External Affairs / Policy / Consultations Consultations
Seat belts on buses and coaches
9th December 2004
David Peagam
Road and Vehicle Directorate
Department for Transport
2/11 Great Minster House
76 Marsham Street
London SW1P 4DR
David.Peagam@dft.gsi.gov.uk
Dear Mr Peagam
CONSULTATION ON SEAT BELT WEARING IN BUSES and COACHES
We wish to take the opportunity of responding to the above consultation that was forwarded to us courtesy of Martin Elliott of DfES. However, you may like to put us on your direct mailing list for any further similar consultations. Our members mainly operate minibuses but do hire larger Passenger Carrying Vehicles and frequently young people are transported to and from Outdoor Centres in such vehicles and in consequence we are interested in any measure that adds to the safety of young people.
The Institute for Outdoor Learning is a registered charity that was formed three years ago as the result of the convergence of six outdoor organisations. We represent probably the broadest spectrum across the industry of any existing organisation. Our members include employers and employees involved in walking, mountaineering, personal development, outdoor activities, field studies, watersports and outdoor recreation. Our members are present in outdoor centres, educational establishments, including schools, or may be lone providers. They work for charities, local authorities commercial enterprises or themselves either in a full time or voluntary capacity. We are the largest outdoor organisation of our kind.
We support the proposals for the amendment to the seat belt wearing regulations as proposed in para 6 of your letter. However, I am sure that you are aware that vehicles used for local transport in urban areas are also used on the 'school runs' in rural areas involving some long distances on a regular basis. I recall my surprise some years ago when working at an outdoor centre on the Northumberland moors when on a Monday morning the group arrived in a double decker bus!
We do not believe any exemptions should be granted under the 3 for 2 rule.
With regard to informing of passengers about the rule requirements, it is questionable whether a display sign will have the slightest effect on some young people, unless of course a teacher is on the vehicle.
We would suggest that you need to consider something more in respect of young people, where perhaps the school could take the responsibility of informing their pupils, and to consider making it a school rule, where the observed breaking or refusal to comply would involve the pupils in the school disciplinary process. This might involve warning parents that non-compliance might forfeit the right to travel on school transport.
As most return home school transport starts with the one pickup you might consider requiring the driver to check that pupils are belted up before the vehicle moves off. In the case of an organised outing or visit from the school where presumably the teacher organiser and other staff would be on the vehicle and as they have a 'duty of care' for their pupils then we consider this should include the wearing of seat belts. Though this might be achieved by advice from DfES to Schools rather than regulations.
With regards to the sign, we live in a world with so many logos, that many adults let alone children would not recognise the significance of this pictogram, excellent as it may be. We believe that it also needs to say 'Wearing of seat belts required' or some such wording.
We are in agreement regarding bringing the regulations into force on 1st July 2005.
There are no comments upon the regulatory impact assessment.
Yours sincerely
Brian Lamb
Vice-Chair IOL
nb Any response to me please
Greystone Cottage, Bere Ferrers, Devon PL20 7JX