Dear Mr. Cannon:
The Braun Corporation of Winamac, Indiana is taking this opportunity to comment on the Access Board’s draft revision to the American’s with Disabilities Act Accessibility Guidelines for Transportation Vehicles. Our comments center on three separate areas of the Guidelines.
Regarding the 36 inch aisle width, we have found it is not presently achievable on paratransit vehicles manufactured on a full size van body/chassis. In attempting to maximize aisle width, fold-away seating systems are utilized. However, present seating systems that are adjacent to side door mounted wheelchair lifts only provide an optimal aisle width of 34 inches when the seats are stowed. This is primarily due to the intrusion of fixed padding systems designed to protect occupants from contacting the stowed wheelchair lift. The Braun Corporation would join the Board in adopting the 32 inch requirement.
As regards the wheelchair design load being increased to 660 pounds, The Braun Corporation can achieve that level, but only with a corresponding decrease in the ultimate load safety factor from 6 to 4 times the rated capacity. For NHTSA’s discussion of this topic (which Braun concurs with), see the FMVSS 403/404 Final rule published at page 79434 of the Federal Register, December, 2002. Specifically, look to section 4 which discusses Static Load Test III- Ultimate Load. Essentially, NHTSA found the 6 times safety factor was unrealistic. The Braun Corporation agrees with NHTSA’s assessment, and would urge the Board to adopt NHTSA’s position.
Finally, regarding ramp slope, we believe the 1:8 proposal may be an oversimplification. This slope is undoubtedly achievable when ramps are deployed to a 6 inch curb. However, Braun is skeptical about whether this can be achieved fleet-wide, using current vehicle kneeling/ramp length technology. Our investigation shows that a1:6 slope would be more representative of the current state of the art.
Sincerely,
Barry E. Wolff
Director of Risk Management
The Braun Corporation
Dennis,
As an addendum to my letter of last week, I offer the following: A peripheral, but no less important concern has just been brought to my attention by our marketing folks. It is obvious that the Access Board is concerned with the ever-increasing size of wheelchairs and their occupants. Witness the questions regarding aisle width, and lift load carrying capacity. It is noteworthy to remember that full-size vans and minivans are utilized in many demand responsive applications, where increasing the space required for a tie-down position may negatively impact the number of wheelchair occupants that can be accommodated. We urge the Access Board to be very circumspect about increasing size of the standard tie-down space, as this may adversely impact whether these smaller type multipurpose passenger vehicles and buses can be used to cost effectively transport wheelchair bound passengers.
Thanks again,
Barry E. Wolff
Director of Risk Management
The Braun Corporation
631 West 11th Street
P.O. Box 310
Winamac, Indiana 46996
' voice: (800) 946-7513 ext. 3024
' fax: (574) 946-2341
* email: [email]