Introduction

This technical assistance document is one of a series provided to help in understanding the
background and underlying rationale of the Americans with Disabilities Act Accessibility Guidelines
for Transportation Vehicles (Vehicle Guidelines) and how the guidelines may apply in a particular case. 
The documents in this series are:
• Buses, Vans & Systems
• Rapid Rail Vehicles & Systems
• Light Rail Vehicles & Systems
• Commuter Rail Cars & Systems
• Intercity Rail Cars & Systems
• Over-the-Road Buses & Systems
• Automated Guideway Transit Vehicles & Systems
• High-Speed Rail Cars, Monorails & Systems
• Trams, Similar Vehicles & Systems
The information in this document is based on the preamble published with the Vehicle
Guidelines, augmented with material developed in response to questions which have been posed to the Architectural and Transportation Barriers Compliance Board (Access Board) since publication of the guidelines. The Department of Transportation (DOT) has issued standards for vehicles based on the guidelines. The guidance in this document does not constitute a determination of compliance with the DOT standards or with your rights or responsibilities under the ADA and is not binding on DOT.

Background
The Americans with Disabilities Act (ADA) [P.L. 101-336, 42 U.S.C. 12101, et seq], signed into
law by President Bush on July 26, 1990, is landmark legislation to extend civil rights protection to
people with disabilities. The ADA prohibits discrimination on the basis of disability in employment,
State and local government services, public transportation, public accommodations, commercial
facilities, and telecommunications. 
Title II of the ADA prohibits discrimination on the basis of disability in services, programs,
and activities provided by public entities, including units of State and local government and the
National Railroad Passenger Corporation (Amtrak). Title II addresses public transportation and
contains provisions specifically addressing the following types of transit systems: fixed route bus,
rapid rail, light rail, commuter rail, and intercity rail. Under title II, transit systems of these types
which are owned or operated by public entities, and persons under contract with such entities, must be made readily accessible to and useable by individuals with disabilities, including individuals who use wheelchairs. With respect to public entities, title II requires that:

New Vehicles. New vehicles purchased or leased after August 25, 1990, must be accessible.

Used Vehicles. If used vehicles are purchased or leased after August 25, 1990, good faith efforts
must be made to obtain accessible vehicles.

Remanufactured Vehicles. If vehicles are remanufactured after August 25, 1990, to extend their
useful life for 5 years or more in the case of buses and rapid and light rail vehicles, or for 10 years in the case of commuter and intercity rail cars, then the vehicles must be made accessible to the maximum extent feasible.

"One-Car-Per-Train" Rule. At least one vehicle or car in each train of two or more cars must be
accessible as soon as practicable but in no event later than July 26, 1995, in the case of rapid, light, commuter, and intercity rail systems.

Demand Responsive Systems. New vehicles purchased or leased after August 25, 1990, for use in a demand responsive system operated by a public entity, or by a person under contract with such an entity, must be accessible unless the system, when viewed in its entirety, provides to individuals with disabilities a level of service equivalent to that provided to other members of the general public.
 

Title III of the ADA prohibits discrimination on the basis of disability in public accommodations and services provided by private entities. Under title III, public transportation services (other than by aircraft) provided by private entities must also be made readily accessible to and usable by individuals with disabilities, including individuals who use wheelchairs. Under title III, the following requirements apply to private entities that are primarily engaged in the business of transporting people and whose operations affect commerce:

New Vehicles. New vehicles purchased or leased after August 25, 1990, must be accessible unless the vehicle is to be used solely in a demand responsive system that, when viewed in its entirety, provides to individuals with disabilities a level of service equivalent to that provided to other members of the general public. This requirement does not apply to automobiles, vans with a seating capacity of less than 8 passengers, or over-the-road buses.

Vans. New vans with a seating capacity of less than 8 passengers purchased or leased after February 25, 1992, must be accessible, unless the system for which the van is being purchased or leased, when viewed in its entirety, provides to individuals with disabilities a level of service equivalent to that provided to other members of the general public.

Rail Cars. New rail passenger cars purchased or leased after February 25, 1992, must be accessible.  Rail passenger cars remanufactured after February 25, 1992, to extend their useful life for 10 years or more must be made accessible to the maximum extent feasible. 

For private entities not primarily engaged in the business of transporting people but whose operations affect commerce, such as hotels, shopping centers, and recreational facilities which operate shuttle service for customers or patrons, title III requires that:

New Vehicles for Fixed Route Systems. New vehicles with a seating capacity of more than 16
passengers purchased or leased after August 25, 1990, for use in fixed route systems must be accessible.  This requirement does not apply to over-the-road buses. New vehicles with a seating capacity of 16 passengers or less purchased or leased after August 25, 1990, for use in a fixed route system must also be accessible unless the system, when viewed in its entirety, provides to individuals with disabilities a level of service equivalent to that provided to other members of the general public.

New Vehicles for Demand Responsive Systems. New vehicles with a seating capacity of more
than 16 passengers, purchased or leased after August 25, 1990, for use in a demand responsive system must be accessible unless the system, when viewed in its entirety, provides to individuals with disabilities a level of service equivalent to that provided to other members of the general public. 

Operation of Demand Responsive Systems. Demand responsive systems must be operated in
such a manner that after July 26, 1990, the system, when viewed in its entirety, provides to individuals with disabilities a level of service equivalent to that provided to other members of the general public. 

Over-the-Road Buses. Title III specifically addresses over-the-road buses operated by private
entities. The Office of Technology Assessment (OTA) is responsible, under title III of the ADA, for
studying the access needs of individuals with disabilities to over-the-road buses and the most cost- effective methods for providing such access. In view of this mandated study, over-the-road buses covered by title III are not required to be accessible to wheelchair or mobility aid users until July 26, 1997, for small providers and July 26, 1996, for other providers. Over-the-road buses purchased or leased after January 26, 1992, but before July 26, 1996 or 1997 may be required to include accessibility features which do not involve structural changes or use of boarding devices.

Regulations
The Department of Transportation is responsible for issuing regulations to implement the
transportation provisions of the ADA, including accessibility standards for transportation vehicles. 
The ADA required the Access Board to develop guidelines to provide guidance to DOT on
establishing the accessibility standards for transportation vehicles. DOT published interim standards on October 4, 1990 (55 FR 40762). Those standards apply to vehicles purchased after August 26, 1990, but before October 7, 1991. 
The Access Board published its minimum guidelines, known as the ADA Accessibility
Guidelines for Transportation Vehicles on September 6, 1991, in the Federal Register (56 FR 45530). 
The provisions for lifts, ramps, and securement devices were dawn primarily from a series of guidelines developed as part of a project sponsored by the Federal Transit Administration (FTA), formerly the Urban Mass Transportation Administration (UMTA), in 1986: Guideline Specifications for Passive Wheelchair Lifts, Guideline Specifications for Active Wheelchair Lifts, Guideline Specifications for Wheelchair Ramps and Guideline Specifications for Wheelchair Securement Devices. Provisions from the Guideline Specifications were supplemented with additional material derived from common accessibility standards, such as the Uniform Federal Accessibility Standards (UFAS) and the American National Standards Institute (ANSI) A117.1-1980 specifications, research sponsored by the Access Board, and industry practice. Some provisions for Automated Guideway Transportation (AGT) "people movers" and rapid rail systems were derived from Los Angeles Downtown People Mover:
Handbook on Accessibility for the Elderly and Handicapped (UMTA, November 1980). In addition,
the guidelines incorporated provisions of 49 CFR Part 609 for buses, light rail and rapid rail systems published by UMTA in 1976.
These guidelines, codified at 36 CFR Part 1192, are not, in and of themselves, the standards
for vehicles but rather form the minimum requirements for standards issued by DOT. DOT has
adopted the substance of the guidelines (with minor editorial differences) as the accessibility standards for transportation vehicles. The final DOT regulation establishes effective dates for the accessibility standard and address when the standards are to be applied to vehicles for which a solicitation closes after October 6, 1991. See 49 CFR 37.7. The Manuals in this series will deal only with the requirements for vehicles procured after this date.

Vehicles Covered
The Board's Vehicle Guidelines primarily address new and remanufactured vehicles instead of
existing vehicles since the ADA does not necessarily require vehicle retrofit. Existing buses, for
example, are not required to be retrofitted to meet the standards of Part 38 of the DOT regulation. 
Even compliance with the "one-car-per-train rule" and the mobility aid seating requirements for
intercity rail cars can be met by the purchase of new vehicles. However, some entities which do not plan to purchase a sufficient number of new vehicles before the compliance date for the "one-car-per- train" rule may choose to retrofit existing vehicles. For these entities, the Board has included provisions in the appropriate general sections concerning such retrofitted vehicles.

Operations
The Vehicle Guidelines cover the design, manufacture and alteration of vehicles, not their
operation. Operational requirements are within the purview of DOT, not the Board, and are covered
by Part 37 of the DOT rule, especially subparts B and G. Except for the possibility of operational
procedures allowed under the equivalent facilitation provision, discussed below, the Board's statutory mandate is to ensure accessibility of the built environment, including instances in which operational procedures might fail. For example, the Board cannot assume that the strength, agility and attention of a driver will be sufficient to prevent a heavy wheelchair from rolling off a lift. Thus, the Board has included a requirement for lift platform barriers. Neither is it appropriate, as one transit operator suggested, to assume that fellow passengers will have the strength or skill to assist persons with disabilities to board vehicles. It is just as inappropriate to expect other passengers to lift a wheelchair user into a vehicle as it is to assume others should lift a wheelchair over a curb or carry someone up a flight of stairs to enter a building. Therefore, specific vertical and horizontal gaps for rail vehicles are specified.

Wheelchair and Mobility Aid Standards
Neither the ADA, nor any other statute, confers upon the Board the authority to set standards
or minimum requirements for wheelchairs and mobility aids. The ADA does, however, provide a clear mandate to the Board to set the minimum requirements for vehicles. The Board has attempted to carry out this charge in the fairest, most cost effective manner possible consistent with the statute.

Minimum Requirements
It should be noted that these Vehicle Guidelines, and the DOT standards based on them, are
minimum requirements. Standards or specifications which provide greater access are permitted. In addition, there are sections which expressly permit alternatives (e.g., rear-facing securement). The word "may" is used where alternatives are permitted and should not be construed as a requirement. Also, an appendix has been included in the guidelines which contains non-mandatory, advisory guidance to assist in applying the rule. The material from that appendix has been generally incorporated into the discussion material in this document.

Periodic Revisions
The Board intends to conduct periodic updates and revision of the Vehicle Guidelines so that
future technologies and practices can be incorporated into them. As noted in the following
discussions, the Board feels that additional data and study are needed in regard to certain issues and it intends to further revise and modify these guidelines based on its review of collected data and study results. Also, some variations determined to provide equivalent facilitation may be explicitly incorporated in future updates.
In addition, the Board plans to revise and update these technical manuals as new information
or technology surfaces or as the Vehicle Guidelines themselves are changed. In some places in these manuals, notation is made of drafting errors or sections where the regulation itself is unclear. Several non-substantive changes in the regulation may be made in the future and these changes will be reflected in revised editions of these manuals.

How These Manuals are Organized
Each of these manuals deals with a separate transportation mode or vehicle type, based on a
particular subpart of the final regulation (e.g., subpart B - Buses, Vans and Systems; subpart C - Rapid Rail Vehicles and Systems; etc.). However, since subpart A applies to all vehicles, it is included at the beginning of each manual. Each manual is self-contained so that reference to other manuals is not necessary. Where the provisions of the Vehicle Guidelines refer to other modes, or where the DOT regulation requires one type of vehicle to comply with the requirements of another type, the relevant sections are repeated.
The portions of this document which appear in bold are the provisions as they appear in the
final Vehicle Guidelines. The text immediately following is a discussion of the rationale. For
purposes of this document, the section numbers correspond to the provisions as they appear in
Title 36 of the Code of Federal Regulations. The numbering system of DOT's regulation follows the same format with the exception of the prefix number (i.e., 1192.23(b)(6) is substantively identical to 38.23(b)(6), etc.). Some of the provisions, particularly the requirements for horizontal gaps and vertical displacement between vehicles and platforms, must be read in conjunction with the station design requirements in 36 CFR Part 1191, which are included as Appendix A of the DOT regulation at 49 CFR Part 37. 
 

Other Publications
The Access Board has also made available a checklist based on its ADA Accessibility Guidelines (ADAAG) for Buildings and Facilities. ADAAG contains requirements for transit facilities, including bus stops and terminals, fixed facilities and stations, and airports. The Board also publishes technical bulletins on certain sections in ADAAG. These publications are available from the Access Board.Subpart A -- General

1192.1 Purpose.
This part provides minimum guidelines and requirements for accessibility standards to be issued by the Department of Transportation in 49 CFR Part 37 for transportation vehicles required to be accessible by the Americans with Disabilities Act (ADA) of 1990, 42 U.S.C. 12101 et seq.

This section merely sets forth the purpose of the guidelines which is to establish the minimum requirements for standards issued by DOT. Section 504 of the ADA requires the Access
Board to issue minimum guidelines and requirements for vehicles and facilities. In turn, DOT must issue standards which are consistent with these guidelines. The DOT standards could be more strict than the guidelines but could not provide a lesser degree of accessibility. This format is similar to that under the Architectural Barriers Act of 1968 in which the Board issued the Minimum Guidelines and Requirements for Accessible Design which sets the baseline for the Uniform Federal Accessibility Standards (UFAS). As discussed previously, the standards themselves have been issued by DOT and are codified at 49 CFR Part 38.
 

1192.2 Equivalent facilitation.
Departures from particular technical and scoping requirements of these guidelines by use of other designs and technologies are permitted where the alternative designs and technologies used will provide substantially equivalent or greater access to and usability of the vehicle. Departures are to be considered on a case-by-case basis by the Department of Transportation under the procedure set forth in 49 CFR 37.7. The Board and DOT agree that there is a need for some flexibility to address unique and special circumstances and to facilitate the application of new technologies. Therefore, an "equivalent facilitation" provision has been included that is similar to the provision in the buildings and facilities guidelines. DOT has established procedures under which an entity (e.g., transit agencies, providers, etc.) may pursue alternative means of providing accessibility with respect to specific requirements of the standard. The FTA or Federal Railroad Administration (FRA) Administrator will determine on a case-by-case basis whether equivalent facilitation is provided. See 49 CFR 37.7 for the detailed procedures which must be followed as part of an application to the Administrator for an equivalent facilitation determination. DOT intends to consult with the Board in making determinations of equivalency.
The Board wishes to point out that equivalent facilitation does not constitute a waiver from
any accessibility requirement and is not a lesser standard of accessibility. Alternate designs and
technologies may be used only where they will provide substantially equivalent or greater access to, and usability of, a vehicle. The Board encourages that, when considering alternative designs and technologies, entities consult with individuals with disabilities and their organizations at the earliest possible stage of the process. The Board is available to provide technical assistance regarding equivalent facilitation.
In developing an equivalent facilitation proposal, an entity should consider the intent of the
guideline or standard requirement. For example, large buses are required to have a doorway height of 5'8" from the raised lift platform. This height, although it accommodates only about 70% of the adult male population, is intended to provide some minimum head clearance for standees. 
This clearance is especially important where a standee would be positioned outside the vehicle
door when the lift is down but is moved up and through the door as the lift is raised. Other models
of lifts do not move the standee through the door, but the individual would need to pass through the door after the lift is raised. While it is not practicable to provide clearance for the 90th percentile
standee, it is desirable to provide as much head room as possible, since ducking to clear the doorway may be more difficult for persons with ambulatory disabilities than for other members of the general population. A greater height was not specified because information supplied by vehicle manufacturers indicated that this height was consistent with that needed to accommodate overhead door opening mechanisms and roof lines.
However, some lifts are designed such that the motion is entirely vertical ("elevator" type lifts)
and a standee is positioned at the full inboard edge and is raised fully within the vehicle, clear of the door lintel. In this case, the FTA Administrator has determined that the intent of the doorway height requirement is being met by the particular lift configuration, provided the location of the handrails is such that the full inboard standing position is viable.
 

1192.3 Definitions. 
Accessible means, with respect to vehicles covered by this part, compliance with the provisions of this part. Automated guideway transit (AGT) system means a fixed-guideway transportation system which operates with automated (driverless) individual vehicles or multi-car trains. Service may be on a fixed schedule or in response to a passenger-activated call button. Such systems using small, slow moving vehicles, often operated in airports and amusement parks, are sometimes called "people movers". Bus means any of several types of self-propelled vehicles, other than an over-the- road bus, generally rubber tired, intended for use on city streets, highways, and busways, including but not limited to minibuses, forty- and thirty-foot transit buses, articulated buses, double-deck buses, and electric powered trolley buses, used to provide designated or specified public transportation services. Self-propelled, rubber tire vehicles designed to look like antique or vintage trolleys or street cars are considered buses. 

Common wheelchairs and mobility aids means belonging to a class of three or four wheeled devices, usable indoors, designed for and used by persons with mobility impairments which do not exceed 30 inches in width and 48 inches in length, measured 2 inches above the ground, and do not weigh more than 600 pounds when occupied.

Commuter rail car means a rail passenger car obtained by a commuter authority (as defined by 49 CFR 37.3) for use in commuter rail transportation. Commuter rail transportation means short-haul rail passenger service operating in metropolitan and suburban areas, operated by a commuter authority whether within or across the geographical boundaries of a state, usually characterized by reduced fare, multiple ride, and commutation tickets and by morning and evening peak period operations. This term does not include light or rapid rail transportation.

Demand responsive system means any system of transporting individuals, including the provision of designated public transportation service by public entities and the provision of transportation service by private entities, including but not limited to specified public transportation service, which is not a fixed route system.

Designated public transportation means transportation provided by a public entity (other than public school transportation) by bus, rail, or other conveyance (other than transportation by aircraft or intercity or commuter rail transportation) that provides the general public with general or special service, including charter service, on a regular and continuing basis.

Fixed route system means a system of transporting individuals (other than by aircraft), including the provision of designated public transportation service by public entities and the provision of transportation service by private entities, including but not limited to specified public transportation service, on which a vehicle is operated along a prescribed route according to a fixed schedule.

High speed rail means an intercity-type rail service which operates primarily on a dedicated guideway or track not used, for the most part, by freight, including, but not limited to, trains on welded rail, magnetically levitated (maglev) vehicles on a special guideway, or other advanced technology vehicles, designed to travel at speeds in excess of those possible on other types of railroads.

Intercity rail passenger car means a rail car intended for use by revenue passengers obtained by the National Railroad Passenger Corporation (Amtrak) for use in intercity rail transportation.

Intercity rail transportation means transportation provided by Amtrak. Light rail means a streetcar-type vehicle railway operated on city streets, semi- private rights-of-way, or exclusive private rights-of-way. Service may be provided by step-entry vehicles or by level-boarding.

New vehicle means a vehicle which is offered for sale or lease after manufacture without any prior use. Over-the-road bus means a vehicle characterized by an elevated passenger deck
located over a baggage compartment. Rapid rail means a subway-type transit vehicle railway operated on exclusive private rights-of-way with high-level platform stations. Rapid rail may also operate on elevated or at-grade level track separated from other traffic.

Remanufactured vehicle means a vehicle which has been structurally restored and has had new or rebuilt major components installed to extend its service life. Specified public transportation means transportation by bus, rail, or any other conveyance (other than aircraft) provided by a private entity to the general public, with general or special service (including charter service) on a regular and continuing basis.

Tram means any of several types of motor vehicles consisting of a tractor unit, with or without passenger accommodations, and one or more passenger trailer units, including but not limited to vehicles providing shuttle service to remote parking areas, between hotels and other public accommodations, and between and within amusement parks and other recreation areas.

Used vehicle means a vehicle with prior use.

The definitions in this section are consistent with the definitions included in the DOT final
rule. This set of definitions, however, does not include some terms which are included in the DOT
rule, primarily those which concern operational issues not addressed by the guidelines. Notice that the term "accessible" means compliance with the provisions of the guidelines (or the DOT standards in 49 CFR Part 38) which includes any determinations of equivalent facilitation. 
 

1192.4 Miscellaneous instructions.
(a) Dimensional conventions. Dimensions that are not noted as minimum or maximum are absolute.
(b) Dimensional tolerances. All dimensions are subject to conventional engineering tolerances for material properties and field conditions, including normal anticipated wear not exceeding accepted industry-wide standards and practices.
(c) Notes. The text of these guidelines does not contain notes or footnotes. Additional information, explanations, and advisory materials are located in the Appendix. 
(d) General terminology. The terms used in this part shall have the following meanings:
(1) Comply with means meet one or more specification of these guidelines.
(2) If, or if...then denotes a specification that applies only when the conditions described are present.
(3) May denotes an option or alternative.
(4) Shall denotes a mandatory specification or requirement.
(5) Should denotes an advisory specification or recommendation and is used only in the appendix to this part.

This section contains several provisions designed to reduce some confusion which became
evident in the responses to the original proposal. It contains miscellaneous instructions, including
dimensional conventions and tolerances, and general terminology. An appendix was also added to the final guidelines that contains additional information, explanations, and advisory materials. That material is summarized in the discussion sections of this document, where appropriate.
With respect to dimensional tolerances, certain materials expand or contract due to variations
in temperature or during the process of "curing" or drying. As a result, even close tolerances during construction or manufacture cannot ensure continued conformance to a given standard. For example, a cable-driven historic inclined system has been modified to be generally accessible. However, the cable
is subject to uncontrollable stretching during the day, especially in hot weather. The cars generally
provide level entry in the morning, but may be significantly out of alignment by the end of the day. 
Such variation, even in a new system, resulting from material variations beyond the control of the
operator would not be deemed in violation of the guidelines. Furthermore, unlike buildings and
facilities which are essentially stationary objects, vehicles move and have dynamic as well as static "envelopes". Springs lose their elasticity, steel rails and wheels wear down, and supposedly "fixed" objects settle due to dynamic stress. The allowance for normal wear, however, is only to be applied in accordance with accepted industry standards and practices, not simply an agency policy. If the industry, including designers, engineers, manufacturers, operators, and recognized professional associations agree that a specific adherence can be achieved above that allowed by an agency policy or practice, it is the industry standard which is to be applied, not the agency policy.
Reliance on dimensional tolerances, however, is not an excuse for improper or deferred
maintenance, or poor design or construction methods. For example, the claim of "dimensional
tolerances" could not be made for a lift which fails to eet the vehicle floor within the limits specified
in these guidelines, simply because an adjustment which could have been reasonably made to a control system or limit switch was not made. Neither could a rail operator be excused from compliance because it accepted vehicles from a manufacturer which did not meet the operator's bid specification.  Nor could a group of manufacturers, operators or designers, for example, simply get together to adopt a lower "standard" solely for the purpose of relaxing compliance. Such a change would need to be acknowledged by a significant segment of the industry to constitute an "accepted industry standard or practice." Moreover, dimensional tolerances apply to the construction, manufacture or operation of a system, not to the design. An entity cannot issue vehicle specifications which are less stringent than those required by the guidelines; nor could it justify a wider horizontal gap as being within dimensional tolerances because it did not specify its vehicles to be within achievable limits for sway or stability.Subpart E -- Commuter Rail Cars and Systems

1192.91 General.
(a) New, used and remanufactured commuter rail cars, to be considered accessible by regulations issued by the Department of Transportation in 49 CFR Part 37, shall comply with this subpart. 

The Americans with Disabilities Act (ADA) requires new or used rail cars that are purchased
or leased after August 25, 1990, to be accessible. A public entity may purchase or lease a used
commuter rail car for use on its system that is not readily accessible to, and usable by, individuals with disabilities if, after making demonstrated good faith efforts to obtain an accessible car, it is unable to do so. See 49 CFR 37.87(c) for a description of what constitutes good faith efforts. Cars that are remanufactured after this date to extend their usable life for 10 years or more are also required to be accessible, to the extent it does not compromise the structural integrity of the car. On October 4, 1990, the U.S. Department of Transportation (DOT) issued an interim set of requirements for such cars. 
The guidelines discussed in this technical assistance document are substantively identical to
standards issued by DOT on September 6, 1991, at 49 CFR Part 38 which replace those issued
previously. The DOT rule at 49 CFR Part 37 further outlines the applicability and effective dates of
these requirements. In general, these requirements became effective on October 7, 1991. Questions as to whether certain vehicles are subject to these standards and specific effective dates should be directed to DOT.
It should be noted that commuter rail bi-level cars, which a growing number of operators are
beginning to use in their systems, although not excluded from coverage, are not specifically addressed by the ADA or these guidelines. The requirements outlined here for commuter rail cars are intended to apply only to the lower level in the case of bi-level cars. Bi-level coach cars which can be entered directly from the station platform, as opposed to  bi-level cars which can only be entered from an adjacent car, should follow the applicable standards for single-level coaches, for doors, passageways, steps and thresholds, etc. Accessible spaces should be provided on the level which can be directly accessed from the platform, usually the lower level. 
 

(b) If portions of the car are modified in such a way that it affects or could affect accessibility, each such portion shall comply, to the extent practicable, with the applicable provisions of this subpart. This provision does not require that inaccessible cars be retrofitted with lifts, ramps or other boarding devices.

This provision is similar to existing requirements of common accessibility codes and should
be viewed as an "opportunity" clause. That is, when modifications are made for any reason, the
opportunity must be explored to provide the maximum access feasible. When a car is modified, each element that is part of the modification should be brought into compliance with the applicable sections of these requirements. For example, if a car's floor is resurfaced and its electrical system rewired, the new floor surface must be slip resistant at aisles and areas used by standees and mobility aid users. If existing audible signals are replaced or rewired, the installation of audible and visual door signals would also be required as part of the modification project. The intent of this provision is to ensure that elements of a car will be made accessible when the opportunity to do so exists in the regular course of modifying or upgrading cars. However, those elements of the car not affected by the modification plan would not have to be brought into conformance with these requirements. Under any modification plan, the installation of a lift, ramp, bridge plate or other boarding device is not required, even if the entrance of a car is modified.
 

(c)(1) Commuter rail cars shall comply with 1192.93(d) and 1192.109 for level
boarding wherever structurally and operationally practicable.

Where structurally and operationally practicable, commuter rail cars are to be coordinated with
boarding platforms as specified in section 1192.93(d) to provide level boarding and are to be equipped with between-car barriers according to section 1192.103. This provision recognizes that level boarding is the best means of providing accessibility and benefits all passengers. It is operationally superior to deploying boarding devices such as lifts, ramps, or bridge plates and can significantly reduce station dwell times required for passenger boarding and alighting. The term "level-boarding," as used by these guidelines, means direct access between the platform and any car of the train without any change in level such as in rapid rail systems. For commuter rail, this would in most cases involve access from a high level platform. Boarding devices, such as lifts, ramps, or bridge plates, are not included in this term. For level boarding, full length high platforms are recommended over mini-high platforms because mini-high platforms can accommodate only a limited number of passengers and may restrict normal passenger flow. Also, mini-high platforms provide a smaller area to which car entrances must be aligned and, in some cases, may require double-stopping of the train, especially when there are more
wheelchair or mobility aid users than can be accommodated on a single car.
This requirement applies only where it is "structurally and operationally feasible" to provide
level boarding. The feasibility of level boarding depends primarily on the boarding platforms of the
system. It is recognized that level boarding is most feasible in new systems where station platforms can be built so as to be level with the floor height of cars. The requirements for transit facilities in subpart C of the DOT rule do require that new and key stations have platforms so that level boarding can be provided unless, again, it is not "operationally or structurally feasible" to do so. In the case of new and key stations, the question of feasibility will depend primarily on whether high platforms can be provided. In the case of existing systems, it would not be considered feasible to provide level- boarding at stations with low-level platforms. Level boarding may not be practicable along track also shared by freight lines since greater platform setbacks are often required. This would be an example of what is meant by "operationally" infeasible.
Under this provision, cars of level boarding systems must be coordinated with the boarding
platform as specified by these guidelines and equipped with between-car barriers that prevent or warn persons from accidently stepping off the platform between cars. 
 

(2) Where level boarding is not structurally or operationally practicable,
commuter rail cars shall comply with 1192.95.

This provision requires that boarding devices such as car-borne, platform-mounted, or portable lifts, ramps or bridge plates be provided according to section 1192.95 where level boarding in not achievable. In new and key stations, the use of such devices is allowed where it would not be feasible to construct high-level platforms. The boarding devices must meet the applicable specifications of these guidelines for mobility aid accessibility.
 

(d) Existing vehicles retrofitted to comply with the "one-car-per-train rule" at 49 CFR 37.93 shall comply with 1192.93(e), 1192.95(a) and 1192.107 and shall have, in new and key stations, at least one door on each side from which passengers board which complies with 1192.93(d). Vehicles previously designed and manufactured in accordance with the program accessibility requirements of section 504 of the Rehabilitation Act of 1973, or implementing regulations issued by the Department of Transportation that were in effect before October 7, 1991 and which can be entered and used from stations in which they are to be operated, may be used to satisfy the
requirements of 49 CFR 37.93.

The ADA requires that at least one car in each train of two or more cars be accessible by 1995. 
Some operators will choose to make existing cars accessible in order to meet this requirement. In such situations, this provision requires only that cars conform to the following:

REQUIREMENTS FOR RETROFITTED CARS
 

One accessible door that in new and key stations:
- provides 32 inches of clear width; 
- is designated by the International Symbol of Accessibility; and
- is coordinated with the platform so that the horizontal gap does not exceed 4 inches and the car floor is within plus or minus 2 inches of the platform height when the car is loaded to 50% of its capacity
 

Boarding devices (lift, ramp or bridge plate) where level entry is not provided
 

Two accessible seating locations (on an accessible route from accessible entrances)
 

An accessible restroom (if restrooms are provided for all passengers) and signage at
adjacent entrances to cars indicating the availability of an accessible restroom
 

Existing cars that meet previous accessibility standards can also be used to meet the "one-car-
per-train" rule without any retrofit, provided they can be entered and used from the stations in which they are to be operated. If not, they cannot be used to satisfy the rule, or they must be modified. 
Specifically, such standards include those issued by DOT under Section 504 of the Rehabilitation Act of 1973, which covers transit systems receiving Federal funds, or the interim standards issued
previously by DOT under the ADA. Further information on these standards can be obtained from
DOT. 
Section 1192.107, which addresses restroom access, applies only where restrooms are provided
for the general public. If restrooms are not provided, an accessible restroom need not be added. If
restrooms are provided, at least one would need to be modified for access.
 

1192.93 Doorways. 
(a) Clear width. (1) At least one door on each side of the car from which passengers board opening onto station platforms and at least one adjacent doorway into the passenger coach compartment, if provided, shall have a minimum clear opening of 32 inches. 

Only one entrance on each side of the car from which passengers board is required to provide a
minimum clear opening of 32 inches. If boarding only occurs from one side, only that side is required to have an accessible door. Many commuter rail cars have an interior doorway into passenger compartments. This doorway must also provide 32 inches of clear width. Accessible seating locations should be located as close as possible to this compartment doorway, as shown in Figure 3 (page 22).
The 32-inch door width does not pertain solely to wheelchairs or other wheeled mobility aids. 
Rather, the dimension is designed to accommodate the crutch-tip-to-crutch-tip distance for a typical crutch user. Also, the requirement is for a "clear opening." Providing a wide doorway with a vertical stanchion in the center does not meet this requirement.

(2) If doorways connecting adjoining cars in a multi-car train are provided, and if such doorway is connected by an aisle with a minimum clear width of 30 inches to one or more spaces where wheelchair or mobility aid users can be accommodated, then such doorway shall have, to the maximum extent practicable in accordance with the regulations issued under the Federal Railroad Safety Act of 1970 (49 CFR Parts 229 and 231), a clear opening of 30 inches.

This requirement applies only to new cars equipped with end doors that can be reached by a
wheelchair or mobility aid user. This means that where there is a route at least 30 inches wide, and without steps, leading from the area containing accessible spaces to the end door, then the end doors must provide a minimum of 30 inches clear width. Since the clear area in which mobility aid users can position themselves is usually located at the ends of cars, the end doors will most likely be in close proximity to accessible spaces. This requirement does not apply to cars not equipped with end doors or cars designed with a route leading to the end doors that is less than 30 inches wide at any point or that is inaccessible in any other aspect (e.g., steps). However, this provision should not be viewed as an excuse to arbitrarily place stanchions or arrange seats to preclude a 30-inch wide passage to avoid having to specify 30-inch wide end doors.
These guidelines do not address evacuation procedures or require that end doors be used in
emergencies or that they be part of an evacuation route. For a variety of reasons, the end doors might not be used by a transit system's evacuation plan. In addition, a transit system's evacuation plan that did not specify use of end doors would not be precluded by this provision. Nevertheless, the end doors of new cars can easily be designed to be functionally accessible (i.e., have 30 inches of clear width) and should be accessible in case they may serve as an accessible means of egress. In limited emergencies, such as when the side doors of a car fail, accessible end doors would be the only means of exit. Additionally, the Board recognizes that this provision does not guarantee access into adjoining cars since existing cars may not have end doors with 30 inches of clear width. However, as old cars are replaced over time and the number of accessible cars on each train increases, the chances of providing an accessible connection between cars will be greater. This provision recognizes that regulations issued under the Federal Railroad Safety Act, which include requirements for collision posts, may effectively prohibit the installation of end doors with 30 inches of clear width. Under these circumstances, the 30-inch width requirement would not apply since these guidelines are not intended to conflict with existing safety requirements. Further, it should be noted that existing cars, including those retrofitted under the "one-car-per-train rule," are not subject to this provision. 
 

(b) Passageways. A route at least 32 inches wide shall be provided from doors required to be accessible by paragraph (a)(1) of this section to seating locations complying with 1192.95(d). In cars where such doorways require passage through a vestibule, such vestibule shall have a minimum width of 42 inches. (See Fig. 3) 

This section, in conjunction with paragraph (a)(1), ensures that an accessible route is provided
to accessible seating locations. Paragraph (a)(1) addresses entrances and doors that are located on such routes, while this provision covers passageways. Commuter rail cars with entrance vestibules typically have routes that require a right-angle turn into the compartment door. Due to the maneuvering involved, this provision requires that such vestibules be at least 42 inches wide so that enough clear space is provided for wheelchair and mobility aid users to negotiate such turns. The 42-inch dimension is based on existing accessibility standards for buildings and facilities and is considered the absolute minimum amount of space necessary for turns at doorways. This requirement would only apply to one vestibule for each car located at the same end where accessible entrances and compartment doors are located. Figure 3 illustrates this configuration.
During the development of these guidelines, many commenters pointed out that existing cars
could not be easily modified to provide 42-inch wide vestibules. However, it should be noted that this requirement pertains only to new cars and that existing cars or cars that are retrofitted under the "one- car-per-train" rule would not be subject to this provision. 
 

(c) Signals. If doors to the platform close automatically or from a remote location, auditory and visual warning signals shall be provided to alert passengers of closing doors. 
Audible signals usually activate before the doors begin to close and thus provide advance
warning that the doors are about to close. Without visual signals, persons with hearing impairments are not afforded any equivalent advance warning and can only detect closings as the doors actually begin to close. According to information received during the development of these guidelines, the addition of audible and visual warning signals for automatically-operated doors of new cars is feasible and represents only a modest cost increase for a chime, light, and associated electrical controls at each doorway. These signals are not required to be provided on existing cars or those that are retrofitted. 
Since proposed requirements for door closing force and speed have been removed, the Board considers the provision of audible and visual indicators to be of even greater importance. 
The term "passengers" means persons within the transit system including those who are on the
train and those waiting to board. Therefore, warning signals must be visible from both inside and
outside the car. This can be achieved by equipping the entrances of new cars with both an interior and exterior light indicator. Also, it is conceivable that a single light indicator, by either its illumination level, design, or placement may be specified so that it is visible both inside and outside the car. Either method of addressing this requirement is acceptable so long as it provides a visual warning that doors are about to close. Further, visual indicators should be synchronized with audible signals so that equivalent advance notification of door closure is provided to all persons, including those with hearing or visual impairments.
Notice that the requirement for audible and visual warning signals applies only to doors which
close automatically or are closed from a remote location.
 

(d) Coordination with boarding platform. - (1) Requirements. Cars operating in stations with high platforms, or mini-high platforms, shall be coordinated with the boarding platform design such that the horizontal gap between a car at rest and the platform shall be no greater than 3 inches and the height of the car floor shall be within plus or minus 5/8 inch of the platform height. Vertical alignment may be accomplished by car air suspension, platform lifts or other devices, or any combination.

This requirement pertains to new cars operating at new stations with high-level platforms
(level boarding) or mini-high platforms. These specifications, and the exceptions that follow, outline the maximum horizontal gap and vertical tolerance allowed. However, cars should be specified to be level with the platform edge and as close to it horizontally as possible, so that under normal passenger conditions these maximum levels are not exceeded. These tolerances, even when specified in the acquisition of new cars, may not be achieved under all conditions. The requirements are based on normal passenger conditions. It is incumbent on the operator not only to specify the correct floor height when ordering cars (and to accept them only if they meet the specification) but also to correctly specify the rail-to-platform height for new stations. Thus, it is important to keep in mind that the horizontal gap and vertical tolerance are dependent not only on the car specifications but also the design and construction of station platforms and track specifications. Those requirements, including gap tolerances, are provided at 49 CFR Part 37, Appendix A. 
In those instances where none of these requirements can be met, including those allowed by
the exceptions, operators would be able to pursue alternative means of reducing gaps under the
procedure for equivalent facilitation contained in DOT's rule (see 49 CFR 37.7). Also, the Board
recognizes that close tolerances during construction or manufacture cannot ensure continued
conformance to a given standard. Variations, such as those resulting from normal wear or material variations would not be deemed violations of the guidelines. However, only those variations within the limits of accepted industry practices or tolerances are allowed. (See Subpart A at the beginning of this manual for further discussion of dimensional tolerances.) The Board recognizes the need for flexibility where feasibility and cost significantly affect the ability to meet the standards for new cars and new stations. The exceptions below take into account circumstances that would make compliance with the gap tolerances for new systems difficult, if not impossible, to meet.
The intent of the above specifications is to define an "accessible interface" which would not
necessitate additional gap-closing methods or devices. If the specifications cannot be achieved,
additional devices or equipment must be provided.
 

(2) Exception. New vehicles operating in existing stations may have a floor height within plus or minus 1-1/2 inches of the platform height. At key stations, the horizontal gap between at least one accessible door of each such vehicle and the platform shall be no greater than 3 inches.

The ability to closely align new cars with existing station platforms is limited by the rail-to-
platform height and the vertical distance between the track and the platform. Existing stations are not required to be altered under the ADA, unless they are a "key" station. This provision allows new cars serving existing stations, including key stations, a greater vertical tolerance since the variability in existing platform height may make the 5/8 inch tolerance infeasible. 
Achieving a consistent horizontal gap along the cars of a train is not feasible at stations with
curved platforms. In view of this, the three inch horizontal gap requirement has been limited only to
key stations which are required to be made accessible under the ADA, and does not apply to other
existing stations. Further, only one door of a new car is required to meet the three inch gap
requirement since, in the case of curved stations, a uniform gap cannot be achieved along the side of a car. A system could, as one transit operator has suggested, designate one location where such tolerances are achieved along a portion of a curved station platform. Also, new cars could be ordered with a slight sill protrusion to reduce the horizontal gap in stations where a wider gap currently exists. 
 

(3) Exception. Where platform set-backs do not allow the horizontal gap or vertical alignment specified in paragraph (d)(1) or (2) of this section, car, platform or portable lifts complying with 1192.95(b), or car or platform ramps or bridge plates, complying with 1192.95(c), shall be provided.

Since many commuter rail lines share track with freight lines, high platforms may not be operationally feasible. Freight lines often require greater platform set-backs from the track. Therefore, it is anticipated that most commuter systems will provide access from low platforms with car-borne, platform-mounted, or portable lifts. Other options include bridging the gap between cars and platforms with ramps or bridge plates or providing mini-high platforms. One commuter rail operator has developed a car-borne bridge plate mounted in a car vestibule compartment which can be easily and quickly deployed where needed.
NOTE: The exception in section 1192.93(d)(3) is also intended to apply to retrofitted vehicles
addressed by section 1192.93(d)(4) (below). However, as currently written in the final rule, this is not apparent. A technical correction will be made to clarify that the alternatives allowed in (d)(3) for lifts, ramps, or bridge plates where platform set-backs prohibit coordination of the vehicle with the
platform as required in (d)(1) or (d)(2) would also apply to retrofitted vehicles operating in new and
key stations addressed by (d)(4).
 

(4) Exception. Retrofitted vehicles shall be coordinated with the platform in new
and key stations such that the horizontal gap shall be no greater than 4 inches and the
height of the vehicle floor, under 50% passenger load, shall be within plus or minus 2
inches of the platform height.

This exception pertains to existing cars that are made accessible to comply with the "one-car-
per-train" rule. Generally, existing cars cannot be coordinated with the platform to the degree that new cars can. Even if feasible, retrofitting existing cars to meet the requirements for new cars could be very expensive. Consequently, this exception allows a greater and more easily achievable horizontal gap and vertical tolerance. These cars need to be aligned with the platform at new stations or key stations so that the horizontal gap does not exceed 4 inches and the vertical tolerance is less than 2 inches. While the Board does not consider such a gap to be desirable, such cars will eventually be phased out as new cars are added to the system. 

HORIZONTAL AND VERTICAL TOLERANCES

NEW STATIONS
KEY (EXISTING)
STATIONS
 

NEW CARS

3" horizontal gap
5/8" vertical tolerance
3" horizontal gap (1 door)
1-1/2" vertical tolerance* 
 

RETROFITTED
CARS
4" horizontal gap
2" vertical tolerance
4" horizontal gap (1 door)
2" vertical tolerance
 

* Also applies to new cars operating at existing stations, not only key stations. Where these
tolerances cannot be met, lifts, ramps, bridge plates, etc., may be used (see note under section
1192.93(d)(3) above).

(e) Signage. The International Symbol of Accessibility shall be displayed on the
exterior of all doors complying with this section unless all cars are accessible and are
not marked by the access symbol. (See Fig. 6) Appropriate signage shall also indicate
which accessible doors are adjacent to an accessible restroom, if applicable.

The accessible entrances of new and retrofitted cars are required to be designated as
accessible by the International Symbol of Accessibility (access symbol) shown in the figure. 
However, new cars acquired for a commuter rail system in which all cars are accessible and not
designated by the symbol do not have to be designated. In fully accessible systems, consistency
is important so that if existing accessible cars are designated, new cars should be designated as well. 
Still, the Board considers the access symbol to be, at times, subject to over-use and thus recommends that transit operators remove symbols when all cars are accessible. Since cars are usually designated by decals, which eventually wear and must be replaced, operators may opt to simply not replace them. 
Signage for accessible restrooms is also required. Since restrooms are not necessarily 
provided on all commuter rail cars, signage must be placed at the entrance so that persons may
determine before boarding which car offers an accessible restroom. This signage should be located at the entrances closest to such restrooms or those entrances one would be expected to use to reach the restrooms. Currently, there is no standard symbol or sign for indicating that an accessible restroom is provided at a certain location. The content of such signs are left to the discretion of operators. Such signs might include written information, such as "Accessible Restroom Available" and any appropriate or assistive symbols. 
 

1192.95 Mobility aid accessibility. 
(a)(1) General. All new commuter rail cars, other than level entry cars, covered by this subpart shall provide a level-change mechanism or boarding device (e.g., lift, ramp or bridge plate) complying with either paragraph (b) or (c) of this section; sufficient clearances to permit a wheelchair or mobility aid user to reach a seating location; and at least two wheelchair or mobility aid seating locations complying with paragraph (d) of this section. 

The requirement for boarding devices applies only to commuter rail systems that do not provide level boarding. This would also apply to the cars of new systems where level boarding is provided at some but not all stops. The clearances required for access to seating locations are the same as those for doorways and passageways (section 1192.93) and for interior circulation (section
1192.97).
 

(2) Exception. If portable or platform lifts, ramps or bridge plates meeting the applicable requirements of this section are provided on station platforms or other stops, or mini-high platforms complying with 1192.93(d) are provided, at stations or stops required to be accessible by 49 CFR Part 37, the car is not required to be equipped with a car-borne device. Where each new car is compatible with a single platform-mounted access system or device, additional systems or devices are not required for each car provided that the single device could be used to provide access to each new car if passengers using wheelchairs or mobility aids could not be
accommodated on a single car.

New, non-level entry cars are not required to be equipped with boarding devices if such devices
are provided at station platforms or if mini-high platforms are provided. To meet this exception,
boarding devices or mini-high platforms would have to be provided at all stations and stops required to be accessible. However, transit operators should consider which option (boarding devices on cars or at stations) offers the most accessibility in determining what method of access to provide. Where platform-mounted devices are provided, new cars need not be equipped with boarding devices as long as each new car is compatible with the boarding devices located on platforms. 
The Board received some comments from operators of light rail systems who currently use
platform-mounted (wayside) lifts or mini-high platforms with which the operator aligns one door of
the vehicle. The entities suggested that more than one vehicle in a train should not be required to be accessible so that a second lift or mini-high platform would not be needed. The ADA, however, is explicit that, except for specific provisions for intercity rail cars, all new vehicles must be accessible. 
Therefore, the final guidelines require that every new vehicle be able to be entered and used and
accommodate at least two wheelchair or mobility aid users. The current requirement does not require the provision of additional lifts or platforms at a station if other vehicles of the train which are required to be accessible are compatible with, and can be served by, the single lift or platform if the train is positioned properly. 
In practical terms, the driver would align the door of the first car with the lift or mini-high
platform and allow all passengers using wheelchairs or mobility aids to board. If all the waiting
passengers who need the lift or platform can be accommodated on the first car, the train would not need to move to allow boarding of the second car. Transit agencies should carefully assess the interior layout of their cars to ensure that sufficient clear floor area is provided to accommodate all the anticipated wheelchair and mobility aid users for a trip. If a larger number of such passengers presented themselves at a stop, and a second car were not full, it would be discriminatory under the DOT rule not to reposition the train to allow those passengers to board the second car. This potential situation is one of the reasons why the Board strongly urges planners and designers to provide level boarding from full length high platforms wherever possible.
 

(b) Car Lift. - (1) Design load. The design load of the lift shall be at least 600 pounds. Working parts, such as cables, pulleys, and shafts, which can be expected to wear, and upon which the lift depends for support of the load, shall have a safety factor of at least six, based on the ultimate strength of the material. Nonworking parts, such as platform, frame, and attachment hardware which would not be expected to wear, shall have a safety factor of at least three, based on the ultimate strength of the material.

The specified design load is consistent with the definition of a "common wheelchair or mobility aid" which weighs 600 pounds or less when occupied. However, the design load does not
represent the maximum load the lift is capable of supporting. The safety factors for the support
components mean the lift cables, pulleys and shaft will support 3600 pounds and the platform, frame and attachment hardware must support 1800 pounds. 
Previous FTA-sponsored guidelines for lifts and some State codes specify a detailed test and
certification procedure to help ensure reliability, maintainability and durability. The Board does not
view these issues as directly related to accessibile design but rather as operational considerations. The DOT rule requires accessibility equipment to be maintained and those factors which could affect maintainability should generally be included in bid specifications. Furthermore, the National Highway Traffic Safety Administration (NHTSA) may issue a regulation on several safety aspects of accessibility equipment on buses which may include some specific testing requirements, and which may be applicable to rail car lifts. The Board views NHTSA as the more appropriate agency to deal with these issues and has not dealt with them in the guidelines.
 
 

(2) Controls. (i) Requirements. The controls shall be interlocked with the car brakes, propulsion system, or door, or shall provide other appropriate mechanisms or systems, to ensure that the car cannot be moved when the lift is not stowed and so the lift cannot be deployed unless the interlocks or systems are engaged. The lift shall deploy to all platform levels normally encountered in the operating environment. Where provided, each control for deploying, lowering, raising, and stowing the lift and lowering the roll-off barrier shall be of a momentary contact type requiring continuous manual pressure by the operator and shall not allow improper lift sequencing when the lift platform is occupied. The controls shall allow reversal of the lift operation
sequence, such as raising or lowering a platform that is part way down, without allowing an occupied platform to fold or retract into the stowed position. 

Many types of vehicles are specified with door interlocks which prevent vehicle movement when the door is open. Since the door must be open to operate the lift, this provision would be satisfied. If an auxiliary door is provided exclusively for a lift or ramp, that door would also need to be interlocked. Alternatively, the lift or ramp itself could be provided with its own interlock system. In some cases, meeting this requirement may involve other solutions, especially for rail cars where door interlocks are not normally provided or where a portable lift may have no direct connection to the car. 
The "appropriate mechanisms or systems" might include some relatively simple electrical interlocks. 
However, a system or mechanism, such as a flashing light or buzzer, which only provides a warning to the driver can be inadvertently overlooked. Such a system does not meet the intent of this provision, although a combination of devices and operating procedures might be approved as equivalent facilitation. The key operational criterion is that the car cannot be moved while the lift or ramp is in use. Furthermore, the lift must be designed to deploy to all levels expected to be encountered in the operating environment. 
Finally, if the lift is electrically operated, the controls must be of the momentary contact type,
requiring continuous pressure to activate and must be interlocked to preclude the possibility of
folding or stowing the lift when the platform is occupied (except as provided below). Some lifts
currently in service can be folded or stowed simply because the operator presses the wrong button at the wrong time. This regulatory provision is intended to preclude this possibility. Some lifts accomplish this function by incorporating a pressure sensitive switch in the platform to sense when it is occupied. Others incorporate a slip-clutch mechanism on the folding motor such that it is not capable of folding anything heavier than an empty platform. Photocells or proximity switches might also be employed to detect the presence of a person on the lift platform. Some lifts also employ pressure switches at pinch points to stop the lift operation if a passenger's foot is caught between opposing members. Whatever system is used, it should be designed so that, if the pressure switch, photocell or proximity switch is not operating, the lift will not operate. 
The lift must be capable of reversal, but without folding or stowing. For example, if the platform is raised to the car floor but the inner barrier fails to retract to allow the user to board, then the controls must allow the lift to be returned to platform level for deboarding. In this case, the fold or stow function must still be precluded until the platform is empty.
 

(ii) Exception. Where physical or safety constraints prevent the deployment at some stops of a lift having its long dimension perpendicular to the car axis, the transportation entity may specify a lift which is designed to deploy with its long dimension parallel to the car axis and which pivots into or out of the car while occupied (i.e., "rotary lift"). The requirements of paragraph (b)(2)(i) of this section prohibiting the lift from being stowed while occupied shall not apply to a lift design of
this type if the stowed position is within the passenger compartment and the lift is intended to be stowed while occupied.

This provision simply permits the use of a certain type of lift which would be precluded by the
previous requirement that the lift cannot be stowed when occupied. The particular type of device, a
rotary lift, intended to be covered by this exception is one in which the platform rotates into the car
and this is the stowed position. In this case, the lift is intended to be stowed while occupied, which
would otherwise be prohibited by strict application of the previous paragraph. It should be noted,
however, that another type of rotary lift in which the platform is intended to be raised to a vertical
position for stowage, is not covered by this exception. Such a design is not precluded, since the
rotation of the platform while occupied is not prohibited, but the actual raising of the platform into
the vertical stowed position must still be prevented when the platform is occupied.
 

(iii) Exception. The brake or propulsion system interlock requirement does not apply to a platform mounted or portable lift provided that a mechanical, electrical or other system operates to ensure that cars do not move when the lift is in use.

This exception for platform-mounted or portable lifts allows the use of a "mechanical, electrical, or other system" in lieu of an interlock system, to ensure that the car does not move while the lift is in use. Under this exception, devices may be installed that do not function as an interlock but, at a minimum, as a warning that a lift is in use or that a door is open. Some mechanical or electrical device must be provided in addition to any operational methods in order to limit the possibility of human error. This provision is written as a performance requirement so that transit operators and manufacturers have as much flexibility as possible in providing such a system. If this requirement cannot be met, operators can develop and propose alternative methods under the procedures for equivalent facilitation.
 

(3) Emergency operation. The lift shall incorporate an emergency method of deploying, lowering to ground or platform level with a lift occupant, and raising and stowing the empty lift if the power to the lift fails. 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, and shall not permit the platform to be stowed or folded when occupied, unless the lift is a rotary lift intended to be stowed while occupied. 

This provision is intended to allow persons who need the lift to deboard if the lift power fails. 
Typically, this operation is performed by a hand operated crank or pump, although some devices
incorporate a back-up power system. The emergency system is only intended to allow the lift to be
deployed and lowered to platform level with an occupant, not to allow the passenger to board. 
Whatever method is used for emergency operation, it must continue to operate safely, when operated according to manufacturer's instructions. The emergency system must not permit the lift to be stowed or folded when occupied. This could be accomplished with a pressure valve in the hand pump system which would not allow sufficient pressure to fold a lift platform which had some specific weight on it. 
Another possible way to comply with this provision is to provide two separate pump control systems, one for raising and lowering and one for stowing, which require a hand lever to be removed from one valve and placed in another to allow operation. This could be especially effective if the stowage control access point were physically blocked by a lift occupant.
 

(4) Power or equipment failure. Platforms stowed in a vertical position, and deployed platforms when occupied, shall have provisions to prevent their deploying, falling, or folding any faster than 12 inches/second or their dropping of an occupant in the event of a single failure of any load carrying component. 

This provision requires some sort of "braking" or "damping" mechanism, similar to those provided on elevators, to prevent "free fall" of an occupied platform in the event of a power failure or single failure of any load carrying component. The fall rate also applies to the deployment cycle in
order to protect persons waiting close to the car for the lift to deploy when the power fails. This is
not a "planned" event which can be anticipated and the slow rate might provide enough time to move out of the way. This provision applies only to those lifts which are stowed in a vertical position, generally the so-called "active" lifts, which could unfold when someone is waiting outside the car. 
Most such lifts with a powered deploy cycle simply stop when the power fails. Preventing rapid
deployment in the event of a single failure of a load carrying component, such as a chain or cable
breakage, will likely require more ingenuity.
 

(5) Platform barriers. The lift platform shall be equipped with barriers to prevent any of the wheels of a wheelchair or mobility aid from rolling off the lift during its operation. A movable barrier or inherent design feature shall prevent a wheelchair or mobility aid from rolling off the edge closest to the car until the lift is in its fully raised position. Each side of the lift platform which, in its raised position, extends beyond the car shall have a barrier a minimum 1-1/2 inches high. Such barriers shall not interfere with maneuvering into or out of the car. The loading-edge barrier (outer
barrier) which functions as a loading ramp when the lift is at ground or station platform level, shall be sufficient when raised or closed, or a supplementary system shall be provided, to prevent a power wheelchair or mobility aid from riding over or defeating it. The outer barrier of the lift shall automatically rise or close, or a supplementary system shall automatically engage, and remain raised, closed, or engaged at all times that the lift platform is more than 3 inches above the station platform and the lift is occupied. Alternatively, a barrier or system may be raised, lowered, opened, closed, engaged or disengaged by the lift operator provided an interlock or inherent design
feature prevents the lift from rising unless the barrier is raised or closed or the supplementary system is engaged.

The first part of this provision covers the barrier (often called a "roll stop") which is intended
to prevent the lift user from rolling or stepping off the platform edge closest to the car. Some lifts
have a flap which rises when the lift is deployed and lowers when the platform reaches the car floor level. Other designs depend on the structure of the car itself or a "close-out panel" to prevent falling off the inner edge. This feature is particularly important in some applications where a persons' toes can be trapped between the rising lift platform and the underside of the door sill (as explained later, the lift must be designed to accommodate both inward and outward facing of wheelchair and mobility aid users).
In addition, side barriers must be provided along those portions of the platform that remain
outside the car when the lift is in the raised position. The portion which is inside the car envelope
does not need side barriers since they could restrict the ability of a wheelchair or mobility aid user in turning into the aisle. In addition, a specific prohibition makes it clear that the side barriers cannot interfere with maneuvering. Care must be taken in this design because there is often a gap between the side of the lift platform and the car floor when the lift is fully raised. For bus lifts, several lift manufacturers and transit operators have indicated that they use various "close-out" gaskets and devices to eliminate or reduce such gaps so that the wheel of a wheelchair or mobility aid will not be trapped when it turns into the aisle. The height requirement for side barriers has been chosen to accommodate some rims on the cambered wheels of sport wheelchairs which may need space to clear the barriers. Higher barriers might interfere with such chairs unless the platform is wider.
Previous FTA-sponsored guidelines for lifts specified a safety test for the loading edge (outer)
barrier. The Board has not required such a test in these guidelines because NHTSA is planning to
issue safety standards for bus lifts which may be suitable for application here. The Board feels that NHTSA is the appropriate agency to define safety tests. In the meantime, this provision includes only a performance requirement. The detailed force test in the original proposal could have been interpreted as meaning that a 3-inch high barrier was sufficient to prevent a power wheelchair from rolling off a platform. This is not the case, since some common power wheelchairs can easily ride over a 3-inch barrier, even if it is firmly locked in its raised position. A barrier with a height greater than 3 inches may be adequate, depending on the angle of the barrier and its rigidity, but a specific test has not been performed to determine what the appropriate height should be. Further, the proposed test seemed to ignore other potential solutions such as a reported Canadian standard which would address the issue of preventing the occupant of a wheelchair or mobility aid from falling from the platform in addition to restraining the chair. Accordingly, the final provision permits a supplementary system as an alternative to a high barrier.
Finally, whatever barrier or supplemental system is used, it must either rise or engage automatically when the lift is raised more than three inches off the platform or ground, or there must be an interlock which prevents the lift from rising more than three inches off the platform or ground unless the barrier or supplementary system is engaged. Thus, the barrier or system could be engaged manually, provided the lift could not rise unless it were properly engaged. Systems could, for example, employ an electrical switch which interrupts power to the lift unless the barrier is engaged or might use a mechanical slip-clutch or gear and sprocket arrangement which is engaged only when the barrier is raised or the supplemental system is engaged.
 

(6) Platform surface. The lift platform surface shall be free of any protrusions over 1/4 inch high and shall be slip resistant. The lift platform shall have a minimum clear width of 28-1/2 inches at the platform, a minimum clear width of 30 inches measured from 2 inches above the lift platform surface to 30 inches above the surface, and a minimum clear length of 48 inches measured from 2 inches above the surface of the platform to 30 inches above the surface. (See Fig. 1)

The requirement for the 1/4 inch maximum protrusion is consistent with common accessibility standards and is intended to reduce tripping hazards for standees.  The requirement for slip resistance is a general performance requirement. As discussed under floor surfaces, there are difficulties in defining an appropriate test procedure for determining the level of slip resistance or the static coefficient of friction. However, a static coefficient of friction of 0.6 is recommended for platform surfaces.
The specified platform surface dimensions are consistent with the definition of "common
wheelchairs and mobility aids" in requiring a 30 inch width and 48 inch length measured 2 inches
above the platform. The reason for the length measurement to be taken at the 2-inch height is to
allow for certain elements such as barrier hinges or control rods to impinge on the 48-inch envelope only if they do not interfere with anti-tip bars and other parts of the wheelchair or mobility aid. While a minimum length at the platform surface is not specified (unlike the width requirement) obviously the platform surface cannot be less than the wheelbase of the mobility aid. The Board acknowledges that some power wheelchairs cannot be accommodated on such a platform but does not have sufficient data on which to base a requirement for a larger platform although some manufacturers and transit operators had suggested that the platform length be 50 inches. Lift platforms which exceed the minimum requirements of this section are desirable to accommodate a larger proportion of the potential population. Such lifts are, in fact, commercially available. 
The width measurement acknowledges that the door structure of some rail cars may not permit
a 30 inch wide platform unless the door or vehicle frame were modified. The width is to be measured 2 inches above the platform to allow a narrower platform at the bottom only, thus permitting wider lifts to be incorporated without modifying the door frame. Also, the lift handrails are often attached to the platform at the bottom and the structural material takes up some portion of the usable surface. 
To have a platform with a clear width of 30 inches at the surface would require a lift with a much
wider overall width. Measuring the width above the handrail anchor points allows a lift which does
not affect door structure but still allows a clear 30 inches between handrails. The clear space is
measured to a height of 30 inches to clear the armrests of most wheelchairs and mobility aids. The clear space required is shown as the shaded portion of Figure 1. In effect, a box of the indicated dimensions must be accommodated on the platform.

The barriers must not intrude into this area when raised. Thus, the inner roll stop and outer barriers must be vertical or, preferably slant outward, to provide the clear area. Under no circumstances may the barriers slant inward into the required clear space.
 

(7) Platform gaps. Any openings between the lift platform surface and the raised barriers shall not exceed 5/8 inch wide. When the lift is at car floor height with the inner barrier down (if applicable) or retracted, gaps between the forward lift platform edge and car floor shall not exceed 1/2 inch horizontally and 5/8 inch vertically. Platforms on semi-automatic lifts may have a hand hold not exceeding 1-1/2 inches by 4-1/2 inches located between the edge barriers.

This section is intended to prevent the front caster of a wheelchair from turning sideways and dropping through the gap between the raised barrier and the platform. It applies only to the gap between the platform and the raised barrier and does not preclude the use of expanded metal platforms. A handhold hole is permitted in the platform for lifts which are manually deployed.
 

(8) Platform entrance ramp. The entrance ramp, or loading-edge barrier used as a ramp, shall not exceed a slope of 1:8, when measured on level ground, for a maximum rise of 3 inches, and the transition from station platform to ramp may be vertical without edge treatment up to 1/4 inch. Thresholds between 1/4 inch and 1/2 inch high shall be beveled with a slope no greater than 1:2.

This required slope is based on common accessibility standards which allow steeper slopes for
short distances where a slope of 1:12 cannot be provided due to existing constraints. A slope of 1:8 is permitted for a maximum rise of 3 inches. If the rise is greater, the slope must be less. In general, the leading edge of the ramp must be tapered. A maximum vertical edge of 1/4 inch is permitted but, if the lip is 1/4 inch to 1/2 inch, the edge must be beveled to a slope of 1:2. In no case may the lip be greater than 1/2 inch high.
 

(9) Platform deflection. The lift platform (not including the entrance ramp) shall not deflect more than 3 degrees (exclusive of vehicle roll) in any direction between its unloaded position and its position when loaded with 600 pounds applied through a 26 inch by 26 inch test pallet at the centroid of the lift platform.

This provision has been clarified so that the platform deflection is exclusive of car roll. In practice, however, the Board expects that the deflection would not be measured on the car but would be measured by the manufacturer on a "test rig" in the factory. The manufacturer would then certify the lift as meeting the standard. The same is also anticipated for other measures, such as acceleration and barrier resistance.
Since the car will normally tilt when the lift is loaded, due to the weight of the wheelchair or
mobility aid and the user, there will be a slope away from the car toward the barrier. The reason for
limiting the deflection of the lift platform is to minimize the contribution to this slope by the platform itself. The deflection load is based on the term "common wheelchair or mobility aid" which is defined as weighing as much as 600 pounds when occupied. Permitting a larger angle would allow the platform to slope more with a heavy wheelchair. This situation is potentially the most dangerous and the most likely to result in a wheelchair or mobility aid overriding or defeating the outer barrier.
 

(10) Platform movement. No part of the platform shall move at a rate exceeding 6 inches/second during lowering and lifting an occupant, and shall not exceed 12 inches/second during deploying or stowing. This requirement does not apply to the deployment or stowage cycles of lifts that are manually deployed or stowed. The maximum platform horizontal and vertical acceleration when occupied shall be 0.3g.

The specified maximum speeds are provided not only for the safety of persons, including standees, occupying the lift, but also of any persons waiting near the lift. The deployment and stowage rate, although allowed a greater speed, may also affect passenger safety. A potential user waiting outside the rail car might not be able to get out of the way of a rapidly deploying lift. Similarly, some lifts which fold up into the passenger compartment, particularly active lifts, could pose a hazard to a person inside the rail car near the lift if the platform stowed too quickly. Accordingly, the final rule specifies a 6 inch per second speed only for the raising and lowering of an occupied lift and a 12 inch per second speed for the deploy and stow portion of the cycle.
The Board considered a requirement for the maximum rate of change of acceleration (jerk) but
did not do so because it is difficult to measure and can be easily affected by other variables not directly related to the rate of change of acceleration of the lift platform itself. Also, there is no research which identifies acceptable rates for persons with disabiliti