Fatal Exit

Chapter 8 - Turn Signals: February to March 2003

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The global road trauma epidemic is real. Every day 3000 people die and 30,000 are seriously injured on the world's roads.

In the blink of a turn signal motor vehicles crash. The emotional cost of a car crash is hard to measure. It varies from individual to individual, from victim to survivor. Motor vehicle crashes are a leading cause of post-traumatic stress disorder (PTSD). People with this disorder can have a variety of symptoms, including psychological numbing of emotions, anxiety, poor concentration, and insomnia. Formal advisory bodies, such as the National Transportation Safety Board and the Transportation Research Board (part of the United States National Academy of Sciences) were set up to provide independent advice and guidance. The combination of new, dedicated institutes on road safety and greater scientific research has in many cases produced major changes in thinking about traffic safety and its interventions. However, at the same time, there is often a real conflict between the aims of traffic safety lobbies and those of campaigners for increased mobility or for environmental concerns. In such cases, the lobby for mobility has frequently been the dominant one. In the long term, increases in mobility, without the corresponding necessary increases in safety levels, will have a negative effect on public health.

- World Report on Road Traffic Injury Prevention, 2004.

The NTSB is an independent Federal agency charged by Congress with investigating every civil aviation accident in the United States and significant accidents in other modes of transportation - railroad, highway, marine and pipeline - and issuing safety recommendations aimed at preventing future accidents.

DOCKET # NHTSA-2OO2-13546-59 02/28/03 National Transportation Safety Board (NTSB)1

On February 28, 2003 the National Transportation Safety Board (NTSB) commented to NHTSA:

The National Transportation Safety Board (NTSB) has reviewed the National Highway Traffic Safety Administration's (NHTSA's) request for comment title, "Event Data Recorders," published in the Federal Register, Volume 67, Number 198, on October 11, 2002. The Safety Board appreciates the opportunity to comment on this important issue affecting highway safety.

The Safety Board has a long history of promoting onboard recorders in all modes of transportation. In fact, the issue of automatic information recording devise for all modes of transportation has been on the Board's "Most Wanted" list of Transportation Safety Improvements since 1997. On-board recording devices have proven themselves to be extremely valuable in the other modes of transportation, particularly aviation. The Board believes effective implementation of on-

board recording in highway vehicles can have a similar, positive impact on highway safety. Accurate recorded data can provide key information to help individual accident investigations. Also, the collection of record data in aggregate from can offer a wealth of information when addressing important safety issues, such as air bag system effectiveness. Even further, standardization of event data recorder (EDR) data could increase the benefit of collecting data in aggregate form.

The Safety Board's first recommendation to NHTSA regarding the on-board recording of data resulted from the 1997 NTSB Air Bag Forum. Safety Recommendation H-97-18 recommended that NHTSA work with the automobile industry to use data stored in current crash parameters. The subsequent initiative by NHTSA and automobiles manufacturers, such as General Motors, went beyond the Board's expectations. The Board is further encouraged by the efforts of some members of the automobile industry to continue to expand the recording capabilities of air bag modules.

As mentioned in the request for comment, the Safety Board's most recent Safety Recommendations to NHTSA regarding on-board recorders were H-99-53 and -54. These recommendations requested that installation of EDRs be required on newly manufactured school buses and motor coaches and that NHTSA work with industry to develop an EDR standard. For the development of a standard, the Board focused on key issues that have been critical to onboard recording standards in other modes of transportation: parameters to be recorded, data sampling rates, duration of recording, and survivability factors.

The Safety Board believes NHTSA's ongoing leadership in response to the Board's recommendations has been invaluable to the implementation of EDRs. NHTSA's formation of two working groups, the Event Data Recorder Working Group and the Truck and Bus Event Data Recorder Working Group, brought together a number of different manufacturers, user groups, and other stakeholders. The Board participated in both of the NHTSA EDR working groups and found that the efforts of these groups were an important first step in the effective implementation of EDRs.

The Safety Board's investigations have already benefited from the availability of on-board recorded data from such devices as engine electronic control modules. The impact that recorded data can have on an accident investigation is no more evident than in the Board's investigation of the Sierra Trailways motor coach accident that occurred in Canon City, Colorado, on December 21, 1999. Investigators were fortunate that the motor coach engine's electronic control module recorded information, though limited, that assisted the investigation. However, despite the important contribution the data made to the investigation, investigators were still left with many unanswered questions regarding the status of the vehicle systems and the actions of the driver. If the motor coach had been equipped with an EDR that recorded the parameters recommended by the Board on H-99-54, investigators would have been able to more clearly identify the status of the vehicles and the driver's actions, and more focused safety recommendations may have resulted.

In 1998, the Safety Board issued Safety Recommendations H-98-23 and -26 to trucking industry organizations, recommending that they advise their members to equip their vehicles with on-board recording devices to gather information on both driver and vehicle operating characteristics. These recommendations focused on two issues. The first issue was the recording of driver data for the purpose of hours of service compliance, which was outside the scope of an EDR. The second issue focused on the recording of vehicle information, as with an EDR. Unfortunately, the trucking industry groups did not choose to take the recommended action, and the recommendations have been classified as "Closed-Unacceptable Action." The Safety Board is disappointed that no action was taken for the recording of vehicle data and continues to believe the recording of data on board heavy vehicles remains an important issue.

The formation this past year of the P1616 Working Group by the Institute of Electrical and Electronic Engineers, Inc. (IEEE) is another promising step in the implementation of EDRs. The Safety Board fully supports the development of a voluntary standard, and the Safety Board staff is participating in the working group. The Board hopes that the standard developed through IEE will provide a framework to promote consistency and availability of EDR data for both light and heavy vehicles.

The Safety Board believes EDRs continue to be a key component in the process to improve highway safety. The issues associated with EDR development and deployment will be an important part of a Topical Technical workshop (TOPTEC) being co-sponsored by the Safety Board and the Society of Automotive Engineers. The TOPTEC will focus on recorders in all modes of transportation and is expected to take place June 4-5, 2003, in Alexandria, Virginia. The Board will keep NHTSA informed as the details are finalized. We hope that NHTSA will actively participate in this effort.

We appreciate the opportunity to comment on this important issue and urge NHTSA to continue pursuing the effective implementation of EDRs on highway vehicles.

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