Article Packet: Background Information on Seatbelts in School Buses

This notice from the Department of Transportation, denies a petition for rule-making filed by Physicians for Automotive Safety (PAS), asking this agency to mandate the installation of seat belts on all school buses. NHTSA believes that the currently mandated occupant protections in school buses provide an adequate level of safety protection, and that seat belts would not raise the level of protection for the occupants unless States and local jurisdictions were willing to take steps to ensure that the seat belts were actually used.

ARTICLE PACKET BACKGROUND INFORMATION ON SEAT BELTS IN SCHOOL BUSES 47032 Federal Register DEPARTMENT OF TRANSPORTATIOW Natlonal Highway Traffic Safety Administration 49 CFR Part 571 Federal Motor Vehicle Safety Standards: Denial of Petition for ~ulemaklng ramcv: National Highway Traffic Safety Administration (NHTSA),DOT. A m o n : Denial of petition for rulemaking. SUMMARY: This notice denies a petition for rulemaking filed by Physicians for Automotive Safety (PAS), asking this agency to mandate the installation of seat belts on all school buses. NHTSA believes that the currently mandated occupant protections in school buses provide an adequate level of safety protection, and that seat belts would not raise the level of protection for the occupants unless States and local jurisdictions were willing to take steps to ensure that the seat belts were actually used. Any jurisdiction willing to take such steps is free under the existine requirements to order seat belts in school buses. Those jurisdictions which are unable to take such steps or which would find adoption of such measures inappropriate or not effective would be forced to purchase safety equipment which would not improve the level of passenger safety in their school buses. For these reasons, the first part of thin petition is denied. PAS asked alternatively that seat belt anchorages be mandated on school buses if seat belts were not because "it ir not possible to retrofit belts correctly in any buses on the road today." The agency rejects this rationale because PAS offered no evidence to support i t More important, agency c a l c u l a t i o ~ indicate that seat belts can be safely retrofitted on almost all school buses. Therefore, the second part of the PAS petition is also denied. 'FOR FURTHER INFORMATION COWIACT: Robert N. Williams. Office of Vehicle Safety Standards, National Highway Traffic Safety Administration, 400 Seventh Street, SW., Washington D.C. 20590 (202426.2264). INFORYITIOW: PAS has filed a petition requesting this agency to mandate the installation of seat belts on all new school buses or, alternatively, to mandate the installation of seat belt anchorages on all new school buses. In support of its requests, PAS asserted that school bus seats meeting the requirements of Standard No. 222 SIJPPSYENTARV / Vo. 48. No. 201 / Monday, October 17, 1983 school Bus Passenger Seating and Cmsh Protection, do not offer restraint to passengers in lateral and rollover crashes unless seat belts are used. As evidence to support this assertion, PAS cited the March.25,1983,crash of a d o 0 1 bus near Newport, Arkansas. which resulted in 9 d e a t h and 27 injuries. PAS' request for the agency to require the installation of seat belts was made in two previous petitions, both of which were denied. As NHTSA explained in those denials, adequate passenger protection is provided in school buses by compartmentalizingthe occupants between high-backed, well-padded. sturdy seats. The compartmentalization process protects occupants whether or not seat belts are used. Fatalities in school buses have declined since the compartmentalization requirement took effect for new school buses on April 1,1977. For the yeam 1975 to 1979, there were 87 people killed while riding in school buses, with an average of 17 persons killed each year. For U80, there were 15 fatalities while riding in school buses, and for 1981, the last year for which complete statistics are available, there were 10 fatalities in school buses. These data support the agency's position that the "compartmentalization" concept does provide an adequate level of safety and that the safety protection for passengem has been raised over what it was before Standard No. 222 became effective. Mandating seat belts in school buses would not raise the level of safeh protection afforded to the occup&ts unless State and local jurisdictions were willing to take steps to ensure that the seat belts were actually used. Any jurisdiction w i h g to take such steps is free, under existing requirements, to order seat belts in their school buees. Those jurisdictions which are unable to take such steps or which would find adoption of such measures inappropriate or not effective would be forced to purchase equipment which would not improve the level of safety in their school buses. It is important to emphasize that Standard No. 222 specifies only the minimum safety requirements applicable to all school buses. Nothing prohibits a State or local jurisdiction from requiring a higher level of safety protection in their school buses. Thus, any school district that wants to order seat belts in its school buses in free to do so. In its petition. PAS cited the experience of a Greenburgh, New York, school district with seat belts installed in school buses, and reported that the belts were being worn. NHTSA is pleased to hear of the success of this program, and believes that it shows the wisdom of allowing / Prcmosed Rules local jurbdictions the option of chooeing whether to equip their school buses with seat belts. Those districts which choose that option will presumably take some additional steps to ensure that the belts are used, and will achieve results similar to those experienced in . Greenburgh. The only new information cited in the PAS petition concerned the tragic school bus accident in Arkansas on March 25 of this year. That accident r h o & , according to PAS, that the compartmentalization concept of passenger protection doee not work The National Transportation Safety Board (NTSB) investigated this accident and concluded that it is doubtful that seat belts could have prevented any of the deaths in this case, given the nature of the crash impact. Ruther, the school bun involved in that accident was built before Standard No. 222 became effective on April 1,1977,and was never certified as complying with the standard. It ir not clear why PAS believes that an accident involving a bum built prior to the effective date of a safety standard indicates that the requirements of that safety standard are ineffective. Since PAS has presented no new data or analyses in support of their contention that seat belts should be required on all new school buees, this part of the petition is denied for the same reasons earlier PAS p e t i t i o ~on this topic were denied. PAS alternatively requested that seat belt anchorages be installed in all new school buses. PAS asserts in their petition that "it ie not possible to retrofit belts correctly in any buses on the road today." PAS sought to support this assertion with two arguments. Fimt, according to PAS, only two school bus manufacturers will install seat belts in the buses at the factory. The other school bus manufacturers, according to PAS, "claim that seats are not strong . enough to cany belt loads." To check this argument, NHTSA asked the School Bus Manufacturem Institute to conduct a poll of its six largest members. That poll found five of the six manufacturers would install seat belts at the factory if so asked by a purchaser. Further, none of the polled manufacturers attempted to justify not providing seat belts on the basis that the seats in the buses are not strong enough to withstand the loading. The agency has no knowledge of any data or analyses which suggest that seats in school buses complying with Standard No. 222 are not strong enough to withstand such loading. Before Standard No. 222 was originally promulgated, NHTSA ran a series of '- 47033 Federal Register / dculationr which rhowed that seab complying with the requirements of the standard could withatand 1600 pounL reat belt anchorage loads, and this ability would allow reat belts to be rafely installed. Those calculatiom have not heretofore been challenged a8 erroneous. Further, this agency ha8 no knowledge of any tests or analyrer conducted by itself, the rchool bun manufacturers, PAS, or any other party which cart doubt on the continuing validity of those calculatiom. NHTSA will continue to rely on thore dculationr until rome terb or analyrer are NII which ruggest there may be rearon to doubt their validity. The recond argument offered by PAS to e lain i b arrertion concerning retr0"IItting problemr war that the . w t designa in some school bumr cauw reat, belb to fail to perform properly. PAS arrerted that installation of seat beltn ir porrible in those rchool burer only if the belb are fed through the crack between the reat curbion and the meat back in an Srhaped path. PAS claim the belt, when ro installed, would mure the reat curhion to deprerr in a o r a h situation, thereby creating a laqe amount-of deck in the belt. According to PAS, this slack would defeat the energy absorption purpose of the belt and might even reeult in small passengem rubmarining under the belt. Contrary to the PAS areertionr, the limited padding thicknese on current bur seat cushions and the angle of the neat belt from the anchorage to the point where it passes around the occupant'r pelvis ir such that only a very mall amount of elack could be created in a craeh rituation. In fact, the eituation diffem little from that of seat beltr in passen~ercars, except that the seat &shio& in passeng& cars generally have much thicker padding than do rchool bus seats. The accident data for passanger cars indicate that the amount of elack in reat belts which results from seat cushion depression is negligible. Further, the agency is unaware of any data suggesting that the negligible slack gives rise to any safety problemr. Accordingly, the agency denies the recond part of PAS' petition, asking for seat belt anchorages to be mandated on all rchool buses. Anchorages can be ' installed along with seat belts, if a 'purchaser wishes fo install seat belts on its school buses. The denial of this PAS petition is based on a consideration of the currently available data. Should some Vol. 48. No, 201 / Monday, October 17, 198'3 / Proposed Rules new data become available indicating that current safety protection for occupants of school buses might be inadequate, the agency will take appropriate stepe. (Sec. 103,119, Pub.L 88-583,80 Stat. 7l8 (15 U.S.C.1392,1407): delegntionr of authority at 40 CFR 1.50 and 49 CFR SOl.8) Irnued: October 11,1983. Kennedy H. D m Acting Asrociote Admini6llolorfor Rulemaking. I ) CART 571--FEDERAL MOTOR VEHICLE SAFETY STANDARDS School Bus Passenger Seating and Cnsh Rotetion This notice responds to two petitions for reconsideration of Standard No. 222, School Bus Pasenper Seating and Clash Protection, as it was h u e d January 22, 1976. Standard No. 222 (49 CFR 871.222) was issued January 22.1976 (41 Pa 4016, January 28; 1S76), in accordance with section 202 of the Motor Vehicle and Schoolbus Safety Amendments of 1974, Pub. L. 93-492 (15 U.8.C. 1392(i) (1) ) and goes into effect on October 26, 1976. The standard provides for compartmentalization of bus passengers between well-padded and well-constructed seats in the event ef collision. Petitions for reconsideration of the standard were re-, ceived from Ohellet-Olobe Corporation and from the Physicians for Automotive Safety (PAB),which ebo represented the views of Action for Chfld T T a ~ p o r tation Safety, wveral adult fndfviduals, and several school bus riders. FEDERAL REGISTER, Vol. 41, No. 134 Monday, J u l y 12, 1976, p.28506 RULES AND REGULATIObIrS . pm e.presed dissatisfaction wfth ,veral aspects of the standard. The organization objected mast strongly to the egency's decision that seat belts should not be mandated in school buses. PAS magreed wlth the agency conclusion (39 lq% 27585, July 30, 1974) that, whatever the potential benefits of safety belts in motor vehicle collisions, the possibility of their non-use or misuse in the hand6 of children makes them impractical in school buses without edegUate ~ ~ p e r sion. In support of safety belt installation, PAS cited statistics indicating that 23 percent of reported school bus accidents involve a side impact or rollover of the bus. While safety belts presumably would be beneficial in these situations, PAS failed to provide evidence that the belts, jf provided, would b e properly utilized by school-age children. The asency will continue to evaluate the wisdom of its decision not to mandate belts, based on any evidence showing that signitlcant numbers of school districts intend to provide the supervision that should accompany belt use. In view of the absence of evidence to date, however, the agency maintains its position that requiring the hitallation of safety belts on school bus passenger seats k not appropriate and denies the P A S petition for reconsideration. The agency continues to consider the reduced hostility of the improved seating to be the best reasonable form of protection against injury. PAS asked ,that a separate standard for seat belt assembly anchorages be issued. They disagree with the agency's conclusion (41 F R 4016) fhat seat belt anchorages should not be required because of indications that only a small fraction of school buses would have belts installed and properly used. However, PAS failed to produce evidence that a substantial number of school buses would be equipped with safety belts, or that steps would be taken to assure the proper use of such belts. In the absence of such information, the agency maintains its position that a seat belt anchorage requirement should not be included in the standard at this time, and denies the PAR petition for reconsideration. The NHTSA doe. find merlt In the PAS concern that in the absence of additional guidance, improper safety belt installation may occur. The Admlnistratlon is considering rulemaking to estabLish performance requirements for safety belt anchorages and assemblies when mch systems are installed on school bus passenger seats. PAS also requested that the seat back height be raised from the 20-inch level specified by the standard to a 24-inch level. In support of this mition, the organization set forth a "common sensew argument that whiplash must be occurring to school bus passengers in rear impact. However, the agency has not been able to locate any quantified evidence that there is a significant whiplash problem in school buses. The crssh forces imParted to a school bus occupant in rear impact are typically far lower than those fmparted in a c a r - t o e impact because FEDERAL of the greater weight of the echo01 bW. The new and higher seating required by the standard specifies e n e m absorption characteristics for the seat back under rear-impact conditions, and the agency over considers that these~~improvements earlier seating designs will reduce the number of injuries that occur in rear Lmpact. For lack of evidence of a signiflcant whiplash problem, the PAS petition for a 24-inch seat back is denied. ~ iPAS - believed that the States and localities that specify a 24-inch seat back height would be precluded from doing so in the future by the preemptive effect of Standard No. 222 under section 103 ( f ) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1392W ) : Bection 103 (d) Whenever a Federal motor vehicle safety standard under this subchapter b in effect, no Bta.te or political subdivision of a Stat* shall have any authority either to e6tablish, or to continue In effect, aith rsspect to any motor vehicle or item of motor vehlcle equipment any safety standard applia b l e to the m e sspect of performance of such vehicle or item of equipment which ls not identical to the Pederal standard. Nothing in this section shall be construed fo prevent the F'ederal Oovernment or the government of any State or political subdivision thereof from estabflshlng a d e t y requirement applicable to motor vehlcle equipment procured for it8 own uae 5f such requirement imposes a hlgher stendard of pe~ormancethan that required to comply with the otherwise applicable Federal standud. Standard No. 222 specifles a minimum seat back height (65.1.2) which manufacturers may exceed as long as their product conforms to all other requlrements of the standards applicable to school buses. I t is the NHTBA's opinion that any State standard of general applicability concerning seat back height of school bus seating would also have to specify a minimum height identical to the Federal requirement. Manufacturers would not be required to exceed this minimum. Thus, the PAS petition to state seat back height as a mintmum b unnecessary and has already been satisfled, although it does not have thceffect I desired by the PAS. With regard to the PAS concern that the States' seat-height requirements would be preempted, the second sentenoe of section 103(d) clarifies that the limitation on safety regulations of general applicability does not prevent governmental entities from specifying additional safety features in vehicles purchased for their own use. Thus, a State or its political subdivisions could specify a seat back height higher than 20 inches in the case of public school buses. The second sentence does not permit these governmental entities to specify safety features that prevent the vehicle or equipment from complying with applicable safety standards. With regard to which school buses qualify as "public school buses" that may be fltted with additional features, it b noted that the agency includes in this category those buses that are owned and operated by a private contractor under contract with a State to provide transREGISTER, VOL. portation for students to and from pubuc schools. Bheller-Globe Corporation (';heUer) petitioned for exclusion from the seating requirements for seating that is deslgned for handicapped or con 'alescent students who are unable to udlize conventional forward-facing seats. ~ i c a l l y .sldefacing seats are installed to improve entry and egress since knee room is United in forward-facing seats. or spaces on the bus are specifically designed to m m modate wheelchairs. The standard presently requires that bus passenger seating be forward-faclng (85.1) and conform to requirements appropriate for forwardfacing seats. Blue Bird Body Company noted in a March 29. 1976, letter that tt also considered the standard's muirements inappropriate for special seating. The agency has considered the W t e d circumstances In which this seetine would be offered in school bwea and concludes that the seat-spacing requirement(65.2) and the fore-and-aft seat performance requirements (85.1.3, 85.1.43 are not appropriate for side-facing seats designed solely for handicapped or convalescent students. Occupant crash protection is, of course, as important for these students as others, and the agency intends to establish requirements suited to these specialized seating arrangements. At this time, however, insuiacient time remains before the effective date of this standard to establish W e r e n t requirements for the eating involved. Therefore, the NHTsA has decided to modify its rule by the exclusion of sidefacing seating installed to accommodate handicapped or convalescent passengem. School bus manufacturers should not. that the limited exclusion does not reUeve them from providing a restrafninS barrier in front of anv forward-facing seat that has a side-facing seat or wheelchair position in front of it. Sheller also petitioned for a madidcation of the head protection wne (855.1.1) that describes the space In front of a seating position where an occupant's head would impact in a crash. The outer edge of this zone is described as axertical longitudinal plane 3.25 inches inboard of the outboard edge of the seat. Bheller pointed out that van-type school buses utilize "tumble home" in the side of the vehicle that brings the bue body side panels and glazing into the bead protection zone. As Sheller noted, the agency has never intended to include body side panels and glazing in the protection zone. The roof structure and overhead projections from the interior are included in this area of the mne. To clarify this distinction and account for the "tumble home," the description of the head impact zone in 85.3.1.1 is appropriate& modifled. In accordance with recently-enunclated Department of Transportation policy encouraging adequate analysia of the consequences of regulatory action (41 FR 16201; April 16, 1976). the agency herewith summarizes its evaluation of the economic and other consequences of thts action on the public and private sectom, including possible lo& of safety benetfts 41, NO, lS+--MONDAY, JULY 12, 1976 - 28508 RULES AND REGULAT?ONS 'nle decision to withdraw repuinments for side-facing seats used by handicapped or convalescent students will rerult in cost savings to manufactureas and purchasers. The action may eacauragc production of specialized buses thot would otherwise not be built if the s e a t lng were subject to the standard. Because the requirements are ~ o appropriate t to the orientation of this seating, it is estimated that no significant loss of safety benefits aill occur as a result of the amendment. The exclusion of sidewall, window or door structure from the bead protection Gone is simply a clarification of the agency's longstanding intent that these components not be subject to the recrulrements. Therefore no new consequences are anticipated as a result of this amendment. In an area unrelated to the Petitlorn for reconsideration, the Automobile Club of Southern California petitioned far rrpectflcation of a vandalism resistance specification for the upholstery that is fnstaUed in school buses In compliance Kfth Standard No. 222. ~ a were k mbmftted on experience with crPsh pad8 installed in school buses operated in Calllomia. Vandalism damage was experienced, and its cost quantitled Ln the submitted dab. The Automobile Club msde oo argument that the damage to the wholstay gnsents o significant saietg poblan. Whne it i~ conceivable thst ranoval of .L1padding from a seat back could occur and m e the rigid seat frame, the .gency estimates that thk would occur rvely ond presumably would result in replacement of the seat. Because the agency's authority under the National RafRc and Motor Vehicle Safety Act is limited to the issuance of standards that meet the need for motor vehicle safety (IS U.S.C. 1392ta)), the agency concludes that a vandalism resistance requirement Ls not appropriate for inclusion in Standard No. 2 Z . In llght of the foregoing, ' Staddard No. 2n (40 CFR 573.222) b amended as foUoWk?: 0 571.222 EefmttVe date: October 26. 1976. Because the stendard becomes effective on October 26, 1976, it Is found to be in the public interest that an edlectfve date sooner than 180 days is in the public interest. Changes fn the text of the Code of Federal Regulations should be made imnleataw; 1 8t.t 718 (See. 103, 119; Pub. L. 69-663, (16 U.8.C. 1892,1407) ; deleptlon of authority at 49 CPB s30) Issued: July 7.1976. JFR Doc.76--4 .. W e d 7-7-76;3:16 pm] [Anendedl 1. Iq 84, Definitions, the defhition of 6chocA'bus passenger seat b amended to. "School bus Passenger seat" mean8 ,a neat in a school bus, other than the drives's seat or a seat installed to accommodate handicapped or convalescent pw'dengers as evidenced by orientation of , t h e seat in a direction that is more than .O degrees fo the left or right of the hmgltudtnal centerline of the vehkle. 2. In S5, Requftements, the !hst W a graph of 85.3.1.1 is amended to read: . , _ 85.9.1.1 T h e head proteetion mnea ln each vehicle are the specs in front of each school bus psssenger sest which are not occupied by bus sidewall, windan, or door structure and which, fn relation to that reat and ib sesttag reference mink are enclosed by the foUoKing vlanss; FEDERAL REGISTER, VOL 41 NO. 1 34-MONDAY JULY 12, 1976 LOS ANGELES COUNTY SUPERINTENDENT OF SCHOOLS AD HOC COMMITTEE REPORT ON THE USE GF SEAT BELTS I N SQi00L BUSES P r e p a r e d by Regionalized Business ~ e & i & o D i v i s i o n o f Business Advisory Services on b e h a l f o f t h e Ad Hoc Committee Robert Austin , Director k i t e l o p e Valley Schools T r ~ s p o r t a t i aAgency Charles Devlin P u p i l T r a m p o r t a t i o n Cbordinator S p e c i a l Education Lor Angeles County S u p e r i n t e d m t of Schoolr )Lx Barney D i r e c t o r of Transpor:ation Lor Angeles Unified School District - D ~ i tdn u i s h tlotor C r r r i e r speci.1irt C a l i f o r n i a LUyhvay P a t r o l Clem U i n e b r c Director of Transportation R w l m d Unified Scbool District Joreph Nauyolru D i r e c t o r of T r u l r p o r t a t i o n Long k a c h Unifiod Scboul Di8tricr Herbert B r r t e l t Deputy Superintendant Business Services L a c a r t e r School D i s t r i c t Clyde tvana Supervisor of T r a m p o r t a t i o n Walnut Vallry Unifled School Dirtrict Dean Speoce Policy b Covem#ntal l l a l r o n A u t o w b i l e Club of S o u t h r a California George Boyce Safety Consultanc Automobill Club of Southern k l i f o r n i a W i l l i a m Crmen '1amEs Vof f e F i e l d Soordlnarot S t a t e Department of fducation Safety Coordinator ' b s Angeler Coprpunity College D i r t r i c t Lom Angelem County Schuolm S t a f f U l e e n L. Okataki &sir cant Adminirtrative Analyst Deborah L. S i m n r , Chair Reglondlized Business S e w i c e s Coordinator November 1983 5 LOS ANGELES COUNTY SUPERINTENDENT OF SCHOOLS AD HOC COXMITTEE REPORT ON THE USE OF SEAT BELTS IN SCHOOL BUSES ~i t h e J u l y 12, 1983, meeting of t h e Los Angeles County ~ o a r d ' o fSupervisors, Supervisor Hahn requested t h a t a study be conducted t o determine: 1) i f m y r t a t e , ccpnty, o r c i t y i n t h e United S t a t e s r e q u i r e s s e a t b e l t 8 In achool buses;-2) whether s e a t b e l t s might have raved l i v e s i n a c c i d e n t s i n v o l v i n g s c h o o l .buses; and 3) a p p r o p r i a t e a c t i o n t h e Board should take regarding i n s t a l l a t i o n of s e a t b e l t s in school buses a f t e r c o n s u l t a t i o n k i t h t h e C a l i f o r n i a Highway P a t r o l and t h e Us Angeles County Superintendent of Schools. The Los Angeles County Superintendent of Schools e s t a b l i s h e d an ad hoc advisory c o d t t e e t o assist i n t h i s i n v e s t i g a t i o n . Members of t h i s committee included r e p r e s e n t a t i v e s from t h e Automobile Club of Southern C a l i f o r n i a , t h e C a l i f o r n i a Highway P a t r o l , t h e S t a t e Department of Education, 8 j o i n t powers agency f o r s c h o o l t r a n s p o r t a t i o n , and a number of Los Angeles County s c h o o l and cornunity c o l l e g e d i s t r i c t s (one b u s i n e s s manager and reveral transportation directors). With i n p u t from t h e committee, r e s e a r c h was done on t h e f e a s i b i l i t y of i n s t a l l i n g s e a t b e l t s i n school buses and t h e r a m i f i c a t i o n s of doing so. A number of r e p o r t s and a r t i c l e s on s e a t b e l t s v e r e reviewed, and a s s o c i a t i o n s l o r g a n i z a t i o n s having an i n t e r e s t i n t h i s a r e a were contacted. CONCLUSI ONS 3 The f i n d i n g s of t h i s r e p o r t a r e t h a t rchool buses are r t a t i s t i c a l l y t h e s a f e s t form of ground t r a n s p o r t a t i o n i n t h e United S t a t e s today. F e d e r a l r t a n d a r d s , which improved passenger r a f e t y and became e f f e c t i v e i n 1977, implemented a new concept c a l l e d compartmentalization. T h i s concept Sr based on reducing i n j u r y and f a t a l i t y by keeping a c h i l d contained i n a small space (passive r e s t r a i n t ) . T h i s concept is designed t o t a k e c a r e of t h e g r e a t e s t nrnzber of c h i l d r e n (both i n t h e v a r i a n c e of age and r i t e and i n most t y p e s of school bus a c c i d e n t s ) . I n a d d i t i o n , C a l i f o r n i a ' r requirements f o r school bus d r i v e r t r a i n i n g and y e a r l y i n s p e c t i o n of vehic l e s have r e s u l t e d i n low f a t a l i t y r a t e s f o r p u p i l passengers. Based on t h e f i n d i n g s i n t h i s r e p o r t , i t is considered that:. 1) t h e absence of a f e d e r a l p t a n d a r d t o mandate s e a t b e l t s i n school buses, and 2) t h e c u r r e n t policy t o not i n s t a l l s e a t b e l t s i n rchoolbuses, a r e appropriate. Although we have found two school d i s t r i c t s vhich have chosen t o have b e l t s I n s t a l l e d on t h e i r buses f o r t h e i r r e g u l a r home t o rchool t r a n s p o r t a t i o n program, we have found no l e g a l requirements f o r s e a t b e l t s t o be i n s t a l l e d on rchool buses i n t h e United S t a t e s . Schools a r e e d u c a t i o n a l f a c i l i t i e s . We b e l i e v e t h a t t h e i n s t a l l a t i o n of r e a t b e l t s on school buses could provide b e n e f i c i a l t r a i n i n g f o r r t u d e n t s t o u s e s e a t b e l t s i n t h e family automobile. However, t h e q u e s t i o n of reduced s a f e t y due t o t h e i n c o m p a t i b i l i t y of s c a t b e l t s and compartmcnt a l i r a t i o n , t h e a d d i t i o n a l c o s t , and l i a b i l i t y r e l a t i n g t o t h e i r i n s t a l l a t i o n f a r outweighs t h i s b e n e f i t of t r a i n i n g . Schools have curriculum programs a v a i l a b l e t o i n s t r u c t s t u d e n t s (not j u s t bus passengers) on t h e . w e and l m p o r t u ~ c eof s e a t belts in t h e f d l y r u t o w b i l e . Education on t h e use of s e a t b e l t s is important. This i n s t r u c t i o n is designed t o inc r e a s e s e a t b e l t usage by t h e motoring p u b l i c where c u r r e n t s t a t i s t i c s on usage, though i n c r e a s i n g , a r e low=-14 p e r c e n t w a g e of s e a t b e l t s nationwide and 18 p e r c e n t usage i n C a l i f o r n i a . The-National S a f e t y Council's s t a t i s t i c s show t h a t School buses have t h e lowest f a t a l i t y r a t e p e r passenger mile i n t h e United S t a t e s . F a c t b r s c o n t r i b u t i n g t o t h e s a f e n e s s of s c h o o l buses u e t h e s i z e , c o l o r m d markings vbich i d e n t i f y ~ c h o o lbuses t o t h e public. I n C a l i f o r n i a , t h e - f a t a l i t y r a t e p e r passenger mlle i s even lower t h a n t h e nationwide f i g u r e . W e b e l i e v e t h a t t h e a d d i t f o n a l s a f e t y of s c h o o l b w c s i n C a l i f o r n i a r e s u l t s i n p a r t from t h e school bus d r i v e r t r a i n i n g program, preventive maintenance undertaken by s c h o o l d i s t r i c t s , and y e a r l y i n s p e c t i o n of school bus v e h i c l e s by t h e C a l i f o r n i a Hlghwey Patrol. Jack Baird, a l e a d i n g s a f e t y e x p e r t in t h e Southern C a l i f o r n i a a r e a (member of r e s e a r c h teams a t t h e UCLA I n s t i t u t e of T r a n s p o r t a t i o n and T r a f f i c Engineering and t h e USC S a f e t y and Systems +nagextent Department), b e l i e v e s that s e a t b e l t s i n school buses w i l l n o t " t a b c a r e of t h e g r e a t e s t number of people." H i s opinion is t h a t improved s e a t s and compartmentalization a r e = r e a p p r o p r i a t e in d e a l i n g w i t h t h e s a f e t y of c h i l d r e n in s c h o o l buses. I n v i e v of t h e p a s t s a f e t y r e c o r d s of s c h o o l buses and u n t i l such time as school buses a r e redesigned t o accorrrmodate t h e i n s t a l l a t i o n of s e a t b e l t s i n s c h o o l buses, i t i s considered t h a t t h e c u r r e n t p o l i c y and f e d e r a l s t a n d a r d s t o n o t i n s t a l l seat b e l t s in school buses are a p p r o p r i a t e . FEDERAL REQUIRPiENTS ON SEAT BELTS I N SCHOOL BUSES The National Highway T r a f f i c S a f e t y Administration (NHTSA) i s t h e f e d e r a l agency r e s p o n s i b l e f o r e s t a b l i s h i n g f e d e r a l s t a n d a r d s (minimum) f o r a11 motor v e h i c l e s . T h e i r province Includes t h e s a f e t y and crashworthiness of a11 motor v e h i c l e s , i n c l u d i n g s c h o o l buses. The NHTSA does n o t r e q u i r e meat b e l t s in s c h o o l buses. They have been p e t i t i o n e d t o r e q u i r e s e a t b e l t s ; however, they have denied t h e p e t i t i o n s s t a t i n g t h a t t h e e x i s t i n g s a f e t y of s c h o o l buses does n o t warrant f u r t h e r expense or f e d e r a l r e g u l a t i o n s a t this time. The NHTSA does n o t , however, discourage t h e implementation of s e a t b e l t s i n s c h o o l buses, b u t does s t a t e t h a t p r i o r t o doing s o , t h e " o v e r a l l p i c t u r e " should be examined (age of bus, age of a t u d e n t s , ' s t r u c t u r a l i n t e g r i t y of bus, etc.). Since s e a t b e l t s a r e not r e q u i r e d , t h e r e i s no f e d e r a l standard d e a l i n g v i t h s e a t b e l t load requirements. The NHTSA b e l i e v e s t h a t some buses have t h e s t r u c t u r a l s t r e n g t h t o withstand s e a t b e l t loads and o t h e r s do not. The determination of c a p a b i l i t y t o v i t h s t a n d s t a t b e l t l o a d s would need t o be done on a n i n d i v i d u a l bus b a s i s . Federal Standards A l l bus-type v e h i c l e s , both c m e r c i a l and school, must comply v i t h t h e same Federal Motor Vehicle S a f e t y Standards. I n a d d i t i o n , school buses must comply w i t h f o u r a d d i t i o n a l s t a n d a r d s , a l l of which became e f f e c t i v e on A p r i l 1, 1977: 1. R o l l Over Protection - 2. Bus Body J o i n t Strength 3 Passenger Seating and Crash P r o t e c t i o n 4. Fuel I n t e g r i t y Tbese a d d i t i o n a l standards required s e v e r a l changes I n bus construction which t e s u l t e d i n passenger s a f e t y . One of t h e major changes i s t h e concept of compartmentalization-keeping a c h i l d contained in a small apace. Thir required i n t e r i o r s e a t i n g changes-seat back heightb were r a i s e d from 20" t o 24" .(federal standard was o r i g i n a l l y proposed a s 32"); and s e a t s were rpaced c l o s e r together. Padding became a requirement on a l l contactable surfacee, e s p e c i a l l y meats, and s e a t s were made t o have some degree of f ~ e x i b i l i t y . S t r u c t u r a l improvements t o t h e body of t h e bur were a h 0 required. SEAT BELT USAGE BY SCHOOL DISTRICTS We a r t unaware of any r t a t e law requiring s e a t b e l t r on rchool burer f o r bomc t o school transportation. I n our research we have found two d i s t r i c t s in t h e United S t a t e s which have i n s t a l l e d s t a t b e l t r on rchool burer. Greenburgh Central School D i s t r i c t #7 The Greenburgh Central 'School D i s t r i c t 17, i n Nev York, i s t h e f i r s t rchool d i s t r i c t t o use s e a t b e l t s i n t h e i r r e g u l a r t r a n s p o r t a t i o n program. This was a d i r t r i c t . d e c i s i o n and not 8 l e g a l requirement. ' Last y e a r , t h e d i s t r i c t ' s t r a n s p o r t a t i o n s e r v i c e was s p l i t beween d i s t r i c t operated t r a n s p o r t a t i o n (17 buses) and a p r i v a t e contractor (20 buses). This year, t h e d i s t r i c t w i l l provide a l l t r a n s p o r t a t i o n r e r v i c e s and w i l l have s e a t b e l t s i n s t a l l e d on a l l buses purchased t o provide r e n t i c e t o those r t u dents previously transported by t h e contractor. A l l of Greenburgh'r buses were manufactured a f t e r A p r i l 1977 and t h e r e f o r e comply with f e d e r a l standards. The Greenburgh D i s t r i c t began i n s t a l l i n g b e l t s I n 1978 and apparently has had no problems with them. A major concern p r i o r t o i n s t a l l i n g r e a t b e l t c was t h a t they would be used a s weapons. However, Salvatore Corda, Assirt8nt we have never had an instance vhere Business Superintendent, s t a t e d " a child.has been s t r u c k with a s e a t b e l t . I'm not saying i t doesn't happen, b u t t h e r e ' s been no i n c i d e n t s e r i o u s enough f o r a d r i v e r t o r e p o r t it." ... The d i s t r i c t does some monitoring of usage of r e a t b e l t s f o r elementary school c h i l d r e n , and s p o t checks usage f o r high school rtudents. The d i s t r i c t estimates 80 percent usage of s e a t b e l t r . To date, no d i s t r i c t bus equipped wfth r e a t b e l t s has been involved I n m accident. The Creenburgh D i s t r i c t is located about 25 m i l t s north of New York City, i n The d i s t r i c t serves 8 middle c l a s s a r e a and serves a mlxed e t h n i c population. kindergarten through 12th grade p u p i l s and t r a n s p o r t s 3200 s t u d e n t s (2500 p u b l i c and 700 p r i v a t e school students) approximately 510,000 udles per school year. Rartland Elementary School D i s t r i c t The Hartland Elementary School D i s t r i c t i n Vermont purchased a new school bus v i t h s e a t b e l t s a t t h e beginning of t h e 1983-84 rchool. year. The bus i s a 48-passenger bus and t r a n s p o r t s s t u d e n t s a maximum d f t e n miles one-way p e r day. The Superintendent, P h i l i p Hamrnond, r e p o r t s t h a t h e h p s received no r e p o r t s of vandalism o r u s e of t h e b e l t s a s veapms. '.- - The Hartland D i s t r i c t i s l o c a t e d in a middle c l a s s a r e a and serves dominantly w h i t e population. 8 pre- S e a t B e l t Usage f o r S p e c i a l Education There i s no l e g a l requirement t o have s e a t b d l t s on s p e c i a l education buses although many c h i l d r e n a r e r e s t r a i n e d i n some manner depending upon t h e i r disability. School d i s t r i c t t r a n s p o r t a t i o n d i r e c t o r s s b e c i f i c a l l y s t a t e d t h a t , f o r t h e purpose of r e s t r a i n t , n o t s a f e t y , some s p e c i a l education c h i l d r e n may b e b e l t e d o r r e s t r a i n e d i n some manner w h i l e r i d i n g t h e bur. REVIEW OF CURRENT RESEARCH STUDIES ON SEAT BELTS I N SCHOOL BUSES Many of t h e r e s e a r c h s t u d i e s on seat b e l t s i n school buses were undertaken in t h e 1960s and 1970s. Those involved i n t h i s i n d u s t r y ( t r a n s p o r t a t i o n d i r e c t o r s , s a f e t y o f f i c i a l s , r e s e a r c h e r s ) have i n d i c a t e d t h a t t h e r e had n o t been any f u r t h g r s t u d i e s i n t h i s a r e a due to: t h e s a f e t y record of school buses, l a c k of funds t o perform r e s e a r c h , and a v a i l a b l e funds going f o r r e s e a r c h i n t h o s e a r e a s where t h e f a t a l i t y r a t e s are higher. UCLA I n s t i t u t e of Transportation and T r a f f i c Engineering Study In 1972, the UCLA I n s t i t u t e of Transportation and T r a f f i c Engineering publ i s h e d a study in which school bus v e h i c l e s vere c r a s h t e s t e d . The s t u d y s t a t e s , "The unacceptable s a f e t y performance of lap-belted school c h i l d r a i , (1966) school bus r i d i n g i n conventional seats was e s t a b l i s h e d by t h e experiments and a g a i n emphasized by t h e s e , , findings." They f u r t h e r s t a t e t h a t "the average s i z e . s c h o o 1 c h i l d (13-year o l d ) vould s u s t a i n less head impact f o r c e s i f l e f t unbelted than i f lap-belted, provided h e was p r o t e c t e s by a 28" high energy absorbing, UCLA-design s e a t back." (The UCLA-design s e a t o r s a f e t y s e a t s in a d d i t i o n a r e w e l l padded s e a t s . ) he^ concluded t h a t s e a t b e l t s a r e n o t recornended f o r school buses having conv e n t i o n a l s e a t s with hard s u r f a c e s , weakly s t r u c t u r e d frames, l a c k of sidef o r c e r e s t r a i n t , and g r o s s l y inadequate back r e s t height. . . . The UCLA ctudy f u r t h e r concluded t h a t seat b e l t s vould c o n t r i b u t e a s i g n i f i c a n t measure of s a f e t y during severe, u p s e t c o l l i s i o n s ( a c c i d e n t s i n v h i c h t h e bus o v e r t u r n s ) i f t h e bus ir equipped v i t h rofety scats. However, i n moderately s e v e r e impacts, seat b e l t s were r e g i r d e d by t h e a u t h o r s t o be of minor importance when s a f e t y s e a t s a r e used. The s i z e , color,and markings of a school bus tend t o g i v e them "special p r o t e c t i o n " due t o p u b l i c r e c o g n i t i o n of t h e s e vehicleo. UCIA researchers noted t h a t they are s t r o n g advocates of l a p b e l t s in passenger vehicles. However, because school bus s e a t s a r e designed d i f f e r e n t l y and positioned c l o s e r together, i n s t a l l a t i o n of l a p b e l t s was inadvisable unless s e a t s t r u c t u r e s were designed i n conformance with l a p b e l t requirements. (It should be noted t h a t t h e UCLA study was published i n 1972, and has contributed t o t h e standards [such a s s a f e t y s e a t s ] vhich tiere adopted i n 1977.) ._ Southwest Research I n s t i t u t e Studp The Southwest Research I n s t i t u t e prepared "A Study Relating t o Seat B e l t s f o r Use i n Buses" under a c o n t r a c t with t h e C a l i f o r n i a Highway P a t r o l b hnuary 1977. Thcir recommendation not t o in;tall . . . seat b e l t s was based on t h e following: \ ~ a l i f o r n i a ' s accident and f a t a l i t y records f o r t h e preceding f i v e y e a r s showed t h a t school buses were 16.2 times more s a f e than automobiles ( l e s s than one c h i l d per year was k i l l e d i n school bus a c c i d e n t s duriag t h a t period). . S t r i n g e n t training,' inspection, maintenance, i d e n t i f i c a t i o n , l i c e n s i n g , and monitoring can accomplish more than t r y i n g t o confine t h e passenger. An estimated c o s t in 1977 of $42,900,000 t o i n s t a l l s e a t b e l t s tn school buses and estimated c o s t of $45,670,000 p e r year f o r monitors on school buses t o ensure t h a t passengers wear b e l t s . ORGANIZATIONS CONCERVED WITH SCHOOL BUS SAFEn Physicians f o r Automotive Safety h e Physicians f o r Automotive Safety, located i n New York, has endorsed both t h e i n s t a l l a t i o n of b e l t s and higher s e a t backs i n school buses f o r a number of years. They f e e l t h a t r e s t r a i n t i s t h e b e s t means of protect i o n a g a i n s t s e r i o u s i n j u r y i n t h e event of an accident. Los Angeles Area Child Passenger Safety Association The Los Angeles Area Child Passenger Safety Association (LAACPSA) i s a non-profit corporation engaged i n promoting c h i l d passenger s a f e t y i n t h e Los Angeles a r e a (includes a portion of Orange and Ventura counties). This a s s o c i a t i o n was a c t i v e l y involved i n t h e passage of t h e c h i l d s a f e t y s e a t law vhich became e f f e c t i v e i n January 1983 and sponsors workshops t o t r a i n i n d i v i d u a l s on t h e proper use of c a r s a f e t y s e a t s r Currently, LAACPSA has formed a school bus s a f e t y committee which i s invest i g a t i n g a11 a s p e c t s of school bus safety. A t t h e t i m e of t h i s r e p o r t , they have reached no formal conclusions although they do recommend t h a t s e a t b e l t s be i n s t a l l e d on post-1977 manufactured buses f o r t h e purposes of s a f e t y and t r a i n i n g . National Transportation Safety Board The National Transportation Safety Board, 8 f e d e r a l agency which r e p o r t s d i r e c t l y t o Congress, prepares accident r e p o r t s on a l l forms of t r a n s portation. These r e p o r t s a r e in-depth analyses of t r a n s p o r t a t i o n ~ c c i d e n t s c i t i n g causes of accidents, f i n d i n g s of conditions (e. g., weather, 'condit i o n of road, d r i v e r s , e t c , ) , i n j u r i e s and f a t a l i t i e s , m d recommendations. There have b e q g e v e r a l r e p o r t s done on a c c i d e n t s In which a school bus has be= involvedo In t h e s t u d i e s , t h e i n v e s t i g a t i o n t e a m has theorized whether occupant restCaint would o r would n o t have reduced i n j u r y o r prevented f a t a l i t y . Occupant r e s t r a i n t i n reducing i n j u r y o r preventing f a t a l i t y appears t o depend on s e v e r i t y of t h e accident, t h e v e h i c l e s involved, cause of accid e n t (e.g., equipment f a i l u r e ) a s w e l l as a namber of o t h e r circumstances (e.g., speed of vehicles, point of impact, etc.). Studies by t h e National Highway T r a f f i c Safety Administration shaw that s a f e t y b e l t s a r e 50-65 percent e f f e c t i v e in preventing f a t a l i t i e s and i n j u r i e s i n automobiles. Thus s a f e t y b e l t s may n o t b e t h e c u r e t o p r r venting a l l i n j u r i e s and/or f a t a l i t i e s i n school buses. Seat b e l t s a f e t y i n school buses has n o t been t e s t e d because t h e f w standard school buses w i t h s e a t b e l t s i n s t a l l e d have n o t been involved in accidents. SCHOOL BUS FATALITY STATISTICS California C a l i f o r n i a HighGay P a t r o l (CRP) s t a t i s t i c s show t h a t no p u p i l passengers v e r e k i l l e d i n a school bus r e l a t e d accident in fiscatl y e a r s 1980-81 and 1981-82, a d one pupil passenger was k i l l e d in f i r c a l p e a r 1982-83.* / The r i n g l e p u p i l f a t a l i t y occurred i n a school bus/truck c o l l i s i o n i n Humboldt County. A p u p i l a d t h e d r i v e r of t h e t r u c k vere both k i l l e d i n t h e head-on c o l l i s i o n in which t h e t r u c k d r i v e r was determined a t f a u l t . The absence of a s e a t b e l t f o r t h e p u p i l passenger was n o t bel i e v e d t o have been a f a c t o r i n t h i s f a t a l i t y . (The bus involved war manufactured p r i o r t o t h e 1977 standards,) Additional C n l i f o n l i a s t a t i s t i c s provided by t h e m P show t h a t , f o r t h e p a s t t e n y e a r s , t h e p u p i l f a t a l i t y r a t e i s 0.25 p e r 100 m i l l i o n miles and t h e f a t a l i t y r a t e f o r t h e motoring p u b l i c i r 3.5 p e r 100 m i l l i o q miles. I n t h i s ten-year period, f i v e p u p i l passengers and 47,701 C a l i f o r n i a m o t o r i s t s and passengers were k i l l e d . Where were no p u p i l p e d e s t r i a n s k i l l e d i n the thrae-year period 1980-81 through 1982-83 i n C a l i f o r n i a . Because t h i r type uf f a t a l i t y would n o t be r e l a t e d t o t h e use of s e a t b e l t s , t h i s s t a t i s t i c vill n o t be discussed f u r t h e r . It should be noted, however, t h a t nationwide, more p u p i l s a r e k i l l e d o u t s i d e t h e school bus than i n s i d e t h e bur. Nationwide The N a t i o n a l S a f e t y Council statistics show t h a t t e n p u p i l p a s s t n g e r s were k i l l e d on s c h o o l b u s e s f o r t h e 1981 c a l e n d a r y e a r i n t h e United S t a t e s . The National Highway T r a f f i c S a f e t y Administration Center f o r S t a t i s t i c s and A n a l y s i s show t h e f a t a l i t y r a t e f o r s c h o o l bus occupants f o r 1981 t o be 0.4 p e r 100 ndllim miles c o n t r a s t e d t o passenger c a r occupants a t 2.4 p e r m i l l i o n miles. AD HOC COMKI~EECONCERNS The Los Angeles County Superintendent of Schools ad hoc committee members had many concerns on t h e i n s t a l l a t i o n of s e a t b e l t s in s c h o o l bus v e h i c l e s which could n o t b e answered a t t h i s time., These concerns a r e based an e i t h e r a c t u a l e x p e r i e n c e o r c o n j e c t u r e based on p a s t experience. \ . Would seat b e l t s b e i s e d as wupon. o r cause i n j u r y a c c i d e n t a l l y ? An i n c i d e n t was r e p o r t e d in a Los Angeles County s c h o o l d i s t r g c t where a s p e c i a l e d u c a t i o n s t u d e n t was a c c i d e n t a l l y h i t by a seat . belt. Would monitors b e r e q u i r e d t o e n s u r e t h a t s t u d e n t s wore b e l t s and t o e n s u r e t h a t s m a l l c h i l d r e n are b e l t e d p r o p e r l y ? A d d i t i o n a l injury could r e s u l t from b e l t s which are worn t o o l o o s e l y . Where should s e a t b e l t s b e anchored-to t h e seat o r t o t h e f l o o r ? (An American S a f e t y B e l t Council r e p r e s e n t a t i v e s t a t e d that t h e ind u s t r y b e l i e v e s b e l t s should b e secured t o t h e f l o o r . ) Would a f i o o r anchor b e a t r i p p i n g hazard t o s t u d e n t s in view o f t h e c u r r e n t bus seat spacing? Buses may n o t b e s t r u c t u r a l l y s t r o n g enough t o w i t h s t a n d seat b e l t l o a d s . Would t h e s e buses r e q u i r e r e t r o f i t ? I n view of c u r r e n t s t a n d a r d s f o r compartmentalization, v i l l s e a t b e l t s cause more i n j u r y s i n c e t h e c h i l d w i l l be r e s t r a i n e d a t t h e h i p s and This could r e s u l t i n any f o r c e w i l l cause t h e c h i l d t o "jack-knife." t h e c h i l d ' s head s t r i k i n g t h e s e a t i n f r o n t . . Would c h i l d r e n p a n i c o r become dazed from s t r i k i n g t h e f o r v a r d s e a t in.emergency s i t u a t i o n s and n o t b e a b l e t o remove t h e i r b e l t s ? ,If t h e bus was overturned, c h i l d r e n could b e suspended as much as e i g h t f e e t i n t h e a i r . Could t h i s cause a d d i t i o n a l i n j u r y ? Would space b e l o s t by i n s t a l l i n g b e l t s (e.8.. elementary s c h o o l c h i l d r e n s i t t h r e e t o a seat, would b e l t s reduce s e a t i n g space t o two; would s e a t b e l t load requirements reduce s e a t i n g from t h r e e t o two passengers p e r s e a t ) ? Would t h e s e a t b e l t s be vandalized? Concern f o r vandrlism of s e a t b e l t s stems from experiences r e l a t e d t o vandalism of t h e s c h o o l bus. Members of t h e cornnittee r e p o r t e d t h a t s e a t c o v e r s had been r i p p e d / s l a s h e d , g r a f f i t i was w r i t t e n on t h e bus, s e a t backs had been broken, e t c . There had a l s o been r e p o r t s of p e n c i l l e a d s and chewing gum i n s e r t e d i n t o t h e buckles of s e a t b e l t s . PROS AND CONS OF SEAT BELTS I N SCHOOL BUSES (con t i m e d ) Organizations . . CON PRO 7 Physicians f o r Automotive Safety .-- Parents Los Angeles Area Child Passenger Safety Association While i t i s n o t p o s s i b l e t o determine any ~ r o u ps p c c i f i c d l y opposed t o 8Ut b e l t s in school buses, t h e following organizations have r e s e r v a t i o n s on i n s t a l l i n g seat b e l t s witho u t design modifications t o t h e buses, o r r p e c i f i c determinations b d e about s e a t i n g and anchorages: . . . . American Safety B e l t Council C a l i f o r n i a Association of School Transportation Officials i Natio-1 Safety Council National Highway T r a f f i c Safety Admiaiotration Bus nranufacturers FUTURE CONSIDERATIONS We b e l i e v e t h a t t h e post-1977 manufactured buses a r e cons'iderably more s a f e s i n c e they comply with t h e f e d e r a l standards dealing with compartmentalization, a t r u c t u r a l s t r e n g t h , etc. The National Transportation Safety Board plans t o do a study o n . t h e s e buses and evaluate t o what degree these standards have r a i s e d t h e s a f e t y l e v e l of school buses. When t h i s study i s released, i t may be appropriate t o reevaluate t h e number of pre-1977 manufactured buses owned by school d i s t r i c t s and seek replacement funds f o r these. What a d d i t i o n a l meintenance would b e required t o c l e a n be1 ts urd ensure they a r e working properly? . ow would ttAed i s t r i c t ' o l i a b i l i t y b e changed i f s e a t b e l t s were i n s t a l l e d ? Currently, bus insurance premsums a r e very l o w . . This i s due t o t h e h i s t o r y of bus safety. However, i f s e a t b e l t s a r e i n s t a l l e d on school buses, r e v e r a l i s s u e s of d i s t r i c t l i a b i l i t y Would t h e d i s t r i c t be l i a b l e when: will b e .raised. . . . . . c h i l d is n o t wearing seat b e l t and i s i n j u r e d i n a echo01 bus accident c h i l d is n o t wearing r e a t b e l t properly and s u f f e r s i n j u r y ( i n j u r y can b e caused when t h e b e l t i s worn e i t h e r t o o l o o s e l y o r t o o high-wer abdomen r a t h e r thrur! h i p r ) c h i l d i s i n j u r e d by t r i p p i n g w e r b e l t , h i t by b e l t , e t c . c h i l d i s n o t wearing s e a t b e l t because i t does not operate prop e r l y (vandalized e a r l i e r i n t h e day) and i s i n j u r e d i n a school bus accident How would t r a n s p o r t a t i o n c o n t r a c t o r s be a f f e c t e d i f s e a t b e l t s on school buses a r e required--would higher c o s t s be passed on t o school d i s t r i c t s ? PROS AND CONS OF SEAT BELTS IN SCHOOL BUSES . . . . may provide p r o t e c t i o n In accidents (particularly " r o l l over") g r e a t e r c o n t r o l of c h i l d r e n i n bus excellent training a t a young age t o u s e b e l t s eliminate confusion of c h a d r e n who use b e l t s i n famlly c a r but have none on school bus CON PRO 7 ' . . . . may cause i n j u r y due t o current design of buses many buses cannot have b e l t s i n s t a l l e d - w o u l d t h e s e buses be required t o b e r e t r o f i t t o withstand seat b e l t loads? b e l t s may b e used as weapons additional costs t o r e t r o f i t , purchase, and maintain b e l t s Should school buses have seat belts? y 16 years of school bus dnving have convinced me that 11's ttme to equtp our buses with seat belts They're needed to ensure that our chtldren will have the best possible protection in emergencies Driving a bus is an enormous responsib~lity When you're stopped wtth a busload of chddren at a rallroad crossing and a full gravel huck IS coming upon you at 40 miles an hour, you realize how great your responstbility a At times ltke those. 1 think how much more secure I'd feel if those children whose lives are in my hands were wearIng seat belts We bus drivers can't control every situat~onwe encounter when we're uavelIng to and from schools. Loohng out for the other driver certainly helps. but even the iafesr d r ~ b e rhas no guarantee that he or i h e won't become involved in an accident. Imagine what can happen if a bus makes an emergency stop or is involved in a collision. Children may be thrown from their seats to unsafe pans of the bus or info the windows. Smaller children are at spec~alrisk because their feet don't touch the floor and because they lack coordination They need seat belts just to prevent them from falling out of their seats when there's any quick movement of the bus. As far as I'm concerned, no handicapped student should be without a seat belt-for obvious reasons. Some would argue t h a t students on school buses are rarely h u n in collisions. They point to the slze and weight of the buses as compared to other vehicles. But school bus accidents occur every year. and children do get hun! According to the latest statistics from the National Safety Councll. there were 3.300 student injuries-and 55 student deaths-in school bus acctdents in 1983. 4ssociarion acnvirr D i ~ Formosa e has h e n school buses In Clover Park-a Tacoma, Wash.. suburb-for 16 years. !he currently trampons borh handicap~ed md regular studmu. Formosa is presiknr of rhe Clover Park Bur Drivers 4ssociafion. Becky Howell Lee IS an Il-year veferan school bur dnver in Alabamo 's Walker Cowuy. President of rhe Alabamn Education Atsociarion 's Educcuional Suppon Personnel Organization, she aLso serves on NEA 's Committee on Educational Suppon Personnel. There an other practical arguments for q u i p p i n g buses with seat belts: W Students who run, jump, or hit other children on the bus would be easier to control if they wore seat belts. W If every child were required to be belted in, school districts would finally have to provide enough buses to eliminate the problem of overcrowding. W Scat belts could be used to control band insuuments-which can become dangerous flying objects. W Havtng seat belts on school buses would reinforce in chddren the importance of the seat belt habit. As things stand now, parents who have tried to make "buckling up" an automatic response in thetr ch~ldrenfind their effort! undermined every time the kids get on a school bus. MI I agree that there a r e p r o b k m s to be worked out before seat belts on school buses become a reality. For example. just installing the belts won't necessarily mean they're w e d . We need legislation requiring that all students who ride school buses must wear seat belts. That leads to another cmcial question: Who would supervise the use of belts? School bus drivers already have more than enough to do, trying to drive safely amidst everyday discipline problems. h d s who get s ~ c kon the bus, and all the rest. It would be more than unreasonable to expect them also to monitor whether each child is buckled up. What districts should have, under any ctrcumscances, are aides on buses to help with the supervision. Just as an airline steward or stewardess checks passengen' seat belts, so would the school bus aide. And he or she would help with evacuation of chddren in case of fire o r other emergencies. Then there's the problem of money. There's no way to get around 11. Hiring school bus aides takes money-as does installing and maintaining seat belts. But compare all the cosls to the value of just one child's life. Our ch~ldrenare more important than any dollar figure a d~strictcan present. Seat belts on school buses are a must. I y main concern as a bus driver is gening students to and from school safely. love the children who ride my bus, and if I thought seat belts would make the bus safer for them. I'd consider helping install them myself. I don't think lap belts would make b u s s safer, though. There are several reasons why I think they might even d o more hann than g w d . One of the mast important nrgumenu against seat belts o n buses is the compartmentalized safety design of buses stnce 1977. & Nattonal Highway Traffic Safety Administration's regulations beginning in that year called for higherbacked, impact-absorbtng x a l s and padded reinforcement of those seats. Companmentalization w o r k when. upon Impact, an unbelted child slides forward on the seat and Into the back of the seat ahead. In contrast, a child with a lap belt will be thrown forward at great force, possibly causing severe injury to his or her abdominal region. Expens contend, and have testified before Congress, that young children aged five to seven may not have strong enough ~nternalorgans to withstand the pressure of a lap belt in a collis~on.Seat belts have caused crushed hdneys. nqhired bladders, and other intemal injunes in young children. I know that those who want seat belts in buses say that in an accident where the bus rolls over, belted students would be less likely to be thrown out of the bus. Think about this, though. If the bus came to rest on its side or roof, pupils could suffer serious head injuries when releasing the belts. In some cases h e i r heads could be as much as three or four feet from the ceiling. A fire in such a s~tuationcould be an even greater catastrophe. An injured child unable to unfasten the seat belt might be trapped in a burning bus. I agree that young children should be taught to use seat belts in c a n , but I think they can understand why that doesn't necessarily apply to buses. Children have the ability to reason. Parents should explan that buses are the safest vehicles on the road-at least 14 times safer than the famtly car. An average auto weighs only one-seventh as much as a bus does, and children transported in b u x s are above the normal impact and penetration zone of an automobile collision. In A l a b m n , there hasn't been a death inside a school bus stnce 1969, and nationally, the number of school bus fatallties IS decreasing yearly The decltne in falalities has many causes Among them drivers who maintain discipline on buses Keep~ngorder among 60 children on a bus is hard enough without the added responslbthty of a seat belt law A driver would have to make sure that students could get the belts on and off-and prcvent certain luds from usmg them as weapons or cuning them out o t the seats altogether Statistics show that children who ride buses are in the greatest danger as they get on and otf the bus, not w h ~ l ethey re tns~de In the last 53 years, most school bus fatalities have occurred tn load~ng and unloading rones, not in moving acctdents Some have happened because a passing motonst d ~ d nt stop, o r a bus dnver didn't see a small head In front o t a bus Better a n d m o r e diverse training f o r drivers, new mirror designs for buses. new crossing gates, and stricter and more f r q u e n t inspections could make buses safer. Public awareness is also an important safety factor. Parents must teach their children the importance of obeying the bus driver and maintaining good conduct on the bus. It's not seat belts that are needed in school buses. What is needed is an adult on each bus to control the chtldren so the bus driver can concentrate on the road and safe drivtng. FIGURE Vi-21 SCHOOL BUS RELATED FATAL ACCIDENTS AND RELATED FATALITIES FOR 1978 TO 1983 SCHOOL BUSES T h i s c a t e g o r y include6 both v e h i c l e s damigned a s buses and used in s c h o o l transportation a s well a s v e h i c l e s of a n y body t y p e f u n c t i o n i n g a s school buses. (Flgure VI-21 i n c l u d e s a c c i d e n t s , i n v o l v e m e n t s and o c c u p a n t f a t a l i t i e s f o r only t h o s e school buses designed as b u s e s ) . 700 600 I n F A R S , a 'school bus-related a c c l d e n t * 1s a n y f a t a l a c c l d e n t In whlch a vehicle functtonlng as a s c h o o l b u s IS e r t h e r d ~ r e c t l y o r indirectly ~ n v o l v e d . T h u s t h e c a t e gory lnciudes, f o r e x a m p i e , any a c c ~ d e n tin whlch a c h i l d a l s e m b a r k rng from a s c h o o l b u s IS s t r u c k by another vehlcle. The fact that the c h l l d w a s s t r u c ~a f t e r e x ~ t t n g t h e bus classes the acctdent as school b u s - r e l a t e d e v e n t h o u g h t h e bus was nelther a struck 7?r str~klllg v e h t c l e . O c c u p a n t s o; t h o s e v e h ~ c l e s w h l c h d ~ dnot h a v e t h e t v p ~ c a l s c h o o l bur body type but w h ~ c h were f u n c t l o n l n g a s school buse?, were ~ n c l u d e dw r t h s c h o o l bus o c c u p a n t a School bus-related accidents h a v e a t e a d ~ l yd e c r e a s e d s i n c e 1 9 7 8 (Figure V I - 2 1 ) . Each year since 1978, between 9 and 23 occupants dled in a c h o o l b u s a c c ~ d e n t s . S i n c e 1 9 8 0 . fatal accidents involving school huge. d r o p p e d 2 3 . 8 p e r c e n t . The n u m b e r o f s c h o o l b u s e s i n v o l v e d in n o n o c c u p a n t I a t a l a c c ~ a e n t s% a s a ! I t s lowest point s ~ n c e 1978. A s m a l l e r proportion ( 5 p e r c e n t ) of t h e occupant. of school buses t h a t were i n v o l v e d in f a t a l a c c t d e n t s In 1983 w e r e t h e m s e l v e s k ~ l i e din t h o s e a c c l d e n t s t h a n was t h e c a s e f o r a c c l d e n t i n v o l v e d o c c u p a n t s o f a n y of t h e o t h e r v e h ~ c l e t y p e s considered In this chapter. Table VI-12 d i s p l a y s whether d a t a f o r s c h o o l - t y p e buse,. o r not they were used as school 500 400 SCO 200 too 0 1 - School Burar Invoked Fatal Accrdents , - lnvolv~ngSchool Buses I -r: School Buses s~Occupant Fatolrtre~ /d -7 Ichool Bus., ,?I Nonoccupant Fatal Andent. TABLE VI-12 Vehicles Nu& r P Occupants 0 Nunber Occupant Fatalities Nunbe r 0 Buses ' School Bus C r o e s C o u n t r y / I n t e r c i t y Bus T r a n s f t &s Other Onknown Burr 306 Total I 100.0 1.099 100.0 53 100.0 Source: U.S. Department of Transportation, Fatal A c c i d e n t Reporting System, 1983 Reproduced by the Library of Congress, Congressional Research Service. T h e 99 achool ku accidents in 1 9 1 3 r e a u l t a d In 1 3 9 d a a t h r . 5 0 people r h o r e r e kllled r a r e oono c c u p a n t a a n d 89 r e r e v e h i c l e o c c u p a n t e . b u t only 1 3 of t b a a e r a r e achool bus occupanta. I n Figure V1-22, vhlch p r e s e n t s a f u r t h e r d i e t r i b u t l o a of t h e r e f a t a l i t l a * . # o t h e r d r i v e r g and ' o t h a r p a a e e n 6 a r m w e r e o c c u p a n t a of involved v e h l c l e a t h a t r e r e n e i t h e r achool b u e a n o r v a h l c l e e b e i n g uaod a# achool bu.8~. FIGURE VI-22 DISTRIBUTION OF FATALITIES IN FATAL ACCIDENTS INVOLVING SCHOOL BUSES (139) T h e a g e d l a t r i h u t i o n of t h e 4 4 p e d e r t r i a n a k i l l e d in t h a r c h o o l bur a c c l d e n t r is d e p i c t a d In F l g u r r V I - 2 3 , Children under nlne accounted for almoat t r o - t h i r d # of t h e pedamtrtan fatalitie.. OWtR DRIVER OlHER PASSENGER PEDL5TRIAN MUCYCLIST FIGURE VI-23 PEDESTRIAN FATALITIES IN FATAL SCHOOL BUS ACCIDENTS (44) UNDER 5 5-9 10-14 AGE 15-l7 18 & UP SCHOOL BUS RELATEC FATALITIES 1975 1976 1977 1978 1979 1980 1581 1982 1983 1984 1985 ------Occuoants o f School Bus Drivers Passengers TOTAL Pedestrian S t r u c k by School Pus Struck by Other Vehicle Other TOTAL Occupants o f O t h e r V e h i c l e Drivers Passengers TCTAL B i c y c l is t s GRAND TCTAL FATALITY RATE ( p e r 1CO m i l l i o n v e h i c l e m i l e s ) PASSENGER CAR OCCUPANTS MOTORCYCLE OCCUPANTS BUS OCCUPANTS SCHOOL BUS CCCUPANTS TRUCK CCCUPANTS 2.5 2.4 2.4 2.4 2.4 2.5 2.0 1.9 - 2.4 - 14.3 14.8 18.2 19.7 2 2 . 2 28.6 32.7 37.1 35.5 1.0 1.3 0.7 0.7 Q.6 0.7 1.2 .5 0.8 -C.6 0.7 0.5 0.6 0.6 0.5 0.4 .3. 0.5 2.1 2.1 2.2 2.3 2.4 2.1 1.7 1.7 1.6 - SINGLE UNIT TRUCK CCCUPANTS 2.3 2.3 2.3 2.5 2.6 2.1 1.8 1.8 1.7 COMB1NATI ON TPUCK KCUPAKTS 1.2 1.4 1.4 1.4 1.5 1.5 1.4 1.2 1.1 Source: National Center for Statistics and Analysis, National Highway Traffic Safety Administration Note: the term "school bus related accident" refers to those fatal accidents in which a vehicle functioning as a school bus is directly or indirectly involved. A child struck by another motor vehicle after exiting the school bus is classified as a school bus related accident even though the schcol bus is not a struck or striking vehicle. American Academy of Pediatrics Policy Statement: School Bus Safety 1. Children can't handle the buckle adeIn 1970,the Pmerican Academy of Pediatrics, quately. (The American Academy of Pediatrics in a supplementto kdiah?cs, reviewed the laws, notes that allchildren,given their fcrrniliarity with regulations, and practices in school busing in the seat belts and buckles, should be able to satisUnited States! This survey was carried out by factorily buckle and unbuckle seat belts.) Physicians for Automotive Safety. The informaThe buckles would entrap children and 2. tion available at that time (from 46 states) could lecm them dangling from the ceiling in indicated that 14,709,000students were being (l'hisis accidentsin which the bus is ave-ed* transported in a total of 203,994vehicles.'Recent true, but it is still preferable for children to be data now indicate that approximately 22 million strapped in rather than thrown out o f the seat or pupils are transported daily to and from schools the vehicle at the time o f a n accident.) in the United States in nearly 400.000 school 3. Wearing seat belts would produce internal buses.= injuries. (With the restraints presently crvailable. Based in part on the recommendationsresultany school aged child can safely wear a seat ing from the 1970survey, the National Highway belt .) Traffic Safety Administration in February 1973 4. Children could use the belts as weapons. issuedthe FederalMotor Vehicle Wety Standard (Children have much better weapons uvdable. (FMVSS-222),which became effective in April including lunch boxes and books. In addition. 1977.That standard prescribed passive protecthe newer, lightweight, smaller,retractable seat tion for school bus passengers and looked spebelts now available are unlikely to be effective cifically at: 1) the seat and seat anchorage as weapons.) strength; 2) the seat and restraining barrier Based on a review of the &able and extenheight and surfacearea; and 3)padding on sursive data, the American Academy of Pediatrics faces within occupants' head space. supports the following changes in School Bus The National Highway Traffic Safety AdrninSafety Standards: istration subsequently has denied a petition from 1. Seat backs should be elevated to 28 inches. Physicians for Automotive Safety that the This is foux inches above the height now manFMVSS-222include requirements for anchorages dated by federal regulations and will support forseat belts. Seat belts presently are required in and cushion a child's head and neck. vehicles weighing 10,000pounds or less with a 2. All seat bucks and tops should be padded maximum passenger capacity of 16.Seat belts with firm materials that adecnlritely absorbs are not required for larger school buses. impact. The padding should completely cover The primary reason given for not requiring seat the entire rear of the seat in addition to the top belts in buses weighing more than 10,000 pounds is that the number of "inside bus fatalirail. The padding also should be placed on all ties" nationally does not justify the expense and stanchions and "modesty panels." Seat con-, maintenance of seat belts. However, in 1982 struction shouldbe designed to eliminate shthere were 140deaths resulting from school bus or unyielding objectsthat could causeor worsen accidents. Included in this total were 60 pupils, inlurv. 5 bus drivers and 75 "others." In addition, there 3. Seat belts should be required on all newlywere 7,000 reported injuries; 4.200 of those manufactured schoolbuses-regardless of their injured were s t ~ d e n t sTherefore, .~ should the size and the number of pupils transported. nurnber of deaths alone not justify changes, the 4. Adequate and appropriate bus driver trainpotential for a reduction in the number of ing should be mandatory in all school districts injuries, andbr in the seriousnessof those injuries, and should include provision for health screenwould seem to make further changesin FMVSSa periodic basis, including vision and ing on 222 highly desirable. hearing evaluations. Unsupported argumentshave been presented in a n effort to prevent seat belt installation on school buses. Amonu - these are: 01985 American Academy of Pediatrics, Reproduced by the Library of Congress, Congressional Research Service with permission of copyright claimant. 19 AIZXICAN ACADEMY OF PEDIATRICS Committee on School Realth Joseph R.Zanga, M.D., Chairman Michael A. Donlan. M.D. Jeny ?Jewton, M.D. Maxine M. Sehring, M.D. Martin W.Sklcdre, M.D. John Trieschmunn. M.D. Liaison Representatives: Janice Hutchinson, M.D., American Medical Association Betty McGinnis, M.A., CPNP, National Association of Pediatric Nurse Associates and Practitioners Marjorie Hughes, M.D.,Amelican SchoolHealth Associalion ThomasColeman.M.D., Section on Child Development Jerry C.Jacobs, M.D.,Section on Rheumatology Charles Zimont, M.D., American Academy of Family Physicians Committee on Accident and Poison Reventlon Joseph Greensher, M.D., Chairman Regine Aronow. M .D. Leonard S. Krassner, M.D. Ronald B. Mack. M.D. H. Biernann Othersen. Jr., M.D, Mcnk D. Widome, M.D. Liaison Representcrttves: Andre l'Archweque, M.D., CancdianPedicrtric ~ e t y Gerard Breitzsr,D.O..American College of Osteopathic Physicians Jerry J. Foster,M.D.,Section on Emergency Medicine Joyce A. Schild, M.D., Section on Otolcnyngolosy Chuck Williams, Product Safety Association References: Charles S, Shelness A: H a w Scde Is Pupil Tramportation?Study of Laws, Regulations, and hact i c s in School Busing in the United StatesCcnried Out by Physicians for Automotiw Safety. Sup plement to Bdiairics January 1970,Pcnt II, 45:1 2 Protection for School Bus Occupants. Issue Paper, U.S. Depadment of Transportation, September 1981; 83:39-46 3NationalSafety Council:SchoolBus Accidents. 1982.Accident krck, 1983ed.,Chicago.IL,p. 92. (cont.) National School frmsponation Association P.O. Box ZO.39 Sprlngflold, VA 2nU . The NSTA Position - \ The National School Transportation Association's prime concern is the safety of the children its members transport daily. In fact, the Association was founded and continues because they are able to get students to and from school in the safest possible manner. Traveling in today's well-equipped, shiny yellow bus is seven times safer than taking the same trip in the family automobile. This is why NSTA supports the National Highway Traffic Safety Administration's position on occupant protection in school buses. Our association is not so much opposed to the use of safety belts in school buses as it is supportive of the concept of compartmentalization. We came to this position after years of tests, experiments and studies resulted in the NHTSA concluding that compartmentalization provides an adequate level of safety protection. In contrast, there are no standards established for seat belts on large school buses. NSTA believes that compartmentalization containing children within a structurally reinforced passenger compartment of fully padded, high-back seats and crash barriers is preferable to any form of containment that relies upon the use of safety belts or other similar restraining devices. Furthermore, we believe that the studies and excellent safety record of school buses support and those that compartmentalization. The real safety problems in school transportation need to be thoroughly addressed by the industry, schools, parents and the public are the the loading zones. fatalities and injuries that occur where children get on and off the buses Those of us who work with the children and school buses every day feel that every new Item that is added or changed on school buses should be well tested and engineered prior to being mandated as a regulation. This is why NSTA will continue to support the compartmentalization concept until documented research establishes that seat belts on school buses will raise the level of protection for the occupants. NSTA is concerned that many interested and well-meaning individuals are not informed of the safety record of school buses, the safety features incorporated into school bus construction, and why seat belts are not mandated or needed on school buses. This is why the board of directors has approved a special edition of the National School Bus Report to address these topics. - - - - - - NSTA Board of Directors The National School Transportation Association was founded in 1964 by private school bus contractors to #'promote and foster the highest degree of safety in the transportation of school children." The Association represents approximately 40 percent of the nation's yellow school bus fleet The bulk of these private contractors, many 0' them from second- and third- generation firms, are members of the NSTA as well as state contractor r e -