OOIDA says a federal push to mandate electronic stability control systems on heavy trucks and buses overstates the benefits and understates the cost.
In comments to the National Highway Traffic Safety Administration filed Aug. 21, OOIDA President Jim Johnston also said the agency’s notice of proposed rulemaking issued in May failed to take into account other viable measures that could reduce crashes, injuries and fatalities.
The notice by NHTSA issued May 23 calls for electronic stability control systems, or ESCs, to be standard on new trucks by 2016.
The agency estimates the cost of an ESC system at $1,160 per truck. But as OOIDA points out in its comments, that number is an average of various models including cheaper ones that may not meet the standards of a mandate.
According to current manufacturers’ pricing, ESC systems by Meritor-Wabco cost around $1,800 while Bendix systems range from $2,000 to $2,300.
By those estimates, a mandate would cost the trucking industry $157 million to $187 million per year, much higher than NHTSA’s estimate of $113 million a year.
Next, OOIDA says the agency has overstated the benefits of an industry-wide mandate for ESC systems.
Johnston says an ESC mandate, when coupled with other costly mandates, is putting the trucking industry on pace for $200,000 trucks.
While NHTSA suggests the extra costs could simply be passed on to customers, OOIDA begs to differ, saying an individual carrier cannot simply pass on all costs and remain competitive in a shipper-driven marketplace.
NHTSA’s claim that ESC could prevent up to 2,300 crashes, up to 858 injuries and up to 60 fatalities each year is based on inaccurate assumptions about truck crashes and about the vehicles that have ESC, Johnston stated in the comments.
OOIDA suggests other viable means to address safety issues than actions that focus solely on equipment mandates.
“OOIDA has consistently proposed better and more comprehensive driver training standards as an alternative solution to a myriad of safety-related problems,” Johnston stated.
“New-driver training could emphasize proper speeds for negotiating ramps and curves, behaviors to avoid on particular road surfaces, dangers of evasive driving maneuvers, and best loading practices. A better understanding of these subjects will help eliminate, at an early stage, the underlying driver errors that NHTSA itself has identified as real-world behaviors that commonly play a role in rollovers and loss-of-control.”
In addition to training, OOIDA says law enforcement should focus on enforcing laws that prohibit certain “unacceptable behavior.”
“Driving too fast for conditions and other unsafe driving practices that undeniably contribute to many rollover and loss-of-control crashes could not only be reduced through better training,” Johnston stated, “… but also by more aggressive enforcement of the plethora of state laws already on the books, laws that prohibit unacceptable behaviors that amount to inattentive or negligent driving practices.”
OOIDA is also advocating for better cab-crashworthiness standards for trucks to prevent injuries and deaths in the driver community.
Tankers could be better designed, as well, to prevent rollovers in those types of vehicles.
Regarding design, OOIDA suggests that NHTSA take a look at the adequacy of signage and markings at crash hotspots such as sharp curves.
“Because warning signs are often put quite close to the rollover hotspots, they do little to ameliorate the problem,” Johnston stated. “NHTSA should work with other government officials to mitigate the problems and improve safety at these sites.”
OOIDA’s comments conclude by saying there is “virtually no direct crash data showing that a costly ESC mandate is the most effective means to reduce crashes due to rollovers or loss of control.”
According to a federal posting by NHTSA, the agency has until July 2014 to take steps toward a final rule.
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