Attached for inclusion in Docket No. NHTSA is a National Highway Traffic

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1 US. Deprtment of Trnsporttion Ntionl Highwy Trffic Sfety Administrtion 1 Docket Submission: Docket No. NHTSA Subject NHTSA Action Pln for 15-Pssenger Vn Sfety Dte From Brbr iigin$&&&r Acting Directo Office of Plnning nd Consumer tndrds, NVS-130 Reply to Attn of NOV (13 To U.S. Deprtment of Trnsporttion Docket Mngement System Docket Ns NHTSA nr~: Jckie AV L Glssmn F- Chief Counsel Attched for inclusion in Docket No. NHTSA is Ntionl Highwy Trffic Sfety Administrtion (NHTSA) pln, entitled NHTSA Action Pln for 15-Pssenger Vn Sfety. Attchment # - SAFETY BELTS SAVE LIVES

2 NHTSA Action Pln for 15-Pssenger Vn Sfety Pge 1 of9 NHTSA Action Pln for 15-Pssenger Vn Sfety September 2003 Introduction There is growing concern regrding the crsh involvement nd sfety of 15-pssenger vns nd the resulting injuries nd ftlities. There were pproximtely 500,000 registered 15-pssenger vns in 2001, n increse of over 280 percent since Between 1990 nd 2001, 1, pssenger vns were involved in ftl crshes tht resulted in 1,003 ftlities. Six hundred nd one (601) of the crshes were single vehicle crshes, of which 316 rolled over. Hevily loded 15-pssenger vns re prticulrly susceptible to rollover. Confounding this problem, the rte of sfety belt use mong occupnts of lrge vns involved in ftl crshes is very low compred to other types of vehicles. While this pln focuses on 15-pssenger vns, the ctions identified lso relte to 12-pssenger vns which re similr to vns configured for 15 pssengers in terms of design, hndling chrcteristics, nd sfety problems. NHTSA defines vehicles designed to crry more thn 10 persons s buses for purposes of the Federl Motor Vehicle Sfety Stndrds (FMVSS). Bc kround Crshes involving lrge vns, especilly rollover crshes nd the resulting ftlities nd injuries, hve rised the level of public nd NHTSA ttention to this issue. In 2001, 130 occupnts of 15-pssenger vns died in crshes involving these vehicles. Single vehicle crshes represented 42 percent of ftl crshes. Eighty-seven percent of people who died in single vehicle rollovers of these vehicles were not wering sfety belts. Between 1990 nd 2001, 15-pssenger vns represented.25 percent of the pssenger vehicle fleet,.26 percent of pssenger vehicles involved in ftl crshes, nd.25 percent of ll pssenger vehicle occupnt deths. During this time, 8 percent of belted occupnts in these vehicles in ftl single vehicle crshes were killed, compred to 22 percent of unbelted occupnts. In October 2002, NHTSA mngement briefed stff from the Sente Commerce, Science nd Trnsporttion Committee nd stff from the office of Sentor Olympi Snowe (R- Mine) on NHTSA ctions pertinent to the sfety of these vehicles in the res of reserch nd consumer informtion. A rollover crsh in Mine killed 14 occupnts of vn in In Mrch 2003, Sentor Snowe introduced S.717 to ddress 15-pssenger vn sfety. A similr bill ws introduced in the House, H.R. 1641, by Representtive Mrk Udll. Sentor Snowe s bill clled on NHTSA to develop dynmic test to ssess http ://m.nhts. dot. gov/hot/ 1 SPssVns/ 1 Sps svn. html 11 /17/2003

3 NHTSA Action Pln for 15-Pssenger Vn Sfety Pge 2 of 9 rollover risk for 15-pssenger vns nd to issue the results s consumer informtion; to test these vehicles t different loding levels s prt of the New Cr Assessment Progrm (NCAP); to test stbility control nd other technologies to ssess effectiveness in reducing rollovers; nd clled on the Federl Motor Crrier Sfety Administrtion (FMCSA) to pply Federl motor crrier sfety regultions (FMCSR) to the commercil opertion of 15-pssenger vns. Since November 2002, the Ntionl Trnsporttion Sfety Bord (NTSB) hs issued nine recommendtions tht relte to these vehicles. These recommendtions encompss vehicle countermesures, consumer informtion, driver progrms, working with FMCSA, nd cooperting with outside groups to promote the sfety of these vehicles. This Pln references these recommendtions under specific ction res. The Sente Commerce, Science nd Trnsporttion Committee is considering provisions ddressing these vehicles for the reuthoriztion of the highwy progrms, nmely: issue finl regultion no lter thn September 30, 2004 to include 15-pssenger vns up to 10,000 pounds gross vehicle weight rting (GVWR) in the dynmic rollover testing progrm mndted by the Trnsporttion Recll Enhncement, Accountbility, nd Documenttion (TREAD) Act; require 15-pssenger vns up to 10,000 pounds GVWR to comply with ll existing nd prospective FMVSS for occupnt protection nd vehicle crsh voidnce; by September 30, 2004 include vehicles up to 10,000 GVWR in the NCAP rollover resistnce test progrm, t vrious lod conditions; require the FMCSA to implement finl rule requiring the ppliction of the FMCSR to 15-pssenger vns used for commercil purposes; nd require NHTSA to evlute nd test, in conjunction with vn mnufcturers, the potentil of technologicl systems (prticulrly electronic stbility control (ESC) systems nd rer-view mirror-bsed rollover wrning systems) to ssist drivers in mintining control of the vns. NHTSA hs initited ctions in the pst nd is implementing new strtegies to ddress the sfety of these vehicles. This Pln describes pst, current, nd plnned ctivities in the res of Problem Identifiction, Consumer Informtion nd Eduction, Countermesure Reserch, nd Ve hicle Countermesures. NHTSA Actions nd Plns 1. Problem Identifiction Prior Reserch: A 2001 NHTSA study included three different nlyses ddressing whether 15- pssenger vns, especilly loded 1 5-pssenger vns, re unusully susceptible to rollover. The results from Stte Dt System nlyses indicted tht the rollover propensity for 15- pssenger vns ws slightly less thn for the overll light truck nd vn (LTV) group, tht rollover propensity increses with the occupncy level of the 15- pssenger vn, nd tht higher occupncy levels cused crsh severity to increse from property dmge only (PDO) to injury nd ftl crshes. Anlysis of stte dt lso found tht rollover rtes for 15-pssenger vns did not show ny significnt correltion to driver ge nd tht ftlities occurred disproportiontely to rer set occupnts, while injuries were proportionl between front nd rer set occupnts. An ssessment lso ws 5PssVndl 5pssvn.html 11/17/2003

4 NHTSA Action Pln for 15-Pssenger Vn Sfety Pge 3 of 9 conducted compring the sttic stbility fctor (SSF) of 15- pssenger vn to 7- pssenger full size vn nd minivn when lightly loded (driver only) nd fully loded to GVWR. This nlysis found tht the SSF for ll three vehicles decresed (higher likelihood of rollover) when fully loded. Bsed on limited number of crshes, hevily loded 15- pssenger vns pper to hve higher rollover rte compred to when these vehicles re lightly loded (with fewer occupnts). The gency lso performed computer modeling to ssess the hndling of these vehicles. The modeling predicted understeer for 15-pssenger vns when lightly loded, similr to minivn behvior. However, when hevily loded, it predicted understeer t low lterl ccelertion, but oversteer t higher lterl ccelertions. This trnsition to oversteer my pose sfety problems for drivers who re unfmilir with this chrcteristic. Loding 15- pssenger vns to gross vehicle weight (GVW) lso moved center of grvity rerwrd, incresing verticl lod on rer tires. Current nd Plnned NHTSA nlyses for problem identifiction: Assessment of Crshes, Ftlities, nd lnjuries in 15-Pssenger Vns: The Ntionl Center for Sttistics nd Anlysis (NCSA) is updting the crsh dt nlysis portion of the 2001 work. The study is tking comprehensive pproch to nlyzing the sfety of 15-pssenger vns in recent crsh dt. The nlysis is evluting the experience of 15- pssenger vns in ftl crshes s compred to other vehicle types nd the experience of 15-pssenger vns in the Stte Dt System. A report on these results will be relesed in conjunction with Consumer Advisory (See Consumer Informtion section). Complete nlysis nd gency review September 2003 Relese report October 2003 Survey Tire Pressure nd Condition in the 12- nd 15-Pssenger Vn Fleet nd Anlyze the Role of Tires in Rollover Custion: As prt of NHTSA s development of long-term performnce requirements for tire pressure-monitoring systems, NTSB recommends (August 2003) NHTSA dopt more stringent detection stndrds thn 25 or 30 percent below mnufcturer-recommended levels. This recommendtion is bsed on the NTSB s view tht pressures t those levels my hve n dverse effect on the hndling of vehicles, such s 12- nd 15-pssenger vns. Work is currently being conducted t the NHTSA Vehicle Reserch nd Test Center (VRTC) on the reltionship of tire pressure in front nd rer tires, loding conditions, nd hndling for 15-pssenger vn (see Countermesure Reserch section for detil). The gency believes tht more informtion is needed on the level of tire pressure under-infltion nd tire wer conditions for 15- pssenger vns in use for potentil utiliztion in consumer informtion, vehicle solutions, or other ctions. To this end, NCSA will conduct study, bsed on methods used in recent light vehicle TPMS survey, to collect tire pressure nd condition informtion on this clss of vehicle. In-house nlysis lso will be done to exmine the involvement of tires in rollover crsh dt. In-house nlysis of rollover crsh dt nd tires 2003-Jnury 2004 Complete tire pressure nd condition survey Publish results of in-house nlysis nd survey October June 2004 July /17/2003

5 NHTSA Action Pln for 15-Pssenger Vn Sfety Pge 4 of 9 Crsh Mechnisms in 72- nd 75-Pssenger Vns: More informtion is needed on wht hppens in crshes involving these vehicles to help formulte potentil vehicle solutions. NHTSA crsh dt will be nlyzed for informtion on crsh dynmics nd injury mechnisms to inform decisions on future ctions. Complete nlysis My 2004 Issue finl report June 2004 Assess the Definition nd Clssifiction of this Vehicle Type: NTSB recommendtion H clls for NHTSA, in coopertion with the FMCSA, to revise it's definitions of buses nd commercil motor vehicles to pply consistently to 12- nd 15-pssenger vns, tking into ccount the unique operting chrcteristics nd multiple functions of these vns. NHTSA will cooperte with the FMCSA to revise its definitions of buses tht re used in interstte commerce. Both gencies hve ssigned stff to work jointly in ssessing the definitions nd how best to revise them. As n djunct to this effort, n nlysis is plnned to identify how this type of vehicle is clssified t the stte nd other jurisdictionl levels. In some cses, legl loopholes exist t the stte level s result of clssifying this type of vehicle s bus (for exmple, exemption from lws requiring use of child restrints). The output of this nlysis will be list of the lws in the 50 sttes nd the District of Columbi tht pply to this clss of vehicle nd n ssessment of the implictions of these clssifictions nd lws on sfety nd recommendtion on how to proceed regrding the development of uniform clssifiction. Complete study of stte lws April 2004 Issue finl report July 2004 Develop Informtion on the Ownership nd Usge of These Vehicles: Little is known bout the pproximtely 500,000 vehicles of this type on the rod, nmely: who owns them, who drives them, who uses them, for wht purposes, their frequency of use nd whether sfety belt use is higher or lower with certin popultions using this type of vehicle. NHTSA will work with the Americn Assocition of Motor Vehicle Administrtors to determine if this informtion is vilble nd not cost-prohibitive to collect, s well s not in violtion of privcy regultions. In ddition, informtion is needed on whether certin groups (e.g., church, school, college, militry, government, migrnt workers) re over or under-represented in crshes, injuries nd ftlities, especilly in rollover crshes. This informtion is needed in order to develop effective, trgeted progrms for the relevnt groups. Complete study My 2004 Issue finl report July 2004 II. Consumer Informtion nd Eduction Prior NHTSA Actions: In April 2001, NHTSA issued Reserch Note nd Consumer Advisory on 15-pssenger vn sfety. The Reserch Note covered the findings from the three prt study conducted by NHTSA (described in the Problem Identifiction section bove). The April 2001 Consumer Advisory informed the public tht 15-pssenger vns should be operted by http :// gov/hot/ 1 5PssVns/l 5pssvn.html 1 1/17/2003

6 NHTSA Action Pln for 15-Pssenger Vn Sfety Pge 5 of 9 "experienced drivers" nd noted tht commercil driver's license (CDL) is required to trnsport 16 or more people for commercil purposes. The Consumer Advisory urged drivers to be fmilir with the hndling of fully loded 15-pssenger vns nd urged institutions using 15-pssenger vns to require sfety belt use t ll times. In April 2002, Dr. Runge reissued the 2001 Consumer Advisory t news conference, together with flyer on 15-pssenger vn sfety nd hng tg to leve in 15-pssenger vns tht provided informtion on the risk of rollover, tips for preventing rollover, buckling up for sfety nd other tips for sfe driving. NHTSAs policy is tht pre-school nd school ged children should not be trnsported in these vehicles due to sfety concerns. In Februry 2002, just prior to NHTSA reissuing the 2001 Consumer Advisory on 15-pssenger vn sfety, NHTSA sent letter to ech stte president of the Ntionl Automobile Delers Assocition (NADA) reminding them of the Federl requirements tht pply to the sle or lese of vehicles used to trnsport students to nd from school nd school-relted ctivities. Letters were lso sent to stte directors of pupil trnsporttion s well s to independent eduction groups outlining these Federl requirements nd NHTSAs school bus sfety stndrds. Similr letters were sent to these groups in 1995 nd Enclosed with ech of these letters ws fct sheet, "School Buses: The Sfest Choice for Student Trnsporttion," explining why school buses re sfer thn 15-pssenger vns for trnsporting children. In August 2003, NHTSA issued new regultions mending the school bus sfety rules to encourge churches nd other groups to use buses insted of vns. In November 2002, NHTSA, in prtnership with the Helth Resources nd Services Administrtion (HRSA) nd the Americn Acdemy of Peditrics (AAP), nnounced trining progrm for child cre providers clled Moving Kids Sfely in Child Cre. The two-dy trining progrm eductes child cre providers bout how to sfely trnsport children using the pproprite child restrints for their ges s well s the benefits of trnsporting children in school buses versus 15-pssenger vns. This trining progrm is vilble through the stte highwy sfety offices. To dte, over 2,900 child cre providers cross the country hve completed this trining progrm. Current nd Plnned Actions: Consumer Informtion Advisory: Develop ConsumedMedi Advisory to inform the public tht only "experienced" drivers should operte 15-pssenger vns nd the importnce of sfety belt use in ll vehicles, especilly 15-pssenger vns. Issue ConsumedMedi Advisory October 2003 Revise Consumer lnformtion Hngtg: The Reducing the Risk of Rollover Crshes in 15-Pssenger Vns hngtg will be modified to summrize messges tht will be simple nd strightforwrd (checklist formt). This revised hngtg will be distributed to our prtners, including AAA, Automotive Service of Excellence (ASE), Jiffy Lube, Ntionl Assocition of Independent Insurers (NAII), nd Ntionl Credit Unions, mong others. This cn be done quickly, prior to development of vehicle lbel. (See Vehicle Countermesures) Issue revised hngtg http ://m.nhts.do t. gov/hot/ 15PssVns/ 1 Spssvn. html 11/17/2003

7 NHTSA Action Pln for 15-Pssenger Vn Sfety Pge 6 of 9 October 2003 (in conjunction with the Consumer Advisory nd Reserch Report) Disseminte Wrning Messges: Include cutionry wrning messges to users of 15- pssenger vns on the sfety issues regrding these vehicles nd the importnce of wering sfety belts, in existing nd future communictions resources. Methods of distribution include CART prtnership distribution of our mterils t its rces nd existing NHTSA mechnisms, nmely, the NHTSA Hotline nd the new NHTSA web site on Rollover t html. Add informtion to new Rollover section of the NHTSA website October 2003 Outrech Actions: Actions include two inititive res. Technicl Assistnce: Include 15-pssenger vn sfety informtion in relevnt Deprtmentl efforts nd regionl outrech ctivities. NHTSA ttends trde shows, conventions, etc., throughout the yer, nd these events offer opportunities to rech vried udience nd promote vehicle sfety messges. Utilize existing prtnerships with Ntionl Collegite Athletic Assocition (NCAA) nd umbrell church nd youth orgniztions. - NHTSA hs existing prtnerships with mny orgniztions to implement trffic sfety nd injury control progrms. Throughout FY 2004, NHTSA will work with the following orgniztions to provide technicl ssistnce for their efforts to develop progrms nd policies to ddress 15-pssenger vn sfety nd provide them with NHTSA mterils to disseminte throughout their orgniztion: Ntionl Automobile Delers Assocition (NADA) Auto mnufcturers Governors Highwy Sfety Assocition Eduction nd school trnsporttion orgniztions Brnches of the militry (they hve expressed interest in developing trining progrm for their drivers) Religious groups Colleges nd universities Rentl vn fleets YMCA nd summer cmp orgniztions Orgniztions tht focus on migrnt workers Hed Strt nd dy cre provider orgniztions Trining nd Eduction: The focus of NHTSA s driver trining progrm is on novice teenge drivers. NHTSA hs coopertive greement with the highwy sfety center t Indin University of Pennsylvni to develop novice driver trining progrms nd driver eduction curriculums. Commercil uses of 15-pssenger vns typiclly involve experienced drivers, nd, becuse of libility issues within this industry, mny commercil opertors require their drivers to tke trining. A mjority of the highly publicized crshes involving 15-pssenger vns hve involved inexperienced drivers for http :// gov/hot/ 1 SPssVndl Spssvn. html 11/17/2003

8 NHTSA Action Pln for 15-Pssenger Vn Sfety Pge 7 of 9 privte orgniztions such s churches nd YMCAs. Becuse of the infrequent use of these vehicles for these purposes, drivers re less likely to hve tken forml trining. In ddition, mny of these orgniztions operte progrms with volunteers nd with limited budgets. Severl progrm efforts re being plnned including development of eductionl mterils focused on the sfe use of 15-pssenger vns; 15 minute video showing the risks of nd tips for reducing the risks ssocited with driving 15-pssenger vn including, but not limited to, operting in hevily loded condition, emergency brking, tire-blowouts, tire pressure nd mintennce nd the importnce of buckling up; nd, s prt of the Intergency Agreement with OSHA, NHTSA will include section on 15- pssenger vn sfety in trffic sfety hndbook for employers. Develop 15-pssenger vn section for hndbook December 2003 Develop video April 2004 Develop eductionl mterils October Countermesure Reserch Prior Reserch NHTSA s April 2001 Reserch Note & pper is described under Problem Identifiction. Current nd Plnned Reserch In response to the NTSB recommendtion on tire pressure monitoring systems with regrd to the potentilly dverse effect mrginlly low tire pressures cn hve on 15- pssenger vn hndling (H-03-17), NHTSA is dding tests for these vehicles to tire testing progrm t VRTC to see the effect on vehicle hndling from different front nd rer tire pressures. Complete testing October 2003 Finl Report Jnury 2004 Dynmic Rollover Resistnce nd Hndling Evlution of 7 5-Pssenger Vns: Testing is underwy t VRTC to see whether it is pproprite to use the rollover resistnce mneuvers developed for the NCAP rollover rtings progrm to ssess the dynmic rollover resistnce of two 15-pssenger vns. Specificlly, the Slowly Incresing Steer, NHTSA J-Turn, nd NHTSA fishhook mneuvers will be used. The minimum mneuver entrnce speed cpble of producing two-wheel lift, the mximum lterl ccelertion, nd understeer grdient of ech vehicle, under 3 lod configurtions (5, IO, nd 15 occupnts) will be documented in report. While NHTSA is not including these tests s prt of NCAP, their results will be posted on the NHTSA website. Complete testing November 2003 Finl Report Februry 2004 http :// dot. gov/hot/ 1 5 PssVns/ 1 Spssvn. html 1 1/17/2003

9 NHTSA Action Pln for 15-Pssenger Vn Sfety Pge 8 of 9 Evlute Electronic Stbility Control (ESC) in 75-Pssenger Vns: In November 2002 the NTSB recommended tht NHTSA "evlute, in conjunction with the mnufcturers of 15- pssenger vns, nd test s pproprite, the potentil of technologicl systems, prticulrly electronic stbility control systems, to ssist drivers in mintining control of 15-pssenger vns." NHTSA will evlute the dynmic rollover resistnce of one 15- pssenger vn with enbled nd disbled stbility control using J-Turn nd fishhook rollover resistnce mneuvers. Only GM nd Ford produce 15-pssenger vns. At this time, only GM intends to implement ESC on these vehicles. It is nticipted ESC will be vilble on GM 15-pssenger vns in mid-to-lte October Complete testing December 2003 Finl Report Februry 2004 IV. Vehicle Countermesures Current nd Plnned Actions: Vehicle Lbeling: Prior NHTSA consumer reserch nd informtion developed for the 2002 hngtg will be used to develop wrning lbel tht might be required for new 15- pssenger vns. Cndidte informtion includes wrnings bout loding, hndling nd proper tire pressure. Evlute previous work on rollover lbels/investigte fesibility of lbels June 2004 FMVSS 208, Occupnt Crsh Protection: Anton's Lw, signed into lw in December 2002, requires lp nd shoulder belts (3-point belts) t ll seting positions (notbly the center rer set) for vehicles with GVWR of 10,000 pound or less. 15-pssenger vns hve bench sets with seting for three or four pssengers, but usully only the outbord sets hve lp nd shoulder belts. NHTSA published n NPRM on August 6, 2003 tht would require lp nd shoulder belts in rer center sets in ll vehicles up to 10,000 pounds GVWR. One prcticl wy to instll lp nd shoulder belts in ll 15-pssenger vn seting positions (nd to stiffen set bcks) might be to use integrted sets. This ctivity reltes to NTSB H Finl rule December 2004 FMVSS 274, Side lmpct Profection: The gency is plnning to upgrde FMVSS No The proposed upgrde will pply to ll pssenger crs, nd trucks, buses nd multipurpose pssenger vehicles with GVWR of 10,000 pounds or less. Some of NTSB's concerns bout dditionl hed impct protection my be ddressed by this upgrde. NPRM to upgrde FMVSS 214 My 2004 Prt 577.3, Definitions: NHTSA is in the process of revising the definition of "designted seting position" to include formul bsed on the width of row of sets. The gency is concerned tht if occupnts re too squeezed together, they would not be ble to ccess or use the shoulder prt of the 3-point belt. So s not to dversely impct big vn sfety, 5PssVnsllSpssvn.html 1 1/17/2003

10 NHTSA Action Pln for 15-Pssenger Vn Sfety Pge 9 of 9 NHTSA is considering whether to pply different formul to pssenger vns tht would require more spce per position on sets designed to hold more thn three pssengers. This would mke it more likely tht ech pssenger would be ble to use - nd not just hve - sfety belt. NPRM December 2003 FMVSS 276, Roof Crush Resistnce: The plnned upgrde of this stndrd will expnd its coverge to vehicles up to 10,000 pounds GVWR (with certin exceptions). This ction reltes to NTSB recommendtion NTSB H The gency s proposed upgrde will provide more uniform protection for 1 5-pssenger vn occupnts. Agency testing of 15-pssenger vns will test roof crush for the front set occupnt positions. Testing t VRTC hs shown tht these vehicles brely pss the current FMVSS 216 requirements nd would require stronger roofs to pss the upgrded requirements. In the upgrde currently under development there re no plns to modify the test procedure by moving the test plte towrd the rer of the roof. It is currently not cler whether there is need to develop test for the rer positions from sfety problem perspective. Current dt nlysis suggests tht the problem of roof crush is lrgely front seting position problem in terms of roof contct nd tht sfety for occupnts in rer seting positions is more dependent on belt use/ejection. However, this problem will be studied to determine if modified test from FMVSS 220, School Bus Rollover Protection is needed, which would test roof strength for rer positions by pplying horizontl forces. Study of rer seting positions s prt of Crsh Mechnisms in 72- nd f5-pssenger Vns (see Countermesure Reserch) NPRM for FMVSS 216 upgrde Mrch 2004 Februry 2004 Conclusions NHTSA will pursue the ctions included in this pln within the prmeters of vilble stff, resources, nd sfety priorities. The recently published NHTSA Vehicle Sfefy Rulemking Priorities nd Supporfing Reserch, (July 2003) describes our top vehicle sfety priorities imed t reducing the gretest number of crshes, injuries, nd ftlities in the coming yers. gov/hot/l 5PssVns/ 1 5pssvn.html 11/17/2003