12/2006-Note from Deborah Stewart, editor of Safe Ride News

Report and Research
Many of us who have been in the field of school bus safety since the
1970s understand that even a lap-only belt is better than nothing.
While the school bus industry has largely been anti-belt, lap belts
have been required in small school buses for many years (by NHTSA).
AND they allow car seat installation! A big bonus for the small
kids. For the vast majority of injuries, belts would have helped.
And "compartmentalization" does not work for roll-overs or lateral
crashes.

Here is a link to a very good report done for a local school district
in NY, to try to get seat belt USE mandated on their buses.
*The link includes most of the research over the years regarding this
topic and the arguments for belt use.

http://www.rheavogel.com/seatbelthome.htm

*Belts are installed in all new buses in NY State for many years, but
use was not required.) While the report was done in 1998, it was
persuasive for the school district to require use on the smaller buses.

1. How Kids Get to School: Risks High in Cars (Sept/ Oct 2002)
      Children traveling to and from school by private vehicle or bicycle or on foot are at much higher risk of death than children riding in school buses. This is the major finding of a study by the Transportation Research Board of the National Academy of Science. The study, released in June, had been commissioned by Congress and was done by a panel of distinguished researchers and school transportation experts.
    The low risk to children in school buses is not news. However, the risks to those in private vehicles going to and from school had not been studied before. Based on data from 1991–1999, it was found that about 800 school-age children are killed in motor vehicle crashes during normal school travel hours (weekday mornings and afternoons during school months) every year. This toll accounts for about 14 percent of the 5,600 child deaths that occur on the nation’s roadways. Of these 800 deaths, about 2 percent are school-bus related while 74 percent occur in private passenger vehicles and 22 percent are the result of pedestrian or bicycle accidents. More than half of all passengers between ages 5 and 18 who die during school travel hours are in a car driven by a teen-ager.
    The study recommends that school districts try to facilitate the use of relatively safe modes of travel while improving the less safe modes. It provides a method for analyzing the shifting of risks that could result from policy changes, such as:
    • reducing school bus costs by eliminating bus access for children living relatively close to        school. How much additional risk would exist if more children rode in family cars, with        teen drivers, walked, or bicycled?
    • providing a larger parking lot at the high school. How much more risk would exist if more       teens were encouraged to drive their own vehicles to school?
    • creating safer walking routes to school or funding more crossing guards. Would this       investment reduce traffic risks while, at the same time, help to increase children’s
      physical activity?

Reference
The Relative Risks of School Travel: A National Perspective and Guidance for Local Community Assessment, Report #269. Transportation Research Board Special Report, PDF copy at www.trb.org (search for School Travel). Print copies, 202/334-3213.
  

2. Bus Safety News (May / June 2003, suppliment)
     The “National Conference and Exhibition on Transporting Students with Disabilities and Preschoolers” is pondering a simpler name for its expanded scope. At the March conference, however, the vision was clear: The pupil transport industry faces a growing demand for customized safety responses for wider ranges of children and challenges. Highlights from the March conference and other recent industry news follow.

Regulatory Developments
     Belts on buses: NHTSA has announced plans to propose a mandate for lap-shoulder belts in small buses and establish performance standards for those buses. Lap-shoulder belts on buses would be a major change with these implications:
•Impact on child restraint use: Currently, neither manufacturer of built-in three-point seat belts includes lockable retractors or latchplates for child restraint installation. The shoulder belts do have height adjusters. Both offer lower LATCH anchors instead. Three-point belts offer opportunities to use belt-positioning boosters if the seats and seat belts do not fit well on small children. Belt/booster/LATCH discussions may emerge.
• Capacity: Bus benches with built-in lap-shoulder belts take up more space in both width and depth.
• Competition: Manufacturers of built-in 3-point restraints differ in their design approaches. Both also offer competing built-in child restraints. Competing with them are three safety vests for use on bus seats without lap belts, plus other emerging technologies.
• Changes in the standard would apply only to future buses, not the current fleet.

Wheelchair requirements in FMVSS 222:
     The school bus seating requirement has been amended recently to add wheelchair placement and lift specifics. (Head Start transporters are looking for clarification regarding slight differences from dimensions that ADA requires for transit vehicles used by many Head Start agencies.)

Extracurricular Use of Buses
     The Federal Motor Carrier Safety Administration and some states are developing a “Moving Kids Safely” project about best practices regarding interstate bus companies. For details: www.fmcsa.dot.gov.

Child Restraints for School Buses
   All three school-bus-safety vest vendors (Besi, E-Z-On, Q’Straint) have said their products meet NHTSA’s 213 interim rule regarding cam wrap use. All also have new labeling regarding the use of the seat behind a CR or cam wrap device.
Besi now offers an “add on” crotch strap retrofit, newly required by FMVSS 213. E-Z-On already has a retrofit strap, and Q’Straint is newer so always had crotch straps built in. Q’Straint also stresses that calling it the “pelvic support strap” is less offensive and more informative to some audiences than “crotch strap.”
     E-Z-On showed two new versions of its vest: The “203” vest has dual red push-button front buckles designed for preschoolers. The “225” vest restraint strap bolts to the reinforced bench as a way to achieve LATCH-like results. It also must be tethered. This model offers an alternative design for buses that do not have LATCH-style anchors in all needed seating positions.
     Q’Straint now has a video showing installation methods for its vests, plus its other products.
IMMI has added the “Chrysler mini-van integrated child restraint” (20 to 40 pounds) to its array of built-in restraints for its bus benches. That complements its “X”-style add-on positioning strap for enhancing three-point belt systems (for children over 40 pounds. only) and competes with C.E. White’s integrated safety harness (for children 20 to 60 pounds).

Child Restraint Training for Preschool Bus Transporters
     NHTSA’s “CPS in Buses” modules of its “School Bus Driver In-Service Safety Series” will be managed by state directors of pupil transportation rather than by state highway safety offices. Highway safety offices handle the other CPS curricula.
     While presenters of the school bus module must be CPSTs, they also will be expected to have technical and networking knowledge of the bus industry beyond what is gained by taking the standardized course or the CPS in School Buses module. States have existing training and CEU processes within their own DOE systems.

Other training tools
     Curriculum and training tools about occupant protection are mushrooming in this field. In addition to NHTSA, several states, and numerous private vendors are distributing and updating training programs and videos about protecting young and older children (with and without disabilities) on school buses. Some deal with select audiences, such as Head Start with its unique rules. Others are more generic, leaving users to customize them for their audience or state. They vary in scope, focus, medium used, date of script, and type of distribution. The following brands* are well-known in the bus industry and continue to add new or updated products:

Coastal Training Technologies Corp.: www.coastal.com, (800) 725-3418
Pupil Transportation Safety Institute: www.ptsi.org, (800) 836-2210
Strategies Training Systems: (800) 600-5636, www.strategiestraining.com
Vidpro: www.vpats.com, (800) 424-3464
White Buffalo: www.whitebuffalopress.com, (210) 614-1395
                                                                                                                   —Sue Miller Smith
* SRN does not endorse any particular product or curriculum.

Resource
“CPS in School Buses” curriculum co-author Cheryl Wolf provides a resource list on CRs on buses. Contact her at: 765-771-6059, ext. 2, or cwolf@lsc.k12.in.us

3. Using Vans for Child Transportation, Part I (Nov/ Dec 2003)
      Most CPS training courses focus on automobiles and SUVs or yellow school buses. As a result, community safety educators may not have all the tools they need for understanding how children are being or should be transported in vans. Safety relates to the type of vehicle used as well as the restraint systems available and driver qualifications.

Large vs. small vans
     A key distinction between small and large vans is based on seating capacity, not the “van” name, to determine regulation applicability. If the van has 10 or fewer seating positions, it belongs to the Multi-purpose Passenger Vehicle (MPV) regulatory class that also includes pickup trucks and truck-based SUVs. If the van has 11 or more seating positions, it belongs to the Bus class that includes larger vans, transit vehicles, commercial carrier buses, and all school bus types.
     Beyond that class division, Federal Motor Vehicle Safety Standards (FMVSS) distinguish applicability based on weight, primary function, and other characteristics of use.

Seat belt rules
     Seat belt installation rules are different for vans and school buses. Vans of either MPV or Bus sizes are governed by FMVSS 208 regarding seat belt installation. That means they typically have center lap belts, and lap-shoulder belts for outboard seating positions.
Only school buses are governed by additional FMVSS covering seating (No. 222), body strength, and traffic control features) but specifically do not have seat belts (see box).

LATCH rules
     For MPV class vans: two sets of LATCH (lower tether and anchors) and one additional tether anchor are required.
    For larger vans: Vehicles over 8,500 pounds are excluded. However, there may be some surprises: for instance, Ford’s 2003/4 15-passenger E-series van has 3 pairs of LATCH anchors that can be used simultaneously, one at the center of each 3-passenger bench seat.
For school buses, two sets of lower LATCH anchors are required for buses up to 10,000 pounds. Tether anchors are not required. (See the box below for general school bus occupant protection standards.)

Vehicle usage requirements
NHTSA has prohibited the sale of vans designed to carry more than 10 passengers (plus driver) for pupil transportation. Larger vans (with 12 or 15 passenger capacity) are called “non-conforming”, since they do not meet school bus requirements for structural integrity, seating, warning lights, and stop-arms. This prohibition on sale does not include the smaller MPV class vans that carry fewer than 10 passengers. In addition, the prohibition applies only to the sale of new vehicles and penalizes only the seller, not the buyer or end-user.
Some schools elect to purchase MPV-sized vans, rather than school buses, for transporting smaller groups of preschoolers, children with disabilities, school trip and after-school program participants, and sports teams. State or local policy also may allow riders’ parents or adult volunteers to drive personal or agency vehicles (not school buses) without any vehicle-specific or occupant protection training.
    Only vehicles used to transport school children or preschoolers to or from schools or school-related events are affected by NHTSA school bus standards, unless an agency other than NHTSA mandates such compliance. Thus institutions that are not schools (such as many child cares, camps, youth groups, church groups, disability service programs) are free to use whatever vehicles they choose. Head Start’s transportation requirement that its agencies use school buses comes from the Department of Health and Human Services, not NHTSA. Head      Starts must phase out all vans for pupil transportation by 2006 (and required to meet child restraint goals by 2004 where compliant vehicles already exist).
Prompted by Head Start needs and looking to inspire other agencies, NHTSA this fall created the new school bus sub-class called Multi-Function School Activity Bus (MFSAB). It meets school bus structural and seating requirements but lacks the traffic control features that many states prohibit for those other than school buses and public safety vehicles. At this time, the rule simply allows such vehicles to be manufactured to safety specifications but does not require their use.
                                                                                                                    —Sue Miller Smith

(Part II will covers other issues related to vans, including roll-over tendency and pending legislation that may require tougher standards for vans. )

Editor’s note:
     CPSTs can help their communities by explaining general crash dynamics principles and resources, by focusing on correct selection and use of child restraints installed using seat belts or LATCH, and by encouraging the safest options given the existing vehicles.
     Although the NHTSA training courses are useful tools for car and limited school bus circumstances, the existing CPS courses may not be directly relevant to some school or other child transport professionals seeking to understand van use. Be careful about pronouncing off-the-shelf courses as “the answer” for community training audiences who need additional resources in their context. Some sections of courses might be on point, but other sections might need to be addressed differently for some audiences.
     Real-world safety lies somewhere between what is “legal,” what technology has accomplished to date, and what is desirable, both as “best practice” and practicality. Where children are concerned, finding the safest course of action is almost always a shared proposition requiring understanding of more than one set of rules and preferences.
     To learn more about applicable rules, check out the FMVSS posted on NHTSA’s web site, www.nhtsa.dot.gov. Other federal and state agencies post their regulations and resources, as well.

Resources:
www.nhtsa.dot.gov/cars/rules/standards/chapt301.html#30125.
www.ntsb.gov/publictn/1999/SIR9902.pdf
www.acf.dhhs.gov/programs/hsb/pdf/1310.pdf

4. Using Vans for Child Transportation, Part 2 (Jan/ Feb 2004)

Large Vans Not Covered by Rollover Rules—Changes Underway
     Rollovers play a major role in fatalities, and large vans stand out as a group of vehicles with serious potential rollover risks. NHTSA and the National Transportation Safety Board both have disseminated high-profile special public alerts and training materials about the higher than average rollover risk posed by 15-passenger vans, especially when carrying a full load of adults or driven by drivers inexperienced in those vehicles’ handling characteristics (1).
As NHTSA states in its Rollover web page, rollovers comprise only 3 percent of passenger vehicle crashes but 33 percent (10,000) of the fatalities in 2002. A startling 72 percent of these fatally injured occupants were not restrained. However, this web page deals only with smaller vehicles, not the larger vans often used by institutions that transport children.
There are few awareness tools or training materials on child transportation issues that deal specifically with large vans. Yet, child care and youth services agencies as well as safety educators need information targeted for the risks associated with such vehicles.

Mixed messages
     • NHTSA’s home page link (on the left-hand index) to “Rollover for Consumer Information” has an FAQ section and a chart showing van safety relative to other classes. Starting in 2001, passenger vehicles in the New Car Assessment Program (NCAP) tests were rated for rollover resistance. The NHTSA rollover rating program currently applies only to vehicles under 10,000 pounds, omitting the heavier 15-passenger vans. Rollover scores can be compared across vehicle types. Small vans as a group show better results than truck-based SUVs.
     • The 10,000-pound vehicle weight is a common limit used in regulations, which is why the larger 15-passenger van models and some heavier “family” vehicles, such as the large Humvee and Ford Excursion SUVs, are exempt from many passenger vehicle safety standards.
     • Many child care and community programs unrelated to schools have complete discretion to use large vans. They even may be required to do so, because funding authorities, including grantors to other groups (such as state DOTs), often offer only vans and have precise vehicle specifications if using their own fun ds. Reasons for this can vary from cost to obsolete bid standards. (As mentioned in SRN, Part 1, (November/December 2003), types of vehicles used by schools and Head Start centers have some federal limitations.)
     • The rollover problem is only one of a number of potential safety issues for large vans. These issues are not well understood by many van-users. Training tools designed to reach them do not focus on van design problems. Excluding known high-risk groups (i.e. children) from federal warnings about vans may lead to a false sense of security and resistance to outreach by safety educators.

Prospects for improvement
     While the messages are mixed, the issue is not being ignored. When NHTSA issued a notice of proposed rulemaking about the rollover information program, petitioners criticized the omission of heavy vehicles. The agency responded: “NHTSA agrees that it is important to investigate the commenters’ concerns about the rollover susceptibility of 15-passenger vans. To do this, we will conduct an evaluation of 15-passenger vans’ rollover susceptibility at different loading conditions and evaluate electronic stability control systems on these vehicles.”
     Meanwhile, in Congress, the Senate voted on February 12 to reauthorize the Transportation Equity Act of the 21st Century (S. 1072) whose funding provisions will, if accepted by the full Congress, include improving 15-passenger van roll-over safety and prohibit more uses for school purposes. The House bill is in sub-committee (2).
                                                                                                                       —Sue Miller Smith
1) NHTSA: www.nhtsa.dot.gov/hot/15PassVans;
NTSB: http://www.ntsb.gov/Surface/highway/alert_15-passenger-vans.htm
2) For details on the van-specific bills, search for S. 1072 and HR 1641 at http://thomas.loc.gov

5. Introducing Booster Use to Child Care: Washington State Experience (Jan/ Feb 03)
      Child care centers can be key organizations to help introduce booster seat use to parents and children. In Washington, the first state to enact a booster-age law (up to age 6 or 60 pounds), a study was undertaken of factors that help or hinder behavior change by child care centers to comply with the law. Centers that transport children on field trips must comply with the law, but school buses are not covered.
    The 28-month gap between enactment and the effective date of the law (July 1, 2002) allowed time for information about boosters to be disseminated and families and centers to prepare. A survey of child care centers (not family child care homes) was conducted 9 months before it became effective. The survey assessed their confidence in their ability to comply.
Over 350 centers responded out of 550 surveyed. The median number of children in the age range of 4 to 6 years was 23. Of the respondents, 70 percent were aware of the law but only 48 percent expected that they would be ready on time. Some (18 percent or 40) were already using boosters, mainly by asking parents to provide boosters for use on field trips. Half of these also required booster seats for pick-up, drop-off, and carpools. In addition, a few had stopped having field trips.
    The more common challenges to compliance cited were:
    • lack of boosters owned by the center (62%)
    • lack of places to store boosters when not in use (38%)
    • confusion over the requirements of the law (31%)
    • expected parental resistance (27%)
    • lack of access to enough vehicles that would accommodate boosters (20%)
    Some child care providers were comfortable asking staff and parents to use boosters. These people were much more likely than others to believe that they could comply on time with the law. Those that did not have resources to purchase boosters were much less likely to believe they could comply. Almost all the center respondents wanted coupons for discounted boosters and informational brochures for staff and parents. When asked from whom they would prefer to learn about child safety, the majority favored the state licensing board, health professionals, and continuing education classes.
    The authors suggest that the financial cost of purchasing boosters for children in centers needs to be addressed in states implementing booster laws. Discount coupons, such as those made available in Washington state, or bulk purchases would be options. In addition, the authors suggested that changes in child care center transportation policies can reinforce car safety messages for children and families. They hope to avert the unfortunate but possible side effect of the law, limitations on field trips.

Reference
“Child Passenger Safety: Potential impact of the Washington State booster seat law on child care centers,” Chang, BA, Ebel, BE, Rivara, FP, Injury Prevention, 2002;8:284–288, December 2002, www.injuryprevention.com.

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