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.
States are translating the National Transportation
Safety Board (NTSB) position in a variety of ways.
As such, camp directors should do the following:
- Investigate your state regulations on transportation
particularly for 15 passenger vans.
- Contact your insurance broker to determine
Federal Motor Carrier
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
- Create a wish list per regulations
- Pursue allowable alternative vehicle
- Clarify non-conforming and conforming
- Educate members to educate themselves
on state laws
- Darrow Milgrim (Public Policy Committee
member) will monitor this issue.