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Memorandum

To: Administrators and Managers of School Bus Operations
From: State School Bus Committee
Re: Retrofitting lap belts, use of child safety seats, or other restraint devices on school bus seats per 575 IAC 1-5.5-11(a)
Date: March 8, 2000

This memorandum is being sent to remind you of State School Bus Committee (Committee) rule when retrofitting lap belts or installing child restraint systems and other restraint devices on school bus passenger seats. The Committee recently denied a request to use a vest and portable seat mount (cam wrap) restraint system on a seat frame that was not manufactured for restraints.

When retrofitting a lap belt or using a child restraint seat, including other styles of restraint systems, on a school bus passenger seat, you are required by 575 IAC 1-5.5-11(a) to:

• use a seat frame manufactured for restraints; (This type of seat frame is commonly know as a ‘seat-belt-ready frame’, ‘reinforced seat frame’, or ‘lap-belt-ready seat frame’);
  
• use lap belt assemblies complying with Federal Motor Vehicle Safety Standard No. 209; and
  
• use lap belt assembly anchorages complying with of Federal Motor Vehicle Safety Standard No. 210.

This rule is applicable for a school bus ordered for purchase and initially placed in service on or after July 1, 1990. School transportation providers are strongly encouraged to follow this guidance for a school bus placed in service prior to July 1, 1990. For reference, 575 IAC 1-5.5- 11(a) is printed at the end of this memorandum.
This rule serves to ensure the safest installation of post-production lap-belt-ready seat frames and lap belt assemblies in school buses by replicating as close as practical how the bus would have been constructed if lap belts were installed at the time of original purchase.

School transportation providers are strongly encouraged to contact the original bus body manufacturer’s distributor to obtain the manufacturer’s original equipment seat frames, belt assemblies, mounting hardware, and installation instructions used at the factory level.

School transportation providers are also strongly encouraged to follow a restraint manufacturer’s directions for use. This will help ensure that the restraint product performs as expected during crashes or emergencies and maximizes protection for the occupant. Improper use or installation can cause injury or death and can increase liability exposure for the transportation provider. The following example is offered to illustrate this point.

• A vest and harness restraint manufacturer states that passengers in the seating position behind a child secured with their restraint vest also are to be secured by an approved child restraint system (e.g., vest, lap belt, child safety seat). This action reduces the effects of ‘double loading impact’ on the seat back of the forward passenger.

Although some restraint manufacturers indicate their product may be used without a reinforced seat frame or other component, please note that their statement does not invalidate State School Bus Committee rule.

For assistance with this memorandum please contact the Indiana Department of Education’s Division of School Traffic Safety and Emergency Planning. The Division may be reached by e-mail to pbaxter@doe.in.gov or by telephone at 317-232-0891.

575 IAC 1-5.5-11 Special requirements

Sec. 11. (a) Any passenger seat that has a child safety seat or restraint system attached to it must: (1) have a reinforced frame; and (2) meet the requirements of FMVSS 208, 209, and 210. (State School Bus Committee; 575 IAC 1-5.5-11; filed May 24, 1990, 4:20 p.m.: 13 IR 1859; filed May 21, 1992, 5:00 p.m.: 15 IR 2222)