The New Hampshire School Transportation Association, formed in 1978, is a not-for-profit membership organization of New Hampshire school bus operators, school districts, and allied industries. Its number one (#1) objective and purpose in its by-laws is as follows: "To promote and foster the highest degree of safety in the transportation of school children." As an association dedicated to safe pupil transportation, we seek to provide the student rider with the safest possible transportation that is reasonable and prudent.

The New Hampshire School Transportation Association is in favor of seat restraint systems on school buses if designed, tested, and proven to be effective for school buses. To date, we believe such restraint systems have not been developed and tested.

Facts about New Hampshire school buses:

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--There are approximately 2,200 state-inspected school buses licensed to operate on New Hampshire highways.

--These buses, driven by an equal number of specially licensed and trained school bus drivers, transport an estimated 162,000 New Hampshire students daily to and from school.

--Annually, our New Hampshire school buses travel more than 11 million miles a year taking our students to and from school. In addition, several million more miles are driven taking students to and from field trips and athletic events.

--New Hampshire has one of the strictest and most progressive set of state-controlled rules and regulations as it relates to school bus operation.

--New Hampshire citizens should be proud of the safety record of school buses.

In more than 30 years of keeping records of school bus accidents only one student has been reported killed while riding inside a school bus. (This student reportedly was not obeying existing school bus rules and regulations at the time of this incident and had his head out the window. This death was not the result of a "vehicle accident".)

--New Hampshire's licensed school bus drivers must complete eight hours of pre-license training before getting school bus driver license permits, and must annually complete six hours of approved in-service training, before they can secure the re-issuance of their annual school bus driver license permit.

National facts about school buses:

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--Federal reports say it is four to seven times safer to have children ride a school bus to and from school than to ride in a private passenger car.

--School buses must meet strict safety manufacturing requirements established by the National Highway Traffic

Safety Administration. These standards, first adopted in 1977, have substantially improved the crashworthiness of school buses, as a way of protecting students in event of a crash. The standards are regularly reviewed, and have been improved in many areas since first adopted.

--Nationally, about 444,000 school buses travel more than 4 billion miles annually, transporting about 24.4 million students daily to and from school (about 51% of the student population). Yet, in a recent year only 32 children were killed in school bus accidents, and approximately two thirds of them were killed outside the bus, where seat belts wouldn't have helped.

--Since 1977, school buses have been designed with extra heavy foam rubber padding on the seats, reduced knee room, and 20-inch-high seat backs, which "compartmentalizes" the seating area to protect passengers in the event of a crash. Additionally, improvements have been made on the overall bus body fuel tank, mirrors, warning lights, heaters and visibility to further protect occupants if a crash occurs.

--A school bus usually weighs seven times as much as the automobile, thus providing a greater degree of safety.

--The school bus passenger space is above the normal impact and penetration zone of the auto that may collide with it.

--Buses providing local bussing generally operate at low speeds, thus making them less dangerous than private vehicles.

School Bus Seat Belt Studies

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The New Hampshire School Transportation Association for years has followed the seat belts on school bus issue, and has tracked more than a dozen studies by the National Transportation Safety Board, National Highway Traffic Safety Administration and many other federal and international research agencies as to their value and effectiveness.

In 1989, the National Research Council (NRC, a long-time research organization conducting studies and investigations in the public interest) concluded an 18-month study on the effectiveness of safety measures on school buses. It stated: "The overall potential benefit of requiring seat belts in school buses is insufficient to justify a federal standard mandating installation." The study had been requested by Congress in 1987 and was funded by the U. S. Department of Transportation.

The NRC, in discussing how students are killed each year with school buses said about 2/3 of those 20 students killed each year with buses are struck by a school bus, usually their own in the loading and unloading zone--that area immediately around the bus at the side and front. This points out that dangers with school buses are far more significant outside the bus, than inside the bus. While even one death is too many, one should not forget the school bus is one of the safest forms of motorized transportation in the world.

To reduce loading-zone accidents, the study committee recommended more careful selection and training of school bus drivers, educating student pedestrians, requiring stop signal arms on all new buses (a requirement after Sept. 2, 1992), and consideration for use of loud speakers, barriers, and sensors to prevent pedestrian accidents, and possibly requiring higher seat backs.

The National Highway Traffic Safety Administration (NHTSA), the nation's agency for establishing motor vehicle manufacturing and crashworthiness standards of all motor vehicles, has continually studied seat belts for improved motor vehicle safety. Even though the NHTSA has supported and promoted state laws for mandatory private passenger use of seat belts, and child passenger restraints for children riding in motor vehicles, the NHTSA has never proposed, nor advocated, seat belts on school buses be mandated for student passengers.

At one time the National Highway Traffic Safety Administration (NHTSA) considered requiring seat belts in school buses. When the evidence was in, however, they ruled that what had seemed to be a reasonable safety measure, was, instead, hazardous and impractical. They required, instead, a new interior design which compartmentalizes passengers in a passive restraint system has shown to be the most effective protection yet.

One of the more notable studies was that of the National Transportation Safety Board conducted over a 29-month period between 1983 and 1986. Primary purpose was to determine how successful the 1977 federal school bus safety standards are in protecting passengers during a crash. The board investigated a total of 43 school bus accidents during the study period, including every accident involving a large post-1977 standard school bus which resulted in a passenger fatality.

Said the NTSB, "We find that large post-standard school buses provide good protection and that unrestrained passengers fare well in all types of crashes, including rollovers....We do not recommend schools or states install lap belts on their buses...We also suggest money be spent on accident prevention such as improved education and programs to train the drivers." The board also recommended improving maintenance practices and equipment, such as better mirrors and other devices designed to protect children in loading and unloading zones, where the majority of school bus related injuries and fatalities occur each year.

In a presentation to the child restraint sub-committee of the Society of Automotive Engineers, Dr. J. Rolf Noer, noted orthopedic surgeon, testified strongly that young children involved in an accident buckled up with just lap belts can be more seriously injured than if they had no seat belt on at all.

In addition, in the event of an overturn of the bus, Dr. Noer said, with just lap belts, the student would be hanging by just their waist area, not the entire torso. Serious interior injuries can result to the young student rider because the frame is so fragile, and usually has such little body muscle and tissue to protect these fragile, vital areas.

Therefore, if installing seat belts, or mandating they be installed and used, the N. H. School Transportation Association believes it important to provide for installation of shoulder harnesses as well as lap belts, as in private passenger cars. Such potential for increased injury--particularly among school age children--if only lap belts are used, is one reason why private passenger cars have a complete passenger restraint system for passengers in the front and back seats--not just lap belts. Currently, technology has not been developed to provide for proper and effective installation of shoulder harnesses on school buses. Thus, it may be considerably safer for no belts at all as the studies suggest.

A study in 1989 by the New York Association of Pupil Transportation, following implementation of the seat belt law in that state, said: "A total of 374 injuries (in NY state) were reported on all buses. 204 were seat belt related, 170 were non-seat belt related (note more injuries with belts, than without). A majority of the reported injuries on both seat belt and non-seat belt equipped buses are caused by fighting. Respondent districts now report seat belts are being used as weapons."

New York is only one of two states in the United States that requires seat belts on school buses. New Jersey is the other. In NY seat belts on school buses are mandated in all new buses manufactured after 1987. There is no such law mandating their usage.

The National Safety Council board of directors on April 17, 1986 reaffirmed its policy as it relates to mandating seat belts on school buses (policy below has not changed since that date):

"The National Safety Council supports methods and procedures that effectively provide safe transportation of pupils aboard school buses. The Council believes that until further research and testing demonstrate that pupils will be safer by the installation of seat belts in school buses, passive protection provided by compartmentalization as required by the current (1977) federal standard on school bus seating and crash protection protects seated pupil passengers in school buses with gross vehicle weight ratings (GVWR) greater than 10,000 pounds. (Compartmentalization involves protecting each passenger by the seat, the seat back, and the back of the seat or restraining barrier immediately in front of it.) The Council also recommends additional research regarding pupil passenger safety in and around school buses, especially as it relates to seat belts."

Our Opinion

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The New Hampshire School Transportation Association encourages the adoption of laws, rules and regulations that promote improved student safety while on school buses. To assure maximum student transportation safety, the Association works closely with the N. H. Dept. of Safety, the N. H. Dept. of Education, and many other groups, agencies and organizations, to find ways to help improve student safety. A typical example of the working relationship this Association has with regulatory agencies to help provide for the maximum safety of school children while on school buses, is the development of a detailed curriculum for use by classroom teachers in Grades K-6 in New Hampshire schools to educate students about school bus safety. This curriculum, now existing in all elementary schools, was the result of volunteers from our Association working closely, and effectively, with officials of the N. H. Departments of Safety and Education over a period of months. Federal highway safety funds made available by the N. H. Highway Safety Agency paid for printing and other incidental costs.

The average cost to install seat belts on a new 71-passenger school bus, has been estimated to be approximately $1,500 per bus. This cost includes installation in accordance with the same federal standards as for the smaller Type II bus.

However, the cost to retrofit existing school buses with seat belts, capable of properly restraining students in their seats during a crash, has been estimated to cost an estimated $11,000 per bus.

Therefore, with 2,200+ state inspected school buses in this state, to equip and retrofit all with seat belts would cost about $24 million. "Mixed messages" would be provided to students if only some buses were equipped with seat belts, or only children of certain ages were required to wear them. In addition, federal studies have shown that additional danger in a crash could be generated if some children are buckled in seat belts, while others are not.

One of the generalized concerns with mandating seat belts on school buses for students, is that many children probably won't wear them unless supervised. Considerable variability exists in seat belt use rates among school districts that now require seat belts. Therefore, if the legislature is to adopt a bill to mandate seat belts on school buses, it should also consider the cost of training and providing for a properly trained monitor on each school bus to assure proper usage at all times by all passengers while the bus is in motion.

The annual cost of 2,200 school bus monitors, which has been estimated to cost $10,000 each, and would add another $22 million annual cost to school district operating budgets.

As indicated, the school bus monitor's role would be to assure that seat belts are properly adjusted, and used. Coinciding with this monitor, we suggest the adoption of a uniform policy to suspend the passenger from the bus, if a passenger is caught, not wearing the seat belt while in motion, after a single, first offense warning.

We believe the cost of equipping our school buses with seat belts and providing for a monitor to assure they are used are expenses that neither the State of NH, school districts, nor our citizens can afford. And, as reputable studies have pointed out, this is not a cost effective use of taxpayers' money.

The N. H. School Transportation Association is very much aware of the New Hampshire law that requires children age 18 and under to be properly restrained while riding in passenger vehicles. The law specifically exempts usage when such children are riding in school buses, and while riding in an antique motor car or motorcycle, or while passengers in vehicles "for hire". We are keenly aware of the typical and responsible feeling-- often emotional--to do everything humanly possible to maximize student safety. We support that view, but seat belts on school buses at this stage do not seem to be the answer.

It is the opinion of the New Hampshire School Transportation Association there needs to be a greater awareness on the part of all publics as to the crashworthiness of school buses, the "compartmentalization" of passengers while riding school buses, the costs to install and maintain proper seat belts on all school buses, and the need to assure the usage by all, if installed and mandated.

We encourage all citizens to:

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--visit their local school transportation department, or local privately owned school bus fleet, and talk with these informed transporters about the "pros" and "cons" of requiring seat belts on buses,

--board a modern day school bus and witness first-hand its crashworthy construction which includes many, many safety standards not readily apparent,

--learn about the various "compartmentalization" requirements that make school buses different (and safer!) from private passenger vehicles.

--learn the positives and negatives of mandating the installation of seat belts on school buses by studying the many federal and international studies that have been conducted on the subject over recent years.

--learn what would be required to install seat belts on new school buses, and to properly "retrofit" existing buses with seat belts.

In Summary

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We caution policymakers against making decisions to require seat belts on school buses, without first becoming fully informed on the issue of requiring seat belts on school buses.

Although the safety record is not perfect, New Hampshire citizens should be proud of the safety and performance record of school buses in this state.

We suggest more attention be given to student safety while around school buses. There needs to be more education of students, parents, and drivers of other vehicles about school bus safety, and we need to better enforce existing laws and regulations designed for student safety.

The N. H. School Transportation Association sees two major safety issues about school buses that should be addressed, and neither of them involve seat belts on buses:

a) National statistics involving students and school buses indicates that when accidents occur students are predominantly seriously hurt or killed while in the bus "danger zone," and not while riding on the school bus. The "danger zone" is defined as the area at the side, front and rear of school buses where students can get hurt when loading or unloading a bus. Citizen and student education needs to be expanded to help improve safety of students while around school buses.

b) All New Hampshire elementary schools in have been provided with a curriculum designed to be used by teachers in educating students about how to improve safety in student transportation. Schools should utilize this educational tool in the classroom, and student education about school bus safety should be mandated for our schools.

As stated earlier, the New Hampshire School Transportation Association is in favor of seat restraint systems on school buses that have been designed, tested, and proven effective for school buses. To date, we believe such restraint systems are not available.

SOME COMPLETED STUDIES/CONCLUSIONS ABOUT SEAT BELTS ON SCHOOL BUSES

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Author's notes: Not listed in any special order. Is nowhere an inclusive list of the studies, but merely those known.

1. University of California at Los Angeles in 1968 (before 1977 federal school bus standards were required), conducted the first formal tests on seat belts for pupil passengers.) Study showed that the greatest injuries occurred to passengers who were seat belted in the bus; the least injuries occurred to passengers who sat unsecured in the bus.
2. National Highway Traffic Safety Administration from 1968-1974 (again before the agency in 1977 set minimum standards for school bus manufacture): conducted extensive research through crash sled tests. Showed that passengers secured in bench seats in a bus by lap belts suffered the most severe injuries in the event of upset or collision, due to the "jackknife effect." Because the child's body is secured, his face and head are aimed at the steel seat ahead, causing head and upper body injuries. (Since 1977 there is a requirement for padded seat backs, not just steel.)
3. National Research Council. 18-month study concluded in 1989. "Overall potential benefits of requiring seat belts in school buses is insufficient to justify a federal standard mandating installation."
4. National Transportation Safety Board. 29-month study between 1983 and 1986 of all fatal school bus accidents, since mandating minimum manufacturing standards in 1977 of school buses. "We find that large post-standard school buses provide good protection and that unrestrained passenger fare well in all types of crashes, including rollovers...We do not recommend schools or states install lap belts on their buses."
5. New York State Association of Pupil Transportation, concluded in 1989, following implementation of seat belt law (on school buses): "A total of 374 injuries (in NY state) were reported on all buses. 204 were seat belt related, 170 were non-seat belt related. A majority of the reported injuries on both seat belt and non-seat belt equipped buses are caused by fighting. Respondent districts now report seat belts are being used as weapons."
6. National Safety Council board of directors April 17, 1986 reaffirms policy against seat belts on school buses. "...The Council believes that until further research and testing demonstrate that pupils will be safer by the installation of seat belts in school buses, passive protection provided by compartmentalization as required by the current (1977) federal standard on school bus seating and crash protection protects seated passengers in school buses with gross vehicle weight ratings (GVWR) greater than 10,000 pounds..."
7. Thomas Built Buses, High Point, NC (major school bus manufacturer), in 1988 warned against dangers of optional seat belt use in school buses. "In a school bus where seat belt use is optional, any given seat might be occupied by students wearing lap seat belts. It is also possible that the seat directly behind that seat could be occupied by students not wearing the available seat belts. In this case, a severe frontal crash could result in the seat with the belted occupants being stressed beyond design limits due to the combined forces exerted by the seat belts on the frame and the forces exerted on the back of their seat by the momentum of the rearward seat unbelted occupants when they are simultaneously thrown against the seat back. In the concept of "compartmentalization" which was standardized on all school buses manufactured after 1977, seats are designed to withstand momentum force from the rear and withstand lap belt pressure, but not both simultaneously..."
8. National Motor Vehicle Research Foundation in 1972. Conducted 200 crash tests with seat belts. Foundation concluded that at least 40 inches of unobstructed area must exist in front of the belted passenger in order to protect him from frontal impact. Seats in school buses are typically spaced 20-28 inches apart.
9. United States Air Force in 1972 performed crash sled tests. Tests showed that lap belts alone severely increase abdominal area injuries. The impact load must be distributed over greater areas than a lap belt provides, and not solely on the abdomen.
10. American Association of Automotive Medicine (1975). Physicians advised against securing young children solely by lap belts in either passenger autos or buses. The abdominal and pelvic sections of young children are not sufficiently developed to withstand the stress caused by lap belts in collisions.
11. California Highway Patrol, in conjunction with Southwest Research Institute (1976). This study concluded that the interior of a bus differs from that of an auto in that appurtenances such as steering wheels, door handles, etc. are not present, and there are no doors or windows through which passengers might be ejected; therefore, the major function of seat belts in automobiles is not present in buses. Study further concluded that seat belted passengers in a large bus cannot be easily removed from outside the bus in event of crash or rollover.
12. Transport Canada performed head-on crash tests in 1984. "The use of lap seat belts in any of the three sizes of recent-model school buses tested may result in more severe head and neck injuries to a belted occupant than to an unbelted one in a severe frontal collision...in general, the results indicated that the belted dummies experienced higher head and lower chest accelerations than did the unbelted ones."
13. Virginia Polytechnic Institute and State University (1974) conducted attitudinal studies of seat belts in school buses. Their findings questioned the compliance of children using seat belts and the ability of drivers to enforce seat belt usage. In addition, the legal and educational barriers to seat belt installation were considered factors that would make seat belts impractical for school buses. Page 3--Some Completed Studies and Conclusions
14. National School Transportation Association (1974-1976) computed the cost of safety belt systems in school buses. Their conclusions were that the economics of seat belts due to hazard, enforcement, vandalism, and attitudinal factors were not cost effective. Also concluded that what on the surface seemed a reasonable safety measure was instead impractical and hazardous. Yet maximum protection to passengers in a school bus from impact was still an important goal.