[Return to Home Page ] [Title Page ] [Preface to 1996 Edition ] [About the Author ] [Foreword to 1990 Edition ] [Table of Contents ] [Main Body ] [Appendix A. Compartmentalization ] [Appendix B. TRB Special Report 222, May 1989 ] [Appendix C. Endorsements ] [Appendix D. Testimonials ] [Appendix F. Legalities ] [Appendix G. Guidelines to Seatbelt Implementation] [INDEX ] [Responses To This Site ] [Related Sites ]
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APPENDIX E. STUDIES AND RECOMMENDATIONS
The seatbelt-related positions taken by related federal agencies seem to be disparate and not at all cohesive. In fact, even the same agency seems to change its position, depending upon what reference one reads, and when it was written. With such confusion "at the top," charges of disinformation are understandable, on the part of those who try to understand what is the best position to take on the school-bus-seatbelt issue.
STUDIES/RECOMMENDATIONS NOT SUPPORTING NEED FOR A SCHOOL-BUS-SEATBELT MANDATE
The following studies do not support the need for a mandate to implement seatbelts on school buses.
National School Transportation Association (NSTA) position
p. 144: "In light of all the accumulated evidence, why do we not have seatbelts on buses? THE SCHOOL TRANSPORTATION INDUSTRY HAS LOBBIED AGAINST SEATBELTS BECAUSE IT AFFECTS THEIR PROFITS. It is the old story: MONEY vs. SAFETY....
"THE NATIONAL SCHOOL BUS CONTRACTORS' ASSOCIATION (NATIONAL SCHOOL TRANSPORTATION ASSOCIATION, or NSTA) THANKS ITS MEMBERS FOR HELPING TO DEFEAT THE FEDERAL STANDARD THAT WOULD HAVE MANDATED 28 [inch] HIGH BACKED SEATS, SEATBELTS AND SEATBELT ANCHORAGES in all new school buses:
"'NSTA is enjoying a major victory due to the elimination of mandatory seatbelt anchorages from Docket #73-3 Notice 5.....
"'Docket #73-3 originally contained...seatbelts. Fortunately, Notice 3 eliminated...seatbelts. THIS WAS DUE TO THE INTENSE PRESSURE APPLIED BY THE NSTA BOARD OF DIRECTORS, WORKING IN CONCERT WITH PUBLIC SCHOOL OFFICIALS NSTA WISHES TO SAY THANKS TO ALL OF YOU for your help, letters, telegrams, trips to Washington again and again and again. THIS EFFORT WILL SAVE EVERY PURCHASER OF SCHOOL BUSES OVER $300 PER BUS...
"'NSTA AND ITS BOARD MEMBERS SPENT WELL OVER $100,000 OVER THE TWO AND ONE-HALF YEAR PERIOD IN TRAVEL, OFFICE AND PERSONNEL EXPENSES TO REACH THIS HAPPY CONCLUSION. If you feel as pleased as we do, NSTA could use some financial assistance to pay the numerous obligations incurred for Docket #73-3 Notice 5'" (National School Transportation Association Newsletter, Feb. 1976).
[Money talks. View the above against the fact that NCSSB is in debt. IF YOU SUPPORT PUTTING SEATBELTS ON SCHOOL BUSES, BACK YOUR FEELINGS WITH DONATIONS TO APPROPRIATE GROUPS!--S.L.]
National Transportation Safety Board (NTSB) Position
p. 142: Federal " ... standards issued in April 1977 don't require passenger seat belts on school buses. What the standards do require, in addition to other crash protection measures, are seats and floors strong enough to support 'the after-market installation and effective use of passenger seat belts, at the purchaser's option.'
"An average of 27 students die in school bus accidents on the road each year, and six years have passed [article written in 1983.--S.L.] since the standards were issued. Still, when the National Transportation Safety Board (N.T.S.B.) issued new safety recommendations for school buses this fall, it was the same old song. Estimating that within four or five years most large school buses will meet the 1977 standards, the safety board said 'it does not believe there is sufficient justification at this time' to recommend that seat belts be made mandatory on large school buses.
"And once again it's up to you to decide whether you want to install seat belts on that fleet of brand new buses you just bought. Most boards, by the way, decide not to. [Oh, where are the leaders?--S.L.] But those who do apparently have the moral support--if not the official recommendation--of N.T.S.B....
p. 142, continued: "But what about a federal oversight group like N.T.S.B., whose mission is, we assume, to help ensure safety? Shouldn't the safety board be standing just as squarely in the opposite corner?
"That's where safety board members want to be, suggests Sweedler, who is director of N.T.S.B.'s Bureau of Safety Programs; they just haven't quite arrived there yet. Sweedler explains 'I would love to be able to justify the need for seat belts on all school buses, but I can't in terms of the data at this time.' [All the studies to date are insufficient, in my view. Therefore, rationale should go beyond available data.--S.L.]
"Most school bus accidents fall in the 'minor to moderate' category, says Sweedler, and that's just where the 'other restraints' seem to do the most good. But to date, investigations of school bus accidents have focused on pre-1977 school buses [article written in 1983]--the newer, presumably safer, ones just haven't been around long enough to produce sufficient accident data yet. And that, ironically, is the rub. 'Our biggest problem,' Sweedler says, 'is that there aren't enough accidents for us to collect data on. And I wish that I could say it's an even bigger problem than it is.'
"Problem or not, N.T.S.B. now is investigating crashes involving buses built since 1977 to find out
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whether existing federal standards are stringent enough. It might take years [Note: There are other reasons for having seat belts, which are going ignored in this argument. How about keeping children seated, so they don't cause accidents by distracting drivers? How about the continuity of approach to seatbelt usage by society--especially by the 'educational' portion thereof?--S.L.], but Sweedler predicts cautiously that, once the facts are in, N.T.S.B. might change its position on seat belts. School board members can help, he says, by reporting school bus accidents--especially the less catastrophic ones that don't make the headlines--to him. The address: Barry Sweedler, Bureau of Safety Programs, National Transportation Safety Board, Washington, D.C. 20594
"'We're big advocates of child safety seats,' Sweedler says. 'Statistically we know that every person will be in an accident sometime during his life. From that standpoint alone, we'd like to see kids using seat belts on buses just to reinforce the need to use them in the family car.'
"Meanwhile, of course, until there are enough fatally injured schoolchildren to make up a statistically significant research sample, seat belts will remain an option on school buses" (From The American School Board Journal, circa 1983).
Aspects of reduced danger when children are kept seated, due to fewer driver distractions, are not mentioned in the above article. Though educational aspects of using seatbelts on school buses are mentioned, they do not receive due emphasis. Humane reasoning should not be confined to statistical data and interpretations thereof. Where safety is concerned, it is best to err on the side of caution.
National Transportation Safety Board Recommendations to Governors, 1983
p. 150-4: "Although the overall safety record of schoolbus transportation in this country has been good, the protection of schoolbus passengers in crashes remains a matter of continuing and intense concern to the National Transportation Safety Board and others involved in schoolbus safety. Parents have little direct control over the crash protection features of the school vehicles their children must ride; furthermore, children's bodies are more vulnerable to certain types of crash injuries than those of adults. Therefore, it is important that crash protection to the maximum practical extent be built into school vehicles.
"Between 1967 and 1983, the Safety Board has investigated and issued recommendations concerning 18 major accidents involving schoolbuses or multipurpose passenger vehicles used to transport school children. These vehicles carried a total of 620 students, ranging in age from pre-kindergarten through high school. Seventeen of the 18 accidents were fatal; 115 students were killed. Another 383 students were injured in the 18 accidents. Six schoolbus drivers were killed, and nine were injured.
"Based on data collected through the National Highway Traffic Safety Administration's (NHTSA) Fatal Accident Reporting System (FARS), there are, on average (based on 1975 through 1978 data), about 15 fatal schoolbus accidents annually, resulting in a total of 27 student passenger fatalities and 146 student passengers. [sic. I'm not sure what they're trying to say, here. Did they somehow drop some such phrase as 'being injured'?--S.L.] In addition, National Safety Council (NSC) statistics for 1975, 1976, and 1977 show that about 40 students are killed each year while waiting for or getting off or on schoolbuses. For the same years, NSC data show that about 2,8000 nonfatal but injury-producing schoolbus accidents occur each year, resulting in about 3,900 student passengers injured. In 97 percent of these accidents, there are no more than three passengers injured; in [?74 percent?; illegible copy], only one passenger is injured. About 90 percent of the injuries in these accidents are minor to moderate. Fatal schoolbus accidents represent less than 1 percent of all injury-producing schoolbus accidents. Based on FARS data, 78 percent of the fatal accidents result in no more than three passenger deaths; in 58 percent, only one passenger is killed.
"There are estimated to be between 300,000 and 400,000 schoolbuses in use in this country, and about 90 percent of them are of the large, conventional type (greater than 10,000 pounds gross vehicle weight rating (GVWR). The remaining 10 percent are small vehicles weighing less than 10,000 pounds GVWR, either passenger vans, designed to carry 10 to 16 passengers, or smaller versions of the conventional schoolbus ('minibuses'). Based on a review of 60 fatal schoolbus accidents included in the FARS data system, 15 percent of both deaths and injuries in fatal schoolbus accidents occur in these small school transportation vehicles.
"Certain aspects of schoolbus(1) design have been regulated by Federal Motor Vehicle Safety Standards (FMVSS) since the early 1970's. In 1974, the U.S. Congress mandated significant improvements in Federal schoolbus regulations(2) and, as a result, the amended several safety standards and issued several additional standards. Now [1983] 30 of the 50 FMVSS' apply to schoolbuses; 6 of these 30 are of particular importance in schoolbus crashes. These set performance requirements for schoolbus windows and emergency exits, rollover protection, body joint strength, fuel system crash integrity, flammability of materials, and seat and occupant restraints.
"In addition to these vehicle performance standards, the NHTSA issued, in the early 1970's, guidelines to the States for school transportation safety in general. Highway Safety Program Standard (HSPS) 17 -- Pupil Transportation Safety addresses such aspects as color and markings for easy discernment of schoolbuses; effective lights and mirrors; driver and pupil safety training; safe procedures for loading and unloading; seating accomodations for each passenger; and use of driver and passenger seatbelts.
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p. 151 (continuing): "In the important area of occupant restraint for crash protection, the Federal standards require that all large schoolbuses manufactured since April 1977 provide:
-- A forward-facing seat for each passenger
-- Seats (or, for front seat passengers, restraining barriers) designed to meet certain specific minimum dimensions, strength, and seat-to-seat spacing requirements; and
"The seat strength requirements are adequate to support the after-market installation and effective use of passenger seatbelts, at the purchaser's option.
"In 1978, the Safety Board [NTSB] recommended that the NHTSA review available accident statistics to determine the effectiveness of the post-1977 vehicle seating standards in reducing fatalities and injuries to schoolbus passengers. In 1980, the NHTSA released the results of such an analysis.(3) Because at that time only a small percentage of the nation's schoolbuses had been manufactured after 1977, and because fatal and injury-producing schoolbus accidents are in any case relatively infrequent, the conclusions of the study were based on data drawn from analysis of accidents involving pre-1977 schoolbuses. The study concludes that:
[Footnotes:]
1) "For the purpose of applying Federal safety standards, a 'schoolbus' is defined as a vehicle, designed for carrying more than 10 persons, that is sold or introduced in interstate commerce for purposes that include carrying students to and from school or related events."
2) "Motor Vehicle and Schoolbus Safety Amendments of 1974, P.L. 93-492."
3) "Statistical Evaluation of the Effectiveness of Federal Motor Vehicle Safety Standard 222: School Bus Seating and Crash Protection (Center for the Environment and Man, Inc. for the National Highway Traffic Safety Administration, U.S. Department of Transportation), Final Report (October 1980)."
p. 152, conclusions: "[The post-1977 schoolbus seating and restraint standards] are probably very effective (about 60 percent injury reduction) in the vast majority of schoolbus accidents, which usually involve minor damage to the bus, with at most a few passengers injured at the [minor to moderate injury] level. In the few violent schoolbus accidents that produce fatalities, [the standards have] lower effectiveness--about 29 percent injury reduction. The [standards have] only limited effectiveness in the extremely small subset of very violent accidents involving rollover, crashes with trains, etc. {But rollovers are quite common, compared to train crashes, I believe! Rollovers are also involved in 50% of fatalities and in 35% of front-end accidents!!--S.L.]
p. 152: "The Safety Board has reviewed this analysis and believes that the inferences drawn in it are sound. The Board estimates that within about 4 to 5 years [written in 1983] most large schoolbuses on the road will meet the Federal seating standards. Because preliminary analysis indicates that these standards appear to be effective in eliminating or substantially reducing the majority of schoolbus passenger injuries (those which are minor to moderate), the Safety Board does not believe there is sufficient justification at this time to recommend extending the mandatory passenger restraint system requirements to large schoolbuses.
"Nevertheless, the Safety Board would strongly support decisions by parents and State and local school authorities to install occupant restraint systems in their large schoolbuses on an after- market basis. The passenger seats in all post-1977 large schoolbuses are required to be designed in such a way that they will support the installation and use of seatbelts. Many pre-1977 schoolbuses can be modified to support seatbelt installation also. [The May 1989 TRB Special Report 222 (National Research Council; NRC) recommends that buses manufactured before April 1977 be phased out as quickly as possible.--S.L.]
"The Board stresses that a decision to install seatbelts in large schoolbuses must be accompanied by a strong and continuing commitment to educate students in the importance of using the seatbelts and using them properly. Such instruction needs to be complemented, in the case of younger children especially, by adequate adult supervision to ensure that seatbelts are properly positioned on each child's body and snugly secured....
p. 153: "It is also important that every schoolbus driver wear the seatbelt that is provided, whenever the schoolbus is moving. Not only is the life of the driver endangered by nonuse of the available restraint, but also the ability to maintain control of the schoolbus in an emergency or crash is seriously jeopardized if the driver is thrown from his or her seat. In a 1972 crash in Virginia, ... a car ran a stop sign and hit a large schoolbus. The bus ran off the road and partially overturned. All the bus occupants were injured. The Board found that 'the second collision of the bus, into the embankment, was caused by loss of driver control; the nonuse of available seatbelts by the driver prevented the regaining of control.'
"As a result of this accident, the Safety Board recommended to each State that they enact appropriate requirements for the provision of seatbelts at the driver's position in all schoolbuses and require their use at all times when persons are being transported. One State responded, saying that its Board of Education would require schoolbus drivers to wear their seatbelts. A county in another State responded similarly. Since that time, the Board has investigated 16 major schoolbus accidents in 10 States; in many of these, the drivers were not wearing their
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[Note: I think the above paragraph strongly implies that children should be
required to use seatbelts. I believe that if children were required to use seatbelts,
and saw a driver who did not, they would "get on his case." This
would tend to improve safety for all.--S.L.]
p. 153: "Therefore the National Transportation
Safety Board recommends that the Governors of the 50 States and
the Mayor of the District of Columbia:
"Review State laws and regulations and take any necessary legislative
action, to ensure that passengers in small (more than 10 passengers and
less than 10,000 GVWR) schoolbuses and school vans are required to use
available restraint systems whenever the vehicle is in motion; ensure that
all users of such vehicles are aware of and comply with these provisions.
(Class II, Priority Action)(H-83-39)
"Review State laws and regulations, and take any necessary legislative action,
to ensure that vehicles designed to carry more than 10 passengers and weighing
less than 10,000 pounds GVWR, used to transport children to and from school,
school- related events, camp, day care center, or similar purposes meet
all Federal Motor Vehicle Safety Standards applicable to small schoolbuses.
(Class II, Priority Action)(H-83-40)
"Review State laws and regulations, and take any necessary legislative
action, to ensure that drivers of schoolbuses are required to wear their
seatbelts whenever the vehicle is in motion, that all schoolbus drivers
are made aware of this requirement, and that periodic monitoring of schoolbus
driver seatbelt use is conducted. (Class II, Priority Action)(H-83-41)"
[See the above note regarding the tendency of children who must wear belts
to keep a belt on the driver, too.--S.L.]
(Letter (1983) from NTSB to Governors of 50 States and 4 Territories
and the Mayor of the District of Columbia, signed by Jim Burnett, Chairman.) National Transportation Safety Board (NTSB) Speech to National
Safety Congress
pp. 156-61: "In the 7 years since the 1977 schoolbus standards
came into being, the Safety Board [NTSB] has investigated 11 accidents
involving schoolbuses or schoolvans. The most frequent type of accident
involved a schoolbus struck headon by a loaded tractor semitrailer. The
second most frequent accident was the schoolbus rollover. In these 11 major
accidents, schoolbuses carried about 300 students ranging in age from kindergarten
through high school, plus the 11 drivers. 12% of the students were killed.
(That is 36 students.) 70% of the students were injured. (That is 210 students.)
The driver's chance for survival in these accidents was less than 50%:
6 drivers were killed and 5 drivers were injured.
"In 9 of 11 accidents, the busdriver was not wearing a seatbelt.
Not only is the life of the driver endangered by non-use
of an available restraint, but also the ability to maintain control of
the schoolbus in an emergency or crash is seriously jeopardized if the
driver is thrown from his or her seat....
p. 157: "On January 10, 1984, a 65-passenger 1979 schoolbus
carrying 15 occupants (ages 5 & 6) was struck headon by a tractor semitrailer
loaded with steel. The schoolbus overturned and came to rest on its roof.
The bus body partially separated from the chassis and the roof collapsed
to the engine firewall at the front of the bus. A small engine fire which
developed in the upsidedown chassis was quickly extinguished, but not with
the fire extinguisher on board the bus. The bus fire extinguisher was inaccessible
in the right front of the wreckage.
p. 157: "The truckdriver and the schoolbus driver died of ruptured
hearts. Fortunately, only 5 of the 15 children were seated on the left
side of the bus, the area of major impact. The only child fatality, as
well as the most severely injured child, were both seated behind the driver.
Both had head injuries. Of the 15 children on board the Rehoboth schoolbus,
only 3 sustained moderate to severe injuries, 9 had minor injuries, and
2 were actually uninjured. If larger high-school-aged passengers had been
seated in the front, they might have suffered serious or even fatal injuries
when the front of the roof collapsed during the rollover.
[This accident is similar to the 31 January 1990 crash of a school bus in Monrovia,
New York. A 1986 bus (delivered one year before New York required seatbelts)
veered off the road, and its top was sheared off. Kindergarten and first-
grade students suffered many head injuries and basic trauma. More deaths
probably would have occurred if the students had been taller. Ironically,
if students had been older and had been wearing the yet-undesigned and
unavailable 3-point restraint systems, they probably would have been decapitated.
This suggeests that no system provides the optimum safety under all scenarios.--S.L.]
p. 157: "If both drivers and the two passengers seated
in the window seats of the first three rows on the left side of the schoolbus
had been using seatbelts, they probably would not have benefited by them
because of the degree of crush at their seating locations. The use of seatbelts
by all other occupants would have prevented them from being thrown out
of their seats and onto the ceiling as the bus collided with the truck
and rolled over. However, the children ------------------------------------- page break -------------------------------------
Page Count: 37 of 79 Page 27 sitting next to the windows still would have contacted the sidewalls,
the seat backs, the windows and window frames either during the initial
collision with the truck, during the rollover, or both....
p. 161: "Recently,
the Safety Board [NTSB] started an indepth study through its field offices
across the U. S. of injury producing accidents involving post 1977 standard
schoolbuses. This study is being undertaken to more closely examine injury
causation in schoolbus accidents. Some preliminary results indicate that
single vehicle accidents involving driver loss of control and a rollover
are common; that the severity level of injuries are being reduced; that
head injuries predominate from impact with shattered side glass side [sic.--
S.L.], interior walls and overhead surfaces; that falls into the aisles
are common; that students can identify the padded vertical seatback support
and the top of the seat as the part of the seat which injured them; and
that latches for emergency side windows and support for these windows in
the open configuration may need improvement. Some areas which might be
explored are: Increased padding on side, rear, and overhead interior surfaces;
more energy absorbing seat padding; more forgiving window and window structures;
reduced fire potential from engines in an upsidedown configuration; reduced
rollover potential in schoolbuses and schoolvans, and a study of whether
body/chassis separation is necessarily beneficial in a catastrophic collision."
[It is sad to see no mention at all of the potential for seatbelts to
save lives, in the above summary paragraph. Nonttheless, this speech shows
that NTSB supports districts' choices to install seatbelts, despite its
not supporting mandatory installation and usage of seatbelts.-- S.L.]
(15 October 1984 speech by Ms. M. E. Jacobs, Chief, Highway Accident Division,
National Transportation Safety Board, 202/382-6850.) National Highway Traffic Safety Administration (NHTSA), No Seatbelt
Mandate
pp. 163-77: "NHTSA believes that the occupant protection required in school
buses manufactured after April 1, 1977, plus the inherent safety of a highly
recognizable vehicle that travels on a regular route, provide a high level
of safety. There is insufficient data available to demonstrate whether
safety belts would increase occupant protection. [As there is insufficient
data on how many school bus accidents are caused by drivers who are distracted
by students moving about, etc. And, as there is insufficient attention
paid, in the quoted argument, to the educational benefit of buckling up
in any moving vehicle, especially one owned by an educational institution!--S.L.]
The number of school bus occupant deaths and serious injuries is so low
that assessing the extent to which safety belts could either prevent deaths
or injury or cause it is not feasible. [Better studies of dummies, etc.,
in artificial conditions might provide better insights. The problem seems
to be the cost of good studies. Ten or eleven deaths of school children,
per year, is not insignificant. Were the Challenger-accident-related deaths
insignificant? What would we have paid to avert that tragedy? How many
"potential Einsteins," "potential Gershwins," "potential
Norman Rockwells," and such are we losing per year, due to this obstinacy
about seatbelts?-- S.L.]
"In view of the effectiveness of the current safety standards,
and the excellent safety record of school buses generally, we do not believe
that a Federal requirement for safety belts in large school buses is warranted.
The National Transportation Safety Board reviewed this matter in 1983 and
found that current NHTSA standards appear to be effective in eliminating
[No, not in eliminating. Strongly disagree.--S.L.] or substantially reducing
[In reducing, perhaps; but more remains to be done.-- S.L.] the majority
of school bus passenger injuries....
"It is important to emphasize that the Federal standards specify the minimum safety
requirements [Is your school board satisfied with minimal safety compliance?--S.L.]
applicable to school buses. Nothing prohibits a State or local jurisdiction from
purchasing buses equipped with safety belts" (From Executive
Summary excerpts, Safety Belts in School Buses, June 1985, NHTSA, Traffic
Safety Programs, Wash., D.C.). p. 164, ff.: [Excerpts from the body of the above-cited report follow:]
Some parents also feel that children who have been taught to use child
safety seats and safety belts in automobiles will get out of the habit
if they ride regularly in a school bus that has no safety belts.
"In 1983, 390,000 school buses transported 21,500,000 pupils daily
[averages 55 students per bus.--S.L.] and accumulated three billion miles
of travel over the course of the year. Given this tremendous exposure to
all types of traffic and weather conditions, it is not surprising that
school buses, on occasion, are involved in accidents. Fortunately, the
overwhelming majority of these accidents are minor, involving only property
damage or minor injury to the bus occupants. For example, from a survey
of State departments of education and State traffic authorities, it is
estimated that in 1983 there were 48,000 school bus accidents, but 46,000
involved property damage only.... Less than half of these accidents were
serious enough to warrant a police report, as reported in [Table 1]. ----------------------------------- page break ---------------------------------------
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*These are only ESTIMATES. In 1983, there were 3,300 ESTIMATED injuries, according
to National Safety Council. Once they began using actual reported injuries,
the number jumped drastically to 8,400 in 1984 - and NOT ALL INJURIES are
reported. Many states do not require an accident to be reported if there
are only "minimal" injuries or property damage. Countless injuries
go unreported every year. Many states do not report accidents which occur
on field trips or sports trips. Accidents involving these "activity"
buses are responsible for 50% of all fatal bus accidents ... [This footnote
to Table 1 seems to have been added by either Carol Fast, Laura Schwartz,
or some other NCSSB worker.--S.L.]
p. 164: "From NHTSA's National Accident Sampling System (NASS) and the
Fatal Accident Reporting System (FARS), we have estimates of the number of police
reported school bus accidents and their injury consequences. FARS gives us absolute
counts of the number of people killed in school bus accidents. (See Table 1.)
p. 166: "What these statistics illustrate so dramatically is that very few
school bus passengers are killed or seriously injured. [But, try telling that to a grieving
parent!--S.L.] In 1983, 42,589 people were killed in traffic accidents (17 were school
bus occupants).... In 1983, approximately 166,000 people were seriously
injured in traffic accidents, 30 were school bus occupants.... For a wide
variety of reasons (protective laws, size of the bus, driver selection,
and training, etc.) school bus transportation is very safe. In the very
few accidents where there are bus occupant fatalities, it is often the
result of a bus being struck by a much larger vehicle (a heavy truck or
a train) or the bus going off the road and striking a large fixed object.
[I expected mention of rollovers, at this point, but that is covered below.--S.L.]
p. 167: "There is no body of data available to definitively demonstrate whether
safety belts in large school buses would increase occupant protection.
[Then, consider added safety of keeping passengers seated, and educational continuity
re seat-belt usage.--S.L.] The number of school bus occupant deaths and serious
injuries is so low that assessing the extent to which adding safety belts
could prevent death or injury (or cause it) is not feasible. [Better, but
costly, studies could be done of impacts with dummies. And, agencies could
choose to err on the side of safety and continuity of approach.--S.L.]
p. 167: "It is important to emphasize that FMVSS No.
222, "School Bus Passenger Seating and Crash Protection," specifies
the minimum safety requirements applicable to school buses. Nothing
prohibits a State or local jurisdiction from purchasing buses equipped
with safety belts. School districts that want to provide safety
belts in their large school buses are free to do so....
p. 168: "There are several
technical considerations that have entered the debate of protecting school
bus passengers in accidents. These considerations include the effectiveness
of safety belts; installation requirements for belts on new buses; and
retrofitting belts on buses. Also, the possibility of belt use on buses
increasing belt use in passenger cars has been raised. The discussion in
this section will focus on large school buses, as small school buses are
already required to have safety belts.
p. 168: "Because there are very few school bus passenger fatalities or serious injuries
in a typical year, there is very little information available to determine the effectiveness
of restraint systems. This is especially true of safety belts because less
than one percent of all large buses currently are equipped with belts.
[Perhaps the least expensive way to get better statistics is to equip more
buses with seatbelts, then!--S.L.] To attempt to explore the question of
effectiveness in greater detail, it is useful to examine the types of accidents
in which buses are involved.
p. 168: "Table 2 [here extracted only for Type-I school
bus data--S.L.] shows that 50 percent of the occupant fatalities in
school buses occur in rollover accidents and 14.7 percent of the
occupant fatalities occur in side impact accidents. It is in these types
of accidents that safety belts might be most likely to provide additional
safety benefits to school bus occupants. One reason for this is
ejections, which could be prevented by belts, represent one-fourth
of all fatalities. [It is not clear whether the underscoring
in this passage is in the original or has been added by NCSSB. This raises
the possibility that other underscored passages may be more reflective
of the NCSSB viewpoint than was the original passage. Time and cost limitations
preclude a rigorous resolution to this question.--S.L.] However, some school
bus accidents that involve fatalities are catastrophic so that it is unlikely
that any type of occupant protection would make any difference.... On the
other hand, there is a significant body of automobile accident data that
demonstrates that lap belts save lives and reduce injuries. [And, they
are used in commercial passenger aircraft.--S.L.] Overall, because of the
limited accident data on school buses and extremely sparce data on belted
occupants, estimates of how much additional protection might be provided
by safety belts on buses in rollover and side impact accidents are, by
necessity, conjectural. ----------------------------------- page break ---------------------------------------
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NUMBER OF AVER. ANNUAL EJECTIONS 3
SCHOOL BUS - FARS 1981-1983 - 34 Fatalities Source: NHTSA Fatal Accident Reporting System Data Base
[NOTES IN ADDITION TO TABLE 2:
Passenger-car data are interesting in comparison, but have been omitted
in this excerpt, for brevity and for as much clarity of presentation as
possible. Nonetheless, the Table 2 given on p. 169 of the NCSSB manual
lists the number of average annual ejections from passenger cars
as 5557. Reporting most of the table in terms of total statistics over
a three-year period, and then throwing in annual data, is a point of confusion.
Those annual data should be multiplied by 3, for an interesting comparative
calculation:
The average, annual number of ejections during accidents in passenger
cars is 5557; for school buses, that number is 3. Over three-year periods,
those numbers translate to 16671 and 9, respectively. Also, the p. 169
NCSSB Table 2 shows 72,376 fatalities in passenger cars, over the 1981-1983
period, v. 34 fatalities of passengers in school buses. So, the ratio of
ejections per number of fatalities, over identical periods, can be compared,
between school-bus and passenger-car data 16671 ------- = 23.0%, for passenger-car accidents 72376 9 ---- = 26.5%, for school-bus accidents 34
These calculations clearly show that ejection plays a highly significant
role in both passenger-car- and school-bus accidents.
Incidentally, a recent TV-news segment (CNN) mentioned that some disease
(I forget which, sorry; can you refresh my memory?) has recently been causing about
20 fatalities each year, in the U.S. -- and has therefore been given national
priority! HOW ABOUT THE SAME CONCERN FOR OUR CHILDREN!? Table 2 does not even
touch on injuries, whether or not "serious" (whatever that means; see
Index entry "Serious injury...."). The most common injuries are
head injuries, most of which could have been prevented by use of lap belts
combined with proper spacing between seats.
PEOPLE WHO SAY COST IS NOT THE ISSUE IGNORE: 1) THE COSTS OF REDESIGN AND RETOOLING TO THE BUS MANUFACTURERS, 2) THE COSTS TO SCHOOL DISTRICTS, WHO MIGHT NEED TO SCRAP OUTDATED BUSES!
COST IS THE ISSUE, but the COST SHOULD BE MEASURED IN
LIVES, NOT IN DOLLARS, and 3) THE HUMAN COSTS INVOLVED WHEN PEOPLE ARE INJURED OR KILLED.
Also, we should ask school districts to tell us just what percent of
their bus fleet is manufactured before 1 April 1977, and just how they
intend to phase out these extremely dangerous portions of their fleets.
Currently, for instance, about one-third of the Amphitheater Unified School
District's fleet is "pre-1977." Those buses should be replaced
immediately, with buses equipped properly with
2) well padded seats which are widely spaced as federal regulations
permit, and
3) color-coded lap belts, which have light-weight, plastic buckles and
straps of proper length.
I encourage school districts to seek out the knowledge of state-of-the-art
bus designs and seatbelt systems, from NCSSB, before ordering such properly
equipped buses. Also, for those in the greater Tucson area, Marana Unified
Schools Director of District Operations, John I. Goss, is a personable,
competent, local source of such information -- whose expert guidance should
be sought before any purchasing decisions are made. Goss has years of cost-
conscious experience in guiding his staff, during the retrofitting of older
school buses for greater safety. ---------------------------------- page break ----------------------------------------
Page Count: 40 of 79 Page 30
Cost IS the issue. Methods of addressing costing problems will
logically become part of this discussion, by school-district officials,
as soon as school-district officials decide to buy properly-outfitted,
new buses -- or, to retrofit "post-1977" buses with seatbelts,
in the best possible way.
It has been suggested (24 January 1990 School-bus Seatbelt Forum, Sunshine School,
Oro Valley, Arizona) that if school districts can not provide our precious children with
the safest possible transportation, they should get out of the business of providing
transportation directly, and should (to paraphrase and borrow a phrase)
"leave the driving to" contractors. School-district officials
who obstinately refuse to put seatbelts in school buses should be strongly
questioned as to whether or not they are providing the optimum safety.
If satisfactory answers to the safety questions can not be obtained, action
to change the situation should be instituted.--S.L.]
p. 168: "Even if the introduction of
safety belts would benefit some [not "most"? Give us a break!--S.L.]
school bus occupants, especially in side impact or rollover accident situations,
it is possible that a few of the occupants of buses involved in
accidents would be at greater risk of injury as a result of wearing
belts. Current compartmentalization countermeasures are most effective
in frontal crashes that still account for 55.9 percent of all school bus
fatalities. [So, are we supposed to forget the other 44.1 percent? And,
are we supposed to forget that 35.3 percent of the fatal, front-end, Type
I school-bus crashes are also rollover accidents? And, we are supposed
to believe that NONE?! of the 14.7 percent of fatal Type I accidents
produces a rollover??!! Just look a little bit critically at the Table
2 excerpt, on that last point of discussion. In any case, the probably
faulty (at the least, "confusing") Table 2 nonetheless documents
that at least 50 percent of fatal Type I school-bus
accidents produce bus rollovers!--S.L.] The high, well padded
seats absorb the crash forces across the occupant's entire body. [So, why
not use only compartmentalization in airplanes?--S.L.] With lap belts,
the midsection of the occupant's body remains at the seat while the head
and upper portion of the body rotates forward. As a result, the head and
face may strike the seat the occupant is facing with greater force than
would have occurred in the absence of belts. [Then seats should be moved
farther apart.--S.L.] Also, correct belt position over the pelvis is important
as injuries could be caused by the belt being positioned over the abdomen.
[No doubt, there is an optimum wearing position for the lap belt. But the
same doctors who may first have raised the abdominal-injury issue also
have reportedly recanted their own first position on that issue. They now
support wearing lap belts in cars' rear seats, for instance. See the many
medical endorsements for seat belts on school buses. Note also that if
an accident were traumatic enough to cause such abdominal injury, some
doctors think the person would be dead, had no lap belt been used. At least
one police officer is reported to have said that he has never had to unbuckle
a dead body, after an accident (though the victim may later have died)--S.L.]
p. 176: "The pupil transportation industry has raised several questions
about potential hazards associated with belts. For example, a school bus
driver wrote in the National School Bus Reporter ... ' ...
my major concern is what would happen in an emergency evacuation, particularly
with the little ones. It would be impossible to get them out in a hurry'
(speaking about the large 60-66 passenger school bus). While there [are]
no hard data on this for large school buses, a report from Nassau County,
New York about a rollover accident involving a small, van-type bus, noted
that 4 to 7 year old children were able to unbuckle themselves and escape
without panic....
p. 176: "Another version of the problem that has been mentioned is that belts
in large buses could leave small children dangling overhead in rollover
accidents. The American Academy of Pediatrics is on record as stating,
"This is true, but it is still preferable for children to be strapped
in rather than thrown out of the seat or the vehicle at the time of an
accident".... In NHTSA and NTSB investigations of major school bus
accidents, ejections account for one- fourth of all fatalities.... [Right;
see note attached to Table 2, above.-- S.L.] Data [are] currently being
analyzed to determine if the age of the bus (pre-1977, post-1977) is a
factor in ejection rates.
"Transportation providers are also concerned that belts can
be fastened easily to another belt across the aisle and act as a tripping
hazard to entering or leaving pupils. The National Coalition for Seat Belts
on School Buses has issued guidelines to help prevent this, stressing the
importance of installing the short end of the belt on the aisle.... [And,
of having similar buckle-end types on the aisle.--S.L.]
"The question of how many belts to install
on each seat must also be considered. If only young children are being
transported, then three belts per seat could be specified. In most cases,
however, the same school bus is used to transport both elementary and high
school students. [This "usual-case scenario" is not written in
stone! Transportation directors can work on alternative logistics.--S.L.]
In this situation, a school district would have to specify the installation
of two or three belts per seat. [The best arrangement might turn out to
be a staggered one, of, say 2, 3, 3, 2, 3, 3, ... , or some such. Such
possibilities should be explored rigorously.- -S.L.]
"[Most] school bus related fatalities occur
outside the school bus. Many accidents might be avoided with improved driver
training or vehicle maintenance. All of these areas might be competing
for the same dollars used for installing belts on buses.
p. 177: "Most pupil fatalities occur when students are
run over by their own bus or oncoming vehicles during loading and unloading.
An educationial program ------------------------------------ page break --------------------------------------
Page Count: 41 of 79 Page 31 for both drivers and pupils should place special emphasis on existing
hazards and how to avoid them. For instance, school bus drivers can have
their field of view blocked by the high hood of the bus which prevents
them from seeing a small child near the front bumper. A safety education
program which explains how to avoid this situation would help drivers save
lives. Pupil transportation funds could also be used to purchase, for example,
special mirrors which are available to allow the driver to see small children
more easily or electro-mechanical sensing devices....
"In cases where some vehicles are of pre-1977 vintage, funds could also be used
to speed up the replacement schedule so that all buses in its fleet would meet the new
safety requirements that became effective April 1, 1977." (From Safety Belts in School Buses, NHTSA Traffic Safety Programs, June
1985; pp. 162 - 177 of NCSSB manual.)
The following is from NHTSA's A. R. Bayer, Jr., School Bus Passenger
Seat and Lap Belt Sled Tests.
p. 181-2: "Abstract: Sled tests were performed to determine the response of
dummies in simulated frontal collisions with and ... without lap belts on both route and
activity passenger seats; and the effect of increased spacing of passenger seats
on occupant protection.
"Comparison
shows that [in general] the use of the lap belts [does] not reduce
the peak head accelerations but in fact, in most cases, actually cause
an increase in peak accelerations.... [This] increase is probably due to
the head contact point moving up on the dummy head with the use of seat
belts. It may also be due to the redirection of the head impact into the
stiff axis of the seat back structure....
"p. 182: "The effect of the use of seat belts on head acceleration appears
to be insignificant for the Wayne and Carpenter seats (approximately
a 20% increase in peak head acceleration ... still well below the
design limit). However, the Blue Bird seat appears to show a significant
decrease in head accelerations due to the use of seat belts....
This can be explained by ... structural failure....
p. 182: "The effect of use/non use of lap belts on torso response is insignificant....
"Compartmentalization is defined herein as the presence of the dummy remaining within
a reference volume during and following impact. The data [show] that in general a belted
dummy receives more containment [that sounds honest!-- S.L.] than an unbelted dummy both
during impact and rebound. It should be noted that all of the
sled tests conducted were normal (0) frontal impacts. It is expected that
compartmentalization will be somewhat sensitive to the obliqueness,
or angle (this will be especially true for the unbelted dummy). TRB Special Report 222, Brief Comment
Since the May 1989 publication of the National
Research Center Transportation Research Board "Special Report 222--Improving
School Bus Safety," people are saying that money spent on seatbelts
for Type I buses is not "cost effective." They argue that the
same dollar should be spent a different way, in order to save more lives.
Not only does that argument touch upon the question of where a school district's
liabilities begin and end (inside v. outside the bus), but it also discounts
the value of human life and demeans the person who speaks the phrase, as
it does humanity in general. No price is too high to pay for safety, especially
if the child concerned is your own. The "cost effectiveness"
argument is one more red herring, as well as a tacit admission that not
enough concern has previously been given to safety around the bus exterior.
Those who have failed to give attention to exterior bus safety should be
held accountable, and should get that job done, now. But that has nothing
at all to do with putting seatbelts in school buses ... except for the
cost-competition factor. See more in Appendix B, above. CANADIAN STUDY CANADIAN-STUDY EXCERPTS
p. 170: "In 1984, Transport Canada (the Canadian Ministry or Department
of Transportation) conducted an extensive ["EXTENSIVE"?!--S.L.]
study of school bus safety which included a frontal test program [6 crash
tests is "extensive"?! 6 tests do not provide enough data
from which to draw valid statistical inferences!--S.L.] for three different
size school buses, comparable to post-1977 buses in the U.S.... (From Safety
Belts in School Buses, NHTSA Traffic Safety Programs, June 1985; pp. 162
- 177 of NCSSB manual).
"[Excerpt of Canadian-study report summary:]
"'This school Bus Safety Study indicates that careful deliberation must be exercised
before deciding whether or not to add lap belts to existing designs of occupant protection
systems found in today's school buses. The barrier crash test results showed that
the potential for head injury in frontal collisions increased, when lap
belts were employed. (From Safety Belts in School Buses, NHTSA Traffic
Safety Programs, June 1985; pp. 162 - 177 of NCSSB manual). [But doctors
dispute that the level of head injuries is significant enough to warrant
the conclusion to omit belts altogether! And, it might be possible to move
seats farther apart, even on buses to be retrofitted. Cost is the contraint.--S.L.]
"'This conclusion was reached after the subject of school bus safety was investigated
in considerable detail. The investigation included a review of existing literature,
discussions with bus manufacturers and operators, and a dynamic barrier crash program
----------------------------------- page break ---------------------------------------
Page Count: 42 of 79 Page 32 [about which doubts are elsewhere detailed, concerning the validity
of the test design--S.L.]. The crash program provided [not enough--S.L.]
data [for statistical significance--S.L.] and photographic evidence, not
before available, to compare the reaction of belted and unbelted test dummies
in a frontal collision'" (From Safety Belts in School Buses, NHTSA
Traffic Safety Programs, June 1985; pp. 162 - 177 of NCSSB manual).
[Fifty percent of Type I fatalities involve rollovers (Table 2, above)! Many other
objections to the Canadian study have been raised, which diminish the study's
credibility. Sadly, it remains a cornerstone of many current arguments
against seatbelts in school buses. Therefore, it must be discussed in this
otherwise briefer Primer.--S.L.]
p. 170: "NHTSA has analyzed the results of the Canadian test and found
them to be in general agreement with laboratory testing conducted within
the United States. [Were U.S. studies also done with "fifth percentile"
(see NCSSB manual, p. 199) dummies?! This is ridiculous, and lends credence
to the challenge that the Canadian test was strongly biased to produce
the results desired by bus manufacturers, whether they be in the U.S. or
in Canada.-- S.L.] It should be recognized that the "compartmentalization"
countermeasure was specifically designed to protect the occupant in frontal
barrier tests, similar to those conducted by the Canadians. The low head
injury readings for the unbelted dummies is indicative that compartmentalization
performs as well in production buses as it did in the research tests which
perfected the concept. [The concept is IMPERFECT, since it entirely
ignores rollovers, which cause 50% of Type I school-bus
fatalities!--S.L.] The lap belted dummies also performed in a predictable
manner in the Canadian tests. In NHTSA sponsored research on lap belted
dummies in the automobile environment, lap belted dummies typically have
higher head injury measurements than unbelted dummies [do]" (From
Safety Belts in School Buses, NHTSA Traffic Safety Programs, June 1985;
pp. 162 - 177 of NCSSB manual).
p. 170: [An anonymous note (by NCSSB's Carol Fast, I guess) seems to have been inserted in
this NHTSA report. The note is underscored, and reads:]
"In examining the Canadian tests, several factors must be considered.
A 30 mph crash force for a large bus is an unlikely occurrence.
For example, a head-on crash between a large school bus and
a full-size car, both travelling at 55 mph, would
be less severe to bus occupants than the 30 mph barier test. Also, only
one size dummy was used which typically represents a junior high
school student. The geometry for younger [and for older?--S.L.] children
would be significantly different with likely different results. Taken together,
the results of the Canadian tests should be VIEWED WITH CAUTION"
(From Safety Belts in School Buses, NHTSA Traffic Safety Programs, June
1985; pp. 162 - 177 of NCSSB manual). [The last three words of that quote
were doubly underlined, so I have capitalized them here.--S.L.].
p. 198: "[Excerpt] taken from "Description of Tests, p. 3 of School Bus Collision
Tests - Transport Canada
"Three different sizes of buses, representing the majority of types of vehicles used
for transporting school children in Canada today, were subjected to a barrier
collision at 48 km/hr (approx. 30 mph). The forces generated during such
a test crash are comparable to those resulting from a head-on crash between
the school bus and a car travelling at highway speed. [That's a very loosely
stated idea!- -S.L.] The buses consisted of a large 66 passenger Blue Bird
conventional type, a mid-sized 22 passenger Thomas Minotour, and a small,
20 passenger Campwagon van conversion.
"Each bus contained six 5th percentile adult female test dummies to represent
large elementary school students. Three different seat spacings representing
all practical forward [facing] seating configurations were also incorporated
in the buses.
"The dummies were instrumented to record forces on the head and
chest during the collision. Three dummies were secured in place by lap
belts and three were left unrestrained. The dummies were arranged in pairs
in the buses so as to provide one restrained and one unrestrained dummy
for each seat spacing arrangement. Highspeed cameras recorded the motion
of the dummies during the collisions.
"The Head Injury Criterion (HIC) [What are the HIC units
and formula?--S.L.], which produces a mathematical combination of resultant
head acceleration and the duration of that acceleration, was used to estimate
the degree of harm occupants might suffer in the collision. This technique
has limitations in its ability to predict injury but is the only widely
accepted measure currently available. Resultant chest acceleration was
used to estimate the degree of harm that might be suffered in that body
region.
"For this analysis, the limit of 1000 for HIC is used as the threshold
above which serious injury or death could be inferred. An upper limit of
60g for resultant chest acceleration is the threshold used when determining
the severity of this variable.
"Summary (excerpt from p.
2) 'The results indicate that, in a frontal collision belted school bus
occupants are liable to suffer more serious injury than unbelted ones.' CANADIAN STUDY CRITIQUES NCSSB CRITIQUE OF CANADIAN STUDY
"The January 1985 Transport Canada report of
school bus crash tests has been widely publicized as proving that seat
belts could not be used on the large (Type I) school bus and that the so-called-
"compartmentalization" school bus seat without seat belt offers
better protection for children. Nothing could be further from the truth. ------------------------------------ page break --------------------------------------
Page Count: 43 of 79 Page 33
"In the Canadian tests a large, a mid-size and a van type bus were subjected to
severe 30 mph front end crashes. On each bus there were six 5th percentile adult
female anthropomorphic dummies, three belted and three unrestrained. From
previous studies at UCLA and at East Liberty, Ohio it was learned that
in such high force front end crashes belted dummies tend to pivot over
their seat belts and strike their foreheads on the padded seat backs in
front of them. Unbelted dummies on the other hand are thrown [forward]
violently by the crash forces into the seat backs which they face. When
measuring devices are placed by the researchers in the head and chest of
these dummies, the belted dummies produce [the] higher head readings and
the unbelted [dummies] produce the higher chest readings. Experimentally,
Head Injury Criteria (HIC) levels of greater than 1000 and Chest Accelerations
of greater than 60g. are generally accepted as [sufficient] to produce
severe injury or death.
"The results of the Canadian test of the large bus are [shown in the table] below.
In this test crash of a 66 passenger bus the only dummy experiencing life threatening forces
was dummy no.1 seated unbelted in the front left hand seat with a chest reading of 60.4g.
All belted dummies were well within acceptable limits. The bus met all
[current] federal standards, including Standard 222 for school buses. [How
would you grade your school board? Does it meet or exceed minimum-requirement
standards?-- S.L.]
"Since it is well known that the Federal 222 seat offers no protection at all
for passengers in side impact [or rollover] and no 'whip lash' protection
for taller riders in rear-end crashes, and that the seat was developed
primarily to protect against injury in front end crashes, the failure to
protect dummy no.1 without a seat belt is of particular concern. [Why?
It provides a good 'baseline,' against which to compare other data (of
which there are nowhere nearly enough for statistical purposes).--S.L.]
"In this type of front end test crash, as explained above, belted dummies will
produce somewhat higher HIC levels than [do] the unbelted dummies. In addition,
the selection of the 5th percentile female which is just the right height
to target the [dummy's] head to the area of the seat back where the padding
[narrowly] covers the metal bars of the seat and the use of the type 572
dummy which has been widely criticized for excessive HIC [readings] in
crash tests severely prejudices these tests against seat belt use. Inspite
of all these test induced disadvantages, the dummies with the seat belts
on the Bluebird bus did remarkably well [How about failure of the floor
as a contributing factor, though?--S.L.]. On the other [hand], in spite
of the large area of the seat back to spread the forces, ... the unbelted
dummy in the front seat would have experienced serious or fatal injury.
"When film of the crash is viewed, dummy No.4, unbelted in the
center seat, is seen to fly [forward] until its throat strikes the top
of the seat back. In a high force frontal crash such as this the resulting
throat injury would have been severe or fatal. It is conceivable that the
HIC and chest readings were lower on this passenger because the throat
and neck absorbed so much of the crash injury. Just how much force was
so absorbed was not determined because, unfortunately, the researchers
decided not to instrument the necks of the dummies.
"Not unexpectedly, HIC levels in the mid-size bus and van were
higher. As the size of the vehicle gets smaller, the crash pulse becomes
greater. The forces on the dummies increase. As a result of these higher
forces coupled with the stiff, targeted 572 dummy, HIC levels were increased.
Further, it has been documented in the 1978 testing of school bus 222 seats
in East Liberty that seats manufactured by the Thomas Bus Company consistently
registered HIC levels 2.4 times greater than seats produced by the Ward
Bus Company in comparative tests. [No Blue-Bird bus tests?--S.L.] Thomas
seats were used in the mid-size bus and van tests in Canada. The National
Coalition is convinced that the higher HIC readings in the smaller vehicles
were the result of the high crash pulse, the height of the dummy, the stiffness
of the type 572 [dummy] and the use of a Thomas seat.
"Investigation of real world accidents in van type vehicles with
passengers wearing belts in 222 seats and forces [approximating] those
used in Canada have not produced injuries of the head anticipated by the
test data. The researchers themselves admit that they were confused by
the head and chest readings in two of the three belted dummies on the van,
calling their own results "inexplicable."
"When Canada implemented their Standard 222,
seat belts were not ordered on smaller vehicles as was done in the U.S.
because of pressure from those who operate school buses. The Coalition
believes that the protocol of these tests was influenced by a desire to
support the decision not to place seat belts on small buses. No assessment
by crash testing of the safety provided by the 222 seat can be considered
a valid measure of passenger protecting ability (compartmentalization)
unless the tests include side and rear impacts to simulate the real world
of school bus accidents. Any test which measures frontal collisions only
must be considered self serving. [Well put! Such testing ignores the 44.1%
of fatal accidents which are not front-enders. It also ignores the fact
that fully 50% of fatal accidents involve rollovers; 35.3% of front-end
accidents are rollovers. See Table 2, p. 169, NCSSB manual.--S.L.]
"The 222 seat was designed to protect in front [end] crashes, a job which it does
reasonably well. The Canadian tests were designed to demonstrate this 222 seat in the best
possible way, and, because of the high crash forces, the dummy height and
stiffness, [and] the Thomas seat, to show the use of seat belts on school
buses in the worst way. In spite of these efforts, the results clearly
indicate that the use of seat belts on large (Type I) school buses as advocated
by the Coalition, provides superior protection to school children in front
end crashes as tested [in Canada] as well as in all other accidents experienced
by children in school buses. Arthur L. Yeager DDS Chairman, NCSSB May, 1985 ----------------------------------- page break ---------------------------------------
Page Count: 44 of 79 Page 34 STUDIES/RECOMMENDATIONS SUPPORTING NEED FOR A SCHOOL- BUS-SEATBELT
MANDATE
p. 144: "According to the
U.S. Dept. of Transportation, MOTOR VEHICLE ACCIDENTS ARE THE NUMBER
ONE KILLER OF CHILDREN AGE 14 AND UNDER in this country today. 4100 children
are killed and several hundred thousand are injured [per year, taking all
accidents into consideration.--S.L.] 50% of those killed are occupants
and half of these deaths could be prevented by use of restraints.
"SEATBELT USE IN ALL SCHOOL BUSES not just in the vans, IS THE
LOGICAL ANSWER TO THE QUESTION OF HOW TO GET CHILDREN TO 'BUCKLE UP' IN THEIR
CARS. By encouraging the installation of seatbelts and their usage in school
buses, there will be a positive carryover to automobiles. IT IS EVEN POSSIBLE
THAT THE PARENTS WILL LEARN FROM THEIR CHILDREN!" (Anonymous remarks
in response to National School Transportation Association (NSTA) lobbying
success (above); probably written by Carol Fast, Founder, NCSSB) Study supporting belts on buses: UCLA, 1967
p. 143: "Seatbelts recommended for Safety Seat:
'These bus experiments, the many actual school bus accidents investigated
by the authors, the many types of collision experiments conducted during
the past 16 years by the authors and investigations by others, CLEARLY
ESTABLISH THE VALUE IN PASSENGER PROTECTION OF LAP BELTS WHEN USED WITH
HIGH BACK SEATS .... These restraints can be added to the safety seat at
very little added cost and their presence provides the continuity needed
for proper training of youth concerning habitual use of restraints when
riding in any vehicle'" (1967 School Bus Passenger Protection,
Severy, Brink & Baird, Institute of Transportation & Traffic Engineering,
UCLA (film entitled "Broken Bus"). UCLA, 1967, More excerpts from the Same Work
p. 184-7: "The greatest single contribution to school
bus passenger collision safety is the high strength, high back safety seat.
Next in importance is the use of a three-point belt [not yet designed?--S.L.],
a lap belt or other form of effective restraint. These restraints can be
added to the safety seat at very little added cost and their presence provides
the continuity needed for proper training of youth concerning habitual
use of restraints when riding in any vehicle....
p. 187: "Lap-type
safety belts would provide substantial additional protection to the school
bus passengers, seated in high back seats that have efficient padding
on the rear panels of its backrests. The use of lapbelts with a low
seatback exposed passengers to extreme hazards of the seatback acting as
a fulcrum across the face, neck, or chest when they are jacknifed across
the horizontal surface of the seatback ahead of them. Accordingly, where
seats with low seatbacks are installed, little benefit, if any, will be
derived from use of seat belts for the typical front-end impact. In the
head-on and side-impact experiments the passengers flexed at the hips,
pitching their heads and upper torsos forward or to the side, striking
objects within reach."
[Since the value of high seat backs has been known at least since 1967,
why should school-district officials not be held accountable for purchasing
"seatbelt-ready" seats that are not high-backed?--S.L.]
p. 187: "For the rear-end collision, lap-belted passengers responded
slightly differently from unbelted passengers, but this factor was not
nearly as important as was the height of the seatback. Lap belts should
not be used for low seatback units because their use substantially increases
the highly adverse forces to the spinal column resulting from whiplash
and they virtually assure severe head or neck impacts with the low backrests
ahead."
[This is only because seats are too close together!
Why should bus manufacturers and school-district officials not be held
accountable? John Goss, Director of District Operations, Marana Unified
Schools (Greater Tucson, AZ) points out that the problem lies with Federal
Standard 222 itself! Std. 222 mandates seats no further apart than 23 inches,
as measured from an "H point." The "H point" is a hip-pivot
point." It is derived from maximization of the compartmentalization
concept design--which should be scrapped, in my opinion. I'm not yet sure
why one does not simply measure from seatback to seatback.--S.L]
p. 187: "The cross-chest lap-belt combination
when properly fitted provides significantly more passenger protection
than does the use of only a lap belt. A comparison was made between
performances of three-point and lap belts in the prior conclusion. In contrast
with no belt, the three-point belt allows its wearer to sustain but one-third
the frash forces received by an unrestrained passenger of the same size
seated beside him. [Crashed from any direction?- -S.L.] More importantly,
the forces are directed by the three-point restraint system to strong parts
of the passenger's body in a generally [mathematicians use "general"
to indicate "in every case;" does this mean "usually,"
instead?--S.L.] noninjury-producing manner, as contrasted with head and
chest injuries commonly sustained for unrestrained passengers on direct
impact with the structures around them. ---------------------------------- page break ----------------------------------------
Page Count: 45 of 79 Page 35
p. 187: "The cross-chest lap-belt
combination restraint is not recommended for use in school buses. As
has been found in prior intersection type collisions where the cross-chest
belt has an anchor point to the rear and substantially above shoulder level,
the belt passes across the throat in a manner which, during side-impact
accelerations, applies injury-producing forces of a lacerative nature to
the throat; the forces may be sufficient to cause neck injury and back
injury as well. The cross-chest belt should have an anchor point, preferably
built into the seat at shoulder level to prevent the belt from passing
diagonally across the neck.
"Passengers rebounding from the school bus side-impact collision slipped from behind
their cross-chest belts, except where the upper anchor point was at their
shoulder level; this left the passenger without upper torso restraint should
any subsequent collision stresses develop, such as an upset [rollover].
"During the head-on collision, passengers with higher-than-shoulder
level anchor points showed evidence of asymmetrical restraining forces
that force their upper torsos to rotate from behind the belt. Thus, an
important condition with the effective use of the cross-chest lap-belt
unit is to make certain the anchor point is at shoulder level in order
to reduce the tendency for the cross-chest belt to injure the necks and
to provide a more effective restraint for the head and upper torso against
lateral and forward collision forces.
"[Adjustments] would have to be provided over a wide range in order to accommodate
this requirement. The anchorage ladder necessary to achieve this would provide
a rigid structure at shoulder and head level that could be struck by all
but the shortest child. The potential gain in the use of cross-chest belts
for school bus passengers is too questionable to warrant their further
consideration. This position in no way should be construed to extend to
passenger vehicles....
[According to John Goss (7 February 1990), the difference between
3- point and cross-chest belts is that, in the sixties, seatbelts belts
were both lap belts and across-the-shoulder belts--both at once. these
two separate belts did not adjust concurrently and nicely to given accident
stresses. In fact, the lap-belt-plus-across-the-shoulder combination comprised
a 4-point system. In a 4-point system, there are four anchorage points.
Many cars, today, rely upon 3-point systems, which bring two belts across
the body, in order to link to a third anchorage point, via the buckle on
the other side.]
p. 186: "Seatbacks and armrests should be designed
using well-padded, broad surfaced metal frames designed to
provide the required strength and attenuate head impact forces in
accordance with the performance specifications of the Federal Motor Vehicle
Safety Standard No. 201, [Par.] 3.2....
p. 187: "Seats having strong but well-padded
armrests provide important lateral constraint. Although seats with
armrests are a little more difficult to enter, sit down in or exit from,
they are more comfortable owing to their additional body support. During
the bus side-impact experiment, it was observed that armrests provided
a significant improvement in passenger safety.... (From School Bus Passenger Protection, D. M. Severy, H. M. Brink, and
J. D. Baird, Inst. Transp. and Traffic Eng., UCLA, 1967.) UCSD & Automobile Club of So. California, 1971
p. 143: "Restraint Systems & Seats: 'In all cases where an individual is
ejected from his seat to strike either the forward seat or other areas within the bus, the
passenger injury level is increased. IT IS, THEREFORE, RECOMMENDED THAT
THE SEATS BE PADDED AND THAT ALL BUSES BE EQUIPPED WITH RESTRAINT SYSTEMS
CAPABLE OF BEING ACTIVATED BY EACH INDIVIDUAL. RESTRAINT WITHIN THE SEAT
AREA IS ESSENTIAL FOR INJURY MINIMIZATION .....
p. 143: "'For many years certain public and pupil transportation officials
have been presenting arguments against installation of restraint systems
in buses, particularly school buses. ..... IT CAN BE STATED QUITE CATEGORICALLY
THAT THE ABSENCE OF LOAD-DISTRIBUTING, ENERGY-ABSORBING SEATS, COUPLED
WITH THE ABSENCE OF BUS PASSENGER RESTRAINT SYSTEMS, HAS [BEEN] AND WILL
CONTINUE TO BE DIRECTLY RESPONSIBLE FOR THE MAJORITY OF BUS INJURIES AND
FATALITIES'" (1971 Bus Collision Causation & Injury Patterns,
Siegel & Nahum, Trauma Research Group, UC San Diego; Runge, Automobile
Club of Southern California).
p. 190: "In all cases where an individual is ejected from a seat to strike either
the forward seat or other areas within the bus, the passenger injury level is increased.
It is, therefore, recommended that the seats be padded and that all buses
be equipped with restraint systems capable of being activated by each individual.
Restraint within the seat area is essential for injury minimization. Restraint
must be coupled with removal or reduction of the hazard of the forward
front seat back.
"For many years certain public officials have been presenting arguments against
installation of restraint systems in buses, particularly school buses.
Some insist that it is too costly to retrofit new seats or to pad [proper?
(illegible)--S.L.] seat backs. Some say that seat structures are too weak,
that restraint system maintenance is too difficult, and that bus discipline
would be hampered. In part, these arguments are emotional excuses and have
delayed needed injury-reducing interior design changes.
"Regardless of the cost and the problems, it can be stated quite categorically that
the absence of load- distributing, energy-absorbing seats, coupled with
the absence of bus passenger restraint systems, has [been] and will continue
to be directly responsible for the majority of bus injuries and fatalities."
(From Bus Collision Causation and Injury Patterns, A.W. Siegel and Nahum, A. M.,
Trauma Research Group, UCSD and D. E. Runge, Auto. Club So. Cal., 1971.) --------------------------------- page break -----------------------------------------
Page Count: 46 of 79 Page 36 Grand-Jury Report, Queens, 1977
p. 143: "Introduction: '.....The injuries suffered ... were directly
attributable to the unsafe construction of the school bus involved. "Recommendation: 'THE GRAND JURY RECOMMENDS ... A 3-POINT
BELT, A LAP BELT OR OTHER FORM OF EFFECTIVE RESTRAINT.
"'In the Clearview accident case, one child was ejected from the
bus onto the roadway. Had this child been wearing a seatbelt, the chances
of this happening would have been greatly diminished.
"'The child who was thrown against the inside back portion of the
bus and suffered serious head injury did not have any lateral constraint
... many children injured in the crash were sitting three to a seat and
consequently ... at the time of impact with the truck, many of these children
were thrown about the inside of the school bus'" (1977 Grand Jury
Report Into School Bus Accident On Clearview Expresseway, Queens). National Transportation Safety Board (NTSB) Press Release, 27
August 1982
pp. 148- 9: "Seat belt usage by children in school buses may be not only possible but
relatively easy to achieve, the National Transportation Safety Board said today.
"Special investigation of a
New York City accident last July 27 [1982] involving a van-type school
bus mirrored the findings of a 1979 investigation -- grade-school children
who had been taught to wear their seat belts all had them on and escaped
injury when their bus overturned.
"Drivers of both buses had taught their students
that unless all belts were fastened, the buses would not be moved. Each driver reported
that only a few days to a week had been required to teach students how to fasten and
unfasten their metal-to-metal seat belts, and for them to become accustomed to 'buckling
up.' Older children were happy to help others and served as an example
to the younger ones.
"The July 27 [1982] accident involved a day camp van occupied by
the driver and three campers -- a 14-year-old and two seven-year-olds.
The van was struck broadside by a car as the van pulled into the intersection
of Rosedale and Storey Avenues in the Bronx with the changing of the traffic
light.
"The collision impact was not severe, but the van overturned on
its right side. One of the seven-year-olds was left hanging from a seat
on the high side of the bus, but none of the three children was injured.
The driver, who also was wearing a seat belt, suffered only a scratched
ankle.
"In the similar 1979 accident, another van-type school bus skidded out of
control on State Route 120 in North Castle, N.Y., when it ran over a motor vehicle
muffler lying on the highway. The bus overturned on th8e shoulder of the road,
but the driver and all six passengers -- all children 5 to 7 years old
-- were wearing seat belts and escaped injury. Most, if not all, of the
children were able to release their own belts and walk out of the van unassisted
even though three were in 'high side' seats.
"The driver told Board investigators it had taken her 'just a few days' to teach
the children to use their seat belts. She reported no serious delays in waiting for
children to buckle their belts, and said the use of belts solved the problem
of the smallest children sliding off their seats because their feet would
not reach the floor, as well as that of dozing children.
"The Safety Board [NTSB] said neither
driver had been given special training in how to carry out their schools'
policy of requiring belt usage.
"The Safety Board observed that 'both accidents suggest that the unquestioned
benefit of being protected by a seat belt when an accident occurs could
be available to our children in their school buses just as it is to us
in our private automobiles.
"'Past suggestions that seat belts would prevent deaths and injuries in school buses
have been met with skepticism that children could be made to wear them,' the
Safety Board said. 'These cases, involving multi-purpose vans in which
seat belts are required, indicate that the added safety of belts may be
quite attainable.' Seat belts are not required on most buses" (Press
Release of NTSB, 27 August 1982, entitled: CHILDREN IN VAN SCHOOL BUSES,
TAUGHT TO USE SEAT BELTS, ESCAPE INJURIES IN ACCIDENTS). Levy Report, New York State, April 1986
The following excerpts are taken from "Increasing School Bus Safety for New York
State's Children through Seat Belts on School Buses and the Elimination
of Standees!," by Sen. Norman J. Levy, Chairman, April 1986, A report
to the Legislature by the New York State Legislative Commission on critical
transportation choices. Page numbers in this section of the Primer refer
to pages in the Levy report, and are designated "Levy p. 123,"
etc.: Transport Canada Study, Levy Report Levy p. 3: "THE TRANSPORT CANADA STUDY
"The selection of the 5th percentile female ----------------------------------- page break ---------------------------------------
Page Count: 47 of 79 Page 37 dummies has been widely criticized because the size of the dummies purposely
targets their heads to the area of seat backs where the padding narrowly
covers the metal bars of the seat. Thus, use of the 5th percentile female
dummy inherently results in excessive HIC readings in crash tests, thereby
severely prejudicing these tests against seat belt use.... [Text cites
23 December 1985 letter to Levy from John D. States, M.D., Chairman and
Professor, Dept. Orthopaedics, Univ. Rochester and Chairman of New York
Coalition for Safety Belt Use; and from Arthyr Yeager's The Canadian
Tests (New York: National Coalition for Seat Belts on School Buses,
1985), p. 2.]
Levy p. 4: "A major flaw in the Canadian study was
the failure of Transport Canada to use dummies of various sizes to represent
all sizes of children. The 5th percentile dummy represents approximately
a five feet, two inch, one hundred pound twelve year old child, and was
chosen as more apt to incur increased head injuries. However, in spite
of these test induced disadvantages, the dummies wearing seat belts on
the large buses were protected adequately from injury and death.
"Experimentally, Head Injury Criteria (HIC)
levels of greater than 1,000 and Chest Accelerations with a force of gravity
greater than sixty [g's] generally are accepted by medical safety experts
as sufficient to produce severe injury or death....
"In the crash of the sixty-five passenger
bus, the only dummy experiencing life threatening forces was dummy number
1 seated unbelted in the front left hand seat which experienced a chest
reading of 60.4g.... All belted dummies recorded impacts within acceptable
safety limits. Although the bus met all current United States Federal standards
including Standard Number 222 for school bus seat height and padding and
for seat performance in crashes, it did not meet New York State's standard
for 28 inch seat backs--a critical omission. Transport Canada also concluded
the use of lap belts in the mid-size bus and small van-type bus also may
result in more severe head injuries for a [belted? word missing?--S.L.]
twelve year old child, than for an unbelted twelve year old child. The
results of the Canadian crash tests prompted LCCTC's [Legislative Commission
on Critical Transportation Choices] study and this report.
Levy p. 11: "[The] findings of the Canadian study raise more questions
than answers about the safety value of seat belts on school buses. Proponents
of seat belts on school buses concluded that the Canadian tests are not
relevant to New York State" .... Critique of Canadian Study, University of Michigan
Levy p. 19: "Subsequent to the LCCTC public hearing, the Department of Mechanical
Engineering and Applied Mechanics (the Department) of the University of
Michigan issued a report critiquing the Transport Canada School Bus Safety
Study.... The report noted that the Department does not agree with the
interpretation of the results presented by the Transport Canada authors.
The report addresses primarily the problems of head and neck injury prediction
as related to the dummies used.
"The reason for the higher values among the unrestrained dummies,
according to the report, is quite clear and supports the need for occupant
restraints on buses. While the restrained dummy heads contacted the padded
seat backs (which could have been better padded), the necks of unrestrained
dummies hit the top of the seat backs where no load cells or accelerometers
were mounted to measure the injury impact. The report also noted that a
shorter belted dummy, such as the one representing a 6-year-old child,
probably would have missed the seat back entirely while still being restrained
safely in its seating position.
Levy pp. 19- 20: "The Transport Canada study pointed out that the dummy
neck is unrealistically stiff, but failed to recognize that the torso is
rigid, according to the Department. This rigid torso transfers the entire
upper-body bending motion to the only flexible unit, the neck. The report
added 'humans bend differently than the stiff dummies used by Transport
Canada and do not tend to suffer life threatening neck injuries in these
situations.'"
Levy p. 20: "The University of Michigan report concluded that the
Canadian School Bus Safety Study does not support the contention that the
use of belts on recent-model large school buses poses a potential danger
to the occupants in terms of increased likelihood of severe head injuries
in frontal crashes. The Department report concluded:
"'Although the best possible occupant restraint system would include
a shoulder belt as well as a lap belt, which is the approach now being
pursued by Transport Canada, this possibility is probably far in the future.
In the absence of any evidence to the contrary, we firmly believe that
newly purchased large school buses should be equipped with lap belts to
provide their occupants with protection similar to that available in the
rear seats of automobiles.'" Statistical Record
On p. 5 of the Levy report, the better safety record of school buses,
compared to passenger cars, is attributed to 1) a weight advantage, 2)
being driven at non-peak-accident hours and in typically less-dangerous
situations, and 3) the conspicuousness of school buses, which motorists
recognize identify easily, [usually yielding the right of way].
Levy p. 5: "Because of the relatively good safety record of the operation, the
National Highway Traffic Safety Administration (NHTSA) has not ranked school bus design
improvements among its top priorities." ...
Levy p. 6: "Deaths and injuries of pupils resulting from school
bus accidents remain at high levels in New York State. In the decade 1975-1985,
there was an average of 844 accidents per year resulting in 5,670 pupil
injuries and 18 pupil fatalities ona and off the buses.... In the 1984-85
school year, school buses were involved in 466 accidents resulting in 239
pupil injuries and one fatality compared to the 1983-84 school year when
school buses were involved in a total of 690 accidents, resulting in 348
injuries and seven fatalities." ... ------------------------------------ page break --------------------------------------
Page Count: 48 of 79 Page 38 Accident Potential, Always Present
Levy pp. 7-8: "The danger of accidents involving school buses is always
present as Senator Norman J. Levy stressed at a public hearing on school
bus safety in Albany on November 14, 1983:
"'Even the most exemplary of busing operations can not anticipate the mistakes that
other users of the road will make as well as their own mistakes. The most vigilant of
bus drivers will be forced to deal with hazardous road conditions caused
by weather and unexpected mechanical failures. It goes almost without saying
that accidents can not be totally avoided." ... Is Relatively-good Safety Good Enough?
Levy p. 8: "Although school buses are one of the safest
forms of transportation and though 'the number of {school bus} fatalities
and injuries is relatively small...we must decide if relative safety is
enough.'" ... [Hearings, 8 December 1983, Agnes Kalemaris'
statement, Suffolk County District Parent- Teacher Association.] Need for Legislative Action, Before a Tragedy Occurs
Levy p. 8: The central concern continues: will New York State or the federal
government have to respond legislatively to a major tragedy because it
settled for relative safety based upon statistical records?" Special Safety Measures Taken by New York State
Levy p. 9: "School buses inherently are much less safe in terms of construction
than intercity buses, city transit buses, and passenger cars [are]....
[School] buses are still not able to protect children in the event of an
accident. The New York State Legislature acted to improve school bus safety
prior to the promulgation of the federal regulations by requiring buses
manufactured after December 31, 1975, to be equipped with 28-inch padded
seats--which have proven to provide whiplash protection superior to that
provided by seats meeting the federal standard.... In 1977, New York State
also exceeded federal standards by requiring roof hatches and additional
emergency exits on school buses."
Levy p. 10: "School bus safety advocates charged that these [federal
school- bus safety standards, effective 1 April 1977] regulations are inadequate
relative to passenger seating, crash protection, and emergency exits.
"Maintaining the State's excellent
school bus safety record is a high priority item on the State legislative
agenda. In a report, School Bus Safety in New York State...Children
at Risk, LCCTC recommended [that] all buses manufactured for use in
New York State after July 1, 1986, be equipped with seat belts, back-up
beepers, front crossing control arms, and twenty-eight inch padded seats
on school passenger vans." ... Standees on School Buses
p. 30: "A related grave and fundamental issue of school
bus safety is the practice of permitting school children to stand in the
aisles of school buses while being transported to and from school. It is
obvious that many of New York State's existing school bus safety features,
such as compartmentalization, do not protect students who are forced [or,
who choose--S.L.] to stand in the aisles.
"Senate Bill 2123B, introduced in the New York State Senate by
Senator Norman J. Levy in the 1985 session, would phase out standees over
a three year period, beginning on September 1, 1987.
"Present New York law permits, and even encourages, this practice. School districts
are required to transport all students who live more than one half mile from their school
and all handicapped children. If a district chooses not to transport children who
do not fit into either of these categories, the New York State Education
Department (NYSED) does not provide transportation aid to the district
for these children and districts must absorb the total cost. Therefore,
in order to receive the maximum State aid available for each bus, some
students will be transported without a seat."
Levy p. 31: "The elimination of standees on school buses was the single most widely
endorsed modification of existing law at the school bus safety hearings
held by the LCCTC in 1983. Ronald Segedy, Assistant Commissioner for the
New York State Department of Motor Vehicles (DMV), stated:>
"'Allowing passengers to stand on buses removes those standees
from the protective features of the bus and makes the standees unnecessarily
susceptible to injury in the event of a rapid change in the speed [I'd
prefer he say "velocity," in this context, since velocity is
a vector, while speed is a scalar quantity--S.L.] of the bus and in the
event of a collision not only are the standees themselves placed at risk
of injury, but also seated school bus occupants who are in the path in
which a standee's body may be thrown in the event of a crash [are at risk].'..."
[Ronald Segedy, Assistant Commissioner, New York State Department of Motor
Vehicles, Hearings, 8 December 1983.] Findings and Conclusions, Levy Report
Levy p. 32: "While considerable progress has been made in school bus safety in the past
years, more of vital importance remains to be done, and now, not in the future, to protect
the children who ride in New York's school buses. Although the skill and
sense of responsibility of the driver and the soundness of operational
practices play a vital role in accident avoidance, the school bus must
be built in the future with more injury and life saving protection in mind
and fact. Even an exemplary busing operation has to contend with the mistakes
of other drivers, hazardous road conditions, or vehicle failure.... Accidents
may be unavoidable, but the outcome need not lead to human tragedy. Although
today's automobiles are built with occupant protection in mind, school
buses have not been designed with the same degree of emphasis upon occupant
protection. ----------------------------------- page break ---------------------------------------
Page Count: 49 of 79 Page 39
"In addition, the required use of seat belts in passenger automobiles in New York State
and their acknowledged safety value make their absence in school buses even less justifiable
and acceptable. Although it is important to recognize that belts alone do not provide
adequate protection, the suggestion that belts in buses create a greater hazard than buses
without belts has been conclusively rebutted as a result of the LCCTC hearing,
extensive staff research, and the University of Michigan study. Another
argument in support of seat belts on school buses is [that] children are
required to use belts in the family automobile and consequently are more
apt to want to buckle up in the school bus, and when they can not, are
put into a state of anxiety when riding unbelted.
Levy p. 33: "The New York State School Board Association,
school transporter associations, many school bus manufacturers and local
school boards are opposed to seat belts on school buses allegedly because
of increased costs. This spurious argument is not borne out by the facts.
The cost for belts varies from $1,100 to $1,500 for a sixty-six passenger
bus and adding additional padding to seat backs and tops will cost an estimated
$300 per bus. However, if seat belts are mandated statewide, the cost of
belts would decrease as a result of increased competition among school
bus manufacturers. School districts receive up to 90 percent reimbursement
in State education aid for state transportationi costs which means that,
for a school district, the cost for seat belts and improved padding will
range from $140 to $180 per bus, a small price for the obvious safety enhancement.
"Another concern which has been raised over the years is that seat belts are used by
children as "weapons." However, this concern is unfounded based on both the
practical experience of school districts already using belts and by the expert testimony
provided by school bus safety advocates such as the New York State PTA, Physicians
for Automotive Safety, National Coalition for Seat Belts on School Buses,
new York Coalition for Safety Belt Use, and the American Pediatrics Association.
Levy p. 34: "Many of the arguments raised against the use of seat belts are similar to
those originally raised in opposition to other safety features such as the twenty-eight
inch padded [seatbacks]. At least one of the groups, the New York State Association for Pupil
Transportation, originally opposed the twenty- eight inch seat backs and later changed
its position based upon the safety record and practical experience since
the use of this safety feature was mandated" ... [Testimony of Michael
Joyce, President, New York State Association for Pupil Transportation,
in Round Table Discussion, pp. 56-57.] Recommendations, Levy Report
Levy pp. 34-36: "Providing safety belts in school buses will save
lives and prevent or reduce the severity of injuries.... Requiring extra
padding on seat backs combined with lap belts will reduce further HIC levels
and facial lacerations in school bus accidents. Seat belt use on school
buses will have a positive carry-over effect on school children when they
are being transported in passenger vehicles.
1. Safety belts should be standard equipment on every school bus manufactured
on and after July 1, 1987, for use in this State. 2. Improved padding on seat backs and metal cross bars should be required
on all school buses equipped with seat belts, with such improved padding
exceeding current federal standards by twenty percent. 3. Standees on school buses should be phased out over a three year period
beginning with the 1987-88 school year. 4. Pre-1977 school buses should have a useful life which does not exceed
ten years unless an exemption is granted by the Commissioner of Transportation. 5. Post 1977 school buses should have a useful life which does not exceed
twelve years, unless an exemption is granted by the Commissioner of Transportation.
6. Post 1977 school buses should be retrofitted with seat belts and
additional padding on a case by case basis. The Commissioner of Transportation
should promulgate rulesand regulations necessary to effectuate such retrofitting
and [should] have the power to prohibit certain designed school buses from
retrofitting. 7. Retrofitting should be 100 per cent state aidable. 8. Pre-1977 school buses should not be retrofitted with seat belts. 9. The Commissioner of Motor Vehicles should develop a course of instruction
on the safe use of seat belts for grades K-12. 10. School bus operators should receive training on the proper use of
seat belts by all school bus passengers. 11. All seat belts should be color coced to eliminate confusion amongst
passengers. [Note other NCSSB recommendations as well. E.g., see Index
entry "NCSSB guidelines to seatbelt installation.--S.L.] 12. The Congress should enact Federal legislation which would require
the installation of seat belts on new school buses, nationwide." ----------------------------------- page break ---------------------------------------
Page Count: 50 of 79 Page 40
Levy p. 36: "Including additional padding on the backs of school bus seats in
conjunction with lap belts in New York State's present 28-inch [seatback] will ensure
children a safer ride to and from school. Logic indicates that there will be less impact
to the head during a front end collision if there is more padding on the seat
back. However, LCCTC recommends additional research by Transport Canada,
NHTSA, and other similar safety organizations relative to the following
alternatives to lap belts which may possibly provide even more protection
to children riding school buses in the future. Additional research should
not be, and is not, a justification for not acting now to require seat
belts on school buses: 1. Three point seat belts. 2. Contoured heavy thick padded seats. 3. Redesigned seat backs employing no metal crossbars. 4. A forward facing multi-point restraint system. 5. A rear facing multi-point restraint system. 6. Harnesses anchoring to the seat in four places--two at the shoulder
and two at the lower back level. 7. An upper torso built system similar to ones used on aircraft.
[Return to Home Page ]
[Title Page ]
[Preface to 1996 Edition ]
[About the Author ]
[Foreword to 1990 Edition ]
[Table of Contents ]
[Main Body ]
[Appendix A. Compartmentalization ]
[Appendix B. TRB Special Report 222, May 1989 ]
[Appendix C. Endorsements ]
[Appendix D. Testimonials ]
[Appendix F. Legalities ]
[Appendix G. Guidelines to Seatbelt Implementation]
[INDEX ]
[Responses To This Site ]
[Related Sites ]
TABLE 1
-----------------------------------------------------------------------------------------
*AVERAGE ANNUAL ESTIMATES OF THE RESULTS OF SCHOOL BUS ACCIDENTS, 1981-83
(Based on NASS and FARS Statistics for 1981-1983, NCSA)
• 17,000 - 18,000 police reported accidents
• 5,000 - 6,000 injured passengers, of which
• 30 seriously injured (requiring hospitalization) passengers, and only
• An average of six fatal accidents with at least one passenger fatality
• An average of 11 passenger and 1-2 driver fatalities
• An additional 50 fatal accidents where the death occurs to a non-bus
occupant: pedestrian, 35; motorcycle, 10; other vehicle, 5.
-----------------------------------------------------------------------------------------
"OCCUPANT FATALITIES BY PRINCIPAL DIRECTION OF IMPACT AND ROLLOVER
[EXCERPT LIMITED TO TYPE I SCHOOL-BUS DATA, ONLY--S.L.]
|----------------|-------------------------------------|
| PRINCIPAL | (PASSENGERS ONLY) |
| |-------------|------------|----------|
| IMPACT | NO | ROLLOVER | TOTAL |
| | ROLLOVER | | |
| DIRECTION | | | |
| | (%) | (%) | (%) |
|----------------|-------------|------------|----------|
| FRONT | 20.6 | 35.3 | 55.9 |
|----------------|-------------|------------|----------|
| SIDE | 14.7 | 0 | 14.7 |
|----------------|-------------|------------|----------|
| REAR | 0 | 0 | 0 |
|----------------|-------------|------------|----------|
| UNDERCARRIAGE | 2.9 | 0 | 2.9 |
|----------------|-------------|------------|----------|
| NON-COLLISION | | | |
| ROLLOVER | -- | 14.7 | 14.7 |
|----------------|-------------|------------|----------|
| NO ROLLOVER | 11.8 | -- | 11.8 |
|----------------|-------------|------------|----------|
| OTHER,UNKNOWN | 0 | 0 | 0 |
|----------------|-------------|------------|----------|
| | 50.0 | 50.0 | 100 |
|----------------|-------------|------------|----------|
©Stephen A. Langford, Oro Valley, Arizona, 29 September 1996.
ALL RIGHTS RESERVED.
This document may be freely transmitted in its entirety,
so long as no monies are earned during the transaction/s.
Permission is required for any and all other pertinent circumstances.
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