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Safety Recommendation Details

Safety Recommendation H-99-054
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: Develop and implement, in cooperation with other government agencies and industry, standards for on-board recording of bus crash data that address, at a minimum, parameters to be recorded, data sampling rates, duration of recording, interface configurations, data storage format, incorporation of fleet management tools, fluid immersion survivability, impact shock survivability, crush and penetration survivability, fire survivability, independent power supply, and ability to accommodate future requirements and technological advances.
Original recommendation transmittal letter: PDF
Overall Status: Closed - Unacceptable Action
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: 7/12/2019
Addressee(s) and Addressee Status: NHTSA (Closed - Unacceptable Action)
Keyword(s): Recorders

Safety Recommendation History
From: NTSB
To: NHTSA
Date: 7/12/2019
Response: We are disappointed that you have not developed performance standards or a requirement to address bus event data recorders [EDRs] in the nearly 20 years since we issued the original recommendations to address this problem. We have continued to investigate crashes in which the lack of available vehicle data prevented us from better understanding why and how the crash occurred; as a result, we have reiterated this recommendation five times (in our Atlanta, Georgia; Orland, California; Davis, Oklahoma; pedal misapplication; and school bus transportation safety reports), and it has been a recurrent issue on our Most Wanted List of transportation safety improvements. Although we understand the challenges of developing a cost-benefit analysis for the rulemaking process, we continue to respectfully disagree with your approach to bus EDRs. Development of performance standards and a federal regulation would create a level playing field for all bus manufacturers, and would improve riders’ safety. However, because you have no plans to implement these recommendations, Safety Recommendations H-99-54 and H-10-7 are classified CLOSED--UNACCEPTABLE ACTION.

From: NHTSA
To: NTSB
Date: 3/4/2019
Response: -From Heidi R. King, Deputy Administrator: Safety Recommendations H-99-054 and H-10-007 request that NHTSA develop and implement standards for on-board recording of bus crash data and require that all buses over 10,000 pounds GVWR be equipped with on-board recording systems, respectively. In a letter to the NTSB dated April 12, 2016, the agency explained why it had determined that no further action on Safety Recommendations H-99-054 and H-10-007 was necessary and requested that they be closed. NHTSA decided not to pursue installation requirements for Heavy Vehicle Event Data Recorders (HVEDRs) because our analysis found that many of the heavy vehicle crash characteristics that are important to our understanding of vehicle crash performance are obtainable through traditional crash investigation methods. While HVEDRs could enable collection of data elements that are not available through investigative means (e.g., advanced safety technology activation), requiring such data to be recorded on a HVEDR would, for several reasons, require installation of additional sensor systems. Event data recorders on light vehicles are triggered by the accelerometers that deploy air bags. Because most heavy vehicles are not equipped with air bags, mandating HVEDRs would require the installation of new sensors and NHTSA would need to conduct research to identify appropriate trigger thresholds. NHTSA is concerned about the cost of mandating HVEDRs due to the added expense of installing sensors to collect these additional data and meet the requirements of a HVEDR rulemaking. Current HVEDR installation rates are also very low and fleet-wide installation would add substantial cost. Any decision to regulate the installation of HVEDRs for large buses must be made only after carefully considering the cost of requiring HVEDRs and the potential benefits the additional information would provide. Careful consideration of costs and benefits is especially important when making decisions regarding school buses, where additional costs to school districts could result in reduced fleet size and more students being forced to take less safe means of transportation to and from school. Combined, these challenges present significant difficulties in justifying an HVEDR mandate. NHTSA requests that Safety Recommendations H-99-054 and H-10-007 be closed.

From: NTSB
To: NHTSA
Date: 6/21/2018
Response: From the NTSB Special Investigative Report “Selective Issues in School Bus Transportation Safety: Crashes in Baltimore, Maryland, and Chattanooga, Tennessee.” Report Number SIR-18-02. The NTSB continues to believe that learning as much as possible about real-world crash dynamics in a school bus collision can be crucial in developing even safer school buses and other student transportation vehicles. NHTSA has not developed standards, nor required the use of HVEDRs, for the commercial passenger vehicles that transport pupils to and from school, school-related activities, and other events—such as school buses, transit buses, or even motorcoaches. These vehicles also transport other passengers for tourism and in commerce, where expectations of safety should parallel those of other modes of commercial passenger transportation. Crash-protected recorders have been required for many years—in some cases, decades—in most large commercial airplanes, marine vessels, and train locomotives. The NTSB concludes that with the continued lack of standards and requirements for HVEDRs, crash data valuable to better understand highway collisions and to improve highway safety continue to go unrecorded. Therefore, the NTSB reiterates Safety Recommendations H-99-54 and H-10-7 to NHTSA.

From: NTSB
To: NHTSA
Date: 11/13/2017
Response: This recommendation is one of four (Safety Recommendations H-99-54, and H-10-7, -14, and -15) that we have issued addressing heavy vehicle event data recorders (EDRs). We are disappointed that performance standards to address this important safety issue have not been developed nearly 18 years after we issued this recommendation. Our 2017–2018 Most Wanted List includes the issue area “Expand Recorder Use to Enhance Safety” because we continue to investigate accidents in which the lack of available vehicle data represents a missed opportunity to better understand why and how the crash occurred. We note that you were drafting a white paper explaining your perspective on heavy vehicle EDRs; however, we understand that you did not publish that paper. We believe it would be helpful for NHTSA and NTSB staff to discuss the current state of EDR use and research. Pending such a discussion, Safety Recommendation H 99 54 remains classified OPEN--UNACCEPTABLE RESPONSE.

From: NHTSA
To: NTSB
Date: 4/12/2016
Response: From Mark Rosekind, Administrator: We provided updates to four of the reiterated Safety Recommendations (H-99-54, H-10-7, H-10-14, and H-10-I5) in a letter dated December 18, 2015. These four Safety Recommendations request that the agency develop and implement performance standards for heavy vehicle event data recorders in trucks and buses over 10,000 pounds. In the December 18 letter, we responded that we intend no further action and requested that these four Safety Recommendations be closed. Safety Recommendation H-10-03 requested that NHTSA's rulemakings include all buses (other than school buses) with GVWRs above 10,000 pounds in order to improve motorcoach roof strength, occupant protection, and window glazing standards. Mid-size buses were discussed in our final rule requiring seat belts on buses 1 and in the proposed rule for bus rollover structural integrity. 2 The agency did not expand applicability of these rulemaking actions to buses with GVWRs between 10,000 and 26,000 pounds because development of a regulation for these buses was not found to be cost beneficial. We intend no further action on this Safety Recommendation, and request that this Safety Recommendation be closed. In summary, we are requesting that Safety Recommendation H-15-04 be classified as "Open Acceptable Response". For the reiterated recommendations H-99-54, H-10-03, H-10-07, H-10-14, and H-10-15, NHTSA intends no further action, and requests that these recommendations be closed.

From: NHTSA
To: NTSB
Date: 12/18/2015
Response: Mark R. Rosekind, Ph.D., Administrator: We intend no further activity for these four Safety Recommendations (H-99-54, H-10-14, H-10-15, and H-10-7) and request they be closed. These four reiterated recommendations request the agency develop and implement performance standards for HVEDRs in trucks and buses over 10,000 pounds. We have studied the issues relating to establishment of performance requirements for HVEDRs and decided not to pursue installation requirements for them. Our analysis found that many of the important heavy vehicle crash characteristics are obtainable through traditional crash investigation methods. For those data elements of most interest that are not available through investigative means (e.g., vehicle acceleration or advanced safety technology activation) recording such data on HVEDR would require installation of additional sensor systems. The added expense of installing sensors to collect these additional data and meet the requirements of a HVEDR rulemaking is likely to remain high for the foreseeable future. Current HVEDR installation rates are also very low and so their fleet-wide installation alone will add cost. All of these factors combined would make justification of a HVEDR mandate difficult through a cost-benefit analysis. We have drafted a white paper outlining these issues and expect to publish that paper this year. A copy of this paper will be provided to NTSB staff when it becomes available.

From: NTSB
To: NHTSA
Date: 12/14/2015
Response: From the Report: Truck-Tractor Semitrailer Median Crossover Collision With Medium-Size Bus on Interstate 35, Davis, Oklahoma,, September 26, 2014, Highway Accident Report NTSB/HAR-15/03 (Washington, DC: National Transportation Safety Board, 2015, Notation 8610B): Dedicated EDRs would not only have been more likely to survive the collision forces and power failure of this crash, but also to yield critical crash data on driver inputs and vehicle dynamics throughout the collision sequence, far beyond the capabilities of a typical EECU. The lack of such data in this collision represents another missed opportunity to better understand the crash why it happened as well as the crash dynamics between the truck-tractor and the bus. Although NHTSA has made progress in developing EDR standards for light vehicles, it has not yet developed standards for nor required the use of EDRs in heavy vehicles, including motorcoaches, school buses, truck-tractor semitrailer combination units, and medium-size buses. The NTSB concludes that because of the continued lack of standards and requirements for EDRs in trucks and buses over 10,000 pounds GVWR, data that are crucial to the improved understanding of crashes, as well as to overall vehicle safety, continue to go unrecorded. Therefore, the NTSB reiterates Safety Recommendations H-99-54 and H-10-7, -14, and -15 to NHTSA.

From: NTSB
To: NHTSA
Date: 8/4/2015
Response: Reiterated in the Highway Accident Report Truck-Tractor Double Trailer Median Crossover Collision with Motorcoach and Postcrash Fire on Interstate 5 in Orland, California on April 10, 2014. HAR-15-01. Notation 8590A. Adopted on July 14, 2015. Issued on August 4, 2015. From the report: The NTSB has also made recommendations concerning the development of standards and requirements for EDRs in heavy vehicles that carry passengers—specifically, school buses and motorcoaches. In a special investigation of bus crashworthiness, the NTSB (1999a) made two EDR recommendations to NHTSA (Safety Recommendations H-99-53 and -54): Develop and implement, in cooperation with other Government agencies and industry, standards for on-board recording of bus crash data that address, at a minimum, parameters to be recorded, data sampling rates, duration of recording, interface configurations, data storage format, incorporation of fleet management tools, fluid immersion survivability, impact shock survivability, crush and penetration survivability, fire survivability, independent power supply, and ability to accommodate future requirements and technological advances. (H-99-54) Safety Recommendation H-99-53 is not listed above because it was superseded by Safety Recommendation H-10-7, as discussed below. As the result of an investigation of a bus loss-of-control and rollover in Dolan Springs, Arizona, in January 2009, the NTSB (2010a) recommended that NHTSA: Require that all buses above 10,000 pounds gross vehicle weight rating be equipped with on-board recording systems that: (1) record vehicle parameters, including, at minimum, lateral acceleration, longitudinal acceleration, vertical acceleration, heading, vehicle speed, engine speed, driver’s seat belt status, braking input, steering input, gear selection, turn signal status (left/right), brake light status (on/off), head/tail light status (on/off), passenger door status (open/closed), emergency door status (open/closed), hazard light status (on/off), brake system status (normal/warning), and flashing red light status (on/off; school buses only); (2) record status of additional seat belts, airbag deployment criteria, airbag deployment time, and airbag deployment energy; (3) record data at a sampling rate sufficient to define vehicle dynamics and be capable of preserving data in the event of a vehicle crash or an electrical power loss; and (4) are mounted to the bus body, not the chassis, to ensure recording of the necessary data to define bus body motion. (H-10-7) Upon issuance of Safety Recommendation H-10-7, Safety Recommendation H-99-53 was classified “Closed?Unacceptable Action/Superseded.” Safety Recommendations H-99-54 and H-10-7 are currently classified “Open–Unacceptable Response.” Additionally, in the investigation of a heavy vehicle collision in Miami, Oklahoma, in June 2009, in which there were 10 fatalities, the NTSB (2010b) made the following recommendations to NHTSA: Develop and implement minimum performance standards for event data recorders for trucks with gross vehicle weight ratings over 10,000 pounds that address, at a minimum, the following elements: data parameters to be recorded; data sampling rates; duration of recorded event; standardized or universal data imaging interface; data storage format; and device and data survivability for crush, impact, fluid exposure and immersion, and thermal exposure. The standards should also require that the event data recorder be capable of capturing and preserving data in the case of a power interruption or loss, and of accommodating future requirements and technological advances, such as flashable and/or reprogrammable operating system software and/or firmware updates. (H-10-14) After establishing performance standards for event data recorders for trucks with gross vehicle weight ratings over 10,000 pounds, require that all such vehicles be equipped with event data recorders meeting the standards. (H-10-15) To date, NHTSA has failed to develop standards or require the use of EDRs for heavy vehicles, which include motorcoaches, school buses, or truck-tractor units such as the one involved in the Orland collision. Had the accident truck-tractor and the motorcoach been equipped with dedicated crash EDRs built to minimum performance standards—which include device and data survivability—vital precrash and crash information could have been captured, allowing for a more comprehensive investigation and analysis. Both Safety Recommendations H-10-14 and -15 are currently classified “Open—Unacceptable Response.” 2.8.2 Safety Recommendations The lack of EDR data for the Orland collision represents another missed opportunity to better understand why and how the crash occurred. The NTSB concludes that, due to a lack of standards and requirements for heavy vehicle EDRs, crash data essential to better understanding collisions continue to go unrecorded, thus impeding improvements in highway safety. Therefore, the NTSB reiterates Safety Recommendations H-99-54 and H-10-7, -14, and -15 to NHTSA.

From: NTSB
To: NHTSA
Date: 2/10/2014
Response: Although we are aware that you have gathered information about electronic data recorders (EDRs), we are disappointed that you have not yet required the use of EDRs on buses. The need for capturing vehicle data is not new; this recommendation has been reiterated in two NTSB reports (the 2007 motorcoach accident in Atlanta, Georgia, and a special investigation report on pedal misapplications) because we continue to investigate accidents in which the availability of additional vehicle data would have been helpful in determining the cause and severity of the crash. Accordingly, pending evidence of significant action, such as actual rulemaking, Safety Recommendation H-99-54 remains classified OPEN—UNACCEPTABLE RESPONSE.

From: NTSB
To: NHTSA
Date: 5/27/2010
Response: Despite the reiteration of Safety Recommendation H-99-54 twice since its issuance, NHTSA has not yet implemented a requirement for the use of electronic data recorders on buses. Accordingly, pending evidence of tangible action, such as the promulgation of rulemaking, to address Safety Recommendation H-99-54, this recommendation remains classified OPEN -- UNACCEPTABLE RESPONSE.

From: NHTSA
To: NTSB
Date: 12/30/2009
Response: Letter Mail Controlled 1/19/2010 2:46:38 PM MC# 2100020: - From Ronald L. Medford, Acting Deputy Administrator: We are currently addressing the two reiterated recommendations at this time. On-board recording systems are one of the seven priority actions in the plan. NHTSA has been working with the Society of Automotive Engineers’ (SAE) Truck and Bus Committee for several years to develop SAE Recommended Practice 52728, Heavy Vehicle Event Data Recorder (HVEDR) Base Standard. These specifications, as well as exploration of other passenger carrier data sources, will inform the agency’s decision on installation and performance characteristics of HVEDRs on motorcoaches in 2010. We will continue to update NTSB with our progress on these recommendations. Based on these on-going, coordinated activities and the progress we are making toward resolving the recommendation, we respectfully request that NTSB change the status of H-99-53 and H-99-54 to Open Acceptable Action.

From: NTSB
To: NHTSA
Date: 9/15/2009
Response: NTSB reiterates and reclassify this recommendation and issues H-09-11 through -13: In 1999, as a result of its special investigation of bus crashworthiness,25 the NTSB made two EDR-related recommendations to NHTSA, Safety Recommendations H-99-53 and -54. In October 2000, NHTSA organized the truck and bus EDR working group to focus on data elements, survivability, and event definitions related to trucks, school buses, and motorcoaches. Findings were published in May 2002.26 In 2004, the National Cooperative Highway Research Program examined current U.S. and international methods and practices for the collection, retrieval, archiving, and analysis of EDR data for roadside and vehicle safety.27 In 2004, both IEEE28 and the Society of Automotive Engineers (SAE) published voluntary standards and recommended practices regarding highway vehicle EDRs.29 IEEE completed project 1616 by publishing the first established standards for motor vehicle EDRs—standards that encompassed all highway vehicles on both light and heavy vehicle platforms. The SAE published a voluntary industry recommended practice (J1698) for displaying and presenting EDR data. This recommended practice was an effort to establish a standardized format for displaying and presenting crash-related data that had been recorded or stored by the electronic components currently installed in many light-duty vehicles. It applies specifically to the postevent format of downloaded data and does not direct how the data should be collected or which vehicle systems should be monitored. Further, SAE J1698 applies to data from frontal impacts only. SAE has not proceeded with plans to continue the standardization of EDR data by developing recommended practices for additional collision types, including multiple impacts, side impacts, and rollovers. An additional SAE working group is reportedly near completion of a recommended practice for heavy vehicle EDRs. SAE J2728 addresses the following for medium- and heavy-duty vehicles: event triggers, data elements, event record duration, time stamping, recording rate, file format, performance requirements, electrical and environmental performance, survivability, power reserves, security, data volatility, access, interfaces, extraction procedures, and alternative extraction methods. Additional industry initiatives include the American Trucking Associations publication of a recommended practice (RP1214) to define the collection of event-related data on board commercial vehicles. This recommended practice, intended for mechanics, outlines data elements, storage methodology, and retrieval approach for event data. The Commercial Vehicle Safety Technology Diagnostics and Performance Enhancement Program of the Federal Motor Carrier Safety Administration (FMCSA), also known as the CV Sensor Study, has worked to define advanced on-board diagnostic and improved safety-related products for trucks and tractor-trailers. The program has developed functional EDR requirements for the analysis of accident data from the FMCSA’s Large Truck Crash Causation Study for both complete accident reconstruction and crash analyses. The CV Sensor Study has also developed requirements for EDR components, hardware, software, sensors, and databases, and has completed a cost-effectiveness analysis.30 During the 2007 SAE symposium on highway EDRs,31 industry representatives discussed the status of standards work; current system operating experience; and evidence that many operators currently use vehicle data recorders to improve operational control, to support insurance rates and claims, and to respond to litigation. The pedal misapplication incidents discussed in the special investigation report exemplify heavy vehicle accidents in which EDRs would have provided essential data. Although research and human factors principles provide a compelling explanation for unintended acceleration incidents in which no mechanical cause is found, some people remain skeptical that pedal misapplication is the cause of such accidents. If these vehicles were equipped with EDRs, the question of the drivers’ actions during specific events could be documented, and investigators would have a physical record of specific actions and control inputs. Had any of the vehicles involved in these accidents been equipped with an EDR, a significantly higher level of science could have been applied to understanding the accident. The NTSB concludes that EDRs would provide essential and specific information regarding the causes and mechanisms of pedal misapplication and unintended acceleration in heavy as well as light vehicles. Recognizing the work of NHTSA in formally requesting comments on bus EDRs and participating in working groups developing standards for EDRs, the NTSB classified both Safety Recommendations H-99-53 and -54 as OPEN -- ACCEPTABLE RESPONSE On April 15, 2004. However, the NTSB reiterated these two recommendations on August 18, 2008, in a report on the motorcoach accident in Atlanta, Georgia, involving 33 members of the Bluffton University baseball team.32 The NTSB’s investigation of the crash dynamics and injury mechanisms was limited because of the lack of an EDR on the motorcoach. Despite the reiteration of Safety Recommendations H-99-53 and -54, NHTSA has not yet implemented a requirement for the use of EDRs on buses. Accordingly, the NTSB is reclassifying Safety Recommendations H-99-53 and -54 to OPEN --- UNACCEPTABLE RESPONSE and reiterating them again: Require that all school buses and motorcoaches manufactured after January 1, 2003, be equipped with on-board recording systems that record vehicle parameters, including, at minimum, lateral acceleration, longitudinal acceleration, vertical acceleration, heading, vehicle speed, engine speed, driver’s seat belt status, braking input, steering input, gear selection, turn signal status (left/right), brake light status (on/off), head/tail light status (on/off), passenger door status (open/closed), emergency door status (open/closed), hazard light status (on/off), brake system status (normal/warning), and flashing red light status (on/off) (school buses only). For those buses so equipped, the following should also be recorded: status of additional seat belts, airbag deployment criteria, airbag deployment time, and airbag deployment energy. The on-board recording system should record data at a sampling rate that is sufficient to define vehicle dynamics and should be capable of preserving data in the event of a vehicle crash or an electrical power loss. In addition, the on-board recording system should be mounted to the bus body, not the chassis, to ensure that the data necessary for defining bus body motion are recorded. (H-99-53) Develop and implement, in cooperation with other government agencies and industry, standards for on-board recording of bus crash data that address, at a minimum, parameters to be recorded, data sampling rates, duration of recording, interface configurations, data storage format, incorporation of fleet management tools, fluid submersion survivability, impact shock survivability, crush and penetration survivability, fire survivability, independent power supply, and ability to accommodate future requirements and technological advances. (H-99-54)

From: NTSB
To: NHTSA
Date: 8/18/2008
Response: About 5:38 a.m. eastern standard time on Friday, March 2, 2007, a 2000 VanHool T2145 57-passenger motorcoach operated by Executive Coach Luxury Travel, Inc., transporting 33 members of the Bluffton University baseball team, the driver, and his wife, was traveling south on Interstate 75 (I-75) in Atlanta, Georgia. The motorcoach had departed from the university, about 60 miles southwest of Toledo, Ohio, about 7:00 p.m. the previous day and was en route to a competition in Sarasota, Florida. When the original driver had stopped in Adairsville, Georgia, approximately halfway through the 18-hour trip, the 65?year?old relief driver, accompanied by his wife, boarded the motorcoach and began driving at 4:30 a.m. to complete the trip to Florida. The relief driver had driven approximately 54 miles and, according to witnesses, was in the southbound high occupancy vehicle (HOV) lane at milepost 250 when the motorcoach departed the interstate, traveling at highway speed, onto the HOV-only left exit ramp to Northside Drive. The exit ramp came to an end at the stop sign-controlled T-intersection with Northside Drive. As the motorcoach entered the intersection at an estimated speed of 50 to 60 mph, the driver steered to the right and collided with the reinforced portland cement concrete bridge wall and chain-link security fence located along the southern edge of the eastbound lanes of the overpass. The motorcoach then overrode the bridge rail, rotated clockwise, and fell 19 feet onto the southbound lanes of the interstate. The motorcoach came to rest on its left side (driver’s side), perpendicular to the southbound lanes of I-75. Two southbound passenger vehicles received minor damage from debris as the motorcoach fell onto I-75; none of the passenger vehicle occupants were injured. Seven motorcoach occupants were killed: the driver, the driver’s wife, and five passengers. Seven other passengers received serious injuries, and 21 passengers received minor injuries. The National Transportation Safety Board determined that the probable cause of this accident was the motorcoach driver’s mistaking the HOV-only left exit ramp to Northside Drive for the southbound Interstate 75 HOV through lane. Contributing to the accident driver’s route mistake was the failure of the Georgia Department of Transportation to install adequate traffic control devices to identify the separation and divergence of the Northside Drive HOV-only left exit ramp from the southbound Interstate 75 HOV through lane. Contributing to the severity of the accident was the motorcoach’s lack of an adequate occupant protection system. Although the primary issue under investigation in this accident was the adequacy of the highway signage and roadway markings, the accident investigation also focused on the lack of event data recorders (EDRs) on motorcoaches and the lack of motorcoach occupant protection systems. The Atlanta accident motorcoach was not equipped with an EDR to provide vital precrash data, severely hampering the investigation. Lack of valuable crash data continues to restrict accident investigations; for example, in this accident, data concerning the exact vehicle speed, status of the cruise control and high beams, throttle position, and driver steering and brake inputs, as well as several other parameters, could not be precisely determined based on physical evidence. The Safety Board’s investigation into the cause of passenger injuries and the points of ejection was severely limited because insufficient data were available from which to calculate reliable crash pulses. An EDR would have provided vehicle dynamics information throughout the accident sequence. Crash pulses and/or Delta V are often used to calculate passenger occupant kinematics, help evaluate injury exposure, and help evaluate passenger protection safety devices and systems. Using these data, investigators can predict potential injury mechanisms and the effects of various design elements on occupant protection systems. Although crash forces can sometimes be estimated by comparing the accident vehicle’s physical damage to instrumented crash test data, this method is not always reliable—particularly when crash test data are substantially limited, as they are for motorcoaches, and when the accident involves a barrier collision or a collision with a hard paved surface. The ability to estimate crash pulses was also limited by the fact that some surfaces of the motorcoach may have undergone multiple collisions. The Safety Board concludes that information on the acceleration time history (or crash pulses) critical to the evaluation of vehicle performance and occupant protection systems was unavailable to accident investigators and researchers because of the motorcoach’s lack of an EDR. As a result of its 1996 safety study on child restraint systems and subsequent 1997 air bag forum, the Safety Board recommended that the National Highway Traffic Safety Administration (NHTSA) address the on-board recording of crash data. About that time, the National Aeronautics and Space Administration and the Jet Propulsion Laboratory also recommended that NHTSA study the feasibility of installing and obtaining crash data for safety analysis from crash recorders on vehicles. In response, NHTSA organized the EDR Working Group, which first met in October 1998. In 1999, the Safety Board held a symposium on transportation recorders. Later that year, as a result of its special investigation on bus crashworthiness, the Safety Board made two additional EDR-related recommendations to NHTSA: one that NHTSA require school buses and motorcoaches to be equipped with EDRs (Safety Recommendation H-99-53) and one that NHTSA work with industry and other Government agencies to develop and implement standards for the on-board recording of crash data (Safety Recommendation H-99-54). In recent years, NHTSA has made progress in developing EDR data standards for light vehicles, which include passenger cars, multipurpose passenger vehicles, light trucks, and vans with a gross vehicle weight rating of 3,855 kilograms (8,500 pounds) or less. In August 2006, NHTSA published a final rule that standardizes the information EDRs collect, making EDR data retrieval easier, and that addresses the survivability requirements for EDRs based on crash testing. The final rule was amended on January 14, 2008, in response to numerous petitions for reconsideration. Based on this revised rule, compliance dates have been changed to September 1, 2012, for most light vehicles and to September 1, 2013, for vehicles manufactured in two or more stages. The new rule, however, does not address vehicles over 8,500 pounds and thus would not apply to buses or motorcoaches. NHTSA’s August 2007 Approach to Motorcoach Safety included a discussion of EDRs, stating that the agency has recently defined mandatory data elements for the voluntary installation of EDRs in light passenger vehicles. However, crash characteristics and relevant measurements for motorcoaches are different, as supported by the 2001 NHTSA EDR Working Group final report’s summary of Findings: given the differing nature of cars, vans, SUVs [sport utility vehicles], and other lightweight vehicles, compared to heavy trucks, school buses, and motorcoaches, different EDR systems may be required to meet the needs of each vehicle class. The EDR Working Group’s final report also noted the following: ·EDRs can improve highway safety for all vehicle classes by providing more accurate data for accident reconstructions, and ·U.S. and European studies have shown that the number and severity of crashes is reduced when drivers know that an on board EDR is in operation. However, NHTSA’s Approach to Motorcoach Safety also makes the seemingly contradictory statement that Safety Recommendations H-99-53 and -54 concerning EDRs do not specifically relate to changes that would have a direct or quantifiable safety benefit for motorcoach occupants. The Safety Board disagrees; the lack of useful event data associated with accident motorcoaches represents a missed opportunity to better understand crash forces, ejection dynamics, and crashworthiness. The Safety Board concludes that EDRs would provide the accurate and detailed event data necessary to better understand crash causation and to establish design requirements for motorcoach crashworthiness and occupant protection systems. The need for such information is particularly significant as EDRs become more widely used in the truck and transit industry, as evidenced at the September 2007 EDR symposium sponsored by SAE International. During the symposium, representatives from industry noted that EDR applications are being more widely used for motor carrier analysis of accidents and to support more accurate insurance underwriting and risk analysis. Also in its “Approach to Motorcoach Safety,” NHTSA states “Upon completion of SAE J2728 [Commercial Vehicle Event Data Recorders], consideration of a requirement for heavy vehicle EDR installation into motorcoaches would be appropriate. The Safety Board recognizes NHTSA’s progress in developing EDR standards for light vehicles. As a result of NHTSA’s work to date, Safety Recommendations H-99-53 and -54 are currently classified OPEN -- ACCEPTABLE RESPONSE. However, this accident again clearly illustrates the importance of this issue for heavy vehicles. The Safety Board therefore concludes that establishing EDR performance standards for motorcoaches and buses is necessary for the timely and efficient implementation of EDRs, which will, in turn, provide the data needed to develop effective occupant protection systems. The Safety Board consequently reiterates Safety Recommendations H-99-53 and -54 and urges NHTSA to actively push to complete standards work and, based on the development of standards for large motorcoaches, to require EDRs on all new motorcoaches.

From: NTSB
To: NHTSA
Date: 4/15/2004
Response: The Safety Board recognizes NHTSA's efforts in reviewing comments (67 Federal Register 63493) on event data recorders (EDRs) and participating in the EDR working groups. The Board also acknowledges NHTSA's actions to study EDRs and evaluate development of industry standards and international activities. The Board encourages NHTSA to continue its progress toward requiring (1) all school buses and motorcoaches to be equipped with EDRs and (2) standards for onboard recording of bus crash data. Pending the development and implementation of such standards and a requirement for EDRs on all school buses and motorcoaches, Safety Recommendations H-99-53 and H-99-54 are classified OPEN -- ACCEPTABLE RESPONSE.

From: NHTSA
To: NTSB
Date: 12/2/2003
Response: Letter Mail Controlled 12/10/2003 8:45:22 AM MC# 2030599 - From Dr. Jeffrey W. Runge, Administrator: On October 11,2002, NHTSA published a request for comments (67 FR 63493) on event data recorders (EDRs). The c notice asked 17 questions in four major areas. The comment period was extended to February 28, 2003 (68 FR 1508). A total of 66 parties responded. The agency is reviewing and analyzing the comments. Additionally, the Society of Automotive Engineers and the Institute of Electrical and Electronics Engineers have joined efforts to develop recommended practices on EDRs. Results of their work are to be published by the end of 2003. NHTSA is also participating on the EDR working group required by International Harmonized Research Activities. The first meeting was held on September 8-9, 2003, in Ottawa, Ontario. Since NHTSA is actively studying EDRs and evaluating development of industry standards and international activities, the agency requests that these recommendations be designated as "Closed--Acceptable Action. "

From: NTSB
To: NHTSA
Date: 2/27/2003
Response: Notation 7528: The National Transportation Safety Board (NTSB) has reviewed the National Highway Traffic Safety Administration’s (NHTSA’s) request for comment titled, “Event Data Recorders,” published in the Federal Register, Volume 67, Number 198, on October 11, 2002. The Safety Board appreciates the opportunity to comment on this important issue affecting highway safety. The Safety Board has a long history of promoting on-board recorders in all modes of transportation. In fact, the issue of automatic information recording devices for all modes of transportation has been on the Board’s “Most Wanted” list of Transportation Safety Improvements since 1997. On-board recording devices have proven themselves to be extremely valuable in the other modes of transportation, particularly aviation. The Board believes effective implementation of on-board recording in highway vehicles can have a similar, positive impact on highway safety. Accurate recorded data can provide key information to help individual accident investigations. Also, the collection of recorded data in aggregate form can offer a wealth of information when addressing important safety issues, such as air bag system effectiveness. Even further, standardization of EDR data could increase the benefit of collecting data in aggregate form. The Safety Board’s first recommendation to NHTSA regarding the on-board recording of data resulted from the 1997 NTSB Air Bag Forum. Safety Recommendation H-97-18 recommended that NHTSA work with the automobile industry to use data stored in current crash sensing and recording devices to gather better information on crash pulses and other crash parameters. The subsequent initiative by NHTSA and automobile manufacturers, such as General Motors, went beyond the Board’s expectations. The Board is further encouraged by the efforts of some members of the automobile industry to continue to expand the recording capabilities of air bag modules. As mentioned in the request for comment, the Safety Board’s most recent Safety Recommendations to NHTSA regarding on-board recorders were H-99-53 and -54. These recommendations requested that installation of EDRs be required on newly manufactured school buses and motorcoaches and that NHTSA work with industry to develop an EDR standard. For the development of a standard, the Board focused on key issues that have been critical to on-board recording standards in other modes of transportation: parameters to be recorded, data sampling rates, duration of recording, and survivability factors. The Safety Board believes NHTSA’s ongoing leadership in response to the Board’s recommendations has been invaluable to the implementation of EDRs. NHTSA’s formation of two working groups, the Event Data Recorder Working Group and the Truck and Bus Event Data Recorder Working Group, brought together a number of different manufacturers, user groups, and other stakeholders. The Board participated in both of the NHTSA EDR working groups and found that the efforts of these groups were an important first step in the effective implementation of EDRs. The Safety Board’s investigations have already benefited from the availability of on-board recorded data from such devices as engine electronic control modules. The impact that recorded data can have on an accident investigation is no more evident than in the Board’s investigation of the Sierra Trailways motorcoach accident that occurred in Canon City, Colorado, on December 21, 1999. Investigators were fortunate that the motorcoach engine’s electronic control module recorded information, though limited, that assisted the investigation. However, despite the important contribution the data made to the investigation, investigators were still left with many unanswered questions regarding the status of the vehicle systems and the actions of the driver. If the motorcoach had been equipped with an EDR that recorded the parameters recommended by the Board in H-99-54, investigators would have been able to more clearly identify the status of the vehicle and the driver’s actions, and more focused safety recommendations may have resulted. In 1998, the Safety Board issued Safety Recommendations H-98-23 and -26 to trucking industry organizations, recommending that they advise their members to equip their vehicles with on-board recording devices to gather information on both driver and vehicle operating characteristics. These recommendations focused on two issues. The first issue was the recording of driver data for the purposes of hours of service compliance, which was outside the scope of an EDR. The second issue focused on the recording of vehicle information, as with an EDR. Unfortunately, the trucking industry groups did not choose to take the recommended action, and the recommendations have been classified as “Closed-Unacceptable Action.” The Safety Board is disappointed that no action was taken for the recording of vehicle data and continues to believe the recording of data on board heavy vehicles remains an important issue. The formation this past year of the P1616 Working Group by the Institute of Electrical and Electronic Engineers, Inc. (IEEE), is another promising step in the implementation of EDRs. The Safety Board fully supports the development of a voluntary standard and Safety Board staff are participating in the working group. The Board hopes that the standard developed through IEEE will provide a framework to promote consistency and availability of EDR data for both light and heavy vehicles. The Safety Board believes EDRs continue to be a key component in the process to improve highway safety. The issues associated with EDR development and deployment will be an important part of a Topical Technical workshop (TOPTEC), being co-sponsored by the Safety Board and the Society of Automotive Engineers. The TOPTEC will focus on recorders in all modes of transportation and is expected to take place June 4-5, 2003, in Alexandria, Virginia. The Board will keep NHTSA informed as the details are finalized. We hope that NHTSA will actively participate in this effort. We appreciate the opportunity to comment on this important issue and urge NHTSA to continue pursuing the effective implementation of EDRs on highway vehicles.

From: NTSB
To: NHTSA
Date: 5/15/2001
Response: At the May 15, 2001 Board meeting addressing the NTSB’s Most Wanted List of Transportation Safety Improvements (MWL), the Board voted to place Safety Recommendations H-99-53 and H-99-54 on the Federal MWL under the issue category “Event Data Recorders.”

From: NTSB
To: NHTSA
Date: 4/18/2001
Response: The Board notes that NHTSA is in the process of developing several working groups, including an EDR group with participation from the motorcoach industry, regarding these recommendations. The Board looks forward to receiving the results of your meetings with schoolbus and motorcoach industry groups. Pending our receipt of these results and the development and implementation of the requirements and standards described, H-99-53 and -54 remain classified OPEN -- ACCEPTABLE RESPONSE.

From: NHTSA
To: NTSB
Date: 10/27/2000
Response: When NHTSA received these recommendations, we indicated to NTSB that the agency would invite the motorcoach industry to participate in the ongoing EDR working group. They accepted and attended the last meeting. Additionally, the agency indicated it would determine if there was sufficient support to form a new working group specifically targeting heavy vehicles, those associated with these recommendations. NHTSA has established a docket for the materials associated with this working group with in the Dept. of Transportation's Document Management System (DMS). Materials for this working group are found in docket NHTSA-1999-5218. In June 2000, NHTSA's Research and Development Office established a new working group specifically for truck and bus EDR's (T&B EDR). NTSB staff from the recorder and highway divisions are participating in this effort. School bus, motorcoach, and truck industries are represented, as well as aftermarket EDR suppliers. NHTSA has organized the second meeting for October 2000. Public materials are being docketed in the DOT's DMS in docket NHTSA-2000-7699. The American Trucking Associations' (ATA) Truck Maintenance Council (TMC) established a working group for EDR technologies for heavy trucks. NHTSA staff are attending ATA's-TMC working group meetings. In a related area, FMCSA is preparing a notice for comment on EDR's. NHTSA R&D will follow the comments received from this notice. 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: 4/24/2000
Response: The Safety Board believes that on-board recording devices represent an available technology that could be implemented to facilitate bus classification and data collection. On-board devices that record accident data, including crash pulses and other vehicle parameters, are now being used on highway vehicles in Europe. This recording technology has recently been introduced in the U.S. market and offers an effective means for NHTSA to gather crash pulse data in school buses and motorcoaches. The Safety Board notes that NHTSA has established an event data recorder (EDR) working group designed to facilitate the collection and utilization of collision avoidance and crashworthiness data from EDR's. We look forward to receiving the findings of the EDR working group and NHTSA's plans to mandate an EDR system. Pending further response, H-99-53 and -54 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: In 1998, NHTSA's Research and Development Office initiated a program under a working group (WG) to study event data recorders (FDR's). The WG is comprised of representatives from industry (light vehicle, heavy vehicle, and school bus), government (NTSB, NHTSA, FHWA, and academia.) The objective of the WG is to facilitate the collection and utilization of collision avoidance and crashworthiness data from on-board EDR's. The WG held four meetings over the past 15 months, discussing issues related to light and heavy vehicles as well as issues related to original equipment manufacturers and after-market EDR systems. The major focus areas of the WG have been: (1) determining the data elements both currently available from manufacturers and those needed by the users of EDR data; and (2) consideration of the legal and privacy issues related to the collection and use of EDR data. The WG has developed eight objectives for completing its fact finding mission: (1) what is the status of EDR technology?; (2) what data should be selected for recording?; (3) how should the data be collected and stored?; (4) how should the data be retrieved?; (5) who should be responsible for keeping the permanent record?; (6) who owns the data?; (7) who are the customers for EDR data; and (8) demonstration and feasibility of EDR technology. The targeted completion date for its fact finding mission is early 2001, at which time the WG plans to produce a summary report for release shortly thereafter. Specifically related to H-99-53, the WG on event data recorders will consider the list of data elements NTSB has recommended. The WG will discuss each of these data elements, including whether they currently exist, and if not, whether their availability is short-term or long-term, and how difficult it will be to collect these data and the cost associated with each. The WG has developed a list of data elements that is quite extensive and the WG will review these additional data elements for inclusion in a school bus and motorcoach EDR. Additionally, the WG will offer membership to the motorcoach community for participating in the discussion of issues related to EDR's. Currently, the WG includes school bus industry members and a member from the heavy vehicle manufacturing industry. Additionally, the WG will consider forming a subcommittee specifically geared to commercial use vehicles. NHTSA anticipates that it will need to conduct research on EDR technology. Many of the items associated with H-99-54 will be considered, in addition to the recommendations of the WG. At the completion, or in conjunction with this research, NHTSA will consider its findings along with the WG report, NTSB's recommendations on EDR's, and findings from NTSB's upcoming symposium on legal issues associated with transportation recorders, to determine what future action the agency will consider regarding EDR's for all motor vehicles, including school buses and motorcoaches. If NHTSA mandates an EDR system, these systems will need to be manufactured according to a specification requirement document, which NHTSA will also mandate. In developing this specification document, NHTSA will take into consideration the NTSB recommendations. Thank you for your commitment to highway safety. I hope that this information is helpful.

From: NTSB
To: NHTSA
Date:
Response: At the 1997 Most Wanted List of Transportation Safety Improvements Board Meeting, the Board voted to add Safety Recommendations H-97-18, M-95-6, and R-97-9 to the MWL in the issue area "Automatic Information Recording Devices." Safety Recommendations A-98-54, A-99-16, A-99-17, A-99-18, A-99-28, A-99-29, A-99-59, A-99-60, A-00-030, H-99-53, H-99-54, and R-98-30 were added at a later date.