Accident Investigations and Safety Studies In Pennsylvania
75 Pa.C.S. 3754: As is evident on the face of the statute, section 3754 is composed of two subsections, both of which apply specifically to "in-depth accident investigations and safety studies".
Clearly, both subsections address the same subject matter. Under provisions of the Statutory Construction Act of 1932, when two such "statutes or parts of statutes . . . relate to the same persons or things or to the same class of persons or things," they are in pari materia and must be construed together as a single provision. See 1 Pa.C.S. 1932(a), (b). See also Commonwealth v. Adamo, 431 Pa. Super. 529, 637 A.2d 302, 305 (Pa. Super. 1994).
3754. Accident prevention investigations: General rule.The department, in association with the Pennsylvania State Police, may conduct in-depth accident investigations and safety studies of the human, vehicle and environmental aspects of traffic accidents for the purpose of determining the causes of traffic accidents and the improvements which may help prevent similar types of accidents or increase the overall safety of roadways and bridges.
In view of the pronounced divergence in the levels of protection afforded investigative records compiled under sections 3751 and 3754, we cannot conclude that a police report or investigation compiled and reported under section 3751 may be subject to protection under section 3754.
Section 3754(a) clearly limits the nature and origin of "in-depth accident investigations and safety studies" subject to protection. Accordingly, section 3754(b) protects only investigations and studies compiled by "the Department, in association with the Pennsylvania State Police".
Because the materials in question here were compiled by a municipal police department rather than by "the Department, in association with the Pennsylvania State Police," they are not entitled to protection under section 3754(b). See 75 Pa.C.S. 3754(a).
Consequently, we find no error in the trial court's order refusing to quash the subpoena seeking production of the materials at issue, as described.