Becoming educated about underride was not a direction I had planned on going with my life and time. But I have gained a great deal of knowledge related to the fact that AnnaLeah’s and Mary’s deaths (and Roya’s, too, along with countless other individual loved ones) might have been prevented had adequate underride protection been on the truck, into which our sturdy Crown Vic crashed — along with the fact that many more countless, unknown individuals will die unless this country takes decisive action.

This information, along with my unresolved grief due to the frustration of knowing that years have gone by without effective protection, fuels my efforts to work collaboratively to bring about widespread and significant change. It is now my aim to equip everyone with the same information — without the accompanying unwanted grief.

The reason we are devoting our lives to pounding on this door and asking for change is that our daughters may have lost their lives due to the lack of a Vision Zero policy. A decision which concluded that recommended changes would not be cost effective—in other words, that it would supposedly cost more to implement safety measures than the lives saved would be worth—may have led to lax underride guard standards.

If the best possible protection had been pursued when the regulations were last updated (1996), the trucks on the road today (including the one on the road May 4, 2013) might be much safer to be driving around. Mary and AnnaLeah might even still be around.

So, here is Part III of Truck Underride 101.

III. Cost Benefit Analysis, Underride Rulemaking, and Vision Zero

1. Public Comments on Underrride Rulemaking & Cost/Benefit Analysis: Public Comments Re: Cost/Benefit Analysis in NHTSA Proposed Underride Rulemaking on Rear Guards for Tractor-Trailers & for Single Unit Trucks and       Current NHTSA #Underride Rulemaking (Cost/Benefit Analysis): Summary of Public Comments and https://annaleahmary.com/2016/10/dot-omb-are-you-using-cea-or-cba-rulemaking-road-to-zero-requires-vision-zero-rulemaking/

2. Jerry Karth’s Public Comments on Underride Rulemaking: Comments on the NPRM for Rear Underride Guards on Trailers and Reflections from a bereaved dad on the Underride Roundtable & what that means for rulemaking

3. Underride Statistics 

   • NHTSA Underride Statistics 1994-2014 Truck Underride Fatalities Chart from the FARS, 1994-2014

   • NHTSA Underride Statistics By TYPE (Front, Side, Rear): The side guard research has the potential to save 1,534 lives in the next ten years. (Per the NHTSA Truck Underride Statistics Chart, 1994-2014: Truck Underride Tragedies Need to End; Enough is enough!     and  https://annaleahmary.com/wordpress/wp-content/uploads/2016/08/Truck-Underride-Deaths-by-TYPE-1994-2014.pdf)

   • More recent statistics from IIHS (May 10, 2017): IIHS tests show benefits of side underride guards for semitrailers

   • NTSB 2014 Recommendations on Underride Protection: National Transportation Safety Board Washington, DC 20594 Safety Recommendations, April 2, 2014
   • March Historically a Momentous Month for Truck Underride Safety Advocacy; Beware the Ides of March! — including  a March 19, 1969, Federal Highway Administration underride rulemaking document on the Federal Register which indicated that their intent was to extend underride protection to the sides of large vehicles! Eight years before my wedding day, when I was 13 years-old, DOT was intending to call for stronger underride protection. And yet, 44 years later, when my daughter Mary was 13 and AnnaLeah was 17, we still had not gotten it right! That’s just wrong!
   • Thanks to Clarence Ditlow Review of 1981 Underride Rule Sheds Light on Current Rulemaking Concerns
   • Cost/Benefit Analysis: Or, How to Put a Price Tag on a Person’s Life
   • With Road to Zero, DOT commits $3 million; compare that to $9.6 million Value of a Statistical Life
   • Let’s remember that we are not merely talking about statistics but about people who unexpectedly and preventably lose their lives and leave shattered families behind. Memorable Moments: Here Today, Gone Tomorrow

4. The Future of Trucking: Who pays for the costs of safer roads?

   I thought about all of this, on a recent trip “back home”, as I reflected on the plight of small trucking companies and independent owner-operator truck drivers. Are the costs of owning a company and the pressure to drive many miles creating a situation where they won’t be able to stay in business?

   Frequently, I hear that changes of one kind or another in the trucking industry–in order to improve safety (i.e., reduce crashes, injuries and deaths)–will result in increased costs for the trucking companies. I hear that it will put them out of business.

   Is this true? According to whom and based on what information? If it is true, then does something need to change in the trucking industry itself in order to allow for the beneficial work, which trucking provides, to continue but to also allow for truckers to make a decent living wage–without jeopardizing their health and the safety of travelers on the roads? . . .  Read more here: The Future of Trucking; Who pays for the costs of safer roads?

5. Whose lives are you going to sacrifice? If decisive action is not taken to end these preventable deaths, then who should we hold responsible? Whose lives are we thereby choosing to sacrifice?

6. TTMA: Truck Trailer Manufacturers Association Reminds NHTSA Why Side Guards Are Not Cost Effective, May 18, 2016 post:

   Yesterday morning, I checked my email and saw that there was a new Public Comment posted on the Federal Register regarding the Notice of Proposed Rulemaking on Underride Guards.

   I quickly went to the site and saw that the Truck Trailer Manufacturers Association had posted a comment (see their comments in the PDFs below). Apparently our Underride Roundtable two weeks ago at IIHS has spurred them to spell out the steps which have been taken over the years to squash side guards from being mandated and manufactured to prevent smaller passenger vehicles from riding under trucks upon collision with the side of the larger vehicle.

   TTMA_Side_Impact_Main_Comment_2016-05-13

   TTMA_Side_impact_Exhibits_A-D_2016-05-13

   Their rationale: Cost/Benefit Analysis shows that adding side guard to trucks is “not cost-effective”. From this post: Truck Trailer Manufacturers Ass’n “Reminds” NHTSA: Side Guards Are “Not Cost-Effective” Says Who? 

   I am encouraged by the closing paragraph of the TTMA letter to NHTSA:

   TTMA would support the implementation of side guards if they ever become justified and technologically feasible. We continue to support the NHTSA review of Petitioners’ requests and stand ready to partner in the development of justified and feasible designs if they possibly emerge. Jeff Sims, President