Tips on Spec'ing a Bus for Pre-School Age Children

Posted on February 1, 2002

The task of spec’ing a school bus that will be used to transport pre-school age children can be tricky. To take some of the guesswork out of the process, the National Highway Traffic Safety Administration (NHTSA) has published “Choosing the Correct School Bus for Transporting Pre-School Age Children,” a booklet that explains the basic components of proper spec'ing procedures. The following article is taken directly from NHTSA’s booklet. To get your own copy of the 16-page publication (which includes several photos not in this article), fax your request to Arlene Harley at (202) 366-7721 or visit NHTSA’s website at to download a copy. Numbers are increasing
The population of pre-school age children riding school buses has grown significantly in the past decade and is expected to continue to grow. Organizations providing pre-school transportation extend beyond traditional school systems to include childcare and Head Start programs. Regardless of which organization is transporting pre-school age children, the goal of them all is to do so safely. In 1999, NHTSA released the “Guidelines for the Safe Transportation of Pre-School Age Children in School Buses,” which recommends each pre-school age child transported in a school bus always be transported in a properly secured Child Safety Restraint System (CSRS, referring to portable child safety seats, integrated child safety seats and safety vests). State law may require school bus equipment not specified in NHTSA regulations. Each state regulates how school buses are to be used and which agencies are responsible for developing and enforcing school bus regulations. In some states, requirements for transporting public school children differ from requirements for transporting children attending private schools and non-school organizations (for example, Head Start programs and childcare agencies). Because each state has its own requirements, it is important to be knowledgeable about the laws of the state(s) in which your vehicles will be registered and used, to avoid ordering a school bus that cannot be registered or used because it does not meet state requirements. As an example, in some states the “crash avoidance” or traffic control features of a school bus (flashing lights, deployment of stop arm) cannot be used if the school bus is not being used to take schoolchildren to or from school. Work with your distributor
It is important to purchase a bus that will provide easy access for the children you plan to transport, as well as one which has the features that drivers and their assistants need to ensure the safety of each pre-school passenger. The key to choosing the correct school bus is to thoroughly discuss your needs with the school bus distributor from whom you will purchase the vehicle. The more the distributor knows about how you plan to use the bus, the easier it will be for him or her to help you make the proper selection. Know your passengers
A school bus that will carry pre-school age children needs different features and equipment than a school bus that will transport only elementary and secondary school students. So the first step in purchasing the correct school bus is to identify who will be transported in the vehicle, both now and in the future. If it is likely that the school bus may be used to transport pre-school age children at any time during the 10 to 15 years that the school bus is likely to be in service, it needs to be properly equipped for those children. Size it right
After identifying how the bus will be used, you need to decide how many passengers it will carry. Those two factors will enable you to determine what size vehicle to purchase. If the bus will be used primarily to transport pre-school age children, you may want to limit the number of passengers and purchase what is commonly referred to as a small school bus (10,000 lb. or less gross vehicle weight rating). These buses usually have four rows of seats. If you anticipate a need to carry a large number of passengers, you may want to purchase a large school bus (above 10,000 lb. gross vehicle weight rating). Seating considerations
Seat size and spacing are critical to the proper use of a CSRS on a school bus. The number of CSRSs you can fit on a school bus seat depends on the seat width, which is defined as the distance of the seat from the aisle to the interior wall of the school bus. A seat of 39 inches or more can usually accommodate two properly secured CSRSs or one CSRS and one older child not requiring a CSRS. A seat less than 39 inches wide can safely accommodate only one CSRS. You might want to consider ordering seats of two different widths for a school bus that will be used exclusively to transport pre-school age children. One side of the bus could be equipped with seats 39 inches in width (accommodating two child safety seats) and the other with seats 30 inches wide (accommodating one child safety seat). This combination is a common configuration when a wider aisle is desired (see aisle width section on page A18). You may want to consider ordering school bus seats with built-in child safety seats. These seats are similar to the integrated child safety seats available in many passenger cars and mini-vans. They consist of a full-harness CSRS that accommodates children at least one year of age and weighing 20 to 50 pounds. The integrated seat can also be used to attach a rear-facing CSRS for infants less than one year of age and under 20 pounds. When not being used, the integrated seat folds into the school bus seat, allowing the space to be used by other passengers. Seat spacing
Any school bus seat that will be used with a CSRS needs to be spaced to the maximum spacing permissible under Federal Motor Vehicle Safety Standard (FMVSS) 222, “School Bus Passenger Seating and Crash Protection.” Crash testing has shown that the injury potential for children in CSRSs is reduced at maximum seat spacing. An additional benefit is that it provides easier access to the person responsible for properly securing the CSRS. Narrowly spaced school bus seats make it extremely difficult and sometimes impossible to secure CSRSs properly. The distance between school bus seats directly affects the seating capacity of the vehicle. Therefore, if the vehicle you are ordering will be used to transport pre-school age children in CSRSs, you must specify to the distributor that you need “maximum seat spacing allowed in FMVSS 222.” The distributor will determine how many seats can fit on the bus when allowing for maximum spacing and the number of rows that must accommodate CSRSs. If the vehicle you are purchasing only needs to accommodate CSRSs in the first few rows, you should order "maximum seat spacing allowed in FMVSS 222" for those rows only. If CSRSs will be used throughout the bus, all rows except for emergency exits should be ordered with maximum seat spacing allowed in FMVSS 222. (Note: A CSRS should never be secured in a school bus seat located in a row with an emergency exit door or window.) Anchorage Systems
Lap belts - NHTSA regulations require that all small school buses (10,000 pounds or less gross vehicle weight rating) sold in the United States be equipped with lap/shoulder belts at the driver’s seating position and at the right front passenger’s seating position (if any) and with lap belts or lap/shoulder belts at all other seating positions. At this time, however, manufacturers only offer lap belts at passenger seating positions. A passive system of occupant protection called compartmentalization is provided in large school buses and lap belts are not required, but they are available as an option. Compartmentalization provides occupant crash protection through a protective envelope consisting of strong, closely-spaced seats that have high energy-absorbing seat backs. If you are buying a large school bus that will be used to transport pre-school age children in CSRSs, you will want to order lap-belt-ready seats (reinforced seats that come with lap belts) in each seating position that will hold a CSRS. When ordering lap-belt-ready seats be sure to specify that they must meet the requirements set forth in FMVSS 209, “Seat Belt Assemblies,” and FMVSS 210, “Seat Belt Assembly Anchorages.” Regardless of the size of the school bus being purchased, you need to order the correct lap belts to properly secure a CSRS. It is important that the non-adjustable end of the lap belt does not extend more than one or two inches from the seat bight (where the seat cushion meets the seat back). A non-adjustable end of the lap belt extending farther than one or two inches from the seat bight may cause the belt buckle to rest on the child safety seat frame and prevent the lap belt from being pulled tightly. This causes the lap belt to loosen as the bus moves. The positioning of the lap belts is another important consideration. It is very difficult to tighten a lap belt when you have to place your hand between a child safety seat and the wall of a school bus or between two child safety seats. To prevent this, the non-adjustable end of the lap belts needs to be positioned in the center of the seat and at the aisle. Placing the short non-adjustable end at the aisle also eliminates a long seat belt from hanging in the aisle and potentially tripping passengers. Make sure the lap belt does not have a built-in retractor that would prevent a child safety seat from being properly secured. A retractor will prohibit you from properly threading the belt through the path of the CSRS. New universal attachment system - By Sept. 1, all small school buses will be required to come equipped with a universal child safety seat attachment system in two seating positions (FMVSS 225 “Child Restraint Anchorage Systems”). School bus manufacturers may offer the system as an option for all seating positions in both small and large school buses. This universal attachment system will greatly simplify child safety seat installation and use and will protect children by keeping the seats secured tightly in vehicles. On a school bus, the system will consist of two lower anchorages. Each will be a rigid, round rod or bar located at the seat bight. As of Sept. 1, each newly manufactured child safety seat will have a buckle, or other connector that can snap into the anchorage bars in the vehicle. All child safety seats sold with the new anchorage system will also continue to be able to be secured in any vehicle using the vehicle’s lap or lap/shoulder belt. All child safety seats manufactured after Sept. 1, 1999, have an attachment for a tether strap at the top of the seat that is used to enhance the proper securement of the seat in a passenger vehicle. In a school bus, however, a tether anchorage is not required, and child safety seats must be secured without a tether strap. Aisle width The average width of the inside of a large school bus is about 90 inches. Small school buses range from 72 to 92 inches wide. The width of a school bus aisle depends upon the width of its seats (typically ranging from 18 to 45 inches). The wider the seats, the narrower the aisle. School buses typically are manufactured with a minimum 12-inch aisle width, except for buses with wheelchair lifts. School buses with wheelchair lifts often have a minimum 30-inch aisle from the lift to the wheelchair attachment position and between the attachment position and the emergency exit door. Some organizations transporting pre-school age children have found it easier to carry child safety seats through aisles that are wider than the standard 12 inches. To obtain wider school bus aisles, the bus is configured with seats of different widths, such as 39-inch seats on one side and 30-inch seats on the other. Some purchasers find it beneficial to order these seating combinations in the first few rows (the rows they use for securing CSRSs). When different aisle widths are used, NHTSA’s school bus standards require protection for the aisle-side occupant in the first wider seat to prevent the occupant from being thrown down the aisle in a crash. To meet this requirement, school bus manufacturers may install a safety barrier in front of that seating position. This may reduce the seating capacity of the school bus. Emergency exits
CSRSs should never be placed in rows with emergency exit doors or windows because they may block the path of escape for other passengers. It is important to take this into account when you are determining how many CSRSs can be used in a school bus. Entry
Young children sometimes have a hard time entering and exiting a school bus. The number and spacing of entry steps can help make it easier for them. Ask the manufacturer to position the lowest step at the lowest height practical for the roads on which the bus will be operated. Reducing the height of each step also may help young passengers. On large school buses, most manufacturers offer the option of three steps in the stairwell rather than the usual two, thus reducing the height of each step. Small buses are naturally low to the ground and usually are only manufactured with a two-step stairwell. Another feature that assists children entering and exiting the school bus is the handrail. Young children often find it easier to climb the stairs if there is a handrail on both sides of the stairwell. This is an available option for all school buses. Because pre-school age children have small hands, you may want to order handrails with the smallest diameter available. To further assist young children entering the school bus, order the handrail to be placed in the lowest possible position. It is important to verify with the school bus distributor that the type of door you are ordering will accommodate handrails starting at the lowest step. Storage
You will need to securely store your CSRSs on the school bus when they are not in use. If you leave them on the bus seat, they must be secured so they do not fly around in the event of a crash or sudden driving maneuver. Leaving empty CSRSs on school bus seats is often not an option however, because the seats are needed for other passengers. If you must store CSRSs on the bus, but not secured to the school bus seat, you may want to order the bus with undercarriage storage areas. These exterior storage spaces are not available on all school buses and, when available, may offer limited storage space, which may not be adequate if you need to store a large number of CSRS. In such cases, your only option then is to store the CSRS off the bus. Retrofitting
A school bus should always be purchased to meet the needs of your current and projected passenger population. Unfortunately, projecting future needs is difficult and the unpredictable often happens. In such instances, you may find yourself needing to retrofit your large school bus with an anchorage system and lap belts. To add lap belts to a large school bus it is necessary to have seats that are reinforced and designed for use with lap belts. These seats, called “lap-belt-ready” seats, are the only seats capable of being retrofitted properly with lap belts. If there is any chance you may need to add an anchorage system to your school bus seats in the future, you should prepare now by ordering “lap-belt-ready” seats. If you are facing the possibility of retrofitting lap belts on a large school bus already in your fleet, it is vital to the safety of the students that the retrofitting is done correctly. The following steps must be taken to retrofit lap belts on large school buses correctly: First, and most important, contact the distributor from whom the bus was purchased. If the distributor is no longer in business, contact any distributor of that school bus, or if necessary, contact the manufacturer directly. Only the distributor or manufacturer can determine if it is possible to retrofit lap belts on a school bus safely. If lap belts can be retrofitted, the retrofit must be done according to the manufacturer’s recommendations. To determine if the bus is equipped with lap-belt-ready seats, the school bus distributor will need the manufacturer’s school bus body number, which is located on the manufacturer’s label posted on the school bus. If the bus is not equipped with lap-belt-ready seats, each seat that needs to be equipped with lap belts will have to be replaced with a “lap-belt-ready” seat. The school bus distributor may also be able to provide you with written instructions on how to install the lap belts correctly. All equipment that you add or replace on a school bus should be purchased from a reputable dealer or manufacturer. If you retrofit a school bus with lap belts, NHTSA recommends that you ensure that all anchorages meet the requirements in FMVSS 210. Further, all lap belts must meet the requirements in FMVSS 209. An easy way to determine if a lap belt meets these requirements is by looking for its certification label. If it is a lap belt designed for motor vehicle use, the certification label will state that it meets all the requirements specified in FMVSS 209. It is important to remember not all school buses can be retrofitted safely with lap belts. Also, federal law does not allow school bus manufacturers or distributors to certify that equipment retrofitted on a vehicle meets safety standards. Some states have regulations governing the retrofitting of occupant protection systems on school buses. Be sure to contact the agency in your state that regulates motor vehicles to determine all applicable regulations before you start any retrofitting project. Currently, manufacturers of school buses do not offer retrofitting of universal attachment systems into existing equipment. However, to find out if it will be possible to retrofit a particular model of school bus with the new universal attachment system, contact the school bus manufacturer’s distributor nearest you. It is recommended that all anchorages meet the requirements specified in FMVSS 225.

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