National Coalition For School Bus Safety
National Coalition For School Bus Safety
 

LETTER TO NTSB MEMBER, GEORGE BLACK -  NOVEMBER 18, 1999

Letter re: NTSB Report" (Founders of P.A.S.S. Legislation)

Nora & Kevin Job
P.O. Box 574
Monticello MN 55362

November 18, 1999

George Black
Member
National Transportation Safety Board
490 L/Enfant Plaza East, SW
Washington, DC 20594

Dear Mr. Black,

Thank you for your response to my letter dated October 7, 1999. your attempt to resolve concerns I held regarding the September 21, 1999 NTSB School Bus Crashworthiness study is greatly appreciated.

In the first paragraph of your letter, you responded by informing me that:

"It is important to understand that the accident cannot be recreated exactly as it happened since the necessary detailed information is not available." "Therefore reconstruction and the simulations are representative of a similar accident but do not portray actual events of the Monticello accident."

The NTSB sent an investigator, Richard Downs to investigate the Monticello School Bus crash. Necessary detailed information should have been included in this investigation and documented. I have reviewed a small portion of the investigative report conducted of the Monticello school bus/truck crash. Thus far, I am compelled to believe that the investigation was conducted in a haphazard manner. I state this based on the following discoveries I have made thus far:

1.None of the three residents first on the scene of the crash were interviewed by Mr. Downs while he was present in Monticello. The NTSB finally contacted, Marn Flicker, the first at the scene also a retired volunteer firefighter, eight months after the crash. One year and four months later it was discovered that neither Mr. Downs nor the NTSB had contacted Mr. Salo or Mr. Ingram. I submitted the name and phone number of Mr. Salo to Jean Marie Poole shortly after the NTSB Crashworthiness Hearing in August of 1998, held in Las Vegas.

2.The environment of the Monticello school bus crash was altered: Tree branches, shrubs and brush obstructing the vision of both drivers were trimmed back within hours of the accident, prior to the reconstruction of the crash. (Freshly cut tree branches, piled and lying in the grass are visible in photographs taken by the Wright County Sheriff Department and provided in the report.)

3.In the report Mr. Downs allows the reader to assume he has interviewed all the children. To my knowledge Mr. Downs interviewed only one child - Jordayna VanCulen.

4.Collection of internal evidence from the school bus was difficult due to:
(This data correlates with the information provided in the report filed by Deputy Dave Clemence)

a. Collection of evidence was conducted several days after the bus was removed to an impound lot.

b. Evidence was tampered from the presence of people who were allowed in the bus and due to items retrieved from the field thrown inside the bus dispersing grass and dirt throughout the bus.

As of this date, I have not had the opportunity to read the entire report mailed to me. The errors listed above are used to illustrate possibilities as to why necessary detailed information was not available to the NTSB for the computer crash simulations.

In the second paragraph you further state:

"The advantage of the simulation is that nothing in the model changes except the restraint and therefore predicted injuries can validly be compared with and without restraints."

Included at the bottom of Table 3 "Summary of Actual Injuries to the Monticello Bus Occupants and Predicted Injuries Based on Various Simulation Conditions", is a key which states:

* = Predicted injury based upon simulation
-- = Data unavailable. Neck Injuries were not examined in the unrestrained condition.

I questioned this conduct in my first letter, of which you did not respond to. I will reiterate from my first letter:

"The computerized crash simulation provided a comparison of unrestrained, lap and lap/shoulder restraint conditions. In the unrestrained condition neck injuries were not examined, yet neck injuries were examined in lap and lap/shoulder conditions. It the goal was to compare the effectiveness of these three occupant protection designs, why were predicted injures sustained to the neck area not examined and compared in all three conditions?"

Predicted injuries sustained to occupants were not equally compared in the unrestrained condition compromising the accuracy of this study.

I realize this study was an investigative study of school bus crashes involving lateral, rear and rollover crash forces and the study would compare the effectiveness of available restraints for occupants involved in these crashes. Simulating these school bus crashes with a change to the seat back height from the current 24 inches up to 28 inches would provide an insight of the safety provided to occupants currently transported in school buses in NY, NJ and many individual school districts across the nation.

I am disappointed in the discovery of the errors existing in the recent study and the lack of initiative to demand an accurate investigation and simulation. I do hope the NTSB will conduct a thorough investigation of the NY bus crash. I also hope this investigation will consist of compiling detailed information necessary for scientific research. Animated simulations of crashes become complicated when sufficient input data is not available. During my computer courses in post-secondary education a vital acronym was forced into our knowledge of computer programming, GIGO: Garbage In Garbage Out. The conclusions of a computerized crash simulation can only be proven accurate when compared to accurate and factual data from the actual crash.

It is my deepest hope that members of the National Transportation Safety Board will see the errors existing in the study, thus committing themselves to investigate the data used to compile the conclusions portrayed in the simulations. I also hope members of the NTSB will require documented factual evidence supporting occupant injuries portrayed in the computerized simulations. Most importantly I hope members of the NTSB will require accurate scientific data to be used for the input of the computerized simulations validating injuries and the effectiveness of occupant restraints installed on large school buses.

The favor of a reply is welcome,
Nora & Kevin Job

Cc:
Jim Hall - Chairman
Robert Francis II - Vice Chairman
John Hammerschmdt - Member
John Goglia - Member

Nora & Kevin Job have not received a response from Mr. Black or any of the other NTSB Members receiving a copy of this letter.

P.A.S.S. Legislation has reviewed the NTSB Highway Special Investigation Report: Bus Crashworthiness Issues. Below are statements regarding the Investigation and the simulations of the Monticello school bus crash, we feel will provide parents, Legislators and Congress with insight.

The computer simulation predicted injuries sustained by occupants were examined in three different areas: head, thorax and neck. The definition of these three areas is as follows:

Head: the upper or anterior division of the animal body that contains the brain, the chief sense organs, and the mouth

Thorax: the part of the mammalian body between the neck and the abdomen; also: its cavity in which the heart and lungs lie

Neck: the part of an animal that connects the head with the body

NTSB Final report regarding the Monticello school bus crash states:
(Comments in italics are added by P.A.S.S. Legislation)

1. A simulation does not replicate the actual accident

2. In Table 3. "Summary of actual injuries to the Monticello bus occupants and of predicated injuries based on various simulation conditions." The column portraying predicted injuries during the computerized crash simulation in the "unrestrained" condition are not equivalent to the actual injuries sustained to unrestrained occupants during the actual crash. (Additionally, occupants of the Monticello school bus collision sustained injuries to arms, stomach, hips and legs. These areas were not examined or listed as actual injuries.)

3. The six passengers in the rear of the bus in the Monticello accident, who ranged from 9 to 11 years old, were simulated using the 6-year-old P6 modeled dummy and the Hybrid III 6-year-old modeled dummy. (In the other two simulated school bus crashes, dummies equivalent to the actual age, height and weight were used to predict injuries)

4.In the Background section of the NTSB Final Report, conclusions from the 1969 UCLA School Bus Crash study, which state, "high seatback (28 inches) was the most important safety feature for large school buses, followed by the use of lap/shoulder belts, lap belts, or another form of restraint. The researchers cautioned against the use of lap belts with low seatbacks because of the risk of head injury." (The use of 28 inch seat back heights, in the NTSB simulations, would have provided a valid portrayal of crash effects for states and school districts now installing 28" seat back heights and lap belts.)

5.Seat back heights used for the NTSB computerized crash simulations were of the minimum safety standard of 24" in height. (School districts and states requiring lap belts installed in school buses follow the recommendations of the UCLA School Bus Crash study by specifying an increase to the seat back height of 28 inches.)

6. The NTSB Final Report includes the following in a footnote: "Because the extreme kinematics contributing to neck injuries were not noted in the unrestrained condition and because the modeling software did not have the capability to measure neck injuries at the time of the unrestrained simulation, neck injuries were not examined for the unrestrained condition". (Why was the simulation conducted if the modeling software was not capable of measuring neck injuries in the unrestrained condition? If the modeling software had the capability of measuring the neck injuries in the lap and lap/shoulder condition of the Monticello collision and in the unrestrained condition of the Holyoke, CO collision why wasn't the unrestrained simulation reconstructed providing data for comparison purpose?)

It should be noted that in the Holyoke CO. collision Table 6. "A summary of actual injuries to the Holyoke bus occupants and of predicted injuries based on various simulation conditions" Again, the computerized crash simulated injuries predicted in the unrestrained condition are not equivalent to the actual injuries sustained to occupants in the unrestrained condition during the actual crash.

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