Interpretation ID: aiam3862
Chairman
National Transportation Safety Board
Washington
DC 20594;
Dear Mr. Chairman: This is in further response to recommendations H-83-44 and H-83-4 which your agency made to the National Highway Traffic Safety Administration (NHTSA) regarding the Highway Accident Report, 'Jonesboro School District Schoolbus Run-Off-Road and Overturn, State Highway 214 at State Highway 18, near Newport, Arkansas, March 25, 1983' (NTSB/HAR-83/03).; NHTSA agrees with the National Transportation Safety Board tha properly inspected and repaired school buses are essential to the safe transportation of school children. We also believe that the current provisions in Highway Safety Program Standard 1, Periodic Motor Vehicle Inspection, and Highway Safety Program Standard 17, Pupil Transportation Safety, as well as the relevant Federal Motor Vehicle Safety Standards, provide for an adequate level of safety when children are transported to and from school.; Of the 15,840 school districts in the United States, about 15,00 provide pupil transportation. Over 400,000 buses are involved in transporting the nation's 22 million public, private and parochial school children to and from school each day. These buses are maintained by a number of persons having diverse backgrounds ranging in skill from 'grease monkey' to those certified by the national institute for Automotive Service Excellence (ASE). This fleet travels over three billion miles a year, and is remarkably free of problems. Information reported at national meetings indicates that accidents due to mechanical failure are estimated to be between three and five percent and very few result in injury or death.; With respect to the specific recommendations, we have the followin comments:; >>>*RECOMMENDATION H-83-44* (Class II, Priority Action) *Include in Highway Safety Program Standard (HSPS) 17--Pupi Transportation Safety and in the Program Manual' for HSPS 17 the requirement that the States institute quality control procedures for schoolbus repairs to determine if needed repairs have been performed adequately or if major repairs are required.; COMMENT* State Directors of Transportation, school business officials and flee supervisors with whom NHTSA has talked agree that school buses should be kept in good repair. They questioned, however, how quality control procedures could be applied to the repair of school buses when almost every repair is different. Most school buses currently undergo at least two inspections a year, as suggested by Standard 17, which procedure helps to detect major defects that require repair. In addition to this inspection, we understand that most drivers conduct a daily inspection which identifies the need for minor repairs. One supervisor observed that school bus drivers act as a form of practical quality control because they check to determine if the school bus is operating safely after the repair has been made.; A survey of almost 1,000 fleets by the National School Transportatio Association revealed that 49 percent operated fewer than 10 buses. To institute quality control procedures for these small fleets would quickly exhaust the limited resources of most States. Instituting formal quality control procedures would be costly to the States, no matter whether facilities were built and equipment purchased, or alternative checking procedures were utilized.; *Recommendation H-83-45* (Class II, Priority Action) This five part recommendation would include in the Program Manual o Highway Safety Program Standard 17-Pupil Transportation Safety, the program areas listed below.; *1. Specific, well-defined qualifications for hiring schoolbu mechanics,; 2. Specific skill areas for schoolbus mechanics for which certificatio of proficiency is required,; 3. A bibliography of available courses that can be attended or cours curricula that can be used as an example to obtain certification of proficiency in the required skill areas, *Comment*; NHTSA plans to use a portion of staff resources to review th literature that pertains to school bus mechanic qualifications and skill areas needed for certification. Upon completion we will disseminate the appropriate information to State and local governments.; Many schools, colleges and vocational training centers offer variou courses in auto-mechanics, but few people ever master all the major areas of vehicle repair and become master-mechanics. The majority of small fleet operators could not afford to hire such a skilled mechanic. Car dealers employ many skilled mechanics but many are neither equipped nor do they desire to repair school buses. It is highly unlikely that owners of small fleets would or could hire an ASE certified mechanic. It is also unlikely that most of the garages or service stations that maintain school buses have such a person in their employ because they are small independent private entrepreneures (sic). The extreme diversity of the school bus fleet in the United States would be a major complication for a practical certification program.; In 1978, hearings were held by the House Subcommittee on Consume Protection and Finance, of the Committee on Interstate and Foreign Commerce, to examine State and local as well as private sector approaches to the problem of unnecessary, incompetent, or fraudulent repair practices. Senator Philip Hart also held hearings in the late 1960s on Mechanic Training and Licensing. In spite of the adverse findings by these two committees, neither the Federal Government nor any State has gone so far as to require certification of mechanics doing work on cars or school buses. Because of the complexity of this problem, and the lack of Congressional action, NHTSA is of the opinion that it cannot go beyond publishing qualifications for school bus mechanics and identifying available training centers.; States whose accident records show the need for better maintenance car can be expected to take remedial action. Michigan, for example, provided workshops especially designed for school bus mechanics for over 10 years.; *4. A requirement to institute and enforce procedures to prevent schoo activity groups from organizing, beginning, or continuing trips in mechanically unsafe vehicles,; Comment* A requirement to institute and enforce procedures to prevent schoo activity groups from organizing, beginning or continuing trips in mechanically unsafe vehicles is commendable. Such a requirement, however, would be effective only if it were enforced. Standard 17 currently suggests pre-trip inspections and a written report of any defect or deficiency discovered. We believe a reminder to the States of this suggestion would encourage them to give the proper attention to this safety area.; *5. Requirements to place fire extinguishers at the front and rear o school buses, post signs in school buses on the location and use of emergency equipment, and brief passengers on the location and use of emergency equipment, both periodically and before beginning activity trips.; Comment* The placement of additional fire extinguishers outside the bus driver' compartment has led to increased theft and vandalism. These essential pieces of emergency equipment need to remain under the watchful eyes of the bus driver. The benefits of placing a second fire extinguisher in the rear of the school bus are so few as to make this requirement unwarranted. In case of a fire, a bus driver's first responsibility is to get the pupils to a place of safety. Having the personal skill and the equipment to handle a small fire are helpful, but not a necessity.; NHTSA suggests that all pupils who ride school buses should hav instruction twice a year in safe riding procedures and emergency drills. This should provide sufficient information to students concerning the location and use of emergency equipment carried on the school bus. The location and use of fire extinguishers should be a part of this instruction.; Thank you for the opportunity to comment on these safet recommendations. If NHTSA can supply any additional information, please let me know.;