
Why
Doesn't My New
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| Webmaster Note: This White Paper was developed by the United Motrocoach Association and published in February 1, 1999 edition of The Docket, the association's official newsletter. The White Paper reflects the association's beliefs about the value of seat belts as an occupant restraint strategy in motorcoaches and over-the-road buses. The statement is presented here in its entiregy and with permission of the UMA. Click here to visit the UMA's website. |
We're
happy you asked. It's one of the most prevalent questions in the American
bus and luxury motorcoach business today. Indeed, the answer is just
as straightforward. As a service to its more than 1,000 member companies,
the United Motorcoach Association (UMA) has prepared this brief summary
of the answer and the issues surrounding the installation and use of
seat belts on coaches.
The answer
We won't keep you in suspense.
The quick answer is, "Because they aren't needed." That's not just our answer.
It's the answer which is offered by the National Transportation Safety Board
(NTSB), the Federal Highway Administration (FHWA) and the agency charged with
vehicular safety and construction standards, the National Highway Traffic
Safety Administration (NHTSA). NHTSA is the federal agency, by the way, which
commonly uses a small graphic image of a safety belt at the foot of its own
letterhead which says "SAFETY BELTS SAVE LIVES." It's on their letter of August
19, 1992, in which they respond to the common inquiry by saying,
"NHTSA expressly determined that there is not a safety need for safety belts or another type of occupant crash protection at these seating positions (aboard commercial buses weighing more than 10,000 pounds)."
That
message has been consistent. As late as December 1998, NHTSA spokespersons
have repeated their belief that large buses simply wouldn't reap a safety
benefit by placing seat belts throughout the seating compartment.
While
the answer is quick and easy, understanding it -- especially in an era when
"Buckle Up!" is a universal and enduring campaign cry for millions of automobile
motorists -- is the tough part. To understand how federal safety experts can
suggest belts are the answer for everyone except motorcoach passengers, we
need to go back to some of the lessons you probably forgot 20 minutes after
your last high school physics exam. And we need to look at the basic construction
of a modern motorcoach, rather than rely on what you already know about the
Buick or Honda you might see on the road today.
Before
we begin, we should also offer one important observation: the commercial motorcoach
of today is the safest form of highway transportation available, bar none.
By NTSB's own count, an average of six coach passengers are fatally injured
each year over the 30-year span from 1968 to 1998. Compare that to highway
death tolls ranging from 30,000 to 50,000 automobile passengers annually,
and we're faced with a basic question, "What problem would seat belts on coaches
fix?" More on that later. First, the science refresher.
What happens
in a crash?
Please note that we, like the
regulators and enforcement community, use the word "crash" to describe vehicle
collisions. While "accident" is the more common term for most of us, it suggests
that the collision happens virtually without avoidable cause. "Crash" makes
no such judgement, it simply describes the event.
In
any vehicular crash, there are really three collisions taking place. The first
is the impact of the vehicle against something else, a wall, another vehicle,
a bridge, etc., which causes a rapid "deceleration impulse." The second collision
is the impact of the person inside the vehicle against whatever object is
there to stop him or her: a steering column, a windshield, a belt or harness.
The third collision is within the passenger, when organs slam against bones
or other organs, causing most of the actual injuries.
This
is where we offer the high school physics refresher. Sir Isaac Newton explained
with his laws of physics that passengers will tend to keep going forward when
a vehicle stops suddenly. But those laws also help us understand that there
are vastly different forces at work when large and small objects collide with
something or with one another. It's apparent (and common knowledge) that when
a large object and a small object collide, the larger object wins. What is
less apparent, though, is the fact that the "G-forces" (one "G" is the force
of gravity) exerted on the large object during that rapid deceleration are
far less than those in the smaller object. A crash which exerts a 20-G force
on an 4,000 pound automobile would exert less than a 7-G force on a 38,000
pound motorcoach.
Seat
belts, air bags and harnesses in automobiles are designed to accomplish one
primary objective: to hold the passenger and the vehicle tightly together
so that they react as a single object. That allows the much smaller passenger
to take advantage of the much greater weight of the vehicle they're riding
in to reduce the G-forces at work on his or her body during impact. Today's
NHTSA load rating requirement for automobile seat belts is 20-G's.
Now the
construction part
Today's motorcoaches aren't
required to have seat belts. That's because regulators and highway safety
experts have long recognized that existing bus design features work extremely
well in protecting passengers from the vast majority of crash circumstances.
First,
passengers are "made part of the vehicle" in a motorcoach by the seating system's
inherent ability to achieve "compartmentalization." What belts accomplish
in autos, compartmentalization accomplishes in today's motorcoach: it keeps
the passenger "contained" during crashes, like eggs in a carton. Passengers'
forward movement is severely limited by the seat ahead of them. In the most
common form of motorcoach crash - - head-on or sideswipe -- passengers essentially
remain in the seated posture, striking the energy-absorbing, high-back seat
ahead of them. The force of the crash is spread over their entire upper body
before they drop back into their seats, generally still in the seated posture.
Indeed, the restraining effect of the forward seat is less immediate than
seat belts would be, but at the large vehicle's lowered deceleration impulse
force, the immediacy of the restraint is far less important.
Today's
motorcoaches are also built to absorb crash energies. While automotive engineers
have spent years building "crush zones" into cars, motorcoaches have always
enjoyed the advantage of an energy-absorbing construction. Using a "monocoque"
or "unibody" design, coaches crush by small increments on impact. And rather
than absorbing the entire crash impulse at the point of impact, monocoque
construction allows crash forces to be distributed through the entire length
of the body.
[Sidebar: School bus construction is different. NHTSA has required that school buses are be built with very rigid boxes which allow school buses to resist intrusions by outside objects, rather than absorb crash energy. Their rigid body construction makes school buses react to crashes differently than monocoque-built motorcoaches.]
Compartmentalization
also provides what might be the ideal "passive restraint" system; it delivers
passenger protection without asking the passenger to take any action other
than sitting in their seat. Air bags and automatic, sliding, seat belts were
the automotive industry's answer to the biggest problem yet identified with
seat belts: people just don't use them. As recently as January 1999, NTSB
took a close look at automotive child restraint systems. It found that in
62-percent of the cases where restraints were present but serious injuries
still resulted, it was because the restraint device was not used, faulty or
simply used incorrectly. By its dependence on compartmentalization and energy-
absorbing construction, motorcoaches have also avoided an unpleasant side
effect of belts: "soft tissue" injuries which are caused by belts themselves.
Is there
more we could do?
Compartmentalization, monocoque
construction, energy-absorbing, high-back seats and soft covered interior
elements all contribute to the passenger protection of motorcoaches, but they
are intended to work together as a "passenger protection system." There are
some places, though, where every element of that system may not be present.
In the United States, for instance, belts are currently mandated for coach
drivers, a seating position which doesn't benefit from compartmentalization.
The NTSB has also been assessing the safety value of belts or other restraint
devices such as exaggerated modesty panels in other "exposed" seat positions
aboard coaches: the forwardmost seats, the center rear seat which faces an
aisle, and seats behind desk or table installations.
Another
element of the protective "system" used in motorcoaches has come under question
in recent years, as well. Investigations of fatal bus and motorcoach crashes
over the past 20-years have shown that a passenger death usually occurs in
one of two ways. The first is a massive intrusion into the passenger space.
In a collision with a large vehicle or stationary object, passengers within
the intrusion zone are at obvious risk. The second most prevalent cause of
death is by ejection or partial ejection. There is strong evidence that most
crashes are survivable when passengers stay inside the vehicle. That's drawn
attention to FMVSS (Federal Motor Vehicle Safety Standards) 217 which determines
construction standards for bus and motorcoach windows.
Created
in an era when gasoline engines were dominant in buses, FMVSS 217 require
manufacturers to install windows which can be opened for use as an emergency
escape during a fire. Since that time, of course, virtually the entire motorcoach
world has moved to diesel engines, significantly reducing the likelihood of
a fire. At the same time, customer demands for a more "European design" have
led to massive, panoramic, window sizes. In circumstances involving violent
vehicle behavior, such as a rare rollover, the windows and latches required
by FMVSS 217 may fail; the result can be passenger ejection. Even when they
function as designed in an overturned coach, the weight of the large windows
has proven difficult to many escaping passengers. In recent months, NHTSA
has acknowledged to UMA that there's a need to revisit its window design mandate.
But its clear that window escape problems have accelerated discussions of
seat belts.
Today's
environment
We've seen that a motorcoach's
size and its construction reduce G forces in a crash and contain and effectively
protect the passenger. And we know that the regulators and safety experts
have responded to the scientific facts by resisting the urge to apply ineffective
(but the most popular) remedies, seat belts. But the politics of seat belts
are far less clear.
From
the time of our child's first ride home from the hospital, proper restraint
is drummed into our consciousness. Buckle Up campaigns dating back 30-years
have effectively convinced drivers and auto passengers that belts are "The
Answer." Attorneys for injured coach passengers accusingly point to the absence
of seat belts in an attempt to capture an easy verdict for their client, despite
the overwhelming evidence that belts wouldn't have helped. Emotion has overtaken
the logic in many cases. Despite very recent testimony from safety experts
that lap belts in school buses may actually present a greater hazard to young
bodies, many belt advocates continue to lobby for a school bus belt mandate.
Politics,
not safety, have driven lawmaking in Europe, as well. Seat belts have been
required in Europe at non-compartmentalized seating positions since 1988 and
in all seating positions for the past two years. Testifying before the NTSB
in the summer of 1998, though, European officials openly admitted that the
installation of belts was a "political" decision, not one driven by safety
research. Starting in Great Britain in response to a particularly bad crash,
political winds carried the seat belt mandate across the Channel and throughout
the European community. At the same time, they acknowledged vastly different
driving conditions than American motorists encounter. For instance, motorcoaches
are limited to highway speeds of about 65-miles per hour in Europe, even on
highways with no speed limit on automobiles. The differential often leads
to violent evasive maneuvers and a much higher incidence of rollover on European
roads. In acknowledgement of the much different physics of the large vehicles,
the European mandate requires only a 6.6-G seat belt load rating for full-sized
coaches. It also requires only the use of two-point (lap) belts.
Professional
motorcoach operators in America have clearly established and accepted the
evidence that seat belts would do little to advance the cause of passenger
safety. And since NHTSA's 20-G load rating requirement remains the only standard
in effect for seat belts in America today, the task would seem virtually impossible.
Trying to install a 20-G seat belt on today's motorcoach could easily add
another 10,000 pounds to the vehicle by forcing new securement structures.
It would reduce also cargo and seating space, cut average fuel economy significantly
and severely limit the seating configurations available. Europe's accepted
6.6-G belt load standard would clearly not meet existing NHTSA rules.
The bottom
line
Safety, above all else, is
the primary goal of this Association and its members companies. After all,
safety is good business. The numbers confirm the fact that the motorcoach
is the safest highway vehicle on the road today. But at the same time, we
aren't smug in our confidence that today's vehicles can't be made even more
safe. Neither NHTSA nor any other highway safety agency, public or private,
has conducted definitive crash testing on today's motorcoaches. UMA stands
eager to step up to the task as a cooperative partner if and when such testing
is conducted. And we stand ready to promote significant safety enhancements
when their value is proven.
With
its manufacturer associates, its safety specialists, its legal team and all
of its resourcefulness and experience, UMA is also trying to help sort out
the issues for you. We know that there are no easy answers, especially when
you're faced by riders, parents, reporters and the inevitable phalanx of challenges
to the "seat belts wouldn't help" response which is most honest of them all.
The
fact remains, however, that seat belts are not just "not mandated," today
they're clearly "not the answer." Any reporter who believes that the issue
has just been overlooked by Congress, NTSB, USDOT, NHTSA, OSHA or a long list
of government and safety agencies just hasn't examined the record.
If
things change, we'll let you know. But until, then, brush up on your physics
and settle in for a long explanation. Or ask your questioners to call us:
(800) 424-8262. We'll even pay for the call.