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Campaigning for safer, cleaner motor vehicles
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  Joan Claybrook's Letter to the National Transportation Safety Board Regarding Solutions to the Safety Hazards of 15-Passenger VansNovember 18, 2002 Dear Madam Chair: On November 1, 2002 the National Transportation Safety Board (NTSB) issued a report and sent a letter to the National Highway Traffic Safety Administration (NHTSA) and to William Clay Ford, Jr., Chairman and CEO of Ford Motor Company, as well as to G. Richard Wagoner, Jr., President and CEO of General Motors Corporation, about the dangers of 15-passenger vans, and their over-involvement in single-vehicle rollover crashes with some recommendations. On November 12, 2002, Public Citizen and C. Tab Turner issued a report assessing the dangers of these vehicles and recommending a technological fix for the vans now on the highway. Based on testing of Ford and General Motors 15-passenger vans by two independent testing companies in traditional stability tests (J-turn and reverse steer), with original equipment and with dual rear wheels on each side, we learned that dual rear wheels can significantly reduce the likelihood of rollover. This great idea did not originate with us. In fact, it was considered by Ford before its van was first manufactured. And as you are undoubtedly aware, dual wheels are an option on pickup trucks with the same or similar designs as 15-passenger vans. In fact, dual rear wheels were offered on pickup trucks as early as 1937. And a dual rear wheel option package can be purchased from dealers, or over the Internet, that fits the 15-passenger vans. We very much appreciate the recent evaluation made by the NTSB and your recommendations, particularly your recommendation that various technological systems be evaluated to assist drivers in controlling the vehicle. While electronic stability control systems and other devices might be useful, adding dual rear wheels and related technology appears to be a far quicker and easier correction for these vehicles. We urge you to review the videotape of the tests and review our report, both of which are enclosed. We believe the manufacturers should offer all owners a dual rear wheel retrofit immediately and spare the lives of so many innocent occupants, often from church groups, college sports teams, day care centers, and airport and other transportation services. We also appreciate the Board’s recommendation to the National Highway Traffic Safety Administration (NHTSA) that it include 15-passenger vans in its research and testing program, and in its forthcoming consumer information dynamic tests for rollover. We would also like to bring to your attention that these vans, because they are classified under NHTSA regulations as a bus (because they carry over 10 passengers), need not meet many of NHTSA’s crash protection safety standards (some of the safety standards, particularly the pre-crash 100-series safety standards, do require compliance by buses). Also, because they are not school buses, they do not have to meet the strength and rollover protection standards required of these vehicles. And because they carry 15 occupants, not 16, the driver does not have to have a commercial driver’s license. In essence, these vehicles fall through a regulatory black hole, and despite their dangers, the safety consequences have been ignored for years by both the manufacturers and NHTSA. This is particularly frightening because these vehicles are highly prone to devastating rollover crashes, and often carry many passengers who remain unprotected. And unfortunately, because these vehicles are larger than a regular automobile or van, and the belts are particularly cumbersome (most shoulder belts in these vehicles are connected to the roof), occupants believe they are secure and often don’t wear them. NHTSA is in the midst of a rulemaking on a multi-activity school bus, one that would not have to be equipped with warning lights or the stop arm that regular school buses must have. By the very same token, NHTSA has the authority to re-classify another "type" of bus — the 15-passenger van. The agency could, by regulation, require that such a vehicle be termed a "small bus" and that it meet all the current motor vehicle safety standards for cars, vans and small multi-activity school buses as appropriate. The agency could also, as you recommended, require that the vans be covered by the New Car Assessment Program’s consumer information measurements, including the Static Stability Factor, and dynamic rollover tests (now in rulemaking). We have urged NHTSA to issue such a regulation as well as taking the other steps we outline in a November 13, 2002 letter to Dr. Jeffrey Runge (enclosed.) We also urge NHTSA to send a warning letter to all owners of these vehicles about the risks involved, steps for how to mitigate them, and advising them of the lifesaving value of dual rear wheels. We ask NHTSA to urge the Federal Motor Carrier Safety Administration to require commercial drivers licenses for drivers of vehicles carrying over 10 passengers as well. We ask you to do the same. We will also be contacting insurance companies and asking them to follow the lead of GuideOne Insurance Company in assisting owners with information and advice about these vehicles. We would urge you to consider contacting insurance companies as well to reinforce this message. We would appreciate the opportunity to meet with you in the near future to discuss the remedies for dangerous 15-passenger vans. We will call your office for an appointment. Sincerely, Joan Claybrook more resources
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