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Safety Recommendation Details

Safety Recommendation H-02-020
Details
Synopsis: On May 31, 2001, about 3:28 p.m. central daylight time, a southbound Gayle Stuart Trucking, Inc., truck-tractor semitrailer exited Interstate 540 at State Highway 282 (SH-282) near Mountainburg. The driver was unable to stop at the stop sign at the bottom of the ramp. The 79,040-pound combination unit was traveling approximately 48 mph when it entered the intersection and collided with the right side of a westbound, 65-passenger, 1990 Blue Bird Corporation school bus operated by the Mountainburg, Arkansas, Public Schools. The school bus rotated approximately 300 degrees clockwise and overturned; the body, which partially separated from the chassis, came to rest on its right side on the eastbound shoulder of SH-282. The tractor semitrailer continued across the roadway, rotated about 60 degrees clockwise, overturned, and came to rest on its left side. Three school bus passengers seated across from the impact area were fatally injured; one was partially ejected. Two other passengers, one of whom was seated in the impact area, received serious injuries, and four passengers had minor injuries. The school bus driver and truckdriver both sustained minor injuries.
Recommendation: The National Transportation Safety Board recommends that the Commercial Vehicle Safety Alliance: Include spring brake caging port dust covers as an inspection item during Motor Carrier Safety Assistance Program roadside inspections.
Original recommendation transmittal letter: PDF
Overall Status: Closed - Reconsidered
Mode: Highway
Location: Mountainburg, AR, United States
Is Reiterated: No
Is Hazmat: No
Is NPRM: No
Accident #: HWY01MH025
Accident Reports: Collision Between Truck-Tractor Semitrailer and School Bus
Report #: HAR-02-03
Accident Date: 5/31/2001
Issue Date: 9/13/2002
Date Closed: 11/12/2008
Addressee(s) and Addressee Status: Commercial Vehicle Safety Alliance (Closed - Reconsidered)
Keyword(s):

Safety Recommendation History
From: NTSB
To: Commercial Vehicle Safety Alliance
Date: 11/12/2008
Response: The Safety Board notes that the original CVSA Vehicle and Training Committee reviews of the NAS Inspection Procedure, OOSC, and training materials found that they were adequate and that no further action was required. Currently, when a broken parking-brake spring is detected during an inspection, it is documented as only a brake violation and not counted toward the 20-percent rule for defective brakes as outlined in Part II of the OOSC. Because the service brakes on the Mountainburg accident vehicle had been affected by damage to the parking-brake side of the spring brake housing, at the March 2008 CVSA Workshop in Denver, Colorado, the CVSA Vehicle Committee developed additional language to include defective parking brake springs and other defective brake components not specifically listed in the 20-percent rule in Part II of the OOSC. The CVSA membership voted to accept the recommended changes in the fall of 2008; the new OOSC language becomes effective on April 1, 2009. These changes permit broken parking-brake springs to be detected and documented during a roadside inspection, contributing to the vehicle’s being placed OOS for 20-percent defective brakes, and, if warranted, the vehicle will be prohibited from proceeding until all brake violations are corrected. Although the Safety Board is pleased with the recommended revision of the service brake inspection methodology, such efforts address this recommendation only tangentially; Safety Recommendation H-02-20 specifically addresses the inspection of spring-brake-caging port dust covers. As you indicated, because no regulation requires CMVs to have these dust covers in place, the inspection and identification of the dust covers would not be an item deemed to be an imminent hazard, and, therefore, they would not be inspected during a law enforcement roadside inspection. Additionally, you indicated that the corrosion and deterioration of spring-brake housings cannot solely be attributed to the absence of the dust covers—environmental factors such as deicing chemicals and salt can also affect the integrity of the housing. The Board is aware that technological advances in brake system manufacturing are moving toward designs for alternative spring-brake housings without caging ports, and drum brakes are being replaced by disc brakes, which aid in a vehicle’s overall stopping distance. With these innovations, the need to include spring-brake-caging port dust covers as an inspection item during roadside inspections is becoming obsolete. Because no Federal regulations address this issue and brake systems are now being designed without spring-brake-caging ports, Safety Recommendation H-02-20 is classified Closed Reconsidered.

From: Commercial Vehicle Safety Alliance
To: NTSB
Date: 12/10/2007
Response: Letter Mail Controlled 12/12/2007 11:40:56 AM MC# 2070737: We appreciate the active participation of the National Transportation Safety Board (NTSB) in the activities of the Commercial Vehicle Safety Alliance (CVSA) and helping to support our mission of Promoting Commercial Motor Vehicle Safety and Security. As a result of our collective efforts, the purpose of this letter is to provide the NTSB with a status update and closure on NTSB Safety Recommendation H-02-020. CVSA is an international not-for-profit organization comprised of local, state, provincial, territorial and federal motor carrier safety officials and industry representatives from the United States, Canada, and Mexico. Our mission is to promote commercial motor vehicle safety and security by providing leadership to enforcement, industry and policy makers. In addition, CVSA has several hundred associate members who are committed to helping the Alliance achieve its goals; uniformity, compatibility and reciprocity of commercial motor vehicle inspections, and enforcement activities throughout North America by individuals dedicated to highway safety and security. The Alliance works to closely monitor, evaluate and identify potentially unsafe transportation processes and procedures as well as to help facilitate and implement best practices for enhancing safety on our highways. Commercial motor vehicle safety continues to be a challenge and we need the involvement of all affected parties to help us better understand these issues and put into place practical solutions. Once this NTSB Safety Recommendation was issued, CVSA conducted a comprehensive review and discussed the issue within the Vehicle and Training Committees of the Alliance to determine what changes to the North American Standard Inspection Program (attachment 1) were required. A random roadside inspection includes many elements of a commercial motor vehicle (CMV) braking system. At this time, it was determined that the information contained in the North American Standard Level I Inspection Procedure (attachment 2), the North American Standard Out-of-Service Criteria (OOSC) (attachment 3) and the training materials provided in Module 6 of the North American Standard Level I - Part “B” (Vehicle) Inspection Course (attachment 4 and 5) were adequate and no further action was required. Broken parking brake springs and the deterioration of spring brake housings would have been discovered at Step 29 - Inspect Axle(s) 2 and/or 3, & Step 30 - Inspect Axle(s) 4 and/or 5, of the North American Standard Level I Inspection Procedure. However, because no regulatory authority exists for a CMV to have spring brake caging port dust covers in place, the inspection and identification of spring brake caging port dust covers would not be an item deemed to be an imminent hazard and therefore not inspected. Additionally, from our observation, the corrosion and deterioration of spring brake housings cannot be solely attributed to the spring brake caging port dust covers not being in place (attachment 6). Steps 28, 29 & 30 of the North American Standard Level I Inspection Procedure are illustrated below: STEP 28 INSPECT STEERING AXLE(S) BRAKES (BOTHSIDES) Check for missing, non-functioning, loose, contaminated or crackedparts on the brake system; such as, brake drums, shoes, rotors, pads, lining, return springs, cam rollers, spiders, cam shaft support brackets, brake chambers, air chamber mounting bolts, push rods, slack adjusters and air reservoir integrity and mounting. Check for “S” cam flip-over. Be alert for audible air leaks around brake components and lines. With the brakes released, mark the brake chamber push rods at a point where the push rods exit the brake chambers or use an alternative method. All push rods will be measured later. Check that the slack adjusters are the same length (from center of “S” cam to center of clevis pin), and that the air chambers on each axle are the same size. STEP 29 INSPECT AXLE(S) 2 AND/OR 3 BRAKES (BOTH SIDES) Inspect as described in Step 28. Inspect for non-manufactured holes (i.e. rust holes, holes created by rubbing or friction, etc.) which have compromised the integrity of the spring brake housing section of the parking brake. Inspect for broken springs in the spring brake housing section of the parking brake. CAUTION: NEVER PLACE YOURSELF IN FRONT OF THE SPRING BRAKE HOUSING SECTION OF THE PARKING BRAKE. IN ADDITION, DO NOT STICK ANYTHING INTO THE SPRING BRAKE CAGING PORT. If you need to exit, always do so in full view of the driver. STEP 30 INSPECT AXLE(S) 4 AND/OR 5 BRAKES (BOTH SIDES) Inspect as described in Steps 28 & 29. During a random roadside inspection, all CMV’s are inspected to applicable highway safety regulations, and any violation(s) identified are cross referenced to the OOSC to determine whether they are likely to cause or contribute to a crash or breakdown if the driver and/or vehicle is allowed to proceed. This is defined as an “Imminent Hazard” under 49 Code of Federal Regulations (CFR) §390.5. The OOSC does not supersede or summarize any federal safety regulation or trade association standards. Although the OOSC was developed with the assistance of (and continues to rely on) a variety of applicable trade associations, it does not reflect their recommended manufacturing or maintenance standards. The North American Standard Inspection Program and the OOSC have been in place for more than two decades and were never intended to serve this purpose (attachment 7). As a result, CVSA has petitioned the Federal Motor Carrier Safety Administration (FMCSA) to remedy the confusion surrounding annual periodic inspections (attachments 8). The deterioration of spring brake housings identified during a random roadside inspection would be cross referenced to Part II of the OOSC, and if warranted, the vehicle would be placed out-of-service (00S) and not be allowed to proceed until the condition is corrected. The North American Standard Out-of-Service Criteria for this violation is illustrated below: 1. BRAKE SYSTEM C. Spring Brake Chambers Any non-manufactured holes or cracks in the spring brake housing section of a parking brake. (396.3(a)(l)) Currently, when a broken parking brake spring is detected during an inspection, it is only documented as a brake violation and it does not count toward the 20 percent rule for defective brakes as outlined in Part II of the OOSC. However, since the service brakes were affected in this investigation by damage in the parking brake side of the spring brake housing, the Vehicle Committee will review and re-evaluate this methodology and consider adding defective parking brake springs and other defective brake components not specifically listed to the 20 percent rule in Part II of the OOSC during our next scheduled CVSA meeting in March 2008 in Denver, CO. This change, if approved by the Alliance membership, would permit broken parking brake springs detected and documented during a roadside inspection to contribute to the vehicle being placed out-of-service (00S) for 20 percent defective brakes, and if warranted, the vehicle would and not be allowed to proceed until all brake violations are corrected. From our observation, the technological advancements of brake systems are steadily progressing. As an example, brake manufactures have started to design alternative spring brake housings without spring brake caging ports and with the evolution from drum to disc brakes to aid in a vehicle’s overall stopping distance, the need for a regulatory authority to prohibit the operation of a CMV with a caging port dust cover removed is becoming obsolete. Additionally, further research needs to be conducted on the corrosion and deterioration of spring brake chambers and parking brake springs; such as the use of alternate materials and the galvanization and/or cryogenic treatment of metals. As a result of these evolving trends, the NTSB should consider updating its April 29, 1992, Heavy Vehicle Airbrake Performance Safety Study. In closing, we appreciate the dedication and commitment of our partner organizations such as the NTSB in helping us address these challenges and hopeful that these actions are acceptable. For more on CVSA visit www.cvsa.org.

From: Commercial Vehicle Safety Alliance
To: NTSB
Date: 7/27/2006
Response: Letter Mail Controlled 7/28/2006 11:05:16 AM MC# 2060368: The NAS Inspection Procedures include many elements of CMV braking systems. However, one of its challenges is that dust covers, which have been installed by industry to help minimize environmental damage to braking systems and prolong their lifespan, present difficulties in terms of inspecting certain components of the braking system during the roadside inspection. We agree that this is an important issue to address, and at our upcoming 2006 Fall Workshop in Toronto the CVSA Vehicle Committee has this item on its agenda for discussion. We will inform the Board of the outcome and of any activities we plan to take action on.