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

T402 Ramps and Bridgeplates

The technical requirements for ramps and bridgeplates in the 2016 Non-Rail Vehicle Guidelines include provisions on design load, installation and operation, emergency operation, surfaces, clear width, edge guards, running slope, transitions, visual contrast, gaps, and stowage. These technical requirements are organized in similar fashion to the proposed rule; they also remain the same substantively as in the proposed rule, with the exception of the requirements for maximum ramp running slopes. Section T402 has been slightly revised to clarify that the ramps and bridgeplate barriers must be a minimum height of 2 inches, but allows them to be reduced to less than 2 inches when they are within 3 inches of the boarding end of the device. This accommodates wheelchair users’ need to turn as they enter and exit the ramp and reduces the likelihood that passersby will trip on the barrier.

The Access Board received several comments relating to technical specifications for the design load of ramps. In the 2010 NPRM, the Board proposed to retain the existing requirement that ramps and bridgeplates longer than 30 inches (as well as lifts) be required to have design loads of 600 pounds (273kg) minimum. See 2010 NPRM, T303.2. These commenters – including a transit agency, an advocacy organization, and two transportation research centers – urged the Board to update (i.e., increase) the specified design loads for lifts and ramps because, over time, occupied wheeled mobility devices have gotten heavier (e.g., larger or more complex devices, growing obesity rates).

While the Board acknowledges the trend towards heavier wheeled mobility devices and other factors having a tendency to increase the weight of various potential ramp-based boarding and alighting scenarios, we do not believe a revision in the existing minimum design load for ramps and bridgeplates is advisable at this time. Additional research directed at evaluating design loads for ramps in buses and vans, as well as potential effects of increase in minimum design load on vehicle design or operation is needed. Moreover, it is also important that any potential revision of requirements for minimum design loads for ramps be coordinated with design loads for public lifts specified in the Federal Motor Vehicle Safety Standards (FMVSS), which are incorporated by reference in the technical specifications for lifts in the final rule. See 2016 Non-Rail Vehicle Guidelines, T403.1. The Board also notes that the design load specified in T403.1 is a minimum requirement. Ramp manufacturers and transit operators are free to develop and use ramps with increased design loads as they deem appropriate. Indeed, there are several commercially available ramp models that have rated load capacities that exceed 600 pounds. 

A bus manufacturer commented that the Federal Motor Vehicle Safety Standards (FMVSS) permit marking of the sides of the barriers to indicate the surface boundaries and warn passersby of a tripping hazard. Nothing in the final rule prevents this additional high contrast marking.