Interpretation ID: aiam4306
Regional Coordinator
National Coalition for Seatbelts on School Buses
P. O. Box 225
Galena
Alaska 99741;
Dear Ms. Osborne: This responds to your January 29, 1987 letter to Mr. Barry Felrice NHTSA Associate Administrator for Rulemaking, asking about our agency's position on safety belt use in small school buses (i.e., school buses with gross vehicle weight ratings (GVWR) of 10,000 pounds or less). Your letter has been referred to me for reply.; In your letter, you explain that you and the Alaska School Bus Safet Committee are interested in Alaska's implementation of Highway Safety Program Standard No. 17, *Pupil Transportation Safety.* You request clarification of NHTSA's position on safety belt use in small school buses because members of the committee believe that safety belts are provided on those buses only for the use of special education students. You also request information on safety belt education programs that schools could use to encourage the proper use of safety belts by student passengers in small school buses.; As you might know, NHTSA has two sets of regulations for school buses The first set, issued under the authority of the National Traffic and Motor Vehicle Safety Act, applies to the manufacture and sale of new school buses and includes our motor vehicle safety standards for school buses. One of these safety standards is Federal Motor Vehicle Safety Standard No. 222, *School Bus Passenger Seating and Crash Protection,* which requires the safety belts for passengers on small school buses. The second set of regulations, issued under the Highway Safety Act, includes Highway Safety Programs Standard No. 17 and relates to the use of school vehicles. Because requirements for the use of school buses are set by the states, Standard No. 17 sets forth recommendations to the states for the pupil transportation aspect of their highway safety programs. We encourage states to consider Standard No. 17's recommendations but do not insist on compliance with every aspect of the standard.; As you are aware, NHTSA does not believe that a Federal requirement fo safety belts on large school buses (GVWR greater than 10,000 pounds) is necessary because large school buses are very safe due to their mass, seating configuration and 'compartmentalized' seating positions. However, because small school buses experience greater force levels in a crash, passengers on these vehicles need the added safety benefits of the belts to mitigate against injuries and fatalities. Of course, the belts on small school buses provide safety benefits only if they are properly used. We thus recommend they be used by all pupils whenever the children are transported. This recommendation is consistent with Program Standard No. 17, which states, 'Passengers in Type II school vehicles equipped with lap belts shall be required to wear them whenever the vehicle is in motion.' (IV.C.3.d(5).); With regard to your question about belt education programs, NHTSA an the National PTA have put together a 'Safety Belt A/V Resource Kit' and a 'Children's Training Kit' as part of our 1986 safety belt awareness campaign. The kit contains material geared toward increasing safety belt use by children in passenger cars, and might be helpful in promoting belt usage in small school buses. I am sending you the resource kits by separate cover.; Further, some states have developed their own safety belt eductio programs for school children. The person in your state who might be able to provide you with more information on the programs available in Alaska is:; <<