Memorandum - NHTSA

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VIII-9 There are no applicable reporting requirements. Each lift manufacturer must identify in its installation instructions the appropriate and suitable vehicle population by make/model and th~:s is reported in the installation instructions with each lift. The lift manufacturer has the burden of certifying compliance with FMVSS No. 403. The OEM vehicle manufactures must certify to FMVSS No. 404. Lift manufacturer certification is passed-through if the OEM and multi-stai,e manufacturers follows the installation instructions. Multi-stage manufacturers, when installin'; the lifts in minivans and full-size must ensure that van OEM certification envelopes for other FMVSS requirements (e.g., FMVSS Nos. 208, 214, 201) are not violated in the process. E. An identification, to the extent practicable, of all relevant Federal rules which may duplicae overlap, or conflict with the Final Rule. The ADA has duplicate requirements in many areas and the FTA has duplicate requirements ii I some areas. F. Each Final Regulatory Flexibility Analysis shall also contain a description of any simificaig altematives to the Final Rule which accomplish the stated obiectives of applicable statutes anc which minimize any simificant economic impact of the Final Rule on small entities. There is one alternative that might minimize any significant impact of the Final Rule on small entities. This alternative would be for manufacturers to install manual or power ramps, rather than power lifts, as these probably would be much less expensive. According to a 1997 APT,'i
VIII-10 Facts Book, 7.2 percent of the new bus sales in 1995 met accessibility requirements via ramps with 12.8 percent ramp-equipped orders in 1996 and 27.5 percent ramp-equipped planned in future orders. In 1996, about 75 percent of the buses ordered with FTA funds were low floodramp equipped buses. Apparently the ramps take up less space and allow more maneuverability for wheelchairs. Many minivans are equipped with folding power ramps, but the floor may have to be lowered. Many, if not all, of the requirement costs could be eliminal ed, but some of the vehicle interlock requirements might remain along with slip resistance, illumination, foot markings, etc CONCLUSIONS FMVSS No. 403/404 is not major within the meaning of E.O. 12866, but is a “significant” rulemaking within the DOT Regulatory Policies and Procedures. No benefits, significant or otherwise, have been quantified although there are qualitative benefits. <strong>NHTSA</strong> has studied tkle number of small business entities, small organizations, and small governmental jurisdictions involved and determined that this Final Rule may have a significant impact on a substantial number of small business entities at the $233-$305 incremental consumer cost level. The aggregate consumer cost is $4.46M-$7.00M. The Unfunded Mandates Reform Act The Unfunded Mandates Reform Act of 1995 (P.L. 104-4) requires agencies to prepare a writt .:n assessment of the costs, benefit and other effects of proposed or final rules that include a federal mandate likely to result in the expenditure of State, local and tribal government funds, in the
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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
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Figure m-3 Allowable transition dim
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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 and 84: VIII-4 many private transit bus ope
Page 85 and 86: VIII-6 Many hundreds of small busin
Page 87: VIII-8 adaptive driving equipment f
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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