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The Evolution Continues

Last updated Dec. 2, 2005

Historically, the primary reasons proponents have urged seat belts on large school buses include the following.

    • If a crash should occur, the use of seat belts will reduce the probability of death (and the severity of injuries) to children correctly seated in post-1977 buses.
    • Seat belt usage improves passenger behavior and reduces driver distractions;
    • Seat belts offer protection against injuries in rollover or side impact crashes;
    • Seat belt usage in school buses has a carryover effect to future use when riding in other vehicles;
    • The cost to install seat belts is nominal.

    Meanwhile, opponents of 2-point seat belts in large school buses contend otherwise.

    • More children are killed in the danger zone around the school bus and as pedestrians walking to and from the school bus stop, than inside the school bus. Seat belts are of no value in these accidents;There is no data to show that seat belts would reduce fatalities or injuries;
    • Fatalities inside school buses represent a very small percent of all school bus fatlities;
    • Over the past two decades compartmentalization has demonstrated it works;
    • The carryover value is negligible, in fact there is no proof of carryover value;
    • Money proposed for seat belt installation would be better spent on other safety measures.

    The bottom line, say opponents, is there are no data to show that a safety problem exists in school buses that would be solved by the installation of lap belts.

Laws and Regulatory Developments

    School transportation is a massive enterprise. Nationwide more than 435,000 yellow school buses are on U.S. roads carrying 22,500,000 school children daily to and from school an average of 180 school days per year. Nationally that computes to more than 10 billion student rides annually, according to a recent Highway Accident Report by the National Transportation Safety Board.

    There is no federal law requiring any form of active occupant restraint system on large school buses!To date only a handful of states have enacted legislation requiring lap belts on large school buses (i.e. over 10,000 lbs. Gross Vehicle Weight Rating). Of these -- New York, New Jersey and Florida -- only New Jersey mandates their use. Meanwhile, California and Louisiana require 3-point systems on large buses purchased after July 31, 2004. In its current 2004 legislative session, Florida legislators are considering adopting 3-point systems, as are those from Missouri, Tennessee, and Washington state.

    Federal regulation does require bus manufacturers to install lapbelts in small school buses weighing under 10,000 lbs. GVWR. However, only six states -- Louisiana, New Jersey, New Mexico, Virginia, Washington, and West Virginia -- have laws or regulations mandating their use on small school buses, according to the National Transportation Safety Board.

    Never-the-less, there have been scores of efforts to require seat belts in school buses in state legislatures for decades. With the exceptions noted above, most failed. In New Jersey proponents labored for 20 years before tasting success.

    Efforts in the U.S. Congress to require seat belts have floundered too.   This is not to suggest the federal government has ignored the matter. Starting in the early-1970s, the U.S. Congress and federal regulatory agencies embarked on a decades-long effort to address various aspects of school transportation.

    The thrust of federal polices governing school bus safety has focused on regulations that embody strategies of crash avoidance and vehicle conspicuity, and on various safety countermeasures designed to enhance safe operations. Chief among these developments was a series of federal motor vehicle safety standards issued in 1977 to improve the crashworthiness of school buses. Included among these was "Federal Motor Vehicles Safety Standard 222: School Bus Passenger Seating and Crash Protection." This regulation introduced a passive occupant restraint system known as compartmentalization. It is unique to traditional U.S.-style school buses.

    Other examples: school buses are painted National School Bus Yellow so motorists nationwide recognize the same vehicles as a school bus; school buses are often outlined with bright reflective tape so they are easier seen during dusk and nighttime hours; school buses, along with fire trucks, ambulances and police cars, are able to stop traffic; and Federal Motor Vehicle Safety Standard 131 requires all school buses to come equipped with driver-activated stop arms for that specific purpose, and so on. The work is not done and continues to this day.

School Bus Fatality and Injury Experience

    While it is undisputable that the use of active restraint systems helps save lives in passenger vehicles, a sobering fact is that they offer no guarantees that fatalities won't occur.

    Hear what the National Transportation Safety Board, based on its extensive research of crash dynamics, said at the 1995 Child Passenger Safety Conference: "In 1992, 5,669 children under the age of 11 were occupants in passenger car crashes involving at least one fatality. About 19 percent of the children were killed. Restraint usage was known for 1,022 of the 1,083 fatally injured children; about 65 percent of them were unrestrained. The percentage of unrestrained children who were killed (25.6) was almost double that of the percentage of restrained children who were not killed (13.6). The data suggest that if all of the children had been restrained, about 350 children who died might have survived."

   In the key measurement of fatalities, student fatalities attributed to school buses fell by three-fourths -- to 23 fatalities in 2001-2002 school from 75 in 1970, according to the annual Kansas Dept. of Education Loading and Unloading Zone Survey. Most occur to children in the loading and unloading zone, and about one third are caused by motorists who fail to stop for a stopped school bus.

    What about injuries? Reliable crash injury data is harder to come by in large part because there is no standardized method to collect the data. Since states do not use standardized definitions or injury reporting criteria it is difficult to compare data from state to state, or from year to year.

      The National Highway Traffic Safety Administration's General Estimates System (GES) is designed to estimate accident injury phenomenon. The GES is a companion database to the National Accident Sampling System (NASS) which, like NHTSA's Fatal Accident Reporting System (FARS), is based on police accident reports,death certificates, coroner/medical examiner reports, hospital medical records, etc. The information is coded utilizing standardized reporting definitions and criteria, and interpreted utilizing statistically valid methodologies. The data are submitted to the U.S. Dept. of Transportation by agencies nationwide. All three databases are maintained by NHTSA's National Center for Statistics and Analysis.

    In late 1997, based on accident reports of nearly 1,900 school bus crashes drawn from the GES database covering 1988 to 1996, NHTSA staisticians found an average of 8,511 school bus injuries annually. Of these 96 percent were minor to moderate (bumps, bruises and scratches) on the Abbreviated Injury Scale (AIS) while the remaining 4 percent were serious, severe, or critical. That computes to over 350 serious injuries annually.

   In a separate study, the National Transportation Safety Board analyzed types of injuries sustained by unrestrained school bus passengers in 43 serious school bus crashes. Noting that "ejection was extremely rare among the unrestrained school bus passengers in the study," the NTSB concluded: "... nearly 86 percent of all the school bus passengers involved in rollover crashes were either uninjured or received only minor injuries." In addition it found that most school bus occupant fatlities and serious injuries were "attributable to the occupants' seating position being in direct line with the crash forces. It is unlikely that the availablity of any type of restraint would have improved their injury outcome."

    In a 1989 report examining the NTSB study, the New Jersey Institute of Technology made an analysis of these accident scenarios, including the number of side impact and rollover collisions, and number of fatalities and injuries. The Institute found less than one percent of the 1,106 surviving student passengers received serious, or severe to maximum injuries. Only 40 of 1,166 passengers in the 43 accidents were restrained by lap belts.

    These findings are consistent with those reported in the National Academy of Sciences' Special Report 222: "Of the estimated 9,500 injured school bus passengers, 5 percent (475) sustained incapacitating (A-level) injuries, 25 percent (2,375) sustained nonincapacitating (B-level) injuries, and 70 percent (6,650) sustained possible (C-level) injuries." Incapacitating injuries include "severe lacerations, broken or distorted limbs, skull or chest injuries, abdominal injuries," etc. Nonincapacitating injuries include "abrasions, bruises, minor and lacertations." And possible injuries include "injuries not evident, limping, compalaint of pain, nausea, hysteria and others," according to Special Report 222.

    Based on these data there are 350 to 475 serious school bus injuries annually.

A Philosophical Difference

    Clearly, the only certainty to emerge from this long-standing, dispute is that agreement is elusive. Well-meaning people on both sides of the debate -- professional school transporters, manufacturers, the medical community, government officials, researchers, parents, school administrators, safety officials, child safety advoctes -- often disagree. It is not unusual that interested parties can look at the same data -- indeed the same school bus accident -- and draw opposing conclusions.

    While opponents point to the safety record of school buses and say that compartmentalization works, proponents cite rollover and side impact accidents, and injuries, and demand seat belts.

    In the late 1960s, during the infancy of occupant protection research when the Great Seat Belt Debate in school buses first became an issue of intense public interest, 2-point lap belts were found in most automobiles that offered any kind of active occupant restraint system. An important development occured in 1963 when Volvo was the first to introduce 3-point lap/shoulder safety belts in the front seat as a standard feature in the automobiles it offered for sale in the USA.

    In 1967 the National Highway Safety Bureau issued "FMVSS 208: Occupant Crash Protection," and "FMVSS 209: Seat Belt Assemblies," setting standards for lap and shoulder belts in front outboard positions and lap belts in all other positions. Within a decade NHTSA issued or amended FMVSS 201: "Occupant Protection in Interior Impact," FMVSS 207: "Seating Systems," FMVSS 210: "Seat Belt Anchorages," and FMVSS 213: "Child Restraint Systems," completing the elements of an active restraint system. In the coming decade, U.S. automakers began offering the 3-point safety belt system in their models. But the school bus seat belt debate remained focused on the 2-point lap belt.    

    During rulemaking of FMVSS 222 in the early to mid 1970s, NHTSA made an intentional, reasoned decision in favor of compartmentalization and rejected lap belts for large school buses.

    FMVSS 222 requires school bus seat backs to bend at 1,000 lbs. force. This bending action causes the seat back (indeed the entire bus) to absorb some of the crash forces, in turn reducing the crash forces absorbed by the passengers seated inside the school bus.

    The flexible seatback requirements of FMVSS 222 are different from the passenger occupant protection requirements of FMVSS 208, which regulates automobiles and small school buses. FMVSS 208 requires seat belt anchorages and anchorage hardware to withstand 5,000 lbs. force per anchorage! Plus, FMVSS 208 requires occupant restraint anchorages to be attached to a structure in the vehicle that will support it.

    Another factor that permits compartmentalization to work is seat spacing. FMVSS 222 establishes seat spacing at 24 inches apart or about 60 centimeters. Researchers for Transport Canada and the important FRG/TOV Rhineland study in West Germany found the optimum distance between seats equipped with seat belts to be approximatly 85 centimeters or 35 inches! Closer than that exacerbated the whiplash effect of lap belts, significantly increasing the possibility and severity of head, neck and spinal injuries. The fact is that seats in all large school buses currently on the road are spaced too close to safely accommodate 2-point lap belts!

    Further dampening federal enthusiasm for two-point lap belts, the U.S. Department of Transportation (and independently, Transport Canada, the Canadian federal government's transportation agency) concluded that lap belts should not be required on large school buses.

    In its seminal report, "Improving School Bus Safety, Special Report 222," the National Academy of Sciences' Transportation Research Board noted "...the overall potential benefits of requiring seat belts on large school buses are insufficient to justify a federal requirement for mandatory installation." This view became official U.S. policy.

    Another factor in the debate is Newton's Law of Motion. This law has to do with a body in motion and the forces exerted on it. Simply put, there are huge differences between the crash forces generated when a large school bus -- typically 22,000-to-25,000 lbs. -- collides with a tree or stone wall, compared to the crash forces generated when a 3,500 lb. automobile, a 66,500 lb. tractor-trailer, or a 700-ton commuter train as occured in the Fox River Grove train-school bus collision in November 1995 collides with a school bus.

    In the Fox River Grove crash, NHTSA's Hott calculates that at the moment of impact the Metra commuter train, traveling at about 55 to 60 mph at the moment of impact, delivered 151,000,000 (that's 151 million) foot-pounds of kinetic energy to the then-stationary school bus. Seven youngsters lost their lives in that horrific accident. Reader please note: The absence of seat belts had nothing to do with these fatalities. It was the force of the impact!

     Meanwhile, the Snyder, Okla. school bus accident of Nov. 10, 1993 offered a different outcome, one that argues forcefully in favor of lapbelts. In this crash a large truck traveling an estimated 55 to 60 mph broadsided a small, 20-passenger school bus. The bus had a gross vehicle weight rating (GVWR) of 10,000 lbs. and its actual estimated weight was 8,324 lbs. The estimated weight of the conventional tractor-truck and its loaded semitrailer was 66,500 pounds. Using the same calculation, the kinetic energy of the tractor-trailer when it struck the small school bus was about eight million foot-pounds of energy. The bus was equipped with seats in compliance with FMVSS 222 and with lap belts. All eight of the unbelted passengers were ejected, four were fatally injured and two were seriously injured. The single belted child had only minor injuries. According to the NTSB ejections would not have occurred, injuries would have been less severe, and lives would have been saved if more of the occupants of the bus had been wearing their lapbelts. Here is what the NTSB wrote in its final report of the Snyder crash:

    "The (National Transportation) Safety Board concludes that if the unrestrained passengers had been wearing the available lap belts, none of them would have been ejected: Prospects for survival might have been better for three of the children who were killed (passengers 6, 8, and 9). Two of the children who survived (passengers 3 and 5) might have received less severe injuries. One seriously injured child who survived (passenger 4) might have been killed, depending on her position on the bench seat. For two children (passenger 1, who received minor injuries, and passenger 7, who was killed), the outcome probably would have been the same." NTSB's Snyder, Okla. Highway Accident Report, p. 33

        Since then , the NTSB weighed in on lap/shoulder belts in 1999, finding that they are more effective than compartmentalization alone in keeping students in their seating area. It cited compartmentalization as not being effective enough in limiting passenger ejections. A group known as the National Coalition for Safety Belts offers an excellent explanation of crash dynamics in a vehicle collision. It explains that a vehicle collision actually comprises three separate collisions: (1) the "car collision" when the vehicle comes to an abrupt stop, (2) the "human collision" when the human occupant strikes some part of the inside of the vehicle, and (3) the "internal collision" when a passenger's internal organs are still moving forward and then come to an abrupt halt. The coalition then argues for 3-point lap/shoulder safety belts as the appropriate restraint system.

    Meanwhile, the authors of the Transport Canada seat belt study point out: "The school bus presents a different problem with respect to occupant protection, unlike passenger cars, whose more aggressive interior, lower mass and more severe deceleration behaviour in a crash situation makes the fitment of seat belts essential for occupant safety...." Severe deceleration indeed! You know the old saying, "It's not the fall that kills you, it's the sudden stop at the end."

    Truth be known, Sir Issac Newton's Laws of Motion are more germane to the Great Seat Belt Debate than the fervor of either the opponents or proponents.

The Future of the Great Seat Belt Debate

   Perhaps the discussion should now be known as the "lap/shoulder belt debate." With adoption by Louisiana and California of legislation requiring lap/shoulder belts on large school buses (and several other states including Florida, Missouri, Tennessee and Washington state considering legislation), and now that three-point lap shoulder belt systems are available commercially, the movement to install an active occupant protection system in large school buses is off to a new start. Moreover, NHTSA announced it will publish proposed rulemaking in late 2006 that would allow for voluntary lap/shoulder belts in all large school buses..

   Buckle up!

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