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For too long, the blame for our nation’s high traffic fatality rate has fallen on individual drivers and factors, rather than on environmental and systemic traffic safety factors.
One of the contributors to and consequences of this approach is insufficient crash data.
Insufficient crash data hinders efforts to define and monitor the problem and identify risk and protective factors, and thwarts strategies to prevent these unnatural and gruesome deaths.
Now is your opportunity to urge federal leaders to collect better crash data to guide traffic safety.
Public comments are wanted by the National Highway Traffic Safety Administration (NHTSA) on revisions to the Model Minimum Uniform Crash Criteria (MMUCC), a voluntary guideline of standardized crash data variables for state and local agencies to consider collecting.
This is important now because the MMUCC won’t be updated again until 2029.
May 2023 Update: 433 Salud America! members submitted our first model comment or our second model comment to tell NHTSA about the need for better guidelines for collecting crash data. NHTSA received 461 comments overall, meaning Salud America! members submitted about 94% of all comments.
May 2023 Update: The Salud America! model comments also got support from The League of American Bicyclists and Transportation for America.
The comment period ended May 3, 2023.
Tell NHTSA to Align Crash Data with a Safe System Approach
Dear National Highway Traffic Safety Administration,
As you know, America is No. 42 of 51 high-income countries for per capita traffic fatalities.
Insufficient and inconsistent crash data has hindered efforts to identify risk factors and protective factors, which thwarts development and adoption of strategies to prevent these unnatural and violent deaths and injuries.
The proposed revision to the Model Minimum Uniform Crash Criteria (MMUCC) does not fully address insufficient and inconsistent crash data because it fails to align with USDOT’s recent adoption of the Safe System Approach, which is a public health approach to prevent crashes from happening and minimize the harm caused when crashes do occur.
As with public health efforts, the Safe System Approach emphasizes prevention. The focus is on systemic change to create a built environment where simple mistakes do not result in serious injuries or deaths. The Safe System Approach seeks to analyze and subsequently reduce risk factors and improve protective factors to prevent crashes and minimize their consequences.
To align MMUCC with a Safe System Approach, MMUCC could categorize variables, also known as data elements, into chapters that align with the five objectives of a Safe System Approach – safer people, safer roads, safer vehicles, safer speeds, and post-crash care.
Currently, MMUCC data elements are detailed in the following six chapters: system populated data elements, crash data elements, vehicle data elements, driver data elements, person data elements, and non-motorist data elements.
Vehicle data elements and driver, person, and non-motorist data elements already align with two objectives of a Safe System Approach (safer vehicles and safer people), but there is no explicit alignment with safer roadways or safer speeds. In fact, the MMUCC revision removed the roadway data elements chapter and most roadway data elements; instead, MMUCC encourages states to rely on separate voluntary guidance to conduct supplemental data collection beyond the data collected in the police crash report. This is a problem because it shifts the priority of crash data collection off local law enforcement officers and onto states, expecting them to take additional, voluntary, steps beyond basic crash data reporting.
Thus, I propose you consider adding back the roadway data elements chapter to the MMUCC. The rationale is that these elements are important for evaluating infrastructure and the effectiveness of countermeasures that prevent or reduce the frequency and severity of crashes.
To align MMUCC with a Safe System Approach, in addition to three chapters for system populated data elements, crash data elements, and vehicle data elements, I propose adding the following chapters and additional data elements:
- Edit the vehicle data elements chapter to be specific to vehicle-related data, rather than include crash data and roadway data, and include vehicle height and vehicle weight (https://salud.to/megacars).
- Combine driver data elements, person data elements, and non-motorist data elements into one chapter on people data elements and include person height and person weight.
- Add back the chapter for roadway data elements, particularly the following roadway elements: roadway functional class, annual average daily traffic, presence of bicycle facility, mainline number of lanes at intersection.
- Add a chapter for speed data elements and include 85th percentile speed (https://salud.to/trafficsafety).
As a proponent of a public health approach to traffic safety, I am concerned that the changes to the MMUCC have weakened rather than strengthened the guidance and will result in even more inconsistent and insufficient crash data.
I hope you will further align the MMUCC with a Safe System Approach.
May 2023 Update: 637 people viewed and 320 people submitted the above comment.
VIEW COMMENT FOR A SAFE SYSTEM APPROACH!
Tell NHTSA to Collect Better Crash Data to Guide Traffic Safety
Dear National Highway Traffic Safety Administration,
It is devastating to me that Americans are dying unnatural and violent deaths on our streets at such high rates, particularly compared to peer countries. I am worried the problem will continue to worsen because America lacks crash data to inform traffic safety improvements.
I am concerned that the changes to the Model Minimum Uniform Crash Criteria (MMUCC) have weakened rather than strengthened the guidance and will result in even more inconsistent and insufficient crash data.
Because the primary cause of serious injuries and deaths on roads is the transfer of kinetic energy in a crash and because efforts to increase free-flowing vehicles and the growing height and weight of vehicles are risk factors for injury and death (https://salud.to/megacars), we need better data collection on factors related to kinetic energy, vehicle height and weight, as well as factors related to free-flowing traffic, such as roadway elements and travel speed (https://salud.to/trafficsafety).
After all, “large vehicles are 2 to 3 times more likely to kill a pedestrian than smaller models due to their weight, height, and aggressive front-end vehicle design,” according to Families for Safe Streets (https://salud.to/ncapfactsheet).
Because there are differences in the frequency and severity of crashes among SUVs and pickup trucks, crash data reporting guidance must consider new classifications for motor vehicle body type categories that considers the height of the vehicle beyond merely the body type.
However, the current MMUCC draft neither includes vehicle height and weight nor 85th percentile speed. Also problematic is that the roadway data elements chapter and most roadway data elements were removed from this MMUCC revision.
To strengthen the MMUCC, it should align with a Safe System Approach, which is a public health approach to prevent crashes from happening and minimize the harm caused when crashes do occur, AND include the follow four groups of data elements to better understand key risk factors and protective factors.
First, MMUCC should include the height and weight of those involved in the crash. This data element is important to evaluate crash outcomes, vehicle design (including occupant protection, non-occupant protection, and other safety systems), and safety equipment design and effectiveness, and to assess infrastructure design.
Second, MMUCC should include vehicle height and weight. This could be achieved through additional data elements related to the height and weight of the vehicle beyond the existing motor vehicle body type categories and beyond the vehicle weight rating. This could also be achieved through the reconsideration of attribute values subfields/groups in V13. Motor Vehicle Body Type Category and through the addition of attribute values in V14. Power Unit Gross Vehicle Weight Rating (GVWR). This data element is important to be used in evaluation, research, and crash comparison purposes, such as to evaluate crash outcomes and vehicle design (including occupant protection, non-occupant protection, and other safety systems).
Third, MMUCC should include 85th percentile speed. This data element is important to evaluate the effectiveness of countermeasures that prevent or reduce the frequency and severity of crashes.
Fourth, MMUCC should add back the chapter on roadway data elements and recommend the chapter for data collection by law enforcement officers. These data elements are important to evaluate infrastructure and the effectiveness of countermeasures that prevent or reduce the frequency and severity of crashes.
Inconsistent and insufficient crash data has hindered efforts to identify risk factors and protective factors, which thwarts the development and adoption of strategies to prevent gruesome deaths and injuries. We need an MMUCC that strengthens crash data.
May 2023 Update: 242 people viewed and 112 people submitted the above comment.
VIEW COMMENT FOR BETTER DATA TO GUIDE TRAFFIC SAFETY!
What Are the Next Steps for the MMUCC?
The public comment period on the MMUCC will end May 3, 2023.
Public input is critical because it gives federal officials information about the potential impact of a proposed regulation, according to Unidos US. Participating in the rulemaking process allows you or your organization to shape federal programs and the rules that govern.
After this 90-day comment period, the NHTSA will review the comments and determine how to move forward with the update to the MMUCC.
This is important now because the MMUCC won’t be updated again until 2029.
May 2023 Update: Our comments were also support by The League of American Bicyclists and Transportation for America.
- “The League supports the comments of Amanda Merck and Salud America, especially the need to collect data on the height of vehicles,” wrote The League of American Bicyclists.
- “We echo the comments shared by the League for American Bicyclists (League) and Salud America, where the MMUCC plays a critical role in creating consistent data on crashes in the United States to better understand trends and patterns in traffic safety and their relationship to user behavior and/or street design,” wrote Transportation for America.
VIEW COMMENT FOR A SAFE SYSTEM APPROACH!
VIEW COMMENT FOR BETTER DATA TO GUIDE TRAFFIC SAFETY!
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