Memorandum - NHTSA

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111. SAFETY NEED 111-1 Although some of the Final Rule requirements can be justified on the basis of accident and inj iry data, the agency's rule is based on Access Board and FTA sponsored guidelines and recommendations as well as SAE practices and procedures. The FTA sponsored guidelines wj :re developed in consultation with bus drivers and transit system operators and reflect engineering judgment and common practice. The requirements being proposed are consistent with those published by many organizations concerned with bus lift systems for the disabled, e.g., the FT.1, the Department of Veteran Affairs (DVA), the Society of Automotive Engineers (SAE). NHTSA estimates 1,238 lift-related accidents and injuries occurred in vehicles covered by this Final Rule (vans and buses) in 1991-95 or 248 injuries per year. NHTSA analyzed the most recent NEISS data (1991-95) from the Consumer Product safety Commission concerning the incidence of lift-related accidents and injuries and found 972 and 266 incidences for vans and buses, respectively, compared to the same data studied in 1986-90 which found 381 and 140 incidences, respectively.' All things being equal, the agency believes there has been an increasing trend in lift-related injuries of 2.5 X and 1.9 X, respectively, for vans and buses for these two five year increments of time. NHTSA believes the increase is due to increased ridershiphage due to the ADA and not a decrease in lift safety. The agency can not pin point the cause of these particular lift-related incidences, whether lift operator or equipment related. 1 Wheelchair Users Injuries and Deaths Associated with Motor Vehicle Related IncideIits, Research Note, September 1997,National Center for Statistics and Analysis, Research and Development, NHTSA, 400 7thStreet SW, Washington, DC 20590. Also see School Transport News, February 1998, for same data page 1 and page 18.
111-2 Generally, there is very little information regarding WC lift accidents and injuries. Very few lj ft related accidents or injuries can be associated directly with the requirements except by anecdo1:al information or defect investigations conducted by the agency. NHTSA has conducted a few defect investigations concerning WC lifts in the 10-12 years prior to the SNPRM. The commenters presented little, if any, lift user injury data (WC user or otherwise). A recent TRP: article on tort liability arising out of the ADA shows that for the 1991- 1995 period there have been a limited number of tort claims, out of millions of fare trips, filed against a sample of 43 transit companies involving disabled riders involving wheelchairs.* WC lifts were not implicz ted as a source of injury or the subject of a tort in this study. Since implementation of the ADA, there has been a doubling in “disabled riders” from 7,534,002 (1991) to 16,839,291 (1995) based on the responses of 43 transit agencies responding to a TCIP survey. For the same agencies (1991-1995), WC ridership, based on the number of trips, increased by a factor of 5 [from 298,912 (1991) to 1,498,395)].3 There are 6,000 agencies that provide public transportation in the U.S. and they have probably experienced similar increases. Although the number of WC related tort claims increased for the same 43 agencies from 1 to 2 7 from 1991 to 1995, liftshamps are not mentioned as a source of injury or a tort liability issue. * Potential Tort Liability for Transit Agencies Arising Out of the Americans with Disabilities Act, Transit Cooperative Research Project (TCRP), Legal Research Digest, No 11 , July 1998, Transportation Research Board (TRB), National Research Council. Ibid
Page 1 and 2: Subject: From: To: U.S.Department o
Page 3 and 4: TABLE OF CONTENTS Summary..........
Page 5 and 6: s-2 The annual number of persons in
Page 7 and 8: 11. BACKGROUND 11- 1 Guidelines per
Page 9: 11-3 and strength; control panel le
Page 13 and 14: 111-4 Table 111-1 Preliminary Natio
Page 15 and 16: 111-6 The NEISS database lacks the
Page 17 and 18: 111-8 Public Transit & Paratransit
Page 19 and 20: w-2 identifying the relevant lift c
Page 21 and 22: IV-4 MEASURE RED FLASHING BEACON OR
Page 23 and 24: IV-6 Acceleration is to be measured
Page 25 and 26: IV-8 FIGURE IV-2 :i a la Y t Permir
Page 27 and 28: IV-10 and vehicle size. This requir
Page 29 and 30: v-12 7. Prepare test block fnction
Page 31 and 32: IV-14 Gaps, Transitions and Opening
Page 33 and 34: Figure m-3 Allowable transition dim
Page 35 and 36: IV-18 sliding or being driven over
Page 37 and 38: v-20 traveling too fast, in the for
Page 39 and 40: WC Retention Overload Test 67.13) I
Page 41 and 42: IV-24 The lift is raised to the flo
Page 43 and 44: N-26 (2 square inches) applicator a
Page 45 and 46: N-28 sufficient to adequately illum
Page 47 and 48: IV-30 lack of follow-up training. N
Page 49 and 50: IV-32 16. Backup Operation (S6.9) -
Page 51 and 52: IV-34 This “looked but did not se
Page 53 and 54: W-36 e Clearance test block (S7.1.3
Page 55 and 56: IV-38 Structural Integrity, to iden
Page 57 and 58: IV-40 NHTSA assumes that the large,
Page 59 and 60: V. BENEFITS v-1 Serious injuries an
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v-3 retention strength test, CG and
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v-5 objective terms which should le
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VI-2 subject to the ADA requirement
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VI-4 averaged 35,000 units per year
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VI-6 In order to make an estimate o
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Cost Estimates VI-8 New Lift Hardwa
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VI- 10 close a circuit and send a s
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VI-12 FMVSS No. 141 Lift Certificat
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VI- 14 Total Cost for Public-Use Li
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VII. LEADTIME VII-1 Since the lift-
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VIII-2 Table VIII-1 SUMMARY OF SBA
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VIII-4 many private transit bus ope
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VIII-6 Many hundreds of small busin
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VIII-8 adaptive driving equipment f
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VIII-10 Facts Book, 7.2 percent of
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A- 1 REFERENCES 1. Americans with D
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A-3 25. A Directory of UMTA-Funded
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Figure 1 Dirgm Showing the Part8 of
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5 Figure 2. Isometric View of Platf
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PLATFORM DEFLECTION ANGLE DEFLECTIO
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.. Lln UP, OUTER BARRIER UP LIFT MI
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i I i I I I I i 1 i I ! j I I ~ __
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Memorandum - NHTSA

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