NHTSA Action Plan for 15-Passenger Van Safety

November 2004
Update

Introduction

There is growing concern regarding the crash involvement and safety of 15-passenger vans and the resulting injuries and fatalities. Between 1990 and 2002, there were 1,576 15-passenger vans involved in fatal crashes that resulted in 1,111 fatalities to occupants of such vans. Of these, 657 vans were in fatal, single vehicle crashes, of which 349 rolled over. Heavily loaded 15-passenger vans are particularly susceptible to rollover. Confounding this problem, t he rate of safety belt use among occupants of large vans involved in fatal crashes is very low compared to other types of vehicles. While this plan focuses on 15-passenger vans, the actions identified also relate to 12-passenger vans, which are similar to vans configured for 15 passengers in terms of design, handling characteristics, and safety problems. NHTSA defines vehicles designed to carry more than 10 persons as buses for purposes of the Federal Motor Vehicle Safety Standards (FMVSS). This plan is an update of the first NHTSA Action Plan for 15-Passenger Van Safety, published in September 2003. The current plan provides new information on agency actions to address these vehicles, and a report on progress and results on activities identified in the 2003 plan.

Background

Crashes involving large vans, especially rollover crashes and the resulting fatalities and injuries, have raised the level of public and NHTSA attention to this issue. In 2001, 130 occupants of 15-passenger vans died in crashes involving these vehicles. Single vehicle crashes represented 42 percent of fatal crashes. Eighty-seven percent of people who died in single vehicle rollovers of these vehicles were not wearing safety belts. Between 1990 and 2001, 15-passenger vans represented .25 percent of the passenger vehicle fleet, .26 percent of passenger vehicles involved in fatal crashes, and .25 percent of all passenger vehicle occupant deaths. During this time, 8 percent of belted occupants in these vehicles in fatal single vehicle crashes were killed, compared to 22 percent of unbelted occupants.

In March 2003, Senator Snowe introduced S.717 bill to address 15-passenger van safety. Representative Mark Udall introduced a similar bill in the House, H.R. 1641. Senator Snowe's bill called on NHTSA to develop a dynamic test to assess rollover risk for 15-passenger vans and to issue the results as consumer information; to test these vehicles at different loading levels as part of the New Car Assessment Program (NCAP); to test stability control and other technologies to assess effectiveness in reducing rollovers; and called on the Federal Motor Carrier Safety Administration (FMCSA) to apply Federal motor carrier safety regulations (FMCSR) to the commercial operation of 15-passenger vans.

Since November 2002, the National Transportation Safety Board (NTSB) has issued nine recommendations that relate to these vehicles. These recommendations encompass vehicle countermeasures, consumer information, driver programs, working with FMCSA, and cooperating with outside groups to promote the safety of these vehicles. This Plan references these recommendations under specific action areas.

NHTSA Actions and Plans

1. Problem Identification

   A 2001 NHTSA study included three different analyses addressing whether 15-passenger vans, especially loaded 15-passenger vans, are unusually susceptible to rollover. The results from State Data System (SDS) analyses indicated that the rollover propensity for 15- passenger vans over all occupancy levels was slightly less than for the overall light truck and van (LTV) group, that rollover propensity increases with the occupancy level of the 15-passenger van, and that higher occupancy levels caused crash severity to increase. Analysis of state data also found that rollover rates for 15-passenger vans did not show any significant correlation to driver age and that fatalities occurred disproportionately to rear seat occupants, while injuries were proportional between front and rear seat occupants. An assessment also was conducted comparing the static stability factor (SSF) of a 15- passenger van to a 7-passenger full size van and a minivan when lightly loaded (driver only) and fully loaded to gross vehicle weight rating (GVWR). This analysis found that the SSF for all three vehicles decreased (higher likelihood of rollover) when fully loaded. Based on a limited number of crashes, heavily loaded 15- passenger vans appear to have a higher rollover rate compared to when these vehicles are lightly loaded (with fewer occupants).

   A 2004 study (see Completed NHTSA Actions section) explored the relationship between vehicle occupancy and several other variables in the NHTSA Fatality Analysis and Reporting System (FARS) database and a 15-passenger van's risk of rollover. The study examines statistics on fatal crashes involving 15-passenger vans from 1990 to 2002. The study also constructs a logistic regression model to model the effects of various factors, most importantly occupancy level, on the risk of rollover. The model is constructed using data from 1994 to 2001 on police-reported motor vehicle crashes in five states that are part of NHTSA's State Data System (SDS).

   The data show that between 1990 and 2002, there were 1,576 15-passenger vans involved in fatal crashes that resulted in 1,111 fatalities to occupants of such vans. Of these, 657 vans were in fatal, single vehicle crashes, of which 349 rolled over. In 450 of these vans, there was at least one fatality, totaling up to 684 occupant fatalities in single-vehicle crashes. The majority of fatally injured van occupants were not wearing seat belts. Only 14 percent of the fatally injured were restrained. Analysis of data from NHTSA's SDS reveals that the rate of rollover observed for 15-passenger vans that are loaded above half their designed seating capacity is 2.2 times the rate observed for vans loaded to or below half their capacity. The odds of a rollover for a 15-passener van at its designated seating capacity is more than five times the odds of a rollover when the driver is the only occupant in the van.

   The agency also performed computer modeling to assess the handling of these vehicles. The modeling predicted understeer for 15-passenger vans when lightly loaded, similar to minivan behavior. However, when heavily loaded, it predicted understeer at low lateral acceleration, but oversteer at higher lateral accelerations. This transition to oversteer may pose safety problems for drivers who are unfamiliar with this characteristic. Loading 15- passenger vans to gross vehicle weight (GVW) also moved center of gravity rearward, increasing vertical load on rear tires.

   Current and Planned NHTSA Analyses for Problem Identification:

   Survey Tire Pressure and Condition in the 12- and 15-Passenger Van Fleet and Analyze the Role of Tires in Rollover Causation:As part of NHTSA's development of long-term performance requirements for tire pressure-monitoring systems, NTSB recommends (August 2003) NHTSA adopt more stringent detection standards than 25 or 30 percent below manufacturer-recommended levels. This recommendation is based on the NTSB's view that pressures at those levels may have an adverse effect on the handling of vehicles, such as 12- and 15-passenger vans. Work has been conducted at NHTSA's Vehicle Research and Test Center (VRTC) on the relationship between inflation pressure in front and rear tires, loading conditions, and handling for a 15-passenger van (see Countermeasure Research section for detail). The agency believes that more information is needed on the level of tire pressure under-inflation and tire wear conditions and tire failure for 15-passenger vans in use for consumer information, vehicle solutions, or other actions. NHTSA's National Center for Statistics and Analysis (NCSA) is conducting a study, based on methods used in a recent light vehicle tire pressure monitoring system (TPMS) survey, to collect tire pressure and condition information on this class of vehicle. In-house analysis also will be done to examine the involvement of tires in rollover crash data.

   Milestones:

   Complete feasibility evaluation		February 2004 (completed)
   In-house analysis of rollover crash data and tires		June 2004 (completed)
   Develop Survey Plan		March 2004 (completed)
   Complete tire pressure and condition survey		August 2004 (completed)
   Publish results of Tire Pressure/Condition Survey		January 2005

   Analyze State Laws Regarding the Use of 15-Passenger Vans: An analysis is being conducted to identify how 12- and 15-passenger vans are classified at the state and other jurisdictional levels. In some cases, legal loopholes exist at the state level as a result of NHTSA classifying this type of vehicle as a bus (for example, exemption from laws requiring use of child restraints) . Each State prescribes its own regulations that apply to the use of any vehicle that is used to transport students and/or pre-school children. The result of our analysis is a list of the laws in the 50 states and the District of Columbia. This list can be found at the end of this Plan. This information will provide input to agency decisions on future actions on the safe operation and use of these vehicles.

   Milestones:

   Complete study of state laws		August 2004 (completed)
   Issue list of state laws		October 2004 (completed)

2. Consumer Information and Education

   In April 2001, NHTSA issued a Research Note and Consumer Advisory on 15-passenger van safety. The Research Note covered the findings from the three-part study conducted by NHTSA (described in the Problem Identification section above). The April 2001 Consumer Advisory informed the public that 15-passenger vans should be operated by "experienced drivers" and noted that a commercial driver's license (CDL) is required to transport 16 or more people for commercial purposes. The Consumer Advisory urged drivers to be familiar with the handling of fully loaded 15-passenger vans and urged institutions using 15-passenger vans to require safety belt use at all times. In April 2002, Dr. Runge reissued the 2001 Consumer Advisory at a news conference, together with a flyer on 15-passenger van safety and a hangtag to leave in 15-passenger vans that provided information on the risk of rollover, tips for preventing rollover, buckling up for safety and other tips for safe driving.

   In June 2004, NHTSA reissued a Consumer Advisory, a cautionary warning to users of 15-passenger vans because of an increased rollover risk under certain conditions. The agency also issued an updated consumer hangtag for 15-passenger van users and announced the publication of three new NHTSA research reports on 15-passenger vans (see Completed NHTSA Actions section).

   NHTSA's recommendation is that pre-school and school aged children should not be transported in these vehicles due to safety concerns. In February 2002, just prior to NHTSA reissuing the 2001 Consumer Advisory on 15-passenger van safety, NHTSA sent a letter to each state president of the National Automobile Dealers Association (NADA) reminding them of the Federal requirements that apply to the sale or lease of vehicles used to transport students to and from school and school-related activities. Letters also were sent to state directors of pupil transportation as well as to independent education groups outlining these Federal requirements and NHTSA's school bus safety standards. Similar letters were sent to these groups in 1995 and 1997. 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. In August 2003, NHTSA issued new regulations amending the school bus safety rules to encourage churches and other groups to use buses instead of vans.

   In November 2002, NHTSA, in partnership with the Health Resources and Services Administration (HRSA) and the American Academy of Pediatrics (AAP), announced a training program for childcare providers called Moving Kids Safely in Child Care. The two-day training program educates childcare providers about how to safely transport children using the appropriate child restraints for their ages as well as the benefits of transporting children in school buses versus 15-passenger vans. This training program is available through the state highway safety offices. To date, over 2,900 childcare providers across the country have completed this training program.

   Current and Planned Actions:

   Technical Assistance: NHTSA attends trade shows, conventions, etc., throughout the year, and these events offer opportunities to reach a varied audience and promote vehicle safety messages. NHTSA plans to continue to include 15-passenger van safety information in relevant Departmental efforts and regional outreach activities. NHTSA also plans to utilize existing partnerships with National Collegiate Athletic Association (NCAA) and umbrella church and youth organizations as a mechanism to reach targeted populations that use 15 passenger vans.

   - Specifically, NHTSA has existing partnerships with many organizations to implement traffic safety and injury control programs. Throughout FY 2005, NHTSA will work with the following organizations to provide technical assistance for their efforts to develop programs and policies to address 15-passenger van safety and provide them with NHTSA materials to disseminate throughout their organization:

   • National Automobile Dealers Association (NADA)
   • Auto manufacturers
   • Governors Highway Safety Association
   • Education and school transportation organizations
   • Branches of the military (they have expressed interest in developing a training program for their drivers)
   • Religious groups
   • Colleges and universities
   • Rental van fleets
   • YMCA and summer camp organizations
   • Organizations that focus on migrant workers
   • Head Start and day care provider organizations
   • VA medical centers

   Milestones:

   Disseminate information		Ongoing
   Educate outreach organizations through educational presentation		Ongoing
   Implement awareness campaign		Annually in May

   Training and Education: The focus of NHTSA's driver training program is on novice teenage drivers. NHTSA has a cooperative agreement with the highway safety center at Indiana University of Pennsylvania to develop novice driver training programs and driver education curriculums. Commercial uses of 15-passenger vans typically involve experienced drivers, and, because of liability issues within this industry, many commercial operators require their drivers to take training. A majority of the highly publicized crashes involving 15-passenger vans have involved inexperienced drivers for private organizations such as churches and YMCAs. Because of the infrequent use of these vehicles for these purposes, drivers are less likely to have taken formal training. In addition, many of these organizations operate programs with volunteers and with limited budgets.

   A driver education piece will be developed to complement the vehicle hangtag that is available through the NHTSA website. It will highlight the known risk factors of driving the vans and include reference to information from new research reports that address issues such as tire blowouts and the importance of correct tire pressure. This educational piece will be aimed at volunteer or social organizations that often utilize the vans, such as religious groups, athletic organizations and summer camps.

   Milestone:

   Develop on-line information, tips and driver educational materials

   December 2004

3. Countermeasure Research

   Refer to NHTSA's April 2001 Research Note & paper which is described under Problem Identification.

   Also, in June 2004, NHTSA published two reports (see Completed NHTSA Actions section). The first examines dynamic rollover resistance of 15-passenger vans with multiple load configurations and the second examines the effects of tire pressure monitoring system minimum activation pressure on the handling and rollover resistance of a 15-passenger van.

   The first study used two vans; one was factory equipped with electronic stability control (ESC). Each van was evaluated with up to four load configurations depending on the test performed. The van with ESC was tested with the ESC enabled and disabled. Generally, static stability factors and dynamic rollover resistance of the vans degraded as the number of occupants increased. Results from the study indicate that installation of ESC on 15-passenger vans may have important safety benefits in some, but not all, on-road driving situations. This report responds to NTSB Safety Recommendation H-02-26 and H-02-28. NHTSA staff briefed NTSB staff about this study on August 5, 2004 and they agreed to close these recommendations based on the results of the study.

   The second study modified the tire inflation pressure to determine the effects on the handling and rollover resistance using one 15-passenger van. In addition to those specified on the vehicle identification card, four other front/rear tire inflation pressure combinations were used along with multiple loading configurations (nominal and maximum occupancy). Tire inflation pressure had a minimal effect on lateral stability in the maximum occupancy configuration. Decreasing the front and rear inflation pressure from that specified on the vehicle's placard to 46-psi front, 60-psi rear had a small adverse affect on the vehicle's dynamic rollover resistance. In summary, the effects of tire inflation pressure on light truck handling and rollover resistance cannot be fully determined from the results of this study because only one vehicle was evaluated. Use of this study's generalized results to predict the performance of other similar vehicles may not be appropriate. This study responds to NTSB safety recommendation H-03-17. NHTSA staff briefed NTSB staff on August 5, 2004 and is in the process of formally requesting that this recommendation be closed based on the results of this study. (See Completed NHTSA Actions section.)

   Current and Planned Research

   The research that was planned under the scope of the 2003 plan has been completed. NHTSA will continue to assess the need for additional research as the agency proceeds with 15-passenger van countermeasure and data collection activities.

4. Vehicle Countermeasures

   NHTSA recently published an NPRM to upgrade FMVSS 214, Side Impact Testing (see Completed NHTSA Actions section) and an NPRM to require lap and shoulder belts in all seating positions for vehicles weighing 10,000 pounds or less. These safety upgrades are expected to improve the crashworthiness characteristics of 12- and 15-passenger vans.

   Current and Planned Actions:

   FMVSS 208, Occupant Crash Protection: Anton's Law, signed into law in December 2002, requires lap and shoulder belts (3-point belts) at all seating positions (notably the center rear seat) for vehicles with a GVWR of 10,000 pound or less. Fifteen passenger vans have bench seats with seating for three or four passengers, but usually only the outboard seats have lap and shoulder belts. NHTSA published an NPRM on August 6, 2003, that would require lap and

   shoulder belts in rear center seats in all vehicles up to 10,000 pounds GVWR. One practical way to install lap and shoulder belts in all 15-passenger van seating positions (and to stiffen seat backs) might be to use integrated seats. This activity relates to NTSB H-03-15. On August 5, 2004, NHTSA staff briefed NTSB staff on the progress made on this recommendation. NTSB plans to close this recommendation following the publication of a final rule.

   Milestones:

   NPRM to require rear center lap/shoulder belts		August 2004 (completed)
   Final rule		December 2004

   FMVSS 214, Side Impact Protection: In addition to the 1995 FMVSS No. 201 upgrade, the agency has proposed to upgrade FMVSS No. 214 by adding a dynamic side impact pole test. The proposed upgrade will apply to all passenger cars, and trucks, buses and multiple passenger vehicles with a GVWR of 10,000 pounds or less. The impact test will be performed on either side of the vehicle and the pole is aimed at the head of the test dummy placed on the front outboard seating position. The expected countermeasures are inflatable head protection systems (HPS), such as side air curtains and other devices. Although the pole test covers only the front seat occupants, it is expected that vehicle manufacturers will provide HPS to cover occupants in second and even third row seats. Therefore, some of NTSB's concerns about additional head protection may be addressed by this upgrade.

   Milestones:

   NPRM to upgrade FMVSS 214		May 2004 (completed)
   Final Rule		2005-2006

   Part 571.3, Definitions: NHTSA is currently working toward revising the definition of "designated seating position" that would incorporate mathematical formulae based on hip room measurements. The agency is concerned with seats that have the hip room to accommodate three occupants, but have only two seat belt assemblies. To address passenger van safety, NHTSA is also considering a formula that would require additional seat belt assemblies where the seat is capable of holding more than three occupants. This proposal would help ensure that each likely occupant be equipped with belt restraints.

   Milestone:

   NPRM

   February 2005

   FMVSS 216, Roof Crush Resistance: Current plans for the upgrade of this standard include expanding its coverage to vehicles up to 10,000 pounds GVWR (with certain exceptions). Agency testing has shown that these vehicles barely pass the current FMVSS 216 requirements and would require stronger roofs to pass the upgraded requirements. This action relates to NTSB recommendation H-03-16. On August 5, 2004 NHTSA staff briefed NTSB about the progress made on this recommendation. NTSB plans to close this recommendation following the publication of a final rule.

   Milestone:

   Publish NPRM for FMVSS 216 upgrade

   March 2005

Completed NHTSA Actions

The following are completed actions since the publication of the September 2003 Action Plan.

1. Problem Identification

   On June 1, 2004, NHTSA released a report, Analysis of Crashes Involving 15-Passenger Vans.

   The report provides an in-depth analysis of crashes involving 15-passenger vans to assess the effect of occupancy level on the risk of rollover. (DOT HS 809 735)

2. Consumer Information and Education

   On June 1, 2004, NHTSA reissued a cautionary warning to users of 15-passenger vans because of an increased rollover risk under certain conditions. Similar warnings were issued in 2001 and 2002.

   • Over 15,000 hangtags have been sent out since the advisory went out first week of June.
   • Many calls have requested information on training materials. Have referred people to Guide One and National Safety Council's "Coaching the Van Driver" training kits.

   In October 2003, NHTSA released a revised consumer information hangtag: Reducing the Risk of Rollover Crashes in 15-Passenger Vans hangtag. The hangtag summarizes safety messages in a checklist format. This revised hangtag has been distributed to our partners, including AAA, Automotive Service of Excellence (ASE), Jiffy Lube, National Association of Independent Insurers (NAII), and National Credit Unions, among others.

   In October 2003, NHTSA disseminated rollover warning messages through a Championship Auto Racing Teams (CART) partnership, providing distribution of our materials at its races and through existing NHTSA mechanisms, namely, the NHTSA Hotline and the new NHTSA web site on rollover at www.nhtsa.dot.gov/rollover. Messages include cautionary warning messages to users of 15-passenger vans on the safety issues regarding these vehicles and the importance of wearing safety belts.

   A new web page was created and is accessible by clicking on the 15 Passenger Van Safety icon located on both the NHTSA and Buying a Safer Car home pages.

   www.nhtsa.dot.gov/cars/problems/studies/15PassVans/15PassCustomerAdvisory.htm. The web page contains:

   • The consumer advisory
   • Three research reports (NCSA report on fatalities, Vehicle Safety Research reports on tire pressure and ESC)
   • Three video clips comparing the Ford E-350 with the GMC Savana (w/ and w/o ESC)
   • Electronic versions of the flyer and hangtags in English and Spanish and information on how to order
   • Drop-in article

   Several hundred national and regional organizations have been contacted and were sent information packets.

   These packets included:

   • An introductory letter from Dr. Runge thanking them for receiving the materials and helping to get the word out
   • A copy of the consumer advisory
   • A copy of a statistical sheet (from the NCSA fatality report)
   • A copy of the drop-in article
   • Copies of the hangtags in English/Spanish as requested by each organization

   Types of organizations contacted:

   • Dozens, if not hundreds, of major national and district level church associations
   • National car rental agencies: Vanguard (National and Alamo), Cendant (Avis and Budget), Enterprise
   • NHTSA regions
   • Non-profits: AAA, 4-H, United Way, Boy Scouts of America, Boys & Girls Clubs
   • Correctional: American Correctional and Jail Associations
   • Migrant workers: United Farm Workers, National Center for Farm Worker Health
   • College athletics: National Association of Intercollegiate Athletics

3. Countermeasure Research

   On June 1, 2004, NHTSA released a report, Testing the Effects of Tire Pressure Monitoring System Minimum Activation Pressure on the Handling and Rollover Resistance of a 15-Passenger Van. This report provides 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 (DOT HS 809 701).

   On June 1, 2004, NHTSA released a report, Testing the Dynamic Rollover Resistance of two 15-Passenger Vans with Multiple Load Configurations. In this study, NHTSA evaluated the dynamic rollover resistance of two 15-passenger vans, one with the electronic stability control (ESC) enabled and disabled (DOT HS 809 704).

4. Vehicle Countermeasures

   In May 2004, NHTSA issued an NPRM to upgrade FMVSS 214, Side Impact Protection. The proposed upgrade includes the addition of a dynamic side impact pole test. The proposed upgrade will apply to all passenger cars, and trucks, buses and multiple passenger vehicles with a GVWR of 10,000 pounds or less. In August 2004, NHTSA published an NPRM that proposes a requirement for lap and shoulder belts in rear center seats in all vehicles up to 10,000 pounds GVWR. In September 2004, NHTSA published an NPRM to require 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 new Federal Motor Vehicle Safety Standard would apply 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.

Deleted Actions

The following are actions that have been deleted from the plan:

1. Problem Identification

   Develop Information on the Ownership and Usage of These Vehicles: NHTSA has determined that collecting this type of information would be costly and time consuming. NHTSA believes that other actions in the plan that have been completed provide beneficial demographic information. NHTSA's recently published NCSA report, Analysis of Crashes Involving 15-Passenger Vans , provides an in-depth analysis of crashes involving 15-passenger vans, including the driver's age in relation to rollover rates and the correlation of fatalities to seating position. In addition, NHTSA will continue with its comprehensive consumer information and education efforts.

4. Vehicle Countermeasures

   Vehicle Labeling: NHTSA reconsidered its decision, based on results of consumer research, that development of a warning label would reduce the instances of rollover or reduce fatalities and injuries. Instead, NHTSA has increased its consumer information and education efforts.

Conclusion

NHTSA will pursue the actions included in this plan within the parameters of available staff, resources, and safety priorities. The NHTSA Vehicle Safety Rulemaking Priorities and Supporting Research, 2003-2006 (July 2003) describes our top vehicle safety priorities aimed at reducing the greatest number of crashes, injuries, and fatalities in the coming years.

Survey of State Laws on 12- and 15-Passenger Vans Used for School Transportation*

While most States require the use of school buses to transport children to and from school and school-related events, some States do not.

• 29 states have laws or regulations that prohibit the use of vans for transporting public school students to and from school and school-related activities.
• 12 states have laws and regulations that prohibit the use of vans for transporting public school students to and from school, but allow the use of vans for school activity trips. [Note: One state has passed legislation that will prohibit the use of vans for activity trips after June 30, 2006.]
• 9 states allow the use of vans for transporting public school students to and from school and school-related activities. [Note: One of these nine states has passed legislation that will not allow the use of vans to transport students after June 1, 2008. Another state has a statewide, self-insurance pool that will not insure vans used to transport students after July 1, 2005.] In many states, the laws and regulations that apply to public schools may not apply to private and church-sponsored schools.

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