Kathy Kitchen, Editor

Seat Belts on Large School Buses

Everyone should know that school buses are the safest form of highway transportation in this country today!   Today’s school buses are built and equipped in a manner to provide a high level of safety to its passengers.  Everyone involved in the pupil transportation business — manufacturers of buses, pupil transportation personnel, and governmental agencies — are constantly looking for improvements to ensure our students are transported daily in a safe a manner as possible.

In the Commonwealth of Virginia, nearly 12,000 buses transport more than 876,000 students daily totaling about 113 million miles annually.  Nationally, these numbers climb to 440,000 buses traveling nearly 4.3 billion miles to transport 23.5 million students every year.  According to the National Highway Traffic Safety Administration, an average of 11 passengers under the age of 19 die in school bus related crashes each year.  While even one is too many, this number of fatalities is very small when compared to the nearly 5,500 deaths among the same age group in all other types of motor vehicles.

The debate over whether or not seat belts should be required on large school buses has been active for many years.  As early as 1967 researchers at UCLA examined school bus occupant protection and recommended the use of lap belts in all large school buses.  Nearly 25 years later, the debate continues with interested groups from local PTAs, government agencies, school boards, and the pupil transportation community expressing varied opinions.

The issue of seat belts on school buses has been very controversial with studies and opinions from many sources advocating the use of seat belts or denouncing the need based on the same accident data.

Proponents cite these major arguments in favor of seat belts on large buses:

• Protecting children in an accident – Children can be thrown around within the bus when involved in a side impact or rollover crash.  Seat belts will keep children in their seats and reduce the likelihood of injury from being “out-of-position.”
• Education – Parents teach children to “buckle up” in their personal automobiles from a very young age.  Many claim that the lack of seat belts on the school bus causes confusion for young children.
• Litigation – Injured parties have filed suit against drivers, school districts/contractors, dealers and manufacturers for failure to provide seat belts.
• Passenger Behavior – Proper use of seat belts may improve student behavior on the bus and reduce driver distraction.
• Low Cost – The cost to install lap belts in school buses is relatively low at approximately $2,000 per bus.

Opponents cite:

• No effect on the most common fatalities and injuries – NHTSA data shows that most school bus injuries and fatalities occur to individuals in other vehicles and students outside of the bus.  The installation of seat belts in buses would not alter these outcomes.
• Ineffective in catastrophic accidents – seat belts may impede rapid egress from the bus in cases of fire or sinking in a body of water; they would also be ineffective in collisions with trains or semi-trucks.
• No guarantee of use – Installation of belts does not guarantee students will use them.  Drivers do not have the ability to monitor that the belts are being used properly or used at all.  Children may receive a mixed message if belts are installed, but not used.
• Seat belts can cause injury – Children have been injured by seat belts used as weapons or by tripping over loose belts.  In addition, much research shows that lap belts are not appropriate for young children and can actually cause internal injury during an accident.
• Speed, weight and mass differences – It is well known that excess speed kills.  School buses are highly regulated to travel at lower rates of speed.  In addition, school buses weigh 8 to 10 times more than automobiles; the energy in a collision is absorbed by the bus with less of the force affecting the occupants.

With all of the positives and negatives cited above, two major issues still come to the forefront whenever seat belts on school buses are discussed.  First is the issue of compartmentalization.  The concept of compartmentalization is to surround the children in a cocoon or compartment to absorb the energy associated with a crash.  This is often referred to as a “passive restraint system” where all students are automatically protected without any action being required on their part.

Seat backs are made higher, wider and thicker, with all metal surfaces covered withenergy absorbing padding.  This design must pass rigid test requirements as if a child were thrown against the seat back.  The seats also have an inner steel structure that bends forward to help absorb the force when a child is thrown forward.  The frame must give enough to absorb the weight of the student, but is solidly anchored to the floor to ensure it will not break loose during a collision.

According to Charles Holt, NHTSA’s school bus specifications engineer, “In compartmentalization the crash forces are absorbed by the vehicle structure which is designed to protect the occupant.  In an occupant restraint system in general passenger vehicles the crash forces are absorbed by the body of the occupant.”  The different concepts, therefore, lead to some difficulty in combining the two systems.  Current bus specifications allow the seat back to bend at 1,000 pounds of force to absorb some of the crash force that is required for compartmentalization to work.  However, Federal Motor Vehicle Safety Standard 208 requires seat backs to withstand 5,000 pounds of force to provide the anchorage strength necessary to provide for a shoulder belt system.  “From a practical standpoint, you have to go with one or the other,” said Holt.  “You can’t have both passive compartmentalization and an active, 3-point occupant restraint system that restrains the torso.”  This leads to a decision that can be difficult to make.  All children are protected by a passive system; however, if a 3-point system is installed without compartmentalization and then it is not used, children are left with little or no protection at all.

The second major issue surrounds the debate over what type of active restraint system would be best suited to use in school buses.  Obviously, the two-point system, commonly referred to as “lap belts,” would be possible to install on buses currently in use.  It is the lap belt system that has been advocated for many years by the proponents of seat belts in buses.  For the reasons cited above, use of the three-point system (lap/shoulder belt) would be more problematic.  Redesign of the school bus body would be required to accommodate such a system.

Much discussion has centered on whether or not lap belts are an effective means forreducing the risk of injury in school bus crashes and whether or not they are appropriate for young children.  Since the mid-1980’s, significant data has been gathered on the benefits of lap belts and lap/shoulder belts in passenger cars.  Based on that data, NHTSA currently estimates that lap belts in school buses would be at best 5 percent effective in reducing school bus passenger fatalities.   After examining the data where lap belts may have caused additional injury, NHTSA estimates that lap belts would have no overall effectiveness in school buses (http://www.nasdpts.org/paperCrashProtect.html)

An internal panel of experts on motor vehicle occupant protection testified in 1998 at a public hearing held by NHTSA on bus crashworthiness and occupant survivability.  Five researchers from Europe, Australia, Canada, and the United States were asked specifically about the appropriateness of lap belts in providing crash protection to small children.  They all agreed that it was not a good way to provide crash protection to small children because their bone structure, particularly their hips, is still developing.  Other research has shown that contusions of the abdomen and spinal injury have been associated with the two-point lap belt system.  While some of the same injuries can occur with the three point system, it appears to provide more support for the lumbar spine.

As far back as 1967, researchers have been examining the issue of school bus occupant protection.  Major events through the years addressing this subject are:

• 1977 ­ The National Highway Traffic Safety Administration promulgated through rulemaking Federal Motor Vehicle Safety Standard 222 “School Bus Passenger Seating and Occupant Protection.”  All buses built prior to this regulation became known as “pre-DOT” buses with most states taking action to eliminate their use over a number of years
• 1987 ­ The National Transportation Safety Board completed detailed analyses of 43 serious accidents involving large school buses to evaluate the effectiveness of compartmentalization.  Entitled “Crashworthiness of Large Poststandard School Buses,” (Report Number NTSB/SS-87/01, March 18, 1987) the report reconstructed each crash, evaluated the movement of occupants inside the bus, and identified the cause of injury or fatality.  An evaluation was made to determine whether the use of lap belts would have made any difference in the outcome.  Among other things, NTSB concluded that lap belts would not have prevented most of the serious injuries or fatalities.
• 1989 ­ The National Academy of Sciences completed a study of ways to improve school bus safety and concluded that the overall benefits of requiring seat belts was insufficient to justify a federal mandate.
• 1999 ­ The National Transportation Safety Board completed a special investigative report entitled,  “Bus Crashworthiness Issues” (NTSB/SIR99/04, September 21, 1999)

http://www.ntsb.gov/Publictn/1999/SIR9904.htm

The report concluded that current compartmentalization is incomplete relating tolateral impacts with vehicles of large mass and in rollovers because passengers do not always remain completely within the seating compartment.  They further concluded that it could not be determined whether the current design of available restraint systems for large school buses would have reduced the risk of injury to passengers in the accidents analyzed.  Therefore, the NTSB recommended that NHTSA develop performance standards for school bus occupant protection systems that account for frontal impact, side impact, and rear impact collisions as well as rollovers.  In essence, this recommendation asked NHTSA to do exactly what their current study, announced in 1998, is intended to do.

In August of 1998, the National Highway Traffic Safety Administration announced a two-year research program to “develop the next generation occupant protection system.”   The objectives of the plan are to:

• enhance current crash data to better define the types of crashes that cause injury to occupants and determine the effectiveness of school bus occupant protection systems;
• evaluate alternative methods of occupant protection in a controlled laboratory setting; and
• propose the next generation of occupant protection requirements for school buses.  They have further stated that the following criteria for future improvements must be met:
• likely to reduce the number of injuries or fatalities associated with school bus crashes;
• provide protection for the wide range of occupants transported;
• be technologically feasible;
• be reasonable in cost; and
• not substantially reduce the seating capacity of school buses or substantially inhibit emergency evacuation.

(http://www.nhtsa.dot.gov/people/injury/buses/schbus/schbusintro3.html)

While the study was originally billed as a two-year research program, no results have yet been released by NHTSA.  The National Association of State Directors of Pupil Transportation have stated in their position paper:

The State Directors Association believes it is inappropriate to consider legislation, at any level, to require lap belts in school buses while the Federal government is conducting research that is designed to develop the next generation of passenger crash protection systems in school buses.  Without attempting to pre-judge the outcome of the NHTSA’s research program, it does not appear that the agency would conclude that lap belts, a 30-year-old technology, were the most effective form of passenger crash protection for school buses for the next century.  Rather, with the advancements that have been made in lap/shoulder belt systems and energy absorbing materials and construction techniques, it would appear that NHTSA would propose changes to school bus passenger crash protection utilizing the latest technologies.

While there is no federal law requiring seat belts on school buses, currently two states require the installation of lap belts on large school buses ­ New York and New Jersey.  However, New York does not have a law requiring students to use the lap belts.  Such requirements are left up to the individual school districts.  Recent data (nasdpts) shows that only 26 of the 709 public school districts have adopted such policies.  Those districts report a high percentage of elementary and middle school students use the belts with less than half of the high school students doing so.

New York required the installation of lap belts in all new school buses purchased after June 30, 1987, with New Jersey having the same requirement in 1992.  Florida, California and Louisiana passed laws 1999, but have announced they will wait for the NHTSA to complete their occupant restraint study before deciding the exact system to use.  NHTSA attempted to conduct a study of the effectiveness of the belts in school buses in New York and New Jersey several years ago.  However, the study did not generate any useful information, as there had been no serious accidents involving buses where lap belts were in use.

One of the regulations put into place shortly before the Clinton Administration left office was the final rule on Head Start transportation.  This regulation was originally published as a Notice of Proposed Rulemaking on June 15, 1995.  Two major issues surfaced during this regulation development process that led to the six-year delay in having a final rule.  First was whether the regulation would require the use of traditional school buses and prohibit the use of non-conforming vans.  This issue was ultimately resolved by requiring that students be transported in school buses or “allowable alternate vehicles.”  The alternate vehicles must meet federal motor vehicle safety standards for crash survivability and mirrors, but do not have to meet the standards for crash prevention such as the flashing lights, stop arms, or color.

The second issue was whether or not seat belts would be required for Head Start students.  The final rule states, “effective January 20, 2004, each agency providing transportation services must ensure that each vehicle used to transport children receiving such services is equipped for use of height- and weight- appropriate child safety restraint systems.”  As defined in the regulation, a child restraint system means, “any device designed to restrain, seat, or position children who weigh 50 pounds or less which meets the requirements of FMVSS 213, Child Restraint Systems.”  The regulation states that lap belts and lap/shoulder belts are “inappropriate for children who weigh 50 pounds or less, because of the potential for injury from the seat belt itself.”

The new regulation poses difficulty for school divisions that transport Head Start students on yellow school buses with school-age children.  These buses cannot be outfitted with child restraint systems as the vehicle is used on multiple runs each day and the systems cannot be installed and removed by the driver between runs.  This may force Head Start to purchase its own vehicles and provide services previously offered at no charge from participating school divisions.

Clearly the issue of whether or not large school buses should be equipped with seatbelts will continue into the foreseeable future.  It is important that the National Transportation Safety Administration complete its current study on the next generation of occupant protection systems.  If necessary, new standards should be promulgated that will improve occupant protection.  In November of 1998, Mr. Jim Hall, Chairman of the National Transportation Safety Board, said  “We have to make sure this is done on the basis of solid science.  We don’t want to simply bolt lap belts in every seating position.  Lap belts are probably not the most effective form of restraint for the millions of students transported on school buses.”

Click here for summary of recent Virginia Legislative history of “Seat Belts on Large School Buses.”

“Occupant Restraints,” School Transportation News, http://stnonline.com/stn/occupantrestraint/index.htm

“Passenger Crash Protection in School Buses,” Position Paper of the National Association of State Directors of Pupil Transportation

http://www.nasdpts.org/paperCrashProtect.html

“School Bus Safety Summary from the National Highway Traffic Safety Administration”

http://www.nhtsa.dot.gov/people/injury/buses/schbus/schbussum.html

“Bus Crashworthiness Issues,” Highway Special Investigation Report

National Transportation Safety Board

http://ntsb.gov/Publictn/1999/SIR9904.htm

Remarks by Jim Hall, Chairman, National Transportation Safety Board before the National Association for Pupil Transportation, 24th Annual Conference and Trade Show, Austin, Texas, November 2, 1998

http://www.ntsb.gov/speeches/former/hall/jhc981102.htm

Final rule on Head Start Transportation, Department of Health and Human Services, Administration for Children and Families, 45 CFR Part 1310

Federal Register: January 18, 2001 (Volume 66, Number 12)

http://www.access.gpo.gov/su_docs/aces/aces140.html

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