February 9, 1998

The Honorable Ida G. Ruben
204 James Office Building
Annapolis, MD 21401-1991

Dear Senator Ruben:

It has come to our attention that the Maryland Senate is considering legislation that would require the installation of seat belts or other appropriate restraining devices in all new Type 1 school buses purchased on or after July 1, 1998 and that all existing Type 1 school buses would have to have such systems retrofitted before July 1, 2003.

The National Association of State Directors of Pupil Transportation Services was founded in 1968 and represents a cross section of individuals and organizations involved in the safe transportation of school children. As the association's name indicates, individuals with the primary responsibility for school transportation in each state are members. In addition, the school bus manufacturers, many equipment suppliers to the school bus industry or the school bus aftermarket, and a number of state associations whose members include school transportation officials, drivers, trainers, and mechanics also are members of affiliated councils within the association. Based on this diversity in membership, we believe that the State Directors Association provides a unique perspective on school transportation issues and speaks for a large segment of the "school transportation industry."

The issue of whether to require seat belts on large school buses is a topic that has been thoroughly studied and debated for many years. An important, but often overlooked fact in the debate, is the difference between seat belts (lap belts only) versus safety belts (lap/shoulder belts). In general, advocates for seat belts point out the potential benefits of seat belts in terms of reduced injuries and fatalities in school bus crashes. They also refer to the importance of consistency in teaching children to buckle-up in all types of motor vehicles -- if there are no seat belts in school buses, advocates believe there is an obvious break in the chain of consistency.

Those opposed to the installation of seat belts on school buses point to a wide variety of data and facts: (1) the safety record of school buses; (2) analyses of real-world school bus crashes; (3) laboratory crash test data; and (4) the realization that there are other safety problems related to pupil transportation that pose significantly higher risks to the Nation's children.

On January 18, 1998, CNN aired a television show that portrayed Type 1 school buses as being unsafe because they are not equipped with seat belts. Millions of viewers were given information about school bus safety, and led to believe that children on school buses are at serious risk without seat belts. However, there was significant misinformation and omissions of data in the show, which you as a legislator should know and understand.

The premise of the show was that data published by the National Safety Council over the past 12 years shows a 94 percent increase in pupil injuries, and the lack of seat belts in large school buses was the reason for those increased injuries. CNN made note that these increases in injuries occurred during a time period when the number of pupils transported each year did not fluctuate significantly, and the number of school bus crashes each year has remained relatively constant.

Given these three pieces of data (number of injuries, number of pupils, and number of crashes), it is unfortunate that the CNN staff did not ask the simple question, "Why has there been an increase in injuries as reported by the National Safety Council?" It is a well-accepted fact in the motor vehicle safety community that increases in injuries are principally the result of increases in motor vehicle crashes. To a lesser extent, increases in injuries are related to the average occupancy of motor vehicles. Also, there is a correlation between fatalities and injuries in motor vehicle crashes -- if injuries increased significantly, there would be an expected increase in fatalities. Since school bus crashes, school bus occupancies, and school bus occupant fatalities have remained relatively constant during the 12-year period cited in the CNN show, the obvious question arises - Are the National Safety Council school bus injury data reliable indicators of what happens in the real world?

The State Directors Association analyzed the National Safety Council school bus injury data and concluded that the data contains serious flaws, and therefore has no utility in assessing injury trends in school bus-related crashes. This comment is not intended to be a criticism of the National Safety Council, but rather recognizes that the injury data obtained from approximately 35 states each year is not collected and maintained among those states using standardized, consistent definitions of what constitutes a "reportable injury." Additionally, the National Safety Council data do not provide any information on the severity level of the injuries. In order to know whether or not a serious safety problem exists in any type of motor vehicle, and more importantly how to develop an appropriate safety countermeasure, it is essential to understand the nature of the injuries. Data indicate that only a very small percentage of school bus passenger injuries are serious.

Discussions are underway with the National Safety Council to see what can be done to improve the consistency of the data supplied by the states, and to better characterize the meaning of the data once it is published. The importance of gathering quality data, using appropriate analytical techniques, and publishing useful reports is well recognized in the school transportation industry.

The CNN report also included a number of comments about several specific school bus crashes that resulted in injuries and fatalities, and left the clear impression that seat belts (lap belts only) may have made a positive difference in the injury/fatality outcome of that particular crash. What CNN did not discuss were the 43 serious school bus crashes that the National Transportation Safety Board investigated to evaluate the effect that seat belts may have had in those crashes.

These crashes included frontal and side impacts, and included a large number of rollovers. A team of professional accident investigators and biomechanical engineers reconstructed each crash, evaluated the motion of the occupants, and identified the cause of the injuries/fatalities. For each crash, an evaluation was made of whether the use of seat belts would have made a difference in the injury levels of the school bus occupants.

These real-world data unequivocally show while seat belts may offer a safety benefit in some instances, that in most crashes, the installation and use of seat belts would not have changed the fatality/injury outcome of the crash. Equally important is the fact that in a significant number of crashes the use of seat belts would have worsened the injury levels. In fact, it appears that in one instance the use of seat belts would have killed a child that would have otherwise survived.

The State Directors Association believes student transportation safety is a subject that should not be taken lightly, much less misrepresented. The real tragedy of the CNN show is that it had an opportunity to inform parents that school buses are the safest way of getting their children to and from school and school-related activities, but did not do so. Instead, parents who saw the show have been misinformed about the safety of school bus transportation. Moreover, these same parents may now be needlessly frightened about putting their children on the safest form of transportation in America, or worse, may think that is safer to take their children to school in their own vehicles, or in a van, or on a public transit vehicle. Nothing could be further from the truth, and tragically, CNN has done nothing to ensure that parents are aware of that fact.

School bus transportation has been and continues to be the safest form of transportation in America. Every year, approximately 440,000 public school buses travel over 4 billion miles to transport 25 million children to and from school and school-related activities. During the past 10 years, an average of 10 school bus passengers per year have sustained fatal injuries in crashes. While each of these fatalities is tragic, the number of school bus passenger fatalities is small when compared to the number of children killed in other types of motor vehicles. For example, in 1996 there were over 5,000 deaths among children aged five to 18 in vehicles other than school buses. Considering the number of miles that school buses travel compared to passenger cars, school buses are about four times safer.

One of the major reasons for the outstanding safety record of school buses is the manner in which they are constructed. As is the case with all motor vehicles sold in the United States, school buses have to meet a stringent series of Federal motor vehicle safety standards designed to provide school bus occupants with high levels of safety should a crash occur. One of those Federal standards, "School Bus Passenger Seating and Crash Protection," establishes minimum crash protection requirements for occupants of all school buses manufactured on or after April 1, 1977.

For Type 1 school buses, those with a gross vehicle weight rating above 10,000 pounds, the Federal standard requires occupant protection through a concept called "compartmentalization" - - strong, well-padded, well-anchored, high-backed, evenly-spaced seats. "Compartmentalization" is a passive means of providing occupant crash protection -- it is always there. The effectiveness of "compartmentalization" has been confirmed by independent studies by the National Transportation Safety Board and the National Academy of Sciences. As discussed above, in 1987 the National Transportation Safety Board completed a detailed analysis of 43 serious accidents involving large school buses. The Board reached several conclusions concerning seat belts, most notably that most school bus occupant fatalities and serious injuries were "attributable to the occupants' seating position being in direct line with the crash forces. It is unlikely that the availability of any type of restraint would have improved their injury outcome."

Laboratory crash tests conducted to evaluate the effects of seat belts in Type 1 school buses concluded that the use of seat belts "may result in more severe head and neck injuries in a severe frontal collision." These laboratory test results substantiate the findings of the National Transportation Safety Board's analyses of real-world crashes where they believe that seat belts would increase the injury severity levels in some crashes.

In 1989, the National Academy of Sciences completed a study at the direction of the United States Congress on "the principal causes of fatalities and injuries to school children riding in school buses and of the use of seat belts in school buses and other measures that may improve the safety of school bus transportation." The Academy was directed to "determine those safety measures that are most effective in protecting the safety of school children while boarding, leaving, and riding in school buses." In its conclusions, the Academy noted that "the overall potential benefits of requiring safety belts on large school buses are insufficient to justify a Federal requirement for mandatory installation. Funds used to purchase and maintain seat belts might be better spent on other school bus safety programs and devices that could save more lives and reduce more injuries." As an example, the Academy pointed out that since children are at greater risk of being killed in the school bus loading zone (i.e., while boarding or leaving the bus) than as a passenger on the school bus, "a large share of the school bus safety effort should be directed to improving the safety of school bus loading zones."

Another example which poses significant safety risks in the area of pupil transportation is the number of children that do not ride school buses to and from school and school-related activities. In Maryland, approximately 40 percent of public school students (about 400,000 children) go to and from school by some means other than school buses. Some walk or ride bicycles, some ride in private vehicles, and some ride public transportation. By every measure, the school bus provides significantly higher levels of safety.

The State Directors Association firmly believes that the data and science concerning seat belts on Type 1 school buses is compelling.

• Real-world crash data prove that Type 1 school buses are extremely safe without seat belts.

• Real-world crash data prove that "compartmentalization" is an effective means of occupant crash protection in Type 1 school buses.

• Laboratory crash test data support the real-world conclusions that seat belts in Type 1 school buses can cause more severe injuries/fatalities.

• There are no dangerous trends in terms of the number of pupils that are injured or killed as passengers on school buses.

  here are no identified safety problems in Type 1 school buses that the installation of seat belts would remedy.

For your information and use, enclosed are copies of position papers written by the National Highway Traffic Safety Administration and this association. If you have any questions or would like to discuss this information further, please call me or Charles Gauthier, Executive Director of the association, at 1-800-585-0340.

Sincerely,

(sgn) Terry L. Voy
President

Contact NASDPTS at 116 Howe Drive, Dover, Delaware 19901 1-800-585-0340