Walgenbach concludes NRMCA and TMMB observations on the "Rear Impact Protection" section with suggestions that NHTSA resubmit a proposed rulemaking for public comment with a completed cost and benefit analysis; an emphasis on determining the best and newest methods for preventing rear
underride crashes and their potential accompanying injury and fatality reductions; clarification of whether a forthcoming mandate would apply to new trucks and in-service vehicles; and, consideration of a five-year phase that would allow SUT manufacturers to address challenges of bringing existing designs into CMVSS-level compliance.
Underride crashes, in which passenger vehicles slide beneath large trucks, are much more common than federal statistics indicate, according to researchers at the Insurance Institute for Highway Safety, Arlington, Virginia.