SCHOOL BUS 

SAFETY

Crash Data Trends 

and Federal and State 

Requirements

Report to Congressional Addressees

January 2017

GAO-17-209

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-17-209, a report to 

congressional addressees

January 2017

SCHOOL BUS SAFETY

Crash Data Trends and Federal and State 

Requirements 

What GAO Found

Based on GAO’s analysis of data for 2000 to 2014, 115 fatal crashes involved a 

school bus on average each year—which is 0.3 percent of the 34,835 total fatal 

motor-vehicle crashes on average each year. The school-bus driver and schoolbus vehicle (e.g., a defect) were cited as contributing factors in 27 percent and 

less than 1 percent of fatal school-bus crashes, respectively. Seventy-two 

percent of fatal crashes occurred during home-to-school and school-to-home 

travel times. Limited national data on school bus crashes exist beyond data on 

fatal school-bus crashes, but some states have richer data—for example, on the 

type of bus or whether the operator was a school district or private contractor. 

Federal laws and regulations set requirements for certain aspects of school bus 

safety, and state laws and regulations in many cases go beyond the federal 

requirements. Federal regulations for school-bus vehicle standards and driver 

licensing apply to both school districts and contractors. DOT has reported that 

new school buses must meet more Federal Motor Vehicle Safety Standards than 

any other type of new motor vehicle. Federal safety regulations for commercial 

motor-vehicle operations apply in certain cases, such as for contractors hired by 

schools to provide transportation for extracurricular activities across state lines. 

Based on a systematic search of state laws and regulations, GAO found that all

50 states require school bus inspections while most states—GAO found 44—

require refresher training for school bus drivers. However, GAO found that less 

than a quarter of states set specific requirements for the maximum age and 

seating capacity of school buses. Overall, according to stakeholders GAO 

interviewed, states’ requirements vary by state for school bus inspections, driver

training, and vehicles but tend not to differ based on the type of operator.

Examples of Federal and State Requirements for School Bus Safety

View GAO-17-209. For more information, 

contact Susan Fleming at (202) 512-2834 or 

flemings@gao.gov.

Why GAO Did This Study

School buses transport over 26 million 

students to school and other activities

every day. While school buses have a 

strong safety record, crashes with 

fatalities and injuries do occur. Since 

school buses transport precious 

cargo—our children—government and 

industry strive to further improve their

safety. Federal and state agencies 

both oversee school bus safety, and 

locally, school buses can be operated 

by school districts or private 

contractors, working on behalf of 

school districts. 

The Fixing America’s Surface 

Transportation Act included a provision 

for GAO to review school bus safety. 

GAO examined (1) fatal crashes 

involving school buses for 2000 to 

2014 and (2) federal and state schoolbus-related laws and regulations, 

among other objectives. GAO analyzed 

two sets of data from the National 

Highway Traffic Safety Administration 

and the University of Michigan 

Transportation Research Institute on 

fatal school bus crashes for 2000 to 

2014, the latest year for which data 

were available; reviewed federal laws 

and regulations; and systematically 

searched state laws and regulations on 

school-bus inspections, driver training, 

and maximum vehicle age and 

capacity in all 50 states. GAO also 

interviewed federal officials from the 

Department of Transportation (DOT), 

school bus industry associations and 

manufacturers, and other stakeholders. 

DOT reviewed a draft of this report and 

provided technical comments that GAO 

incorporated as appropriate.
Page i GAO-17-209 School Bus Safety

Letter 1

Background 4

Detailed Data Are Limited on School Bus Crashes, but Fatal 

School-Bus Crashes Are a Very Low Percentage of All Fatal 

Motor Vehicle Crashes 7

Federal Laws and Regulations Set a Baseline for School Bus 

Safety, upon which State Laws and Regulations Build 17

Stakeholders Identified Voluntary Industry Standards as a Primary 

Source of Leading Practices, and Work Is Under Way in Areas 

Where Stakeholders Most Often Said Additional Federal 

Guidance Would Be Useful 30

Agency Comments 33

Appendix I Objectives, Scope, and Methodology 34

Appendix II Description of Eight Selected States’ Requirements on School Bus 

Safety 41

Appendix III GAO Contact and Staff Acknowledgments 46

Tables

Table 1: Selected States’ School Bus Inspection Results 26

Table 2: List of Interviewed School Bus Safety Stakeholders 40

Table 3: Selected Eight States’ School Bus Safety Requirements 41

Figures

Figure 1: Types of School Buses 5

Figure 2: Number of Fatal Crashes Involving School Buses, by 

Travel Time, 2000–2014 14

Figure 3: Fatal School Bus Crashes by Type of Driver-Related 

Factors, 2000–2014 15

Figure 4: Examples of Federal Laws and Regulations and 

Department of Transportation Oversight Agencies for 

School Bus Safety 19

Figure 5: Examples of State Requirements for School Bus Safety 23

Contents
Page ii GAO-17-209 School Bus Safety

Abbreviations

BIFA Buses Involved in Fatal Accidents 

FARS Fatality Analysis Reporting System 

FAST Act Fixing America’s Surface Transportation Act

FMCSA Federal Motor Carrier Safety Administration 

FMVSS Federal Motor Vehicle Safety Standards

GES General Estimates System 

NASDPTS National Association of State Directors of Pupil 

Transportation Services

NCST National Congress on School Transportation 

NHTSA National Highway Traffic Safety Administration 

UMTRI University of Michigan Transportation Research Institute

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-17-209 School Bus Safety

441 G St. N.W.

Washington, DC 20548

January 12, 2017

The Honorable John Thune

Chairman

The Honorable Bill Nelson

Ranking Member

Committee on Commerce, Science, and Transportation

United States Senate

The Honorable Bill Shuster

Chairman

The Honorable Peter DeFazio

Ranking Member

Committee on Transportation and Infrastructure

House of Representatives

The Honorable Edward J. Markey

United States Senate

Every day, school buses across the country transport over 26-million 

students to school and other activities. The National Highway Traffic 

Safety Administration (NHTSA) has reported that school buses are the 

safest means of getting children to and from school and school-related 

activities. School buses have a strong safety record, but school bus 

crashes with fatalities and injuries still occur and are often high-profile, 

since they involve precious cargo—the nation’s schoolchildren. Thus, 

government agencies, student transportation groups, and others strive to 

further improve the safety of school buses. Federal, state, and local 

government agencies all play a role overseeing the safety of school bus 

transportation. For example, at the federal level, NHTSA sets vehicle 

standards for brakes and emergency exits, and the Federal Motor Carrier 

Safety Administration (FMCSA) establishes rules, including those for 

commercial driver licensing and drug and alcohol testing of commercial 

motor vehicle drivers. Also, states set additional requirements for school 

bus transportation, including requirements to periodically inspect school 

buses to help ensure their safe operation.

The Fixing America’s Surface Transportation (FAST) Act included a 

provision for us to review school bus safety, including examining any 

differences in the safety performance of different types of school bus 

Letter
Page 2 GAO-17-209 School Bus Safety

operators—that is, public school districts and private contractors—and 

what safety requirements apply to them.1 We examined:

• data federal and state agencies collect on school bus crashes and the 

number and characteristics of fatal school-bus crashes that have 

occurred since 2000;

• federal and state laws and regulations pertaining to school bus 

inspections, vehicles, and drivers, as well as state data on 

inspections’ outcomes; and

• sources for leading practices for safe school-bus transportation, as 

identified by stakeholders and literature, as well as any areas where 

further federal guidance could be useful.

As part of this work, we also examined whether there were differences for 

school-district- and contractor-operated school buses in any of the above 

areas. Overall, we focused our review on the transportation of public 

school students from kindergarten through grade 12 (K-12) traveling to 

and from home and school and for extracurricular activities, and not 

transportation of private-school students.

To examine federal and state data on school bus crashes, we reviewed 

the Department of Transportation’s documents describing NHTSA’s and 

FMCSA’s crash data. We also surveyed state pupil transportation 

directors in the 50 states to determine whether and how states collect 

data on the type of operators (i.e., school districts or contractors) that are 

involved in school bus crashes; type of operator is one school-busspecific variable that aligned with the FAST Act provision and scope of 

our review.2 We received completed surveys from 47 of 50 respondents 

for an overall response rate of 94 percent. In addition, we interviewed 

federal officials, industry associations, and other stakeholders to identify 

sources of crash data and the strengths and limitations of existing school 

bus crash data. To describe the number and characteristics of fatal 

school-bus-related crashes, we analyzed data on school bus crashes for 

2000 to 2010 in the Buses Involved in Fatal Accidents (BIFA) database of 

the University of Michigan Transportation Research Institute (UMTRI) and 

data for 2011 to 2014 in NHTSA’s Fatality Analysis Reporting System 

(FARS), the most current data available. Based on interviews with 

 1

Fixing America’s Surface Transportation Act, Pub.L. No.114-94, § 5511,129 Stat. 1312, 

1556 (2015).

2

We did not include the District of Columbia or territories.
Page 3 GAO-17-209 School Bus Safety

NHTSA and UMTRI officials, as well as reviewing system documentation 

and electronic data testing, we determined that the data were sufficiently 

reliable for the purpose of describing the number of fatal school-bus 

crashes.3

To describe requirements pertaining to school bus safety, we reviewed 

federal laws and regulations for inspections, driver training, and vehicle 

standards that apply to school buses, in particular standards for maximum 

vehicle age and capacity that apply to school buses.4 We also conducted 

a systematic search of current laws and regulations in each of the 50 

states in a legal database to identify requirements in state laws or 

regulations in the above three categories. We took steps to verify the 

results of our search, including comparing the requirements we found with 

the lists of requirements compiled by school bus associations and other 

organizations. Our search sought to identify the existence of state 

requirements in the above areas and did not seek to identify any local 

requirements. We also performed additional research on and conducted 

in-depth interviews with officials in eight selected states—California, 

Illinois, Nebraska, New York, Pennsylvania, Tennessee, Virginia, and 

Washington—to better understand their oversight of school bus safety 

and discuss inspection data. We selected states to include those with the 

highest number of students transported daily by school bus, the highest 

annual route miles traveled per student, variation in the number of school 

buses owned by states/school districts and contractors, geographic 

variation, and availability of school-bus crash data.

To identify sources of leading practices and any areas where further 

federal guidance could be useful, we conducted a literature review of 

pertinent studies in peer-reviewed journals, trade publications, and 

conferences, among others, covering the last 15 years. We also 

interviewed 30 stakeholders—including federal officials, officials in the 8 

selected states, industry associations, school bus manufacturers, and 

school bus contractors, among others—to gather their views and 

 3

Crashes for BIFA are selected from FARS, so the data are compatible. We used BIFA 

data as they were the only source of national crash data we identified that included busspecific variables like type of operator and bus. Since BIFA data build from FARS data, we 

used the more recent FARS data from 2011 to 2014 to extend our analysis for other 

variables like atmospheric and road conditions and time of day of the crash.

4

NHTSA is in the process of further researching the safety impact of requiring seat belts 

on all school buses. We did not examine requiring seat belts on all school buses as part of 

our review. 
Page 4 GAO-17-209 School Bus Safety

expertise on leading practices and the other areas we examined for this 

review. We selected stakeholders to represent a range of roles in the 

school bus industry and to cover federal and state levels of government. 

See appendix I for more information on our scope and methodology.

We conducted this performance audit from February 2016 to January 

2017, in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

School buses are used to transport students to and from home and 

school and extracurricular activities like field trips and athletic events. The 

industry defines four basic types of school buses. Types A and B are 

comparatively small in size, while types C and D are comparatively large 

in size, as shown in figure 1. In general, the capacity of a school bus 

increases from type A to type D buses, and type D school buses can 

have a capacity up to 90 students. Type C school buses are most 

common, representing 70 percent of school bus sales in 2014 (23,715 of 

34,021 buses) according to figures reported by School Bus Fleet.

5

 5

School Bus Fleet is a trade publication for school transportation professionals in the 

United States and Canada.

Background
Page 5 GAO-17-209 School Bus Safety

Figure 1: Types of School Buses

School districts or private contractors can operate school buses 

transporting public school students. School districts have a spectrum of 

contracting options from which to choose school bus transportation. 

When a school district contracts with a private company, the contractor 

could manage and provide all or some aspects of student transportation, 

depending on the school district’s needs and preferences. In full-service 

or “turnkey” contracts, the contractor takes on all aspects of pupil 

transportation services, such as hiring and training drivers and managing 

school bus routes. In other contracts, the district may retain ownership of 

school buses but have the contractor operate the buses, or the district 

may only have the contractor provide particular operations, such as 

special needs transportation.

Whether district-operated or contracted, oversight of school bus 

transportation occurs across all levels of government and can involve 

multiple agencies at each level of government.

• At the federal level, NHTSA sets vehicle safety standards for new

motor vehicles and administers grant programs as part of its mission 

to reduce deaths, injuries, and economic losses resulting from motor 

vehicle crashes. NHTSA also collects and analyzes crash data for a 

variety of purposes, such as to determine the extent of a safety 

problem and steps it should take to develop countermeasures. Two 

data sets are used to generate national statistics: FARS is a census of 

fatal crashes, and the General Estimates System (GES) is a sample 
Page 6 GAO-17-209 School Bus Safety

of fatal, injury, and property-damage crashes.6 In addition to these 

activities that apply broadly to motor vehicle safety, including school 

buses, NHTSA provides guidance and holds workshops specific to 

school bus safety. For example, in December 2016 NHTSA hosted a 

day-long meeting on school transportation safety that included panels 

on school transportation risks and school bus vehicle technology, 

among other topics.

• Also at the federal level, FMCSA’s mission is to reduce crashes and 

fatalities involving commercial motor vehicles. FMCSA is responsible 

for setting and enforcing federal safety regulations that apply to large 

commercial truck and bus operators. For school bus transportation, 

FMCSA’s safety regulations for commercial motor vehicle operations 

do not apply to home-to-school and school-to-home transportation.

These regulations apply in very limited circumstances such as for 

contractors hired by schools who provide transportation for 

extracurricular activities across state lines. The primary exception to 

this, however, is commercial driver’s licensing; school bus drivers 

must have a commercial driver’s license with a school bus 

endorsement, which requires a driver to pass additional knowledge 

and skills tests specific to operating a school bus, and are subject to 

drug and alcohol testing.

7 FMSCA collects data on motor vehicle 

crashes but focuses on crashes involving large trucks and commercial 

buses, given its mission and jurisdiction. This crash data is collected 

in the Motor Carrier Management Information System.

• At the state level, multiple agencies are often responsible for setting 

or enforcing state-specific requirements for school-bus driver 

qualifications and training, vehicles, inspections, and other operational 

aspects. Some states require school districts to provide students with 

 6

In fiscal year 2012, Congress provided $25 million from the Safety Belt Performance 

Grants program, which was created to encourage states to enact and enforce seat belt 

laws, to NHTSA to modernize the National Automotive Sampling System, which includes 

GES. Under the new system, the Crash Report Sampling System will replace GES. Pub. 

L. No. 112-55. 125 Stat. 552, 658 (2011). 

7

A commercial driver’s license is needed to drive a motor vehicle that has a gross 

combination weight rating or gross combination weight of 26,001 pounds or more, or is 

designed to transport 16 or more passengers including the driver, among other vehicles, 

according to the definition for a commercial motor vehicle in 49 C.F.R. § 383.5. Most 

school bus vehicles fall into this definition for a commercial motor vehicle and therefore 

require the driver to have a commercial driver’s license. 
Page 7 GAO-17-209 School Bus Safety

transportation to and from home and school, while other states allow 

school districts to decide whether to provide such transportation.8

• Finally, local school districts are responsible for implementing and 

supervising school bus operations. This includes managing and 

establishing routes and policies, operating and maintaining school 

buses, and training and assigning staff, sometimes in conjunction with 

contractors.

At the federal level, both NHTSA and FMCSA collect data on motor 

vehicle crashes that include crashes involving school buses. Since these 

data cover crashes involving a range of vehicles, information that is 

specific to school buses, like the specific type of school bus or whether it 

was operated by a school district or contractor, is not included in these 

national data. States may have richer data on school bus crashes, and 

we found that a small number of states collect some school-bus-specific 

information in their crash data, such as the type of operator. However, 

state data on school bus crashes vary because states determine what 

specific data elements to collect in crash data.

 8

Federal laws and regulations require school districts (local educational agencies) to 

provide transportation for students in certain situations. Local education agencies must 

provide students experiencing homelessness with transportation to and from their schools 

of origin, if requested by a parent or guardian or by the local liaison on behalf of an 

unaccompanied homeless youth. 42 U.S.C. § 11432(g)(1)(J)(iii). Further, transportation is 

a related service available for students eligible for special education and related services 

under the Individuals with Disabilities Education Act. Pub. L. No. 101-476, 104 Stat. 1142 

(1990). Decisions about whether transportation is required and the type of transportation 

are made at the local level as part of a child’s individualized education program. 34 C.F.R. 

§ 300.34(c)(16).

Detailed Data Are 

Limited on School 

Bus Crashes, but 

Fatal School-Bus 

Crashes Are a Very 

Low Percentage of All 

Fatal Motor Vehicle 

Crashes

While Little Federal Data 

Exist beyond School Bus 

Fatalities, State Data May 

Contain More Detailed 

Information
Page 8 GAO-17-209 School Bus Safety

NHTSA collects basic data on motor vehicle crashes, including schoolbus-related crashes, but not any in-depth data specific to school buses, 

such as whether a school bus was district or contractor operated or the 

type of school bus. NHTSA’s FARS and GES crash data both include a 

variable to identify school-bus-related crashes.9 Therefore, NHTSA uses 

this variable to isolate school-bus-related crashes in FARS data and 

generates an annual report describing the number and some 

characteristics of fatal school-bus-related crashes.10 For example, the 

report describes characteristics of fatal school-bus crashes such as the 

time of day and whether the fatality(ies) was an occupant or nonoccupant of the school bus or other involved vehicles. NHTSA can also 

isolate school bus crashes from GES data; however, because GES is a 

sample of crashes and school bus crashes are such rare events, GES 

data cannot be used to reliably examine year-to-year trends, according to 

NHTSA. NHTSA’s crash data aim to cover all types of traffic accidents, 

and as such, FARS and GES do not include additional variables tailored 

to accidents involving school buses. Moreover, the source for FARS and 

GES—police accident reports—vary from state to state and may not 

contain such school-bus-specific information, such as type of bus and 

type of operator, for NHTSA to aggregate across states.11

FMCSA’s crash data for large truck and bus crashes do not include a 

variable to identify school-bus-related crashes.12 FMCSA’s crash data, 

 9

This variable identifies any crash that involves, directly or indirectly, a school bus or a 

non-school bus functioning as a school bus, transporting children to or from school or 

school-related activities.

10NHTSA, School-Transportation-Related Crashes: 2005–2014 Data, DOT HS 812 272 

(Washington, DC: May 2016).

11As reported in guidance for the Model Minimum Uniform Crash Criteria, states have their 

own data collection guidelines, resulting in variation across states in what data are 

collected in police accident reports and maintained in the crash databases. GAO has also 

reported on this variation in the past. See, for example, GAO, Highway Safety: Federal 

and State Efforts Related to Accidents That Involve Non-Commercial Vehicles Carrying 

Unsecured Loads, GAO-13-24 (Washington, D.C.: November 2012).

12According to FMCSA, a crash must be reported to the agency if it (1) involves a truck, 

used for commercial purposes, with a gross vehicle weight rating or gross combination 

weight rating greater than 10,000 pounds; a commercial bus designed to transport nine or 

more persons, including the driver; or any vehicle carrying hazardous material that 

requires placarding, regardless of the vehicle’s weight and (2) results in at least one 

fatality, at least one injury involving immediate medical attention away from the crash 

scene, or at least one vehicle disabled as a result of the crash and transported away from 

the crash scene.

Federal Crash Data
Page 9 GAO-17-209 School Bus Safety

which come from police accident reports, identify the vehicle involved as 

a bus or truck but does not further delineate the type of bus (e.g., transit 

bus or school bus).13 In addition, it does not define or collect data on the 

type of school bus operator.14

States collect crash data to help implement and evaluate highway safety 

policies, but the specific crash data that states collect vary. Some states 

have richer data on all types of school bus crashes, including fatal, injury, 

and property-damage-only crashes than NHTSA and FMCSA, based on 

our review of federal and select state’s crash data collection processes. 

However, since states have discretion in determining what specific data 

elements to collect, state data on school bus crashes vary. Each state 

has its own crash data system, and police accidents reports—a key 

source of crash data—are unique to each state. For example, on 

California’s police accident report, officers enter codes to identify the 

involved vehicles, and specific codes classify the type of school bus and 

operator (e.g., public or contractor). Other states’ police accident reports 

may not collect as detailed information on a school bus involved in a 

crash. For example, our review of police accident reports in our selected 

states found that one state’s police accident report had a field to indicate 

whether a crash involved a school bus, and another state’s report used 

the narrative section to note a school bus’s involvement.15

We surveyed states to determine whether they track the type of school 

bus operator in crash data, or other state data such as inspection or 

funding data, since information states collect on school bus crashes and 

 13While FMCSA’s Motor Carrier Management Information System crash data include a 

field that would further classify the type of bus, this field is outside the required data points 

that come from the police accident reports and is therefore, according to FMCSA officials, 

not reliable.

14Most school transportation is exempt from many Federal Motor Carrier Safety 

Regulations for motor carrier operations, 49 C.F.R. § 390.3(f)(1), and the exemption is 

based on the type of entity operating the bus and type of trip (e.g., whether it is home-toschool or school-to-home transportation, whether the trip will cross state lines).

15NHTSA and FMCSA do not have independent authority to seek changes in state police 

reports; however, on a voluntary basis, most states have begun collecting a similar 

minimum core of information in their police crash reports. See GAO-13-24. These core 

elements are outlined in voluntary guidelines called the Model Minimum Uniform Crash 

Criteria, which includes a school-bus-related data element. 

State Crash Data
Page 10 GAO-17-209 School Bus Safety

operations differs.16 In our survey of states, about half of states that 

responded (22/47) reported that they track whether school buses are 

district operated or contracted, though least often in crash data. States 

most commonly reported tracking the type of operator in funding or 

reimbursement data (15), followed by inspection data (10), and statewide 

crash data (7).17 We asked these states why they tracked the type of 

operator, and states reported doing so most often for funding purposes 

(18), followed by compliance with state contracting laws (10), and 

educational or training purposes (7). For example, in its inspection data, 

New York state officials said they track the type of school bus operator 

along with several other variables that allow the state to analyze data on 

inspection outcomes, such as the number of buses passing inspection or 

being placed out of service, to see if there are different outcomes across 

these variables. For the 25 states that reported they do not track whether 

school buses are school-district or contractor operated, states nearly 

always indicated there was no need or requirement to track such data. 

For example, 17 states said there is no distinction made in state law or 

regulation on the type of operator.18 Three states also reported that there 

are no contractors operating school buses in the state because school 

districts choose not to use them, so there is no need to track such 

information.

The Transportation Research Board noted in 2002 that fatalities and 

injuries involving students make up a relatively small proportion of all 

fatalities and injuries, so the benefits of additional data collection efforts 

that focus solely on school travel should be carefully considered before 

being recommended or implemented.19 Stakeholders we interviewed had 

 16Our focus was whether states tracked type of operator in crash data, but we also asked 

whether the states tracked type of operator in other types of databases to understand 

whether this was a data element that states defined or tracked at all.

17We asked states whether they tracked the type of operator in each of these types of 

databases or systems, so states could report that they tracked this information in more 

than one dataset. In addition, three states responded that while they don’t specifically 

track the type of operator in a database, they could use information available in their 

systems to differentiate between types of operators, if needed. 

18In addition, 11 states said there is no need or purpose to track this data and 16 states 

said there is no requirement to track the data. Two states said there is a lack of staff 

resources to collect such data. States were able to select more than one reason for not 

tracking the type of operator.

19Transportation Research Board. Special Report 269: The Relative Risks of School 

Travel (Washington, D.C.: 2002.)
Page 11 GAO-17-209 School Bus Safety

mixed views on whether data improvements should be a priority for the 

federal government. For example, one stakeholder said that the federal 

government could create a repository for national school-bus data that 

would require standardized methods of data collection by the states and 

that the resultant data would help illuminate key areas of school bus 

safety, such as illegal passing of stopped school buses, that are not 

currently being highlighted. However, another stakeholder we 

interviewed, who believes national data is lacking, said examining and 

collecting additional crash data for other modes of transportation may be 

more revealing than it would be for school buses, given the safety record 

of school buses. School buses continue to have a strong safety record 

relative to other types of motor vehicles based on more recent fatal crash 

data, which we discuss in more detail below. According to NHTSA, only 8 

percent of fatalities in crashes involving a school bus from 2005 to 2014 

were school bus occupants (i.e., drivers or passengers).20 We also found 

that school bus crashes constituted less than 1 percent of all crashes in 6 

of our selected states for which annual crash reports included a section 

on school bus crashes.21

NHTSA and FMCSA officials we interviewed said the agencies have no 

plans to change their data collection processes specific to school bus 

crashes, but both have efforts under way to improve the overall quality of 

crash data. For example, FMCSA is in the process of establishing a 

working group, as required in the FAST Act, to examine the information 

collected in police accident reports on commercial motor vehicles, a 

process that could lead to improvements in the data collected on crashes 

involving large trucks and buses.22 Also, if funding is available, NHTSA 

officials said the agency plans to analyze states’ reporting requirements 

for school bus crashes in fiscal year 2017. This analysis would identify 

sources of crash data and whether these sources provide reliable 

 20For the 110 school-bus-occupant fatalities from 2005 to 2014, 46 were drivers and 64 

were passengers. Of the remaining fatalities in crashes involving school buses, 71 percent 

were occupants of other involved vehicles and 21 percent were pedestrians and other 

non-occupants. 

21We examined crash data for 2014, the most recent year for which data was consistently 

available for the states at the time of our research; for one state, 2013 data was the most 

recent available. 

22Pub. L. No. 114-94, § 5306(a), 129 Stat. 1312, 1544 (2015). According to FMCSA, the 

Department of Transportation is in the process of creating a federal advisory committee to 

conduct this work.
Page 12 GAO-17-209 School Bus Safety

information that could be used to determine causative factors and 

examine potential countermeasures for all reported school bus crashes.

Additionally, states play a primary role in overseeing school bus safety, as 

described later in this report, and states have their own mechanisms to 

use state crash data to identify and use federal grant programs to 

address highway safety issues in their state. NHTSA and FMCSA have 

grant programs whereby each state identifies its priorities for highway and 

motor carrier safety, respectively. For example, for NHTSA’s Highway 

Safety Grant Program, each state must develop a Highway Safety Plan 

based on an evaluation of highway safety data, including crash data, to 

identify safety problems within the state.23 Therefore, if a state identifies a 

need for initiatives to improve school bus safety and has jurisdiction, the 

state could include it as a priority in its grant application and target federal 

and state spending for related initiatives. NHTSA and FMCSA said that, 

at present, no states identified school bus safety as a priority area in 

applications for the State and Community Highway Safety Grant Program 

or Motor Carrier Safety Assistance Program.24

While national data on school bus crashes are limited, from 1999 to 2010 

UMTRI collected BIFA data, with support from FMCSA; however, these 

data are no longer collected.25 BIFA data supplemented FARS data with 

detailed information collected through interviews and from police accident 

reports about the physical configuration and operating authority of each 

bus involved in a fatal crash, including the type of operator. For this 

report, we analyzed BIFA data for 2000 to 2010 to describe 

characteristics of fatal crashes involving school buses during that time 

period. However, for variables included in BIFA data that originated in 

FARS data, we also analyzed data from FARS for fatal crashes involving 

school buses for 2011 to 2014 to provide more recent information as 

BIFA data were only collected through 2010. Since this analysis 

examined data on fatal crashes involving school buses, it is not 

generalizable to all types of crashes involving school buses. Further, we 

did not have exposure data (e.g., vehicle miles traveled by school buses 

 2323 U.S.C. § 402.

2449 U.S.C. §§ 31102-31104.

25According to FMCSA officials, the agency’s funding support for BIFA ended in 2011. 

Fatal Crashes Involving 

School Buses Constitute a 

Very Low Percentage of 

All Fatal Motor Vehicle 

Crashes
Page 13 GAO-17-209 School Bus Safety

of different types or used for different types of trips) to allow us to report 

rates of crashes for the characteristics we examined.

We found that from 2000 to 2010, an average of 118 fatal crashes 

involving a school bus occurred each year. The total number per year 

ranged from 93 (2009) to 128 (2008). When we extended our analysis to 

include 2011 to 2014, the average fell slightly to 115 fatal crashes each 

year, which is 0.3 percent of the 34,835 fatal motor-vehicle crashes that 

occurred on average each year during this time. Most fatal crashes 

involved local travel and occurred during times that would indicate the 

buses were traveling to and from school, according to our analysis. For 

2000 to 2010, most fatal crashes (89 percent) were considered local, 

meaning the total trip distance was less than 50 miles. Seventy-four 

percent of fatal crashes from 2000 to 2010 occurred during home-toschool and school-to-home travel times.26 From 2011 to 2014, this 

percentage fell to 65 percent of fatal crashes, with the remainder of fatal 

crashes occurring during other times (see fig. 2).27

 26No variable identified the type of school bus transportation. We approximated crashes 

for home-to-school and school-to-home transportation by looking at the day and time of 

the crash, specifically crashes occurring Monday through Friday, from September 1 to 

June 15, during 6:00-8:59am and 2:00-4:59pm.

27From 2000 to 2014, 72 percent of fatal crashes occurred during home-to-school and 

school-to-home travel times.
Page 14 GAO-17-209 School Bus Safety

Figure 2: Number of Fatal Crashes Involving School Buses, by Travel Time, 2000–2014

Our analysis of BIFA and FARS data also examined driver and vehicle 

factors that may have contributed to the fatal school bus crashes and 

found such factors were not prevalent.28

• Driver-related factors: The data on fatal school bus crashes from 2000 

to 2014 identified a driver-related factor involving the school bus driver 

for 27 percent of these crashes (see fig. 3). The most common type of 

driver-related factor was miscellaneous (e.g., leaving vehicle 

unattended with engine running, failing to keep in the proper lane), at 

68 percent of all driver-related factors. The next most common 

category, identified for 12 percent of driver-related factors, was 

physical or mental condition (e.g., careless driving, reaction to or 

failure to take drugs or medications). In 8 percent of fatal crashes from 

both 2000 to 2010 and 2011 to 2014, the school bus driver was 

 28We only examined factors related to the school bus driver and school bus vehicle. For 

the fatal crashes, there may be driver- or vehicle-related factors for the other involved 

vehicles.
Page 15 GAO-17-209 School Bus Safety

charged with a violation. The most common type of violation fell under 

either the “rules of the road” turning, yielding, and signaling category 

(e.g., failure to signal for a turn or stop) or the reckless/careless/hitand-run category (e.g., inattentive, careless, improper driving), 

representing 36 and 32 percent of all violations, respectively.

Figure 3: Fatal School Bus Crashes by Type of Driver-Related Factors, 2000–2014

Note: We only examined driver-related factors for the school bus vehicle involved in the fatal crash 

and not for other involved vehicles. More than one factor could be noted for a driver in a fatal crash.

• Vehicle-related factors: Vehicle-related factors involving the school 

bus were rarely cited in fatal crashes involving school buses. Of the 

1,731 total fatal crashes from 2000 to 2014, only 5 crashes had an 

identified vehicle factor for the school bus—3 for brakes, 1 for tires 

and wheels, and 1 for other components.29

Examining other vehicle and crash characteristics, we found that about 80 

percent of fatal crashes involved large school buses (type C or D)—which 

account for most bus sales, according to in recent sales data—and 6 

percent involved small school buses (type A or B), with the remainder 

 29Across all years, 31 crashes were coded as unknown for vehicle-related factors. 
Page 16 GAO-17-209 School Bus Safety

unknown or of another body type. Seven percent of buses involved in 

fatal crashes during this time were classified as special needs school 

buses.30 In addition, the average age of the school buses in fatal crashes 

from 2000 to 2010 was 7 years; the average age for school buses in fatal 

crashes rose slightly to 8 years for 2011 to 2014.31 Most of these crashes 

occurred on dry roads (81 percent) and in clear weather conditions (85 

percent) for both the 2000 to 2010 and 2011 to 2014 time period.

We found that school districts operated 67 percent of school buses 

involved in fatal crashes from 2000 to 2010, and contractors working for 

school districts operated 25 percent of school buses involved in these 

fatal crashes, which is roughly proportional to the operations conducted 

by districts and contractors.32 We found no definitive national data on the 

number of each type of operator or the miles driven by each type of 

operator, so we cannot directly compare the rates of fatal crashes for 

each type of operator. However, the percentage of fatal crashes involving 

buses operated by school districts and contractors roughly aligns with 

industry association estimates of operations conducted by each type of 

operator. One association estimates that contractors provide one-third of 

pupil transportation services in the United States. An official from another 

association estimated the extent of contracting in two ways: first, by 

number of buses (contractors operate about one-third of school buses); 

second, by the number of operations (contractors conduct about onefourth of school bus operations).33 We also examined the share of fatal 

 30Since we do not have exposure data on school bus trips, we do not know what percent 

of all school bus trips are specifically for special needs transportation to put this number in 

context. 

31To analyze the age of school buses for each year of BIFA data, we sorted the bus for 

each crash into categories by model year of the school bus (e.g., 1985 and older, 1986-

1990, etc.). We then used the mid-point of the range to estimate the average age of all 

school buses for each year. For the 1985 and older category, we used 1985 as the basis 

for estimating the age of buses in that category. While this could underestimate age, only 

29 of 1,731 buses fell into this category from 2000 to 2014.

32We identified public-school-district and contractor-operated buses using a variable that 

described the type of operating authority. The remaining 8 percent of school buses were 

operated by other entities, such as a private school or a charter school, or it was not clear 

whether the operator was a public school district or contractor transporting students for a 

public school district. 

33A proxy in FARS data for contractors operating school buses is whether a bus has a 

motor carrier identification number. Twenty-one percent of buses in fatal crashes for 2000 

to 2014 had a motor carrier identification number, and another 4 percent of buses were 

coded as “not reported” meaning that it was expected the vehicle would have a number 

but a state’s crash report didn’t have a field for or a narrative containing the information. 
Page 17 GAO-17-209 School Bus Safety

school bus crashes with driver- or vehicle-related factors, by type of 

operator, and did not find any major deviations from the overall 

percentage of fatal crashes involving school-district and contractoroperated school buses.

Federal laws and regulations establish minimum requirements for school 

bus safety. Building on federal requirements, states establish more 

comprehensive safety requirements for school bus vehicles and 

operations. We found that all 50 states require school bus inspections, 

and most states also require driver training. However, fewer states 

require a specific maximum vehicle age or seating capacity for school 

buses. While state requirements build on federal laws and regulations, 

the specific requirements states set for school bus safety vary.

The same two federal agencies that collect crash data set minimum 

safety regulations for school bus vehicles and operations.

• NHTSA sets Federal Motor Vehicle Safety Standards (vehicle safety 

standards) that create a baseline for school bus standards. Forty-eight 

out of 62 vehicle safety standards apply to new school buses, 

according to NHTSA.34 For example, Federal Motor Vehicle Safety 

Standard No. 217 establishes standards for emergency exits and 

window retention and release, and Federal Motor Vehicle Safety 

Standard No. 221 specifies requirements for the strength of the body 

panel joints in the bodies of school buses. NHTSA has reported that 

new school buses have to meet more vehicle safety standards than 

any other type of new motor vehicle. All manufacturers of new motor 

vehicles and equipment must certify compliance with vehicle safety 

standards; therefore, school buses operated by school districts and 

contractors all must meet these federal standards.

• FMCSA is responsible for setting and enforcing Federal Motor Carrier 

Safety Regulations that apply to large commercial truck and bus 

operations. However, FMCSA’s safety oversight of school bus 

operations is limited because most school bus transportation is 

exempt from its safety regulations. In particular, all school bus 

 34Of the 48 vehicle safety standards that apply to school buses, 17 apply only to small 

school buses that weigh 10,000 pounds or less, according to NHTSA. The remaining 31 

standards apply to all school buses. 

Federal Laws and 

Regulations Set a 

Baseline for School 

Bus Safety, upon 

which State Laws and 

Regulations Build

Federal Regulations Lay 

the Groundwork for School 

Bus Safety and Can Differ 

Based on the Type of 

Operator
Page 18 GAO-17-209 School Bus Safety

transportation to and from home and school is exempt.35 Beyond 

home-to-school and school-to-home transportation, the type of 

operator—whether it is a private contractor or a school district or other 

governmental entity—and the type of trip—including whether the trip 

will cross state lines—determine whether all Federal Motor Carrier

Safety Regulations apply. For example, contractors hired to provide 

interstate transportation for extracurricular activities, such as field trips 

or sporting competitions, are required to comply with other Federal 

Motor Carrier Safety Regulations such as limits on driving and on-duty 

time.36 School district employees are exempt from these 

requirements. However, even with these exemptions, federal 

regulations for commercial drivers’ licenses and drug and alcohol 

testing for commercial driver’s license holders apply to all school bus 

drivers and operators. Figure 4 provides examples of federal 

regulations for school bus safety.

 35Federal Motor Carrier Safety Regulations, which apply to commercial motor vehicles, 

exempts “school bus operations”—the use of a school bus to transport only school 

children and/or school personnel from home to school and from school to home—with 

some exceptions, noted below. 49 C.F.R. §§ 390.3(f)(1). The exemption for school bus 

operations is part of a statutory exemption for transportation performed by employees and 

employers that are part of the federal government, a state, or any political subdivision of a 

state. 49 U.S.C. § 31101(2) and (3). School bus drivers, however, are subject to federal 

regulations that prohibit a commercial driver from operating a commercial vehicle while 

using a hand-held mobile telephone or texting while driving, and provide for 

disqualification periods for convictions of these provisions. 49 C.F.R. §§ 391.15(e), 392.80 

and 392.82.

36In these cases, contractors are subject to additional Federal Motor Carrier Safety 

Regulations as part of their commercial operations. The scope of our review focused on 

inspections, driver training, and specific vehicle requirements and did not include such 

other regulations. 
Page 19 GAO-17-209 School Bus Safety

Figure 4: Examples of Federal Laws and Regulations and Department of Transportation Oversight Agencies for School Bus 

Safety

Note: FMVSS No. 220, which specifies school bus rollover protection requirements, and FMVSS No. 

221, which specifies requirements for the strength of the body panel joints in the bodies of school 

buses, are two other standards that are specific to school buses. These vehicle standards are part of 

the 48 federal vehicle standards that apply to new school buses.

Within federal laws and regulations for school bus operations and 

vehicles, we specifically examined what federal requirements exist for 

school bus inspections, driver training, and maximum vehicle age and 

seating capacity. While many federal requirements, like vehicle standards 

for school buses, apply to both school districts and contractors, some 

federal requirements apply to only certain types of school transportation.

FMCSA’s safety regulations require inspections of commercial motor 

vehicles. However, most school bus operations are exempt from this 

requirement, as noted above. Federal Motor Carrier Safety Regulations 

School Bus Inspections
Page 20 GAO-17-209 School Bus Safety

require other types of commercial operators to systematically inspect, 

repair, and maintain vehicles under their control, requirements that 

include inspecting service brakes, the steering mechanism, lighting, and 

tires, among other components. For inspections, commercial operators 

must conduct periodic (at least annual) vehicle inspections, which could 

be conducted in-house, at a commercial business, or through a state-run 

inspection program.37 Therefore, a contractor’s school-bus operations 

may be subject to this federal inspection requirement if, for instance, the 

contractor is hired by the school district to transport students across state 

lines for school-sponsored extracurricular activities; a school district’s 

school-bus operations would not be subject to the federal inspection 

requirement if the district provides the transportation for this type of trip. 

Representatives of contractors we spoke with stated that in practice, most 

contractors usually comply with Federal Motor Carrier Safety Regulations, 

even when they are not using the school buses for interstate activities, as 

contractors want the flexibility and maximum ability to operate buses 

under different circumstances, such as chartered services on the 

weekend.38 NHTSA does not have an oversight role in school bus 

operations but recommends that states establish procedures for regularly 

scheduled inspections of school buses in accordance with FMCSA’s 

requirements, as described above.39

FMCSA recently established minimum training regulations for entry-level 

school bus drivers. In December 2016, FMCSA issued a final rule 

requiring all drivers—employed by school districts and contractors—to 

complete entry-level driver training when applying for a commercial 

 3749 C.F.R. § 396.17. Federal regulations set out qualifications for inspectors (49 C.F.R. § 

396.19) as well as roadside inspections and inspections done through a mandatory state 

inspection program to meet the periodic inspection requirement.

38Depending on state requirements, contractors and school districts may be subject to a 

state’s adoption of federal regulations for intrastate operations, particularly for 

extracurricular school transportation. For example, in one of our selected states, all school 

buses are included in the state’s definition for commercial motor vehicles, and thus, all 

operators—contractors and school districts—are subject to the state’s safety regulations, 

including those for inspections. However, another of our selected states adopted Federal 

Motor Carrier Safety Regulations in such a way that requirements for inspections apply to 

contractors when conducting intrastate transportation for extracurricular activities.

39NHTSA, Highway Safety Program Guideline No. 17, Pupil Transportation Safety

(Washington, D.C.: March 2009.)

Driver Training
Page 21 GAO-17-209 School Bus Safety

driver’s license, including those seeking a school bus endorsement.40 As 

part of this final rule, FMCSA established a training curriculum to address 

the specific training needs of school bus drivers. Training providers are 

required to cover all topics in the curriculum, including loading and 

unloading, railroad-highway grade crossings, and emergency exit and 

evacuation, but FMCSA set no minimum hours for the knowledge and 

behind-the-wheel training for the school bus endorsement. Additionally, 

NHTSA developed a series of refresher (i.e., in-service) training modules 

for school bus drivers in 2011.41 NHTSA officials told us they developed 

this training module because school bus stakeholders often asked 

NHTSA for guidance and assistance on training experienced school-bus 

drivers. Stakeholders we interviewed, including selected state officials, 

told us that they widely use NHTSA’s refresher training materials for 

school bus drivers.

As previously noted, 48 federal vehicle safety standards apply to school 

buses. However, federal vehicle safety standards do not stipulate a 

maximum vehicle age or maximum seating capacity for school buses 

because, according to NHTSA, it does not have regulatory authority 

regarding how school buses are used. Nevertheless, NHTSA has made 

recommendations and issued guidance related to both of these items. In 

its pupil transportation guideline, issued in March 2009, NHTSA 

recommended replacing school buses manufactured before April 1, 1977, 

with school buses that meet current vehicle safety standards for buses 

and recommended prohibiting schools from purchasing school buses built 

prior to April 1, 1977, for school transportation.42 For capacity, NHTSA 

has reported in information posted on its website that school bus 

manufacturers determine the maximum number of persons who can sit on 

a school bus seat, which is based on sitting three small elementary age 

school children or two high school age persons into a typical 39-inch 

school-bus seat. In this same posting, NHTSA also reported that states 

 4081 Fed. Reg. 88732 (Dec. 8, 2016). Pursuant to federal regulations, states issue 

commercial driver’s licenses according to different licensing classifications. School bus 

drivers generally receive a class B or C license and must have additional passenger and 

school bus endorsements, which consists of passing knowledge and skills tests in 

passenger and school bus safety. The rule is effective February 6, 2017, and has a 

compliance date of February 7, 2020.

41According to NHTSA officials, the agency plans to update the training, if needed, in 

fiscal year 2017, after consulting with school-bus industry stakeholders regarding the 

potential need to update the training.

42NHTSA is currently working to update this guideline, according to NHTSA officials.

Vehicle Standards for 

Maximum Age and Capacity
Page 22 GAO-17-209 School Bus Safety

and school bus operators are responsible for determining the number of 

persons who can safely fit into a school bus seat, and NHTSA 

recommended that all passengers be seated entirely within the confines 

of the school bus seats while the bus is in operation. NHTSA sets vehicle 

safety standards, and FMCSA does not have a role setting vehicle 

standards for school buses.

States build upon federal laws and regulations and usually set additional, 

state-specific requirements for school bus safety that generally apply to 

both school districts and contractors, according to stakeholders we spoke 

with. We found that multiple state agencies often play a role overseeing 

school bus vehicles and drivers. For example, in Illinois, the State Board 

of Education and Secretary of State oversee school bus driver training, 

and the Department of Transportation oversees school bus inspections, 

while in Pennsylvania the Department of Transportation oversees school 

bus driver training and the State Police oversees school bus inspections. 

In addition, state laws and regulations vary widely across states. For 

example, three school bus manufacturers we spoke with told us that no 

two states have the same vehicle standards for school buses, with 

varying requirements for eight-way flashing signal lights, content and 

location of first aid kits, and location of switch panels, among other things. 

Figure 5 describes examples of state requirements for school bus 

transportation.

Building on Federal 

Requirements, States Set 

Requirements for School 

Bus Safety That Vary by 

State but Generally Not by 

Type of Operator
Page 23 GAO-17-209 School Bus Safety

Figure 5: Examples of State Requirements for School Bus Safety

Upon examination of state laws and regulations, we found that states set 

requirements for inspections, driver training, and vehicle standards that 

supplement the baseline federal requirements. States’ school-bus safety 

requirements vary widely across states but tend not to differ based on the 

type of operator, according to all eight selected state officials we spoke 

with, as described below. Four other stakeholders we interviewed 

affirmed that there are no differences in state requirements for school bus 

transportation for different types of operators. However, for state 

requirements for commercial motor vehicles, which can apply to but are 

not specific to school buses, six stakeholders we interviewed, including 

manufacturers and contractors, said there are some differences in 

requirements for contractors and school districts. For example, two 

stakeholders commented that states vary in the extent to which they 

exempt school bus operations from state requirements for commercial 

motor vehicles, requirements that are not school-bus-specific but apply to 

a wider range of vehicles and that are similar to Federal Motor Carrier 
Page 24 GAO-17-209 School Bus Safety

Safety Regulations.43 See appendix II for additional descriptions of state 

requirements for school bus inspection, driver training, and maximum 

vehicle age and seating capacity in the eight selected states.

Based on our review of laws and regulations in the 50 states, we found 

that all 50 states require school bus inspections to check for defects and 

safety compliance with state rules at the state or local level.44 We also 

found that the frequency of these inspections and agency conducting or 

overseeing inspections varies across states. For 41 states, we found that 

the state required periodic inspections of school buses to be conducted 

by state inspectors or third-party inspectors. For example, California 

requires its state highway patrol to inspect school buses at least once 

every year,45 while the Illinois state transportation agency requires 

certified, private inspection stations to inspect school buses at least twice 

a year.46 In the other nine states, we found the state requires local school 

districts to conduct inspections and/or authorizes the state to conduct 

spot check inspections of school buses without any set frequency. For 

example, Nebraska requires local school districts to conduct an 

inspection of each school bus before the start of the school year and then 

every 80 days during the school year.47 According to a Nebraska state 

official, the state discontinued its state school bus inspection program due 

to resource constraints and delegated responsibility for inspections to 

local school districts. State officials in all eight selected states told us that 

all school bus operators, including contractors, are subject to the state’s 

school-bus inspection requirements.

States may also require additional inspections to supplement the periodic 

inspections, including conducting random or unannounced inspections. 

Officials from four of the eight states we interviewed—Illinois, 

 43For example, one stakeholder told us that contractors in some states are subject to 

stricter qualification requirements to be a school bus driver and more training; therefore, a 

contractor generally has to meet a higher bar than school districts.

44This and other counts of state requirements in this section are based on our search of 

state laws and regulations in a legal database. Our search sought to identify state 

requirements and did not seek to identify any local safety requirements. Therefore, there 

may be requirements that our search did not find for school bus inspections, driver 

training, and vehicle standards. For more information on our search, see appendix I.

45CAL. VEH. CODE § 2807(a) (2016).

46625 ILL. COMP. STAT. 5/13-109(a) (2016).

47NEB. ADMIN. R. & REGS. Title 92, Ch. 93 (2016).

School Bus Inspections
Page 25 GAO-17-209 School Bus Safety

Washington, Tennessee, and Pennsylvania—stated that they 

complement annual or biannual inspections with unannounced or random 

school-bus inspections. For example, a Tennessee state official told us 

that the state conducts random inspections of school buses for at least 10 

percent of the statewide school-bus fleet annually to ensure that all 

operators maintain their buses safely and appropriately. States may also 

require even more frequent inspections, sometimes on a daily basis. For 

example, California requires all school bus operators to inspect their 

school buses regularly—every 45 days or 3,000 miles, whichever occurs 

first—as part of a preventive maintenance program.48

To provide context to understand how states implement these 

requirements and the results of inspections, we asked the selected states 

about the data they collect on inspection outcomes. The selected states 

vary in how they collect and maintain inspection data and the extent to 

which results are accessible to the public, as was the case with the 

frequency of inspections. Officials from selected states told us there are 

different methods of collecting and compiling inspection results. For 

example, a Tennessee state official told us that the state uses electronic 

devices (e.g., tablets, laptops) to collect data during inspections and 

maintain results in a central database. Illinois state officials told us that 

private, certified inspection stations can use an electronic or paper form to 

document inspection results, and all completed forms are maintained by 

the state. Given these differences, states vary in their ability to easily 

search and summarize inspection results for school buses in the state. 

We found school bus inspection results are generally accessible to the 

public, but how the public can access results varies. For instance, 

Washington posts the number of school buses inspected and the number 

and percentage of buses placed out of service by school district each 

school year on its state agency website, while Pennsylvania and 

Tennessee state officials told us that school bus inspection results are 

accessible only through a formal request.49

Additionally, in our review of selected states’ school-bus inspection 

results, we found that a relatively small number of school buses were 

placed out of service after an inspection because they were determined to 

 48CAL. CODE REGS. tit. 13, § 1232 (2016).

49In several selected states, each school bus receives a sticker indicating whether the bus 

passed inspection. According to one state official, these stickers allow the public to see 

when a school bus in operation last received and passed an inspection.
Page 26 GAO-17-209 School Bus Safety

be unsafe to operate without repairs. Specifically, 3 to 5 percent of 

inspected school buses in a given year were put out of service for 

violations, based on data from four of our selected states, as shown in 

table 1 below.50 By contrast, the out-of-service rate for all types of buses 

nationwide is about 7 percent, according to FMCSA. Problems that could 

put a school bus out of service in one state we interviewed include any 

leaks on the exhaust system, an exterior brake or stop-arm light that 

doesn’t work, or a bus alarm not sounding when the emergency door is 

opened. In three states, the most common problems identified during 

inspection involved brakes, lights or signals, and exhaust systems. 

Officials we spoke with in the six selected states that had state inspection 

programs stated that out-of-service school buses cannot be operated until 

the identified problem has been fixed and the bus passes another 

inspection.

Table 1: Selected States’ School Bus Inspection Results

Source: GAO analysis of state data. | GAO-17-209

We found that a majority of states require training for all school bus 

drivers.51 Specifically, we found that 44 states require entry-level (i.e., 

pre-service) training and 44 states require refresher training for all school 

bus drivers.52 However, as with inspection requirements, we found that 

the frequency, length, and other attributes of the required training vary 

across states. For example, Pennsylvania requires a minimum of 20 

 50The remaining four selected states either do not centrally collect inspection results or it 

would have required significant state resources to search and summarize results.

51For school bus drivers, the scope of our review focused on state requirements for driver 

training. However, states may set additional requirements for drivers. According to officials 

in selected states, additional requirements can include passing federal and state criminal 

background checks, annual or biannual medical exams, CPR training, and physical 

performance or agility tests, such as exiting the bus through the back emergency exit in 20 

seconds and dragging 120 pounds down the bus aisle.

52We found that 40 states required both types of training, 4 states only required entry-level 

training, and 4 states only required refresher training.

States

Total number of school buses 

inspected in most recent available year

Total number of out-ofservice school buses

California Calendar year 2015: 23,242 770 (3%)

New York State fiscal year (April 1, 2015, to 

March 31, 2016): 97,163

5,172 (5%)

Tennessee June 2015 to June 2016: 16,071 415 (3%)

Washington 2015-2016 school year: 12,773 491 (4%)

Driver Training
Page 27 GAO-17-209 School Bus Safety

hours of school-bus-specific training for all entry-level drivers and a 

minimum of 10 hours of refresher training for drivers every 4 years.53

Tennessee requires all school bus drivers to receive at least 4 hours of 

annual refresher training on various topics, including operational safety of 

school buses, loading and unloading of students, and managing student 

behavior, but the state does not require entry-level school-bus driver 

training, according to a Tennessee state official. While the training 

requirements vary across states, officials from all eight of our selected 

states stated that all school bus drivers must meet state training 

requirements, whether they are employed by a school district or 

contractor.

States administer school bus driver training in different ways, and 

additional training requirements may exist at the local level. For example, 

in Virginia and New York, the state departments of education oversee 

school bus driver training programs and train and certify instructors, who 

can be school district or contractor employees, to provide training to 

drivers. In Nebraska, the state department of education contracts with the 

Nebraska Safety Center at the University of Nebraska to develop training 

curriculum and train instructors to provide training. Beyond state 

requirements, local school districts and contractors may have additional 

training programs and requirements for school bus drivers. Contractors 

we spoke with told us that they also require entry-level and refresher 

training for their drivers that meets or exceeds state requirements. State 

officials in California, Pennsylvania, and Tennessee also told us that local 

school districts may require additional, supplemental training for drivers. 

For example, a state official told us that one large school district requires 

drivers to complete a minimum of 40 hours of gang awareness training.

Additionally, all eight selected states require school bus drivers to receive 

training on transporting students with special needs. Drivers in these 

states typically receive training on transporting special needs students as 

part of the training curriculum for entry-level or refresher training for 

school bus drivers. For example, in New York, under state law, entry-level 

school bus drivers are required to take a minimum of two hours of 

instruction related to transporting special needs students during the first 

year of employment, and all school bus drivers are required to take one 

hour of annual training related to transporting special needs students.54

 5367 PA. CODE § 71.5 (2016).

54N.Y. COMP. CODES R. & REGS. tit. 8, § 156.3(b)(5)(ii)(a) and (b) (2016).
Page 28 GAO-17-209 School Bus Safety

State officials in a few of our selected states said additional training on 

special needs transportation is provided to drivers at the local level. A 

Washington state official told us that the state trains all instructors on 

special needs transportation topics so the instructors can in turn provide 

more targeted training to drivers, such as how to secure wheelchairs on a 

particular bus model.

In our search of state laws and regulations, we found six states that set a 

requirement for the maximum vehicle age for when a school bus must be 

replaced or no longer used. The requirements in these six states varied. 

For example, Tennessee sets a maximum age for school buses that 

applies to school districts and contractors; specifically, type A and B 

buses can be used for up to 15 years, and type C and D buses can be 

used for up to 18 years with unlimited miles, or up to 19 years for buses 

with less than 200,000 miles that have passed inspections twice a year.55

According to a state official, Tennessee has a maximum vehicle age 

requirement because older school buses may not be cost-effective to 

maintain, as older vehicles have more mechanical and maintenance 

issues. In other states, all types of school buses were subject to the same 

maximum age, such as stating that school buses used to transport 

students cannot be more than 20 or 25 years old.

In addition to these six states with specific requirements, we also found 

instances where states provide funding or set a school bus depreciation 

schedule to replace school buses. Although these programs do not 

necessarily prohibit school bus operators from operating school buses 

that exceed the parameters of a state’s funding program, they encourage 

school districts to regularly replace school buses. For example, according 

to a state official, Washington provides replacement funding for school 

buses to school districts and contractors, and the state established a 

useful life cycle for each type of school bus, but the state does not require 

school districts and contractors to retire or stop using a bus at the end of 

the established life cycle. Washington sets an 8-year life cycle for type A 

buses and a 13-year life cycle for type C and D buses owned by the 

 55TENN. CODE ANN. § 49-6-2109, TENN. COMP. R. & REGS. ch. 0520-01-05-.01 (2016). 

School buses older than 15 years are subject to biannual inspections, according to a 

Tennessee official.

Vehicle Standards for 

Maximum Age and Capacity
Page 29 GAO-17-209 School Bus Safety

school district.56 In Virginia, the state has a 15-year life cycle for all school 

bus types, but according to state officials, a school bus older than 15 

years can continue to be used as long as it passes inspections.

While states do not typically set maximum school bus age requirements, 

local school bus operators usually make decisions on when to replace a 

school bus, according to stakeholders we interviewed. In particular, 

according to seven stakeholders we interviewed—3 manufacturers, 3 

state agencies that conduct inspections, and 1 contractor—local 

operators make these decisions based on a business case that includes 

factors such as maintenance costs and environmental conditions. 

Representatives from two school bus manufacturers we interviewed told 

us that most states do not have a maximum vehicle age requirement and 

that many school districts will continue to use buses as long as they pass 

inspections and maintenance costs are not too high. State officials from 

Washington and Virginia said school bus operators need to maintain any 

school buses that are used for longer than the state-established life cycle 

and that these buses must pass the state inspection.

With regard to school bus seating capacity, we found eight states that 

have a specific requirement for maximum seating capacity on school 

buses. Eight states set a specific maximum capacity or parameter that 

would yield a specific maximum capacity. For example, New York has a 

maximum seating capacity of 84 student passengers in type C and D 

school buses.57 We also found that about half of the states (23) had other 

types of seating capacity requirements, such as explicitly restricting 

school buses from transporting more student passengers than the

manufacturer’s rated seating capacity. For example, Illinois does not 

allow a school bus to be operated with more passengers than 

recommended by the manufacturer’s rated seating capacity.58

 56According to a Washington state official, the replacement system for school-districtowned vehicles provides enough funding to replace the bus at the end of the established 

life cycle. The state uses a different replacement system for contractor-owned buses, 

where it provides payments to the districts for school buses on a straight line depreciation 

based on the original cost of the buses.

57N.Y. COMP. CODES R. & REGS. tit. 17, § 720.4 (p)(2)(i) (2016).

58625 ILL. COMP. STAT. 5/12-707 (2016).
Page 30 GAO-17-209 School Bus Safety

Stakeholders from the school bus industry most commonly cited the 

National Congress on School Transportation (NCST) and its National 

School Transportation Specifications and Procedures as a source of 

leading practices for safe school bus transportation.59 Seventeen of the 

30 stakeholders we interviewed, including state directors of student 

transportation and manufacturers, identified NCST and the voluntary 

document as a national standard for school bus safety.60 An NCST official 

told us that the National School Transportation Specifications and 

Procedures is meant to build on federal laws and regulations and for 

states to consider when establishing their standards, specifications, 

regulations, and guidelines for school transportation.

NCST holds a congress roughly every 5 years. The primary purpose and 

product of the congresses is the specifications and procedures document

that contains recommendations across different aspects of student 

transportation, including school-bus body and chassis specifications, 

procedures for conducting school bus inspections, and selecting and 

training drivers. As the congress meets regularly, NCST has discussed 

new safety concerns or needed guidance and amended its specifications 

and procedures document accordingly. For example, one stakeholder we 

spoke with said a relatively recent change in the document was the 

inclusion of criteria, based largely on federal regulations, to use in a 

school-bus inspection program to determine when a school bus should be 

placed out of service.

Stakeholders also cited federal and state requirements and industry 

associations and experts as sources of leading practices. Eleven of 30 

stakeholders we spoke with identified state laws and regulations, while 10 

stakeholders identified federal laws and regulations and industry 

associations as sources they turn to for leading practices. Eight 

stakeholders also mentioned federal guidance as sources of best 

practices for school bus operations and inspections. For federal guidance, 

two stakeholders mentioned they look to NHTSA’s Highway Safety 

Program Guideline No. 17, Pupil Transportation Safety, which 

recommends strategies for a school bus safety program at the state level. 

For example, this guideline recommends developing a training plan for 

 59NCST consists of representatives of state agencies responsible for administering 

student transportation, school district officials, contract operators, and representatives 

from other professional organizations and groups.

60We did not ask four of the 30 stakeholders to identify leading practices as the question 

did not apply (e.g., focus of interview was sources of school bus crash data).

Stakeholders 

Identified Voluntary 

Industry Standards as 

a Primary Source of 

Leading Practices, 

and Work Is Under 

Way in Areas Where 

Stakeholders Most 

Often Said Additional 

Federal Guidance 

Would Be Useful
Page 31 GAO-17-209 School Bus Safety

drivers and establishing a systematic preventive-maintenance program 

for school buses that includes periodic vehicle inspections.

Our literature review identified these same sources and also provided 

general practices for states and local school districts and contractors to 

follow. For example, we found NCST’s specifications and procedures 

document, NHTSA’s Highway Safety Program Guideline No. 17, and 

textbooks that often cited federal vehicle safety standards and FMCSA’s 

safety regulations in our literature research. In our review of these 

sources, including NCST’s specifications and procedures document, we 

found recommended practices for maintaining school buses, including 

establishing an inspection program with uniform criteria for placing school 

buses out of service and analyzing the intended life cycle of school buses 

with ongoing efficiencies associated with vehicle replacement.

A few stakeholders we spoke with indicated that specific, national leading 

practices for certain aspects of school bus transportation may not always 

be appropriate, as school bus operations are driven by local or regional 

factors such as available funding and environmental and geographic 

conditions. For example, stakeholders we spoke with said that different 

factors, like weather and road conditions, can contribute to how long a 

school bus should remain in use. Three stakeholders, including a 

manufacturer, noted that school buses operating in adverse road and 

weather conditions in some states may need to be replaced more 

frequently due to higher maintenance costs. A 2002 National Association 

of State Directors of Pupil Transportation Services (NASDPTS) report 

noted that accurate and thorough records on operating and maintenance 

costs of a school bus fleet provide data needed to analyze and 

understand costs and said that establishing school bus replacement 

policies are important.61 As noted earlier, states and local districts largely 

oversee school bus safety, and as such, school bus transportation is 

subject to local district decisions, practices, and differences in operations.

When we asked stakeholders what additional federal research and 

guidance would benefit the school bus industry, there was no consensus 

among the stakeholders. Seven of thirty stakeholders said current federal 

 61NASDPTS represents state directors responsible for student transportation in all 50 

states. NASDPTS works with federal agencies that influence student transportation and 

other school bus industry associations at the state and national level. The 2002 report also 

suggested, under normal operating conditions, anticipated lifetimes of 8- to 10-years for 

type A and B school buses and 12- to 15-years for type C and D school buses.
Page 32 GAO-17-209 School Bus Safety

research and guidance is sufficient and did not cite a need for additional 

guidance.62 For the two areas stakeholders mentioned most often, federal 

agencies have related efforts under way.

• Five stakeholders said data on or guidance to combat illegal passing 

of school buses would be useful. NASDPTS conducts an annual 

survey on illegal passing, whereby school bus drivers voluntarily count 

the number of vehicles that pass them when they stop to load and 

unload students. For each of the 5 years NASDPTS has collected this 

data, participating school bus drivers have observed more than 

74,000 instances of illegal passing on a single day.63 In 2000, NHTSA 

issued a best practices guide on reducing the illegal passing of school 

buses. Further, NHTSA officials told us that research on the 

effectiveness of using cameras to enforce laws on passing school 

buses is currently under way with data collected at multiple locations, 

to be completed in early 2018. Based on the results of this research, 

NHTSA officials said they may update the content of the best 

practices guide on reducing the illegal passing of school buses.

• Four stakeholders said that additional federal guidance on school bus 

driver training on various topics, including loading and unloading 

students and technology distraction, would be helpful. As previously 

mentioned, FMCSA recently established minimum training regulations 

for entry-level training for school bus drivers when applying for 

commercial driver’s license, and two school bus associations—

NASDPTS and the National School Transportation Association—were 

part of the negotiated rulemaking committee that helped develop the 

training regulations. Additionally, NHTSA’s 2011 refresher training for 

school bus drivers covers several topics, including loading and 

unloading students. NHTSA officials said they plan to update the 

content, if needed, after consulting with school-bus industry 

stakeholders in fiscal year 2017. 

Finally, NHTSA officials and stakeholders commented that the school bus 

industry is a close-knit community that keeps one another informed with 

 62We did not ask four of the 30 stakeholders to identify areas for federal guidance or 

research as the question did not apply; three of these stakeholders were federal agencies, 

as we instead asked them about current and future research on school-bus safety issues.

63NASDPTS encourages states and school bus drivers to track illegal passing of school 

buses for one day between March 1 and May 31 of each year and report the illegal 

passing data to NASDPTS. NASDPTS publishes the survey results in July to help inform 

back-to-school safety efforts for the upcoming school year. School bus drivers in about 30 

states participate in the survey each year. 
Page 33 GAO-17-209 School Bus Safety

conferences and networks across all levels of government. Stakeholders 

we spoke with said that much of the school bus industry’s awareness 

comes from annual forums and conferences at the state and national 

level. For example, the annual NASDPTS conference held in November 

2015 included sessions on incidents of dragging students in bus doors 

and FMCSA’s then proposed rule on entry-level driver training. Another 

stakeholder told us that they confer with state school transportation 

associations—state organizations of school bus drivers and transportation 

managers—to identify and address any school-bus safety issues in the 

state. In addition, NHTSA and FMCSA officials and one stakeholder told 

us that three of the national school bus associations meet annually with 

FMCSA and NHTSA to discuss various school-bus safety issues.

We provided a draft of this product to the Department of Transportation 

for comment. The Department of Transportation provided technical 

comments, which we incorporated as appropriate.

We are sending copies of this report to the appropriate congressional

committees, the Secretary of the Department of Transportation, and other 

interested parties. In addition, the report is available at no charge on the 

GAO website at http://www.gao.gov.

If you or your staff have any questions about this report, please contact 

me at (202) 512-2834 or flemings@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. GAO staff who made key contributions to this 

report are listed in appendix III.

Susan A. Fleming

Director,

Physical Infrastructure Issues

Agency Comments
Appendix I: Objectives, Scope, and 

Methodology

Page 34 GAO-17-209 School Bus Safety

The Fixing America’s Surface Transportation Act included a provision for 

GAO to conduct a review of school bus safety, including examining any 

differences in the safety performance of different types of school bus 

operators—that is, school districts and contractors—and what safety 

requirements apply to them.1 We examined: (1) data federal and state 

agencies collect on school bus crashes and the number and 

characteristics of fatal school-bus crashes that have occurred since 2000; 

(2) federal and state laws and regulations pertaining to school bus 

inspections, vehicles, and drivers, as well as state data on inspections’

outcomes; and (3) sources for leading practices for safe school-bus 

transportation, as identified by stakeholders and literature, as well as any 

areas where further federal guidance could be useful. As part of our work, 

we also examined whether there were differences for school-district and 

contractor-operated school buses in any of the above areas. Overall, we 

focused our review on the transportation of public K-12 students traveling 

to and from home and school and for extracurricular activities and not 

transportation of private school students.

To describe what data federal and state agencies collect on school bus 

crashes, we reviewed agency documents that describe or use National 

Highway Traffic Safety Administration (NHTSA) and Federal Motor 

Carrier Safety Administration (FMCSA) crash datasets, including the 2014 

FARS/NASS GES Coding and Validation Manual and Large Truck and 

Bus Crash Facts 2014. We interviewed NHTSA and FMCSA officials to 

understand what data each agency collects on school bus crashes and 

whether they track the type of operator involved in school bus crashes. 

We also asked about any planned or ongoing efforts to change or 

improve the data collected on school bus crashes. To understand crash 

data collected by states, we reviewed NHTSA guidance on crash data 

systems, primarily the Traffic Records Program Assessment Advisory. 

We also interviewed school-bus industry associations, the Association of 

Transportation Safety Information Professionals, and other stakeholders 

to identify national and state data on school bus crashes and to discuss 

the strengths and limitations of existing datasets.

We also administered an e-mail survey to the 50 state pupil-transportation 

directors to gather information on school bus data. Specifically, the survey 

asked whether states systematically collect data on the type of school bus 

 1

Fixing America’s Surface Transportation Act, Pub. L. No.114-94, § 5511, 129 Stat. 1312, 

1556 (2015).

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 35 GAO-17-209 School Bus Safety

operator—that is, school district or contractor—in crash or other data, and 

the reasons why these data were or were not collected.2 We obtained 

contact information for the survey recipients from the National Association 

of State Directors of Pupil Transportation Services (NASDPTS) and 

administered the survey between June 20, 2016, and August 8, 2016. 

Because this was not a sample survey, there are no sampling errors. 

However, the practical difficulties of conducting any survey may introduce 

errors, commonly referred to as nonsampling errors. For example, 

difficulties in how a particular question is interpreted can introduce 

unwanted variability into the survey results. We took steps in the 

development of the questionnaire, the data collection, and the data 

analysis to minimize these nonsampling errors. For example, we 

pretested the survey with the pupil transportation directors in three states 

and NASDPTS to ensure that questions were clear and unbiased and to 

minimize the burden the survey placed on respondents. Based on 

feedback from the pretests, we made minor changes to the content and 

format of survey questions. We received completed surveys from 47 

respondents for an overall response rate of 94 percent.3

To describe the number and characteristics of fatal school-bus crashes 

since 2000, we analyzed data from two data sets. First, we analyzed 

Buses Involved in Fatal Accidents (BIFA) data from the University of 

Michigan Transportation Research Institute (UMTRI) for calendar years 

2000 to 2010 to describe the attributes of crashes involving school buses. 

BIFA includes data on fatal traffic crashes in the United States involving a 

bus.4 We used BIFA data as they were the only source of national crash 

data we identified that included bus-specific variables like type of operator 

and bus, and 2010 was the last year for which BIFA data were collected. 

Cases for BIFA are selected from NHTSA’s Fatality Analysis Reporting 

System (FARS) file. BIFA supplements the FARS data; UMTRI collected 

police reports for each crash and trained interviewers to contact owners, 

operators, or drivers of the buses to collect detailed information on the 

bus, operator, and driver. Our analysis of BIFA data included variables 

collected by UMTRI, such as the type of bus, type of operator (school 

district or contractor), and length of trip, as well as FARS variables, such 

as driver- and vehicle-related factors, model year of the vehicle, and road 

 2

We did not include the District of Columbia or territories. 

3

Georgia, Mississippi, and New Hampshire did not respond to our survey.

4

For BIFA, a bus is defined as a vehicle with seating for nine or more occupants, including 

the driver, not for personal use (such as a family) or for 15 or more passengers.
Appendix I: Objectives, Scope, and 

Methodology

Page 36 GAO-17-209 School Bus Safety

and atmospheric conditions. Since the BIFA data were last collected for 

calendar year 2010, we reviewed NHTSA’s school-transportation-related 

analysis for 2000 through 2014 to compare the overall number of fatal 

school-bus crashes during and after BIFA data collection and examine 

whether there were any trends or changes after 2010. We also examined 

whether there were any changes to federal rules for school bus vehicles 

and operators that would substantially change the regulatory landscape 

for school bus operations after 2010. In reviewing the data and federal 

rule changes, we found no substantial changes that would raise concerns 

about using the BIFA data from 2000 to 2010 for our review. For BIFA, we 

identified crashes using the included variable for “school-bus-related 

crashes.” Second, we analyzed FARS data for calendar years 2011 to 

2014, the latest year for which data were available, to examine this more 

recent FARS data to extend our analysis for certain variables like 

atmospheric and road conditions and time of day of the crash. For FARS, 

we implemented guidance NHTSA provided to use four variables from the 

accident and vehicle data files to identify school-bus-related crashes. 

Based on interviews with NHTSA and UMTRI officials, as well as 

reviewing system documentation and electronic data testing, we 

determined that the data were sufficiently reliable for the purpose of 

describing the number and type of fatal school-bus crashes. While these 

data sets allow us to describe the attributes of fatal crashes, the 

descriptive information is not generalizable to crashes with non-fatal 

injuries or with property damage only. Moreover, we did not have 

exposure data, such as the total miles traveled by different types of buses 

or operators, so we could not calculate crash rates that would allow for 

directly comparing different types of crashes.

To describe federal school bus safety requirements, we reviewed federal 

laws and regulations on school bus inspections, driver training, and 

vehicle standards—specifically, vehicle age and seating capacity of 

school buses. We primarily focused our review on these three areas 

based on our initial research into school bus safety requirements and the 

content of the mandate. We reviewed inspection requirements in the 

Federal Motor Carrier Safety Regulations that would apply to school bus 

operators, but the scope of our review did not include all other aspects of 

these regulations, such as hours-of-service requirements for drivers and 

driver qualifications. We did not examine seat belts as part of our review 

due in part to NHTSA’s current effort to further research seat belts on all
Appendix I: Objectives, Scope, and 

Methodology

Page 37 GAO-17-209 School Bus Safety

school buses.5 We also reviewed and analyzed guidance and reports 

from NHTSA, FMCSA, and the National Transportation Safety Board, 

including NHTSA’s Highway Safety Program Guideline No. 17, Pupil 

Transportation Safety; National Transportation Safety Board’s accident 

investigation reports involving school buses; and FMCSA’s March 2016 

Notice of Proposed Rulemaking and December 2016 Final Rule on entrylevel driver training.6 We also interviewed officials from those agencies to 

understand the scope and applicability of federal laws and regulations for 

school bus vehicles and operators.

To describe state laws and regulations, we systematically searched laws 

and regulations for all 50 states to determine the extent to which states 

set requirements for school bus inspections, driver training, and vehicle 

standards. Specifically, we searched for state requirements for: (1) school 

bus inspections;7 (2) entry-level or refresher training for school bus 

drivers; (3) maximum age, mileage, or use that require retiring or no 

longer using school buses;8 and (4) maximum seating capacity for school 

buses. We conducted this search on state statutes and administrative 

codes in a legal database. In consultation with GAO’s Office of General 

Counsel and our librarian, we developed search terms and protocols and 

used a data collection instrument for each of the requirements to ensure 

consistent collection of information. For example, for our searches on 

state requirements for school bus inspections, we used the search term 

“school bus w/10 inspect!” and increased the proximity of the key words 

from within 10 words to within 15 and 20 words. When our search 

returned no results for a state, we then searched the websites of the 

state’s education, transportation, motor vehicle, and/or police agencies 

and used any information found from these searches, such as a legal 

citation or terminology, to direct additional searches in a legal database.

 5

In July 2015, NHTSA held a daylong workshop on occupant protection, including seat 

belts, and since that time has met with states that require seat belts on school buses.

6

81 Fed. Reg. 11944 (Mar. 7, 2016) and 81 Fed. Reg. 88732 (Dec. 8, 2016).

7

Our search focused on state requirements for school bus inspections and not more 

broadly on state requirements for commercial-motor-vehicle inspections. Also, as with our 

review of federal laws and regulations, our scope did not include other state requirements 

for commercial-motor-vehicle operators. 

8

In our search on maximum vehicle age or use, we did not include states that required 

retiring school buses based on a single date of manufacture. In several cases, we found 

that states set these requirements for purposes such as reducing emissions that were 

outside of scope of our review. 
Appendix I: Objectives, Scope, and 

Methodology

Page 38 GAO-17-209 School Bus Safety

We also consulted with our Office of General Counsel on coding the 

results of our searches in the data collection instrument. After completing 

our searches, we compared the results of our search on states’ schoolbus inspection requirements with the 2011 survey results from South 

Carolina and NASDPTS on school bus inspection practices to verify our 

research. We also compared the results of our research on vehicle age 

with a list provided by the National Conference of State Legislatures and 

the results of our research on vehicle age and seating capacity with a 

stakeholder’s compiled list of state requirements and practices on school 

bus vehicle age/life cycle use and seating capacity. We took steps to 

reconcile any identified differences, including conducting further research 

in a legal database and state agency websites and contacting state 

officials to clarify and verify the information we found in our legal search. 

We also validated our search results with eight selected states as part of 

our in-depth review on how selected states implement school-bus safety 

requirements, as further described below. Finally, our Office of General 

Counsel reviewed and verified the search results for all 50 states. The 

scope of our research did not include local requirements, and thus we did 

not include any local requirements for school bus inspections, driver 

training, or maximum vehicle age or seating capacity that may be 

applicable to school bus operators. In addition, our search terms and 

protocols aimed to identify states with requirements, but due to the nature 

of keyword searches, we may not have identified all relevant school bus 

requirements. Further, for states for which we didn’t identify requirements, 

we attempted several types of searches to try to find state inspection, 

driver training, or maximum age or capacity requirements. However, we 

cannot definitively conclude that there are no requirements in the 

mentioned categories for these states.

To better understand implementation of federal and state rules and 

whether public and private bus operators face different safety 

requirements, we performed additional research on and conducted indepth interviews with state officials from eight selected states. Using 

School Bus Fleet’s 2013–2014 school year school transportation data, we 

selected states to include those with the highest number of students 

transported daily by school bus, the highest annual route miles traveled 

per student, and variation in the number of school buses owned by 

states/school districts and contractors. We also selected states that vary 

geographically and maintained data available on school bus involved 

accidents and school bus inspections. We selected eight states: 

California, Illinois, Nebraska, New York, Pennsylvania, Tennessee, 

Virginia, and Washington. These eight states account for about 28 

percent of public K-12 students transported daily on school buses. We 
Appendix I: Objectives, Scope, and 

Methodology

Page 39 GAO-17-209 School Bus Safety

conducted semi-structured interviews with state officials from the selected 

eight states and, when available, collected data on the outcomes of 

school bus inspections and the age of school buses. These eight selected 

states are a non-probability sample of states, and thus, the information 

we obtained is used for illustrative purposes and is not generalizable.

To identify sources of leading practices, we conducted a literature search 

to identify leading practices on school bus inspections, driver training, and 

maximum vehicle age and seating capacity. We reviewed literature for the 

last 15 years for pertinent studies in peer-reviewed journals, trade 

publications, and conferences, among others, to identify sources and 

leading practices. We also interviewed school bus industry stakeholders, 

including officials from school-bus industry associations, federal agencies, 

select state agencies, school bus manufacturers, and school bus 

contractors, to identify sources of leading practices. We selected 

stakeholders to represent a range of roles in the school bus industry and 

the federal and state levels of government. A full list of stakeholders 

interviewed for this review is provided in table 2 below. In these 

interviews, we asked stakeholders an open-ended question for them to 

generate sources of leading practices, rather than offering a list of 

possible sources. Therefore, not every stakeholder we interviewed 

commented on whether a particular document or organization 

represented a source of leading practices; we can only report counts of 

stakeholders that identified a particular document or organization. We 

also asked school bus industry stakeholders what areas of additional 

federal guidance and research, if any, are needed. In identifying sources 

of leading practices and areas of further federal guidance and research, 

our questions did not apply to 4 of the 30 stakeholders in both cases. For 

example, we did not ask federal agencies about what additional federal 

research or guidance would be useful as we instead asked them about 

current or future research on school bus safety. The views of these 

school bus stakeholders are not generalizable to the entire school bus 

community, but they provide us with valuable insights. We analyzed the 

content of interviews with stakeholders and identified sources of leading 

practices from our literature review in the areas of inspections, driver 

training, and vehicle standards.
Appendix I: Objectives, Scope, and 

Methodology

Page 40 GAO-17-209 School Bus Safety

Table 2: List of Interviewed School Bus Safety Stakeholders 

Association of Transportation Safety Information Professionals

Blue Bird (manufacturer) 

California Department of Education 

California Highway Patrol

Federal Motor Carrier Safety Administration 

First Student (contractor) 

IC Bus (manufacturer)

Illinois Department of Transportation 

Illinois State Board of Education 

National Association for Pupil Transportation 

National Association of State Directors of Pupil Transportation Services 

National Congress on School Transportation

National Express (contractor)

National Highway Traffic Safety Administration

National Safety Council

National School Transportation Association

National Transportation Safety Board

Nebraska Department of Education and Nebraska Safety Center

New York State Department of Transportation 

New York State Education Department

Pennsylvania Department of Transportation

Pennsylvania State Police

Pupil Transportation Safety Institute 

School Bus Fleet (periodical)

Tennessee Department of Safety and Homeland Security

Thomas Built (manufacturer)

Transportation Advisory Services (consultant)

Virginia Department of Education

Washington Office of Superintendent of Public Instruction

Washington State Patrol

Source: GAO. | GAO-17-209
Appendix II: Description of Eight Selected 

States’ Requirements on School Bus Safety

Page 41 GAO-17-209 School Bus Safety

In our review of eight selected states, we found variation in state 

requirements for and implementation of school bus inspection, driver 

training, and vehicles standards for maximum age and seating capacity, 

as shown in table 3 below.

Table 3: Selected Eight States’ School Bus Safety Requirements

State

Number of school buses 

and K-12 public students 

transported daily in 2013–

2014 school year

Inspections Driver traininga Maximum age and 

seating capacityb

California

• 15,926 district- and 

stated-owned buses

• 8,287 contractor-owned 

buses

• 666,314 students

• California Highway Patrol 

oversees school bus 

inspections.

• State inspectors annually 

inspect all school buses. (CAL.

VEH. CODE § 2807(a) (2016))

• All school bus operators are 

required to inspect their school 

buses every 3,000 miles or 

every 45 days, whichever 

occurs first (CAL. CODE REGS. tit. 

13, § 1232(b) (2016))

• California Department of 

Education oversees school bus 

driver training.

• Entry-level training: A minimum 

of 20-hours classroom and 20-

hours behind-the-wheel training. 

(CAL. EDUC. CODE § 40082 

(2016))

• Refresher training: A minimum of 

10 hours each year. (CAL. EDUC.

CODE § 40085 (2016))

• State-certified instructors train 

school bus drivers.

• No state 

requirements on 

maximum vehicle 

age or seating 

capacity.

Illinois

• 29,000 busesc

• 1,157,791 students

• Illinois Department of 

Transportation oversees school 

bus inspections.

• Private, certified inspectors 

inspect all school buses every 6 

months or 10,000 miles, 

whichever occurs first, at official 

testing stations. (625 ILL. COMP.

STAT. 5/13-109 (a) (2016))

• State inspectors also conduct 

random inspections of school 

buses. (625 ILL. COMP. STAT. 

5/13-109 (b) (2016))

• Illinois State Board of Education 

and Secretary of State oversee 

driver training program.

• Entry-level training: Training is 

required, but no set minimum 

hours. It generally takes a 

minimum of 8-hours. (625 ILL.

COMP. STAT. 5/6-106.1 (2016)) 

• Refresher training: A minimum of 

2-hours of training is required 

annually. (625 ILL. COMP. STAT.

5/6-106.1 (2016) and 92 ILL. ADM.

CODE § 1035.10 (2016))

• No state 

requirements on 

maximum vehicle 

age.

• School buses 

cannot operate with 

more passengers 

than manufacturer’s 

recommended 

capacity. (625 ILL.

COMP. STAT. 5/12-

707 (2016))

Appendix II: Description of Eight Selected 

States’ Requirements on School Bus Safety
Appendix II: Description of Eight Selected 

States’ Requirements on School Bus Safety

Page 42 GAO-17-209 School Bus Safety

State

Number of school buses 

and K-12 public students 

transported daily in 2013–

2014 school year

Inspections Driver traininga Maximum age and 

seating capacityb

Nebraska

• 5,743 district-owned 

buses

• 1,310 contractor-owned 

buses

• 44,619 students

• Local districts and contractors 

are required to inspect school 

buses before the beginning of 

school year and every 80 days 

thereafter during the school 

year. (NEB. ADMIN. R. & REGS. 

Title 92, Ch. 93 (2016))

• Nebraska Department of 

Education contracts with 

University of Nebraska -

Nebraska Safety Center to 

provide training.

• Entry-level training: A minimum 

of 11 hours. (NEB. ADMIN. R. &

REGS. Title 92, Ch. 91, 002.5 

(2016))

• Refresher training: A minimum of 

3 hours within 5 years of 

completing entry-level training 

and then every 5 years 

thereafter. (NEB. ADMIN. R. &

REGS. Title 92, Ch. 91, 002.7 and 

003.03C3 (2016))

• Instructors are experienced 

school bus drivers trained by the 

Nebraska Safety Center.

• No state 

requirements on 

maximum vehicle 

age.

• School buses 

cannot operate with 

more passengers 

than manufacturer’s 

recommended 

capacity. (NEB. REV.

STAT. § 79-609 

(2016))

New York

• 25,000 district-owned 

buses

• 25,000 contractorowned buses

• 1,875,000 students

• New York State Department of 

Transportation oversees school 

bus inspections.

• New York State Department of 

Transportation inspectors 

inspect all school buses every 

six-months. (N. Y. COMP. CODES 

R. & REGS. tit. 17, § 720.2 

(2016))

• New York State Education 

Department oversees school bus 

driver training.

• Entry-level training: A minimum 

of 3 hours of initial instruction 

(i.e., pre-service) and 30-hour 

basic training course within the 

first year of employment, 

including at least 2 hours of 

training on transporting special 

needs students. (N. Y. COMP.

CODES R. & REGS. tit. 8, § 

156.3(b)(5)(ii)(a)(b) (2016))

• Refresher training: A minimum of 

2 hours is required at least twice 

a year. (N. Y. COMP. CODES R. &

REGS., tit. 8, § 156.3(b)(5)(iii) 

(2016))

• State-certified instructors, who 

are school district employees or 

contractors, train school bus 

drivers.

• No state 

requirement on 

maximum vehicle 

age.

• State has a 

maximum seating 

capacity of 84 

student 

passengers. (N. Y.

COMP. CODES R. &

REGS. tit. 17, § 

720.4 (p)(2)(i) 

(2016))
Appendix II: Description of Eight Selected 

States’ Requirements on School Bus Safety

Page 43 GAO-17-209 School Bus Safety

State

Number of school buses 

and K-12 public students 

transported daily in 2013–

2014 school year

Inspections Driver traininga Maximum age and 

seating capacityb

Pennsylvania

• 4,418 district-owned 

buses

• 17,400 contractorowned buses

• 1,525,579 students

• Pennsylvania State Police 

oversees school bus 

inspections.

• State inspectors annually 

inspect all school buses. (67 

PA. CODE § 171 (2016))

• State inspectors also conduct 

spot checks on school buses 

between October and May of 

each year.

• Pennsylvania Department of 

Transportation oversees school 

bus driver training.

• Entry-level training: A minimum 

of 20 hours including 14 hours 

classroom training and 6 hours 

behind-the-wheel training. (67 

PA. CODE § 71.5 (c)(1)(2) (2016))

• Refresher training: A minimum of 

10 hours including at least 7 

hours in classroom and 3 hours 

behind-the-wheel, every 4 years. 

(67 PA. CODE § 71.5 (d) (2016))

• State-certified instructors train 

school bus drivers.

• No state 

requirements on 

maximum vehicle 

age or seating 

capacity.

Tennessee

• 6,319 district-owned 

buses

• 1,991 contractor-owned 

buses

• 654,785 students

• Tennessee Highway Patrol 

oversees school bus 

inspections.

• State inspectors annually 

inspect all school buses, and 

inspect older school buses twice 

a year. (TENN. COMP. R. & REGS.

CH. 1340-03-03-.03 (2016))

• State inspectors also conduct 

random inspections of at least 

10 percent of the statewide 

school bus fleet annually.

• Tennessee Highway Patrol also 

oversees and provides driver 

training.

• Entry-level training: No entrylevel training required.

• Refresher training: An annual 

minimum of 4 hours is required. 

(TENN. COMP. R. & REGS. CH.

1340-03-03-.07 (2016))

• School-district staff can also 

provide training with oversight 

and approval from the state.

• State limits using 

small buses up to 

15 years and large 

buses up to 18 

years. Large school 

buses can also be 

used up to 19 years 

as long as it has 

less than 200,000 

miles and has 

passed inspections. 

(TENN. CODE ANN. § 

49-6-2109 (2016), 

TENN. COMP. R. &

REGS. 0520-01-05-

.01 (2016))

• School buses 

cannot operate with 

more passengers 

than manufacturer’s 

recommended 

capacity. (TENN.

CODE ANN. § 49-6-

2110 (2016))
Appendix II: Description of Eight Selected 

States’ Requirements on School Bus Safety

Page 44 GAO-17-209 School Bus Safety

State

Number of school buses 

and K-12 public students 

transported daily in 2013–

2014 school year

Inspections Driver traininga Maximum age and 

seating capacityb

Virginia 

• 16,020 district-owned 

buses

• 159 contractor-owned 

buses

• 860,999 students

• Local districts and contractors 

are required to inspect school 

buses every 45 days or 5,000 

miles. (VA. CODE ANN. 20-70-

130 (2016))

• Virginia Department of 

Education staff conduct periodic 

fleet assessments of school 

buses and transportation 

operations.

• Virginia Department of Education 

oversees driver training.

• Entry-level training: A minimum 

of 24-hours classroom and 24-

hours behind-the-wheel training. 

(VA. CODE ANN. § 22.1-181 

(2016), VA. ADMIN. CODE, tit. 8, § 

20-70-350 (2016))

• Refresher training: A minimum of 

4 hours of training each year—2 

hours before the school year 

starts and 2 hours during second 

half of the school year. (VA. CODE 

ANN. § 22.1-181 (2016), VA.

ADMIN. CODE, tit. 8, § 20-70-360 

(2016))

• State-certified instructors train 

school bus drivers.

• No state 

requirements on 

maximum vehicle 

age or seating 

capacity.

• State has a funding 

program to replace 

school buses with a 

15-year life cycle, 

but operators can 

use buses beyond 

this life cycle. 

Washington

• 8,839 district- and 

stated-owned buses

• 1,310 contractor-owned 

buses

• 355,288 students

• Washington State Patrol 

oversees school bus 

inspections.

• State inspectors annually 

inspect all school buses. (WASH.

REV. CODE § 46.32.010 (2016) 

and WASH. ADMIN. CODE § 392-

143-035 (2016))

• State also requires an 

unannounced, second 

inspection of 25 percent of each 

school bus operator’s fleet each 

year.

• Washington Office of 

Superintendent of Public 

Instruction oversees driver 

training.

• Entry-level training: Training is 

required, but no set minimum 

hours. It generally takes about 

48-to-58 hours based on driver’s 

previous experience. (WASH.

ADMIN. CODE § 392-144-101 

(2016))

• Refresher training: Training is 

required, but no set minimum 

hours. It generally takes about 4 

hours and is required by 

November 1 of each year. 

(WASH. ADMIN. CODE § 392-144-

102 (2016))

• State-trained instructors, who are 

school district employees or 

contractors, train school bus 

drivers.

• No state 

requirements on 

maximum vehicle 

age or seating 

capacity.

• State has a funding 

program to replace 

small school buses, 

with a life cycle of 8 

years for small 

buses and 13 years 

for large buses, but 

operators can use 

buses beyond 

these life cycles. 

(REV. CODE WASH. 

§ 28A.160.205 

(2016))

Source: GAO analysis of state data and interviews with state officials. | GAO-17-209
Appendix II: Description of Eight Selected 

States’ Requirements on School Bus Safety

Page 45 GAO-17-209 School Bus Safety

a

Across the eight states, we use the terms entry-level training and refresher training to consistently 

distinguish training required for new drivers before or as they start driving school buses from training 

required of all drivers on a regular basis in our report. However, individual states may use other terms 

in law, regulation, and guidance. For example, entry-level training may also be called pre-service, 

basic, original, or initial training, and refresher training may also be called in-service, recurrent, or 

renewal training.

b

For the selected states where our search did not identify state requirements for maximum vehicle 

age or seating capacity on school buses, state officials confirmed that no state requirements existed.

c

According to a state official, this is an estimated number of school buses.
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 46 GAO-17-209 School Bus Safety

Susan A. Fleming, (202) 512-2834 or flemings@gao.gov

In addition to the contact named above, Susan Zimmerman (Assistant 

Director), Joanie Lofgren (Analyst in Charge), Carl Barden, Pamela 

Daum, Leia Dickerson, H. Brandon Haller, David Hooper, Jennifer Kim, 

Avani Locke, Grant Mallie, Janet Mascia, SaraAnn Moessbauer, Malika 

Rice, Amy Rosewarne, and Carter Stevens made key contributions to this 

report.

Appendix III: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(100657)
The Government Accountability Office, the audit, evaluation, and investigative 

arm of Congress, exists to support Congress in meeting its constitutional 

responsibilities and to help improve the performance and accountability of the 

federal government for the American people. GAO examines the use of public 

funds; evaluates federal programs and policies; and provides analyses, 

recommendations, and other assistance to help Congress make informed 

oversight, policy, and funding decisions. GAO’s commitment to good government 

is reflected in its core values of accountability, integrity, and reliability.

The fastest and easiest way to obtain copies of GAO documents at no cost is 

through GAO’s website (http://www.gao.gov). Each weekday afternoon, GAO 

posts on its website newly released reports, testimony, and correspondence. To 

have GAO e-mail you a list of newly posted products, go to http://www.gao.gov

and select “E-mail Updates.”

The price of each GAO publication reflects GAO’s actual cost of production and 

distribution and depends on the number of pages in the publication and whether 

the publication is printed in color or black and white. Pricing and ordering 

information is posted on GAO’s website, http://www.gao.gov/ordering.htm. 

Place orders by calling (202) 512-6000, toll free (866) 801-7077, or 

TDD (202) 512-2537.

Orders may be paid for using American Express, Discover Card, MasterCard, 

Visa, check, or money order. Call for additional information.

Connect with GAO on Facebook, Flickr, Twitter, and YouTube.

Subscribe to our RSS Feeds or E-mail Updates. Listen to our Podcasts.

Visit GAO on the web at www.gao.gov.

Contact:

Website: http://www.gao.gov/fraudnet/fraudnet.htm

E-mail: fraudnet@gao.gov

Automated answering system: (800) 424-5454 or (202) 512-7470

Katherine Siggerud, Managing Director, siggerudk@gao.gov, (202) 512-4400, 

U.S. Government Accountability Office, 441 G Street NW, Room 7125, 

Washington, DC 20548

Chuck Young, Managing Director, youngc1@gao.gov, (202) 512-4800

U.S. Government Accountability Office, 441 G Street NW, Room 7149 

Washington, DC 20548

James-Christian Blockwood, Managing Director, spel@gao.gov, (202) 512-4707

U.S. Government Accountability Office, 441 G Street NW, Room 7814, 

Washington, DC 20548

GAO’s Mission

Obtaining Copies of 

GAO Reports and 

Testimony

Order by Phone

Connect with GAO

To Report Fraud, 

Waste, and Abuse in 

Federal Programs

Congressional 

Relations

Public Affairs

Strategic Planning and 

External Liaison

Please Print on Recycled Paper.