Project Table of Contents

Harness/Vest Basics: General Issues

• Vehicle issues general to all harness/vest types
• Harness issues general to all vehicle audience types

• Vehicle types glossary
• Aircraft issues
• Ambulance issues
• Commercial bus and van issues
• Personal vehicle (including van) Issues 
• School bus issues
  • School bus regulatory explanations
  • School bus glossary

• Aircraft
• Ambulance
• Commercial buses and vans
• Personal vehicles (including vans)
• School buses

 
Project development and research for Safe Ride News Publications by Sue Miller Smith, CPST Instructor, Resource Builders LLC

 Vehicle Issues General to All Harness/Vest Types

• The National Highway Traffic Safety Administration (NHTSA), is the chief federal agency addressing passenger safety designs or equipment for all motor vehicles. NHTSA is one of several agencies within the U.S. Department of Transportation which have complementary duties. To compare or explore DOT agencies in detail, see www.dot.gov/DOTagencies.htm. Each background piece in this project outlines the authorities specific to that vehicle category.
• NHTSA does not required passenger seat belts in vehicles heavier than 10,000 lbs. LATCH, the Lower Anchors and Tethers for Children hardware for securing child safety restraints, is required until 8,500 lbs. plus in school buses under 10,000 lbs. NHTSA also grants a variety of exceptions to rules. Consult vehicle owners manuals and the Safe Ride News LATCH Manual.
• Other agencies may exceed NHTSA requirements voluntarily but typically are tasked with only addressing driver, employee, and fleet management issues rather than occupant safety restraint equipment.
• States address user behavior such as statewide policies for its employees and seat belt and child restraint laws that set mandatory restraint usage requirements. State usage laws vary, especially regarding children’s ages, or weights for specific types of restraints and types of vehicles excluded.
• Vehicle classes: Federal Motor Vehicle Safety Standards (FMVSS) from NHTSA are based first on vehicle class, and then list exceptions within that class. Safety restraint manufacturers also base their designs on the allowances and requirements for specific vehicle classes. To make browsing by audience interest areas easier, this project combines and divides some regulatory class references.
• Compatibility of vehicles with restraints under FMVSS 225 (LATCH -- Lower Anchors and Tethers for Children) and FMVSS 213: The rules governing vehicle and child restraint (CR) equipment employ different types of tests so the upper weight limits set by manufacturers for anchorage of LATCH devices often differ. This leads to a need to check compatibility of high-weight CRs (for children weighing over 40 lbs.) to the stated maximums for the vehicle anchors. 

Some vehicle manufacturers set their maximum at 40 lbs. for a child using a product anchored using LATCH hardware. Others set their ceiling at 48 pounds for lower anchors and/or tethers or 60 or above for tether anchors in a few cases. Some defer to the child restraint instructions. One, Ford (and its related brands: Lincoln and Mercury) have a two-tier tether anchor maximum: 60 lbs. for shell-type child restraints and 80 lbs. for harness products, acknowledging the light-weight nature of the harness products.

The SRN LATCH manual offers charts reporting lower and top anchor weights as reported to SRN by vehicle manufacturers.  These figures are not always included in vehicle owner's manuals.  For easy comparison, the manual also offers a chart of anchor needs for high-weight-harness products (covering both shell and harness/vest types) as available at the time of printing.  Manual revisions are made every two years.  The 2007 edition of the LATCH manual includes School Bus installation instructions variations wherever those CR manufacturers offered clarifications.

This harness-vest project, developed in 2008, complements the LATCH manual by reporting harness-vest  availability and vehicle compatibility in more detail and for more vehicle categories.  The 2009 LATCH Manual will expand its comparative lists, charts, and manufacturer detail reports to aid in understanding and comparing tether- and LATCH-related issues across this wider view of vehicle types. To Order: Click Here

• Clear government crash-test and compliance/recall protocols exist for some vehicle types but not for others. Recalls can only occur where such rules exist. Each background section notes where rules or gaps exist. For recall detail, see NHTSA recalls, SRN LATCH-Tether recalls (link to www.saferidenews.com/pdfs/LATCH Tether recalls.pdf).

• “Seating” typically is understood by vehicle manufacturers to mean the vehicle bench for one or more passengers. Sometimes restraint manufacturers or educators may refer to “seat” to mean the harness “seating” position for an occupant (either the location or the restraint on it). Clarify terminology to be sure both source or listener define the word in the same way.

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 Harness/Vest issues General to all Vehicle Types

• The terms “harness” and “vest” mean different things to different manufacturers. To some, those refer to different shapes of products. To some, “harness” can mean a seat belt or only a webbing-only style of upper body restraint. Language variations are even greater in areas outside the current scope of regulations. This project’s charts call attention to manufacturer-specific meanings. Additionally, some fields – especially special education and disability-related advocacy – might avoid “harness” or “restraint” terms to avoid sounding unduly restrictive. Recognize that language comes out of particular experiences and sensitivities. Carefully confirm terms used in different contexts.
• Developmental restraint orientation recommendation: The American Academy of Pediatrics and the National Highway Traffic Safety Administration (NHTSA)’s Standardized Child Passenger Safety certification curriculum recommend as ideal that children ride rear-facing well into their second year, to the maximum capacity of available (rear-facing) convertible child restraints.  Most harness-vest products are forward-facing only. Some cite low weight thresholds for forward-facing use, which should be evaluated with other factors.
• Current professional certification or general awareness training curricula and other technical references that we are aware of currently do not offer comprehensive overview of the whole harness-vest category range of competitors and vehicle-environment issues that affect assessment. Be careful about assumptions based on limited exposure or incomplete verification of all factors that might apply to a given situation.
• Federal Motor Vehicle Safety Standard (FMVSS) 213 from the National Highway Traffic Safety Administration (NHTSA) governs CRs with shells and add-on or built-in harnesses/vests for motor vehicle passenger use. Currently (2008), FMVSS 213 requirements cover devices for children up to 65 lbs., with standard testing suiting the personal vehicle and school bus environments (with limited overlap concerning personal/commercial vans).  These are dynamic sled tests along with specific criteria for physical characteristics and labels/instructions. (Vehicle LATCH anchor requirements are not dynamic, but static-pull: see Vehicle issues, above.)
• FMVSS 213 defines a “safety harness” as “a combination pelvic and upper torso child restraint system that consists primarily of flexible material … and that does not include a rigid seating structure for the child.” 
• FMVSS 213 exemptions for safety harnesses:
  1. Harnesses are not required to offer attachments for fastening to lower vehicle anchors installed under FMVSS 225 (Lower Anchors and Tethers for Children). Some manufacturers offer variations voluntarily (see product chart comments).
  2. Harness/vest crash-tests are only required to meet a 32-inch (813 mm) limit on forward head movement while installed with a fastening strap (usually called a ‘tether”) to secure the top of the restraint. Other forward-facing child restraints (CRs) must also meet a tighter 28-inch (720 mm) forward limit using a tether strap as well as the 32-inch test without the tether strap.
  3. Some harnesses may perform better than others in the dynamic tests, but consumers have no way to compare such performance. These differences mean that the vest-using public has less mandatory or verifiable safety assurance, especially regarding possible misuse of the tether-type straps relied upon by the majority of add-on harness/vest products, especially in Personal Vehicles operated by civilians rather than by fleet professionals. Misuse might include attaching the tether to an object that is not a tether anchor or leaving the strap too loose. See SRN LATCH manual for extensive background on these issues.
• FMVSS 213 currently regulates products for children weighing up to 65 lbs. Companies offering products for higher weight children cite voluntary proprietary crash testing using the same criteria as in FMVSS 213.
• Recalls can only be issued where government mandates and standards exist. Recalls HAVE occurred for built-in harnesses/vests and for some vehicle anchor hardware pertinent to some harnesses/vests. For details, see NHTSA recalls (http://www-safercar.gov/), SRN LATCH-Tether recalls (link to new web site – URLs in old web site: www.saferidenews.com/pdfs/LATCH Tether recalls.pdf).
• The 2007 National Child Passenger Safety Certification Training Program manual (for CPS Technician educators), issued by NHTSA, teaches about this restraint type: “Vests or harnesses may help children with behavior issues, weak muscles, excess weight or other situations when a conventional restraint cannot be used.” The curriculum, even though updated in early 2008, predated the unveiling or wide use of several products in this project. (The CPS certification manual is the root of NHTSA’s revised CPS training for school buses, due out around mid-2008. See School Bus background for details.).

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Vehicle Types Glossary

Cars, MPVs, Trucks, and Buses, 5/04
Glossary of Vehicle Distinctions for Understanding Federal Safety Standards
(listed in logical sequence)

NOTE:

• The bold-face terms are NHTSA’s broad vehicle classifications or sub-classes cited in Federal Motor Vehicle Safety Standards (FMVSSs). The italicized terms may appear in official references related to other standards such as fuel economy, emissions, import-export issues, or may be imprecise terms used in marketing and popular discussion.
• Several terms in this glossary overlap because they come from various sources that have different purposes. In some cases, regulations predated the development of new vehicle types, such as SUVs and minivans.
• Within the official vehicle classes, safety standards may specify exemptions or special conditions, using distinctions other than vehicle appearance. With all vehicles, it is important to look beyond appearance to find the authority and circumstance that determines which rules apply.  For example, vehicles made for military use are not covered by the FMVSSs; gray areas exist when those military vehicles are sold as surplus to civilians and then used on public highways.

Categories/Terms to Know
Passenger Cars

Car, automobile– Generally interchangeable terms for vehicles with 10 or fewer passenger positions built on an automobile rather than truck chassis. Some small “sport utility vehicles” (SUVs) fit this category.

Trucks

Truck – A vehicle built on a truck chassis and traditionally used primarily for transporting property or special equipment). Some of those functions allow car-like or SUV-like passenger vehicles to qualify under the cargo capacity provisions. Example: the PT Cruiser’s removable seat creates a level cargo area, so it is considered a “truck.”

Light truck – A term for coming originally from fuel economy standards (requiring higher efficiency than for other trucks but less than for passenger cars). Eligibility for this class involves features for off-highway use and/or conditions other than just weight. This class includes many SUV, pickup truck, and van models.

Multi-purpose Passenger Vehicle (MPV) – A vehicle with 10 or fewer passenger positions and built on a truck chassis. Most (but not all) minivans, pickup trucks and SUV’s fit this category.

Sport Utility Vehicle (SUV) – An SUV usually has four-wheel drive capability and a higher chassis than a regular passenger car. Some are built on a car chassis (see Crossover Vehicle, below). This is a popular term used in automotive marketing materials and is understandable to the lay audience.
Crossover Vehicle – Small SUV-style vehicle built on a car chassis.

LTV – NHTSA shorthand for “Light Trucks and Vans,” typically used in research references.

Van – Van appears as a generic description in some regulations, such as “walk-in van-like vehicles” that qualify for some exemptions. This group overlaps other terms. For example, a 15-passenger van is actually a bus (see below), while one with 10 or fewer seating positions is an MPV.

Car /Truck Differences to Note

For occupant protection purposes, today’s light trucks and cars differ little in FMVSS demands, except that the 8,500 pound limit on LATCH and tether anchor requirements means heavier vehicles are exempt.

Prior to 1997-1998, FMVSSs allowed more car/light truck differences. Trucks were granted more time to make the transition to standard rear-seat shoulder belts and frontal passenger air bags.  Trucks had a different phase-in schedule for tether anchors than cars, but the same schedule for LATCH, which came later. Trucks were not required to have rear shoulder belt anchor points that have been standard in cars since 1972, but a few MPVs had such anchor points (and shoulder belt retrofit kits).

The only significant difference now between cars and light trucks is that cars are not permitted (by FMVSS) to have privacy tinted glass behind the B-pillar, while trucks may have such tinting.

Other car-truck confusions: convertibles (whether cars or trucks) are not required to have tether anchors, while vehicles over 8,500 lbs. are not required to have LATCH. Because most convertibles are cars and most heavy vehicles are trucks, many assume, incorrectly, that the regulations divide according to “car” vs. “truck” categories.

Recreational vehicles – These are trucks with specific limited purposes and appear in some safetyrelated FMVSS as a descriptive example but not as a separately regulated class.

Buses

Bus — Car- or truck-based passenger vehicle having more than 10 seating positions, such as a 12- or 15-passenger van or a school buses (truck-based) or stretch limos (car-based).

School bus — A specific subclass of Bus, used significantly to take children to or from pre-primary, primary or secondary school. This type must meet specific school bus FMVSSs for body and rollover structure, occupant protection, and emergency exits. School vehicles are required to meet those Federal standards if taking the children from home to school and school to home.

One major occupant restraint distinction is for the small school bus (including MFSAB type—see below) under 10,000 lbs. Small buses are required to have lap belts for all passengers and — most recently — LATCH anchors in two positions.

Gray areas have existed for other school-related transport uses, such as for school-to-school athletic events, or to venues for special classes; states generally regulate types of vehicles allowed for such services.

Those loopholes now are being addressed, but confusion comes from judging by appearances and past practices rather than from comparison to current requirements, definitions, and phase-in allowances. Many community-transit van-style vehicles might be performing regulated functions without complying with the structural and equipment standards NHTSA now requires for vehicles doing that function. Some functions or vehicles, such as those used for day care (that some families and agencies call “school”), camps, and youth groups, can still be outside the federal or state requirements.

“Multi-function School Activity Bus” (MFSAB) – A new sub-class of school bus, a school bus of any weight or size that lack the traffic control features (flashing lights, sweep arm, possibly even yellow color) typically required of school buses. Such buses are not intended for delivery of children to and from school.

“Allowable alternative vehicle” (AAV) — U.S. Department of Health and Human Services/Head Start term for the MFSAB concept before NHTSA created its new sub-class definition to match. In requiring its own Head Start buses to meet vehicle integrity standards, HHS said Head Starts could use either traditional school buses or similar vehicles that lacks traffic control measures. That “or” was a compromise to satisfy states that allowed only school or emergency vehicles to control traffic on public highways. NHTSA’s definition of AAV-style school buses as a new MFSAB sub-class meant local agencies such as Head Starts (or others) could meet federal bus structural safety
requirements without violating state laws.

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• Products for use only in aircraft (not also in ground vehicles) are regulated by the Federal Aviation Administration (FAA) and will have a label stating “FAA approved in accordance with 14CRF 21.305(d). Approved for aircraft use only.” FAA certification does NOT authorize use on the ground outside airplanes.
• Products intended for use in passenger vehicles on the ground AND in aircraft are regulated by National Highway Traffic Safety Administration’s (NHTSA’s) Federal Motor Vehicle Safety Standard (FMVSS) 213. They will have a label stating “This restraint is certified for use in motor vehicles and aircraft.” 
• NHTSA does not allow FMVSS-governed add-on harness/vests and boosters to be certified for aircraft use. Those are labeled as not allowed for use in aircraft.
• The test within FMVSS 213 for adequate passenger protection in airplanes is an inversion test that simulates a sudden drop during turbulence.

For information about occupant protection research in rescue-aviation, see www.ntsb.gov and www.objectivesafety.netand this project’s Ambulances section.

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Ambulance Issues
This section presumes familiarity with the general regulatory background about points affecting all vehicle types and all vest/harness products, such as how differing arms within the Department of Transportation coordinate internally or relative to markets.

• The National Highway Traffic Safety Administration regulates occupant protection equipment in motor vehicles.  Separately, NHTSA’s Emergency Medical Services division oversees regulation and training regarding ambulance vehicle design and safe practices standards.
• General Services Administration (GSA) Ambulance Standard: KKK-A-1822E (“Star-of-Life”) ambulance design standards do not currently include child restraint-specific standards. Manufacturers define their own goals and standards for related products; manufacturer “due diligence” typically involves adapting existing government tests and thresholds to apply in a way that no standards currently cover.
• No explicit federal rulemaking or legislated mandates currently are actively under way for this vehicle class or the products proposed for them. Public and private research has been going on and is expected to continue.  New child occupant protection devices (see also, research references below) developed for this market fill a need, but manufacturer tests and claims are the only documentation of performance.
• NHTSA’s Office of Chief Counsel’s database of legal findings does include findings specific to inquiries combining ambulance and occupant protection issues.  Archives (copies of letters giving findings) can be searched by key words from http://isearch.nhtsa.gov.
• NHTSA EMS’s general Do’s and Don’ts of Occupant Protection for Ambulances dates from 2000 but is still current state-of-the-art for the 2007 update of the National CPS Certification Training Program. (Link to new PDF I am sending for )
• Research: Outside of the Department of Transportation, most ongoing federal government research into ambulance occupant protection issues is done by the Centers for Disease Control’s National Institute for Occupational Safety and Health.  For instance, the Federal Fire Administration within the Federal Emergency Management Administration joined in 2004 in support of NIOSH’s recent study called “Evaluation of Emergency Services Vehicle Occupant Safety Project that included occupant restraint issues.  NIOSH also lists as still (in 2008) under way another project called “Ambulance Crash Survivability Improvement” that includes examination of mobile safety restraints for EMS workers en route, plus ambulance design issues.  The NIOSH web site and study results releases can be searched by occupation type, use of injury means (such as Motor Vehicles) or other factors.  In January 2008, the Transportation Research Board of the National Academies (see, especially, News) launched an EMS Transportation Safety Subcommittee (seewww.objectivesafety.net for presentations and materials).  Other research about crash testing for ambulances or passengers also can be found at www.objectivesafety.net, http://www.preventinjury.org/research.asp and SRN’s own earlier but still relevant ambulance report. (move to AP-8b and link http://www.saferidenews.com/html/Spec_Amb.html)
• To explore field practices with practitioner groups:  Ambulance affinity group of fleet manufacturers, owners or managers are organized under the National Truck Equipment Association (link to  http://www.ntea.com/mr/divisions/amd/default.asp.  Moderated occupant protection list serves include these at groups.yahoo.com: CPS4EMS (specifically for EMS providers), CPSforHealthCare, and the general issues CPSPList. [SMS1]

For references to aviation rescue resources, see the Background on aircraft restraints.

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Commercial  Bus and Van  Issues (transit, community agencies, etc.)
This section presumes familiarity with the General Background section about points affecting all vehicle types and all vest/harness products.

• This group (commercial vans and buses) reflects a variety of uses rather than one specific vehicle category or type of rider. See Personal Vehicles for issues relating to private use of vans covered in both categories. (See Vehicle glossary for regulatory definitions). 
• All products reported by this web resource (as of June 2008) are built-in, rather than add-on in nature. Sometimes a vehicle can be retrofitted by replacement of seating with a product that includes built-in child harnesses.  It is important, however, to understand that “compatibility” is a subjective calculation involving multiple factors, typically requiring direct discussion with the vehicle manufacturer regarding factors below. 
• Defining occupant protection issues for this group commonly involves overlapping authorities that may have differing assumptions of what is allowable or acceptable or may involve aspects that are not clear. 
• Regulation of this group is divided among several branches of the U.S. Department of Transportation. For access to all, see www.dot.gov/DOTagencies.htm.  Generalizations and specific web sites to know include:
  • National Highway Traffic Safety Administration (NHTSA),  is the chief federal agency addressing passenger safety designs or equipment for all motor vehicles.  NHTSA does not currently require passenger seat belts or LATCH/tether anchors for any vehicle – all types --heavier than 10,000 lbs.  In commercial group transport, then, “other voices” than NHTSA decide whether or not to exceed these rules voluntarily and are tasked with driver and fleet management rather than passenger safety restraint jobs.
  • Alongside NHTSA’s scope in DOT, small and large mass-transit vans and buses are regulated by Federal Transit Administration, (FTA).
  • Commercial carrier buses for hire and those that cross state lines are regulated by Federal Motor Carrier Safety Administration (FMCSA). 
• For passengers with disabilities, the Americans with Disabilities Act may influence passenger access to and choice of equipment.  This often includes non-use as a choice.
• Among “buses” as a group, “school buses” are an exceptional subgroup distinct from the rest of the class.  This explanation about “working vehicle” comparison about what is “normal” is easily misunderstood.  NHTSA’s meaning of “Bus” is very broad: 10 or more passengers, including what most people call “vans” or “shuttles.”  “School buses” are Buses with EXTRA design and population rules to meet, beyond that for the class as a whole. (See Vehicle glossary, School Bus background and glossary and SRN LATCH Manual for assessment guidance on what applies when). 
• Manufacturers of built-in harnesses for commercial vehicles typically are competing also in the school bus industry, but the regulatory or design or “normal audience” factors differ.  In the current (2008) regulatory climate, manufacturers offering built-in harnesses are pioneering the development of safety equipment beyond or In addition to what regulations of various kinds require.
• Motor coach safety legislation: In November 2007, Senator Sherrod Brown, D-OH, and Senator Kay Bailey Hutchinson, R-Texas, introduced the “Motor Coach Enhanced Safety Act of 2007 (S 2326)” to require regulation to reduce the potential for ejection, reduce flammability, and prevent roof-crushing and increase owner/driver training and auditing to reduce passenger risk for vehicles regulated by FMCSA.  See www.motorcoachsafetynow.com for details.
• The bill follows National Transportation Safety Board advisories and coincided with NHTSA’s first crash-testing of a full-sized motor coach, for coordinated research purposes, in December 2007.  Current vehicle definitions in the bill are not applicable to city transit vehicles or to in-state commercial buses such as airport shuttles or local agency vehicles.
• NHTSA motorcoach crash-test reports, see links below.  Cautions:
  1. These are long downloads (i.e. pictures, a 1308-page report.) of engineering reports for research purposes.
  2. Disclaimer on this work done by NHTSA’s Vehicle Research and Test Center (early 2008 report from December test): Transportation Research Center Inc. does not endorse or certify products of manufacturers.  The manufacturer’s name appears solely to identify the test article. Transportation Research Center Inc. assumes no liability for the report or use thereof. It is responsible for the facts and the accuracy of the data presented herein. This report does not constitute a standard, specification, or regulation.
          Links to NHTSA crash test  Reports:   Photos:
• Harness options for children in commercial vans: It can be easier to retrofit seating with built-in harnesses in older vehicles than new ones.  Considerations depend on year of manufacturer and weight of vehicle.  Vehicles under 10,000 pounds made after Sept. 1, 2007 must have center-position lap-shoulder belts, which may preclude built-in harnesses.  Discuss harness options with seating supplier.
• Fifteen-passenger vans:  Safety warnings related to equipment, maintenance, and usage. See NHTSA advisory about 15-passenger vans (www.nhtsa.dot.gov/cars/problems/studies/15PassVans/15PassCustomerAdvisory.htm)  and background about “non-conforming vans” from School Transportation News.
• LATCH: Some manufacturers voluntarily are offering “Lower Anchors and Tethers for Children” (LATCH) anchor variations despite the fact that those anchors are not required for this group under FMVSS 225. (The LATCH rule exempts vehicles over 8,500 lbs.)  Voluntarily devised efforts may use/interpret terms such as “anchor” or “hook” differently than are the norm for vehicles required to have LATCH.
• Other terminology: Manufacturers in this category and for school buses use “seat’ or “seating” to mean the vehicle “benches” into which built-in harnesses are fabricated or onto which add-on shell-style restraints are attached.  This can be confusing to people such as Certified Child Passenger Safety Technicians or other professionals for whom “seating” means the child’s single position or a safety restraint that is on the “bench.” The product grids have differentiated these issues into adjacent columns to clarify this.
• For occupation-oriented research or peer networking about vehicle occupant safety, see also the Center’s for Disease Control’s National Institute for Occupational Safety and Health (NIOSH), the Transportation Research Board of the National Academies of Science, and the National Truck Equipment Association.    

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Personal Vehicle (including Van) Issues — Passenger Safety Background and Issues

• This section presumes familiarity with the general vehicle and restraint comments offered in Background for general issues about harnesses/vests.
  • This grouping includes family/private users of automobiles, mini-vans and larger vans, pickup trucks, and sport utility passenger vehicles. See vehicle definitions for regulatory types within this grouping.
  • Securing groups of children or adults: A wide range of larger vehicles, called Buses, covered in separate sections. School Bus Background explains issues unique to school-specific uses of “Bus” vehicles.  Commercial Vehicles Background explains issues about larger non-school vans and buses, plus personal use of small or large public vehicles. (In pursuit of enhanced safety, organizations transporting non-school passenger groups (child care or day camps, for example) may voluntarily use vehicles meeting school bus standards rather than non-school vehicles. This project's focus reflects general audience types.)
• This group (overlapping with some smaller commercial vans) is the only one for which the National Highway Traffic Safety Administration (NHTSA) requires dedicated anchors for securing tether straps.  (See General Background caution about crash-test exemptions for harnesses/vests, which generally utilize tether straps to secure the shoulder straps.)
• Federal Motor Vehicle Safety Standard (FMVSS) 225 (Lower Anchors and Tethers for Children, known as “LATCH”) allows substitution of built-in child restraints for required LATCH anchor positions for child safety restraint installation in vehicles.   FMVSS 208, which now requires lap-shoulder belts in center seating positions, does not allow built-in vests to substitute for that requirement.  See Commercial Vehicles background for issues relating to the larger vans in this class.
• Some compatibility issues exist for add-on harnesses and family vehicles. See this project’s product charts and SRN LATCH manual for manufacturer-by-manufacturer compatibility information, plus troubleshooting detail about harnesses/vests that rely on tether straps.  Common themes:
  • Conflicting weight capacities for vehicle anchors and vests. Most harness manufacturers allow use for riders weighing 60 or more pounds.  Some vehicle manufacturers allow built-in tether anchor use only to 40 or 48 lbs.  Ford brands (including Ford, Lincoln, and Mercury) allow tether use to 80 lbs. for a harness (60 for a shell-type CR due to light weight of the harness itself) and others give no weight maximums, referring to CR instructions only.  FMVSS 225 and 213 use different types of regulatory tests for vehicles and restraints, making comparisons challenging.
  • Problems with installation of “heavy-duty” tether anchors for heavier children, Guidance from the vehicle and restraint manufacturers may differ.  Dealerships generally will not install aftermarket tether anchors.
  • Seating location challenges in matching riders with needed anchors or space to install them.  The factory-installed tether anchor positions in newer vehicles might not be suitable for the vest-user.
• No vests with “cam wrap” attachments (ones with a strap that wraps around the back of the seat, common for school bus installation) are designed for use in Personal Vehicles.
• See brief online video tutorials about some travel vests and integrated harnesses at www.videojug.com/tag/child-car-safety  (explanations by SafetyBeltSafe U.S.A.).
• See NHTSA advisory about 15-passenger vans for either personal or institutional use.  (www.nhtsa.dot.gov/cars/problems/studies/15PassVans/15PassCustomerAdvisory.htm). 

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School Bus Issues Concerning Harness/Vest Use
This section presumes familiarity with this project’s general vehicle and restraint notes

• School Buses are a subtype of the Bus regulatory class. See Commercial background and Vehicle Glossary to examine how this subgroup relates to the overall Bus class. Some manufacturers in this project build products for more than one type of vehicle.
• Training -- The National Child Passenger Safety Technical certification course includes brief background about school bus issues.  There also is a parallel non-certification (awareness) course specific to school buses (an updated version expected in summer of 2008).  Instructors of the bus course must be both certified CPS Technicians and conversant in school bus industry issues.  The latest bus course revision will match the core certification course format but also include a new chapter devoted to add-on, built-in and integrated safety restraint products.  Both courses are overseen by the National Highway Traffic Safety Administration. 
• This resource includes additional issues/resources/updates and is designed to be used in addition to existing curricula to increase awareness of fine points of vehicle-specific issues of occupant restraint selection and usage.

Consult www.eduprogroup.com for the “Transporting Pupils with Disabilities, and Preschoolers” annual conference and skills “roadeo.”  See www.schoolbusconference.com for the School Transportation News Expo conference that includes Education and Head Start and special education audiences.  Occupant protection-related list-serves exist at groups.yahoo.com.  The CPSP List has the widest, most general use group.

• NHTSA encourages school transporters to use small school buses (under 10,000 pounds) for preschool children who are to be transported in child restraints, because these buses are required to have lap belts installed.
• Mixing restrained and unrestrained passengers: Some bus body/seating manufacturers claim their newest seating designs for built-in lap/shoulder belts or built-in harnesses can overcome incompatibilities between compartmentalization and occupant restraints (See Compartmentalization, Glossary). This is not currently (July, 2008) covered by any government standard, but the extensive school buses rulemaking change proposed by NHTSA in November, 2007, would establish a standard method of testing this feature. Consult manufacturing and regulatory resources to explore related claims or plans.
• Head Start, a federal program within the Department of Health and Human Services, is currently one of the few agencies that requires its providers to use vehicles that satisfy NHTSA’s school bus safety standards and to use occupant protection devices that meet FMVSS 213.
• Large vans cannot legally be purchased by public school districts and some states ban their use for school purposes.  See non-conforming vans: http://www.stnonline.com/stn/nonconformingvans/index.htm (see Commercial vehicle background: Who makes the rules?)
• LATCH and Tether/floor-mount anchors:  Because harnesses as a restraint class are exempted by NHTSA from LATCH requirements, only a few offer lower LATCH attachments. See manufacturer details in this project and the SRN LATCH Manual.  Harness manufacturers have developed their own ways to provide the equivalent of a tether, such as a cam wrap, for school bus seats.  These go beyond federal requirements so are tested to manufacturer standards. When two different manufacturers are involved, such as a harness maker and a bus body maker, both sources must be consulted to determine compatibility and limitations.
• Direction of current invention with eye on future standards change: In November 2007, under pressure from Congress, NHTSA proposed requiring higher seat backs for all school buses and mandating lap-shoulder belts for new small school buses.  It includes a standard against which to measure performance of seating with built-in lap-shoulder belts.  NHTSA has not changed its position that states should have discretion about requirements to install/use seat belts in large buses. (See Commercial vehicle background: Who makes the rules? and Reform and research)

If/when finalized, the rules will allow one year or more lead time for most of the requirements to take effect.  Many bus fleets, which turn over very slowly, will continue to  have a mixture of restraint and seat types on buses for years to come.  So add-on and built-in harnesses remain a critical and evolving group to understand.

• Seat back height differences -- Vest makers offer cam wrap straps for “high” or “low” seat backs, because some states, ahead of the federal government, already have mandated high back seats.  (Pre-1997 school bus seat backs were even lower than the current minimum seat height under FMVSS 222).

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School Bus Regulatory Explanations
FMVSS: Federal Motor Vehicle Safety Standards -- National Highway Traffic Safety Administration (NHTSA) crash test rules as of April, 2008:

• FMVSS 210, seating installation/reinforcement standard: applies to school bus seating/benches if they are made to have seat belts installed.
• FMVSS 213, child restraints: the standard that applies to safety restraints, including harnesses/vests, for children up to 65 pounds in any type of vehicle.
• FMVSS 222, school bus seating standard: requires compartmentalization for all buses. Requires lap belts on small school buses (under 10,000 pounds gross vehicle weight).  School buses over 10,000 lbs. are not required to have seat belts.
• FMVSS 225, child restraint anchorage (“LATCH” system) in vehicles: includes a requirement for two positions in school buses to have lower LATCH (Lower Anchors and Tethers for Children) anchors, but not tether anchors, despite the “T” in LATCH.).

School Bus Glossary
School bus vehicle terms (alphabetical order):

• Compartmentalization:  FMVSS 222 requires all school buses/MFSABs (see MFSAB, below) to offer this passive protection system of closely spaced seats with high, padded, flexible backs. In a frontal crash, the seat back absorbs energy of passengers propelled forward against it from behind.
  • FMVSS 213 as of 2003 required harnesses to have labels stating that the harness could only be used if the entire seat behind was empty or had only restrained occupants.  This was intended to prevent an unrestrained rider being thrown forward into the back of a seat occupied by a rider secured in a harness or a child restraint, as the restraint might interfere with compartmentalization. (Both the riders need to be restrained or the seat behind the restrained rider needs to be empty.) (See “Mixing restrained and unrestrained passengers” above and specific products listed for more discussion about how some products claim to have overcome this problem.
  • One of the debates in has been whether lap-belts in this environment are advantageous to prevent ejection out of the compartment or vehicle or instead interfere with spreading out energy as compartmentalization intends.  Emergence of lap-shoulder belts and built-in harnesses for school buses has changed the debate about seat belts into a need for regulation of three-point seat belt technologies.
• LATCH (Lower Anchors and Tethers for Children): The informal but commonly used term for the anchorage system for children’s restraint systems that was implemented fully in 2003 model year vehicles.  It requires most passenger vehicles to have a LATCH system (two lower bars and one upper tether bracket) in at least two seating positions.  In school buses, two seating positions are required to have the lower bars (“lower LATCH anchors”) but not the tether bracket.  NHTSA does not require these positions to offer tether anchors and does not define a clear standard specific to add-on tether anchors in school buses.
• Multi-Function School Activity Bus (MFSAB): A regulatory subset of School Bus category. MFSABs meet some school bus standards, such as FMVSS 222 and bus body construction requirements, but not the traffic-control features (e.g. external stop-arms, yellow color, and lights).  NHTSA allowed this distinction so non-school agencies (for children and adults) might use vehicles with the safety construction of school buses (instead of Commercial type designs) while not usurping traffic control authority that states might wish to keep more limited.
• “Reinforced” or “unreinforced” seating:  Unreinforced seating (most common on existing school buses) meets FMVSS 222 but is not equipped for seat belt installation under FMVSS 210.  Reinforced seating is strong enough for the addition of a seat belt and often is called “seatbelt-ready” seating, whether seat belts have been attached or not.
• School bus: Subset of the “Bus” category that is required by NHTSA to meet FMVSS 222 (among other school bus-specific standards) for buses that transport children to or from school.  (See Vehicle glossary for definitions of non-school buses.)
• Seating: School bus bench seats are referred to as “seating” by manufacturers of school bus and commercial bus vehicles.  This can be confusing when conversations are with occupant protection safety advocates who may understand “seating” to mean a particular occupant’s seating location or add-in equipment for it.  School bus seating also comes in various widths.
• Small buses: School buses – not non-FMVSS-222 vans – weighing under 10,000 pounds.  FMVSS 222 requires lap belts for small buses as smaller vehicles experience more violence in crashes and are more likely to roll over than large buses.

School bus occupant protection terms (alphabetical order): 

• Cam wrap: An anchorage strap supplied by the harness/vest manufacturer for use in a school bus instead of a tether strap.  A cam wrap encircles the whole bus seat back vertically, routed through the opening between the back and lower pad, instead of going over the top of the seat to an anchor, as a tether strap would do.  Manufacturers vary in how they attach the cam wrap to their harnesses, but typically it attaches to the shoulder straps and waist or hip straps.
• Child safety restraint system (CSRS): term for child restraint preferred by many  in pupil transportation field, to avoid any suggestion of "restraint" of behavior.
• Crotch strap:  FMVSS 213 as of 2003 required harnesses to have a feature that prevents riders from “submarining” or sliding under and out of the harness.  Most, but not all, achieve this with a harness style that includes a strap between the rider’s legs and fastened to the harness’s torso support system.  Some are using the vehicle lap belt as part of the “combined pelvic” “system” in the 213 standard.
• “Seat belt:” Can refer to a 2-point/lap-only belt or a 3-point lap-shoulder belt.  Many variations, not standardized beyond meeting FMVSS regulations, may be integrated into the seating or separate for wheelchair use.  When using this term, define features very specifically and recognize differences existing.

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 [SMS1] The reason for including the other CPS-related list serves is  this category is highly likely to draw other than CPSTs only and THEY need to know how to get further discussions.  The health care list would combine more than just basic CPS programs but more about protocols and policies.  The main CPS list would help know how to tap into the OP-related network in their community, state, etc.

©2008 Safe Ride News Publications, For SRN by Sue Miller Smith, Resource Builders, LLC