Interpretation ID: 12975-1.pja

Dana Schuman
1443 Revelation Road
Meadowbrook, PA 19046

e-mail: CloonCraze@aol.com

Via e-mail and mail

Dear Dana Schuman:

This responds to your October 27, 1996 e-mail to President Clinton enquiring about where you could get information about writing a bill to require seat belts on school buses. Your inquiry was referred to the National Highway Traffic Safety Administration (NHTSA) because this agency is authorized to develop motor vehicle safety standards applicable to all new motor vehicles, including school buses.

Before referring you to sources of information on school bus seat belt legislation, I will briefly review this agency's existing belt installation requirements for school buses and the rationale behind them. Small school buses, those with a gross vehicle weight rating under 10,000 pounds, must be equipped with lap or lap/shoulder belts at all designated seating positions. For larger school buses, our requirements only specify that a safety belt must be installed for the bus driver. Note that NHTSA regulates only belt installation. Belt use regulation is left to the States.

We have not required large school buses to have safety belts for passengers because we have not found sufficient justification for such a requirement, given that these buses have excellent safety records. This safety record arises in part from the fact that, in crashes with other vehicles, buses tend to be substantially heavier than the other vehicle. As a result, the crash forces experienced by bus occupants tend to be less than those experienced by car occupants. Also, because of the elevated seating positions in large buses, bus occupants sit above the area typically damaged in a collision with another vehicle. Since the size and weight of small school buses are closer to those of passenger cars and trucks, the agency believes seat belts in those vehicles are necessary to provide occupant protection.

Larger school buses have a protection system so that children are protected without the need to buckle-up. Our regulations require large school buses to use a concept called "compartmentalization," which protects occupants by a protective envelope consisting of strong, closely-spaced seats that have energy-absorbing seat backs. The effectiveness of compartmentalization has been confirmed in studies by the National Transportation Safety Board and the National Academy of Sciences (NAS).

Although large school buses are not required by Federal law to have passenger safety belts, NHTSA does not prevent States and local jurisdictions from requiring safety belts on their own large buses. If you are considering drafting such legislation, we urge you to include provisions designed to promote proper belt use. The NAS report states that if seat belts are to be beneficial, "states and local school districts that require seat belts on school buses must ensure not only that all school bus passengers wear the belts, but that they wear them correctly."

Since no Federal legislation requiring seat belts on school buses has been introduced, the best sources of information are in the two States that have such requirements, New York and New Jersey. We suggest you contact one of the following people:

Nick Geiger, Deputy Director New Jersey Division of Highway Traffic Safety 225 E. State Street, CN-408 Trenton, NJ 08625 (609) 633-9300

Phyllis Scheps, President New Jersey PTA 5 Tanney Court West Orange, NJ 07052 (201) 731-3304

I hope this information is helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact Paul Atelsek of my staff at (202) 366-2992.

Sincerely,

John Womack

Acting Chief Counsel

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