Practical Approach for Improving Safety of School Transport in Thailand [ATRANS 2018]

Thanachart PALIYAWATE
Part-time Lecturer, Faculty of Humanities and Social Sciences
Phranakhon Rajabhat University, Bangkok, Thailand
Telephone 0-81480-0186, Fax. 0-2391-7984
E-mail: poppy_mom@yahoo.com

Abstract
This paper aims at studying problems and obstacles of provision of safe school transport in Thailand and finding practical means to improve safety of school transport in Thailand based on automotive engineering, legal and management approach. This paper is made as a result of qualitative research, mainly from documentary analysis, in-depth interview and a quasi-focus group discussion. The research tackles situation that passengers/pupils are taking risk of being in fatal traffic accidents at all times, as those unlicensed and modified PHVs in various types used for school transport are hazardous by their unsafe physical condition, nature of utilization and drivers’ qualification despite existing safety requirements by law. Based on the safe system approach and international pillars of action for road safety i.e. safe vehicle, road user behavior and road safety management, the research finds unsupportive and impractical mechanism for compliance with all specification and safety standard, effective management of school transport i.e. insufficient technical and financial support, less public attention and lack of appropriate management point. The writer suggests technical support and funding for provision of safe PHVs, stricter enforcement of the DLT regulation on PHVs against substandard structure, component and equipment, overloading, misuse of vehicles and disqualified drivers, setting up a joint committee to assign management point/focal point, to provide financial support from local administrative organizations and to support and expand setting up multi-lateral school transport network.

Keywords: School bus, school transport, safety, private hire vehicles, provision of education

1. Introduction
Children and parents do struggle for access not only into formal education and extensive education but also opportunity of routine safe transport to and from school. In general, nationwide provision of school bus is limited and standardized school bus that ensures safe transport is scarcely available as well as public bus services are poor in respect of area coverage and sufficiency.

A number of parents, commonly, do not have alternative means of safe transport for their children, particularly those who are in shortage households and remote areas. The children have to travel by challenging modes of transport between home in distance and school located in downtown/city. They take school transport by the private hire vehicles (“PHVs”) which are personal car/private-owned or local people-owned vehicles (between 8-12 seats) including van, pickup truck, six-wheeled truck/Songthaew with cushion seats, roof and standard safety equipment.

The Road Safety Group Thailand’s report unveiled the statistics* that, in 2017 at least 30 accidents occurred in relation to school transport by all type of vehicles, the unlicensed PHVs that mostly resulted 7 pupils dead and 386 pupils injured or in average at least one pupil got injury by school transport in each day (Jardbandista, 2018, p.2),
According to Land Transport Department, number of PHVs applied for registration of the vehicle of school transport is very less in comparison to all PHVs being in actual service all over the country. A number of PHVs’ bodies are modified to supply space or load passengers (pupils) as many as possible and are also not improved to comply with safety standard. Those PHVs’ structure and component do not meet safety standard or legal requirement (Jardbandista, 2018, p.2) such as being obsolete, incomplete and unsecured, aside from misuse.

In addition, their drivers sometimes cause nervousness and danger, as they may be unhealthy, ineligible for driving or may leave and lock children in PHVs unknowingly or negligently for long time. The drivers hold different type of motor vehicle license, or otherwise do not hold any driving license.

Besides, nowadays those children/pupils have to ride routinely motorcycle allowed by their parents, although they do not qualify to ride it by age of below 15 and to apply for the motorcycle rider license. They also take a private hire motorcycle for transporting them to and from school under the fact that riding motorcycles is a common mode of transport for Thais everywhere.

The main question is how to improve safety of school transport in Thailand by means of automotive engineering, legal and management, as those unlicensed and modified PHVs in various types and motorcycles used for school transport are hazardous by their unsafe physical condition, nature of utilization and drivers’ factor despite existing safety requirements by law. The passengers/pupils are taking risk of being in fatal traffic accidents at all times.

This paper aims at 1) studying problems and obstacles of provision of safe school transport in Thailand; 2) studying principles, guideline and best practices of Thailand and foreign countries by safety engineering, legal and management approaches; and 3) suggesting practical improvement of the safety of school transport in Thailand.

2. Literature review
Gibson (2015) stated students who get to school in their own vehicles or ride with others. This is considered the most dangerous form of transportation to or from school. In fact, students are 50 times more likely to arrive to school alive if they take the bus than if they drive themselves or ride with friends, according to the American School Bus Council. European Commission (2004) indicated also in a final report on road safety in school transport that travelling by bus or coach appears to be by far the safest mode. Statistics suggest that a child travelling by car is seven times more likely to take part of being involved in a road traffic casualty than a child travelling by bus.

Deng, F. and Kurgan, G. (2012) pointed out many countries establish a regulatory framework to govern bus design, driver qualifications, and motorist behavior around schools and school buses.
Regulations in Australia, Belgium and Germany require school buses to use warning signals to alert traffic when a school bus is about to load or offload school children and traffic must reduce speeds. New Zealand has set a maximum speed limit of 20km/h around school buses, in Japan and the United Kingdom vehicles are required to drive slowly when passing a school bus. Vigorous enforcement of regulations is essential. In the United States, local, state, and school officials work with law enforcement entities to enforce traffic safety laws around buses, bus routes, and in school zones.

Jardbandista, (2018) indicated that public buses provide service only along the route of concession and may not pass the pupils’ home. In addition, the buses take more time with any passengers hop in and get off the buses, being not able to control the time. The situation of public buses has become worse because the operators cannot improve the service quality since they encounter negative result of operation such as less passengers, discontinued transportation, more competitors, more payment for concession fee, loss, etc. The public buses are unlikely to be the main choice of the pupils’ travel to and from the school in many areas and many provinces as well as the number of public buses in provincial tend to diminish.

Wongtienthana (2018) indicated that existing regulations do not facilitate management of safe school bus and bring about loss. Related regulations include:

1) A Ministry of Interior’s ordinance (2004) on finance and audit of local administrative organization (“LAO”) that does not clearly provide an authority of LAO to disburse or commit binding financial obligation in relation to provision of school bus;
2) A Ministry of Education’s ordinance (1993) on supervision of the use of school bus that merely provides a duty of school operators to ensure safety of picking-up and dropping-off pupils but does not determine a duty of management of the travel or school transport;
3) A guideline of Department of Land Transport (“DLT’)’s registrar (2016) on permission to make use of the vehicle utilized for school transport that such vehicle’s specification, equipment and nature of utilization must meet safety requirements for transporting passengers and the school’s certification is required. For obtaining DLT’s permission, the owners’ expenditure is high and not worthy in calculation with income obtained from engaging the school transport.

3. Methodology
This paper is developed by qualitative research, mainly from documentary analysis of secondary data i.e. news, statistics, report, research paper. The research also includes in-depth interview and discussion with primary data i.e. informants who are teachers, students in secondary level and transport operators participating in a seminar namely “Policy on Management of Standard and Safety for School bus” which is equivalent to a focus group discussion together with other participants from concerned government agencies, delegates of international organization, road safety network, civil society and foundation.

The writer collects such information to synthesize and analyze pursuant to 3 objectives especially in order to answer the research’s main question on how is practical ways of improving safety of school transport based on 3 approaches i.e. safety engineering, legal and management. To suggest practical improvement of the safety of school transport in Thailand, the writer considers basic elements of road traffic or transport system which relates to automotive and safety engineering principle i.e. vehicle, driver, road and environment. The safe system approach and international five pillars under Decade of Action for Road Safety 2011-2020 are kept in mind as a main principle and methodology in the study. The study focuses on three of such five pillars are in connection with actions for safe school transport i.e. (1) Road safety management (lead agency strategy, target and funding); (2) Safe vehicles (safety engineering and standard and roadworthiness) and (3) Road user behavior (speed management and qualified/licensed). The research also focuses on domestic and foreign best practices of safety engineering, legal and management approaches

4. Results
The writer finds nature of school transport, problem and obstacle as well as good practice of foreign countries in provision of safe school transport in Thailand as detailed in these following findings: 1) Tackling unsafe PHVs and school transport and regulatory framework; 2) School transport in connection with provision of education and government support and 3) Good practices of the provision of safe school transport in Thailand

4.1 Tackling unsafe PHVs and school transport and regulatory framework
Modes of school transport by road in Thailand mainly comprise with the following 4 groups of vehicles.

The first group, school bus which are a vehicle having yellow/black color, entrance and exit at its body’s side, safety belts in every seats (optional), categorized in registration no. 40 under the Land Transport Act B.E. 2522 (“LTA”), so called “school bus”, owned or managed by the school to transport pupils to and from the school, fulfill safety standard of both vehicle and driver in pursuance with legal requirements.

Although the registered school bus can assure safety of the school transport in equivalent to safety standard of school bus in developed countries, huge amount of money must be spent by the school for its procurement, management, maintenance and qualified driver. The utilization of school bus for other business is limited. As a result, registration of school bus is minimal.

Fig. 1 The public bus registered under LTA

The second group, public buses, as for current public transportation system, are categorized in registration no. 10 or 30 under the Land Transport Act B.E. 2522 (“LTA”). Service of public buses is usually provided along the route or limited to implement concession contractual obligations made with the state agency. It is widely known their service may not cover all areas, not pass or address into sub-soi/alley and where are location of a number of pupils’ home. In addition, the buses take more time with any passengers hop in and get off the buses, being not able to control the time. Thus, pupils may not reach the school on time and their parents may not trust or have reliance on travel by public bus. The situation of public buses in many routes has become worse since they encounter negative result of operation such as less passengers, discontinued transportation, more competitors, more payment for concession fee, loss, etc. Public buses are unlikely to be main choice of the pupils’ travel to and from the school and the number of public buses in provincial tend to diminish (Jardbandista, 2018, p.1).

The third group, private hire vehicles (PHVs) which are personal car/private-owned or local people-owned vehicle (between 8-12 seats) such as pickup truck (as appeared in Fig. 3 herein), six-wheeled truck/Songthaew with cushion seats, roof, various component and equipment, and van complied with safety standard for transporting passengers subject to specification, nature of utilization and driver’s qualification, acquiring the school’s certification and the DLT inspection for registration and specific license to make use of the vehicle utilized for school transport (short-term, by semester) issued under the Motor Vehicle Act B.E. 2522.

The DLT issued a new regulation to ensure PHVs and the drivers meeting safety standard for specific PHVs (for school transport) license and then issued a revised guideline of Department of Land Transport (“DLT’)’s registrar (2016) on permission of making use of the vehicle utilized for school transport for better implementation of safety requirements. (Remark: group of PHVs for non-school transport are connection with taxi services of Uber and Grab)

Such DLT’s new regulation issued in response to the PHVs’ misuse and unsafe physical conditions impair security and safety of cars and passengers i.e. obsoleteness, substandard structure, component and equipment such as fastening loosely passenger seats on vehicle floor, installing many extra seats to supply space or loaded pupils as many as possible, sticking opaque mirror film, none of locked door or blockage-metal bar at the door-end (pickup truck), none of extinguisher and hammer to break mirror etc.

In an effective management, the schools prefer to contract with the vehicles operators (private sector) to provide school transport by PHVs, as its cost and expenditure are cheaper and risk is slighter. However, this school arrangement of school transport service, parents have to pay for it for instance international schools providing air-conditioned buses between home and school independently checked at regular intervals, trained bus drivers and monitors.

However, for obtaining DLT’s permission or license, the PHVs owners/operators’ cost and expenditure is high and not worthy in calculation with income obtained from engaging the school transport. As for the fare is increased higher, parents might not able to pay in long term.

Accordingly, a part of parents themselves have to transport their children by personal car and motorcycle. But such transport also brings about increasing expenditure and loss of time and resources of transport. Meanwhile, a lot of parents turn to find somebody like neighbor or people in community or transport operator who is able to drive personal car and motorcycle to transport their children and the amount of fare, route and time is flexible; therefore, the fourth group of vehicle takes place to be another mode of the school transport.


Fig. 2 Many unlicensed and modified private hire vehicles (PHVs) are overloaded by pupils during school transport.

The fourth group, unlicensed PHVs which are personal car/private-owned or local people-owned vehicle utilized for transporting pupils to and from the school, include several types of agricultural motor vehicle, truck, van, motorcycle, six-wheeled truck, but neither meets safety standard for transporting passengers in terms of specification, equipment and nature of utilization. The vehicle owners/operators normally undertake a school transport and directly charges fare individuals from parents on voluntary basis without the school’s involvement. Its drivers hold different type of motor vehicle license (Pu-ar-ree, 2017).

The DLT information unveiled that as of July 2016 total 22,861 registered PHVs for school transport, breakdown into 15,781 vans, 3,175 six-wheeled truck, 2,667 pickup truck and 2,755 misused vehicles (the unlicensed PHVs) (SMBUYER Magazine, n.d. [Online]). In fact, huge number of the unlicensed PHVs are out of record due to they have not yet been unfounded and not arrested.

A part of all modified PHVs having substandard structure, component and equipment deny and neglect improvement and application for license of school transport under such DLT’s new regulation.

The DLT’s regulations set specifications for the vehicles in which school bus (PHVs) operators have to invest more. This is not practical for those providing informal bus services in rural areas. As a result, the regulations cannot bring about quality services and the operators prefer not to register their vehicles. Meanwhile, general road safety standards have also not been properly enforced. As such, the operation of informal buses (unregistered and unlicensed PHVs) has become a popular but dangerous choice for students (Thongphat, 2018).

Moreover, unlicensed PHVs may cause danger and fatal risk due to misbehaviors of the PHVs’ drivers and misbehaviors of the other party passengers such as hi-speed driving, impetuous driving, aside from loading excessive passengers/pupils and disqualified.

With reference to the statistics* reported by Road Safety Group Thailand in 2017, at least 30 accidents occurred in relation to school transport by all type of vehicles, the unlicensed PHVs that mostly resulted 7 pupils dead and 386 pupils injured or in average at least one pupil got injury by school transport in each day (Jardbandista, 2018, p.2), as appeared in statistics during 2015-2017 in table 1 and table 2 below. (*derived from mere collection of news and report through media and networking organizations, as the official statistics was not available and found)

Table 1 Number of Accidents of School Transport (by year and type of private hire vehicle/PHVs)

Table 2 Number of Deceased and Injured by School Transport
(D =Deceased people and I = Injured people)

Source: Road Safety Group Thailand by Jardbandista, T., 2018

Among the aforesaid 4 groups of vehicles for school transport, big number of accident and loss having occurred in relation to the unlicensed PHVs are the most (Jinwong, 2015 and Jardbandista, 2018, p.2). From the statistics by year and type of private hire vehicle/PHVs appeared in Table 1 and Table 2, the pickup truck seems to be the most dangerous vehicle of school transport.

According to the American School Bus Council the most dangerous form of transportation to and from school is students getting in their own vehicles or ride with others which are 50 times more likely to arrive to school alive if they take the bus than if they drive themselves or ride with friends (Gibson, 2015 [Online]) and the school transport that travelling by bus or coach appears to be by far the safest mode, with reference to final report on road safety (European Commission, 2004, p.2).

In another mode of school transport, nationwide, as mentioned above, a number of parents allow their children to ride motorcycle to and from school, although they do not qualify to ride it by age of below 15 and immaturity and to apply for the motorcycle rider license. According to Ramathibodi Hospital’s Child Safety Promotion and Injury Prevention Centre (CSIP), approximate 15,800 children annually get into motorcycle-related accidents that result around 700 deceased and most of them getting injury. This is another issue of grave safety concern.

The unlicensed PHVs are advantageous due to their lower cost, affordable fare/payment, flexible route and time, its utilization for other income-earning activities or businesses out of time of school transport, more convenient from and to individuals’ home than public buses and school bus for school transport. Safety of such PHVs is not prioritized or concerned by many parents. With reference to a survey of PHVs users/pupils in 6 regions of Thailand made by the road safety network strengthening for safe public vehicles project in 2016, major reason of selecting PHVs for school transport is convenience and rapidness (56%), safety (19%), none of other choice (14%).

A number of accident and loss having occurred in relation to the unlicensed PHVs seems to be the most since drivers’ disqualification, substandard structure, component and equipment with reference to automotive engineering specifications and safety standard, as stipulated in the DLT regulation. Likewise, many countries establish a regulatory framework to govern bus design, driver qualifications, and motorist behavior around schools and school buses (Deng, F. and Kurgan, G., 2012 [Online]). However, for obtaining DLT’s license for school transport and compliance with all safety standard, this is not practical since the PHVs owners/operators’ cost and expenditure is high and not worthy in engaging the school transport as well as those PHVs are improperly utilized for other income-earning or businesses at the same time. As a result, the regulations cannot bring about quality services and the operators prefer not to register their vehicles. Meanwhile, general road safety standards have also not been properly enforced. As such, the unlicensed PHVs) has become a popular but dangerous choice for students (Thongphat, 2018).

It is also noted that insurance system may not fully help protection and remedy pupils/passengers (in case of death, loss of organs or permanent disability) because a number of unlicensed PHVs are old, modified and misused vehicles holding only mandatory insurance policy, not voluntary insurance policy that provides additional passenger coverage.

4.2 School transport in connection with provision of education and government support
In consideration of problem and obstacle of provision of safe school transport in Thailand, education system of Thailand is a main issue. The mandatory education to children from pre-school/kindergarten to secondary level 3 (grade 9) is provided all over the country. Local administrative organizations and private sector are allowed to participate in provision of education by decentralization. In virtue of law and policy, access into education and educational extensive opportunity are definitely set out to create an educational equality. However, provision of education and its access usually cover free study, public service and welfare in educational place/institution such as lunch, uniform, educational materials etc. but it generally excludes provision of school transport.

Provision of safe school transport in general to pupils/students which is, actually, a support for regular travel for class attendance or a facilitation of addressing education is interpreted by concerned government agencies that it is out of mission or extent of the provision of education. Wongtienthana (2018) indicated that the local administrative organization’s duty of provision of education covers curriculum, educational personnel, surroundings in school compound, academic excellence, various equipment but excludes provision of school transport. Nevertheless, such school transport may be provided for particular groups i.e. the small children development center, disadvantaged or disabled children on social services basis (State Audit Office of the Kingdom of Thailand, 2017).

In Thailand, such travel needs safe school transport supported by government sector in particular a number of schools located in rural or remote area where the government budget has allocated fewer and limited manner due to less and decreasing number of pupils, less potential and attention by any way. These schools face difficulties to provide standard and safe school bus or safe school transport by their own.

On the other hand, the government budget and subsidy are allocated more to large-sized schools located in urban or central city where a number of pupils choose to enroll since they are attractive among pupils who can get easier access into sources of knowledge, information technology, intensive tuition, educational resources etc. This regard can be questioned whether it is inequality or not, in respect of educational access and opportunity (Jardbandista, 2018, p.2). For international schools and schools having bi-lingual or other special programs, parents

afford tuition fee, materials, expenses and extra services including contracting standard school.
In principle, the regular travel to the school compound for attending class is still noteworthy for children’s education and development, although nowadays access into learning and education has expanded to education via online, open source, distance education, informal education. In respect of Convention on the Rights of the Child, to recognize the right of the child to education, measures to encourage regular attendance at schools and the reduction of drop-out rates shall be taken (Article 28e). In mind of the best interests of the child services and facilities responsible for the care or protection of children shall conform to the standards..…particularly in the areas of safety (Article 3) (Thanachart, 2018).

In UK, such facilitation of addressing education and support for regular travel to and from school are some objectives of the provision of school transport and as a part of the provision of education. As a result of decentralization, with annual budget and other financial support, the local administrative authorities implement education missions as the local education authorities/LEAs for instance under Education Act 1996 the Council as an education authority has a duty to promote high standards of education and fair access to education and another duty on school transport i.e. to make provision for suitable home to school travel arrangements for eligible children of compulsory school age (5-16) to facilitate attendance at a relevant educational establishment at free of charge (s508B), to promote sustainable modes of travel to assess general school travel needs (s508A) (Surrey County Council, 2017, pp.1-3). The LEAs provide free transport for all pupils of compulsory school age (5-16) if their nearest suitable school is beyond 2 miles (below the age of 8) and beyond 3 miles (between 8-16), making transport arrangements for all children who cannot reasonably be expected to walk to school because of their mobility problems or because of associated health and safety issues related to their special educational needs (SEN) or disability (Department for Education of UK. (2014).

4.3 Good practices of the provision of safe school transport in Thailand
Good practices of provision and improvement of safe school transport can be highlighted, based on the safe system approach, as follows:
Safe vehicles

1) Technical support to develop safe vehicle for school transport: In June 2018 MTEC, Road Safety Group Thailand and Thai Health Promotion Foundation collectively handed over “a prototype of school pickup truck” to Baan Ta Reung School, Chantaburi province, as appeared in Fig.2. The pickup truck is equipped with strong and safe-structured metal roof, seats, floor and various safety component and equipment i.e. double locked- rear door with alarm at the time of opening, staircase, vivid amber color light signal that clamped with car body by strong device in order to prevent removal and protect passenger in the event of accident. Such prototype will be expectedly used for testing and further manufacturing standard and economical roof truss, component and equipment from domestic raw materials. The output would be installed on the pickup truck by entrepreneurs of car modification shop for transporting the pupils in line with Thai local people’s lifestyle.

Fig. 3 The prototype of school pickup truck, as a modified private hire vehicle (PHVs), not exceeding 12 seats)

Road user behavior and road safety management
2) Bang Pla Mar model: an initiation of an administrative teacher Bussakorn of Bang Pla Mar school, Supanburi province in 2008 becoming a school bus model by “provision of safe private hire vehicle/PHVs. The initiation came from circumstances of pupils’ assembly for improper activities after school and pupils’ unsafe transport to and from school as well as conflict between concessionary route buses and modified private hire vehicle of local people. An agreement on sharing-school transport among them was reached, encouraging formation of a school transport club, an issuance of internal regulation and sanction in place and recruitment of owners/drivers to be members and the club’s committee member. The school coordinated with Provincial Transport Office to issue a certificate for the club’s members and with the club to develop equipment and accessories ensuring pupil’s safety and to set up a fund for maintenance of vehicles. However, this Bang Pla Mar management was changed by teacher Bussakorn official transfer to new position in the other school in 2014 and lasted in long term due to its merely ad hoc and informal setting in local area with less involvement of all concerned government agencies and senior management level of Ministry of Education, etc.
3) Development of the school bus/PHVs network and effective management in various districts in Chantaburi province: such network includes (1) school and teacher facilitating school transport; (2) school bus/PHVs club; (3) pupils taking service of school transport and their parents; (4) capacity building on road user/drivers’ behavior; (5) awareness raising on road safety and (6) land transport official and police official. Thus, safety measures and management process of school bus/PHVs has been set up, in connection with the club’s management rules and recommended management point/focal point e.g. school.
4) The Association of Confederation of Consumer Organization of Thailand and the Foundation for Consumers organize several activities such as “Prototype and Cooperation for Safe School Bus” seminar held in March 2018, a survey of PHVs users/pupils in 6 regions of Thailand made by the road safety network strengthening for safe public vehicles project in 2016 in order to improve safety of school transport.

5. Conclusion and suggestions
Safety of the PHVs for school transport is not prioritized by a number of parents and pupils, according to survey’s result in 2016. Safer modes of school transport i.e. school bus, public buses personal/private car, licensed PHVs, as a whole, are not available or otherwise not favorite. In taking consideration of number of road accidents and loss, unsafe school transport in particular the unlicensed PHVs (esp. pickup truck) which is obsolete,modified, misused and substandard is very concern of their unsafe physical condition (structure, component and equipment ), nature of utilization and drivers’ qualification under the DLT regulation on PHVs covering safety engineering specification (vehicle), qualification (drivers) and management that linked to the safe system approach. The research finds unsupportive and impractical mechanism for compliance with all specification and safety standard, effective management of school transport i.e. insufficient technical and financial support, less public attention and lack of appropriate management point. The safety concern extends to pupils routinely riding motorcycle as a mode of school transport.

With regard to management issue, provision of school transport to pupils/students is actually a support for regular travel for class attendance or a facilitation of addressing education in pursuance with protecting a right of the child to education, as nowadays attending class at school compound is still noteworthy for children’s education and development. But it is interpreted by concerned government agencies of Thailand that it is out of mission of provision of education. As a result, Standardized school bus/PHVs that ensures safe transport is scarcely available and government financial support or funding has been provided fewer and limited manner for safe school transport or even for provision of school buses especially schools located in rural and remote areas.

This writer realizes that the aforesaid local good practices, principles and lessons learnt from global experiences are useful to be guidance and practical ways to provide and improve safety of the school transport in Thailand. To increase compliance with engineering specification and safety standard and to have effective management, suggestions are as follows:

Fig. 4 model of each type of PHVs for school transport in the DLT regulation on PHVs

Safe vehicles and road user behavior
1) To find technical support and funding so as to develop safe PHVs for school transport in compliance with engineering specifications, safety standard and model of each type of vehicle (pickup truck, van and 6 wheeled-truck) in the DLT regulation on PHVs (as appeared in Fig.4 herein) in cooperation with the DLT, technical agencies, engineering academic institutions and funders;
2) The DLT as a lead agency, to take actions against substandard structure, component and equipment, overloading, misuse of vehicles and disqualified drivers by stricter enforcement of the DLT regulation on PHVs;

Road safety management
3) To set up a joint committee among ministries and concerned agencies such as Ministry of Education, Department of Local Administration, Department of Land Transport and/or Ministry of Industry to assign management point/focal point to find practical measure for improving safety of school transport i.e. technical support, budget or funding;
4) To have various local administrative organizations supported budget or financial contribution to provide more safe and standardized vehicles transport pupils to and from school;
5) To support and expand setting up multi-lateral school transport network among (1) school and teacher facilitate school transport; (2) school bus/PHVs club; (3) pupils taking service of school transport and their parents and (4) land transport official and police official in local area for developing safe and standardized PHVs and for better management

6. Acknowledgement
The writer is hereby very thankful to Legal Development Program (LDP) under Asia Injury Prevention Foundation supported by WHO and the Bloomberg Initiative for Global Road Safety (BIGRS), AIP country manager, LDP team members and staff, Road Safety Group Thailand’s members participating in the safety of school bus research and activities, participants in the forum on “Policy on Management of Standard and Safety for School bus held on 21 May 2018 at Sukosol Hotel, Bangkok.

7. References
[1] Deng, F. and Kurgan, G. (2012). On the Road to Safe School Transport in China. World Bank paper. Retrieved from http://www.worldbank.org/en/topic/transport/publication/on-the-road-to-safe-school-transport-in-china
[2] Department for Education of UK. (2014). Home to school travel and transport: Statutory guidance for local authorities. Reference: DFE-00501-2014, Department for Education, p. 10.
[3] European Commission. (2004). Road safety in school transport study – Final report, Brussels: TIS, p. 2.
[4] Gibson. (2015, March 4). School transportation: how to keep students safe. Blog. [Online]. Retrieved from https://www.gibsonins.com/blog/school-transportation-how-to-keep-students-safe
[5] Jardbandist, T. (2018). Regulating School Buses – Are we heading in the right direction?. LDP Thailand, pp.1-3. Retrieved from https://bit.ly/2IgIarI
[6] Jinwong, T. (2015, 13 August). Accidents of unlicensed private hire vehicles causing persistent loss has still had none of solution. Isranews. Retrieved from https://www.isranews.org/isranews/40559-aa_405599870.html
[7] Paliyawate, T. (2018). A Study on the Provision of Safe School Transport in Foreign Countries. LDP Thailand. Retrieved fromhttps://bit.ly/2JDoQ48
[8] Pu-ar-ree, C. (2017). Safety Standard of School Bus in Pilot area of Chantaburi Province, Research Paper. Road Safety Group Thailand
[9] SMBUYER Magazine. (n.d.). How do pupils think about school bus?, Vol.198, Accessed on 30 May 2018. Retrieved from https://www.chaladsue.com/article/2642
[10] State Audit Office of the Kingdom of Thailand. (2017, 20 April). Report on verifying the operation of contract for school bus service for schools under Pathumthani Provincial Administrative Organization, p. Kor and Kor and Official Letter of Department of Local Administration No. Mor.Tor. 080.2/1736 dated 8 February 2016 on seeking for consultation of entering into an agreement on financial support for management of school buses
[11] Surrey County Council. (2017). Surrey Education in Partnership: Local authority education duties 2017. Version 2. Surrey: Surrey County Council, pp. 1-3.
[12] Thongphat, N. (2018, 10 May). Safer school buses need not be pricey.Bangkok Post. Retrieved from
https://search.bangkokpost.com/search/result?category=all&q=Safer+school+buses+need+not+be+pricey
[13] Wongtienthana, T. (2018). Safe and standardized school buses are an educational necessity. LDP Thailand. Retrieved from https://bit.ly/2IZ6NIZ

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