NTSB study points a finger, stirs debate

The hottest industry news this week is the release of the findings of a six-month report by the National Transportation Safety Board (NTSB) regarding curbside motorcoach safety.

New York Senator Chuck Schumer

U.S. Senator Charles E. Schumer and U.S. Congresswoman Nydia M. Velázquez requested the investigation and study following the Bronx coach crash in March that killed 15 and injured 18 others.

Since March the NTSB has initiated investigations into two curbside bus crashes and has been assessing safety issues in three others. These five accidents resulted in 22 fatalities and 159 injuries.

This report is the first comprehensive evaluation of the motorcoach industry, with an emphasis on what are commonly known as curbside carriers. Curbside motorcoach operations consist of scheduled trips that begin or end at locations other than traditional bus terminals.

The study analyzed the Federal Motor Carrier Safety Administration’s (FMCSA) data and conducted fieldwork, which included interviews, focus groups, and observations of compliance reviews and inspections.

Key findings by the NTSB include:

  • In general, motorcoach travel is safe. However, curbside carriers with ten or fewer buses AND carriers who have been in business for ten years or less have higher accident rates and higher roadside inspection violation rates.
  • The fatal accident rate for curbside carriers from January 2005 to March 2011 was seven times that of conventional bus operations: 1.4 fatal accidents per 100 vehicles for curbside carriers compared with 0.2 fatal accidents per 100 vehicles for conventional scheduled carriers.
  • The exclusion of buses from routine en route inspections – especially of curbside carriers that don’t operate from terminals – reduces opportunities to discover safety violations.
  • The FMCSA is overburdened. For example, 878 FMCSA and state personnel are responsible for compliance reviews for more than 765,000 U.S. motor carriers, a ratio of 1.15 investigators per 1,000 motor carriers.
  • Bus driver fatigue, a contributing factor in many accidents, is a continuing safety concern.
  • There is a lack of transparency in ticket sales. More than conventional carriers, curbside operators use online bus brokers. FMCSA has no authority to regulate these brokers.
NTSB Chairman Deborah A.P. Hersman

NTSB Chairman Deborah A.P. Hersman put it only too lightly during the press conference Oct. 31 to present the study. “Business and safety practices within the growing curbside bus industry create challenges for enforcement authorities and consumers alike when it comes to separating the safe operators from the unsafe operators,” Hersman said.

On the other hand, with all respect to his good intent, Senator Schumer may have failed in his comment to actually separate the safe operators from the unsafe operators.

“It’s abundantly clear that the oversight of this industry has not kept pace with its growth and the consequences have been deadly,” said Schumer. “The NTSB report is a wake-up call that we need a more rigorous regulatory regime, and it provides a blueprint for how to fill the gaps. I look forward to working with [Chairman Hersman] as we now begin the process of working to overhaul how this industry is regulated and monitored.”

The NTSB’s report clearly indicates that the good companies are doing an excellent job. Had the Senator included just one well-placed adjective to describe the operators in question, the public would not be led to believe the entire motorcoach industry is coming under fire. It is more like oversight of this rogue segment of the industry remains lax and the consequences have proven deadly.

Not that the industry doesn’t need constant reminding, but a wake-up call? This is the kind of thing that has been keeping the industry awake at night for as long as the non-compliant cut-rate bus lines have been operating off the safety radar.

The American Bus Association issued a statement soon after the report was released. It commended the NTSB for its comprehensive report on the safety — or the lack thereof — of these operators, adding: “Chairman Deborah Hersman, the other members of the NTSB and the staff have done a very good job highlighting the concerns we at the ABA and have had for many years concerning unsafe bus companies that are operating outside the law and well below the accepted level of safety.”

The ABA also noted the NTSB study clearly points out traveling by motorcoach remains the safest form of surface transportation in the U.S. The average 745 million passenger trips provided annually by the industry are done so with passenger safety and comfort in mind.

Nonetheless, ABA President and CEO Peter Pantuso said: “While all ABA members who provide scheduled and point-to-point service, whether they operate from the curb or from terminals, are safe and have the highest safety ratings, there are companies on the roads that are not operating safely, and the Federal Motor Carrier Safety Administration must do a better job finding, inspecting and shutting down bus companies that operate outside the law.”

This issue has been simmering for a good seven years, as long as I have been with BUSRide. When I came on board I kept hearing about safety concerns with the Chinatown buses. A short time later Megabus and Bolt Bus came along and legitimized curbside express coach service, making me think curbside is neither the problem nor a bad word. The danger to the public and to the industry has less to do with where the coaches pick up and deliver passengers than it does with the general disregard for their safety.

“Greyhound’s Bolt Bus is one of the leaders in curbside service and our company has a strong culture and history of safety,” says Dave Leach, president and CEO Greyhound Lines Inc. “The NTSB report clearly indicates that there is a real need for safe and dependable curbside bus service, and we are doing all we can to make sure customers know when they ride with us we’ve done all we can to make the ride safe.”

Speaking on behalf of Megabus, Dale Moser, president, Coach USA, stated: “Coach USA, parent company of Megabus.com, supports the efforts to enforce compliance of the federal and state regulations and has spent millions on driver hiring, training and on equipping are coaches to make them some of the safest motorcoaches in the industry.”

Pantuso says the ABA remains on call to help solve the problem with the illegal companies, citing specific points of agreement in the study.

  • The NTSB and ABA support a higher entry fee than the current $300 for a company to apply to the Department of Transportation to obtain a DOT license to carry people.
  • The NTSB report points out critical problems exist with some companies and its drivers not being able to master the requirement to speak or read English. This is an issue the ABA has addressed on many occasions to FMCSA and in the media.
  • The NTSB report says driver fatigue is a contributing factor in many accidents and a continuing safety concern. This issue is being addressed by the ABA’s Bus Industry Safety Council (BISC) and research is being done by the FMCSA by one of the country’s leading human performance/sleep experts to address ways the government, motorcoach companies and drivers can improve significantly in this area.
  • Among those areas where the FMCSA can do better: the ABA believes more emphasis needs to be placed on inspecting motorcoaches in facilities at their point of origin or the destination.
  • Vehicle inspectors should place a top priority on inspecting motorcoaches rather than commercial trucks. While commercial products, such as food, are important, people deserve a higher priority.
  • The NTSB report indicates the FMCSA’s own database needs a thorough review and updating.

The issues the NTSB addressed – driver fatigue, reincarnated carriers, the FMCSA’s database problems, the lack of inspectors dedicated specifically to motorcoach companies, states with weak compliance and oversight and drivers who don’t speak or read English to an acceptable level – are all ones the ABA has addressed at one time or another during the last several years as the trade association for the motorcoach industry and as a leading safety advocate.

The ABA does agree with the NTSB that a system should be in place to inspect new bus companies before they begin transporting passengers. However, it respectfully disagrees with the NTSB on the issue of en route bus inspections.

According to the ABA, bus inspections need to be done at a company’s place of business, point of origin or maintenance facility before a passenger even gets on the motorcoach. The ABA contends this is an important safety issue for passengers, theorizing that while the inspection is being done passengers would be left along the side of the road without food, drinking water or restrooms.

While fully supporting inspections, the ABA advises compliance reviews and spot inspections in places where they do the most good. Pantuso asserts that en route inspections currently would be difficult to do because, as the NTSB report indicates, bad motor coach companies “engage in practices that make oversight difficult.”

In other words, rogue operators break the law by repainting buses, re-registering the company in a relative’s name, avoiding weight stations, having multiple DOT numbers or operating from states that have a well-known lax reputation and history when it comes to motorcoach inspections and regulation.

It is ironic and confusing that state and federal inspectors say they, in many cases, cannot find the bus companies or motorcoaches to inspect them. The passengers certainly can, and legitimate operators can point them in the right direction.

— David Hubbard

4 Responses to “NTSB study points a finger, stirs debate”

  1. Darlene Cochran

    The areas of concern are not exclusive to the North East region. We have the same type of issues with ” Casino Buses” picking up the public in various malls and at the curbside with or without any reservation. Some are legitimate and others are not.

    They rarely fall in the line for inspection and often times fail to carry identification on the bus. We agree that there is a serious need for the curbside pick up to create transportation that works in the area for those who need it , or wish to be greener in thier transportation choices. We also hope that the need to address the “bandit type” operators will be given a boost with manpower and funding.

    Thanks you

  2. gary guinan

    the treemont bus bolts rattle ever time i go on the bus is it safe to ride on a bolt rrattled bus. you should inspectrd it. 5550 harvest hill road dallas texas

  3. Pablo

    By Aaron Brown Jul 30, 2012 10:30 am
    The NTSB’s report on a terrible bus accident shows why it is no model for financial industry investigations.
    The Death of the PC – Merrill Lynch calls it a $160 billion opportunity.


    MINYANVILLE ORIGINAL A few months ago, I commented unfavorably on proposals to create a Food and Drug Administration for financial products. It’s not that the idea of testing and approval is inherently bad. My complaint was that the proponents (Eric Posner and E. Glen Weyl) had selected the FDA as a model, the poster child for regulatory capture, instead of, for instance, the Center for Disease Control.

    There is a similar popular idea to create a National Transportation Safety Board to investigate financial disasters, originally proposed by Eric Fielding, Andrew W. Lo, and Jian Helen Yang and more recently championed in a Bloomberg editorial by Simon Johnson. Once again, people are picking the worst possible model.

    Like an FDA for finance, there is some logic to the idea on paper. The dozens of existing federal financial regulatory authorities have difficulty conducting impartial investigations because they were involved in the regulation that possibly contributed to, and certainly failed to prevent, the disaster. Creating a relatively small and simple independent organization without regulatory powers to investigate and make recommendations seems like common sense.

    However, you would think people would do at least a little bit of research into the organizations they want to clone before suggesting things like this. To get an idea of how a National Financial Safety Board would operate in practice—not theory—let’s consider a terrible event last year: A bus accident in the Bronx that killed 15 people. The carrier, World Wide Travel, was a “curbside” bus company, meaning its intercity busses picked up riders at designated street locations instead of bus terminals. New York Representative Nydia Velázquez and Senator Charles Schumer immediately called for an NTSB investigation into the safety of curbside carriers.

    Seven months later, the NTSB issued an 80-page report. Only a couple of pages deal with the question of whether curbside bus carriers are safe, and even those give only snippets of data. Most of the report describes the difficulty of the investigation, how much effort went into it, how great the NTSB is, and various vaguely-related NTSB programs. There is one picture in the report: The overturned World Wide Travel bus. This is typical of government reports—ninety parts self-promotion, eight parts conclusions, one part sensationalism, and one part data.

    Of the report’s 27 findings and 76 subpoints, only one subpoint got significant news coverage: “The fatal accident rate for curbside carriers from January 2005 to March 2011 was seven times that of conventional bus operations.” That is the only clear and dramatic statement in the NTSB press release. It sets off immediate alarm bells for any numerate person. Flying on small private airplanes is 6 times as dangerous as flying on commercial airliners, US military personnel in Iraq died at 3 times the rate for comparable US civilians, construction workers are killed on the job at 3 times the rate of average workers, and miners at 6 times the rate. These are all things everyone knows without government statistical studies. It’s pretty hard to believe that the curbside bus industry could grow to overtake conventional intercity bus carriers in less than a decade while killing so many of their customers, and without anyone noticing. And if it is true, shouldn’t the NTSB have said something before 15 people got killed in the Bronx? Isn’t that their only job?

    I did a Google search for “curbside bus service safety.” All of the first 100 hits mentioned this figure. Most were stories about how unsafe curbside bus service is. The next biggest group were stories about all the curbside bus services shut down in a federal sweep instigated by the NTSB report. One story from Salon claimed the NTSB report proved that Libertarians are wrong.

    The NTSB report told an entirely different story than the headline figure. There are only a few pieces of data presented that relate to the question. The main pieces of data are that curbside carriers have 25% fewer accidents per bus than conventional carriers, and 30% fewer accidents with injuries. You won’t find these anywhere in the text or figures; you have to combine data from different tables and charts with a little arithmetic. These facts certainly escaped mention in the press release and all the news stories based on the study, and they didn’t prevent federal regulators from closing down nearly a quarter of curbside carriers.

    There is only one safety statistic on which curbside carriers appear to be worse: 1.4 people are killed per fatal accident versus 1.0 for conventional carriers. So it appears that curbside carriers have fewer accidents, but more deadly ones. However, this is misleading. The period of study is 2005 to 2011, during which conventional carriers had 26 accidents with fatalities and 27 people killed. That is, all but one were single fatality accidents, and one killed two people. In the same period, curbside carriers (who operate more total busses) had 37 accidents with 52 people killed. If we take out the one accident in the Bronx that initiated the investigation, that’s 36 accidents with 37 people killed, which is essentially the same ratio as conventional carriers. Again, none of this is explained in the report.

    So the real situation is that there was one completely anomalous bus accident in six years, and it happened to involve a curbside carrier. Basing conclusions entirely on this crash violates two statistical principles. It is selection bias because that accident is the reason you did the study in the first place. If you initiate a study every time there is a multiple-fatality accident involving a curbside bus carrier and include that accident in your sample, you will get an upwardly-biased estimate of curbside fatality rates per accident. The bias is severe since fatal accidents are rare and you started with one with 15 times the average number of fatalities. The second violation is that there is negligible statistical significance to a single observation. The press release did not mention the essential concept of “standard error” of estimate. The report also omitted the term (the word “error” is reserved for bus drivers, not NTSB estimates), but one set of charts contains bars.

    Even with this distortion, curbside carriers appear safer. If you have 70% as much chance of being in an injury accident, even if that accident is 1.4 times as likely to kill you, it’s better than a conventional carrier. Your accident and injury probabilities are lower, and your chance of being killed is the same. By the way, when you see numbers like this as a statistician, you immediately look for other explanations than the type of carrier. Generally you either run a safe operation or not, if you don’t, you get both more accidents and more serious ones. Differences like the kind in the NTSB data are more likely to be explained by things like urban versus rural routes or different vehicle types.

    The data presented a big problem for the NTSB. Congress had called for a denouncement of curbside carriers. Members were already on record decrying the terrible danger of these less-regulated, inexpensive carriers that were taking increasing shares of business away from established companies and government-owned terminals. It would be embarrassing to admit error. Moreover, the NTSB is part of the federal transportation-regulatory complex. It could not suggest that tighter regulation of established carriers not only drove up prices to many times the curbside fares, but it also made them less safe. On top of all that, established carriers were getting into the curbside business. If they could convince the public and legislators that the competition was dangerous, it would give them major commercial advantages.

    How can you twist data that clearly showed curbside carriers were safer into a conclusion that they were seven times more dangerous? The NTSB computed a fatality per bus value for each company, then averaged the rates for curbside and conventional carriers. Curbside carriers averaged 1.4 fatal accidents per 100 busses operated over the six year period; conventional carriers averaged 0.2. There is your seven times as dangerous figure.

    How is this consistent with curbside carriers actually being safer? Simple. Remember World Wide Travel, with 15 fatalities. At the time of the accident, it was operating 13 busses. If it had the same number over the entire sample period, that would be a rate of 15 / 0.13 = 115 fatalities per 100 busses. Even if none of the 70 other curbside carriers had any fatalities at all, that would be an average rate of 115 / 71 = 1.6 fatalities per 100 busses. If the other curbside carriers had the same average rate as conventional carriers, this one accident explains almost the entire difference in fatality per bus rates.

    If this point is not clear, consider a simpler example from baseball. So far this year, Minnesota has the worst pitching in the American League with a team earned run average of 4.8 (meaning its pitchers gave up an average of 4.8 runs per nine innings, excluding “unearned runs” which are blamed on fielding errors), while Tampa Bay has the second-best with a team ERA of 3.4.

    Suppose Minnesota were regulated by federal baseball authorities with revolving-door employment for regulators, while Tampa Bay was an upstart team outside the regulatory umbrella. How could you show that Minnesota pitching was actually better? You could take the earned run average for each Tampa Bay pitcher. The two least-used pitchers on Tampa Bay are Josh Lueke, who has given up seven earned runs in three and a third innings work, and Dane De La Roas, who has given up five earned runs in one inning of work. That makes their ERAs 18.9 and 45 respectively, and raises the average ERA of all Tampa Bay pitchers from 3.4 to 6.6. Although Minnesota pitchers have been worse than their Tampa Bay counterparts at nearly every position, they have no pitchers with ERAs above 10, and the average of their pitcher’s ERAs is the same as their team ERA, 4.8.

    It is statistical malpractice to average rates this way instead of taking total fatalities for each type of carrier and dividing by total number of busses (or total earned runs divided by total games pitched). However, you can mitigate this somewhat by presenting standard errors. As mentioned above, these are provided only graphically in the report (hopefully showing some conscience on the part of some NTSB analyst), but not given in figures and certainly not mentioned anywhere in the text or press release (suggesting less conscience on the part of editors and managers). The standard error suggests that the fatality rate for curbside carriers is between 0.2 and 200 times the fatality rate for conventional carriers. Reporting that range as “seven times” without qualification is wrong. Not just sloppy or incomplete, but wrong. This is especially true because you know exactly why there is such a large range; it’s not random noise or an inherently difficult to estimate figure. In non-quantitative language, when the data are analyzed this way, they tell you nothing. The confidence intervals are much bigger than the reported number, meaning there is more uncertainty than information in your analysis.

    The NTSB has refused to make the raw data available. This is malpractice for any statistical analysis, but it is staggering in the case of a government entity set up to disseminate information. It’s pretty good evidence that the NTSB knows how bad its analysis is. We’re not talking about private or proprietary information, fatal bus crashes are a matter of public record. The only thing the Board is concealing is their estimates of the number of busses for each carrier. Curbside carriers are on double super secret probation, which seems to be precisely the opposite of the NTSB’s charter. How can it possibly improve transportation safety to conceal information?

    In some ways, even more shocking than the number abuse is the terrible quality of the data. The organization charged with investigating transportation safety had no information on curbside bus safety, despite the fact that these companies had grown rapidly to account for the majority of scheduled intercity bus service. The NTSB had to get data from other places, and it could not obtain or estimate crucial figures like the average number of people on each bus, and the average mileage per bus. A company that carries twice as many passengers per bus, and runs each bus twice as many miles per month, could have four times the fatalities per bus and be just as safe as another company. Less important, but still significant, is you need data to adjust for urban versus rural routes, long versus short trips, day versus night runs, and other variables that influence accident rates.

    Another key omission is the data do not distinguish between bus occupants killed and those people killed either in other vehicles or as bystanders, and do not distinguish fault. If there is a major pile-up involving 20 cars, and a bus dents a fender slightly at the tail end, all the fatalities among all vehicles are charged to the bus, the same as if a drunken bus driver had killed the same number of people driving his bus off a cliff or if a negligently-maintained bus exploded. Since most of the fatalities listed in the study were not bus occupants, this is a major point.

    Not only do these basic data problems mean it was irresponsible for the NTSB to issue any report at all on the subject, but it calls into question the NTSB’s ability to do meaningful investigations. Suppose a bus crash is caused by a driver falling asleep after driving twelve hours with only short breaks. In order to issue a finding that may be turned into regulations by other agencies and will be used to cripple an innovative industry, you need information about overall accident rates as a function of driver fatigue, and how rules will affect price and convenience of service, and whether those changes might send some passengers into more dangerous modes of transportation. If you don’t have those data, and if the data you do have come from the agencies and companies you were created to be independent from, it’s hard to see how you’re adding to the discussion.

    Getting back to my real subject, imagine how this will play out in a financial disaster. Suppose that curbside venture capitalists begin raising capital for small, local businesses from middle-income residents by making presentations in school auditoriums and church basements. There is a spectacular collapse in which hundreds of investors lose their savings. Congress calls for an investigation into curbside venture capital firms.

    The National Financial Safety Board will not have any data on these curbside companies as it is focusing all its attention on the large, regulated firms doing mainstream business. So the NFSB does a study that finds that curbside venture capitalists have a 30% better track record than big firms: Better average returns to investors, less risk, and more successful businesses, not to mention lower fees. Is anyone naïve enough to believe these facts will get published? It seems more likely to me that the NFSB will find some way to twist the numbers to the convenience of Congress and the established industry, and so they are less embarrassing to federal regulators. The press will report the distortions as fact; no one will read the report and think about the data. The NFSB will act to suppress innovation and competition.

    What is a good model for disaster investigations? All the useful data in the NTSB report come from the University of Michigan Transportation Research Institute. UMTRI operates on $13 million per year, versus $98 million for the NTSB. It puts out a wealth of authoritative and useful reports, and maintains valuable data for other researchers (including the NTSB). It also provides extensive educational services. Although it is funded by car manufacturers and the government—and accepts paid consulting work—that does not seem to compromise its independence.

    So if you want to argue for more independent investigation of financial problems, consider funding a university research institute. At least you can point to an example that seems to work.

    Read more: http://www.minyanville.com/business-news/politics-and-regulation/articles/Transportation-Safety-financial-regulation-safety-statistics/7/30/2012/id/42805?page=full#ixzz2Sj3aHgyE