Interpretation ID: nht95-2.64

TYPE: INTERPRETATION-NHTSA

DATE: May 2, 1995

FROM: Bonnie Ward -- Director of Transportation, Eagle County School District (Colorado)

TO: Chief Council, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO 8/2/95 LETTER FROM JOHN WOMACK TO BONNIE WARD (REDBOOK 2; PART 571); ALSO ATTACHED TO 5/28/85 LETTER FROM DIANE K. STEED TO GEORGE L. SIMONTON

TEXT: Dear Sir:

I am preparing a presentation for our district administrators detailing a comparison of the safety standards for over-the-road passenger buses versus school buses. I requested and received the enclosed letter from Charlie Hott, which is very informat ive about school buses, but gives very little information about over-the-road buses.

In a follow up conversation with Mr. Hott, he assures me that these regulations are above and beyond the requirements for over-the-road coaches. I would like this statement in writing. Any additional information you have concerning the safety standa rds for over-the-road coaches would be greatly appreciated.

Thank you for your information and support.

Enclosure (letter)

Ms. Bonnie Ward Eagle County School District P.O. Box 740 Eagle, CO 81631

Dear Ms. Ward:

Thank you for your recent inquiry about the differences in the Federal motor vehicle safety standards (FMVSSs) between over-the-road type buses and school buses. The National Highway Traffic Safety Administration (NHTSA) is responsible for establishing FMVSSs to reduce the number of fatalities and injuries that result from motor vehicle crashes, including those involving school buses and over-the-road type buses.

You stated in your letter dated March 20, 1995, that you wished a comparison between the crashworthiness of over-the-road buses and school buses. However, in a follow up conversation, you stated that a comparison of the FMVSSs would suffice because of t he lack of crash test data in that area.

In 1974 Congress directed NHTSA to establish or upgrade school bus safety standards in eight areas: Emergency Exits; Interior occupant protection; Floor strength, Seating systems; Crashworthiness of the body and frame; Vehicle operating systems; Windshields and windows; and Fuel systems.

As a result of the 1974 amendments to the Highway Safety Act, three new motor vehicle safety standards were established and four existing standards were amended. Standard No. 220, "School bus Rollover Protection" improved the structural resistance of sc hool buses in rollover-type accidents. Standard No. 221, "School bus Body Joint Strength" improved the strength of the joints between panels which make-up the school bus body. Standard No. 222, "School Bus Passenger Seating and Crash Protection" improv ed the crash protection provided by school buses through a series of interior changes known as "compartmentalization" -- well padded, well anchored, closely spaced high-backed seats that are designed to absorb energy.

Standard No. 105, "Hydraulic Brake Systems" was amended to upgrade the requirements for hydraulic brakes on school buses. Standard No. 111, "Rearview Mirrors" was amended to establish requirements for cross-view mirrors on school buses. Standard No. 21 7, "Bus Emergency Exits and Window Retention and Release" was modified to require all school buses to be equipped with either a rear exit door or a side exit door and rear push-out window. Standard No. 301, "Fuel System Integrity" amended fuel system in tegrity requirements for large school buses. All of these requirements were effective for school buses manufactured after April 1, 1977.

Recently, there have been several additional changes to the FMVSSs for school buses. Additional emergency exits were required, depending on the capacity of the school bus. These exits included emergency exit doors, emergency roof exits, and emergency e xit windows. A standard that required stop signal arms on all school buses was implemented. The mirror standard was amended to require that the driver be able to see the area directly in front of and along both sides of the school bus. These last two standards were implemented to reduce the number of fatalities that occur outside the school bus, typically in the loading zone. School bus pedestrian fatalities account for the highest number of school bus related fatalities each year.

School buses must meet the above mentioned safety standards in addition to the FMVSSs that are applicable to over-the-road type buses.

In the legislative history of the School Bus Safety Amendments of 1974, Congress stated that school transportation should be held to the highest level of safety, since such transportation involves the Nation's most precious cargo -- children who represen t our future. As a result, NHTSA believes that school buses should be as safe as possible. Under Federal law, dealers are prohibited from selling or leasing buses for use in transporting students to and from school and school-related activities, unless they comply with Federal school bus safety standards. Federal regulations do not prohibit the use of over-the-road buses by schools, but require any bus sold or leased for use as a school bus to meet the safety standards applicable to school buses.

School bus transportation has been and continues to be one of the safest forms of transportation in America. Occupant deaths in school buses per vehicle mile traveled are about one-fourth those for passenger automobiles. Every year, approximately 394,0 00 public school buses travel approximately 4.3 billion miles to transport 23.5 million children to and from school and school-related activities. Since 1983, on the average, 11 passengers per year have died in school bus crashes. While each of these f atalities is tragic, the numbers of fatalities among school bus occupants are small when compared to those in other types of motor vehicles. For example, in 1993, 3 children between the ages of 5 and 18 died in crashes of school-bus-body type vehicles. During the same year, 5357 children between the ages of 5 and 18 died as passengers or drivers in all other types of motor vehicles. School bus pedestrian fatalities account for the highest number of school bus related fatalities each year. There are about 30 such fatalities per year, about two-thirds of which involve the school bus itself and about one-third of which involve motorists illegally passing the stopped school bus.

I hope that this information is helpful to you. If I can be of further assistance, please contact me or Charles Hott, Safety Standards Engineer, at 202-366-0247.

Sincerely,

Leon DeLarm, Chief Pedestrian, Heavy Truck, and Child Crash Protection Division, NHTSA