(a) New, used and remanufactured rapid rail vehicles, to be considered accessible by regulations issued by the Department of Transportation in 49 CFR Part 37, shall comply with this subpart.
The Americans with Disabilities Act (ADA) requires new or used vehicles that are purchased or leased after August 25, 1990, to be accessible. A public entity may purchase or lease a used rapid rail vehicle for use on its rapid rail system that is not readily accessible to and usable by individuals with disabilities, if after making demonstrated good faith efforts to obtain an accessible vehicle, it is unable to do so. See 49 CFR �.81(c) for the criteria for good faith efforts. Vehicles that are remanufactured after this date to extend their usable life for 10 years or more are also required to be accessible, to the extent that it does not compromise the structural integrity of the vehicle. On October 4, 1990, DOT issued an interim set of requirements for such vehicles.
The guidelines discussed in this technical assistance document are substantively identical to standards issued by DOT on September 6, 1991, at 49 CFR Part 38 and replace the interim rules. The DOT rule at 49 CFR Part 37 further outlines the applicability and effective dates of these requirements. Questions as to whether certain vehicles are subject to these standards and specific effective dates should be directed to DOT.
(b) If portions of the vehicle are modified in a way that affects or could affect accessibility, each such portion shall comply, to the extent practicable, with the applicable provisions of this subpart. This provision does not require that inaccessible vehicles be retrofitted with lifts, ramps or other boarding devices.
This provision is similar to existing requirements of common accessibility codes and should be viewed as an "opportunity" clause. That is, when modifications are made for any reason, the opportunity must be explored to provide the maximum access feasible. When a vehicle is modified, each element that is part of the modification should be brought into compliance with the applicable sections of these requirements. For example, if a vehicle's floor is resurfaced and its electrical system rewired, the new floor surface must be slip resistant at aisles and areas used by standees and mobility aid users. If existing audible signals are replaced or rewired, the installation of audible and visual door signals would also be required as part of the modification project. The intent of this provision is to ensure that elements of a vehicle will be made accessible when the opportunity to do so exists in the regular course of modifying or upgrading vehicles. However, those elements of the vehicle not affected by the modification plan would not have to be brought into conformance with these requirements. Under any modification plan, the installation of a bridge plate or other boarding device is not required, even if the entrance of a vehicle is modified.
(c) Existing vehicles which are retrofitted to comply with the "one-car-per-train rule" of 49 CFR 37.93 shall comply with Ё1192.55, 1192.57(b), 1192.59 and shall have, in new and key stations, at least one door complying with �92.53(a)(1), (b) and (d). Removal of seats is not required. Vehicles previously designed and manufactured in accordance with the accessibility requirements of 49 CFR Part 609 or Department of Transportation regulations implementing section 504 of the Rehabilitation Act of 1973 that were in effect before October 7, 1991 and which can be entered and used from stations in which they are to be operated, may be used to satisfy the requirements of 49 CFR 37.93.
The ADA requires that at least one car in each train having two or more cars be accessible by 1995. Some operators will choose to make existing cars accessible in order to meet this requirement. In such situations, this provision requires only that vehicles conform to the following requirements listed in the chart below.
The requirement for "at least one door" is designed to accommodate curved platforms in existing stations where not all vehicle doors can attain the same horizontal gap. Notice also that the gap requirements pertain only to existing stations which have been designated as key stations. The horizontal gap requirements can be met by installing a protruding sill at some doors or adding material to the platform edge face. However, information supplied to the Board suggests most existing vehicles will meet these requirements without modification.
Existing vehicles that meet previous accessibility standards can also be used to meet the "one-car-per-train" rule without any retrofit. Specifically, these standards include those issued by FTA for vehicles obtained with FTA funds and those issued by DOT under Section 504 of the Rehabilitation Act of 1973, which cover transit systems receiving Federal funds. Further information on these standards can be obtained from DOT.
Requirements for retrofitted vehicles:
Priority seating signs
Clear floor space (so that a route 32 inches wide leading to an area that can accommodate two wheelchair spaces each 30 by 48 inches in size is provided)
Slip resistant floor surfaces
One accessible door that in new and key stations:
- provides 32 inches of clear width;
- is designated by the International Symbol of Accessibility; and
- is coordinated with the platform so that the horizontal gap does not exceed 4 inches and the vehicle floor is within plus or minus 2 inches of the platform height when the vehicle is loaded to 50% of its capacity.
(a) Clear Width
(1) Passenger doorways on vehicle sides shall have clear openings at least 32 inches wide when open.
The provision for a clear opening width of 32 inches has been in effect since 1976 for FTA-funded vehicles and should be met easily. The door width specified is not designed solely to accommodate wheelchair users. Rather, the dimension is designed to provide space for the crutch-tip-to-crutch-tip distance of a typical crutch user. Also, the requirement is for a "clear opening." Providing a wide doorway with a vertical stanchion in the center does not meet this requirement.
(2) If doorways connecting adjoining cars in a multi-car train are provided, and if such doorway is connected by an aisle with a minimum clear width of 30 inches to one or more spaces where wheelchair or mobility aid users can be accommodated, then such doorway shall have a minimum clear opening of 30 inches to permit wheelchair and mobility aid users to be evacuated to an adjoining vehicle in an emergency.
This requirement applies only to new vehicles equipped with end doors that can be reached by a wheelchair or mobility aid user. This means that where there is a route at least 30 inches wide leading from the area containing accessible spaces to the end door, then the end doors must provide a minimum of 30 inches clear width. Since the clear area in which mobility aid users can position themselves is usually located at the ends of cars, the end doors will most likely be in close proximity to accessible spaces. This requirement does not apply to vehicles that are designed with a route leading to the end doors that is less than 30 inches wide at any point or that is inaccessible in any other aspect (e.g., steps). However, this provision should not be viewed as an excuse to arbitrarily place stanchions or arrange seats to preclude a 30-inch wide passage to avoid having to specify 30-inch wide end doors.
These guidelines do not address evacuation procedures or require that end doors be used in emergencies or that they be part of an evacuation route. For a variety of reasons, the end doors might not be used by a transit system's evacuation plan. In addition, a transit system's evacuation plan that requires the use of side doors would not be precluded by this provision. Further, the evacuation route leading from the train itself is often inaccessible, especially in tunnels, because of narrow walkways, catwalks, and escape ladders that are part of evacuation routes. Nevertheless, the end doors of new vehicles can easily be designed to be functionally accessible (i.e., have 30 inches of clear width) and should be accessible in case they may serve as an accessible means of egress. In limited emergencies, such as when the side doors of a car fail, accessible end doors would be the only means of exit. Additionally, the Board recognizes that this provision does not guarantee access into adjoining cars since existing cars may not have end doors with 30 inches of clear width. However, as old cars are replaced over time and the number of accessible cars on each train increases, the chances of providing an accessible connection between cars will be greater.
Existing cars or cars retrofitted under the "one-car-per-train" rule are not subject to this requirement.
(b) Signage
The International Symbol of Accessibility shall be displayed on the exterior of accessible vehicles operating on an accessible rapid rail system unless all vehicles are accessible and are not marked by the access symbol.
Under this requirement, all new vehicles must be designated by the International Symbol of Accessibility (access symbol). However, new vehicles acquired for a rapid rail system in which all vehicles are accessible and which are not designated by the symbol do not have to be designated. In fully accessible systems, consistency is important, so that if existing accessible vehicles are designated, new vehicles should be designated as well. Still, the Board considers the access symbol to be at times subject to over-use and thus recommends that transit operators remove symbols when all cars are accessible. Since cars are usually designated by decals, which eventually wear and must be replaced, operators may opt to simply not replace them.
The placement of the access symbol is not specified by these guidelines. It is recommended that the symbol be placed at each accessible passenger door of an accessible vehicle. If the clear floor area for wheelchair or mobility aid users is provided at only one end of a car, then only those passenger doors at that location should be designated.
(c) Signals
Auditory and visual warning signals shall be provided to alert passengers of closing doors.
Audible signals have been required by existing FTA regulations since 1976. Audible signals usually activate before the doors begin to close and thus provide advance warning that the doors are about to close. Without visual signals, persons with hearing impairments are not afforded any equivalent advance warning and can only detect closing as the doors actually begin to close. According to information received during the development of these guidelines, the addition of audible and visual warning signals for automatically-operated doors of new vehicles is feasible and represents only a modest cost increase for a chime, light, and associated electrical controls at each doorway. These signals are not required to be provided on existing vehicles or those that are retrofitted. Since proposed requirements for door closing force and speed have been removed, the Board considers the provision of audible and visual indicators to be of even greater importance.
Visual warning signals should be visible from both inside and outside the car. This can be achieved by equipping the entrances of new cars with both an interior and exterior light indicator. Also, it is conceivable that a single light indicator, by either its illumination level, design, or placement may be specified so that it is visible both inside and outside the car. Either method of addressing this requirement is acceptable so long as it provides a visual warning that doors are about to close to persons who are entering or exiting the car. Further, visual indicators should be synchronized with audible signals so that equivalent advance notification of door closure is provided to all persons, including those with hearing or visual impairments.
(d) Coordination with Boarding Platform
(1) Requirements
Where new vehicles will operate in new stations, the design of vehicles shall be coordinated with the boarding platform design such that the horizontal gap between each vehicle door at rest and the platform shall be no greater than 3 inches and the height of the vehicle floor shall be within plus or minus 5/8 inch of the platform height under all normal passenger load conditions. Vertical alignment may be accomplished by vehicle air suspension or other suitable means of meeting the requirement.
These specifications for vehicle coordination with the platform pertain to new vehicles operating at new stations. This provision, and the exceptions that follow, outline the maximum horizontal gap and vertical tolerance allowed under these guidelines. However, the goal is that vehicles be specified to be level with the platform edge and as close to it horizontally as possible, so that under normal passenger conditions these maximum levels are not exceeded. It is understood that these tolerances, even when specified in the acquisition of new vehicles, may not be achieved under all conditions. These requirements are based on normal passenger conditions. It is incumbent on the operator not only to specify the correct floor height when ordering vehicles (and accepting them only if they meet the specification) but also to correctly specify the rail-to-platform height for new stations. Thus, it is important to keep in mind that the horizontal gap and vertical tolerance are dependent not only on the vehicle specifications but also the design and construction of station platforms and track specifications. Those requirements, including gap tolerances and the rail-to-platform height, are provided at 49 CFR Part 37, Appendix A.
In those unique instances where a new rapid rail system cannot meet these gap requirements, the operator would be able to pursue alternative means of reducing gaps under the procedure for equivalent facilitation contained in DOT's rule (see 49 CFR 37.7). Also, the Board recognizes that close tolerances during construction or manufacture cannot ensure continued conformance to a given standard. Variations, such as those resulting from normal wear or material variations would not be deemed violations of the guidelines. However, only those variations within the limits of accepted industry practices or tolerances are allowed. (See Subpart A of the beginning of this manual for further discussion of dimensional tolerances.) When the variation exceeds these limits, adjustments would be required to bring the vehicle back into alignment.
(2) Exception
New vehicles operating in existing stations may have a floor height within plus or minus 1-1/2 inches of the platform height. At key stations, the horizontal gap between at least one door of each such vehicle and the platform shall be no greater than 3 inches.
The ability to closely align new vehicles with existing station platforms is limited by the rail-to-platform height and the vertical distance between the tracks and the platform. Existing stations are not required to be altered under the ADA, unless they are a "key" station. This provision allows new vehicles serving existing stations, including key stations, a greater vertical tolerance since the existing platform height may make the 5/8 inch tolerance infeasible. The design of existing platforms, such as those that are curved, can make the provision of the same horizontal gap infeasible at all doors. In view of this, the three inch horizontal gap requirement has been limited only to key stations, which are required to be made accessible under the ADA, and does not apply to other existing stations. Further, only one door of a new vehicle is required to meet the 3 inch gap requirement since, in the case of curved stations, a uniform gap cannot be achieved along the side of a vehicle. A system could, as one transit operator has suggested, designate one location where such tolerances are achieved along a portion of a curved station platform. New vehicles could be ordered with a slight sill protrusion to reduce the horizontal gap in stations where a wider gap currently exists.
(3) Exception
Retrofitted vehicles shall be coordinated with the platform in new and key stations such that the horizontal gap shall be no greater than 4 inches and the height of the vehicle floor, under 50% passenger load, shall be within plus or minus 2 inches of the platform height.
This exception pertains to existing vehicles that are made accessible under the "one-car-per-train" rule. Generally, existing vehicles cannot be coordinated with the platform to the degree that new vehicles can. Even if feasible, retrofitting existing vehicles to meet the requirements for new vehicles could be very expensive. Consequently, this exception allows a greater and more easily achievable horizontal gap and vertical tolerance. These vehicles need to be aligned with the platform at new stations or key stations so that the horizontal gap does not exceed 4 inches and the vertical tolerance is less than 2 inches. While the Board does not consider such a gap to be independently negotiable by many wheelchair users, such vehicles will eventually be phased out as new vehicles are added to the system.
| Horizontal and Vertical Tolerances | ||
|---|---|---|
| New Stations | Key (Existing) Stations | |
| New Vehicles | 3" horizontal gap, 5/8" vertical tolerance | 3" horizontal gap (1 door), 1-1/2" vertical tolerance* |
| Retrofitted Vehicles | 4" horizontal gap, 2" vertical tolerance | 4" horizontal gap (1 door), 2" vertical tolerance |
* Also applies to new vehicles operating at existing stations, not just key stations.
(a) Each vehicle shall contain sign(s) which indicate that certain seats are priority seats for persons with disabilities, and that other passengers should make such seats available to those who wish to use them.
The content of signs is not specified by this requirement and is left up to the discretion of transit operators. At a minimum, the sign should indicate which seats are intended for use by persons with disabilities.
(b) Characters on signs required by paragraph (a) of this section shall have a width-to-height ratio between 3:5 and 1:1 and a stroke width-to-height ratio between 1:5 and 1:10, with a minimum character height (using an upper case "X") of 5/8 inch, with "wide" spacing (generally, the space between letters shall be 1/16 the height of upper case letters), and shall contrast with the background, either light-on-dark or dark-on-light.
These requirements for the character height and proportion are based on existing Federal requirements for building and facility signage, augmented by the results of research sponsored by the Board. In general, the requirement is designed to eliminate type faces with letters which are short and fat or tall and thin. Also, the individual stroke lines should not be especially thin or thick. Many common type faces fit within these aspect ratios. If the specifications are included in bid documents, signage manufacturers should have little difficulty supplying appropriate type styles.
Contrast can be provided either with light characters on a dark background or dark characters on a light background. However, light_colored characters against a dark background are preferred since studies have shown that this type of contrast is more readable for persons with low vision. A minimum level or percentage of contrast between characters and the background of the sign is not specified. Research, however, indicates that signs are more legible for persons with low vision when characters contrast with their background by at least 70 percent. Contrast in percent is determined by:
Contrast = [(B1 - B2)/B1] x 100
where B1 = light reflectance value (LRV) of the lighter area
and B2 = light reflectance value (LRV) of the darker area.
Note that in any application both white and black are never absolute; thus, B1 never equals 100 and B2 is always greater than 0.
Although not required, it is also recommended that the characters and background of signs should be eggshell, matte, or other non-glare finish. An eggshell finish (11 to 19 degree gloss on 60 degree glossimeter) is preferred.
�92.57 Interior circulation, handrails and stanchions
(a) Handrails and stanchions shall be provided to assist safe boarding, on-board circulation, seating and standing assistance, and alighting by persons with disabilities.
This provision is written as a general performance requirement in order to allow as many options as possible in the design of accessible vehicles. Handrails and stanchions must be placed near the doors and along the path of entrance into the vehicle. However, they should not interfere or restrict the necessary clearance at doors or along an accessible route leading to accessible spaces as required by the following provision.
(b) Handrails, stanchions, and seats shall allow a route at least 32 inches wide so that at least two wheelchair or mobility aid users can enter the vehicle and position the wheelchairs or mobility aids in areas, each having a minimum clear space of 48 inches by 30 inches, which do not unduly restrict movement of other passengers. Space to accommodate wheelchairs and mobility aids may be provided within the normal area used by standees and designation of specific spaces is not required. Particular attention shall be given to ensuring maximum maneuverability immediately inside doors. Ample vertical stanchions from ceiling to seat-back rails shall be provided. Vertical stanchions from ceiling to floor shall not interfere with wheelchair or mobility aid user circulation and shall be kept to a minimum in the vicinity of doors.
Designating accessible spaces for wheelchair or mobility aid users is not required. During the development of these guidelines, it was apparent that some transit operators assumed that "bays" or "berths" would have to be provided in order to meet this requirement. Such accommodations are not required or recommended. All that must be provided is enough clear floor space so that two wheelchair or mobility aid users can board and position themselves on the vehicle. The 30 by 48 inch dimension is based on the standard space allowance for a person in a wheelchair. The clear floor area where persons with disabilities can position themselves must be connected to the doors by a route with at least 32 inches of clear width. The clear floor space that is typically provided for standees is usually large enough to meet this requirement.
Handrails or stanchions must be placed so that the required clear floor spaces and routes are not obstructed. It is also recommended, but not required, that consideration be given to the proximity of handrails or stanchions to the area in which wheelchair or mobility aid users may position themselves. When identifying the clear floor space where a wheelchair or mobility aid user can be accommodated, it is suggested that at least one such area be adjacent to, or in close proximity to a handrail or stanchion. Of course, such a handrail or stanchion cannot encroach upon the required 32 inch width required for the doorway or the route leading to the clear floor space. This recommendation should not be interpreted as a requirement that the area where wheelchair or mobility aid users can position themselves be designated at a specific location. It is important that wheelchair and mobility aid users have as many options as possible in positioning themselves in view of the crowding that can take place and the limited time allowed to enter or exit the vehicle.
There is no requirement for securement systems or tie-down devices. Previous research conducted for DOT and comments received during the development of these guidelines indicate that such devices are not needed on rapid rail vehicles because of the low acceleration and deceleration forces.
(c) The diameter or width of the gripping surface of handrails and stanchions shall be 1 1/4 inches to 1 1/2 inches or provide an equivalent gripping surface and shall provide a minimum 1 1/2 inches knuckle clearance from the nearest adjacent surface.
Most car handrails are made of pipe. In the building industry, pipe size typically specifies inside diameter so that a 1 1/2 inch pipe handrail actually has a larger outside diameter, sometimes up to 2 inches. Such handrails have not posed any known problem. Thus, the 1 1/2 inch diameter requirement can result in a handrail of approximately 2 inches under current building industry practices.
Floor surfaces on aisles, places for standees, and areas where wheelchair and mobility aid users are to be accommodated shall be slip-resistant.
A specific measure, or static coefficient of friction, has not been specified for slip-resistance. Slip resistance is based on the frictional force necessary to keep a shoe heel or crutch tip from slipping on a walking surface under conditions likely to be found on the surface. While the dynamic coefficient of friction during walking varies in a complex and non-uniform way, the static coefficient of friction, which can be measured in several ways, provides a close approximation of the slip resistance of a surface. Contrary to common belief, some slippage is necessary for walking, especially for persons with restricted gaits. A truly "non-slip" surface could not be negotiated.
The Occupational Safety and Health Administration recommends that walking surfaces have a static coefficient of friction of 0.5. A research project sponsored by the Board conducted tests with persons with disabilities and concluded that a higher coefficient of friction was needed by such persons. A static coefficient of friction of 0.6 is recommended for steps, floors, and lift platforms and 0.8 for ramps.
The coefficient of friction varies considerably due to the presence of contaminants, water, floor finishes, and other factors not under the control of transit providers and may be difficult to measure. Nevertheless, many common materials suitable for flooring are now labeled with information on the static coefficient of friction. While it may not be possible to compare one product directly with another, or to guarantee a constant measure, transit operators or vehicle designers and manufacturers are encouraged to specify materials with appropriate values. As more products include information on slip resistance, improved uniformity in measurement and specification is likely to develop. The Board has published a brochure, "Slip Resistant Surfaces," available at no cost, which provides additional information and advisory guidelines on slip resistant surfaces.
A variety of common materials used on transit vehicle floors can provide adequate slip resistance. Common rubberized matting may be slip resistant depending on the orientation of the grooves. Carpet is more variable depending on pile and weave and should probably be tested before it is specified.
�92.61 Public information system
(a)(1) Requirements
Each vehicle shall be equipped with a public address system permitting transportation system personnel, or recorded or digitized human speech messages, to announce stations and provide other passenger information. Alternative systems or devices which provide equivalent access are also permitted. Each vehicle operating in stations having more than one line or route shall have an external public address system to permit transportation system personnel, or recorded or digitized human speech messages, to announce train, route, or line identification information.
(2) Exception
Where station announcement systems provide information on arriving trains, an external train speaker is not required.
This provision requires cars to be equipped with a public address system that provides either recorded or digitized human speech messages or announcements made by drivers or other transit personnel. Digitized human speech uses spoken sounds and words recorded digitally and rearranged for customized messages. While other systems that provide equivalent access to information are permitted, the use of synthetic speech is not recommended. According to Board-sponsored research, synthetic speech, which is generated electronically, has not yet been proven to be as easily recognized or understood as recorded or digitized human speech. Information received by the Board during the development of these guidelines did not contradict this assessment.
It is also required that rapid rail vehicles be equipped with an external speaker. This does not apply to vehicles operating on only one line or route since the destinations announced would be the same for all vehicles. The Board is aware of the concern about the use of external speakers on vehicles that operate in quiet residential areas and notes that transit operators have full discretion over the volume of external announcements and that a minimum decibel level is not specified by this provision.
(b) [Reserved]
These guidelines do not currently contain technical specifications for the provision of public information in a format that is accessible to persons with hearing impairments. Such a technical requirement has been reserved pending further study of the options that are available in making such information fully accessible. The Board expects to include some requirements in the future. Nevertheless, general prohibitions of discrimination in the ADA itself and the "provision of service" requirements of the DOT rule require, in esssence, that information necessary for the operation or use of a transit system be made available to persons with hearing impairments. See 49 CFR 37.167(f). Thus, it is recommended that the information for passengers contained in audible announcements also be made available to persons with hearing loss or who are deaf. Of course, announcements intended only for system personnel are not part of the information needed by passengers. DOT is assessing available and soon-to-be available technology in a study to be conducted during Fiscal Year 1992. Entities are encouraged to employ whatever services, signage or alternative systems or devices that are available and that provide equivalent access.
Information can be provided in different ways, some of which are relatively simple and inexpensive. For example, one transit system has a policy of flashing interior train lights to indicate to passengers who are deaf that the train is malfunctioning and that all passengers must exit the train at the next station. Of course, the meaning of this signal must be conveyed in advance to potentially affected passengers for it to be useful and may not be useful to persons unfamiliar with the system, such as tourists. A prominent sign in the vehicle also would be useful. In general, such information should be included in the brochures and guides available to the general public rather than only in a "special services" brochure intended for persons with disabilities. Access to some information may also be conveyed by a system of signage providing information routinely provided in announcements (e.g., no smoking, fares, hours of operation) while information provided in special announcements (e.g., changes in schedule, elevators not in service) could be posted in strategic areas, such as at entrances to the station or at information kiosks. Announcements of elevator outage, for example, could be easily conveyed on a simple chalkboard in the station kiosk.
More sophisticated solutions could include visual display systems and electronic message boards. Visual display systems provide information through electronic message boards or video monitors and can accommodate persons who are deaf as well as those with hearing loss. Electronic message boards using a light emitting diode (LED) or "flip-dot" display are currently provided in some transit stations and terminals and may be usable in cars. One transit system is testing the feasibility of on-board visual displays for next-station announcements and even points of interest, news headlines and weather reports. At least two such systems have been installed at no cost to the transit agency since the company providing the equipment is seeking paid advertisements to support the installation and operation. Such visual displays can supplement audio announcements and are useful to all passengers where the noise level or reverberation is high. These devices may be used to provide real time or pre-programmed messages. However, real time message displays require the availability of an employee for keyboard entry of the information to be announced.
Video monitor systems, such as visual paging systems provided in some airports (e.g., Baltimore-Washington International Airport), are another alternative. The Board can provide technical assistance and information on these systems, including a free technical assistance manual, "Airport TDD Access: Two Case Studies."
Assistive listening systems (ALS) may possibly provide another alternative although they benefit a narrower population of people with hearing loss. These types of systems are intended to augment standard public address and audio systems by providing signals which can be received directly by persons with special receivers or their own hearing aids and which eliminate or filter background noise. Magnetic induction loops, infra-red and radio frequency systems are types of listening systems which are appropriate for various applications. These systems, however, are not usable by persons who are deaf. Further, the feasibility and cost of installing such devices on cars remain uncertain. The Board has published a pamphlet, "Assistive Listening Systems," available at no cost, which lists demonstration centers across the country where technical assistance can be obtained in selecting and installing appropriate systems. The State of New York has also adopted a detailed technical specification which may be useful.
(a) Requirements
Suitable devices or systems shall be provided to prevent, deter or warn individuals from inadvertently stepping off the platform between cars. Acceptable solutions include, but are not limited to, pantograph gates, chains, motion detectors or similar devices.
(b) Exception
Between-car barriers are not required where platform screens are provided which close off the platform edge and open only when trains are correctly aligned with the doors.
A serious danger posed to passengers, particularly those with visual impairments, is stepping in-between cars and falling onto the tracks. The light from end windows can sometimes cause persons with visual impairments to mistake the gap between vehicles as an entrance. This provision mentions some possible solutions to prevent accidents of this nature. Other available solutions are acceptable so long as they serve to "prevent, deter, or warn" individuals of the gap.
Although the Board does not require or recommend one device or solution over another, spring or pantograph gates are more effective than chains or motion detectors in stopping a person from stepping over the platform edge and falling between cars. Chains, if mounted high enough, may actually prevent falls, but if mounted at a low height may serve only as a warning to persons with visual impairments who use canes. Motion detectors are strictly a warning device and will not physically restrict someone from falling between cars. Operators concerned about the manual connection and disconnection of spring gates or chains can specify pantograph gates, motion detectors, or other devices.