October 25, 2000
Docket Clerk
Docket Management Room
PL-401
400 Seventh Street, SW
Washington, DC 20590
RE: Docket Number NHTSA-98-4511
Dear Docket Clerk:
The American Public Transportation Association (APTA) is pleased to
respond to the National Highway Traffic Safety Administration’s (NHTSA) Supplemental
Notice of Proposed Rulemaking (SNPRM) on Platform Lift Systems for Accessible Motor
Vehicles and Platform Lift Installations on Motor Vehicles.
About APTA
APTA is a nonprofit international trade association of over 1,300
member organizations including transit systems; planning, design, construction and finance
firms; product and service providers; academic institutions, and state associations and
departments of transportation. APTA members serve the public interest by providing safe,
efficient and economical transit services and products. Over ninety percent of persons
using public transportation in the United States and Canada are served by APTA members.
Background
The SNPRM proposes federal motor vehicle safety standards that would
require platform lift manufacturers to ensure that lifts meet minimum platform dimensions
and size limits on platform protrusions and gaps between the platform and either the
vehicle floor or the ground. The standards would also require handrails, a threshold
warning signal, and retaining barriers for lifts.
Comments
Overview
We note that transit equipment was only "observed" in
developing these requirements and the cited injury statistics were gathered before or in
the early days of the Americans With Disabilities Act (ADA). The vehicles observed may not
have been compliant yet with 49 CFR Part 38 (Transportation for Individuals with
Disabilities, subpart B - Buses, Vans and Systems) standards. Since that time, transit
operators have developed significant experience regarding ADA matters, and ADA-compliant
equipment is standard throughout the industry. The use of this new equipment may have had
some impact on statistics relating to injuries associated with lifts, and we thus urge
NHTSA to consider whether a review of more recent data in this regard would be warranted.
Particular Comments
S5.4.7 Wheelchair Retention would require that the lift have a
means of retaining the test device specified in S6.4.2 upright with all of its wheels on
the platform surface, vehicle floor, bridging device or a combination of these throughout
the range of passenger operation. S6.4 Wheelchair Impact Retention Test and S6.10 Wheelchair
Retention Overload Test would specify a complex set of tests with a mobility aid
meeting certain criteria to ensure that the lift meets the requirements. Included in S6.10
is the specification that the wheelchair retention device be able to withstand a force of
1,600 pounds.
These requirements raise a number of questions, including the
possibility of whether any current lift, particularly lifts commonly used on paratransit
vehicles, would meet this specification without significant redesign. Moreover, the
proposed language is unclear about whether the mobility aid wheels must remain on the
floor throughout the entire test; absent any specific guidance to the contrary, it appears
this is the case.
S5.10 Interlocks contains several requirements for preventing
further motion of the lift when certain conditions are met. Many of these are currently
required by Part 38 specifications or were contained in the NPRM. Several which have been
added in this SNPRM are of particular concern. For example, S5.10.2.6 would prohibit
stowing of the wheelchair retention device unless the lift is three inches or less above
the ground. This requirement would seem to prohibit certain types of lifts' cycles, which
stow the lift when they reach the level of the first step. Other requirements raise
numerous concerns, particularly about the use of sensitive edges. For a variety of
reasons, it is likely that the result of applying these requirements in the public
transportation environment would be an increase in lift failures and operational delays as
well as added maintenance, with only a marginal increase in safety when the lift is
properly operated by a trained professional.
In addition, the requirement for continuous edge guards along the
entire length of the platform would prohibit the current practice of ending the guard
approximately three inches before the inward edge of the lift along the wheelwell side.
This would reduce maneuverability by requiring mobility aid users to go further into the
vehicle before being able to turn and would not increase safety as the inner roll stop
would prevent the passenger from moving forward enough to go off the side.
Regarding the Unobstructed Platform Operating Volume: on the upper
surface of the platform, we suggest a minimum clear width of 32 inches. This is based on
operator experience regarding several wheelchair/scooters that are too wide for the 30
inch platforms.
Finally, we are also concerned that the proposed rules do not address
rebuilding or retrofitting lifts in vehicles purchased prior to the effective date of
these rules.
Conclusion
We appreciate the opportunity to comment on this SNPRM, and stand ready
to help NHTSA in the implementation of requirements that enhance safety in public
transportation. For further information, please contact Jerry Trotter at (202) 496-4887,
or internet e-mail jtrotter@apta.com.
Sincerely yours,
William W. Millar
President
WWM/cbo
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