Memorandum - NHTSA

VI-12
FMVSS No. 141 Lift Certification Labor Hours of the Preliminary Regulatory Evaluation and
Regulatory Analysis Platform Lifts for Motor Vehicles FMVSS Nos. 141 and 142 on page VI- 14
to VI-16.
Lift Improvement Hardware Labor Cost
There will also be design engineering/production engineering labor costs as well as one-time tc )ol
and die capital equipment cost for the new lift hardware components. The variable
desigdproduction engineering labor costs are estimated to be about $20K - $40K per lift
manufacturer to modify two (2) existing lifts and includes owners manual inserts and installation
instruction upgrades. The certification labor cost and the design engineering production
engineering labor cost per unit is passed on to the consumer. The tool and die costs are estimated
at $5K - $10K per 2 lift designs. The one-time tool and die capital equipment costs are
amortized over a 10 year lift production cycle and are passed to the consumer in higher lift costs.
These costs are added to the incremental hardware improvement costs.
Total Labor or Variable Cost per Lift - There are at least 10 known lift manufacturers namely:
Braun, Lift-U, Ricon, Mobile-Tech, Crow River, T.E.S.Provost, Stewart & Stevenson,
Environmental Equipment Corporation, Collins and Champion. There may be other unknown lift
manufacturers. The assumption is made that about 6 manufacturers will have 2 basic lift desil ps
to certiQ over the next 10 years for (Public-Use) MPVs and buses >4,540 kg (10,000 lbs.)
GVWR. The total certification labor cost for these manufacturers is estimated to be $52,000 =
(2 X 6 X $4,300).