Memorandum - NHTSA

Iv-39
Vehicle Tests vs. Fixture Tests - Some requirements are lifthehicle interface related and so
certification tests must be conducted on the test vehicle itself (e.g., roll stop pinch test, Static
Load I, fatigue endurance, Static Test Load 11, platform deflection, etc.), whereas some
requirements are lift-only related (independent of the test vehicle) [e.g., slip resistance,
environmental resistance, inner and outer bamer dynamic tests, hand rail strength test, outer
barrier over load test, platform marking contrast, 1,088 kg mass (2,400 lbs.) Static Test 111, etc ]
can be conducted on a static fixture or jig. The latter approach using jigdfixtures is an option 1 If
the lift manufacturers can use to certify.
Note: The Access Board did not specify tests, but rather performance and design guidelines.
To facilitate FMVSS objectivity NHTSA added a platform deflection test, a static load test, an
inner roll stop test, a dynamic outer barrier retention test and a slip resistance test among man3
others.
OTHER APPLICABILITY CONSIDERATIONS
WC Lifts vs. Ramps - A large proportion of vans used for paratransit purposes are ramp equip led
(driver operated) and many personal minivans are equipped with power operated ramps. In 1996,
over 75 percent of the transit buses subsidized with federal funds by FTA were low floor/ramr
equipped. Although a ramp may be considerably less expensive compared to a lift, the
incremental cost of a lower floor bus would probably offset any savings. According to 1997
APTA data, 7.2 percent of new buses purchased in 1995 included ramps as a means of WC
accessibility. WC ramps are not subject to the requirements of FMVSS No.403/404.