Memorandum - NHTSA

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v-9 3. Platform Requirements (S6.4) Unobstructed Platform Operating Volume (S6.4.2) - The Final Rule requires that the lift platform have a minimum clear width of 762 mm (30 in.) measured from the platform surface to 762 mm (30 in.) above the platform, and a minimum clear length of 1,219 mm (48 in.) measui ed from 5 1 mm (2 in.) above the surface of the platform to 762 mm (30 in.) above the surface of.he platform. This represents an unobstructed volume of length, width and height 1,219 X 762 X 724 mm (48” X 30” X 28.5”). See Figure 6 in the Appendix. <strong>NHTSA</strong>’s unobstructed platform operating volume is based on the Access Board’srequiremenix The size of the lift platform was determined by the length and width of the population of wheelchairs-in-use and constrained by the known distance between structural members (A and B pillars) of doors in buses. In addition, at least 1,219 mm (48 in.) of length is also needed to accommodate three-wheeled mobility aids called “scooters” which are longer than most traditional wheelchairs and as long as the larger wheelchairs. <strong>NHTSA</strong>’s requirement is believt ,d to accommodate 90-95 percent of the wheelchair population and nearly 100 percent of the scooter population. This requirement is consistent with the Access Board’s guidelines. The requirements would apply to lifts on vehicles greater than 4,540 kg (10,000 lbs.) GVWR II.S these would be commercial vehicles serving the public with a variety of wheelchair/mobility ai.d sizes and configurations. No platform volume or size is required for MPV lifts or lifts on vehicles 4,540 kg (
IV-10 and vehicle size. This requirement is consistent with the Access Board’s guidelines. All buse,;, except the ones with narrow entrance ways mentioned above, can accommodate a 762 X 1,21’1 mm (30” X 48“)platform, hence, there is no FMVSS cost impact of this requirement. Platform Slip Resistance (S6.4.12 and S7.2) A minimum platform surface slip resistance of 0.65 is required to prevent wheelchairs and people using walkers and canes from slipping on the platform’s surface, particularly when wet. A slip resistant surface reduces the accident potential for people standing on the lift and provides traction for a wheelchair. A performance test (S7.2) measures the slip resistance of the lift loading platform when wet using a friction block rather than a specific wheelchair design as proposed in the NPRM. The Friction Block Method proposed in the SNPRM and adopted in the Final Rule has been shown to be practicable, objective and repeatable. The Department of Transportation (DOT) regulations for disabled individuals are contained in 49 CFR, Part 38 - Americans with Disabilities Act (ADA) Accessibility Specifications for Transportation Vehicles. Section 38.23(b) is concerned with vehicle lifts and states “...the platform surface shall be slip resistant.’’ The Federal Transit Administration=s (FTA) procurement guidelines for bus lifts also requires slip resistant surfaces. The Department of Veterans Affairs (DVA) standard for wheelchair lifts specifies that the lift platform surfaces must provide “adequate tire traction.” The same requirement is contained in the SAE draft standard for wheelchair lifts. However, none of the requirements stated above provide an objective test procedure for determining the adequacy of the slip resistance of the lift platform.
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 and 10: 11-3 and strength; control panel le
Page 11 and 12: 111-2 Generally, there is very litt
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: IV-8 FIGURE IV-2 :i a la Y t Permir
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
Page 61 and 62: v-3 retention strength test, CG and
Page 63 and 64: v-5 objective terms which should le
Page 65 and 66: VI-2 subject to the ADA requirement
Page 67 and 68: VI-4 averaged 35,000 units per year
Page 69 and 70: VI-6 In order to make an estimate o
Page 71 and 72: Cost Estimates VI-8 New Lift Hardwa
Page 73 and 74: VI- 10 close a circuit and send a s
Page 75 and 76: VI-12 FMVSS No. 141 Lift Certificat
Page 77 and 78:
VI- 14 Total Cost for Public-Use Li
Page 79 and 80:
VII. LEADTIME VII-1 Since the lift-
Page 81 and 82:
VIII-2 Table VIII-1 SUMMARY OF SBA
Page 83 and 84:
VIII-4 many private transit bus ope
Page 85 and 86:
VIII-6 Many hundreds of small busin
Page 87 and 88:
VIII-8 adaptive driving equipment f
Page 89 and 90:
VIII-10 Facts Book, 7.2 percent of
Page 91 and 92:
A- 1 REFERENCES 1. Americans with D
Page 93 and 94:
A-3 25. A Directory of UMTA-Funded
Page 95 and 96:
Figure 1 Dirgm Showing the Part8 of
Page 97 and 98:
5 Figure 2. Isometric View of Platf
Page 99 and 100:
PLATFORM DEFLECTION ANGLE DEFLECTIO
Page 101 and 102:
.. Lln UP, OUTER BARRIER UP LIFT MI
Page 103 and 104:
i I i I I I I i 1 i I ! j I I ~ __
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Memorandum - NHTSA

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