Editor's note: This article, by NAPT President Don Carnahan and NSTA President Tim Flood, was published in the October issue of School Bus Fleet, before Carnahan died suddenly on Oct. 3. For more information, go here.
The call for belts on buses seems to ebb and flow each year, with the tide rising each fall when a new group of children begin riding the school bus. Their parents wonder why the children are required to buckle up in the family car but not in their school bus.
While this view has strong common-sense appeal, the National School Transportation Association (NSTA) and the National Association for Pupil Transportation (NAPT) — unlike others — have been and remain unwilling to embrace the mainly emotional rationale it embodies. Instead, we have held the position throughout our participation in federal rulemaking regarding seat belts and discussions with federal officials that the National Highway Traffic Safety Administration (NHTSA) should conduct research, evaluate the results and then clearly explain the information so everyone can understand it.
NAPT even formally petitioned NHTSA several years ago to do research and make recommendations that would enhance or even replace the current standards for school bus occupant crash protection and perhaps even lead to the next evolution in school bus occupant safety. They denied our request.
In the wake of recent recommendations from the National Transportation Safety Board (NTSB), NSTA and NAPT met recently with NHTSA officials, asking again for clarity on their perspective, and for additional crash testing to document benefits/unintended consequences of belt use.
NHTSA made it clear they are not planning to do additional crash testing of school buses using anthropomorphic test dummies (ATDs) and said, “NHTSA believes that both ATD test data and real world crash data of occupant kinematics and associated injuries, if available, are important to obtain a better understanding of restraint performance.” NHTSA also said, “Where human response and injury outcome in a crash environment are available, we consider both sources of information (ATD test data and real world crash data) when evaluating restraint performance.”
In addition, NAPT and NSTA were informed that the agency’s best advice on the matter of seat belts in large school buses — superseding all other guidance — is contained in a single document: the Aug. 25, 2011, denial of a petition from the Center for Auto Safety (CAS) and others requesting that NHTSA mandate seat belts in large school buses.
We urge you to read the entire petition denial notice carefully; it can be found via this link: schoolbusfleet.com/PetitionDenial.
From this point forward, the NHTSA petition denial is, and will remain unless it is superseded, the document NSTA and NAPT will reference whenever we are asked for our “position” on belts in school buses. And we believe the following are statements from that document that stand out:
• “NHTSA has considered the question of whether seat belts should be required on large school buses from the inception of compartmentalization and the school bus safety standards and has reassessed its decisions repeatedly. Each time, after analyzing the implications of a seat belt requirement and all available information, we have concluded that a seat belt requirement for large school buses has not been shown to be warranted.”
• “In large school buses, fatal rollover crashes are rare (approximately 1 crash per year, resulting in 2 fatalities annually), as are fatal side impact crashes in which seat belts would have prevented death or serious injury. Fatal non-rollover frontal crashes in large school buses are uncommon (less than 1 crash per year). Large school buses are already very safe vehicles. More important ... requiring seat belts on large school buses is likely to have the effect of increasing fatalities related to school transportation.”
• “After considering all views [including a recommendation by the NTSB — H-99-46], we could not agree with those asking us to propose to require seat belts on large school buses. We assessed the safety need for seat belts. Since school buses are already very safe and are the safest mode of school transportation, a seat belt mandate would result in very few benefits.”
• “We determined that it would be inappropriate for NHTSA to require seat belts given the low safety need for the belts, when such a decision has a direct bearing on the ability of the local decision-makers to allocate and spend limited pupil transportation resources on other school transportation safety needs that are likely to garner greater benefits, perhaps at lower cost.”
• “It is true that seat belts have been proven beneficial in rollover crashes. However, real world data show that school bus passenger fatalities and injuries in rollover events are rare. The CAS petition cites two school bus accidents in support of its position that there is a safety need for seat belts on large school buses. We cannot agree that citing these rare instances of fatal rollover crashes forms the basis for a finding of a problem of national significance that warrants trumping local policymaking on this matter.”
• “We believe that it is most appropriate if the decision to order seat belts on large school buses were left to the States and local jurisdictions rather than to NHTSA. States and local school districts are better able to recognize and analyze school transportation risks particular to their areas and identify approaches to best manage and reduce those safety risks. Local officials are in the best position to decide whether to purchase seat belts, since the officials must weigh a multitude of unique considerations bearing on purchasing decisions, especially when faced with budgetary constraints.”
NAPT and NSTA understand that these statements don’t bring perfect resolution to this long-standing issue, and some ambiguity remains. We regret this and will continue to try earnestly to seek clarity for you from federal regulators.
Moreover, we want to replace with unequivocal science-based information the emotional arguments and personal opinions that sometimes dominate the conversation on this subject. Until such time, however, NSTA and NAPT are confident that states, communities and local school transportation service providers will continue to make decisions that keep yellow school buses as the absolutely safest way for children to get to and from school, and indispensable to our public education system.