Interpretation ID: 7782
Chairman, Committee on Energy and Commerce
U.S House of Representatives
Room 2125, Rayburn House Office Building
Washington, DC 20515-6115
Dear Chairman Dingell:
Thank you for your letter of September 17, 1992, enclosing correspondence from Mr. Aaron Gordon concerning seat belts on school buses. You requested comments on Mr. Gordon's letter and on H.R. 896, a bill referred to in Mr. Gordon's letter.
The issue of safety belts on school buses is an important topic which the National Highway Traffic Safety Administration (NHTSA) has thoroughly studied for many years. School bus transportation has been and continues to be one of the safest forms of transportation in America. Every year, approximately 370,000 public school buses travel approximately 3.5 billion miles to transport 22 million children to and from school and school-related activities. Since NHTSA began tracking traffic fatalities in 1975, an average of 16 school bus occupants per year have sustained fatal injuries. While each of these fatalities is tragic, the number of school bus occupant fatalities is small compared to the number of occupant fatalities to children in other types of vehicles. For example, in 1989 there were 5,287 deaths among children aged five to 18 in vehicles other than school buses.
In 1977, NHTSA issued Federal motor vehicle safety standard No. 222, School Bus Passenger Seating and Crash Protection, which established minimum crash protection levels for occupants of all school buses. For large school buses, those with a gross vehicle weight rating (GVWR) above 10,000 pounds, the standard requires occupant protection through a concept called "compartmentalization" -- strong, well- padded, well-anchored, high-backed, evenly spaced seats. The effectiveness of "compartmentalization" has been confirmed by independent studies by the National Transportation Safety Board (NTSB) and the National Academy of Sciences (NAS). Under the current requirements of Standard No. 222, small school buses, those with a GVWR of 10,000 pounds or less, must provide "compartmentalization" and be equipped with lap or lap/shoulder belts at all designated passenger seating positions. The agency believes that safety belts are necessary in addition to "compartmentalization" in small school buses because of their smaller size and weight, which are closer to that of passenger cars and light trucks.
In 1987, the NTSB completed a study of the crashworthiness of large school buses, and concluded that most school bus occupant fatalities and serious injuries were "attributable to the occupants' seating position being in direct line with the crash forces. It is unlikely that the availability of any type of restraint would have improved their injury outcome."
In 1989, NAS completed a study of means 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. 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." The NAS pointed out that since children are at greater risk of being killed in school bus loading zones (i.e., boarding and leaving the bus) than on board school buses, "a larger share of the school bus safety effort should be directed to improving the safety of bus loading zones." A summary of the NAS report is enclosed.
In response to the recommendations from the NAS study, NHTSA has initiated several rulemaking actions, such as improvements to school bus visibility by the driver and requiring stop signal arms on school buses, designed to improve the safety of students in school bus loading zones. Besides the actions taken in response to the NAS study, NHTSA has initiated several other rulemaking activities to improve further the safety of school buses, e.g., increasing the number of emergency exits, establishing wheelchair securement/occupant restraint requirements, and improving the body joint strength requirements.
While there are no Federal requirements for safety belts on large school buses, states are free to install them if they feel it is in the best interest in their state. However, as noted in the NAS report, if the safety 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."
In summary, the safety record of school buses is outstanding. As such, there is no compelling evidence to suggest that safety belts would provide even higher levels of occupant crash protection. Also, the agency agrees with the conclusion from the NAS report, that there is insufficient reason for a Federal mandate for safety belts on large school buses.
I hope you find this information helpful.
Sincerely,
Marion C. Blakey Enclosure
cc: Mr. Aaron Gordon
ref:222 d:11/9/92