Transportation at Camp 2001 Archives

Reminder of Transportation
Issues Shared Spring 2001

(November 11, 2001)

Safety Requirements for Operators of Small Passenger-Carrying
Commercial Motor Vehicle used in Interstate Commerce
does not necessarily relate to the camp community.

National Transportation
Safety Board

States are translating the National Transportation
Safety Board (NTSB) position in a variety of ways.
As such, camp directors should do the following:

  1. Investigate your state regulations on transportation
    particularly for 15 passenger vans.
  2. Contact your insurance broker to determine
    insurance requirements.

Federal Motor Carrier
Safety Regulations

Effective April 13, 2001, this regulation requires
that anyone operating commercial motor vehicles
used to transport 9 to 15 passengers to:

This regulation does apply to camps.  Please
read the CampLine articles below for more information.

In the 1970's,
the U.S. Department of Transportation enacted
Federal regulations containing bus occupant
crash protection standards to safeguard
children being transported to and from school
or school-related activities.  The
Federal Motor Vehicle Safety Standards (FMVSS),
which are contained in 49 Code of Federal
Regulations (CFR 571), require that school
buses have body joint strength, roof rollover
protection, and energy-absorbing seats that
specialty buses, vans, or motorcoaches are
not required to have.  Requiring the
use of school buses that conform with federal
standards is the purview of the states.
Most states require that children only be
transported to and from school on buses
meeting federal school bus crashworthiness
standards.  However, despite National
Highway Traffic Safety Administration (NHTSA)
recommendations and interpretations to the
contrary, some states either allow or do
not prohibit the use of nonconforming buses
for school-related activities, Head Start
programs, child care facilities, and "for-hire"

MFVSS definitions (CFR 571.3) indicate
that bus means a motor vehicle designed
to carry more than 10 persons, and school
bus means a bus that carries students to
or from school or school-related activities.

As a result of a special investigation
involving "nonconforming buses,"
the National Transportation Safety Board
(NTSB) is firmly convinced that the best
way to maximize pupil transportation safety
is to require the use of school buses or
buses built to equivalent occupant crash
protection standards. According to the Safety
Board, when States and various school systems
allow the transportation of children in
vehicles not meeting federal school bus
construction standards, the federal intent
of protecting school children is undermined. 
NTSB concluded that State laws regarding
student transportation do not provide uniform
safety. The lack of federal and state legislation
regarding Head Start and day care transportation
allows for situations in which students
may be transported in a vehicle that does
not provide the maximum available protection
during accidents.


April 2001

  • Create a wish list per regulations
  • Pursue allowable alternative vehicle
  • Clarify non-conforming and conforming
    vehicle language
  • Educate members to educate themselves
    on state laws
  • Darrow Milgrim (Public Policy Committee
    member) will monitor this issue.


Available to ACA Professional
Members - help
logging in

Following their investigation, NTSB made the
following safety recommendations:

To the Department of Health
and Human Services:

  1. Require that Head Start children be transported
    in vehicles built to federal school bus structural
    standards or the equivalent.
  2. Incorporate and mandate the use of the guidelines
    from the National Highway Traffic Safety Administration's
    Guideline for the Safe Transportation of Pre-school
    Age Children in School Buses into the rules
    for the transportation of Head Start children.

To the Governors of the 50 states
and the Mayor of the District of Columbia:

  1. Require that all vehicles carrying more than
    10 passengers (buses) and transporting children
    to and from school and school-related activities,
    including, but not limited to Head Start programs
    and day care centers, meet the school bus structural
    standards or the equivalent as set forth in
    49 Code of Federal Regulations Part 571.
  2. Review your state and local laws and, if applicable,
    revise to eliminate any exclusions or exemptions
    pertaining to the use of age-appropriate restraints
    in all seat belt-equipped vehicles carrying
    more than 10 passengers (buses) and transporting
    school children.
  3. Adopt the National Highway Traffic Safety
    Administration's Guideline for the Safe Transport
    of Pre-School Age Children in School Buses and,
    distribute the guidelines and encourage their
    implementation by all operators of school buses
    that transport preschool-age children to and
    from school or school related activities.