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7/31/2019 Truck Trailer Manufacturers Association Underride Guard Response
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TTMA is an international trade association comprised of truck trailer and tank trailer
manufacturers, along with manufacturers of cargo containers, cargo tanks for trucks and
container chassis. The associate membership includes material, component, and various
service suppliers to the industry. TTMA monitors and participates in regulatory
initiatives that affect its members, but it does not design or manufacture trailers or set
standards for the manufacture of trailers. The following responses are therefore those ofthe association and not of any particular member.
Questions: The IIHS is asking NHTSA to strengthen the designs and to include
many other types of trucks that are now exempt from the regulations. NHTSA tells
us they are doing their own field evaluation now. We would like to know what this
could mean to the trucking businesses, truck drivers, and trailer manufacturers.
TTMA is aware of, and it supports, NHTSAs rulemaking and research initiatives that
seek 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 rules
already in place to prevent these accidents must be followed, including laws that prohibit
driving while impaired or distracted, or driving at speeds that are too fast for the roadway
and visibility conditions presented. In addition, proper maintenance of vehicle lighting
equipment is also critical, both for passenger vehicle headlights and for trailer tail and
brake lights and the red and white retro-reflective tape that FMCSA has required by
retrofit since 2001 on the rear and sides of trailers.
Beyond prevention, TTMA supports the FMCSA requirement that motor carriers
maintain the rear impact guards that have been installed on trailers in accordance with the
federal safety standards. If a guard has been damaged, it should be repaired properly.
Bent components, poor quality repair welds or excessive corrosion can undermine guard
performance in a rear collision.
As for the IIHS petition to change the current federal safety standards, the goal must be to
make sure that any new regulation is actually effective and does not cause unintended
consequences. NHTSAs 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 the
occupants even without underride. These forces will necessarily increase if guards are
made more rigid. As shown in the IIHS data, fatalities have continued to occur in rear
collisions even without excessive underride. The potential for more fatalities of this type
will go up as guards are made more rigid. An unbelted occupant who strikes a dashboard
and is merely injured in a rear-end collision would strike that dashboard with a greater
and possibly fatal force if the trailers rear impact guard is made rigid. The belted
occupants who are not being injured in rear-end collisions now will also face greater risks
of deceleration injury if guards are made rigid. These are real world scenarios, and for
this reason NHTSA has previously rejected rigid guards.
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If rigid guards are going to be proposed again, all of the consequences must be
considered. The suggestion that rigid corner structures on trailers will save lives in offset
underride crashes may seem intuitively correct in one crash test scenario, but the analysis
must also consider deceleration injuries and deaths in all types of rear crashes into those
same proposed guards. In addition, adding structural components to trailers to support
full-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 nations highways and thus increase the potential for
crashes of all types involving cars and trucks, including those that result in fatalities in
non-underride crashes. More miles would be driven by heavy trucks to move the same
amount of cargo nationwide, and more crashes would occurmost not involving rear end
collisions.
Questions: Are the manufacturers working with IIHS or looking at what they have
done 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 ofsafety the IIHS is proposing? What would it cost to add them to all the trucks on
the 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 crash
tests that are not mentioned in the IIHS report. The recent crash tests by IIHS will add to
the accumulated knowledge about the risks of underride injuries, but they have not led
IIHS 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 the
regulations, TTMA is unable to respond to any proposed change. The feasibility and
costs of a proposed change, and whether it should apply to all trailers, cannot be
determined until the specific change is proposed.
Questions: The IIHS says they have seen design changes by some of the
manufacturers guard design already. Is this a result of the crash testing and results
they 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 customers
component selections on items such as tire size, wheel type, suspension type, subframe
flooring, rear frame and door type, will often affect the rear impact guard design, even
within the same trailer model line. In addition, trailers manufactured for use in Canada
have to comply with rear impact guard standards that are different from those in the
United States. So there are many reasons why guards may appear different, and these
differences 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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recent NHTSA study suggests there has been a benefit, and we know that the crash tests
conducted by NHTSA before implementing these standards predict benefits at closing
speeds up to 30mph. High closing speeds present greater challenges, as do rigid guards
as noted above, and NHTSA has recognized that no guard will be perfect given the vast
array of possible crash scenarios (vehicle type, speeds, angles, offsets, etc.). Crash
avoidance technologies are being developed for passenger vehicles, and these may helpprevent all kinds of crashes, including rear-end collisions involving vehicles of all types.