kiefer:
  1. Innovative combined side & rear guard promises better underride protection
  2. Imagine a truck UNDERRIDE GUARD which provides REAR & SIDE protection.
  3. Witnessed safety defect in action at underride crash tests; this is what snuffed out my daughters’ lives.
  4. Just got home from the latest side guard crash test. Watch it here!
  • the Virginia Tech Senior Underride Design Team and their advisors, Jared Bryson and Robin Ott:
  1. Virginia Tech Senior Design Project is Addressing the Need for Stronger Underride Guards; Mid-Semester Progress Report
  2. Senior Underride Design Project Mid-Year Report Presented by Virginia Tech Students
  3. Virginia Tech Senior Underride Design Team Spring Midterm Report
  4. Hurrah! VA Tech Sr. Dream Team has attached their underride guard to a trailer!
  5. VA Tech Student Engineers Shine in Underride Roundtable Presentation

This year, I am putting together another request for underride design proposals. This time, I would like to be a little bit more specific and put out a call for research and data to put to rest, once and for all, the controversy over underride guard rigidity/strength and the potential for unintended injuries from too rigid guards. I would like to see it result in data which could lead to design of the best possible underride protection and practical solutions for underride guards to incorporate energy absorption components where appropriate.

Beyond that, because the crashworthiness of passenger vehicles could change over time, I would hope that the information compiled from past research and/or new research completed in the coming year would provide practical means for updating underride prevention technology in the future.

I hope to submit an abstract by June 30, 2016 to be considered for the presentation of compiled research and data on these issues at the First International Roadside Safety Conference in San Francisco in June 2017, as well as at future Underride Roundtables and made available to the engineering and trailer manufacturing community.

If only

instead of like this:

IMG_4465

Note: At the Knights of the Underride Roundtable on June 24, 2016, we briefly discussed the decades-old controversy of “too rigid guards” causing unintended injuries, deceleration forces, need for energy absorption, etc.

Yesterday, I recorded my thoughts about this confusing issue. I hope some will take the time to listen. In any case, expressing it was helpful to me as a survivor of an underride crash which killed my two daughters:

AnnaLeah & Mary for Truck Safety underride research goals

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 will say this in the subject line:  “Almost done! Verify your Petitions.WhiteHouse.gov account.” Follow the instructions to verify your signature.

Knights of the Underride Roundtable: Finding Some Common Ground to Protect Travelers!

Safety Advocacy, Truck Safety,

On June 24, 2016, people from diverse backgrounds met around a table at the IIHS offices in Arlington, Virginia, to continue the good work begun at the Underride Roundtable on May 5, 2016. This time, we rolled up our sleeves and hammered out a written recommendation for better rear underride guard requirements for tractor-trailers. To save lives.

First of all, we heard a presentation from Raphael Grzebieta on the approach which Australia is taking to improve rear underride protection in their country.

The basic idea is that they are not concerning themselves with spelling out detailed design specifications (e.g., what loads a guard needs to be able to withstand) but simply outline the performance evaluation criteria of: prevention of underride with the result of a survivable crash (with no injury criteria but instead relying on the crashworthiness of the passenger vehicle). While we might not yet be ready for that radical of an approach, we were given some food for thought.

(If anyone else had a different perception or would like to clarify my simplified explanation, please let me know and I can edit this description.)

Then, we had some useful discussion about the goals for improving underride protection, as well as some of the challenges which trailer manufacturers face. We benefited from some heated discussion which helped us to clarify terms and priorities. (See the bottom of the post for the Meeting Binder which I handed out for discussion purposes.)

After a break for lunch, we got down to work and spent some time brainstorming. As suggestions were tossed out for discussion, Andy Young typed up the suggestions , which were projected onto a screen for us to analyze and refine. Andy worked us hard and enabled us to reach a consensus and common ground upon which we could all agree.

What we came away with was a very good draft of recommendations for updated rear underride guard regulations for tractor-trailers. We also decided upon a tangible process for moving forward:

  1. David Zuby will send the list of recommendations to me.
  2. I will mail them out to the meeting participants.
  3. They will make suggestions for revision, if appropriate.
  4. We will come to a consensus for the creation of a final document to which we are all willing to sign our names.
  5. Then I will distribute that document to the entire list of participants of the original May 5 Underride Roundtable — giving them the opportunity to review it and decide if they want to sign it as well.
  6. We will then send the document to NHTSA via the Federal Register as a Public Comment on the Underride Rulemaking from the Coalition of Stakeholders Interested in Underride Prevention (CSIUP). [Tentative title for our group for lack of a better name to which we can refer]

We agreed to wait for future meetings to address other topics of importance* in the drive for underride prevention. These include such vital things as protection at higher speeds than 35 mph, Single Unit Trucks (which currently have inadequate or non-existent underride protection), side guards, front override, parking and conspicuity issues, and retrofitting.

Good work, team! Knights of the Roundtable! Just maybe, we will finally get our Dragon Underride Protector! To make Mary & AnnaLeah proud!

*Additionally, we briefly discussed the decades-old controversy of “too rigid guards” causing unintended injuries, deceleration forces, need for energy absorption, etc. See my thoughts on that: Urgent Underride Discussion of Deceleration Forces/High Speeds. Don’t Dawdle.

And today, I recorded my thoughts about this confusing issue. I hope some will take the time to listen. In any case, expressing it was helpful to me:

Underride Roundtable Follow-up Work Group (all 94 Roundtable participants from May 5 were invited):

  1. David Zuby (Chief Research Officer, Insurance Institute for Highway Safety)
  2. John Lannen (Director, Truck Safety Coalition)
  3. Gary Fenton (VP of Engineering, Stoughton Trailers — read that Sto like go)
  4. Ted Scott (Director of Engineering, American Trucking Associations)
  5. Aaron Kiefer (Consulting Engineer, Accident Research Specialists)
  6. Paul Hutson (ECU engineering student and intern with Aaron)
  7. Jared Bryson (Virginia Tech, Center for Technology Development, SR Mechanical Systems Group Leader)
  8. Perry Ponder (President, Seven Hills Engineering)
  9. Raphael Grzebieta (Professor of Road Safety & Australian Naturalistic Driver Study, Lead Chief Investigator)
  10. Jerry Karth
  11. Isaac Karth
  12. Marianne Karth

Underride meeting 6.24 001 Underride meeting 6.24 004 Underride meeting 6.24 006 Underride meeting 6.24 008 Underride meeting 6.24 003If onlysusanna mary annaleah in costumeDragon Underride Protector 004

International Call for Underride Research Re: Injury Prevention & Energy Absorption Issues

Contents of the Meeting Binder which I handed out for discussion purposes:

  1. Five Points Concerning Prevention of Truck Underride
  2. Proposal for an Energy Absorbing Underrun Protection System for Commercial Vehicles by Detlef Alwes
  3. UMTRI-89-2, Final Report: Examination of Features Proposed for Improving Truck Safety, May 1989 The University of Michigan Transportation Research Institute, Aaron Adiv and Robert D. Ervin:  https://deepblue.lib.umich.edu/bitstream/handle/2027.42/817/78350.0001.001.pdf?sequence=2&isAllowed=y Reveals how and why earlier underride rulemaking was opposed despite evidence to show that it was expected to be effective.
  4. Article by Andy Young, panel moderator at the Underride Roundtable: Broken Glass And Shattered Lives – A Mother’s Journey Through Grief Brings Hope For Preventing Underride Truck Crashes
  5. Preliminary_Regulatory_Evaluation_-_Re_NPRM_published_Dec_16_2015 (1)
  6. Highlights of the NPRM Rear Impact Guards, Rear Impact Protection December 2015 document
  7. Truck Underride Fatalities, 1994-2014
  8. Other documents and links provided to meeting participants:
    1. March Historically a Momentous Month for Truck Underride Safety Advocacy; Beware the Ides of March!
    2. Informative articles on underride:
    3. Voluntary Efforts:
    4. Underride Research:
    5. Underride Rulemaking:
      1. NHTSA Has Initiated a Rulemaking Process to Evaluate Options for Improving Underride Guards
      2. Good news from Australia: A Stronger Rear Underride Guard Rule Has Been Proposed!
      3. A Mom’s Knee-Jerk Reaction to NHTSA’s Proposed Rule to Improve Rear Underride Protection The basic problem is that the proposed rule is simply adopting the Canadian rule which 93% of existing trailers already comply with and does not address offset crashes. So it is not much of an improvement, plus it does not address side or front and SUTs. Or retrofitting.
      4. Comments on the NPRM for Rear Underride Guards on Trailers by Jerry Karth
      5. Truck Trailer Manufacturers Ass’n “Reminds” NHTSA: Side Guards Are “Not Cost-Effective” Says Who?
      6. NPRM Upgrade Rear Underide–Federal Register with Public Comments links
      7. ANPRM Underride Protection of Single Unit Trucks

Visual Rulemaking Law Review Article and Deadly Underride Discussion June 24 at IIHS

Safety Advocacy, Truck Safety,

Pray for an important meeting on Friday at IIHS in Arlington, VA. We will be discussing details for underride regulations and hearing a presentation from an Australian on their proposed underride rule.

Also, here is a draft of the “Visualizing Rulemaking” law review article (to be published in the fall). See pp. 43-44 and 65 for reference to AnnaLeah & Mary and our safety advocacy efforts.
http://ssrn.com/abstract=2799334

Minolta DSCMinolta DSCIf only

“Critics Say Underride Fix Will Do Little to Curb Deadly Hazard” As controversy continues, so do deaths.

AnnaLeah and Mary, Safety Advocacy, Truck Safety, ,

FairWarning.org’s reporter, Paul Feldman, reports on the deadly underride problem and the controversy over how to solve it:

Critics Say Underride Fix Will Do Little to Curb Deadly Hazard by Paul Feldman, June 23, 2016

Meanwhile, as the discussion continues, people all over the world die every day because their vehicle is not prevented from riding under a truck. Just like AnnaLeah. Just like Mary.

If onlyNegotiated Rulemaking

There will be a meeting on June 24, at IIHS in Arlington, VA, with some of the participants from the Underride Roundtable, attempting to hammer out a better solution.

 

 

 

UN Regulation (No. 58) on rear underrun protection

Safety Advocacy, Truck Safety,

Underride regulations from the UN, Number 58:

E/ECE/324 E/ECE/TRANS/505 } Rev.1/Add.57/Rev.2 Regulation No. 58 page 3 Regulation No. 58 UNIFORM PROVISIONS CONCERNING THE APPROVAL OF:

I. REAR UNDERRUN PROTECTIVE DEVICES (RUPDs)

II. VEHICLES WITH REGARD TO THE INSTALLATION OF AN RUPD OF AN APPROVED TYPE

III. VEHICLES WITH REGARD TO THEIR REAR UNDERRUN PROTECTION (RUP

REAR UNDERRUN PROTECTIVE DEVICES (RUPDS)

This will take some careful review to understand the relevance and significance of this United Nations underride regulation.

This is what John Creamer told me today:

There is a UN Regulation (No. 58) on rear underrun protection.  In fact, a German-sponsored amendment to increase the stringency of this regulation (the 03 series of amendments) entered into force today, having been adopted by WP.29 last November.  The new requirements become mandatory starting from September 2019. 

However, UN R58 is a type approval regulation not applicable under the US system.  For a regulation to be established that could apply outside the type approval world, a signatory to the 1998 Agreement would have to propose working on one.  In principle, the United States could make such a proposal to WP.29.

Negotiated Rulemaking

More information on Underride & the World Forum for Harmonization of Vehicle Regulations

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

That’s exciting. I woke up to a comment on our website related to my post about the World Forum for Harmonization of Vehicle Regulations.

Here’s the comment:

The United States has been involved with WP.29 since its inception; however, the Forum originally focused on developing standards for Europe. It has only been a truly global effort since the late 1990’s. The US (NHTSA and the EPA) has been a major contributor to international research and development efforts, but when it comes to specific regulations, the US legal system operates under different principles from Europe.

The US was the first nation to set up a regulatory system for vehicle safety. Ralph Nader and others saw the issue as one of consumer protection and product liability while Europe later addressed safety more as an engineering and product certification issue. As a result, we have two main approaches (self-certification and type approval) and there are two international agreements (1958 and 1998) to allow for uniform regulations. Under the 1998 Agreement, WP.29 establishes Global Technical Regulations (GTR) that can be used under any system. (UN Regulations can only be used under a type approval system.) So at the international level, a state-of-the-art standard for rear underrun protection would involve looking at the current regulations in use around the world to see if the harmonization of requirements through a GTR would be practicable and beneficial. John Creamer, globalautoregs.com

John Creamer is the founder of GlobalAutoRegs.com and a partner in The Potomac Alliance, a Washington-based international regulatory affairs consultancy. In his client advisory role, Mr. Creamer is regularly involved with meetings of the UN World Forum for the Harmonization of Vehicle Regulations (WP.29). Previously, he has held positions with the US International Trade Commission and the Motor & Equipment Manufacturers Association (representing the US automotive supplier industry), as the representative of the US auto parts industry in Japan, and with TRW Inc. (a leading global automotive safety systems supplier).

I just emailed John to see what else I can find out from him about this possibility for world-wide collaboration on improving protection against deadly underride. Stay tuned.

(Just so long as it does not get in the way of forward progress meanwhile!)

Negotiated Rulemaking

In memory of AnnaLeah and Mary (and so many others). . .

Never forgotten

A Mother’s Journey Through Grief Brings Hope For Preventing Underride Truck Crashes-Andy Young

Safety Advocacy, Truck Safety, , ,

Energy absorbing bumpers, crumple zones, and seatbelts could not save the lives of backseat passengers, 13 year-old Mary and 17 year-old AnnaLeah. They were traveling in a four-door sedan driven by their mother, Marianne Karth.

Highway traffic slowed to a stop as the Karth sedan was hit from behind by a semi-truck. The first impact spun their blue, four-door sedan 180 degrees. The same semi-truck’s momentum caused a second impact which shoved the Karth sedan backwards underneath yet another truck’s trailer. The rear bar on the second truck’s trailer was not strong enough to prevent the Karth vehicle from going underneath. The rigid structure of the trailer’s steel frame effortlessly shattered the back window, which failed to protect the back of the Karth girls’ heads and bodies. AnnaLeah died instantly. Four days later, Mary died as a result of her catastrophic injuries.

None of the car’s manufactured, safety engineering made a difference to save the lives of Marianne’s daughters. Why? Because the dynamics of the crash resulted in a truck underride.

Little did Marianne Karth know at that moment, on May 4, 2013, that she would become one of the nation’s leading truck safety advocates working toward meaningful prevention of underride truck crashes.

Read more here: Broken Glass And Shattered Lives – A Mother’s Journey Through Grief Brings Hope For Preventing Underride Truck Crashes  by Andrew Young

We were privileged to have Andy serve as the awesome panel moderator at the Underride Roundtable on May 5, 2016, at IIHS.

Andy Young and Marianne Karth

 

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.

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