If rigid guards are going to be proposed again, all of the consequences must beconsidered. The suggestion that rigid corner structures on trailers will save lives in offsetunderride crashes may seem intuitively correct in one crash test scenario, but the analysismust also consider deceleration injuries and deaths in all types of rear crashes into thosesame proposed guards. In addition, adding structural components to trailers to supportfull-width rigid guards will add weight to the trailers and necessarily require thedisplacement of some cargo onto other trucks and trailers. This would increase the
number of trucks and trailers on the nation’s highways and thus increase the potential for
crashes of all types involving cars and trucks, including those that result in fatalities innon-underride crashes. More miles would be driven by heavy trucks to move the sameamount of cargo nationwide, and more crashes would occur
most not involving rear endcollisions.
Questions: Are the manufacturers working with IIHS or looking at what they havedone in terms of research? Do you oppose or agree with the proposed changes?What would it cost to strengthen these guards, to bring them up the standard of safety the IIHS is proposing? What would it cost to add them to all the trucks onthe road as they are proposing? Should it apply to all truck trailers on the road?
The current NHTSA safety standards for rear impact guards are based on dozens of crashtests that are not mentioned in the IIHS report. The recent crash tests by IIHS will add tothe accumulated knowledge about the risks of underride injuries, but they have not ledIIHS to propose any specific strength or energy absorption criteria for rear impact guards
only the IIHS opinion that guards should be more rigid than any of the guards it tested.Since neither IIHS nor NHTSA has issued any specific proposal to change theregulations, TTMA is unable to respond to any proposed change. The feasibility andcosts of a proposed change, and whether it should apply to all trailers, cannot bedetermined until the specific change is proposed.
Questions: The IIHS says they have seen design changes by some of themanufacturers guard design already. Is this a result of the crash testing and resultsthey have obtained? Is there a better solution?
TTMA is not sure what design changes IIHS is referencing and therefore it cannot
respond. TTMA does note, however, that trailers are highly customized and a customer’s
component selections on items such as tire size, wheel type, suspension type, subframeflooring, rear frame and door type, will often affect the rear impact guard design, evenwithin the same trailer model line. In addition, trailers manufactured for use in Canadahave to comply with rear impact guard standards that are different from those in theUnited States. So there are many reasons why guards may appear different, and thesedifferences may well have nothing to do with the IIHS.
As for other “solutions,”
TTMA certainly hopes that the 1998 safety standards willeventually be shown to have reduced the number of lives lost in underride accidents. The