One far-too-underused benefit of membership in a multi-disciplinary professional community is the chance to observe the issues and challenges faced by colleagues in fellow sectors. On June 11, 2007, NHTSA held another landmark hearing on the subject of seat belts on school buses – revisiting issues last explored in 1999 at a similar hearing hosted by the NTSB. Unlike that last hearing, this one provided a rare departure from the normally rigid isolation among the various transportation communities, and the mostly pupil transportation community audience was well-stocked with representatives from the motorcoach field – including a few individuals who, like myself, are heavily involved in both sectors.
This mixed representation was neither a surprise nor a coincidence. Two months ago, another Congressional bill mandating the installation of three-point occupant restraints on all motorcoaches began working its way through the corridors of Capital Hill – following the death of five schoolchildren killed in a recent catastrophic motorcoach accident, and the reaction of that state’s Congressional representatives to this tragedy. Similarly, requirements for the installation of three-point seatbelts on motorcoaches providing school-based activity trips were promulgated in California, and more recently, in Texas. Because of the timeliness, if not urgency, of these events, the NHTSA hearings provided a preview of what the motorcoach industry may soon face at the regulatory level – regulatory changes with serious implications for bus and coach design and operations.
That these implications arrived on the heels of exploding costs for fuel, pollution control devices, safety and liability ramifications of now-hotter-running engines, cut-throat competition from discount carriers, and profit-sharing with brokers and other middlemen made paying attention to them even more compelling. With many of these other costs and issues lying beyond the industry’s control, we cannot afford to passively observe yet another set of unfunded mandates swallowing up our riders and pricing service beyond their means.
Listening and Good Faith
Most of the hearing’s speakers were selected to represent the views of both the anti-seatbelt pupil transportation community, and a collection of pro-seatbelt parents, advocacy groups and child psychologists – including some heartbreaking pleas for change from the parents of children whose deaths would likely have been prevented had their school buses been equipped with three-point seatbelts. Having followed this issue’s ebb and swell for more than a decade in the school bus arena, I was both prepared for, and familiar with, the arguments on both sides. Surprisingly, the rancor between these communities during the 1999 hearing seems to have softened a tad – perhaps as the result of a four-year NHTSA study completed in 2004 that fell considerably short of endorsing three-point occupant restraints, yet acknowledged their value compared to lap belts. But that study also concluded that the NHTSA-developed concept of compartmentalization was “incomplete.”
What may fairly be called the “parents’ view” is not hard to summarize: If seatbelts provide such substantial benefits to automobile passengers, and several generations of school-age children have grown accustomed to deploying them, it stands to reason that these same benefits would accrue to school bus passengers following this technology’s installation on their school buses. In contrast, the school bus community’s rebuttal focused largely on the impacts of the increased costs associated with the installation of this technology – and its translation into fewer vehicles and fewer passengers, and more serious injuries and deaths. Alluding to a study by the National Academy of Science’s Committee on School Travel Safety (of which I was a member), the study emphasized the exponential differences in travel safety between student bus riders and students traveling to and from school by other modes, including walking bicycling and passenger cars – particularly trips provided by teenage drivers. The focus of this argument is that the few lives that might be saved by installing seatbelts on school buses would be offset by a considerably higher volume of deaths and serious injuries suffered by schoolchildren forced to travel on other modes as the increased costs of school buses would translate directly into a shrinkage of the nation’s school bus fleet, and doom millions of otherwise school bus passengers to travel to and from school by means bearing dramatically greater risks.
Some of this reduction in seating capacity would flow simply from increased vehicle costs, and the reduction in buses manufactured and sold as a consequence. But much of it also reflects the reduction in seating capacity per bus stemming from the widening of seats to accommodate a typical run’s largest riders – high school students in the commonly multi-tiered provision of service (elementary, middle and high school) that has become the norm throughout the country. Unlike the flat seat benches that do no define the number of passengers (within reason) that they can accommodate, the installation of three-point seatbelts would require a commitment of seat spacing to accommodate the largest riders, and which could not be adjusted to accommodate more smaller ones, like current school bus seats can. In California, the requirement for three-point belts on school buses led to a 17 percent reduction in seating capacity, as the seat positions were widened from 13 to 15 inches, and the otherwise pair of 39-inch seats on both sides of the aisle were replaced by a 45-inch and 30-inch counterpart – known as a “3 plus 2” configuration.
Technology and Populism
Such rebuttals are, understandably, hard to take for parents robbed of their loved ones after accidents where the installation of three-point occupant restraints would likely have kept them from being ejected – the principal scenario by which bus passengers (on all type of buses) are generally killed or seriously injured. In truth, these arguments would be persuasive if school bus seating systems did not already contain a proven safety technology that worked for students merely seated, and if decreased seating capacity did not translate into more students traveling on other, more dangerous modes. But more importantly, lurking at the center of this debate was the largely misunderstood concept of compartmentalization.
With compartmentalization, seat design and spacing are optimized to reduce the acceleration of the passengers’ most vulnerable body parts (primarily the head and neck) into the closely-spaced seatbacks in front, and (particularly in collision orientations other than head-on frontal crashes) by minimizing their rebounding within the passenger compartment. As NHTSA acknowledged in the study completed in 2004, however, school bus seat compartmentalization is “incomplete,” and provides little impact protection in side- or oblique-impact collisions, particularly for passengers seated on the aisle side of the seat bench.
The Motorcoach Gallery
Representatives of the motorcoach community standing on the sidelines of this debate were treated to a rare but sobering preview of a similar debate looming over our own horizon – particularly as the motorcoach community’s seating systems make us both more and less vulnerable to the forces unleashed during this current hearing. On the plus side, while motorcoach seats are not truly compartmentalized, many of their features – large, heavily-cushioned, forward-facing, high-back, contoured seats with headrests and armrests — provide a far superior starting point for the development of a genuinely compartmentalized motorcoach seat. Often forgotten (or unknown) was the effort of one seat manufacturer (Freedman Seating) – more than 15 years ago – to design a fully-compartmentalized motorcoach seat. While perhaps not quite as fancy as many other motorcoach seats, this technology’s existence provides a foil to the line-in-the-sand over-simplicity of what many in the school bus community characterized as “The Great Seat Belt Debate” – a debate still flailing around from state to state, with resolutions often backfiring as the majority of states mandating seat belts (New York, New Jersey and, more recently, Florida) require only lap belts, a technology whose dangers for full-size school buses have been demonstrated in study after study since the mid 1960s.
In contrast to the patchwork quilt of logic that a handful of states have woven with their mandates (with California and Texas requiring three-point belts, and the three mentioned above mandating only lapbelts), motorcoaches are largely an interstate phenomenon. As a consequence, mandates to install seatbelts in even a handful of key states would pretty much translate into their installation throughout the country. Following California’s lead, Texas recently adapted a mandate to install seatbelts on motorcoaches used to transport schoolchildren. The fact that two of our largest states may soon require them on this subset of motorcoaches, and as service to schoolchildren represents 30 percent of all motorcoach trips, the installation of seatbelts (in one form or another) on virtually all motorcoaches may come about even without a Federal mandate. Witnessing the capricious state-by-state evolution of seatbelt mandates for school buses, the notion of similar state-by-state requirements for motorcoach seatbelts is far more frightening than the technology’s requirement by Federal agencies.
Having your Cake and Eating it Too
The advocates of “compartmentalization” commonly emphasize its most important characteristic: The passenger need do nothing but remain in his or her seat for the technology to provide the protection for which it was designed. In contrast, were one to rely on seatbelts for this protection, a passenger not belted in would receive virtually no protection. This reality has been illustrated by discouraging studies that repeatedly demonstrate that usage diminishes dramatically with age: Some figures bandied about during this hearing cited 70% of elementary students using their school buses’ seatbelts while as few as 15 or 20% of high school students did so. What do such figures imply about their usage by a motorcoach full of adults?
As the hearing demonstrated, there are plenty of ways to spin the comparison between seatbelts and compartmentalization. But logic suggests that the most effective approach is to treat compartmentalization as the cake, and integrate seatbelts into its structure – mandatory or optional – as the frosting. For doing this, the motorcoach industry is both ahead and behind. We are ahead because our current seating configurations lend themselves, at least in theory, to a vastly superior form of compartmentalization than school buses contain – although there are some tough design challenges (e.g., reclining seats that compromise the compartmentalization) that must be resolved in order for the technology to achieve its goals. We are also ahead in the seatbelt arena because the motorcoaches of our European and Australian counterparts (many of whom sell motorcoaches in both the U.S. and European markets) already contain them – and have had them, as a regulatory matter, for a considerable period of time during which their characteristics have been refined, and their levels of usage measured. And while seatbelts in motorcoaches will undoubtedly increase vehicle costs – mostly in the changes to seatbelt anchorages to accommodate the greatly-increased loads that a seat attached to a passenger must bear compared to a seat from which the passenger can fly forward upon impact – these increased costs will not be compounded by a loss in seating capacity – a principal disbenefit of their installation in school buses. At the same time, our failure to seriously explore, develop, refine and install compartmentalized seats on motorcoaches has placed us far behind international trends, and one may argue that their absence has led, at least in part, to the public clamor for seatbelts. With neither compartmentalization nor seat belts, motorcoach operators and manufacturers have been toasted in lawsuits following catastrophic accidents – often when seat anchorages have been torn asunder from their moorings even without the greatly-increased loads that seat-belted passengers would have placed on them. The correlation between seat loadings and anchorage strenght requirements represents a major component of the system’s increased costs, while reclining seats present a design challenge whose solver will reap substantial profits – if the solution does not eventually overtake practically the entire passenger seat market.
Talent and Preparation
NHTSA’s one-day hearing obviously could not cover all the issues and tradeoffs involved in a topic with such dramatic cost- and safety-related consequences, much less with the range of choices available within the debate. But the NHTSA hearing provided a clear preview of the likely shape of this debate, and the types of individuals and advocates likely to align themselves with various positions, in the motorcoach arena, if and when it occurs. This dichotomy does not even consider the issue of liability exposure that has proven costly to motorcoach manufacturers deluded by the belief that their cushy, forward-facing seats are actually compartmentalized.
In Hollywood, where the supply of job applicants exceeds demand by perhaps the greatest margin on the planet, a common concern of most would-be entertainers is the rarity of opportunity. Demonstrating his uncommon wisdom, the late Johnny Carson inspired and helped prepare generations of actors, comedians, musicians, songwriters, dancers and other artists for those opportunities by sharpening their focus. As Carson often stated, “The question is not whether or not you will get a break. The question is, if you do, are you ready?”
I myself do not feel that the motorcoach industry is well prepared for a debate mirroring the one just experienced by out school bus community cousins. But we are also not far behind. If we focus on improving the cake, particularly while keeping the frosting in mind – at least as an option – the resolution of the debate will be orders of magnitude less costly and less disruptive than were we to take the extremist position of providing neither. This is largely because, with fully-developed compartmentalized seating, there would be both less urgency and less need for seatbelts.
For this to happen, we cannot sit on our hands and hope to keep the seatbelt advocates at bay, much less indefinitely. Particularly with a bill that might fund much of this development being laid at our very doorsteps, we would be fools to simply enjoy the simplicity and comfort of our hand-warmers. As vulnerable as our community is to the whims of a single state’s legislature – keep in mind Florida’s response to the NHTSA study – it will cost us far less to act as leaders than to continue dawdling as laggards. With the type of compartmentalized motorcoach seating we are capable of developing, it will be far easier to fend off the seat belt advocates. But even if we cannot, a cleverly-developed compartmentalized motorcoach seat will minimize the costs of adding seatbelts to the mix.
To our followers, the recent NHTSA hearing provided some interesting entertainment. To our leaders, it presented a scary premonition. If we think we can keep the forces of change at bay simply through rhetoric and lobbying, we are even bigger fools than our past resistance suggests. With an hours-of-service framework considered antiquated by both the Canadian bus industry and our own trucking industry (not to mention experts in fatigue within and outside these communities), we will continue to remain one fatigue-related catastrophic accident away from the sudden imposition of technology and change that much of our industry may be unable to sustain, or which will magnify our existing hardships.
Since it did not focus on our community, the recent NHTSA hearing was a blessing of enormous value. But if we squander its insights, the preview we obtained from this hearing may quickly turn into a curse.