Background:
Safety
recalls of motor vehicles are fairly routine events. A recall
occurs when a safety-related defect exists in the design,
manufacture or performance of a component such that an unreasonable
risk to motor vehicle safety exists. A safety recall also
occurs when a motor vehicle or item of motor vehicle equipment
does not comply with an applicable Federal Motor Vehicle Safety
Standard (FMVSS). All types of motor vehicles and items of
motor vehicle equipment are recalled. In 1999, there were
371 safety recalls involving 19.8 million motor vehicles with
fewer than 36,000 school buses involved in 25 of those safety
recalls. Potential safety-related defects and safety recalls
involving school buses are taken very seriously because of
the nature of the passengers transported on school buses -
young children.
Under federal law, all safety-related recalls must be
reported to the National Highway Traffic Safety Administration
(NHTSA) so the agency can assure that vehicle owners are
properly notified and that the proposed remedy is effective
in eliminating the safety-related defect or correcting
the non-compliance with a FMVSS. Manufacturers of motor
vehicles or items of motor vehicle equipment initiate
some safety-related recalls. Others are initiated as a
result of a safety defect or non-compliance investigation
by NHTSA.
Often times a component that is used on various types
of motor vehicles has a safety-related defect. In such
instances, all of those vehicles generally will be included
in the safety recall. However, there are instances where
only the school buses are recalled because the school
bus manufacturers and NHTSA seek the highest levels of
safety in school buses - primarily because of the child
passengers. For example, several years ago when a safety
problem occurred with the drive shafts on various types
of trucks and school buses, only the school buses were
recalled. The logic was simple - while a broken drive
shaft may be a problem for the driver of a truck, a school
bus that broke a drive shaft in traffic with 50 or more
children onboard presented a serious safety concern.
While all safety recalls are important, and the vehicles or
items of motor vehicle equipment involved need to be fixed
according to the safety recall, some safety defects or non-compliance
with a FMVSS present a more serious risk than others do. If
a school bus recall involved a safety problem that presented
an imminent risk, then the school bus manufacturer or NHTSA
would order that the buses be taken "out-of-service" until
repaired. Historically, that has been a very rare event.
Most safety recalls involve a safety-related defect, or
a non-compliance with a FMVSS, that needs to be remedied,
but not at the expense of taking the motor vehicles involved
"out-of-service." The federal law governing safety recalls
provides for an 18-month time frame for manufacturers
to notify owners of the safety defect or non-compliance
and fix the vehicles under the safety recall. During this
period, manufacturers are required to submit detailed
reports to NHTSA on the number of owners notified of the
recall and the number of vehicles remedied under the recall.
The agency uses that information, and information from
consumers, to ensure that the recall is conducted in accordance
with federal requirements and that the recall remedy is
effective.
It is important that all motor vehicles included in safety
recalls be remedied in accordance with the recall. Unfortunately,
it is sometimes difficult to locate and inform all vehicle
owners of the safety recalls. As discussed further below,
this is particularly true for school buses.
Discussion:
By every measure, school buses are the safest form of
motor vehicle travel in the United States. Unless a school
bus is taken "out-of-service" by a safety recall, the
school bus is still the safest way for children to get
to and from school and school-related activities. It would
be an error in judgment for parents to take their children
off a school bus just because it was involved in a safety
recall. Children that go to and from school in passenger
motor vehicles are exposed to significantly higher safety
risks. According to the most recent NHTSA data, children
in school buses are more than 100 times safer than children
going to and from school in passenger motor vehicles.
The pupil transportation industry is made up of thousands
of people who have the safety of children as their highest
priority. Most are parents, also, and have their own children
or even grandchildren riding in school buses. If there
were an imminent safety risk associated with the continued
operation of a school bus, the pupil transportation industry
would be at the forefront to insure the vehicles were
not used until the safety problem was corrected.
Because both public and private carriers own school buses,
there are no readily available lists that provide the name/address
of the person(s) responsible for each individual school bus
operating in the United States. Therefore, when a safety recall
is initiated, it is often difficult for a manufacturer to
send recall notification letters to persons that can locate
the appropriate school buses that need to have recall work
performed. In addition to sending owner notification letters
to the known purchasers of the school buses, various supplementary
techniques are employed to ensure safety recalls of school
buses are completed. One of these involves a multi-tiered
notification system, starting with the State Director of Pupil
Transportation, or equivalent position, in each State.
While it takes additional time and effort to make sure
the information about safety-related recalls is disseminated,
and that the recall remedy has been completed on all school
buses, the additional time and effort is well spent.
Conclusions:
The National Association of State Directors of Pupil Transportation
Services believes that it should do whatever it can to
assist in ensuring that school buses that have been recalled
for a safety-related defect, or non-compliance with a
FMVSS, are remedied in accordance with the safety recall.
Accordingly, whenever the State Directors Association
receives notification of a safety-related recall from
either a manufacturer or NHTSA, an article will be published
in the association's newsletter. Recalls will be listed
by manufacturer and will include a detailed description
of the vehicles involved in the recall, the safety-related
problem and potential consequences, and the manufacturer's
recall identification number.
The State Directors Association encourages each State
Director, or equivalent position, to provide this recall
information to each school jurisdiction in his/her state
by some reasonable and feasible manner. Additionally,
each State Director, or equivalent position, is encouraged
to notify the organization in his/her state that conducts
the school bus inspections and specify that the safety-related
recall remedy be included as one of the items inspected
the next time the school bus is scheduled for inspection.
The State Directors Association will work with the media
to help inform the public of the "facts" involved in each
safety recall involving school buses. When necessary,
the State Directors Association will provide information
to the School Bus Information Council for use on its web
site as a means of informing the media and the public
about safety recalls and the overall safety of school
buses.
It is noted that manufacturers also conduct recalls of
school buses for problems that have no potential safety
consequences. Such recalls do not have to be reported
to NHTSA. The State Directors Association believes State
Directors, or equivalent positions, should use their own
judgment about notifying school jurisdictions of a non-safety
recall.
The State Directors Association will work with NHTSA to
ensure that any information developed by the agency concerning
school bus safety recalls, such as NHTSA's "School Bus
Safety Assurance Program: Recall Listing," is disseminated
to each State Director or equivalent position. Upon request,
the State Directors Association will provide assistance
to NHTSA in fulfilling its responsibility to monitor the
status of school bus safety recalls.
© 2000 National
Association of State Directors of Pupil Transportation
Services. All rights reserved. Revised September 2000