“[It’s a] step that can be taken today to prevent underride crashes on hundreds of thousands if not millions of trailers,” said Aaron Kiefer, a committee member who represents motor vehicle crash investigators.

Doug Smith, representing motor carriers, emphasized the impracticality of retroactively applying this standard to trailers manufactured before 1998 due to their extensive lifecycle.

“Yeah, they’re out there, but they’re a very small percentage,” he said.

Conversely, Harry Adler, representing truck safety organizations, argued for the inclusion of older trailers, citing wear and tear and the possibility of their reactivation.

Additionally, the committee proposed extending rear impact guard standards to single-unit trucks and enforcing conspicuity standards. The IIHS ToughGuard award, established in 2017, is granted to trailers passing rigorous crash tests without underride.

While the committee focused on rear underride during their meeting, they deferred action on side underride pending further evaluation. NHTSA previously solicited feedback on mandating side underride guards, estimating potential lives saved but also acknowledging the substantial financial implications.

Additionally, with “a weight increase of 450 to 800 pounds per trailer, requiring side underride guards is estimated to increase lifetime fuel costs for new trailers entering the fleet each year by approximately” $200 million to $450 million, NHTSA wrote.

The DOT’s report suggests exploring alternative approaches due to cost considerations outweighing the benefits of a mandate.

Source: Commercial Carrier Journal

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In April, NHTSA’s Advance Notice of Proposed Rulemaking (ANPRM) generated over 2,000 comments on the Federal Register; however, it is evident that the agency lacks clarity on how mandating side underride guards would impact the operational safety of commercial truck drivers.

“NHTSA did not take into consideration the practicability and feasibility of side underride guards on trailer and semitrailer operations,” the ANPRM reads.

Operational concerns are a significant issue in the transportation industry. One area of concern a coalition of rail and port associations brought up is the need for an exemption for intermodal chassis, which are frequently stacked. This stacking could be hindered by underride guards, making an exemption necessary.

The most pressing safety concerns, however, revolve around the issue of ground clearance at rail crossings. This raises important questions regarding the safety of vehicles traversing these crossings.

“Could side underride guards scrape or snag on the road surface when the trailer travels over humped surfaces like some rail crossings or when the truck backs into a steep loading dock ramp?” asks NHTSA’s ANPRM. “Could movement of the trailer then be disabled, damaging the guards and necessitating replacement?”

The answer to these questions is most likely a resounding yes. The Owner-Operator Independent Drivers Association (OOIDA), expressing their views through comments filed in the Federal Register, firmly believes so.

“OOIDA has notably heard from drivers about the dangers of traversing highway-rail crossings with side underrides attached to their trailers,” the organization wrote. “In 2022, there were more than 2,000 highway-rail crossing collisions in the U.S. and more than 30,000 reports of blocked crossings submitted to the Federal Railroad Administration’s public complaint portal.”

Truck driver Patrick Newbill’s comment cuts to the core of the problem in the regulatory docket. “We already have a hard enough time backing up into steep docks, going over rail crossings, and making sharp turns,” he said. “Things are not set up to accommodate underride guards. They will just cause more trailer and property damage.”

Flatbed truck driver Norman Lassen provided an insightful comment on the potential effects of the mandate, highlighting the significant and unforeseen impacts it could have on his operations.

“As a flatbed owner, I will be forced to put my dunnage, V boards, ladders, and other equipment I currently store under the trailer between the frame rails, out of sight,” he said. Storing it all on top of the trailer “will reduce the loading space on the trailer and will invite theft. Not to mention the added weight on a truck that needs the lightest weight possible to serve my customers.”

Lassen added he felt that “the guards will cause more truck-train collisions, as they will high-center trucks on sloped crossings even more than what happens now.”

The Truck and Trailer Manufacturers Association (TTMA) stands with drivers who are against the mandate.

“TTMA believes that adoption of current SUG designs will necessarily increase incidents of trailers getting hung up at railway crossings,” the organization wrote in its comment to NHTSA. “[That] would increase risk of death and injury at these crossings. Again, the magnitude of this risk is hard to quantify accurately, but also could be greater than any benefit.”

The recent increase in high-profile train derailments has raised concerns about liability in cases of potential rail disasters. What happens if a truck equipped with a government-mandated side underride guard gets stuck at a rail crossing, intersection, ramp, or hill? It is important to note that existing roads were not designed with side underride guards in mind, and the OOIDA believes that the carrier and/or its driver would be held responsible for any liability in such situations.

“In these situations,” the OOIDA wrote, “due to sovereign immunity at the federal and state level for claims relating to negligent roadway design and construction, motor carriers will be unable to recover damage costs sustained from underride equipment on poorly designed or constructed areas of the current infrastructure.”

According to OOIDA, motor carriers could “find themselves facing liability for damage caused by underride equipment. Both of these scenarios require the motor carrier, or its insurer if the policy provides applicable coverage, to bear the cost of resulting damage.”

Trailer owners and pullers face a lengthy list of potential issues and costs associated with installing and maintaining side underride guards. These include increased fuel consumption, interference with inspections, and damage to trailer bodies and low-hanging rails. It’s important to note that the NHTSA’s own analysis does not assert that the benefits of the mandate outweigh the costs.

In fact, the ANPRM estimates that the mandate could cost the trucking industry approximately $73 million per year for each life saved. This calculation is based on dividing the projected costs of around a billion dollars by the projected lives saved: 17.

Rail crossings lack the same clear signage as highway bridges, leaving truck drivers uncertain about clearance heights. The Federal Railroad Administration (FRA) does not provide information on clearance heights, and there is no publicly available source for such information. The responsibility for calculating clearance falls solely on the driver, with no clear guidance from the FRA.

The FRA has discussed the issue of lowering trailer clearances with the NHTSA, but no solutions have been implemented yet. Truck drivers are responsible for avoiding trailer-related incidents at rail crossings, with minimal assistance from signage or other information sources.

Source: Overdrive

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Over 2,000 parties, including trucking associations, owner-operators, safety nonprofits, and even bicycle riders, have submitted comments on the proposal. The consensus is that additional research and data are crucial before implementing this rule.

Below is an excerpt from American Trucking Associations on the proposal, which the group does not support:

“ATA policy is that equipment requirements should be based on sound engineering and economic principles that enhance safety, take into account real-world operations and weigh potential unintended consequences,” the trade organization wrote. “Side underride guards are approximately 40 feet long [rear guards are only about 8 feet long] and would be subjected to a wide variety of crash scenarios, but only have limited testing data on one specific scenario. ATA believes that efforts to decrease and eliminate side underride crashes should be focused on preventing the crash from occurring in the first place.”

The American Truck Dealers division of the National Automobile Dealers Association wrote, “NHTSA made appropriate use of, and drew reasonable conclusions from, the limited available data and research. However, proceeding with a side underride mandate based on this incomplete information and testing that does not replicate realistic highway conditions is premature and untenable.”

The Truckload Carriers Association was quoted saying it was “disappointed that NHTSA has proceeded with this notice when the market has such limited options available to an industry that is far and away the leading mode of freight delivery in this nation.” They went on to add, “Any rulemaking, bestowed upon this industry, must be based on sound engineering principles, and include rigorous testing and research, things that have not yet been done. TCA questions the lack of testing and research committed to a device with one manufacturer and limited trials.”

“Before deploying any potential safety device, it is imperative that the manufacturer and others ensure that it has undergone thorough testing for safety and effectiveness, and also that the effect in the real world is both safe and well understood,” The Truck Trailer Manufacturers Association added in agreement. “Although the ANPRM did not directly ask this, it is important to note that trailers come in a vast multitude of designs such as dry bulk, low-boys, gasoline tankers, etc. Some trailers are designed to operate with equipment under them, or go off-road such as grain and agricultural trailers. As far as TTMA is aware, commercially available side underride designs only exist for box-type trailer designs, and no device has yet been developed for the multitude of other designs.”

Werner Enterprises, Inc, noted that they have “overriding concerns” regarding the potential for unintended consequences to safety and operations.

“Werner notes the numerous technical challenges posed by adding weight to trailers, including possible increases in fuel consumption and emissions, as well as difficulty in making high-grade railroad crossings and completing certain docking tasks, which may hang up or damage cargo and create safety hazards for other motorists, train operators, train passengers and dockworkers,” the company reportedly said.

“The Owner-Operator Independent Drivers Association opposes efforts that would mandate the installation of side underride guards on commercial motor vehicles, CMV trailers and semitrailers,” the trade association wrote. “Over the last several years, NHTSA has considered numerous options involving side underride guards, but has consistently concluded a federal mandate would be impractical and costly, thus outweighing possible safety benefits. Advancing any side underride mandate disregards this reality and ignores the safety, economic and operational concerns that have been raised by small-business truckers.”

The Truck Safety Coalition stated that the public was right to view NHTSA’s commitment to reducing underride crashes with a healthy dose of skepticism.

“In analyzing the side underride guard ANPRM, it appears several subjective decisions were made in the analysis that artificially limits the estimated number of lives saved and fails to quantify the deadly impact of multigenerational side underride guard inaction,” the coalition wrote. “In addition, NHTSA did not conduct any robust side underride guard impact testing with real-world prototypes from multiple manufacturers to properly inform its analysis.”

Source: Transport Topics

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