The photo below is taken from the National Transportation Safety Board (NTSB) report of April 23, 2026, discussing the rollover collision of a school bus on March 4, 2024 near Millstone, West Virginia. Investigations conducted by the NTSB are often of exceptional quality with few of the biases that accompany investigations of other agencies. However there are important issues in the current NTSB report that are not fully addressed. Let us first provide a brief summary of the NTSB report on the current collision and then we will follow-up with our comments.

The best summary of the NTSB report is provided in its opening paragraphs which we attach below.

What Happened

On Monday, March 4, 2024, about 5:50 p.m. eastern standard time, a 2022 IC
77-passenger school bus occupied by a driver and 19 students was traveling south
on State Highway 16 (SH-16) near Millstone in Calhoun County, West Virginia, to take
students home from after-school activities. The bus departed the right side of the
roadway, returned to the roadway, and rolled over onto its right side, coming to rest
across both lanes of SH-16. As a result of the crash, 3 students on the bus sustained
serious injuries, 16 students sustained minor injuries, and the driver was not injured.
In addition, the National Transportation Safety Board conducted a limited
investigation of a multivehicle crash involving a school bus that occurred in Dale,
Texas, to examine occupant protection safety issues. In that crash, a 5-year-old bus
occupant was fatally injured and 43 other preschool students, 10 chaperones, and the
school bus driver sustained injuries of varying degrees.

What We Found

At the time of the crash, the Millstone school bus driver was impaired by
alcohol, which resulted in his loss of control. We found that implementing alcohol
detection systems on school buses can prevent alcohol-impaired driving by school
bus drivers.
We also found that unbelted bus passengers were injured from impacting
other occupants and the school bus interior during the rollover sequence.
Lap/shoulder belts, had they been installed and properly worn, would have provided
the best protection for the students by keeping the occupants within the protective
seating compartment.
The National Transportation Safety Board determines that the probable cause
of the Millstone, West Virginia, crash was the school bus driver’s alcohol impairment
resulting in his loss of vehicle control and the school bus’s roadway departure and
rollover. Contributing to the severity of the passenger injuries was the lack of
passenger lap/shoulder belts on the large school bus.

What We Recommended

As a result of the investigation, we recommended that the National Highway
Traffic Safety Administration require all new school buses to be equipped with a
vehicle-integrated alcohol detection system that prevents or limits vehicle operation if
driver impairment by alcohol is detected.
We reiterated Safety Recommendation H-18-10 to West Virginia to enact
legislation that requires new large school buses to be equipped with passenger
lap/shoulder belts. We issued new recommendations to West Virginia to enact
legislation to require all passengers to wear school bus seat belts when they are
available, and to establish enforceable policies and procedures for all school districts
to ensure students properly use passenger seat belts. Finally, we classified Safety
Recommendation H-25-26 Open—Acceptable Response for the Leander Independent
School District issued as a result of a 2025 school bus crash in Leander, Texas.

A diagram showing the collision sequence was shown in the NTSB report and this is reproduced below.

A photo showing the culvert that was struck by the school bus is also shown below, taken from the NTSB report.

And finally, the bus passenger seating positions and their injuries were shown in the NTSB diagram shown below.

Gorski Consulting Comments

There is an important sentence in the above wording of the NTSB report that we highlight again below:

“We issued new recommendations to West Virginia to enact legislation to require all passengers to wear school bus seat belts when they are available, and to establish enforceable policies and procedures for all school districts to ensure students properly use passenger seat belts.“

There is little doubt that, in a loss-of-control collision with rollover, the availability and proper use of seat-belts would improve the safety of school bus occupants. A collision like this evokes lateral and vertical forces and a seat-belt can be very effective in keeping occupants within their seating space while riding down the marginal forces that exist. It needs to be emphasized that during a rollover the bus deceleration would be at a rate in the range of 0.4 to 0.6g and that represents a low level of force. This emphasizes that rollovers can be managed with relative safety if one can be assured that occupants are kept in their seating positions, are not ejected and that there is little or no structural intrusion into the occupant space. However the danger of rollovers is that their injury consequences are often unpredictable.

If one could be assured that most school bus collisions would occur in the manner shown here then there is little argument that seat-belts should be mandated on school buses. But that is not the case. Collisions can also occur where the school bus is not involved a loss-of-control and rollover. They can occur where there is frontal contact of the bus with something of substantial mass. They may occur where an impact occurs with another heavy vehicle or with a non-yielding object such as a large tree or a permanent roadside fixture such as a concrete bridge abutment. Collisions of this type, can create large longitudinal decelerations, that could be of much higher levels than the lateral and vertical forces discussed above. Levels of longitudinal deceleration could easily be ten times greater than the forces occurring in a loss-of-control and rollover.

One might be convinced to conclude that such longitudinal forces should not be a problem because seat-belts are specifically designed to improve occupant protection from these kinds of forces. But the situation for children on school buses is actually more complicated than this.

In modern, light-duty vehicles collision forces are controlled not only by ride-down with seat-belts but there are numerous other safety features that add to the occupant’s protection. Frontal air bags, for example, help in the occupant’s ride-down. Features such as knee-bolsters help in controlling the forces at the legs and lower trunk. Collapsible steering rims/columns, padded dashs and other devices are all used in conjunction with seat-belts to protect an occupant in light-duty vehicles. But essentially none of these devices exist in the interior of school buses. So, on school buses we are asking the seat-belt restraint to do the primary, and sometimes the only, work of ride down in a school bus frontal collision. But there are other issues.

When the NTSB recommends that jurisdictions “establish enforceable policies and procedures for all school districts to ensure students properly use passenger seat belts” the issue is more complex and the NTSB report has not addressed this complexity.

Even in the general realm of seat-belt safety issues, there are common problems with proper usage even before we look at the specifics of children on school buses. Seat-belts are a benefit to reducing injury and death but one must also understand that certain conditions can make seat-belts dangerous and sometimes they can be difficult to wear “properly”.

The first problem is that persons who ought to know better inform the general public that they must wear seat-belts – period, without informing them that seat-belts must be worn properly. And then officials do not inform the public how to wear seat-belts “properly”. And so there are many persons riding in vehicles who are oblivious to the dangers that exist when they do not wear their seat-belts “properly”. In fact those persons who tell persons to wear seat-belts “properly” do not understand what “properly” means. And so they misinform the gullible public who do not question the seemingly authoritative officials.

Seat-belts are beneficial because they apply a force to the occupant’s body at locations that can absorb that impact force with less consequence. So the torso (shoulder) belt applies a load to the collar (clavicle) bone and upper ribs. And the lap belt applies a force to the pelvic bones (below the illiac crests). However, if the seat-belt webbing position strays from these ideal points of application dangerous consequences can occur, particularly at the lap belt. If the lap belt is positioned too high, or if the occupant’s body slides out of position, the lap belt can apply a force to the unprotected abdomen where there are multiple, important organs. Displacement from the ideal points of force application also occur if the seat-belt restraint system does not fit the occupant primarily due to occupant size differences.

And this is a problem with children on school buses because they come with large size differences. There could easily be 10 children on any given school bus route where the children are as little as 4-years-old. However there might be routes where no such children exist. And there could be several children who are comparable in size to adults. This wide variety of occupant sizes must be accommodated with properly fitting restraints. The 4-year-olds may require a forward-facing, child-seat system while larger children may require seating in a booster-type system to increase the angle of the lap webbing from the anchorage. And the adult sized children may only need to wear a restraint that is similar to the three-point, adult-style of seat-belt system. When the type of available restraint does not properly match the size of the child the restraint becomes difficult to wear “properly” and increases in injury levels can occur.

What will happen if the unique composition of child sizes on any given school bus route happens to place some children into seats wear the restraints are not suitable for their size? Will someone prevent some children from riding on that route? Highly unlikely.

There are other safety issues with respect to the type of clothing worn by children and how this changes the interaction between the restraint and the occupant’s body. And this also applies to all occupants in general, particularly in Canada where the weather may be different than in southern parts of the U.S. Winter clothing, for example, can create problems with keeping a restraint system properly applied to the previously mentioned ideal locations on the body. And in some instances the type of clothing material matters. Slippery nylon can create the conditions wear a child’s body could slip underneath a lap belt in scenario historically known as “submarining”. In winter conditions it is important to ensure that a winter coat is unzipped and pushed to the sides of the occupant and to tighten the webbing such remove any slack in the system. But will a 4-year-old child understand that concept, highly unlikely.

Specially-trained, school bus monitors will be required to ride along with the school bus driver to make sure that these essential conditions of restraint systems are met. The addition of such monitors will cost money. And the installation of proper restraint systems will also cost more money. Are those responsible for transporting children on school buses prepared to pay these additional costs?

It is easy for the NTSB to recommend “enforceable policies and procedures for all school districts to ensure students properly use passenger seat belts” however the reality is not that simple. While recommendations of a U.S. safety agency do not apply to what happens in Canada, there is an influence that filters up across the border. What the NTSB has recommended in its current report is important to take into account. However there are complications resulting from these recommendations that are not discussed and ought to be known. As suggested by the NTSB the current reliance on compartmentalization is inadequate for scenarios involving lateral and vertical collision forces. Children are minimally protected from striking the sides of school buses and from striking themselves. Something has to be done to reduce those types of collision consequences.