Skip Ribbon Commands
Skip to main content
Safety Recommendation Details

Safety Recommendation H-06-029
Details
Synopsis: On November 14, 2004, about 9:30 a.m., eastern standard time, a 44-year-old bus driver departed the Baltimore/Washington International Thurgood Marshall Airport, operating a 2000 Prevost, 58-passenger motorcoach for an approximately 60-mile trip to Mount Vernon, Virginia. Vehicle occupants were the bus driver, an adult chaperone, and 27 high school students. This vehicle was the second one of a two-bus team traveling to Mount Vernon. The motor carrier, Eyre Bus Service, Inc., (Eyre) operates this route frequently, and the accident bus driver had driven this route on one previous occasion 9 days earlier (November 5, 2004). About 10:40 a.m., the bus was traveling southbound in the right lane of the George Washington Memorial Parkway in Alexandria, Virginia, at an electronic control module-recorded speed of approximately 46 mph. As the bus approached the Alexandria Avenue bridge, the bus driver passed warning signs indicating that the bridge had a 10-foot, 2-inch clearance in the right lane. Nonetheless, the driver remained in the right lane and drove the 12-foot-high bus under the bridge, colliding with the underside and side of the overpass.1 At the time of the accident, the 13-foot, 4-inch-high left lane was available to the bus, and the lead Eyre bus was in the left lane ahead of the accident bus. The accident bus came to a final stop in the right lane about 470 feet beyond the bridge. Witnesses and the bus driver himself reported that the bus driver was talking on a hands-free cellular telephone at the time of the accident.
Recommendation: TO 6 MOTORCOACH INDUSTRY, PUBLIC BUS, AND SCHOOL BUS ASSOCIATIONS AND 3 UNIONS: Develop formal policies prohibiting cellular telephone use by commercial driver’s license holders with a passenger-carrying or school bus endorsement, while driving under the authority of that endorsement, except in emergencies.
Original recommendation transmittal letter: PDF
Overall Status: Open - Await Response
Mode: Highway
Location: Alexandria, VA, United States
Is Reiterated: No
Is Hazmat: No
Is NPRM: No
Accident #: hwy05mh008
Accident Reports: Motorcoach Collision With the Alexandria Avenue Bridge Overpass George Washington Memorial Parkway
Report #: HAR-06-04
Accident Date: 11/14/2004
Issue Date: 11/30/2006
Date Closed:
Addressee(s) and Addressee Status: Amalgamated Transit Union (Open - Await Response)
American Bus Association (Open - Await Response)
American Public Transportation Association (Closed - Acceptable Action)
Community Transportation Association of America (Closed - Unacceptable Action - No Response Received)
International Brotherhood of Teamsters (Open - Await Response)
National Association for Pupil Transportation (Closed - Acceptable Action)
National Association of State Directors of Pupil Transportation Services (Open - Await Response)
National School Transportation Association (Closed - Acceptable Action)
United Motorcoach Association (Open Acceptable Alternate Response)
Keyword(s): Distraction

Safety Recommendation History
From: NTSB
To: National Association of State Directors of Pupil Transportation Services
Date: 2/13/2014
Response: CC# 201301266- ANPRM Response to Federal Transit Administration: ANPRM - The National Public Transportation Safety Plan, the Public Transportation Agency Safety Plan, and the Public Transportation Safety Certification Training Program; Transit Asset Management: Although the introduction of the ANPRM states that FTA “intends to focus its initial oversight and enforcement efforts on rail transit systems’ implementation of and compliance with these requirements,” the NTSB would like to provide some additional comments with regard to transit bus safety for FTA’s future planning purposes. As was noted in the ANPRM, the NTSB held an investigative hearing on transit bus safety in March 1998, investigated several transit bus accidents, and issued a Special Investigation Report titled Transit Bus Oversight. The report noted that FTA was unable to identify conditions on buses for the traveling public or resolve any unsafe conditions due to a lack of effective safety oversight and enforcement. In addition, the NTSB questioned the utility of the safety data that was being collected on transit bus safety. Finally, the NTSB was concerned that, at the time, a comprehensive bus safety program was not available to transit agencies outside of APTA’s membership program. Based on the findings of the investigation, the NTSB issued the following safety recommendations to the US Department of Transportation: Develop and implement an oversight program to assess and ensure the safety of transit bus operations that receive Federal funding. (H-98-43) Collect accurate, timely, and sufficient data so that thorough assessments can be made relating to transit bus safety. (H-98-44) Evaluate the collected data, as part of the oversight program, to identify the underlying causes of transit bus accidents that could lead to the identification of safety deficiencies at transit agencies. (H-98-45) Develop, in cooperation with the American Public Transit Association, the Community Transportation Association of America, and the American Association of State Highway and Transportation Officials, a model comprehensive safety program(s) and provide it to all transit agencies. (H-98-46) In response, the FTA-sponsored outreach and research efforts to develop a model program for transit bus safety and security. Subsequently, the recommendations were closed with an acceptable response status by the NTSB. Moving forward, however, these recommendations must not be forgotten as data collection and evaluation is an integral component of any safety management program. It is vital that FTA continue to assess and monitor the safety of transit bus operations, including the collection of accurate, timely, and sufficient data so that thorough assessments can be made relating to transit bus safety. Likewise, it is essential that a program be maintained whereas transit bus accidents are thoroughly investigated to identify the underlying causes of crashes so that safety improvements can be implemented in a timely manner. While the NTSB is encouraged that FTA has developed a well-received bus safety program, we are concerned that the program remains completely voluntary and that FTA is unable to ensure that all bus transit agencies are positively affected. In 2013, the safety of bus operations was highlighted as a safety issue area of concern as part of the NTSB’s Most Wanted List. Over the years, the NTSB has made numerous recommendations to the motorcoach and school bus associations, manufacturers, and regulatory agencies such as the Federal Motor Carrier Safety Administration (FMCSA) and the National Highway Traffic Safety Administration (NHTSA), which the NTSB believes should be considered when establishing a robust oversight program for bus transit operations. These recommendations address safety concerns such as driver distraction, driver fatigue, medical oversight, fire safety, event data recorders, and vehicle safety equipment. FTA should refer to the NTSB safety recommendations database for additional information. The following are examples of some of the NTSB recommendations which should be considered. Driver Distraction • To FMCSA: Prohibit the use of both handheld and hands-free cellular telephones by all commercial driver’s license holders while operating a commercial vehicle, except in emergencies. (H-11-26) • To Motorcoach Industry, Public Bus, and School Bus Associations and Unions: Develop formal policies prohibiting cellular telephone use by commercial driver’s license holders with a passenger-carrying or school bus endorsement, while driving under the authority of that endorsement, except in emergencies. (H-06-29)

From: NTSB
To: Community Transportation Association of America
Date: 2/13/2014
Response: CC# 201301266- ANPRM Response to Federal Transit Administration: ANPRM - The National Public Transportation Safety Plan, the Public Transportation Agency Safety Plan, and the Public Transportation Safety Certification Training Program; Transit Asset Management: Although the introduction of the ANPRM states that FTA “intends to focus its initial oversight and enforcement efforts on rail transit systems’ implementation of and compliance with these requirements,” the NTSB would like to provide some additional comments with regard to transit bus safety for FTA’s future planning purposes. As was noted in the ANPRM, the NTSB held an investigative hearing on transit bus safety in March 1998, investigated several transit bus accidents, and issued a Special Investigation Report titled Transit Bus Oversight. The report noted that FTA was unable to identify conditions on buses for the traveling public or resolve any unsafe conditions due to a lack of effective safety oversight and enforcement. In addition, the NTSB questioned the utility of the safety data that was being collected on transit bus safety. Finally, the NTSB was concerned that, at the time, a comprehensive bus safety program was not available to transit agencies outside of APTA’s membership program. Based on the findings of the investigation, the NTSB issued the following safety recommendations to the US Department of Transportation: Develop and implement an oversight program to assess and ensure the safety of transit bus operations that receive Federal funding. (H-98-43) Collect accurate, timely, and sufficient data so that thorough assessments can be made relating to transit bus safety. (H-98-44) Evaluate the collected data, as part of the oversight program, to identify the underlying causes of transit bus accidents that could lead to the identification of safety deficiencies at transit agencies. (H-98-45) Develop, in cooperation with the American Public Transit Association, the Community Transportation Association of America, and the American Association of State Highway and Transportation Officials, a model comprehensive safety program(s) and provide it to all transit agencies. (H-98-46) In response, the FTA-sponsored outreach and research efforts to develop a model program for transit bus safety and security. Subsequently, the recommendations were closed with an acceptable response status by the NTSB. Moving forward, however, these recommendations must not be forgotten as data collection and evaluation is an integral component of any safety management program. It is vital that FTA continue to assess and monitor the safety of transit bus operations, including the collection of accurate, timely, and sufficient data so that thorough assessments can be made relating to transit bus safety. Likewise, it is essential that a program be maintained whereas transit bus accidents are thoroughly investigated to identify the underlying causes of crashes so that safety improvements can be implemented in a timely manner. While the NTSB is encouraged that FTA has developed a well-received bus safety program, we are concerned that the program remains completely voluntary and that FTA is unable to ensure that all bus transit agencies are positively affected. In 2013, the safety of bus operations was highlighted as a safety issue area of concern as part of the NTSB’s Most Wanted List. Over the years, the NTSB has made numerous recommendations to the motorcoach and school bus associations, manufacturers, and regulatory agencies such as the Federal Motor Carrier Safety Administration (FMCSA) and the National Highway Traffic Safety Administration (NHTSA), which the NTSB believes should be considered when establishing a robust oversight program for bus transit operations. These recommendations address safety concerns such as driver distraction, driver fatigue, medical oversight, fire safety, event data recorders, and vehicle safety equipment. FTA should refer to the NTSB safety recommendations database for additional information. The following are examples of some of the NTSB recommendations which should be considered. Driver Distraction • To FMCSA: Prohibit the use of both handheld and hands-free cellular telephones by all commercial driver’s license holders while operating a commercial vehicle, except in emergencies. (H-11-26) • To Motorcoach Industry, Public Bus, and School Bus Associations and Unions: Develop formal policies prohibiting cellular telephone use by commercial driver’s license holders with a passenger-carrying or school bus endorsement, while driving under the authority of that endorsement, except in emergencies. (H-06-29)

From: NTSB
To: Community Transportation Association of America
Date: 4/24/2012
Response: Notation 8403: The National Transportation Safety Board (NTSB) has reviewed the National Highway Traffic Safety Administration (NHTSA) notice of proposed federal guidelines, "Visual-Manual NHTSA Driver Distraction Guidelines for In-Vehicle Electronic Devices" (proposed guidelines), which was published at 77 Federal Register 11200 (February 24, 2012). The nonbinding, voluntary guidelines represent one component of NHTSA's Driver Distraction Program, and are a useful step toward addressing the problem of driver distraction. Specifically, NHTSA is proposing a long-term, phased approach, through the issuance of guidelines to address the distraction potential of in-vehicle and portable electronic devices (PED). This initial proposal only addresses guidelines for the first of three planned phases and concerns the visual-manual interface of devices installed in vehicles as original equipment. The second phase will include PEDs and aftermarket devices, and the third phase will expand the guidelines to include auditory-vocal interfaces. The NTSB supports NHTSA's efforts to promote attentive driving but is concerned about the rapid migration of potentially distracting navigation, communications, and information and entertainment systems into vehicles. Issuing guidelines is one important step of many necessary to ensure appropriate safety oversight of the design and use of in-vehicle systems, aftermarket devices, and PEDs-which can distract drivers from the critical task of safely operating a motor vehicle. The following are suggestions for NHTSA to maximize the effectiveness of these guidelines. They discuss NHTSA's underemphasis of the cognitive component of operating in-vehicle information systems, the need to record data about in-vehicle communication system use in the event of crashes, the importance of moving quickly toward requiring collision avoidance technologies on all vehicles, and the need to evaluate in-vehicle technologies in large commercial vehicles. Background On March 27, 2012, the NTSB hosted a forum on Attentive Driving: Countermeasures for Distraction that examined countermeasures to mitigate distracted driving behaviors. Forum panelists discussed the findings of distracted driver research, distracted driving laws and enforcement, changing attitudes and behaviors through education and outreach, and technology and design countermeasures. The forum was the culmination of a decade of accident investigations involving distractions in all modes of transportation. The following paragraphs summarize NTSB highway investigations that have resulted in recommendations to reduce driver-distraction-related accidents and fatalities. On August 5, 2010, a highway accident occurred in Gray Summit, Missouri, I in which a pickup truck, whose driver was engaged in texting, rear-ended the back of a tractor and set off a series of collisions that killed two people. On December 13, 2011, as a result of its investigation of the accident, the NTSB called on the 50 states and the District of Columbia to ban the nonemergency use of PEDs while driving (other than those devices designed to support the driving task) for all drivers. The safety recommendation also urged the use of targeted education and enforcement campaigns to support these bans. Also in 2010, near Munfordville, Kentucky,2 a truck-tractor in combination with a 53-foot-Iong trailer left its lane, crossed the median, and collided with a IS-passenger van, resulting in 11 fatalities. The truck driver failed to maintain control of his vehicle because he was distracted by use of his cell phone. As a result of this and previous investigations, the NTSB issued a recommendation that all holders of commercial driver's licenses (CDL) be prohibited from using both hand-held and hands-free cell phones while operating a commercial vehicle, except in emergencies. In 2004, an experienced motorcoach driver failed to move to the center lane and struck the underside of an arched stone bridge on the George Washington Parkway in Alexandria, Virginia. Eleven of the 27 high school students on the bus were injured. The NTSB determined that the probable cause of this accident was the bus driver's failure to notice and respond to posted low-clearance warning signs and to the bridge itself due to cognitive distraction resulting from a hands-free cell phone conversation while driving. The NTSB issued a recommendation that the 50 states and the District of Columbia ban cell phone use by commercial drivers with school bus or passenger endorsements, except in emergencies. In 2002, a novice driver, distracted by a cell phone conversation, crossed the highway median near Largo, Maryland, flipped over, and landed on a minivan, killing five persons. As a result of this investigation, the NTSB issued a recommendation that the 50 states and the District of Columbia prohibit novice drivers from using interactive wireless communication devices while driving. Across all modes of transportation, the NTSB has issued 18 recommendations calling for the prohibition of PED use by aviators, railroaders, mariners, young drivers, and bus and truck drivers. Although the NTSB has not made any specific recommendations on driver distraction related to in-vehicle navigation, communications, or information and entertainment systems, the emergence of new in-vehicle technologies not related to the driving task is of significant concern and should be closely monitored to detect potential adverse effects upon driving performance. Maximizing the Effectiveness of Voluntary Guidelines NHTSA provides a detailed explanation of why it is proposing voluntary guidelines rather than mandatory Federal Motor Vehicle Safety Standards. The NTSB appreciates that the rapid pace of technology evolution cam10t be fully addressed with a static rule. One advantage of guidelines over safety standards is that they present the opportunity to set performance criteria above a minimum acceptable level and do so more quickly than standards would, given the time required for rulemaking. The proposed guidelines are somewhat stronger than current industry guidelines, but NHTSA should set the safety bar even higher. The NTSB urges NHTSA to go beyond its stated expectation of "interfaces that do not exceed a reasonable level of complexity for visual-manual secondary tasks" and strive for more than "discouraging the introduction of egregiously distracting non-driving tasks performed using integrated devices." Instead, NHTSA should be promoting integrated devices that provide a safety benefit, or that at least do not increase the risk in any measureable way. In the absence of a regulatory requirement for in-vehicle information system design, consumers need a method to determine whether a vehicle has a safe design, and manufacturers need incentives to demonstrate that they are meeting or exceeding the guidelines. One such mechanism would be to create a safety marketplace in which automakers compete to provide safer vehicles that meet or exceed the proposed guidelines, as NHTSA has been doing for more than three decades with its New Car Assessment Program (NCAP) five-star safety rating system. Beginning with model year 2011, NHTSA has provided more information about vehicles, indicating whether rated vehicles are equipped with electronic stability control, lane departure warning, and forward collision warning systems. As soon as the proposed Driver Distraction Guidelines are adopted, NHTSA should immediately add to its NCAP information a notice of whether a new car complies with the guidelines and also note those vehicles that do not comply. As NHTSA develops a better understanding of driver distraction and the means to evaluate the effects of in-vehicle systems on driving safety, it should consider developing a more refined rating system akin to NCAP's crashworthiness rating system that considers in-vehicle information systems. Furthermore, NHTSA's experience with evaluating in-vehicle information systems for the purpose of ratings will improve its ability to determine the effectiveness and sufficiency of the guidelines. Phased Approach to Driver Distraction Guidelines NHTSA intends to release the guidelines in three phases. The first phase will explore the visual-manual interfaces of devices installed in vehicles. The second phase will include portable and aftermarket devices, and the third phase will include auditory-vocal interfaces. Although it is understood that NHTSA intends to develop guidelines for aftermarket and PED interfaces immediately following completion of the first phase, it is essential to minimize the delay between phases to avoid (1) migration to systems that are not designed for the driving environment and (2) reliance on voice-based in-vehicle systems with flawed designs that may increase the cognitive distraction of drivers. Specifically, the NTSB is concerned that drivers may increase their use of PEDs due to the restrictions being placed on in-vehicle systems in phase one. Although general usability is a strong consideration in the design of some PEDs, the safety of their use as a secondary task to driving is not a factor in their design. Additionally, automotive and device manufacturers are adding greater connectivity for drivers, and in-vehicle information systems increasingly rely on voice activation. A release of guidelines in 2014 will not address nl0del year 2015 vehicles, further exacerbating the problem that first-generation auditory-vocal interfaces will be in widespread use in on-road vehicles without the benefit of design guidelines. Given the current deployment of in-vehicle computing with voice commands and synthetic speech, NHTSA needs to expedite the roll out of phases two and three. Underemphasis on Cognitive Distraction The NTSB is concerned that the NHTSA Driver Distraction Program is based on the assumption that the primary risk associated with in-vehicle PED use by drivers is visual-manual interaction. It is essential to understand the cognitive demands associated with secondary tasks, particularly auditory-vocal communication tasks, in the context of in-vehicle information and communication devices. As evidenced by the work of panelists attending the recent NTSB forum on countermeasures to distraction, numerous studies have shown that driver distraction occurs during both handheld and hands-free cell phone conversations. 8 NHTSA acknowledges that there is a large amount of research on the topic of driver distraction, yet the guidelines appear to focus on naturalistic driving studies. Particularly, this notice refers to naturalistic driving research that reports that engaging in hands-free phone conversations while driving is safe and provides a protective effect. This finding, from the commercial vehicle naturalistic study, is but one piece of an overall body of research and should be considered within the context of its limitations. Although naturalistic studies provide extremely strong evidence for distraction involving driver behaviors such as visual or manual activities, naturalistic studies, given their dependence on video data, cannot fully assess the cognitive demands associated with hands-free secondary tasks. The measurement of cognitive distraction that does not result in drivers taking their eyes off the road is essential. Both driver performance and brain activity should be assessed to better understand cognitive load. The NTSB findings from its investigation of the 2004 Alexandria, Virginia, motorcoach accident involving the driver's use of a hands-free cell phone are consistent with research showing that drivers conversing on a cell phone-whether handheld or hands-free-are cognitively distracted from the driving task. Need for Improved Event Data The NTSB agrees with NHTSA that efforts are needed to improve the validity and reliability of distracted driving data and believes that such data are necessary both to track the magnitude of distracted driving as a risk factor in accidents and to assess the efficacy of countermeasures. In its notice, NHTSA explains that identifying specific distracting activities and behaviors has presented challenges, partly because police reports may list "other distraction" or "distraction unknown" rather than identifying a specific distraction source, and partly because police may not have enough information to recognize the contribution of distraction to an accident. The NTSB supports NHTSA's ongoing modifications to the Model Minimal Uniform Crash Criteria (MMUCC), which may better capture and classify crashes related to distraction. The proposed 4th edition of the MMUCC currently does not have a specific code to distinguish in-vehicle electronics from PEDs. As integrated devices for navigation, communication, and information and entertainment continue to proliferate in the vehicle fleet, it is critical for NHTSA and others, such as the NTSB and law enforcement, to be able to determine whether drivers were using such systems immediately before or during a crash. Consequently, NHTSA should require manufacturers to include a recording capability in their in-vehicle and integrated systems, such as exists in some vehicles already on the market, to facilitate accident investigation and safety research. NHTSA recognized the value of recording vehicle data in its 2006 rulemaking on vehicle event data recorders (EDR) when it said, "EDR data can provide information to enhance our understanding of crash events and safety system performance, thereby potentially contributing to safer vehicle designs and more effective safety regulations. Crash Avoidance Technologies The proposed guidelines also cite the April 2010 "Overview of the National Highway Traffic Safety Administration's Driver Distraction Program," which summarized steps that NHTSA intends to take "to help eliminate crashes attributable to driver distraction." One of the four initiatives discussed in the program involves keeping drivers safe through the introduction of crash warning or crash avoidance technologies. The NTSB strongly agrees that such systems can prevent or mitigate accidents; and, for more than a decade, we have made recommendations advocating technological solutions to reduce or mitigate collisions for both passenger and commercial vehicles. A large body of evidence now shows that collision warning, lane departure warning, and automatic braking systems are effective, based on research sponsored by the U.S. Department of Transportation, automobile manufacturers, the Insurance Institute for Highway Safety, and other organizations. These systems address driver inattentiveness from all potential sources of distraction, including PEDs. Scope of Guidelines According to the notice, because NHTSA's research focus to date has been on light vehicles, the proposed guidelines are limited to passenger cars, multipurpose passenger vehicles, and trucks and buses with a gross vehicle weight rating of not more than 10,000 pounds. However, considering the significance of large commercial vehicles in overall crash and fatality rates, and given the increasing availability and use of electronic logs, global positioning system, and other potentially distracting systems in these vehicles, the NTSB encourages NHTSA, with the Federal Motor Carrier Safety Administration, to monitor the introduction of in-vehicle technology and aftermarket technology into medium trucks, heavy trucks, and buses, including motorcoaches, and to conduct research as appropriate. Conclusion The NTSB is pleased that NHTSA is moving forward with providing visual-manual guidance to manufacturers, but we view this phased approach as a limited effort, given the varied nature of driver distraction and new car market indications of future in-vehicle information system designs. The NTSB has concerns about the voluntary nature of the guidelines and believes that NHTSA's Distracted Driver Program underemphasizes the role of cognitive distraction. The NTSB also has made safety recommendations concerning crash avoidance technology. We are encouraged to see that NHTSA has included standards for these systems in the NCAP program that, in tum, provide an incentive for vehicle manufacturers to incorporate these technologies in new vehicles. We continue to believe that much could be gained by acquiring data on the use of in-vehicle systems prior to accidents, and we are interested in learning more about NHTSA's plans for evaluating the effects of in-vehicle, aftermarket, and portable systems in all vehicles. Thank you for this opportunity to comment on the proposed guidelines.

From: NTSB
To: Community Transportation Association of America
Date: 4/2/2010
Response: NMC# 103358: Safety Recommendation H-06-29 was issued to the CTAA on November 30, 2006, as a result of the NTSB’s investigation of a motorcoach collision with the Alexandria Avenue Bridge Overpass on the George Washington Memorial Parkway in Alexandria, Virginia, on November 14, 2004. The NTSB has not received your response to this recommendation. The NTSB determined that the probable cause of the Alexandria accident was the bus driver’s failure to notice and respond to posted low-clearance warning signs and to the bridge itself because of the cognitive distraction of conversing on a hands-free cellular telephone while driving. Because payment for transportation services creates an implicit contract between the passenger and the carrier that the carrier will transport the passenger safely and not allow the vehicle operator to take unnecessary risks, CDL drivers have a special obligation to provide the safest driving environment possible for the passengers in their care. The NTSB remains concerned that the use of either a hand-held or hands-free cellular telephone while driving can impair the performance of a CDL holder and believes that the motorcoach industry, public and school bus associations, and unions should develop policies to address cellular telephone use while driving. As we previously stated in our March 10, 2008, correspondence regarding these recommendations, because of the CTAA’s lack of response on Safety Recommendation H-06-29, this recommendation is classified CLOSED UNACCEPTABLE ACTION/ NO RESPONSE RECEIEVED.

From: NTSB
To: Community Transportation Association of America
Date: 3/10/2008
Response: NMC# 103170: Again, the Safety Board has not received a response to this recommendation. The Board is interested in knowing whether and how its recommendations are implemented, both to ensure that the public is provided the highest level of safety and to identify creative solutions that might be shared with others. That is why we monitor the implementation of all our recommendations. We would appreciate receiving an update from you regarding actions taken or planned to implement this recommendation. When responding, please refer to the recommendations by number. Copies of the letters transmitting these recommendations are enclosed for your reference. In addition, the full reports of both the Normandy, Missouri, and Alexandria, Virginia, accidents are available electronically on our Web site: http://www.ntsb.gov/Publictn/H_Acc.htm. Thank you for your assistance. If you require further information regarding Safety Recommendations H-98-6, H-98-7, or H-06-29, please contact Ms. Julie Perrot, Highway Safety Specialist, Office of Safety Recommendations and Advocacy, at (202) 314-6180, or by e-mail at Julie.perrot@ntsb.gov.

From: NTSB
To: American Bus Association
Date: 2/13/2014
Response: CC# 201301266- ANPRM Response to Federal Transit Administration: ANPRM - The National Public Transportation Safety Plan, the Public Transportation Agency Safety Plan, and the Public Transportation Safety Certification Training Program; Transit Asset Management: Although the introduction of the ANPRM states that FTA “intends to focus its initial oversight and enforcement efforts on rail transit systems’ implementation of and compliance with these requirements,” the NTSB would like to provide some additional comments with regard to transit bus safety for FTA’s future planning purposes. As was noted in the ANPRM, the NTSB held an investigative hearing on transit bus safety in March 1998, investigated several transit bus accidents, and issued a Special Investigation Report titled Transit Bus Oversight. The report noted that FTA was unable to identify conditions on buses for the traveling public or resolve any unsafe conditions due to a lack of effective safety oversight and enforcement. In addition, the NTSB questioned the utility of the safety data that was being collected on transit bus safety. Finally, the NTSB was concerned that, at the time, a comprehensive bus safety program was not available to transit agencies outside of APTA’s membership program. Based on the findings of the investigation, the NTSB issued the following safety recommendations to the US Department of Transportation: Develop and implement an oversight program to assess and ensure the safety of transit bus operations that receive Federal funding. (H-98-43) Collect accurate, timely, and sufficient data so that thorough assessments can be made relating to transit bus safety. (H-98-44) Evaluate the collected data, as part of the oversight program, to identify the underlying causes of transit bus accidents that could lead to the identification of safety deficiencies at transit agencies. (H-98-45) Develop, in cooperation with the American Public Transit Association, the Community Transportation Association of America, and the American Association of State Highway and Transportation Officials, a model comprehensive safety program(s) and provide it to all transit agencies. (H-98-46) In response, the FTA-sponsored outreach and research efforts to develop a model program for transit bus safety and security. Subsequently, the recommendations were closed with an acceptable response status by the NTSB. Moving forward, however, these recommendations must not be forgotten as data collection and evaluation is an integral component of any safety management program. It is vital that FTA continue to assess and monitor the safety of transit bus operations, including the collection of accurate, timely, and sufficient data so that thorough assessments can be made relating to transit bus safety. Likewise, it is essential that a program be maintained whereas transit bus accidents are thoroughly investigated to identify the underlying causes of crashes so that safety improvements can be implemented in a timely manner. While the NTSB is encouraged that FTA has developed a well-received bus safety program, we are concerned that the program remains completely voluntary and that FTA is unable to ensure that all bus transit agencies are positively affected. In 2013, the safety of bus operations was highlighted as a safety issue area of concern as part of the NTSB’s Most Wanted List. Over the years, the NTSB has made numerous recommendations to the motorcoach and school bus associations, manufacturers, and regulatory agencies such as the Federal Motor Carrier Safety Administration (FMCSA) and the National Highway Traffic Safety Administration (NHTSA), which the NTSB believes should be considered when establishing a robust oversight program for bus transit operations. These recommendations address safety concerns such as driver distraction, driver fatigue, medical oversight, fire safety, event data recorders, and vehicle safety equipment. FTA should refer to the NTSB safety recommendations database for additional information. The following are examples of some of the NTSB recommendations which should be considered. Driver Distraction • To FMCSA: Prohibit the use of both handheld and hands-free cellular telephones by all commercial driver’s license holders while operating a commercial vehicle, except in emergencies. (H-11-26) • To Motorcoach Industry, Public Bus, and School Bus Associations and Unions: Develop formal policies prohibiting cellular telephone use by commercial driver’s license holders with a passenger-carrying or school bus endorsement, while driving under the authority of that endorsement, except in emergencies. (H-06-29)

From: NTSB
To: American Bus Association
Date: 11/21/2013
Response: Because we have never received a response from the ABA regarding this recommendation, it has been classified OPEN—AWAIT RESPONSE since its issuance. We are interested in knowing whether and how our recommendations are implemented, both to ensure that the traveling public is provided the highest level of safety and to identify creative solutions that might be shared with others. Therefore, please inform us about the status of the ABA’s actions to implement Safety Recommendations H 06 29, H 07 12 through 14, H 09 9, H 12 28, and H 12 67.

From: NTSB
To: National School Transportation Association
Date: 2/13/2014
Response: CC# 201301266- ANPRM Response to Federal Transit Administration: ANPRM - The National Public Transportation Safety Plan, the Public Transportation Agency Safety Plan, and the Public Transportation Safety Certification Training Program; Transit Asset Management: Although the introduction of the ANPRM states that FTA “intends to focus its initial oversight and enforcement efforts on rail transit systems’ implementation of and compliance with these requirements,” the NTSB would like to provide some additional comments with regard to transit bus safety for FTA’s future planning purposes. As was noted in the ANPRM, the NTSB held an investigative hearing on transit bus safety in March 1998, investigated several transit bus accidents, and issued a Special Investigation Report titled Transit Bus Oversight. The report noted that FTA was unable to identify conditions on buses for the traveling public or resolve any unsafe conditions due to a lack of effective safety oversight and enforcement. In addition, the NTSB questioned the utility of the safety data that was being collected on transit bus safety. Finally, the NTSB was concerned that, at the time, a comprehensive bus safety program was not available to transit agencies outside of APTA’s membership program. Based on the findings of the investigation, the NTSB issued the following safety recommendations to the US Department of Transportation: Develop and implement an oversight program to assess and ensure the safety of transit bus operations that receive Federal funding. (H-98-43) Collect accurate, timely, and sufficient data so that thorough assessments can be made relating to transit bus safety. (H-98-44) Evaluate the collected data, as part of the oversight program, to identify the underlying causes of transit bus accidents that could lead to the identification of safety deficiencies at transit agencies. (H-98-45) Develop, in cooperation with the American Public Transit Association, the Community Transportation Association of America, and the American Association of State Highway and Transportation Officials, a model comprehensive safety program(s) and provide it to all transit agencies. (H-98-46) In response, the FTA-sponsored outreach and research efforts to develop a model program for transit bus safety and security. Subsequently, the recommendations were closed with an acceptable response status by the NTSB. Moving forward, however, these recommendations must not be forgotten as data collection and evaluation is an integral component of any safety management program. It is vital that FTA continue to assess and monitor the safety of transit bus operations, including the collection of accurate, timely, and sufficient data so that thorough assessments can be made relating to transit bus safety. Likewise, it is essential that a program be maintained whereas transit bus accidents are thoroughly investigated to identify the underlying causes of crashes so that safety improvements can be implemented in a timely manner. While the NTSB is encouraged that FTA has developed a well-received bus safety program, we are concerned that the program remains completely voluntary and that FTA is unable to ensure that all bus transit agencies are positively affected. In 2013, the safety of bus operations was highlighted as a safety issue area of concern as part of the NTSB’s Most Wanted List. Over the years, the NTSB has made numerous recommendations to the motorcoach and school bus associations, manufacturers, and regulatory agencies such as the Federal Motor Carrier Safety Administration (FMCSA) and the National Highway Traffic Safety Administration (NHTSA), which the NTSB believes should be considered when establishing a robust oversight program for bus transit operations. These recommendations address safety concerns such as driver distraction, driver fatigue, medical oversight, fire safety, event data recorders, and vehicle safety equipment. FTA should refer to the NTSB safety recommendations database for additional information. The following are examples of some of the NTSB recommendations which should be considered. Driver Distraction • To FMCSA: Prohibit the use of both handheld and hands-free cellular telephones by all commercial driver’s license holders while operating a commercial vehicle, except in emergencies. (H-11-26) • To Motorcoach Industry, Public Bus, and School Bus Associations and Unions: Develop formal policies prohibiting cellular telephone use by commercial driver’s license holders with a passenger-carrying or school bus endorsement, while driving under the authority of that endorsement, except in emergencies. (H-06-29)

From: NTSB
To: National School Transportation Association
Date: 4/24/2012
Response: Notation 8403: The National Transportation Safety Board (NTSB) has reviewed the National Highway Traffic Safety Administration (NHTSA) notice of proposed federal guidelines, "Visual-Manual NHTSA Driver Distraction Guidelines for In-Vehicle Electronic Devices" (proposed guidelines), which was published at 77 Federal Register 11200 (February 24, 2012). The nonbinding, voluntary guidelines represent one component of NHTSA's Driver Distraction Program, and are a useful step toward addressing the problem of driver distraction. Specifically, NHTSA is proposing a long-term, phased approach, through the issuance of guidelines to address the distraction potential of in-vehicle and portable electronic devices (PED). This initial proposal only addresses guidelines for the first of three planned phases and concerns the visual-manual interface of devices installed in vehicles as original equipment. The second phase will include PEDs and aftermarket devices, and the third phase will expand the guidelines to include auditory-vocal interfaces. The NTSB supports NHTSA's efforts to promote attentive driving but is concerned about the rapid migration of potentially distracting navigation, communications, and information and entertainment systems into vehicles. Issuing guidelines is one important step of many necessary to ensure appropriate safety oversight of the design and use of in-vehicle systems, aftermarket devices, and PEDs-which can distract drivers from the critical task of safely operating a motor vehicle. The following are suggestions for NHTSA to maximize the effectiveness of these guidelines. They discuss NHTSA's underemphasis of the cognitive component of operating in-vehicle information systems, the need to record data about in-vehicle communication system use in the event of crashes, the importance of moving quickly toward requiring collision avoidance technologies on all vehicles, and the need to evaluate in-vehicle technologies in large commercial vehicles. Background On March 27, 2012, the NTSB hosted a forum on Attentive Driving: Countermeasures for Distraction that examined countermeasures to mitigate distracted driving behaviors. Forum panelists discussed the findings of distracted driver research, distracted driving laws and enforcement, changing attitudes and behaviors through education and outreach, and technology and design countermeasures. The forum was the culmination of a decade of accident investigations involving distractions in all modes of transportation. The following paragraphs summarize NTSB highway investigations that have resulted in recommendations to reduce driver-distraction-related accidents and fatalities. On August 5, 2010, a highway accident occurred in Gray Summit, Missouri, I in which a pickup truck, whose driver was engaged in texting, rear-ended the back of a tractor and set off a series of collisions that killed two people. On December 13, 2011, as a result of its investigation of the accident, the NTSB called on the 50 states and the District of Columbia to ban the nonemergency use of PEDs while driving (other than those devices designed to support the driving task) for all drivers. The safety recommendation also urged the use of targeted education and enforcement campaigns to support these bans. Also in 2010, near Munfordville, Kentucky,2 a truck-tractor in combination with a 53-foot-Iong trailer left its lane, crossed the median, and collided with a IS-passenger van, resulting in 11 fatalities. The truck driver failed to maintain control of his vehicle because he was distracted by use of his cell phone. As a result of this and previous investigations, the NTSB issued a recommendation that all holders of commercial driver's licenses (CDL) be prohibited from using both hand-held and hands-free cell phones while operating a commercial vehicle, except in emergencies. In 2004, an experienced motorcoach driver failed to move to the center lane and struck the underside of an arched stone bridge on the George Washington Parkway in Alexandria, Virginia. Eleven of the 27 high school students on the bus were injured. The NTSB determined that the probable cause of this accident was the bus driver's failure to notice and respond to posted low-clearance warning signs and to the bridge itself due to cognitive distraction resulting from a hands-free cell phone conversation while driving. The NTSB issued a recommendation that the 50 states and the District of Columbia ban cell phone use by commercial drivers with school bus or passenger endorsements, except in emergencies. In 2002, a novice driver, distracted by a cell phone conversation, crossed the highway median near Largo, Maryland, flipped over, and landed on a minivan, killing five persons. As a result of this investigation, the NTSB issued a recommendation that the 50 states and the District of Columbia prohibit novice drivers from using interactive wireless communication devices while driving. Across all modes of transportation, the NTSB has issued 18 recommendations calling for the prohibition of PED use by aviators, railroaders, mariners, young drivers, and bus and truck drivers. Although the NTSB has not made any specific recommendations on driver distraction related to in-vehicle navigation, communications, or information and entertainment systems, the emergence of new in-vehicle technologies not related to the driving task is of significant concern and should be closely monitored to detect potential adverse effects upon driving performance. Maximizing the Effectiveness of Voluntary Guidelines NHTSA provides a detailed explanation of why it is proposing voluntary guidelines rather than mandatory Federal Motor Vehicle Safety Standards. The NTSB appreciates that the rapid pace of technology evolution cam10t be fully addressed with a static rule. One advantage of guidelines over safety standards is that they present the opportunity to set performance criteria above a minimum acceptable level and do so more quickly than standards would, given the time required for rulemaking. The proposed guidelines are somewhat stronger than current industry guidelines, but NHTSA should set the safety bar even higher. The NTSB urges NHTSA to go beyond its stated expectation of "interfaces that do not exceed a reasonable level of complexity for visual-manual secondary tasks" and strive for more than "discouraging the introduction of egregiously distracting non-driving tasks performed using integrated devices." Instead, NHTSA should be promoting integrated devices that provide a safety benefit, or that at least do not increase the risk in any measureable way. In the absence of a regulatory requirement for in-vehicle information system design, consumers need a method to determine whether a vehicle has a safe design, and manufacturers need incentives to demonstrate that they are meeting or exceeding the guidelines. One such mechanism would be to create a safety marketplace in which automakers compete to provide safer vehicles that meet or exceed the proposed guidelines, as NHTSA has been doing for more than three decades with its New Car Assessment Program (NCAP) five-star safety rating system. Beginning with model year 2011, NHTSA has provided more information about vehicles, indicating whether rated vehicles are equipped with electronic stability control, lane departure warning, and forward collision warning systems. As soon as the proposed Driver Distraction Guidelines are adopted, NHTSA should immediately add to its NCAP information a notice of whether a new car complies with the guidelines and also note those vehicles that do not comply. As NHTSA develops a better understanding of driver distraction and the means to evaluate the effects of in-vehicle systems on driving safety, it should consider developing a more refined rating system akin to NCAP's crashworthiness rating system that considers in-vehicle information systems. Furthermore, NHTSA's experience with evaluating in-vehicle information systems for the purpose of ratings will improve its ability to determine the effectiveness and sufficiency of the guidelines. Phased Approach to Driver Distraction Guidelines NHTSA intends to release the guidelines in three phases. The first phase will explore the visual-manual interfaces of devices installed in vehicles. The second phase will include portable and aftermarket devices, and the third phase will include auditory-vocal interfaces. Although it is understood that NHTSA intends to develop guidelines for aftermarket and PED interfaces immediately following completion of the first phase, it is essential to minimize the delay between phases to avoid (1) migration to systems that are not designed for the driving environment and (2) reliance on voice-based in-vehicle systems with flawed designs that may increase the cognitive distraction of drivers. Specifically, the NTSB is concerned that drivers may increase their use of PEDs due to the restrictions being placed on in-vehicle systems in phase one. Although general usability is a strong consideration in the design of some PEDs, the safety of their use as a secondary task to driving is not a factor in their design. Additionally, automotive and device manufacturers are adding greater connectivity for drivers, and in-vehicle information systems increasingly rely on voice activation. A release of guidelines in 2014 will not address nl0del year 2015 vehicles, further exacerbating the problem that first-generation auditory-vocal interfaces will be in widespread use in on-road vehicles without the benefit of design guidelines. Given the current deployment of in-vehicle computing with voice commands and synthetic speech, NHTSA needs to expedite the roll out of phases two and three. Underemphasis on Cognitive Distraction The NTSB is concerned that the NHTSA Driver Distraction Program is based on the assumption that the primary risk associated with in-vehicle PED use by drivers is visual-manual interaction. It is essential to understand the cognitive demands associated with secondary tasks, particularly auditory-vocal communication tasks, in the context of in-vehicle information and communication devices. As evidenced by the work of panelists attending the recent NTSB forum on countermeasures to distraction, numerous studies have shown that driver distraction occurs during both handheld and hands-free cell phone conversations. 8 NHTSA acknowledges that there is a large amount of research on the topic of driver distraction, yet the guidelines appear to focus on naturalistic driving studies. Particularly, this notice refers to naturalistic driving research that reports that engaging in hands-free phone conversations while driving is safe and provides a protective effect. This finding, from the commercial vehicle naturalistic study, is but one piece of an overall body of research and should be considered within the context of its limitations. Although naturalistic studies provide extremely strong evidence for distraction involving driver behaviors such as visual or manual activities, naturalistic studies, given their dependence on video data, cannot fully assess the cognitive demands associated with hands-free secondary tasks. The measurement of cognitive distraction that does not result in drivers taking their eyes off the road is essential. Both driver performance and brain activity should be assessed to better understand cognitive load. The NTSB findings from its investigation of the 2004 Alexandria, Virginia, motorcoach accident involving the driver's use of a hands-free cell phone are consistent with research showing that drivers conversing on a cell phone-whether handheld or hands-free-are cognitively distracted from the driving task. Need for Improved Event Data The NTSB agrees with NHTSA that efforts are needed to improve the validity and reliability of distracted driving data and believes that such data are necessary both to track the magnitude of distracted driving as a risk factor in accidents and to assess the efficacy of countermeasures. In its notice, NHTSA explains that identifying specific distracting activities and behaviors has presented challenges, partly because police reports may list "other distraction" or "distraction unknown" rather than identifying a specific distraction source, and partly because police may not have enough information to recognize the contribution of distraction to an accident. The NTSB supports NHTSA's ongoing modifications to the Model Minimal Uniform Crash Criteria (MMUCC), which may better capture and classify crashes related to distraction. The proposed 4th edition of the MMUCC currently does not have a specific code to distinguish in-vehicle electronics from PEDs. As integrated devices for navigation, communication, and information and entertainment continue to proliferate in the vehicle fleet, it is critical for NHTSA and others, such as the NTSB and law enforcement, to be able to determine whether drivers were using such systems immediately before or during a crash. Consequently, NHTSA should require manufacturers to include a recording capability in their in-vehicle and integrated systems, such as exists in some vehicles already on the market, to facilitate accident investigation and safety research. NHTSA recognized the value of recording vehicle data in its 2006 rulemaking on vehicle event data recorders (EDR) when it said, "EDR data can provide information to enhance our understanding of crash events and safety system performance, thereby potentially contributing to safer vehicle designs and more effective safety regulations. Crash Avoidance Technologies The proposed guidelines also cite the April 2010 "Overview of the National Highway Traffic Safety Administration's Driver Distraction Program," which summarized steps that NHTSA intends to take "to help eliminate crashes attributable to driver distraction." One of the four initiatives discussed in the program involves keeping drivers safe through the introduction of crash warning or crash avoidance technologies. The NTSB strongly agrees that such systems can prevent or mitigate accidents; and, for more than a decade, we have made recommendations advocating technological solutions to reduce or mitigate collisions for both passenger and commercial vehicles. A large body of evidence now shows that collision warning, lane departure warning, and automatic braking systems are effective, based on research sponsored by the U.S. Department of Transportation, automobile manufacturers, the Insurance Institute for Highway Safety, and other organizations. These systems address driver inattentiveness from all potential sources of distraction, including PEDs. Scope of Guidelines According to the notice, because NHTSA's research focus to date has been on light vehicles, the proposed guidelines are limited to passenger cars, multipurpose passenger vehicles, and trucks and buses with a gross vehicle weight rating of not more than 10,000 pounds. However, considering the significance of large commercial vehicles in overall crash and fatality rates, and given the increasing availability and use of electronic logs, global positioning system, and other potentially distracting systems in these vehicles, the NTSB encourages NHTSA, with the Federal Motor Carrier Safety Administration, to monitor the introduction of in-vehicle technology and aftermarket technology into medium trucks, heavy trucks, and buses, including motorcoaches, and to conduct research as appropriate. Conclusion The NTSB is pleased that NHTSA is moving forward with providing visual-manual guidance to manufacturers, but we view this phased approach as a limited effort, given the varied nature of driver distraction and new car market indications of future in-vehicle information system designs. The NTSB has concerns about the voluntary nature of the guidelines and believes that NHTSA's Distracted Driver Program underemphasizes the role of cognitive distraction. The NTSB also has made safety recommendations concerning crash avoidance technology. We are encouraged to see that NHTSA has included standards for these systems in the NCAP program that, in tum, provide an incentive for vehicle manufacturers to incorporate these technologies in new vehicles. We continue to believe that much could be gained by acquiring data on the use of in-vehicle systems prior to accidents, and we are interested in learning more about NHTSA's plans for evaluating the effects of in-vehicle, aftermarket, and portable systems in all vehicles. Thank you for this opportunity to comment on the proposed guidelines.

From: NTSB
To: National School Transportation Association
Date: 7/30/2007
Response: The Safety Board notes that NSTA distributed the policy and the Board’s recommendation to its members. In an attempt to reach non-association-member school bus companies, NSTA also provided the policy to national industry trade publications. The Board commends NSTA for its prompt action to adopt this extensive cellular phone-use policy that restricts drivers from using all personal electronic devices during both driving tasks and the supervising of loading and unloading of children. As these actions satisfy the intent of this recommendation, Safety Recommendation H-06-29 is classified CLOSED -- ACCEPTABLE ACTION.

From: National School Transportation Association
To: NTSB
Date: 3/26/2007
Response: Letter Mail Controlled 3/27/2007 10:00:40 AM MC# 2070128: - From Robin L. Leeds, Industry Specialist: On January 31, the Board of Directors of the National School Transportation Association unanimously adopted the enclosed policy in response to your recommendation H-06-29 regarding cell phone use by commercial drivers. As you can see, our policy goes two steps further than your recommendation by restricting the use of all personal electronic devices and by extending the restriction to periods not only when the driver is driving the bus but also when he or she is supervising the loading and unloading of children. We have distributed this policy and recommendation to all the members of NSTA. In an attempt to reach school bus companies who are not association members, we also provided it to the national industry trade publications. Cell Phone Use by School Bus Drivers, Policy adopted by the NSTA Board of Directors, January 31, 2007 The National School Transportation Association agrees with the National Transportation Safety Board that --School bus drivers have a professional duty to direct 100% of their attention to the safe operation of the school bus and the safety of their passengers; --Communicating on a cellular phone or other personal portable electronic device, whether it is hands-on or hands-free, while driving a school bus or supervising the loading and unloading of students distracts drivers from their professional duties; --Research indicates that talking on a cellular phone is related to an increased risk of motor vehicle accidents. Therefore, NSTA recommends that school bus companies adopt the following policy regarding cellular phone use by school bus drivers: Drivers may not use a cell phone or other personal portable electronic device while operating a school bus or any other vehicle transporting students, including while loading and unloading students, except in an emergency. For the purpose of this policy, an emergency exists if the driver requires immediate assistance to ensure the safety of his/her passengers or to report a dangerous or life-threatening situation

From: NTSB
To: National Association for Pupil Transportation
Date: 12/9/2014
Response: We are pleased that you included a statement against distracted driving in your public policy agenda. We note that you support this policy through regular reminders to your members regarding the importance of safe driving practices and the high level of professionalism that the public expects from school bus drivers. Accordingly, Safety Recommendation H-06-29 is classified CLOSED—ACCEPTABLE ACTION.

From: National Association for Pupil Transportation
To: NTSB
Date: 9/29/2014
Response: -From Michael J. Martin, Executive Director: Thank you for your letter dated June 25, 2014 regarding NTSB Safety Recommendations H-06-09, H-09-04 and H-11-48. Because we highly value our relationship with the Board, and want to be responsive to its recommendations, we have for quite some time informed our members of any recommendation we receive from NTSB via our newsletter. Due to an unfortunate internal mishap, we do not have hard copy of our newsletters published prior to May of 2009 but in our electronic newsletters published on September 8 and September 15, 2009, for example, we informed our members of the meeting on September 1, 2009, when "the National Transportation Safety Board (NTSB) met to discuss a report scheduled for imminent release based upon a school bus crash in Liberty, Missouri in 2005. During the course of its investigation, NTSB discovered that pedal misapplication was a probable cause of the accident---that is, depressing the accelerator instead of, or in addition to, the brake pedal. The NTSB subsequently investigated four additional accidents involving heavy vehicles in which pedal misapplication was also determined to be a factor. Those accidents included several school bus and transit bus accidents. We provided a link to the Board's report and encouraged our members and other readers of our newsletter to use the link and read the report. As another example, we published information about the results of your Gray's Summit crash investigation in both our February 7 and February 14, 2012 electronic newsletters. In the latter issue, then Vice Chairman Hart's testimony before the New York State Senate Committee on Transportation on the NTSB's cell-phone ban recommendation was our headline story. On this issue in particular, the NAPT Public Policy Committee spearheaded the drive to make NAPT the first national-level trade association in the pupil transportation field to integrate a statement in our public policy agenda that "school bus drivers should not engage in text messaging or similar activities while operating a school bus." In announcing the move, we said, "Awareness of and action to prevent any form of distracted driving is critical in pupil transportation where there is an especially high public expectation of safety excellence. Driving a school bus requires focused attention and situational awareness at all times. Distraction of any kind could compromise the safety of passengers, children getting on and off the school bus, and other motorists. The use of cell phones or other electronic devices to talk or text while driving is particularly distracting. Many states, school districts and school bus operators already have policies that prohibit cell phone use and texting while driving. NAPT encourages those that do not yet have such policies to mark Distracted Driving Awareness Month by enacting them. Further, we encourage all NAPT members to support national, state and local efforts to deter distracted driving, and remain focused on providing the safest form of ground transportation in America throughout the year." As I'm sure you are aware, the school bus industry is unlike most other public services in the country. It receives no federal funding and all decisions are made in communities and states, and all have different political, cultural and economic factors that impact decision-making. While NAPT as a trade association can communicate information, we must defer to local sensibilities to decide whether or not to adopt them. But since we received your recommendations H-06-29 and H-11-48, we try to include whenever possible some type of article in our electronic newsletter about the dangers of distracted driving and cell phone use behind the wheel. In addition to publicizing NTSB's recommendations and encouraging our members in particular and the industry at large to take notice and pay heed to them, we make it a point of inviting NTSB representatives to our annual conference. We do this not just to round out our program with engaging speakers, but because our conference is the most effective way for the Board to communicate with our industry about its recommendations, investigations and any other matters it deems important. Of all our communications efforts, the face-to-face at our conference is the one that conveys the most immediacy and we know these presentations are both well-received and the information imparted taken back to states and communities. We consider them a conference highlight and always make them keynotes during primetime conference scheduling. We also encourage Board representatives to attend informal sessions for interaction with our members if travel scheduling permits it. I believe former Chairman James Hall was the first NTSB representative I invited to speak at our annual Summit; that was in 1997, shortly after I began working here, when our conference was in Indianapolis. Since then, NAPT has made it a point to invite someone from NTSB to speak at our conference whenever possible; in fact, there is a standing invitation to do so, any time, any place. Over the past three successive years we have been honored by the attendance of then-Chairman Hersman in 2011; and Vice Chairman Hart in 2012 and 2013. We are excited that Acting Chairman Hart will again be with us this year in Kansas City. I want to underscore that we view these visits and presentations not just as "conference speakers." They are critical to our safety culture, and are the ideal opportunity for the Board to let our members know not just about recommendations, and the basis and importance of them, but also summaries of ongoing investigations involving school bus crashes. This is always viewed by our members as some of the most important information they glean at the annual conference. With Acting Chairman Hart speaking in Kansas City on November 10, we would encourage the NTSB staff to include in his remarks the recommendations listed in your letter and why they are important, along with any other new information he wishes to impart. In our view, this is the single best way to get this information to states and communities for their decision-making processes and underscore the Board's view of their importance. I hope this letter provides you with information that demonstrates our respect for NTSB and its recommendations as well as our commitment to working with the Board, and especially its outstanding staff. We look forward to continuing to work with you to promote safety excellence, particularly in school transportation.

From: NTSB
To: National Association for Pupil Transportation
Date: 6/25/2014
Response: Because we have received no response regarding these recommendations, Safety Recommendations H-06-29, H-09-14, and H-11-48 have been classified OPEN—AWAIT RESPONSE since their issuance. We are interested in knowing whether and how our recommendations are implemented, both to ensure that the traveling public is provided the highest level of safety and to identify creative solutions that might be shared with others. Therefore, please inform us about your progress in implementing Safety Recommendations H-06-29, H-09-14, H-11-48, and H-13-35 and -36 preferably electronically at correspondence@ntsb.gov. If a response, including attachments, exceeds 10 megabytes, please e mail us at the same address for instructions. Please do not submit both an electronic copy and a hard copy of the same response.

From: NTSB
To: National Association for Pupil Transportation
Date: 2/13/2014
Response: CC# 201301266- ANPRM Response to Federal Transit Administration: ANPRM - The National Public Transportation Safety Plan, the Public Transportation Agency Safety Plan, and the Public Transportation Safety Certification Training Program; Transit Asset Management: Although the introduction of the ANPRM states that FTA “intends to focus its initial oversight and enforcement efforts on rail transit systems’ implementation of and compliance with these requirements,” the NTSB would like to provide some additional comments with regard to transit bus safety for FTA’s future planning purposes. As was noted in the ANPRM, the NTSB held an investigative hearing on transit bus safety in March 1998, investigated several transit bus accidents, and issued a Special Investigation Report titled Transit Bus Oversight. The report noted that FTA was unable to identify conditions on buses for the traveling public or resolve any unsafe conditions due to a lack of effective safety oversight and enforcement. In addition, the NTSB questioned the utility of the safety data that was being collected on transit bus safety. Finally, the NTSB was concerned that, at the time, a comprehensive bus safety program was not available to transit agencies outside of APTA’s membership program. Based on the findings of the investigation, the NTSB issued the following safety recommendations to the US Department of Transportation: Develop and implement an oversight program to assess and ensure the safety of transit bus operations that receive Federal funding. (H-98-43) Collect accurate, timely, and sufficient data so that thorough assessments can be made relating to transit bus safety. (H-98-44) Evaluate the collected data, as part of the oversight program, to identify the underlying causes of transit bus accidents that could lead to the identification of safety deficiencies at transit agencies. (H-98-45) Develop, in cooperation with the American Public Transit Association, the Community Transportation Association of America, and the American Association of State Highway and Transportation Officials, a model comprehensive safety program(s) and provide it to all transit agencies. (H-98-46) In response, the FTA-sponsored outreach and research efforts to develop a model program for transit bus safety and security. Subsequently, the recommendations were closed with an acceptable response status by the NTSB. Moving forward, however, these recommendations must not be forgotten as data collection and evaluation is an integral component of any safety management program. It is vital that FTA continue to assess and monitor the safety of transit bus operations, including the collection of accurate, timely, and sufficient data so that thorough assessments can be made relating to transit bus safety. Likewise, it is essential that a program be maintained whereas transit bus accidents are thoroughly investigated to identify the underlying causes of crashes so that safety improvements can be implemented in a timely manner. While the NTSB is encouraged that FTA has developed a well-received bus safety program, we are concerned that the program remains completely voluntary and that FTA is unable to ensure that all bus transit agencies are positively affected. In 2013, the safety of bus operations was highlighted as a safety issue area of concern as part of the NTSB’s Most Wanted List. Over the years, the NTSB has made numerous recommendations to the motorcoach and school bus associations, manufacturers, and regulatory agencies such as the Federal Motor Carrier Safety Administration (FMCSA) and the National Highway Traffic Safety Administration (NHTSA), which the NTSB believes should be considered when establishing a robust oversight program for bus transit operations. These recommendations address safety concerns such as driver distraction, driver fatigue, medical oversight, fire safety, event data recorders, and vehicle safety equipment. FTA should refer to the NTSB safety recommendations database for additional information. The following are examples of some of the NTSB recommendations which should be considered. Driver Distraction • To FMCSA: Prohibit the use of both handheld and hands-free cellular telephones by all commercial driver’s license holders while operating a commercial vehicle, except in emergencies. (H-11-26) • To Motorcoach Industry, Public Bus, and School Bus Associations and Unions: Develop formal policies prohibiting cellular telephone use by commercial driver’s license holders with a passenger-carrying or school bus endorsement, while driving under the authority of that endorsement, except in emergencies. (H-06-29)

From: NTSB
To: United Motorcoach Association
Date: 2/13/2014
Response: CC# 201301266- ANPRM Response to Federal Transit Administration: ANPRM - The National Public Transportation Safety Plan, the Public Transportation Agency Safety Plan, and the Public Transportation Safety Certification Training Program; Transit Asset Management: Although the introduction of the ANPRM states that FTA “intends to focus its initial oversight and enforcement efforts on rail transit systems’ implementation of and compliance with these requirements,” the NTSB would like to provide some additional comments with regard to transit bus safety for FTA’s future planning purposes. As was noted in the ANPRM, the NTSB held an investigative hearing on transit bus safety in March 1998, investigated several transit bus accidents, and issued a Special Investigation Report titled Transit Bus Oversight. The report noted that FTA was unable to identify conditions on buses for the traveling public or resolve any unsafe conditions due to a lack of effective safety oversight and enforcement. In addition, the NTSB questioned the utility of the safety data that was being collected on transit bus safety. Finally, the NTSB was concerned that, at the time, a comprehensive bus safety program was not available to transit agencies outside of APTA’s membership program. Based on the findings of the investigation, the NTSB issued the following safety recommendations to the US Department of Transportation: Develop and implement an oversight program to assess and ensure the safety of transit bus operations that receive Federal funding. (H-98-43) Collect accurate, timely, and sufficient data so that thorough assessments can be made relating to transit bus safety. (H-98-44) Evaluate the collected data, as part of the oversight program, to identify the underlying causes of transit bus accidents that could lead to the identification of safety deficiencies at transit agencies. (H-98-45) Develop, in cooperation with the American Public Transit Association, the Community Transportation Association of America, and the American Association of State Highway and Transportation Officials, a model comprehensive safety program(s) and provide it to all transit agencies. (H-98-46) In response, the FTA-sponsored outreach and research efforts to develop a model program for transit bus safety and security. Subsequently, the recommendations were closed with an acceptable response status by the NTSB. Moving forward, however, these recommendations must not be forgotten as data collection and evaluation is an integral component of any safety management program. It is vital that FTA continue to assess and monitor the safety of transit bus operations, including the collection of accurate, timely, and sufficient data so that thorough assessments can be made relating to transit bus safety. Likewise, it is essential that a program be maintained whereas transit bus accidents are thoroughly investigated to identify the underlying causes of crashes so that safety improvements can be implemented in a timely manner. While the NTSB is encouraged that FTA has developed a well-received bus safety program, we are concerned that the program remains completely voluntary and that FTA is unable to ensure that all bus transit agencies are positively affected. In 2013, the safety of bus operations was highlighted as a safety issue area of concern as part of the NTSB’s Most Wanted List. Over the years, the NTSB has made numerous recommendations to the motorcoach and school bus associations, manufacturers, and regulatory agencies such as the Federal Motor Carrier Safety Administration (FMCSA) and the National Highway Traffic Safety Administration (NHTSA), which the NTSB believes should be considered when establishing a robust oversight program for bus transit operations. These recommendations address safety concerns such as driver distraction, driver fatigue, medical oversight, fire safety, event data recorders, and vehicle safety equipment. FTA should refer to the NTSB safety recommendations database for additional information. The following are examples of some of the NTSB recommendations which should be considered. Driver Distraction • To FMCSA: Prohibit the use of both handheld and hands-free cellular telephones by all commercial driver’s license holders while operating a commercial vehicle, except in emergencies. (H-11-26) • To Motorcoach Industry, Public Bus, and School Bus Associations and Unions: Develop formal policies prohibiting cellular telephone use by commercial driver’s license holders with a passenger-carrying or school bus endorsement, while driving under the authority of that endorsement, except in emergencies. (H-06-29)

From: NTSB
To: United Motorcoach Association
Date: 2/11/2013
Response: We note that, in 2006, the UMA published an article regarding our investigation findings in its biweekly newspaper Bus and Motorcoach NEWS. When the Federal Motor Carrier Safety Administration published its final rule prohibiting the use of hand-held cell phones by commercial vehicle drivers in December 2011, the UMA distributed guidance to its members about the regulation change and the increased vigilance by law enforcement officers of drivers who are texting, and encouraged all its members to develop cell phone use policies for their companies. Although we appreciate the efforts the UMA has taken to encourage its member companies to adopt policies for texting and hand-held cell phone use, to our knowledge, the UMA has been silent with regard to the dangers of hands-free cell phone use. In addition, the UMA, at a minimum, should indicate to their members that their cell phone policies should at least address the risks associated with hands-free use of cell phones. Until the UMA takes such action, Safety Recommendation H 06-29 is classified OPEN—ACCEPTABLE ALTERNATE RESPONSE.

From: United Motorcoach Association
To: NTSB
Date: 10/2/2012
Response: -From Victor S. Parra, President and CEO: At the request of Julie Perrot, I am sending you back issues of Bus and Motorcoach NEWS which contained your open recommendations. Please let me know if you have any questions. As always, we appreciate the great work you and the Board do to promote safety on our Nation's highways.

From: NTSB
To: Amalgamated Transit Union
Date: 2/13/2014
Response: CC# 201301266- ANPRM Response to Federal Transit Administration: ANPRM - The National Public Transportation Safety Plan, the Public Transportation Agency Safety Plan, and the Public Transportation Safety Certification Training Program; Transit Asset Management: Although the introduction of the ANPRM states that FTA “intends to focus its initial oversight and enforcement efforts on rail transit systems’ implementation of and compliance with these requirements,” the NTSB would like to provide some additional comments with regard to transit bus safety for FTA’s future planning purposes. As was noted in the ANPRM, the NTSB held an investigative hearing on transit bus safety in March 1998, investigated several transit bus accidents, and issued a Special Investigation Report titled Transit Bus Oversight. The report noted that FTA was unable to identify conditions on buses for the traveling public or resolve any unsafe conditions due to a lack of effective safety oversight and enforcement. In addition, the NTSB questioned the utility of the safety data that was being collected on transit bus safety. Finally, the NTSB was concerned that, at the time, a comprehensive bus safety program was not available to transit agencies outside of APTA’s membership program. Based on the findings of the investigation, the NTSB issued the following safety recommendations to the US Department of Transportation: Develop and implement an oversight program to assess and ensure the safety of transit bus operations that receive Federal funding. (H-98-43) Collect accurate, timely, and sufficient data so that thorough assessments can be made relating to transit bus safety. (H-98-44) Evaluate the collected data, as part of the oversight program, to identify the underlying causes of transit bus accidents that could lead to the identification of safety deficiencies at transit agencies. (H-98-45) Develop, in cooperation with the American Public Transit Association, the Community Transportation Association of America, and the American Association of State Highway and Transportation Officials, a model comprehensive safety program(s) and provide it to all transit agencies. (H-98-46) In response, the FTA-sponsored outreach and research efforts to develop a model program for transit bus safety and security. Subsequently, the recommendations were closed with an acceptable response status by the NTSB. Moving forward, however, these recommendations must not be forgotten as data collection and evaluation is an integral component of any safety management program. It is vital that FTA continue to assess and monitor the safety of transit bus operations, including the collection of accurate, timely, and sufficient data so that thorough assessments can be made relating to transit bus safety. Likewise, it is essential that a program be maintained whereas transit bus accidents are thoroughly investigated to identify the underlying causes of crashes so that safety improvements can be implemented in a timely manner. While the NTSB is encouraged that FTA has developed a well-received bus safety program, we are concerned that the program remains completely voluntary and that FTA is unable to ensure that all bus transit agencies are positively affected. In 2013, the safety of bus operations was highlighted as a safety issue area of concern as part of the NTSB’s Most Wanted List. Over the years, the NTSB has made numerous recommendations to the motorcoach and school bus associations, manufacturers, and regulatory agencies such as the Federal Motor Carrier Safety Administration (FMCSA) and the National Highway Traffic Safety Administration (NHTSA), which the NTSB believes should be considered when establishing a robust oversight program for bus transit operations. These recommendations address safety concerns such as driver distraction, driver fatigue, medical oversight, fire safety, event data recorders, and vehicle safety equipment. FTA should refer to the NTSB safety recommendations database for additional information. The following are examples of some of the NTSB recommendations which should be considered. Driver Distraction • To FMCSA: Prohibit the use of both handheld and hands-free cellular telephones by all commercial driver’s license holders while operating a commercial vehicle, except in emergencies. (H-11-26) • To Motorcoach Industry, Public Bus, and School Bus Associations and Unions: Develop formal policies prohibiting cellular telephone use by commercial driver’s license holders with a passenger-carrying or school bus endorsement, while driving under the authority of that endorsement, except in emergencies. (H-06-29)

From: NTSB
To: American Public Transportation Association
Date: 5/29/2019
Response: We note that, in December 2009, you issued APTA Standard BTS-BS-RP-006-09, “Reducing Agency-Controlled Distractions While Operating a Vehicle on Agency Time.” This standard addresses reducing distractions while operating transit buses, and states that drivers’ personal electronic devices, such as cell phones, pagers, MP3 players, and video games, should be turned off and stowed away from the driver and out of sight. Further, the standard states that these devices should never be used while the vehicle is in motion, and that their use should be restricted to when the vehicle is parked. This standard satisfies Safety Recommendation H 06 29, which is classified CLOSED--ACCEPTABLE ACTION.

From: American Public Transportation Association
To: NTSB
Date: 1/28/2019
Response: -From Paul P. Skoutelas, President and Chief Executive Officer: APTA has developed two documents through its Standards Development Program that address distractions while operating rolling stock. Through our rail Operating Practices Working Group (OPWG), a Rail Transit Standard, titled: “APTA RT-OP-S-017-11 Rev. 1: Electronic Device Distraction Policy” was originally published on November 1, 2011 and reissued on October 8, 2018. This document references the use of Cell Phones and Electronic Devices. The standard states that although the use of electronic devices can be helpful in many transit situations, the use of them while working in or around revenue or non-revenue vehicles in motion must be regulated in order to keep transit employees focused on their duties while performing safety-critical tasks. This standard provides direction as to when and where electronic devices may and may not be used by rail transit employees. The standard is in place to improve the safety of rail transit systems and guide rail transit agencies as to the implementation of electronic device usage policies. The second standard, APTA BTS-BS-RP-006-09 Reducing Agency-Controlled Distractions While Operating a Vehicle on Agency Time, was published in December 2009. It addresses reducing distractions while operating transit buses. This recommended practice states that personal electronic devices such as cell phones, pagers, MP3 players and video games should be turned off and stowed away from the driver’s person and out of sight. These devices should never be used while the vehicle is in motion and the use of these devices should be restricted to times when the vehicle is in a parked condition. The rail standard and bus recommended practice have been developed by APTA and public transportation industry members, and constitute consensus among the rail and bus transit industry. Further, they may both be updated, as necessary, in the future. APTA believes it has met the intent of NTSB Recommendation H-06-29 and accordingly requests that the recommendation be classified as ‘‘Closed.”

From: NTSB
To: American Public Transportation Association
Date: 10/16/2018
Response: In the 13½ years since this recommendation was issued, we have not received any information regarding your activities to satisfy it, and Safety Recommendation H-06-29 is currently classified OPEN--AWAIT RESPONSE. We generally expect actions to satisfy our recommendations to be completed 3 to 5 years after we issue them. Please update us on actions that you have completed or plan to take to address this recommendation.

From: NTSB
To: American Public Transportation Association
Date: 2/13/2014
Response: CC# 201301266- ANPRM Response to Federal Transit Administration: ANPRM - The National Public Transportation Safety Plan, the Public Transportation Agency Safety Plan, and the Public Transportation Safety Certification Training Program; Transit Asset Management: Although the introduction of the ANPRM states that FTA “intends to focus its initial oversight and enforcement efforts on rail transit systems’ implementation of and compliance with these requirements,” the NTSB would like to provide some additional comments with regard to transit bus safety for FTA’s future planning purposes. As was noted in the ANPRM, the NTSB held an investigative hearing on transit bus safety in March 1998, investigated several transit bus accidents, and issued a Special Investigation Report titled Transit Bus Oversight. The report noted that FTA was unable to identify conditions on buses for the traveling public or resolve any unsafe conditions due to a lack of effective safety oversight and enforcement. In addition, the NTSB questioned the utility of the safety data that was being collected on transit bus safety. Finally, the NTSB was concerned that, at the time, a comprehensive bus safety program was not available to transit agencies outside of APTA’s membership program. Based on the findings of the investigation, the NTSB issued the following safety recommendations to the US Department of Transportation: Develop and implement an oversight program to assess and ensure the safety of transit bus operations that receive Federal funding. (H-98-43) Collect accurate, timely, and sufficient data so that thorough assessments can be made relating to transit bus safety. (H-98-44) Evaluate the collected data, as part of the oversight program, to identify the underlying causes of transit bus accidents that could lead to the identification of safety deficiencies at transit agencies. (H-98-45) Develop, in cooperation with the American Public Transit Association, the Community Transportation Association of America, and the American Association of State Highway and Transportation Officials, a model comprehensive safety program(s) and provide it to all transit agencies. (H-98-46) In response, the FTA-sponsored outreach and research efforts to develop a model program for transit bus safety and security. Subsequently, the recommendations were closed with an acceptable response status by the NTSB. Moving forward, however, these recommendations must not be forgotten as data collection and evaluation is an integral component of any safety management program. It is vital that FTA continue to assess and monitor the safety of transit bus operations, including the collection of accurate, timely, and sufficient data so that thorough assessments can be made relating to transit bus safety. Likewise, it is essential that a program be maintained whereas transit bus accidents are thoroughly investigated to identify the underlying causes of crashes so that safety improvements can be implemented in a timely manner. While the NTSB is encouraged that FTA has developed a well-received bus safety program, we are concerned that the program remains completely voluntary and that FTA is unable to ensure that all bus transit agencies are positively affected. In 2013, the safety of bus operations was highlighted as a safety issue area of concern as part of the NTSB’s Most Wanted List. Over the years, the NTSB has made numerous recommendations to the motorcoach and school bus associations, manufacturers, and regulatory agencies such as the Federal Motor Carrier Safety Administration (FMCSA) and the National Highway Traffic Safety Administration (NHTSA), which the NTSB believes should be considered when establishing a robust oversight program for bus transit operations. These recommendations address safety concerns such as driver distraction, driver fatigue, medical oversight, fire safety, event data recorders, and vehicle safety equipment. FTA should refer to the NTSB safety recommendations database for additional information. The following are examples of some of the NTSB recommendations which should be considered. Driver Distraction • To FMCSA: Prohibit the use of both handheld and hands-free cellular telephones by all commercial driver’s license holders while operating a commercial vehicle, except in emergencies. (H-11-26) • To Motorcoach Industry, Public Bus, and School Bus Associations and Unions: Develop formal policies prohibiting cellular telephone use by commercial driver’s license holders with a passenger-carrying or school bus endorsement, while driving under the authority of that endorsement, except in emergencies. (H-06-29)

From: NTSB
To: International Brotherhood of Teamsters
Date: 2/13/2014
Response: CC# 201301266- ANPRM Response to Federal Transit Administration: ANPRM - The National Public Transportation Safety Plan, the Public Transportation Agency Safety Plan, and the Public Transportation Safety Certification Training Program; Transit Asset Management: Although the introduction of the ANPRM states that FTA “intends to focus its initial oversight and enforcement efforts on rail transit systems’ implementation of and compliance with these requirements,” the NTSB would like to provide some additional comments with regard to transit bus safety for FTA’s future planning purposes. As was noted in the ANPRM, the NTSB held an investigative hearing on transit bus safety in March 1998, investigated several transit bus accidents, and issued a Special Investigation Report titled Transit Bus Oversight. The report noted that FTA was unable to identify conditions on buses for the traveling public or resolve any unsafe conditions due to a lack of effective safety oversight and enforcement. In addition, the NTSB questioned the utility of the safety data that was being collected on transit bus safety. Finally, the NTSB was concerned that, at the time, a comprehensive bus safety program was not available to transit agencies outside of APTA’s membership program. Based on the findings of the investigation, the NTSB issued the following safety recommendations to the US Department of Transportation: Develop and implement an oversight program to assess and ensure the safety of transit bus operations that receive Federal funding. (H-98-43) Collect accurate, timely, and sufficient data so that thorough assessments can be made relating to transit bus safety. (H-98-44) Evaluate the collected data, as part of the oversight program, to identify the underlying causes of transit bus accidents that could lead to the identification of safety deficiencies at transit agencies. (H-98-45) Develop, in cooperation with the American Public Transit Association, the Community Transportation Association of America, and the American Association of State Highway and Transportation Officials, a model comprehensive safety program(s) and provide it to all transit agencies. (H-98-46) In response, the FTA-sponsored outreach and research efforts to develop a model program for transit bus safety and security. Subsequently, the recommendations were closed with an acceptable response status by the NTSB. Moving forward, however, these recommendations must not be forgotten as data collection and evaluation is an integral component of any safety management program. It is vital that FTA continue to assess and monitor the safety of transit bus operations, including the collection of accurate, timely, and sufficient data so that thorough assessments can be made relating to transit bus safety. Likewise, it is essential that a program be maintained whereas transit bus accidents are thoroughly investigated to identify the underlying causes of crashes so that safety improvements can be implemented in a timely manner. While the NTSB is encouraged that FTA has developed a well-received bus safety program, we are concerned that the program remains completely voluntary and that FTA is unable to ensure that all bus transit agencies are positively affected. In 2013, the safety of bus operations was highlighted as a safety issue area of concern as part of the NTSB’s Most Wanted List. Over the years, the NTSB has made numerous recommendations to the motorcoach and school bus associations, manufacturers, and regulatory agencies such as the Federal Motor Carrier Safety Administration (FMCSA) and the National Highway Traffic Safety Administration (NHTSA), which the NTSB believes should be considered when establishing a robust oversight program for bus transit operations. These recommendations address safety concerns such as driver distraction, driver fatigue, medical oversight, fire safety, event data recorders, and vehicle safety equipment. FTA should refer to the NTSB safety recommendations database for additional information. The following are examples of some of the NTSB recommendations which should be considered. Driver Distraction • To FMCSA: Prohibit the use of both handheld and hands-free cellular telephones by all commercial driver’s license holders while operating a commercial vehicle, except in emergencies. (H-11-26) • To Motorcoach Industry, Public Bus, and School Bus Associations and Unions: Develop formal policies prohibiting cellular telephone use by commercial driver’s license holders with a passenger-carrying or school bus endorsement, while driving under the authority of that endorsement, except in emergencies. (H-06-29)