2.21 School Bus Safety Program. Introduction

Transcription

1 2.21 Scool Bus Safety Program Introduction Te Motor Registration Division (MRD) of te Department of Government Services is responsible for administering all activities and legislation respecting veicles and drivers including driver licensing, veicle registration, driver examination, and igway safety. Te MRD performs inspection and enforcement activities in relation to several legislative autorities including te Higway Traffic Act, Motor Carrier Act and te Dangerous Goods Transportation Act. Tere are a significant number of regulations under te Higway Traffic Act including tose governing: veicle weigt and dimensions; ours of service; load security; carrier safety; maintenance standards; driver requirements; licensing and equipment; insurance; trip inspections; and regulations for specific veicles suc as buses and ambulances. Total expenditure for te MRD for te year ended 31 Marc 2003 was $8.4 million, consisting of $5.1 million for salaries, $1.7 million for information tecnology, $0.7 million for transportation and communication, and $0.9 million for various oter expenditures. Primary functions of te MRD igway safety program include setting driver and veicle licensing standards, and conducting programs wic enforce tose standards. Enforcement programs include suc measures as veicle inspections, commercial carrier audits, and portable and fixed weig scale operations. A large part of te igway safety program is veicle inspections. Te purpose of a veicle inspection is to ensure tat te veicle meets legislated requirements and standards for veicle safety on te Province s igways. Te primary focus of tese inspections is commercial motor veicles aving a gross veicle mass in excess of 4,500 kilograms. A commercial motor veicle includes a passenger bus, scool bus, truck, tractor and oter motor veicles designed for commercial use. Figure 1 provides information on te number of motor veicles registered in te Province. Auditor General of Newfoundland and Labrador 355

2 2.21 Scool Bus Safety Program Figure 1 Licenced Veicles by Category 30 December 2002 Licence Plate Type Veicle Classification Number of Licenced Veicles H, A Passenger veicles and motor omes 226,400 B >4,500kg Buses (primarily scool buses, some passenger buses included) 1,510 C <4,500kg Commercial (less tan 4,500 kg) 81,997 C, P >4,500kg Commercial (greater tan 4,500 kg) 7,924 M Motorcycle 5,753 T Trailer 35,511 X Construction equipment 2,769 Oter E.g. special plates, taxis, government, emergency 9,894 Source: MRD Management Information System Total 371,758 In addition to Provincially registered veicles, tere are a significant number of out-of-province commercial motor veicles wic are subject to Provincial legislation wen travelling witin te Province. Te MRD could not provide an estimate of te number of out-of-province commercial motor veicles travelling witin te Province. Scope and Objectives Te scool bus safety program administered by te Motor Registration Division provides for inspection and enforcement activities in relation to scool bus safety. We completed our review in January Te objectives of our review were to determine weter: tere were establised policies, procedures, standards and guidelines in place to adequately reflect scool bus safety processes; practices in place were adequate in addressing program objectives; and weter management receives information necessary for planning, decision making, control and ensuring compliance wit legislative responsibilities. 356 Auditor General of Newfoundland and Labrador

3 2.21 Scool Bus Safety Program Conclusions Te Motor Registration Division of te Department of Government Services is responsible for administering all activities and legislation respecting veicles and drivers including driver licensing, veicle registration, driver examination, and igway safety. Te scool bus safety program administered by te MRD provides for inspection and enforcement activities in relation to scool bus safety. Tere were 1,044 licensed scool buses in te Province at 30 September Te average age of licensed scool buses at tat time was 11 years, wit 739 or 70 % being 1993 model year or older. Tere were 205 Official Inspection Stations licensed in te Province to inspect scool buses. Of tese, 43 were operated by scool bus contractors (including 5 scool boards) wo ave a combined total of 612 scool buses (including 335 operated by scool boards) or 59% of te total 1,044 licenced scool buses at tat time. We are concerned about te ig incidence of defects identified during scool bus inspections performed by MRD staff and te types of defects being identified. All of tese defects relate to brakes, steering, mecanical and safety, and some result in buses being taken out of service. Of te 1,047 inspections performed by MRD during , 1,130 defects were identified and 172 scool buses (16% of all buses inspected) were taken out of service. Te significance of tis finding is increased given tat MRD does not routinely perform surprise inspections on scool buses. Instead, operators are given advance notice of upcoming inspections. As a result, operators are given an opportunity to identify and correct scool bus deficiencies before it is inspected. Given te extent of scool buses being taken out of service, it is likely tat, regardless of MRD s inspection efforts, tere are scool buses on te Province s igways tat do not meet te required safety standards. We note tat, altoug all scool buses are inspected by an Official Inspection Station twice a year, te MRD inspections still identify a significant number of serious defects. Tere are weaknesses in te inspection and enforcement activities administered at te MRD wic could contribute to te presence of unsafe scool buses on te Province s roads. In particular: Te scool bus inspection process is not adequately documented. Altoug te inspection forms list te items to be inspected, our review indicated tat it is not normally indicated on te form weter an inspection of eac item as been completed - only deficiencies are noted. Unlike te scool bus inspection process, commercial veicle inspections performed at Official Inspection Stations require tat eac inspection item be noted on te inspection form as accepted or rejected/deficient. Auditor General of Newfoundland and Labrador 357

4 2.21 Scool Bus Safety Program Altoug te manufacturer of te brake meters used by te MRD to assess braking efficiency on scool buses strongly recommends tat te meters be recalibrated at least every two years, tis is not done. As a result, scool buses determined by te MRD inspectors to be safe may not be. Given te precision required in using tese brake meters, it is necessary tat te equipment be accurate. Not all scool bus inspections were completed by an autorized inspection station in tat te Official Inspection Stations were not licensed at te time te inspections were completed. We found 69 scool bus inspections wic were performed by Official Inspection Stations operated by scool bus contractors wo ad not renewed teir license. Te MRD did not perform te required annual inspection for 8 of te 43 Official Inspection Stations operated by scool bus contractors for te 2003 year. For 6 of tese 8 stations, tere was also no inspection performed in Te MRD as not developed a policy and procedures manual to provide guidance to Higway Enforcement Officers relating to scool bus safety. Findings and Recommendations Scool Bus Safety Enforcement Te Higway Traffic Act outlines requirements relating to te registration and licensing of veicles, te licensing of drivers, motor veicle insurance, te rules of te road and related enforcement. Tere are a significant number of regulations under te Act. Bus Regulations under te Act specify requirements for scool buses including scool bus design, signage, colour, equipment, and oter standards. As well, te Regulations provide for te scool buses to be inspected by MRD staff. Official Inspection Station Regulations under te Act specify requirements for Official Inspection Stations tat can, upon appointment by te Minister and subject to an annual renewal certificate, inspect and issue an inspection certificate for various classes of veicles including scool buses. Information on te age of scool buses licenced in te Province as well as information relating to te inspection of scool buses by MRD is outlined in te following sections. 358 Auditor General of Newfoundland and Labrador

5 2.21 Scool Bus Safety Program 1. Age of Scool Buses Figure 2 During our review of scool bus inspection procedures, MRD staff indicated tat older scool buses pose a iger risk of deficiencies and are generally selected for more regular inspection tan newer scool buses. We used information available on te model year of scool buses licensed in te MRD registration system to analyse te age of scool buses operating on te Province s roads. Figure 2 summarizes scool buses by model year and by region. Licenced Scool Buses by Model Year 30 September 2003 Model Year Number of Buses by Region Eastern Central Western Labrador Total Cumulative Total Total % Cumulative % % 0.29% % 1.25% % 16.86% % 37.26% % 59.00% % 70.78% % 75.47% % 78.06% % 78.63% % 82.65% % 83.51% % 87.72% % 91.74% % 95.48% , % 97.01% , % 99.12% , % % Total , % Source: Scool Bus Inspection Report 30 September 2003 Auditor General of Newfoundland and Labrador 359

6 2.21 Scool Bus Safety Program As outlined in Figure 2, tere were 1,044 licensed scool buses in te Province at 30 September Details relating to tese 1,044 are as follows: Many of te licensed scool buses in te Province are quite old. Of te 1,044 scool buses, 739 or 70 % were 1993 model year or older. Of te 1,044 licensed scool buses only 128 or 12% were 2000 model year or newer; Te average age of licensed scool buses in te Province at 30 September 2003 was 11 years. Figure 3 provides information on scool bus age restrictions reported for our Province and five oter Canadian Provinces and Territories responding to an MRD survey in January Figure 3 Scool Bus Age Limit by Jurisdiction January 2003 Jurisdiction Type of limit Maximum number of years Quebec Provincial legislation 12 Alberta Municipal policies Generally 10, may extend to 15 in certain instances Newfoundland and Labrador Scool board contracts 14 Nova Scotia Scool board contracts 13 Yukon Scool board contracts 13 Ontario Scool board contracts Not specified Source: MRD Survey Results 360 Auditor General of Newfoundland and Labrador

7 2.21 Scool Bus Safety Program 2. Scool Bus Inspections Te two primary means of igway safety enforcement for scool buses are troug sceduled inspections of scool buses by igway enforcement officers and troug required semi-annual inspection of scool buses at Official Inspection Stations. As well, MRD staff are required to perform annual inspections of Official Inspection Stations. Te Official Inspection Station Regulations under te Higway Traffic Act specify requirements for Official Inspection Stations including an autorized inspection mecanic, equipment, enclosed space size and oter conditions specified in an Official Inspection Station Manual. A scedule to te Regulations states tat inspections for scool buses are required eac July and December from te age of 6 monts. As of October 2003, tere were 205 Official Inspection Stations licensed in te Province to inspect scool buses. Of tese, 43 were operated by scool bus contractors (including 5 scool boards) wo ad a combined total of 612 buses (including 335 operated by scool boards) or 59% of te total 1,044 licenced buses at tat time. (a) Sampling Process In 1997, an official wit te MRD s National Safety Code office designed a process for selecting scool buses for inspection based upon operator fleet size. Te process uses a two step approac Auditor General of Newfoundland and Labrador 361

8 2.21 Scool Bus Safety Program wic, based upon te scool bus fleet size of a contractor, specifies te required number of annual inspection visits and related sample size range for eac visit. Te sample size indicated in te model can be increased, if in te judgement of te inspectors, poor results ave been encountered in initial bus samples tested. Te scool bus operators are contacted te day before planned inspections and are informed wic scool buses will be inspected. Tis raises an issue wit respect to te predictability of inspections in tat providing advance notice would give te operator enoug time to correct deficiencies on te scool buses identified for inspection. Once a scool bus as been inspected in te first visit of a scool year, tat scool bus would not normally be subject to a planned inspection during a second visit later in te scool year. In addition, no surprise inspections are used to supplement tis effort. However, surprise inspections may be used in response to complaints or at a road-side ceck. MRD officials indicate tat due to te fact tat tere can be a number of drivers and scool bus runs affected during tis inspection activity, tey feel te current metod is necessary. It was also indicated tat additional inspections can occur as a result of road cecks, complaints or a Higway Enforcement Officer s observation wile travelling on te road. (b) Documentation of Inspection Procedures Tere is no policy and procedure manual in place to provide guidance to Higway Enforcement Officers in conducting scool bus inspections. Te absence of formal direction and guidance can lead to inconsistencies in te conduct of scool bus inspections by MRD staff situated in te four regions trougout te Province. Scool bus inspections are performed using a prescribed scool bus inspection report wic lists a series of 60 inspection items tat are grouped into 11 categories. Te inspection reports once completed are forwarded to MRD s National Safety Code Office were tey are input by staff into te Management Information System. We reviewed a sample of 20 recent inspection forms contained in 20 different scool bus contractor files to determine weter inspection procedures were appropriately performed and documented. 362 Auditor General of Newfoundland and Labrador

9 2.21 Scool Bus Safety Program Wile te items to be inspected are listed on te form, our review indicated tat it is not normally indicated on te form weter an inspection of eac item as been completed - only deficiencies are noted. Consequently, te complete scool bus inspection process is not adequately documented on te forms provided. Unlike te scool bus inspection process, commercial veicle inspections performed at Official Inspection Stations require tat eac inspection item be noted on te inspection form as accepted or rejected/deficient. Te scool bus inspection forms ave been in use for some time. Officials indicate tat some procedures are regularly performed during inspections but are not included on te inspection form - e.g. cecks of te bus orn and te cross-over arm at te front of te bus. Tere are also a number of inspection items listed on te inspection form tat are not regularly cecked - e.g. te emergency stop and tire cains. As well, we were informed tat wile das and instruments is listed as an auxiliary inspection item on te bus inspection report, cecks are not consistently performed to assess weter te speedometer on te scool bus under inspection is working properly. Once te scool bus inspection reports are completed, tey are forwarded to MRD s National Safety Code Office were staff input tem into te Management Information System. Te completed inspection forms are not submitted to te Higway Enforcement Officer s supervisor for review, nor are tey signed as reviewed and approved by an official of MRD. Suc a review would ensure tat te inspection forms are completed in a consistent, appropriate manner and would also serve as a supervisory tool. (c) Results of Scool Bus Inspections Te Veicle Regulations require tat all scool buses be inspected by an Official Inspection Station twice a year. In addition, MRD staff are required to visit eac operator for at least one annual scool bus inspection visit, wit larger fleets requiring up to four annual inspection visits. Given tese requirements, a low level of veicle deficiencies would be expected. However, reports provided by MRD staff for te fiscal year ended 31 Marc 2003 sow tat of 1,047 scool bus inspections completed by MRD staff during te period, 1,130 defects were identified. Furtermore, in 172 instances or 16 % of all scool buses inspections, deficiencies identified resulted in te veicle being taken out of service until te deficiencies could be Auditor General of Newfoundland and Labrador 363

10 2.21 Scool Bus Safety Program corrected. One explanation offered by an official of MRD as to wy results would not ave been better is te older age of many of te veicles. Anoter official indicated tat operators say te late notice of scool bus contract awards by te scool boards contribute to poor inspection results in tat tey don t ave sufficient time to get te buses in te proper working order. We are concerned about te ig incidence of defects identified during scool bus inspections performed by MRD staff and te types of defects being identified. All of tese defects relate to brakes, steering, mecanical and safety, and some result in scool buses being taken out of service. Te significance of te defects identified during MRD inspections is increased given tat MRD does not routinely perform surprise inspections on scool buses. Instead, operators are given advance notice of upcoming inspections. As a result, operators are given an opportunity to identify and correct scool bus deficiencies before it is inspected. Given te extent of scool buses being taken out of service, it is likely tat, regardless of MRD s inspection efforts, tere are scool buses on te Province s igways tat do not meet te required safety standards. We note tat, altoug all scool buses are inspected by an Official Inspection Station twice a year, te MRD inspections still identify a significant number of serious defects. Figure 4 Figure 4 outlines information on bus inspection statistics for te year ended 31 Marc Scool Bus Inspection Statistics Year Ended 31 Marc 2003 # of Buses September 2003 Region Inspections Bus Taken Out of Service Total Defects Type of Defect Brakes Steering Mecanical Safety 579 Eastern Central Western Labrador ,044 Total 1, , Source: Montly Inspection Statistics report - Marc Auditor General of Newfoundland and Labrador

11 2.21 Scool Bus Safety Program MRD officials indicated tat, in most instances, tere is no followup visit by Higway Enforcement Officers to ensure tat te defects noted ave been repaired. Instead, if an inspection form is returned containing a certification from a representative of te scool bus operator tat te repair as been made, ten no followup action would normally be taken. MRD tracks te required follow-up troug te MRD Management Information system. In te event a certified inspection form is not returned, MRD officials will take follow-up action. (d) Brake Inspection Procedures Tere is an area on te inspection form tat provides for brake tests to be performed. MRD staff perform tests of a veicle s braking efficiency using a specially designed brake meter. Te scool bus is accelerated to a speed of approximately 30 kilometres per our and ten te brakes are firmly applied. As a result, te brake meter registers an amount for bot braking efficiency and stopping distance. In practice, scool buses not acieving a 65% efficiency rating after 3 attempts in te brake test are placed out of service until te operator inspects te brake system and certifies tat required brake repairs ave been made. Officials indicate tat te 65% efficiency rating is an MRD policy tat ad been researced wit te meter manufacturer and after considering te general provisions under te Higway Traffic Act tat allow a veicle wic is deemed unsafe to be placed out of service. As a result of te precision required in using tis brake meter, it is necessary tat te equipment is accurate. Altoug te manufacturer strongly recommends tat te meter be recalibrated at least every two years, tis is not done. As a result, scool buses determined to be safe may not be. We requested information on maintenance of te meters; owever, maintenance records could not be located. We looked at two meters at te Mount Pearl office and were informed by MRD officials tat tese meters ad not been calibrated in te last two years. In one instance, te certificate of calibration retained wit te meter was dated May 1999, wile documentation relating to te oter meter indicated tat it was last calibrated in January Staff provided a transmittal document related to te second meter dated January 2001 wic suggested it was recalibrated at tat time and sould ave been recalibrated in January 2003; owever, it wasn t. Auditor General of Newfoundland and Labrador 365

12 2.21 Scool Bus Safety Program Upon follow-up wit an official of MRD, we were informed tat maintenance records are not available and tat a process will be put in place to ave all te brake meters in use sent for recalibration in te near future. A staff member from te National Safety Code office as recently been assigned tis task as well as te responsibility to keep records of recalibration for te meters so tat future requirements can be met. We were informed tere were tree brake meters at te Mount Pearl office; owever, one could not be located. Tis brake meter cost approximately $800 and a number of years ago, it was sent to a Government department to ave a protective box made for it. Te meter was not returned and could not readily be accounted for. Effectively, tis meter as not been available for use for a number of years. We were informed tat officials would follow up on tis matter. (e) Inconsistency in enforcement Higway Enforcement Officers ave a continuum of enforcement options available to tem in dealing wit instances of noncompliance wit autorities identified during veicle inspections. Tese include a verbal warning, a written warning, or a ticket summons. We found tat tese penalties are not consistently applied by Higway Enforcement Officers. For example, we were informed tat Higway Enforcement Officers working at te Mount Pearl office do not issue ticket summonses for scool bus inspections in a comparable manner as tey would for oter commercial veicles. We were informed tat Higway Enforcement Officers at oter regions do issue ticket summonses during scool bus inspections. As a result, tere is inconsistency of enforcement for all commercial veicles subject to inspections by Higway Enforcement Officers trougout te Province. Official Inspection Stations Official Inspection Station Regulations under te Higway Traffic Act require tat scool buses be inspected eac July and December. In practice, MRD does not enforce tis requirement for te mont of July, as long as te scool buses are inspected prior to being used for scool transportation at te start of eac scool year in September. Te required inspections must be completed by an Official Inspection Station appointed under te Regulations to inspect scool buses. 366 Auditor General of Newfoundland and Labrador

13 2.21 Scool Bus Safety Program We reviewed a listing of Official Inspection Stations generated from te MRD Management Information System on 21 October Te listing included 205 Official Inspection Stations in te Province permitted to inspect scool buses. Of tese 205 Official Inspection Stations, 43 or 21% were operated by scool bus contractors (including 5 scool boards) wo ave a combined total of 612 buses (including 335 operated by scool boards) or 59% of te total 1,044 licenced buses at tat time. Tis means tat tese contractors perform inspections on teir own buses. Officials of MRD indicated tat from 1 April 2002 to 31 January 2004, tere were 4 instances in wic carges were laid by MRD staff related to improper scool bus inspections performed at Official Inspection Stations. Six of te 43 Official Inspection Stations operated by scool bus contractors completed 69 veicle safety inspections for teir own scool buses prior to renewing teir certificate of appointment under te Official Inspection Station Regulations. As a result of tese Official Inspection Stations not being licensed at te time te inspections were completed, te inspections were not completed by an autorized inspection station. Te inspection reports once completed are forwarded to MRD s National Safety Code Office were tey are input by staff into a stand alone Official Inspection Station Information System. Te inspection forms are not submitted to te Higway Enforcement Officer s supervisor for review, nor are tey signed to evidence review and approval. Annual Reviews of Inspection Stations All Official Inspection Stations are required to be reviewed eac year by MRD staff. Our review indicated tat for 8 (19%) of te 43 Official Inspection Stations operated by scool bus contractors, te required annual inspection for te 2003 year was not completed. We also noted tat for 6 of tose 8 inspection stations were te 2003 annual inspection ad not been done, te required annual inspections ad not been completed in We reviewed files for 20 of te 43 operator-owned Official Inspection Stations. Altoug te computerized Official Inspection Stations reports indicated tat no annual review for te 2003 year ad been performed for 9 of te 20 stations, in 1 instance an inspection ad been performed but not recorded in te system. We selected an additional 11 files were inspections ad been sown as performed. Our review of tese files indicated te following: Auditor General of Newfoundland and Labrador 367

14 2.21 Scool Bus Safety Program in 1 instance not all inspection items were cecked as accepted or rejected on te inspection form as required; in 5 instances te section related to recording autorized inspection mecanics ad not been completed; and in 1 instance tere was no follow-up on an inspection item wic was deficient. We were informed tat te item, a tire dept gauge, was not considered significant enoug for follow-up. During discussions wit MRD officials it was determined tat tere is no process in place to produce overall inspection statistics and ensure tat all inspections were performed as required. Furtermore, tere is no specific procedure to ensure tat a station tat ad not been inspected in a given year was priorized for inspection in te subsequent year. Unfavourable Carrier Safety Ratings MRD as adopted and maintains a computerized motor carrier safety rating system under te National Safety Code for commercial motor carriers operating witin te Province. For eac carrier, te system records information in a motor carrier profile tat includes information on items suc as reportable accidents, commercial veicle inspections, motor carrier facility audits and convictions under various governing legislation related to te operation of motor veicles. Information contained in te motor carrier profile is used to determine a safety rating for te motor carrier. Te 4 safety rating categories are satisfactory audited, satisfactory unaudited, conditional and unsatisfactory. From a review of motor carrier ratings provided in January 2004, we identified tat 5 motor carriers were operating wit a conditional safety rating. Tese operators ave a total of 136 licenced scool buses or about 13 % of all licenced scool buses in te Province. Tere were no carriers operating scool buses tat ad been assigned an unsatisfactory rating. Te conditional safety rating is assigned to motor carriers tat ave: demonstrated deficiencies in safe operation, compliance wit applicable igway safety legislation and National Safety Code standards or te results of a facility audit; or are reapplying for a safety fitness certificate after teir first safety certificate as been revoked by MRD. 368 Auditor General of Newfoundland and Labrador

15 2.21 Scool Bus Safety Program Tese 5 scool bus operators ad deficiencies wit respect to veicle operation and mecanical condition. As well, tey ad failed MRD facility audits, i.e. an inspection of te operator s facility, including a review of te operator s records. If tese operators continue wit tese deficiencies it may lead to an unsatisfactory motor carrier rating and result in te cancellation of te operators licences. Recommendations Te Department of Government Services sould: ensure tat eac inspection item be noted on te inspection form as accepted or rejected/deficient; ensure tat brake meters used by te MRD to assess braking efficiency on scool buses be recalibrated at least every two years as recommended by te manufacturer; address te issue of scool bus inspections being performed by unlicensed inspection stations; perform inspections of Official Inspection Stations as required; and develop a policy and procedures manual to provide guidance to Higway Enforcement Officers relating to scool bus safety. Department s Response Wile we appreciate te torougness of your review, we differ on te substantive matter of weter scool buses are meeting safety standards. Your report states tat...tere were 172 instances or 16% were deficiencies identified resulted in te veicle being taken off te road until te deficiencies could be corrected. Te fact tat veicles are being inspected at a minimum of tree times per year and taken out of service (OOS) until deficiencies are corrected is evidence of te ig level of safety standards to wic tese veicles are subjected. Tere is zero tolerance wit respect to most defects, wic may not necessarily imply tat tey represent a risk to passenger safety. Tis is furter demonstrated by te fact tat, in 2003, none of te 33 accidents reported were as a result of mecanical failure (see appendix). In fact, te accident rate for scool buses as a class of veicles was only 1.9%, significantly lower tan for te classes of veicle referenced and, specifically, less tan alf te rate for ligt passenger veicles and less tan a tird of te public passenger bus rate. Auditor General of Newfoundland and Labrador 369

16 2.21 Scool Bus Safety Program Your report as noted five recommendations: Te Department of Government Services sould: ensure tat eac inspection item be noted on te inspection form as accepted or rejected/deficient. Te Department is of te view tat te practice of exception reporting or only noting deficiencies requiring correction is an appropriate approac to igligting te most important information - te deficiencies encountered during te inspection. Tere is a systematic approac to te inspection of scool buses, starting wit driver qualifications, veicle documentation (registration, insurance, body year, etc.), and moving from inspection of interior components, te exterior of te bus and, lastly, underneat te bus. All items are cecked according to tis systematic approac in wic enforcement officers are well versed. Te current process easily identifies tose areas requiring attention. ensure te brake meters used by te MRD to assess braking efficiency on scool buses be recalibrated at least every two years as recommended by te manufacturer; Te Department is in agreement wit tis recommendation and MRD as already introduced a program to ave tese meters recalibrated on a regular basis. All of te brake meters used by MRD ave now been recalibrated. address te issues of scool bus inspections being performed by unlicensed inspection stations; Te Department is in agreement tat all Official Inspection Station license renewals sould be conducted on a timely basis to avoid gaps in license validity. It sould be noted, owever, tat te cases cited were stations wic ad originally been certified, were well aware of te inspection requirements outlined in te OIS manual, and te inspections were conducted by qualified personnel. Tis was a question of a temporary lapse of a license renewal as opposed to a never licensed facility performing inspections. 370 Auditor General of Newfoundland and Labrador

17 2.21 Scool Bus Safety Program perform inspections of Official Inspection Stations as required; Te Department is in agreement wit tis recommendation and will take measures witin available resources to ensure tat inspections of Official Inspections Stations are conducted in a timely manner. develop a policy and procedures manual to provide guidance to Higway Enforcement Officers relating to scool bus safety. Te Department notes tat tere is already proper and very detailed documentation wit respect to te requirements for scool bus inspections and te inspection and reporting procedures are well understood by enforcement personnel. A detailed Official Inspection Station (OIS) manual outlines all bus/scool bus areas to be inspected and provides comments on eac area: power train, suspension, ydraulic brake systems, air brake system, steering, instruments & auxiliary equipment, lamps, electrical system, body, tires and weels. It sould also be noted tat te OIS manual outlines te equipment requirements for official inspection stations, duties of inspection station operators, duties of autorized inspection mecanics, duties of official inspection stations performing inspection on salvage veicles, inspection procedure, out of service criteria and affixing te inspection sticker. Tis manual as separate sections on cars, ligt trucks and vans; trailer and semi-trailer; salvage veicles; truck and truck-tractor; bus/scool bus; and disabled passenger veicle. In addition to tis detailed documentation, te vast majority of existing HEO s are mecanics by trade and all are very experienced. Any new HEO s ired are required to be qualified mecanics. HEO s are properly trained and know wat is required to properly conduct inspections. To develop a separate policy and procedures manual around tese requirements would be a duplication of effort and may cause uncertainty over wic document takes precedence in te case of unintentional conflicts. Auditor General of Newfoundland and Labrador 371

18 2.21 Scool Bus Safety Program Appendix Scool Bus Accident Statistics /03 Summary of Accident Reports April 01, 2002 to Marc 31, 2003 Total Accidents 33 HumanError: Bus Driver Oter Driver Student Error 1 MecanicalFailure 0 Unknown 1 Calender Year end December 2003 *Note: tese statistics are taken from different sources. Te difference in numbers is a result of calendar year versus fiscal year time frames. Te rate for scool bus accidents is less tan alf te rate for ligt passenger veicles and less tan a tird of te public passenger bus rate. As noted above, driver error is te most prevalent factor in tese accidents Veicle # ofaccidents # of Ve. Regist. % Ligt passenger veicles 9, , Trucks< 4,500kgs 2,335 83, Trucks> 4,500kgs 215 8, PublicPassenger bus Scool bus* 31 1, Auditor General of Newfoundland and Labrador