Memorandum - NHTSA

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11-2 In developing the Final Rule, NHTSA has relied extensively on the Access Board and Federal Transit Administration (FTA) sponsored guidelines, as well as standards and recommended practices/procedures of other organizations, such as the Department of Veteran Affairs (DVA) [formerly the Veterans Administration (VA)] and the Society of Automotive Engineers (SAE).2,&,3The DVA requirements and the SAE draft recommended practices are intended foi, the private, personally-licensed lift user (e.g., a disabled person with a modified van or MPV). The Access Board's guidelines were adopted from FTA sponsored active and passive lift guidelines, and are believed to reflect the capabilities of lift equipment on the market today. The FTA guidelines were developed by a large panel of regulators; transit bus owners/operators; ussrs and bus manufacturers in the 1986-87 time NHTSA added requirements beyond the Board's guidelines that are based on the FTA guidelines. Most lifts are currently being market(:d and designed around the FTA's guidelines, and the improvements required by NHTSA in the Final Rule are not expected to increase lift costs significantly. The agency identified a number of reasonable safety improvements in the SNPRM, not contair ed in the Access Board's guidelines. These improvements include: upgraded outer barrier height 2 VA Standard Design and Test Criteria for Safetv and Quality of Automotive Wheelchair Lift Systems fig Passenger Motor Vehicles, VAPC-A-7708-3, June 28, 1977 3National Workshop on the Bus-Wheelchair Accessibility, Guideline Specifications for Active Wheelchllir (WC) Lifts, Passive WC Lifts, WC Ramps, and WC Securement Device ,UMTA Publication-UMTA-ITO6-0322-87, May 1986 4 National Workshop on the Bus-Wheelchair Accessibility, Guideline Specifications for Active Wheelchiiir (WC) Lifts, Passive WC Lifts, WC Ramps, and WC Securement Device ,UMTA Publication-UMTA-IT06-0322.87, May 1986
11-3 and strength; control panel lettering size and illumination; high contrast platform markings for standees; threshold warning device; anti-crush interlock; outer barrier and inner roll stop interlock devices; and a bridging interlock device. The final rule included all these improvements except for the anti crush interlock and the bridging interlock device. The SNPR M also proposed a number of safety tests, which include: slip resistance test; wheelchair retentioi i test; handrail test; corrosion resistance test; and fatigue endurance test. In no area did the agen,:y propose a less stringent requirement than specified by the Access Board.
Page 1 and 2: 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: 11. BACKGROUND 11- 1 Guidelines per
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 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
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Cost Estimates VI-8 New Lift Hardwa
Page 73 and 74:
VI- 10 close a circuit and send a s
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VI-12 FMVSS No. 141 Lift Certificat
Page 77 and 78:
VI- 14 Total Cost for Public-Use Li
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VII. LEADTIME VII-1 Since the lift-
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VIII-2 Table VIII-1 SUMMARY OF SBA
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VIII-4 many private transit bus ope
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VIII-6 Many hundreds of small busin
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VIII-8 adaptive driving equipment f
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VIII-10 Facts Book, 7.2 percent of
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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
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.. 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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