I am writing to comment on the report "To Belt or Not To Belt? - Experiences of School Districts that Operate Large School Buses Equipped with Seatbelts," published last fall by the Center for Urban Transportation Research at the University of South Florida, and discussed in a STN article in January 1995.

I write as someone who is familiar with many of the debates and controversies about this issue. As the State Director of Pupil Transportation here in New York, I am keenly aware that many of my friends and colleagues in the industry have been adamantly opposed to seat belts on buses. I've also seen firsthand the confusion that has resulted from the way New York's seatbelt law was written. As you may be aware, our law required the installation of belts on all school buses built after July 1, 1987, but left the decision of what students should do with the belts up to individual school districts. Becaiuse many of our transportation supervisors were against seatbelts, only a small minority of New York State school districts have established a policy that required belt use.

"To Belt or Not to Belt?" claims to be objective survey of the "operational experiences" of the 814 school districts in hte U.S. that currently operate large school buses equipped with seatbelts. It focuses on important questions such as whether students will wear belts and whether belt use improves student behavior.

Unfortunately, the study's methodology is fundamentally flawed, and although its appearance is "scientific," with an abundance of numbers, percentages, charts, and graphs, its conclusions are anything but objective.

The flaw is glaring. By its own account, the study reveals that only a tiny percentage of the 814 districts mandate seatbelt use. In every way, the experience of districts that mandate use is different from districts that have belts installed on buses but don't require their use. Yet the study lumps survey data from these two divergent experiences into one pool.

For example, look at "Question 8: What percentage of your students use the seatbelts?" The study concludes that very few students wear the belts. On the surface, this conclusion supports the argument that seatbelts are a bad idea on school buses; if kids won't wear them, what's the point of installing them in the first place?

But in reality, "To Belt or Not to Belt?" cannot support such a conclusion. As the study itself admits, "seat belt use is dependent on the presence of a mandatory school bus seatbelt use policy." Seatbelt use doesn't just "happen". Like lots of things having to do with safety and children, success takes a concerted and continuous effort. Drivers and districts that require or even just strongly encourage belt use, have experienced success. Lumping together survey data from districts that do and do not mandate belt use invalidates the study.

This distortion exists throughout. Asking transportation supervisors, who (rightly or wrongly) don't like seatbelts, for informaiton about seatbelt use, is like surveying gas stations owners on their opinion about alternate fuels. Nothing new is learned. Also, putting seatbelts on buses without clearly explaining what to do with them is going to contribute operational problems, including low use, misuse, and vandalism.

The more interesting question is, what happens when a district makes a serious effort to have children use seatbelts? Will children wear them? Does student management improve when kids wear the belts? Do passenger injuries decline? Does belt use on a bus increase children's desire to wear belts in cars? These are important questions, and it's unfortunate that the study's methodology didn't allow these questions to be answered.

To really be "empirical" and objective about what belts do and don't do for school bus safety, the study should have focused on a careful and in-depth analysis of the 6% of districts that presently use them. Then we might have learned something about the real world -- and not just "opinions."

(sgn) Richard R. Ahola
Executive Liason
New York State Education Department