Memorandum - NHTSA

11-2
In developing the Final Rule, NHTSA has relied extensively on the Access Board and Federal
Transit Administration (FTA) sponsored guidelines, as well as standards and recommended
practices/procedures of other organizations, such as the Department of Veteran Affairs (DVA)
[formerly the Veterans Administration (VA)] and the Society of Automotive Engineers
(SAE).2,&,3The DVA requirements and the SAE draft recommended practices are intended foi,
the private, personally-licensed lift user (e.g., a disabled person with a modified van or MPV).
The Access Board's guidelines were adopted from FTA sponsored active and passive lift
guidelines, and are believed to reflect the capabilities of lift equipment on the market today. The
FTA guidelines were developed by a large panel of regulators; transit bus owners/operators; ussrs
and bus manufacturers in the 1986-87 time NHTSA added requirements beyond the
Board's guidelines that are based on the FTA guidelines. Most lifts are currently being market(:d
and designed around the FTA's guidelines, and the improvements required by NHTSA in the
Final Rule are not expected to increase lift costs significantly.
The agency identified a number of reasonable safety improvements in the SNPRM, not contair ed
in the Access Board's guidelines. These improvements include: upgraded outer barrier height
2 VA Standard Design and Test Criteria for Safetv and Quality of Automotive Wheelchair Lift Systems fig
Passenger Motor Vehicles, VAPC-A-7708-3, June 28, 1977
3National Workshop on the Bus-Wheelchair Accessibility, Guideline Specifications for Active Wheelchllir
(WC) Lifts, Passive WC Lifts, WC Ramps, and WC Securement Device ,UMTA Publication-UMTA-ITO6-0322-87,
May 1986
4 National Workshop on the Bus-Wheelchair Accessibility, Guideline Specifications for Active Wheelchiiir
(WC) Lifts, Passive WC Lifts, WC Ramps, and WC Securement Device ,UMTA Publication-UMTA-IT06-0322.87,
May 1986