Memorandum - NHTSA

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v-4 Many of the Final Rule requirements lack a demonstrated safety need and are based on logic, common sense and engineering judgment. Some of the requirements are based on anecdotal information shared with the agency staff. Although <strong>NHTSA</strong> examined the NEISS wheelchair incidence data for lifts, no information was contained in the file pertaining to cause and effect. Therefore, the requirements of the Final Rule can not be matched with incidence data. A number of commenters (e.g. Flexible, Mobile-Tech, St. Paul Public Schools, and the Iowa Department of Education) pointed out that they have no record of mishaps or injuries due to people getting caught in folding mechanisms or entangled in moving lift parts. In those cases where injuries or death are known to have occurred, and the cause was known, requirements that address those causes have been included in the Final Rule (e.g., interlocks that prevent stowag :if an occupant is on the lift, interlocks that prevent the outer barrier from flipping the WC and its occupant over, and a dynamic WC retention test that will prevent WC climbing or plowing- through the outer barrier). FMVSS No. 403 will allow the agency to remove defective ifts from the market (e.g., in effect DOT’Srecall and remedy authority is extended to WC lifts). This is not the case with ADA and voluntary standards such as FTA and SAE. Most of the requirements in the Final Rule are based on other standards, however, in many caE es these standards did not provide an objective means of determining compliance. .The Final Ruli: has addressed this issue extensively by describing as many requirements as possible in
v-5 objective terms which should lead to less ambiguity for the manufacturers and more effective :md efficient federal enforcement (recall and remedy) action on behalf of the consumer. The agency has not been able to quantify the benefits associated with the Final Rule because the NEISS accident data lacks adequate and sufficient descriptive information needed to pinpoint he probable cause of injury. However, there are a number of qualitative benefits associated with he Final Rule that incorporates the most relevant requirements of industry standards and guidelinl:s (e.g., DVA,SAE and FTA.) Thus, manufacturers need only comply with one standard rather than several, which will provide a consistent level of safety for all lift users. The Final Rule st ts minimum safety standards for lifts. In addition, the Final Rule addresses the injury mechanisn IS that have been identified by the agency.
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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
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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 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: v-3 retention strength test, CG and
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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