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NHTSA Receives Responses
From Varying Sources

WASHINGTON, D.C. (Jan. 25, 2008) — Over 100 public submissions were collected during the two-month comment period. Every facet of the school bus industry sent in their thoughts, concerns and overall opinions on NHTSA’s proposed rule on seat belts in school buses. Manufacturers, bus OEMs, NASDPTS, NAPT, state pupil associations, a former director of NHTSA’s Office of Crashworthiness, transportation directors, drivers and even students took time out — some much more than others — to comment for or against the NPRM. Look for a comprehensive article in the March issue of School Transportation News.

Comments:

“As a 6-foot-tall high [sic] school sophomore, I know that school bus seat backs are far too short. My concern is not so much passenger override as possible neck injury from whiplash to tall students. Based on the cost estimate for raising the seat backs from 20 inches to 24 inches ($150), my proposed change from 20 inches to 30 inches would cost no more than $500 per bus (probably less). That is a bargain compared to money and lives it will save.”
Christopher Pannier, a 10th grader from Miramar High School in Miramar, Fla.

“I want to commend NHTSA for taking the initiative to open this important issue for review. However, I find the proposal and underlying analysis deficient in several regards, many of which would be fatal to any subsequent final rulemaking action.”
— James E. Hofferberth, former director of NHTSA’s Office of Crashworthiness

“The Michigan Association for Pupil Transportation (MAPT) … believes modifications to the current system of school bus passenger crash protection should only occur when we can be sure beyond a reasonable doubt that the modifications will improve the safety of each and every child in a school bus.”
— Karen Losch, MAPT executive director

“As statistics demonstrate, school buses are already one of the safest forms of transportation. We support NHTSA’s desire that there be no reduction in the number of children that are transported to and from school on school buses.”
— Bruce Miles, engineering manager of policy & validation for Blue Bird

“Pupil Transportation within the State of Washington is currently under-funded, at some districts by as much as 40 to 60 percent. By adding another unfunded mandate, districts will be required to seek financial assistance through local tax dollars.”
— Delphie Nielsen, director of transportation for Clover Park School District in Lakewood, Wash.

“...It seems that NHTSA is adding considerable complexity to the seat belt issue by proposing one set of regulations for small school buses, and a different set of regulations for larger school buses; and by proposing seat belt regulations for school buses that differ significantly from similar regulations that have been applied somewhat consistently to most other types of vehicles for many years...”
— Patrick M. Glance, president of Concept Analysis Corporation

“There seems to be a contradiction in the philosophy regarding passenger accommodation for school bus seats with seat belts. The NPRM accommodates the full range of school bus passengers with regards to the seat belt system but not with regards to seat width.”
— Freedman Seating Company

“... We believe that school districts and other providers of school bus transportation should consider equipping their school buses with seats that incorporate lap/shoulder belts, as long as they can do so economically and without reducing the capacity of their school bus fleets in a manner that would lead students to use other less safe means of transportation to and from school.”
— James Johnson, director of sales, and Charles Vits, market development and compliance manager, for SafeGuard/IMMI

To read all of the comments, as well as related documents click here.

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