Another Victims comments on paper presented to TRB from

Another victims viewpoints and comments on the Revised abstract and underride research presentation paper at presented at Transportation Research Board’s First International Roadside Safety Conference, June 12-15, 2017, in San Francisco.

This paper basically outlined recommendations obtained from reviews of current underride research by this victim and others including experts that provided information and recommendations for the Underride Roundtable. I am in agreement on the recommendations for side and front underride guards as they are basically my recommendations for the Roundtable. The front underride guard recommendations are compilations of the best research from Europe with speed recommendations from real world crash speeds from the MASH crash tests at FHWA, more on FHWA and their importance later. The side guard recommendations are basically the recommendations from MUARC in Australia with speed recommendations at our minimums as we are basically starting from nothing or no guards at all. The rear guard recommendations are the recommendations from the Roundtable which I refused to sign, it needs to be made clear that other victims have a different position on rear guards and crash testing locations and regimes. The paper recommends stiff guards with a minimum performance at 35 mph in both straight and 30% offset crashes with guards attached to trailers. Victims thru the organization known as CRASH since 1992 had the choice to choose stiff wall underride guards over energy-absorbing guards and they chose the latter. Stiff guards are the guards you choose when you have given up on saving lives, the forces are too strong at real world speeds for stiff guards to absorb enough energy to protect car occupants or to prevent possible failure of mounting hardware. Any new rear guard regulation at 35 mph would only legalize guards already on the road as the successful crash tests at IIHS have already pushed much of the industry to voluntary compliance for new trucks as it is so cheap and easy. A new regulation would take a minimum of two years to implement and most manufacturers would already be in compliance, the new law like it’s predecessor from the Clinton Administration which also legalized guards already on the road at the recommendation of U.S. Car Companies would only be used against victims in court. Costing victims families the loss of their financial well-being for current and future generations. These rear guards like their earlier counterparts will save no lives and cost thousands of lives around the world as American refusal to regulate guards is adopted by other countries.

The paper left out critical issues to safety. Crash testing regulated by NHTSA has largely become a political tool of whatever party is in power in the Whitehouse. We already have scientific based crash testing at FHWA thru their MASH crash testing of mostly highway crash hardware. They crash test guards for trucks at highway work sites called crash attenuators which perform to 72 mph as MASH crash tests for real world speeds at 62 mph. A speed that is common for truck crashes. We need science based crash testing to influence the political based regulation. We need real world crash test speeds, not low-speed 35 mph tests that do not cover speeds for a majority of fatal crashes.

The recommendation for reviews of the regulations every 5 years are unrealistic and probably illegal. Every 4 years we elect new presidents and past presidents cannot tie the hands of the newer office holders. Car technology is changing rapidly and NHTSA is regulating only technology that is already on the roads. They need a massive infusion of funding and should start immediately to crash test and design their own and existing guard designs as industry has shown zero interest in safety research at least in America.

We need a crash testing regime like the NCAP crash testing for cars where guards are rated on their performance. Low-speed crash tests allow poorly performing guards to pass easy tests that will not save most lives lost in fatal truck crashes. We must crash test at real world speeds (62 mph or 100 kph) as crashes and fatalities occur at real world speeds. Eventually, guards will pass these stronger tests and we will have real underride guards. Attenuators were developed to pass high-speed tests and sales pressure pushed other manufacturers to comply. Crash test rating of five stars equals more sales of your brand.

This is a different vision from many victims for the future of truck underride guards and regulation.