Side underride guards: what we know about them— and what we have yet to learn.
Smart safety policy must be guided by sound data.
America’s vast transportation system serves many stakeholders with competing interests, but the paramount importance of safety is the common denominator that connects all users. Whether you’re in a plane, train or automobile — hauling commercial freight in a truck or carpooling with coworkers in a passenger vehicle — we all rely on safety and its widespread practice to get from A to B.
We in the trucking industry are not shy about our commitment to safety, proudly investing $10 billion every year in safety technology and initiatives, ranging from collision avoidance systems, electronic logging devices for driver hours, and video event recorders — to driver safety training, driver safety incentive, and pre-employment and random drug testing. While some of these efforts are required by government regulations, others are taken on voluntarily.
And the results also speak for themselves: Since 1980, we’ve seen a steady and substantial decline in the total number of fatal crashes involving large trucks, and an astronomical 74% drop in the fatal crash rate involving large trucks.
Our philosophy is simple: let sound data guide safety policy decisions. In a world of limited resources, smart safety strategy requires prudence when determining how best we invest in safety to protect our most precious resource of all: human lives.
While every proposal may be noble in its intent, not every policy is equal when measured by effectiveness. Diverting resources to one piece of technology or standard can deny critical resources for another, more proven solution. But by relying on data, we can best navigate these complex choices and avoid the unintended consequences that can potentially harm safety outcomes rather than improve upon them.
This is particularly important as we examine the recent uptick in fatal crashes since 2009, which can be explained by several factors. The first is a rise in distracted driving, exacerbated by the proliferation of smart phones over the past ten years. According to NHTSA, distracted driving claimed 3,166 lives in 2017 alone. Second, America’s deteriorating infrastructure and the substandard condition of our roads and bridges are making driving more dangerous.
While policymakers in Congress and the federal agencies explore ways to reverse this uptick, it is imperative that they do not pursue policies that miss the root cause and true nature of the problem. Pursuing new policies haphazardly — regardless of how noble the intent is — can actually move us further from our common, national goal of zero highway fatalities.
One timely example is the Stop Underrides Act, introduced this Congress by Reps. Steve Cohen (D-TN) and Mark DeSaulnier (D-CA) in the House and Sens. Kirsten Gillibrand (D-NY) and Marco Rubio (R-FL) in the Senate. The bill would mandate that new and existing truck trailers be equipped with side underride guards — barriers attached to the sides of a trailer to prevent vehicles from crashing underneath.
Let’s review what existing data tells us about the potential costs and benefits of this proposal, and how the legislation could affect our progress on reducing crash fatalities.
Safety Impact
Congress tasked GAO with reviewing the scope of the problem of underride crashes as well as the potential benefits that side guards could offer. But GAO’s report, released in March, found a serious lack of data to fully understand the issue, and it concluded more study is needed before an informed determination can be made:
GAO recommends that DOT take steps to provide a standardized definition of underride crashes and data fields, share information with police departments on identifying underride crashes, establish annual inspection requirements for rear guards, and conduct additional research on side underride guards. DOT concurred with GAO’s recommendations.
From 2008 through 2017, an average of about 219 fatalities from underride crashes involving large trucks were reported annually, according to GAO. However, the differing methods by which states collect crash data could lead to these types of crashes being underreported.
Regarding the effectiveness of side underride guards, the report concluded more study is needed, citing real-world challenges to their application, such as the stress placed on trailer frames from the additional weight. For example, without further study we don’t know the impact that side guards will have on a trailer’s structural integrity over time — concerns echoed by trailer manufacturers in comments to NHTSA. European manufacturers have experienced trailer failures due to the increased rigidity of the trailer structure caused by the added frame supports for underride guards.
“NHTSA recently issued a study on the safety performance of certain materials used for side underride guards. However, NHTSA has not performed research on the overall effectiveness and costs associated with or the design of side underride guards.” — GAO Report
If further study were to find that guards indeed weaken the trailer, causing them to fail when traveling at highway speeds, this bill could actually be creating new safety hazards on a scale that could dramatically outnumber the problem of underride crashes that it seeks to remedy.
While tests have been conducted by guard manufacturers to demonstrate side underride guards’ stopping power, these demonstrations have been limited to controlled environments and at speeds no higher than 40mph. We have not witnessed nor do we know what may happen when a car collides with a side underride-equipped truck in a realistic highway scenario — at highway speeds, with a moving truck and trailer, and with other traffic present.
It’s not just carriers saying this — even side underride guard manufacturers agree. As stated in the GAO report, “the manufacturer also said that more information on how side underride guards might affect everyday operations is needed before more widespread adoption by the industry.”
We do know from operating current trailers that side underride guards would significantly increase the likelihood of trailers high-centering on uneven streets, curbs, elevated roadway crossings and warehouse docking wells. These concerns further underscore GAO’s conclusion that more study is needed.
The Costs
In recent Congressional testimony, the cost of a side underride guard was placed at $2,900 including shipping — and there’s an estimated 12 million truck trailers either currently registered or recently ordered. By those numbers, the Stop Underrides Act would cost a staggering $34.8 billion to fit all new and existing trailers with side guards. When factoring in the cost of labor for installation, this legislation would likely amount to the largest unfunded mandate on a private sector industry in U.S. history. That staggering sum actually exceeds the industry’s annual net earnings, and would put large segments of it out of business. (While the industry’s total revenue exceeds $600 billion, motor carriers runs on extremely thin profit margins — once you factor in operating costs: labor, fuel, healthcare, retirement, new equipment, maintenance & repair, safety and training, insurance, capital expensenses and so on. That operating margin is the reason everything we buy at the store is affordable.)
The consequences of such a disastrous scenario are hard to overstate. Trucks move more than 70% of the freight tonnage in the U.S., and virtually every consumer good rides on the back of a truck at some point in its lifecycle. Straddling our essential industry with a mandate this gargantuan would bring the economy to a screeching halt, resulting in empty grocery store shelves, delayed shipments of life-saving medical supplies, and other large-scale disruptions to our economy’s supply chain, which would be hard felt by every American in their quality of life. Look no further than the home states of the bill’s original Senate co-sponsors. In both New York and Florida, 89% of communities rely exclusively on trucks to move their goods.
But even more concerning than the financial costs of this proposal are the opportunity costs to safety that it would impose. Such an expensive mandate would undoubtedly divert the entire $10 billion our industry invests each year away from more promising safety technology and standards, which are backed by sound data. That investment would be taken away from combating the approximate 37,000 annual motor vehicle fatalities — including the 3,400 involving large trucks — and instead appropriate that sum threefold toward reducing the fewer than 300 reported underride fatalities that occur every year.
Make no mistake: every life matters. But the massive funding disparity this legislation creates cannot be ignored — costing more lives than it is intended to save, skyrocketing the prices we all pay at the store for daily goods, and putting hundreds of thousands of Americans out of work. When deciding how best we as a nation invest in safety, we must consider all options available, and which policies achieve the greatest overall safety outcomes.
Take for instance vehicle-to-vehicle connectivity. Whereas side underride guards are a crash-mitigation technology, designed to lessen the impact in a small subset of crashes, V2V is a crash-avoidance technology designed to prevent all crashes from occurring in the first place. NHTSA estimates V2V regulations could avoid or mitigate 89% of light-duty vehicle crashes. NHTSA is also conducting research on V2V for heavy vehicles, and estimates 70% of crashes involving trucks occur in scenarios that could be addressed by V2V. If the Stop Underrides Act were come to pass, the forward momentum toward developing these systems would be derailed.
In Closing
By investing in technology that removes human error from the equation, we are on the cusp of major breakthroughs in motor vehicle transportation that could dramatically reduce the number of fatal crashes each year, of which there were 37,133 in 2017. That is why it’s so important for government and industry work together, hand in glove, to enact policies that are backed by sound data.
But if we take our eye off the road and pursue policies of unproven benefit and astronomical cost, we risk jeopardizing this progress. Safety is a core value of our industry and at the foundation of every decision we make at American Trucking Associations. That is why we urge policymakers to follow GAO’s well-founded recommendations and conduct more study on the feasibility of side underride guards.
The road to zero fatalities is a long and difficult one, but data is the key that shows us the way forward. And with a smart strategy supported by science, we can get there sooner than many think.
