Displaying items by tag: Safety

Safety & Security

Loading & Unloading

The National School Bus Loading and Unloading Survey is a collection of fatality accident records provided by the state agencies responsible for school transportation safety and/or accident records. Only those fatality accidents involving K-12 school children in or around the loading or unloading areas of a school bus or transit bus are included in this survey. Fatalities that occur on-board a school bus are not reported here. Student fatalities that occur at a bus stop before or after the bus has departed are not listed. Neither are fatalities that occur on the way to or from the bus stop, nor those that occur to motorists who strike, or are struck by, a school bus.

Compiled annually by the School Bus Safety Unit at the Kansas Department of Education (and previously the Kansas Department of Transportation), this series started with the 1970-1971 school year. Over the 40-plus years of this series, 66 percent of the fatalities occured to students ages 2 to 9 years of age. Students departing the bus or on their way home from school experienced 60 percent of all fatalities. School buses were the cause of 57 percent of the total fatalities while motorists who passed a stopped school buses with its red light flashing, struck and killed nearly 39 percent of the total fatilities. The report indicates "other information" accounts for the remaining four percent.

The survey shows fatalities that occur going to school, coming home, on activity trips, and by motorists that pass a school bus that has stopped to load or unload school children. Survey results are usually released in December for the previous school year. Fatalities during activity trip transportation are not included since only six occured during the three decades reported. One activity trip-related fatality occured in 1970, 1973, 1974, 1990, and one in 2005; two occured in 1978. Fatalities involving school children that occur on public transit buses have only been included since 1996. The data is spotty since the public transit industry does not report for this study.

There has also been an argument within the school transportation industry of what constitutes a loading/unloading fatality or injury. Historically, only fatalities were reported by states that occurred when the bus was at the stop. But news reports nationwide chronicle all-too frequent instances of child deaths occuring minutes before or after the school bus is on scene. School Transportation News compiles its own data based on these news reports. For the 2009-2010 school year, STN found twice as many accounts of student deaths at or near the school bus stop as the 13 student fatalities reported by the Kansas State Department of Education.



NHTSA Final Rule Enhances Passenger Vehicle Roof Strength

While school buses have had reinforced roofs to better secure occupants in the event of rollover crashes since the mid-1970s, other passenger vehicles such as vans and Suburbans utilized in some school activity trips do not. They will soon be required to meet similar federal requirements after the National Highway Traffic Safety Administration published a final rule last month [PDF].

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Federal Laws

SAFETEA-LU: The reauthorization of the federal highway bill enacted in August 2005 added a provision (49 USC 30112) that outlaws the nation's public schools from purchasing or leasing a non-conforming van for use in pupil transportation services. States may now lose federal highway safety funds if residing schools are discovered to be in violation. SAFETEA-LU expired at the end of September 2009, and Congress passed a half-dozen extensions to keep federal funding of state transportation and highway infrastructure funds flowing. A new reauthorization was expected by fall 2011.

Federal Law on Nonconforming Vans: 49 USC 301 outlining the prohibitions on manufacturing, selling, and importing noncomplying motor vehicles and equipment.

School Bus Safety Act of 2001: Proposed law in the 107th Congress by Rep. Mark Udall (R-CO) to prohibit the purchase, rent, or lease, for use as a schoolbus, of a motor vehicle that does not comply with motor vehicle safety standards that apply to schoolbuses, and for other purposes. The purpose of the law is to ban the use of non-conforming vans in school transportation use. Status: Enacted in SAFETEA-LU


Interpretation Letters

Since the late 1980s, the National Highway Traffic Safety Administration has stored Interpretation Letters that that are particularly important in understanding the questions raised by school systems especially when they use vans to transport students that don't meet the federal laws and regulations that NHTSA administers. Before users look at any of these letters they should take a few minutes to read about Interpretation Files and why they are important?

Listen to what NHTSA says about the subject: "NHTSA's Chief Counsel interprets the statutes that the agency administers and the regulations that it promulgates. The Chief Counsel's interpretations, issued in the form of letters responding to questions from the motor vehicle industry and the public, represent the definitive view of the agency on the questions addressed and may be relied upon by the regulated industry and members of the public. These interpretations have always been available to the public in the agency's technical reference library. The World Wide web enables (NHTSA) to make them available through the Internet."

The Interpretations Database File is a collection of three databases contining Interpretation Letters issued by the agency's Chief Counsel. The first is the Chief Counsel's database consisting of all Interpretation Letters issued since January 1988 when NHTSA first began storing information in an electronic format. In addition, General Motors Corporation and the Association of International Automobile Manufacturers have made their files available for Interpretation Letters issued prior to 1988.

There are several hundred Interpretation Letters found on the NHTSA site that speak to the subject of vans in school service as well as school bus construction. NHTSA issues a word of caution about these interpretations. According to the agency: "In attempting to use these interpretations to resolve a question, please be aware that they represent the views of the Chief Counsel based on the facts of the individual cases at the time the letter was written. Further, interpretations that are relevant to your situation may not be available on the web site. Consequently, if you are aware of a previous interpretation that appears to address your question, please cite that interpretation and present your question to the Chief Counsel. Do not assume that the interpretation applies to your situation. Critical factual differences may exist between your situation and those addressed in previous interpretations. Further, the Agency's standards and regulations change from year to year, and past interpretations may no longer be applicable."

Written requests for additional interpretations should be addressed to:

The Chief Counsel
National Highway Traffic Safety Administration, NCC-01
400 7th Street, SW
Washington, D.C. 20590

Non-Conforming Vans

A June 2006 report by the National Transportation Safety Board released a national status report on implementing pupil transportation safety recommendations as part of its "Most Wanted List" of recommended transportation safety improvements. It found a majority of states have failed to take any action on following up on  SAFETEA-LU, federal law passed in 2005 that prohibits nonconforming vans in school bus transportation and closes a loophole that previously only penalized dealerships from selling the vehicles to school districts.

The NTSB reported that 25 states from Connecticut to Hawaii had taken limited or no action, including the District of Columbia. Another 15 states had implemented limited or partial restrictions on so-called 15-passenger vans, and only 10 states prohibited the vehicles from transporting children to all schools and day care centers.

In February 2004 the National Association of State Directors of Pupil Transportation Services released the results of a survey of State Director members that found 29 states have laws or regulations that prohibit the use of vans for transporting public school students to-and-from school and school-related activities.

Meanwhile, a 1997 National School Transportation Association (NTSA) national survey found that 22 states at the time still allowed the use of 11-15 passenger vans in pupil transportation, albeit regular transportation or certain special activity trips. Only six states prohibited the use of smaller eight to 10 passenger vans for student transportation. Some states have since enacted laws that prohibit the vehicle altogether, though they are not required to do so. Regardless, all public school districts are now prohibited by federal law from purchasing or leasing these non-conforming vans for use in any form student transportation whatsoever.

The Safe, Accountable, Flexible, Efficient Transportation Equity Act: A Legacy for Users (SAFETEA-LU), the reauthorization of the congressional highway bill enacted in August 2005, closed a loophole that previously banned only the manufacture or sale of these non-conforming vehicles "knowingly" for the purpose of pupil transportation to school districts. The new provision bans the illicit purchase of these vehicles by public school districts. Fines range from $10,000 for the first offense up to $15 million. Private and parochial schools, day care facilities and colleges and universities are not affected. Some schools still use the non-conforming vans to transport teachers and staff.

The National Highway Traffic Safety Administration and National Transportation Safety Board have found that the vehicles are prone to rollovers when at or above capacity. Foremost is the fact that passenger vans (generally carrying eight to 15 passengers) are not required to be manufactured to the same federal motor vehicle safety standards as traditional yellow school buses. For example, FMVSS 111, 131, 220, 221 and 222 are not required in the manufacture of vans. As a result, these vehicles do not provide the same degree of occupant protection to passengers that school buses do.

The entire issue of van safety in school transportation came to a head with the 1994 when 6-year-old Jacob Strebler was killed after an 18-wheeler slammed into the 15-passenger van carrying him and classmates to a swim lesson. The vehicle did not meet federal motor vehicle safety standards.

Transport Canada, the nation's equivalent of NHTSA in the United States, published an October 2012 paper that examined two non-conforming van crashes and the results of a "Paired Side-Impact Crash Testing of a 15-Passenger Van and a MFAB (Multifunction Activity Bus)." The vehicles studied were a 2011 Ford E350 15‐passenger van and a 2011 Girardin MFAB with crash-test dummies onboard secured with lap-shoulder seat belts. During the tests, the dummies slipped out of the restraint systems. The severity of the tests wassubstantially greater than the severity of tests that are conducted for regulatory compliance and consumer safety rating side impact protection programs.Transport Canada concluded that inflatable curtain technology can reduce the risk of head injury for "struck-side" occupants. Meanwhile, countermeasures to limit occupant ejection from the shoulder portion of the seat belt and prevent subsequent occupant to occupant contact in all types of passenger vehicles are still under development. But Transport Canada added that a potential candidate measures may include improved designs of restraints and seats and the introduction of in‐board side airbags.

The Great Debate

The issue of whether or not to install seat belts in large school buses has been a matter of public policy debate for more than a quarter century. A handful of states and localities have enacted legislation to require the devices, but more states rejected the idea than accepted it.

Following ground-breaking research by the National Highway Traffic Safety Administration in 2002, and the introduction of three-point lap/shoulder belt systems in 2003, the terms of the debate have changed. To properly understand the likely future outcome of the debate it is helpful to understand the new technology first. Since then, NHTSA published a final rule that requires 3-point lap/shoulder securements in small Type A school buses manufactured as of September 2011 and provides voluntary requirements for all large school buses manufactured as of the same date.

Over the years, the terms "seat belt" and "safety belt" have been used to describe seat belt systems in motor vehicles, and even airplanes. From the 1950s through the mid 1960s, such terms were easily understood, since lap belts were the only type of seat belt system available. Starting in the late 1960s, lap/shoulder belts were installed in new passenger motor vehicles.

2-Point vs. 3-Point Systems

Here is another way to understand the distinction. Lap belts (left) are a 2-point belt system that anchors the user on both the right and left side of their lap. Lap/shoulder belts (right) are a 3-point belt system that anchors the user on both the right and left side of their lap AND at the shoulder, typically nearest the side door. Data demonstrating the effectiveness of seat belts or "safety belts" in passenger motor vehicles is actually derived from the use of 3-point safety belts, as auto manufacturers do not offer 2-point lap belts any longer, except in the center seating locations!

As a result, the continued use of the terms "seat belt" and "safety belt" causes confusion. This is especially true with respect to large school buses.

Meanwhile, all manufacturers of small or so-called Type A school buses always install either 2-point lap belt systems or 3-point lap/shoulder belt systems on their products, the latter required by September 2011. This is required by Federal Motor Vehicle Safety Standard 222.

Up until mid-1991, the only type of "seat belt" or "safety belt" that was available for installation in a large school bus was a lap belt. However, since lap/shoulder belts are now far and away the most prevalent type of "belt" system in passenger motor vehicles, it is likely that many people who read or hear the terms "seat belt" or "safety belt" believe that it referred to lap/shoulder belts, when if fact the term referred to lap belts.

This misinterpretation can easily give the reader both incorrect and inappropriate information, and could lead the reader to make ill-informed decisions that could actually increase the safety risks to children.

How did this conundrum involving such an important safety device come about?

As far back as 1967, researchers at UCLA conducting pioneering research into school bus occupant protection, recommended "passenger protection of lap belts when used with high back seats" in school buses. In the intervening years, this recommendation become a cornerstone of the belief that seat belts should be required in all large school buses. [Remember however, that in the 1960's lap belts were seat belts, and vice versa.]

Now, three decades later, the Great Seat Belt Debate has entered a new phase. In the past couple of years, three companies have begun to offer 3-point lap/shoulder belt systems. C.E. White Co., IMMI/Safeguard and M2K/Takata are independent suppliers to an increasing number of school bus manufacturers. The previous challenge of losing passenger capacity due to seat belts has been solved by the seat manufacturers, which now provide bench seats that can fit three smaller children or two larger children. IC Bus, a major bus manufacturer, developed a 3-point lap shoulder belt system available only on its bus products. Three-point systems are optional equipment as well on all larges Blue Bird buses and Thomas Built Buses.

At this point it is helpful to look at both the case for, and the case against, "seat belts." But bear in mind that the use of the terms "seat belt" and "safety belt" can be confusing. Scholarship does not permit changing the language in the original documents that framed The Great Seat Belt Debate, many more than a decade old, to reflect the evolving use of these terms. Instead, the reader has to judge whether the original author likely was using the term seat belt to denote a 2-point lap belt or 3-point lap/shoulder belt.

Webmaster note: It is interesting that some authors have contacted this Web site and requested their documents be removed altogether, as their solution to the evolving meaning of these important terms.

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School Bus Seat Belts Web Resources

Presented below are links to Web pages devoted to seat belts in motor vehicle transportation and in school buses.

Final Rules:

  • School Bus Passenger Seating and Crash Protection: Seating Systems, Occupant Crash Protection, Seat Belt Assembly Anchorages
    Final rule effective Oct. 21, 2011 that upgrades the school bus passenger crash requirements of FMVSS 222
    • Requires new school buses of 4,536 kilograms (10,000 pounds) or less gross vehicle weight rating (GVWR) (“small school buses”) to have lap/shoulder belts in lieu of the lap belts currently required.
    • Sets performance standards for seat belts voluntarily installed on school buses with a GVWR greater than 4,536 kilograms (10,000 pounds) (“large school buses”).
    • Raises the height of seat backs from 508 mm (20 inches) to 6102 mm (24 inches) on all new school buses and requiring a self-latching mechanism on seatbottom cushions that are designed to flip up or be removable without tools.
    • Each State or local jurisdiction may decide whether to install seat belts on these large school buses.

Web Sites:

  • Alabama School Bus Seat Belt Pilot Program: A three-year study to assess the impact of lap/shoulder restraint systems for passenger safety. The program is a result of a study group formed by Alabama Gov. Bob Riley in November 2007 following a fatal school bus crash in Huntsville. The final report was released in the fall of 2010. Study authors admitted that pilot tests at school districts failed to incorporate data from new flexible-seat technology that allows for either two or three students to be bucked up per seat, depending on the student's age and size (two per seat for large middle school students or high school students; three per seat for elementary school and most middle school students).

  • National Education Association: Seat Belts, School Buses & Safety
  • Safeguard4kids.com: A public awareness website by IMMI describing the benefits of occupant secure ment systems on school buses.

  • School Bus Safety: The Seat Belt Issue
    A review of the issue by the New Brunswick Department of Education, January 2002 [PDF file]

  • IMMI of Westfield, Ind., offers the SafeGuard 3-point lap/shoulder belt securement system. The company's Web site describes IMMI's four year research project, including half a dozen full scale dynamic bus crash tests and more than 70 sled tests, to develop a lap and shoulder belt occupant protection system for school buses.

  • HSM's C.E. White line features the Student Safety Seat System, a 3-point lap/shoulder belt system.

  • Syntec Seating Solutions is another school bus seat manufacturer that offers a 3-point lap/shoulder belt solution for school districts that need to fit either two or three students per seat depending on their age and size.

  • Users interested in learning the arguments in favor of seat belts on large school buses should visit National Coalition for Seat Belts on School Buses. This site offers extensive documentation about the pro seatbelt position.

  • The Network of Employers for Traffic Safety offers guidance about increasing seat belt usage among employees.

Position Papers:




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What does compartmentalization mean? The term is at the heart of the Great Seat Belt Debate. It was coined during the 1967 and 1972 Series 1 and Series 2 "School Bus Passenger Protection" collision tests conducted at the University of California at Los Angeles. Although not an element of compartmentalization, the UCLA researchers concluded that after high back seats, next in importance to school bus passenger collision safety is the "use of a three-point belt, a lap belt or other form of effective restraint."

Other UCLA conclusions included:

  • High back seats of 28 inches or more greatly contribute to the compartmentalization of passengers thereby reducing the chances of injuries sustained by passengers being hurled against one another, regardless of their size. Seatback height for school buses should not be less than 28 inches."

  • Lap belts should not be used with low seat back seats as this would lead to head and chest injuries caused by belted passengers rotating forward and striking the upright backrest ahead.

  • School bus seats should not be provided with rigid protruding structures such as handgrips, handrails or similar injury producing fixtures.

  • Lap belts would provide substantial additional protection if used in combination with high-back seats equipped with additional efficient padding on the rear panel of the backrest ahead.

  • Standees should not be permitted.

  • Seat belts are not recommended for school buses equipped with seats with hard surfaces, a metal bar along the back side of the top of the frame ahead, weak seat frames, or low-back 24 inch seats.

Compartmentalization became the heart of the federal government's policy of school bus safety. The concept of compartmentalization envisions children riding in a cocoon or compartment surrounded by an energy-absorbing, passive occupant protection system. Some industry experts use the metaphor "egg carton" as in cushioning the eggs inside, to describe compartmentalization.

This is why standees on school buses should never be permitted.

However, the National Transportation Safety Board (NTSB) found that compartmentalization is "incomplete" and "does not protect passengers during lateral impacts with vehicles of large mass, in rollovers and from ejection." According to NTSB, an occupant crash protection system should be developed that would protect passengers in most accident scenarios.

In response, NHTSA updated FMVSS 207, 208, 210 and 222 to enhance compartmentalization with mandatory requirements for equipping all small Type A school buses manufactured as of September 2011 with 3-point lap/shoulder seat belts. Partly due to compartmentalization and the higher cost of larger school buses equipped with these 3-point seat belts, NHTSA only published voluntary standards for equipping school buses that weigh more than 10,000 pounds with the occupant securement systems.

In addition to padding, today's seats also must have a steel inner structure that bends forward to help absorb energy when a child is thrown against it, especially those students seated behind who may not be wearing their seat belt. Also, of course, the seat is required to be anchored to the floor strongly enough that it will not pull loose during this bending action, or during collisions. Federal regulation requires each passenger seat to be anchored to the school bus floor and withstand 15,000 lbs. pulling force per seat. The floor itself must be strong enough that it will not be bent or torn by the pulling action of the seat anchors. The NHTSA final rule in 2008 also required quasi-static testing of these seats to ensure that belted as well as unbelted passengers remain protected, or compartmentalized, in the event of a crash.

Seat manufacturers CE White, IMMI/Safeguard and Takata/M2K have also solved the potential of losing passenger capacity on school buses with seat belts by creating seats flexible enough to fit two largers students, such as high schoolers, or three smaller elementary or some middle schoolers per seat.

Seat backs in school buses are also now made higher, wider and thicker than before. After the most recent final rule, seat backs will be required to be at least 24-inches high. All metal surfaces are covered with energy-absorbing padding. This structure must pass rigid test requirements for absorbing energy, such as would be required if a child's body were thrown against the padded back. The equivalent of a seat back, called a barrier, is placed in front of the first seat at the front of the bus.

Finally, seat backs cannot be farther apart than a distance that is deemed safe. Clearly, if the seats are too far apart, the child could be thrown too far before being cushioned and/or could be thrown outside the compartment altogether. Following further research by the federal government, 24 inches spacing was established as the optimal distance between school bus seats.

"In compartmentalization the crash forces are absorbed by the vehicle structure which is designed to protect the occupant," said Charles Hott. NHTSA's school bus specifications engineer. "In an occupant restraint system in general passenger vehicles the crash forces are absorbed by the body of the occupant."

Source: School Bus Passenger Protection; Institute of Transportation and Traffic Engineering, University of California at Los Angeles, by Severy, Derwyn M.; Brink, Harrison M. and Baird, Jack D. (Los Angeles, CA 1967).

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