LoginNHTSA Rulemaking at Heart of NCST Resolutions Focused on Safety
Besides thanking the various individuals involved in putting together the 17th National Congress on School Transportation last month in Des Moines, Iowa, and providing copies of the proceedings to the National Highway Traffic Safety Administration and other organizations, resolutions focused on increased safety and data keeping.
The most time-sensitive resolution is No. 6, which requests clarification on FMVSS 213a and 213b final rules related to the performance and use of child safety restraint systems (CSRS). NCST submitted the resolution to the National Highway Traffic Safety Administration immediately. It notes that the school transportation industry takes great pride in providing the safest form of transportation available and that preschool and special needs transportation are a sizable component of the industry.
The resolution states the importance of further engaging NHTSA “to ensure children requiring securement based on age and weight are carried safely and securely, child safety restraint systems are attached to the seatback to ensure a secure fit for the child. It is believed that there are approximately 310,000 to 335,000 [child safety restraint systems] specifically designed for school buses on the road.”
NHTSA is currently accepting comments for a notice of proposed rulemaking initiated as a result of the final rules for FMVSS 213a and 213b that would exempt CSRS from side-impact protection requirements and lower anchorage attachment requirements (due to being designed for school buses specifically). The NPRM also states that the CRABI-12MO test dummy is no longer being used to test forward-facing CSRS for side impact, and that labels on school bus CRSs will also be updated to reflect their installation method, versus referencing vehicle belts or child restraint anchorage systems.
The NPRM also seeks to delay the implementation of FMVSS 213a and 213b to Dec. 5, 2026 from June 30, 2025, giving more time to manufacturers to test and certify their products.
Submit a Federal Register public comment on Docket NHTSA-2025-0046 by June 30.
Resolution 1 expressed appreciation to Patrick McManamon for serving as NCST Chair from 2015 to 2024. He stepped down as chair earlier this year citing professional and personal reasons.
Resolution 3 recognized the following individuals for serving as on-site officials and for their dedication and service to NCST.
– Mike LaRocco, conference chair
– Charlie Hood, on-site chair
– Susan Miller, on-site coordinator
– Lori Wille, editor
– Laura Meade, parliamentarian
– Rene Dawson & Reginald White, timekeepers
– Samantha Kobussen, National School Transportation Specifications and Procedures artwork
– Zander Press, printer
– Ronna Weber and NASDPTS leadership for “making the Congress a success in the manner it was organized and concluded.”
However, the NCST resolution asks NHTSA if CSRS specifically designed for school buses — such as the IMMI Star, BESI ProTech, and HSM Portable Child Restraint — are exempt from the side-impact requirements under FMVSS 213a, as of the effective date of June 30. If they are not exempt, NCST questioned if devices manufactured prior to June 30 will remain permissible for continued use beyond the implementation deadline. The resolution also asks, in the event the specified CSRS are not exempt and in consideration of maintaining a high standard of safety, what alternative CSRS models or types would be deemed acceptable for continued use on school buses.
The resolution seeks clarification from NHTSA if it will be issuing any additional guidance or initiating rulemaking specifically addressing the use and approval of CSRSs for school bus applications prior to the June 30 effective date. It also asks NHTSA if it will be updating the curriculum for the Child Passenger Safety on School Buses training courses to reflect the forthcoming changes, particularly those involving add-on school bus securement systems.
“The NCST respectfully urges NHTSA to provide a formal response and guidance at the earliest possible opportunity, mindful of the June, 30, 2025 implementation date to support informed decision-making, training readiness, and procurement planning by school transportation providers nationwide,” the resolution states.
NHTSA mandates transportation equipment design and safety performance requirements but does not regulate use. States establish requirements for each type of CSRS based on a child’s age and weight as well as the vehicle. NHTSA did publish Guideline for the Safe Transportation of Pre-school Age Children in School Buses, which essentially recommends using CSRS for the appropriate weight and height of children and following CSRS manufacturer installation instructions. That guideline, which is not binding for states, came out in February 1999 and no updates have been made since.
Additionally, the NHTSA-sponsored Child Passenger Safety on School Buses, taught at TSD Conference, is also best-practice guidance and not a regulation. It was already updated in 2023 by the National Safety Council. The organization develops and maintains the curriculum. The NHTSA website also includes a School Bus Safety page that links to more information on the eight-hour, hands-on securement training.
Meanwhile, Resolution 2 referenced a March 2024 School Transportation News article that identified a student passenger reporting challenge that indicates school bus ridership is disappearing. The Editor’s Take column by Ryan Gray noted that the National Household Travel Survey (NHTS) sponsored by the Federal Highway Administration indicates the number of students transported nationwide by the yellow school bus is about one-third less than the figure used by the industry.
The resolution recognizes the need to develop a standardized reporting system for collecting school bus ridership data and “requests the interim steering committee of the 18th NCST to appoint a focus group to research and develop recommendations for standardization of data collection relative to ridership on school bus and make periodic reports to the Interim Committee.”
Data collection for the 2024 survey is expected to be completed this fall.
Resolution 5 “encourages transportation professionals to plan bus stops that are not in proximity to known registered sexual offenders when made aware, when possible. Training programs should be provided to all transportation personnel on recognizing and reporting suspected or known human trafficking.”
The resolution states that the NCST is aware of the safety concerns associated with sexual predators and offenders as well as human trafficking, noting an increase these crimes occurring across the U.S.
All NCST resolution proposals presented to the state delegations passed.
Related: Invest in Child Safety Restraint Training Today, Reap Benefits Tomorrow
Related: NHTSA Denial of Built-in School Bus Booster Seats Won’t Impact Industry
Related: Legalities of Transporting Students with Special Needs Focus of Day 3
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