In a recent FleetOwner article, Kevin Jones outlined the pending inspection changes regarding rear underride guards on trailers. On December 29th, the FMCSA published a Notice of Proposed Rulemaking adding underride guards to the list of components requiring periodic inspection for trailers. Overall, I do not see this as a major concern if two technical issues are addressed as outlined in the article; labeling and repair/replacement guidelines. Many years ago, when regulations for rear underride guard structure and certification were issued, OEMs placed temporary labels on rear underride guards to inform the installer, and the eventual owner of the vehicle, that the product had been tested and met all applicable regulations. As stated earlier, there were no requirements for periodic inspection of the underride guard’s label, so it was not maintained or inspected for being in place. After a few months, or years, the labels would degrade and detach from the guard. This became a major issue in 2018 when the CVSA began issuing citations, not because the rear guards were defective but for missing the required (in their opinion) labels. After major pushback from fleets, the CVSA reversed its practice of inspecting underride guards and citing fleets and drivers for missing labels. In reviewing the proposed rulemaking there is nothing in the proposal to address the requirement of a permanent label. Before the new rules are released the underride, guard label issue must be addressed. The other issue raised by the article is the repair process for underride guards. During the operation of the trailer, damage to the rear guard is inevitable and the regulations are silent regarding repair / replacement processes. This also needs to be addressed before enforcement begins. If the industry can receive more definition around these two concerns, acceptance will not be an issue. Without answers we are doomed to repeat the same issues we encountered in 2018.
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