SBIC News Flash on IMMI Marketing Campaign
March 9, 2004

The School Bus Information Council has learned that IMMI, Inc, a Westfield, Indiana, manufacturer of vehicle safety restraints, developed and launched an advertising campaign designed to persuade parents and state policy makers to require lap/shoulder belts, and specifically its product named “SafeGuard”, in school buses. The campaign began on Monday, March 8, 2004.

The campaign features television commercials that are designed to make parents ponder why school buses are not required to have lap/shoulder belts. The commercials make a very emotional appeal. Viewers are directed to visit an IMMI web site (www.safeguard4kids.com), or call a toll-free telephone number (1-877 BUS SEAT), to request additional information.

The IMMI website suggests that parents and other interested parties contact the state and local pupil transportation directors in their area to express their desire to have SafeGuard seats in school buses. The website provides the name and address of each state director of pupil transportation and each state pupil transportation association. Suggested letters also are provided.

The commercials are in 30- and 60-second formats, and will air in the Columbus, OH, Indianapolis, IN, Grand Rapids, MI, Kansas City, KS/MO, Macon, GA, Naperville, IL, and Oklahoma City, OK markets. However, these commercials may reach other locations in and around these areas, and their existence may be picked up by other news media.

No doubt these commercials will motivate some parents and state legislators to call for lap/shoulder belts on all school buses. As always, we want you to be informed and prepared with suggested responses in the event local news media or others contact you. We suggest that you visit the IMMI website, and then focus on the following talking points, tailoring them as appropriate to local circumstances and the nature of the inquiry:

1. This is a commercial public relations enterprise created solely by IMMI and designed to market the company and the SafeGuard seat. The commercials play upon the fact that the installation of lap/shoulder belts on school buses is a complex and emotional issue. As with any topic like this, it is impossible to explain all of the relevant issues in a 30- or 60-second commercial.

It is important that viewers and public policy makers take the time to analyze all of the available information to fully understand and appreciate the complexity of this subject. Important information can be found on the following websites:

School Bus Information Council – www.schoolbusinfo.org

National Association of State Directors of Pupil Transportation Services -- www.nasdpts.org

National Association for Pupil Transportation – www.napt.org

National Highway Traffic Safety Administration – www.nhtsa.dot.gov

National Transportation Safety Board – www.ntsb.gov

2. The National Highway Traffic Safety Administration (NHTSA) is the federal agency that establishes requirements for the safety of all motor vehicles, including school buses. NHTSA has exhaustively studied the issue of both lap belts and lap/shoulder belts on school buses -- reviewing all available research, real-world crash data and various laboratory crash tests. As a result, the agency has announced that it intends to issue a new Federal requirement that will require lap/shoulder belts in small school buses (those under 10,000 pounds gross vehicle weight rating), because their crash dynamics are somewhat like passenger cars. However, NHTSA does not believe there is sufficient data to warrant a Federal mandate for lap/shoulder belts in large school buses (those over 10,000 pounds gross vehicle weight rating.)

3. Although the pupil transportation industry has long opposed the installation of lap belts in school buses, the industry does not oppose the voluntary installation of lap/shoulder belts in school buses.  It is important to point out, however, that there are construction and equipment performance standards that apply to all school buses and NHTSA has not yet developed the performance standards for the installation of lap/shoulder belt systems in any size school bus.  NHTSA has announced that it intends to issue mandatory performance requirements for lap/shoulder belt systems that are optionally installed in school buses, but the agency is still in the process of researching the issues involved.

4. IMMI attempts to draw an analogy between the crash dynamics in a passenger car and that of a school bus. In addition, IMMI points to federal government estimates that there are approximately 26,000 school bus accidents each year as a reason for using its lap/shoulder belts. Unfortunately, IMMI did not provide all of the facts.

First and foremost, the crash environment inside a car is very different from that of a large school bus.  Large school buses not only have the advantage of size and weight in most crashes, they must meet more Federal Motor Vehicle Safety Standards than any other vehicle on the road. The fact that school buses have been subject to this strict Federal regulation for nearly 30 years is the primary reason school buses are the safest motor vehicle on the Nation's highways.

Secondly, what IMMI does not tell you about the federal government accident estimates is that the overwhelming majority of school bus crashes do not include injuries to school bus passengers.  In fact, NHTSA estimates that there are fewer than 400 serious school bus crash-related injuries each year. Even with lap/shoulder belts, some school bus passengers will still be injured in school bus crashes.

Viewers, especially parents, who are truly concerned about safety should know that there are approximately 48 million children that attend public schools across America every day. Just about half of them - approximately 24 million - ride yellow school buses to and from school each day; the other half does not.

Tragically, there is an average of 8 deaths per year among those 23 million school bus passengers. Even more tragic is the fact that more than 800 school-aged children who do not ride a school bus are killed during normal school transportation hours each year. From an overall safety perspective, this is a much greater cause for concern than the fact that school buses are not required to be equipped with lap/shoulder belts.

What should viewers “take away” from these commercials?

1. The current lap/shoulder belt debate must include discussions about the allocation of tight resources. School budgets around the country are generally stretched beyond their limits and pupil transportation costs are constantly in the crosshairs of budget cutters. In some localities the decision is even more desperate—legislators are struggling just to maintain the current level of pupil transportation funding and discussions of either buying more buses or adding lap/shoulder belts are out of the question. Armed with all of the relevant information, parents and policymakers should consider if the dollars that IMMI wants you to spend on its seats might better be spent ensuring that more children have the opportunity to ride to school in a school bus, or replacing older buses or vans in their school district’s fleet.

2. The most important action a parent can take is to communicate with their School Board and state/local legislators that school transportation is just as important as the classroom education of their children. Teachers cannot educate our children unless they arrive at school safe and ready to learn.

3. Parents should demand that school transportation budgets be fully funded, and that additional funding be made available to improve the safety, health and security of school buses.

4. Funding to replace older school buses with new school buses will not only provide school buses with the latest safety equipment, but also with the latest low-emission engines and advanced emission control systems that will help clean air efforts, and also reduce fuel consumption. Adding global positioning systems and other technologies will increase the level of security provided to school buses.