Guide to Post comments for NHTSA Rear Guards Rulemaking

The NPRM for rear underride protection on trailers was posted on the Federal Register. The Public Comment Period will be open through February 16, 2016.

Here is the link:
http://www.regulations.gov/#!documentDetail;D=NHTSA_FRDOC_0001-1548
Open in a new window so you can cut and paste from this document.

Press the “Comment Now” button in the upper corner of the page.

You can post something similar to the following in the comments box. You must list attached documents if you upload PDFs to be included. Cut and Paste the following with suggested changes to the box on the comments page:

 

Docket No: NHTSA-2015-0118-0001
National Highway Traffic Safety Administration (NHTSA) Proposed Rule: Rear Impact Guards, Rear Impact Protection,
http://www.regulations.gov/#!documentDetail;D=NHTSA_FRDOC_0001-1548

Submitted 12/17/2015 (Change this to current date)

Submitted by the Underride Network (Change to your name and yours or parents email)
Stephen Hadley, Coordinator
https://www.underridenetwork.org
stephenhadley@frontier.com

Comments submitted in honor and loving memory of (Add Lost loved One’s Name if appropriate)

(Died or injured in crash at 35 mph and extreme offset etc.) (Add some loving thoughts and memories)

I support a high speed standard such as recommendations from MUARC in Australia would present, at least 40 mph (64 km/h) for majority of fatal crashes. We demand at a minimum compliance with Vision Zero which your current recommendations violate thru lack of any effort to save lives as first priority. Guards must be energy absorbing (Energy absorption: 50kJ minimum) for future car designs and must be low to the road 16 inches (406 mm) for future car designs. Angled struts must be attached to strengthen ends of guard for offset impacts and must be required to upgrade older guards. If these minimums are not met and the standard only legalizes guards “already on the road” then we demand an end to this rulemaking, immediate withdrawal.

When we crash test guards at 30 to 35 mph (48 to 56 km/h) we get guards for 50 years that perform at 30 to 35 mph (48 to 56 km/h). When you try something over and over and over again and get a negative result, why would you continue this activity. If we crash test guards at high speeds perhaps we will see guards that perform at high speeds. The FHWA tests crash attenuators in 62.2 mph (100 km/h) crash tests (Real World Crash Speeds) and attenuators protect cars and trucks in crashes at 62.2 mph (100 km/h) and more!

See attachments: List if you uploaded

No. 1: NHTSA Mad Gods Letter in PDF

No. 2: NHTSA Rear Guard NPRM Comments Guide Underride Network

RECOMMENDATIONS I support from MUARC

1. Barrier test Forces:
P1 (outer edge) P2 (off centre) P3 (centre)
200 kN 200 kN 100 kN
2. Barrier height: 400mm
3. Barrier width: Within 100mm of the outer frame of the rear of the truck
4. Energy absorption: 50kJ minimum

 

 

That should do it for quick comment!

Here are pdfs you can download to your desktop and then browse to using links at the registration page to upload to include with your comments:

https://underridenetwork.org/wp-content/uploads/2015/12/NHTSA-Mad-Gods.pdf

Download (PDF, 279KB)

https://underridenetwork.org/wp-content/uploads/2015/12/NHTSA-Rear-Guard-NPRM-Comments-Guide-Underride-Network.pdf

 

Download (PDF, 67KB)