Memorandum - NHTSA

Cost Estimates
VI-8
New Lift Hardware Costs - As discussed earlier in Section IY.NHTSA’s Supplemental Notice of
Proposed Rulemaking, it is believed that most of the lift equipment on the market designed for
MPVs > 4,540 kg (10,000 lbs.) GVWR and buses, already meet the proposed minimum
performance requirements, except for those items in Table VI-2. The SNPM proposed
additional lift safety features that incur incremental consumer costs. These include: an outer
barrier (S5.4.7), standee platform markings (S5.4. lo), control system lettering size and
illumination per FMVSS No.101 (S5.7), threshold warning device (S5.1., S5.1.1 and S5.1.2), is
well as several interlocks [e.g., Anti-Crush Interlock (S5.10.2.7), Occupied Outer Barrier
Interlock (S5.10.2.8), Occupied Roll Stop Interlock (S5.10.2.9) and Occupied Bridging Devici:
Interlock (S5.10.2.10)]. A relay switch would have to be added as well to the lift control system
in order to process the lift interlock signals. The lift interlock signals essentially override the
operator’s controls and stop the lift. In the Final Rule, the requirements for the Anti-Crush
Interlock and the Occupied Bridging Device Interlock were omitted due to cost and feasibility
considerations.