Adaptive Engineering Inc. would like to provide the following comments to the recent revisions of the above Guidelines:
1. We would suggest that manually powered lifting devices be deemed acceptable for providing access to Temporary Structures (v.201.3). In our experience, it is often the case that temporary structures cannot be accessed in any other way. If Temporary Structures need to be accessible, as appears to be the case in the Guidelines, it will put operators in a difficult position if there is no reasonable way of providing access. Manually powered lifts provide a reasonable and proven solution to this problem.
2. In v.206.7 it is clear that platform lifts must be capbable of idependent entry, operation & exit. It could be clearer, perhaps, that this is not either expected or possible with respect to manually powered lifts. We suggest that it be very clear that this is the case so that there is no confusion about the compliance of a manually powered lift.
3. In v.305.7.1 & 2 the sections refer to a depth measurement. It is unclear to us, and therefore probably others, to what this depth refers. If this could be clarified in the sections, it would be very helpful.
4. In v.304.3.1 refers to a turning space of 60". We would suggest that this space should refer to available turning area, rather than a deck space of 60". If the deck needs to be a 60" radius, it will render the lifts so big that there will be limited applications. Most lifts will be of the straight-on/straight off variety to avoid this problem, but that means in areas (e.g. smaller tenders) where there is not enough room for the lift and a straight-on approach, there will be no alternative because the turning radius required on the right-angle lifts renders the lift too large for the space. If there is room for the turning of the wheelchair, as in the railroad specifications, with feet passing in the space under the handrails, this achieves the desired result, but allows for a more effective lift footprint.
We would be happy to elaborate on any of our responses at your convenience.
Adaptive Engineering Inc.
Tel. (403) 243-9400 Ext. 102
Fax (403) 243-9455