Interpretation ID: 86-6.15
TYPE: INTERPRETATION-NHTSA
DATE: 12/15/86
FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA
TO: Slade Gorton
TITLE: FMVSS INTERPRETATION
TEXT:
The Honorable Slade Gorton United States Senate Washington, DC 20510
Dear Senator Gorton:
Thank you for your November 3, 1986, letter on behalf of your constituent, Mrs. Laurel Kuther of Clarkston, who asks that safety belts be required on school buses. your letter has been referred to my office for reply, since the National Highway Traffic Safety Administration (NHTSA) is responsible for administering Federal programs relating to school bus safety.
I appreciate this opportunity to respond to your concerns. As explained below, NHTSA does not require large school buses to have safety belts for passengers because we require those buses to provide an alternate form of passenger crash protection. Our safety standards are directed at improving the interior of large school buses so that passengers will be provided adequate crash protection even if safety belts are not used.
I would like to begin with some background information on our school bus regulations. NHTSA is responsible for developing safety standards applicable to all new motor vehicles, including school buses. In 1977, we issued a set of motor vehicle safety standards for various aspects of school bus safety. Included in that set is Federal Motor Vehicle Safety Standard No. 222, School Bus Passenger Seating and Crash Protection. Standard No. 222 requires large school buses--i.e., those with gross vehicle weight ratings over 10,000 pounds--to provide passenger crash protection through q concept called "compartmentalization." Compartmentalization requires that the interior of large buses be improved so that children are protected regardless of whether they have fastened a safety belt. The seating improvements include higher and stronger seat backs, additional seat padding, and better seat spacing and performance.
Our safety standards require a safety belt for the school bus driver since the driver's position is not compartmentalized. We also require safety belts for passengers in smaller school buses because those buses experience greater crash forces than do larger buses and the additional restraint system is needed to provide adequate crash protection for passengers.
However, because large school buses already offer substantial protection to passengers, we believe a Federal requirement for safety belts in those vehicles is unnecessary: In addition to meeting Federal school bus safety standards, large school buses are very safe vehicles because of their size and weight, the training and experience of their drivers and the extra care that other road users employ in the vicinity of school buses. NHTSA does not prevent States and local jurisdictions that wish to order safety belts on their own large school buses from doing so. Such a decision is a matter for the officials of the particular State or local jurisdiction, who are best able to assess their own pupil transportation needs.
A June 1985 NHTSA publication entitled, "Safety Belts in School Buses," discusses many of the issues relating to safety belts in large school buses. I have enclosed a copy of the report for your information.
I hope you have found this information to be helpful. If you or your constituent have any further questions, please do not hesitate to contact me.
Sincerely,
Erika Z. Jones Chief Counsel
Enclosure
U.S. Department of Transportation Washington, D.C. 20590 December 1, 1986
Dear Senator Gorton:
Thank you for your letter forwarding correspondence from your constituent, Mrs. Laurel Kuther.
I have transmitted your Inquiry to the appropriate Departmental officials who are familiar with this matter and they will respond to you directly.
I appreciate your contacting me and hope you will not hesitate to call if I can be of any further assistance.
Sincerely,
Edward J. Babbitt Director, Office of Congressional Affairs
Mr. David P. Sloane Director of Congressional Affairs Department of Transportation 400 7th Street SW, Rm. 10408 Washington, D.C. 20590
Dear Mr. Sloane:
Enclosed please find a copy of a letter from Mrs. Laurel Kuther. As you will note, this constituent is concerned with seat belts on school buses.
Your comments on this matter may be forwarded to my Washington, D.C. office, Senate Office Building. Washington, D.C. 20510. I look forward to your prompt response. PLEASE MARK THE ENVELOPE TO THE ATTENTION OF: Pat McCausland.
Thank you for your attention to this inquiry.
Sincerely,
SLADE GORTON United States Senator
SG:pmm Enclosure SEE HARD COPY OF HAND WRITTEN LETTER