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:

Investigate your state regulations on transportation
particularly for 15 passenger vans.
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:

File a "motor
carrier identification report [1]" with
the Federal Highway Administration
Mark their vehicles with a USDOT identification
number
Maintain an accident register

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" transport. 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.
ACA Position April 2001 Create a wish list per regulations Pursue allowable alternative vehicle language 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. CampLine articles New Federal Regulations and Safety Issues Regarding Passenger Vans [2] May 2001 Transporting Children in Vans [2] Feb. 2001 Available to ACA Professional Members - help logging in [3]

Following their investigation, NTSB made the
following safety recommendations:

To the Department of Health
and Human Services:

Require that Head Start children be transported
in vehicles built to federal school bus structural
standards or the equivalent.
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:

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.
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.
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.