--- END PAGE 1 OF 4 --- --- START PAGE 2 OF 4 --- 2) By not having seat belts on buses, we are participating in "negative education" in that all our educational effort of training children to wear seat belts in passenger cars and light trucks are undone when they start riding in school buses. 3) Seat belts on school buses are endorsed by the American Academy of Pediatrics, American Academy of Orthopaedic Surgeons, American Medical Association, and the National Parent-Teacher Association.First, I would like to address your concern about the effectiveness of the current requirement for occupant protection in school buses. 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.
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 children are protected without the need to buckle-up. Occupant crash protection is provided by a protective envelope consisting of strong, closely-spaced seats that have energy-absorbing seat backs. The effectiveness of compartmentalization has been confirmed in the NTSB and NAS studies.
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.
The school. bus driver has a seat belt. A belt is needed to protect the driver because the area around the driver is not compartmentalized. Thus, in a crash, as padding and spacing of the seats protect the passengers from harmful contact with components of the bus, the seat belt protects the driver from contact with the windshield, steering wheel or other area.
--- END PAGE 2 OF 4 --- --- START PAGE 3 OF 4 ---School bus accident data show that there are approximately 23,000 school bus crashes per year. Most of these crashes are from the rear. The accident data also show that school bus rollovers are infrequent, less than 0.5 percent of the accidents. The high back seats in school buses provide occupant protection from rear crashes. These seats are also designed to absorb the impact energy from rear crashes, as well as, frontal crashes. Most crashes with fatalities in school buses are from frontal collisions. [Exactly where are the data, source, and authority for this particular statement? Does he refer to TRB Special Report 222 here, or what? --SL, 1 Feb 1997]
You stated that studies have shown that seat belts in school buses solve discipline problems since all students are confined to their seats and that the tall seats in school buses encourage passengers to stand up and bend over the seats to talk to their friends. NHTSA is not aware of any official study that indicates that the addition of seat belts on school buses improves student behavior. [Has NHTSA ever used simple common sense, consulted with child psychologists on this point, or read anything written or compiled by National Coalition for Seatbelts on School Buses or the summaries thereof presented at my Web site? --SL, 1 Feb 1997] A study performed for the State of Florida, "To Belt or Not To Belt?; Experiences of School Districts that Operate Large School Buses Equipped with Seat Belts" indicates that student behavior did not improve with the installation of seat belts in school buses (Executive Summary enclosed). . . .
[It is easy to present one study that bolsters the NHTSA position. It would be more honest to present various studies and opinions expressed by various authorities, on such issues, and then to present NHTSA's rationale for holding to its current position or for changing its ?mind?. For instance, what about citing as well the study "Seat Belts and School Buses," a 1994 report resulting from a project developed by Madison-Oneida BOCES and funded by the New York State Governor's Traffic Safety Committee for the New York State Education Department (and cited by Ms. DiGirolamo)? That study STRONGLY endorses and recommends the use on ALL school buses. --SL, 1 Feb 1997]
. . . The use of high back seats is the only known means of providing adequate crash protection from the rear.
[I do not argue against high seat backs or compartmentalization. I believe that compartmentalization can be improved by installation and use of seatbelts, which Ms. DiGirolamo points out in her response to this letter from Shelton, were part of the original compartmentalization rationale. These need not involve either/or choices! To say that they do is to confuse the issues. --SL, 1 Feb 1997] Discipline problems such as standing while the bus in motion [sic., --SL, 1 Feb 1997] can only be resolved by the use of effective training and enforcement programs. ["Only"? How stupid!! Seatbelts help to keep students in their seats, when bus drivers enforce that they be used properly. Seatbelt usage is part and parcel of effective childhood training. To argue otherwise is simply to display stupidity. Have bureaucrats no sense of reason at all? --SL, 1 Feb 1997]
You also stated that by not having seat belts on buses, we are participating in "negative education" in that all our educational efforts of training children to wear seat belts in passenger cars and light trucks are undone when they start riding in school buses. NHTSA is not sure how to interpret the term "negative education" but it can be interpreted to mean that not requiring seat belts on all school buses sends a conflicting message to children about wearing seat belts. [ La-de-da! --SL, 1 Feb 1997] 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. [Pure, stupid obstinacy. --SL, 1 Feb 1997] We are sensitive to the fact that wearing seat belts is important. Seat belts have been required on passenger cars since 1968. Most states have enacted laws requiring wearing of seat belts in passenger cars acid light trucks. Laws governing the usage of occupant restraints are the prerogative of each state. 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 school buses is much less than that experienced by occupants of passenger cars, light trucks, or vans.
You further stated that seat belts on school buses are endorsed by the American Academy of Pediatrics, American Academy of Orthopaedic Surgeons, American Medical Association, and the National Parent-Teacher Association. NHTSA considers all opinions during its rulemaking activities, however, its primary goal is to establish standards for motor vehicle that have a firm basis in scientific fact. Therefore, 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 3 OF 4 --- --- START PAGE 4 OF 4 ---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." 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 1989 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. I hope that this information is helpful to you. If I can be of further assistance, please contact me or James R Hackney, Director, Office of Crashworthiness Standards, at (202) 366-1740. [It ought to be possible to sue such people directly. At the very least, I can here suggest that such people should not be working for my Federal Government.--SL, 1 Feb 1997]
Sincerely, [Signature] L. Robert Shelton Associate Administrator for Safety Performance Standards 2 Enclosures cc: White House --- END PAGE 4 OF 4 ---
©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 1 February 1997.)
