Donald R. Erden - Comment

Putting seatbelts in motorcoaches simply makes good sense to me. It’s hard to believe that the first recommendation to add seatbelts can be traced all the way back to 1968, yet we still do not have a requirement on the books. After carefully reading through the through federal docket number NHTSA-2010-0112, I couldn’t agree more with its conclusions and the mandate to have all new motorcoaches manufactured with lap/shoulder seatbelts for all passenger positions. The history of motorcoach accidents are deadly, 186 deaths in just 54 motorcoach crashes reported between 1999 and 2008. More importantly, 75 percent of those deaths were attributed to rollovers with passengers ejected from the motorcoach. As a Texas resident, this subject is especially important to me since two of the worst motorcoach crashes in recent history happened right here on Texas highways. The fiery crash during the Hurricane Rita evacuation left 23 dead in 2005, while a blown motorcoach tire in Sherman Texas claimed the lives of 17 in 2008. The Sherman crash left nearly all of its 54 passengers killed (17) or severely injured (38) in part because they were not wearing seatbelts and many were ejected from the coach as it rolled over. I think the time has come that we quit neglecting our responsibility to at least afford the public the opportunity to “buckle-up” on commercial transportation. We mandate that passengers on airplanes strictly follow the Federal Aviation Regulations that requires them to fasten their seatbelt as indicated by the “Fasten Seat Belt” illumination, yet we turn a blind-eye to these types of rules or even afford the public the common courtesy of providing a simple seatbelt when the mode of public commercial transportation switches from air to ground. The “click-it or ticket” nation-wide campaign to enforce the use of seatbelts is evidence that the science proves wearing seatbelts saves lives, reduces injuries and ultimately saves taxpayer money through reduced medical care expenses. Previous attempts to require seatbelts have failed despite being sponsored by Senators from both political parties. Texan Republican Senator Kay Bailey Hutchison, and Ohio Democratic Senator Sherrod Brown both strongly supported previous legislation which was ultimately defeated by lobbyists representing bus manufactures. Peter J. Pantuso, president of the American Bus Association, who has previously opposed legislation to mandate motorcoach seat belts, is even on record to support this proposal because this legislation is based on sound science. This time I think the government has proven their case with solid scientific data and a recommendation that has a very practical implementation plan. Installing lap/shoulder belts in motorcoaches should conservatively save between 1 and 8 lives per year, while preventing nearly 800 injuries at an average cost of just $12,900 per motorcoach. With only an estimated 2,000 new motorcoaches purchased annually nationwide, $26M/year seems like a small price to pay with huge benefits to public safety. My only recommendation to this proposal would be to reinvestigate the decision to not mandate retrofitting seatbelts requirements on existing motorcoaches. At a minimum, there should be incentives offered to those companies who voluntarily retrofit their existing fleet of older motorcoaches. This proposal determined that most motorcoaches have a lifespan of greater than 20 years. Considering this fact, the National Highway Traffic Safety Administration should look into the feasibility of cost-sharing for the retrofitting of motorcoaches less than 10 years old. The next logical step is to study and propose rules than will mandate the use of seatbelts on motorcoaches, similar to the rules currently used by the airline industry and private motor vehicles.