Section-by-Section Analysis

The other proposed revisions to the 1991 guidelines for buses, over-the-road buses, and vans are discussed below.  Most of the revisions are editorial only, and the requirements are the same as in the 1991 guidelines.  Revisions that modify current requirements or add new requirements are discussed under each section below.

Question 21:  Comments are requested on whether any of the revisions that modify current requirements or add new requirements would add to the costs of the vehicles.  Comments should identify the requirement and section number, and provide specific information about any costs.

Chapter T1: Application and Administration

T101 General

This section clarifies that the scoping and technical requirements apply to the acquisition of new, used, and remanufactured vehicles and the remanufacture of existing vehicles to the extent required by regulations issued by the Department of Transportation.  As discussed at the beginning of the preamble, the Department of Transportation regulations specify which public and private entities must comply with the transportation provisions of the ADA, and when transportation vehicles acquired or remanufactured by the public or private entities must be accessible.  As explained above, the Department of Transportation will conduct a separate rulemaking to amend its regulations so that the accessibility standards included in the regulations are consistent with the revisions to Access Board’s transportation vehicle guidelines.  When the Department of Transportation amends its regulations, the Department of Transportation will establish the effective date for the revised accessibility standards.

T102 Equivalent Facilitation

The revisions to this section are editorial only.  Transit operators can use alternative designs and technologies that result in substantially equivalent or greater accessibility or usability.  The Department of Transportation regulations contain procedures for determining whether alternative designs and technologies provide equivalent facilitation.24

T103 Conventions

The revisions to T103.1 on dimensions and T103.2 on tolerances are editorial only.  T103.3 explains that figures are provided for information purposes only, except for the International Symbol of Accessibility in Figure T703.  T103.4 explains that measurements are stated in metric and U.S. customary units and that each system of measurement is to be used independently of the other.  T103.5 explains that the length of buses, over-the-road buses, and vans is measured from standard bumper to standard bumper, exclusive of any additional protrusions.

T104 Definitions

T104.1 adopts the definitions in the Department of Transportation regulations for terms that are used in the proposed rule and are defined in the Department of Transportation regulations.  These terms include: accessible, bus, fixed route system, new vehicle, over-the-road bus, public entity, remanufactured vehicle, used vehicle, and wheelchair.25  T104.2 uses collegiate dictionaries to determine the meaning of terms that are not defined in the proposed rule or the Department of Transportation regulations.  T104.3 explains that singular and plural words, terms, and phrases are used interchangeably.  T104.4 adds new definitions for the terms: boarding device, bridgeplate, level boarding bus system, operable part, and surface discontinuities.

Chapter T2: Scoping Requirements

T201 General

This introductory section states that new, used, and remanufactured vehicles are required to comply with the scoping requirements in Chapter 2 to the extent required by the Department of Transportation regulations.

T202 Reduction in Access Prohibited

This section clarifies that modifications to an accessible vehicle must not decrease the accessibility of the vehicle below the requirements in effect at the time of the modification.

T203 Buses, Over-the-Road Buses, and Vans

This section contains the scoping requirements for buses, over-the-road buses, and vans.  The scoping requirements address 14 features that affect the accessibility and usability of the vehicles, and reference the technical requirements in Chapters T3 through T8 that the features must comply with to be readily accessible to and usable by individuals with disabilities.  Some scoping requirements are based on the size of the vehicles, or apply only to vehicles operated in fixed route systems or vehicles operated by public entities (i.e., State or local government units).  The scoping requirements in T203 should be consulted before reading the technical requirements in Chapters T3 through T8 to determine what technical requirements apply to the vehicle.

T203.1 is a general introductory subsection that plainly states the scoping requirements in T203 apply to buses, over-the-road buses, and vans.  The subsequent subsections in T203 simply refer to buses, over-the-road buses, and vans as vehicles.  Buses, over-the-road buses, and vans are simply referred to as vehicles in the discussion of those subsections below.

Accessible Boarding

The scoping requirements for accessible boarding in T203.2 are modified to address bus rapid transit systems in which some or all of the designated stops have station platforms that are coordinated with the vehicle floor to provide level boarding.  These systems are referred to as level boarding bus systems in the proposed rule.

T203.2.1 retains the current requirement in the 1991 guidelines that all vehicles provide lifts or ramps for accessible boarding.  The current exception that permits over-the-road buses to provide portable or station-based boarding devices is removed.

T203.2.1 clarifies that lifts and ramps must be capable of being deployed to all designated stops on the route to which the vehicle is assigned and to the roadway.

T203.2.1.2 modifies the scoping requirements for ramps as follows:

  • Ramps on vehicles more than 6.7 m (22 feet) in length must be permanently installed and power operated.
  • Vehicles that operate in level boarding bus systems where all the designated stops have station platforms are permitted to provide on board the vehicle portable ramps that can be deployed to the roadway in the event that the vehicle breaks down on the roadway.

Additional scoping requirements apply to vehicles operating in level boarding bus systems as follows:

  • T203.2.2.1 requires the design of the vehicles to be coordinated with the station platforms to minimize the gap between the vehicle floor and the station platform.
  • T203.2.2.2 requires the vehicles to provide ramps or bridgeplates that can be deployed to the station platforms where the gap between the vehicle floor and station platforms is greater than 51 mm (2 inches) horizontally or 16 mm (⅝ inch) vertically when measured at 50 percent passenger load with the vehicle at rest.  Where these gap dimensions are not exceeded, accessible boarding can be provided at station platforms without ramps or bridgeplates.  Where ramps or bridgeplates are provided on vehicles, T303.8.2 specifies a 1:8 maximum ramp slope to the station platforms.
  • Where ramps or bridgeplates are required to provide accessible boarding at station platforms, T203.2.2.2.1 requires vehicles with doorways on one side of the vehicle to provide ramps or bridgeplates in at least one doorway; and T203.2.2.2.2 requires vehicles with doorways on two sides of the vehicle to provide ramps or bridgeplates in at least one doorway on each side of the vehicle.  The ramps or bridgeplates must be permanently installed and power operated.  Ramps provided to comply with T203.2.1 can be used to provide accessible boarding at one doorway.  Bridgeplates can be used to provide accessible boarding at additional doorways.

The technical requirements for lifts, ramps, and bridgeplates are discussed under Chapter T3.

Wheelchair Spaces

The scoping and technical requirements for wheelchair spaces are discussed under Proposed Changes That Received Substantial Comment.

Circulation Paths

T 203.4.1 requires all circulation paths to comply with the technical requirements for surfaces.  The technical requirements for surfaces are discussed under T802.

T203.4.2.1 clarifies that circulation paths must connect each wheelchair space to a doorway with a boarding device that can be deployed to the roadway.  Where a portable ramp is permitted on vehicles operating in level boarding bus systems, a circulation path must connect each wheelchair space to a doorway where a portable ramp can be deployed to the roadway.

Additional scoping requirements apply to vehicles operating in level boarding bus systems.  T403.4.2.2 requires a circulation path to connect each wheelchair space to a doorway that provides accessible boarding at station platforms.  Where doorways are provided on two sides of the vehicle, a circulation path must connect each wheelchair space to a doorway on each side of the vehicle that provides accessible boarding at station platforms.  The technical requirements for circulation paths that connect wheelchair spaces to doorways are discussed under Proposed Changes That Received Substantial Comment.

Doorways

T203.5.1 through T203.5.3 require doorways with lifts or ramps, doorways with level-entry boarding, and doorways with steps on over-the-road buses to comply with the applicable technical requirements in T503, which are discussed under that section.  T203.5.4 requires doorways that provide accessible boarding to be identified on the exterior of the vehicle by the International Symbol of Accessibility, unless all the doorways provide accessible boarding.  Where lighting is provided at doorways, T203.5.5 requires the lighting to comply with the technical requirements for lighting in T803, which are discussed under that section.

Steps

T203.6 requires steps on vehicles to comply with the technical requirements in T504, which are discussed under that section.

Handrails, Stanchions, and Handholds

The revisions to the scoping requirements for handrails, stanchions, and handholds at passenger doorways, at fare collection devices where provided, and along circulation paths in T203.7.1 are editorial only.  Transit operators and vehicle manufacturers commenting on the drafts of the proposed rule noted it is not practical to provide stanchions or handholds on high-back reclining seats that are typically provided on over-the-road buses.  T203.7.2 clarifies the location of handrails, stanchions, and handholds at forward and rear-facing seats on large vehicles that are more than that are more than 6.7 m (22 feet) in length.  Handholds or stanchions must be provided on the back of low-back non-reclining seats, and handrails must be provided overhead or on overhead luggage racks at high-back reclining seats.  The technical requirements for handrails, stanchions, and handholds are discussed under T505.

Wheelchair Securement Systems

The scoping and technical requirements for wheelchair securement systems are discussed under Proposed Changes That Received Substantial Comment.

Seat Belts and Shoulder Belts

The revisions to the scoping requirements for seat belts and shoulder belts in T203.9 are editorial only.

Seats

T203.10.1 clarifies the scoping requirements for the number and location of priority seats for passengers with disabilities on vehicles operated in fixed route systems.  At least two seats must be designated as priority seats for passengers with disabilities.  The seats must be located as near as practicable to a doorway that is used for both boarding and alighting.  Where aisle facing and forward facing seats are provided, one of the priority seats must be an aisle facing seat and one of the priority seats must be a forward facing seat.  The revisions to the scoping requirements for priority seat signs in T203.10.2 are editorial only.  The signs must inform other passengers to make the seats available to passengers with disabilities.

T203.10.3 modifies the scoping requirements for folding or removable armrests on the aisle side of seats on over-the-road buses.  The 1991 guidelines require at least 50 percent of aisle seats, including all moveable or removable seats at wheelchair spaces, to provide folding or removable armrests to permit easy access to the seats by passengers with disabilities.26  T203.10.3 requires all moveable or removable aisle seats at wheelchair spaces and at least 25 percent of all other aisle seats to provide folding or removable armrests.

Destination and Route Signs

The revisions to the scoping requirements for destination and route signs in T203.11 are editorial only.  Where destination and route signs are provided on the exterior of a vehicle, the signs must be provided on the front and boarding side of the vehicle, and must be illuminated.  The technical requirements for characters on the signs are discussed under T702.

Public Address Systems

The revisions to the scoping requirements for public address systems in T203.12 are editorial only.

Automated Stop and Route Announcements

The scoping and technical requirements for automated stop and route announcements in T203.13 are discussed under Proposed Changes That Received Substantial Comment.

Stop Request Systems

The revisions to the scoping requirements for stop request systems in T203.14 are editorial only.  Vehicles more than 6.7 m (22 feet) in length that operate in fixed route systems and stop at multiple designated stops on passenger request must provide stop request systems.  The technical requirements for stop request systems are discussed under T705.

Fare Collection Devices

T203.15 requires fare collection devices on vehicles to comply with the technical requirements in T806, which are discussed under that section.

Chapter T3: Boarding Devices

T301 General

This section states that the technical requirements for boarding devices in Chapter T3 apply where required by the scoping requirements in Chapter T2.

T302 Lifts

This section contains the technical requirements for lifts.  Advisory information is added after T302.1 regarding the Federal Motor Vehicle Safety Standards (FMVSS) for motor vehicle lifts issued by the National Highway Traffic Safety Administration.  The FMVSS are generally consistent with T302.  Some of the requirements in T302 are more stringent than the FMVSS, including openings in lift platform surfaces in T302.5.1 and T802.3, and transitions at the boarding edges of threshold ramps on lift platforms in T302.5.5 and T802.5.  T302 also contains some requirements that are not addressed in the FMVSS, including door releases for manual operation of lifts in T302.4, boarding direction in T302.5.9, and use by standees in T302.5.10.

T302.2 specifies a 273 kg (600 pounds) minimum design load for lifts.  The drafts of the proposed rule considered increasing the design load to 300 kg (660 pounds).  Comments from transit operators and vehicle manufacturers recommended that changes to the design load be coordinated with the FMVSS.  The FMVSS requires a series of tests for lifts using a standard load of 273 kg (600 pounds).  Based on the comments, the design load is not changed.

The following technical requirements in T302 are modified:

  • T302.4 requires doors that must be opened to manually operate the lift if the power fails to have interior and exterior manual releases.  Exterior releases can have locks to secure the vehicle when unattended.  The other requirements in T302.4 for manual operation of lifts in the event of power failure are the same as in the 1991guidelines.
  • T302.5.2 increases the height for measuring the clear width and length above the lift platform surface from 766 mm (30 inches) to 1015 mm (40 inches) minimum to accommodate the controls on power wheelchairs.  T 302.5.2 also clarifies that the clear length measured at the platform surface is 1015 mm (40 inches) minimum.  The other dimensions in T302.5.2 for the lift platform surface are the same as in the 1991 guidelines.
  • T302.5.4 revises the specification for gaps between the lift platform surface and the vehicle floor to be consistent with the specifications for openings in T302.5.3.  Gaps and openings must not allow the passage of a sphere more than 16 mm (? inch) in diameter.
  • T302.5.5 requires transitions at threshold ramps on the boarding edge of lift platforms to comply with T802.5.  T802.5 limit surface discontinuities to 6.4 mm (¼ inch) high maximum without edge treatment and 13 mm (½ inch) high maximum with beveled edge treatment.  The bevel must have a slope not steeper than 1:2 (50 percent) applied across the entire surface discontinuity.  The other requirements in T302.5.5 for the slope of threshold ramps on the boarding edge of lift platforms are the same as in the 1991 guidelines.
  • T 302.5.6 revises the requirement for visual contrast on the sides of lift platform surfaces to be consistent with the FMVSS.  The perimeter of lift platform surfaces must have a 25 mm (1 inch) minimum outline that contrasts visually with the rest of the platform surface.
  • T302.5.7 eliminates the load test for lift platform deflection.  The FMVSS specifies a load test for lift platform deflection.  The other requirements in T302.5.7 for lift platform deflection are the same as in the 1991 guidelines.

The revisions to the other technical requirements in T302 are editorial only.  Those technical requirements are the same as in the 1991 guidelines and are summarized below:

  • T302.3.1 requires interlocks to prevent the vehicle from moving when the lift is not stowed and the lift controls from operating unless the interlocks are engaged.
  • T302.3.2 requires lift controls to be of a momentary contact type; permit the operator to change the operation sequence; and prevent the lift platform from folding, retracting, or stowing when occupied, unless the platform is designed to be occupied when stowed in the passenger area of the vehicle.
  • T302.5.1 requires lift platform surfaces to comply with the technical requirements for surfaces in T802.
  • T302.5.3 requires edge barriers on the sides of lift platforms to prevent the wheels of wheelchairs from rolling off the platforms.
  • T302.5.8.1 specifies the movement rate for lifts under normal operating conditions.
  • T302.5.8.2 specifies the movement rate for lifts in the event of a power failure or single failure of a load carrying component.
  • T302.5.9 requires lift platforms to permit passengers who use wheelchairs to board the platforms facing either toward or away from the vehicle.
  • T302.5.10 requires lift platforms to be usable by passengers who use mobility aids or have difficulty using steps.
  • T302.5.11 requires lift platform to have handrails on two sides of the platform that move in tandem with the platform to provide support for passengers in a standing position.

T303 Ramps and Bridgeplates

This section contains the technical requirements for ramps and bridgeplates.  The technical requirements for ramp slope in T303.8 are discussed under Proposed Changes That Received Substantial Comment.

The following technical requirements in T303 are also modified:

  • T303.4 requires power operated ramps and bridgeplates to be operated manually if the power fails.
  • T303.5 requires ramp and bridgeplate surfaces to comply with the technical requirements in T802 for surfaces.  T802.3 requires that openings in surfaces not allow the passage of a sphere more than 16 mm (? inch) in diameter, and that elongated openings be placed so that the long dimension is perpendicular to the dominant direction of travel.  Cut-outs are permitted in ramps and bridgeplates that are deployed manually for the operator to grasp the surface.  The other requirements in T802 for slip resistant surfaces and protrusions on surfaces are the same as in the 1991 guidelines.
  • T303.7 clarifies that edge barriers are required where the edges of ramps and bridgeplates are more than 75 mm (3 inches) above the boarding or alighting area.
  • T303.9 requires transitions at the boarding edge of ramps and bridgeplates to comply with T802.5.  T802.5 limits surface discontinuities to 6.4 mm (¼ inch) high maximum without edge treatment and 13 mm (½ inch) high maximum with beveled edge treatment.  The bevel must have a slope not steeper than 1:2 (50 percent) applied across the entire surface discontinuity.
  • T 303.10 revises the requirement for visual contrast on the sides of ramp and bridgeplate surfaces.  The perimeter of ramp and bridgeplate surfaces must have a 25 mm (1 inch) minimum outline that contrasts visually with the rest of the ramp and bridgeplate surface.

The revisions to the other technical requirements in T303 are editorial only.  Those technical requirements are the same as in the 1991 guidelines and are summarized below:

  • T303.1 permits ramps and bridgeplates to fold or telescope if all the requirements in T303 are met.
  • T303.2 specifies the minimum design load for ramps and bridgeplates.  The drafts of the proposed rule considered increasing the design load for ramps and bridgeplates to correspond with an increase in the design load for lifts.  As discussed under T302, the design load for lifts is not changed and no corresponding change is made to the design load for ramps and bridgeplates.  The design load for ramps and bridgeplates that are 760 mm (30 inches) or more in length is 273 kg (600 pounds).  The design load for ramps and bridgeplates that are less than 760 mm (30 inches) in length is 136 kg (300 pounds).
  • T303.3 requires ramps and bridgeplates to be firmly attached to the vehicle when in use.
  • T303.6 specifies the minimum clear width for ramps and bridgeplates.
  • T303.11 specifies the gap permitted between the ramp or bridgeplate surface and the vehicle floor when the ramp or bridgeplate is deployed.
  • T303.12 requires portable ramps and bridgeplates to be stowed safely when not in use and not to interfere with the maneuvering of wheelchairs.

Chapter T4: Wheelchair Spaces and Securement Systems

The technical requirements for wheelchair spaces in T402, and wheelchair securement systems in T403 are discussed under Proposed Changes That Received Substantial Comment.  The revisions to the technical requirements for seat belts and shoulder belts in T404 are editorial only.

Chapter T5: Circulation Paths and Doorways on Buses, Over-the-Road Buses, and Vans

T501 General

This section states that the technical requirements for circulation paths on buses, over-the-road buses, and vans in Chapter T3 apply where required by the scoping requirements in Chapter T2.

T502 Circulation Paths

The technical requirements in T502 for circulation paths that connect wheelchair spaces to doorways that provide accessible boarding are discussed under Proposed Changes That Received Substantial Comment.

T503 Doorways

T503.1 specifies the minimum vertical clearance at doorways with lifts or ramps.  The revisions to this section are editorial only, and the technical requirements are the same as in the 1991 guidelines: 1420 mm (56 inches ) on vehicles 6.7 m (22 feet) or less in length; 1650 mm (65 inches) on over-the-road buses; and 1725 mm (68 inches) on other vehicles more than 6.7 m (22 feet) in length.  A minimum clear opening is not specified for doorways with lifts or ramps since a minimum clear width of 760 mm (30 inches) is specified for lift platforms in T302.5.2 and for ramps in T303.6.

T503.2 adds new technical requirements for doorways with level entry boarding.  T503.2.1 specifies the minimum clear opening at the doorways: 810 mm (32 inches).  T503.2.2 requires thresholds at the doorways to be marked by a contrasting strip 25 mm (1 inch) wide minimum.

T503.3 specifies the minimum clear opening at doorways with steps on over-the-road buses.  The revisions to this section are editorial only, and the technical requirements are the same as in the 1991 guidelines: 760mm (30 inches) from the lowest step tread to a height 1220 mm (48 inches) above the lowest step tread.  Where compliance is not structurally feasible, the clear opening is permitted to be 685 mm (27 inches).  The clear opening is permitted to taper to 457 (18 inches) from a height 1220 mm (48 inches) above the lowest step tread to the top of the doorway.  Hinges and other door mechanisms are permitted to protrude 100 m (4 inches) maximum into the clear opening.

T504 Steps

T 504.2 requires step tread surfaces to comply with the technical requirements for surfaces in T802, which are further discussed under that section.  T504.3 clarifies the current requirement for contrasting strips at step tread edges by specifying the minimum width of the strips: 25 mm (1 inch).

T505 Handrails, Stanchions, and Handholds

The revisions to the technical requirements for handrails, stanchions, and handholds in T505 are editorial only, and the requirements are the same as in the 1991 guidelines.  T505.2 specifies that handrails and stanchions at doorways be configured so that passengers with disabilities can grasp them from outside the vehicle and use them throughout the boarding and alighting process.  T505.3 specifies that handrails at fare collection devices be configured so that passengers with disabilities can use them for support when using the fare collection device.  T505.4 specifies that handrails and stanchions along circulation paths be configured so that passengers with disabilities can use them when moving through the vehicle.  T505.5 specifies that handholds and stanchions on the backs of forward and rear facing seats be located directly adjacent to the aisle so that passengers with disabilities can use them when moving from the aisles to the seats.

Chapter T6: Circulation Paths and Doorways on Rail Vehicles

The technical requirements for circulation paths and doorways on rail vehicles will be included in Chapter T6 when the guidelines for rail vehicles are revised.

Chapter T7: Communication Features

T701 General

This section states that the technical requirements for communication features in Chapter T7 apply where required by the scoping requirements in Chapter T2.

T702 Signs

T702 revises the technical requirements for characters on signs to be consistent with the accessibility guidelines for buildings and facilities.  The technical requirements address character proportions, character height, stroke thickness, character spacing, line spacing, and contrast.

T703 International Symbol of Accessibility

T703 adds new technical requirements for the International Symbol of Accessibility, and specifies that the symbol have a background field of at least 100 mm (4 inches) and a non-glare finish, and contrast with its background.

T704 Automated Stop and Route Announcements

The technical requirements for automated stop and route announcements in T704 are discussed under Proposed Changes That Received Substantial Comment.

T705 Stop Request Systems

T705.1 clarifies the technical requirements for audible and visible indicators for stop request systems.  Audible stop indicators can be verbal or non-verbal signals.  Visible stop indicators can be a light or sign.  T705.2 clarifies the location of operable parts for stop request systems at wheelchair spaces, and specifies that the operable parts be located on a side wall or partition 610 mm (24 inches) minimum and 915 mm (36 inches) maximum from the back of the wheelchair space.

Chapter T8: Other Features

T801 General

This section states that the technical requirements for other features in Chapter T8 apply where required by the scoping requirements in Chapter T2 or where referenced in another technical requirement.

T802 Surfaces

T802 contains the technical requirements for surfaces.  These requirements are referenced in: T203.4.1 for all circulation paths; T302.5.1 for lift platforms; T303.5 for ramps and bridgeplates; T402.2 for wheelchair spaces; and T504.2 for step treads.

T802.2 requires surfaces to be slip resistant.  The 1991 guidelines contain the same requirement.

T802.3 specifies that openings in surfaces not allow the passage of a sphere more than 16 mm (? inch) in diameter, and that elongated openings be placed so that the long dimension is perpendicular to the direction of travel.  Cut-outs are permitted in lift platforms that are folded and stowed manually and in ramps and bridgeplates that are deployed manually for the operator to grasp the surface.  The 1991 guidelines contain similar requirements for lift platforms.

T802.4 permits protrusions on surfaces to be 6.4 m (¼ inch) high maximum.  The 1991 guidelines contain the same requirement for lift platforms and ramps.

T802.5 addresses differences in levels between two adjacent surfaces, which are referred to as surface discontinuities.  Surface discontinuities can be up to 6.4 m (¼ inch) high without beveled edge treatment, and up to 13 mm (½ inch) high with beveled edge treatment.  The 1991 guidelines contain the same requirement for thresholds at lift platforms and ramps.  T802.5 modifies the requirement for beveled edge treat by specifying that the bevel extend across the entire surface discontinuity.

T803 Doorway Lighting

T803 addresses doorway lighting and specifies illuminance levels at lift platforms, ramps and bridgeplates, steps, and boarding and alighting areas adjacent to doorways.  The illuminance levels are the same as specified in the 1991 guidelines except for lift platforms, which is modified to be consistent with the illuminance levels in the Federal Motor Vehicle Safety Standards for lifts on motor vehicles.

T804 Additional Requirements for Handrails, Stanchions, and Handholds

T804 contains additional technical requirements for handrails, stanchions, and handholds.  T804.2 simplifies the requirements for edges by requiring them to be rounded.  T804.3 modifies the requirements for cross section to be consistent with the accessibility guidelines for buildings and facilities.  The revisions to the requirements in T804.4 on clearances and in T804.5 on structural strength of handrails on lift platforms are editorial only, and those requirements are the same requirement as in the 1991 guidelines.

T805 Operable Parts

T805 contains technical requirements for operable parts.  These requirements are referenced in: T706.2 for stop request systems and T806 for fare collection devices.

T805.2 modifies the location height for operable parts: 610 mm (24 inches) minimum and 1220 mm (48 inches) maximum above the floor.

T805.3 requires operation without tight grasping, pinching, or twisting of the wrist and a maximum activation force of 22.5 N (5 pounds).  The 1991 guidelines contain the same requirements for stop request systems.

T806 Fare Collection Devices

T806 requires fare collection devices to comply with the technical requirements for operable parts in T805, and the operable parts on fare collection devices to be located so that a wheelchair can approach within 255 mm (10 inches) maximum.