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Bus and Motor Coach Library

Safe & Secure Passenger Services – How Can You be Sure?

Author – Brian Niddery (2005)

There seems to be a desire by many in the industry to implement some kind of measurable or recognized rating program that could provide quality operators with the means to better market their services more effectively, without the frustration of being under-priced by less-than-quality operators.  The military seems to have achieved this, much of this in conjunction with Consolidated Safety Services (CSS).  Recently CSS has developed a similar civilian-based program at the request of several school districts.  Perhaps this civilian-based program can be adapted to a more universal role in the bus industry, and perhaps eventually lead to a recognized industry-wide rating system.

A number of highly-visible fatal accidents involving passenger motor carriers have occurred over the last ten years - some involving schoolchildren - and all raise the same question for nearly every school administrator, teacher, coach or parent who hears about them:  "Just how safe is the carrier that is transporting our children?"  Until now, no one has been able to answer that question with confidence - but that situation is changing.

School districts find it difficult to confirm the safety record of passenger motor carriers because there is currently no centralized planning, coordination, or control over the safety of pupil transportation via school-chartered motorcoach rather than school bus.  The U.S. Department of Transportation National Highway Travel Safety Administration "Guideline 17" recommends that each state assist its counties and/or school districts to establish a comprehensive pupil transportation safety program that ensures the highest possible level of safety for school buses and school-chartered motorcoaches.  While programs that ensure the safety of school buses have been highly successful, school officials are frequently left on their own to put together programs regarding school-chartered motorcoaches.  In many cases, the person(s) making the decisions about chartering a motorcoach do not have sufficient expertise, knowledge, or resources to carry out this responsibility.

Currently, when parents, teachers, and school administrators wish to make what would be considered an "informed decision," they must go through masses of government safety, performance and compliance data and must also be reasonably knowledgeable about the Federal Motor Carrier Safety Regulations.  As a result, many school districts continue to use the "same old" carriers or to thumb through the phone book to find a passenger motor carrier when they need one.  Each school district independently selects a motor carrier from its own list, if it has a list at all.  Using the "same old" carrier does not necessarily mean that the district is choosing an unsafe carrier.  But the question remains, how can a school district be certain that the motor carrier has an excellent safety record?

Over 16 years ago, the U.S. Department of Defense (DoD) was faced with a similar question - how to assure the safety of the passenger motor carriers who were under contract to transport military personnel.  Deregulation was swelling the ranks of motor carriers operating on U.S. highways, and, due to limited resources, the Federal Motor Carrier Safety Administration (FMCSA) was unable to provide the level of oversight and assurance DoD sought regarding motor carrier safety.  In 1990, Fairfax, Virginia-based Consolidated Safety Services, Inc. (CSS) provided a solution that fully satisfied DoD's requirements.  CSS developed and implemented a nationwide Quality Assurance Program for DoD, and from then until today, has helped to ensure the safe, secure and efficient movement of military personnel nationwide.
In 2004, Giles R. Benson, Director of the Department of Materials Management for the Montgomery County Public Schools (MCPS) of Maryland, asked whether he was assured of the safety of the motor carriers he used, and realized that he could not answer that question with confidence.  Benson learned of the DoD program from one of MCPS' approved passenger motor carriers that was DoD-approved, and thought that if a program like the one provided DoD could deliver the necessary assurances, it could certainly do the same for MCPS.

Discussions between Benson and Robert Watkins, who heads the Transportation Safety and Security Division of CSS, led to the development of the Pupil Transportation Safety Passenger Program, a mirror image of the DoD program.  CSS now provides MCPS with a proactive motor carrier inspection and approval program, which gives school administrators, teachers, coaches and parents the ability to select with confidence from a national approved list a passenger motor carrier that can, with the highest degree of probability, provide safe, secure, and reliable transportation services for school children.

The initial phase of implementing the program provided a clear illustration of the kind of concerns facing virtually every U.S. school district that seeks safe, reliable transportation for its school children.  CSS identified four carriers on the list that MCPS was then using that were not approved to transport military personnel for DoD - but those carriers were considered "qualified" to transport MCPS school children. 
Benson is pleased with the program.  "I don't have 36 questionable carriers on our approved list any more," he said, "I have 24 highly qualified carriers.  They provide fantastic service, they're more reliable and responsive to our needs, and to put it simply, I sleep better at night knowing CSS is keeping an eye on them for me."  Benson also said that MCPS is committed to continuing the program regardless of what other districts and counties might do, but said that if other districts and counties throughout the country joined together in a collaborative effort, "We would have one heck of a program, at minimal cost to everyone."
The Pupil Transportation Safety Passenger Program CSS developed for MCPS is a proactive program.  It provides a comprehensive, aggressive inspection program modeled after the successful DoD motor carrier inspection program, which has been in existence for 15 years.  As Watkins describes it, the goal of the program is for a carrier to be "compliant and safe by design, not by default."

School administrators, teachers, and parents may often assume that because a motor carrier is registered with DOT, it has a good safety record.  However, following deregulation, the number of registered carriers rose dramatically, from 190,000 in 1990 to 700,000 today.  FMCSA, the responsible government agency, does not have the personnel to conduct detailed inspections of all these carriers and must focus its limited enforcement resources on those carriers who pose the greatest potential safety risk.  FMCSA uses its Motor Carrier Safety Status Measurement System, commonly called SafeStat, an automated system that uses current and historical safety performance information, such as Federal and state data on crashes, roadside inspections, on-site compliance review results and enforcement history, to measure relative commercial motor carrier safety.

SafeStat is valuable, but according to Watkins, it only provides enough data for FMCSA to effectively score 1.27% of the 700,000 registered carriers.  Also, unlike the Pupil Transportation Safety Passenger Program, Safestat is reactive in nature, in that a carrier is deemed a safety risk only after the carrier has been involved in a sufficient number of accidents or has had an excessive number of its drivers and/or vehicles placed out of service.  Only then is a compliance audit conducted. 
In the Pupil Transportation Safety Passenger Program, when a school district or county nominates a carrier for inclusion on the national approved list, the carrier must supply specific documentation (authority, insurance, etc.) for review.  CSS then conducts an extensive investigation into the compliance and performance history of the carrier.  Once the carrier is verified, CSS schedules a core competency evaluation, using a seven-page questionnaire to test one of the motor carrier's key responsibilities, that is, its knowledge of and compliance with the regulations governing its operations.  The questionnaire serves as a screening tool, because roughly one-quarter of the carriers applying for approval fail to pass the core competency evaluation.  In those cases, the carrier generally must wait six months before reapplying for consideration.

A carrier that passes the core competency evaluation undergoes a comprehensive on-site pre-qualification inspection, covering all aspects of its business, including general provisions, drivers, operations, hours of service, maintenance, and vehicles.  CSS calculates the carrier's accident and vehicle out-of-service rates during the review and incorporates them into the evaluation and scoring process.  The combined scores enter the calculation of a safety performance rating; only carriers achieving an overall safety performance rating of 1, 2 or 3 gain approved status.  Following the inspection, both the jurisdiction that initiated the inspection and the carrier receive a detailed inspection report of the findings, along with recommendations to correct any operational deficiencies.

Once a carrier passes the initial screening and the pre-qualification inspection, CSS places it on the national approved list.  The carrier is then subject to biannual onsite inspections, using the same process and criteria as the pre-qualification inspection, in order to remain approved.  If CSS found any operational deficiencies during previous inspections, it confirms that the carrier has taken sufficient action to correct the deficiencies.
In addition, CSS conducts no-notice or surprise inspections on drivers and vehicles; these are similar to Federal and state "roadside" inspections.  The inspections monitor the quality and safety of the service being provided by the carrier, and generally take place at the point of origin or pick-up before students are allowed to board the motorcoach.  A carrier must pass these surprise inspections or run the risk of disqualification from the program.  "We know that the carrier has the ability to provide safe service," Watkins said, "and these random inspections verify that the quality of service expected is actually being provided."

An approved carrier is also subject to routine on-road performance monitoring every six months.  CSS obtains the carrier's performance data (inspection/accident data collected and submitted to FMCSA by state and Federal officials) from FMCSA's Motor Carrier Management Information System (MCMIS), and calculates and scores the carrier's performance.  If a carrier fails to maintain acceptable levels of performance, depending on the severity of the shortfall, CSS will either disqualify it or place it on notice of pending disqualification unless its performance attains acceptable levels during the next review period.
The program treats violations as symptoms of deeply-rooted problems, such as insufficient knowledge of regulations, inadequate training, poor execution, ineffective management oversight, or lack of accountability.  By conducting comprehensive inspections, CSS seeks the root cause of any problem with the intent of helping the carrier improve, thereby minimizing risks to school children.

School districts incur some costs to participate in the Pupil Transportation Safety Passenger Program, but the program is designed to reduce costs wherever possible.  For instance, because the program follows the same inspection procedure used by DoD, CSS automatically approves any carrier already on the DoD list and places it on the national approved list, pending the carrier's application for approval and its sponsorship by a participating jurisdiction.  The preliminary core competency evaluation serves to screen out carriers before CSS schedules the on-site pre-qualification inspection reduces.  Finally, data exchange between the program and FMCSA also screens out the "bad guys" before they enter the program.

Because the program is a collaborative effort, as it grows larger, costs to individual districts and counties will continue to decrease to literally pennies per student.  Since the inspection and monitoring process is the same nationwide, no matter where the carrier is approved, participating jurisdictions get access to all approved carriers at no cost.  Districts and counties benefit from nationwide access when they need ground transportation outside the jurisdiction to supplement air travel.

The program benefits carriers as well, which incur no cost for inclusion and can benefit from increased business.  By asking carriers to meet minimum standards and demonstrate sufficient safety management controls in order to be included on the national approved list, Watkins said, it is possible to direct more business to the approved safer carriers and to cut off unsafe carriers' sources of revenue.  Parents, teachers, and school administrators can use the list to shop for the best price, in the knowledge that even the lowest price is still offered by a qualified, competent passenger motor carrier. 

CSS has developed the Pupil Transportation Safety website (http://pupiltransportation.consolidatedsafety.com/index.asp) to assist those seeking more detailed information on the program.  The website provides information on the program, including answers to frequently asked questions (FAQs) for both school administrators and motor carriers.  Access to the national list of approved carriers is also housed on the website, but is password-protected and only available to participating jurisdictions.