Summary

In the aftermath of a transit bus crash, deposition questions are essential for uncovering details pertinent to analysis. Thes shed light on driver responsibility, training adequacy, and potential oversights that may have contributed to the incident.

Since driver errors account for a high percentage of bus crashes, these depositions are critical to understanding factors that influenced the driver’s performance.

Key areas to explore include:

• the driver’s training and certification history,
• weekly working hours leading up to the crash,
• and specific duties associated with their assigned route.

Gathering information on the driver’s professional background and experience, as well as the nature of their workload, helps build a comprehensive picture as to whether the driver was adequately prepared and alert.

Additionally, questions surrounding the specific transit route, equipment used, and unique route challenges are essential for pinpointing situational factors that may have affected the driver’s response.

By asking detailed, targeted questions, attorneys can assess whether training gaps, fatigue, or other preventable circumstances contributed to the crash.

These questions potentially clarify liability and inform policy changes to prevent future collisions.

Click to see duty of care for bus drivers.

Deposition Questions to Ask Transit Bus Drivers

Training & Driver History

## Do you work for the transit authority, or another company that outsources driver to the transit authority?

Some larger transit authorities have outsourced their hiring and personnel management to third party companies.

## When did you start working for the transit authority?

Is the driver new, or do they have a great deal of experience as a transit bus driver with that company?

## How many years have you worked as a bus driver?

Has the driver worked all her time with one company, or has she moved around from company to company? Most city bus companies are unionized with benefits. This working environment provides incentives for drivers to stay long-term.

## What training did you undergo when you started working for the transit authority?

What courses has the driver undergone?

Are the courses pre-employment, new hire, professional development, or remedial training?

## Have you undergone any professional development training such as defensive driving, air brakes, or customer service?

List the courses and the duration of those courses. If the courses were administered by the transit company, there will be certifications of completion in the driver’s personnel file.

## Have you undergone any remedial training?

In other words, have you had a crash or been discplined for poor performance on the job?

## Did you have your bus license before you were hired by the transit authority?

Some transit authorities will train their own drivers. The ideology is that the company can train the person to drive the bus, but they can’t train for customer service.

## What driving school did you attend?

If it is a reputable driving school, there will be rankings and customer reviews online. This question is only relevant if it’s been less than three years since the driver attended driving school.

## How long was the course at the driving school?

The duration of the course.

How long did they attend the driving school and the frequency.

Some driving programs may be two weeks, but they attended every day. Others may be six months, but the student attended only once a week.

## What topics were covered at the driving school?

Courses will include but are not limited to:

• learner license preparation,
• on-road driver training,
• pre-trip inspection,
• defensive driving,
• air brakes,
• and passenger safety.

## What type of equipment did you learn on at the driving school?

Most driving schools use vintage school buses for their training.

## Have you done any online driver training?

Include a list of the courses and request their certificates. Companies such as Smart Drive Test offer online driver education courses.

## Have you taken an air brake course?

If they are operating vehicles fitted with air brakes, they MUST have taken and passed an air brake course for their state or province. The air brake endorsement will be listed on their driver’s license.

## Where did you take your air brake course? (truck driving school, transit authority, or online driver training)

How did they earn earn their air brake endorsement?

Who taught the air brake course?

Number of Hours Worked Per Week

These deposition questions move to discover driver fatigue.

## What is  your work schedule most weeks?

Most transit bus drivers work 40 hours per week.

The less time they have with the commision, the less drivers have a set schedule.

Most newer drivers will work Thursday to Monday with Tuesday and Wednesday as their off-days.

Also, they will work charters and numerous split-shifts during the week.

## Did you work any overtime leading up to the crash/incident?

The driver may have taken extra shifts which led to fatigue and misjudgement during the incident.

## Were you working a split shift?

During morning and afternoon rush-hours, transit authorities will put more buses (riders) on the busy routes.

Junior drivers will work split-shifts, which entails them working 4 hours in the morning, a period of time off-duty, and another 4 more work hours in the late-afternoon.

## When and where did you take your break during that shift?

Where did they take their break and for what duration?

Driver’s Overall Health

These deposition questions move to discover driver fitness.

## When was the last time you had a medical done to validate your CDL license?

A copy of the driver’s medical will be in their personnel file.

For most, a DOT (Department of Transport) medical examination is required at 5 year intervals.

## Do you sleep well?

If driver isn’t sleeping well, she may be suffering from sleep apnea.

## Are you on any medication?

Does this medication affect the driver’s ability to function?

Does the medication warn that you shouldn’t operate heavy machinery or driver?

Does the medication affect you negatively in any way?

## Have you had any medical conditions that have affected your driving?

Has the driver had major surgery, a heart attack, or stroke?

## Is the driver diabetic?

Does the driver take regular injections or medication to control diabetis or other medical condition?

Transit Route Being Driven

Was Driver Familiar With Route

## How long had you been on this particular route?

Did their inexperience with the route cause them to make a mistake?

## Were you trained on this route?

Did they go with a mentor to learn about the route?

How long were they with the mentor?

## Is there a school (high school, college, university) on this route?

When school is in session, this can cause the bus to be full.

During the summer months, Christmas and winter breaks, the buses are generally empty. When the bus is empty and still running the route, this can some times cause the driver to run ahead of schedule. When drivers run ahead of schedule this can cause pedestrians to “run for the bus” if it leaves a stop early.

Were the passengers a distraction to the driver?

## How far is the school from the site of the crash?

Some times, the school’s schedule will cause the bus to run behind or ahead of schedule.

Was running ahead or behind the bus’ schedule a factor?

## How many passengers were on the bus at the time of the crash?

## Where there any wheelchairs or mobility devices on the bus at the time of the crash?

If there are a number of wheelchair or mobility devices on the bus, this can cause the driver to run behind schedule. Lowering the bus at the stop, deploying the ramp, and/or restraining the wheelchair on the bus all take time.

## At the time of the crash, were you ahead or behind schedule?

Behind schedule

## What happened to put you behind schedule?

There are a number of factors that can cause a driver to run behind schedule:

• route has changed and the times haven’t been updated making it impossible to keep schedule

• it’s the busy time of day (students going to or getting out of school) and the bus is full or the driver is stopping at every stop

• there was a crash along the route

• there was construction along the route

Ahead of schedule

## Were you running ahead of schedule?

A driver running ahead of schedule often happens when the driver is at the end of shift.

In other words, it’s the last run of their shift.

The transit authority will have GPS and other tracking software that will indicate if the bus was being operated behind, on, or ahead of schedule.

Request that information from the transit authority.

It’s summer time, for example, and school is out-of-session which may cause the driver to run one or two minutes ahead of schedule.

In the event of a transit bus being operated ahead of schedule, this will cause passengers to miss the bus.

Also, it will cause some passengers to chase after the bus.

During morning and afternoon rush-hours, transit authorities will put more buses (riders) on the busy routes. Junior drivers will work split-shifts, which entails them working 4 hours in the morning, a period of time off-duty, and another 4 more work hours in the late-afternoon.

Compliance

Required duties and requisite paperwork

## Copy of Driver’s License?

Ensure the driver has the correct class of license to operate the vehicle they were driving.

Also, if the vehicle is fitted with air brakes, does the driver have an edorsement to operate a vehicle fitted with air brakes.

Is the license valid?

## A copy of the driver’s abstract?

A driver’s abstract will show any traffic violations that the driver has accumulated, both in a commercial and private vehicle. The company should have a copy of this in the driver’s personnel file. Or you can request it directly from the driver.

## Pre-trip inspection sheets for that vehicle for previous 60 days?

Pre-trip inspections sheets are required to be filled out by drivers a minimum of once every 24 hours for the vehicle they are operating. In some instances, only the first driver of the day fills out the required paperwork.

## Request maintenance records for vehicle for previous 6 months.

These records will show if there are any problems with the vehicle.

Also, these will indicate if the vehicle is being regularly checked and maintained.

Some vehicles have recurring problems that drivers will note on the daily pre-trip inspection sheet.

If the same driver is filling out numerous reports for repairs, it can indicate that the driver is problematic.

If different drivers are filling out requests for repairs, it may indicate that the company lacks the initiative or the resources to fix the vehicle.

## Request a copy of the transit authorities’ driver’s manual.

What is the company’s policy and training on defensive driving, fatigue, and customer service to name but a few of the topics that a professional transit driver is to know.

Owing to the potential size of the driver’s manual, some authorities may only send you the sections relevant to the crash, or sections you request.

Equipment & Route Notifications

These factors may be caused by driver inexperience, poor training, or these circustances simply overwhelmed the driver causing distraction

## Was the bus you were driving fitted with air brakes?

Are you familiar with the operation of air brake vehicles?

Was there any extra steps you had to take with the brakes to open and close the doors at stops?

On some older model buses, the brake pedal had to be applied and released after to closing the doors to release the brakes and move.

## Was the bus you were driving a low-floor bus capable of taking wheelchairs and other mobility devices?

Almost all transit buses are low-floor buses.

Were there passengers with mobility devices on the bus that may have caused the schedule to be affected?

## Was there construction along the route you were driving?

How did the construction affect the bus’ route?

Did the crash occur in the construction?

Were lanes closed owing to the construction?

Was there a detour?

How did the construction affect the road surface? Was it gravel? Was it corrigated pavement? Was there a bump?

How did the construction affect the flow of traffic?

## Were there other issues that had been identified by the company for this route?

Discover how this information was conveyed to the driver:

• text message,
• company internet portal,
• or bulletin in the drivers’ room.

## Was the bus you were operating fitted with blind spot detectors, backup cameras, proximity sensors or other observation technology?

Automotive technology at times can negatively affect drivers’ skills.

Was the bus fitted with proximity sensors, for example, that caused the driver to NOT shoulder check.