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NHTSA puts cost of mandatory side underride guards at up to $1.2B

Agency to use recent analysis to inform potential requirements for new truck trailers

Trucking groups say data is not there to support an underride guard mandate. (Photo: IIHS)

WASHINGTON — Federal regulators have estimated the annual cost to equip new truck trailers with side underride guards at up to $1.2 billion as the Biden administration takes the first step toward a potential requirement aimed at reducing crash fatalities.

The National Highway Traffic Safety Administration announced on Tuesday it will be publishing in the Federal Register a notice and comment on the preliminary cost estimates, which are based on the agency’s most recent research and analysis. At the same time, NHTSA named 16 members of a new Advisory Committee on Underride Protection to make recommendations to the secretary of transportation on regulations related to underride crashes.

“The selection and establishment of this committee is a step forward in saving lives and fulfilling the goals of the Bipartisan Infrastructure Law,” said NHTSA Deputy Administrator Sophie Shulman. “This committee will inform future actions and ensure that key stakeholders have a seat at the table on this important issue.”

The 16 committee members and the groups they represent are:


  • Marianne Karth and Jane Mathis (families of underride crash victims).
  • Harry Adler and Jennifer Tierney (truck safety organizations).
  • Lee Jackson and Aaron Kiefer (motor vehicle crash investigators).
  • Adrienne Gildea (law enforcement).
  • Daniel McKisson (labor organizations).
  • Jeff Bennett and Jeff Zawacki (motor vehicle engineers).
  • Matthew Brumbelow and Claire Mules (insurance industry).
  • Dan Horvath and Doug Smith (motor carriers).
  • John Freiler and Kristin Glazner (truck and trailer manufacturers).

According to NHTSA’s Advance Notice of Proposed Rulemaking, 17 lives would be saved and 69 serious injuries would be prevented each year if underride guards were installed on all trailers under a new standard.

The agency estimates that such a requirement would boost the cost of a new trailer by approximately $3,740 to $4,630 depending on the discount rate applied (which take into account the effects on investment and business and the return received by consumers), with total annual cost projected at $970 million to $1.2 billion.

“These estimated cost impacts do not include additional costs that accrue due to incremental wear and tear on equipped trailers,” NHTSA pointed out. “Side underride guards may impose non-uniform loads on trailer floors, adding stresses that decrease trailer lifetimes in the absence of repair. It is possible that side underride guards would obstruct proper safety inspections of the underside of the trailer. They may also strike or entangle with road structures and loading area components, leading to additional repair costs or restricted access to destinations.”

Also not included in the estimate is the additional operating costs resulting from side underride guards restricting the movement of trailer rear axles, which normally can be adjusted to accommodate loading conditions.


“Furthermore, the estimated costs do not include any potential effects of side underride guards on port and loading dock operations and freight capacity, and on increased greenhouse gases and other pollutants resulting from increased fuel consumption,” NHTSA cautioned.

“We seek comment on the practicability and feasibility of side underride guards regarding intermodal operations and effects of side underride guards on intermodal equipment, freight mobility, freight capacity, and port operations.”

Trucking interests already pushing back

Both big carriers and owner-operators have long been concerned about the costs of a potential side-guard mandate, asserting that there is a lack of evidence showing the benefits would outweigh the costs.

“To make matters worse, we now have an advisory panel in place that gives more influence to representatives who have no clue how to operate a heavy vehicle than those who understand the serious operational challenges and hazards created by side underride guards,” Todd Spencer, president of the Owner-Operator Independent Drivers Association, said of the upcoming proposed rulemaking.

“We will not see improvements in highway safety until lawmakers and federal regulators prioritize the expertise of professional drivers above other interest groups.”

David Heller, vice president of safety and government affairs for the Truckload Carriers Association, believes more research needs to be done before the government rolls out a mandate.

“If a rule got done today on equipment that hadn’t been tested out, it would be the most expensive mandate ever placed on the trucking industry,” Heller said during a TCA regulatory update in October.

“It’s one of those issues for which we still have a ton of questions, and they will need to be answered before they move forward with a rule.”


Click for more FreightWaves articles by John Gallagher.

8 Comments

  1. Einstein Jones

    It’s the cars. In 1968 Ford calculated it was cheaper to pay lawsuits for their exploding Pinto gas tanks than to spend $11 dollars to put in new gaskets and a stronger fill pipe.

  2. Charles Quail

    Einstein wishes to weigh in on this problem. What exactly IS the problem? There will also be the solution.
    Cars sliding under a trailer from the side, they say, and passengers getting crushed when the roof and windshield collapse.
    Well, says Einstein, the problem IS THE CAR CONSTRUCTION, NOT THE TRUCK
    The solution is to mandate the auto makers to reinforce their cars roofs, windshields and the structure holding them all together. But trucks are such easy scapegoats blame them rather than the car makers’ inferior construction. Next they’ll want all telephone poles to have rubber baby buggy bumpers on them for the folks that drive cars that cannot survive a collision with them. Yeesh, when will they finally mandate that the cars be safer?

  3. ridiculous

    Again the trucker has to foot the BILL.
    Instead of going after the automobile drivers, they always punish the truckers.

  4. Victor

    17 lives saved? I saw at least 17 people on their cell phones while driving on the interstate around Chicago today. How about the cops handle that first and we’ll worry about under ride guards later.

  5. Dave

    Of all the years driving OTR, more than 80% of accidents that I had witnessed were cause by the car driver; either trying to overtake the truck, or cutting in front of the truck, or (this one really gets me aggravated), merging in a lane that had signs both 1 mile, and a 1/2 mile before the merge, and waited until the last moment to cut into the driver’s lane. Nowadays, I see so many people on their cell phones, not paying attention, but of course, let’s blame the truck driver because his vehicle is so much bigger. Let’s impound more rules on the truck driver, but get our freight delivered faster. You cannot have you cake and eat it too. Why doesn’t the Federal Regulators go after the car driver doing 80 – 90 miles an hour (some upwards of 100MPH) and causing problems, and let the driver do his job without more Red Tape road blocks,

  6. Carlos🇺🇸

    ⚠️💥 Once again they’re trying to FIX the Trucks instead of the Cars that cause 80% of the Accidents and 100% of the underrides ⚠️💥

    Congratulations #Idiocracy_USA once again 👌🇺🇸👌🇺🇸

  7. Steve

    I see two problems right away.
    1. Half loading docks unaccessible due to ramps being too low
    2. Many many many railroad crossings that are elevated bottoming out trailers

  8. OGM Production Studio BBYUA Trucking LLC

    Technology wide based computer programming links with self driving cars and trucks Wi-Fi Bluetooth and other forms of data communication links have a dangerous effect on highway safety for human life without proper training; all rules of the road being followed would greatly help without speeding incorrect lane changes. This new Technology will help law enforcement be able to pin point everything with a click of a button but will it be to late………..
    Truckers stay safe FMCSA safety rules and regulation drive responsibly.
    OGM Production Studio BBYUA Trucking LLC

Comments are closed.

John Gallagher

Based in Washington, D.C., John specializes in regulation and legislation affecting all sectors of freight transportation. He has covered rail, trucking and maritime issues since 1993 for a variety of publications based in the U.S. and the U.K. John began business reporting in 1993 at Broadcasting & Cable Magazine. He graduated from Florida State University majoring in English and business.