NHTSA is publicly pushing a guard regulation in their rulemaking CBA that is only effective for all types of crashes to 30 mph at minimal compliance which is almost universal. NHTSA now admits that most fatalities occur at 30 mph and above speeds in crashes with big trucks. Most American semi-trucks and trailers on the road already meet the Canadian Regulation. They are using an example regulation that is not effective at fatal speeds in crashes? It is beyond time for Canada to update their underride regulation as world experts recommended when they passed the current weak regulation. Underride guards should be effective at speeds that cause most fatalities. MUARC in Australia and Impact Project in Brazil designed cheap high speed guards decades ago and the American public deserves the true story not phony underride guards.