vision zero - annaleah & mary · 2016. 3. 6. · however, we are concerned that these safety...

VISION ZEROZERO CRASH DEATHS AND SERIOUS INJURIES

VISION ZEROZERO CRASH DEATHS AND SERIOUS INJURIES

The Delivery

of a

Vision Zero

Petition

March 2016

AnnaLeah & Mary for Truck Safety

© 2016 Marianne W. Karth. All rights reserved.

Published by AnnaLeah & Mary For Truck Safety

Interior design, layout, and production: Isaac Karth

Presidential Edition

annaleahmary.com

10 9 8 7 6 5 4 3 2

This book is lovingly compiled

in memory of AnnaLeah Karth

(forever 17) and

Mary Lydia Karth (forever 13)

Precious ones, your lives were cut

far too short.

Contents

Contents vii

Introduction ix

I Letter to President Obama 1

1 Petition Letter to President Obama 3

2 Letter of Support for the AnnaLeah & Mary for Truck SafetyVision Zero Executive Order Petition 5

3 Selected Comments From Current Executive Order PetitionSigners 9

II Executive Order 13

4 Why do we need a Vision Zero Executive Order? 15

5 What is Needed to Bring About a National Vision Zero Goal? 215.1 Action One: Set a National Vision Zero Goal . . . . . . 225.2 Action Two: Establish a White House Vision Zero Task

Force To Achieve Significant Crash Death Reduction . . 235.3 Action Three: Sign a Vision Zero Executive Order To Au-

thorize Vision Zero Rulemaking Policies . . . . . . . . . 27vii

viii CONTENTS

III Vision Zero 336 What is Vision Zero? 35

7 Why Are We Advocating For Vision Zero? 37

8 Traffic Injuries & Fatalities Data 41

9 Truck Underride: A Practical Application of a Vision Zero Goal 43

IV Petition 4710 Petition Letter to Secretary Foxx 49

11 About the Signers 51

12 Selected Comments by Signers of the Vision Zero Petition 53

13 Signatures to the Petition 57

14 Comments by Signers of the Petition 611

A Vision Zero Posts from AnnaLeahMary.com 621A.1 Chronologically archived: . . . . . . . . . . . . . . . . . . 621A.2 Alphabetical listing of Vision Zero posts: . . . . . . . . . 627

Introduction

In the aftermath of losing our two youngest daughters, AnnaLeah (17)and Mary (13), due to a truck underride crash on May 4, 2013, we becameaware of far too many facts about traffic fatalities.Along the way, we discovered that a global movement is underway-calledVision Zero. This term was coined in Sweden and has as its basis a coupleof “ethical rules” 1:

• “Life and health can never be exchanged for other benefits withinthe society”

• “Whenever someone is killed or seriously injured, necessary stepsmust be taken to avoid a similar event”

Every life is worth saving; there is no person who will not be missed bysomeone: 2

In an effort to do more than just put a bandaid on the problem, welaunched a campaign to call for major change in how safety laws andregulations are determined. This book is a compilation of our request fora National Vision Zero Goal and for a Vision Zero rulemaking policy.It includes our petition letters to President Obama and DOT SecretaryFoxx—along with the signatures and comments of thousands of peoplewho signed the petitions and are speaking up with us to call for a moveTowards Zero Crash Deaths & Serious Injuries.

1http://www.monash.edu/miri/research/reports/papers/visionzero2https://www.youtube.com/watch?v=bsyvrkEjoXI

ix

http://www.monash.edu/miri/research/reports/papers/visionzerohttps://www.youtube.com/watch?v=bsyvrkEjoXI

Part I

Letter to President Obama

1

1Petition Letter to President

Obama

Dear President Obama:

After losing two daughters, AnnaLeah (17) and Mary (13) in a truckunderride crash on May 4, 2013, the Karth family took over 11,000 en-velopes with signed petitions from the “AnnaLeah & Mary Stand Up ForTruck Safety Care2 Petition” to Washington, DC, one year later on May5, 2014. At that time, they met with administrators from FMCSA andNHTSA and discussed, at length, their concerns about truck safety issues.

Since that time, they have set up a non-profit, AnnaLeah & Mary forTruck Safety, to promote highway safety research and federal regulationsto protect motorists, pedestrians, & cyclists. And, in fact, there has beensome progress with the issuing of a final rule for Electronic Logging De-vices and the initiation of rulemaking steps related to underride guardsand minimum liability insurance for truck companies.

However, we are concerned that these safety measures, as well as oth-ers, are being unnecessarily delayed and/or weakened by the restrictionsplaced upon the rulemaking process by President Clinton’s Executive Or-der 12866. As you know, the Department of Transportation makes high-way safety rules based upon how much safety measures will cost. Instead,we want to establish a U.S. Vision Zero goal and move toward ZeroDeaths, Zero Injuries, Zero Fear of Traffic.

One of the biggest challenges to making change is the cost/benefit anal-ysis. On the one side there are lives to be saved and on the other sidethere are companies working to make money. The trick is to try and meeteveryone’s needs. The solution has to be effective in saving lives while

3

4 CHAPTER 1. PETITION LETTER TO PRESIDENT OBAMA

still being affordable for companies so that they can make the changesnecessary without a lot of struggle.The problem comes in when human life and health get the short end ofthe stick. The result is that many safety measures are blocked because theywould cost more to implement than the “worth” of the “small” number ofhuman lives which would be saved. That’s just not right.Therefore we are asking you to write an Executive Order which would seta Vision Zero goal for our country. This EO will pave the way for strongersafety measures to be established in a more timely manner; saved lives willbe a higher priority than saved dollars.This Executive Order should also provide DOT with resources and au-thority to hold appropriate parties responsible for implementing the rules,as well as hold them accountable to meet performance outcomes whichensure human life and health. Furthermore, the Executive Order shouldinclude a requirement for annual progress reports.On average, 33,000 people die each year in crashes on our roads. Our fam-ilies cannot continue to sustain this unacceptably high number of lossesand injuries. We urge you to take immediate action so that more lives willnot be lost and to assure us that safety is your number one priority.Sincerely,The AnnaLeah & Mary for Truck Safety Vision Zero Petition onChange.org1

1https://www.change.org/p/obama-adopt-a-vision-zero-goal-and-sign-an-executive-order-to-save-lives-not-dollars

https://www.change.org/p/obama-adopt-a-vision-zero-goal-and-sign-an-executive-order-to-save-lives-not-dollarshttps://www.change.org/p/obama-adopt-a-vision-zero-goal-and-sign-an-executive-order-to-save-lives-not-dollars

2Letter of Support for the

AnnaLeah & Mary for Truck SafetyVision Zero Executive Order

Petition

Due to a shared interest in reducing preventable traffic fatalities andserious injuries, we are working together to raise awareness and garnerwidespread support for a national Vision Zero Goal and to petitionPresident Obama to sign a Vision Zero Executive Order.This effort is supported by the following individuals and organizations:

Jerry & Marianne KarthAnnaLeah & Mary for Truck SafetyRocky Mount, North Carolinahttp://annaleahmary.com/

Andy YoungHusband, father, truck owner, Class A CDL driver, truck accident at-torney, and trial attorney fighting for you and your loved ones to have aSafeDriveHome, Cleveland, Ohiohttp://www.nphm.com/about-us/attorneys/andrew-young/

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http://annaleahmary.com/http://www.nphm.com/about-us/attorneys/andrew-young/

6 CHAPTER 2. LETTER OF SUPPORT

Neil ArasonRoad Safety Researcher, Author of No AccidentVictoria, British Columbiahttp://neil.arason.ca/

Lance HammRoad Safety AdvocateKingsville, Texas

Stephen Hadley, CoordinatorUnderride Network, Victim/SurvivorWashougal, Washingtonhttp://www.underridenetwork.org/

Emily Stein, President, Safe Roads AllianceDaughter against distracted driving, safety advocate who aims to increaseawareness of the dangers caused by distracted drivinghttps://twitter.com/emstein30?lang=en

Louis LombardoAuto Safety Researcher and AdvocatePublisher of safety resources at Care for Crash Victimshttp://www.careforcrashvictims.com/

Carol S. “Cally” Houck, Attorney at LawMother and Survivor of Raechel and Jacqueline Houck Safe Rental CarActAdvocate and activist for highway safety and Auto Industry accountabilityOjai, CaliforniaSupport the Raechel and Jacqueline Houck Safe Rental Car Act1

1https://www.change.org/p/rep-fred-upton-repfredupton-support-the-raechel-and-jacqueline-houck-safe-rental-car-act

http://neil.arason.ca/http://www.underridenetwork.org/https://twitter.com/emstein30?lang=enhttp://www.careforcrashvictims.com/https://www.change.org/p/rep-fred-upton-repfredupton-support-the-raechel-and-jacqueline-houck-safe-rental-car-acthttps://www.change.org/p/rep-fred-upton-repfredupton-support-the-raechel-and-jacqueline-houck-safe-rental-car-act

7

Laura ChristianBirth mother of Amber Marie Rose, who died in 2006 due to the ignitionswitch defect that GM covered up for a decadehttps://www.facebook.com/gmrecall.survivors/?fref=ts

John Lannen, DirectorTruck Safety Coalitionhttp://trucksafety.org/

Michael Lemov, authorCar Safety Wars: 100 Years of Technology, Politics, & Deathhttp://www.amazon.com/Car-Safety-Wars-Technology-Politics/dp/161147745Xhttp://www.johnemossfoundation.org/bio/lemov.htm

Leah ShahumFounder & Director, Vision Zero NetworkNonprofit campaign supporting Vision Zero efforts across the U.S.http://visionzeronetwork.org/

Paul and Sue Oberhauser,National Co-Chairs, Traffic Safety Coalitionhttp://www.trafficsafetycoalition.com/

Melissa WandallPresident of the National Coalition for Safer RoadsThe Mark Wandall Traffic Safety Act of FloridaReducing the Risk at our Intersectionshttp://www.MelissaWandall.com

https://www.facebook.com/gmrecall.survivors/?fref=tshttp://trucksafety.org/http://www.amazon.com/Car-Safety-Wars-Technology-Politics/dp/161147745Xhttp://www.amazon.com/Car-Safety-Wars-Technology-Politics/dp/161147745Xhttp://www.johnemossfoundation.org/bio/lemov.htmhttp://visionzeronetwork.org/http://www.trafficsafetycoalition.com/http://www.MelissaWandall.com

3Selected Comments From Current

Executive Order Petition Signers

We need truck laws to improve highway safety Trucks kill toomany people every year.

—Pamela Batchelor, Hendersonville, NC

I’m signing because as a Texan, my state has shamefully av-eraged 3,500 annual road deaths in the past 20 years. Basedon historical data, I seriously doubt the Texas state legislatureor state DOT has the skill or the desire to improve in thearea of fatality reduction on Texas roads. For the safety of allroad-users, the USA needs the help of a national Vision Zerostrategy.

—Lance Hamm, Kingsville, TX1

Vision zero in road safety is an imperative public health goal,and one that is now fully realistic to embark upon.

—Neil Arason, Victoria, Canada2

As President of the National Coalition for Safer Roads http://ncsrsafety.org we believe in working together to cutdown on crashes and save lives! Please! We urge you to signthis life saving petition.

1https://www.change.org/p/obama-adopt-a-vision-zero-goal-and-sign-an-executive-order-to-save-lives-not-dollars/c/367963670


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http://ncsrsafety.orghttp://ncsrsafety.orghttps://www.change.org/p/obama-adopt-a-vision-zero-goal-and-sign-an-executive-order-to-save-lives-not-dollars/c/367963670https://www.change.org/p/obama-adopt-a-vision-zero-goal-and-sign-an-executive-order-to-save-lives-not-dollars/c/367963670https://www.change.org/p/obama-adopt-a-vision-zero-goal-and-sign-an-executive-order-to-save-lives-not-dollars/c/366095674https://www.change.org/p/obama-adopt-a-vision-zero-goal-and-sign-an-executive-order-to-save-lives-not-dollars/c/366095674

10 CHAPTER 3. SELECTED COMMENTS

—Melissa Wandall, Bradenton, FL3

I lost my dad due to a crash that was 100% preventable. Vi-sion Zero works, and if we take it on as a country, we can dra-matically reduce the number of fatalities and serious injuries.Motor Vehicle crashes are the #1 killer for people aged 3-34.This must change.

—emily stein, Brooklyn, NY4

I don’t think that people should die as an accepted cost of ourtransportation infrastructure.

—Kristin Dubrule, Seattle, WA5

I’m signing because I don’t want to we another family gothrough what the Karth family has.

—tina ogg, Grand Rapids, MI6

Road safety is everybody’s business and responsibility.

—Joan Moore, san francisco, CA7

I lost my mother in a truck crash.

—Shannon Shumaker, Saint Petersburg, FL8

I am signing this petition as a widow and now single mother ofthree children because a tired or distracted truck driver killedmy husband while he was inspecting a bridge repair in hisclosed-off work zone. The pain of losing a loved one to thesepreventable crashes is beyond words. Losing a father at such ayoung age will leave emotional scars for decades, and our soci-ety doesn’t fully understand or offer appropriate resources forcoping.







https://www.change.org/p/obama-adopt-a-vision-zero-goal-and-sign-an-executive-order-to-save-lives-not-dollars/c/380563126https://www.change.org/p/obama-adopt-a-vision-zero-goal-and-sign-an-executive-order-to-save-lives-not-dollars/c/380563126https://www.change.org/p/obama-adopt-a-vision-zero-goal-and-sign-an-executive-order-to-save-lives-not-dollars/c/374802846https://www.change.org/p/obama-adopt-a-vision-zero-goal-and-sign-an-executive-order-to-save-lives-not-dollars/c/374802846https://www.change.org/p/obama-adopt-a-vision-zero-goal-and-sign-an-executive-order-to-save-lives-not-dollars/c/369845466https://www.change.org/p/obama-adopt-a-vision-zero-goal-and-sign-an-executive-order-to-save-lives-not-dollars/c/369845466https://www.change.org/p/obama-adopt-a-vision-zero-goal-and-sign-an-executive-order-to-save-lives-not-dollars/c/369638010https://www.change.org/p/obama-adopt-a-vision-zero-goal-and-sign-an-executive-order-to-save-lives-not-dollars/c/369638010https://www.change.org/p/obama-adopt-a-vision-zero-goal-and-sign-an-executive-order-to-save-lives-not-dollars/c/368811686https://www.change.org/p/obama-adopt-a-vision-zero-goal-and-sign-an-executive-order-to-save-lives-not-dollars/c/368811686https://www.change.org/p/obama-adopt-a-vision-zero-goal-and-sign-an-executive-order-to-save-lives-not-dollars/c/368558002https://www.change.org/p/obama-adopt-a-vision-zero-goal-and-sign-an-executive-order-to-save-lives-not-dollars/c/368558002

11

—Amy Fletcher, Perrysburg, OH9

I am signing in honor of my late wife Tamara Mills-Hadleywhom lost her life because a phoney underride guard law waspassed that was not meant to save any lives, instead it justlegalized the guards already on the road in order to save moneyand garner campaign donations. We also lost a family friendto unsafe trucks. No more!

—Stephen Hadley, Washougal, WA10

I’m signing because no one should have to suffer a sudden,unexpected loss of a loved one due to a preventable crash.

—Andrew Young, North Ridgeville, OH11

WE NEED A VISION ZERO GOAL ANDSIGNS…NOW TO SAVE LIVES!!!

—DONNA LAGOMARSINO, Wilmington, MA12

I’m signing because the loss of one human life in the pursuitof profit is wrong! Safety first!

—Hershel Hartford, Fayetteville, AR13

I’m signing because tragedies like this one can be avoided.

—Aaron Kiefer, Morrisville, NC14







https://www.change.org/p/obama-adopt-a-vision-zero-goal-and-sign-an-executive-order-to-save-lives-not-dollars/c/368460858https://www.change.org/p/obama-adopt-a-vision-zero-goal-and-sign-an-executive-order-to-save-lives-not-dollars/c/368460858https://www.change.org/p/obama-adopt-a-vision-zero-goal-and-sign-an-executive-order-to-save-lives-not-dollars/c/367847506https://www.change.org/p/obama-adopt-a-vision-zero-goal-and-sign-an-executive-order-to-save-lives-not-dollars/c/367847506https://www.change.org/p/obama-adopt-a-vision-zero-goal-and-sign-an-executive-order-to-save-lives-not-dollars/c/367268046https://www.change.org/p/obama-adopt-a-vision-zero-goal-and-sign-an-executive-order-to-save-lives-not-dollars/c/367268046https://www.change.org/p/obama-adopt-a-vision-zero-goal-and-sign-an-executive-order-to-save-lives-not-dollars/c/366575618https://www.change.org/p/obama-adopt-a-vision-zero-goal-and-sign-an-executive-order-to-save-lives-not-dollars/c/366575618https://www.change.org/p/obama-adopt-a-vision-zero-goal-and-sign-an-executive-order-to-save-lives-not-dollars/c/366309238https://www.change.org/p/obama-adopt-a-vision-zero-goal-and-sign-an-executive-order-to-save-lives-not-dollars/c/366309238https://www.change.org/p/obama-adopt-a-vision-zero-goal-and-sign-an-executive-order-to-save-lives-not-dollars/c/366298758https://www.change.org/p/obama-adopt-a-vision-zero-goal-and-sign-an-executive-order-to-save-lives-not-dollars/c/366298758


Because business shoots for zero defects. Because my wife isdead and two sons seriously injured, one permanently, whenan overworked trucker fell asleep at the wheel.

—Ed Slattery, Lutherville-Timonium, MD15

I’m signing for Susan Slattery!

—Camille Dobson, LUTHERVILLE, MD16



https://www.change.org/p/obama-adopt-a-vision-zero-goal-and-sign-an-executive-order-to-save-lives-not-dollars/c/366099098https://www.change.org/p/obama-adopt-a-vision-zero-goal-and-sign-an-executive-order-to-save-lives-not-dollars/c/366099098https://www.change.org/p/obama-adopt-a-vision-zero-goal-and-sign-an-executive-order-to-save-lives-not-dollars/c/366132414https://www.change.org/p/obama-adopt-a-vision-zero-goal-and-sign-an-executive-order-to-save-lives-not-dollars/c/366132414

Part II

Executive Order

13

4Why do we need a Vision Zero

Executive Order?

Vision Zero, in the simplest language, is the embracing of a vision or hopethat we could work toward reducing crash deaths (and serious injuries)to zero. That no one would ever die in a traffic crash. It is, of course,understood that—life being what it is—we will never actually reach zero.But Vision Zero insists that certainly such a goal is desirable and, in fact,so much so that everything humanly possible should be done to accom-plish it. One life at a time. To do anything less would be unthinkable.And yet, that is exactly what we find ourselves doing—too often makingdecisions based on other priorities. Somehow we are unable to justifyspending time or resources to make it a tangible priority to do somethingabout crash deaths—especially because we might even think that they areinevitable. And that’s another thing about Vision Zero; it understandsthat many, if not most, crash deaths are in fact preventable and, oh, sounnecessarily tragic.What does this look like in real life? It is beyond the scope of this bookto describe the multitude of traffic issues which could and should be ad-dressed, but let me just point out one: truck underride guards. Despiteknowledge about the horrific deaths and injuries which take place when acar rides under a truck and the research which has shown how weak thecurrent underride guards are and what could be done to strengthen them,there continues to be too little done to correct this situation.The result is that year after year countless more people needlessly die be-cause the underride problem did not get adequately fixed. When it couldhave.

15

16 CHAPTER 4. WHY AN EXECUTIVE ORDER?

To illustrate this, let me share part of the public comment made by thehusband of a woman who died in an underride crash twenty years ago.He was commenting on the recent rulemaking for the upgrade of rearimpact protection on trailers,

As Luis Otto from Brazil used to say, you can change. Youdo not have to be “Mad Gods with power over life and death”,you do not have to champion laws that kill! We know from arecent study that the previous underride guard law from 1996which also legalized guards already on the road saved none orfew lives! This law broke the heart and spirit of victims andsafety activists and your recent actions will do no less. I workin honor of my late wife Tamara Mills Hadley as most victimslabor in honor of their lost loved ones. We also work to savethose we have not met, those waiting to meet their fate in thefuture. That boy or girl a couple of years from now that willdie or be maimed or become an orphan if we fail! They arewaiting, what will be my fate!

We as spouses, or parents, or grandparents worry everydayabout our families safety on American roads. Roads and carsare safer but those increasing numbers of big trucks can stillkill you in an instant. You will probably survive crashing intoa telephone pole at mid range speeds but a stopped or slowmoving truck, not so much! We worry! This sickness called‘cost benefit analysis’ you and corporations worship so muchcan never value our hearts, it is a validation of our worst fears.You are in the process of giving away a windfall for the carand trailer manufacturers, no improvement or cost for the nexttwenty years, but you are smashing the hopes and wishes of somany. Tears will be shed! We demand Vision Zero, we do nothave time for anything less anymore. Our hearts have achedfor too long. —Steve Hadley1

What he expresses is the shared frustration of those who work diligentlyto face one unnecessary hurdle after another in the attempt to make theroads safer. And then, when they come to the end of the race, find thatthey have lost and that the race was hopeless to begin with because theiropponent was impossible to beat. With an unfair advantage.

1http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0118-0004

http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0118-0004http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0118-0004

17

Only it is not a mere matter of a lost contest but an apparently hopelessquest to save other lives. Read that: to save someone from a sentence ofDeath by Motor Vehicle. When it could have been preventable.And why is that opponent so impossible to beat? Because the plumblineused to measure whether a safety standard or regulation is affordable isthe cost/benefit analysis delineated in Executive Order 12866 2., whichrequires that a dollar value be attached to the benefit of a human life. Andif the costs calculated are higher than the benefit, then that human lifeis not considered worthy of saving. The rule is thus rejected (or compro-mised) because it does not provide “significant safety consequence.”3

The Office of Information and Regulatory Affairs (OIRA) as an agency ofthe Office of Management and Budget has been given the responsibility tooversee this cost/benefit analysis and to make decisions accordingly aboutwhat safety standards are issued.4

OIRA, not the agency, makes the final determination ofwhich rules are considered to be significant. For all signifi-cant rulemakings, the agencies must provide OIRA with thetext of regulation, a statement of need, and “an assessment ofcosts and benefits of the regulatory action.” 5

Economically significant regulations must meet additional an-alytical requirements: Anticipated benefits and costs must bequantified to the extent possible; Agencies must provide cost-benefit analysis of reasonable alternatives and “an explanationof why the planned regulatory action is preferable to the iden-tified potential alternatives.” 6

It is this process that we would like to see addressed by a Vision Zero Ex-ecutive Order that would revise the rulemaking process to provide for thetimely issuance and implementation of reasonable and appropriate safetymeasures which are proven to save lives. The opposite is to reject suchmeasures because they would cost “too much” per life saved. Whose lifeare we planning on giving up?We are not asking to throw out all research and analysis. After I discussedthis concern with another safety advocate, he suggested the alternative ap-

2http://www.foreffectivegov.org/node/2243http://www.regulations.gov/#!documentDetail;D=NHTSA_FRDOC_0001-

15484https://www.whitehouse.gov/omb/oira/about5http://www.foreffectivegov.org/node/2246http://www.foreffectivegov.org/node/224

http://www.foreffectivegov.org/node/224http://www.regulations.gov/#!documentDetail;D=NHTSA_FRDOC_0001-1548http://www.regulations.gov/#!documentDetail;D=NHTSA_FRDOC_0001-1548https://www.whitehouse.gov/omb/oira/abouthttp://www.foreffectivegov.org/node/224http://www.foreffectivegov.org/node/224

18 CHAPTER 4. WHY AN EXECUTIVE ORDER?

proach of cost-effectiveness analysis vs cost/benefit analysis. I have takena quick look at a description of it online and will be thinking about itfurther. This is a brief description of such an approach:

“Cost-effectiveness analysis (CEA) is a form of economic anal-ysis that compares the relative costs and outcomes (effects) oftwo or more courses of action. Cost-effectiveness analysis isdistinct from cost-benefit analysis, which assigns a monetaryvalue to the measure of effect.”7

My question is, “Would such an approach lead to a reduction in crashdeaths & serious injuries?” In other words, would it further the goal ofVision Zero? Towards Zero.A cost effectiveness model is used by the Center for Disease Control, asdescribed here:

Cost-effectiveness analysis (CEA) is a type of economic anal-ysis where both the cost and the outcome (impact, result, ef-fect, benefit, health gain…) of an intervention are evaluatedand then expressed in the form of a cost-effectiveness ratio.The numerator of the cost-effectiveness (CE) ratio representsthe cost of the intervention associated with one unit of “out-come”. The denominator is the unit of outcome. It can be ex-pressed using many types of measures including: years of lifegained, quality-adjusted life years gained (QALYs), new diag-noses, infections averted, and deaths averted. CEA is usuallyconducted on interventions that are known to be effective.

The CE ratio is a fraction used to compare the relative costsand outcomes of two or more interventions. In Example 1,the outcome measure chosen is “new HIV diagnoses” and theCE ratio of the programs evaluated is expressed in terms of“cost per new HIV diagnosis”. The CE ratio of Program Ais $41,667 per new HIV diagnosis. This ratio does not re-veal the cost of implementing the program nor the number ofnew HIV diagnoses detected by the program. However, whencomparing the CE ratio of Program A to that of Program B,we can say that Program B is more cost-effective than Pro-gram A when CE is measured in terms of “cost per new HIVdiagnosis.”8

7https://en.wikipedia.org/wiki/Cost-effectiveness_analysis8http://www.cdc.gov/hiv/prevention/ongoing/costeffectiveness/

https://en.wikipedia.org/wiki/Cost-effectiveness_analysishttp://www.cdc.gov/hiv/prevention/ongoing/costeffectiveness/

19

If one were to apply cost effectiveness analysis to underride guards, a com-parison would be made between alternative means of obtaining the de-sired outcome—prevention of underride. The most cost effective means,i.e, the one able to prevent the most underride deaths, would be selected.The performance standard would be an underride guard that did what itwas supposed to—save a life. That is what the regulation would require.If we do not pursue this course of action, then who is ethically responsiblefor all of the deaths which will occur as a result?

5What is Needed to Bring About a

National Vision Zero Goal?

A proposal by Marianne KarthAs we have indicated, our experience with a truck crash and its aftermathhas enlightened us as to the state of the nation regarding traffic safety.It is our conviction that in order to bring the senseless and preventablehighway carnage to an end in a timely fashion, the following actions areneeded:

1. Set a National Vision Zero Goal.2. Establish a White House Vision Zero Task Force to Achieve Sig-

nificant Crash Death Reduction.3. Sign a Vision Zero Executive Order to Authorize Vision Zero Rule-

making Policies.

We have prepared a draft of each of the above in order to clarify what weare petitioning the President/United States to do in this regard.

21

22 CHAPTER 5. NATIONAL VISION ZERO GOAL

5.1 Action One: Set a National Vision Zero GoalDevelop and formally adopt a Vision Statement such as the following:“Move Towards Zero Crash Deaths & Serious Injuries—Choosing toSave Lives Not Dollars”

5.1. ACTION TWO: TASK FORCE 23

5.2 Action Two: Establish a White House Vision ZeroTask Force To Achieve Significant Crash DeathReduction

Memorandum for the Heads of Executive Departments and Agencies:SUBJECT: Establishing a White House Task Force to Achieve the VisionZero Goal of Crash Death ReductionOn average, 40,000 people die each year in crashes on our roads. Accord-ing to Advocates for Highway & Auto Safety, 362,532 Americans are“missing” i.e., lost their lives due to vehicle violence over the last 10 years.Using NHTSA figures of estimated injuries, nearly 1.5 million additionalpeople suffered serious injuries during that time. Using DOT values of $9million in comprehensive costs per fatality, these losses would be valuedby DOT to be about $3 trillion.Our families cannot continue to sustain this unacceptably high number oflosses and injuries. Therefore, I am directing the Office of the Vice Presi-dent to lead an inter-agency effort to address traffic safety issues, includingcoordinating Federal enforcement efforts by executive departments andagencies (agencies) and helping institutions meet their obligations underFederal law. To these ends, it is hereby ordered as follows:Section 1. Establishment of the White House Task Force to Protect Trav-elers From Traffic Crashes.There is established a White House Task Force to Protect Travelers FromTraffic Crashes. The Task Force shall be chaired by a designee of the Officeof the Vice President.

(a) Membership of the Task Force. In addition to the Chair, the TaskForce shall consist of the following members:

(b) the Attorney General;

(ii) the Secretary of Transportation;(iii) the Secretary of Health and Human Services;(iv) the Secretary of Education;(v) the Secretary of Labor;(vi) the Secretary of Commerce;(vii) the Director of the Office of Science and Technology Policy;(viii) the Director of the Domestic Policy Council;(ix) the Cabinet Secretary; and


(x) the heads of agencies or offices as the Chair may designate.

(b) A member of the Task Force may designate, to perform the TaskForce functions of the member, senior officials who are part of themember’s agency or office, and who are full-time officers or employ-ees of the Federal Government.

(c) The Chair will also establish an Ad-Hoc Committee to advise thisTask Force, and appoint to the Committee at least 12 individualswith expertise in areas related to traffic safety, including—but notlimited to—driver training, truck driver training, driver fatigue, traf-fic safety engineering, state and local traffic law enforcement, crashreconstruction, the automotive industry, the trucking industry, in-jury prevention, truck drivers, and safety advocacy. At least onemember will be someone who has been directly affected by a trafficfatality.

Section 2. Mission and Function of the Task Force.

(a) The Task Force shall work with agencies to develop a coordinatedFederal response to traffic safety issues. The functions of the TaskForce are advisory only and shall include making recommendationsto meet the following objectives:

(b) providing all stakeholders with evidence-based best and promisingpractices for preventing and responding to traffic crashes;

(ii) building on the Federal Government’s existing regulations and en-forcement efforts to ensure that institutions comply fully withtheir legal and ethical obligations to prevent and respond to trafficcrashes;

(iii) increasing the transparency of the Federal Government’s enforce-ment activities concerning traffic safety issues;

(iv) broadening the public’s awareness of traffic safety issues and, in par-ticular, driver fatigue as it affects all drivers; and

(v) facilitating coordination among agencies engaged in addressing traf-fic safety issues and those charged with helping bring institutionsinto compliance with the law.

(b) In accordance with applicable law and in addition to regular meet-ings, the Task Force shall consult with external stakeholders, in-cluding the Governors Highway Safety Association, MADD, othersafety groups, ATA, TTMA, paramedics, coroners, ER profession-als, law enforcement agencies, DMVs, DAs, American Association

5.2. ACTION TWO: TASK FORCE 25

for Justice, research and crash test organizations, educational orga-nizations, truck drivers, and others as deemed wise and appropriate.

(c) Because traffic crashes affect all ages, the Task Force shall evalu-ate how its educational proposals and recommendations may applyto, and may be implemented by, schools, school districts, and otherelementary and secondary educational entities receiving Federal fi-nancial assistance.

Section 3. Action Plan.

(a) Within 90 days of the date of this memorandum, the Task Forceshall develop and submit proposals and recommendations to thePresident for a National Vision Zero Goal. This will include spe-cific strategies for moving toward the reduction of crash deaths andserious injuries. It will also outline specific strategies for establish-ing national traffic safety standards which are proven to reduce crashdeaths and which could then be adopted, as is, by every state. Thesestrategies will ensure that the following will occur:

(b) address the problem of traffic safety in a coordinated manner, includ-ing the following concerns: road design and conditions; all kinds ofenforcement issues to be pro-active in preventing crashes; handlingof traffic safety when crashes occur; driver fatigue—acknowledgingthe scope, extent, and gravity of Driving While Fatigued (DWF) asa reckless behavior both for truck drivers and drivers of light vehi-cles, and adjusting the legal system to reflect this reality; all kinds ofdistracted and impaired driving; automotive safety defect issues andtheir resolution as a high priority issue in a timely manner; and otherproblems as deemed appropriate, including the need for manufac-turers to be held liable for deaths due to their criminal negligenceand for DOT to act with the necessary authority to issue and en-force Vision Zero safety regulations which impact not only vehicleoccupants but also Vulnerable Road Users.

(ii) address truck safety as a high priority due to the multitude of is-sues which need addressing, including: truck driver scheduling poli-cies; truck driver compensation policies; safety technology; under-ride guards; truck driver training; CDL granting policies and proce-dures; hours of service monitoring; and truck maintenance.

(iii) maximizing the Federal Government’s effectiveness in addressingtraffic safety issues by, among other measures, enhancing commu-nication among vital stakeholders—fostering an attitude of cooper-ation and shared goals rather than opposition and competition—as


well as making its enforcement activities transparent and accessible;and

(iv) promoting greater coordination, communication, and consistencyamong the agencies and offices that enforce the Federal laws ad-dressing traffic safety issues and support improved system-wide re-sponses to traffic crashes and newly-identified factors, research in-formation, and recommended solutions; and measuring the successof prevention and response efforts and providing the public with thisinformation;

(b) Within 1 year of the date of this memorandum, and then on anannual basis, the Task Force shall provide a report to the Presidenton implementation efforts with respect to this memorandum.

Section 4. General Provisions.

(a) This memorandum is not intended to, and does not, create any rightor benefit, substantive or procedural, enforceable at law or in equityby any party against the United States, its departments, agencies, orentities, its officers, employees, or agents, or any other person.

(b) Nothing in this memorandum shall be construed to impair or oth-erwise affect:

(c) the authority granted by law to an agency or the head thereof; or

(ii) the functions of the Director of the Office of Management and Bud-get relating to budgetary, administrative, or legislative proposals.

(iii) The heads of agencies and offices shall assist and provide informa-tion to the Task Force, consistent with applicable law, as may benecessary to carry out the functions of the Task Force. Each agencyand office shall bear its own expenses of participating in the TaskForce.

(iv) This memorandum shall be implemented consistent with applicablelaw and subject to the availability of appropriations, which will bespecifically sought after to support the effective and timely imple-mentation of the goals of this Task Force.

(e) The Secretary of Transportation is authorized and directed to pub-lish this memorandum in the Federal Register.

Respectfully submitted, Marianne Karth, February 3, 2016

5.2. ACTION THREE: EXECUTIVE ORDER 27

5.3 Action Three: Sign a Vision Zero Executive Order ToAuthorize Vision Zero Rulemaking Policies

Federal Register Presidential DocumentsFor Immediate ReleaseTitle 3—The President Executive Order _____ of ___________, 2016Application of Vision Zero Principles to Highway Safety Regulatory ReviewBy the authority vested in me as President by the Constitution and thelaws of the United States of America, and in order to improve regula-tion and regulatory review which impacts highway safety and thereby thepreservation of human life and health, it is hereby ordered as follows:Section 1. Statement of Vision Zero Regulatory Philosophy and Princi-ples.

(a) Our regulatory system must protect public health, welfare, safety,and our environment while promoting economic growth, innova-tion, competitiveness, and job creation. It must be based on thebest available science. It must allow for public participation and anopen exchange of ideas. It must promote predictability and reduceuncertainty. It must identify and use the best, most innovative, andleast burdensome tools for achieving regulatory ends. It must takeinto account benefits and costs, both quantitative and qualitative. Itmust ensure that regulations are accessible, consistent, written inplain language, and easy to understand. It must measure, and seekto improve, the actual results of regulatory requirements.

(b) However, in the review of highway safety regulations having an im-pact upon human life and health, agencies must apply a Vision ZeroPolicy which expresses the imperative that,

“It can never be ethically acceptable that people are killed or seriouslyinjured when moving within the road transport system.” Such a pol-icy must apply these core principles: “Life and health can never be ex-changed for other benefits within the society.” and “Whenever some-one is killed or seriously injured, necessary steps must be taken toavoid a similar event.” http://www.monash.edu.au/miri/research/reports/papers/visionzero.html

(c) This Vision Zero Policy should replace the more conventional ap-proach which compares costs and benefits, where a monetary value

http://www.monash.edu.au/miri/research/reports/papers/visionzero.htmlhttp://www.monash.edu.au/miri/research/reports/papers/visionzero.html


is placed on life and health, and where that value is then used to de-termine whether those benefits (human life and health) justify (out-weigh) the costs.

(d) This order is supplemental to and reaffirms the principles, structures,and definitions governing contemporary regulatory review that wereestablished in Executive Order 12866 of September 30, 19931, aswell as Executive Order 13563 of January 18, 20112, with the dif-ference that, in the process of selecting among alternative regulatoryapproaches those which maximize net benefits, the agency will notmake decisions at the expense of human life and health. Towardthat end: (1) Human life and health, as benefits of a regulation, willbe assigned a higher priority over any costs of that regulation; (2)to the extent feasible, performance objectives or standards will bespecified which have as their outcome the preservation of humanlife and health; and (3) when a regulation has been disregarded ornot properly adhered to, so that the performance objectives havenot been met, there will be a civil fine imposed and criminal chargesfiled where appropriate.

Sec. 2. Public Participation

(a) Regulations shall be adopted through a process that involves publicparticipation. To that end, regulations shall be based, to the extentfeasible and consistent with law, on the open exchange of informa-tion and perspectives among State, local, and tribal officials, expertsin relevant disciplines, affected stakeholders in the private sector,and the public as a whole.

(b) To promote that open exchange, each agency which impacts high-way safety, consistent with Executive Order 12866 and other appli-cable legal requirements, shall endeavor to provide the public withan opportunity to participate in the regulatory process. To the extentfeasible and permitted by law, each agency shall afford the public ameaningful opportunity to comment through the Internet on anyproposed regulation, with a comment period that should generallybe at least 60 days. To the extent feasible and permitted by law, eachagency shall also provide, for both proposed and final rules, timelyonline access to the rulemaking docket on regulations.gov, includingrelevant scientific and technical findings, in an open format that can

1http://www.archives.gov/federal-register/executive-orders/pdf/12866.pdf

2https://www.whitehouse.gov/the-press-office/2011/01/18/executive-order-13563-improving-regulation-and-regulatory-review

http://www.archives.gov/federal-register/executive-orders/pdf/12866.pdfhttp://www.archives.gov/federal-register/executive-orders/pdf/12866.pdfhttps://www.whitehouse.gov/the-press-office/2011/01/18/executive-order-13563-improving-regulation-and-regulatory-reviewhttps://www.whitehouse.gov/the-press-office/2011/01/18/executive-order-13563-improving-regulation-and-regulatory-review


be easily searched and downloaded. For proposed rules, such accessshall include, to the extent feasible and permitted by law, an oppor-tunity for public comment on all pertinent parts of the rulemakingdocket, including relevant scientific and technical findings.

(c) Before issuing a notice of proposed rulemaking, each agency, wherefeasible and appropriate, shall seek the views of those who are likelyto be affected, including those who are likely to benefit from andthose who are potentially subject to such rulemaking.

Sec. 3. Integration and Innovation.Some sectors and industries face a significant number of regulatory re-quirements, some of which may be redundant, inconsistent, or overlap-ping. Greater coordination across agencies could reduce these require-ments, thus reducing costs and simplifying and harmonizing rules. In de-veloping regulatory actions and identifying appropriate approaches, eachagency shall attempt to promote such coordination, simplification, andharmonization. Each agency shall also seek to identify, as appropriate,means to achieve regulatory goals that are designed to promote innova-tion.Sec. 4. Flexible Approaches.Where relevant, feasible, and consistent with regulatory objectives, andto the extent permitted by law, each agency shall identify and considerregulatory approaches that reduce burdens and maintain flexibility andfreedom of choice for the public. These approaches include warnings, ap-propriate default rules, and disclosure requirements as well as provision ofinformation to the public in a form that is clear and intelligible.Sec. 5. Science.Consistent with the President’s Memorandum for the Heads of ExecutiveDepartments and Agencies,“Scientific Integrity” (March 9, 2009), andits implementing guidance, each agency shall ensure the objectivity of anyscientific and technological information and processes used to support theagency’s regulatory actions.Sec. 6. Administrative Procedures for Adhering to a Vision Zero Policy.

(a) As required by Executive Order 12866, for each matter identifiedas, or determined by the Administrator of OIRA to be, a significantregulatory action, the issuing agency shall provide to OIRA:

(b) The text of the draft regulatory action, together with a reasonablydetailed description of the need for the regulatory action and anexplanation of how the regulatory action will meet that need; and


(ii) An assessment of the potential costs and benefits of the regulatoryaction, including an explanation of the manner in which the regu-latory action is consistent with a statutory mandate and, to the ex-tent permitted by law, promotes the President’s priorities and avoidsundue interference with State, local, and tribal governments in theexercise of their governmental functions.

(b) For those matters identified as, or determined by the Administratorof OIRA to be, a significant regulatory action within the scope ofsection 3(f )(1), the agency shall also provide to OIRA the followingadditional information developed as part of the agency’s decision-making process (unless prohibited by law):

(c) An assessment, including the underlying analysis, of benefits antic-ipated from the regulatory action (such as, but not limited to, thepromotion of the efficient functioning of the economy and privatemarkets, the enhancement of health and safety, the protection of thenatural environment, and the elimination or reduction of discrimi-nation or bias) together with, to the extent feasible, a quantificationof those benefits;

(ii) An assessment, including the underlying analysis, of costs antici-pated from the regulatory action (such as, but not limited to, thedirect cost both to the government in administering the regulationand to businesses and others in complying with the regulation, andany adverse effects on the efficient functioning of the economy, pri-vate markets (including productivity, employment, and competitive-ness), health, safety, and the natural environment), together with, tothe extent feasible, a quantification of those costs; and

(iii) An assessment, including the underlying analysis, of costs and ben-efits of potentially effective and reasonably feasible alternatives tothe planned regulation, identified by the agencies or the public (in-cluding improving the current regulation and reasonably viable non-regulatory actions), and an explanation why the planned regulatoryaction is preferable to the identified potential alternatives.

(iv) An assessment of the impact of the proposed regulatory action onHuman Life and Health and a explanation of how the regulatoryaction will ensure that Vision Zero outcomes will be adequatelyachieved.

(v) Within 120 days of the date of this order, each agency shall developand submit to the Office of Information and Regulatory Affairs(OIRA) a preliminary plan, consistent with law and its resources


and regulatory priorities, under which the agency will submit its ad-ministrative plan for achieving the regulatory objectives outlined bythis Vision Zero mandate for human life and health as the priorityoutcome measures.

Sec. 7. Retrospective Analyses of Existing Rules.

(a) To facilitate the review of existing significant regulations, agenciesshall consider how best to promote retrospective analysis of rulesthat may be outmoded, ineffective, insufficient, or excessively bur-densome, and to modify, streamline, expand, or repeal them in ac-cordance with this Vision Zero mandate. Such retrospective analy-ses, including supporting data, should be released online wheneverpossible.

(b) Within 120 days of the date of this order, each agency shall developand submit to the Office of Information and Regulatory Affairs(OIRA) a preliminary plan, consistent with law and its resourcesand regulatory priorities, under which the agency will review its ex-isting significant regulations to determine whether any such regula-tions should be modified, streamlined, expanded, or repealed so asto make the agency’s regulatory program more effective in achievingthe regulatory objectives with this Vision Zero mandate for humanlife and health as the priority outcome measures.

Sec. 8. General Provisions.

(a) For purposes of this order, “agency” shall have the meaning set forthin section 3(b) of Executive Order 12866, although this order isintended specifically for regulations which impact highway safety.

(b) Nothing in this order shall be construed to impair or otherwise af-fect:

(c) authority granted by law to a department or agency, or the headthereof; or

(ii) functions of the Director of the Office of Management and Budgetrelating to budgetary, administrative, or legislative proposals.

(iii) This order shall be implemented consistent with applicable law andsubject to the availability of appropriations.

(iv) This order is not intended to, and does not, create any right or bene-fit, substantive or procedural, enforceable at law or in equity by anyparty against the United States, its departments, agencies, or enti-ties, its officers, employees, or agents, or any other person.


Drafted by Marianne Karth, October 2015

Part III

Vision Zero

33

6What is Vision Zero?

Vision Zero, in the simplest language, is the embracing of a vision or hopethat we could work toward reducing crash deaths (and serious injuries)to zero. That no one would ever die in a traffic crash. It is, of course,understood that—life being what it is—we will never actually reach zero.But Vision Zero insists that certainly such a goal is desirable and, in fact,so much so that everything humanly possible should be done to accom-plish it. One life at a time. To do anything less would be unthinkable.What would a Vision Zero philosophy/goal/policy mean to us as a coun-try? Here is how Neil Arason, Canadian author of No Accident, viewsVision Zero:

“I think people have different views about vision zero but hereis mine. The airline industry does not apply cost benefit anal-ysis to fixing aviation problems. They just fix problems andthat is that. Using a cost benefit model is incompatible withvision zero because it applies trade-offs and vision zero doesnot entail that. Vision zero is about making the system a safeone and does not assign value to a human life because doingthat, the thinking goes, is unethical.” 1

This book is a compilation of our request for a National Vision Zero Goaland for a Vision Zero rulemaking policy. It includes our petition lettersto President Obama and DOT Secretary Foxx—along with the signaturesand comments of thousands of people who signed the petitions and arespeaking up with us to call for a move Towards Zero Crash Deaths &Serious Injuries.

1http://annaleahmary.com/2015/12/starting-tzd-traffic-safety-conversation-who-should-pay-for-the-cost-of-saved-lives/

35

http://annaleahmary.com/2015/12/starting-tzd-traffic-safety-conversation-who-should-pay-for-the-cost-of-saved-lives/http://annaleahmary.com/2015/12/starting-tzd-traffic-safety-conversation-who-should-pay-for-the-cost-of-saved-lives/

36 CHAPTER 6. WHAT IS VISION ZERO?

The book also includes an appendix full of annaleahmary.com2 posts writ-ten on how and why Vision Zero should be applied. For example, oneof the posts describes why we are pushing so hard to get people to sign aVision Zero petition. What difference would it make anyway? The reasonwe are devoting our lives to pounding on this door and asking for changeis that our daughters may have lost their lives due to the lack of a VisionZero policy.A decision which concluded that recommended changes would not becost effective—in other words, that it would supposedly cost more to im-plement safety measures than the lives saved would be worth—may haveled to lax underride guard standards. If the best possible protection hadbeen pursued when the regulations were last updated (1996), the truckson the road today (including the one on the road May 4, 2013) might bemuch safer to be driving around.Mary and AnnaLeah might even still be around.Furthermore, the issue of underride guards is just one among many prob-lems which, if a National Vision Zero Goal were in place, could be ad-dressed more compassionately—as if human lives were really more impor-tant to us than our pocketbook.There is also a drafted Vision Zero Executive Order as a recommendationfor outlining a means of implementing a National Vision Zero Goal andgranting DOT the authority to adopt a Vision Zero rulemaking policy.Finally, there is a draft for a presidential memorandum mandating a taskforce to address these issues in a collaborative effort at a national level inorder to establish national traffic safety standards which should be adoptedby all states.

2http://annaleahmary.com

http://annaleahmary.com

7Why Are We Advocating For

Vision Zero?

32,675 people died in U.S. traffic crashes in 2013.1 Two of those peo-ple were my daughters, AnnaLeah (17) and Mary (13). That numberdecreased to 32,675 deaths in 2014. Down by 44, but still far too manydeaths in my book. In fact, early estimates show an increase in trafficfatalities in 2015. 2

I survived a horrific truck crash in which our car was pushed by a truckinto the rear of another truck. Backwards. My daughters in the back seatwere not so fortunate; they went under the truck and the truck broke theirinnocent bodies.Underride deaths are preventable and unnecessary and now is the time totake extreme action to reduce these deaths—no matter who caused thecrash! Let’s not wait for collision avoidance technology to kick in beforekicking out preventable underride deaths!The underride problem is just one example of the fixable problems we needto address. Michael Lemov has written an eye-opener, Car Safety Wars:One Hundred Years of Technology, Politics, and Death, in which he tells usthat in the more than 110 years since the first traffic crash in 1898, morethan 3.5 million Americans have been killed and more than 300,000,000injured in motor vehicle crashes [p.9]. This, I learned, is 3x the numberof Americans who have been killed and 200x the number wounded in allof the wars fought by our nation since the Revolution [p.10]. Imagine.

1http://www.nhtsa.gov/About+NHTSA/Press+Releases/2014/traffic-deaths-decline-in-2013

2http://www.nhtsa.gov/About+NHTSA/Press+Releases/2015/2014-traffic-deaths-drop-but-2015-trending-higher

37

http://www.nhtsa.gov/About+NHTSA/Press+Releases/2014/traffic-deaths-decline-in-2013http://www.nhtsa.gov/About+NHTSA/Press+Releases/2014/traffic-deaths-decline-in-2013http://www.nhtsa.gov/About+NHTSA/Press+Releases/2015/2014-traffic-deaths-drop-but-2015-trending-higherhttp://www.nhtsa.gov/About+NHTSA/Press+Releases/2015/2014-traffic-deaths-drop-but-2015-trending-higher

38CHAPTER 7. WHY ARE WE ADVOCATING FOR VISION ZERO?

Are you aware that Death by Motor Vehicle is one of the leading causesof deaths?

“Worldwide it was estimated that 1.2 million people werekilled and 50 million more were injured in motor vehicle colli-sions in 2004.[2] Also in 2010 alone, around 1.23 million peo-ple were killed due to traffic collisions.[3] This makes motorvehicle collisions the leading cause of death among children10–19 years of age (260,000 children die a year, 10 million areinjured)[4] and the sixth leading preventable cause of deathin the United States[5] (45,800 people died and 2.4 millionwere injured in 2005).[6] It is estimated that motor vehiclecollisions caused the deaths of around 60 million people dur-ing the 20th century,[7] around the same as the number ofWorld War II casualties.”3

Lemov’s book sheds light on many things including the fact that, althoughthe blame was often put on the driver for crashes in the 20th century,in fact crashes and crash deaths are additionally caused by other factorsincluding environmental and vehicle factors. He uses a term which I hadnever heard before—post-crash injury or “second collision.” He describesit this way:

“It is the collision of the occupants of a vehicle with its interior,or the road, after the initial impact of a car crash. Ultimatelythe creativity of a few scientists, doctors, and investigators. . .developed an understanding of what actually happens to a hu-man body in a car crash. . . Researchers gradually developedideas they hoped would prevent this second collision.” [p.16]

We can thank these researchers for paving the way for improved vehiclesafety, including things like seat belts, air bags, and even car seats that lockin position. But, for far too long, it has been a major battle—as Lemovsays, a car safety war—to bring about changes which will save lives.Our own crash demonstrated the many factors which can contribute to theoccurrence of crashes as well as to the deaths and horrific injuries whichtoo often occur as a result. We learned the hard way that many of theseare preventable and that Our Crash Was Not An Accident.Following our truck crash, on May 4, 2013, we have learned more than weever wanted to about traffic safety issues. We took the AnnaLeah & Mary

3https://en.wikipedia.org/wiki/Epidemiology_of_motor_vehicle_collisions

https://en.wikipedia.org/wiki/Epidemiology_of_motor_vehicle_collisionshttps://en.wikipedia.org/wiki/Epidemiology_of_motor_vehicle_collisions

39

Stand Up for Truck Safety—Save Lives and Prevent Injuries! Petition toDC on May 5, 2014 and helped to initiate an update in the underrideprotection for tractor-trailers.Following that, we worked to promote underride research and have helpedto organize an international Underride Roundtable on Thursday, May 5,2016, when researchers, government officials, and industry leaders willgather to discuss truck underride crashes and how to reduce the risks forpassenger vehicle occupants, bicyclists, and pedestrians. We will explorethe scope of the problem and how regulation and voluntary action canhelp address it. There will also be a demonstration of underride guardperformance in a crash test.But, along the way, as I engaged in safety advocacy efforts—calling, email-ing, and meeting with legislators—I quickly realized that all too-often itwas 2 steps forward 3 steps backward. I began to ask, “Why is it so diffi-cult to get anything done to save lives?” and “Why isn’t the best possibleprotection being adopted?”I learned that one of the biggest obstacles was that public policy andmore specifically DOT rulemaking is impacted by a requirement forcost/benefit analysis which tips the scale in the favor of industry lobbyand the almighty dollar and makes a mockery out of the word safety. Hu-man life becomes devalued in the process when a safety measure is rejectedbecause it “may not have significant safety consequence.”4

This is illustrated in the history of Federal rulemaking on truck underrideguards outlined by the Insurance Institute for Highway Safety, where itwas indicated that in “1974: US Secretary of Transportation says deathsin cars that underride trucks would have to quadruple before underrideprotection would be considered cost beneficial.”5

I determined to battle such an inconceivable, incomprehensible, and un-conscionable attitude and determined to find a better way to protect trav-elers on the road. After talking with numerous engineers who either wereconvinced that safer underride guards could be made or had already de-signed ones, I also discovered a global movement that calls for the re-duction of crash deaths and serious injuries: Vision Zero—An ethicalapproach to safety and mobility.After launching an online petition Save Lives Not Dollars: Urge DOTto Adopt a Vision Zero Policy on September 29, 2015, I discovered that

4http://www.regulations.gov/#!documentDetail;D=NHTSA_FRDOC_0001-1548

5http://www.iihs.org/media/faa5dfa3-e46b-4f10-a542-228bb8844f17/-2034281871/Testimony/testimony_2009-05-18.pdf

http://www.regulations.gov/#!documentDetail;D=NHTSA_FRDOC_0001-1548http://www.regulations.gov/#!documentDetail;D=NHTSA_FRDOC_0001-1548http://www.iihs.org/media/faa5dfa3-e46b-4f10-a542-228bb8844f17/-2034281871/Testimony/testimony_2009-05-18.pdfhttp://www.iihs.org/media/faa5dfa3-e46b-4f10-a542-228bb8844f17/-2034281871/Testimony/testimony_2009-05-18.pdf

40CHAPTER 7. WHY ARE WE ADVOCATING FOR VISION ZERO?

an Executive Order had been signed by Clinton which had set in placethe cost/benefit analysis rulemaking policy which all-too-often delays orblocks traffic safety regulations. I immediately set out to petition PresidentObama to set a National Vision Zero Goal with the establishment of aWhite House Task Force to Achieve a Vision Zero Goal of Crash DeathReduction. Furthermore, I believe that it is necessary to cancel out thenegative impact of Executive Order 12866 in order to end this senselesswar over safety. That is why I am asking President Obama to sign a newVision Zero Executive Order.Why are we devoting our lives to pushing for a DOT Vision Zero pol-icy? Because I truly believe that it can have an impact not just on trucksafety but on all issues related to highway and auto safety—including autosafety defects, driver training requirements, all kinds of impaired driving(including distracted driving, drunk driving, and driving while fatigued),and proven national traffic safety standards which should be adopted byall states.We are taking these petitions (over 16,000 signatures to date) to Wash-ington, DC, on March 4, where we will be meeting with DOT policyofficials to discuss the need for this radical change in how our nation pro-tects the travelers on our roads. Help us persuade President Obama to seta National Vision Zero Goal & to sign a Vision Zero Executive Orderwhich will allow DOT to adopt a Vision Zero rulemaking policy.It is time to stop acting like the value of a human life can be measuredwith and compared to corporate dollars. Every delay costs someone theirlife.Let’s get it right, America. Somebody’s life depends on it. Lots of some-bodies.

8Traffic Injuries & Fatalities Data

Figure 8.1: In 2004-2014, the leading cause of death in the United Statesfor ages 1-45 was Unintentional Injury Motor Vehicle Traffic

41

42 CHAPTER 8. TRAFFIC INJURIES & FATALITIES DATA

Figure 8.2: Motor Vehicle Traffic continues to be a leading cause of deathin the Unintentional Injury category for all ages.

9Truck Underride: A Practical

Application of a Vision Zero Goal

An Essay by Marianne KarthIt is a common business practice to develop a Vision Statement whichexemplifies the goals of the organization and which will direct its decisions,practices, and activities.Let me give an example of this. Our family helped to develop a VisionStatement for Family Promise of Midland, Texas: End Homelessness, OneFamily at a Time. Will there ever be zero homeless families? Probablynot. But that vision is what we aimed for; it guided our steps.What can a vision statement do? It can, “encourage strategic thinkingand help organizations share concise information about their plans andprogress toward impact.” 1 2

Similarly, Vision Zero: Reduce Crash Deaths & Serious Injuries is a visionstatement that serves to move us ever closer to ending preventable, sense-less and tragic crash deaths & serious injuries—one life saved at a time.That vision guides our steps to discover and implement proven means tosave lives—to make saving human life a priority over saving money.Specifically, we have chosen to advocate for resolution of a problem whichhas too-long been ignored: truck underride crashes. It is well-known thatthe current underride guard standards are inadequate; they result in guardsthat are weak and ineffective and all-too often lead to tragic deaths andhorrific injuries. The really bad thing about this is that many people have

1https://www.guidestar.org/report/chartingimpact/650820583/family-promise-midland-texas.pdf

2http://www.midlandvolunteerconnections.org/agency/detail//?agency_id=42248

43

https://www.guidestar.org/report/chartingimpact/650820583/family-promise-midland-texas.pdfhttps://www.guidestar.org/report/chartingimpact/650820583/family-promise-midland-texas.pdfhttp://www.midlandvolunteerconnections.org/agency/detail//?agency_id=42248http://www.midlandvolunteerconnections.org/agency/detail//?agency_id=42248

44 CHAPTER 9. TRUCK UNDERRIDE

already taken the time to prove that this situation is unnecessary and thatbetter protection is possible.Therefore this is what I am asking for as a Vision Zero strategic applica-tion:We have spent a lot of time reflecting on the inadequacy of current rear-impact guards to prevent underride by passenger vehicles along with theconcomitant difficulty of holding trailer manufacturers accountable for thehorrific injuries and deaths which all-too-often occur as a result.The current means of regulating the manufacture of underride guards re-quires the trailer manufacturer to design its underride guards to meet cer-tain specifications. Once the manufacturer has met those requirements,then, currently, it cannot normally be held liable for any failure of theguard to withstand a crash–along with any resultant property damages,injuries, or death.We would like to propose a change in the approach to regulating truck un-derride guards. We are requesting/recommending that the manufacturerbe required to design and crash test a guard which would withstand a crashat any speed up to 50 mph and at any point along the back of the trailer.Furthermore, we are requesting that, when a real-life underride crash doesoccur with one of their trucks, the manufacturer be held financially re-sponsible for the cost of a thorough crash reconstruction, which wouldidentify—at minimum—the speed which was traveled and whether theguard gave way with the impact of the crash.With this new approach to regulating underride guards, the manufacturerwould thereby be accountable for any failure of the guard to withstanda crash and thus be held responsible for ensuring a very important pub-lic outcome: prevention of horrific injuries and deaths due to underridecrashes.This is in sharp contrast to the current situation where no penalty is nor-mally paid for a failed underride guard–except by the victims and theirloved ones.p.s. This link provides a perspective on prevention of crash fatalities as apublic health outcome (although it does not mention truck safety issues inparticular): World Health Organization: Road Traffic Injuries3 and see,also: NHTSA: The Crash Outcome Data Evaluation System (CODES)And Applications to Improve Traffic Safety Decision-Making4

3http://www.who.int/mediacentre/factsheets/fs358/en/4http://www-nrd.nhtsa.dot.gov/Pubs/811181.pdf

http://www.who.int/mediacentre/factsheets/fs358/en/http://www-nrd.nhtsa.dot.gov/Pubs/811181.pdf

45

p.p.s. We do not pretend to be experts on details such as whether 50 mphis the most appropriate speed limit to require. We do know, however, thatrequiring manufacturers to prevent crashes only at lower speeds inevitablymeans that many lives will be unnecessarily lost–placing a low value onhuman life. Corporate gain over tragic, preventable, and irrevocable lossof life.p.p.p.s. Additionally, we have been told that this level of protection ishighly possible and we are taking steps to encourage further research onthis in the near future.p.p.p.p.s. Oh, and did I ask for a requirement to install not only rear un-derride guards but to likewise protect people from side and front underridecollisions on all new trucks, as well as retrofitting existing trucks?The stated mission of the National Highway Traffic Safety Administration(NHTSA) is “to save lives, prevent injuries, and reduce economic costsdue to road traffic crashes, through education, research, safety standards,and enforcement activity.”5To be in accord with that mission, NHTSAshould act now to make a comprehensive underride regulation in a timelyand decisive manner. Why wait?To not provide the best possible protection, and thereby sentence countlesspeople to Preventable Death by Motor Vehicle, is ethically and morallyunconscionable and unthinkable.Marianne Karth,The Survivor of a truck crashwhich resulted in rear underrideand Passenger Compartment Intrusion (PCI)into the back seat of her Crown Victoriawhere AnnaLeah (17) and Mary (13) met their untimely endhttp://annaleahmary.com/

http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0018

February 5, 2016

5

http://annaleahmary.com/http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0018http://www.regulations.gov/#!documentDetail;D=NHTSA-2015-0070-0018

Part IV

Petition

47

10Petition Letter to Secretary Foxx

Dear Secretary Foxx:

After losing two daughters, AnnaLeah (17) and Mary (13), in a truckunderride crash on May 4, 2013, the Karth family took over 11,000 en-velopes with signed petitions from the AnnaLeah & Mary Stand Up ForTruck Safety Care2 Petition to Washington, DC, one year later on May5, 2014. At that time, they met with administrators from FMCSA andNHTSA and discussed, at length, their concerns about truck safety issues.

Since that time, they have set up a non-profit, AnnaLeah & Mary forTruck Safety, to promote highway safety research and federal regulationsto protect motorists, pedestrians, & cyclists. And, in fact, there has beensome progress with the upcoming implementation of Electronic LoggingDevices and the initiation of rulemaking steps related to underride guardsand minimum liability insurance for truck companies.

However, we are concerned that these safety measures, as well as others,are being unnecessarily delayed and/or weakened. As you know, the De-partment of Transportation makes highway safety rules based upon howmuch safety measures will cost. We are hoping to change that and pro-mote a Vision Zero safety strategy model with goals of Zero Deaths, ZeroInjuries, Zero Fear of Traffic.

One of the biggest challenges to making change is the cost/benefit anal-ysis. On the one side there are lives to be saved and on the other sidethere are companies working to make money. The trick is to try and meeteveryone’s needs. The solution has to be effective in saving lives whilestill being affordable for companies so that they can make the changesnecessary without a lot of struggle.

49

50 CHAPTER 10. PETITION LETTER TO SECRETARY FOXX

The problem comes in when human life and health get the short end ofthe stick. The result is that many safety measures are blocked because theywould cost more to implement than the “worth” of the “small” number ofhuman lives which would be saved. That’s just not right.Therefore we are asking you to:

1. Change DOT rulemaking policy to move away from a cost/benefitmodel and adopt a more humanistic, rational Vision Zero safetystrategy model.

2. Apply Vision Zero principles by requiring crash-test-based perfor-mance standards for truck underride guards rather than force-baseddesign standards along with success at higher speeds—to includerear (both centered and offset) and side guards for both Single UnitTrucks and trailers.

3. Apply Vision Zero principles by requiring NHTSA to initiate rule-making to require forward collision avoidance and mitigation brak-ing (F-CAM) systems on all new large trucks and buses with a grossvehicle weight rating of 10,000 lbs. or more.

On average, 33,000 people die each year in crashes on our roads. Our fam-ilies cannot continue to sustain this unacceptably high number of lossesand injuries. We urge you to take immediate action so that more lives willnot be lost and to assure us that safety is your number one priority.Sincerely,(Complete listing of signatures starts on page 57)

11About the Signers

Figure 11.1: Signatures by State, as of February 12th 2016

51

52 CHAPTER 11. ABOUT THE SIGNERS

Figure 11.2: Signatures by Country, as of February 12th 2016

12Selected Comments by Signers of

the Vision Zero Petition

These are just some of the comments about the petition left by the peoplewho signed it.

Please adopt stronger safety rules so that more lives can besaved. My sisters AnnaLeah and Mary Lydia are gone foreverdue to a truck collision, and no other family should have to gothrough this. Save lives.

—Rebekah Karth Chojnacki, Arlington, Texas

There shouldn’t be a cost benefit analysis for lives…

—Katy Hartigan, Grayslake, Illinois

Secretary Foxx, it is avoidable and inexcusable that about40,000 Americans die in vehicular crashes every year. Stopthe cost/benefit analysis bean counting.

The lives of Americans are at stake.

—Lana Briscoe, Northport, New York

53


Three years ago, I was sitting in my apartment, working on myclass projects, when I got a phone call that turned my worldupside down. My family’s car had been hit by a truck, and Iwas the first person that the hospital was able to reach. Therewas a lot of confusion; no one knew where my two sisters whohad been in the back seat of the car had been taken. I had apair of dice in my pocket that day, the same pair of dice thatI had when my father called me later that evening with thenews that my sister had died in the crash.

Humans are bad at estimating probabilities. A one-in-a-million chance sounds rare, but that’s close to the odds theNWS reports for being struck by lightning, and 330 Ameri-cans are injured that way every year. It’s rare, but it happens.In probability theory, it’s called the law of large numbers. Ifyou roll the dice often enough, or for enough people, the diceare going to come up as ones at a predictable, measurable rate.

The IIHS reported that in 2013, there were 10.3 deathsfrom motor vehicle crashes per 100,000 people. That’s aboutone-in-ten-thousand, way more likely than one-in-a-million.And, unlike other leading causes of death, this is an entirelyhuman-created problem, one that didn’t exist two hundredyears ago.

Automotive safety has been improving over time. But it is stillone of the leading causes of death in America. Curing cancer,one of the other leading causes, is expensive and difficult, re-quiring research just to figure out if it is even possible. In con-trast, for motor vehicle deaths there are many cases where wealready know simple ways to reduce motor vehicle fatalities,such as effective underride guards, and we have promising re-search for even more. We shouldn’t settle for one-in-ten thou-sand, or even one-in-a-hundred-thousand. We should striveto be better than that. Human lives shouldn’t be a nickle anddime proposition.

Even low chances of death are still too high. I shouldn’t haveto roll the dice every time I need to leave my house. I shouldn’thave to wonder, every time my family is out on the road, iftoday is going to be the day that they roll the wrong numberagain.

—Isaac Karth, Rocky Mount, North Carolina

55

Our families’ lives are worth more than the cost in dollars.

—Donna Profeta, Ballston Lake, New York

The bottom line should NEVER outweigh the cost of a hu-man life. The status quo needs to be changed before anyoneelse suffers such a tragedy as the Karths.

—Brie Handgraaf, Rocky Mount, North Carolina

I work in the accident reconstruction industry and see count-less underride accidents each year, many ending in serious in-jury or death. The severity of injury in these types of crashescould be significantly reduced with the simple implementa-tion of additional bracing on the trailers that travel our road-ways.

—Ryan McMahan, Holly Springs, North Carolina

Seriously? Putting profit before human life is short termthinking and, by the way, immoral.

—David M. Dunn, LANSING, Michigan

Please prevent another family from losing a loved one and go-ing through this heartbreak.

—LELA Lesson, Cortaro, Arizona


We should be living in a country of HUMAN VALUES,NOT DOLLAR VALUES

—Dianne Sullivan, Modesto, California

The Traffic Safety Coalition is proud to support the call fora Vision Zero safety model working towards zero deaths andzero grave injuries on our nation’s roads.

—Michelle Dutton, Chicago, Illinois

We lost our daughter in a red light running crash on 1/26/02.A red light camera might have stopped the man who killedher. Our State has now virtually outlawed the use of red lightcameras. Where is the cost/benefit in that???

—Suzann Oberhauser, Somerset, Ohio

Vision Zero has worked to reduce deaths in NYC, as well as inmany countries in Europe. It’s time for the US to take trafficsafety seriously and prevent more deaths on our roads.

—Emily Stein, Medford, Massachusetts

Please support this lifesaving Policy! We are losing preciouslives daily around our country. Best practices and safety de-vices alike must be utilized. #Safetysaveslives

—The National Coalition For Safer Roads, Bradenton,Florida

Protect the Nations highways for everyone. We have waitedlong enough. This insanity must stop. Families are dying.

—Joan Moore, san francisco, California

13Signatures to the Petition

1. Julie Shmeleva, Moscow,Russian Federation

2. Alessandra Fernandes, SãoVicente, Brazil

3. Dina Smith,NEWINGTON, NewHampshire

4. Louis Lombardo, Bethesda,Maryland

5. John Brewer, MARIETTA,Ohio

6. Derek Lockwood, Lisburn,United Kingdom

7. Jackie Novak,Hendersonville, NorthCarolina

8. Devon Ambrose,Burlington, Canada

9. Mark Stewart, Aberdeen,United Kingdom

10. Jen S., INDIANAPOLIS,Indiana

11. mauricio carvajal, santiago,Chile

12. Tami Friedrich, Corona,California

13. Jo-Anna Dueck,Woodstock, Canada

14. Rebekah Black, Arlington,Texas - See comment #14on page 611

15. Tina Ogg, Grand Rapids,Michigan

16. – –, TACOMA,Washington

17. jerry karth, Rocky Mount,North Carolina

18. Maryann Staron,EVERGREEN PARK,Illinois

19. Faith Vilas, Seabrook,Texas

20. Mary Vickerman,Delafield, Wisconsin

21. katy Hartigan, Grayslake,Illinois - See comment #21on page 611

22. Michele terpstra, GrandRapids, Michigan

57

58 CHAPTER 13. SIGNATURES TO THE PETITION

23. Mi Ae Lipe, Seattle,Washington

24. Tanya Proby, Milwaukee,Wisconsin

25. Shawn Mayer, Dallas,Texas

26. Janet Bryant, Chicago,Illinois

27. Kate Monte, Evanston,Illinois

28. Maggie Robinson,Evanston, Illinois

29. Cindy Glass, Walker,Michigan

30. Nancy stewart, Roberts,Wisconsin

31. Donna bryant, Glenview,Illinois

32. Brenda Harris, Zion,Illinois

33. Karen Word, Davis,California

34. Scott Orlinsky, Chicago,Illinois

35. Cassie Kimbrough,Abilene, Texas

36. Diana Johnson,Stockbridge, Georgia

37. Melanie Holmes, DesPlaines, Illinois

38. Claire Golan, Riverwoods,Illinois

39. Janet Schweitzer, Chicago,Illinois - See comment #39on page 611

40. Breanna Lonas, Glen Allen,Virginia

41. Patti Gouker, Albuquerque,New Mexico

42. Alexander Kovesy,Christchurch, NewZealand

43. Frances Ilia, scarborough,Canada

44. Ernest Cooper,Indianapolis, Indiana

45. John Nimmo, ElizabethBay, Sydney, Australia

46. analia veronica mercado,cordoba, Argentina

47. marsha maxwell,WALNUT CREEK,California

48. Sharon Schranz, Thornhill,Canada

49. Corie Walters, Whyalla,Australia

50. robin zepeda,WENTZVILLE, Missouri

51. Ellen Ayalin, Chicago,Illinois

52. Michael Trepp, Seattle,Washington

53. Martha Rudy, Evanston,Illinois

54. Sheryll Punneo, Liberty,Missouri

55. Kay M, METAIRIE,Louisiana

56. Barbara Tucker,Wellington, Florida

57. sarika arora, Alpharetta,Georgia

58. T Mo, Inver GroveHeights, Minnesota

59

59. Candy LeBlanc, Placerville,California

60. Juanita Navarro, SilverSpring, Maryland

61. Kay Lowe, THORNTON,Colorado

62. Elizabeth L. Anderson,Campbell, California

63. Bobbie Flowers, New York,New York

64. Tracy Carlson Hall,Evanston, Illinois

65. Richard Dotter,DUMONT, New Jersey

66. Sara Elkins,NORTHAMPTON,Massachusetts

67. genoveva legaspi, distritofederal, Mexico

68. Patricia Miller, Manchester,Pennsylvania

69. Julie Cannon, ROSWELL,New Mexico

70. Lindsey Dakin, Boston,Lincolnshire, UnitedKingdom

71. Cheryl McCoy, St.Petersburg, Florida

72. Lynne Minore, Brooklyn,New York

73. Jan Novotny,JACKSONVILLEBEACH, Florida

74. Merry Preston, Camrose,Canada

75. Yasiu Kruszynski,CHICAGO, Illinois

76. paul haugen, Eau Claire,Wisconsin

77. Ankie Brunschot,veldhoven, Netherlands

78. Pat Wu, Hong Kong,Hong Kong

79. Lily Yang, Las Vegas,Nevada

80. Ana Altamiranda, 3700,Argentina

81. Alice Neuman, Sacramento,California

82. Janice Banks, CenterBarnstead, New Hampshire

83. Cati patricio, Campinas,Brazil

84. Epaminondas Kovanis,Koridallos, Greece

85. Mary Burt, Utica,Minnesota

86. zulma fonseca, carolina,Puerto Rico

87. morgana odin, Berlin,Germany

88. Mary Van Way, Portland,Oregon

89. E Dumbleton, Toronto,Canada

90. Mitch Franks,WOONSOCKET, RhodeIsland

91. Maria Vitória Magri, SãoPaulo, Brazil

92. Jocelyn valdez-Loqui,BRONX, New York

93. Danelle Karth, RockyMount, North Carolina

60 CHAPTER 13. SIGNATURES TO THE PETITION

94. Julia Cabrera-Woscek,BELTSVILLE, Maryland

95. Paula Puskadi, Budapest,Hungary

96. David Ary, Reno, Nevada97. Robert Padilla-Montufar,

NEW YORK, New York98. Cynthia Brickner,

TOLEDO, Ohio99. Katrina & William

Dresbach, Sheffield Lake,Ohio

100. Misbah Malik, CORALSPRINGS, Florida

101. Michael Carney,Runnemede, New Jersey

102. eric archambault, paris,France

103. Mike Lu, Austin, Texas104. CARMEN DELIA

ARCHILLA,ORLANDO, Florida

105. Надежда Яшина,Санкт-Петербург,RussianFederation

106. Lynn Juozilaitis,AURORA, Illinois

107. Fabiana Uteda, SheppartonEast, Australia

108. Glennis Whitney, NthRockhampton, QueenslandAustralia, Australia

109. Темирова Оксана,Санкт-Петербург,RussianFederation

110. Melanie Asbach,Wuppertal, Germany

111. Olga Troyan, Taraz,Kazakhstan

112. reita newkirk, santa fe, NewMexico

113. a f, Washington,Connecticut

114. sabina gaddi, valencia,Spain

115. Jeffrey DeCristofaro,ASHEVILLE, NorthCarolina

116. francoise stichelbaut,bruxelles, Belgium

117. Shannon Cauthen,AURORA, Colorado

118. Sarah Sivro, Genève,Switzerland

119. Maren Erickson,MILWAUKEE,Wisconsin

120. Nancy Black, St. Charles,Missouri

121. Ana King, Chicago, Illinois122. Dylan Ross,

CANTONMENT, Florida123. Linda Jones, ONTARIO,

California124. Carrie Darling, Phoenix,

Arizona125. Mary Sullins,

HITCHCOCK, Texas126. Ann Stuart, Bangkok,

Thailand127. Justin Knight, Torquay,

United Kingdom128. Rob Lozon, Flint,

Michigan

61

129. Keaton Jones, SALTLAKE CITY, Utah

130. Arnold Davis, Chicago,Illinois

131. Julia Basabe-Jennings,Imperial Beach, California

132. Sandra d, Bakersfield,California

133. Valeska Gann, Scottsdale,Arizona

134. Christa Mötbh,Hollabrunn, Austria

135. Evangelina Fajardo,Vancouver, Canada

136. Jana Menard, South LakeTahoe, California

137. michael Bruck,Maalot-Tarshicha, Israel

138. jackie De Sepibus,Echirolles, France

139. DEBORAH SMITH,OKLAHOMA CITY,Oklahoma

140. d lanesk, grand rapids,Michigan

141. Patricia Hawkins, St.Ignatius, Montana

142. Millie OConnor, COCOA,Florida

143. Hent catalina - maria,bucarest, Romania

144. addy singh, delhi, India145. Christopher Snowden,

Manchester, UnitedKingdom

146. Heini Laitila, Helsinki,Finland

147. Inge Tinga, amsterdam,Netherlands

148. Tina Florell, Stockholm,Sweden

149. Sarah Dyson, WACO,Texas

150. kerry ford, hamilton, NewZealand

151. Danuta Zakurzewska,Toruń, Poland

152. Paola Iocco, Bergamo, Italy153. Audra Moricca, New York,

New York154. jean tenaille, mexico,

Mexico155. Leslie Hammon, Louisville,

Kentucky156. Janis King, RENO, Nevada157. Wilson Hodges, St.

Catharines, Canada158. Lisa Shaffer, Naperville,

Illinois159. Marianne Bradley,

Frankford, Delaware160. lynda leigh, SANTA

CRUZ, California161. Candy Bowman,

Sacramento, California162. J