The National School Transportation Association (NSTA) was pleased to be invited to and participate in the National Highway Traffic Safety Administration’s (NHTSA) July 23 discussion on school bus occupant protection.

We all know the debate on whether or not to require three-point seat belts on school buses has been ongoing for some time. Regardless of what each of us believes, we all have one thing in common: our commitment to providing the highest level of safety for the children our industry transports every day.

Nationwide, yellow school buses transport 26 million students every school day, providing more than 9 billion student rides every year, with an average student occupant fatality rate of four students per year during school travel hours, and an injury rate of less than 0.01% annually.

The average number of student fatalities among students who travel to school by any means other than a school bus is 580 annually. School buses are the safest form of transportation available today, with children being 23 times safer on a school bus than being driven by a parent in the family car and 58 times safer than riding with a teen driver.

In the industry, we know that school buses comply with 36 Federal Motor Vehicle Safety Standards (FMVSSs) in addition to other design factors that have evolved over the years with one purpose in mind: passenger safety. If you only examine the most severe and rare collision types, three-point seat belts appear to provide additional protection as long as they are being used and worn properly.

The real question, however, is who should make the decision to put three-point seat belts on school buses, and would the money spent on those three-point seat belts be the best use of the limited resources available to improve safety for the greatest number of students?

NSTA agrees fully with the statement offered by NHTSA in its 2011 petition of denial to the Center for Auto Safety: “We believe 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.”

Three-point seat belts would only be added to a school bus at a cost, and that additional cost would have to come from somewhere within a local budget. We are concerned that if mandated and unfunded, that additional cost could force some districts to make choices that may not be in the best interests of safety, which could result in an increase of 10 to 19 school transportation fatalities annually, according to NHTSA.

NSTA also recognizes that a review of occupant protection would not be complete if concerns on emergency evacuation were not addressed. In our comments to NHTSA on July 23, we urged them to consider situations including driver incapacitation and bus rollover with a focus on the youngest passengers and those with disabilities.

The overall greatest effect on safety, however, could be to focus precious resources and attention on the fatality rate in the danger zone area around the bus. As noted in the 2010 summary report of the Alabama School Bus Seat Belt Pilot Project, “Most school bus pupil fatalities occur outside buses in or near loading zones. If funding is to be spent on school bus safety, it appears more lives could be saved by investing in enhanced safety measures in loading/unloading zones. These treatments are likely more cost-effective than seat belts.”

On July 23, we encouraged NHTSA to consider all options for enhancing school bus passenger safety — including focusing on the danger zone area — before deciding on one option in particular.

We expect NHTSA to release information this fall indicating their intentions on this issue. We look forward to continuing to be part of the conversation.