12- & 15-Passenger Vans Position Statement


The Redwoods Group

September 2008 Position Statement

The NHTSA (National Highway Traffic Safety Administration) recently released another safety advisory on 15-passenger vans. In it they noted that the number of deaths from 15-passenger van rollover crashes has declined steadily since 2001. Do not be misled by gross statistics – 12- and 15-passenger vans are still unsafe. Why should one assume that the primary reason for the decrease in deaths is safer vehicles instead of fewer passenger miles? The efforts of TRG and many others who have campaigned so vigorously against the use of 15-passenger vans has retired many from passenger service and altered the use of many more that now carry fewer passengers at lower speeds. The amount of passenger miles driven were not recorded so there is no real basis for comparison when trying to determine the safety of the vehicles. While it is good that fewer people have died, if, for example, a 15% reduction in miles driven results in a 10% reduction in deaths is that a good result? Fewer people have died but those who still used the vehicles were even more likely to perish.

Manufacturers argue that they have made changes in their 15-passenger vans that make them safer. All major manufacturers (Ford, Dodge, Chevrolet, and GMC) cite driver and front-seat-passenger air bags and stabilizer bars, Ford and Dodge tout rollover sensors, and Dodge even has a crash sensor. Those improvements are good, as are those of aftermarket entities like Safety Van who have strengthened the passenger cage and made other improvements. Such actions have even convinced many insurers to change their position and to accept the newer 15-passenger vans because of their improved technology.

However, in its last advisory the NHTSA did not comment upon technology or the supposedly safer 15-passenger vans. Instead it repeated its list of recommended safety precautions:

  • Keep your passenger load light – preferably fewer than five, but definitely less than 10
  • Check tire pressure frequently – at least weekly; a recent study showed that 74% of all vans surveyed had under-inflated tires
  • Require all occupants to use their seat belts – historically nearly 80% of those killed in 15-passenger vans were not wearing them
  • Position passengers and cargo ahead of the rear axle – that means don’t use the rear seat because it is directly above or slightly behind the rear axle
  • Be mindful of speed and road conditions – rollover risk increases significantly at speeds over 50 mph or on curved roads
  • Only qualified drivers should be used – special training and experience are required to properly operate a 15-passenger van

Those guidelines probably look familiar – they are basically what we have been recommending for years. It is interesting that none of the six precautions are addressed by technology. They all deal with behavior – something that no insurer should assume and certainly cannot guarantee.

Our historical stance has been to accept only a van or bus meeting the following criteria:

The reason for that position is that people sometimes do things that are less than prudent – they skip checking their tires’ pressure to save time; they load a van full of kids instead of taking two vehicles to save money or because of lack of drivers; they don’t enforce the seatbelt rule because it’s too much effort; they drive too fast for their vehicle too keep up with the traffic flow or because they’re late. We know that sooner or later someone we insure will make one of those or a similar error in judgment. If we have required them to use a vehicle that meets the above standards at least the vehicle will be much less likely to overturn and even less likely to crumple if it does. The stronger passenger cage and body panels, the compartmentalization, and use of seatbelts will help the people inside the vehicle escape with less significant injuries. We cannot always affect changes in behavior; we cannot always prevent people from doing those unwise acts that often result in vehicle accidents; but we can reduce the chance that their unwise acts will result in human injury and suffering; we can take steps to protect the innocent passengers who had no part in the misguided decisions or actions.

Ford makes no claims whatsoever regarding the federal standards, nor does Dodge. GMC and Chevrolet state that they have incorporated a steel cage, but do not comment upon its relation to the standards (presumably because their cage is not robust enough to warrant comment). The aftermarket company Safety Vans claims that their roof meets FMVSS 220, but they make no mention of the rest of the passenger compartment cage, no do they address 221 or 222 at all.

For the safety of the kids (and others) being transported as well as for the sake of our own consciences we are retaining our historic stance and will continue to require dual rear wheels and verification that the vehicle meets FMVSS 220, 221, 222, and 225 before agreeing to provide insurance coverage.

  1. FMVSS No. 220 - School Bus Rollover Protection: Specifies performance requirements for school bus rollover protection. This standard increases the structural resistance of school buses in rollover-type accidents.
  2. FMVSS No. 221 - School Bus Body Joint Strength: Specifies requirements for the strength of the body panel joints in school bus bodies. This standard improves the body strength of school buses through increased strength of the joints between panels that comprise the bus body. Applicable to all school buses with a gross vehicle weight rating (GVWR) in excess of 10,000 pounds.
  3. FMVSS No. 222 - School Bus Passenger Seating and Crash Protection: Specifies occupant protection requirements for school bus passenger seating and restraining barriers. This standard provides increased protection to passengers through a series of interior changes known as “compartmentalization” - meaning high-backed, well-padded, and well-constructed seats.
  4. FMVSS No. 225 - Child Restraint Systems; Child Restraint Anchorage Systems: Specifies restraint systems and anchorages for child carriers in motor vehicles.


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