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NRMCA, TMMB Voice Opposition to Federal Underride Guard Proposal

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Last week, NRMCA and the Truck Mixer Manufacturers Bureau (TMMB) filed joint comments on the National Highway Traffic Safety Administration’s (NHTSA) advanced notice of proposed rulemaking (ANPRM) aimed at requiring and strengthening rear underride guards for single unit trucks (SUTs), such as ready mixed concrete trucks. The proposal aims to consider possible amendments to the federal motor vehicle safety standards (FMVSS) requiring rear impact (underride) guards on all SUTs, including mixer trucks. While mixer trucks are currently required to install rear guards if they qualify, as per the Federal Motor Carrier Safety Regulations (FMCSRs), the proposal would now require that SUTs be compliant under NHTSA with a more robust standard, similar to the Canadian motor vehicle safety standards. Such a new requirement, which would also be imposed on tractor-trailer trucks as well, would potentially mean new mixer trucks would need to be equipped with a larger, heavier, more expensive underride guard than is currently required. The proposal also included questions about possible requirements for adding reflective tape to SUTs to increase truck visibility.

NRMCA’s and TMMB’s comments stressed concerns about increased added costs for purchasing mixer trucks with the updated guards, safety improvements and increased weight issues. Specifically, NRMCA and TMMB stated that, "the consequence of adding more weight to mixer trucks for compliance with each and every new regulation results in the industry being forced to reduce payload in order to stay compliant with weight tolerances. Meaning the industry is then forced to use more trucks, making more trips to deliver the same amount of ready mixed concrete. More trips means increased emissions, increased fuel consumption, more trucks sitting in traffic, and longer hours for industry drivers." NRMCA and TMMB also noted their opposition to a reflective tape mandate, stating, "...truck mixer manufacturers already apply reflective tape to all new mixer trucks in various capacities. Depending on the manufacturer, the mixer type, and equipment on the mixer truck, there are different amounts of reflective tape in different areas on mixer trucks. Moreover, many mixer truck clients have their own company safety requirements that dictate greater amounts of reflective tape on multiple surfaces."

Click here for more information on the underride guard proposal or contact Kevin Walgenbach at kwalgenbach@nrmca.org.
 

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