Executive Order 13043 requires belt use by federal employees on the job and all motor vehicle occupants traveling in national parks and defense installations. When issued, the Executive Order recommended that there be seat belt use polices and programs for federal contractors, grantees, and Tribal Governments. Response to the Executive Order 13043 has been sporadic, though some continuous exemplary efforts were found. This chapter documents the response from a number government agencies to meet the requirements of Executive Order 13043, starting with Department of Defense (all branches), followed by the Department of the Interior's, Indian Nations and National Parks Service, and lastly, the Department of Energy.
Department of Defense (DOD) policies have long required occupant restraint use in both government vehicles and in privately owned vehicles (POVs) operated on military bases. The armed forces also have a tradition of vigorous enforcement of the policy and promotion of traffic safety to military personnel and their families.
The organizational culture of the military services enables them to pursue an initiative like Buckle Up America with vigor. Safety has always been one of the military's top priorities. Each branch of DOD service has a Safety Office. Each Safety Office has trained personnel promoting a broad range of safety issues, including traffic safety. Additionally, commissioned and non-commissioned officers are held accountable for the safety of the people in their command. It is not surprising then that military bases with the most outstanding seat belt programs have a commanding officer that has made a personal commitment to safety, and this attitude has permeated the chain of command.
Enforcement practices vary from base to base. Primary enforcement takes place on some bases, but not all. Some bases go beyond state enforcement laws, and some impose sanctions that exceed the state statutory sanctions. At Tyndall Air Force Base, for instance, violations are reported to the supervisors of military personnel and penalty points are put on the DOD driver license. The license is suspended for one year for a second offense and for three years for a third offense. At Tyndall Air Force Base, civilian contractors are also asked to discipline their employees for seat belt violations.
Military service policy requires routine POV inspections and one-on-one safety briefing by each soldier's superior. Safety committees hold regular briefings to report progress toward safety performance goals and to plan injury prevention efforts. These committees include Safety Office staff, representatives of each command, emergency service personnel, health care professionals, and military police. Typically, bases also have accident review boards that investigate serious injury accidents, determine probable causes, and recommend preventative measures.
Most bases require that all entering vehicles stop at the entrance gate, where guards check seat belt use. Motorists who are not in compliance may or may not get a ticket, but they are required to buckle up before proceeding. In most locations, the Military Police enforce the seat belt regulations on their regular patrols, as well as in special patrols and at checkpoints. At Fort Benning, for example, there are weekly checkpoints at random times and locations.
There are many instances of exemplary seat belt and child passenger safety programs on military bases. Those included in this report attracted attention by participating in innovative activities, having high seat belt compliance, and/or making remarkable improvement in belt usage. All of the exemplary bases were conducting frequent belt use observation surveys and vigorously enforcing occupant restraint. Finally, the level of publicity and education related to occupant restraint was very high at all of these bases.
The commanding General at Fort Hood was concerned with the high motor vehicle fatality rate near his installation. Many fatal crashes had occurred on Texas Highway 95, a two-lane road used by his personnel as a shortcut to Austin. Although promoting seat belt use would not lower the incidence of crashes involving Fort Hood personnel, the Commanding General and the Fort Hood Safety Office believed that buckling up would help reduce the severity of injuries.
Fort Hood's Safety Office, Provost Marshall, and the Director of Community Activities often work together to promote safety, including the use of seat belts and child safety seats. They organize quarterly Safety Stand-Down meetings and frequent other base events where representatives from safety organizations are invited to speak. Speakers from the Texas Department of Public Service, MADD, and other highway safety groups frequently appear at these events. The Safety Office supports these activities by providing brochures, posters, and other materials devoted to traffic safety, and the weekly paper, The Fort Hood Sentinel, rarely appears without at least one article on traffic safety and the use of occupant restraints.
The importance of seat belt and child safety seat use in POVs is included in most of the post's safety training activities. The four-hour National Safety Council Defensive Driving Course is given to all incoming military personnel up to an E-4 rank. Others may take the course voluntarily. Between 10,000 to 14,000 enroll in the course each year. Additionally, the Safety Office teaches a bi-monthly safety course to officers, and occupant restraint use is included in the curriculum. Company commanders also have a quarterly class on POV safety, which battalion executive officers and staff sergeants are required to attend. As on other Army posts, the Commanding General reminds the chain of command to do safety briefings of their direct subordinates before each long weekend holiday.
The Fort Hood Provost Marshall frequently does spot checks for seat belt use. In Spring 1999, the belt use rate was measured at 85 percent.
Norfolk Naval Station is the world's largest naval base with nearly 40,000 military and civilian personnel. In 1997 and 1998, the Station coordinated the "Battle of the Belts," a challenge to all commands in the Hampton Roads region to increase seat belt use. In 1998, 19 commands responded. Participating commands did unannounced seat belt checks of 100 vehicles before the event and two follow-up checks after the program was publicized. Commands passed out LifeSavers candy to belted occupants or children in child safety seats and "dum-dums" candy to those not properly restrained. The Station's Safety Office also provided informational materials for distribution at the gate.
Belt use is required on the base, and base security personnel issue seat belt citations routinely. Enforcement is secondary, however, in keeping with the Virginia seat belt law. The facility is gated, and motor vehicle checks are often made at the gate, especially late at night and early in the morning.
Seat belt use is a recurring agenda item at quarterly meetings of the base's Traffic Safety Council. The meetings are attended by representatives of all commands based in Norfolk, as well as the Safety Office, Base Security, the fire department, medical clinic, engineers, maintenance department, and other groups that are concerned with safety and security. There are frequent safety stand-downs open to the entire community at the post. The events feature guest speakers and usually fill the 2,500 seat theater where they are held.
Occupant restraint is a high priority for the base's Drive Smart Safe Community Coalition, coordinated by the base's Safety Office. The coalition also includes civilian highway safety organizations, law enforcement agencies, colleges, and businesses in the surrounding communities. The Coalition sponsors activities to promote the use of seat belts and child safety seats. For example, the post celebrates "National Night Out" each year, when security officers do seat belt enforcement patrols and the Safety Office distributes promotional materials.
Many of the base's fire fighters are NHTSA-certified child passenger safety technicians. They hold frequent child passenger safety clinics on the post and work with civilian organizations holding clinics outside the base gates. Safety characters, including Buckle-Bear, Vince and Larry, and the "seat belt convincer" are frequently present at these events.
Although crashes involving Naval Station personnel remain high, seat belt use rates have increased and injuries are said to be both less frequent and less severe.
The Marine Corps Air Station in Cherry Point, North Carolina is the Corps' largest base. The base has a daytime population of about 15,000, including military personnel, their families, and civilian contractors.
At the Commanding General's order, the penalty for non-use of seat belts on the facility was increased on August 1, 1999, from two points on the driver license to drive on base, to three points for the first offense. A license is suspended seven days for the second offense and six months for subsequent violations. The penalty for child safety seat violations was made even tougher, with a one-month license suspension for the second offense.
Belt use surveys are done weekly. In the year preceding the new regulation, belt use ranged from 84 percent to 94 percent. In the week following the new regulation, belt use reached a high of 98 percent. Signboards at the entrance gates display the current and record use rates to all that enter the gates. The Safety Office has ordered new signs that can display three digits, so that 100 percent can be displayed, when attained. In addition to the large feedback signs at the gates, there are about 75 smaller "Buckle Up" signs placed throughout the post. There are plans to post additional signs with information about the increased penalties.
The Provost Marshall calls for vigorous enforcement of seat belt regulations. Although MPs do not conduct primary enforcement, they do frequent safety checkpoints, where all vehicles are stopped and seat belt and other traffic violations are cited. In January and February 1999, for example, MPs wrote 300 to 400 seat belt tickets at checkpoints.
Child passenger safety is addressed through cooperative efforts with the installation's Child Development Center. The POV Safety Manager at Cherry Point is a certified child passenger safety technician, and he is available to provide individualized instruction on request.
Seat belt use and child safety are highlighted in safety briefings, which are held at least three times a year, usually around major holidays. In addition, individual units on the post hold their own safety stand-downs. For example, on August 5, 1999, the Second Marine Corps Air Battalion conducted an event at the base theater. Marines were given a one-day leave to attend. To attract families, the event featured the newly released "Tarzan" movie. Before the movie began, the Commanding General spoke on the importance of POV safety. There also were presentations on seat belts and child safety seats by the Safety Office and the North Carolina Highway Patrol.
"Safety Expo 99," involving the entire Marine Corps Air Station, was held on the mall and in the parking lot of the Marine Corps Exchange. The annual event is designed to cover a wide range of safety issues and to appeal to persons of all ages. Activities this year included the Station's "Convincer," a device that conveys the experience of a five-MPH crash while belted, and a child safety seat booth, one of the busiest attractions. Following the Expo, the POV Safety Manager's mornings were booked for two weeks with appointments for child safety seat inspections and training.
The Safety Office recently initiated the formation of a county-wide Safety Community Coalition, involving local police departments, the sheriff's office, the North Carolina Highway Patrol, schools, a medical center, volunteer fire and rescue personnel, and other interested individuals. A $15,000 grant from the North Carolina State Highway Safety Office is funding the effort.
Belt use surveys continue to be used by the Air Station to indicate when action is needed. When a recent belt use survey indicated a use rate of only 78 percent, the Provost Marshall increased enforcement activity during the following week, and the usage rate increased to 92 percent.
The latest seat belt survey at Tyndall Air Force Based showed 100 percent belt use in government vehicles and 98 percent use in POVs. The goal at Tyndall is 100 percent use in both government and private vehicles. In addition to periodic surveys by the Base's Safety Office, the Inspector General's office conducts annual surveys. Their last annual survey, in 1998, showed 100 percent belt use in government vehicles and 96 percent in POVs.
The Base's Safety Manager believes that maintaining high belt use rate requires continued education and enforcement. Enforcement waves are initiated immediately when observation surveys indicate the use rate is declining. Military Police are responsible for traffic enforcement on the base. In accordance with Air Force regulations, MPs make primary seat belt/child restraint enforcement stops of both government and POVs.
Seat belt education is an ongoing effort. Seat belts are included in the safety briefing given to all incoming personnel. The issue is also promoted at the base's annual safety day, as part of the "101 Critical Days of Summer" campaign, and in mandatory individual pre-holiday safety briefings given to all military personnel under age 26.
Recently, the Safety Office published a "Saved by the Belt" story in the Base's Newspaper. The story involved two airmen who were belted when their vehicle hit a concrete median barrier in an attempt to avoid a collision. Saved by the Belt awards were presented to the men's commanding officer.
Child passenger safety is also taken seriously at Tyndall. Two safety specialists have been certified as Child Safety Technicians. They voluntarily participate in child passenger safety clinics with civilian organizations and have had two clinics on the base in the past year. More than 30 safety seats, supplied by civilian organizations, were given to parents to replace recalled seats found in the clinics. The Tyndall safety seat clinics revealed that a high percentage of the seats inspected were incorrectly installed.
Seat belt and child restraint use rates on Native American reservations are generally much lower than the rates in the states where they are located. Many Native American communities have poorly maintained roadways in sparsely populated, remote areas, and this severely limits the ability to transport crash victims to medical facilities in a timely fashion, and therefore, increased use of occupant restraints has a great potential to save lives.
The Department of the Interior, Bureau of Indian Affairs (BIA), had led many efforts prior to BUA to increase seat belt and child restraint us among Native Americans. For example, BIA administered numerous successful NHTSA funded highway safety programs, including Selective Traffic Enforcement Programs (sTEPs), Community Traffic Safety Programs (CTSPs) and tribal Safe Community grant programs. Now, with BUA, tribes are making even more, substantial progress.
New laws, strong enforcement, and public outreach associated with BUA have led to increases in occupant protection across Indian Nations. For example, the Umatilla Tribe in Oregon used occupant protection sTEPs to achieve 95 percent belt use in 1999. The Lummi Nation in Washington promoted the importance of buckling enough, so that the use rate increased 61 percent to 75 percent in 1999. Also, the Navajo Nation, under a strong primary enforcement law, attained a 92 percent seat belt use rate in 1999.
Other Native American groups have begun passing primary seat belt enforcement laws. The Turtle Mountain Band of Chippewa in North Dakota and the Oglala Siouz on the Pine Ridge Reservation in South Dakota passed them in 1997 in states that do not have primary enforcement. Prior to the passage of these laws, both communities had high crash rates and seat belt use below 10 percent. As a result of a six-month awareness campaign, following passage of the laws and preceding the initiation of enforcement, seat belt use increased to 38 percent among the Turtle Mountain Band of Chippewa. Following the initiation of enforcement, usage increased to 42 percent by fall 1999. Similarly, seat belt use among the Oglala Sioux increased to 25 percent after six months of enforcement and to 46 percent by fall 1999.
The Department of Health and Human Services, Indian Health Service (IHS), has promoted belt and child restraint use for many years through various injury prevention programs. Programs to distribute child safety seats, at either no or low cost, have been established on most reservations. Additionally, the IHS has provided a great deal of training in the safe installation of child safety seats. Hundreds of health care professionals received training prior to the Child Passenger Safety Technician certificate program, and now efforts are underway to expand the number of certified technicians.
As of the end of 1999, there were 13 Safe Tribal Communities that had conducted a variety of activities associated with BUA. Case studies were used to thoroughly document exemplary activities for three.
Although the Umatilla Tribal Police Department has jurisdiction throughout Umatilla County, the primary patrol area is within the Umatilla Reservation, which accounts for 6,000 of the county's 70,000 residents. There is a casino on the reservation that draws a great deal of traffic from urban centers in Washington and Oregon.
Seat belt use on the reservation reached an all-time high of 96 percent after the Tribal Police Department's 1999 year-end seat belt enforcement blitz. This represents an increase of more than 30 percentage points in less than two years time.
Tribal Police conduct four occupant restraint sTEPs and at least seven DUI sTEPs each year. Since checkpoints are not legal in Oregon, the occupant restraint sTEPs involve saturation patrols. Each officer is asked to make 14 stops during each four-hour shift. There is considerable publicity on television and radio before, during, and after each enforcement wave. In particular, the primary television cable company airs numerous interviews and other promotions. Effects of the enforcement blitzes on seat belt use are tracked using pre and post observations of belt use.
With nearly universal seat belt use, few citations are issued, only 72 citations in 1998. The Police Department believes the enforcement campaigns maintain a high usage rate as well as having other enforcement benefits. In fact, 39 arrests were made on warrants and several DUI arrests were made as a result of occupant protection sTEPs in 1999.
Child restraint safety is the next priority. Child passenger safety clinics and a safety seat loaner program are planned, the first such program on the reservation.
The Pine Ridge Reservation is one of the largest in the Aberdeen District; it covers 1.7 million acres and has a population of nearly 20,000 Lakota Sioux. The road system on the reservation is dangerous. Many of the roads are unpaved, and even the state highway traversing the reservation is narrow and without shoulders. Between 1993 and 1996, there were 1,305 crashes, including 35 fatal crashes. Making matters worse, the seat belt use rate was only five percent in late 1996.
In 1996, an Oglala Sioux health educator and the then Indian Health Service (IHS) Sanitarian for Pine Ridge organized a tribal Highway Safety Coalition. The Coalition included Oglala Police, MADD, school counselors, health education workers, IHS, Tribal Health and Human Services, and several churches. In April 1997, the Coalition proposed a primary enforcement law to the Tribal Council. The Council enacted the law immediately.
Given the very low use rate, the Council allowed for a one-year grace period before $35 tickets were issued. The grace period allowed time to educate tribal members about the new law and the importance of wearing a seat belt. The public awareness efforts included numerous promotions on the most popular radio station serving the reservation, signs at all entrances to the reservation, and "Vince and Larry" presentations at health fairs and public schools. A BUA poster contest was held in schools, and the winning posters were displayed on billboards located throughout the reservation.
Despite these efforts, the seat belt use rate was only 14 percent by April 1997, immediately before the new law took effect. However, within six months after enforcement began, the rate had increased to 25 percent. Currently, belt use surveys are conducted every six months. Usage was 46 percent in November 1999.
The seat belt law is enforced on regular patrols and at weekly safety checkpoints conducted at random times and places during both day and night. During the Operation ABC Mobilization, November 1999, 137 seat belt and child restraint citations were issued.
Other recent initiatives on the reservation include training several certified child passenger safety technicians, establishing a safety seat loaner program, and holding frequent child passenger safety clinics.
The Turtle Mountain Band of Chippewa has approximately 10,000 members; most living on or near the six-square-mile reservation. The seat of tribal government is Belcourt, which has a population of about 3,500 residents. Seat belt use on the reservation had hovered around seven percent until recent efforts were undertaken. An initiative for a primary enforcement belt law was launched by the Director of Highway Safety, a position funded by grants from the State Highway Safety Office and Master Health, a tribal injury prevention program. On the fourth attempt to persuade the Tribal Council to pass a primary enforcement law, the law was adopted on January 5, 1998.
In persuading the Tribal Council, the Director of Highway Safety demonstrated that the number of traffic fatalities on the reservation was more than twice the number in Fargo, North Dakota's largest city. She also provided evidence that in nearly all injury crashes, the victim was unbelted. She credits passage of the law to seven years of relentless public information and education efforts, aided by the tribal radio station and members of the Turtle Mountain Safe Community Coalition. The Coalition includes the Tribal Elders, IHS, health educators, public schools, the BIA Police, and the courts. She also credits the influence of a newly elected councilman, who related his experiences in responding to traffic crashes as a volunteer for a tribal search and rescue squad.
The law, which carries a $25 fine for the first offense, took effect on February 5, 1998, following a 30-day period for public comments. Although citations were not issued until June 1, 1998, usage had already increased to 38 percent by that time. Motorists were alerted to the new law by "Click It or Ticket" signs posted on tribal roads. An award-winning program conducted by the high school student council aided the publicity effort. The students' activities included pep rally skits, "Vince and Larry" appearances at basketball games, poster contests, school bulletin articles, student pledges, and pre and post belt use surveys of students and staff. Consequently, belt use at the school rose from five to 25 percent during the campaign. Currently, the group sponsors an annual "Ghost Out" in the tradition of SADD chapters.
Police now issue seat belt citations on regular patrols and at safety/sobriety checkpoints. By fall 1999, usage had increased to 42 percent. The Tribe's highway safety program has evolved into a Safe Tribal Community Program with nearly 20 members. This program conducts monthly observation surveys, using high school students as observers.
In response to the BUA initiative, the National Park Service (NPS) revised its rules, effective December 1997, to require all occupants of motor vehicles to use seat belts and child restraint devices at all times within park areas.
The Director of NPS urged compliance with the revised rules by circulating a memorandum, with special emphasis on assuring that all federal employees must wear a seat belt while on official business, that contractors adopt and enforce seat belt policies, and that visitors to parks wear seat belts and, when appropriate, use child safety seats. Parks were encouraged by the Director to implement a plan that proposed some actions that the parks could take to support BUA without burdening employees with excessive workloads. The plan called for continued enforcement of seat belt use by Park Rangers and Park Police and distribution of BUA brochures and other materials provided to NPS from NHTSA. The plan also called for the use of NHTSA videos by NPS Regional Training Managers during employee training. Finally, the plan called for an increased effort to capture and report seat belt use data.
In a number of parks, posters in visitor centers and bumper stickers on park vehicles were put on display. Some parks began distributing brochures, stickers, and hand tags to park users in the visitor center. This is the case at the Lake Meredith National Recreation Area in Texas, where an exceptional effort has been put forth. The Lake Merideth Safety Committee obtained a wide assortment of public information and education materials from NHTSA that they hand out and put on display. In addition, Lake Merideth Park Rangers regularly enforce the Texas occupant restraint laws and stop drivers and passengers under violation.
The Park Rangers in Saratoga National Historic Park now enforce New York's occupant restraint laws on ten miles of tour roadway and on some adjoining federal roadways that they patrol, issuing written warnings for seat belt violations whenever they are observed. Only a few violations are seen since the use rate in the park is high. As requested by the Regional NPS Office, an observational survey was done in 1999 on employee seat belt compliance, and the use rate was said to be close to 100 percent.
One of NPS's biggest success stories occurred at Harpers Ferry National Park in West Virginia, where seat belt use increased from 63 percent in October 1998, to 87 percent in 1999. This was accomplished mostly through employee training and through an effort to publicize seat belt safety benefits throughout the park. First, an effort was made to make all employees aware that seat belt use is required by Executive Order 13043, as well as by state law in West Virginia. As part of the park's ongoing "Safety Watch" program, employees receive credits for viewing safety videos, including tapes on occupant restraint use. The park also displays posters and buttons promoting BUA. Finally, the Harpers Ferry Safety Office leads a defensive driving program for their NPS Region that includes seat belt safety material.
While the U.S. Department of Energy (DOE) has had longstanding policies requiring seat belt use and programs to encourage their use, the BUA Initiative led to an increased emphasis on the occupant restraint issue. As a direct result of the Executive Order, beginning in mid-1998, DOE conducted a departmental assessment of seat belt use rates and site-specific occupant protection programs. The Deputy Assistant Secretary for Worker Health and Safety directed field offices to assess the effectiveness of their programs by conducting observation surveys of belt use and implementing the program elements delineated in a model seat belt program.
In August 1999, DOE's Federal Employees Occupational Safety and Health (FEOSH) office published the results of the assessment in a 42-page document, "Lessons Learned and Good Practices for the Department of Energy Seat Belt Safety Initiative." The report contained sections of the Executive Order and DOE policies on belt use, NHTSA-provided rationale for wearing seat belts, step-by-step instructions for implementing a model program, and a list of resources to aid safety managers in implementing an effective program.
The assessment indicated that the department-wide belt use rate was 88 percent, which exceeded the benchmark of 85 percent. However, belt use varied widely from facility to facility. Seat belt use tended to be higher in larger facilities, reflecting the influence of more highly developed belt campaigns. Higher rates also were observed in facilities with security guards to enforce the seat belt policies; at sites located in states with primary seat belt enforcement laws; and in more populated areas. Use rates were as much as 20 percentage points higher in government vehicles than in privately owned vehicles.
The "Lessons Learned" report stressed that observation surveys provide more accurate estimates of seat belt use than self-report surveys. Observation surveys also permit collection of data on all occupants. As part of its 1998 evaluation of belt use, at the Brookhaven National Laboratory, the Chicago Operations Office conducted both written and observational surveys. While 91 percent of employees self-reported that they buckled up daily and on the day of the survey, a subsequent observation survey of employees arriving at work revealed that far fewer were buckling up.
DOE policy mandates that facilities' seat belt programs provide for enforcement. In facilities that do not have guards, the Lessons Learned report urged supervisors to conduct spot checks of employees entering parking lots. The report also recommended that seat belt programs promote seat belt use not only in government vehicles, but also in personal vehicles. Suggested promotional strategies included crash simulations and demonstrations or display of crashed vehicles.
The Hanford Washington facility has one of DOE's most active seat belt programs. The emphasis on seat belts arose partly in response to concerns over an increase in the number of crashes and rising costs attributable to crashes. In response to the Executive Order and the BUA Initiative, the FEOSH Office at Hanford expanded its focus to include all 500 federal employees who work at the facility and the 12,000 contractor employees. Previous observation surveys targeted only federal employees and only a few locations. The 1999 survey was conducted by a team of 40 observers in multiple locations over a three-to-four-hour period. According to the survey, 90 percent of vehicle occupants were belted. Even though the 1999 survey is not directly comparable to previous surveys due to changes in methodology, it appears that belt use has improved noticeably. Belt use at Hanford was around 40 percent a decade ago. According to the FEOSH Manager for Hanford, much of the improvement can be attributed to changes in the state's seat belt law, which imposes a $150 fine for violations.
The most visible activity to promote seat belt use occurs at the annual three-day Hanford Health and Safety Expo. The event is funded fully by the DOE and is open to the entire community. During the last Expo, seat belt questions were included in a voluntary survey administered to Expo participants. The importance of seat belt use was most dramatically presented in mock crash demonstrations repeated every two hours. The demonstration showed a two-vehicle crash caused by a drunk driver, and the occupants of the other vehicle were not belted. Responding emergency personnel included the police, sheriff's department, fire fighters, paramedics, a medi-vac helicopter, and even the coroner's office. Most of the 13,000 people who attended last year's Expo saw at least one performance. There was also a BUA booth. Last year's Expo received wide media coverage. Many of the major area employers participate in the Expos, and some give employees release time to attend.
Members of the Expo planning committee also volunteer their time to give talks on safety to local civic groups and high schools. A video of the crash demonstration given at the most recent Expo is being produced and will be distributed on CD-ROM to high school driver education classes throughout the state. DOE is paying the $12,000 production costs, and a group of insurance companies will pay the distribution costs, estimated at about $100,000.
Other public information and education efforts at Hanford include: a component on seat belt safety in the annual safety orientation program required of all employees; seat belt questions in the annual medical risk evaluation required of all federal and contract employees; and continued press coverage of seat belt issues, e.g., reports on observation surveys at the facility.