Memorandum - NHTSA

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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 <strong>NHTSA</strong> 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.
IV-40 <strong>NHTSA</strong> assumes that the large, full-size vans would be equipped with vertical lifts because th(:y are higher off the ground and would be subject to FMVSS 404. However, minivans (with lowered floors) would tend to be equipped with power ramps, which would not be subject to a iy FMVSS. The proportion of lift vs. ramps used in minivans is unknown. Some large vans are less than 4,540 kg mass (10,000 lbs.) GVWR and some with the same body style exceed 4,540 kg mass (10,000 lbs.) GVWR - given different suspension options. This implies two different FMVSS equipped lifts would be needed for the same vehicle. MPVs >4,540 kg (10,000 lbs.) are used as commercial or public vehicles. Most MPVs 4,540 kg mass (10,000 lbs.) GVWR and buses. FMVSS No. 403 is consistent with the ADA guidelines for these vehicles. The non-ADA affected vehicles in the subject rulemaking are personal vehicle s
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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 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: IV-38 Structural Integrity, to iden
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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