January 24, 1997

L. Robert Shelton
Associate Administrator for
 Safety Performance Standards, NHTSA
400 Seventh Street, S.W.
Washington, D.C.  20590

Dear Mr. Shelton:

1) In that response you say that "Since 1984 on the average, 11 passengers per year have died in school bus crashes. While each of these fatalities is tragic, it should be noted that the numbers of fatalities among school bus occupants are small compared to those in other types of motor vehicles."

While I am sure this is true, considering the percentage of time a child spends on a school bus is relatively small compared to the time spent in the family car, I don't think that these deaths should be trivialized because of their small number. Each death represents a significant loss and unimaginable anguish and suffering for that child's parents, family members, and community. I wonder: How many of those deaths could have been avoided had seat belts been used?

A larger issue is the number of injuries which could be avoided by seat belt usage. According to Special Report (SR) 222 by the Transportation Research Board (TRB), it is estimated that 11,400 injuries occur inside of school buses each year. These injuries result in lost educational time and possibly long-term medical problems for children. TRB Report 222 concludes that 50% usage of seat belts on school buses would reduce injuries by up to 20%. This represents a significant savings in medical bills, lost educational time, and perhaps lost work time on the part of the parents to obtain/provide medical care.

Consequently, seat belt usage on school buses is endorsed by the American Academy of Pediatrics, the American Society for Adolescent Medicine, the American Medical Association, The American College of Emergency Physicians, the American Association for Oral and Maxillofacial Surgeons, the American College of Preventive Medicine and Physicians for Automotive Safety. These physicians see first-hand the consequences of not using seat belts on school buses and obviously believe a significant number of the injuries and deaths are preventable.

     
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I believe this means that the children were not properly seated and thus were ejected from their compartment. Proper seating is an absolute necessity for compartmentalization to work at all. Enclosed is a report by the Pupil Transportation Safety Institute which concludes that seat belts do help to ensure that children stay properly seated.

Furthermore, I would like to relate my own personal experience during a recent field trip for my son's first grade class. We were going to see the Baltimore Symphony Orchestra perform "Peter and the Wolf." The kids were extremely excited, bouncing on the school bus seats, standing up to talk to friends and turning around in the seats. Repeated warnings from the teachers and school bus driver to sit down went unheeded. I am sure this scenario is typical of most school bus commutes, whereas if the kids had been in seat belts, the ride would have been undoubtedly much safer and calmer.

3) You say that "In 1989, NAS completed a study of ways to improve school bus safety and concluded that the overall potential benefits of requiring seat belts on large school buses are insufficient to justify a Federal requirement for mandatory installation."

I would like to point out that this is not a unanimous conclusion of the study's committee members. The NAS report also says "Nevertheless some members believe that a uniform occupant- restraint policy for all motor vehicles is important enough that states and local school districts should be encouraged to equip new school buses with seat belts."

Indeed, New York State has adopted a mandatory seat belt law for school buses and there are many local school districts nationwide which have installed seat belts on school buses. However, a great deal of time, energy and money is now wasted by state and local communities in arguing repeatedly for seat belt installation on school buses, whereas a change in policies could obviate the need for this. I am seeing this first-hand since I am now also pursuing this issue with my local school district.

Other valid arguments with the TRB Special Report are made in Appendix B of "Seat belts for School Buses," the paper which I attached to my original letter. It is also available on the Internet at http://www.theriver.com/Public/busbeltkids.

4) You say "Rather than requiring seat belts, NHTSA decided that the best way to provide crash protection to passengers is through a concept called 'compartmentalization.' This requires that the interior of large buses provide occupant protection so that

     
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However, the original concept of compartmentalization called for 28" high padded seats, padded arms at the ends of seats to keep children from falling into the aisle, and lap-style seat belts. Federal standards implemented in 1977 reduced the seat backs to 24" and eliminated the padded arms and seat belts. Although this dilution of the standards is still called compartmentalization, it does not provide the level of protection envisioned by its creators and is not the panacea that was hoped for.

5) You say that "NHTSA is not aware of any official study that indicates that the addition of seat belts improves student behavior."

The aforementioned report by the Pupil Institute does conclude that consistently implemented seat belt use policy "will improve student behavior, control certain types of fatal student actions, and reduce driver distraction."

6) You say that "We know of no evidence to suggest that requiring seat belts in school buses would have a significant carry-over-effect causing children to wear seat belts in other motor vehicles that are required to be equipped with seat belts."

The attached report by the Pupil Institute states that "Students who have been asked to wear seat belts on school buses since they were in kindergarten, wear seat belts as much as 80% of the time on the school bus. High school students who have only been exposed to belts on buses for a few years tend to comply 30-50% of the time. This indicates that seat belt use on school buses starting at a young age creates positive habits."

In my letter to President Clinton, I mentioned that my son's question after his first day of school was "Mommy, why doesn't my school bus have seat belts?" I think his question shows the conflicting message being sent to our children regarding seat belt usage and the need to correct it. Other children have had the same question as my son's.

It has been 20 years since compartmentalization was introduced, and there has since been no significant reduction in deaths or injuries. It is time for NHTSA to accept that this concept, as implemented, is not working as planned and for you personally to take corrective action so that additional injuries and deaths can be minimized.

     
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                    Sincerely,
     
     
     
                    Darleen M. DiGirolamo
   
Attachment:
"Seat Belts and School Buses"  
 
cc:  President Clinton
     Vice President Gore

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[Gee! I couldn't have said it better myself! ;) --SL, 1 February 1997]

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Responses To This Site

[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 E. Studies and Recommendations ] [Appendix F. Legalities ] [Appendix G. Guidelines to Seatbelt Implementation] [INDEX ] [Related Sites ]

©Stephen A. Langford, Oro Valley, Arizona, 1 February 1997.  
ALL RIGHTS RESERVED.  
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Permission is required for any and all other pertinent circumstances.


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