Memorandum - NHTSA

W-27
potential for head contact with the bus door header area for a standing lift user. The marking c f
the platform edges will provide visual guidance to the wheelchair occupant so that they can
properly position themselves prior to operation of the lift, assuring unimpeded operation of the
outer barrier and inner roll stop. Knowing where to stand or place their wheelchair will reduce
the potential for lift user accidents and speed up overall operation.
NHTSA is requiring that the contrasting color or shade be at least 60 percent contrast for the
painted solid or chevron type stripe at the bus door opening, the lift platform perimeter, the
bridging device, and any designated standing area calculated as follows:
% Contrast = ((Ll-L2)/Ll) X 100 %
where L1 equals the luminance in foot-lambert of the lighter color or shade and L2 equals the
luminance in foot-lambert of the darker color or shade. L1 and L2 are measured perpendiculai to
the platform surface with illumination provided by a diffuse light and a resulting illuminance clf
the platform surface of 323 lm/m2(30 lumen/ft2).
Platform markings are not required by the Access Board, but standee markings are. All lifts
being manufactured are believed to include perimeter marking and could comply with the abo.re
requirements with little cost impact. It is proposed that only lifts on transit vehicles would have
a designated standing area. Although these may currently be marked in some fashion, they mz y
not meet the SNPRM requirement so there may be a small incremental cost.
13. Platform Lighting (S6.4.11) - Buses and MPVs providing public transportation often 0perit.te
at night when vision is obscured. Indirect lighting from the vehicle’s interior may not be