36 CFR Part 1192 Americans with Disabilities Act (ADA) Accessibility Guidelines for Transportation Vehicles (2016 Non-Rail Vehicle Guidelines) - Preamble

D. Chapter 3: Building Blocks

Chapter 3 in the 2016 Non-Rail Vehicle Guidelines has been significantly reorganized from the proposed rule. Chapter 3 in the 2016 Non-Rail Vehicle Guidelines contains the technical requirements related to three areas—walking surfaces (T302), handrails, stanchions, and handholds (T303), and operable parts (T304)—that formerly were located in a different chapter in the 2010 NPRM. See 2010 NPRM, Sections T802 (Surfaces), T804 (Additional Requirements for Handrails, Stanchions, and Handholds), and T805 (Operable Parts). While relatively few commenters addressed the proposed technical requirements in the 2010 NPRM relating to these three areas, some of these comments did lead the Board, as discussed below, to slightly revise the provisions in Chapter 3 of the final rule.

T302 Walking Surfaces

The technical requirements for walking surfaces include provisions on slip resistance, the maximum size of surface openings, and the maximum height of vertical surface discontinuities (i.e., changes in level), with and without edge treatment. Exceptions are also provided for certain openings in wheelchair securement system components affixed to walking surfaces and for manual placement and removal of ramps and bridgeplates (as, for example, on small buses or vans in cases of emergency), as well as walking surfaces on steps that are not part of onboard passenger access routes.

With respect to slip resistance, a bus manufacturer urged the Access Board to incorporate specific measures for slip resistance (i.e., maximum and minimum friction coefficients) in the final rule. The Board declines to adopt this recommendation. As with our other existing accessibility guidelines for the built environment and other areas, we do not specify in this rule any coefficients of friction because a consensus method for rating slip resistance still remains elusive. While different measurement devices and protocols have been developed over the years for use in the laboratory or the field, a widely accepted method has not yet emerged. Since rating systems are unique to the test method, specific levels of slip resistance can only be meaningfully specified according to a particular measurement protocol. Some flooring products are labeled with a slip resistance rating based on a laboratory test procedure.

Another commenter, a transportation research center, noted that the wheelchair securement systems used in many non-rail vehicles—especially small buses and vans—are floor mounted and have openings that allow wheelchair tie downs to be attached using the openings. As a consequence, this commenter observed that most securement systems would not satisfy the proposed maximum opening in walking surfaces (i.e., passage of a sphere no more than 5/8 inch or 16 mm in diameter). See 2010 NPRM, Section T802.3). To address this concern, an exception has been added to the final rule that allows a larger opening (7/8 inch width maximum) for wheelchair securement system components affixed to walking surfaces, provided that, where such openings are greater than 5/8 inch in width, they visually contrast with the rest of the walking surface. See 2016 Non-Rail Vehicle Guidelines, T302.3, Exception 1. We do not, however, adopt this commenter’s additional suggestion that wheelchair securement system components be exempted from the surface discontinuity requirements, which, in their view, was needed due to concerns about the commercial availability of products that meet this standard. We have identified several recessed or flush-mounted securement systems currently on the market that would comply with the requirements in the final rule. Accordingly, the final rule does not exempt wheelchair securement systems from compliance with the technical requirements for surface discontinuities in T302.4.

T303 Handrails, Stanchions, and Handholds

The technical requirements for handrails, stanchions, and handholds include specifications on edges, cross sections, and clearances (i.e., space between gripping surface and adjacent surface). We received only one comment on the proposed technical requirements in the 2010 NPRM related to the cross section of seat-back handholds. In the 2010 NPRM, we proposed that gripping surfaces with circular cross sections (such as those used on seat-back handholds) have an outside diameter of 1 1/4 inches minimum and 2 inches maximum. A seating manufacturer expressed concern that larger diameter handholds would result in significant industry-wide expense and lead to potential safety issues because greater rigidity would be less likely to absorb energy on impact. This commenter suggested that the Access Board instead harmonize with specifications for seat-back handholds in APTA’s model bus procurement guidelines, which provide a 7/8 inch diameter (minimum) handhold with quantification of minimum energy absorption for the seat back and handhold.¹⁶ APTA’s model bus procurement guidelines are well-established in the public transportation industry, and the Board is unaware of any concerns regarding the smaller seat-back handhold minimum specified in those guidelines. Accordingly, in the final rule, the Board has lowered the minimum dimension for seat-back handhold cross sections from 1 ¼ inches (32 mm) to 7/8 inches (22 mm). See T303.3.1.

T304 Operable Parts

The technical requirements for operable parts in the 2016 Non-Rail Vehicle Guidelines remain the same as in the proposed rule; however, they have been slightly reorganized so that all requirements are consolidated into a single section, T304. The technical requirements for operable parts include provisions on height, location, and operation. Operable parts on fare collection devices serving passenger access routes, stop request systems, wheelchair spaces, and priority seats must comply with these technical requirements.

In the 2010 NPRM, the Access Board proposed to raise the minimum height of operable parts in non-rail vehicles from 15 inches to 24 inches. See 2010 NPRM, Section T805.2. A commenter to the 2008 Draft Revised Vehicle Guidelines noted that some operable parts—such as those on stop request devices—are small and difficult to reach for some transit users. To address the problem, the commenter suggested raising the specified minimum height for operable parts. No commenters objected to the revised minimum height (24 inches) for operable parts in the proposed rule. A transit agency did note that, based on a survey of its existing bus fleet, all operable parts on its buses were already mounted higher than 24 inches. Accordingly, the Access Board believes that compliance with this revised minimum height for operable parts—which has been retained in the final rule (see T304.2)—is unlikely to cause transit agencies to incur new costs or significantly alter existing practices.