NHTSA, you do not have to be “Mad Gods”!

As Luis Otto from Brazil used to say, you can change. You do not have to be “Mad Gods with power over life and death”, you do not have to champion laws that kill! We know from a recent study that the previous underride guard law from 1996 which also legalized guards already on the road saved none or few lives! This law broke the heart and spirit of victims and safety activists and your recent actions will do no less. I work in honor of my late wife Tamara Mills Hadley as most victims labor in honor of their lost loved ones. We also work to save those we have not met, those waiting to meet their fate in the future. That boy or girl a couple of years from now that will die or be maimed or become an orphan if we fail! They are waiting, what will be my fate!

We as spouses, or parents, or grandparents worry everyday about our families safety on American roads. Roads and cars are safer but those increasing numbers of big trucks can still kill you in an instant. You will probably survive crashing into a telephone pole at mid range speeds but a stopped or slow moving truck, not so much! We worry! This sickness called “cost benefit analysis” you and corporations worship so much can never value our hearts, it is a validation of our worst fears. You are in the process of giving away a windfall for the car and trailer manufacturers, no improvement or cost for the next twenty years, but you are smashing the hopes and wishes of so many. Tears will be shed! We demand Vision Zero, we do not have time for anything less anymore. Our hearts have ached for too long.

We are witnessing the birth of printed and laminated plastic car bodies, super strength aluminum frames, and super lightweight and smaller cars that are and will be lower to the ground. We have fuel cells and battery packs, both of which are capable of explosion. We are witnessing the birth of self driving cars. We still have cheap and ineffective underride guards on big trucks and trailers, technology so ancient it does not include any basic pistons yet, just welded strips of crap metal! NHTSA does not provide estimates of fleet makeup during the 20 year average reign of this law, there is no mention of crash characteristics of new technology, there is no estimate of negative consumer choices fueled by fear to adopt smaller and lighter fuel efficient vehicles due to increased crash incompatibility. We just receive education that is beneficial to adoption of this corporate preferred standard. You are building your legacy and you will be judged!

Underride guards that absorb energy and have improved angled struts reinforcing the end of the guards to protect for offset impacts are the cheap and simple answer to save lives and prevent thousands of injuries. They will cost no more than the ineffective guards by your own study that you are trying to force on the American and world public. American lax safety laws have held up world safety efforts for decades and are a source of shame for those of us that know we could do so much better, that we are better than the least we can do. These guards are phony safety, they fool the public that problems are fixed, they bring false confidence and encourage lack of caution. This should be enough, but then you completely discourage fixing older guards as not worth doing! Older guards can be easily fixed! You simply weld or bolt on an angled reinforcing strut to the end of the guard and to the frame rails of the truck or trailer, they increase strength and effectiveness for both full and offset crashes. These changes are crash tested and proven, all companies should upgrade all of their fleets guards, immediately!

Australian research at MUARC in the 1990’s was a light for the world, and more light and hope came from the Brazil standard, and further hope from efforts in Canada. Then the truck and trailer and car company manufacturing associations chimed in and a good effort was watered down, hopes were diminished. We have the technology and research to have guards that extend from the ends of trailers with curved ends to deflect cars at high speeds. We get NHTSA claiming survival in high speed crashes is impossible stopping all efforts. We are not asking for the best, we have given up on that! We just ask for lower guards, that are energy absorbing, with reinforced ends for offset crashes. The same request survivors made in 1992, no more and no less.

Wake up! Change this, change this, change this!! Or withdraw this monstrosity, so we can work on the next administration and not be forced to endure another 20 years without a real standard, only the legalizing of guards already on the roads. We must do better, that boy or girl is waiting!

MUARC Guard Pic

The Underride Network supports a high-speed standard such as recommendations from MUARC in Australia would present.

RECOMMENDATIONS

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