Janet Lee

Janet Lee
Photo:Janet Lee, injured by a taxi partition.

Friday, June 29, 2012

Steven W. Crowell

USDOT
Inspector General
Calvin L. Scovel III
1200 New Jersey Ave SE
West Bldg, 7th Floor
Washington, DC 20590

Dear Mr. Scovell,
Frank Armstrong (USDOT-MVSCES) and Jeffery Miller (USDOT Chief Counsel) are not in agreement with Randy Reid (USDOT-ODI). Frank was with the USDOT Motor Vehicle Safety Enforcement Compliance Section, Jeffery was the Chief Counsel for the USDOT and Randy is with the USDOT Office of Defect Investigations.
In 1984 Frank wrote letters of warning. No enforcement ensued. I wrote to Mr. Miller and he reinforced my perception that federal law is applicable to interior partition performance in 1985.
I wrote to Randy Reid of the Office of Defect Investigation in 2012. He replied with a letter which states a position that is in complete contradiction with Armstrong and Miller.
In the first letter listed, Armstrong warns manufacturers to comply.
In the second letter below, Armstrong ‘recommends’ ‘consideration of compliance’ to the sanctioning agency.
In the third letter, Armstrong trades off occupant safety for hollow allegations of driver protection from assailants.
In the fourth letter, Miller explains in detail how the law applies to partition performance.
In the fifth letter, Reid explains that no laws apply and that taxis and police cars are exempt.
In the sixth letter, I ask Reid to explain what might have changed since 1984 or 1985.
The attached documents are;
1. 1984 Letter of warning to manufacturers from Armstrong
2. 1984 Letter advising consideration of compliance to taxi regulator from Armstrong
3. 1984 letter to S. Crowell from Armstrong
4. 1985 3 page letter of interpretation from Jeffery Miller
5. May 2012 Letter from Randy Reid
6. May 2012 Letter to Randy Reid
I have no reason to believe that Randy Reid is telling the truth. His delay in replying to my May 7th letter leads me to believe there are no corroborating documents able to be presented. I believe he is lying about so-called exemptions for taxis and emergency vehicles. Please correct me if I am wrong.
I have invested many years trying to bring about enforcement of federal safety laws where they apply to interior partitions used in taxis and police cruisers. I make federal compliant interior partitions for police cars. Nobody else, building partitions, has ever notified the DOT or ever certified compliance.  For every year the USDOT fails to enforce the law, there are many hundreds injured and too many killed by illegal, uncertified, non-complying interior partitions on impact in collisions. Trauma surgeons have done more than one study on the dangers of taxi partitions. The injuries are devastating. The deaths are final.
Can you explain why Randy Reid is telling me I’ve wasted my time trying to enhance safety in taxis and police cars?

Sincerely,

Steve Crowell

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