Ghostly gray smoke rose from mountains of rubble as rescuers continued their desperate search for miracles. All the world knew that where the towers known as the World Trade Center once stood majestically in salute to the prosperity, ingenuity and might of the world's greatest people, there lay America's phoenix. From those ashes a stronger, more resolute America already had begun to rise within a very few hours after tragedy struck.

The events that turned our world topsy-turvy are a horrific reminder that we must be vigilant.we must be prepared. It takes great effort to turn our attention back to the chores of life. But turn we must if we are to restore normalcy to our daily lives. In so doing, we recognize that normal has been, and shall be, redefined in so many different ways.

One example of the need to regain our focus is the realization that at the time of our nation's great tragedy, nearly nine months had passed since we learned that change was imminent in the world of pupil transportation-specifically as it relates to transporting children to and from Head Start and Early Head Start. It was on January 18, 2001 that the Department of Health and Human Services issued 45 CFR 1310, the "Final Rule," which defines regulations that will govern Head Start and Early Head Start transportation systems in the near and more distant future.

The Final Rule clearly indicates that the published regulations apply to contractors, to school districts, to Head Start agencies and to all other entities that provide transportation services to children who participate in Head Start and Early Head Start programs. But has the message sunk in? In September's excitement and horror, have we been steered off course?

Since the issuance of the Final Rule, days have melted into weeks, and now, weeks into months. Distractions caused by the beginning of a new school year and then by the attack on America interrupted our routines. But now, the January 18, 2002 deadline looms like an unstoppable giant. Are you on schedule? Is your plan in place? Is it time for a wake-up call?

A quick review of the pivotal document will serve to remind us of its impact. These are the major topics addressed in the Final Rule:

1. Types of allowable vehicles used on daily routes;
2. Equipment requirements for allowable vehicles;
3. Vehicle maintenance and inspection;
4. Driver qualifications and employment practices;
5. Use of monitors on vehicles;
6. Training for drivers, monitors, parents and children;
7. Administrative procedures;
8. Records-keeping.

Did this list attract your attention? Do you need more details? Are you unsure of the degree of compliance within your own transportation operation? Read on. Here are some specifics. (And as you read, note the deadlines.)

Deadline: January 18, 2002

1. Vehicles that transport children to and from Head Start and Early Head Start programs must be equipped with a communication system, with a reverse warning beeper, with a seat belt cutter, with a fire extinguishers and with a first aid kit. (1310.10)

2. Use of auxiliary seats is limited to seats installed by vehicle body manufacturers and must be included in inspection and maintenance procedures. (1310.10)

3. Vehicles must be inspected annually by state-licensed inspectors. (1310.13)

4. Drivers and monitors (as appropriate) must conduct daily pre-trip and post-trip vehicle inspections. (1310.13)

5. A system of conducting and documenting preventive maintenance for vehicles must be in place. (1310.l3)

6. All accidents involving Head Start vehicles must be reported. (1310.10)

7. A child may be released at the Center or at the home bus stop only to an individual who has been authorized in writing by a parent or a legal guardian to receive the child. (1310.10)

8. Up-to-date rosters of passengers must be carried on respective vehicles at all times. (1310.10)

9. Bid announcements for vehicles to be used to transport children must include the correct specifications and a clear statement of the vehicle's intended use. (1310.14) 10. Vehicle bid announcements must contain a notice that vehicles will be inspected for compliance with bid specifications, with Federal Motor Vehicle Safety Standards, with applicable state specifications and with Head Start and other applicable regulations. (1310.14)

11. A procedure for inspecting vehicles at the time of delivery must be in place, and vehicles must be inspected for compliance at the time of delivery. Each manufacturer must include with each vehicle a certificate of compliance with applicable FMVSSs. (1310.14)

12. On vehicles equipped for use of such devices, children weighing 50 pounds or less must be seated in height- and weight-appropriate child safety restraint systems while the vehicle is in motion. (1310.15)

13. Baggage and other items must be properly stored and secured, and aisles, doors and emergency exits must remain unobstructed at all times. (1310.15)

14. All drivers must have a valid commercial driver's license (in states where such licenses are granted) and must meet physical, mental and other requirements necessary to perform job-related functions. (1310.16)

15. Driver applicants must be notified of required background checks. (1310.16)

16. Employing agencies must establish an applicant review process and criteria for rejection of unacceptable applicants. (1310.16)

17. Classroom and behind-the-wheel in-service training is required of presently employed drivers. Pre-service training is required of newly hired drivers. (1310.17) 18. Drivers must be evaluated. Annual evaluations shall include on-board evaluations. (1310.17)

19. Pre-service and in-service training is required of monitors. (1310.17)

20. Parents and children must be trained in pedestrian and vehicle safety. (1310.21)

21. Emergency evacuation drills are required:
a. Within the first 30 days of the Head Start program year on the same vehicle the child will be riding; and
b. At least twice during the year thereafter. (1310.21)

22. Special requirements for children with special needs must be described in the IEP or the IFSP. Compliance with the requirements must be assured. (1310.22)

23. Whenever possible, children with disabilities shall be transported with their non-disabled peers. (1310.22)

24. Safety must be the primary consideration in planning fixed routes. Vehicles must not be overloaded; one-way ride times must not exceed one hour unless required for safety or practical application. (1310.20)

25. Backing and u-turns shall be allowed only when necessary for reasons of safety. (1310.20)

26. Stops should be located so as to eliminate the need for children to cross roadways to board or to leave the vehicle. If crossing a roadway is required, children must be escorted by a monitor or by another adult. (1310.20)

27. Alternate routes must be designed for use in case of emergencies that would affect the safety of passengers. (1310.20)

28. Reasonable attempts must be made to coordinate transportation resources with other local human services agencies. (1310.23)v 29. True costs of transportation must be identified. (1310.23)

30. Options must be explored for coordinating transportation with local public or private transportation systems. (1310.23

These requirements, remember, are for implementation by January 18, 2002. Adequate planning is essential to prepare for the two remaining phases of the Final Rule.

Deadline: January 20, 2004

1. All vehicles must be equipped with height- and weight-appropriate child safety restraint systems. (1310.11) 2. At least one monitor must be on board each vehicle at all times with passengers. Additional monitors shall be used as necessary to meet the needs of passengers. (1310.15)

Deadline: January 18, 2006

1. All vehicles must be school buses or allowable alternate vehicles (AAVs). Allowable Alternate Vehicle means a vehicle designed for carrying eleven or more people, including the driver, that meets all the Federal Motor Vehicle Safety Standards applicable to schools buses, except 49 CFRR 571.108 and 571.131 (alternately flashing signal lights and stop arm). (1310.12)

2. All vehicles must be equipped with height- and weight-appropriate child safety restraint systems, reverse warning beeper, communication system, belt cutter, fire extinguisher and first aid kit. (1310.12)

In summary, following are some practical examples that serve to illustrate how the Final Rule may affect you, the transportation provider. (The word may is used throughout the illustrations because the extent of change depends on your current level of compliance.)

Changes with vehicles may be required. Vehicles currently utilized to transport children in Head Start programs may have to be modified or replaced and new vehicle specifications revised to accommodate child safety restraint systems (e.g., seats, belts, vests) and other required equipment (i.e., reverse warning beeper, seat belt cutter, communication equipment, fire extinguisher, first aid kit). Vans no longer are permitted for transporting children to and from the program on daily fixed routes.

Monitors may have to be added or vehicle assignments modified. Whenever a Head Start child is placed on a route vehicle, a monitor must be present. (Will this result in Head Start-specific routing for you?)

Routing may otherwise be affected. Routes may have to be reconfigured to reduce ride times for children in Head Start. Routes need to be evaluated to establish safety as the primary criterion for design. Bus stops may have to be more frequent and stops relocated in order to comply. Children may experience more integration of children with special needs with children without special needs during transport.

Training regimens may have to be modified. Training may be expanded to a broader spectrum of persons and must include specific minimal topics listed in the Final Rule. Before drivers are permitted to drive and monitors are permitted to serve, they must undergo pre-service training. Annual in-service training is required, also. Training for other Head Start personnel, for parents and for children in mandated. Training for employees must include passenger management, evacuation procedures and other techniques appropriate for Head Start children. Training must include cultural diversity and social issues described in Head Start regulations, as well.

Emergency evacuation drills may have to be modified. One drill must be held within the first thirty (30) days of the program year, and it must conducted on the specific vehicle that each child rides. Two additional drills must be held thereafter during the year. (Two annual drills currently is a common local practice.)

Systems of sharing information with bus drivers and monitors may need to be improved. Directory and emergency information, along with a photograph of each child, should be available for each driver to carry on board the vehicle. For children in special education programs, IEPs or IFSPs must include all transportation-specific requirements, and these requirements must be shared with drivers and monitors. Transporters must ensure that the requirements are being met. Drivers and monitors also must be provided the names of authorized adults to whom children may be released along routes or at Head Start Centers.

Job qualifications and personnel selection procedures may need an overhaul. Background checks are required. Applicants must be informed at the time of application of all required background checks. Established criteria for rejecting applicants are required. Compliance with Head Start regulations detailed in sources referenced in the Final Rule is required. Parents of Head Start children who meet job qualifications, licensing and other requirements must be given preference in filling job vacancies. (Just a thought: Will the latter become a political issue for school districts?)

Bus driver evaluations may have to be modified. Annual evaluations are required, and on-board observations must be conducted while drivers are operating their vehicles on routes.

Accounting systems may have to become more sophisticated. Detailed cost analyses for transporting children for Head Start programs are required. Vehicle and equipment acquisition, maintenance and repairs, fuel and supplies, personnel-these are some of the items that must be included in accounting procedures. If current accounting details do not reflect costs as they relate specifically to Head Start, changes should be made.

All transportation providers-Head Start agencies, contractors, school districts or other agencies-should be well underway with planning and implementation of required procedures and practices defined in the Final Rule. We must be prepared for the quickly approaching deadline, and there may be much work still to be completed. September's distractions have to be cleared away to make way for the rise of a new system of operation. The Final Rule may prove to be Head Start transportation's phoenix.