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Vehicle engineering experience, general knowledge of the trucking industry, and in-depth involvement in the safety research and rulemaking history discussed below are utilized as a basis for rendering professional opinions on vehicle design and crash-performance issues. 

I) Industry Sponsored Research

Upon enactment of the National Traffic and Motor Vehicle Safety Act of 1966 ( 1966 Safety Act) Truck Manufacturers, individually and collectively through their trade association, became proactively involved in the USDOT rulemaking process.  Manufacturers were vitally concerned that the Agency’s initial primary focus on promulgating a host of new vehicle regulations was not adequately supported by necessary precursory research and problem-identification accident analysis.  In support of  expressed  commitment to the USDOT regulatory rulemaking process, truck manufacturers embarked upon sponsoring a focused 25-year searching-for-the-truth research program. This initiative was dedicated to acquiring a factual understanding of emerging real-world vehicle/driver safety issues to support the development of responsive countermeasure programs.

Reference document MVMA SPONSORED MOTOR TRUCK RESEARCH December 1992 provides a bibliography of approximately 150 research projects that were funded, totally or in part, by truck manufacturers through the Motor Vehicle Manufacturers Association (MVMA). Following is a representative list of vehicle-focused research topics that have been addressed by the MVMA sponsored research programs: 1) accident/injury analysis, 2) vehicle handling, braking, and stability, 3) cab crashworthiness/restraint systems/crash injury protection, 4) driver environment and ergonomics, 5) driver comfort/fatigue, 6) driver ingress/egress, 7) driver visibility, 8) fuel system integrity/fires, 9) ride quality, 10) splash & spray, 11) tire/wheel systems, 12) vehicle underride/conspicuity, 13) vehicle/highway interface and compatibility.

Above research programs were structured to develop an understanding of real-world safety issues, highway accident  analysis, component performance evaluation, vehicle design parametric studies, development of analytical engineering design tools, development of laboratory and proving ground test procedures, etc.

II) Cooperative Government/Industry Research

In the mid-1980’s truck manufacturers and the USDOT embarked upon the concept of sponsoring jointly funded cooperative research initiatives.  As a prime example, this approach was utilized to carry out the S216/217 studies mandated by the Motor Carrier Safety Act of 1984.  The S.216 study focused on brakes, handling, stability, and truck aggressivity in truck-car crashes; while S.217 mandated a study of truck occupant crash protection.  Sections 2.0 and 3.0 of reference report The Decade of Declining Heavy Truck Fatalities…a tribute to the cooperative process provide an overview of several government/industry sponsored programs, including the S.216/217 studies.

The S.217 study on occupant crash protection evolved to become an essential element of a long-term effort, on the part of truck manufacturers, to address the issue of crash-injury protection.  Reference document Heavy Truck Occupant Crash Protection…A Historical Chronology  provides a 35-year chronology of research studies and related program endeavors that were carried out to address the important issue of mitigating truck crash injuries. Slides 44 thru 51 of reference document Legislative Impact on the Design and Operational Safety of Large Truck in the United States provide additional information regarding the highly successful government/industry sponsored crashworthiness initiatives. The S.216 & S.217 cooperative effort programs are offered as examples.  Similar successful approaches have been employed as a means of addressing many of the other above-referenced safety topics.

III) USDOT Regulatory Rulemaking History

During the above-referenced tenure, the USDOT National Highway Traffic Safety Administration (NHTSA) and the Federal Motor Carrier Safety Administration (FMCSA) have  promulgated an extensive list of vehicle-based safety regulations.  It is gratifying to note that results of the above-referenced research have been very effective in influencing the final-rule regulatory requirements adopted by both USDOT Agencies. In other instances, vehicle manufacturers have utilized research results to make product design improvements on a voluntary basis, thus negating need for the Agency’s promulgation of new or revised regulations.  The topic of cab crashworthiness, as discussed above, is a good example to illustrate this situation. Truck manufacturers have significantly upgraded cab crashworthiness designs even though the applicable FMVSS-208 still only requires the installation of lap belts.  Thus, FMVSS-208 has not been amended since it was initially issued by NHTSA in 1972.

Summary Comment  

The above history provides a wealth of information that can be used to substantiate the  significant progress made in improving the design of heavy trucks since enactment of the 1966 Safety Act. Reference document Four Decades of Truck Safety Progress provides an overview of this 40-year process and accomplishments.

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