Highway safety affects us all.

Roadtraffic injury prevention is a highly politicized issue. Most people have their opinions on what could make the roads safer. Ancedotal information and its reporting by the media all too often allow issues to be understood as major traffic safety problems requiring priority action, which in turn puts pressure on policymakers to respond. Policy decisions for effective road injury prevention need to be based on data and objective information, not on anecdotal evidence. First, data on the incidence and types of crashes are needed. After that, a detailed understanding of the circumstances that lead to crashes is required to guide public safety policy. Furthermore, knowledge of how injuries are caused and what type they are is a valuable instrument for identifying interventions and monitoring the effectiveness of interventions.

On January 7, 2003, the School Bus Manufacturer's Technical Council (SBMTC) commented to NHTSA:

DOCKET # NHTSA-2002-13546-16 01/07/03 School Bus Manufacturers Technical Council (SCMTC)¹

The School Bus Manufacturers Technical Council (SBMTC) represents the major school bus body and chassis manufacturers. SBMTC is a council within the National Association of State Directors of Pupil Transportation Services and provides technical expertise to association members and the entire school bus transportation industry. SBMTC also serves as technical advisor to the National Conference on School Transportation, which publishes the National School Transportation Specifications and Procedures. It is the intent of these specifications to accommodate new technologies and equipment that will better facilitate the transportation of students. In order to be acceptable, the new technology or equipment shall generally increase efficiency and/or safety of the bus, generally provide for a safer or more pleasant experience for the occupants or pedestrians in the vicinity of the bus, or generally assist the driver and make his/her many tasks easier to perform.

SBMTC believes those comments are applicable to EDRs. Additionally, SBMTC believes that the National Highway Traffic Safety Administration (NHTSA) should continue to encourage and facilitate development of EDRs, but should not consider mandating them until they have been proven cost beneficial. As NHTSA knows, school bus accidents are already closely monitored and studied by both NHTSA and the National Transportation Safety Board. The data from those crash investigations have provided extensive information upon which NHTSA developed the Federal Motor Vehicle Safety Standards (FMVSSs) for school buses. The same data has provided the school bus industry with the foundation for many safety improvements that are not covered by the FMVSSs.

Given the outstanding safety record of school buses (fewer than 10 passenger fatalities per year), it is clear that further improvements in the safety of school buses will result in small incremental benefits. As noted in a recent report from the National Academy of Sciences' National Research Council, more than 800 school-age children are killed each year during normal school transport hours. Of these, only 20 are passengers in or pedestrians outside of school buses. The others are either drivers or passengers in other types of motor vehicles, pedestrians, or bicyclists. SBMTC believes the 800 fatalities per year to children not in school buses are a national tragedy that must be addressed at all levels of government.

While SBMTC certainly supports technologies that can make school bus transportation safer, it also recognizes that the limited school transportation resources that are available make it imperative to assess the costs and benefits of each potential action. From an overall safety perspective, unless funding is made available to improve the safety of the 24 million students that ride school buses each day, as well as the safety of the 24 million students that do not ride school buses each day, it is important to only expend resources when proven safety benefits can be achieved.

SBMTC members were active participants in the two working groups that NHTSA organized to study EDRs. Of the two working groups, the second was focused specifically on heavy trucks and buses. The work of that group did not indicate that there are bases at this time to mandate EDRs in such vehicles, including school buses.

However, the EDR technology does have the potential to allow for a better understanding of motor vehicle crashes, which could lead to new or improved safety requirements for motor vehicles. As such, SBMTC supports the views and comments made by the Truck Manufacturers Association (TMA) to the referenced docket.