In the previous parts of the series, we have already looked at the establishment and evolution of commercial trucking underride standards. We have also looked at whether current underride standards adequately protect the health and safety of Pennsylvania and American motorists when a commercial trucking accident occurs. In the last piece we concluded that in the more than 60 years that have passed since the first underride protection standard, we have learned enough to know that our current protections are not sufficient and that already-proven solutions are available.
In this article, we will briefly examine Canadian and European standards for underride protection. By looking at these standards and how well they protect against known dangers, we can begin to assess the changes that can improve safety on the roads and highways of the United States. Furthermore, we can also identify problem areas with even the strengthening Canadian or European standards. For instance, the Canadian standard, like the American standard, can struggle with off-set impact collisions. These types of commercial trucking collisions are more likely to result in death or catastrophic injuries to the driver and passengers in the smaller vehicle.
Canadian Underride Protection Standards Were Enhanced in 2007
The Canadian rear impact protection standard came into force in September of 2007. While the Canadian read Impact Guard standard is substantially similar to FMVSS 223, there are some key differences between them. To start with, the two standards are compatible and consistent with how they define the point load present at P1 and P2. However, unlike the U.S. regulation, P3 is not defined. In place of P3, the Canadian standard requires the guard to be able to withstand an evenly distributed 350kN load across the face. Furthermore, the under guard must be able to absorb a minimum of 20,000 joules of energy. If the guard can withstand a uniform load that is greater than 700kN, then the under guard does not need to pass the energy absorption test. Upon completion of the load bearing test, the ground clearance of the vehicle may not exceed 560mm from the ground – approximately 22 inches. The 560mm/22 inch standard for the guard height is equivalent to the current standard in the U.S. While P3 can apply when only half of a guard is tested, this standard can also be satisfied by bearing a uniform load of 175,000 joules or greater.
Unlike the U.S. standards which are based on a point-to-point load-bearing system, the regulations for rear-impact protections in Canada are based on a uniform bearing system. Physicists believe that a uniform load system is likely a better model for underride standards because it better reflects the physics involved in a real-world rear-end truck accident. Aside from the close correlation to real-world accidents, the way the Canadian standard is written also allows for improved performance of underride guards. While the U.S. standard allows the horizontal bar to contribute to the load bearing by allowing the bar to bend, the Canadian standard’s focus on uniform loadbearing does not permit the bar to deform. Furthermore, the option to disregard the energy absorption requirement when the load bearing requirement greatly exceeds normal levels provides a model that manufacturers can work within to significantly exceed strength minimums in the regulation. However, even in a worst-case scenario, the Canadian standards require an underride guard to withstand about 2 times the force compared to the US federal standard
European Underride Standards Provide Protections not Found in US Law
European underride standards exceed those required by the U.S. federal law in several ways. To begin with, the U.S. government does not require a tractor-trailer to have front or side underride guards – only a rear guard is required on covered commercial trucks that do not fall within an exemption such as special-purpose trucks. However in Europe since 1994, front underride guards and side underride guards have been required on large trucks.
Also in 2007, the European underride standards also went under major revisions. The new standards came into effect in March of 2007 in Annex II. As per the new regulatory standards, underride guards must protect against point forces of:
- P1: 50kN
- P2: 100kN
- P3: 50kN
This mirrors the point forces present in the US underride standards. However, the additional requirements for side and rear guards likely improve roadway safety. A statistical study regarding fatal crashes conducted in 2012 by IIHS revealed that in accidents involving a passenger vehicle and a large truck:
- 63-percent of accidents involved the front of the truck
- 22-percent involved the sides of the truck
- 15-percent involved the rear of the truck
Thus, in fatal accidents, rear underrides represents a minority risk. The risk of front and side underride risk is not being addressed by the U.S. standard. Making this even more troubling, a smaller study found that 88 percent of side-accidents produce underride. 82 percent of rear accidents caused underride incidents.
IIHS tests Reveal Safety Deficiencies in Guards Meeting Both U.S. and Tougher Canadian Standards
In a 2013 crash test designed and administered by IIHS, a 2010 Chevy Malibu struck a parked truck while traveling at 35 miles per hour. The test was run to simulate 3 different impacts for each of the 8 underride guards tested. The first impact test involved a scenario where the vehicle struck the center rear of the truck trailer. For this classic, straight-forward scenario all eight underride guards passed. The second test’s impact involved a collision where only about 50-percent of the car’s width came into impact with the truck’s rear guard. In the second test, all but a single guard passed. In the third test, the impact overlap area was further reduced to 30-percent of the width of the Chevy Malibu. In this test, seven of eight of the guards failed. IIHS includes the 30-percent overlap test because it represents the minimum overlap level where a driver or passenger in a sedan or another vehicle are likely to strike their head if the guard should fail. The fact that 7 of 8 guards fail this test should be cause for concern for all motorists. Furthermore the fact that one of eight of the best-selling guards also fails the 50-percent test also causes for alarm. Since all of these guards are certified to meet both federal and Canadian standards, there is clearly room for error under the standards. Part of this error is likely the method of attachment for the underride guard’s vertical supports. On every trailer that failed the 30-percent impact test, the supports are attached to the trailer’s slider rails, the rails that run underneath the trailer along the length of its body and allow the wheel positioning to be changed. Using this rail as a point of attachment requires the vertical supports to be positioned, on average, approximately 28 inches from each edge. This positioning appears to fail to provide sufficient strength and force absorption when the impact is focused along the edges and sides of the trailer.
Comprehensive Underride Protection From All Directions Can be Achieved by Already Existing Guards
Only one underride guard passed all three series of tests. This proves that, at least in testing settings, a commercially-viable guard providing more comprehensive protection can be designed and installed. This particular guard is currently manufactured by Manac, but competitors are likely to offer their own improved solutions in the months to come. This guard is designed differently from the other guards, likely explaining its improved performance on off-set impact tests. Rather than attaching the guard supports to the slider bars, the Manac guard is attached to a reinforced floor. This allows for the guards to be installed much closer to the edges of the trailer – approximately 18 inches compared to the 28 inches of the other guards.
Apparently, this design allows the guard to better withstand impacts and forces when the impact is offset. This led to less damage to the Chevy Malibu and its crash test dummy occupants. Additionally, the trailer equipped with this guard also showed the least amount of damage to the trailer itself. A number of safety advocates have declared guards like this a win-win-win solution because everyday drivers win through improved safety and reduced injuries when an accident occurs. Trucking companies win because when an accident occurs, injuries are less severe and the truck and cargo are likely to suffer reduced damage. Likewise, the client of the trucking company also wins because their cargo or goods are better protected and less likely to be damaged or destroyed due to the accident.
Injured in an Underride Accident?
Accidents, including underride accidents, can happen to good people inflicting catastrophic injuries without warning. However reasonable, common-sense steps taken by the trucking company can reduce the severity of injuries when an accident does occur. These steps can include the installation of underride guards that not only feet federal standards, but guards that are known to be effective in foreseeable and likely accident types. If you have been injured, contact the attorneys of The Reiff Law Firm for a free consultation by calling (215) 246-9000 today.