St-Hubert, November 28th 2008
TO : Mr Dennis Cannon
Office of Technical and Informational Services, Architectural and Transportation Barriers Compliance Board
1331 F Street NW, suite 1000
Washington DC
20004-1111
SUBJECT: Comments on Draft Revision to Guidelines
RIN: 3014-AA38
Sir,
Calmo thanks you for this opportunity to aid you in developing new guidelines. Over the years, Calmo has gathered quite a lot of experience in designing wheelchair ramps as well as a great insight into the various components involved in manufacturing these ramps. We submit to you these comments based on our experience.
Slope
Calmo agrees with a minimum 1:6 slope for ramps but for a different reason. In the Discussion of Revisions, the reason given for the new 1:6 slope is wheelchair approach angle. If this were the only problem, a 1:4 ramp with an initial 1:6 section ( see figure 1) could have prevented contact with the footrests while keeping the ramp much shorter and therefore easier to deploy. A solution we previously considered.
However, research provided on the access board website and other research papers confirm that even a 1:8 slope requires a considerable physical effort for a manual wheelchair user. We feel 1:6 is a realistic minimum and have already started development of a 1:6 ramp.
Gaps
A significant change for us in this latest draft is the reduction of permissible gaps from 5/8 in. to a ½ in.. Calmo has developed custom ramps to fit any type of bus frame using a mechanism that fits tightly in a 5/8 in. gap. This new requirement would necessitate a major redesign. We would need until 2011 to implement.
Calmo inc was founded in April 2000 and is located in the city of Champlain, in New York State. We are a manufacturer of wheelchair access ramps with experience in the development of flip-type and telescopic ramps, hydraulically or electrically powered.
Sincerely,
Michel Morin, p. eng.
Project Manager
Calmo Inc. (Part of the Fedico Group)
mmorin@fedico.ca
Click here to see the attached file.