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Safety Recommendation Details

Safety Recommendation H-99-050
Details
Synopsis: School bus and motorcoach travel are two of the safest forms of transportation in the united states. Each year, on average, nine school bus passengers and four motorcoach passengers are fatally injured in bus crashes, according to National Highway Traffic Safety Administration (NHTSA) and motorcoach industry statistics. In comparison, NHTSA statistics show that in 1998, over 41,000 people were fatally injured in highway crashes. Although much has been done to improve the safety of school buses and motorcoaches over the years, the safe transportation of bus passengers, especially students and senior citizens, continues to be a national safety priority. Children and seniors are predicted to be the fastest growing segments of our society, and these groups are the primary users of bus transportation. Therefore, the national transportation safety board initiated a special investigation to determine whether additional measures should be taken to better protect bus occupants.
Recommendation: TO THE NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION: In 2 years, develop performance standards for motorcoach roof strength that provide maximum survival space for all seating positions and that take into account current typical motorcoach window dimensions.
Original recommendation transmittal letter: PDF
Overall Status: Open - Unacceptable Response
Mode: Highway
Location: Washington, DC, United States
Is Reiterated: Yes
Is Hazmat: No
Is NPRM: No
Accident #: 80399
Accident Reports:
Report #: SIR-99-04
Accident Date: 11/2/1999
Issue Date: 11/2/1999
Date Closed:
Addressee(s) and Addressee Status: NHTSA (Open - Unacceptable Response)
Keyword(s):

Safety Recommendation History
From: NTSB
To: NHTSA
Date: 11/13/2017
Response: We are encouraged by your August 6, 2014, efforts to issue an NPRM to enhance motorcoach structural integrity. However, although this rulemaking represents long-awaited progress toward improving motorcoach roof strength, we are concerned that the proposed standards and requirements would only apply to certain types of large buses. As discussed later in this letter in the response to Safety Recommendation H-10-3, we recommended that you extend the scope of these recommendations to include all buses, other than school buses, with a gross vehicle weight rating (GVWR) greater than 10,000 pounds. Because we continue to investigate accidents in which motorcoach roof structures are compromised, we are disappointed that a final rule to address this important safety issue is still pending 18 years after these recommendations were issued. Pending publication of the recommended standards and requirements, Safety Recommendations H-99-50 and -51 remain classified OPEN--UNACCEPTABLE RESPONSE.

From: NTSB
To: NHTSA
Date: 12/30/2015
Response:

From: NHTSA
To: NTSB
Date: 7/13/2015
Response: -From Mark R. Rosekind, Administrator: In 2011, NHTSA completed its development of a set of performance standards for improving motorcoach roof strength, with consideration for occupant survival space and window dimensions. On August 16, 2014, NHTSA formally published and proposed these performance standards in a Notice of Proposed Rulemaking (NPRM) to require motorcoach rollover structural integrity (79 FR 4090). We request that our efforts to develop performance standards under Safety Recommendation H-99-50 be classified as "Closed-Acceptable Action."

From: NHTSA
To: NTSB
Date: 8/6/2014
Response: Correspondence Control # 201400941: The National Transportation Safety Board (NTSB) has reviewed the National Highway Traffic Safety Administration (NHTSA) Notice of Proposed Rulemaking (NPRM) “Federal Motor Vehicle Safety Standards; Bus Rollover Structural Integrity, Motorcoach Safety Plan; Proposed Rule,” which was published at 79 Federal Register 46090 on August 6, 2014. The proposed rule is intended to enhance the rollover structural integrity of certain types of large buses—generally, over-the-road buses of any weight (commonly referred to as motorcoaches)—and non-over-the-road buses with gross vehicle weight ratings (GVWR) greater than 11,793 kilograms (kg), and proposes a definition for over-the-road buses. Bus Rollover Structural Integrity The NTSB is encouraged that NHTSA has issued an NPRM concerning bus rollover structural integrity. Recognizing that occupant protection involves vehicle designs that prevent ejection, maintain survivable space, and minimize sharp interior surfaces that can lead to injury, the NTSB has long advocated for rollover structural integrity for all buses, including motorcoaches and medium-size buses weighing over 10,000 pounds. The proposed requirements for rollover structural integrity in this NPRM will address our longstanding Safety Recommendations H-99-50 and -51, issued in our special investigation report on bus crashworthiness, examining the lack of occupant protection standards for motorcoaches. Our safety recommendations on bus and motorcoach occupant protection have appeared on the NTSB Most Wanted List since 2000. Our highway crash investigations have shown that current bus designs lack adequate crashworthiness protection for occupants; buses often lack sufficient roof strength to limit intrusion into occupant seating areas during a rollover event. They also are often built with large side windows that can break, become dislodged, or open during an overturn. We are encouraged that the proposed rule includes performance standards intended to ensure that, during a rollover, restrained occupants have enough survival space, seats and overhead luggage racks stay secured, window glazing remains attached to its mounting, and emergency exits stay closed (but remain operable after the crash). Despite our overall support for the proposed rulemaking, we have some concerns about the rule. In particular, we are concerned that the scope of this NPRM is limited to larger buses; however, medium-size buses also need occupant protection in the event of rollover.

From: NTSB
To: NHTSA
Date: 2/10/2014
Response: Although we are encouraged by your efforts to initiate rulemaking to address the structural integrity of motorcoaches and to allow for further work to improve window glazing requirements, we are concerned about your slow progress in implementing these recommendations. Because we continue to investigate accidents in which motorcoach roof structures and windows have been compromised, we have reiterated these recommendations in multiple accidents (New Orleans, Lousiana; Sherman, Texas; Doswell, Virginia); nevertheless, they remain open more than 14 years after we issued them. Accordingly, pending evidence of significant action, such as actual rulemaking, Safety Recommendations H-99-49 through -51 remain classified OPEN—UNACCEPTABLE RESPONSE.

From: NTSB
To: NHTSA
Date: 8/16/2012
Response: From the NTSB report Motorcoach roadway departure and overturn on Interstate 95 near Doswell, Virginia on May 31, 2011 (report adopted July 31, 2012, report published August 16, 2012): The NTSB has a long history of investigating accidents involving the inadequacy of occupant protection systems on motorcoaches. The Board’s 2008 report on its investigation of a motorcoach accident in Atlanta, Georgia,91 lists 33 motorcoach accidents investigated, and since then, the NTSB has completed 6 more major investigations of this type. Nearly all these investigations have considered the issue of motorcoach occupant protection, with particular emphasis on the need to prevent ejections and maintain survivable space in the event of an accident. The following NTSB recommendations to NHTSA on occupant protection and roof strength standards, which were originally made in the NTSB’s 1999 report on selective motorcoach issues, are classified “Open—Unacceptable Response:”92 In 2 years, develop performance standards for motorcoach occupant protection systems that account for frontal impact collisions, side impact collisions, rear impact collisions, and rollovers. (H-99-47) Once pertinent standards have been developed for motorcoach occupant protection systems, require newly manufactured motorcoaches to have an occupant crash protection system that meets the newly developed performance standards and retains passengers, including those in child safety restraint systems, within the seating compartment throughout the accident sequence for all accident scenarios. (H-99-48) In 2 years, develop performance standards for motorcoach roof strength that provide maximum survival space for all seating positions and that take into account current typical motorcoach window dimensions. (H-99-50) Once performance standards have been developed for motorcoach roof strength, require newly manufactured motorcoaches to meet those standards. (H-99-51) In spring 2009, partially in response to open NTSB safety recommendations, the Secretary of Transportation ordered a full departmental review of motorcoach safety. Based on this review, on November 16, 2009, the DOT published a Motorcoach Safety Action Plan that described a systems-oriented approach for enhancing motorcoach safety.93 Three of the plan’s seven action items—roof strength, seat belts, and accident avoidance technology—address the prevention or mitigation of the effects of rollovers. In August 2010, NHTSA published an NPRM to amend FMVSS No. 208 on occupant crash protection to require lap/shoulder belts for each passenger seating position in new motorcoaches. The NPRM also proposed to require a lap/shoulder belt for the motorcoach and large school bus drivers’ seating positions, which currently are required to have either a lap-only belt or a lap/shoulder belt. NHTSA is expected to publish an NPRM on roof strength standards for motorcoaches94 and a final rule on motorcoach occupant crash protection later this year. School buses have long demonstrated the ability to resist roof crush during rollover events in real-world accidents and in NHTSA testing (based on FMVSS No. 220 for school bus rollover protection). NHTSA has tested motorcoaches to the school bus roof strength standard. The two motorcoaches NHTSA tested in this fashion showed roof displacements of more than five times the allowable limit. Although NHTSA is working to improve occupant protection and roof strength on motorcoaches, standards are needed to advance these efforts effectively. In its report on the New York City accident, the NTSB concluded that even in severe intrusion events, passenger lap/shoulder belts would most likely mitigate serious and fatal injuries for some passengers. As a result, the NTSB reiterated Safety Recommendations H-99-47 and -48.95 The occupant protection failures in the Doswell motorcoach rollover further emphasize the need for full and prompt implementation of these recommendations. On this basis, the NTSB again reiterates Safety Recommendations H-99-47 and -48 to NHTSA, and these recommendations remain classified “Open—Unacceptable Response.” Further, given that the roof collapse of the motorcoach in the Doswell accident had such catastrophic consequences in terms of passenger deaths and injuries, the NTSB reiterates Safety Recommendations H-99-50 and -51 to NHTSA, and these recommendations remain classified “Open—Unacceptable Response.” Window glazing is also important for a complete occupant protection system. Window glazing that remains intact can act as a form of passive occupant protection by preventing full ejection of unrestrained passengers and reducing injuries due to partial ejection of restrained passengers. One of the objectives under the occupant protection category of vehicle integrity in the DOT Motorcoach Safety Action Plan is to accelerate research on improved glazing and window retention techniques. This effort was planned to follow the development of roof crush performance requirements. Also in its 1999 report on motorcoach issues, the NTSB made the following recommendation concerning window glazing to NHTSA:96 Expand your research on current advanced glazing to include its applicability to motorcoach occupant ejection prevention, and revise window glazing requirements for newly manufactured motorcoaches based on the results of this research. (H-99-49) The recommendation is currently classified “Open—Acceptable Response.” Two occupants of the accident motorcoach were partially ejected due to the collapse of the roof and the loss of the window glazing; the vehicle structure subsequently struck these two occupants during the roof collapse, causing fatal crushing injuries. Therefore, the NTSB concludes that the loss of window glazing contributed to the fatalities in this accident, in connection with the deterioration of vehicle integrity due to the roof collapse. Consequently, the NTSB reiterates Safety Recommendation H-99-49 and classifies it “Open—Unacceptable Response.”

From: NTSB
To: NHTSA
Date: 3/1/2011
Response: Although NHTSA has indicated that it continues to conduct research on roof strength to provide maximum survival space for all seating positions, the NTSB is disappointed in the slow progress NHTSA has made in implementing these recommendations since their issuance. The NTSB believes that the delay in the development of roof strength crashworthiness standards increases the likelihood that injuries and fatalities resulting from roof crush could occur in otherwise survivable accidents. This issue was most recently demonstrated in the Dolan Springs, Arizona, accident, in which the roof above the driver’s area was severely damaged and left an opening from which the unbelted driver was likely ejected. Therefore, we urge NHTSA to accelerate its efforts to satisfy this safety recommendation. Accordingly, pending NHTSA’s development and requirement of roof strength standards for motorcoaches, Safety Recommendations H-99-50 and -51 remain classified OPEN -- UNACCEPTABLE RESPONSE.

From: NTSB
To: NHTSA
Date: 10/18/2010
Response: Notation 8250A, NPRM Comments October 18, 2010: The National Transportation Safety Board (NTSB) has reviewed the National Highway Traffic Safety Administration's (NHTSA) Notice of Proposed Rulemaking (NPRM), "Federal Motor Vehicle Safety Standards; Motorcoach Definition; Occupant Crash Protection," which was published at 72 Federal Register 50958 on August 18,2010. The notice proposes to amend the Federal Motor Vehicle Safety Standard (FMVSS) on occupant crash protection (FMVSS No. 208) to require lap/shoulder belts for each passenger seating position in new motorcoaches. The notice also proposes to require a lap/shoulder belt for the motorcoach and large school bus driver's seating position, which currently can have either a lap-only belt or a lap/shoulder belt. To accomplish these requirements, the notice also proposes a motorcoach definition. The NTSB supports this rulemaking and is encouraged that NHTSA is moving forward on the November 2009 U.S. Department of Transportation (DOT) Motorcoach Safety Action Plan. I The NTSB also notes that the proposed rule provides for significant improvements in occupant safety for motorcoach passengers and for drivers of both large school buses and motorcoaches. However, the NTSB notes that the NPRM is inadequate with regard to the motorcoach definition because it does not adequately consider other buses that are often built, marketed, and used in a manner similar to a motorcoach; consequently, such buses would not afford their passengers any required form of occupant protection under this proposed rule. Occupant protection is a comprehensive system involving both proper restraint usage and maintenance of sufficient survival space surrounding each passenger. Motorcoaches and other buses, except school buses, currently lack standards to ensure survival space for restrained occupants in a rollover crash. Although the NTSB is pleased to see NHTSA propose motorcoach passenger lap/shoulder belts, the NTSB also encourages NHTSA to propose motorcoach roof crush performance standards. Occupant Protection Requirements for Motorcoaches The NTSB has long been concerned that motorcoach passengers are not adequately protected in collisions and has issued numerous recommendations since 1968 relating to seat belts and occupant protection systems. Motorcoach occupant protection has been an issue on the NTSB's Most Wanted List of Transportation Safety Improvements since 2000. Although FMVSSs exist for occupant protection, roof strength, and body joint strength for school buses, no similar standards apply to motorcoaches or other buses, except at the driver's position, where seat belts are required. The NTSB supports the proposal to require lap/shoulder belts for all passenger seating positions in motorcoaches. The NTSB's 1999 special investigation report on bus crashworthiness3 found that one of the primary causes of preventable injury in motorcoach accidents involving a rollover, ejection, or both, is occupant motion out of the seat during a collision when no intrusion occurs into the seating area. In addition, the NTSB concluded that the overall injury risk to occupants in motorcoach accidents involving rollover and ejection may be reduced significantly by retaining the occupant in the seating compartment throughout the collision. The NTSB is pleased that NHTSA is proposing to require lap/shoulder belts at each passenger seating position for motorcoaches, which addresses Safety Recommendations H-99-47 and -48, which were issued as a result of the 1999 special investigation. The NTSB also supports the proposal to require lap/shoulder belts for the driver's position for both large school buses and motorcoaches. The Alton, Texas, accident highlighted the need for upper and lower body restraint for the driver as well as for all passengers. Lap/shoulder belts provide additional restraint for the upper body and, therefore, the NTSB is pleased with NHTSA's proposal to require lap/shoulder belts for the driver's position in both large school buses and motorcoaches, which addresses Safety Recommendation H-90-75. Motorcoach Definition The NPRM proposes that a motorcoach be defined as a bus with a gross vehicle weight rating (OVWR) of 26,000 pounds or greater, a seating capacity of 16 or more designated positions including the driver, and at least two rows of forward-facing seats rearward in the driver's seating position. The definition further specifies that motorcoaches include buses sold for intercity, tour, and commuter bus service but does not include school buses or urban transit buses. The NPRM also notes that "shuttle" buses are not excluded from the motorcoach definition, but requests comments as to whether shuttle buses should be excluded, noting that some traverse substantial distances at highway speeds but that others may be operated in a manner that would make seat belts inappropriate. The NTSB is pleased that NHTSA included the NTSB's discussion and recommendations on recently investigated accidents involving buses that may be referred to as "shuttle" buses and believes that such accidents provide evidence that shuttle buses should be included in the motorcoach definition. Dolan Springs, Arizona The January 30, 2009, Dolan Springs, Arizona, accident 6 involved a 2007 Chevrolet/Starcraft 29-passenger medium-size bus with a GVWR of 19,500 pounds and an overall length of 32 feet. 7 The interior configuration was designed with seven rows of forward-facing motorcoach style seats behind the driver. Overhead luggage racks were located above the seats, and storage space for luggage was provided in the rear of the bus (see figures 1 and 2). In this accident, the bus overturned 1.25 times after it left the roadway and then came to rest on its right side. During the rollover sequence, 15 of the 17 occupants, including the driver, were ejected. Seven passengers were killed and nine passengers and the driver were injured. Lake Placid, Florida In February 2010, the NTSB investigated an accident in Lake Placid, Florida, involving a 2001 Ford/Krystal 32-passenger medium-size bus with a GVWR of 19,000 pounds and an overall length of 33 feet. The interior configuration was designed with eight rows of forward-facing motorcoach style seats behind the driver. Overhead luggage racks were installed above the seats for storage of luggage and personal items. After a collision on the left side with a passenger car, the bus driver swerved to the right. The bus then rolled onto its roof, ejecting, eight passengers, three of whom were killed. Twenty-eight of the 31 occupants were injured. As shown in figure 3, the roof of the Lake Placid bus sustained significant damage during the rollover. Although the interior design of these buses, their use for tour operations, and their 29- and 32-passenger seating capacity would be reasons to categorize them as motorcoaches, such medium-size buses are excluded from the current proposed regulations for passenger (and driver) lap/shoulder belts because of the 26,000-pound GVWR requirement. The NTSB concluded, as a result of the Dolan Springs accident investigation, that because of the lack of Federal standards for occupant protection systems, roof strength, and advanced window glazing, occupants of motorcoaches and medium-size buses (or "shuttle" buses) are similarly at risk of ejection during rollover accidents. Similar "shuttle" or medium-size buses can be built to carry up to 45 passengers and are often marketed as buses that have "big coach features" at an "affordable price.” Although these buses have an interior configuration similar to a motorcoach, are often operated like a motorcoach, and have only a slight reduction in passenger capacity, they are significantly less expensive to purchase. The Dolan Springs accident investigation found the use of these buses increasing due to their ability to generate high revenues, their low retail costs compared to motorcoaches, and their passenger capacity. Simple observation in the downtown Washington, D.C., area highlights the fact that medium-size buses travel long distances carrying paying passengers for sightseeing tours. The NTSB believes that medium-size buses, such as the Dolan Springs and Lake Placid buses, should be included in the motorcoach definition contained in this proposed rulemaking. The NTSB also believes that all buses with a GVWR above 10,000 pounds should be defined and have standards addressing roof strength, occupant protection, and window glazing. An accident that occurred during the comment period for this NPRM provides additional support for the NTSB's belief that shuttle buses including those weighing 26,000 pounds and greater should be included in the proposed rulemaking. The September 29, 2010, Bethesda, Maryland, accident involved a 2006 Freightliner/General Coach America 29 passenger medium-size bus with a GVWR of26,000 pounds and an interior configuration with eight rows of forward-facing motorcoach-style seats behind the driver. Eleven passengers (including one child who was ejected from the bus) sustained injuries when the bus struck a guardrail and a bridge rail and subsequently rolled 360 degrees down a steep bridge embankment. If passenger lap/shoulder belts had been available and worn, passengers would most likely have been retained in their seating compartment throughout the collision, and the injury severity probably would have been reduced. The medium-size bus in the Bethesda accident would qualify as a motorcoach under the proposed definition; consequently, it would be required to have lap/shoulder belts for the driver and all passengers. However, the Dolan Springs bus, which had the same seating capacity, a similar configuration, and a similar use in tour operations but which weighed slightly less than the Bethesda bus, would not be included in the proposed rulemaking. Although the Bethesda and Dolan Springs buses are essentially the same, under the proposed changes to Federal regulations, they would have significantly different levels of occupant protection because of the weight requirement. Comprehensive System of Roof Crush Performance Standards and Occupant Protection Standards Occupant protection is a comprehensive system requiring both proper restraint and maintenance of survival space, which could be compromised without roof crush performance standards. Requiring passenger lap/shoulder belts without also establishing a roof crush performance standard exposes passengers to potential injuries if the roof crushes downward onto the restrained passengers. The Lake Placid accident 15 is a good example of where seat belts alone would not have been an effective occupant protection system because of compromised survival space due to the significant roof crush. A motorcoach overturn in Old Bridge, New Jersey, in which the vehicle sustained significant roof crush and at least one fatality resulted from compressional asphyxia, is another example of where a comprehensive occupant protection system was needed. Roof crush performance standards are essential to protect the occupants of both motorcoaches and other buses. The need for these standards was addressed in both the 1999 special investigation17 and the Dolan Springs accident investigation,18 where the NTSB issued Safety Recommendations H-99-50, -51, and H-10-3 urging NHTSA to develop and require roof strength performance standards. The NTSB encourages NHTSA to propose roof crush performance standards, as detailed in the November 2009 Motorcoach Safety Action Plan, to complete the comprehensive system for occupant protection. Motorcoach roof crush performance standards and standards for passenger lap/shoulder belts should both be mandated to ensure a comprehensive occupant protection system. The NTSB appreciates the opportunity to comment on this NPRM addressing motorcoach safety and looks forward to working with NHTSA in the near future to address the concerns presented in these comments.

From: NHTSA
To: NTSB
Date: 3/11/2010
Response: MC# 2100114: - From David L. Strickland, Administrator: Thank you for your letter of November 19,2009, to the National Highway Traffic Safety Administration (NHTSA) in which the National Transportation Safety Board (NTSB) issued three new safety recommendations (H-09-22,23, and 24) and reiterated four existing safety recommendations (H-99-47,48, 50, and 5 1). Safety recommendation H-09-22 requires all new motor vehicles weighing over 10,000 pounds to be equipped with direct tire pressure monitoring systems (TPMS). Safety recommendations H-09-23 and H-09-24 require new performance standards for overhead luggage racks on newly manufactured motorcoaches to ensure that they remain anchored during a crash and mitigate head and neck injuries. The four existing safety recommendations, H-99-47, 48, 50 and 5 1, are to develop and implement performance standards for motorcoach occupant protection systems that account for frontal, side, rear, and rollover crashes, and for motorcoach roof strength. I am pleased to provide you with a response on these important safety issues. Regarding the new safety recommendation H-09-22, the agency agrees that monitoring and maintaining tires at their proper inflation pressure are important issues for all drivers. As you stated in your letter, in response to the Transportation Recall Enhancement, Accountability, and Documentation (TREAD) Act of 2000, the agency finalized a rule that requires a low pressure warning system for new motor vehicles with a gross vehicle weight rating (GVWR) of 10,000 pounds or less. In promulgating this new requirement, the agency explained why we were not pursuing a similar warning system for vehicles with a GVWR above 10,000 pounds. In short, we stated that the issues associated with underinflated tires on these types of vehicles are more complex because these vehicles are typically commercial trucks, truck tractors, trailers, and motorcoaches with several axles and larger tires that have higher inflation pressures. We, therefore, focused our initial efforts on the problem as it related to typical passenger vehicles until we had sufficient time to fully investigate these more complex issues. Over the past several years, NHTSA and the Federal Motor Carrier Safety Administration (FMCSA) have conducted several studies to better understand the problem of underinflation as it relates to commercial trucks, truck tractors, trailers, and motorcoaches. A synopsis of completed studies is attached to this letter. More recently, in August 2007, FMCSA initiated a second field operation test project on large truck TPMS, which is scheduled to be completed in August 2010. We believe these actions complement our effort to improve the underlying performance of the tires used on commercial trucks, truck tractors, trailers, and motorcoaches. We expect to issue a proposal in 2010 that will outline new tests with tires that are underinflated. We believe that these new tests will lead to improved tire performance. Therefore, based on the studies conducted to date, our effort to improve the underlying performance of large truck tires, and in recognition of the new study being conducted by FMCSA, we believe requiring TPMS on commercial vehicles and motorcoaches is premature at this time. As such, we recommend that this NTSB safety recommendation be classified as open acceptable. Regarding the two new motorcoach safety recommendations and the four existing motorcoach safety recommendations, we would like to emphasize that NHTSA remains committed in our efforts to improve motorcoach occupant crash protection. In August 2007, NHTSA published a comprehensive plan describing the priority actions the agency identified for improving motorcoach safety. In November 2009, NHTSA further collaborated with other modal administrations in the Department of Transportation (DOT) to develop a broader, systems-oriented safety action plan for enhancing motorcoach safety. NHTSA's August 2007 plan and the DOT'S November 2009 plan collectively identified the most effective strategies to reduce fatalitieslinjuries in motorcoach crashes through: requiring seat belts, improving rollover structural integrity, requiring electronic stability control systems, and upgrading requirements for emergency evacuation and fire safety in motorcoaches. In accordance with our plans to improve motorcoach safety, NHTSA conducted a full-scale motorcoach frontal crash test in 2007, and numerous sled tests and static component tests in 200812009, to develop performance requirements for seat belts in motorcoaches. In 2010, the agency plans to publish a notice of proposed rulemaking (NPRM) based on our research to install laplshoulder belts at passenger seating positions in motorcoaches. If ultimately adopted in our safety standards, we believe this action directly responds to the NTSB recommendation H-99-47 and H-99-48 which require the development and adoption of performance standards for motorcoach occupant protection systems that account for frontal, side, rear, and rollover crashes. As such, we recommend that these two NTSB safety recommendations be classified as open acceptable. The agency also conducted roof crush and rollover tests on two motorcoach models in February 2008 to assess and compare U.S. and European roof strength and structural integrity requirements for buses. In July 2009, NHTSA conducted an additional verification test with a late model motorcoach using the European rollover test procedure. We believe these actions directly respond to the existing NTSB safety recommendations H-99-50 and H-99-5 1 which require the development and adoption of performance standards for motorcoach roof strength that provide maximum survival space for all seating positions. We also believe that the two new safety recommendations regarding motorcoach luggage rack anchorages and impact protection, H-09-23 and 24, will be suitably addressed in our current research and rulemaking plans. In summary, NHTSA has made significant progress in building the underlying scientific foundation necessary for establishing meaningful performance requirements for motorcoach safety. Therefore, we recommend that the NTSB classify the two new safety recommendations on motorcoach luggage racks and reclassify the four recommendations on motorcoach occupant protection and roof strength as open acceptable.

From: NTSB
To: NHTSA
Date: 3/9/2010
Response: The NTSB is pleased that NHTSA is currently evaluating the results from its previous roof-strength, full-scale frontal, and occupant restraint motorcoach testing to determine how to proceed with rulemaking, and that an additional roof-strength ECE R.66 test was conducted on a 2000 MCI motorcoach on July 22, 2009 to assist NHTSA in developing roof-strength-related rulemaking. Following the NTSB Board Meeting on the Mexican Hat, Utah, motorcoach rollover accident, the Secretary of Transportation ordered a full departmental review of motorcoach safety by NHTSA, the Federal Motor Carrier Safety Administration, the Federal Highway Administration, and the Pipeline and Hazardous Materials Safety Administration, and the development of the Department of Transportation’s Motorcoach Safety Action Plan, which was publicly released on November 16, 2009. The action plan outlines additional steps needed to improve motorcoach safety, such as rulemaking requiring the installation of seat belts on motorcoaches that is expected to be published in May 2010, and enhanced emergency egress requirements focusing on children, aging persons, and people with disabilities, to be developed in 2010. According to the Action Plan, NHTSA had planned to make a decision on regulatory action regarding roof strength requirements late in 2009, but no updates have yet been released. Although the NTSB is pleased that progress is being made to improve motorcoach safety, we are concerned with the delayed start and lengthy time to completion. Accordingly, at its February 18, 2010, meeting, the Board voted to classify Safety Recommendation H-99-9 Open Unacceptable Response. Safety Recommendations H-99-47 and -50 remain classified OPEN -- UNACCEPTABLE RESPONSE. The Board also voted that these recommendations remain on the Most Wanted List in the issue area of Enhance Protection for Motorcoach Passengers, with a timeliness designation of red (unacceptable response).

From: NTSB
To: NHTSA
Date: 11/19/2009
Response: This recommendation was reiterated in H-09-22 through -24. In 1999, the NTSB conducted a bus crashworthiness special investigation and issued a series of safety recommendations to improve occupant protection in the event of an accident.19 In that report, the NTSB concluded that one of the primary causes of preventable injury in motorcoach accidents involving a rollover, ejection, or both, is occupant motion out of the seat during a collision when no intrusion into the seating area occurs. Safety Recommendations H-99-47, 48, -50, and -51 asked NHTSA to take the following actions: In 2 years, develop performance standards for motorcoach occupant protection systems that account for frontal impact collisions, side impact collisions, rear impact collisions, and rollovers. (H-99-47) Once pertinent standards have been developed for motorcoach occupant protection systems, require newly manufactured motorcoaches to have an occupant crash protection system that meets the newly developed performance standards and retains passengers, including those in child safety restraint systems, within the seating compartment throughout the accident sequence for all accident scenarios. (H-99-48) In 2 years, develop performance standards for motorcoach roof strength that provide maximum survival space for all seating positions and that take into account current typical motorcoach window dimensions. (H-99-50) Once performance standards have been developed for motorcoach roof strength, require newly manufactured motorcoaches to meet those standards. (H-99-51) All of these recommendations are classified OPEN -- UNACCEPTABLE RESPONSE. Safety Recommendations H-99-47 and -50 are on the NTSB Most Wanted List of Transportation Safety Improvements. All four recommendations have been reiterated to NHTSA as a result of several motorcoach accident investigations over the last decade and as recently as this year in conjunction with the NTSB’s investigation of a motorcoach rollover accident near Mexican Hat, Utah.20 The Sherman accident motorcoach experienced multiple collisions, including a rollover with an 8-foot drop. Previous NTSB motorcoach investigations concluded that passengers would be safer with an occupant protection system and sufficient roof strength. Recent NHTSA crash testing showed that injury risk was much lower for lap/shoulder-belted dummies than for unrestrained dummies. The NTSB concluded that if NHTSA had implemented the requirements for motorcoach occupant protection systems following the issuance of Safety Recommendations H-99-47, -48, -50, and -51, fewer injuries and fatalities might have occurred because more occupants might have been retained within the accident motorcoach. Once again, the NTSB reiterates these safety recommendations to NHTSA, and they remain classified ?Open--Unacceptable Response.

From: NTSB
To: NHTSA
Date: 10/27/2009
Response: From the accident report of a motorcoach run-off-the-bridge and rollover in Sherman, Texas (report adopted 10/27/2009): In 1999, the NTSB conducted a bus crashworthiness special investigation and issued a series of safety recommendations to improve occupant protection in the event of an accident. In that report, the NTSB concluded that one of the primary causes of preventable injury in motorcoach accidents involving a rollover, ejection, or both, is occupant motion out of the seat during a collision when no intrusion into the seating area occurs. Safety Recommendations H-99-47, 48, -50, and -51 asked NHTSA to take the following actions: In 2 years, develop performance standards for motorcoach occupant protection systems that account for frontal impact collisions, side impact collisions, rear impact collisions, and rollovers. (H-99-47) Once pertinent standards have been developed for motorcoach occupant protection systems, require newly manufactured motorcoaches to have an occupant crash protection system that meets the newly developed performance standards and retains passengers, including those in child safety restraint systems, within the seating compartment throughout the accident sequence for all accident scenarios. (H-99-48) In 2 years, develop performance standards for motorcoach roof strength that provide maximum survival space for all seating positions and that take into account current typical motorcoach window dimensions. (H-99-50) Once performance standards have been developed for motorcoach roof strength, require newly manufactured motorcoaches to meet those standards. (H-99-51) All of these recommendations are classified Open—Unacceptable Response. Safety Recommendations H-99-47 and -50 are on the NTSB Most Wanted List of Transportation Safety Improvements. All four recommendations have been reiterated to NHTSA as a result of several motorcoach accident investigations over the last decade and as recently as this year in conjunction with the NTSB’s investigation of a motorcoach rollover accident near Mexican Hat, Utah. The Sherman accident motorcoach experienced multiple collisions, including a rollover with an 8-foot drop. Previous NTSB motorcoach investigations concluded that passengers would be safer with an occupant protection system and sufficient roof strength. Recent NHTSA crash testing showed that injury risk was much lower for lap/shoulder-belted dummies than for unrestrained dummies. The NTSB concludes that if NHTSA had implemented the requirements for motorcoach occupant protection systems following the issuance of Safety Recommendations H-99-47, -48, -50, and -51, fewer injuries and fatalities might have occurred because more occupants might have been retained within the accident motorcoach. Once again, the NTSB reiterates these safety recommendations, and they remain classified Open—Unacceptable Response. In 2008, NHTSA briefed the NTSB regarding its plans to publish a Notice of Proposed Rulemaking in 2009 that would require motorcoach occupant restraints. Following the NTSB Board Meeting on the Mexican Hat accident investigation, the Secretary of Transportation on April 30, 2009, ordered a full departmental review of motorcoach safety. The Secretary established a Departmental Motorcoach Safety Action Group to develop an action plan. NHTSA, the FMCSA, the FHWA, and the Pipeline and Hazardous Materials Safety Administration have participated in creating the plan. The Secretary indicated that the report was expected to be completed and released by summer 2009. The Motorcoach Safety Action Group gave the NTSB a status briefing on October 16, 2009. During the briefing, action group representatives indicated that the group’s report was under review by the DOT’s Office of the Secretary.

From: NTSB
To: NHTSA
Date: 7/8/2009
Response: A comprehensive occupant protection system considers many aspects of a vehicle, including roof strength, window glazing, seat strength, and restraints and their anchorage strength all working together to protect occupants in the event of a crash. During a crash, the vehicle needs to remain intact and protect the survivable space of the occupants, and the occupants need to remain within their seating compartments. The NTSB’s 1999 bus crashworthiness special investigation called for NHTSA to develop standards for motorcoach occupant protection systems and require their use. As a result of that special investigation, the NTSB issued recommendations concerning occupant protection and roof strength. Ten years later, no federal regulations or standards require motorcoaches operated in the U.S. to be equipped with occupant protection systems except for the driver. With 50 ejections, the Mexican Hat accident represents an extreme case, but motorcoach passenger ejections during accidents are not rare. From 1998 to 2008, the NTSB has investigated 33 motorcoach accidents involving 255 passenger ejections. The NTSB is currently investigating six additional motorcoach accidents involving ejections; the total number of passenger ejections in these accidents has not yet been determined. Complete separation of a motorcoach roof during rollover is a rare accident event that increases the likelihood of passenger ejections from the motorcoach. The NTSB recognizes the extreme catastrophic nature of this particular rollover accident; however, what is at issue is not whether the crash forces exceeded the design standards, because no design standards currently exist for motorcoach roofs, seats, seat belts, or seat anchorages. Although the NTSB is encouraged that NHTSA developed a plan titled NHTSA’s Approach to Motorcoach Safety and is working toward developing standards by conducting tests, no improvements will be implemented until rulemaking is completed in this area. Accordingly, at the Mexican Hat, Utah, Board meeting, the NTSB concluded that because of NHTSA’s delay in defining motorcoach occupant protection performance standards, U.S. motorcoaches have not been equipped with such systems, leaving the traveling public inadequately protected during motorcoach crashes, particularly during rollovers. Because of NHTSA’s unacceptably slow progress in defining and developing motorcoach occupant protection standards, the NTSB classified Safety Recommendations H-99-47, -48, -50, and -51 Open Unacceptable Response. Safety Recommendations H-99-47 and -50 remain on the Most Wanted List in the issue area Enhance Protection for Motorcoach Passengers.

From: NTSB
To: NHTSA
Date: 4/21/2009
Response: This Information is part of the National Transportation Safety Board Report Motorcoach Run Off the Road and Rollover U.S. Route 163 Mexican Hat, Utah Report: Occupant Protection Systems Section: A comprehensive occupant protection system considers many aspects of the vehicle, including roof strength, window glazing, seat strength, and restraints and their anchorage strength all working together to protect occupants in the event of a crash. Further, the vehicle needs to remain intact and protect the survivable space of the occupants, and the occupants need to remain within their seating compartments. The most direct method of retaining passengers in motorcoach seating compartments is lap/shoulder belts, but because no Federal regulations require motorcoaches in the United States to have occupant protection systems, few motorcoaches are so equipped. The Safety Board’s 1999 bus crashworthiness special investigation109 called for NHTSA to develop standards for motorcoach occupant protection systems and require their use. As a result of that special investigation, the Safety Board issued recommendations concerning occupant protection and roof strength, two of which (H-99-47 and -50) are on the Safety Board’s Most Wanted List of Transportation Safety Improvements: In 2 years, develop performance standards for motorcoach occupant protection systems that account for frontal impact collisions, side impact collisions, rear impact collisions, and rollovers. (H-99-47) Once pertinent standards have been developed for motorcoach occupant protection systems, require newly manufactured motorcoaches to have an occupant crash protection system that meets the newly developed performance standards and retains passengers, including those in child safety restraint systems, within the seating compartment throughout the accident sequence for all accident scenarios. (H-99-48) In 2 years, develop performance standards for motorcoach roof strength that provide maximum survival space for all seating positions and that take into account current typical motorcoach window dimensions. (H-99-50) Once performance standards have been developed for motorcoach roof strength, require newly manufactured motorcoaches to meet those standards. (H-99-51) The Safety Board’s 1999 special investigation concluded that the overall injury risk to occupants in motorcoach accidents involving rollover and ejection would be reduced significantly by retaining the occupant in the seating compartment throughout the collision. Ten years later, no Federal regulations or standards require motorcoaches operated in the United States to be equipped with occupant protection systems except for the driver. This accident, with 50 ejections, represents an extreme case, but motorcoach passenger ejections during accidents are not rare. From 1998 to 2008, the Safety Board investigated 33 motorcoach accidents involving 255 passenger ejections (see appendix D) Complete separation of a motorcoach roof during rollover is a rare accident event that increases the likelihood of passenger ejections from the motorcoach. However, because energy increases exponentially with speed, the failure mechanisms affecting a vehicle traveling approximately 88 mph indicate little about the roof’s ability to withstand controlled crash forces at significantly slower test speeds. Furthermore, because motorcoaches in the United States are not required to meet any roof strength standards, or even passenger crash protection standards, assessing the vehicle’s ability to protect passengers during a crash at any speed is difficult. Subsequent to issuance of the Board’s safety recommendations, NHTSA developed a plan entitled NHTSA’s Approach to Motorcoach Safety. NHTSA subsequently conducted frontal crash tests in December 2007 and rollover tests with instrumented dummies, both belted and unbelted, in February 2008, with the results of both sets of tests published in August 2008.113 Vehicle and occupant instrumentation data, photographs, videos, and reports are currently being analyzed. The Safety Board recognizes the extreme catastrophic nature of this particular rollover accident; however, what is at issue is not whether the crash forces exceeded the design standards, because no design standards currently exist for motorcoach roofs, seats, seat belts, or seat anchorages. Although the Safety Board is encouraged that NHTSA is working toward developing standards by conducting tests, no changes can be anticipated until rulemaking occurs in this area. The Safety Board concludes that because of NHTSA’s delay in defining motorcoach occupant protection performance standards, U.S. motorcoaches have not been equipped with such systems, leaving the traveling public inadequately protected during motorcoach crashes, particularly during rollovers. Because of NHTSA’s unacceptably slow progress in defining and developing motorcoach occupant protection standards, the Safety Board is reclassifying Safety Recommendations H-99-47, -48, -50, and -51 from Open Acceptable Response to OPEN -- UNACCEPTABLE RESPONSE.

From: NTSB
To: NHTSA
Date: 4/6/2009
Response: NMC# 103252: [The Safety Board addressed this recommendation at its October 28, 2008, Federal Most Wanted List Board Meeting. The following letter transmits the Board's findings from that meeting.] The Safety Board notes that, on August 6, 2007, NHTSA issued a memorandum, NHTSA’s Approach to Motorcoach Safety, which presents a comprehensive review of motorcoach safety issues and the course of action that NHTSA will pursue to address them. Emergency egress, seat belts, and roof strength were determined to be priorities that NHTSA will be focusing on over the next 2 to 3 years. In the course of its research, NHTSA will study its own regulations such as FMVSS No. 217, which establishes minimum requirements for bus window retention and release to reduce the likelihood of passenger ejection in crashes—as well as international standards, to determine the best way to proceed with the establishment of new requirements to better protect motorcoach passengers. The Safety Board is aware that NHTSA has moved forward with motorcoach testing. In December 2007, the agency conducted a motorcoach frontal impact test using crash test dummies in various belted and unbelted seating positions; preliminary results show that the lap/shoulder restraints resulted in the best outcome. NHTSA conducted further seat belt research during summer 2008 with sled testing, which the agency plans to use as the basis for developing a static loading test procedure. In February 2008, NHTSA also conducted a motorcoach roof-crush test using both the U.S. school bus procedure (uniform load crush) and the European procedure (quasi-static drop off raised platform). Testing results are currently being evaluated. Accordingly, Safety Recommendations H-99-9, -47, and -50 remain classified OPEN -- ACCEPTABLE RESPONSE pending completion of action to improve motorcoach design and to address construction and occupant protection issues. The Safety Board voted that these recommendations would remain on the Most Wanted List in the issue area of Enhance Protection for Motorcoach Passengers with a timeliness designation of yellow acceptable response, progressing slowly.

From: NTSB
To: NHTSA
Date: 2/29/2008
Response: The Safety Board notes that on August 6, 2007, NHTSA issued a memorandum, NHTSA’s Approach to Motorcoach Safety, which presented a comprehensive review of motorcoach safety issues and the course of action that NHTSA will pursue to address them. Emergency egress, seat belts, and roof strength were determined to be priorities that NHTSA will be focusing on over the next 2 to 3 years. In the course of its research, NHTSA will study its own regulations such as FMVSS No. 217, which establishes minimum requirements for bus window retention and release to reduce the likelihood of passenger ejection in crashes as well as international standards to determine the best way to proceed with the establishment of new requirements to better protect motorcoach passengers. The Board was pleased to learn about NHTSA’s December 14, 2007, full-scale frontal crash test of an MCI motorcoach, which carried unrestrained, lap-belted, and lap/shoulder belt restrained crash test dummies. Board staff from the Offices of Research and Engineering and Highway Safety were present at the test, and we look forward to viewing the resulting video and data. The Board also looks forward to receiving periodic updates on NHTSA’s progress towards achieving its planned actions. Accordingly, Safety Recommendations H-99-9, -47, and -50 remain classified OPEN -- ACCEPTABLE RESPONSE pending completion of action to improve motorcoach design and to address construction and occupant protection issues. The Safety Board voted that these recommendations would remain on the Most Wanted List in the issue area of Enhance Protection for Motorcoach Passengers.

From: NHTSA
To: NTSB
Date: 10/25/2007
Response: Letter Mail Controlled 11/1/2007 2:49:20 PM MC# 2070621: - From Nicole R. Nason, Administrator: Roof Strenatb and Window Retention (H-99-50) NTSB recommends developing performance standards for motorcoach roof strength that provide maximum survival space for all seating positions. The agency is addressing roof strength and window retention as a priority initiative. The approach being taken for roof strength involves evaluation of two existing roof crush procedures: FMVSS No. 220 and ECE R.66. A determination will be made to determine which is more stringent or applicable to motorcoaches and what practical countermeasures could be employed. The following tasks will be required: 1. Conduct a survey of the current motorcoach fleet to determine the range of roof characteristics (such as design, material, pillars, shape, etc.) of existing motorcoach roofs. 2. Based on the fleet survey, select two motorcoach models that bracket the fleet in terms of roof characteristics judged to be most and least likely to sustain loading and retain occupant survival space. 3. Conduct baseline testing using both the FMVSS No. 220 and ECE R.66 test procedures. 4. Based on the above test results, determine the relative stringency and practicabilityof the ECE R.66 and FMVSS No. 220 requirements for motorcoaches. 5. From the above testing and analyses, determine the feasibility of proceeding with establishment of a roof crush performance requirement for motorcoaches. In conclusion, this course of action to improve motorcoach safety will help us make progress in strategic areas that will help reduce these fatalities as effectively as possible. NHTSA believes that these activities will address NTSB’s concerns in the area of motorcoach safety in a timely fashion, We request that these safety recommendations remain classified as Open-Acceptable Response and that the issue area of Enhanced Protection for Motorcoach Passengers be changed to Green: Acceptable response, progressing in a timely manner. I hope that this information is helpful. If I can be of further assistance, please contact me or Mr. Ronald L. Medford, Senior Associate Administrator for Vehicle Safety, at (202) 366-1810.

From: NTSB
To: NHTSA
Date: 2/13/2007
Response: The Safety Board notes that, in 2002, NHTSA met separately with motorcoach manufacturers and operators to address, through a cooperative research program, the issue of bus window retention and release, including hold-open devices for breakout windows; however, no research plan was agreed upon at those meetings. In June 2004, NHTSA indicated that it would be focusing its efforts on roof crush and window retention technology, with a goal of keeping occupants in the vehicle, because most motorcoach fatalities occur when passengers are ejected from the vehicle. The Board understands that NHTSA chose this approach, rather than requiring the installation of seatbelts on buses, because increasing roof crush strength and the structural integrity of buses, and improving glazing retention technology for windows, are all safety improvements that require no action by passengers, yet improve their safety. A memorandum of understanding was signed in fall 2004 with Transport Canada to carry out research in these areas. Completion of Transport Canada’s research was anticipated by summer 2006, but NHTSA had not received the final report as of early December 2006. The Board notes that NHTSA will brief Safety Board staff on the findings when they become available. In an effort to further address Safety Recommendations H-99-09, -47, and -50, and as part of its regulatory review cycle, reviews of FMVSS Nos. 217 and 302 were initiated. NHTSA’s response to improvements in window emergency exits will be included in the review of FMVSS No. 217, which establishes minimum requirements for bus window retention and release to reduce the likelihood of passenger ejection in crashes. NHTSA’s research shows that in most accidents, the bus only rolls 1/4 turn and comes to rest on its side; therefore, installation of roof exits to serve as an alternate to window exits as a means of rapid emergency egress for bus passengers is being examined. In response to issues that arose from the Wilmer, Texas, bus fire accident, FMVSS No. 302 specifies burn resistance requirements for materials used in the occupant compartments of motor vehicles. NHTSA anticipates that review of the standards will be completed by early 2007, and it will brief Safety Board staff on the progress of this effort. Accordingly, Safety Recommendations H-99-9, -47, and -50 remain classified OPEN -- ACCEPTABLE RESPONSE pending action to improve motorcoach design and to address construction and occupant protection issues. The Safety Board voted that these recommendations would remain on the Most Wanted List in the issue area of Enhance Protection for Motorcoach Passengers.

From: NHTSA
To: NTSB
Date: 10/12/2006
Response: Letter Mail Controlled 10/19/2006 8:40:44 AM MC# 2060515: - From Ron Medford, Senior Associate Administrator for Vehicle Safety: Recommendations H-99-9, H-99-47 and H-99-50 pertain to occupant emergency egress, occupant protection in different crash scenarios and vehicle roof crush strength, respectively. As you are aware, the Agency initiated a cooperative agreement with Transport Canada to support contract work on finite element analysis to establish roof and window loading forces during a crash. In addition to the finite element work, there has been some limited testing of bus structures. The results of the work have just been completed and the report is being reviewed by NHTSA and Transport Canada. In addition to this cooperative contract work with Canada, last year NHTSA initiated a review of two standards relevant to motor coach safety as a part of our regulatory review cycle. The Agency contracted with Battelle Corporation to assist with some of the technical review. The contract effort includes a review of issues included in the current NTSB recommendations as well as new issues that arose from the Wilmer, Texas crash (e.g., flammability). We expect to complete our review of these standards by early 2007. At that time, we would like to again meet with NTSB to discuss our progress on this review, as well as the work by Transport Canada. Please let me know if you have questions or if you want to further discuss these issues with me prior to the November board hearing. I want to ensure that we maintain satisfactory progress in resolving these outstanding issues and would appreciate you letting me know if there’s anything further we can do in that regard.

From: NHTSA
To: NTSB
Date: 3/1/2006
Response: In its 3/1/2006 annual report to Congress, Regulatory Status of the National Transportation Safety Board's "Most Wanted" Recommendations to the Department of Transportation, the DOT wrote: NHTSA is conducting a joint research project with Transport Canada to address this recommendation. The initial stage of the research was partially funded by NHTSA and funding for the second stage began in September 2005, with completion expected in the summer of 2006. NHTSA staff has indicated that Transport Canada is focusing its research on keeping passengers inside vehicles (reducing ejection), widow glazing materials and latches, and roof strength as funding allows. As most accidents involve a ‘A roll and 50 percent of fatalities are caused by ejection, occupants retained inside may be bruised, but may survive the crash. Studies show that the structural integrity around the emergency release windows is unstable, causing windows to pop out during an accident, or passengers open them prior to a roll during the accident, thereby reducing the ability to keep the occupants inside the vehicle. Preliminary information from Europe indicates that passengers do not tend to use seat belts on buses, even though they are provided. Transport Canada plans to brief NHTSA on research progress in the spring of 2006. NHTSA will test all findings from Transport Canada.

From: NHTSA
To: NTSB
Date: 9/8/2005
Response: On September 8, 2005, NHTSA met with Safety Board staff and provided the following update on H-99-50: NHTSA is conducting a joint research project with Transport Canada to address this recommendation. The initial stage of the research was partially funded by NHTSA, and funding for the second stage began in September 2004, with completion anticipated by summer 2006. NHTSA staff indicated that Transport Canada is focusing its research on keeping passengers inside vehicles, reducing ejection, by researching window glazing materials and latches, and will include research on roof strength as funding allows. As most accidents involve a 1/4 roll, and 50 percent of fatalities are ejected, occupants retained inside the vehicle may be bruised, but will be alive. Studies show that the structural integrity around emergency release windows may be unstable, causing windows to pop out during an accident, or passengers strike and force them open prior to a roll during the accident, thereby reducing the ability to maintain passengers inside the vehicle. Preliminary information from Europe indicates that passengers do not tend to use seat belts on buses, even though they are provided. NHTSA staff will test all findings from Transport Canada. Transport Canada plans to brief NHTSA staff on research progress, most likely in spring 2006; NHTSA will invite NTSB staff to the briefing. NTSB staff encourages NHTSA in its research to make buses safer and looks forward to the Transport Canada briefing. As there is currently no legislation to enforce the use of 3-point seat belts on buses, NHTSA's focus on window glazing and latches is an acceptable solution to address these recommendations.

From: NTSB
To: NHTSA
Date: 3/18/2005
Response: The Safety Board notes NHTSA's contention that while the low average annual number of motorcoach occupant fatalities versus other passenger vehicle occupants does not warrant reducing funds for other programs, the issues do deserve attention. NHTSA reported that it has entered into a joint research program with Transport Canada focused on improving glazing retention and structural integrity requirements for motorcoach-type buses. The initial report from that research focused on the forces impacting the windows and structure during rollover. Completion of the overall research project is expected by September 2006. The Safety Board appreciates NHTSA's and Transport Canada's efforts in completing the initial window impact force study. Passengers who use public transportation are at the mercy of factors beyond their control and it is imperative that all possible efforts be made to ensure their safety. As you know, the issue of enhanced protection for bus passengers is on the Board's Most Wanted list. The Board is concerned that passengers on motorcoaches continue to be at an avoidable risk of death or injury due to the roof strength, window retention, and occupant containment issues identified in our investigations. The recent motorcoach accident on October 6, 2004, near Turrell, Arkansas, reinforced the need for improved occupant retention and protection systems. While that accident is still under investigation, there were 14 fatalities and 16 serious injuries, due in part to a lack of window retention, motorcoach roof collapse, and occupant ejection. The Safety Board continues to believe that motorcoach passenger safety is a major concern. The Safety Board asks to be updated on the progress of your research no later than summer of 2005. Pending this review, Safety Recommendations H-99-47 through -51 remain classified OPEN -- ACCEPTABLE RESPONSE.

From: NHTSA
To: NTSB
Date: 2/1/2005
Response: In its 2/1/2005 annual report to Congress, Regulatory Status of the National Transportation Safety Board's "Most Wanted" Recommendations to the Department of Transportation, the DOT wrote: NHTSA has entered into a Memorandum of Understanding with Transport Canada to perform a study on glazing retention during motor coach rollovers. Upon completion of that study, NHTSA plans to perform additional research to evaluate roof crush and window retention and, depending on the results of the research, issue a NPRM to upgrade FMVSS No. 217, Bus Emergency Exit, Window Retention and Release, and possibly other requirements, including motor coach roof crush strength.

From: NHTSA
To: NTSB
Date: 10/5/2004
Response: About 10 motorcoach occupants are killed per year- in the United States compared to approximately 31,000 other passenger vehicle occupants, and each life lost is a tragedy that we must do our best to prevent. In addressing the motorcoach issue, we also must consider using our limited resources most efficiently. While we will not reduce funding of other programs that have the potential to make larger reductions in the 43,000 deaths and millions injuries that occur each year the motorcoach crashworthiness issues raised by the Board also deserve attention. In our past correspondence, NHTSA stated that there were no industry standards upon which to base Federal motor vehicle safety standards, and that primary research had to be performed to ensure that any proposed regulation would be based on valid scientific data. Previously, we focused much of our attention on obtaining motorcoach manufacturers' cooperation in performing the research needed to develop effective safety standards. However, after our joint public meeting with Transport Canada in April 2002, it was determined that this approach was not likely to yield the safety improvements that are needed. We have subsequently, in 2003, entered into a joint research program with Transport Canada. Our joint program has examined worldwide motorcoach regulations, including those in Europe, and is now conducting the primary research necessary to establish performance requirements and objective compliance test procedures. We are focusing on improved glazing retention and structural integrity requirements or motorcoach type buses. We have chosen this approach rather than safety belts because these countermeasures require action by the users to bring about a safety improvement. Many coach type buses in Europe now have safety belts, but we have no information regarding passenger belt usage in those buses. The 2003 joint research with Transport Canada determined the forces on the windows and structure during rollover using a computer simulation enclosed is a copy of that report. Building upon these results, a program to test motorcoach windows and the surrounding structure has been initiated to determine occupant protection improvements that are feasible with advanced glazing materials and bonding techniques, as well as the structure's role in window retention. We expect to complete the research by September 2006. NHTSA recommends that Safety Recommendations H-99-47 and 48 continue to be classified as OPEN -- ACCEPTABLE RESPONSE.

From: NHTSA
To: NTSB
Date: 9/15/2004
Response: On September 15, 2004, NHTSA met with Safety Board staff and provided the following update on H-99-50: NHTSA reported that they are working with Transport Canada to develop a crash/rollover test that can be used to test motorcoach glazing retention and structural integrity, and that a memorandum of understanding between NHTSA and Transport Canada will be signed in the very near future. NHTSA indicated that this sort of testing has not been done before, but that they are developing a model and a testing device (neither one currently exist) that will test a motorcoach window and surrounding structure under the types of forces exerted in a rollover crash, both in contact with the ground, and from occupants inside the bus. The testing is based upon the roof strength standards in Western Europe, and should provide us with data that will support glazing retention and structural integrity requirements.

From: NTSB
To: NHTSA
Date: 6/28/2002
Response: The Safety Board is pleased that NHTSA concurs that a review of whether current regulations afford adequate protection to motorcoach occupants in serious crashes is appropriate. The Board notes that the motorcoach manufacturers have established a Bus Manufacturers Council to specifically address motorcoach safety issues and that NHTSA will work with the council. The Board commends NHTSA for holding, with Transport Canada, a public motorcoach safety forum on April 30, 2002; Safety Board Vice Chairman Carmody and staff participated in this forum. Pending further information on NHTSA's efforts to address these recommendations, Safety Recommendations H-99-47 through -51 remain classified OPEN -- ACCEPTABLE RESPONSE. Thank you for your response to these recommendations and for your continued partnership with the Safety Board to improve highway safety. We also look forward to your response regarding Safety Recommendations H-99-45 and -46 that relate to performance standards for schoolbus occupant protection.

From: NHTSA
To: NTSB
Date: 3/6/2002
Response: Letter Mail Controlled 03/25/2002 4:16:59 PM MC# 2020323 - From Jeffrey W. Runge, M.D., Administrator: NHTSA shares the NTSB's views that it is appropriate to examine whether current regulations afford adequate protection to motorcoach occupants in serious crashes. NHTSA has been working with the motorcoach manufacturers to remind them of their responsibility to ensure safety by considering occupant protection in crashes throughout their design and manufacturing processes. In response to this, I am pleased to report that the motorcoach manufacturers have now formed Bus Manufacturers Council to specifically address motorcoach safety issues. NHTSA plans to continue working closely with the Bus Manufacturers Council to facilitate industry wide standards that will enhance the safety of motorcoach passengers. In addition, NHTSA has met with our counterparts in Transport Canada to discuss what our governments can and should do together to offer better protection for motorcoach occupants. NHTSA and Transport Canada are now planning a joint public meeting to address motorcoach safety, to be held this spring in the Washington, D.C., area. We have not yet finalized the exact. Location, date, and time for this meeting.

From: NTSB
To: NHTSA
Date: 9/10/2001
Response: In April 2001, the Safety Board acknowledged that NHTSA had initiated a research plan to address Safety Recommendations H-99-47 through 51. Accordingly, pending an update on NHTSA’s activitiesin this area, the Safety Board has classified Safety Recommendations H-99-47 through 51 as OPEN -- ACCEPTABLE RESPONSE. Further, as a result of the New Orleans accident investigation, the Safety Board reiterates these recommendations to the National Highway Traffic Safety Administration.

From: NTSB
To: NHTSA
Date: 8/28/2001
Response: From the accident report of the motorcoach run-off-the-road accident in New Orleans, LA on May 9, 1999 (adopted 8/28/2001): In the New Orleans accident, many of the passengers were thrown forward from their seating compartments and later found lying on top of other passengers near seat row four. In addition, EMS personnel found nine passengers and the driver lying outside the vehicle. In all, 22 passengers were fatally injured as a result of this accident. The loss of survivable space was apparent for some seating positions; in others, survivable space was present and could have been utilized had the passenger been retained within the seating compartment. Investigators determined, based upon the driver’s injuries and the distance that he was thrown from the bus, that the driver was not wearing a seat belt at the time of the accident. The driver.s seat was the only belted position on the motorcoach and is the only position required by Federal regulations to have a seat belt. From its investigations of past motorcoach accidents, the Safety Board has become concerned that motorcoach passengers are not adequately protected in collisions. Although Federal Motor Vehicle Safety Standards exist for large school buses relating to passenger seating, crash protection, and body joint strength, no similar standards apply to other types of large buses, including motorcoaches. In other words, no Federal regulation or standard requires that large buses sold or operated in the United States be equipped with active or passive occupant protection (other than for the driver). In September 1999, the Safety Board published a report titled Bus Crashworthiness Issues that addressed these concerns and examined 36 motorcoach accidents investigated by the Board from 1968 through 1997. Based on the investigations and current knowledge of occupant protection systems, the Safety Board concluded that one of the primary causes of preventable injury in motorcoach accidents involving a rollover, ejection, or both is occupant motion out of the seat compartment during a collision when no intrusion occurs into the seating area. In addition, the Board concluded that the overall injury risk to occupants in motorcoach accidents involving rollover and ejection could be reduced significantly by retaining the passenger in the seating compartment throughout the collision. In the bus crashworthiness report, the Safety Board issued five recommendations to improve the structure and safety of motorcoaches. The Safety Board notes that the improvements identified in this report also apply to the New Orleans accident. Accordingly, the Board is reiterating Safety Recommendations H-99-47 through H-99-51 from the bus crashworthiness report to the National Highway Traffic Safety Administration (NHTSA). NHTSA has responded favorably to these recommendations. With regard to H-99-47 and -48, NHTSA stated in March 2000 that it would consider whether seat belts would be beneficial in motorcoaches. However, NHTSA also noted that since only about five passengers are killed in motorcoach accidents each year, it would be inappropriate to reduce funding for other programs that have the potential to save many more lives to concentrate on motorcoach issues. NHTSA acknowledged that the crashworthiness issues raised by the Safety Board deserve to be analyzed and said that it would examine opportunities to share the cost of research with motorcoach manufacturers. With regard to H-99-49, in August 2001, a NHTSA representative stated that the agency is working on testing procedures for ejection mitigation in light vehicles. The procedures take into account window glazing as well as advanced designs for side curtains/airbags. NHTSA further stated that once it has an ejection mitigation testing procedure that works for light vehicles, the agency plans to use it as a starting point for investigating ejection mitigation in motorcoaches. With regard to H-99-50 and -51, NHTSA responded that it was unaware of recent incidents where roof crush was a predominant factor in the injuries to occupants in motorcoaches.165 It stated that although the increased sizes of side windows may lead to motorcoaches having fewer side support columns to support the weight of the motorcoach during rollovers, the material and manufacturing processes have improved in the 30 years since the Safety Board last reported an accident in which roof strength was a factor in occupant injuries. However, contingent upon the availability of resources, NHTSA stated that it will begin assessing the possibility of requiring motorcoaches to meet the same or similar standards for roof crush as do large school buses. In April 2001, the Safety Board acknowledged that NHTSA had initiated a research plan to address Safety Recommendations H-99-47 through -51. Accordingly, pending an update on NHTSA.s activities in this area, the Safety Board has classified Safety Recommendations H-99-47 through -51 as Open-Acceptable Response.

From: NTSB
To: NHTSA
Date: 4/18/2001
Response: The Safety Board understands that NHTSA has initiated a research plan to address H-99-47 through -51. Accordingly, pending an update on NHTSA's activities in this area, H-99-47 through -51 are classified OPEN --- ACCCEPTABLE RESPONSE.

From: NHTSA
To: NTSB
Date: 10/27/2000
Response: NHTSA has begun developing a research plan to support these five recommendations. Motor Carrier Industries (MCI) requested a meeting regarding the crash testing of motorcoach buses. On 6/15/00, representatives from American Bus Association, United Motorcoach Association (UMA), MCI, NTSB, NHTSA, Federal Motor Carrier Safety Administration (FMCSA), and the Office of the Secretary of Transportation (OST) met to discuss issues related to motorcoaches. At a 7/6/00, meeting, NHTSA solicited support for a joint research program to address motorcoach bus crashworthiness issues, ejection, etc. One motorcoach manufacturer agreed to share some existing data on rollover tests. Other manufacturers requested that NHTSA review existing European requirements to determine feasibility. In a related area, NHTSA's glazing report is due to be finalized around December 2000. NHTSA will share these data with motorcoach manufacturers. We do not request any reclassification of these recommendations at this time.

From: NTSB
To: NHTSA
Date: 8/16/2000
Response: On 8/16/00, the Safety Board met with NHTSA regarding the implementation of this recommendation. NHTSA promised to send an updated response within 30 days.

From: NTSB
To: NHTSA
Date: 5/3/2000
Response: At the May 3, 2000 Board meeting addressing the NTSB’s Most Wanted List of Transportation Safety Improvements (MWL), the Board voted to place Safety Recommendations H-99-09, H-99-43 through H-99-48, H-99-50, and H-99-51 on the Federal MWL under the issue category “Enhance Protection for Bus Passengers.”

From: NTSB
To: NHTSA
Date: 4/24/2000
Response: The Safety Board notes that depending upon the development of a cooperative cost agreement and the availability of resources, NHTSA will assess the possibility of requiring motorcoaches to meet similar roof crush standards as schoolbuses. Since NHTSA expects to initiate the development of a roof crush standard for motorcoaches later this year, we look forward to receiving the results of this assessment. H-99-50 and -51 are classified OPEN – ACCEPTABLE RESPONSE.

From: NHTSA
To: NTSB
Date: 3/3/2000
Response: Letter Mail Controlled 03/08/2000 2:40:19 PM MC# 2000363 - From Rosalyn G. Millman, Acting Administrator: NHTSA is not aware of any recent incidents with motorcoaches where roof crush was a predominant factor in the injuries to occupants in motorcoaches. The last incident the Safety Board cites where roof strength was a factor occurred in 1971, with a 1970 model motor coach industries bus. NHTSA is aware that the increased side window size in motorcoaches may lead to motorcoaches having less side support columns to support the weight of a motorcoach should it be involved in a rollover situation. However, material and manufacturing processes have most certainly improved over the last 28 years. Nonetheless, contingent upon the availability of sufficient resources, NHTSA will assess the possibility of requiring motorcoaches to meet the same or similar standards for roof crush, as do large school buses. Depending on the development of a cooperative agreement to share the burden of cost, we expect to begin looking into developing a roof crush standard for motorcoaches in the summer of 2000.