RIA Case Study from the United States FMVSS No RIA Case Study from the United States FMVSS No. 208: Lap/Shoulder Belts for Over-The-Road Buses

The Problem Millions of people ride commercial buses every year National Transportation Safety Board (NTSB) had investigated several serious commercial bus crashes Each crash had at least three fatalities and six people with serious injuries NTSB determined that the risk of passenger fatalities or injuries would have been reduced if passengers wore a lap/shoulder safety belt Lap/shoulder belts may reduce the risk of fatal injuries in crashes where the bus rolls over crashes by 77 percent

Regulatory Environment Prior to the rule, there were no federal requirements for seat belts to be installed at the passenger positions for these buses The Moving Ahead for Progress in the 21st Century Act (MAP-21) required NHTSA to issue the rule The requires lap/shoulder belts at all passenger seating positions on New over-the-road buses (except school buses) New buses, other than over-the-road buses, with a gross vehicle weight rating greater than 11,793 kilograms (26,000 pounds) Final rule published November 2013

Research: Scientific Basis for the Rule (Simplified) Full scale crash test with twenty-two test dummies The dummies with lap/shoulder belts generally stayed in their seats and had lowest injury during the crash test.

Data Foundations Fatality Analysis Reporting System (FARS) All police-reported fatal motor vehicle crashes within the U.S. State data recoded into a uniform national data set Fatalities w/in 30 days of crash 20.9 annual fatalities in the vehicles of interest National Automotive Sampling System/General Estimate System (NASS/GES) Nationally representative sample of police reported motor vehicle crashes Trained data entry personnel interpret and code data Approximately 90 data elements in a common format 7,934 annual injuries in the vehicles of interest

Benefits: What the Rule Would Accomplish Effectiveness: the safety belts will not prevent 100 percent of all injuries/fatalities in a bus crash Belt Usage Rate: Not everyone will use the safety belts even if installed (about 15 percent to 83 percent projected to actually use the belts) In light of <100 percent effectiveness/usage, the rule was estimate to prevent (annually) 1.7 to 9.2 fatalities 89 to 536 minor injuries 57 to 322 moderate to critical injuries

Costs: The Rule’s “Price” Installation costs on new buses Weight impacts: adding the safety belts increases the bus weight and reduces fuel economy; bus operators will experience some increase in fuel costs Estimated Costs: $2,895 to $3,178 per vehicle

Alternatives to Lap/Shoulder Belts Alternatives analyzed Lap belts only Alternative anchorage strength requirements Retrofitting existing, old buses The alternatives were rejected in favor of the rule The lap belts only option and lower anchor strengths decreased costs only very modestly (or not at all), but would not increase the number of fatalities/injuries avoided significantly Requiring retrofitting not reasonable because it would be very expensive (particularly for small businesses) and yield little in terms of benefits

Summary: Net Benefits of the Rule Annualized Costs and Benefits of Requiring Lap/Shoulder Belts for Over-The-Road Buses (millions of $2008) Costs Benefits Net Benefits 3% Discount Rate $7.0 $28.5 – 158.6 $21.5 to 151.6 % Discount Rate $6.4 $21.8 – 121.1 $15.4 to 114.7