The government has several efforts underway to support crash prevention and crash impact mitigation. While both are important aspects of safety that need to be part of our solutions toolkit, it also is critical to view these efforts more broadly in terms of their impacts on the overall crash picture.

The National Highway Traffic Safety Administration (NHTSA) recently released a Notice of Proposed Rulemaking to require automatic emergency braking (AEB) and pedestrian systems on passenger cars and light trucks. This action was taken in response to the Bipartisan Infrastructure Law (BIL), which requires NHTSA to create a rule to establish minimum performance standards for AEBs on all passenger vehicles. Also, as part of the BIL, NHTSA was directed to complete a rulemaking to require AEBs on commercial vehicles, which was recently announced as a joint NPRM by NHTSA and FMCSA.

There is widespread support across the industry and for safety groups for requiring AEBs on commercial vehicles. Several years ago, the Insurance Institute for Highway Safety (IIHS) released results of a study of over 2,000 crashes which found that 2 out of every five rear-end crashes could be eliminated if large trucks were equipped with AEBs. This is a big deal.

Contrast this action with another provision from the BIL, whereby Congress directed NHTSA to conduct research on side underride guards on trailers, with the aim of potentially making them mandatory. In April, NHTSA published an Advance Notice of Proposed Rulemaking to outline the results of its research on costs and benefits, requesting public comment and acknowledging that it lacked information on several factors that impact its calculations. In its analysis, NHTSA concludes that the costs to equip trailers with side underride guards significantly outweigh the benefits. It also indicated that 17.2 lives would be saved and 69 injuries would be avoided annually, which is a small percentage of the fatalities and injuries that occur in large truck-related crashes. To compare, the AEB rule is projected to save 155 lives and prevent 8,814 injuries annually.

While there are crashes whose consequences can be mitigated through the installation of side underride guards, it is important to understand and account for the totality of the factors that influence these occurrences. STC is all about safety, but both government and industry have limited time and resources to devote to efforts to improve it. In our view, we should be spending more of these finite resources on efforts to prevent crashes in the first place because this will have more profound impacts on safety in the long run. It also will help to drive improvements in behavioral change, which clearly are the leading factors that influence crashes.