As the comment period neared its end in late January for the National Highway Traffic Safety Administration’s (NHTSA) proposal to enhance school bus passenger protection, state officials weighed in on the matter.

The National Association of State Directors of Pupil Transportation Services (NASDPTS) expressed its support for many of the components of the Notice of Proposed Rulemaking (NPRM), including raising seat back heights from 20 to 24 inches, requiring latching devices for seat cushions and requiring lap-shoulder belts in small school buses.

However, the association asked NHTSA to reconsider its proposal to require a minimum of 15 inches of seat width per passenger position. A standard 39-inch seat, NASDPTS said, has been proven to sufficiently hold three elementary students — which equates to 13 inches per passenger — or two high school students.

The association also asked NHTSA to reconsider its position that there is no need to prohibit lap belts in school buses. NASDPTS cited NHTSA research suggesting that lap belts provide little or no safety benefit in school buses. The association said that prohibiting lap belts could reduce the potential for head, neck and abdominal injuries in severe frontal crashes.

The association went a step further than the NPRM, recommending that all new large school buses be equipped with lap-shoulder belts.

“NASDPTS believes it is inconsistent for NHTSA to have a ‘voluntary’ standard for a basic vehicle safety system on a school bus and that the time has come for lap-shoulder belts to be required in school buses, as they have been since 1968 for smaller passenger vehicles,” the association wrote.

NASDPTS acknowledged, however, that some of its members dissented on this topic. Those members said that a nationwide requirement for lap-shoulder belts on large school buses is inappropriate. They support the current NPRM proposal that NHTSA provide guidance for voluntarily installing lap-shoulder belts.

Regarding funding for lap-shoulder belts, NASDPTS said that a dedicated federal source should be provided, rather than drawing from existing Section 402 highway funding, as the NPRM proposes. Section 402 funds are used for other safety initiatives, such as speed limit enforcement and drunken-driving abatement.

At press time, the NPRM and the numerous comments it drew were still available for viewing online. The docket could be found at www.regulations.gov by performing an “Advanced Docket Search” for Docket ID “NHTSA-2007-0014.”