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Underride Network – Truth in Truck Safety Issues and Trucking Victim Advocacy Blog
The Underride Network is concerned with issues affecting crash compatibility between small and larger vehicles including all sizes of trucks and SUV’s. We support improved underride guards for large trucks and trailers; on the front, side, and rear! World regulation of guards has not kept pace with technological advancements to save lives and prevent injuries. We believe truck safety and vehicle compatibility are human rights issues and governments must address these issues from this perspective to ensure the safety and well-being of their citizens.
Safety begins when we acknowledge victims, without victims there can be no safety initiative, without victims there is no reason or need for safety. Governments and organizations that do not acknowledge victims provide zero motivation for safety efforts and do not promote a healthy safety culture. Safety must be an shared effort, we must not exclude victims voices and we must maintain a shared responsibility for safety. Responsibility for safety must lie with road users, vehicle designers, roadway designers, and law makers equally.
Systematic Safety: The Principles Behind Vision Zero.
Cost-benefit analysis always limits the lives saved as too costly for industry. Vision Zero works to save all lives. Which of your relatives would you sacrifice for cost-benefit?
The U.S. government and large cities in the U.S. have removed protection of car occupants from the very definition of side underride guards. They have endorsed guards specifically designed to not protect car occupants, guards that leave most children in crashes with the side of trucks and trailers in danger of fatal and severe injury crashes. We believe they will bring this extreme cost/benefit analysis to front guards for trucks and trailers endangering all road users including vulnerable road users. Vision Zero demands you reduce severity of crashes for all victims and road users and does not allow this cruel form of discrimination. There are no good victims and bad victims just victims.
Nosecone designed to be integrated into the truck body and underride prevention systems that will divert bikes and pedestrians at low speeds and divert cars at higher speeds, low-weight and low-cost were design factors. Most victims of all types die in crashes to the front of the truck.
APROSYS – “It is shown that the risk for injuries to head and lower extremities may be reduced by up to 97% at impact velocities of up to 40 km/h (25 mph).”
When we crash test guards at 30 to 35 mph we get guards for 50 years that perform at 30 to 35 mph. The FHWA crash tests at real world speeds with a suggested 62.2 mph and gets guards (Attenuators) that perform to 62.2 mph.
The FHWA Office of Safety considers that a 100 km/h (62.2 mph) crash test is representative of worst case run-off-road crashes. We agree, real world fatal crashes happen on 50 mph roadways and between 50 and 60 mph. If we test at real world crash speeds we will get underride protection that performs at these speeds. See Front Underride Guards.
The Underride Network supports a similar criteria for underride guard crash tests as those submitted by Prof. Raphael Grzebieta and (Adj) Associate Professor George Rechnitzer and Transport and Road Safety (TARS) Research Centre in Australia based on the criteria used for MASH crash tests in the AASHTO Manual. We would submit requiring multiple speed tests to include real world crash speeds and would not limit extension of guards to increase crush or stroke distance to increase guards effective speed while diminishing deceleration forces. Tests might be performed at 44 mph and 50 mph and 62.2 mph to test minimally compliant guards in low-speed test and using higher speed tests to monitor performance at real world crash speeds. We support testing for Practical Worst Case (PWC) scenario crashes that happen in the real world just as MASH includes PWC in it’s crash test series. We must include tests of offset controlled after crash direction of vehicle spin or VRU (Vulnerable Road User or bikes and pedestrians) after crash spin to assess high-speed crash avoidance for cars and prevention of running over VRU users in frontal crashes. John E. Tomassoni “It is expected that certain offset conditions could result in car rotation such that the passenger compartment may beneficially avoid intrusion entirely”. WE would encourage annual NCAP type testing of truck and trailer underride guards to encourage industry improvement of guards on an annual basis such as crash performance of cars improves on an annual basis using publication of the results of NCAP tests for cars to increase sales of better performing products.
NHTSA has stated that truck and trailer frames must be redesigned before side guards for car crashes could be installed as the truck frames are too weak to withstand car crashes. We refer you to a research study by APROSYS in Europe titled “APROSYS D224 Demonstration of truck side design improvements” at https://www.underridenetwork.org/side-underride-guards/ . They designed cheap and simple reinforced pallet boxes and attached them as side guards to trailers. They crash tested them at 40 mph or 62 km/h and they successfully protected mid-sized cars in crashes at 90 degrees. The trailer frames were undamaged, they protected cars in crashes without trailer frame reinforcement or redesign.
NHTSA legalized underride guards already on the roadway in their 1996 rulemaking just as they are attempting to do with the current rulemaking (See paragraph below). NHTSA research could not find any reduction in fatalities. If the rulemaking in 1996 had required energy absorbing guards, 16 inches from the ground, and met MUARC recommendations we may have saved as many as 300 lives a year (about 1/3) for the past twenty years of the rulemaking equaling as much as 6,000 lives saved in high speed crashes. We know that 75% of fatal crashes occur on roadways posted at 55 mph or more which require higher speed underride guards such as those from MUARC and the Impact Project. Do we really want NHTSA to legalize guards already on the road for the next twenty years? We can build guards effective in high speed crashes counter to NHTSA public statements. Extending guards a few inches beyond the trailer increases high speed performance.
VC-COMPAT: “Plans are underway to extend the front of the truck 300mm to 500mm or more to create a crash zone or deformable soft nose that would absorb crash energy and might reduce serious injuries and fatalities another 10% from the current standard on trucks with energy-absorbing guards and survivable speeds would be increased to 80-90 km/h (50 to 55 mph).”
“The size of an energy-absorbing truck front structure directly correlates to the survivable closing speed between car and truck in head-on collisions (e.g. 75 km/h (47 mph) survivable closing speed requires a 400 mm long energy-absorbing structure, 90 km/h (55 mph), requires 800 mm).” From Volvo Report
“In 2010, NHTSA published the results of a study, analyzing several data sources, to determine the effectiveness of trailer rear impact guards compliant with FMVSS Nos. 223 and 224 in preventing fatalities and serious injuries. The agency’s analysis of the Fatality Analysis Reporting System (FARS) could not establish a nationwide downward trend in fatalities to passenger vehicle occupants in impacts with the rear of trailers subsequent to the implementation of FMVSS Nos. 223 and 224.”
We are asking the FMCSA (Federal Motor Carrier Safety Administration) and NHTSA (National Highway and Traffic Safety Administration) to publicly recognize the existence of millions of underride victims and give them long overdue dignity and honor. These U.S. government sites overseeing truck safety laws and regulations refuse to mention trucking victims and underride victims. We are on the verge of eliminating all traffic fatalities, we finally have the technology and just need the safety culture and the motivation to implement change. We are starting the process to regulate new underride guard technology and hope to include regulation of crash avoidance technology on all new vehicles. This technology could virtually eliminate traffic deaths and serious injuries. We are at the end of the nightmare, the inclusion of victim stories and advocacy will motivate us to finish the journey. Imagine the U.S. government trying to end drunk driving and refusing to mention drunk driving victims, it does not make sense. It is those victims that motivated the public to demand needed change in law enforcement and in our safety efforts. Please help us to finish this great task. Let us demand that the FMCSA and NHTSA include victims on their sites and publications and create a strong safety culture. Please support our victims.
New crash tests and analysis by the Insurance Institute for Highway Safety demonstrate that underride guards on tractor-trailers can fail in relatively low-speed crashes confirming similar results in NHTSA’s own crash tests in the early 1990s. The Truck Trailer Manufacturers Association (TTMA) had already issued a voluntary Recommended Practice in April 1994 that included all the essential elements of the subsequent NHTSA standards except for the energy absorption requirement, the new guard standard issued by the Clinton Administration was a rubber stamp of the industry guards already on roadways, even these worthless guards were exempted from large trailers manufactured prior to January 26, 1998, single unit trucks, truck tractors, pole trailers, low chassis and special purpose vehicles, and “wheels-back” vehicles. These guards were shown to be ineffective in low speed crashes above 25 mph with catastrophic failures of the guard attachment to the truck or trailer common.
Exerpt below from NHTSA’s recent study of underride crashes, we would add rear underrides seem to fall at 52% thus making underride an issue in the vast majority of serious crashes and an issue for an majority of trucking victims, we feel the most important issue and the only issue it seems without an lobby.
“The review of LTCCS cases produced evidence that front override and side underride are a significant problem in serious crashes between heavy trucks and light vehicles. Front override and side underride were found in most of the crashes examined. Preliminary estimates from this review are that override occurs in almost three-quarters of crashes in which the front of the truck is involved, and in over half of the crashes when the sides of the trucks were struck. The results here are based on only a limited sample of serious crashes for which detailed investigations were available, but they clearly indicate that the safety problem of the geometrical mismatch between light vehicles and trucks as currently configured is significant.”
Exerpt from NHTSA – Heavy-Vehicle Crash Data Collection And Analysis to Characterize Rear and Side Underride and Front Override in Fatal Truck Crashes: Impact speed estimation
“Impact speeds and relative speed of trucks and light vehicles at impact were estimated for 193 light vehicles that struck the rear of a truck in fatal crashes. The mean velocity of trucks at impact was estimated at 16.3 mph, but almost 41 percent were stopped at impact and 52 percent were estimated to be going 5 mph or less (including stopped). For striking vehicles, mean speed was 59.8 mph at impact, with a range of 15 mph to 110 mph. Relative velocity is more meaningful in terms of impact however. Overall, the mean relative velocity at impact was estimated at 44.0 mph. About 32 percent of the impacts occurred at relative velocities less than 35 mph, and in 43 percent, the relative velocity was 40 mph or less. However, many impacts were at very high relative velocities, and probably not survivable. In over 25 percent of the cases, relative velocity was over 55 mph and in 13 percent it was more than 60 mph.”
We clearly require an high speed standard in the U.S. of at least 50 mph to save a majority of victims. We must not accept the Canadian Standard as it is only effective in all types of crashes to about 30mph and does not save most victims and it clearly is not adequate for 30 years of technology improvement and increasing energy efficiency. We are told to extend the front of the truck to handle high velocities of both the truck and colliding vehicle but clearly high speed impacts are the majority in rear impacts also. We must also extend truck and trailer length restrictions to incorporate longer high speed guards in the front and rear of the truck.
Vision Zero – An ethical approach to safety and mobility
Safety science demands an integrated approach to safety which includes sharing blame between users and designers of the system, implementing a safety culture.
UNICAMP “IMPACT PROJECT” teaches the technical aspects of truck underride while searching for moral and political solutions. If you wonder what the “wedge effect” is, go here to learn!
OBJECTIVES OF THE UNICAMP “IMPACT PROJECT”: To save thousands of lives every year mainly in Brazil (but in the whole world as well), to reduce injuries and the handicapping of many more thousands in the name of human intelligence, and to promote concepts of traffic safety.
THE ENORMOUS CHALLENGE: A TECHNICAL-JUDICIAL-POLITICAL-SOCIAL CHALLENGE
To fight ignorance, carelessness, apathy, the negligence and omission of government agents, and impunity (ignorance being the most difficult aspect) in all segments of society, including the judicial system and the media.
Newer underride guard designs have the possibility to protect vehicles in higher speed crashes. Governments need to begin crash testing new designs and find those capable of better speed performance and determine the distance from the front and back of trucks or trailers to extend guards for improved high speed performance. Truck size and weight length limitations will need to be adjusted to accommodate the new guards length.
It is time to adopt modern reflective colors for truck and trailer conspicuity enhancements. The Underride Network had several member activists receive awards from then President Clinton for their work for reflective tape on big rigs and trailers. We recommended then and now that fluorescent colors replace the poor performing red and white to save lives. A Canadian study found white tape increased driver recognition by over 350 feet from that of red and white tape. Fluorescent colors have similar candlepower to white tape with the added visibility of color for daytime recognition. Lime green and bright orange are commonplace on traffic signs and emergency vehicles because of their superior candlepower. Increasing the amount of reflectors and maintaining cleanliness of reflective material can also increase reaction time for motorists approaching slow moving trucks on hills and in slow moving traffic. Road film can decrease effectiveness of tape and reflectors by 90%.
Results from VC-COMPAT Project show underride deaths can be reduced!
The analysis revealed that about 11 % of the fatally and 30 % of the seriously injured car occupants could be saved if trucks were equipped with energy absorbing front underrun protection systems (e.a. FUPS) instead of rigid FUPS, and that approximately 57 % of the fatalities and 67 % of seriously injured could be prevented from their injures due to improved rear underrun protection systems (RUPS). The report closes up with the major conclusion that improving rear underrun protection systems show a comparable reduction potential as for improving front underrun protection systems.
“The size of an energy-absorbing truck front structure directly correlates to the survivable closing speed between car and truck in head-on collisions (e.g. 75 km/h survivable closing speed requires a 400 mm long energy-absorbing structure, 90 km/h, requires 800 mm).” From Volvo Report
Road traffic crashes kill 1.2 million people a year or an average of 3242 people every day. Road traffic crashes injure or disable between 20 million and 50 million people a year. Road traffic crashes rank as the 11th leading cause of death and account for 2.1% of all deaths globally. Most of the victims are young and classified as vulnerable road users (pedestrians, cyclists, and bicyclists). Current projections indicate fatalities will rise to 2 million per year by 2020. We are in the midst of a world crisis and vehicles designed to be crash compatible with vulnerable road users will be a critical part of the solution.
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The crash compatibility of all vehicles is a human right!
Truck Safety is a Human Rights issue.
Governments will be judged on the value they place on the lives of their citizens.