May 9, 1990

Mr. James Arena, Director
Department of Law and Public Safety
Division of Highway Traffic Safety
Quakerbridge Place, Building 5
CN 048
Trenton, N.J. 08625

Dear Mr. Arena:

I am writing in response to former Director William T. Taylor's request to review the School Bus Safety Belt Study undertaken by the Division of Traffic Highway Safety. The Department has reviewed the study and I offer the following comments.

For the reasons listed below, we cannot agree with the recommendation that requires Type I (> 10,000 lbs) school buses to be equipped with seat belts. Since federal regulations already mandate seat belts in Type II buses (<10,000 lbs), this part of the recommendation is moot.

All information presented in the report indicates that school bus accident rates are among the lowest of any vehicle type on our roads. The information and analyses presented in the report conclude that seat belts on Type I buses will prevent .074 fatalities (1 every 13 years), 5 incapacitating injuries and 21 non-incapacitating injuries each year in New Jersey.

The cost of installing and maintaining seat belts is estimated at $1 million each year. Because of the relatively small effect on the accident rate that installing seat belts is expected to have, strong consideration should be given to investigating other safety programs which may benefit school bus passengers and pedestrians. The $1 million per year might have a greater benefit if used in driver training and student education on dangers which can occur during boarding and leaving the bus.

The report states that the number of student pedestrians killed in school bus accidents is nearly 4 times that of bus passengers. It further states that the injuries sustained by student pedestrians are typically more severe than those suffered by bus passengers and that more than1/3 of the pedestrian injuries occur when students are struck by their own bus. Based on this information, we feel that spending the limited resources available to local school boards on seat belts is unwise since the more severe problem exists for pedestrians.

Our opposition to the recommendations of the study is in agreement with the results of two school bus accident investigations presented in the report. The NTSB Study did not recommend large buses be equipped with seat belts and stated that the "compartmentalization" already dictated by federal standards worked well in protecting school bus passengers. The second study, TTI, concluded that "with limited funds available, lap belts in school buses are not safety cost-effective". It also concluded that "improved vehicle maintenance, bus driver training and rider training may have a greater potential in reducing the frequency and severity of accidents over time".

We also have the following comments on the design, conduct and analysis of data in the study: The research design is good. It encompasses a variety of approaches to evaluate seat belt use in buses including crash tests, accident statistics, expert analysis of specific accidents, operating experience with seat belts and the views of professional and other interest groups. A section also exists on alternative restraint systems to seat belts. The presentation of this information is well written and organized.

We are not comfortable with the estimation of seat belt effectiveness and subsequent prediction of the prevention of fatalities and injuries. Since the recommendation of the study is to install seat belts in Type I buses, and since this recommendation is tied to the predicted fatality and injury reductions, the manner in which seat belt effectiveness is estimated is crucial.

As far as fatalities are concerned, two studies were used in determining seat belt effectiveness. The NTSB study suggests little or no effect for seat belts on fatalities. A study by TTI suggested that 63-84% of fatalities might have been prevented with the use of seat belts. Some questioning of this effectiveness was presented which suggested 25-35% effectiveness rate for the prevention of fatalities by seat belts is a conservative estimate. Since only two studies were used (no criticism intended - they are probably the only two in existence) and since they differ by a very large degree in their results, any estimate of the ability of seat belts to prevent fatalities on Type I buses is highly speculative.

Estimates for injuries suffer from the same problems as fatalities, that is, the two studies have quite different results. However, even with the different results, both studies concluded that seat belts might not be cost-effective in large buses.

It should be noted that, even if the estimates of fatality and injury reduction given in this report are accepted, the criticisms of the conclusions reached by the study, outlined earlier in this letter, are still compelling enough for us to recommend they be rejected.

I hope this information is helpful to you. Should you have any questions, please contact Eugene F. Reilly, Director of Research & Demonstration, at 292-4650.

Sincerely,

(sgn.)Thomas M. Downs
New Jersey Commissioner of Transportation

cc: Eugene F. Reilly

May 18, 1990

Dear Mr. Arena:

Department staff have reviewed the School Bus Safety Belt Study conducted by the New Jersey Institute of Technology Center for Transportation.
In a previous letter to Mr. Taylor dated March 8, 1990 my staff expressed several concerns regarding the technical aspects of the report.
It has been by position that if compelling evidence was presented which proved seat belts to be beneficial to childrens' safety, I would endorse a mandate for their use. Based on the conclusions of this study, which recommend that school buses be equipped with set belts, I will support such a mandate.

Sincerely,

(sgn.) Saul Cooperman
Commissioner of Education

SC/RJS/jh:1.49