Lacey can MOT Boys Ruaortord MARYLAND DEPARTMENT Us, Covsinor (OF TRANSPORTATION James Farts Jc MOTOR VEHICLE Christine Nizer ADMINISTRATION. Senn April 14, 2022 Dr. Jess Baltimore County Public School 9610 Pulaski Park Drive Suite 219 Middle River Maryland 21220 SUBJECT: Results of Maryland Department of Transportation Motor Vehicle Administration Independent Inspection of the Baltimore County Public School Bus Fleet ‘The Maryland Department of Transportation Motor Vehicle Administration (MDOT MVA) has compiled a report on the independent inspection of the Baltimore County Schools (BCPS) bus fleet initiated on November 22. This report provides an overview of the inspection results as well as a set of recommendations for BCPS to address findings. MDOT MVA would like to thank Baltimore County Public School representatives the cooperation during the inspection process and the assistance in logistical issues regarding the coordination of activities in jently completing the bus inspections. We would appreciate a written response to the attached report by April 27, 2022. Should you have any questions, please contact me on 410-424-3706. Sincerely, Leslie Dews Deputy Administrator, Field Operations MDOT MVA {6601 Richie Highway NE. Glan Burnie, Maryland 21062 | 410.768.7000 | 800950.MVA | Maryland Relay TY 600.492.4575 | mvemorylond.govCe: Christine Nizer, Administrator, MDOT MVA, McKandy Gale, Manager, MDOTMVA Michael Groff, BCPSBaltimore County School System Bus Inspection Review BACKGROUND In November 2021, the Maryland Department of Transportation Motor Vehicle Administration (MDOT MVA) began an independent inspection of the entire Baltimore County School System (BCPS) bus fleet. Conducted by vehicle compliance agents (VCA) in the MDOT MVA School Bus Safety and Inspection Division, this was to ensure that all buses were safe to transport students in accordance with COMAR 11.19.04, following a media inquiry by FOX 45. SCOPE AND METHODOLOGY MDOT MVA conducted Type 8 inspections (This is a bumper-to-bumper inspection of the vehicle with the exception of the removal of the wheels. Items included in the Type B inspection range from ‘examination of systems such as suspension and frame, engine and exhaust and lightning and gazing as well as emergency equipment on the vehicle.) Under COMAR 11.19.04.03.8, Type B inspections are to be conducted at least twice a year and at minimum 60 days apart. On the BCPS-owned fleet of 806, buses from November 22, 2021 to January 14, 2022. In addition to the Type B inspection, MDOT MVA. also; ‘+ Examined fuel straps on each bus to determine if any were defected/deteriorated and presented a safety issue for transporting students, © Reviewed BCPS inspection documents for the Type B-certified inspections conducted by BCPS in October 2021 ‘+ Reviewed 8CPS's electronic submission to MDOT MVA of the October 2021 certified inspections. All MDOT MVA school bus inspection results are recorded electronically. The type of inspection used to. ‘complete the Baltimore County authorized inspections in the MDOT MVA system are referred to as “Random” inspections. During the inspection process the inspectors have the capability to input and record any defects found and provide a copy of the repair order to the bus owner to address identified defects. All MDOT MVA school bus inspections are certified under penalty of perjury by our inspectors and guided by federal and state regulations. FINDINGS Under COMAR 11.19.04.01, “At any time during regular Administration or school business hours, the Administration may: (1) Audit school vehicle inspection operations and records; and (2) Conduct schoo! vehicle inspections,” MDOT MVA and BCPS worked cooperatively to schedule inspections for each bus in the fleet and to address any issues that arose. MDOT MVA completed inspections except for one bus that was removed from BCPS fleet, and the tags were returned to MDOT MVA. Inspection Results MDOT MVA conducted a total of 815 inspections from November 12, 2021 to January 14, 2022, which exceeds the 806 buses in the Baltimore County fleet because some were inspected twice — the 12-year inspection was required for some during the same period of our independent inspection. Bus #5867 was not inspected because it was retired from the fleet and the tags were returned. The results of the independent inspections are illustrated in Table 1. A total of 145 defects were identified, with 40 considered major and 105 minors. COMAR defines a major defect as “damage or wear which is cause for rejection under COMAR 11.14.02 or 11.14.04, and other damage, wear, ormissing equipment or part which may make the vehicle unfit or unsafe for the transportation of Passengers,” and a minor defect is defined as “damage or wear not specified as a major defect.” Table 1 MDOT MVA Independent inspection Results of BCPS Fleet ont Ser eS Precracrs) Wane eacct fees) 815 40 105, 18 For each bus where a defect was found, VCAs issued a repair order to the owner that identified the repairs needed to bring the vehicle into compliance. A total of 113 repair orders were issued. It is important to note that a repair order for a bus may consist of multiple defects. In accordance with COMAR 11.19.04.04, a mechanically unfit or otherwise unsafe school vehicle, including a school vehicle found to have a major defect that was not immediately corrected during an inspection, shall be removed from service. A minor repair item requires 30 days to be addressed and if not, the bus is removed from service. Exhibit 1 below provides an illustration of the repair items identified during the inspections. As shown, the top five defects identified include fluid leaks (found in 34 buses or 23%), upholstery (16 buses or 11%), heaters and defrosters (11 buses or8%), lift door/lift (11 buses or 8%), and red and amber warning system (10 buses or 7%). BCPS corrected 100% of repairs for major and minor defects identified during ‘the inspections within required timeframes and MOOT MVA returned all 18 tags confiscated. Exhibit Repair Item Defect by Type Repair Item Defect 2% 22 5 15% E tox = 5% bia PUdn tana een eee eg ZPLSPESRELLLEL ESE SSERES seegiseg Teese PZgteesga? SRR SSig geese s* este ESTES ES ESSE REL RS 2 aE go" g" 2888s & Repair ItemExamination of Fuel St ‘The MDOT MVA performed a manual examination of all buses to ensure that the fuel straps were not damaged or deteriorated. The MDOT MVA found that there were 53 buses in which the fuel straps were either replaced (17 buses) or repaired (36 buses). This represents 6% of the overall BCPS bus fleet. The majority of the buses that had the fuel tank strap issue were lift buses used to transport students with disabilities. BCPS reached out to the MDOT MVA on November 10 concerning a reported issue with fuel straps on six buses (4864, 4854, 5056, 4897, 4867 and 4866). Immediately, MDOT MVA sent inspectors to the CPS bus lot to examine all six buses and make a note of the condition of the fuel tank straps for each bus. During the examination of the six buses, VCAs found that all six buses were in the shop for inspection and repair, if required. in November, during the review of inspection records (which are maintained by BCPS and not submitted to MDOT MVA), we found that two of the six buses examined on November 10had a discrepancy between the reported date of repair and the status of the fuel straps on November 10. * According to the BCPS inspection document, the fuel strap on Bus #4897 was certified as being repaired on October 26, however, MDOT MVA inspectors noted during the November 10 inspection that three out of four broken fuel straps were broken but secured by the fuel cage. * Likewise, for Bus # 4854, the BCPS inspection document certified repair on November 4, however, MDOT MVA inspectors found on November 10 that all fuel straps on the tank were broken at the tack weld, being held in by the fuel cage. ‘* MDOT MVAis asking Baltimore County to respond to both these discrepancies. Inspection Documents and Certified Inspections Submitted to MDOT MVA Local school systems are required to submit electronically to MDOT MVA the results of all inspections required under the regulations. All physical school bus inspection and repair documents are maintained by the local school systems and are made available for review by MDOT MVA upon request. BCPS fains a two-part inspection document wherein once a defect is found, one part of the document goes to the central repository and the other to the repair shop to certify completion of repairs — itis then sent back to the central repository for reconciliation. Upon review of the October 2021 Type B inspection documents at the BCPS central repository, the MDOT MVA identified inconsistencies, such as missing signatures, date discrepancies and complete repair needs on some, primarily due to the two- part forms not being carbon copies. The MDOT MVA team verified repairs were made using certifications submitted by BCPS electronically. It is important to note that the discrepancies related to the two-part inspection forms were brought to the attention of BCPS and they modified the document to be a carbon copy and reported retraining all staff on how to complete it appropriately. In accordance with COMAR 11.19.04.05, Type B inspection certifications must be submitted to MDOT MVA within 10 days of inspection completion. In reviewing the Type B certifications for the October 2021 Type B inspections submitted by BCPS, we found that the inspections were submitted on November 16, six days beyond the required timeframe for submission. CONCLUSION MDOT MvA's independent inspection of the BCPS fleet identified 148 defects (39 major and 109 minor), Most of the major defects identified were related to fuel leaks. BCPS technicians addressed all ‘outstanding repair items prior to the completion of the MOOT MVA inspection of the fleet.The inspection of the fuel straps on each bus revealed that 6% were either replaced or repaired. Except for a few vehicles, BCPS inspection documentation did not include the timeframe regarding when fuel straps were repaired or replaced. in reviewing the documentation provided by BCPS for six buses, we Identified discrepancies in the repair records of two buses (114897, #4854) during a random inspection conducted on November 10. Specifically, the documentation was certified that the fuel strap repairs were made prior to November 10, however, on that date VCAs noted that the fuel straps were still broken. Based on the results of the independent inspection, MDOT MVA recommends: 1 BCPS and all local school systems ensure that issues with fuel straps are identified and recorded on all inspection documents and repaired within the specified timeframe under the regulations. MDOT MVA now conducts second inspections on all buses with fuel strap issues identified to verify repairs. BCPS regularly audit inspection and repair documents to ensure they are accurate and complete. BCPS leadership review the discrepancy identified on the repair documents for the two vehicles examined on November 10 to determine why repairs were certified as complete when the repairs had not been made. ‘Awritten response from Baltimore County by April 27, 2022 would be appreciated.‘Tracking Log showing Fuel Tank Strap for BCPS Bus observed during inspection Fuel Tank Strap Repair/Replaced Fiestumber | Repaid | Roplacod Now am x 4880 x | asst 4882 x 2884 x 4955 x 4856 x 4887 x 4858 x 4859 x 4860 x _ 4083 x 064 x 4865, x 866 x 4967 x 4988 x 4969 x 4870 x ast x 4872 x 4874 x 4878 x 879 x 081 x x x x x x x x x 4900 x 4901 x 4902 x 4903 x 4905 xFuel Tank Strap Repair/Replaced (cont.) Flect Number _| Repaired | Replaced New 4908. 4907 a0 ant 4913 x [oe epee 5100 5809 x 5815. x 5837 x 5851 x 5053 x 5854 x 5867 x 5896 x. 5990. x