See attached WORD document.
January 15, 2009
Office of Technical and Informational Services
Architectural and Transportation Barriers Compliance Board
1331 F Street, NW, Suite 1000
Washington, DC 20004-1111
Subject: LIFT-U Comments on the Second Draft of Revisions to the
Accessibility Guidelines for Transportation Vehicles
Attn: Dennis Cannon
Dear Mr. Cannon,
Thank you for the opportunity to respond to the second draft of revisions proposed by the Access Board for the purpose of updating the ADA Accessibility Guidelines for Buses and Vans dated November 19, 2008. LIFT-U respectfully submits the following comments.
In both the 1991 Guidelines and the Access Board’s draft revision dated April 11, 2007, §1192.23(b)(3) regarding emergency operation stated in part: “… No emergency method, manual or otherwise, shall be capable of being operated in a manner that could be hazardous to the lift occupant or to the operator when operated according to manufacturer’s instructions…”” In the subsequent draft revision dated November 19, 2008, the paragraph was renumbered to §T302.4 and edited to state in part: “Lifts shall be capable of being operated manually if the power to the lift fails. The manual operation shall be safe for the occupant and operator…” LIFT-U would like to point out that the latest revision omitted the phrase “when operated according to manufacturer’s instructions.”
It should be obvious that when power to the lift fails, electrically controlled safety features become inoperable, and moveable edge barriers or supplementary systems no longer raise or engage automatically. Typically manual operation is performed by a hand crank or pump, and often includes manual activation of directional control hydraulic valves, one at a time and in a particular sequence. Although lift operators are trained how to manually operate the lift properly, the need for manual operation occurs so rarely that the operator must refer to an instruction label posted near the crank or pump handle to perform the task safely. In addition, FMVSS 49 CFR §571.403 S6.9 requires manual operating instructions near the lift controls, “… which must include manual operation of the wheelchair retention device and inner roll stop during backup operation of the lift.”
For further historical reference, the March 1991 NPRM did not include the “instruction” phrase either, and three manufacturers and one transit organization submitted comments expressing their concerns and recommendations. The Board agreed and added the phrase “when operated according to manufacturer’s instructions” to §1192.23(b)(3) when the Final Rule was published in September 1991.
In view of the above comments and rationale, LIFT-U strongly recommends the Board add the phrase “when operated according to manufacturer’s instructions” to §T302.4 Manual Operation.
Your consideration on this matter is greatly appreciated.
Click here to see the attached file.