Memorandum - NHTSA

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N-13 Platform Protrusions (S6.4.3) - Protrusions on the lift platform make it difficult for wheelchair boardinddeboarding. For an electric wheelchair, additional propulsive power may be needed o overcome a floor level obstruction, but the sudden acceleration could result in loss of control and an accident. NHTSA is proposing that when the lift's outer barrier (wheelchair retention devic :e) or inner roll stop is down, movement on or off the lift platform should be easy and uninhibited For buses and MPVs (>4540 kg (10,000 lbs.) GVWR), NHTSA is proposing in the SNPRM tllat lift platform surfaces are not to have protrusions which rise more than 6.5 mm (0.25") when measured perpendicular to the platform surface. For personal use vehicles, lift platform surfaces are not to have protrusions, which rise more than 13 mm (0.5") when measured perpendicular lo the platform surface. All portions of the sides of a protrusion that are between 6.5 mm (0.25") and 13 mm (0.50") above the platform are to have slopes not exceeding a 1:2 ratio. For buses and MPVs>4,540 kg (10,000 lbs.) GVWR, NHTSA's SNPRM is consistent with all aspects of the ADA including for protrusion height. The Access Board has a 6.25 mm (0.25") maximum, which NHTSA has adopted. Lift manufacturers have indicated that mechanisms tc, hold the required outer barrier in-place may require protrusions through the lift platform when the outer barrier is up. Such protrusions would be allowable in the subject SNPRM. The Acc.:ss Board, FTA and SAE all have protrusion limitations and NHTSA is adopting the Access Board's specifications. All currently manufactured lift equipment would be expected to comply.
IV-14 Gaps, Transitions and Openings (S6.4.4) NHTSA is concemed about vertical transitions entering or exiting the platform at the ground/floor levels, slopes between transitioning vertic: 1 planes, vertical gaps, horizontal gaps, platform surface openings and edge guards gaps. Poor vertical transitions can be an impediment to power as well as manually operated wheelchairs. In addition, vertical gaps, which are too large, can impede boardingdeboarding passengers. The small tires of the wheelchair could get caught in horizontal gaps or platform openings. TI Le requirements are as follows: S6.4.4.1 Vertical Transitions - For ground level loading, the maximum vertical transition heig it is 6.5 mm (0.25") and for lift to bus floor transitions, the maximum vertical height is 6.5 mm (0.2 5'I). S6.4.4.2 Slopes - No vertical transition can be more than 6.5 mm (0.25") at either the ground or vehicle level. Horizontal gaps are limited to13 mm (0.50"). Between 6.5" and 13 mm (0.25"- 0.50") rise, the platform or vehicle surface slope can not exceed a 1:2 ratio. Above a 13 mm (0.50") rise, the slope an not exceed 1:8 ratio. The total allowable rise is limited to 76 mm (3.0"). (See Figure IV-3 - Allowable Transition Dimensions and Slopes for Platform Entranc.: and Exit at Vehicle and Ground Level.) S6.4.4.3 Vertical Gaps - For the inner roll stop and outer barrier (eg, Wheelchair Retaining Device) in the upright, deployed position, the SNPRM defines a Block Test 15.9 X 15.9 X lo:? mm (0.625" X 0.625" X 4") where the long axis is held perpendicular to the "platform referen1:e
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 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: v-12 7. Prepare test block fnction
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
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.. 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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