Interpretation ID: 86-1.44

TYPE: INTERPRETATION-NHTSA

DATE: 02/21/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: The Honorable Ted Stevens

TITLE: FMVSS INTERPRETATION

TEXT:

The Honorable Ted Stevens United States Senate Washington, D.C. 20510

Dear Senator Stevens:

Thank you for your letter on behalf of your constituent Mrs. Teresa Kalfsbeek of Kasilof, Alaska, regarding our regulations for safety belts 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.

Mrs. Ralfsbeek asks whether we have proposed to make safety belts mandatory on school buses. As explained below, our regulations already require safety belts on smaller school buses. i.e., those with gross vehicle weight ratings (GVWR's) of 10,000 pounds or less. While we have not proposed to require safety belts on large school buses over 10,000 pounds, we issued a proposal in October 1985 to ensure that if safety belts are voluntarily installed on a large new school bus, they meet appropriate performance requirements.

I appreciate this opportunity to explain our requirements for safety belts on school buses. NHTSA is responsible for developing safety standards applicable to all new motor vehicles, including school buses. We do not require safety belts in large school buses because those buses have been required since 1977 to provide improved crash protection to passengers through a concept called "compartmentalization." Compartmentalization requires that the interior of large buses be improved so that children are protected without the need to fasten safety belts. The seating improvements include higher and stronger seat backs. additional seat padding, and better seat spacing and performance. Our safety standards do require safety belts for passengers in smaller school buses since those buses do not offer the same protection as that provided by compartmentalization.

Although this agency has determined that a safety standard requiring safety belts in those buses is not warranted at this time. State and local governments are nevertheless free to order safety belts on their new school buses if they wish to do so. Most school bus manufacturers are capable of installing them in those vehicles.

As mentioned earlier, we have proposed to set performance standards for safety belts voluntarily installed on large new school buses. If the proposal is adopted, we would require manufacturers to ensure that the voluntarily-installed safety belts meet performance criteria established by our safety standards. A copy of our rulemaking notice is enclosed for your information.

In addition, we are providing you with a copy of a report issued by NHTSA entitled "Safety Belts in School Buses" (June 1985), which might be of interest to your constituents.

I hope this information is helpful. Please do not hesitate to contact us if you have any further questions.

Sincerely,

Erika Z. Jones Chief Counsel

Enclosures

January 21, 1986

David P. Sloane, Director Office of Congressional Relations Department of Transportation 400 Seventh Street, S.W. Washington, D.C. 20590

Dear Mr. Sloane:

I've been contacted by Mrs. Teresa Kalfsbeek of Kasilof, Alaska regarding requirements for seat belts on school buses. Mrs. Kalfsbeek would like to know if there are any proposals to make seat belts mandatory on these buses.

I'd appreciate your responding to Mrs. Kalfsbeek's inquiry and filling me in on existing federal regulations on seat belt use on school buses.

Thanks for your help.

With best wishes,

Cordially, TED STEVENS