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Technical Assistance Manual

October, 1992
Table of Contents
Introdu ction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
Regulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
Vehicles Covered . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
Operat ions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
Wheelchair and Mobility Aid Standards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
Minimum Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
Periodic Revisions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
How These Manuals ar e Organ ized . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
Ot her Publ icat ions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
1192.1 Purp ose. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
1192.2 Equivalent facilitation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
1192.3 Definitions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
1192.4 Miscellaneou s instru ctions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
1192.71 Gener al. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
1192.73 Doorways. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
(a) Clear width. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
(b) Signage. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
(c) Signals. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
(d) Coordination with boarding platform. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
(1) Requirements. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
(2) Exception. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
(3) Exception. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21
(4) Exception. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21
1192.75 Priority seating signs. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
1192.77 Interior circulation, han dr ails and stanchions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23
1192.79 Floors, steps an d th reshold s. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25
1192.81 Lighting. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26
1192.83 Mobility aid accessibility. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
(a)(1) Gener al. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
(2) Exception. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
(b) Vehicle lift. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29
(1) Design load. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29
(2) Contr ols. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29
(3) Emergency operation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
(4) Power or equ ipment failure. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32
(5) Platform barriers. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32
(6) Platform surface. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34
(7) Platform gaps. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35
(8) Platform entrance ramp. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35
(9) Platform deflection. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
(10) Platform movement. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
(11) Boarding direction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37
(12) Use by standees. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37
(13) Han dr ails. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37
(c) Vehicle ramp or brid ge plate. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39
(1) Design load. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39
(2) Ramp surface. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39
(3) Ramp thresh old. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40
(4) Ramp barriers. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40
(5) Slope. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40
(6) Attachmen t. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42
(7) Stowage. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42
(8) Ha nd rails. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42
1192.85 Between-car barr iers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43
1192.87 Public information system. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44
This technical assist ance document is one of a ser ies provided t o help in un dersta nd ing
the background and und erlying rationale of the Americans with Disabilities Act Accessibility
Guidelines for Tran sport ation Vehicles (Vehicle Guid elines ) and how the guidelines may app ly
in a particular case. The documents in t his series are:
o Buses, Vans & Systems
o Rapid Rail Vehicles & Systems
o Light Rail Vehicles & Systems
o Commuter Rail Cars & Systems
o Intercity Rail Cars & Systems
o Over-the-Road Buses & Systems
o Aut oma ted Gu ideway Transit Vehicles & Systems
o High -Speed Rail Cars, Monorails & Systems
o Trams, Similar Vehicles & Systems
The information in th is document is based on t he p reamble published with the Vehicle
Guid elines, augmented with mat erial developed in response to questions wh ich have been
posed to t he Ar chi tect ural an d Trans por tation Bar riers Complian ce Boar d (Acces s Boar d) since
publication of the guidelines. The Department of Transportation (DOT) has issued standard s
for vehicles based on the Guid elines. The guidance in th is document d oes not constitute a
deter mination of comp liance with the DOT stand ard s or with you r right s or responsibilities
und er t he ADA and is not binding on DOT.
The Ameri cans with Disa bilit ies Act (ADA) [P.L. 101-336, 42 U.S.C. 12101, et seq], signed
into law by President Bush on July 26, 1990, is land mark legislation to extend civil rights
protection to people with disabilities. The ADA p rohibits discrimination on the basis of
dis ability in employment , State an d local government services, pu blic transp ort ation , pu blic
accommod at ions, commerci al facilities, an d telecommuni cat ions.
Title II of the ADA p rohibits d iscrimination on th e basis of disability in services,
progr ams, an d act ivit ies p rovid ed by public ent ities, including uni ts of Stat e an d local
govern men t and the National Railroad Passen ger Corp oration (Amtr ak). Title II addr esses
pu blic transportation and contains provisions specifically add ressing the following typ es of
transit systems: fixed rout e bus, rap id rail, light ra il, commuter rail, and intercity rail. Und er
title II, transit systems of these types which are owned or operated by p ublic entities, and
persons und er contract with such entities, must be mad e readily accessible to and u seable by
individu als with disabilities, includ ing individuals who use wheelchairs. With respect to
public entities, title II requires that:
New Vehicles. New vehicles pu rchased or leased after August 25, 1990, must be a ccessible.
Used Vehicles. If used vehicles are purchased or leased after August 25, 1990, good faith
efforts must be ma de to obtain a ccessible vehicles.
Remanufactured Vehicles. If vehicles are reman ufactured 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 commu ter and intercity rail cars, then the vehicles must be made
accessible to the maximum extent feasible.
"One-Car-Per-Train" Rul e. At least one vehicle or car in each train of two or more cars must be
accessible a s soon as practicable bu t in n o event later than July 26, 1995, in th e case of r apid,
light, commuter , and intercity rail systems.
Demand Responsive Systems. New vehicles pu rchased or leased after August 25, 1990, for use
in a deman d respon sive system operated by a public entity, or by a person un der contract with
such an entity, must be accessible unless the system, when viewed in its entirety, provides to
individu als with disabilities a level of service equivalent to that provided to oth er members of
the general public.
Title III of the ADA p roh ibits d iscrimination on t he basis of d isabilit y in pu blic
accommoda tions and s ervices pr ovid ed by p riva te entities. Und er tit le III, public
transportation services (other than by aircraft) provided by p rivate entities must also be mad e
read ily accessible to and usable by ind ividu als with disabilities, includin g ind ividu als wh o use
wheelchairs. Under title III, the following requirements apply to private entities that are
primar ily engaged in the bu siness of tr anspor ting peop le and whose opera tions affect
New Vehicles. New vehicles pu rcha sed or leased after August 25, 1990, mu st be a ccessible
unless the vehicle is to be used solely in a demand responsive system that, when viewed in its
entirety, provid es to ind ividu als with disabilities a level of service equivalen t to tha t pr ovided
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 pu rchased or leased after
Februar y 25, 1992, must be a ccessible, unless the system for which the van is being purchased
or leased , when viewed in its ent irety, pr ovides t o individ uals with disabilit ies a level of serv ice
equivalent to that provid ed to other member s of t he gen era l public.
Rail Cars. New rail passenger cars purchased or leased after February 25, 1992, must be
access ible. Rail passenger cars remanufa ctured after Febru ar y 25, 1992, to ext end their u seful
life for 10 year s or mor e must be mad e accessible to the maximum extent feas ible.
For private entities not primarily engaged in the business of transporting people but
wh ose oper ations affect commerce, such as hotels, shopp ing center s, and recreational facilities
wh ich operate shuttle service for customers or patrons, title III requires that:
New Vehicles for Fixed Route Systems. New veh icles with a seat ing capacit y of mor e th an 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
seat ing capacity of 16 passengers or less pur chas ed or leased after August 25, 1990, for use in a
fixed route system mu st also be accessible unless the system, when viewed in its entirety,
provides to individu als with disabilities a level of service equivalen t to tha t pr ovided to other
member s of t he gen era l 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
respon sive system mu st be accessible unless the system, when viewed in its entirety, provid es
to individuals with disabilities a level of service equivalent to that provided to other members
of th e general public.
Operation of Demand Responsive Systems. Demand r esponsive systems must be operat ed in
such a man ner that after July 26, 1990, the system, when viewed in its entirety, provides to
individu als with disabilities a level of service equivalent to that provided to oth er members of
the general public.
Over-the-Road Buses. Title III specifically addresses over-the-road bu ses operated by private
entities. The Office of Technology Assessment (OTA) is responsible und er title III of the ADA
for studying the access needs of individuals with d isabilities to over-the-road buses and the
most cost-effective method s for prov iding such access. In view of this mand ated stud y, over-
the-road buses covered by tit le III are not required to be accessible t o wheelchair or mobility aid
users u ntil July 26, 1997, for small providers an d July 26, 1996, for other provid ers. Over-the-
road buses purchased or leased aft er Jan uar y 26, 1992, bu t befor e July 26, 1996 or 1997 may be
required to include accessibility features wh ich do not involve structural changes or use of
board ing d evices.

The req uirements for t he size of p lat for m lifts and minimum door heigh t for buses over 22
feet in lengt h a pply t o solicita tions closin g on or aft er Jan uar y 26, 1992. See 49 CFR 37.13 an d
the December 9, 1991, Federal Register (56 FR 64214).
The Depa rtment of Transp ortation is respon sible for issuing regu lations to implement
the transp ortation prov isions of the ADA, including accessibility standard s for transportation
vehicles. The ADA required the Access Board to develop guidelines to provide guidance to
DOT on establishing th e accessibility stand ard s for transpor tation vehicles. DOT published
interim stand ard s on October 4, 1990 (55 FR 40762). Those standards app ly to vehicles
purchased aft er Augu st 26, 1990, but befor e Oct ober 7, 1991.
The Access Board p ublished its minimum guidelines, known as the ADA Accessibility
Guid elines for Transp ortation Vehicles on September 6, 1991, in the Federal Register (56 FR
45530). The provisions for lifts, ramp s, and securemen t devices were dawn pr imarily from a
series of guidelines d eveloped a s pa rt of a pr oject sponsored by th e Federal Tr ansit
Ad min istra tion (FTA), former ly the Ur ban Mass Transport ation Ad min istra tion (UMTA), in
1986: Guideline Specifications for Passive Wheelchair Lifts, Guideline Specifications for Active
Wheelchair Lifts, Guidelin e Specifica tions for Wheelcha ir Ramps and Guideline Specifications
for Wheelchair Securement Devices. Provisions from the Guideline Specifications were
supp lemented with add itional material derived from common accessibility standards, such as
the Uniform Federal Accessibility Standards (UFAS) and the American Na tional Standards
Institute (ANSI) A117.1-1980 specifications, research sponsored by the Access Board, and
ind ustry pr actice. Some p rovisions for Aut omated Guideway Tra nsp ort ation (AGT) "peop le
movers" and r apid rail systems were derived from Los Angeles Downtown People Mover:
Ha nd book on Accessibility for the Elder ly and Ha nd icapped (UMTA, November 1980). In
addit ion, t he guid elines incor porat ed pr ovisions of 49 CFR Part 609 for bu ses, 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
standard s for vehicles but rather form the minimu m requirements for standards issued by
DOT. DOT has adopted the substance of the guidelines (with minor editorial differences) as
the accessibility stand ard s for transpor tation vehicles. The final DOT regu lation establishes
effective da tes for the accessibility stand ard and add ress when the stan dards are to be ap plied
to vehicles for whi ch a soli citation closes aft er October 6, 1991.
See 49 CFR 37.7. The manua ls
in this series will deal only with the requiremen ts for vehicles procured after this d ate.
Vehicles Covered
The Board's Vehicle Guidelines p rimar ily add ress new and rema nu factured vehicles
inst ead of existing vehicles sin ce the ADA does not necessar ily requir e veh icle retr ofit. Existing
buses, for example, are not required to be retrofitted to meet the standard s of Part 38 of the
DOT regulation . Even compliance with the "one-car -per -train rule" and the mobility aid seat ing
requirements for intercity rail cars can be met by the pu rchase of new vehicles. However, some
entities wh ich do not plan to pu rchase 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, th e Board has inclu ded p rovisions in t he a pp rop riat e gen eral s ections concer nin g
such r etrofitted vehicles.
The Vehicle Guidelines cover the design, manu facture 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 procedu res allowed und er the equivalent facilitation provision, discussed below,
the Board's statutor y manda te is to ensur e accessibilit y of th e built environment , includin g
instan ces in wh ich opera tional procedu res migh t fail. For examp le, the Board cannot assume
that the strength, agility and attention of a driver will be sufficient to prevent a heavy
wh eelchair from rolling off a lift. Thus, the Board h as included a requiremen t for lift platform
barriers. Neither is it app ropriate, as one transit operator su ggested, to assume th at fellow
pa ssen ger s will have th e str ength or skill t o assist persons with disabilities to boar d veh icles. It
is just as ina pp rop riat e to exp ect oth er p assen gers 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 horizon tal gaps for rail vehicles are specified.
Wheelchai r and Mobility Aid Standards
Neither the ADA, nor a ny oth er statu te, confers upon th e Board the au thor ity to set
stand ard s or min imum req uirements for wheelchairs an d mobility aids. The ADA does,
however, p rovid e a clear mandat e to the Boar d to set t he minimum req uirements for vehicles.
The Board ha s attempted to carry ou t this char ge in the fairest, most cost effective mann er
possible consistent with the stat ute.
Mi ni mum Requi rements
It should be n oted that these Vehicle Guidelines, and the DOT stand ard s based on th em,
are minimum requirements. Standard s or specifications which provide greater access are
permitted . In ad dit ion, t her e are sections which expr essly p ermit alternatives (e.g., rear -facing
securement). The word "may" is used wh ere alternatives are permitted and shou ld not be
constr ued as a req uirement. Also, a n a ppendix has been included in the gu idelines whi ch
contains non-ma nd atory, advisory guidance to assist in applying the rule. The ma terial from
that app endix has been generally incorporated into the d iscussion material in this document.
Periodic Revisions
The Board inten ds to condu ct period ic upd ates and r evision of the Vehicle Guid elines so
that future technologies and p ractices can be incor porat ed into them. As noted in th e following
dis cussions , the Boar d feels that add itional data and s tudy are n eeded in r egar d t o certa in
issues and it intend s to further revise and mod ify these guidelines based on its review of
collected d ata an d stu dy results. Also, some variations deter mined to p rovid e equivalent
facilitation may be explicitly incorporated in futu re up dates.
In addition, the Board plans to rev ise and up date these techn ical manu als as new
informati on or t echnology surfaces or as t he Vehi cle Gu idelines th emselves are ch anged . In
some places in these man uals, notation is made of drafting errors or sections where the
regu lation itself is unclear. Several non -substan tive ch anges in the regulation ma y be made in
the fut ure a nd these chan ges will be reflected in revised editions of these manu als.
How These Manuals are Organized
Each of these manu als deals with a sep arate tr ansp ortation mod e or vehicle type, based
on a p articular su bpa rt of the final regulation (e.g., subpart B - Buses, Vans an d Systems;
subpart C - Rapid Rail Vehicles and Systems; etc.). However , since su bpart A ap plies to all
vehicles, it is included at the beginning of each man ual. Each manual is self-contained so that
reference to other ma nu als is not necessar y. Where th e prov isions of the Vehicle Guidelines
refer to other mod es, or where the DOT regulation requires one type of vehicle to comp ly with
the requirements of another type, the relevant sections are rep eated.
The p ort ions of this document which appear in bold are the provisions as they appear
in the final Veh icle Gu idelines. The text immediat ely following is a d iscussion of the ra tiona le.
For pu rposes of this docu men t, the section nu mber s correspon d to t he provisions as they
appear in Title 36 of the Code of Federal Regulation s. The numbering system of DOT's
regulat ion follows th e same for mat with the exception of the prefi x nu mber (i.e., 1192.23(b)(6)
is substantively identical to 38.23(b)(6), etc.). Some of the provisions, particularly the
requ iremen ts for horizon tal gaps and vertical disp lacement between veh icles and p latforms,
must be read in conjunction with the st at ion design r equirements in 36 CFR Part 1191, wh ich
ar e included as Appendix A of the DOT regulat ion at 49 CFR Part 37.
Other Publications
The Access Board ha s also made available a checklist based on its ADA Accessibility
Guidelines (ADAAG) for Buildings and Facilities. ADAAG con tain s requir ement s for tr ansit
facilit ies, in cluding bus st ops an d ter minals, fixed facilit ies and stations , and air por ts. 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
vehi cles requi red to be accessi bl e by the Americans with Disabi li ties Act (ADA) of 1990,
42 U.S.C. 12101 et seq.
This section merely sets forth the pu rpose of the guidelines which is to establish the
minimu m requ irements for standards issued by DOT. Section 504 of the ADA requires the
Access Board to issue minimu m gu idelines and requirements for vehicles and facilities. In turn ,
DOT must issue standard s which are consistent with these guidelines. The DOT standard s
could be mor e st rict than the gu idelines but cou ld not provid e a lesser d egr ee of accessibility.
This format is similar to that und er 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
sta nd ar ds th emselves have been issu ed by DOT and ar e cod ified 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
technol ogies us ed wil l provide subs tantial ly equivalent or greater access to and usabil ity of
the vehicl e. Departures are to be cons idered on a case-by-cas e bas is 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 p rocedures und er which an entity
(e.g., transit agencies, providers, etc.) may pursue alternative means of providing accessibility
with resp ect to specific requiremen ts of the standard . The FTA or Federal Railroad
Administration (FRA) Administrator will det ermin e on a case-by-case basis wheth er equivalent
facilitation is p rovid ed. See 49 CFR 37.7 for the d etailed p rocedu res which must be followed as
part of an app lication to the Administrator for an equivalent facilitation determination. DOT
inten ds to consult with the Boar d in making d eterminat ions of equ ivalency.
The Board wishes to point ou t 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 on ly where th ey will provide substantially equivalent or
grea ter a ccess to, an d u sabilit y of, a vehicle. The Board encou rages that, when consid ering
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
provid e technical assistance regarding equivalent facilitation.
In developing an equivalent facilitation proposal, an entity should consider th e intent of
the gu ideline or st and ard requiremen t. For example, large bu ses are requ ired to h ave a
door wa y heigh t of 5'8" from the ra ised lift platform. This height, althou gh it accommoda tes
only about 70% of the adult male popu lation, is intended to provide some minimu m head
clearance for stand ees.
This clearance is especially imp ortant wh ere a standee wou ld be positioned outside the
vehi cle door when t he lift is down but is moved up and through the door as t he lift is raised .
Other mod els of lifts do not move the st and ee throu gh th e door , but th e individu al wou ld need
to p ass through the door aft er t he lift is raised . While it is not p racticable to p rovid e clearance
for the 90th percent ile st andee, it is desir able to provid e as much h ead room as p ossible, since
du cking to clear the door wa y ma y be more difficult for per sons with ambulat ory d isabilities
than for other member s of the general pop ulation . A greater h eight was not sp ecified becau se
information supp lied by vehicle manufacturers indicated that this height was consistent with
that need ed to a ccommod ate overh ead door open ing mechanisms and roof lines.
However, some lifts are designed such that th e 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 requ irement is being met by th e particular lift configuration,
provided the location of the han dr ails is such tha t the full inboard stand ing position is viable.
1192.3 De fi ni tions.
Accessible means, with res pect to vehi cles cove red by this part, compl iance with the
provi si ons of this part.
Aut omat ed gui dew ay t ransit (AGT) sys tem means a f ixed-gui deway transportation
system whi ch operates with automated (driverless) i ndividual vehi cles or mul ti-car trains.
Service may be on a fi xed schedul e or in response to a pass enger-activated cal l button. Such
systems using smal l, slow movi ng vehi cles, often operated i n ai rports and amusement
parks, are sometimes called "people movers".
Bus means any of several types of self -propel led vehicl es, other than an over-the-road
bus, generally rubber tired, intended for use on city streets, highways, and busways,
including but not l imited to minibuses, forty- and thirty-f oot transit buses, articulated bus es,
doubl e-de ck buses, and el ectric powered trol ley buses, us ed to provide de si gnated or
specif ied publ ic transportation services . Sel f-propel led, rubber tire vehi cles des igned to l ook
li ke anti que or vintage troll eys or street cars are consi dered buses.
Common wheelchairs and mobility aids means belonging to a class of three or four
wheel ed devices , usable indoors, des igned for and used by persons with mobil ity
impai rments 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 pas senger car obtained by a commuter authority (as
defi ned by 49 CFR 37.3) for use in commuter rail transportation.
Commuter rail transportat ion means short-haul rail passenger service operating in
metropol itan and suburban areas, operated by a commuter authority whether withi n 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 i nclude li ght or rapi d rail transportation.
Demand responsiv e sy st em means any system of transporting individuals, including
the provis ion of des ignated publi c transportation service by publ ic entitie s and the
provision of transportation service by private entities, including but not limited to specified
publi c transportation service , whi ch is not a f ixed route s ystem.
Designated public transportation means transportation provided by a publ ic entity
(other than publ ic school transportation) by bus, rail, or other conveyance (other than
transportation by aircraft or intercity or commuter rail transportation) that provi des the
general publ ic with general or spe cial service, includi ng charter servi ce, on a regular and
continuing basis.
Fixed rout e sy st em means a system of transporting indi vi duals (other than by
aircraft), including the provision of designated public transportation service by public
entitie s and the provis ion of transportation service by private entiti es, incl udi ng but not
li mi ted to specif ied publi c transportation service, on whi ch a ve hi cle is operated along a
prescribed route according to a fixed schedule.
High speed rail means an interci ty-type rai l service which operates primari ly on a
dedi cated gui deway or track not used, for the most part, by f reight, incl udi ng, but not
li mi ted to, trains on wel ded rail , magnetical ly levi tated (maglev) vehicl es on a speci al
guideway, or other advance d technol ogy vehicl es, desi gned 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 Rail road Pass enger Corporation (Amtrak) for use in intercity rail
Intercity rail transportation means transportation provided by Amtrak.
Light rail means a s treetcar-type vehicl e 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 vehicl e means a vehicl e which is offered for sal e or lease af ter manufacture
without any prior use.
Ov er-the-road bus means a vehi cle characterize d by an el evated passenger deck
located over a baggage compartment.
Rapid rail means a s ubway-type transi t vehicl e railway operated on excl usive private
rights-of-way with high-level platform stations. Rapid rail may also operate on elevated or
at-grade level track separated from other traff ic.
Remanufact ured v ehicl e means a vehi cle whi ch has been structurall y restored and has
had new or rebui lt major components instal led to extend its service li fe.
Specified public transportation means transportation by bus, rail, or any other
conveyance (other than aircraft) provided by a private entity to the general publ ic, with
general or spe cial service (includi ng charter servi ce) on a regular and conti nuing basi s.
Tram means any of several types of motor vehicl es cons isting of a tractor uni t, wi th or
without passenger accommodati ons, and one or more passenger trailer uni ts, i ncl uding but
not li mi ted to vehicl es providing shuttle service to remote parki ng areas, be tween hotels and
othe r publ ic accommodations, and between and withi n 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 r ule. This set of d efinitions, however , does not inclu de some ter ms which are in clud ed in
the DOT rule, primarily those which concern operational issues not add ressed by the
guidelines. Notice that the term "accessible" means compliance with the pr ovisions of the
guidelines (or the DOT standa rds in 49 CFR Part 38) wh ich includ es any determinations of
equivalent facilita tion.
1192.4 Misce ll aneous ins tructions.
(a) Dimensional conventions. Dimensions that are not noted as minimum or
maximum are absolute.
(b) Dimensi onal tolerances. Al l dimensi ons are subject to conventi onal
engi neering tolerances for material properties and f ield condi tions, includi ng normal
anti cipated wear not exceeding accepted i ndustry-wide standards and practices.
(c) Notes. The text of these guidelines does not contain notes or footnotes.
Addi tional information, expl anati ons, and advi sory materials are located in the Appendix.
(d) General terminology. The terms used in this part shall have the following
(1) Comply wit h means meet one or more specification of these guidelines.
(2) If, or if...t hen denotes a specification that applies only when the conditions
describe d are present.
(3) May denotes an option or alternative.
(4) Shall denotes a mandatory specif ication or requireme nt.
(5) Should denotes an advisory specification or recommendation and is used only in
the appendi x to thi s part.
Thi s sect ion contains sev era l provisions designed to r educe some con fusion whi ch
became evident in th e responses to the original prop osed regulation. It contains miscellaneous
instr uctions , incl uding d imension al conv entions and tol era nces, an d gen era l ter minology. An
app endix was also added to the final guidelines that contains additional information,
explanations, and a dvisory materials. That material is summarized in the discussion sections of
this document, where ap propriat e.
With respect to dimensional tolerances, certain materials expand or contract due to
variation s in tempera tur e or durin g the p rocess of "curing" or drying. As a result, even close
tolerances during construction or manu facture cann ot insure continu ed conforman ce to a given
standard . For example, a cable-driven historic inclined system has been modified to be
genera lly accessible. However, the cable is subject to un controllable stretching d urin g the d ay,
especially in hot weather. The cars generally provide level entry in the morning, but may be
significantly out of alignmen t by the end of the day. Such variation , even in a n ew system,
resu lting from ma teria l var iation s beyond t he con trol of the operat or would n ot be deemed in
violation of the guidelines. Furth ermore, u nlike buildin gs an d facilities which are essentially
stationa ry objects, vehicles move and h ave d ynamic as well as static "envelop es". Springs lose
their elasticity, steel rails and wh eels wear d own, and sup posedly "fixed" objects settle du e to
dynamic stress. The allowance for nor mal wear, however, is only to be ap plied in accor dance
with accep ted industr y st andar ds an d practices , not simply an agency policy. If the industry,
includ ing designers, engineers, manu facturers, operators, and recognized professional
ass ociations agree that a sp ecific adheren ce can be achi eved above th at allowed by an agency
policy or practice, it is the industry standard which is to be applied, not the agency policy.
Reliance on dimensiona l tolerances, however, is not an excuse for improper or d eferred
mainten ance, or poor design or construction method s. For example, the claim of "dimensional
tolerances" could not be mad e for a lift wh ich fails to meet the vehicle floor within the limits
specified in these gu idelines, simply becau se an adjustment which could have been reas onably
mad e 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 manu facturer which d id not meet
the op erator's bid specification. Nor could a grou p of manu facturers, operators or design ers,
for example, simply get t oget her to ad opt a lower "stan da rd " solely for th e pu rpose of r elaxing
compliance. Such a change would need to be acknowledged by a significant segment of the
indu stry to constitute an "accepted indu stry stand ard or p ractice." Moreover, dimensional
tol era nces ap ply t o th e con str uction, manufact ure or opera tion of a system, not to the design.
An entity cannot issue vehicle specifications which are less stringent than those required by the
guid elines; nor could it justify a wider h orizont al gap as being within d imensional toleran ces
because it did not specify its vehicles to be within achievable limits for sway or stability.
Subpart D -- Light Rail Vehicles and Systems
1192.71 General.
(a) New, used and remanuf actured li ght rail vehicl es, to be consi dered 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 vehicles that are
pu rchased or leased after August 25, 1990, to be accessible. A pu blic entity may p urchase or
lease a used light rail vehicle 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
access ible vehicle, it is un able to do so. See 49 CFR 37.87(c) for a descr iption of wha t
const itutes good faith efforts. Vehicles that are rema nu factured after this date t o exten d t heir
usable life for 5 years or more are also required to be accessible, to the extent it does not
compromise the structural integrity of the vehicle. On October 4, 1990, the U.S. Department of
Trans por tation (DOT) issued an inter im set of requ irements for su ch vehicles.
The guid elines dis cussed in th is technical assistance d ocument are s ubstan tively
identical to standard s issued by DOT on September 6, 1991, at 49 CFR Part 38 and replace the
int erim rules. The DOT rule at 49 CFR Par t 37 furt her outlines the applicability an d effective
dates of these requ iremen ts. Questions as to wheth er certain vehicles are subject to these
sta nd ar ds an d specific effective dat es sh ould be d irected to DOT.
(b)(1) Vehicl es intended to be operated solely in light rail systems confined enti rely
to a dedi cated right-of -way, and for whi ch all stations or stops are desi gned and constructed
for revenue service af ter the eff ective date of standards for desi gn and construction issued
pursuant to s ubpart C of 49 CFR Part 37, shal l provide l evel boardi ng and s hall comply with
1192.73(d)(1) and 1192.85.
This provision requ ires that n ewly d esigned and constru cted light r ail systems
operating on d edicated rights-of-way provid e level boarding. Level boarding p rovides the
most accessibility for the maximum number of people and is operationally superior to
deploying board ing d evices such a s lift s, ra mps, or br idge p lat es. It can signi fican tly red uce
station d well times required for p assenger board ing an d aligh ting. In new constru ction, level
boarding can be achieved in some cases wh en grading th e site by piling the dirt fill next to the
track and p lacing a concrete slab on top to coordinate with the level of the train floor. In oth er
cases, it may be necessary to constr uct a high-level platform. The vehicles of such systems mu st
be coordinated with the boa rding platform as specified by section 1192.73(d)(1) and equipped
with between-car barriers that prevent or warn persons from accidently stepping off the
plat for m bet ween car s accord ing t o section 1192.85.
It is importa nt that op erators review subp art C of DOT's rule for the effective date of
standard s for design and construction of transit facilities, including light rail stations. In its
rule, DOT explains that the requirement that new facilities be accessible "is keyed to
constru ction which 'begins' after January 25, 1992. The regu lation d efines 'begin' to mean when
a notice to proceed has been issued. This term ha s a standard meaning in the construction
indu stry as an instruction to the contractor to proceed with the work." Thus, regardless of the
design wor k which preceded it, the issuan ce of a notice to proceed with constru ction on or after
January 26, 1992, trigger s the requir ement s for new stat ions . See also 49 CFR Part 37, Ap pend ix
(2) Vehi cles des igned for, and operated on, pe destrian mall s, city streets , or other
areas where level boarding is not practicable shall provide wayside or car-borne lifts, mini-
hi gh platf orms, or other means of acces s i n compl iance with 1192.83(b) or (c).
This provision takes into account th at level boarding is not easily provided at stops
along city streets or on ped estrian malls. Often, there is no space at such sites for platforms for
level board ing. The "other areas where level boa rding is not pra cticable" wou ld includ e any
other st op location s lacking space for p latfor ms . It is imp ort ant in t he d evelopment of light rail
systems that consideration be given to the selection of stop locations. A new system that
operated on both a ded icated right-of-way and p edestrian malls or city streets would not be
requir ed to provide level boar din g accor din g to p ara graph (b)(1) since that p rovision per tain s
to systems "confined entirely to a d edicated right-of-way." However, the Board recommend s
that, in such systems, level boarding be prov ided at a ll stops where it is feasible to do so.
(c) If portions of the vehi cle are modi fi ed in a way that aff ects or coul d af fect
accessi bi li ty, each such portion shall compl y, to the extent practicabl e, with the appli cabl e
provisions of this subpart. This provision does not require that inaccessible vehicles 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 mad e for any
reason, the opp ortunity must be exp lored to prov ide the maximum access feasible. When a
vehicle is modified, each element that is part of the mod ification should be brought into
compliance with th e applicable sections of these requirements. For examp le, if a vehicle'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 alarms would also be required as part
of the modification pr oject. The int ent of this pr ovision is t o ensure th at element s of a vehicle
will be made accessible when the opportu nit y to d o so exist s in t he r egu lar cou rse of modifying
or up grading vehicles. However, those elements of the vehicle not affected by th e mod ification
plan wou ld not have to be brought into conformance with these requirements. Under any
mod ification plan, the installation of a lift, ramp , bridge plate or other board ing device is not
requ ired, even if the entra nce of a vehicle is mod ified.
(d) Existi ng vehicl es retrofitted to comply with the "one-car-per-trai n rule" at 49 CFR
37.93 shall comply with 1192.75, 1192.77(c), 1192.79(a) and 1192.83(a) and shall have, in new
and key stations, at least one door whi ch compli es with 1192.73(a)(1), (b) and (d). Vehicl es
previ ousl y de si gned and manuf actured i n accordance with the acces si bi li ty requireme nts of
49 CFR Part 609 or Department of Transportation regulations implementing section 504 of
the Rehabi li tation Act of 1973 that were i n eff ect bef ore October 7, 1991 and whi ch can be
entered and us ed from s tations i n whi ch they are to be operated, may be use d to s atisf y 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 op erat ors will choos e to make existing cars accessible in ord er to meet th is
requirement. In such situations, this provision requires only that vehicles conform to the
Pr ior ity seating si gns an d signs designa ting wheelchair / mobility aid locations (if such
locations are provid ed)
Clear floor space (so that a route 32 inches wide leading to an area that can
accommodate two wh eelchair spaces each 30 by 48 inches in size is provid ed)
Slip resistan t floor surfaces
Board ing d evices (lift, ramp or brid ge plate) where level entry is not prov ided
One accessible door that in new and key stations:
- provides 32 inches of clear width ;
- is designat ed by th e In tern at ional Symbol of Accessibili ty; an d
- is coord inated with the p latform so th at the horizon tal gap does n ot exceed 4
inches and the veh icle floor is within plu s or minu s 2 inches of the platform
height when th e vehicle is loaded to 50% of its capacity
Existing vehicles that meet previous accessibility standard s can also be used to meet the
"one-car-per-train" rule without an y retrofit, provided they can be entered an d u sed from the
stations or stops at wh ich they ar e to be used . Specifically, these stan dards include those issued
by the FTA, vehicles obtained with FTA funds, and those issued by DOT un der Section 504 of
the Rehabilitation Act of 1973, which cover tr ansit systems receiving Feder al fund s. Further
infor mat ion on these stand ar ds can be obt ain ed from DOT.
1192.73 Doorways.
(a) Clear width. (1) All passenger doorways on vehicle sides shall have minimum
clear openings of 32 inches when open.
This provision for a clear opening width of 32 inches has been in effect since 1976 for
FTA-funded v ehicles a nd should be met eas ily. The d oor widt h sp ecified is n ot d esign ed solely
to accommoda te wheelchair users. Rather, the dimension is designed to pr ovide space for
crutch-tip-to-crutch-tip d istance of a typical crut ch user . Also, the requiremen t is for a "clear
opening." The provision of a wide d oorway with a vertical stanchion in the center d oes not
meet the requirement.
(2) If doorways connecti ng adjoining cars i n a mul ti-car train are provided, and i f
such doorway is connected by an aisl e with a minimum clear width of 30 inches to one or
more spaces where wheel chai r or mobil ity aid users can be accommodated, then such
doorway shal l have a mi ni mum cl ear opening of 30 i nches to permi t wheel chai r and
mobi li ty ai d users to be evacuated to an adjoining vehicl e i n an emergency.
This requirement applies only to new vehicles equipped with end doors that can be
rea ched by a wheelchair or mobility aid user . This mean s th at where t here i s a r oute at lea st 30
inches wide lead ing from the ar ea containing accessible spaces to the en d d oor, then the end
doors mu st provide a minimum of 30 inches clear width . Since the clear area in which mobility
aid u sers can position themselves is usually located at the en ds of cars, the en d d oors will most
likely be in close proximity to accessible spaces. This requ iremen t does n ot apply to vehicles
that are 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 asp ect (e.g., steps). However, this provision should not
be viewed as a n excuse t o ar bit rarily place stanch ions or ar range sea ts t o precl ude a 30-in ch
wid e passa ge to avoid having to sp ecify 30-inch wide end door s.
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 t ran sit sys tem's eva cuation plan. In addit ion, a transit
syst em's eva cuation plan t hat requir es the us e of side doors would n ot be pr eclud ed by th is
provision. Furth er, the evacu ation route lead ing from the tra in itself is often ina ccessible,
especially in the case of rapid rail where narrow walkways, catwalks, and escape ladders are
pa rt of ev acuation rou tes from t un nels. Non etheless, the end d oors of new vehicles can easily
be designed to be functionally accessible (i.e., have 30 inches of clear width) and should be
accessible in case they may ser ve as a n a ccessible mean s of egr ess. In li mited emergencies, such
as when t he sid e door s of a car fail, accessible end door s would be t he only mean s of exit.
Ad dit iona lly, the Board recognizes that th is pr ovision d oes not gu ara nt ee access in to ad joining
cars sin ce existing cars ma y not have end doors with 30 inches of clear widt h. However , as old
cars are replaced over time and the number of accessible cars on each train increases, the
cha nces of p rovid ing an a ccessible connection between car s will be gr eat er.
Existing cars or cars r etrofitted un der th e "one-car -per -train " rule are not su bject to th is
req uirement.
(b) Signage. The International Symbol of Accessibility shall be displayed on the
exterior of each vehicl e operating on an accessible light rail system unless al l vehicl es are
accessi bl e and are not marked by the access symbol . (See Fig. 6)
Under this requirement, all new vehicles must be
designated by the International Symbol of Accessibility
(access symbol) shown in Figure 6 below. Howev er,
new veh icles a cqu ired for a light rail system in whi ch
all vehicles are accessible and which are n ot design ated
by t he symbol d o not have to be designated . In fully
accessible s ystems , consist ency is imp ort ant, so th at if
existing accessible vehicles are designa ted, new
vehicles 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 a ll car s ar e accessible. Since
cars are u sually d esign ated by d ecals, which even tually
wear and must be replaced, operators may opt to
simply not r eplace them.
The p lacement of the access symbol is not specified by these gu idelines. It is
recommend ed that th e symbol be placed a t each accessible p assen ger d oor of an a ccessible
veh icle. However , if the clear floor area for wheelchair or mobility aid users is p rovided a t only
one end of a ca r, t hen onl y t hose p ass enger door s at that location s hould be d esigna ted .
(c) Signals. Auditory and visual warning signal s shal l be provided to al ert
passengers of cl osing doors.
Audible signals ar e requir ed by exist ing FTA regu lation s, in effect sin ce 1976. Audible
signals usually activate before the doors begin to close and th us provide advan ce warning that
the door s are about to close. Without visua l signals, persons with hearing impairments are not
afford ed any equivalent ad van ce wa rning and can on ly detect closin gs as the doors actually
begin to close. According to information received du ring th e development of these guid elines,
the ad dition of aud ible and visual warning signals for automat ically-operated door s of new
vehicles is feasible and r epresen ts only a modest cost increase for a chime, light, an d associated
electrical con trols at ea ch d oorway. These sign als ar e not requir ed to be pr ovid ed on existing
vehicles or those that are retrofitted. Since proposed requirements for door closing force and
speed hav e been removed, the Board considers the provision of audible and visual indicators to
be of even grea ter impor tance.
The term "passengers" means persons within the transit system including those who are
on the train and those waiting to board. Therefore, warning signals should be visible from both
inside a nd outsid e the veh icle. This can be achieved by equ ipping the entra nces of new
veh icles with both an interior and exterior ligh t ind icator . Also, it is conceivable that a single
light ind icator , by eith er its illu min ation level, d esign , or placement ma y be specified so that it
is visible bot h inside and out side the veh icle. Either method of addr essing this requir ement is
acceptable so long as it provides a visual warning that doors are about to close. Further, visual
indicators should be synchronized with au dible signals so that equivalent ad vance notification
of door closure is prov ided to all person s, including those with hea ring or visual impairments.
(d) Coordination with boarding platform. - (1) Requirements. The design of level-
entry vehicl es shal l be coordinated with the boarding platform or mini-high platform design
so that the horizontal gap between a vehicl e at rest and the pl atform shall be no greater than
3 inches and the he ight of the vehicl e f loor shal l be withi n pl us or minus 5/8 inch of the
platform height. Verti cal al ignment may be accomplished by vehicl e ai r suspension,
automatic ramps or lif ts, or any combination.
This provision and the exceptions that follow outline the maximum horizontal gap and
vertical tolerance allowed. However, vehicles should be sp ecified to be level with the platform
edge and as close to it horizontally as possible, so that un der normal passen ger cond itions these
maximu m levels are not exceeded . These tolerances, even when sp ecified in the acquisition of
new veh icles, may not be ach ieved und er a ll conditions throughout th e vehi cle lifetime. The
requirements are based on normal passenger conditions. It is incumben t on the op erator not
only to sp ecify the correct floor height when ordering vehicles (and to accept them only if they
meet the sp ecification) but also t o cor rect ly specify the ra il-to-plat for m heigh t for new stations .
Thus, it is important to keep in mind that the horizontal gap and vertical tolerance are
dep endent not only on the vehicle specifications but also the d esign and construction of station
platforms. Those requirements, including gap requirements and the rail-to-platform height, are
provid ed at 49 CFR Part 37, Appendix A.
In those instances where a n ew light rail system could n ot meet these gap requirements,
the op erator would be able to pursu e alterna tive mea ns of red ucing gaps u nd er the p rocedu re
for equivalent facilitation contain ed in DOT's rule (see 49 CFR 37.7). Also, the Board recognizes
that close tol era nces durin g con str uction or manufact ure ca nn ot i ns ure cont inued confor mance
to a given standard . Variations, such as those resulting from normal wear or material
variations wou ld not be d eemed violations of the guidelines. However, only those variations
within the limits of accepted indu stry practices or tolerances are allowed. (See Subp art A at the
beginning of this manual for further discussion of dimensional tolerances.) Adequate
main tenan ce must be per formed to ensu re the vehicles remain with in acceptable tolerances.
(2) Exception. New vehicl es operating in exi sti ng stati ons may have a f loor height
within pl us or mi nus 1-1/2 i nches of the pl atform height. At key stations, the horizontal gap
between at l east one door of each such vehi cle and the pl atform shall be no greater than 3
The ability to closely align new vehicles with existing station platforms is limited by the
rail-to-platform height and t he vertical distan ce between the tra ck and t he p latfor m. Existin g
stat ions are n ot required to be alter ed un der th e ADA, unless th ey ar e a "key" stat ion. This
provision allows new vehicles serving existing stations, includ ing key sta tions, a great er
vert ical t oler ance sin ce th e existing plat for m heigh t may make th e 5/ 8 inch tol era nce infeas ible.
Nevertheless, the goal is for the vehicle floor and platform to be at th e same h eight. The great er
allowance und er t hi s provision is not a n excuse t o creat e unn ecessar y bar riers.
A consistent horizontal gap along all vehicles of a train may not be feasible due to the
design of existing stations, such as those that h ave curved platforms. (This, however, is more
pertinent to commu ter and rapid rail stations). In view of this, the three-inch horizontal gap
requir ement has been limit ed only to key sta tions, wh ich ar e requir ed to be ma de accessible
un der the ADA, and does n ot apply to ot her existing sta tions. Furth er, only one door of a new
vehi cle is r equired to meet the 3 inch gap req uirement sin ce, in the case of cu rved stations , a
uniform gap cannot be achieved along the entire side a vehicle. A transit system could, as one
transit operator h as suggested, designate on e location wh ere such tolerances are achieved along
a port ion of a cur ved stat ion p latfor m. New vehicles could be or dered with a sligh t sill
protrusion to red uce the h orizont al gap in stations wh ere a wider ga p cur rently exists.
(3) Exception. Retrofitted vehicles shall be coordinated with the platform in new and
key stati ons such that the horizontal gap shall be no greater than 4 inches and the he ight of
the vehicl e f loor, under 50% pass enger load, shall be withi n pl us or minus 2 inches of the
pl atform hei ght.
Thi s exception p ert ain s to exist ing vehicles t ha t are mad e accessible und er t he "one-car -
per-train" rule. Generally, existing vehicles cannot be coordinated with the platform to the
degree that new vehicles can. Even if feasible, retrofitting existing vehicles to meet the
requ iremen ts for new vehicles, could be ver y expensive. Consequ ently, this exception allows a
greater and mor e easily achievable horizont al gap and vertical tolerance. These vehicles need
to be aligned with the p latform at new stations or key stations so that the horizont al 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 ind epen den tly negot iable by many wh eelchair user s, such veh icles
will eventually be p ha sed out as new veh icles a re a dded to t he sys tem.
NEW VEHICLES 3" horizontal gap
5/ 8" ver tical toler ance
3" horizontal gap (1 door)
1-1/ 2" vertical tolerance*
4" horizontal gap
2" ver tical toler ance
4" horizontal gap (1 door)
2" ver tical toler ance
* Also app lies to new vehicles opera ting at existing stations, not only key stations.
(4) Exception. Where i t is not operationall y or structurall y practicabl e to meet the
horizontal or verti cal requirements of paragraphs (d)(1), (2) or (3) of this section, platform or
vehicl e devices complying with 1192.83(b) or platform or vehicl e mounted ramps or bridge
plates complying with 1192.83(c) shal l be provided.
This exception acknowledges that, in many systems, high platforms are n ot
oper ationally feasible and p ertains to those systems that a re not r equired to p rovid ed level
board ing. Such systems are requ ired to p rovid e access from low p latforms with car-born e,
platform-mounted, or portable lifts in accordance with the specifications for lifts. Access may
also be provided by ramps or bridge plates meeting the applicable requirements. Such ramp s
or brid ge plates may be au toma tically or man ually d eployed .
1192.75 Priority s eati ng si gns.
(a) Each ve hi cle s hall contai n si gn(s) whi ch indi cate that certain seats are priority
seats for persons with disabil iti es, and that other passengers should make such seats
available to those who wish to use them.
The content of signs is not specified by this requirement an d is left up to the d iscretion
of transit op erators. At a minimum, the sign should indicate which seats are int end ed for u se
by persons with d isabilities.
(b) Where designated wheel chai r or mobil ity aid seating l ocati ons are provided, si gns
shall indi cate the l ocati on and advise other passengers of the need to permi t wheel chai r and
mobility aid users to occupy them.
This requirement p ertains to vehicles that provide specific locations for wheelchair or
mobility aid users. Sometimes, these areas are accessed by folding up a regular seat. Operators
shou ld take into accoun t how one accesses and uses su ch locations in d etermining th e content
of signs. This provision is not inten ded to suggest tha t specified areas or "bays" be provid ed.
(c) Characters on signs required by paragraphs (a) or (b) of this section shall have a
width-to-height ratio between 3:5 and 1:1 and a stroke width-to-height ratio between 1:5 and
1:10, wi th a mi ni mum character hei ght (usi ng an upper case "X") of 5/8 i nch, with "wide"
spacing (generally, the s pace between le tters shall be 1/16 the he ight of upper case l etters),
and s hall contrast with the background, ei ther li ght-on-dark or dark-on-l ight.
These requir ement s for th e character height an d p rop ort ion a re ba sed on existing
Federa l requ irements for building and facilit y si gnage, au gmented by the results of res ear ch
sponsored by the Board. Contrast can be provided either with light characters on a dark
backgrou nd or dark cha racters on a light background . However, light-colored cha racters
against a dark backgrou nd are p refer red since st ud ies ha ve sh own t hat this typ e of cont rast is
mor e readable for persons with low vision. A min imum level or p ercentage of contrast
between char acters and the background of the sign is not specified. Research, however,
indicates that signs are more legible for persons with low vision when characters contrast with
their background by at least 70 percent. Contrast in percent is determined by:
Con tra st = [(B
- B
)/ B
] x 100
wh ere B
= light reflectance value (LRV) of the light er area
and B
= light reflectance value (LRV) of the d arker a rea.
Not e t ha t in an y applica tion b ot h w hi te an d bla ck a re ne ver absolu te;
thus , B
never equal s 100 and B
is always gr eat er than 0.
Although not required, it is also recommended tha t the characters and background of
signs should be eggshell, matte, or other non-glare finish. An eggshell finish (11 to 19 degree
gloss on 60 d egr ee gloss imeter) is preferr ed.
1192.77 Interior circulati on, handrails and stanchi ons.
(a) Handrai ls and stanchions shal l be suffici ent to permit saf e boarding, on-board
circulation, seating and standing assistance, and alighting by persons with disabilities.
This provision is written as a general performance requirement in order to allow as
man y opt ions as p ossible in the d esign of accessible vehicles. Hand rails and stanchions must
be placed near t he d oors and alon g the p ath of entrance into the vehicle for those usin g crutches
or walkers, among others. However, they should not interfere or restrict the necessary
clearance at doors or along an accessible route leading to accessible spaces as required by the
following p rovision.
(b) At entrances equipped with steps, handrai ls and stanchions shal l be provided in
the e ntrance to the vehicl e i n a confi guration whi ch all ows pas sengers to grasp such ass ists
from outsi de the vehi cle whi le starting to board, and to continue using such handrail s or
stanchions throughout the boardi ng proces s. Handrails shal l have a cross -secti onal di ameter
between 1-1/4 i nches and 1-1/2 inches or shal l provi de an equivalent graspi ng surface, and
have ease d edges with corner radii of not l ess than 1/8 inch. Handrails s hall be placed to
provide a minimum 1-1/2 i nches knuckle cl earance from the nearest adjacent surface. Where
on-board f are coll ection de vi ces are used, a horizontal pas senger assi st shall be l ocated
between boarding passengers and the fare collection device and shal l prevent passengers
from sustai ni ng injuries on the f are col lection device or windshi el d i n the event of a sudden
deceleration. Without restri cting the vesti bule space, the assist shal l provide support f or a
boarding passenger from the door through the boarding procedure. Pass engers shall be abl e
to lean agai nst the assist f or security while paying fares.
Stepped entran ces are required to be equipped with hand rails and stanchions that can
be r each ed by the pass enger from the ou tsid e befor e act ually stepping into t he veh icle. Such
hand rails and stanchions must be placed so that passengers can use them at all stages of the
boar ding pat hway. This par t of t he req uirement is d eri ved from 49 CFR Part 609, in effect since
1976. This would in clud e a horizontal r ail in fr ont of an y fare collection device, which not only
provides support while paying fares but can help prevent someone from falling against the fare
box or wind shield du ring a sud den stop.
Most car handr ails ar e made of pipe. In the buildin g indu stry, pip e size t ypically
specifies insid e diameter so that a 1-1/ 2 inch p ipe h andr ail actu ally has a la rger outsid e
diameter, sometimes up to 2 inches. Such h and rails have not p osed a ny kn own problem. Thus,
the 1-1/ 2 inch diameter requ iremen t can resu lt in a ha nd rail of app roximately 2 inches u nd er
curr ent building industr y practices .
(c) At al l doors on level-entry vehicl es, and at e ach entrance accessi bl e by l if t, ramp,
bridge plate or other suitable means, handrai ls, stanchions, passenger seats, vehicl e driver
seat pl atforms, and f are boxes, if appli cabl e, shal l be l ocated so as to al low a route at l east 32
inches wide so that at least two wheel chai r or mobil ity aid users can enter the vehi cle and
posi tion the wheel chai rs or mobi li ty ai ds in areas, each having a minimum clear space of 48
inches by 30 i nche s, whi ch do not unduly restrict movement of othe r passengers. Space to
accommodate wheelchairs and mobility aids may be provided within the normal area used
by standees and desi gnation of specif ic spaces i s not requi red. Particul ar attenti on shall be
gi ven to ensuring maxi mum maneuverabi li ty i mmediately insi de doors. Ample vertical
stanchi ons f rom ceil ing to seat-back rails shall be provided. Vertical stanchions from cei li ng
to fl oor shall not i nterfe re wi th wheel chair or mobi li ty aid circulati on and s hall be kept to a
mi ni mum i n the vici ni ty of accessible doors.
Des ign at ing accessible spaces for wheelchair or mobility aid user s is n ot r equired.
During the development of these guidelines, it was apparent that some transit operators
ass umed that "bays" or "bert hs " would ha ve to be provid ed in order t o meet this requirement.
Such accommod ations are not required or recommended. All that must be provided is enough
clear floor space so that two wheelchair or mobility aid users can board a nd position
themselves on t he veh icle. The 30 by 48 inch dimension is ba sed on the st andar d space
allowance for a person in a wh eelchair. The clear floor area where persons with disabilities can
position themselves must be connected to the doors by a route with at least 32 inches of clear
width . The clear floor space that is typically provided for standees is usually large enough to
meet this requirement.
Hand rails or stanchions must be placed so that the required clear floor spaces and
routes are not obstru cted. It is also recommen ded , but not requ ired, that consideration be given
to th e pr oximity of handr ails or stan chion s to th e area in which wheelchair or mobility aid
users may position themselves. When id entifying the clear floor space where a wheelchair or
mobility aid user can be accommod ated, it is suggested that at least one su ch area be a djacent
to, or in close proximity to a hand rail or stanchion. Of course, such a han drail or stanchion
cann ot en croach up on the requir ed 32 inch widt h r equ ired for th e doorway or th e rou te lead ing
to the clear floor space which mu st be at least 30 by 48 inches in size. This recommendation
should not be interpreted as a requirement that the area where wheelchair or mobility aid users
can position themselves be designated at a specific location. It is importan t that wheelchair and
mobility aid u sers have as many options as possible in positioning themselves in view of the
crowding t ha t can t ake place and the limited time al lowed to ent er or exi t th e vehi cle.
There i s no requirement for secu rement systems or tie-d own d evices. Prev iou s research
conducted for DOT and comments received du ring th e development of these guid elines
indicate that such d evices are not need ed on light rail vehicles because of the low acceleration
and deceleration forces.
1192.79 Floors, steps and thresholds.
(a) Floor surfaces on aisles, step treads, places for standees, and areas where
wheel chai r and mobil ity aid users are to be accommodated shall be sl ip-resi stant.
A sp ecific meas ur e, or st atic coefficient of friction, has not been specified for slip-
res ista nce. Slip r esistance is ba sed on the fri ctiona l for ce necessar y t o keep a sh oe h eel or cr utch
tip from slip ping on a walking su rface und er cond itions likely t o be found on the su rface.
While the dyn amic coefficient of friction during walking varies in a complex and n on-uniform
wa y, the static coefficient of friction, wh ich can be measur ed in several ways, prov ides a close
appr oximation of the slip resist ance of a surface. Con trary t o common belief, some slippa ge is
necessar y for walking, especially for p ers ons with res tr icted gaits. A tr uly "non-slip " sur face
could not be negotiated .
The Occupational Safety and Hea lth Ad ministration r ecommend s that walking su rfaces
have a static coefficient of friction of 0.5. A research project sponsored by the Board conducted
tests with persons with d isabilities and concluded that a higher coefficient of friction was
need ed by such p ersons. A stat ic coefficient of friction of 0.6 is recommen ded for steps, floors,
and lift p lat for ms an d 0.8 for r amps.
The coefficient of friction va ries consider ably due to th e presen ce of contaminants,
water, floor finishes, and other factors not under the control of transit providers and may be
difficult to measu re. Nevertheless, many common materials suitable for flooring are now
labeled with information on the static coefficient of friction. While it may not be possible to
compa re on e pr oduct d irectly with another, or to gu ara nt ee a con stan t measu re, tr ansit
operators or vehicle designers and manufacturers are encouraged to specify materials with
app ropriate valu es. As more p roducts includ e information on slip resistance, imp roved
un iformity in measur emen t and specification is likely to develop. The Board h as pu blished a
brochure, "Slip Resistant Surfaces," available at no cost, wh ich provides ad ditional information
and adv isory guidelines on slip resistant sur faces.
A va riety of common mater ials used on t ran sit vehicle floor s can pr ovid e ad equ ate slip
resistance. Common rubberized matting ma y be slip resistant depend ing on the orientation of
the grooves. Carpet is more variable depend ing on pile and weave and should probably be
tested before it is specified.
(b) Al l thres holds and step edges shal l have a band of color(s) runni ng the f ul l width
of the s tep or threshold whi ch contrasts from the s tep tread and ris er or adjacent f loor, either
li ght-on-dark or dark-on-l ight.
The band of contrasting color required by this provision must span the full width of the
threshold and steps along the nosing. However, a minimum width for the ban d itself is not
specified. The Board recommen ds a minimum of three inches, although the actual size is left to
the d iscretion of operators. Althou gh a minimu m level of contra st for this ban d is not specified,
it is recommend ed that th e following formula be used in d eter min ing the cont rast level:
Con tra st = [(B
- B
)/ B
] x 100
wh ere B
= light reflectance value (LRV) of the light er area
and B
= light reflectance value (LRV) of the d arker a rea.
Not e t ha t in an y applica tion b ot h w hi te an d bla ck a re ne ver absolu te;
thus , B
never equal s 100 and B
is always gr eat er than 0.
1192.81 Lighti ng.
(a) Any stepwel l or doorway with a l if t, ramp or bridge pl ate immedi ately adjacent to
the driver shal l have, when the door is open, at l east 2 footcandles of illumination measured
on the step tread or lift platform.
This requirement is based on existing FTA requirements for light rail vehicles and
pert ain s on ly t o th e inter ior ligh ting provid ed at entr ances eq uipped with boa rd ing d evices.
The r equ irement only per tain s to op en d oors so that th e light will not reflect off th e wind shield
wh ile the vehicle is moving. The measurement pertains to all step treads of the entrance or to
the lift platform at floor level. While a maximum lighting level is not specified, high levels may
increase t he t ime necessary for th e vision of exiting passen gers to ad just to a darker, nighttime
environmen t.
(b) Other stepwel ls, and doorways with li fts, ramps or bridge plates, shal l have, at all
times, at least 2 f ootcandles of i ll umination measured on the step tread or li ft or ramp, when
depl oyed at the vehi cle fl oor level .
This p rovision requir es the same level of light ing in ot her doorways with board ing
devices and stepwells of the vehicle. Since such stepwell lighting would n ot interfere with the
oper ator's visibility, the minimu m level is requ ired at all times.
(c) The doorways of vehicles not operating at lighted station platforms shall have
outside lights which provide at least 1 footcandle of illumination on the stati on platform or
street surface f or a dis tance of 3 feet perpendicular to al l poi nts on the bottom step tread.
Such lights shal l be located below window level and shielded to protect the eyes of entering
and exiting passengers.
Thi s provision is al so based on an exist ing FTA
requirements and specifies that the 3 foot distance is to be
measu red per pend icular ly from the step trea d, as shown in
the figure. The meaning of "3 feet p erp end icular to all
points on th e bottom step tr ead outer edge" is to define a
rectangle on the groun d out side the veh icle door which is
three feet d eep an d as wide as th e door lower st ep. In most
cases, the actual area illuminated will be a semi-circular
pat tern. Such a p attern wou ld meet the above requ iremen t
as long as t he specified rectan gle wer e illuminated.
This requirement pertains only to vehicles that serve
un lighted stat ions . While t hes e guidelines p erta in on ly to vehicles, n ot st ation s, it is
recommended th at stations be lighted to serve both those passengers waiting at stations and
those passengers entering or exiting vehicles. If stations are lighted, vehicle doorways do not
have to be illuminated .
1192.83 Mobil ity aid accessi bi li ty.
(a)(1) General. All new light rail vehicl es, other than level entry vehicl es, covered by
thi s subpart shall provide a l evel -change mechanism or boarding device (e.g., li ft, ramp or
bridge pl ate) complying with ei ther paragraph (b) or (c) of thi s secti on and suff ici ent
clearances to permit at l east two wheel chair or mobi li ty aid use rs to reach areas, each with a
mi ni mum cl ear fl oor space of 48 inches by 30 i nches, whi ch do not undul y restrict passenger
fl ow. Space to accommodate wheel chairs and mobil ity aids may be provided withi n the
normal area used by standees and designation of speci fic spaces is not required.
This requirement for board ing devices applies only to light rail systems tha t do not
pr ovid e level boar din g. This would a pp ly to t he vehicles of new systems wher e level boar din g
is provided at some but n ot all stops. The clearances required for access to seating locations
wou ld include those for doorways (section 1192.73) and for interior circulation (section
(2) Exception. If lifts, ramps or bridge plates meeting the requirements of this section
are provided on station platforms or other stops, or mini-high platforms complying with
1192.73(d) are provided, at stations or stops required to be accessible by 49 CFR Part 37, the
vehi cle is not required to be equipped with a car-borne device. Where each new vehi cle is
compatible with a s ingl e pl atform-mounted access sys tem or device, addi tional s ystems or
devi ces are not required f or each vehicl e provided that the si ngle device coul d be use d to
provide access to each new vehi cle if passengers usi ng wheel chai rs or mobi li ty ai ds could
not be accommodated on a single vehicle.
New, non-l evel en tr y cars a re n ot r equired to be equipped with boa rd ing d evices if such
devices ar e pr ovid ed at st ation platforms or mini-high platforms are pr ovid ed. To meet this
exception, boarding devices or mini-high platforms would h ave to be provid ed at all stations
and stops required to be accessible. However, transit opera tors should consider wh ich option
(boarding d evices on cars or at st ations) offers the most accessibility in d etermining th eir course
of action.
The Board received s ome comment s from operat ors of light rail systems who cur rently
use platform-moun ted (wayside) lifts or mini-high platforms with which the operator aligns
one d oor of the vehicle. The op erators su ggested that the second vehicle shou ld not be requ ired
to be accessible so that a second lift or mini-high platform would not be need ed to serve the
second vehicle in the train. The ADA, however, is explicit that, except for specific provisions
for intercity rail car s, all new vehicles mu st be a ccessible. Ther efore, th e final guidelines r equ ire
that every new vehicle be able to be entered and used an d accommod ate at least two
wh eelchair or mobility aid users. The current requiremen t does not requ ire the provision of
add itional lifts or platforms at a station if other vehicles of the train which are required to be
acces sible are compat ible with, and can be serv ed by, the lift or plat for m if posit ioned properl y.
In practical terms, the dr iver would a lign the door of the first car with the lift or mini-
high platform and allow all passengers using wh eelchairs or mobility aids to board. If all the
waiting passengers wh o need the lift or platform can be accommodated on the first car, the
train would n ot need to move t o allow board ing of the second car. The t ran sit agency should ,
therefore, carefully assess th e interior layou t of its cars to ensure tha t sufficient clear floor area
is prov ided to accommodate all th e an ticipated wheelchair and mobil ity aid us ers for a trip . If a
larger number of such passengers presented th emselves at a stop, and a second car were not
full, it may be d iscriminator y un der the DOT rule not t o move the tra in 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 wh erever p racticable.
(b) Vehicle lift. - (1) Design load. The design load of the lift shall be at least 600
pounds. Working parts, such as cables, pulleys, and shaf ts, which can be expected to wear,
and upon whi ch the l if t depends f or support of the load, shal l have a saf ety factor of at l east
six, based on the ulti mate strength of the material . Nonworking parts, such as platform,
frame, and attachment hardware which would not be expected to wear, shal l have a saf ety
factor of at l east three, based on the ul timate strength of the material .
The specified design load is consistent with th e definition of a "common wh eelchair or
mobility aid" which weighs 600 poun ds or less when occup ied. However, the design load does
not represent the maximum load th e lift is capable of supp orting. The safety factors for the
supp ort components mean the lift cables, pulleys and shaft will supp ort 3600 poun ds and the
plat for m, frame an d at tachment har dwar e must suppor t 1800 pound s.
Previou s FTA-sponsored guid elines for lifts and some state codes sp ecify a detailed test
and certification procedu re to help ensure reliability, maintainability and d urability. The Board
does not view these issues as directly related to accessibility design but rather operational
consider ations. The DOT ru le requires a ccessibility equip men t to be maintain ed an d th ose
fact or s whi ch could affect main tainability should gen era lly be included in bid specifications .
Furthermore, the National Highwa y Traffic Safety Administration (NHTSA) may issue a
regu lation on s ever al safet y asp ects of accessibility equip ment on buses which ma y includ e
some specific testing requirements, and which may be applicable to rail car lifts. The Board
views NHTSA as the more app ropriate agency to deal with these issues and has not dealt with
them in the guid elines.
(2) Controls. - (i) Requirements. The controls shall be interlocked with the vehicle
brakes, propulsion system, or door, or shall provide other appropriate mechanisms or
systems, to ensure that the vehicle cannot be moved when the lift is not stowed and so the
li ft cannot be deployed unless the i nterlocks or systems are engaged. The l if t shal l de pl oy to
all levels (i.e., ground, curb, and i nterme di ate posi tions) normal ly encounte red in the
operating environment. Where provi ded, each control for deployi ng, lowering, raising, and
stowing the li ft and lowering the rol l-off barrier shall be of a momentary contact type
requiring continuous manual pressure by the operator and shall not allow improper lift
seque ncing when the li ft pl atform i s occupi ed. The controls shal l all ow reversal of the l if t
operation seque nce, s uch as raising or lowering a platf orm that i s part way down, without
allowing an occupied platform to fold or retract into the stowed position.
Most large vehicles are specified with d oor inter locks which prevent movement when
the door is open. Since the door mu st be open to operate the lift, this provision wou ld be
satisfied. If an auxiliary door is pr ovided exclusively for a lift or ramp , that d oor would also
need to be interlocked. Alternatively, the lift or ramp itself could be p rovided with its own
interlock system. In some cases, meeting this requirement may involve other solutions,
esp ecially for r ail cars where d oor int erlocks are n ot n ormally pr ovided or where a porta ble lift
ma y have no d irect con nect ion t o the car. The "app rop riat e mechanisms or systems" migh t
include some relatively simple electrical interlocks. However, the system or mechan ism cannot
work only as a warning to the driver, such as a flashing light or buzzer, which can be
inadv ertent ly overlooked . The key operat iona l criterion is t hat the car can not be moved while
the lift or ramp is in u se.
Furthermore, the lift must be designed to dep loy to all levels expected to be en count ered
in the opera ting environmen t. In some systems wh ere all of the stops are at ra ised platforms,
then the lift would only be requ ired to d eploy to p lat for m level.
Finally, if the lift is electr ically opera ted , the con trols must be of t he momentary contact
type, requiring continuous pressure to activate and mu st be interlocked in such a way as to
preclude the possibility of folding or stowing the lift when th e platform is occupied (except as
provided below). Some lifts currently in service can be folded or stowed simp ly because the
operator presses the wrong bu tton at the wron g time. This regulatory provision is intended to
preclude th is possibility. Some lifts accomplish this fun ction by incorp orating a pressur e
sen siti ve switch in the plat for m to sense when i t is occupied . Ot hers i ncorp or at e a slip-clutch
mechanism on the folding motor such that it is not capable of folding anything heavier than an
empty p latform. Photocells or proximity switches might also be emp loyed to detect the
presence of a lift user on the platform. Whatever system is used, it should be d esigned so that,
if the pres sure s witch, ph otocell or proximity switch is not opera ting, th e lift will not opera te.
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 t he con trols must allow the lift to be ret ur ned to platfor m level for deboard ing. In this
case, the fold or stow function mu st still be preclud ed un til the platform is empty.
(ii ) Exception. Where physi cal or saf ety constraints prevent the deployment at some
stops of a lif t havi ng its l ong di mension pe rpendicul ar to the vehicl e axis , the transportation
entity may specif y a li ft whi ch is des igned to deploy with i ts long dimensi on parallel to the
vehi cle axis and whi ch pivots into or out of the vehicl e whi le occupi ed (i.e., "rotary li ft"). 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 simp ly permits the use of a certain typ e of lift wh ich wou ld be p recluded
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 th is exception is one in which the p latform
rotates into the car a nd this is the stowed p osition. In this case, the lift is intended to be stowed
wh ile occupied, which wou ld otherwise be prohibited by strict application of the previous
pa ragrap h. It sh ould be noted , however , that an other type of rot ary lift in which the pla tform is
inten ded to be ra ised to a ver tical posit ion for stowage, is n ot covered by this exception. Such a
design is not precluded, since the rotation of the platform wh ile occupied is not prohibited, but
the actu al raising of the platform into the vertical stowed p osition must still be pr evented wh en
the p latform is occup ied.
Since rotary lifts deploy with the long dimen sion of the lift platform parallel to the
veh icle, and the us er en ters and exits para llel to th e veh icle, they can be deployed in r elatively
narrow spaces. Such a lift could be d eployed into a n arrow island between traffic lanes on a
street, for examp le. This would allow str eet stops t o be accessible wher e a light rail system
oper ates on city street s along with au tomobiles.
(ii i) Exception. The brake or propulsion system interlocks requirement does not
appl y to a s tation platf orm mounte d li ft provided that a mechani cal, el ectrical or other
system operates to ensure that ve hi cles do not move when the l if t is in use.
This excep tion for platfor m-mount ed or p ort able lifts allows us e of a "mech anical,
electrical, or other system" in lieu of an interlock system, to ensure that th e car does not move
wh ile the lift is in use. This provision is intend ed to cover situations in wh ich the lift is not
electrically or mechanically connected to the vehicle. Under this exception, devices may be
installed that do n ot function as an interlock but, at a min imum, as a warning that a lift is in use
or that a door is open. Some mechanical or electrical device must be provid ed in add ition to
any op erat iona l methods in ord er to limit the possibility of hu ma n er ror . This provision is
written as a performance requirement so that transit operators and man ufacturers have as
mu ch flexibility as possible in providing such a system. If this requirement cannot be met,
oper ators can develop an d p ropose alterna tive met hod s under the p rocedu res for equivalent
(3) Emergency operation. The lift shall incorporate an emergency method of
depl oying, lowering to ground l evel with a l if t occupant, and raising and stowing the empty
li ft i f the power to the l if t fai ls. No emergency method, manual or othe rwi se, shall be
capabl e of bei ng ope rated in a manner that coul d be hazardous to the li ft occupant or to the
operator when ope rated according to manuf acturer's i nstructions, and shal l not permi t the
pl atform to be s towed or fol ded when occupi ed, unl ess the li ft is a rotary l if t inte nde d to be
stowed whi le occupi ed.
This provision is intend ed to a llow persons who need th e lift to deboard if the lift power
fails. Typically, this operation is performed by a han d op erated crank or p ump, 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 op erated according to manu facturer' s instructions. Notwithstanding the
cautionary note about man ufacturer' s instructions, the emergency system mu st not permit the
lift to be stowed or fold ed when occup ied. This could be accomplish ed with a pressu re valve in
the hand pump sys tem whi ch would not allow sufficient pres sure t o fold a lift plat for m whi ch
had s ome specific weight on it . Also, providin g two sep ara te control systems , one for raisin g
and lowerin g and one for stowing, wh ich required a h and lever, for example, to be removed
from one valve and p laced in another, could p rovide safety. This could be especially effective if
the stowage control access point were physically blocked by a lift occupant.
(4) Power or equipment failure. Lift platforms stowed in a vertical position, and
deployed platforms when occupied, shall have provisions to prevent their deploying,
fal li ng, or fol di ng any f aster than 12 inches/second or thei r droppi ng of an occupant i n the
event of a s ingl e f ail ure of any l oad carrying component.
This provision requires some sort of "braking" or "damping" mechanism, similar to
those p rov ided on elevators, t o prevent "free fa ll" of an occupi ed pl atform in t he event of a
power failure or single failure of any load carrying componen t. The fall rate also applies to the
dep loyment cycle in ord er to protect any persons waiting close to the car for the lift to deploy
wh en the power fails. This is not a "planned " event wh ich can be anticipated and the slow rate
might pr ovide enough time to move out of the way. This provision app lies only to those lifts
which are s towed in a ver tical position , generally the so-called "active" lifts, wh ich could fall
outward (i.e., unfold) when someon e is waiting out side the car. Most such lifts with a powered
deploy cycle simpl y st op when t he power fails. Pr event ing rapi d deployment in the event of a
single failure of a load carr ying componen t, such as a cha in or cable breakage, will likely
req uire mor e ingen uity.
(5) Platform barriers. The lift platform shall be equipped with barriers to prevent
any of the wheel s of a wheel chair or mobi li ty aid from rol li ng of f the li ft during i ts
operation. A movable barri er or inherent design feature shal l prevent a wheelchai r or
mobility aid from rolling off the edge closest to the vehicle until the lift is in its fully raised
posi tion. Each si de of the li ft platf orm whi ch extends beyond the vehi cle in its raised
positi on shal l have a barri er a minimum 1-1/2 i nches high. Such barri ers shal l not i nterfere
with maneuvering into or out of the aisle. The l oading-edge barrier (outer barrier) which
functi ons as a loadi ng ramp when the l if t is at ground l evel , shall be suff ici ent when raised
or cl osed, or a supplementary system shal l be provided, to prevent a power wheelchai r or
mobi li ty ai d f rom riding over or defe ating i t. The outer barrier of the l if t shall automati call y
rise or close, or a supplementary system shall automatically engage, and remain raised,
cl osed, or engaged at al l ti mes that the lift i s more than 3 i nches above the stati on platform
or roadway and the l if t is occupi ed. Al ternati vely, a barrier or sys tem may be raised,
lowered, opened, closed, engaged or disengaged by the li ft operator provided an i nterlock or
inherent design f eature prevents the l if t from risi ng unless the barrier is rais ed or closed or
the supplementary system is engaged.
The first part of this pr ovision covers t he barr ier (often called a "roll stop ") which is
inten ded to p rev ent th e lift user from rolling or stepping off t he plat for m edge closest to the car .
Some lifts have a flap wh ich rises when the lift is deployed and lowers when the platform
reaches the car floor level. Other d esigns depen d on the structur e of the car itself or a "close-out
panel" to p rev ent falling off t he inner ed ge.
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 as such barriers 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 maneu vering. Care mu st be taken in this d esign because
there is often a gap between the side of the lift pla tform and t he car floor when the lift is fully
raised. In regard to bus lifts, several lift manufacturers and tr ansit op erators h ave ind icated
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 tr ap ped when i t tu rns into t he aisle. The
height requirement for side barriers has been chosen to accommodate some rims on the
camber ed wheels of sport wh eelchairs 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
(out er) barrier . The Board has not requir ed such a test in th ese gu idelines because NHTSA is
plann ing to issue proposed safety standar ds for bus lifts which may be su itable for app lication
here. The Board feels that NHTSA is the approp riate agency to define safety tests. In the
mean time, th is provision includes onl y a performance requ irement.
Finally, whatever barrier or supplemental system is used, it must either rise or engage
aut oma tically when the lift is raised more tha n three inches off the p latform or ground , or there
mu st be an interlock which prevents the lift from rising more than th ree inches off the platform
or grou nd unless the bar rier or supp lementary syst em is engaged . Thus, the bar rier or system
could be engaged manually, pr ovided the lift could not r ise u nl ess it were properl y en gaged .
Systems cou ld, for exa mpl e, empl oy a n electr ical switch which int err up ts p ower t o th e lift
un less the bar rier is engaged or migh t use a mechanical slip-clutch or gear and sp rocket
arr angement which is engaged only when the bar rier is raised or th e supp lement al system is
(6) Platf orm surface. The lift platform surface shall be free of any protrusions over
1/4 inch high and shal l be sl ip resis tant. The li ft pl atform s hall have a minimum clear width
of 28-1/2 inches at the platf orm, a minimum clear wi dth of 30 inches measured from 2 inches
above the li ft pl atform s urface to 30 inches above the surface, and a minimum clear length of
48 inches measured from 2 i nche s above the s urface of the platf orm to 30 i nche s above the
surface. (Se e Fig. 1)
The requirement for the 1/ 4-inch ma ximum protru sion is consistent with common
acces sibility stand ar ds an d is inten ded to r educe tr ipping hazar ds for stand ees.
The requ iremen t for slip resistance is a general performa nce requ iremen t. As discussed
under floor surfaces, there are difficulties in defining an ap prop riate test procedure for
determining the level of slip r esistance or the static coefficient of friction. However , a stat ic
coefficient of friction of 0.6 is recommend ed for p latform su rfaces.
The specified platform su rface dimensions are consistent with the definition of
"common wh eelchairs and mobility aids" in requiring a 30 inch width an d 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 oth er parts
of the wheelchair or mobility aid. While a minimum length at the platform su rface is not
specified (unlike the width requ irement) obviously the platform surface cannot be less than the
wheelbase of th e mobility aid .
The width measurement position acknowledges that the door structure of some cars
may not permit a 30 inch wide platform unless the door frame is modified. The width is to be
measured 2 inches above the platform to allow a na rrower p latform at the bottom on ly, thus
permittin g wider lift s to be in corp ora ted without modifying th e door frame. Also, th e lift
han dr ails are often atta ched t o the p latform at the bottom and the stru ctural material takes u p
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
hand rail anchor points allows a lift which does not affect door structure but still allows a clear
30 inches between hand rails. The clear space is measured to the height of 30 inches to clear the
armrests of most wheelchairs and mobility aids. The clear space required is shown as the
shad ed p ortion of Figur e 1. In effect, a box of the ind icated d imensions must be a ccommod ated
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,
pr eferably slan t outward , to provide
the clear area. Under no
circumstances may the barriers slant
inward into the required clear sp ace.
(7) Platform gaps. Any openi ngs between the l if t pl atform surface and the raised
barriers shal l not exceed 5/8 inch wide. When the li ft is at vehicl e f loor hei ght with the i nne r
barrier (if appli cabl e) down or retracted, gaps between the f orward li ft platf orm edge and
vehicl e floor shal l not exceed 1/2 i nch horizontally and 5/8 i nch verti cally. 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 sect ion is intend ed to prevent the front caster of a wheelchair from turning
sideways and d ropping thr ough the gap between the raised barrier an d th e platform. It applies
only to the gap between th e platform and the raised barrier and d oes not preclude the use of
expanded metal platforms. A hand hold hole is permitted in the platform for lifts which are
man ually d eployed .
(8) Platf orm entrance ramp. The entrance ramp, or loading-edge barrier used as a
ramp, shall not exceed a slope of 1:8 measured on level ground, for a maximum rise of 3
inches, and the transiti on from the stati on pl atform or roadway to ramp may be vertical
without edge treatment up to 1/4 inch. Thres holds between 1/4 i nch and 1/2 inch high shal l
be beveled with a sl ope no greater than 1:2.
This required slop e is based on common accessibility stand ard s wh ich allow steep er
slop es for sh or t d ista nces where a slop e of 1:12 can not be provid ed due to exist ing con str ain ts.
A slope of 1:8 is permitted for a maximum rise of 3 inches. If the rise is greater, the slope mu st
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
defl ect more than 3 de grees (exclusi ve of vehi cle roll ) in any di rection between i ts unl oaded
posi tion and i ts positi on when l oaded with 600 pounds appl ied through a 26 inch by 26 i nch
test pal let at the centroid of the lift platform.
The p rovision has been clarified so that th e pla tform deflection is exclusive of veh icle
roll. In practice, however, the Board expects that the deflection would not be measured on the
vehi cle bu t would be meas ured by the manufact urer on a "test r ig" in the fact or y. The
man ufacturer would then certify the lift as meeting t he stan dard. The same is also anticipated
for other measur es, such as acceleration an d ba rrier resistan ce.
Since the vehicle will normally tilt when th e lift is loaded, due to the weight of the
wh eelchair or mobility aid and the u ser, there will be a slope away from the vehicle toward the
barrier. The reason for limiting the d eflection of the lift platform is to minimize the
contribu tion to th is slope by the platform itself. The deflection load is based on the term
"common wheelchair or mobility aid" wh ich is defined as weighing as much as 600 pound s
when occupied. To increase the angle would allow the platform to slope more with a heavy
wheelchair , this situation is potentially t he most d angerous and t he most likely to r esult in a
wheelchair or mobility aid overriding or defeating the outer barrier.
(10) Platform movement. No part of the platf orm shal l move at a rate exce eding 6
inches/s econd during lowering and l if ting an occupant, and s hal l not exceed 12
inches/second during deploying or stowing. This requirement does not apply to the
depl oyment or stowage cycl es of li fts that are manual ly depl oyed or stowed. The maximum
pl atform horizontal and vertical acceleration when occupied shal l be 0.3g.
The specified maximum sp eeds ar e prov ided not on ly for the safety of persons,
including st andees, occupyin g t he lift, but also of any pers ons wait ing near the lift . The
dep loymen t and stowage rate, although allowed a greater speed , may also affect passen ger
safety. A poten tial user wait ing outsid e th e car might not be able to get out of t he way of a
rapidly deploying lift. Similarly, some lifts which fold up into the p assenger compartment,
particularly active lifts, could pose a hazard to a person inside the car near the lift if the
platform stowed too quickly. Accordingly, the final ru le specifies the 6 inch per second speed
only for the raising and lowering of an occupied lift and a 12 inch per second sp eed for the
dep loy and stow port ion of the cycle.
The Board considered a requirement for the maximu m rate of change of acceleration
(jerk) but did not d o so because it is difficult to measur e and can be easily affected by oth er
variables not d irectly rel at ed to t he rate of cha nge of acceler at ion of th e lift plat for m itself.
Also, there is no r esearch with iden tifies acceptable rates for persons with d isabilities.
(11) Boarding direction. The lift shall permit both inboard and outboard facing of
wheelchairs and mobility aids.
While some operat ors adv ise wheelchair or mobility aid users to back ont o the lift, it is
difficult for some people to do so. Therefore, the lift must permit persons to board and alight
facing either in toward the veh icle or ou t toward the pla tform or board ing area . This
requ iremen t shou ld be consid ered in conjunction with the barrier or su pp lemental system
design ed to r etain th e wh eelchair or mobility aid on the p latform. For examp le, some barr iers
ha ve been designed to r ise u nd er t he cur ve of the rear wheel or un der t he fron t footrests of a
wheelchair . Some designs may be u sable on ly if t he occupant is fa cing a par ticu lar direction.
This is not permitted. Similarly, at least one supp lementary lift restraint system used in Canad a
involves a belt connected between hand rails. This belt must be long enough to go arou nd the
back of the wh eelchair or mobility aid if the person were facing inward, not just across the
armrests for a person facing outward .
(12) Use by standees. Lifts shall accommodate persons usi ng walkers, crutche s, canes
or braces or who othe rwi se have dif fi culty usi ng steps. The li ft may be marked to indi cate a
preferred standing position.
The DOT rule requires that operators accommodate stand ees on lifts which meet the
design requirements of Part 38. Some current lifts already meet these standard s with respect to
stan dees while others d o not. Accord ing to DOT, it is not the int ent of the DOT r ule t o requir e
that stand ees be a ccommod at ed on lifts whi ch d o not meet those stand ar ds. See 49 CFR
(13) Handrails. Platforms on li fts shal l be equipped with handrail s, on two si des,
whi ch move in tandem with the l if t whi ch shall be graspabl e and provi de support to
standees throughout the entire l if t operation. Handrails shall have a usable component at
least 8 inches long with the l owest portion a mi ni mum 30 inches above the platf orm and the
hi ghest portion a maxi mum 38 i nches above the pl atform. The handrail s shal l be capabl e of
withs tandi ng a force of 100 pounds concentrated at any poi nt on the handrail without
permanent deformation of the rai l or its supporti ng structure. Handrai ls shal l have a cross-
sectional di ameter between 1-1/4 i nches and 1-1/2 inches or shal l provi de an equivalent
grasping surface, and have eased edges with corner radi i of not l ess than 1/8 i nch. Handrail s
shal l be placed to provide a minimum 1-1/2 i nches knuckle cl earance from the nearest
adjacent surface. Handrails shall not interfere with wheelchair or mobility aid
maneuverabil ity when entering or leavi ng the vehi cle.
Con sid era ble res ear ch h as been conducted in the past on the height of a h andrail whi ch
can be used by person s with disabilities. Until recently, the accepted h eight has been a
minimum 30 inches and a maximu m 34 inches above the platform. More recent research on
han dr ail height h as suggested that a heigh t from 34 inches to 38 inches is better an d th ese
dimension s hav e been a ccepted by the mod el build ing cod es and incorp orated in the Board's
final guid elines for buildings an d facilities. Because of design constraints imp osed by a veh icle,
the Boar d is not i ncl ined to fu lly impose these new dimension s on ha nd rails.
With resp ect to the force requ iremen ts, handr ails in build ings an d facilities are required
to withstan d much high er forces because they are intend ed to provide sup port for rising from a
sitting position, maneuvering into and out of a wh eelchair or mobility aid, or walking u p or
down stairs or ramps. The ha nd rails on a lift are inten ded only to p rovid e stability as opposed
to major suppor t. Lift h andrails meet ing t he 100 pound force requ irement have been in ser vice
for many years with n o known problem. Moreover, hand rails mounted on walls, are subject to
tor qu es whi ch a re v ery differ ent fr om those on lift handrails atta ched only t o th e plat for m. To
withstan d equivalen t forces would r equ ire su bsta nt ial rein forcement of the lift ha nd rail
attachment points, with correspond ing increases in weight, and a p otential decrease in the
platform widt h. In the abs ence of information that th e 100 pou nd force req uir ement is
inad equate, it has not been changed.
In regar d to h and rail shap e or configur ation, the Board is not aware of any problems
with eith er cu rved or ver tical handrails, provid ed they move in tand em with the plat for m. As
for han dr ail diameter, the requirements in t his section are consistent with the Board spon sored
hand anthropometrics research project which tested gripping by persons with various hand
disabilities and confirmed th e app ropriateness of the specified dimensions. A 1-inch d iameter
hand rail would not be usable. Most car hand rails are made of pipe. In the building industry,
pipe size typically specifies inside d iameter so that a 1-1/ 2 inch pipe han dr ail actually ha s a
larger outside d iameter, sometimes up to 2 inches. Such ha nd rails have not posed any known
pr oblem. Thus, the 1-1/ 2 inch d iameter requir ement can r esult in a hand rail of app roximately
2 inches un der curren t build ing ind ustr y pr actices. The 1-1/ 2 inch clearance also received
genera l suppor t and has been included.
It is critical that more than on e hand rail be provided if standees are to be able to use the
lift. The presence of two handrails is also critical for rotary lifts. However, because of the
design of rotary lifts, it may be that a suitable configuration can be achieved with hand rails that
are not necessarily on opposite sid es of the plat form, but migh t be on two ad jacent sid es.
Accordingly, this section specifies handrails on "two sides" rather than "both sides" of the
(c) Vehi cle ramp or bridge pl ate. - (1) Design load. Ramps or bridge plates 30 inches
or longer shal l support a load of 600 pounds, placed at the centroid of the ramp or bridge
pl ate di stributed over an area of 26 inches by 26 i nche s, with a s afety factor of at leas t 3
based on the ul timate strength of the material . Ramps or bridge plates shorter than 30 inches
shall support a load of 300 pounds.
Since ramps are permitted in some cases instead of lifts, it is essential that they be
designed to a ccommod at e th e same ra nge of common wheelchair s an d mobility aid s.
Con sequently, the design l oad specified for lifts is al so r equired for ramps or br idge p lat es 30
inches or longer . Ramps or br idge p lat es u nd er 30 in ches must h ave a d esign l oad of 300
poun ds; such ramp s or bridge plates are approximately the length of a test pallet and
placement of a load ed pa llet on the ramp would n ot test th e str ength of the ramp but would
instead merely r est on th e car and platform or curb. Furthermore, ramps shorter th an 30 inches
need sup port only about half the weight of a wheelchair or other mobility aid at a given point:
wh en the front wheels are on the ra mp , the rear wheels are still on th e board ing area , and wh en
the rea r wheels move onto the r amp , the front wheels will be inside the car. The p rovision d oes
not specify a test pallet for making this measurement, but manu facturers should u se a method
wh ich approximates the loading that would be expected from either th e front or rear wh eels of
a wheelchair or mobility aid, applied at en ough point s alon g the ramp len gth to ensure th at it
will supp ort a common wh eelchair or mobility aid user withou t significant deflection.
(2) Ramp surface. The ramp or bridge plate surface shall be continuous and slip
resistant, shall not have protrusions from the surface greater than 1/4 inch, shall have a clear
width of 30 i nches, and s hal l accommodate both four-wheel and three-wheel mobi li ty ai ds.
The term "continuou s surface" means a single, uninterrup ted surface from edge to edge
as opp osed to a platform with a gap in the midd le that may incorp orate step s. It is also
intended to pr eclude th e use of two separ ate ramps p laced some distan ce apart . Those
configura tions can a ccommod ate four wheeled devices but cann ot accommoda te thr ee wh eeled
scooters. Ramps h aving two par ts are permitt ed, provid ed th ey are d esigned to be deployed
together to pr ovid e a unifor m, u nin terr up ted sur face. The ter m was not intended t o preclude
expanded metal ramp s which are often much lighter than solid platforms of the same strength.
While lift platforms are permitted to be 28-1/ 2 inches wide, ramps must have a clear
wi dt h at the su rface of 30 inches. This is because ramps ar e design ed to be traver sed, while a
wheelchair or mobility aid user essent ially r emains stationary on a lift platform while it is in
operation. For this reason, a wheelchair or mobility aid user needs more clearance on a ramp
for man euvering th an on a lift platform. The restr iction on 1/ 4-inch high p rotru sions is taken
from common accessibility stand ard s for accessible surfaces.
A minimu m value or coefficient of friction is not specified for slip resistance due to
practical difficulties in measur ing such a value. However, the Board has cond ucted research on
slip res ista nce and recommends a static coefficient of fr iction of 0.8 for r amp surfaces.
(3) Ramp threshold. The transition from roadway or station platform and the
transiti on from vehicl e f loor to the ramp or bridge pl ate may be vertical without edge
treatment up to 1/4 inch. Changes in level between 1/4 inch and 1/2 inch shall be beveled
with a sl ope no greater than 1:2.
Thi s provision is drawn fr om common accessibility req uirements for accessible pat hs .
The ends of the ramp, both wh ere it meets the platform, and the transition to car floor, must be
tapered to 1/ 4 inch vertical lip or up to 1/ 2 inch, beveled to a slope of 1:2. In no case may the
lip exceed 1/ 2 inch .
(4) Ramp barri ers. Each si de of the ramp or bridge pl ate shall have barriers at leas t 2
inches high to prevent mobility aid wheels from slipping off.
The height requirement for side barriers on ramp s is derived from common accessibility
requ iremen ts for ramps. The heigh t differs from th at for lift platform side bar riers because
wheelchair s and mobility aids move a long the ramp d ur ing board ing and a lighting an d t her e is
subst antially more oppor tun ity for wh eels to ride over barr iers on ramp s than for lift platforms.
Although short ramp s or bridge plates that are placed between door posts limit the
likelihood of a wheelchair or mobility aid rolling off, the Board believes th ere is still sufficient
danger in many si tuat ions to req uire edge bar riers.
(5) Slope. Ramps or bridge plates shall have the least slope practicable. If the height
of the vehi cle fl oor, unde r 50%passenger load, f rom whi ch the ramp is depl oyed is 3 inches
or les s above the s tation platf orm a maxi mum slope of 1:4 is permitte d; if the hei ght of the
vehicl e floor, under 50% passenger load, f rom which the ramp is deployed is 6 i nches or less,
but more than 3 inches, above the station pl atform a maximum slope of 1:6 is permitte d; if
the height of the vehicl e f loor, under 50% passenger load, f rom whi ch the ramp is depl oyed
is 9 inches or less, but more than 6 i nches, above the stati on pl atform a maxi mum slope of 1:8
is permi tted; if the he ight of the vehicl e f loor, under 50% pass enger load, f rom whi ch the
ramp is deployed is greater than 9 inches above the station platform a slope of 1:12 shall be
achi eved. Foldi ng or tel escoping ramps are pe rmitted provi ded they meet al l structural
requirements of this section.
Previous tests of ramps on bu ses have shown th at a slope of 1:6 is generally the
maximum slope which could be negotiated but th at short ramps of 1:4 slope could be used by
some persons under some circumstances. The Board recognizes that there are practical
difficulties in meeting common accessibility standards in vehicles which are constrained by
other factors, such as ma ximu m widt h. In view of these factors, this section requir es that, in
general, the least slope pr acticable be obtained. A slope of 1:4 is permitted if the vertical floor
height is 3 inches or less above the station platform. This would require a ramp ap proximately 1
foot long an d would be short enou gh to be negotiable by ma ny p eople. If the floor height d oes
not exceed 6 inches above th e pla tform, a slope of 1:6 would be permitted . A slope of 1:8 would
be p ermitt ed if the floor height does not exceed 9 inch es above the plat for m. A slope of 1:12
would be r equired for gr eat er r ises.
Height of Vehicle Floor
Above Platform
Maximum Ramp Slope
3 in. or less 1:4
6 in. or les s but more t han 3 in. 1:6
9 in. or les s but more t han 6 in. 1:8
more t han 9 i n. 1:12
(6) Attachment. - (i) Requirement. When in use for boarding or alighting, the ramp or
bridge pl ate shal l be attached to the vehicl e, or otherwi se prevented from movi ng such that
it i s not subject to di splacement when l oading or unl oading a heavy power mobi li ty ai d and
that any gaps between vehicl e and ramp or bridge plate, and s tation platf orm and ramp or
bridge plate, shall not exceed 5/8 inch.
The 5/ 8 inch gap specified is based on th e wid th of a wheelchair fron t caster.
(ii ) Exception. Ramps or bridge plates which are attached to, and deployed from,
station pl atforms are permi tted i n li eu of vehicl e de vi ces provided they meet the
displacement requirements of paragraph (c)(6)(i) of this section.
With respect to portable ramps, the ADA legislative history specifically ment ions
portable ra mp s as a viable option for some veh icles. The principal comp laint about port able
ramps has us ua lly been the possibility of slipp ing which the Board believes is ad equ ately
addr essed by th e requir ement that th e ramp be firmly at tached to th e car or platform when in
use for boarding and alighting. Several commercially available portable ramps have brackets
wh ich are attached t o the car an d which permit quick connect and disconn ect. Others ha ve a
hole-and-pin ar rangement which allows for firm attachment while in use. The definition of
"firmly attached" in this case means that the ramp d oes not move enough to allow a gap
between car and ramp greater than 5/ 8 inch un der any cond itions, not necessarily that the
ramp be r igid ly atta ched.
(7) Stowage. A compartment, securement system, or other appropriate method shal l
be provided to ensure that stowed ramps or bridge plates, i ncl uding portabl e ramps or
bridge plates stowed in the passenger area, do not i mpinge on a passenger's wheelchai r or
mobility aid or pose any hazard to passengers in the event of a sudden stop.
This section of the final guidelines addr esses the provision of a stowage compa rtment,
securement system, or other means of ensuring that the ramp d oes not pose a hazard. In man y
situation s wh ere por table ramps ar e curren tly used , the ramp is simp ly set inside th e passen ger
compartment, sometimes leaning aga inst the passen ger's mobility aid, where it could cause
injury in a sudd en stop. Some ramp s automatically stow in a pocket under the floor or are
folded back over the step . At leas t one manufactur er p rovides a storage area immedia tely
insid e th e door as p ar t of t he ha nd rail configu ration.
(8) Handrails. If provi ded, handrails shall all ow persons with di sabil iti es to grasp
them from outsi de the vehicl e whi le starting to board, and to continue to us e the m
throughout the boarding process, and shall have the top between 30 inches and 38 inches
above the ramp surface. The handrails shall be capabl e of withstandi ng a force of 100
pounds concentrated at any point on the handrail without permanent def ormati on of the rail
or its supporting s tructure. The handrail shall have a cross-secti onal diameter between 1-1/4
inches and 1-1/2 i nches or shall provide an equi val ent grasping surface, and have eased
edges with corner radii of not l ess than 1/8 inch. Handrails s hall not i nterfe re wi th
wheelchair or mobility aid maneuverability when entering or leaving the vehicle.
These hand rail specifications are similar to those required on lifts (see previous
The Board generally recognizes th at "short" ramp s and bridge plates d o not n eed
hand rails while "long" ones may. Unfortunately, there is no general agreement on the
definition of "short " or "long." Since mos t ramp s and bridge plates will pr obably be "shor t" in
some sen se, the Board has not made the p rovision of hand rails on ramp s or brid ge plates
mand atory. The Board will further review this issue when the guidelines are revised and
1192.85 Between-car barri ers
Where vehicl es ope rate in a high-pl atform, l evel -boardi ng mode, devices or sys tems
shall be provided to prevent, deter or warn individuals from i nadvertentl y ste ppi ng of f the
pl atform between cars. Appropriate devi ces include, but are not l imited to, pantograph
gates, chains, moti on detectors or othe r sui tabl e devices.
At h igh platforms pr ovid ing level boar din g, a ser ious danger t o passen gers , particularly
those with visual impair ments, is stepping in-bet ween car s an d fallin g on to t he tr acks. The
light from end windows on some car designs can sometimes cause persons with visual
imp airment s to mistake the gap between cars as an ent ran ce. There a re several p ossible
solutions to prevent a ccidents of this nature noted in the prov ision. Other available solutions
not mentioned in the provision are acceptable so long as they serve to "prevent, deter, or warn"
individu als of the gap. The typical bellows provided between many commuter and intercity
rail car s serves this same pu rpose an d n o ad dit iona l device is needed. One light rail system is
consider ing insta lling barriers on the p latform which would correspon d to t he gap between
cars wh en the train stops.
Althou gh th e Board does n ot requ ire or recommend one d evice or solution over
another, it is known that spr ing or pan tograph gates are more effective than chains or motion
detector s in stopping a pers on from stepping ov er t he plat for m edge a nd fallin g between car s.
Chains, if mounted high enou gh, may actually prevent falls, but if mounted at a low height
may serve only as a warning to visually-impaired persons using canes. Motion detectors are
str ictly a war ni ng device an d will not p hysically r est rict someon e from fallin g between car s.
Operat ors con cerned about the manua l conn ection and d isconn ection of spring gates or chain s
can specify pantograph gat es, motion d etectors, or other devices.
1192.87 Publ ic i nf ormati on system.
(a) Each ve hi cle s hall be e qui ppe d with an inte rior publi c address system permi tting
transportation system personne l, or recorded or digiti zed human s peech message s, to
announce stati ons and provi de other passenger information. Alternative systems or devices
whi ch provi de equi val ent access are al so permitted.
This provision requires vehicles to be equipped with a p ublic add ress system that
provides either recorded or digitized hu man speech messages or announcements made by
drivers or other transit personnel. Digitized human speech uses spoken sound s and word s
arr anged digitally a nd rear ran ged for customized messages. While other systems that p rovide
equivalent access to information ar e permitted, the use of synthetic speech is not
recommend ed. Accordin g to Board-sponsored research, synthetic speech, which is generated
electronically, has not yet been p roven to be as easily recognized or u nd erstood as recorded or
digitized human speech. Information received by the Board du ring th e development of these
gu idelines d id not con tr ad ict t hi s as sessment.
(b) [Reserved]
These guidelines do not currently contain requirements or specifications for the
pr ovision of p ublic information in a format th at is accessible to per sons with hea ring
impairments. Such a requirement has been reserved pen ding further study of the options that
are available in making such information fully accessible; the Board expects to include some
requir ement s in t he fu ture. However , general p roh ibition s of discrimination in th e DOT r ule
require, in essence, that information necessary for the operation or use of a transit system be
mad e available to persons with hearing imp airments. Thus, it is recommend ed that the
information for passengers contained in au dible announ cements also be mad e available to
person s with hearin g loss or who ar e deaf. Of course, ann oun cement s intend ed on ly for system
person nel are not part of the infor ma tion needed by passen gers . DOT is ass essing available
and soon-t o-be availa ble tech nology in a st udy t o be conducted durin g Fisca l Year 1992.
Entities are encou raged to emp loy wh atever ser vices, signage or altern ative systems or devices
that ar e availa ble and that provid e equivalent access.
Information can be provided in different ways, some of which are relatively simple and
inexpensive. For examp le, one transit system has a policy of flashing interior train lights to
indicate to passengers who are deaf that the train is malfunctioning and that all passengers
mu st exit the train at the n ext station. Of course, the meaning of this signal must be conveyed
in advan ce to potentially affected passengers for it to be useful and may not be u seful to
person s unfamiliar with the system, such as tourists. A prominent sign in th e vehicle also
wou ld be u seful. In general, such information sh ould be includ ed in the br ochur es and guid es
available to the public rather than only in a "special services" brochure intended for persons
with disabilities. Access to some information may also be conveyed by a system of signage
provid ing information rou tinely provided in announcemen ts (e.g., no smoking, fares, hour s of
oper ation) while information p rovid ed in special ann oun cement s (e.g., changes in schedu le,
elevators not in service) could be posted in strategic areas, such as at entran ces to the station or
at information kiosks.
Mor e sop hist icated solutions could in clud e visu al displa y sys tems and electron ic
message boards. Visual display systems provide information through electronic message
boards or video mon itors and can accommodate persons who are deaf as well as those with
hea ring loss. Electr onic mess age boar ds usin g a ligh t emitting diode (LED) or "flip-dot" disp lay
are currently provided in some transit stations and terminals and may be usable in cars. One
transit system is testing the feasibility of on-board visual displays for next-station
announ cement s and even point s of int erest , news headlines a nd weath er reports. Pa id
adver tisement s may be us ed to su pp ort the syst em. Such vis ua l displays can sup plement audio
ann oun cement s. These devices may be used to pr ovide r eal time or p re-programmed
messages. However, real time message displays require the availability of an employee for
keyboar d en try of the informat ion to be an nou nced.
Video monitor systems, su ch a s vi sual p aging systems provid ed in some ai rp or ts (e.g.,
Baltimor e-Wash ington Internation al Air port), ar e another alt ernative. The Board can p rovide
technical assistance and information on th ese systems, including a free pamp hlet, "Airport TDD
Access: Two Case Stu dies."
Assistive listening systems (ALS) may possibly provide another alternative although
they benefit a narrower population of people with hearing loss. These types of systems are
inten ded to a ugment st andar d public addres s an d au dio systems by provid ing si gnals whi ch
can be r eceived directly by pers ons with special receivers or their own h ear ing aids an d whi ch
eliminat e or filter backgr ound noise. Magnetic in duction l oop s, infra-red and radio fr equency
systems are typ es of listening systems wh ich are ap propriat e for various app lications. These
systems, however, are not u sable by persons who are d eaf. Further, the feasibility and cost of
installing such devices on cars remain un certain. The Board ha s published a p amp hlet,
"Assistive Listening Systems," available at no cost, wh ich lists demonstration centers across the
country wh ere technical assistance can be obtained in selecting and installing approp riate
systems. The state of New York has also adopted a d etailed technical specification which may
be useful.