Memorandum - NHTSA

IV-30
lack of follow-up training. NHTSA is trying to eliminate or reduce human error by requiring t’le
lift operator to have a clear view of the lift user and lift at all times. This requirement was
designed to accommodate all types of controls and all types of lifts. The ability of an operator to
simultaneously operate more than one function at a time (e.g., the lift can not stow when
occupied) has been identified as a source of error leading to injury. This possibility has been
eliminated, by requiring the sequential operation of each control function. The sequentially
operated lift controls functions are to be clearly labeled in English using 2.5 mm (0.1”) high
letters:
1. “POWER” (ordoff switch) control located to avoid inadvertent operation, “DEPLOY”or
“FOLD”contro1, “DOWN” or “LOWER’ control, “UP” or “RAISE” control and “STOW’or
“FOLD” control.
2. Except for the “POWER’ control, these functions are not allowed to operate simultaneously.
3. The lift controMdisplays are located near the lift platform so the operator has a clear view o I‘
the lift passenger or passenger/mobility aid throughout the range of passenger motion.
4. Lift backup operating procedures (e.g., manual lift operation due to loss of electrical power)
are described in English and located on a placard near the lift controls/displays.
5. The lift controls and display board are illuminated for MPVs > 4,540 kg (10,000 Ibs.) GVW R
and buses, when the headlamps are actuated. For transit vehicles used in the fleet various
driver/operators may need to operate various lift designs under various lighting conditions. Fc r
personal use vehicles with lifts, the user and the operator are the same, and would be very
familiar with their lift controls.
6. A control system single point failure does not prevent operation of the vehicles’ interlocks.
Lift manufacturers currently label controls, but may use different size lettering, and NHTSA is
uncertain as to how many would comply with the Final Rule control illumination requirement::.