Perry Ponder, who first brought the 1969 DOT discussion of side underride protection to my attention in 2016 and has invented the AngelWing side guard, recently submitted another Public Comment to NHTSA. He addresses industry concerns about side guards — providing thorough documentation.
IIHS Side Guard Crash Test, March 20, 2017
An excerpt of Ponder’s 2020 comments: Continuing to allow truck and trailer induced PCI in rear and side underride crashes to occur at otherwise survivable crash speeds (delta-V’s of 45mph and beyond) discards years of crashworthiness efforts and wastes the safety benefits we have come to expect and pay for in our cars.
From an engineering perspective the need for vehicle crash compatibility in the form of adequate heavy truck underride guarding is apparent in order to protect against the hazard of PCI which exposes the vulnerable head and neck region to severe, potentially fatal or crippling injury. This hazard is easily remedied by readily available materials and simple structural analysis. Read more here.
Here is Perry’s 2016 Public Comment in which he asked for NHTSA to extend underride protection to the sides of trucks and mentioned that it was the original intent of the underride rulemaking in 1969. This is what the Federal Highway Administration said at that time,
It is anticipated that the proposed standard will be amended, after technical studies have been completed, to extend the requirement for underride protection to the sides of large vehicles.
Imagine! In 1969.
Here is that 1969 document:
This was the original intent of NHTSA rulemakers in the 1969 NPRM, Docket No. 1-11; Notice 2.
When a vehicle goes under a big truck, it’s called an underride crash. This type of crash is extremely dangerous and completely preventable. Installing better guards on big trucks would prevent this type of crash.
There is an Infrastructure Bill being considered by the House Transportation & Infrastucture Committee called the INVEST in America Act which includes underride legislation. We are also waiting for the Senate Commerce Committee to introduce their version of an Infrastructure Bill soon. We are hoping it will include underride legislation.
Become part of the solution by sending an email TODAY to U.S. Legislators in Congress. Tell them that you want them to support Underride Legislation in the Infrastructure Bill.
Members of the U.S. Congress U.S. Senators – Get contact information for your Senators in the U.S. Senate. U.S. Representatives – Find the website and contact information for your Representative in the U.S. House of Representatives. Find your Rep by zip here.
You can also tag them on a Tweet. Use these hashtags: #STOPunderrides#UnderrideVictimsMatter.
Thank you for taking action. Share this message with your friends so we can make a significant impact at a crucial time.
Finally, we’re getting someplace in our efforts to make trucking safer. Legislation is being considered which looks promising to address the issues from our AnnaLeah & Mary Stand Up For Truck Safety Petition in 2014.
You can become part of the solution by making a quick phone call or send an email to U.S. Representatives on the House Transportation & Infrastructure Committee (T&I). They will be considering the INVEST in America Act on Wednesday, June 17, at 10:00 a.m. in a live hearing.
Use this website link to search for your U.S. Representative, or ones from your state who are on the T&I Committee. Send these two simple messages in your own words — asking them to make trucking safer by:
Supporting the Cohen Amendment 089 to strengthen the Underride legislation in the INVEST in America Act by directing NHTSA to do a pilot program in order to prove that underride protection is effective and technically feasible.
Supporting the Garcia Amendment 062 which will raise the Minimum Insurance Liability for truck companies from $750,000 – an amount set in 1980 – to $2 million in a simple adjustment for inflation. This needed change has been neglected for decades and will help not only truck crash victims but also truck drivers, who are often victims of truck crashes. It creates a financial incentive to enforce safety.
Watch this short video which vividly tells the story of Mike, a truck crash victim who was impacted by the woefully-low insurance requirement:
Thank you for taking action. Share this message with your friends so we can make a significant impact at a crucial time.
In order to encourage trucking companies to buy and drive safer trucks, AnnaLeah & Mary for Truck Safety has created decals to affix to trucks which have installed a stronger rear guard and/or added side guards — thereby meeting safety standards for rear and side underride protection, as spelled out in the STOP Underrides Bill.
In hopes that this recognition of fleet safety leadership will help to prevent the loss of other precious lives, we launched this program on May 4, 2020 –remembering our loss of AnnaLeah and Mary in an underride crash seven years earlier on May 4, 2013.
Jerry attached the first SaferTruck Bono Award to a trailer in the process of being upfitted with a Rear Reinforcement Attachment and a full-length side guard system.
In order to encourage trucking companies to buy and drive safer trucks, AnnaLeah & Mary for Truck Safety has created decals to affix to trucks which have installed a stronger rear guard and/or added side guards — thereby meeting safety standards for rear and side underride protection, as spelled out in the STOP Underrides Bill.
In hopes that this recognition of fleet safety leadership will help to prevent the loss of other precious lives, we are launching this program on May 4, 2020, as we remember our loss of AnnaLeah and Mary in an underride crash seven years ago on May 4, 2013.
The SaferTruck System Bono Award is for trucks on which a stronger rear underride guard has been installed to prevent underride deaths at the rear of trucks. We chose this name in reference to the patron saint, Beuno or Bono (Latin, bonus = good), known for the protection of children — using the image of Mary’s beloved stuffed toy St. Bernard, Gertie.
Statue of Mary’s Gertie at the girls’ gravesiteMary with her beloved Gertie in 2012
The SaferTruck System Christopher Award is for trucks which have had side guards installed to prevent underride deaths at the sides. We chose this name in reference to the patron saint/advocate of travelers, Christopher — keeping in mind AnnaLeah’s love of medieval history and dragons.
Dragon statue at the gravesite
AnnaLeah’s stuffed toy dragonAnnaLeah with her nephewAnnaLeah with her niece and nephew, 2012Mary and her Gertie in a photoshoot by her sister Susanna, circa 2010
With special thanks to Mary & AnnaLeah’s brother, Isaac Karth, who created the designs for these two SaferTruckSystem awards.
Safer Trucks Receive Commemorative Awards for Contribution to Safer Roadsflipbook
See more underride tragedies at Underride Crash Memorials.To add more information on this story or to add other underride crashes to be remembered, send an email to underridemap@gmail.com. Please use this Interactive Underride Crash Map Crash Location Input Form to provide us with accurate information . (Note: the map is currently not online; but we would keep the information for future updating.)
Members of the trucking industry have expressed concern about potential operational issues which might occur with long-term use of the AngelWing side guards. Last week, we received an email with feedback from Glen Berry, COO of Thomas Transport Delivery, Inc., a transport company which installed the AngelWing side guards, in August 2017, on one of their trailers which goes back and forth between Ohio and Texas every week.
Marianne/Andy,
As requested…We now have 305,000 miles of Angel Wing use. There has not been a single issue with the structural integrity of the trailer since its installation. My initial concerns, of the Angel Wing System making the trailer frame rails excessively rigid, have dissipated. Because of the bracing structures design characteristics being very stout, to serve their purpose of course, I was worried they may cause frame rail stress, resulting in cracks or other compromises. This has not been the case. Again, I have had zero issues. I am very happy to inform everyone involved…The Angel Wing Test has been an outstanding safety project to be a part of.
Thank you.
Glen Berry
Update on January 28, 2021: Here is an August 12, 2020 Public Comment to NHTSA related to operational & cost issues of underride protection.
Here’s another happy owner of an AngelWing side guard system:
Here’s a crash test of a car into the side of a flatbed trailer at 47.2 mph:
Regarding cost of production of AngelWing: Not all 11 million trailers would require side or rear guards based on their height relative to the ground, and many trailers are wheels-back trailers (see page below). And using a $2,900 price for a single aftermarket guard is clearly not where the price would end up. If a 13,000 lb trailer sells for no more than $30k or $2.3/lb then a side guard is gonna end up an absolute max of $1,300, but likely way less due to its simplicity relative the rest of the trailer. I have designs and costs estimates from trailer makers showing it would be far less. (Perry Ponder, email, 9/18/2019)
AngelWing installed on a flatbed trailer:
Strick Trailers was motivated briefly to design side guards for their trailers after the Maravilla verdict back in ’00. Anyway this 700ish pound side guard was estimated to cost them $328 materials and labor to make at that time. A straight inflation conversion takes that to $450 in 2019 dollars… (Perry Ponder, email, 9/18/2019)
Remember the UVW study about length of trailer, wheelbase length and the height of trailer’s lower edge. It showed that a trailer would have to be much lower than the AW makes it to hang up on in-spec RR crossings and driveway transitions (see diagram below from that study). But the RR crossing argument is another red herring. Google “semi trailer hits overpass” and you’ll see more instances of the height of a trailer causing problems than low trailers at RR crossings…is anyone in the industry arguing for lowered trailer roofs? (Perry Ponder, email, 10/16/18)
Backing a trailer with the SafetySkirt side guard across a raised median:
Update on January 28, 2021: August 12, 2020 Public Comment to NHTSA related to operational & cost issues of underride protection.
Are you aware that AngelWing was successfully tested when a mid-size car was crashed into the side of a tractor trailer at both 35 and 40 MPH at the Insurance Institute for Highway Safety with no Passenger Compartment Intrusion?
Are you aware that DOT administrators were invited to view crash testing of side guards less than a mile from the D.C. DOT Offices on March 26, 2019? (at least one FMCSA official attended)
Are you aware that AngelWing has been in commercial use for over 8 years?
Are you aware that AngelWing has over 800,000 miles in commercial use on the U.S. highways?
Are you aware that AngelWing has been durability tested?
Are you aware that AngelWing has shown no operational issues (such as loading docks and railroad crossings)?
Are you aware that AngelWing has shown no stress or damage on the trailer frame?
Are you aware that AngelWing is being commercially used and one route is from Cleveland, Ohio to San Antonio, Texas round trip every week over 3,000 miles per week without any issues — since August 2017?
Are you aware that AngelWing and a side skirt increase MPG for a tractor trailer?
UPDATE March 13, 2026: Hundreds of people die every year when pedestrians, cyclists, motorcyclists, and occupants of passenger vehicles go under trucks. Please consider joining a STOP Underrides National Town Hall via Zoom April 15 | 8 – 9 pm ET |RSVP HERE.
Your voice at this unique advocacy gathering will let your U.S. Senators and Representative know that you want them to pass the STOP Underrides Act of 2026.
Indiana State Police say 32-year-old Ashley Williams, of Marshall, Illinois was killed in a Sunday afternoon crash on Interstate 70.
According to troopers, a semi tractor-trailer driven by 54-year-old Sergiy S. Shadrin, 54, of Newmarket, Ontario, was traveling westbound on Interstate 70 in the driving lane near the state line with its hazard lights activated because of slow traffic. Shadrin told police he felt an impact in the rear of his semi and immediately stopped.
According to police, a 2011 Jeep driven by Williams was traveling westbound in the driving lane directly behind the semi tractor-trailer and failed to observe slowed traffic, running into the rear of Shadrin’s semi-tractor trailer. Williams died from her injuries at the scene.
See more underride tragedies at Underride Crash Memorials and #STOPunderrides. To add more information on this story or to add other underride crashes to be remembered, send an email to underridemap@gmail.com. Please use this Interactive Underride Crash Map Crash Location Input Form to provide us with accurate information . (Note: the map is currently not online; but we would keep the information for future updating.)
Note: In order to raise awareness and preserve the memories of underride victims — precious ones gone too soon — I have been writing memorial posts on what appear to me to be underride crashes. I am not a crash reconstructionist, and I do not have all the facts on these crashes; but underride should be investigated as a potential factor in truck crash injuries and deaths.
UPDATE March 13, 2026: Hundreds of people die every year when pedestrians, cyclists, motorcyclists, and occupants of passenger vehicles go under trucks. Please consider joining a STOP Underrides National Town Hall via Zoom April 15 | 8 – 9 pm ET |RSVP HERE.
Your voice at this unique advocacy gathering will let your U.S. Senators and Representative know that you want them to pass the STOP Underrides Act of 2026.
We learned that the Illinois woman who was killed in a semi versus vehicle accident this morning on Route 1 in Marshall was a Lincoln Trail College student and member of the softball team. . .
According to the Illinois State Police 20 year old Audria Truelove, of Martinsville, Illinois was traveling behind a semi-truck driven by 39 year old Rahshawn Jordan of Maryland.
When Jordan slowed down due to feeling ill, ISP says Truelove did not slow down and struck the back of the trailer, causing the fatal accident.
See more underride tragedies at Underride Crash Memorials and #STOPunderrides. To add more information on this story or to add other underride crashes to be remembered, send an email to underridemap@gmail.com. Please use this Interactive Underride Crash Map Crash Location Input Form to provide us with accurate information . (Note: the map is currently not online; but we would keep the information for future updating.)
Note: In order to raise awareness and preserve the memories of underride victims — precious ones gone too soon — I have been writing memorial posts on what appear to me to be underride crashes. I am not a crash reconstructionist, and I do not have all the facts on these crashes; but underride should be investigated as a potential factor in truck crash injuries and deaths.
What is DOT going to do about deadly truck underride? That is the question.
On February 27, 2020, at an Appropriations Subcommittee Hearing on DOT’s 2021 Budget Request, Congressman David Price (D-NC) asked Secretary of Transportation Elaine Chao about DOT’s plans to address the GAO truck underride recommendations. Here’s her reply:
“We actually just talked about this just yesterday. So this is a priority. We understand it. We do have a timeline & we want to get that to you.” @SecElaineChao
I’m looking forward to seeing DOT’s timeline for addressing GAO Truck Underride Recommendations. I’m hoping that it will reflect a decision to make underride a priority. After all, rear underride regulations have not been updated since 1996, we’ve been waiting for DOT to act on side underride regulations for fifty-one years, and there’s been radio silence on front underride/override.
And it may well be more as underride deaths are vastly undercounted.
Underride can happen to anyone at any time anywhere.
