We refer to the Malaysiakini report Another express bus tragedy, 10 killed .

We at the Malaysian Association of Standards Users (Standards Users) call on all the agencies related to public transport and road safety to Immediately make compliance to the Safety, Health and the Environment Code of Practice and UNECE regulations R66, R80 and R36 mandatory.

We believe that we represent all citizens in calling for immediate and effective actions to be taken to prevent loss of lives due to express bus accidents which are becoming an annual calamity on Malaysian roads. If all the actions trumpeted after the Bukit Gantang tragedy in 2007 were seriously implemented, monitored, evaluated and continuously improved, chances of this latest accident happening could have been minimised if not totally avoided.

The Sani express bus which rammed the divider and resulted in 10 lives being lost was a double decker bus operating from Klang to Kangar during the wee hours. The Road Safety Department has immediately recommended to the Commercial Vehicle Licensing Board (CVLB, which falls under the Prime Minister’s Department) that the entire fleet of buses from the company involved in the bus accident be suspended, pending an investigation.

Now, referring to the recent study by Malaysian Institute Of Road Safety Research (Miros) on the banning of public express buses from operating during the wee-hours, Miros concluded that the long-term solutions for the problem was not a total ban on wee hours operations but rather all of the following:

all bus operators have to fully comply with the Safety, Health and the Environment Code of Practice (SHE COP) for transportation sector which was developed in 2007 with the approval of the Malaysian government as a result of a series of high profile accidents involving commercial vehicles).

All buses have to comply with good safety standards such as the UNECE R66, R80 and R36 to be on the road.

Strengthen and have full enforcement of the log book system.

Complete compliance with driving and working hour requirements as stated in the SHE COP (MCP 1/2007).

Develop and enforce complementary requirements to the SHE COP in scheduling night shifts for drivers.

Another point (from the Miros study above) that requires critical attention is that drivers will have very little time for training and re-training and personal development when they chase for additional trips for increased income with increased trips thus compromising on the safety of passengers due to fatigue. The current perks and working conditions offered to public express bus drivers will not attract quality candidates.

It is reported that the CVLB has no plans to temporarily suspend the operations of the Sani express bus service. Having pointed out the issues above, it is dawning upon us that the operation of the public express bus system has failed at almost all levels to provide safe and comfortable service to its passengers.

At the top level, there is no political will to enforce full compliance with SHE COP. We cannot depend on self-regulation when every year since 2006, we have had high-profile accidents causing loss of lives. After the unprecedented Bukit Gantang tragedy, there were many ‘recommendations’ put forth by ministers and agencies related to road transportation and safety.

How far have all these ‘recommendations’ been implemented? How many audits has the transport ministry carried out? How can interested stakeholders such as civil society have access to such audit reports?

It appears that policies change with a change in a ministry’s leadership. How will stakeholders who are directly affected by the policies and recommendations above know the status of their implementation?

How much and to what stage have the recommendations put forth by Miros or the Road Safety Department been implemented by the more than 10 agencies managing various aspects of public transport?

We were informed that all these agencies will be consolidated under a single agency next year, 2010. What are the roles and powers of this agency? What are its key deliverables and how will it proactively take substandard vehicles and /or their parts off the market? How will it make sure that express bus operators are not burdened by unnecessary bureaucracy and make compliance to SHE COP mandatory and monitor this compliance?

On what grounds can the CLVB turn down the Road Safety Department’s recommendations? If not on grounds of safety but on cost and difficulty in implementation, then it seems there is no will to solve road accidents. Are the implementation issues like ‘hot potatoes’ which no agency wants to claim ownership to solve?

We wish to find out if a study has been carried out by Miros to assess the suitability of double deck (DD) busses to be used on Malaysian roads with the current level of drivers’ competency and traffic conditions. We have read that DD busses are designed for short city routes and not for long distances.

We wish to remind all relevant agencies related to public transportation and road safety that policy-makers have frequently encouraged the public to use public transport to reduce road accidents.

With such lack of accountability, transparency and good governance, we believe most of us will take our chances with our own private vehicles. Let the statistics speak for themselves - there was an increase in cars from close to 6.5 million in 2005 to close to eight million in 2008 (source: Road Transport Department).

We hope that the official response towards this latest tragedy and to those before this will not remain as promises unfulfilled to those who suffered the loss of loved ones. High-income nations enjoy a high standard of safety with regards to public transportation.

Many of the infrastructure and safety management system improvements in developed countries were lessons learnt from accidents in their own countries or from others. But the most commendable is that in most developed countries, the lessons learnt are immediately implemented and monitored and continuously improved.

The writer is attached to the Malaysian Association of Standards Users.