OOSC, Part II, Item 14. Emergency Exits (Buses)

The revised April 1, 2007 North american Standard Out-of-Service Criteria (OOSC) made a sufficient change for the roadside inspector in Part II, Item 14. Emergency Exits (Buses). The previous OOSC placed a bus out-of-service when the emergency exits were missing, inoperative, or obstructed when passengers were on board. The revised OOSC removed the passenger requirement and added the following "NOTE: Carrier has the option to remove the bus from the inspection site to repair or replace the vehicle at their discretion." This now raises several questions for the roadside inspector. Should the violation be recorded as an OOS violation? If so, and the vehicle is stopped by another inspector, action may be taken as operating a vehicle after having been placed out-of-service. Non out-of-service violations must be corrected before the vehicle is re-dispatched. If a roadside inspector stops a bus with passengers for another violation and notes the exits are in an OOS condition, the carrier has the option to move the bus (with passengers) to repair or replace. How far may the carrier take the bus?

Knowingly allow a bus to operate with passengers for an unknown distance could become a serious problem if the bus is involved in an accident and the exits are required for a safe exit. If discretion is the issue, discretion should be given to the inspector and not the carrier.

Request the Passenger Carrier Committee (PCC) to revisit the issue, reinstate the passenger requirement and give the discretion to the inspector as stated in the OOSC Part II Policy Statement (Paragraph 3).