NHTSA Side Underride Guards Review for Trailers: 8 Key Facts and Considerations
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NHTSA Side Underride Guards Review for Trailers: 8 Key Facts and Considerations

May 26, 2023

Maximizing safety benefits of side underride guards can enhance overall road safety for passenger vehicles.

The National Highway Traffic Safety Administration (NHTSA) has recently started the rule-making process on NHTSA side underride guards for trailers. This follows a March 2019 Government Accountability Office recommendation and the November 2021 Infrastructure Investment and Jobs Act, which required the Department of Transportation (DOT) to research NHTSA side underride guards, report its findings, and seek public comment.

An increase in fatalities related to side underride accidents has prompted this review. After analyzing police reports, NHTSA concluded that there are 78 percent more fatalities associated with side underride than reported in the Fatality Analysis Reporting System (FARS).

Key points to consider in NHTSA's review of side underride guards:

"NHTSA's latest research once again indicates there is absolutely no reason to mandate side underride guards on commercial trucks." – Todd Spencer, OOIDA President

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Side underride guards are designed to prevent a passenger vehicle involved in a crash with a large truck or trailer from sliding underneath. Currently, no federal requirements for side guards on trailers exist in the U.S. However, cities like Boston, Chicago, New York, Philadelphia, Seattle, and San Francisco require side underride guards on city-owned truck fleets.

The NHTSA has recently started the rule-making process on NHTSA side underride guards for trailers

The NHTSA has conducted extensive research to assess the potential benefits and drawbacks of implementing side underride guards on trailers. According to their analysis, 17.2 lives could be saved, and 69 serious injuries could be prevented annually if all trailers were equipped with side underride guards. However, the agency acknowledges that there are several factors that could significantly impact these calculations.

NHTSA's analysis is based on the AngelWing guard by AirFlow Deflector, which estimates the average total cost of installing side underride guards on a trailer at $2,990 in 2020 dollars. Adding incremental fuel costs due to the additional weight, NHTSA's final estimate of the cost per trailer ranges between $3,740 and $4,630.

The NHTSA has estimated that the total annual initial cost of outfitting approximately 260,000 new trailers with side underride guards would be about $778 million. This figure does not account for additional costs associated with factors such as extra weight, reinforcing trailers to accommodate the guards, and changes to trailer loading patterns.

The agency is asking for information on other side underride guards available in the U.S. and more information on factors not included in its cost-benefit analysis, such as:

The Owner-Operator Independent Drivers Association (OOIDA) opposes a side underride guard mandate, citing NHTSA's research as evidence that the cost of a mandate would outweigh the benefits. OOIDA President Todd Spencer criticized the new Advisory Committee on Underride Protection, which will make recommendations to the Secretary of Transportation on safety regulations related to underride crashes.

NHTSA announced the committee members, selected for their expertise, training, or experience in trucking and transportation safety areas, as well as law enforcement. The committee includes representatives from families of underride crash victims, truck safety organizations, motor vehicle crash investigators, law enforcement, labor organizations, motor vehicle engineers, the insurance industry, motor carriers, and truck and trailer manufacturers.

Comments on the advance notice of proposed rule-making close 60 days after publication in the Federal Register. To view the full ANPRM and to comment, visit www.regulations.gov; the docket number is NHTSA-2023-0012.

Cost-benefit analysis of side underride guards is crucial in determining their implementation.

Should the NHTSA move forward with mandating side underride guards for trailers, it could have significant implications for the trucking industry. These potential effects include:

While the NHTSA's cost-benefit analysis has raised concerns among some stakeholders, it is essential to consider the potential benefits of implementing side underride guards. These benefits include:

Advancements in technology can play a vital role in the development and implementation of side underride guards.

As the NHTSA seeks more information on alternative side underride guards available in the U.S., it is possible that new technologies and designs may emerge to address some of the concerns raised during the rule-making process. Potential advancements in side underride guard technology could include:

It is crucial for the NHTSA, trucking industry stakeholders, safety organizations, and the public to collaborate in developing effective regulations for side underride guards. By working together, these parties can ensure that any potential mandate addresses the concerns of all involved while maximizing the safety benefits of side underride guards.

The NHTSA's review of side underride guards for trailers has sparked a debate on the costs and benefits of implementing such regulations. While the agency's cost-benefit analysis has raised concerns, it is essential to consider the potential benefits of side underride guards for road safety. By engaging with stakeholders and exploring advancements in technology, the NHTSA can develop effective regulations that balance costs and benefits, ultimately enhancing safety on U.S. roadways.

"Maximizing safety benefits of side underride guards can enhance overall road safety for passenger vehicles."

"Advancements in technology can play a vital role in the development and implementation of side underride guards."

More information on Side Underride Guards:

To view the full ANPRM and comment, visit www.regulations.gov; the docket number is NHTSA-2023-0012.

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Key points to consider in NHTSA's review of side underride guards: