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Truck Trailer Manufacturers Association Underride Guard Response

Truck Trailer Manufacturers Association Underride Guard Response

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Published by LynnKWalsh
Truck underride guards: are they a hidden danger on the road? The WPTV Contact 5 team looked at the dangers of rear-impact accidents involving cars and trucks. The full story is on www.wptv.com. This is the response received from the Truck Trailer Manufacturers Association to the study from the Insurance Institute for Highway Safety which is calling for stricter federal guidelines.
Truck underride guards: are they a hidden danger on the road? The WPTV Contact 5 team looked at the dangers of rear-impact accidents involving cars and trucks. The full story is on www.wptv.com. This is the response received from the Truck Trailer Manufacturers Association to the study from the Insurance Institute for Highway Safety which is calling for stricter federal guidelines.

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Published by: LynnKWalsh on May 21, 2012
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TTMA is an international trade association comprised of truck trailer and tank trailermanufacturers, along with manufacturers of cargo containers, cargo tanks for trucks andcontainer chassis. The associate membership includes material, component, and variousservice suppliers to the industry. TTMA monitors and participates in regulatoryinitiatives that affect its members, but it does not design or manufacture trailers or setstandards for the manufacture of trailers. The following responses are therefore those of the association and not of any particular member.
Questions: The IIHS is asking NHTSA to strengthen the designs and to includemany other types of trucks that are now exempt from the regulations. NHTSA tellsus they are doing their own field evaluation now. We would like to know what thiscould mean to the trucking businesses, truck drivers, and trailer manufacturers.
TTMA
is aware of, and it supports, NHTSA’s rulemaking and
research initiatives thatseek effective ways to reduce injuries and deaths in accidents involving motor carriers,including crashes into the rear of trailers.This type of accident often involves driver error, so we recognize first that the rulesalready in place to prevent these accidents must be followed, including laws that prohibitdriving while impaired or distracted, or driving at speeds that are too fast for the roadwayand visibility conditions presented. In addition, proper maintenance of vehicle lightingequipment is also critical, both for passenger vehicle headlights and for trailer tail andbrake lights and the red and white retro-reflective tape that FMCSA has required byretrofit since 2001 on the rear and sides of trailers.Beyond prevention, TTMA supports the FMCSA requirement that motor carriersmaintain the rear impact guards that have been installed on trailers in accordance with thefederal safety standards. If a guard has been damaged, it should be repaired properly.Bent components, poor quality repair welds or excessive corrosion can undermine guardperformance in a rear collision.As for the IIHS petition to change the current federal safety standards, the goal must be tomake sure that any new regulation is actually effective and does not cause unintendedconsequences.
 NHTSA’s past studies have shown that serious injuries and deaths can
occur in rear crashes due to the sudden forces of deceleration that are imposed on theoccupants even without underride. These forces will necessarily increase if guards aremade more rigid. As shown in the IIHS data, fatalities have continued to occur in rearcollisions even without excessive underride. The potential for more fatalities of this typewill go up as guards are made more rigid. An unbelted occupant who strikes a dashboardand is merely injured in a rear-end collision would strike that dashboard with a greater
and possibly fatal force if the trailer’s rear impact guard is made rigid. The belted
occupants who are not being injured in rear-end collisions now will also face greater risksof deceleration injury if guards are made rigid. These are real world scenarios, and forthis reason NHTSA has previously rejected rigid guards.
 
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

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