Public Comments

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U.S. Department
of Transportation

1200 New Jersey Avenue SE.
Washington, DC 20590

National Highway
Traffic Safety
Administration

April 23, 2025
Mr. Eric Hein

Dear Mr. Hein:
Thank you for your December 16, 2024, email referencing your April 21, 2023, correspondence
regarding underride/override data in the Fatality Analysis Reporting System (FARS). We have
reviewed your requests and have provided our responses below. The National Highway Traffic
Safety Administration's (NHTSA) lifesaving mission relies on accurate data, and we remain
committed to improving our crash data collections wherever possible. Since NHTSA
representatives met with you about these specific items on April 3, 2023, the agency has taken
several additional actions and we have provided details on these updates in the below responses
to each of your requests.

"l. Update the Fatality Analysis Reporting System (FARS) analytical user's manual (NCSA
2023), the 2021 FARSICRSS Coding and Validation Manual (NHTSA 2023), the Model
Minimum Uniform Crash Criteria (MMUCC; NmSA 2023a), and other guidance documents to
provide a standardized definition ofunderride (NHTSA 2022a) and override crashes for the
required underrideloverride data element (.~ee Appendices);"
NHTSA has implemented a standardized definition ofunderride and override. The Model
Minimum Unform Crash Criteria, 6th ed., released in 2024, includes the data element Vehicle
Underride or Override with the following attributes: None or Not Applicable, Underride,
Override, and Unknown- as well as a data element that collects the Initial Contact Point clock
points. The definition of Vehicle Underride or Override is: "Indicates whether this vehicle
experienced an underride or override with another vehicle during the crash. An underride refers
to this motor vehicle sliding under another motor vehicle during a crash. An override refers to
this motor vehicle riding up over another motor vehicle during a crash. Either can occur with a
parked or working motor vehicle." NHTSA has implemented this definition across the FARS
and Crash Report Sampling System (CRSS) data collection programs and related documentation.

"2. Modify the existing underride FARS data element, which is already required to be reported
by each State, in the FARS analytical user's manual (NCSA 2023), the 2021 FARSICRSS Coding
and Validation Manual (NHTSA 2023), the MMUCC (NHTSA 2023a), and other guidance
documents, to differentiate and collect data on rear underride, side underride, and front override
crashes (see Appendices);"

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NHTSA cannot require States to provide specific data via the FARS program. Even
participation in FARS is not mandatory. Instead, the Uniform Procedures for State Highway
Safety Grant Programs, 23 CFR Pait I 300, Appendix A, encourages participation in FARS by
making certain formula grant funding contingent on State participation in FARS. This grant
provision, however, does not contain any specific data requirements.
NHTSA has, however, made several alterations to the FARS data element and associated
documentation in recent years to improve accuracy. Starting with the 2021 data collection year,
the agency amended the underride and override coding, with underride and override assessed for
each vehicle in every veh icle-to-vehicle coll ision. These changes were highlighted in the coding
manuals and prominently featured in the related training programs. Preliminary analysis
indicates that these revisions are performing well and have improved data coding to more
accurately reflect underride fatality risk, and the agency will continue to monitor this as further
improvements and clarifications are deployed.
Most recently, the FARS/CRSS underride data element has been further amended to align with
the MMUCC 6th ed., starting with the 2025 data collection year. The agency hopes this change
will further enhance accuracy and clarity for both coders and researchers.
Researchers can currently determine the underride or override type by combining data from the
Vehicle Underride or Override data element with Sequence of Events and other data elements
(Initial Contact Point, Damaged Areas, etc.).

"3. Require an Underride/Override "Checkbox" and mandatory reporting ofthis data element
on State Police Crash Report Forms when States upgrade and standardize their electronically
reported State crash data systems to enable electronic real- or near real-time uploading ofcrash
data;"
NHTSA cannot require States to provide specific data via the FARS program nor can the agency
mandate modifications to State police crash report forms. The Uniform Procedures for State
Highway Safety Grant Programs, 23 CFR Part 1300, Appendix A, merely specifies that certain
formula grant funding is contingent on State participation in FARS. As noted above, this
provision does not contain any specific data requirements. Nevertheless, NHTSA actively
encourages States to adopt the MMUCC 6th Ed., which includes the data e lement Vehicle
Underride or Override.

"4. Provide training and ieformation to State FARS analysts and State and local departments on
how to identify and record underride and override crashes. "
NHTSA develops and delivers a variety of FARS trainings. State-employed FARS analysts
learn how to identify and code Vehicle Underride or Override during their initial onboarding and
receive regular refresher training on this data element specifically at annual System-Wide
Trainings. FARS analysts are, however, limited to the information in the official State records
they receive. NHTSA has also developed and distributed an underride training pamphlet to State
and local law enforcef!}ent departments. The Government Accountability Office deemed this

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effort sufficiently responsive to close out the related recommendation made in the report Truck
Underride Guards: Improved Data Collection, Inspections, and Research Needed
(GA0-19-264).
Thank you again for your queries regarding FARS data quality. If you need more information or
have additional questions, do not hesitate to contact Barbara Rhea, Chief of the State Data
Reporting Division, at [email protected].
Sincerely,

Chou-Lin Chen
Associate Administrator
National Center for Statistics and Analysis