Fwd Submission to DOT of the Comprehensive Underride Consensus Petition with Letter of Support

Fwd: Submission to DOT of the Comprehensive Underride Consensus Petition with Letter of Support

September, 2016

Dear Care for Crash Victims community Members:

Marianne Karth has organized a Petition to DOT Officials on a Comprehensive Consensus for action on protecting people from violent injuries from Truck Underride.

After decades of tragedies not prevented by DOT, DOT should finally act to protect people rather than profits.

Lou Lombardo

———- Forwarded message ———-
From: Marianne Karth <mariannekarth@gmail.com>
Date: Fri, Sep 23, 2016 at 12:45 PM
Subject: Submission to DOT of the Comprehensive Underride Consensus Petition with Letter of Support
To: Anthony.Foxx@dot.gov, mark.rosekind@dot.gov, Scott.Darling@dot.gov
Cc: “Shelton, Terry (NHTSA)” <terry.shelton@dot.gov>, “Summers, Lori (NHTSA)” <Lori.Summers@dot.gov>, “Kuppa, Shashi (NHTSA)” <Shashi.Kuppa@dot.gov>, “Posten, Ryan (NHTSA)” <ryan.posten@dot.gov>, bryna helfer <bryna.helfer@dot.gov>, “Stephen Batzer, PhD, PE” <batzer@batzerengineering.com>, Byron Bloch <byron@autosafetyexpert.com>, Jared Bryson <jbryson@vtti.vt.edu>, Roy Crawford <roycrawford17@icloud.com>, Bruce Enz <bruceenz@gmail.com>, Jeannette Holman-Price <thejessicacampaign@gmail.com>, Isaac Karth <isaackarth@gmail.com>, Jerry Karth <jkarth1@yahoo.com>, Aaron Kiefer <AKiefer@accident-research.com>, “Louis V. Lombardo” <louis.v.lombardo@gmail.com>, Perry Ponder <sevenhillsengineering@gmail.com>, George Rechnitzer <georger@netspace.net.au>, Andrew Young <ayoung@nphm.com>, john.vansteenburg@dot.gov

Secretary Anthony Foxx, Administrator Mark Rosekind, Administrator Scott Darling
Department of Transportation
1200 New Jersey Ave. S.E.
Washington, DC 20590
Dear Secretary Foxx, Administrator Rosekind, and Administrator Darling:
On May 5, 2016, almost 100 people participated in an Underride Roundtable hosted by the Insurance
Institute for Highway Safety at their Vehicle Research Center in Ruckersville, Virginia, with cosponsors Truck Safety Coalition and AnnaLeah & Mary for Truck Safety. Participants included
researchers, safety advocacy groups, the trucking industry, truck trailer manufactures and government
officials, including members of NHTSA staff.
Discussions during the meeting ranged from descriptions of the nature and magnitude of the underride problem to potential solutions including better conspicuity, new rear underride guard designs and the potential for side guards to prevent runovers of pedestrians and cyclists in urban environments, as well as prevention of side underride by passenger vehicles. Information shared during our meeting clearly illustrated the need to do more to address underride crashes as well as the possibility of doing so.
In light of the tragic and unnecessary countless loss of lives which delays in underride prevention have already cost, as well as the continued tragic and preventable loss of life sure to occur if decisive action is not taken now, we are hereby petitioning the DOT to take the following steps to mandate comprehensive underride protection:
1. NHTSA should immediately craft a final rule for rear underride guards on semi-trailers which will prevent underride and compartment intrusion when struck by a typical passenger vehicle (1500 kg/3307 lbs) and a typical SUV (2000 kg/4409 lbs) at initially at least 35 mph — 30% offset and center impacts.
1. NHTSA should immediately issue a Notice of Proposed Rulemaking (NPRM) for rear underride guards of Single Unit Trucks (SUTs), with the intent of aligning SUT and semi-trailer requirements.
2. NHTSA should immediately issue a Notice of Proposed Rulemaking (NPRM) for semi-trailer and SUT side underride protection.
3. NHTSA should immediately issue a Notice of Proposed Rulemaking (NPRM) for heavy truck front underrun protection.
4. In order to ensure that underride equipment is strong enough to allow the inherent crashworthiness of modern passenger vehicles to be realized, as well as to significantly increase the survivable impact speeds through the energy absorption capability of the underride equipment itself, NHTSA should immediately issue a RFP to investigate, develop, and test such technology and update the standards accordingly.
5. NHTSA should thereafter conduct a periodic review of underride standards every five years in order to assess the need for changes in conjunction with advancements in technology and update the standards accordingly. This would include issuing additional RFPs to conduct research as needed.
6. FMCSA should take the necessary steps to enforce the requirement of proper maintenance of underride guards through annual safety inspection.
This petition has been carefully crafted with contributions from many concerned citizens and experts in this issue. The signatures below represent the support already gained for this petition. We will continue to gather signatures from others in the field, as well as launching an online petition to garner widespread support for the advancement of underride protection.
Please read all of the attached documents which accompany this petition letter.
With gratitude for the efforts of your Department and entreaties for you to go further,
Stephen A. Batzer
Batzer Engineering, Inc.
Byron Bloch
Institute for Car Crash Justice
Jared Bryson
Virginia Tech Transportation Institute
Roy Crawford
R R Crawford Engineering, Inc.
Bruce Enz
Injury & Crash Analysis, LLC
Jeannette Holman-Price
The Jessica Campaign
Isaac Karth
AnnaLeah & Mary for Truck Safety
Jerry Karth
AnnaLeah & Mary for Truck Safety
Marianne Karth
AnnaLeah & Mary for Truck Safety
Aaron Kiefer
Accident Research Specialists
Lou Lombardo
Care for Crash Victims
Perry Ponder
Seven Hills Engineering
George Rechnitzer
George Rechnitzer & Associates Pty Ltd,
Andrew Young
Nuremberg, Paris, Heller & McCarthy