Memorandum - NHTSA

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VIII-5 o Each initial regulatory flexibility analysis shall also contain a description of any significant alternatives to the Final Rule which accomplish the stated objectives of applicable statutes and which minimize any significant economic impact of the proposed rule on small entities. The following is the agency’s Final Regulatory Flexibility Analysis for the Final Rule: A. A description of the reasons why action by the agency is being taken. The objectives of the Final Rule are to support the Americans with Disabilities Act (ADA) saf.:ty requirements for wheelchair lifts on vehicles such as transit, paratransit buses and school buse!.,. B. A succinct statement of the obiectives of. and legal basis for, the Final Rule. The objectives of the Final Rule are to support the requirements of the ADA specifically the Architectural and Transportation Barriers Compliance Board, 36 CFR Part 1192 (Part 111), Americans with Disabilities Act (ADA) Accessibility Guidelines for Transportation Vehicles, Final Guidelines. (See 56 FR 45558, September 6, 1991). <strong>NHTSA</strong>’s NPRM was issued (58 FIX 11562, February 26, 1993) in support of these requirements and proposed incorporating many proven wheelchair lift safety and design features prescribed by the ADA, FTA (formerly UMT 4) and the Department of Veteran Affairs into a Federal Motor Vehicle Safety Standard. Several new <strong>NHTSA</strong> initiated safety requirements were also proposed. An SNPRM was issued to ma�e these tests more objective and repeatable from a test procedure point of view. Other new wheelchair lift improvements such as 3 new lift safety interlock features, durability cycle testirlg and corrosion resistance requirements were included in the Final Rule. C. A description of and an estimate, if feasible, of the number of small entities to which the Final Rule will apply.
VIII-6 Many hundreds of small business entities will be affected as well as numerous other small organizations and small governmental jurisdictions. There are a number of small organization s and small government jurisdictions that will have to pay more for a wheelchair lift. The agency does not have an estimate of their number. The affects will be direct and indirect. The requirements are being proposed in the form of a wheelchair lift equipment standard (FMVSS No. 403) and a vehicle-based standard FMVSS No. 404. Many of the lift manufacturers whicl L are small businesses would be directly affected as would many of the transit/paratransit bus manufacturers, school bus manufacturers, and van converters/modifiers which alter minivans and full-size vans for personal use or paratransit use. The lift manufacturers would directly incur the added design and manufacturing expenses needed to modify their equipment to meet the new FMVSS requirements, if necessary, as well as incu . the added costs of conducting certification testing, identifying the applicable vehicles that theii lift designs fit and providing installation instructions/documentation for each configuration. The incremental FMVSS consumer cost is estimated to be $285-$305 for a wheelchair lift designecI for MPVs >4,540 kg (10,OO lbs.) GVWR and buses, and $233 for wheelchair lifts designed foi MPVs
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Subject: From: To: U.S.Department o
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TABLE OF CONTENTS Summary..........
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s-2 The annual number of persons in
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11. BACKGROUND 11- 1 Guidelines per
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11-3 and strength; control panel le
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111-2 Generally, there is very litt
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111-4 Table 111-1 Preliminary Natio
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111-6 The NEISS database lacks the
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111-8 Public Transit & Paratransit
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w-2 identifying the relevant lift c
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IV-4 MEASURE RED FLASHING BEACON OR
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IV-6 Acceleration is to be measured
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IV-8 FIGURE IV-2 :i a la Y t Permir
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IV-10 and vehicle size. This requir
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v-12 7. Prepare test block fnction
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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 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: VIII-4 many private transit bus ope
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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