Asphalt group: Underride guard rule unworkable in current dump trucks

Sources: National Asphalt Pavement Association (NAPA), Lanham, Md.; CP staff

While the National Ready Mixed Concrete Association cites cost and weight concerns surrounding prospective changes NHTSA outlines in “Rear Impact Protection, Lamps, Reflective Devices, and Associated Equipment, Single Unit Trucks,” NAPA sees new underride guard specifications fundamentally altering members’ truck and paving machine fleets.


In comments to Transportation Secretary Anthony Foxx, NAPA Vice President for Environment, Health & Safety Howard Marks, Ph.D., J.D. observes: “Standardized underride guards cannot be installed on standard rear-discharge dump trucks that haul asphalt pavement mix without affecting the configuration between current paving machines and dump truck beds—necessitating the redesign and replacement of an entire class of equipment, specifically asphalt paving machines, which would be extremely expensive, time intensive, and disruptive to the entire transportation infrastructure sector.

“While the asphalt pavement industry is supportive of efforts to improve the safety of paving operations and equipment, it is clear that shortening the effective ‘wheels back’ clearance exemption from 24 inches to 12 inches and mandating the fixing of underride guards on SUTs, such as rear-discharge dump trucks, is impractical and would cause significant hardship and disruption to the road construction sector.”

Regarding the “Lamps, Reflective Tape” provision, Marks adds, “The inclusion of retroreflective material on dump trucks that haul asphalt pavement mix would likely be ineffective due to the physical nature of asphalt pavement mixture; specifically, its elevated temperature, black color, and stickiness … A requirement for retroreflective material is likely to have little benefit because normal operational activities are almost certain to reduce its reflective properties.”

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