We are extremely grateful for this opportunity to participate in the dialogue on school bus safety. Segments of the public, perhaps a majority of American parents, believe that school bus safety is the peculiar province of the federal government, because our regulatory responsibility is both visible and, at times, controversial.

But safety of school bus operation depends on a great deal more than federal regulation, as important as that is. The findings and opinions of your association, of school boards, of state governments, and of course parents are all essential.

Thirteen years ago a tragic California school bus crash triggered major changes in school bus construction. Last year a severe bus accident in Kentucky stimulated and exhaustive review of regulations and guidelines still in process.

My intent today is to make you aware of our progress. But I hope the message is also implicit that progress is not exclusively the fruit of tragedy. We move resolutely to upgrade school bus safety as a never-ending responsibility.

School buses are the safest form of motor vehicle transportation - four times safer than passenger cars. If it were possible, I would hitch a ride on a school bus to get to and from work. It would be safer than driving myself.

They have attained this high level of safety because of our joint concerns, expressed over the years, which have resulted in the evolution of a vehicle and a transportation process which achieves exceptional records year after year.

Of course we cannot rest on the knowledge that school bus transportation is the safest; we must continue to pursue improvement. And we will.

A word here about safety belts, because you will recall that belts on buses has been a high-pitched emotional issue for many years. We were talking about the belts well before the Carrollton crash, but the point was raised again as an adjunct to the Carrollton discussions.

In May of 1989, the National Academy of Science issued a major report on school bus safety, ordered by Congress, to assess every aspect of pupil transportation. One of their findings was: There is no basis for requiring that safety belts be installed on school buses.

The NAS words echoed a long list of studies which concluded very much the same thing - that all of the safety measures now built into buses - the inherent protective advantage of compartmentalization - suggested that ordering that installation of belts could not be justified.

Which of course does not prevent individual school districts from taking this step if they choose.

The NAS study did make a number of significant recommendations, however, and part of NHTSA's responsibility (we had been instructed by Congress to contract with the Academy for this study in response to the Carrollton crash), was to assess the effectiveness to various potential school bus modifications and transportation operational procedures. For example, the study illuminated the fact that approximately three times as many youngsters are killed outside the bus, as on board. Sometimes a child is struck by the bus itself, sometimes by another nearby vehicle.

This pointed up the proportionately greater necessity for actions to reduce pedestrian deaths than passenger deaths. Let me review all of these recommendations, because many of these points will be handled in planned revisions to the Highway Safety Program Guidelines (#17) for Pupil Transportation Safety, which affect your daily operations.

Two Academy recommendations of principal consequence are, first, that school districts move as rapidly as possible to replace pre-1977 buses. Buses built to the 1977 standard incorporate a number of improvements which make them more crashworthy, and certain features (such as cross view mirrors and better brakes) which also help them avoid crashes more readily. And second, that districts should prohibit standing passengers, a recommendation we have long supported. This will be addressed in the revision of the Guidelines now in process.

The remaining academy recommendations deal with pupil pedestrians - youngsters about to enter the bus, or who have just left it. These are:

(1) Cross View Mirrors - Federal Motor Vehicles Standard 111 already requires multiple mirrors (including one cross view mirror) which afford the driver a view of the area immediately in front of and along the sides of the bus. The National Academy of Sciences proposes an additional cross view mirror.

NHTSA has prepared a rulemaking issue paper, the first step in the regulatory process which leads to an Advance Notice of Proposed Rulemaking. Of course, an additional cross view mirror is only on possible alternative. We also will review such mechanisms as a crossing control arm which forces children to skirt the front of the bus at a distance where they are always in view of the driver; and proximity sensors which detect children, warning the driver of nearby youngsters whose presence might otherwise be unknown.

(2) Stop Signal Arms - Motorists who fail to stop for school bus loading or unloading passengers are responsible for a significant share of pupil pedestrian casualties. Twenty-eight states already require stop signal arms; the NAS report suggests that NHTSA make this a standard school bus equipment item.

Stop signal arms are but one of several visual indicators used by states to halt passing vehicles. Strobe lights and flashing red lamps are two others. We plan to initiate rulemaking which would require to stop signal arms, but we also are evaluating the alternatives.

(3) School Crossing Programs - NAS proposed that states field-test programs whereby youngsters are escorted across the roadway at bus stops, by either the driver or an adult monitor.

We intend to address the issue in the safety program guidelines, emphasizing the importance of making children aware of safe walking practices in the area of a school bus; how to wait safely for a bus; and how to board and leave a bus. Elementary points, you might think, but clearly needed in view of the casualty history of pupil pedestrians.

(4) School Bus Routes and Stops - This may be a "secret weapon" for many districts which had been unaware of the significant safety advantages offered by more careful planning of routes and stops.

Review is critical, because circumstances change. New businesses, new traffic patterns, new residential areas all create potential new hazards. The guidelines revisions will also address this point.

(5) School Bus Driver Training - Many states have excellent school bus driver education and training programs. Some of them are based on the 1974 NHTSA model program, which was funded in part by $33 million in NHTSA grant moneys. Yet a number of states still do not require specialized training. Once again, the Guidelines will emphasize the importance of this training.

The recent passage of the Commercial Motor Vehicle Safety Act of 1986 has a direct bearing on any driver who operates a school bus which seats more than 15 passengers. These drivers must obtain commercial driver's licenses no later than April 1992. Since the test for this license typically will be conducted in the vehicle ordinarily driven by the potential licensee, a strong practical knowledge of how to drive a school bus will be essential.

NHTSA plans to cooperate with states in providing more widespread school bus driver training.

The National Academy of Science study advance several other safety proposals - ideas which we did not include in the "most effective" category, but still felt could be beneficial to school bus safety programs. These included:

(1) Emergency Evacuation Drills - Twice-a-year drills were proposed; the NHTSA safety program guidelines will suggest that at least one such supervised emergency evacuation from the bus be conducted each year. Two is preferable if time and resources permit. Incidentally, we wrote to state pupil transportation officials last fall (1988) to stress the importance of these drills.

(2) Emergency Exits - Safety standard 217 now sets requirements for emergency exits, including window and door retention and release mechanisms. The rule is in the revision process, however, and a Notice of Proposed Rulemaking will be published shortly, probably before the end of the year. It will incorporate the proposed changes in emergency exits requirements.

(3) Flammability of Interior Materials. The status of this rule (FMVSS 302) is very similar to that for emergency exits. An Advance Notice of Proposed Rulemaking was issued last November, followed by execution of a contract with the Center for Fire Research at the National Institute of Standards and Technology to provide the test data on which we can base revised flammability criteria and test procedures. The fire research report is expected in December. Our decisions on rulemaking actions therefore should be made in early 1990.

(4) Structural Integrity - Two potential rulemaking actions are under study. Standard 221 deals with body joint strength. A rule modification to include maintenance access panels is being researched.

In addition, improved test procedures which could result in increased floor joint strength and body panel strength are being considered. Fuel system integrity is being re-evaluated on the basis of comments made in response to NHTSA's Advance Notice of Proposed Rulemaking issued in March.

(5) Seat Back Height - The NAS study recommended that NHTSA increase the minimum required height of school bus seat backs to 24 inches (from 20) to gain added protection for the head, further enhancing the compartmentalization effect.

Conversely, higher seat backs could impede access to emergency exits, which could in turn lead to reduced seating. Higher backs might also inhibit the driver's capacity to monitor behavior. We expect to gather more information before we proceed.

(6) Reflective Markings on Buses - NAS found that night-time school bus accidents are disproportionately high, and a more prominent bus silhouette might be beneficial. We are now working on a similar problem regarding trucks, and both our findings and the resulting technology -particularly in relation to reflective material - could be applied to school buses. We will make a judgement when the evaluation is complete.

(7) School Bus Accident Data - Finally, NAS recommended that NHTSA work with states in standardizing the collection of school bus accident data. We will do that, and also initiate an annual "Summary of Available School Bus Statistics," which should be particularly useful to states trying to measure their own experience against that of other states.

Now, the significance of defining certain school bus safety improvements as potentially "most effective" lies in the possibility of obtaining funds from NHTSA to carry out specific state upgrades. We have been granted authority to set aside up to $5 million in both fiscal 1990 and fiscal 1991 to help states carry out programs designated "most effective" in upgrading school bus safety.

These is one exception - bus replacement. I think you are aware that by long-standing policy we do not permit purchase of buses with 402 funds. The measures which do qualify include safety education for youngsters, school bus driver training, school bus route evaluation, bus stopping procedure review, acquisition of stop signal arms, outside crossview and rearview mirrors.

In some instances, grant funds may be available for developing emergency evacuation drill procedures, school bus crash data systems, improvement of bus reflective characteristics, or modifications that will upgrade emergency exits, interior materials or fuel system integrity.

So, it's clear that lots of things are in process in relation to school bus safety. But my summary obviously is one-dimensional, because it deals exclusively with what we are doing at the federal level.

If we really believe that a team approach can accomplish more, then what you are doing, and what bus manufacturers are doing will move the process along considerably faster. I have always felt that manufacturers could provide a valuable assist through research & development, tested in the crucible of demonstration programs.

A corollary from the passenger car industry is indicative. Anti-lock brakes are being incorporated on a number of models now, and the availability broadens each year. Anti-lock brakes are NOT a required item. Perhaps some day they may be. But manufacturers have assumed the initiative on this one, and establishing a rule may prove to be unnecessary.

School bus manufacturers could - I might even say should - encourage school districts to order optional equipment as a way of gaining the on-road experience necessary to make informed value judgements. Districts should take some initiative too - they can keep their antennae in the sensory position to be sure they know when innovations become available, and thus be in a position to take advantage. Stop arms, for example, are here now, in use by 28 states as a required item, and a potentially valuable addition in the other 22.

School bus safety has still another dimension which I would like to address for a moment - a dimension which may not have been apparent. In recent weeks I have had the opportunity - and I use that word advisedly - to appear on two national television news programs to respond to inquiries about school bus safety.

I declined to appear on one important program because it was clear the producers were taking an unbalanced approach to the issue of school bus safety. The intent was to contrast in one joint interview the views of a government agency official against the opinion of a parent whose child had died in a school bus crash.

I accepted the second interview because I foresaw a format which would allow logic to be voiced. Unfortunately I was wrong. My interview was chopped down to a few words which, now totally outside of the original context, tended to characterize the federal position as unconcerned and flexible.

In both cases I prepared lengthy critiques which I directed to the networks, because this type of misrepresentation, repeated over time, can only build distrust and disrespect in the public mind.

School bus safety is inevitably sensitive, highly personal, and fraught with emotional overtones. For a parent who has lost a child in a bus accident, the urgency of seeking improvements in the system, in buses, in rules must be overwhelming. To stand in the way of such impetus appears heartless. Bus of course that is my point. We're not standing in the way.

Every step we have taken in the realm of school bus safety has been well conceived, carefully dovetailed into school bus regulations, and as indicated by the overwhelming evidence at hand, has been enormously successful. And we haven't stopped working. We still are moving along a dozen different paths.

We will make buses safer. And you know this. I am making the point because we frankly need your support and your assistance. We need reinforcement of reality; transmittal of the knowledge that the school bus safety regulation process is both sensitive and responsive.

It does produce safer school pupil transportation because a lot of people who really care have put their best effort into it. Starting with federal regulators, and including school bus fleet managers, and maintenance experts, and drivers, and state and local governments.

This has always been a team effort, and that's not going to change. We've never seen ourselves as anything but a team player, with a special responsibility to make sensible rules.

Another part of that responsibility is assuring that what we do not preclude the rest of the team from taking part. That particularly means you, who manage bus fleets. That's why today's dialogue is so useful and so important. Thanks for letting us be a participant in your conversation.

** Source: Jeffrey Miller, Acting Administrator of the National Highway Traffic Safety Administration, at National Association for Pupil Transportation, October 30, 1989, Louisville, Kentucky.