Joint Comments on Update to Model Minimum Uniform Crash Criteria (MMUCC) Guideline
May 5, 2023
Comments from the Institute for Safer Trucking and Road Safe America on Agency Information Collection Activities; Proposals, Submissions, and Approvals: Draft Model Minimum Uniform Crash Criteria Guideline, Sixth Edition
Docket No. NHTSA-2023-0002
The Institute for Safer Trucking (IST) and Road Safe America (RSA) submit the following joint comments in response to the National Highway Traffic Safety Administration’s (NHTSA) request for comments to inform updates to the forthcoming Sixth Edition of the Model Minimum Uniform Crash Criteria (MMUCC) Guideline, anticipated in 2024.
IST and RSA strongly support the inclusion of the new Vehicle Data Element, V42. Vehicle Underride/Override, in the Sixth Edition of the MMUCC. Including this specific field for underride and override will help improve data collection effort. Consequently, better data will enhance NHTSA’s ability to accurately determine the benefits of technologies, like underride protection devices, that can reduce the number of deaths and serious injuries that occur in underride crashes.
Underride Crashes are Undercounted
Currently, the number of fatal crashes that are coded in the Fatality Analysis Reporting System (FARS) as involving underride/override are undercounted. This finding was corroborated in a recent report from the Government Accountability Office, Truck Underride Guards: Improved Data Collection, Inspections, and Research Needed. The report also found that only 17 states had a specific field for "underride." The GAO report can be found here: https://www.gao.gov/products/gao-19-264
In the 2022 Safer Trucking Report, Institute for Safer Trucking looked at the differences in reported underride fatalities between five states with an underride field on their police accident report (PA, NC, IL, KY, IA) and five states without such a field (TX, CA, FL, GA, OH). The differences were alarming. From 2011 to 2020, states with an underride field reported 2.7 times as many truck underride deaths as states that did not have a field for underride.
Put another way, approximately 12 percent of truck crash deaths in states with a field for underride were coded as having underride, whereas this number fell to just four percent in states without a field for underride. So, while the total underride deaths from 2011 to 2020 for the five states was 664, it could be much higher. For example, if the abovementioned five states without an underride field reported at similar levels to five states with a field, the number of deaths would have been closer to 1807 (15,311 total deaths times 11.8 percent). The 2022 Safer Trucking Report, which used data from FARS, can be found here: https://static1.squarespace.com/static/5ea971b432e2ec4105a9a422/t/63b8683a689a2f0cfae26591/1673029691886/2022+Safer+Trucking+Report+-+Final.pdf
Conclusion
We look forward to the inclusion of a specific field for underride/override in the Sixth Edition of the MMUCC as it will address the significant undercount of underride crashes involving vehicles. We strongly encourage NHTSA to also address vulnerable road users that are injured and killed in truck underride crashes. Unfortunately, even with this change, bicyclists and pedestrians would still not be captured as having been involved in an underride crash since NHTSA considers underride/override to be a vehicle factor.
