(Seal, U.S. Dept.
Transportation)
U.S. Department 400 Seventh Street, S.W.
of Transportation Washington, D.C. 20590
Traffic Safety
National Highway
Administration
SEP 10 1996
Mr. Stephen A. Langford
9140 North Shadow Mt. Drive
Tucson, AR 85737
Dear Mr. Langford:
Thank you for your letter to Secretary Peña concerning seat belts on school buses. Your letter has been forwarded to the National Highway Traffic Safety Administration (NHTSA) for reply. NHTSA is responsible for establishing Federal motor vehicle safety standards to reduce the number of fatalities and injuries from motor vehicle crashes, including those involving school buses. We also work with the states on school bus safety and occupant protection programs. School bus safety is one of our highest priorities. You asked that we review your paper entitled "Seatbelts for School Buses" and make suggestions concerning improvements to your paper. We do not review and comment on position papers from individuals or outside interests. However, we can provide you with information concerning seatbelts on school buses.
School bus transportation is one of the safest forms of transportation in the United States. We require all new school buses to meet safety requirements over and above those applying to all other passenger vehicles. These include requirements for improved emergency exits, roof structure, seating and fuel systems, and bus body joint integrity. These requirements help ensure that school buses are extremely safe.
Every year, approximately 394,000 public school buses travel approximately 4.3 billion miles to transport 23.5 million children to and from school and school-related activities. 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 when compared to those in other types of motor vehicles. For example, in 1994, no occupants of a school-bus-body type vehicle bus died in a crash. During the same year, 5,725 children between the ages of 5 and 18 died as passengers or drivers in all other types of motor vehicles.
School bus crash data show that a Federal requirement for belts on buses would provide little, if any, added protection in a crash. The National Transportation Safety Board (NTSB) and the National Academy of Sciences (NAS) have come to the same conclusion. NTSB concluded in a 1987 study of school bus crashes that most fatalities and injuries were due to occupant seating positions being in direct line with the crash forces. NTSB stated that seat belts would not have prevented most of the serious injuries and fatalities occurring in school bus crashes.
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. NAS also stated that the funds used to purchase and maintain seat belts might better be spent on other school bus safety programs and devices that could save more lives and reduce more injuries. A summary of the NAS report is enclosed.---------------------------- END PAGE 1 ------------------------------- ---------------------------- START PAGE 2 -------------------------------
[This is insulting. If Hackney had bothered to look at my Web site, he could easily have discovered that his enclosure is none other than my paper's Appendix B., TRB Special Report 222, May 1989. He might also have taken time to counter arguments presented in the paper against these stale, hackneyed N.H.T.S.A. positions. S.L., 29 September 1996]
Small school buses, those with a gross vehicle weight rating under 10,000 pounds, must be equipped with lap or lap/shoulder belts at all designated seating positions. Since their sizes and weights are closer to those of passenger cars and trucks, the agency believes seat belts in those vehicles are necessary to provide occupant protection.
School bus pedestrian fatalities account for the highest number of school bus related fatalities each year. There are about 31 such fatalities per year, about two-thirds of which involve the school bus itself and about one-third of which involve motorists illegally passing the stopped school bus. In its 2989 report, NAS stated that since children are at "greater risk of being killed in school bus loading zones (i.e., boarding and leaving the bus) than in the bus, a larger share of the school bus safety effort should be directed to improving the safety of school bus loading zones." NHTSA agrees with NAS that states and localities should focus their efforts toward improving school bus loading zones.
While no Federal requirement exists for seat belts on large school buses, states and localities are free to install them if they feel it is in the best interest of safety in their area. However, the NAS report states that if seat belts are to be beneficial, "states and local school districts that require seat belts on school buses must ensure not only that all school bus passengers wear the belts, but that they wear them correctly.
Seat belts have been required on passenger cars since 1968. Most states have enacted laws requiring wearing of seat belts in passenger cars and light trucks. Laws governing the usage of occupant restraints are the prerogative of each state. We are sensitive to the fact that wearing seat belts is important. School buses are heavier, experience less crash forces, and distribute crash forces differently than do passenger cars and light trucks. Because of this, the crash force experienced by the passengers of large buses is much less than that experienced by occupants of passenger cars, light trucks, or vans. Federal regulations require the installation of occupant restraints in motor vehicles based on the? vehicle type and size.
Because the safety record of school buses is outstanding and because there is no compelling evidence to suggest that seat belts would provide even higher levels of occupant protection in crashes, NHTSA agrees with the NAS report that there is insufficient reason for a Federal mandate for seat belts on large school buses.---------------------------- END PAGE 2 ------------------------------- ---------------------------- START PAGE 3 -------------------------------
I hope that this information is helpful to you. If I can be of further assistance, please contact me or Charles Hott, Safety Standards Engineer, at (202) 366-0247.
Sincerely, James R. Hackney, Director Office of Crashworthiness Standards Enclosure---------------------------- END LETTER ------------------------------- 
Too many points made in my paper
go ignored in this standardized response from N.H.T.S.A. I encourage readers to contact Hackney. But, I suspect all you'll get from him is more boilerplated bureaucratese. S.L., 29 September 1996. ©Stephen A. Langford, Oro Valley, Arizona, 1 February 1997. 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. (Metering for this page begun 29 September 1996.)
