Dear Madam Chair and Members of the Board:
Ricon Corporation appreciates the opportunity to offer input to the Access Board on the proposed changes to the Americans with Disabilities Act (ADA). With over 35 years experience in design, manufacture, and installation of wheelchair lifts and ramps in all types of passenger vehicles, Ricon believes it is uniquely qualified to comment on the important design issues being proposed in docket 2007-1.
Increased Capacity: While we understand the desire to safely accommodate a wider range of individuals that may use heavier mobility devices, it is important that federal regulatory specifications be consistent. Current Federal Motor Vehicle Safety Standards (FMVSS) call for lifting capacity of 600 pounds. FMVSS testing requirements for manufacturers are based on this 600 standard load. We believe the Access Board should coordinate with NHTSA to insure a common test criterion is communicated to the transportation industry and that a reasonable period of time be established for manufacturers to implement design changes and complete testing of their products at any increased capacity specification instituted by the Access Board. Ricon Corp would recommend a minimum of two years from the date of final rulemaking to accomplish this design and testing process.
Ramp Slope Decrease: Ricon Corp believes achieving a 1:8 slope at ground level is not possible given the structural and dimensional constraints within the entry doors of existing transit buses. We believe the vast majority of bus boarding requiring ramp deployment occurs on a dedicated raised surface. We are therefore recommending the ramp slope specification include one slope requirement for a standard 6 inch “curb” height while retaining the current slope requirement of 1:4 for ground level boarding.
Bridgeplates should be considered separately from ramps in as much as they actually function as “gap fillers” between vehicle floors and raised loading platforms where the height variance is typically very small. As such, they should remain level or near level in any boarding situation. We recommend the current 1:4 slope ratio be retained for Bridgeplates as long as the vehicle is also equipped with a ramp in a secondary access point for entry from below the loading platform.
Ramp Side Edges: Ricon Corp agrees with the proposed change to side barrier requirements on ramps where the surface of the ramp is 3" or less above the boarding or alighting surface. This change would be beneficial to the disability community as it allows greater maneuverability when entering and exiting the ramp where infrastructure may create obstructions.
Ricon Corp. recommends the Access Board establish any new rulemaking be applicable only to construction of new vehicles as structural design changes would most likely be impossible or impractical on existing buses undergoing refurbishing or retrofit.
Thank you again for your consideration of our comments and recommendations to this draft proposed rulemaking. Please contact us should you have any questions.
William W. Hinze