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FIFTEEN PASSENGER VAN SAFETY – RECOMMENDATIONS ON BEST PRACTICES FOR COMMUTER AND COMMUNITY TRANSPORTATION Dr. Frederick Wegmann Department of Civil and Environmental Engineering University of Tennessee Knoxville, Tennessee Dr. Melany Noltenius Department of Geography University of Tennessee Knoxville, Tennessee JULY 2008

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FIFTEEN PASSENGER VAN SAFETY – RECOMMENDATIONS ON BEST

PRACTICES FOR COMMUTER AND COMMUNITY TRANSPORTATION

Dr. Frederick Wegmann Department of Civil and Environmental Engineering

University of Tennessee Knoxville, Tennessee

Dr. Melany Noltenius Department of Geography University of Tennessee

Knoxville, Tennessee

JULY 2008

2

ACKNOWLEDGEMENTS

The assistance of the Tennessee Vans Program in providing matching funds and sharing its crash

records and expertise is greatly appreciated. The assistance of Dr. Ted Newsom, Director of

Tennessee Vans, and Bill Gilpin, Tennessee Vans Nashville Program Coordinator, and Danielle

Meyers, Senior Research Assistant, is greatly appreciated. Also acknowledged is the

background and insights into 15-passenger van safety by Steve Pederson and Jim Cipollone of

VPSI. The crash data for the King County Metro Commuter Van Pool provided by Lorraine

Desrochers, Van Pool Risk Specialist, is greatly appreciated.

3

Table of Contents Introduction..................................................................................................................................... 4 Rollover Issue and Federal Response ............................................................................................. 6

A History of 15-Passenger Vans................................................................................................. 6 Rollover Experienced.................................................................................................................. 7 Federal Advisories ...................................................................................................................... 8

Crash Summaries and Statistical Analysis.................................................................................... 11 Tire Pressure Study ................................................................................................................... 20 Electronic Stability Control ...................................................................................................... 22

The Reaction Varies by Market Segment ..................................................................................... 22 K-12 Schools and State Law..................................................................................................... 23 State University Systems .......................................................................................................... 24 Church Van Use........................................................................................................................ 25 Tennessee Rural and Specialized Transit Providers ................................................................. 26 Commuter Vanpools ................................................................................................................. 27 A Further Investigation of Commuter Vanpools ...................................................................... 29 The Tennessee Vans Program................................................................................................... 33

Recommended Practices and Conclusion ..................................................................................... 37 Agency Responsibilities............................................................................................................ 38

Minimum Driver Requirements............................................................................................. 38 Minimum Vehicle Requirements ........................................................................................... 39 Driver Training ..................................................................................................................... 39

Driver Responsibilities.............................................................................................................. 40 Van Modifications .................................................................................................................... 42

References..................................................................................................................................... 45 Appendix A: NHTSA Consumer Advisory – April 9, 2001......................................................... 49 Appendix B: NHTSA Consumer Advisory – April 15, 2002....................................................... 52 Appendix C: NHTSA Hangtag ..................................................................................................... 55 Appendix D: State Laws Prohibiting the Use of 15-Passenger Vans ........................................... 57 Appendix E: State University Systems Use of the 15-Passenger Van.......................................... 60 Appendix F: Rural and Specialized Transit Providers in Tennessee........................................... 63 Appendix G: Safe Driving Practices Acknowledgement Statement............................................. 66 Appendix H: Defensive Driving Techniques................................................................................ 69

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Introduction

Currently, there are over 500,000 15-passenger vans being driven in the United States.1

In the early 1970s, first Dodge, then Ford sought to accommodate emerging demand for a

vehicle that could carry small groups of passengers. Instead of creating a new vehicle, the car

manufacturers chose to modify existing cargo vans by extending the body of the vehicle and

adding seats for 15 passengers. The manufacturers, however, did not lengthen the wheel base.2, 3

Many different groups began using the 15-passenger vans as a low cost alternative to purchasing

a bus. These market segments included day care centers, church groups, public and private

schools, universities, rural transit providers, and commuter groups. Though the 15-passenger van

could be used like a bus, the vans did not meet the federal safety regulations of a bus.4

During the ensuing 30-year period since the introduction of the 15-passenger van, a

number of crashes occurred, but the crash data for these incidents were not analyzed until the late

1990s as the crashes were considered unrelated incidences. One high-profile accident that

began to highlight the safety concerns of the 15-passenger van occurred in the mid-1990s. In

1994 near Columbia, South Carolina, Jacob Strebler, age 6, was killed on his way to swimming

classes while riding in a private school 15-passenger van. Though the van was hit by a truck,

experts determined that his death could have been avoided if he had been riding in a vehicle that

met with federal safety standards for a school vehicle.5

By 1999, the National Transportation Safety Board (NTSB) began warning school

districts, day care centers, and any agency that transported children that 15-passenger vans met

the federal definition of a bus, but not the federal occupant crash protection standards of a bus.6

By early 2001, the National Highway Traffic Safety Administration (NHTSA) had conducted a

brief review of crash data to look at the record of 15-passenger vans, and simulated the handling

5

of unloaded and loaded 15-passenger vans.7 As the result of this study, in April 2001 NHTSA

issued a Consumer Advisory to all users of the 15-passenger van that the van had an increased

risk of rollover (Appendix A: NHTSA Consumer Advisory – April 9, 2001). The 2002

publication of Safety Report: Evaluation of the Rollover Propensity of 15-passenger Vans by the

NTSB recommended that the 15-passenger van be operated by an experienced driver, and that all

passengers be required to wear a seatbelt. 8 NHTSA also recommended the same (Appendix B:

NHTSA Consumer Advisory – April 15, 2002). Yet, no federal legislation was passed

prohibiting the use of the 15-passenger van to transport students.9

The reaction of the various market segments using 15-passenger vans to the consumer

advisories was varied and the responses were loosely based on state regulation, insurance

company response, and perceived risk of users. As a result, some of the market segments

continued to use the 15-passenger van, while other segments stopped using it. For example, the

State of Tennessee legislators passed a law in 2002 requiring vehicles that transport students to

school to meet school bus structural standards, but vehicles that transport school students on

activity trips do not have to meet school bus structural standards.10 This included all public

school students from pre-kindergarten through twelfth grade. Some insurance companies

responded by refusing to insure 15-passenger vans or requiring drivers to meet certain standards,

and many state universities responded by eliminating the 15-passenger vans from their fleets.

However, other market segments, such as the rural transit providers and commuter pools,

responded less dramatically, but it may be argued just as effectively. Under the leadership of the

Association of Commuter Transportation (ACT), commuter vanpool management agencies, such

as VPSI, Inc., have created guidelines for driving 15-passenger vans, as well as designed and

implemented driver training programs.11 Rather than preventing the use of the 15-passenger van,

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these market segments are paying more attention to vehicle condition and maintenance, driver

training, vehicle loading, and 15-passenger van alteration and modification, like rear seat

removal.

Rollover Issue and Federal Response

The 15-passenger van rollover propensity was not clearly identified until the federal

government began reviewing crash statistics and investigating the van’s handling when fully

loaded with passengers. Some van manufacturers were aware of some of the 15-passenger van’s

safety issues as early as the 1970s, but did not stop manufacturing the vehicles. A number of

high profile accidents prompted the NTHSA to issue consumer advisories starting in 2001, and

test the vehicle’s performance.

A History of 15-Passenger Vans

In the early 1970s, first Dodge, then Ford accommodated demand for a vehicle that could

carry small groups of passengers. Instead of creating a new vehicle, the manufacturers modified

their existing cargo vans by making the body longer and installing seats for 15 passengers,

without lengthening the wheel base.12

Ford began producing 15-passenger vans in 1975, and even allegedly ignored its own

engineers’ recommendations to extend the wheel base and add dual rear wheels to prevent

fishtailing. These recommendations were rejected because of the added cost and subsequent

production delays.13 Former Ford engineer, John Stilson, has testified in lawsuits stating that

Ford’s E-350 15-passenger van was difficult to control and maneuver when driven by

experienced test drivers.14 In 1990, General Motors began manufacturing a 15-passenger van.

GM expanded its 12-passenger van to 15 passengers by lengthening the wheel base. However,

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GM did not conduct any side pull tests, rejecting its own advise to NHTSA that side pull tests

were the best approach to determine rollover resistance.15

Crashes involving the 15-passenger van were considered as independent incidences until

the mid to late-1990s. By this time a number of well-reported collisions and rollovers had

occurred. This media coverage was partially responsible for the attention the 15-passenger van

received from the federal government.

Rollover Experienced

For 30 years, there have been 15-passenger van fatalities; however, fatalities were not the

result of rollover in all cases. Other factors contributing to fatal crashes included tire under-

inflation, passengers not wearing seatbelts, driver loss of van control, driver errors, and other

vehicles hitting the 15-passenger van. Nine examples of these crashes are found below. Four of

these crashes involved university or college students; three involved church related activities,

one involved a preschool, and one involved a high school.16, 17

• Bennettsville, South Carolina, February 16, 1998: A 1996 Dodge van carrying six children home from a church-run after-school program was hit by a tow truck after the van ran a stop sign, according to a witness. All six children, ages 7-11, were killed. Three were ejected from the van.

• East Dublin, Georgia, December 8, 1998: A 1995 Ford van carrying five 4- and 5-year-

olds and one adult to a Head Start program reportedly ran a stop sign and crashed into a pickup truck. One 4-year-old was ejected and fatally injured. The van and truck both overturned. Eight van windows shattered.

• Hampstead, Texas, February 10, 2000: A 1990 Ford van carrying 11 members of Prairie

View A&M University’s track team tried to pass a vehicle that was turning left into a convenience store parking when the driver lost control of the van. Four team members were killed and seven injured.

• Grand Canyon, Arizona, Summer 2000: One student and the teacher-driver were killed

when a 2000 Dodge van carrying 10 students from Chaminade High School on Long Island veered off a two-lane highway near the Grand Canyon and overturned. Police said the driver had “over-corrected” when the van left the pavement.

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• Wichita Falls, Texas, May 2001: A 1993 Dodge Ram 3500 15-passenger van owned by

the First Assembly of God Church of Burkburnett, Texas, was taking 12 women to an outlet mall when a tire lost its tread and the van overturned. The driver and three passengers were killed; eight others were severely injured.

• Marianna, Florida, September 24, 2001: On State Road 8, the right rear tire separated on

a 1990 Dodge 3500 van, causing the driver to lose control and the van to roll over. There were 10 Florida Baptist College students in the van, of which three were ejected and killed.

• Birmingham, Alabama, July 20, 2002: Two college cheerleaders were killed and four

others injured, one with partial paralysis, when their Ford Super Club Wagon 15-passenger van overturned after its left rear tire lost its tread. The victims were all members of the North Carolina-based Christian Cheerleaders of America.

• East St. Louis, Missouri, January 31, 2003: A thirteen year old boy was killed, and five

children injured when their Ford E350 15-passenger van, used by their church, fishtailed on wet pavement and rolled over.

• Salt Lake City, Utah, September 2005: Eight students and an instructor were killed and

two students injured when the left rear tire of their Dodge 15-passenger van blew, causing the van to roll four times. The van's roof collapsed to the windows. All 11 passengers were ejected from the van. The Utah Highway Patrol determined that none of the passengers were wearing a seatbelt, and that the van was traveling more than 75 mph.

Because of high profile tragedies similar to these, the 15-passenger van rollover record

was studied by NHTSA, which released a series of consumer advisories. However, the

federal government did not prevent any market segment from using the van. Since 2001,

NHTSA has issued more than twelve advisories, reports or recommendations for the use of

the 15-passenger van.

Federal Advisories As a result of the crashes and fatalities involved in the use of 15 passenger vans, NHTSA

began to study the crashes, not as isolated incidences but as a 15-passenger van safety issue.

Using the results from the State Data System (SDS), researchers at NHTSA noticed that the

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rollover propensity for 15-passenger vans was slightly less than that for the light truck and van,

but that the rollover propensity increased dramatically with higher occupancy levels, and that

fatalities occurred disproportionately to rear seat occupants of 15-passenger vans.18 NHTSA

determined that heavily loaded 15-passenger vans appeared to have a higher rollover rate than

when lightly loaded.

In April 2001, NHTSA issued a Research Note and Consumer Advisory on 15-passenger

van safety. The advisory stated that 15-passenger vans should be operated only by experienced

drivers, and that seat belts should be used at all times (Appendix A: NHTSA Consumer Advisory

– April 9, 2001). In April 2002, the advisory was reissued at a news conference, and the public

was made aware of the existence of a flyer on 15-passenger van safety and provided a hangtag,

which was to be left in 15-passenger vans, that made available information about the risk of

rollover, tips for preventing rollover, and the need for all drivers and passengers to use seat belts.

(Appendix B: NHTSA Consumer Advisory – April 15, 2002).

On November 4, 2002, NHTSA issued another advisory which was used to convince

transit providers to stop using the 15-passenger van for the transportation of children. The notice

alerted the public to a new school bus category (van-bus) that was exempt from traffic control

requirements imposed on regular school buses (e.g. emergency signaling and stop arms). The

van-bus was defined as any school bus of 15,000 pounds or less sold for purposes other than

transportation between home and school for students from kindergarten through high school.

NHTSA said that the new school bus category provided schools, day care centers, and other

institutions with a safer alternative to the 15-passenger van.19 Since November 2002, the NTSB

has issued nine more reports and/or recommendations that relate to the safety of the 15-passenger

van.

10

In October 2003, NHTSA released a revised consumer information hangtag: “Reducing

the Risk of Rollover Crashes in 15-Passenger Vans.” The hangtag summarizes safety messages

in a checklist format (Appendix C: NHTSA Hangtag). Several hundred national and regional

organizations were sent information packets containing the new hangtag.

In May 2004, NHTSA issued a notice of a proposed rule that would upgrade the side

impact protection requirement for “all passenger cars, and trucks, buses and multiple passenger

vehicles with a gross vehicle weight 10,000 pounds or less,” which included 15-passenger

vans.20

In June 2004, NHTSA released “Analysis of Crashes Involving 15-Passenger Vans.” The

report provided an in-depth analysis of crashes involving 15-passenger vans to assess the effect

of occupancy level on rollover. NHTSA also released “Testing the Effects of Tire Pressure

Monitoring System Minimum Activation Pressure on the Handling and Rollover Resistance of a

15-Passenger Van.” This report provided the results of a study that measured the effects of

modifying tire inflation pressure on the handling and rollover resistance of a 15-passenger van.

Additionally, in June 2004, NHTSA released “Testing the Dynamic Rollover Resistance of two

15-Passenger Vans with Multiple Load Configurations.” This study evaluated the dynamic

rollover resistance of two 15-passenger vans, one with the electronic stability control enabled

and one with the control disabled. NHTSA reissued its warning to users of 15-passenger vans

because of an increased rollover risk under certain conditions. The advisory stated that

passengers and cargo should be forward of the rear axle and loads should not be placed on the

roof of the van. Also, tires should be properly maintained and inflated.21

In August 2004, NHTSA published a notice of a proposed rule that would require lap and

shoulder belts in rear center seats in all vehicles weighing up to 10,000 pounds, which includes

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the 15-passenger van.22 In September 2004, NHTSA issued a notice of a proposed rule that

required all manufacturers to install a four-tire Tire Pressure Monitoring System (TPMS) that is

capable of detecting when a tire is more than 25 percent under-inflated and warning the driver.

The rule applies to “passenger cars, trucks, multipurpose passenger vehicles, and buses with a

gross vehicle weight rating of 10,000 pounds or less, which include a substantial number of 12-

and 15-passenger vans.”23 In May 2006, NHTSA reissued its earlier warnings regarding the use

of the 15-passenger van.

In May 2008, NHTSA issued a report concerning 15-passenger van crashes in the 10-year

period from 1997-2006. The report stated that “In 2006, fatalities to occupants of 15-passenger

vans reached the lowest level since 1992” and “Fatalities to occupants of 15-passenger vans have

been on a downward trend since 2001.”24 The report also stated that about half of van fatalities

occurred in vans that were loaded with ten or more passengers. Also nearly 60 percent of the

fatalities involved in rollover incidents were non-restrained passengers.

Crash Summaries and Statistical Analysis

To more fully understand the 15-passenger van statistics, a crash summary is provided.

NHTSA explored the relationship between vehicle occupancy and other variables contained in

the Fatality Analysis and Reporting System (FARS) database with regard to the 15-passenger

van's risk of rollover. The study examined statistics on fatal crashes involving 15-passenger vans

from 1990 to 2002. According to this study, NHTSA analyzed 1,957 crashes that involved 15-

passenger vans and discovered that the more passengers the van was carrying, the more likely it

was to overturn. With fewer passengers (five or less), the 15-passenger van had the same

rollover rate as the light truck. The 15-passenger van’s rollover rate increased to about 20

percent when five to nine passengers were in the van, and when fully loaded with ten or more

12

passengers, the van rollover rate increased to more than 30 percent (Table 1).25 With ten or more

people in a 15-passenger van, the additional passenger weight causes the van’s center of gravity

to shift rearward, which increases the likelihood of fishtailing. When the van is carrying cargo

on the roof, the center of gravity shifts upward, and this increases the van’s likelihood of

overturning. In addition, panic steering situations, like swerving to avoid an obstacle or a sudden

tire failure, increases the likelihood of rollover. Overall, the 15-passenger van was three times

more likely to roll over in a crash when loaded with ten or more passengers than when they

carried fewer than five. Furthermore, the data revealed that 80 percent of people killed in 15-

passenger van rollovers in 2000 were not wearing their seatbelts.26

In another 2004 study, NHTSA analyzed 1,576 15-passenger vans that were involved in

fatal crashes resulting in 1,111 fatalities. Single vehicle crashes accounted for 62 percent of

fatalities for occupants of 15-passenger vans. Of the 1,111 fatalities that occurred, 725 occurred

when the van rolled over (Table 2).27 Thus, about two-thirds of the fatalities to occupants of 15-

passenger vans occurred when the vans rolled over. Of the 1,576 vans involved in crashes, 657

vans were in fatal, single vehicle crashes. Of these 657 vans, 349 vans rolled over.28 The

National Transportation Safety Board (NTSB) calculated that the 15-passenger van overturned

more than half the time they were involved in single-vehicle crashes, compared to 33 percent for

other vehicles.

NHTSA data indicated that 725 fatalities occurred for both single vehicle and multiple

vehicle crashes involving a 15-passenger van. More than three-quarters of all fatalities that

occurred in 15-passenger van rollover incidents were in single vehicle crashes.29 In 2002, 15-

passenger vans involved in fatal single vehicle crashes were more than twice as likely to have

13

Table 1: Loaded Vans At Greater Risk to Roll25

Passengers Crashes Rollovers Rollover Rate* Less than 5 1,815 224 12.3% 5 - 9 77 16 20.8% More than 9 65 23 35.4% Total 1,957 263 * Percentage of crashes that are rollovers

Table 2: 15-Passenger Vans Involved and Occupant Fatalities by Rollover Occurrence, 1990-200227

Rollovers No Rollovers All Crashes Year Vehicles Fatalities Vehicles Fatalities Vehicles Fatalities

1990 21 23 69 14 90 37 1991 20 28 53 11 73 39 1992 25 21 68 27 93 48 1993 22 27 81 21 103 48 1994 29 42 81 28 110 70 1995 41 64 87 30 128 94 1996 41 52 92 37 133 89 1997 42 69 85 39 127 108 1998 53 71 105 41 158 112 1999 45 76 105 40 150 116 2000 55 91 76 21 131 112 2001 66 91 81 39 145 130 2002 50 70 83 38 133 108 Total 510 725 1,066 386 1,576 1,111

14

rolled over as compared to those vans that were involved in multiple vehicle crashes (Table 3).30

In the period from 1990 to 2002 about 68 percent of all rollovers involving the 15-passenger van

occurred in single vehicle crashes.

NHTSA also examined the rate of fatal, single vehicle crashes per 100,000 registered

vehicles by vehicle type from 1995 to 2002 (Table 4). The number of 15-passenger vans

involved in fatal, single vehicle crashes per 100,000 registered vans has been decreasing since

1995, but is still higher than other categories of passenger vehicles.31 Thus, the higher rate of

fatal, single-vehicle crashes could be due to the increased occupancy level in the larger 15-

passenger van, and the occupancy level, in turn, increases the probability of a fatality.

In 2004, when data collected from NHTSA State Data Reporting System (SDRS) for

Florida, Maryland, North Carolina, Pennsylvania, and Utah are analyzed to compare the 15-

passenger van’s propensity of rollover to other vehicles, unique results are found. According to

Table 5, single vehicle crashes with rollover have low rates of incidence for 15-passenger vans

when compared to SUVs, Pickup Trucks, and Other vans.32 About nine percent of all crashes

involving 15-passenger vans were single vehicle crashes. The incidence of single-vehicle crashes

as a proportion of all crashes was the lowest for minivans at eight percent and highest for SUVs

at 14 percent.33

NHTSA studied rollover rates in terms of 100,000 registered vehicles. Overall, the

occupant fatality rates in all fatal crashes for passenger cars, SUVs, and pickup trucks were

similar, and higher than the rate for minivans and large vans, which includes cargo and

commercial, as well as, both 12 and 15-passenger vans.34 For example, the occupant fatality rate

per 100,000 registered passenger car, SUV, and pickup truck vehicles was about 15, the occupant

fatality rate per 100,000 registered vans was 10.75.35 In 2004, compact cars had an occupant

15

Table 3: 15-Passenger Vans that Rolled Over and Subsequent Fatalities by Type of Crash, 1990-200230

Single Vehicle Multiple Vehicles All Rollovers Year Vehicles Fatalities Vehicles Fatalities Vehicles Fatalities

1990 12 17 9 6 21 23 1991 15 20 5 8 20 28 1992 15 16 10 5 25 21 1993 18 24 4 3 22 27 1994 19 25 10 17 29 42 1995 29 49 12 15 41 64 1996 31 42 10 10 41 52 1997 28 55 14 14 42 69 1998 35 49 18 22 53 71 1999 31 60 14 16 45 76 2000 39 72 16 19 55 91 2001 44 70 22 21 66 91 2002 33 57 17 13 50 70 Total 349 556 161 169 510 725

Table 4: Number of Fatal, Single-Vehicle Crashes per 100,000 Registered Vehicles, 1995-200131

Vehicle Type 1995 1996 1997 1998 1999 2000 2001 Passenger Cars 9.6 9.3 8.9 8.6 8.2 8.1 8.0 SUVs 14.3 14.1 13.6 13.3 13.0 12.7 11.8 Pickup Trucks 13.0 12.3 11.8 11.8 11.7 11.3 11.4 15 Passenger Vans 19.8 19.6 14.7 14.3 14.2 12.9 13.9 Other Vans 7.3 7.4 7.5 7.7 7.4 7.2 6.5

Table 5: Crashes and Rollovers by Crashes Type and Type of Vehicle32

Single Vehicle Crashes Multiple Vehicle Crashes All Crashes Vehicle Type Crashes Rollovers % Crashes Rollovers % Crashes Rollovers %

15-P Vans 1,441 315 22 14,181 172 1 15,622 487 3 Passenger Cars 423,760 66,318 16 3,201,707 24,320 1 3,625,467 90,638 3 SUVs 61,968 23,927 39 378,949 9,625 3 440,917 33,552 8 Pickup Trucks 98,282 26,187 27 654,532 9,936 2 752,814 36,123 5 Minivans 16,205 2,746 17 186,224 2,389 1 202,429 5,135 3 Other Vans 15,745 3,592 23 154,360 2,476 2 170,105 6,068 4 Other/Unknown 71,855 14,491 - 543,700 7,943 - 615,555 22,434 - Total 689,256 137,576 20 5,133,653 56,861 1 5822909 194437 3

16

fatality rate of 17.76 fatalities per 100,000 registered vehicles, followed by compact pickup

trucks at 16.87, subcompact cars at 16.85, and midsize SUVs at 16.16 (Table 6). Large vans,

which included all vans of similar size irrespective of whether or not they were passenger or

cargo vans, is a broad category; nonetheless, the large van had the lowest occupant fatality rate at

9.34 (Table 7). On the whole, subcompact cars, compact cars and compact pickup trucks have

the highest overall occupant fatality rate while large vans, and minivans have the lowest

occupant fatality rate.

Since 2000, the occupant fatality rates for all vehicle types and sizes in all crashes are

trending flat or downward. The same holds true for vehicles that rolled over, with the exception

of the full-size SUV, where there is an upward trend.36 Among vehicles that rolled over, midsize

and full-size cars had the lowest occupant fatality rate while midsize SUVs had the highest

occupant fatality rate. According to Table 7, among vehicles that rolled over, midsize SUVs had

an occupant fatality rate of 9.86 followed by full-size SUVs at 7.92 while full-size cars had the

lowest occupant fatality rate at 2.47 fatalities per 100,000 vehicles.37 The data for this research

was limited to one year (2004), and the data for the large van category of vehicle was not just

limited to 15-passenger vans.

Generally, regardless of the number of vehicle occupants, 15-passenger vans have the

same rollover ratio as does light trucks and vans; however, when rollover ratios associated with

vehicle occupancy were studied, the propensity for 15-passenger vans to roll over increased with

the occupancy level.38 It can be inferred from the data that a 15-passenger van that has 15

occupants runs almost six times the risk of rolling over as compared to a 15-passenger van that

has less than five occupants, when involved in a single vehicle crash.39

17

Table 6: Total Occupant Fatality Rates per 100,000 Registered Vehicles by Vehicle Type and Size, 200435

Vehicle Type and Size Rate Compact Cars 17.76 Compact Pickups 16.87 Subcompact Cars 16.85 Midsize SUVs 16.16 Standard Pickups 13.87 Full-size SUVs 12.34 Full-size cars 12.16 Midsize cars 11.49 Minivans 11.09 Large Vans 9.34

Table 7: Total Occupant Fatality Rates in Vehicles that Rolled Over, per 100,000 Registered Vehicles by Vehicle Type and Size, 200435

Vehicle Type and Size Rate Midsize SUVs 9.86 Full-size SUVs 7.92 Compact Pickups 7.19 Standard Pickups 6.38 Compact Cars 4.24 Large Vans 4.04 Subcompact Cars 3.62 Minivans 3.45 Midsize Cars 2.71 Full-size Cars 2.47

18

In May 2008 NHTSA published a study that examined fatalities of 15-passenger vans

that rolled over from 1997-2006.40 The research indicated that fatalities have been on a

downward trend since 2001, when the first NHTSA consumer advisory was issued for the 15-

passenger van. In 2001 there were 91 fatalities in vehicles that rolled over; this constituted 70

percent of all crashes involving the 15-passenger van. This number steadily decreased to a total

of 28 fatalities in 2006 or 43 percent of all crashes (Table 8).41 This steady decrease could also

be found in the percentage of 15-passenger van crashes where the van rolled over. In 2006, 18

percent of 15-passenger vans involved in fatal crashes rolled over; whereas in 2001 this

proportion was much higher at 45 percent.42 With regard to 15-passenger van occupancy and

vehicle rollover from 1997 to 2006, one quarter of vans involved in fatal crashes with fewer than

ten occupants rolled over; whereas 70 percent of vans involved in fatal crashes with ten or more

passengers rolled over.43 In 2006, 15 percent of 15-passenger vans with fewer than ten

occupants rolled over, and 43 percent of vans with ten or more occupants rolled over.44

Furthermore, there is a relationship between fatalities in 15-passenger vans rollover crashes and

van occupancy during the time period from 1997 to 2006 (Table 9).45 In the vans that had ten or

more occupants, 89 percent of fatalities occurred when the vans rolled over; in vans that had ten

or fewer occupants, only 49 percent of the fatalities occurred when the vans rolled over.46 In

2006, 42 percent of fatalities occurred when the van rolled over with ten occupants or less, and

when loaded with ten passengers or more, 50 percent of fatalities occurred when the van rolled

over. Overall from 1997 to 2006, about 67 percent of the all occupants in 15-passenger vans

involved in fatal rollover crashes were unrestrained.47 Of the fatally injured occupants in these

vans, 83 percent were unrestrained.

19

Table 8: Fatalities (Total and Rollovers) to Occupants of 15-Passenger Vans, 1997-200641

In Vehicles that Rolled Over

Crash Year Total Number % of Total 1997 108 69 64% 1998 112 71 63% 1999 116 76 66% 2000 112 91 81% 2001 130 91 70% 2002 108 70 65% 2003 127 65 51% 2004 120 69 58% 2005 99 60 61% 2006 58 28 45% Total 1,090 688 63%

Table 9: Occupant Fatalities in 15-Passenger Vans (Total and Rollovers) by Occupancy 1997-200645

Fewer Than 10 Occupants 10 or More Occupants

In Rollovers In Rollovers Year Total Number % Total Number % 1997 59 28 47% 49 41 84% 1998 67 33 49% 45 38 84% 1999 68 34 50% 48 42 88% 2000 58 41 71% 54 50 93% 2001 66 41 62% 64 50 78% 2002 61 28 46% 47 42 89% 2003 79 27 34% 48 38 79% 2004 79 36 46% 41 33 80% 2005 69 34 49% 30 26 87% 2006 38 16 42% 20 10 50% Total 644 318 49% 446 370 83%

20

NHTSA’s research has shown that that the more passengers a 15-passenger van is

carrying, the more likely the van is to overturn. A 15-passenger van that has 15 occupants runs

almost six times the risk of rolling over as compared to a 15-passenger van that has less than five

occupants, when involved in a single vehicle crashes. About two-thirds of the fatalities to

occupants of 15-passenger vans occurred when the vans rolled over, and when the 15-passenger

van overturned more than half the time they were involved in single-vehicle crashes. More than

three-quarters of all fatalities that occurred in 15-passenger van rollover incidents were in single

vehicle crashes. However, overall single vehicle crashes with rollover have low rates of

incidence for 15-passenger vans when compared to SUVs, Pickup Trucks, and Other vans.

Overall there has been a decrease in occurrence of 15-passenger van rollover crashes and

associative fatalities, but unrestrained occupants in vans with ten or more passengers have a

higher fatality rate than restrained occupants. NHTSA has continued its research of 15-

passenger vans by studying the effects of tire pressure on the vehicle’s propensity for rollover

and the use of electronic stability control devices.

Tire Pressure Study

In 2003, NHTSA’s National Center for Statistics and Analysis conducted a 12 and 15-

passenger Van Tire Pressure Study (VTPS) to determine the extent of tire under or over-

inflation, as well as to observe the tire condition in 12- and 15-passenger vans. The research

focused on moderately to fully-loaded vehicles and those that are used to transport children and

young adults. Church and community groups, universities and colleges, day care facilities, and

camps made up 48 percent of the sample. Vanpool providers, transportation and limo services

made up 24 percent of the sample, while local governments, and the military made up eight

percent of the survey. Hotels at five percent and an other category at 14 percent made up the

21

remainder of the sample. The total is not 100 percent due to rounding errors.48 The total

number of vehicle inspections completed was 1,242, including 937 15-passenger vans.

The study defined a tire as under-inflated if the PSI (Pounds Per Square Inch) was 25

percent or less than the PSI indicated as the correct tire pressure found on the placard located

either in the door frame or owner’s manual. VTPS found that 56 percent of all vans had at least

one tire under inflated by 25 percent or more.49 The study also found that 16 percent of the 15-

passenger vans in the study had recommended pressures below this value.

With regard to over-inflation, the study found that 22 percent of all 12 and 15-passenger

vans had at least one tire over inflated by at least 25 percent of the recommended pressure.50

This could possibly be explained by the difference between the placard pressure (typically 45 or

55 PSI) and the maximum pressure listed on the tire sidewall (80 PSI). Finally, the study found

that 18 percent of the 15-passenger vans had at least one bald tire defined as a tread depth of

1/8th of an inch or less.51

NHTSA then conducted a second study to determine the effects on the handling and

rollover resistance using only one 15-passenger van with under-inflated tires. Four different

front/rear tire inflation pressure combinations were used, along with multiple loading

configurations.52 Overall, decreasing the front and rear inflation pressure from that specified on

the vehicle's placard had a small adverse affect on the vehicle's rollover resistance.53 Though

this second study is limited in that it only included one vehicle, correct tire pressure has been

found to improve vehicle handling.

Overall, good tire care improves vehicle handling and fuel efficiency. Theoretically,

proper tire maintenance could decrease the probability of tire blowouts that cause a loss of

vehicle control. Low tire pressure could also increase stopping distances and the chance of

22

hydroplaning on wet surfaces. The data from the VTPS shows that a fairly high percentage of

large vans have significantly under inflated tires, a much larger percentage than passenger cars.54

Electronic Stability Control

In 2004, NHTSA began a preliminary study on the use of electronic stability control

devices (ESC) in 15-passenger vans. ESC systems use automatic computer-controlled braking of

individual wheels to assist the driver in maintaining control in panic driving situations. The first

study used two vans; one was factory equipped with ESC, and the other was not. Four different

load configurations were used to compare the van’s performance. Generally, van stability and

rollover resistance degraded as more occupants were loaded into the vans irrespective of ESC.

Results of the study indicated that ESC on 15-passenger vans may increase the stability and

rollover resistance in some, but not all, on-road driving situations.55 However, NHTSA

estimated that ESC has the potential to prevent 71 percent of passenger car rollovers and 84

percent of SUV rollovers in single-vehicle crashes.56

The Reaction Varies by Market Segment

As early as 1999, NHTSA began to strongly recommend that pre-school and school aged

children not be transported in 15-passenger vans. NHTSA mailed letters to each state president

of the National Automobile Dealers Association, and to each state director of pupil transportation

outlining the Federal requirements and restrictions concerning the sale or lease of vehicles used

to transport students to and from school, and NHTSA's school bus safety standards.57 Enclosed

with each of these letters was a fact sheet, "School Buses: The Safest Choice for Student

Transportation," explaining why school buses are safer than 15-passenger vans for transporting

children.

23

In spite of these warnings, no federal law was passed regulating the use of the 15-

passenger van since these vans were not deemed school buses; federal regulations only addressed

the sale of new 15-passenger vans to transport children. This lack of comprehensive federal

regulation prompted states to pass their own legislation regarding the use of 15-passenger vans to

transport children.

The market segments that use the 15-passenger van (i.e. day care centers, church groups,

public and private schools, universities, rural transit providers, and commuter groups) responded

differently based on state laws, as well as perceived risk. Unfortunately, state laws and

regulations vary widely. Also, state laws do not necessarily apply to private or church-related

schools, day care centers, companies that contract directly with parents of school-age children or

students attending state universities. According to the National Transportation Safety Board

“State laws…do not provide uniform safety. Further, the lack of [uniform] 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 crashes.”58

K-12 Schools and State Law

Some states do not require the use of school buses to transport children to and from

school and school-related events. In 2004, NHTSA published a report on a survey of state laws

on 12- and 15-passenger vans used for school transportation. This report has been updated to

reflect the laws as of June 2008. Of the 50 states surveyed, 29 states have laws or regulations

that prohibit the use of 12 and 15-passenger vans for transporting public school students both to

and from school as well as any school-related activities (Appendix D: State Laws Prohibiting the

Use of 15-Passenger Vans). Thirteen states prohibit the use of 15-passenger vans to transport

24

students to and from school, but not to transport students to and from school related events, and

eight states allow use of vans for transporting public school students to and from school and

school-related activities. Seventeen states have passed laws or regulations that do not apply to

private schools or private day care centers.59 However, some states also have passed legislation

prohibiting the transportation of day care children in 15-passenger vans. For example, as of

January 1, 2007, the State of Tennessee requires all vehicles used by child care agencies that

carry ten or more passengers to conform to school bus standards. Vehicle providers such as the

Tennessee Vans Program have purchased school buses to meet the transportation needs of the

daycare segment. Agencies that transport children in vans, which are designed to carry fewer

than ten passengers, are not affected.

State University Systems

The reaction of the state university systems to state regulation and the perceived risk of

operating 15-passenger vans was unique to this particular market segment because state

regulation often did not directly impact the state university systems. Of the 50 state universities

contacted, 23 responded to a questionnaire regarding the use of 15-passenger vans to transport

students, faculty and staff. The assumption was that there were system wide policies for every

state university campus. This was not necessarily true for all state university systems. For

example, the state universities for Florida, New York, Utah and Wisconsin have no single state-

wide policy and allow different campuses to develop their own policies and/or training programs.

Eight of the state university systems do not use the 15-passenger van to transport students,

faculty members or other clients. Two of these universities converted their 15-passenger vans to

an 11-passenger van by removing the rear seat, and one university converted their 15-passenger

vans to utility vehicles for facilities staff use. Eleven university systems use the 15-passenger

25

van. Because the vans are often driven by inexperieinced dirvers, all but two systems require

some type of training (e.g. online, face-to-face, behind the wheel driver training, etc.). Three

systems modified the van to increase safe operation; these include dual rear tires, and removal of

roof racks and trailer hitches (Appendix E: State University Systems Use of the 15-Passenger

Van).

Church Van Use

Unlike commuter vanpools, church vans are often driven infrequently by different drivers

without any age, licensing or experienced driver restrictions. Unfortunately, except for

incidental examples of 15-passenger crashes involving church groups, there are no methods for

gathering crash data or data about the drivers from churches that use 15-passenger vans. A

number of incidental accident and fatality stories can be found (e.g. First Baptist Church of

Piedmont, S.C., First Assembly of God Church in Burkeburnett, Texas, Holy Prayer Apostolic

Church in Tyler, Texas, and St. Antonius Coptic Church in Yermo, California), but there is no

one source to find information about all crashes. However, church insurance companies can

provide guidelines for church van use. According to Church Underwriters:

Each insurance company treats these vehicles [15-passenger vans] differently, but each does recognize the rollover risk inherent with these vehicles. Some companies just flat out will not write these vehicles. Some will, but will only consider newer vehicles and have controls or guidelines in place. These guidelines may include requirements for driver experience/training, altering the seating capacity to keep the center of gravity lower, restrictions on trailers, etc.60 One example of a church insurance company that requires guidelines includes Church Mutual.

Church Mutual requires the rear seat and trailer hitch to be removed, all drivers to be at least 25

years old, and for the church to keep a list of all drivers who can use the van. The driving record

of each van driver is checked annually, and anyone with a violation or ticket in the last 3 years

cannot drive the van.61 On the other hand, Liberty Mutual, which is not a church specific

26

insurance carrier, will insure any 15-passenger van that is 10,000 pounds or lighter in weight; no

special license or van modifications are required. Between 1999 and 2001, GuideOne Insurance

policyholders filed claims totaling $4.3 million for five crashes involving 15-passenger vans,

which caused 11 deaths and 20 serious injuries. GuideOne responded by strongly urging

churches to consider other transportation options, and imposing driver guidelines for the vans use

and insurance. For example, the church must have a list of current drivers, the vehicles they

drive, and the motor vehicle report of each driver. Driver requirements include:

• Not have any alcohol or drug-related violations for the prior five years. • Have a valid U.S. driver's license. • Be 25-70 years old. • Have no more than one at-fault accident for the prior three years. • Have either a Commercial Driver's License or passed a defensive driving course to

operate a 15-passenger van.62 Tennessee Rural and Specialized Transit Providers

Rural transit providers are similar to commuter vanpool drivers in that training is

required. Unfortunately, unlike commuter vanpool training, this training does not necessarily

cater specifically to the operation of a 15-passenger van. In Tennessee, there are 37 rural and

specialized transit providers, 32 of these providers answered questions regarding their use of 15-

passenger vans, van modification, and driver training. Twenty-four of the 32 providers used 15-

passenger vans to transport their clients; eight agencies used other van types, such as 12-

passenger vans or mini-vans (Appendix E: Rural and Specialized Transit Providers in

Tennessee). Of the 31 organizations that provide either rural or specialized transit for Tennessee

residents, 23 use 15-passenger vans and eight agencies do not use the 15-passenger van to

transport their clients. The number of 15-passenger vans used range from 84 for the Southwest

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Human Resource Agency, which has eight satellite offices, to the one 15-passenger van used by

Hancock County Rural Transportation System.

Techniques used to mitigate rollover, such as removing the rear seat to reduce vehicle

capacity or installing dual rear tires, was only implemented by three of the 31 agencies – one

removed the rear seat, one agency installed dual rear tires on two of their five vans, and one

agency installed dual rear tires on all of their vans as well as removed the rear seat. Finally,

driver training is not consistent for rural transit or specialty transit providers in Tennessee. Three

of the 23 agencies that use 15-passenger vans do not require any special training or licensure for

their drivers. Nine agencies require an F-endorsement, which allows the driver to operate a

vehicle that is designed to seat 15 or less individuals including the driver.63 One agency required

a Commercial Drivers License, which allows the driver to transport more than 15 passengers,

and one agency required a Class C license with a P-Endorsement, which also allows the driver to

transport more than 15 passengers.64 All but three agencies required some type of training.

These transportation agencies used the Tennessee Transit Training Center at Middle Tennessee

State University and some type of in-house training, consisting of classroom and/or road

experience training, most often.

Commuter Vanpools

Because of state regulation or perceived risk, some day care centers, primary and

secondary public schools, and state universities began to eliminate the 15-passenger van from

their fleet. However, the problem of 15-passenger van rollover is not constant throughout all

market segments. Commuter vanpools and rural transit providers do not have the 15-passenger

van fatality rates of state universities or churches. In fact, the Vanpool Council of the

Association of Commuter Transportation (ACT) stated that vanpools are the safest form of

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public transportation.65 According to the USDOT Bureau of Transportation Statistics there have

been no reported fatalities to passengers in commuter vanpools using 15-passenger vans since

1998.66 In 2004, the head of NHTSA made a point of stating that commuter vanpool drivers

tended to have experience handling the vans, and that infrequent drivers of 15-passenger vans

were at greatest risk. These infrequent drivers include university students and church van drivers;

whereas the more experienced drivers include vanpool drivers and rural transit providers.

According to VPSI, a leader in the vanpool industry for 30 years, “VPSI supports and

agrees with the position of NHTSA in that fifteen passenger vans should be operated by

experienced drivers familiar with the handling characteristics of vans, especially when fully

loaded.”67 To ensure the safety of all 15-passenger van riders, VPSI established minimum age,

driving experience, training, and motor vehicle record requirements as eligibility standards for

becoming an approved commuter vanpool driver. VPSI also conducts post accident reviews of

driving records and bi-annual reviews of all existing drivers. VPSI requires all drivers and

passengers to use a three point seat belt harness, and provides coupons for divers to routinely

service their vehicles, including the regular inspection and rotation of tires.68 Typically,

commuter vanpools are driven by the same one or two people every day over the same route.

The average VPSI commuter vanpool driver is 46 years old, with at least six months of vanpool

experience. 69

The average VPSI commuter vanpool diver is trained and experienced, but accidents do

occur. However, in most cases occupants of commuter vanpool vehicles involved in crashes

have survived with minor, if any, injuries. Of the five single vehicle crashes from the past five

years resulting in van rollover, three were a result of the driver losing control on ice and sliding

off the road, and two were the result of hitting a median or guardrail.70 There were no fatalities.

29

In two of the crashes, there were three injuries consisting of a shoulder injury, a minor cut, and a

broken elbow.71 The one exception was a commuter van rollover incident in California that

resulted in fatalities. In 2004 three people who worked for NASA's Jet Propulsion Laboratory

(JPL) died when their commuter van plummeted off a mountain road in the Angeles National

Forest.72 The cause of the accident could have been due to clouds and fog, as well as the

highway, a twisting, two-lane blacktop with steep drops. About 450 of the 5,500 people who

work at JPL participate in its vanpool program, which involves about 30 vans.73

A Further Investigation of Commuter Vanpools

At the 2007 ACT International Conference contact was made with a number of commuter

vanpool operators. ACT is an organization that provides advocacy, networking services,

publications, professional development and information sharing opportunities to members

interested in transportation demand management policies and program evaluation for carpools

and vanpools. A number of representatives shared their experiences with vanpool rollover issues.

These representatives included individuals from state, county and regional markets (Table 10). 74

All representatives stated they had experienced no problems with “rollover” with 15-

passenger vans used as commuter vehicles. Currently the representatives reported that the vans

are being upgraded with stabilizer technology, which will further serve to alleviate any concerns.

The success in avoiding rollover issues was attributed to the following factors:

1. Drivers are mature and their record is scrutinized before being able to operate a vanpool. Driver records are continuously monitored.

2. Drivers receive extensive training, which may include in-field driving checks. 3. Drivers are continuously made aware of the rollover issue. 4. Many vanpools do not operate in high speed traffic conditions, which is felt to reduce the

chances of rollover incidents. 5. Seat-belt use is absolutely required by both passengers and driver.

30

Table 10: Organizations that Operate Vanpools74

Organization Commuter Vans Washington State Department of Transportation State Vanpool Program

373

North Carolina Rural Vanpool Program 14 Puget Sound Vanpool Program 1662 King County Metro Vanpool 50 Mid-Ohio Regional Planning (Columbus Ohio VPSI Operated)

40

Representatives of vanpool services who operate other van pool projects

4,000

Total 6,139

Figure 1: Fatalities per 100 Million Vehicle Miles By Commuter Mode75

Fatalities per 100 Million Vehicle Miles Transit Safety Date by Mode for All Reported Accidents: 1990-1999

National Transportation Statistics 2000 - USDOT Bureau of Transportation Statistics

31

In response to the June 2004 NHTSA warning to users of 15-passenger vans, ACT president, Jon

Martz reiterated that “When compared, mode by mode, to other types of public transportation

(including bus and rail), commuter vanpooling is by far the safest form of public transportation”

(Figure 1). 75 According to the "National Transportation Statistics 2000," a report compiled for

the U.S. Congress:

• Between 1990-2000, there were no reported fatalities to passengers in commuter vanpools. The reported sample represented ~35% of national fleet of 8,000 vanpools.

• Between 1998-2000, there were no reported fatalities to passengers in commuter vanpools. This ACT-expanded sample represented ~80% of the national fleet of 8,000 vanpools.

Commuter rail has the highest number of fatalities per 100 million vehicle miles at 27.4. On the

other hand, demand response vehicles, which do not operate over a fixed route and often pick up

several handicapped or elderly passengers at different pick-up points, has the next to the lowest

number of fatalities per 100 million vehicle miles at 1.4. Based on these statistics, commuter

vanpools had no fatalities at this time period.76

In addition, using the National Transit Database over a ten-year period, Jon Martz

compiled numbers from the largest private, public and public/private partnerships across the

United States. Using those numbers, he detailed fatalities per 100 million vehicle miles traveled

and fatalities per 100 million passengers with respect to the different kinds of public

transportation in certain areas. According to his statistics, commuter vanpooling had no fatalities

in 2000.77

For a more complete assessment of non-fatal and non-injury crashes (property damage

only crashes) an analysis of the crash records from the Tennessee Vans program was initiated.

These statistics include fatality rates, injury rates, rollover incidences, property damage and cost

32

Table 11: Summary Statistic for Tennessee Vans*79

Data Description Tennessee Vans National Average Fatalities

• Leased vans 0 0 • Vanpools 0 0

Fatality Rate • Per 100 Million Vehicle Miles of Travel 0 1.48

Personal injuries • Leased vans 0 -- • Vanpools 0 --

Personal Injury Rate • Per 100 Million Vehicle Miles of Travel 0 100.0 (2006)

Rollover Incidents • Leased vans 0 -- • Vanpools 0 --

Property Damage Events • Leased vans 26 -- • Vanpools 10 --

Property Damage Crash Rate -- • Per 100 Million Vehicle Miles of Travel 240 270.0 (1996)

o Leased vans 338 245.0 (Average) o Vanpools 161 219.0 (2003)

Tennessee Property Damage • Crash Rate per 100 Million Vehicle

Miles of Travel 287.0

Crash Cost per Vehicle Mile (Cents) 0.57 0.61 • Leased Vans 0.63 -- • Vanpools 0.54 --

* For 256 vans placed in service between 1990 and retired by May 2008

33

per vehicle mile for the 256 vans placed in service between 1990 and retired by May 2008.78

National averages are provided for comparison.

The Tennessee Vans Program

An independent assessment was conducted analyzing the crash record of Tennessee Vans

and the safety history of 256 vans placed in service since 1990 and retired before May 2008. Of

these vans 128 were commuter vanpools and 128 were leased vans operated by public, private,

and non-profit community agencies, churches and other groups. The Tennessee Vans program

has a property damage crash rate of 240 per 100 million vehicle miles of travel; this is less than

the 1996 national average of 270 per 100 million vehicle miles of travel (Table 11).79 The cost

per vehicle mile is less than the national average, a difference of four cents per mile. Many of

the leased vans are operated using drivers who are not dedicated drivers as in commuter

vanpools. The Tennessee Vans vehicle fleet operated over 17.5 million vehicle miles over the

life of the vans (9.8 million for commuter vanpools and 7.7 million miles for leased vans) (Table

12). Over the life of these vans, they were operated on the average of 12,568 vehicle miles per

year. There were no fatalities, no injuries and no rollover incidents. In fact, Tennessee Vans

with a history of operating 823 vans since 1990 had only one fatal incident in 1999 that was

caused when a flatbed trailer struck the van.80 The van was operated by a youth group as part of

the van purchase group. Since the van purchase program does not relay on insurance provided

by Tennessee Vans, reliable crash records were not available to the researchers. However no van

in the fleet had ever had a rollover incident.

Over the history of this sample of vans in the Tennessee Vans program, property damage

occurred in 42 vehicles (15 reported for vanpools and 26 reported for leased vans) as indicated in

Table 12. These incidents caused $101,500 dollars of damage ($48,800 dollars for leased vans

34

Table 12: Tennessee Vans: Leased and Commuter Vanpooling Van Use*79

Year 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 No. leased vans operated

3 12 12 13 19 20 27 40 46 54

No. commuter van operated

9 11 22 38 52 57 63 69 62 60

Leased van vehicle miles

4,586 112,210 214,732 223,738 257,309 301,101 358,543 494,210 659,223 675,755

Commuter van vehicle miles

28,624 177,038 264,067 539,236 769,455 1,006,254 1,107,611 1,110,282 1,022,569 791,496

Fatalities 0 0 0 0 0 0 0 0 0 0 Injuries 0 0 0 0 0 0 0 0 0 0 Rollover 0 0 0 0 0 0 0 0 0 0 No. of Events -- -- 2 3 5 2 3 5 4 1 Leased -- -- 2 3 -- 1 2 2 3 1 Vanpool -- -- -- -- 5 1 1 3 1 -- Year 2000 2001 2002 2003 2004 2005 2006 2007 2008 Total No. leased vans operated

68 76 72 63 49 35 16 13 3 --

No. commuter van operated

40 37 33 30 27 23 12 9 -- --

Leased van vehicle miles

683,253 901,275 965,795 818,676 537,092 254,231 147,596 73,384 10,552 7,693,261

Commuter van vehicle miles

595,704 500,946 442,364 468,768 472,258 294,946 163,276 80,658 -- 9,835,552

Fatalities 0 0 0 0 0 0 0 0 0 0 Injuries 0 0 0 0 0 0 0 0 0 0 Rollover 0 0 0 0 0 0 0 0 0 0 No. of Events 4 3 3 2 4 1 -- -- -- 42 Leased 3 1 1 2 4 1 -- -- -- 26 Vanpool 1 2 2 -- -- -- -- -- -- 16 *Crashes per 100 million vehicle miles

35

and $52,700 dollars for vanpools). Aggregated summary data are provided in Table 12 for the

performance of these vans. The results indicated that on a per-vehicle mile basis commuter

vanpools operated much safer than individual passenger vehicles, while leased vans operated a

little bit above the national rate for passenger vehicles. So a difference in safety performance is

illustrated by comparing the statistics of commuter vanpools with leased van operators, partly

reflecting that leased van operators utilize a diverse pool of divers with varying driver

experience. The cost in cents per vehicle mile are comparable for the two programs, but leased

vans are a little higher than the national average for passenger cars in 2000, while vanpools are

less than the national average. It is agreed by program management that vanpool drivers receive

more staff contact and may be more experienced. Most significantly is the fact that the

Tennessee Vans statistics represent vehicle miles of travel and the vans have average vehicles

occupant of 10 to 12 passengers, while the average passenger car has an occupancy of less than

two occupants per vehicle. These statistics would be even most impressive if viewed as

passenger miles of travel.

Comparative data for 15-passenger vanpools were provided by the King County Metro

Vanpool program for 2003-2007. Again no rollovers or fatalities were recorded for the fifty 15-

passenger vans in the fleet of 740 vans (Table 13).81 The injury rate was 59.1 per 100 million

vehicle miles of travel which is half of the national rate. Like Tennessee Vans, the King County

Metro Vanpool program had no fatalities or rollover incidents.

However, the fact remains that commuter vanpools, such as the Tennessee Vans program,

that relay on the use of 15-passenger van for transportation, had exemplary safety records

involving no fatalities, no injuries and no rollovers. Anecdotal evident from other commuter

vanpool programs confirm this observation.

36

Table 13: King County Metro Vanpool: Commuter Vanpooling and 15-Passenger Van Use*81

Data Description 2003 2004 2005 2006 2007 Total Number of Fatalities 0 0 0 0 0 0 Number of Rollover Accidents

0 0 0 0 0 0

Number of Injuries 1 0 2 0 0 3 Number of Events 9 6 5 12 6 38 Number of 15-Passenger Vans in Operation

51 41 49 57 59 257

Miles Traveled 15-Passenger Vans

1,181,728 900,529 991,166 970,333 1,030,088 5,073,844

Average Number of Riders in 15-Passenger Vans

9 8.7 10 9.4 9.1 --

Average Number of Riders in All Vans

8.2 8.1 8.3 8.3 8.2 --

Number of All Vans in Operation

663 662 732 801 845 --

*Note: Events include situations other than collisions and are not comparable with the Tennessee Vans Program statistics or national data for passenger vehicles.

37

The different market segments of public schools and universities, commuter vanpools,

church groups, and rural transit providers responded in varying degrees to the state legislation

and perceived risk of using the 15-passenger vans. As a result of state regulation, a large number

of public elementary and secondary schools were prohibited from using 15-passenger vans to

transport students. Generally, these state laws did not apply to private schools or state

universities. Eleven of the nineteen universities that had a statewide policy still used 15-

passenger vans, and nine of the eleven require training for their van drivers. By and large, the

commuter vanpool drivers have to undergo very strict driver training and regulation before

driving a 15-passenger van. The requirements for rural transit providers in Tennessee are also

somewhat strict; however, because there is not one central entity regulating churches, church use

of the 15-passenger van is regulated only by the insurance agencies.

Recommended Practices and Conclusion

Guidelines were assembled from a variety of data sources in an attempt to generate a list

of best practices regardless of market segment. The guidelines are appropriate to all

organizations that use the 15-passenger van. Solutions to mitigating the 15-passenger van’s

propensity for rollover include agencies adapting guidelines for the use of the vehicle, drivers

receiving proper and periodic training, and the physical alteration of the 15-passenger van. A

number of guidelines are presented that could help steer an agency’s decisions to ensure

passenger and driver safety. None of the guidelines should be considered a requirement, but a

reflection of what other agencies do to make travel with a 15-passenger van dependable and

secure.

38

Agency Responsibilities

Agencies (i.e. churches, universities, private transportation service, etc.) should have the

responsibility of choosing an appropriate van driver. Guidelines should be related to driver age

and experience, license type, driving record, and any other restrictions. In some cases, agencies

have required drivers to map out a route that limits use of high-speed interstates. Below are a list

of guidelines for agencies, these include minimum driver standards, preparing the van, training

options, and defensive driving techniques. Agencies have the responsibility of making sure their

vans are driven correctly and that their passengers are safe. When possible 15-passenger vehicles

should be selected with stability control devices and tire pressure gauges already installed.

Minimum Driver Requirements

• Choose a driver with a courteous and calm attitude • Ask for and check references of all drivers • Check that the driver has a valid driver license; some agencies require a special

endorsement or a Commercial Drivers License • Establish a minimum age requirement for all drivers; some agencies require all drivers to

be at least 21 years old • Establish a minimum experience level; some agencies require all drivers to have at least

five years of licensed driving experience • Check the driving record of all drivers; some agencies require three years of a clean

vehicle record • Continuously recheck the driving record of all divers • Choose a driver in good physical condition; some agencies require an annual physical

exam • Provide a form that drivers can sign to ensure that they understand the challenges of

operating a 15-passenger van; the “Vehicle Use Acknowledgment Form” (Appendix G: Safe Driving Practices Acknowledgement Statement) provides one example

• Provide driver training and/or refresher training, either by an in-house program or outside vendor, for the following types of drivers:

o New Drivers are drivers who have never driven a 15-passenger van o Experienced Drivers are drivers who have taken driver training, signed the vehicle

use agreement form, have no violations, and, for example, have driven at least 10 hours or 400 miles in the past 3 months

o Infrequent Drivers are drivers who have not driven at least 10 hours or 400 miles in the past three months

39

o Suspended Drivers are drivers who have had two moving violations/crashes/validated complaints within two years or have had a DUI in the past year

• Review each driver every three months to make sure each driver remains qualified (10 hours or 400 miles in the preceding three months)

Minimum Vehicle Requirements

• Place copies of National Highway Traffic Safety Administration’s (NHTSA) “Reducing

The Risk of Rollover Crashes in 15-Passenger Vans" Hangtag,82 and "Reducing The Risk of Rollover Crashes in 15-Passenger Vans" Flier83 in each van

• Establish a maximum number of riders; some agencies limit the total number of passengers to 10 or 12

• Establish limitations on the hours of operation; some agencies limit the use of the van to daylight hours only and/or require another driver to be in the vehicle if more than 400 miles are traveled in one day

• Establish limitation on the number of hours a driver can operate a vehicle; some agencies limit the number hours a driver can continuously operate the van to 4 hours

Driver Training

Driver training is divided between learning how to drive the 15-passenger van and

learning how to inspect the van before using it in both a classroom and a behind-the-wheel

environment. Training can take many forms, like face-to-face instruction, videos, testing,

mailings, online training, behind-the-wheel or any combination of teaching methods. The four

groups of van drivers (New Drivers, Experienced Drivers, Infrequent Drivers, and Suspended

Drivers) require training depending on agency policies. For example, most agencies require basic

van driver training (classroom and behind the wheel) to be taken by new and infrequent drivers,

if they have not driven at least 10 hours or 400 miles in the past three months. Refresher training

should be made available to experienced drivers. Suspended drivers should re-take all training,

both classroom and behind-the-wheel. Suspended drivers may also require additional instruction

or direction not covered here. Training takes two forms: Classroom Training and Behind-the-

Wheel Training.

40

For the classroom training, either through face-to-face or online classes, the classroom

aspect of the training should contain the following:

• Training should be a minimum of 60 minutes • Class size should be six to eight students • A pre-test should be conducted and passed on the basic rules of the road so that the

classroom training can focus on 15-passenger van operation • A test dealing specifically with the 15-passenger van must be passed at the end of the

class before the student can participate in behind-the-wheel training • Online training options include “Coaching the Van Driver”84 produced by National

Safety Council, and the “The Vanpool Difference”85 by VPSI, Inc. The classroom curriculum should also include the following:

• A review of National Highway Traffic Safety Administration (NHTSA) advisories • A review of NHTSA’s Hangtag and Flier for 15-passenger vans • Instruction on the differences between a sedan and the 15-passenger van • Instruction on loading the vehicle so the center of gravity is at the lowest point possible • Instruction on how to inspect the tires, mirrors, signals, fluids, etc. of the van • Instruction on defensive driving techniques (Appendix H: Defensive Driving Techniques)

The behind-the-wheel training portion should contain:

• Class size should be small, no more than six students • Each student should have a minimum of 30 minutes driving time behind the wheel; this

should include lane changes, merging, turning, parking and backing up • Each agency should have a check list of driving maneuvers to cover in the behind the

wheel training portion Driver Responsibilities

Driver responsibility does not simply begin and end with the operation of the vehicle.

Driver responsibility begins before entering the 15-passenger van and only ends when all

passengers are driven safely to their destinations. The driver is accountable for vehicle exterior

pre-trip inspections, interior vehicle inspections and both driver and passenger safety.

Pre-trip vehicle safety inspection requires the driver to do the following: • Make a visual check under the vehicle to check for leaking fluids • Use a tire gauge to check for correct tire pressure and wear • Make a visual check of:

o Head lights

41

o Signal Lights o Tail Lights o Turning Lights o Flasher Lights

Interior vehicle safety inspection includes the following:

• Examine the cleanliness and condition of interior – steps, floor, seats and seat belts • Properly adjust the rearview and side mirrors • Properly adjust drivers seat • Turn on the engine and check:

o Windshield Wipers o Oil level light o Check engine light o Fuel gauge o Power steering o Electric doors and windows working o Horn o Heater/cooler o Unusual noises

Driver safety tips include:

• Wear seatbelt at all times • Get an adequate amount of rest before driving • Do not use alcohol or drugs, including prescriptions that warn of drowsiness, before

driving • Use relief drivers • Avoid highway hypnosis by talking with your passengers • Schedule rest breaks • Study maps and directions prior to the trip • Do not eat while driving • Do not use a cell phone while driving • Do not operate other electronic equipment (iphone, ipod, etc.) when driving • Do not listen to loud music that would prevent hearing sirens and other traffic warning

devices • Transport authorized passengers only • Never leave the driver’s seat when the engine is running • Before leaving the van unattended:

o Shut off the Engine o Remove Keys o Lock all doors/windows

Passenger safety tips include:

• Make sure all passengers are wearing their seatbelts • Load passengers in forward seats first • Ensure that the number of passengers do not exceed the number of seats with seat belts • Check doors to ensure they are closed

42

• Use a positive approach to maintain control of passengers • If needed review with your passengers rules of behavior

Van Modifications

Another solution is to physically alter the 15-passenger van to eliminate its propensity for

rollover. These alterations could be completed by the van users or by the manufacturer. The van

driver/owner could add stabilizers or dual rear wheels to the vehicle, as well as perform other

simple modifications. Other ways of making the vans safer have to be part of the vehicle’s

assembly. This includes widening the vehicle or reducing its height, and using laminated

windows, which is nearly shatterproof.

Modifications to the 15-passenger vans, which could possibly be done by the

driver/owner to reduce the propensity for rollover include: the physical removal of roof racks,

the rearward most seat, and trailer hitches. The driver/owner of a 15-passenger van could have a

licensed professional alter the vehicle to make it safer. Such alterations could include:

installation of anti-sway springs, an electronic stability control, such as StabiliTrak, dual rear

tires, speed control (55 mph or less), and automatic tire pressure gauges.

Changes in the van manufacturing could make the vehicle safer. The manufacturer could

widen the body and reduce its height. These modifications would lower the center of gravity and

further improve stability and resistance to rollovers. The vans could also be produced with

laminated side windows. Laminated glass is far less likely to shatter in a crash than tempered

glass and therefore it is more likely to prevent passengers from being ejected from the vehicle in

a crash. Ultimately, van design is paramount in the safe operation of the 15-passenger van.

The Tennessee Vans Program currently offers 2008 Ford vans that have electronic

stability control capability, three-point passenger restraints, and a tire pressure monitoring

43

system. Ultimately safe operation of the 15-passenger van is the responsibility of both agencies

and drivers.

It is imperative that as new vans are introduced into the fleet they should be equipped

with electronic stability controls and tire pressure monitoring systems. This action will serve to

mitigate the rollover problem; however, continual warnings and consumer advisories are

required for the 15-passenger vehicles currently in the fleet. Safety is an ongoing issue and must

be continually stressed, especially to the driver of the 15-passenger van. Though progress is

being made with manufacturers trying to produce a 15-passenger van that is stable, many older

vans are still being used. Though, it can be demonstrated that the 15-passenger van can be

operated safety for some market segments. The most significant difference between the drivers

of the van in different market segments is experience level. Most church and university drivers

used the vans infrequently, while vanpool and transit providers drove the vans nearly every day.

This level of practice proves very valuable when comparing the accident rates between

experienced and inexperienced drivers. In addition to the skills learned through practical driving

experience, both vanpool and transit providers have a higher level of training than church or

university drivers. Vanpool drivers are taught specifically about the differences between a 15-

passenger van and smaller vehicles. This type of training could be successfully applied to the

incidental van driver to lower the likelihood of vehicle rollover. In addition, requiring all

passengers to wear a seat belt at all times is a must. In 2006, 88 percent of fatally injured

occupants of 15-passenger vans involved in crashes that rolled over were unrestrained.86 Yet,

every seat in the 15-passenger van is equipped with at least a lap belt. Finally, electronic stability

controls could be used to enhance the driver’s ability to maintain control of the vehicle by

selectively braking individual wheel(s), or changing power applied to the wheels. Also tire

44

pressure monitoring systems could be used each time the van is used in order to check for the

correct tire pressure, which can make the 15-passenger van easier to control.

45

References 1 Public Citizen. Accessed March 2, 2008. Fifteen Passenger Van Safety Hazard Information. <http://www.citizen.org/autosafety/passengervan/> 2 Pelley, Scott. Sept. 4, 2002. Rollover. <http://www.cbsnews.com/stories/2002/04/17/60II/main506479.shtml> 3 Public Citizen. Accessed April 1, 2008. 15-Passenger Van Safety Hazards – Thirty years of Faulty Design and Agency Inaction. <http://www.citizen.org/documents/Chron_15.pdf> 4 Healing, Richard F. February 24, 2004. Testimony for H.B. 697 - Pupil Transportation In Vehicles Not Meeting Federal School Bus Safety Standards. < http://www.ntsb.gov/speeches/healing/rfh040224.htm> 5 Gergel, Richard Mark. August 11, 1998. The Jacob Strebler Case presented at School Transportation News: Western States Conference. <http://www.stnonline.com/stn/nonconformingvans/court/strebler_case.htm> 6 SafetyForum. December 27, 2002. 15-Passenger Vans: High-Riding Death Traps. <http://www.safetyforum.com/passengervans/> 7 Garrott, R.W. et al. 2001. The Rollover Propensity of Fifteen-Passenger Vans, National Highway Traffic Safety Administration, Department of Transportation. <http://www-nrd.nhtsa.dot.gov/Pubs/01-030.PDF> 8 National Transportation Safety Board. 2001. Safety Report: Evaluation of the Rollover Propensity of 15-passenger Vans. <http://www.ntsb.gov/publictn/2002/SR0203.pdf> 9 National Association of State Director of Pupil Transportation Services. February 2004. Survey of State Laws on 12- and 15-Passenger Vans Used for School Transportation. < http://www.nasdpts.org/documents/VansSurveyFeb04.pdf> 10 Tennessee Association of Pupil Transportation. Accessed April 2008. Laws and Opinions. < http://www.tapt.org/LawsandVans.pdf> 11 VPSI, Inc. Accessed October 2007. The VanPool Difference. <http://www.vanpoolusa.com/home/submenu.asp?MMID=1&SMID=17&OID=261> 12 Pelley, Scott. Sept. 4, 2002. “Rollover.” <http://www.cbsnews.com/stories/2002/04/17/60II/main506479.shtml> 13 Ammons, Robert E. and Brian Augustus Beckcom. February 1, 2003. The risky ride of the 15-passenger van. <http://goliath.ecnext.com/coms2/gi_0199-2662247/The-risky-ride-of-the.html> 14 Pelley. Ibid. 15 SafetyForum. Ibid. 16 SafetyForum. Ibid. 17 Vehicle Injuries. 2008. “A National Tragedy: Repeated 12- and 15-Passenger Van Rollover Accidents.” <http://www.vehicle-injuries.com/van-rollover-lawsuits.htm> 18 NHTSA Action Plan for 15-Passenger Van Safety. November 2004. <http://www.nhtsa.dot.gov/cars/problems/studies/15passvans/15passvan.html> 19 NHTSA Action Plan for 15-Passenger Van Safety. Ibid. 20 NHTSA Action Plan for 15-Passenger Van Safety. Ibid. 21 NHTSA Action Plan for 15-Passenger Van Safety. Ibid. 22 NHTSA Action Plan for 15-Passenger Van Safety. Ibid. 23 NHTSA Action Plan for 15-Passenger Van Safety. Ibid.

46

24 NHTSA Traffic Safety Research Note DOT HS 810 947. May 2008. “Fatalities to Occupants of 15-Passenger Vans, 1997-2006.” < http://www-nrd.nhtsa.dot.gov/Pubs/810947.PDF> 25 SafetyForum. Ibid. 26 SafetyForum. Ibid. 27 Subramanian, Rajesh. May 2004. National Center for Statistics and Analysis - Technical Report. “Analysis of Crashes Involving 15-Passenger Vans.” Report no. DOT HS-809-753. <http://www-nrd.nhtsa.dot.gov/pdf/nrd-30/NCSA/Rpts/2004/809735.pdf> 28 Subramanian. May 2004. Ibid. 29 Subramanian. May 2004. Ibid. 30 Subramanian. May 2004. Ibid. 31 Subramanian. May 2004. Ibid. 32 Subramanian. May 2004. Ibid. 33 Subramanian. May 2004. Ibid. 34 Subramanian, Rajesh. January 2006. Passenger Vehicle Occupant Fatality Rates by Type and Size of Vehicle. Traffic Safety Facts: Research Note DOT HS 809 979. NHTSA. <http://www-nrd.nhtsa.dot.gov/Pubs/809979.PDF> 35 Subramanian. January 2006. Ibid. 36 Subramanian. January 2006. Ibid. 37 Subramanian. January 2006. Ibid. 38 Garrott. Ibid. 39 Garrott. Ibid. 40NHTSA Traffic Safety Research Note. May 2008. Ibid. 41NHTSA Traffic Safety Research Note. May 2008. Ibid. 42NHTSA Traffic Safety Research Note. May 2008. Ibid. 43NHTSA Traffic Safety Research Note. May 2008. Ibid. 44NHTSA Traffic Safety Research Note. May 2008. Ibid. 45NHTSA Traffic Safety Research Note. May 2008. Ibid. 46NHTSA Traffic Safety Research Note. May 2008. Ibid. 47NHTSA Traffic Safety Research Note. May 2008. Ibid. 48 Thiriez, Kristin K., Eric Ferguson, and Rajesh Subramanian. May 2005. 12 & 15 Passenger Vans Tire Pressure Study: Preliminary Results. Traffic Safety Facts: Research Notes. DOT HS 809 846. NHTSA. <http://www-nrd.nhtsa.dot.gov/pdf/nrd-30/NCSA/RNotes/2005/809846.pdf> 49 Thiriez. Ibid. 50 Thiriez. Ibid. 51 Thiriez. Ibid. 52 NHTSA Action Plan for 15-Passenger Van Safety. Ibid. 53 NHTSA Action Plan for 15-Passenger Van Safety. Ibid. 54 Thiriez. Ibid. 55 NHTSA Action Plan for 15-Passenger Van Safety. Ibid. 56 Dang, Jennifer. September 2004. Evaluation Note: Preliminary Results Analyzing the Effectiveness of Electronic Stability control (ESC) Systems. DOT HS 809 790. NHTSA. <http://www.nhtsa.dot.gov/cars/rules/regrev/evaluate/809790.html> 57 NHTSA Action Plan for 15-Passenger Van Safety. Ibid. 58 NHTSA Action Plan for 15-Passenger Van Safety. Ibid. 59 NHTSA Action Plan for 15-Passenger Van Safety. Ibid.

47

60 Walseth, Erik. Email sent on Tuesday, 23 Sept 2007. Church Underwriters, Inc. <[email protected]> 61 Church Mutual. Accessed February 1, 2008. 15-Passenger Van Alert. <http://www.churchmutual.com/index.php/choice/risk/page/rm_vanalert/id/35> 62 Corporate Communications. Email sent on Monday, 5 Nov 2007. GuideOne Insurance. <[email protected]> 63 2007 Tennessee Driver Handbook. Accessed april 23, 2008. Tennessee Department of Safety. < http://www.state.tn.us/safety/dlhandbook/DL_HandbookWeb2007.pdf> 64 2007 Tennessee Driver Handbook. 65 Martz, Jon. June 3, 2004. Association for Commuter Transportation Vanpool Council Press Release. < http://www.commuteinfo.org/pdf/ACTResponse.pdf> 66 Martz. Ibid. 67 Pederson, Steve. Email sent on Monday, 17 Dec 2007. Vice-President VPSI, Inc. <[email protected]> 68 Pederson, Steve. Ibid. 69 Pederson, Steve. Ibid. 70 Pederson, Steve. Ibid. 71 Pederson, Steve. Ibid. 72 CNN.com. December 8, 2004. “Three killed in nASA van plunge.” < http://lmtonline.com/news/archive/120904/pagea10.pdf> 73 Jablon, Richard. December 9, 2004. “NASA commuter van crash kills 3, injures 7.” Daily Lobo. < http://media.www.dailylobo.com/media/storage/paper344/news/2004/12/09/News/Nasa-Commuter.Van.Crash.Kills.3.Injures.7-825961.shtml>

74 Wegmann, Frederick. Fall 2007. Personal Discussions at the ACT Fall 2007 Conference in Seattle, Washington. 75 Martz, Jon. June 3, 2004. “ACT Responds to NHTSA Rollover Warning Re: 15-Passenger Vans.” Press Release. < http://www.commuteinfo.org/pdf/ACTResponse.pdf>

76 Martz. June 3, 2004. Ibid. 77 Metropolitan Washington Council of Governments. March 16, 2004. Meeting Minutes. < http://www.mwcog.org/uploads/committee-documents/vV5YVl420040510164817.pdf> 78 Gilpin, Bill, Project Coordinator with Tennessee Vans. Spring 2008. Multiple discussions with Dr. Fred Wegmann. 79 Gilpin, Bill. Ibid. 80 Satterfield, Jamie. August 6, 1999. “Deadly Van Wreck: Trucker was too close, authorities say.” Knoxville News-Sentinel, pp. A1, A5. 81 Desrochers, Lorraine, VanPool Risk Specialist for King County Rideshare Operations. Email correspondence on May 16, 2008. < [email protected]> 82 Flyer: Reducing the Risk of Rollover Crashes in Fifteen Passenger Vans, National Highway Traffic Safety Administration, Department of Transportation. <http://www.nhtsa.dot.gov/cars/problems/studies/15PassVans/NHTSA_FLYER.pdf> 83 Hangtag: Reducing the Risk of Rollover Crashes in Fifteen Passenger Vans, National Highway Traffic Safety Administration, Department of Transportation. <http://www.nhtsa.dot.gov/cars/problems/studies/15PassVans/ROLLOVER_HANGTAG_LaserRes.pdf> 84 Coaching the Van Driver, Training Video: National Safety Council FLI Learning Systems (800) 621-7619 (609) 466-9000

48

<http://www.nsc.org/ http://www.flilearning.com/> 85 VPSI. Inc. 2008. <http://www.vanpoolusa.com/> 86NHTSA Traffic Safety Research Note. May 2008. Ibid.

49

Appendix A: NHTSA Consumer Advisory – April 9, 2001

50

U.S. Department of Transportation Office of Public Affairs Washington, D.C. http://www.nhtsa.dot.gov/ News FOR IMMEDIATE RELEASE Media Calls: Rae Tyson (202) 366-9550 April 9, 2001 Consumer Calls: Auto Safety Hotline 1-888-327-4236

CONSUMER ADVISORY

The National Highway Traffic Safety Administration (NHTSA) is issuing a cautionary

warning to users of 15-passenger vans because of an increased rollover risk under certain

conditions.

The results of a recent analysis by NHTSA revealed that 15-passenger vans have a

rollover risk that is similar to other light trucks and vans when carrying a few passengers.

However, the risk of rollover increases dramatically as the number of occupants increases from

fewer than five occupants to over ten passengers.

In fact, 15-passenger vans (with 10 or more occupants) had a rollover rate in single vehicle

crashes that is nearly three times the rate of those that were lightly loaded.

NHTSA's analysis revealed that loading the 15-passenger van causes the center of gravity to shift

rearward and upward increasing the likelihood of rollover. The shift in the center of gravity will

also increase the potential for loss of control in panic maneuvers.

Because of these risks, it is important that these vans be operated by experienced drivers. A

person transporting 16 or more people for commercial purposes is required to have a

Commercial Driver's License, which requires certain specialized knowledge and driving skills.

51

Although the drivers of these vehicles are not required to possess a Commercial Driver's License,

they should still understand and be familiar with the handling characteristics of their vans,

especially when the van is fully loaded.

NHTSA's analysis reinforces the value of seat belts. Eighty percent of those nationwide

who died last year in single vehicle rollovers last year were not buckled up. Wearing seat belts

dramatically increases the chances of survival during a rollover crash. NHTSA urges that

institutions using 15-passenger vans require seat belt use at all times.

NHTSA is making this information available because of these findings and because of several

highly publicized rollover accidents involving 15-passenger vans loaded with college students

(often driven by a fellow student rather than a professional driver).

While federal law prohibits the sale of 15-passenger vans for the school-related transport of high

school age and younger students, no such prohibition exists for vehicles to transport college

students or other passengers.

A copy of the NHTSA analysis of the rollover characteristics of 15-passenger vans can be

found at: http://www-nrd.nhtsa.dot.gov/departments/nrd-12/23rev.html.

###

52

Appendix B: NHTSA Consumer Advisory – April 15, 2002

53

U.S. Department of Transportation Office of Public Affairs Washington, D.C. http://www.nhtsa.dot.gov/ News NHTSA 27-02 Monday, April 15, 2002

Contact: Rae Tyson Telephone: (202) 366-9550

NHTSA Repeats Rollover Warning

To Users of 15-Passenger Vans

The nation's top motor vehicle safety executive, Jeffrey Runge, M.D., head of the U.S.

Department of Transportation's National Highway Traffic Safety Administration (NHTSA),

today reissued a cautionary warning to users of 15-passenger vans because of an increased

rollover risk under certain conditions. A similar warning was issued in 2001.

The safety agency also unveiled a consumer flyer for users of 15-passenger vans.

NHTSA research has shown that 15-passenger vans have a rollover risk that increases

dramatically as the number of occupants increases from fewer than five to more than ten. In fact,

15-passenger vans (with 10 or more occupants) had a rollover rate in single vehicle crashes that

is nearly three times the rate of those that were lightly loaded.

"Because of these risks, it is vital that users of 15-passenger vans be aware of some safety

precautions that will significantly reduce the risk," said Dr. Runge.

Among the recommendations are the following:

It is important that 15-passenger vans be operated by trained, experienced drivers.

Insist that all occupants wear seat belts at all times. Eighty percent of those who died in 15-

passenger van rollovers nationwide in the year 2000 were not buckled up. Wearing seat belts

54

dramatically increases the chances of survival during a rollover crash. In fatal, single-vehicle

rollovers involving 15-passenger vans over the past decade, 92 percent of belted occupants

survived.

NHTSA is reissuing this advisory to specifically alert summertime users of 15-passenger

vans. The agency also has prepared a flyer on 15-passenger van safety that is available on the

web at www.nhtsa.dot.gov/cars/problems/studies/15PassVans/Index.htm. The agency also is

considering the potential benefits of an additional warning label about rollover and seat belt use

that would be visible to the driver and passengers of 15-passenger vans, respectively.

While federal law prohibits the sale of 15-passenger vans for the school-related transport

of high school age and younger students, no such prohibition exists for vehicles to transport

college students or other passengers.

A copy of the NHTSA analysis of the rollover characteristics of 15-passenger vans can be found

at: http://www-nrd.nhtsa.dot.gov/departments/nrd-30/ncsa/AvailInf.html under "Research

Notes". The new consumer advisory also is available at:

http://www.nhtsa.dot.gov/nhtsa/announce/press/pressdisplay.cfm?year=2002&filename=Apr15a

dvisory.html.

###

55

Appendix C: NHTSA Hangtag

56

Source: NHTSA website at www.nhtsa.gov/cars/problems/studies/15PassVans/

ROLLOVER_HANGTAG_LaserRes.pdf

57

Appendix D: State Laws Prohibiting the Use of 15-Passenger Vans

58

State To/From School

To/From School Events

Comments

Alabama No No State laws do not apply to private schools. Alaska No Yes State laws do not apply to private schools. Arizona No Yes Arkansas Yes Yes California No No Colorado No No State-wide, school district insurance provider

refused to insure vans after July 1, 2005. Connecticut No Yes Delaware No No Florida No No Does not apply to private schools or

companies that contract directly with parents. Georgia No Yes State laws do not apply to private schools. Hawaii Yes Yes Idaho No Yes State laws allow for some exceptions.

State laws do not apply to private schools. Illinois No Yes Indiana No No State laws do not apply to private schools. Iowa No No Kansas No No Kentucky No No Louisiana No No State laws do not apply to private schools. Maine No No State laws do not apply to private schools. Maryland No No State laws do not apply to private schools. Massachusetts Yes Yes Michigan No No Minnesota No No Mississippi Yes Yes State law does not prohibit the use of vans but

Department of Education will not approve van purchases.

Missouri No Yes State laws do not apply to private schools. Montana No No State laws do not apply to private schools. Nebraska Yes Yes Nevada No Yes New Hampshire

No No

New Jersey No No New Mexico No No New York No No N. Carolina No Yes State laws do not apply to private schools. N. Dakota No No State laws do not apply to private schools. Ohio No No Oklahoma No No

59

State To/From School

To/From School Events

Comments

Oregon No No Pennsylvania No No Unless the van was registered as a bus in

Pennsylvania prior to March 1, 1993. Rhode Island No No Child care organizations are exempt S. Carolina No No S. Dakota No No Tennessee No Yes Texas No Yes State laws do not apply to private schools. Utah No No Vermont Yes Yes Virginia No No State laws only apply to public schools. Washington No No State laws only apply to public schools. W. Virginia No Yes Wisconsin Yes Yes Wyoming No No State laws only apply to public schools.

Source: NHTSA Action Plan at http://www.nhtsa.dot.gov/cars/problems/studies/ 15passvans/15passvan.html

The National Association of State Directors of Pupil Transportation Services surveyed its State Director members to determine the current state-by-state laws/regulations on the use of 12- and 15-passenger vans to transport students to and from school or on school-related activity trips. The 2005 table has been updated to reflect legislative restrictions that were enacted as contained in the original table.

60

Appendix E: State University Systems Use of the 15-Passenger Van

61

State 15-Passenger Van Used

Additonal Comments

Alaska No Converted into utility vehicles Facilities staff use only

Arizona Yes Classroom training Behind-the-wheel training Driver 3 years driving experience Driver 19 years old or older Motor vehicle record check required

California No Connecticut Yes Double rear tires

Classroom training Behind-the-wheel training Drive 5-10 mph below posted sped limit Seatbelt use required

Florida No state wide policy Georgia Yes Illinois Yes Classroom training

Behind-the-wheel training University employees use only

Indiana No Iowa Yes Classroom training

Behind-the-wheel training Kentucky No Converted to 11-passenger van

Rear seat removed On-line training Students use prohibited

Maryland No Minnesota Yes Classroom training Missouri Yes Roof racks removed

Trailer hitches removed Driver 21 years old or older Drive 65 mph or less Seatbelt use required Capcity limited to 10 Driving after midnight prohibited

Montana Yes Classroom training Driver 21 years old or older

62

Nebraska No Converted to 11-passenger van Rear seat removed Roof racks removed Trailer hitches removed Driver record checked Drive 65 mph or less Capcity limited to 10 Driving more than 4 hours between 10pm and 7am prohibited

New York No state wide policy North Dakota Yes Electronic stabitlity controls installed

On-line training Behind-the-wheel training

Oklahoma Yes Decals in vans warn agaainst overloading Drive 55 mph or less

Pennsylvania Yes Vans only allowed on city streets Classroom training

Utah No state wide policy Vermont No Virginia No Wisconsin No state wide policy Source: Melany Noltenius, email correspondence

63

Appendix F: Rural and Specialized Transit Providers in Tennessee

64

Rural Transit Provider Organization Name

15-Passenger Van used

Mitigate Rollover Driver Training

Delta Human Resource Agency

Yes 18 vans

No MTSU Training Center

Southwest Human Resource Agency

Yes 84 vans

No F- Endorsement In-house van driver training

Southwest Human Resource Agency

Yes No In-house van driver training Annual Drivers Safety/PASS training

Northwest Tennessee Human Resource Agency

Yes 25 vans

No MTSU Training Center

Mid-Cumberland Human Resource Agency

Yes 6 vans

No F- Endorsement In-house van driver training

Upper Cumberland Human Resource Agency

No

Southeast Tennessee Human Resource Agency

Yes 6 vans

No In-house van driver training

Hancock County Rural Transportation System

Yes 1 van

Rear seat removed

MTSU Training Center Insurance provider training materials

East Tennessee Human Resource Agency

Yes 18 vans

No F- Endorsement MTSU Training Center

First Tennessee Human Resource Agency

Yes 9 vans

No In-house van driver training MTSU Training Center

Specialized Transit Provider Organization Name

15-Passenger Van used

Mitigate Rollover In-house van driver training

Alexian Brothers PACE program

Yes 2 vans

No Commercial Drivers License

C. S. Patterson Training Center, Inc.

Yes 5 vans

No F- Endorsement

Chester County Senior Center No Comcare, Inc. No Decatur County Senior Center No Douglas Cooperative, Inc. Yes

3 vans No F- Endorsement

Church Mutual safety video Evergreen Presbyterian Ministries

No

Franklin County Adult Activity Center

No

Greene County Skills, Inc. Yes 9 vans

No F -Endorsement In-house van driver training

Habilitation & Training Yes No None required.

65

Specialized Transit Provider Organization Name

15-Passenger Van used

Mitigate Rollover In-house van driver training

Services, Inc. 3 vans Hardin County Skills, Inc. Yes

6 vans No F-Endorsement

Hilltoppers, Inc. Yes 5 vans

Dual rear tires

In-house van driver training MTSU training center

Knoxville-Knox County CAC*

Yes Commercial Class C License with Passenger Endorsement

McKendree Village, Inc Yes 4 vans

F- Endorsement In-house van driver training

Metropolitan Inter-Faith Association

Yes 10 vans

Class C license with P endorsement

New Horizons Corporation Yes 2 vans

Dual rear tires and rear seat removed

None required.

Orange Grove Center No Prospect, Inc.

Yes 7 vans

No None required.

Sertoma Learning Center, Inc Yes 7 vans

No In-house van driver training AAA defensive driving course

Trevecca Towers Retirement Community

No

Waves, Inc Yes 2 vans

No F-Endorsement In-house van driver training

* Head Start program does not operate any 15 passenger vans.

66

Appendix G: Safe Driving Practices Acknowledgement Statement

67

Tennessee Vans

15-PASSENGER FULL SIZE VAN DRIVER SAFE DRIVING PRACTICES ACKNOWLEDGEMENT STATEMENT

Risks Associated with Operating 15-Passenger Full Size Vans

1. The National Highway Traffic Safety Administration’s (NHTSA) safety advisory recommends that drivers insist all occupants wear safety belts at all times. Drivers should verbally remind van passengers that safety belts are to be properly used until the vehicle is stopped and legally parked.

2. Drivers should visually check passenger safety belt use, and during transit, stop and legally park the van if made aware of passenger safety belt non-use.

3. 15-passenger full size vans have a rollover risk similar to other light trucks and vans. Prior NHTSA research has shown that 15-passenger vans have a rollover risk that increases dramatically as the number of occupants increases from fewer than five to more than ten.

4. The weight of the van, particularly when fully occupied, causes the center of gravity to shift rearward and upward increasing the likelihood of rollover.

5. The shift in the center of gravity will also increase the potential for loss of control in panic maneuvers.

6. The weight of the van when fully occupied requires additional stopping distance, an especially important factor in rain, fog, or other difficult driving situations caused by weather conditions.

7. The width of the van allows for less lane room. 8. The length of the van increases distance needed for making turns, changing lanes, and

braking. 9. General maintenance of the vehicle, including proper tire pressure is important to safety,

and can be referenced in the vehicle owner's manual. BASIC DRIVING PRACTICES FOR SAFE VAN OPERATION

• Driving at posted or lower speeds. • Adjusting to lower speeds for special conditions such as: rain, snow, fog, wind, and any

other condition impacting visibility, stopping distance or general safe handling of the vehicle.

• Minimizing potential driver distraction by using a cell phone or other electronic devices ONLY when the van is safely stopped or asking passengers to assist with calls for emergency situations.

• Properly loading passengers and equipment, and never placing equipment/luggage on the top of passenger vans.

• Minimizing driver fatigue on long trips by one or more of the following: driving rested, taking appropriate breaks, or sharing driving with authorized drivers. Follow agency policies on travel time restrictions.

• Do not drive while under the influence of intoxicating beverages, drugs, or any other impairing substances as advised by health professionals.

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I have read and understand potential risks involved while operating 15-passenger full size vans. (Initial)_______ I am aware the handling characteristics of 15-passenger full size vans may change dramatically, especially when fully loaded. (Initial)_______ I understand extra caution is required when operating 15-passenger full size vans, including reduced speeds. (Initial)_______ I understand van driver/passenger safety belt use is required and will remind passengers and visually check for belt use. I will stop and legally park the van if made aware of passenger non-use during transit. (initial)_______ Driver’s Name (Print) _______________________________ Date ________________ Driver’s Signature _______________________________________Agency ______________ A copy of the signed form will be maintained on file with Tennessee Vans, the agency, and a copy provided to the driver.

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Appendix H: Defensive Driving Techniques

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The 15-passenger van does not handle like a sedan. There are major differences drivers

need to be aware of because of the van’s increased height, length, and weight. The center of

gravity of a 15-passenger van is higher due to its size and shape. As the van is loaded with

passengers and/or equipment, the center of gravity continues to rise. The vans also require more

pavement length in order to stop, and a wider turning radius. These facts adversely compromise

the stability of the van, especially during panic maneuvers, such as sudden turns, striking a curb

at a high rate of speed, or running off the pavement. Some basic defensive driving tips are to

avoid or minimize distractions, obey all traffic rules, to scan the road continuously, to drive the

posted limit or under, to trail the vehicle in front by at least four seconds, to scan the rearview

and side mirrors every ten seconds, and always use signals.

If the van goes off the road: • Slow down, but avoid severe brake application • Ease the vehicle back onto the pavement • Avoid turning the steering wheel too sharply while returning to the road surface; it may

be safer to stay on the apron or shoulder of the road and slow down gradually before returning to the pavement; it may be less risky to strike small objects (such as highway reflectors) with minor damage to your vehicle rather than attempt a sudden return to the pavement

When changing lanes or merging into traffic:

• Create more space around the 15-passenger van by reducing or increasing van speed • Signal intentions by engaging blinkers early • Use the merge lane as intended and designed • Use the mirrors as needed • Yield the right-of-way when necessary • Ask for passenger assistance if needed to verify maneuvering for merging • Allow for a four second following distance between the van and the vehicle in front of

the van

When turning the van: • Reduce the speed of the van • Signal turning intentions farther in advance than normal • Complete a check to ensure there is no on-coming traffic • Start left turns farther forward into the intersection • When turning right, make a square turn by moving the vehicle just far enough to the left

so when the right turn is made, the rear of the vehicle won’t run over the curb.

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• Be aware that due to the length of the van, the van will have a tendency to take the turn in a diagonal direction

• Plan plenty of room in the intersection • Do a “last glance at the right-side mirror” to avoid a situation where a pedestrian, bike or

another automobile may have “squeezed” in between the van and the curb as more space was made for a wider turning radius.

When parking the van:

• Make sure the parking place has plenty of room and, if possible, should enable the driver to pull forward rather than having to back out

• Turn the wheels so the van will roll against the curb • Set the parking brake • Set the transmission gear in “park” • Close all windows • Shut off all electrical accessories (e.g. lights, radio, etc.)

When backing a van:

• Try to park in a spot that allows it to be pulled forward to avoid backing • Visually survey the area behind and beside the van for obstacles • Ask passengers for assistance as spotters • Back towards the driver’s side • Use the mirrors

When picking up or dropping off passengers:

• Position the van out of the traffic flow • Turn on hazard flashers • Park the van on a level surface • Apply the emergency brake • When unloading passengers, remind exiting riders to walk behind the van and to be

cautious of traffic • Before pulling forward, make sure all passengers have cleared the forward path of the

van

When driving in inclement weather: • Consider postponing the trip altogether • Reduce travel speeds below posted speed limit • Pay attention to conditions affecting traffic by scanning the roadway and mirrors as

frequently and as far ahead as possible • Be aware of what is happening with the next several cars ahead • Keep both hands on the wheel • Allow for longer stopping and following distances • Plan turns in advance to allow adequate space • Low beams are recommended for driving in fog or snow • Use the center line or edge of the roadway as a guide when visibility is reduced • If driver cannot see a safe distance ahead, reduce speed or pull off the roadway and stop • In ice and snow, if the wheels start spinning, ease up on the accelerator and downshift

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In a highway emergency:

• Park on the side of the road or other safe place • Raise the hood • Tie a white handkerchief to the antenna or left door handle • Turn emergency flashers on • Have the driver and all passengers stay in the vehicle until help arrives • Keep a list of local emergency phone numbers in each vehicle