Prepared for Sandy Garrett
Oklahoma State Superintendent of Public Instruction

By Randy McLerran
School Transportation Officer
January 11, 1993

School transportation is a very unique institution. The very ubiquitousness of school buses creates a "surprise factor." On a daily basis, public school buses quietly transport students millions of miles so safety that when tragedy occurs the public reaction is great. While automobile accidents annually account for approximately 50,000 deaths, accidents involving public school buses average approximately 100 deaths. While school transportation officials would be overjoyed to reduce that figure to zero the fact remains that public school buses remain the safest form of transportation in the United States.

The latest national school bus accident statistics available are for the school year 1989-1990. There were 29,000 reported school bus accidents resulting in 9,800 pupils injured. Of these an estimated 90 persons were killed - 35 pupils, 5 bus drivers, and 50 other persons. Of the 35 pupils killed, 5 were killed while riding the bus and 30 were killed in the loading zone area. More than half of the pupils killed in the loading zone were struck by their own school bus. A more complete analysis of this data and the methodology utilized in gathering data is available.

Oklahoma has been very fortunate in providing safe student transportation. In the period from 1965 until the present there has been four recorded occupant fatalities due to accidents, the number of loading zone fatalities is perhaps four times that, with one loading zone fatality since 1981. In 1989 a vehicle passed a school bus with red lights flashing striking a young boy. The school years from 1990 to 1992 had two occupant fatalities. Both of these accidents resulted from heavy equipment impacting into a school bus. It is felt that in both instances seat belts would not have affected the outcome of the accident.

Analysis of School Bus Crash Test Data:
In response to a serious school bus accident in Jonesboro, Arkansas in the early 1980's two scientific studies were conducted to determine the crashworthiness of poststandard school buses and the effectiveness of seat belts. The Department of Transportation in Canada, the Canadian counterpart to the U.S. Department of Transportation conducted extensive crash testing of school buses. Since 50 percent of school bus collisions are frontal impact, the tests were conducted by utilizing fixed barriers for frontal impact. Dummies equipped with sensors were utilized and the tests were filmed by various camera locations utilizing both high speed and real time cameras. The crash speed was 48 kilometers or approximately 35 mph.

Six instrumented dummies were used, three belted and three unbelted. They were arranged in pairs so as to provide one restrained and one unrestrained dummy for each seat spacing. The dummies utilized were also representative of various body sizes.

The Head Injury Criterion (HIC) which produces a mathematical combination of resultant head acceleration and the duration of that acceleration was used to estimate the degree of harm occupants might suffer in the collision. While this technique has limitations in its ability to predict injury it is the only widely accepted measure currently available. Resultant chest acceleration was used to estimate the degree of harm that might be suffered in that body region.

The HIC readings for the belted dummies exceeded the unrestrained dummies with at least one reading above the threshold level in which severe injury or death would probably occur. In addition the recorded "g" factor for unbelted dummies was once again below the threshold level and the belted dummies above the acceptable limit.

In 1985 an independent testing facility duplicated the Canadian test on smaller buses with Thomas bodies. This test included a side impact test. The results of both tests were correlated and produced the same results. Data is available regarding the statistical analysis and the methodology used.

In both tests the cameras recording the movements, of the test dummies produced a clear understanding of the test data. The unrestrained dummies, upon impact moved forward off the seat cushion striking the padded seat back with the upper chest. The impact was widely distributed over the chest area. The restrained dummies lower torso remained on the seat cushion and the resultant acceleration drove the dead and upper body into the seat back. The dummies face bore the brunt of the impact, often driving the head backwards with sufficient force to cause severe neck injuries.

Both the National Highway Traffic Safety Administration (N.H.T.S.A.) and the National Transportation Safety Board (N.T.S.B.) concur with the findings of these tests and agree that seat belts would not significantly reduce student injuries and in some instances might exacerbate them. The "compartmentalization concept" for passive restraint in demonstrated effective in loss control especially in conjunction with other safety standards regarding vehicle rollover protection, joint body strength, seat securement, window size, and retention.

There is additional medical and safety research that indicates that lap belts improperly worn can result in renal contusions and ruptures of the liver, pancreas, kidneys, bladder, and spleen. Sudden deceleration can result in "abdominal trauma" if the seat belt isn't properly worn. Due to the developmental difference between children and adults it is almost impossible to fit a lap belt to a child in manner that will not cause injuries.

It is interesting to note that in 1990 N.H.T.S.A. ordered auto manufacturers to refrain from rear lap belts in cars in lieu of three point systems. General Motors of Europe recently lost a huge lawsuit due to injuries sustained from rear seat lap belts in automobiles.

The only commonality between cars, trucks, and school buses in the basic configuration of the vehicles. The passenger compartment of school buses is not the "hostile environment" of an automobile with protuberances such as knobs, levers, or switches that could cause injury.

There are other less quantifiable concerns regarding seat belts in school buses. It is generally accepted in the student transportation industry that in most severe accidents the maximum allowable evacuation time is 60-90 seconds. If the students were belted, especially younger students, this time might be lengthened due to panic or confusion in releasing buckles. Due to the vehicle's structural integrity a rollover may result in students dangling upside down and releasing the buckles prematurely. In the last two severe accidents involving school buses, the fatalities were incurred in attempting to evacuate the bus, not from the impact.

Another concern that is justifiable is the belt itself. If a retractor device is not installed, students may use these belts as weapons on each other. It is sad to note, but true, that there have been lawsuits against school districts in New York as a result of this.

Vandalism to school buses in an escalating expense. It has reached a point that schools have been forced to take reactive steps to curb this loss. The number one act of vandalism is cut seat coverings. Jenks Public Schools have reported that the buses equipped with seat belts have had a number of them cut off by students. Installing seat belts on school buses is not simply a one time capital outlay.

Realistically another consideration that must be studied is compliance. New York and New Jersey report only a fifty percent usage by students. Most experts agree that the addition of seat belts on school buses may lead to a "Pandora's Box" of litigation. Without an onboard monitor to enforce usage, unbelted students sustaining injuries might sue the school districts for negligence in not exercising "due care" to ensure that all students are restrained. New Jersey's law has a caveat for this purpose but it is generally agreed that it will not withstand a court test.

Cost of installing seat belts based upon two passengers per seat: for new school buses the average cost is $37.50 per passenger. The following is a breakdown for larger school buses. School buses under 10,000 pounds Gross Vehicle Weight Rating (GVWR) are equipped with lap belts by federal regulations.

• 35 passengers - 12 seats X $75 = $900
  
• 47 passengers - 16 seats X $75 = $1,200
  
• 54 passengers - 18 seats X $75 = $1,350
  
• 60 passengers - 20 seats X $75 = $1,500
  
• 66 passengers - 22 seats X $75 = $1,650
  
• 72 passengers - 24 seats X $75 = $1,800
  
• 79 passengers - 26 seats X $75 = $1,950
  
• 84 passengers - 27 seats X $75 = $2,025
  

The average cost based upon two lap belts per seat = $1,547

The average price of buses sold in FY 91-92 is $35,342

Recommendation:
The consensus of all governmental agencies regulating student transportation, crash testing studies, insurance industry, school bus manufacturers, and student transportation advocacy groups have found no significant advantage to lap belts on school buses. If the safety of transported students is to be improved the following is recommended.

1. The replacement of all prestandard (pre 1977) school buses.

2. Tougher penalties for violating school bus stop laws.

3. Tougher laws prohibiting "standees" in the school bus.

4. Improved school bus driver training.

5. Improved educational programs for parents and children in the areas of ridership and passenger loading and unloading safety.

6. Improved mirror system and emergency exits on school bus. (This has recently been addressed by the National Highway Traffic Safety Administration.)

Whereas, the Nation's greatest resource is children and their safety is a high public priority; and

Whereas, the transportation of children in certified school buses is recognized as the safest mode of passenger transportation available on the highways today; and

Whereas, behavioral research conducted by public and private agencies has indicated that passive restraint systems may offer more passenger protection for children who are not immediately supervised by adults; and

Whereas, research conducted by the United States government resulted in radically improved construction design and seating systems for collision protection and passive restraint systems for passengers protection in school buses manufactures after April 1, 1997; and

Whereas, extensive research conducted by the United States and Canadian governments, and other public and private agencies have yielded negative conclusions on the safety of seat belts installed in school buses, therefore, be it resolved

1. That local, state and federal governments and the general public recognize and affirm the outstanding safety record of school buses; and

2. That local, state and federal governments and the general public recognize the passive restraint system in school buses manufactured after April 1, 1977, have been proven to be a more effective passenger protection system in school buses than the protection provided by seat belts; and

3. That local, state and federal governments discourage the mandatory installation and use of seat belts in school buses until such time that extensive and scientific research proves them to be more effective in injury prevention that the existing passive restraint systems; and

4. That local, state and federal governments and interested organizations conduct sound, comprehensive testing on current occupant protection systems in school buses and determine if the passive restraint system currently mandated in school buses can be further improved to increase the safety of passengers; and

5. That all states are encouraged to accelerate the replacement of school buses manufactured prior to April 1, 1977; and

That a copy of this resolution be transmitted to the President of the United States, and to the leadership of the United States Congress and the governors of each state.