National Center for Accessible Transportation, Joe Zaworski
June 13, 2007  [via Email]

Comments on Draft Revisions to ADAAG for Buses and Vans
prepared by
The National Center for Accessible Transportation

PREFACE TO COMMENTS

We have reviewed this document as well as comments by some others that people planned to submit in response to this document.  It is clear that different people have different ideas about what the ADAAG is supposed to do.  Our point of view is that it’s important to stress performance and therefore to avoid prescribing specific solutions as much as possible.  We do recognize that we don’t have as much background knowledge on some aspects of this material as do others and therefore may be making comments that are in some respects inappropriate.  On the other hand, those comments may be useful in pointing out a need for clarification or explanation in the document.

Also, it is much easier to find fault with documents like this than it is to develop and offer a good alternative.  Wherever possible, we try to offer an improvement rather than just point out a problem.  However, in some cases we couldn’t come up with anything we consider to be a good alternative.  In those cases please consider the pointing out of potential problems to be a flag, not a criticism.

COMMENTS

1192.1 Purpose - no comment

1192.2 Equivalent Facilitation - no comment

1192.3 Defintions

Designated public transportation - This definition is not clear to us.  On first reading it seems to apply to intra-city and excludes inter-city as well as aircraft and commuter rail.  It might be clearer to move all of the exclusions (parenthetical phrases) to the end and to perhaps include an explanation that they are excluded because they are covered under different regulations. 

1192.4 Miscellaneous Instruction - no comment

1192.21 General - no comment

1192.23 Mobility aid accessibility

     (a) General

• (a2) Sufficient clearances… to turn with a minimum of back-and-forth movement.  This is a tough one.  It might be worth considering being a little bit more specific.  For example, in addition to saying that clearances must accomodate mobility aids have maximum length and width with steering at one end only (like a scooter).  It also might be worth considering a number on the back-and-forth maneuvering, something like no more than 4 changes of direction (back-and-forth twice).

     (b) Vehicle Lift

• (b1)  Design load - Although we don’t believe that it is intended this way, we read into this that basically the lift should be designed for 660 lb but should work right on up to 3960 lb before failure.  Perhaps a better approach would be to say that it should be designed for a lift capacity of 660 lb and the design should be such that up to 6 times the design load could be supported without any failure that would present a safety hazard to the passenger. 
  
• (b2ii) Exception - The first phrase of the sentence (about rotary lifts) should be eliminated because the second phrase should apply to any arrangement where the lift is intended to be stowed while occupied (perhaps a rear door lift that comes up and straight in to rest on the vehicle floor?)  This section on an exception should begin “The requirements of this paragraph prohibiting the lift from being stowed while occupied shall not apply..”
  
• (b4) Power or equipment failure – For safety and to improve clarity  we recommend this statement be changed to read as follows: “Platforms, either stowed or deployed, shall be designed to prevent, in the event of any power or equipment failure, the dropping of an occupant and any type of movement faster than 12 inches/second.
  
• (b7) Platform Gaps - We don’t understand either what the last sentence says or how it fits into this section.  It’s probably clear with the right mental image but without a picture, we don’t get it.
  
• (b10) Platform movement – The movement speed requirement should apply to all platforms.  We can think of no valid reason why there should be an exception for manually operated devices.  Higher speed movement is a hazard independent of the source of energy causing it or preventing it.

     (c) Vehicle ramps and bridgeplates

• (c1) Vehicle ramps and bridgeplate Design Load - For the shorter bridge plates a design load of more than 330 lb might be considered. A quick test on a Pride Mobility Quantum 610 power chair (a very popular model) occupied by a 175 lb person showed that the total front to rear wheel distance was 30 inches and the center (drive) wheels were supporting 300 lb. (150 lb each).  Likewise, a 660 lb occupied 4-wheel chair cannot be loaded up a ramp without the load on the center of the ramp exceeding 330 pounds at some point during the process.
  
• (c4) Vehicle ramps and bridgeplate Barriers – This section calls for 2” high barriers where the platform requirement (section b5) calls for 1-1/2” barriers.  Consistency is suggested.

     (d) Securement devices

General Comments

1. This is certainly one of the most difficult sections.  The variety of chairs, occupant capabilities, and now securement/containment options makes the writing of a guideline to cover all foreseeable circumstances virtually impossible.
2. If we understand correctly what is written, this document says that rear facing wheelchairs must still be secured to the same requirements as forward facing but with the additional requirement of having a barrier behind the passenger’s head.  This should be stated clearly in the guideline and it should be pointed out that this is very different than the rear facing containment being worked on by several groups and which is currently being used by several transportation providers.
3. Because it is already quite well known in the mass transit community, the concept of rear facing containment (for wheelchairs on large vehicles only) should be addressed in this document.  If it is deemed inappropriate to provide a guideline at this time, then at least its existence should be acknowledged in this guideline.
4. If rear facing containment is to be included then we think it might be useful to re-organize this section into two sub-sections, one for forward facing securement and one for rear facing containment.  The intent and specific requirements are different enough that separating them would help keep the requirements clear.  A comment might be included somewhere that for a single space to be used for both possibilities, it must meet both sets of requirements.

• (d1) Design load – The proposed loads for large vehicles are higher than necessary,  13g where 3g is probably adequate. The load for smaller vehicles, almost 17g is probably appropriate although there is no reported testing available to use as a basis for this number.
• (d2) Location and size –We don’t know if an aisle side stanchion for use with rear facing was considered in writing this section.
• (d4) Orientation – See general comments above.

1192.25 Doors, steps and thresholds –no comment

1192.27 Priority Seating Signs – no comment

1192.29 Interior circulation, handrails and stanchions

(c )  There are no requirements for stanchions to be placed on side facing seats. On large vehicles these are often the most frequently used seats by people with disabilities and also the most hazardous…Some requirement for stanchions for each seat location is needed.

1192.39 Destination and Route Signs
(a)  this merely says illuminated but does not suggest a contrast level or basic reading distance say 50 feet.
(b(6)) Contrast   it is possible to specify basic Contrast levels…by using the international definition of contrast…