Wheelchair

Status Report on the Use of Wheelchairs and Other Mobility Devices on Public and Private Transportation
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Easter Seals Project ACTION 1425 K Street, NW Suite 200 Washington, D.C. 20005
About Easter Seals Project ACTION

The United States Congress established Easter Seals Project ACTION (ESPA) in 1988 to promote and facilitate cooperation between transportation providers and people with disabilities. ESPA receives funding through a cooperative agreement with the U.S. Department of Transportation, Federal Transit Administration, and is administered by Easter Seals Inc. Easter Seals Project ACTIONthe acronym stands for Accessible Community Transportation In Our Nation strives to make the Americans with Disabilities Act work for everyone in both worlds, extending resources to all that are free of charge. These include technical assistance and a toll-free number (800-659-6428 between 9 a.m.-5 p.m., Eastern Time, Monday through Friday), Web site (www. projectaction.org), and training activities at meetings and conferences. Easter Seals Project ACTION was established in 1988. ESPA also offers more than 100 print, video and audio resources from a physical and online clearinghouse. We are pleased to add this Status Report on the Use of Wheelchairs and Other Mobility Devices on Public and Private Transportation to the collection.
Easter Seals Project ACTION 1425 K Street NW Suite 200 Washington, D.C. 20005 www.projectaction.org (202)347-3066 (800)659-6428 (202) 347-7385 (TDD) (202)737-7914 (Fax) March 2008
Prepared for Easter Seals Project ACTION by Nelson/Nygaard Consulting Associates San Francisco, California
Project Advisory Committee

Janet Abelson, Oakland, Calif., chair of Alameda County Transit and Bay Area Rapid Transit Accessibility Advisory Committees Billy Altom, Pine Bluff, Ark., executive director, Delta Resource Center for Independent Living Dennis Cannon, Washington, D.C., senior transportation/facility accessibility specialist for U.S. Access Board Bob Carlson, Washington, D.C., technical assistance specialist, Community Transportation Association of America (CTAA) Marilyn Golden, Berkeley, Calif., policy analyst, Disability Rights Education and Defense Fund (DREDF) Chris Hart, Boston, Mass., project coordinator, Adaptive Environments Donna McNamee, Grand River, Ohio, member and immediate past president, Board of Trustees, LAKETRAN (Lake County, Ohio Regional Transit Authority) Larry Schneider, Ann Arbor, Mich., research professor, University of Michigan Transportation Research Institute; chair, ANSI/RESNA Committee on Wheelchairs and Transportation; co-director, Rehabilitation Engineering Research Center for Wheelchair Transportation Safety Sue Stewart, Seattle, Wash., transit safety officer, King County Metro Linda van Roosmalen, Ph.D., Pittsburgh, Pa., assistant professor, Department of Rehabilitation Science and Technology, School of Health and Rehabilitation Sciences, University of Pittsburgh; task leader, Rehabilitation Engineering Research Center for Wheelchair Transportation Safety Tom Whelan, Longmont, Colo., product director, Sunrise Medical, Inc. Annette Williams, San Francisco, Calif., manager of accessible services, San Francisco Municipal Railway Nelson\Nygaard Team Richard Weiner, Connie Soper, Norm Ketola, Jeff Flynn, San Francisco, Calif., Nelson\Nygaard Consulting Associates Doug Cross, Oakland, Calif., Douglas J. Cross Transportation Consulting Roderick L. RL Grubbs, Atlanta, Ga., principal, Accessible & Universal Design Research & Training Katharine Hunter-Zaworski, Ph.D., P.E. , Corvallis, Ore., associate professor, Transportation Engineering, Oregon State University
Preface
The Status Report on the Use of Wheelchairs and Other Mobility Devices on Public and Private Transportation is a very needed and informative document. I would like to congratulate Easter Seals Project ACTION, Nelson/Nygaard, the Project Advisory Committee and all other involved parties for creating this essential piece of work. The Advisory Committee for this report represents some of the best professionals with disabilities and disabled activists in the United States. On July 26, 1990, President George H.W. Bush signed the Americans with Disabilities Act into law. The ADA is a comprehensive Civil Rights law that gives people with disabilities the same rights as all others who reside in the United States. It covers public as well as private entities to ensure that people with disabilities are not discriminated against unfairly in this country. The transportation provisions cover bus, rapid rail, commuter rail, light rail, ferries, paratransit services, sidewalks and pedestrian access and privately operated transportation services. Since passage of the ADA, new technologies have been introduced in the areas of boarding and securement, and new designs for different types of wheelchairs have been developed. This report looks at the current issues of seniors and people with disabilities boarding and being secured on public transportation vehicles. Safe boarding and proper securement are critical to ensuring a safe ride for all passengers. If people feel safer and more comfortable with riding transit, they will more frequently utilize public transportation services. Once again, my congratulations to all who helped produce this report. Let us all work together to create an accessible and safe ride for everyone. Michael Winter Senior Program Analyst International Research Office Federal Transit Administration U.S. Department of Transportation
(Michael Winters role as a leader in transportations public sector and the field of disability rights spans two decades. Prior to his arrival at the FTA in Washington, D.C., he served on California transit boards and as president of the National Council on Independent Living, helping to lead the grass-roots effort to achieve the Americans with Disabilities Act. Before recently achieving a new career milestone in the FTAs International Research Office, he served as director of the Office of Civil rights.)
Table of Contents
How to Use this Document.............................................................................................. 4 Executive Summary........................................................................................................ 4 Chapter 1. Background.................................................................................................9 Problem Statement. .......................................................................................................10 About the Study............................................................................................................. 11 Chapter 2. Transit Vehicle and Equipment Design. .................................................13 Description of the Issues...............................................................................................14 Space and Maneuvering on Board Vehicles..............................................................14 Lift and Ramp Boarding. ............................................................................................14 Best Practices...............................................................................................................15 Recommendations........................................................................................................15 Chapter 3. Wheelchair Design, Purchasing, Usage and Prescription....................17 Description of the Issues...............................................................................................18 Oversized Wheelchairs. .............................................................................................18 Non-wheelchair Mobility Aids.....................................................................................18 Other Items Carried with Mobility Devices. ................................................................18 Best Practices...............................................................................................................19 Recommendations........................................................................................................19 Chapter 4. Transit Operations and Training. ............................................................21 Description of the Issues...............................................................................................22 Securement Issues. ...................................................................................................22 Transit Personnel Proficiency and Awareness...........................................................22 Training Standards and monitoring of service performance.......................................23 Best Practices...............................................................................................................23 Transit System Policy Statements and Educational Information................................24 Training Program Elements........................................................................................24 Auxiliary Aids..............................................................................................................24 Transit System Performance Monitoring....................................................................25 Recommendations........................................................................................................25 Chapter 5. Regulation and Policy..............................................................................27 Description of the Issues...............................................................................................28 Progress in making Transit-safe wheelchairs available...........................................28 Elements of Federal Guidance...................................................................................29 Best Practices ..............................................................................................................30 Recommendations........................................................................................................31 Appendix......................................................................................................................33 Appendix A: Project Methodology.................................................................................34 Appendix B: Annotated List of Documents Reviewed...................................................39 Appendix C: Survey Tool...............................................................................................52 Appendix D: Statistical Results of Survey.....................................................................60 Appendix E: Summary Issues from the Perspective of Consumers..............................68 Appendix F: Links to Relevant Regulatory Sources......................................................72 Appendix G: Samples of Informational Brochures .......................................................73
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How to use this document

This report represents a snapshot of current issues and promising practices regarding the Use of Wheelchairs and Other Mobility Devices on Public and Private Transportation. A goal of this study is for the findings to serve as a practical tool and guidance for the following types of groups: Transportation provider agencies and related organizations/associations Disability advocacy and service organizations Consumers Manufacturers (of mobility devices, vehicles, securement equipment, etc,) Government transportation regulatory and funding agencies Government and private health care funding agencies Consistent with this goal, this report includes a listing of topics for development of potential new best practices, educational/training materials, research and demonstration, or policy guidance. It is intended to serve as a catalyst for advancing the ability of providers to serve their riders with disabilities more effectively and safely, and for riders to make the best use of the services available to them. It is also intended as an advocacy tool to encourage manufacturers to design safely transportable mobility devices as well as to design vehicles and equipment that can accommodate a greater variety of devices.
Using the ramp of a low-floor bus
Executive Summary
Wheelchair usage on fixed-route transit has increased dramatically in recent years as improvements have been made to vehicle design, and wheelchair users become more active in the community. Some transit agencies report more than 10,000 annual wheelchair boardings on their buses. Despite these ridership trends, changes in wheelchair designs are often at odds with improvements in transit vehicles and securement equipment that have occurred since the passage of the Americans with Disabilities act. Many, if not most, new power wheelchairs and scooters do not provide adequate securement points to ensure they can be safely accommodated on public transit. Standards that were developed to include attachment points on mobility devices (WC19) are not well known by consumers and their support services, and the new designs are available on only a fraction of wheelchair models. Other challenges include transit equipment design, transit operations and training, and regulatory and policy issues.
How to Use this Document
In response to concerns within the transportation industry and the disability community on this important topic area, Easter Seals Project ACTION (ESPA) selected Nelson\Nygaard Consulting Associates to prepare a comprehensive national report on the status of the current use of wheelchairs and other mobility devices on public and/or private fixed-route and paratransit vehicles. The Nelson\ Nygaard team included: ADA policy and practice experts The Director of the National Center for Accessible Transportation A mobility device engineering research and development expert A consultant who is the chair of the American Public Transportation Associations Wheelchair User Issues Subcommittee and who was also a former transit agency accessibility and paratransit manager In addition, report findings were reviewed by a 12-member advisory committee representing a broad range of perspectives, including those of the transit industry, the disability advocacy community, and wheelchair and vehicle manufacturers. In addition to report review, committee members provided significant input into the report content. Four approaches were adopted to complete this report: Review of more than 50 documents that address pertinent regulations, industry standards, public transportation industry policies and practices, wheelchair industry information, technical research and synthesis reports Interviews with key stakeholders representing diverse perspectives: those of advocates, transit agencies, wheelchair and vehicle manufacturers Web-based survey of more than 100 wheelchair users Policy roundtable conference call with key stakeholders The report synthesizes the results of these research efforts by identifying the key issues, documenting current best practices in the field, and identifying areas that require further research or greater guidance to transportation providers and riders with disabilities. The research methodology, an annotated bibliography, and survey results are detailed in appendices to the report. The report highlights key issues in the following areas: Example of a non-traditional wheelchair Oversized wheelchairs Space and maneuvering onboard vehicles Lift and ramp boarding Issues with oversized wheelchairs Non-wheelchair mobility aids Other items carried with mobility devices Securement issues Transit personnel proficiency and awareness Training standards and monitoring of service performance Progress in making transit-safe wheelchairs available Clarification needed in federal guidance Research and development to support industry-wide standards and new design approaches Education and dissemination of available resources
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The report then provides a distillation of the best practices identified through the teams research and concludes with a series of topics for development of potential new best practices, educational/training materials, research and demonstration, or policy guidance, as summarized in the following table:
Issue area Transit Vehicle and Equipment Design
Issues Space and maneuvering on board vehiclesconstrained spaces Lift and ramp boardingsteep angles and reliability
Recommendations For manufacturers and mobilityrelated industries: Develop industry standards or guidelines for wheelchair space layouts, aisle clearances, placement of securement equipment, etc.; to be used by both vehicle purchasers and manufacturers/designers. Increase development and real-world (in transit service environment) demonstration of new technologies. For transit providers: Encourage standardized wheelchair securement equipment by retrofitting older vehicles with updated equipment, and increase or improve maintenance programs for older wheelchair lifts. Routinely involve advisory committee members and drivers in the selection of new and replacement vehicles.
Executive Summary
Issue area Wheelchair Design, Purchasing, Usage and Prescription
Issues Oversized wheelchairsincreasing number of chairs that dont fit into minimum ADA vehicle standards Non-wheelchair mobility aids segways, strollers Other items carried with mobility devicesoxygen, large backpacks
Recommendations For wheelchair users: Learn about the dimensions established for wheelchair space aboard transit vehicles For vendors and prescribers: Be cognizant of the dimensions established for wheelchair space aboard transit vehicles, clearly including this aspect in dealings with wheelchair users For wheelchair manufacturers: Develop guidelines for manufacturers to use in making information about transit friendliness of mobility devices accessible and available to prospective purchasers
Issue area Transit Operations and Training
Issues Securement issues customer preferences, variety of devices, securement policies, ergonomics, time Transit personnel proficiency and awarenesssensitivity, securement skills Training standards and monitoring of service performance inconsistent, little direct monitoring
Recommendations For the industry: Development of a template type of document that can be used by transit systems to educate customers of accessibility features and more Development and dissemination of model training program elements Development of best-practice policies and guidelines for accommodating Segways and other non-traditional mobility devices Development of guidelines on how to implement wheelchair marking and tether strap programs Dissemination of best practices or guidelines for monitoring transit system performance regarding mobility aid accommodations
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Issue area Regulation and Policy
Issues Progress in making WC19compliant wheelchairs available limited outreach to users Education and dissemination of available resourceslimited and inconsistent
Recommendations For the industry: Additional research Examination of barriers to making WC19-compliant mobility devices available to transit users. Activities: Development of guidelines for transit providers on how/why to choose mandatory vs. optional rider choice policy for securement. Increased coordination of various regulations that affect mobility device accessibility and design.
Chapter 1. Background
Problem Statement About the Study
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Problem Statement
The need to accommodate travel by passengers with disabilities on various transportation modes has increased dramatically in recent years, with some transit agencies reporting more than 100,000 annual wheelchair boardings on their buses. Fixed-route ridership is increasing as wheelchair users become more active in the community, the nations fixed-route transit bus fleet nears 100 percent accessibility, and transit agencies implement more accurate ADA paratransit eligibility screening processes, thereby shifting a portion of paratransit ridership to fixed-route service. Wheelchairs and scooters have evolved into a wide range of varied and complex designs, often without traditional frame joints that can accept vehicle tie-down devices. This has been exacerbated by the development of newer securement systems to promote less cumbersome, faster securement performance. The newer systems tend to utilize hooks instead of the older buckle or clasp closures, sometimes resulting in less flexibility for attaching to non-traditional wheelchair frame geometries. In April 2000, WC19 Wheelchairs Used as Seats in Motor Vehicles was approved by the American National Standards Institute (ANSI) and the Rehabilitation Engineering and Assistive Technology Society of North America (RESNA) as a U.S. standard. Wheelchairs that meet the design and performance requirements of this voluntary standard are labeled to show that they comply with WC19. A WC19 wheelchair has four crash-tested securement points where tie-down straps and hooks can be easily attached so the chair can be effectively secured to the vehicle. Although an increasing number of wheelchair models are being designed and tested to be WC19-compliant, many mobility devices on the market, especially scooters, are not available with this option. Moreover, for a variety of reasons, the percentage of WC19-compliant mobility devices in actual use is much lower than the number of models that can be purchased with this important feature. But WC19 standards are not well known by consumers and their support services. It is not uncommon for third-party funding sources, which cover most of the costs of most mobility devices, to deny coverage for WC19-compliant features, forcing the end-user to either pay for these features out of pocket, or skip them. An increasing number of mobility aids are also too large or difficult to maneuver in order to board transit vehicles. Several research and development projects are under way to improve the situation. Some of these projects are being conducted within the Rehabilitation Engineering Research Center (RERC) on Wheelchair Transportation Safety, funded by the National Institute for Disability and Rehabilitation Research (NIDRR), and include testing of innovative new securement designs, evaluating existing securement devices, occupant restraints and crash testing requirements, and investigating new universal docking and rear-facing compartmentalization solutions. However, these are long-term prospects, and could require significant change in federal regulations to implement. Meanwhile, there is a fast-growing need to find a way for wheelchair users, manufacturers, dealers and medical funding agencies to offer and use devices that are more readily compatible with securement systems used on various modes of public transportation. In short, the most immediate and significant progress for both safety and usability can be achieved by increasing the number of WC19 wheelchairs available and in use. Dialogue on wheelchair (and other mobility aids) usage on vehicles is needed to determine priority topics of concern, the kinds of standards that are needed, and how existing standards can be more effectively implemented. Education is needed for wheelchair users, manufacturers, securement equipment and vehicle suppliers, transit managers, and medical funding and regulatory entities on the benefits of proper securement and WC19 wheelchairs.
Chapter 1. Background
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About the Study

In response to concerns within the industry and the disability community on this important topic area, Easter Seals Project ACTION (ESPA) selected Nelson\Nygaard Consulting Associates to prepare a comprehensive national report on the status of the current use of wheelchairs and other mobility devices on public and/or private fixed-route and paratransit vehicles. The primary focus of this study is on wheelchair users who remain seated in their wheelchairs when traveling in public and private vehicles. However, the study necessarily encompasses a very broad range of disciplines and stakeholders, as well as technical, operational and policy issues that have important roles regarding transportation for travelers seated in wheelchairs. In order to explore the breadth of issues and generate a report of substantive value to key stakeholders, the Nelson\Nygaard team employed four distinct approaches: literature review stakeholder interviews Web-based survey of wheelchair users policy roundtable conference call with key stakeholders. The following chapters present a synthesis of the key issues that emerged from research and document current best practices in the field. Areas are identified that require further research or greater guidance to transportation providers and riders with disabilities. The research methodology, including detailed results of a survey of the consumer perspective, is detailed in a series of appendices. Since this topic has been the focus of increased attention during recent years, policy, practice and regulations are constantly changing. For example, during the course of this project the U.S. Access Board released a notice of potential amendments to the accessibility requirements for vehicles and systems which were not finalized prior to the release of the study. As a result, some of the regulatory guidance sought by stakeholders who provided input to the report may well be addressed in the near future. This report therefore represents a snapshot of current issues and practice, and should serve as a catalyst for advancing the ability of providers to serve their riders with disabilities more effectively and safely, and for riders to make the best use of the services available to them. Consistent with the goal of ESPA, the objective of this study is ultimately to enhance the ridership experience of those who use wheelchairs and other mobility devices on public and private transportation. The following chapters represent a synthesis of the key issues, barriers, promising practices, and recommendations for further research in the use of mobility devices on public and private transportation that emerged from a literature review, stakeholder interviews and a policy roundtable (see appendices for details on research methodology). While this listing of issues has been selected to reflect what we believe to be the most salient concerns in the field, we have made no attempt to determine the veracity of all of the issues or to quantify the degree to which they are problems. Such an effort would be beyond the scope of this study, but may well be appropriate for additional research. Essential to discussion is the perspective of transit passengers, and the views of those who participated in,the survey are described. Current best practices are presented in the context of applicable issues.
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The issues and promising practices described in the following chapters cover the use of the following devices: Manual wheelchairs Power wheelchairs Scooters (3and 4wheeled) Walkers Segways Crutches, canes and other assistive devices Non-mobility aid devices (bicycles, tricycles, go-ped scooters, carts, gurneys, etc.) Oxygen tanks and other durable medical equipment The study addresses the status of accommodating and securing these devices on various types of vehicles, including: Public and private paratransit vehicles Taxis Fixed-route and over-the-road buses
Power Wheelchair (rear wheel drive)
3-wheeled scooter
4-wheeled scooter
Segway
Power Wheelchair (mid wheel drive)
Note: Some of the issues identified in the following chapters were included in the draft guidance released by the Access Board on April 11, 2007. Depending on the commentary received and follow-up actions by the board, it is possible that some of these issues may be addressed within months of the release of this report.
Chapter 2. Transit Vehicle and Equipment Design

Description of the Issues Space and Maneuvering on Board Vehicles Lift and Ramp Boarding Best Practices Recommendations
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Description of the Issues

Space and Maneuvering on Board Vehicles
Interior space is limited on vehicles, wheelchair sizes are increasing, and more problems are being encountered with less maneuverable devices. The trend toward low-floor large urban buses with ramps (as opposed to traditional high-floor buses with lifts) has exacerbated space and maneuverability issues, and also brings more potential for difficulties with ramp boarding, especially where steep angles are encountered due to lack of curbs. Maneuverability also depends on the location of the Minivan with rear ramp ramp. A rear-door ramp provides more clearance to reach the securement location than a front-door ramp, but it can be more difficult to maneuver the bus to position a rear-door ramp for boarding from the curb. Second, where the ramp must deploy to streetlevel, the angle is measured from the street, not from the curb. Improvements have been made in bus design to alleviate problems with the farebox or other structures at the front of the bus from impeding a wheelchair riders maneuverability, but some wheelchair users who have experienced difficulty in the past may not be aware of such improvements and therefore may shy away from using fixed-route transit. Small vehicles such as minivans can present even more serious challenges than other vehicles due to inherent space constraints and vehicle suspension characteristics. Issues differ for smaller, paratransit vehicles than for larger, fixed-route buses. Nevertheless, each type can be prone to problems with mobility aid maneuvering space and securement equipment placement if careful attention is not paid in designing interior layouts. There is a lack of standardization of vehicle interiors, related to the size of wheelchair spaces and placement/usability of securement equipment. Poor vehicle layouts sometimes exacerbate the other issues. The problem occurs when new vehicles are purchased and different seating layouts or other features are selected, without full understanding of the relationship between components.
Lift and Ramp Boarding

DOT ADA regulations require transit personnel to provide boarding assistance as necessary, which can include pushing a manual wheelchair up a ramp. This includes situations in which either a manual or power wheelchair user attempts to navigate a ramp that is too steep. The steeper the ramp, the more likely it is that boarding assistance will be necessary, so transit operators should have an incentive to ensure the lowest slope possible. Problems persist with the reliability of accessibility equipment such as bus lifts, which are sometimes related to maintenance issues with older equipment. Various generations of older securement equipment are still in use alongside newer, more modern devices, resulting in a confusing array of equipment
Example of a poorly placed shoulder belt in a securement system
Chapter 2. Transit Vehicle and Equipment Design
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that bus operators and customers must understand and use. While lifts are sometimes replaced and rehabilitated, they are not always given high priority in relation to other maintenance needs even though there are requirements concerning lift maintenance under DOT ADA regs.
Best Practices
Size the wheelchair lift, ramp, aisle way, and securement location dimensions to provide for accommodation of at least the common wheelchair dimensions, as well as maneuverability and ability to reach and use securement equipment. When buses are in early stages of procurement, test wheelchair layouts via a configuration audit. Along with consumer/disability advisory involvement, a surrogate common wheelchair is sometimes used in place of or in addition to a sample wheelchair, sometimes referred to as the box test (although the latter can have technical limitations). Have the first article prototype tested by mobility aid users at the transit system. This is also helpful toward identifying any outstanding issues before general production begins. (NOTE: Some systems are testing a rear facing securement approach, especially in BRTbus rapid transitapplications.) Pilot the new, innovative boarding approaches such as double-folding ramps (to minimize the angle that may cause difficulty boarding where the surface is not close to the bus floor), and rear-door ramp entry (to minimize difficulty maneuvering to securement locations).
Recommendations
For the industry: Develop industry standards or guidelines for wheelchair space layouts, aisle clearances, placement of securement equipment, etc., to be used by both vehicle purchasers and manufacturers/designers. Included could be the development of surrogate wheelchairs or other methods for testing maneuvering clearances, as well providing for consumer/ disability advisory input. Increase development and real-world (in transit service environment) demonstration of new technologies for innovative securement solutions and entry designs, including evaluation of approaches such as rear door entry. For transit providers: Encourage standardized wheelchair securement equipment and increase or improve maintenance programs for older wheelchair lifts. Approaches could include technical assistance, joint purchasing programs, and prioritization by funding sources. Routinely involve advisory committee members and drivers in the selection of new and replacement vehicles.
Chapter 3. W heelchair Design, Purchasing, Usage and Prescription
Description of the Issues Oversized Wheelchairs Non-wheelchair Mobility Aids Other Items Carried with Mobility Devices Best Practices Recommendations
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Oversized Wheelchairs
Oversized wheelchairs, meaning devices that are larger and/or heavier than the ADAs common wheelchair definition, are being encountered by transit providers. (In some cases, even common wheelchairs are encountering difficulties due to failure on the part of vehicle manufacturers to provide adequate clearance as required under DOT ADA regs). Agencies have difficulty transporting large or heavy wheelchair/user combinations. Larger and heavier power wheelchairs and scooters, combined with passenger size, cannot always be accommodated within existing transportation vehicles. For example, there may be an inability to maneuver into or out of lifts, ramps and securement areas; damage may be caused to lifts; and weight distribution may be a problem on smaller vehicles. Significant customer service and operational problems and confusion also exist, such as how to determine when a mobility aid actually cannot or should not be accommodated as opposed to merely falling outside the ADA common wheelchair parameters, and how to determine whether there are viable alternatives for such customers. Fixed-route transit providers have varying responses to carrying oversized mobility aids, ranging from allowing whatever will fit on vehicles, to denying service to any mobility aid/user combinations that exceed the ADA definition. Some paratransit agencies are screening out oversized or overweight wheelchairs during the ADA eligibility certification process. While they are not necessarily finding the applicants ineligible, the effect in some instances where the applicant has no alternative device is to make it impossible for them to ride paratransit.
Non-Wheelchair Mobility Aids

The use of non-traditional mobility aids is increasing and there is confusion and lack of uniformity in how they are accommodated. Examples are wheeled walkers with seats, Segways, orthopedic strollers and other devices. Segways, where encountered, pose unique challenges such as how the machines are to be stowed on the vehicle. A related issue is that numerous non-mobility aids, such as shopping carts, bicycles, baby strollers also vie for spaces intended for wheelchair users.
Other Items Carried with Mobility Devices

People may carry backpacks, shopping bags, oxygen tanks or other devices onto the bus, or attached to their wheelchairs. This may exacerbate problems of maneuverability and access to securement points on the mobility device, and can also block the aisles for other passengers, especially in fixedroute bus services. There is limited guidance on how best to accommodate these devices, such as if/how oxygen tanks should be secured.
Chapter 3. Wheelchair Design, Purchasing, Usage and Prescription
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Best Practices
Manufacturersstatements of model specifications that include dimensions, weight, and turning radius, aa Ride Safe brochure and www.travelsafer.org Web site by RERC-WTS at University of Michigan, describing wheelchair transportation safety and standards; WC19Your Ticket to Ride in, including a list of WC19-compliant wheelchairs at the RERC WTS Web site http://www.rercwts.org/WC19 Floor demonstration models at wheelchair dealers that are equipped with Transit or Transport equipment (such as WC19-compliant) Checklists used for evaluation of wheelchair purchasersneeds in order to configure the most appropriate device, including whether they will take public transportation. This can be provided by prescribers, health care insurers/funders, or wheelchair vendors, especially those with training and certification such as RESNA-certified Assistive Technology Suppliers (ATS). WTORS manufacturerstraining materials, including training videos
Recommendations
For wheelchair users: Learn about the benefits of transit-safe mobility devices. For vendors and prescribers Increase coordinated efforts to educate wheelchair users about the benefits of WC19-compliant mobility devices. An example is broad promotion of materials such as the current Ride Safe brochure and www.travelsafer.org Web site by RERC-WTS at University of Michigan, describing wheelchair transportation safety and standards, but tailored more for educating people involved in mobility device purchasing decisions (see Appendix E). For wheelchair manufacturers Development of guidelines for manufacturers to use in making information about transit friendliness of mobility devices accessible and available to prospective purchasers For funding entities Extend coverage eligibility to include WC19-compliant options/equipment [NOTE: Insurers/CMS/other 3rd parties will argue that WC19-complilant equipment is unnecessary for in the home use; however, it may be very essential for transportation to medical appointments, etc.]
Chapter 4. Transit Operations and Training

Description of the Issues Securement Issues Transit Personnel Proficiency and Awareness Training Standards and monitoring of service performance Best Practices Transit System Policy Statements and Educational Information Training Program Elements Auxiliary Aids Transit System Performance Monitoring Recommendations
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Securement Issues
Some transit passengers refuse or prefer their wheelchair not be secured. Lack of independence, the stigma of special attention (or holding up the bus), and fear of mobility aids being damaged are a few of the reasons cited for non-securement. Wheelchair users may also experience discomfort with the invasive physical contact that may be required. Mobility devices are increasingly difficult to secure because of a lack of identifiable tie-down attachment points on wheelchairs, incompatibility of some newer securement systems with wheelchair frame structures, and limited space in vehicles. Some stakeholders, including consumers/advocates and transit industry professionals, indicated a preference for a universal securement method, and for wheelchair vendors to better inform customers about whether wheelchairs are transit friendly. Some consumer advocates report they would not support any requirement that such features be mandatory due to concerns that this could interfere with full mobility. Transit personnel also experience difficulty with the ergonomics of attachment points on wheelchairs that are hard to reach, and with conflicts and challenges related to physical contact/exposure with the wheelchair user while performing wheelchair securement and positioning occupant restraints. Drivers and caregivers are sometimes injured while performing securement, and customers indicate that the time taken for securement on busy routes has been a reason given for pass-ups by bus drivers. Both customers and transit personnel are annoyed by dirty, twisted, or missing tie-down straps and occupant restraint belts. [NOTE: A good pre-trip inspection should include a check of the securement equipment, as well as cycling the lift/ramp.] In rail transit, securement policies and designs are highly variable and often not well explained or understoodthe ADA does not require tie-downs, and a variety of vehicle interior layouts are used, from simple open areas to passive compartmentalization or basic tie-downs such as wheel clamps.
Example of a mobility device that is difficult to secure.
Transit Personnel Proficiency and Awareness

Some consumers report that drivers are not sensitive to their needs, and dont listen to how devices should be secured, or say they cant do it or dont know how to. This is part of a larger issue that includes ongoing problems such as wheelchair users being passed by at bus stops, inoperative lifts on vehicles, and other barriers to using fixed-route transit services. It is required under 49 CFR 37.173 that each public or private entity which operates a fixed-route or demand-responsive system shall ensure that personnel are trained to proficiency, as appropriate to their duties, so that they operate vehicles and equipment safely and properly assist and treat individuals with disabilities who use the service in a respectful and courteous way.
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Training standards and monitoring of service performance

Training and disability awareness of transit provider personnel is variable and sometimes inadequate or inconsistent concerning mobility aid accommodations, resulting in ongoing problems. Transit provider training on proper boarding and securement procedures is not standardized among various national train-the-trainer programs, and can be highly variable at the local transit system level. Such training is sometimes not given to agency personnel who may need it, such as managers and customer service personnel who handle passenger issues, risking a position of violating the requirement cited above. Diligent monitoring of transit drivers will help to ensure proper performance and reduce the incidence of anecdotal reports and customer complaints. Some transit systems use secret rider or other type of Wheelchair securement policy posting on fixed-route bus. monitoring, sometimes in conjunction with monitoring of ADA announcements.
Best Practices
Transit System Policy Statements and Educational Information
Service guides, including print and alternate formats, should describe system accessibility features and policies. Availability on a Web site will help meet accessibility needs. Policies with clear statements of transit system responsibilities/limitations, as well as customer responsibilities, should include: Statement of assistance that will be provided by vehicle operators Size limitations of vehicle mobility aid accommodations Policy on securement (mandatory or optional)
Caveat language re: transporting mobility aids that cannot be secured or if securement equipment is missing or broken
Statements recommending (but not mandating) transferring to a regular seat Use of occupant restraints (including optional on fixed-route)
Special policies and procedures for Segways Instructions on stowage of portable oxygen, walkers, shopping carts, and other nonwheelchair items (also how orthopedic strollers will be treated)
Posting of wheelchair securement policies in conspicuous locations in vehicle interiors, such as by decals, advertising-type cards, posters, or other signage Wheelchair securement policy posting on fixed-route bus Auditory and visual message board announcements on transit vehicles explaining securement policies. This has been especially useful to transit systems instituting new policies, such as moving from optional to mandatory securement.
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Offering of orientation to vehicle features for transit customers, especially new wheelchair users. This can be part of traditional travel training programs, or offered separately, and can be encouraged by the use of courtesy cards handed out by vehicle operators when they encounter a passenger having difficulty. Transit system participation in disability conferences and product expositions, ideally with both educational materials and actual vehicle demonstrations Press releases and news coverage of improvements such as new bus securement equipment, training programs, wheelchair marking/tether strap programs, etc.
Training Program Elements

How-to guides that use pictures and/or videos to demonstrate technical issues of securement (including some videos that show what can happen when securement is not done properly) Using a variety of types of wheelchairs and scooters in hands-on practicum sessions, especially on each type of vehicle in use Visiting local wheelchair dealers, either to understand wheelchair features or to actually do training such as for wheelchair marking/tether straps Inviting wheelchair-using transit customers and disability advocates to participate in training. Incorporating wheelchair boarding and securement into simulated driving practice throughout new driver training, instead of relegating it to a single class Addressing proper use and placement of seatbelts, not just wheelchair securement, in training materials Sign-off sheets that both trainees and trainers sign to document successful proficiency and understanding of procedures Use of quiz-type tests to gauge proficiency in classroom information
Wheelchair with tether strap (front) and markings (rear)
Wheelchair securement as a component of roadeo driving skill competitions Tips on proper ergonomic practices to minimize risk of injury while performing securement Vehicle operators should be periodically evaluated on their ability to safely and effectively secure wheelchair users Staff in addition to vehicle operators receive training in accessibility accommodations and disability awareness (including supervisors, managers, and customer service staff)again, in compliance with 49 CFR 37.173.
Auxiliary Aids
Wheelchair securement-point marking and securement-loop programs Auxiliary straps or other devices for securing oxygen tanks, Segways, or other non-wheelchair items A boarding belt, which is used by some paratransit providers to secure the passenger to their wheelchair and to provide extra safety and comfort during lift boarding Kneeling pads, reaching tools and other equipment to aid in use of securement equipment by vehicle operators Ergonomic reviews of existing transit vehicle interiors to identify space and equipment issues that may need to be addressed in order to provide training instructions or equipment replacement/ retrofit guidelines
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Transit System Performance Monitoring

Use of secret rider programs or professional monitors to observe mobility aid boarding and securement performance, both on a random basis and targeted based on specific complaints Tracking of complaints in detailed categories that include mobility aid boarding and securement in order to track trends and identify issues. Statistics should be shared with all interested partiestransit system management staff, policy boards, disability advisory committees, and the public. Stakeholder perspectives varied on whether this information should be made universally available, or whether it should initially (or only) be provided to transit agency staff, boards and advisory committees. Reports would in any case be available to the public through open records legislation (sunshine laws), but limiting their initial distribution could ensure that limited staff resources could be assigned to correcting deficiencies rather than responding to media inquiries.
Recommendations
For Public Transportation Providers Development of a template type of document that can be used by transit systems to explain:
Mobility aid accessibility features on vehicles and at transit facilities, including what to know about how various sizes, weights, maneuvering capabilities, and baggage/medical devices can be accommodated Policies and procedures for boarding and securement Information about the benefits of transit-safe mobility devices Availability of transit vehicle orientation and/or travel training for mobility aid users Information on auxiliary aids such as wheelchair marking and tether strap programs
This information can be used in riders guides, accessible services guides, Web sites, brochures, posters (including onboard vehicles). Photos, diagrams, and other graphic presentation methods should be used to illustrate features and concepts as much as possible. Development and dissemination of model training program elements Development of best practice policies and guidelines for accommodating Segways and other non-traditional mobility devices Development of guidelines on how to implement wheelchair marking and tether strap programs, including ensuring that participation is voluntary on the part of riders and that operating personnel must perform securement appropriately for those who choose not to participate Dissemination of best practices or guidelines for monitoring transit system performance regarding mobility aid accommodations
Chapter 5. Regulation and Policy

Description of the Issues Progress in making Transit-safe wheelchairs available Elements of Federal Guidance Best Practices Recommendations
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Progress in Making Transit-safe Wheelchairs Available
Use of wheelchairs with specific securement attachment points, such as WC19-compliant wheelchairs, can improve safety during transportation and make securement easier and faster, but so far there is little industry implementation or consumer/public understanding of this voluntary industry standard type of approach. Wheelchair manufacturers include information about transit options or transportation features in product literature about models that have these features available, but the information is often difficult to find. The WC19Your Ticket to Ride Web page of the Rehabilitation Engineering Research Center on Wheelchair Transportation Safety (RERC WTS) Web site (www.rercwts.org) contains a list of available models equipped with these features. At the same time, it should also be noted that custom seating configurations may affect the availability of OEM (original equipment manufacturer) WC19 features, if such features were designed into the OEM seating instead of the base. There is a general belief that education is needed for consumer, transit providers, third-party payers, and government agencies regarding the costs vs. benefits of transit-safe wheelchairs, and that transportation safety should be included as a basic feature of wheelchairs. There is some belief that voluntary industry standards are not enough, and that some type of mandatory requirements will be necessary. However, it is not clear which sector(s) should have such mandates applied to them, which agencies would issue and regulate such guidelines, and how they would be applied in the end, since one cannot unilaterally declare all current mobility devices unsuitable for transit. Wheelchair manufacturers have not seen a market demand for transit-safe features, and voluntary industry standards carry less weight when viewed beside allowances under insurance and other funding guidelines (such as CMS coding). Issues such as the Medicare in-home limitation present significant barriers. The use of wheelchairs as seats in motor vehicles has not historically been addressed through the specifications issued for purchasing wheelchairs by major purchasers such as Veterans Administration and Centers for Medicare and Medicaid Services/CMS. Also, many people with disabilities have specific seating requirements that dictate custom seating systems from after-market specialists such as Motion Concepts, and care would be needed to ensure that the need for a high-end seating system would not somehow remove transportation from the users list of daily activities. The transportation industry must remember Example of a securement point that the inside of a transit bus should not be regarded as the native environment for mobility equipment, and that the seating, above all else, must be compatible with the individual users specific requirements. Addressing this issue and including WC19 features in wheelchair specifications would provide a significant incentive to manufacturers to develop transit-safe wheelchairs. Most wheelchair manufacturers, including those with products that comply with WC19, do not advertise or mention the availability and importance of purchasing WC19 products for people who travel while seated in their wheelchairs. Consequently, consumers are less likely to be aware of WC19 wheelchairs.
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Most transit providers and some vehicle and equipment manufacturers agree that some type of certification of wheelchairs and scooters compatible with use of transit should be mandatory. Such certification would include size, maneuverability, and secure-ability. However, consumer advocates are justifiably concerned about the use of this certification as the basis for denying access to non-certified devices, and none of the federal entities with ADA-related responsibilities have the statutory authority to regulate the design or use of medical devices such as wheelchairs There appears to be a great need for solutions to be sought through processes that include all relevant stakeholders in a coordinated WC19 attachment point placement. manner, which does not seem to have been done in the past. For example, full participation in discussions regarding WC19 wheelchairs by CMS and other health care funding agencies has not yet been a priority.
Elements of Federal Guidance

From the customers perspective, inconsistency of optional vs. mandatory securement policies from community to community may also be confusing: She may be accustomed to having the option of riding unsecured on her home system, and face service denial on another citys transit system if she attempts to exercise this option. The U.S. Access Board is currently updating guidelines for buses and vans. The updated guidelines were released in draft form for public comment in April 2007. The draft revisions have not been integrated into this document, but may be reviewed on the Access Board Web site along with the comments received through the following Web page: http://www.access-board.gov/news/vehicle-comments.htm. The existing ADA vehicle specifications require a combination of design and performance criteria for tie-down and occupant restraint devices (in order to prevent wheelchairs from moving about inside the vehicle). Some stakeholders indicated confusion regarding how wheelchairs should be expected to fit or maneuver into vehicles based on the ADA vehicle specifications. For example, the minimum required wheelchair parking space is the same as the maximum wheelchair size that must be accommodated. The requirement for sufficient clearances to permit a wheelchair or other mobility aid user to reach a securement location (38.23 [a]General) does not say how this should be measured, as opposed to detailed treatment of this issue in the architectural requirements of the ADAAG. It is also placed apart from the section on the required location and size of the securement space (38.23 [d]7Securement devices), even though the latter section also discusses proximity to the vehicle entrance. (NOTEthis issue is being addressed in the proposed Access Board revision.)
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Research and Development to Support Industry-Wide Standards and New Design Approaches
Voluntary industry standards and ADA vehicle requirements are not in harmony, and the result can be less-than-ideal vehicle configurations. The ideal securement system for large urban buses may not be the best approach for small vehicles. For example, the defacto standard (actually just a common practice in terms of equipment design) of four-point tie-downs is not uniformly agreed upon or followed. In some cases, such as on busy urban routes, the time and ergonomics involved in securing a customers wheelchair may not seem feasible to a transit operator. Transit managers have expressed the desire for a more universal, automatic, and less physically complicated and demanding system for securing wheelchairs. Historically, however, the transit provider segment of the industry has not been very involved in developing standards, and has relied mainly on ADA compliance as its guide, rather than seeking out best practices that may exceed ADA requirements. Potential alternative securement technologies, such as docking and the European/Canadian rear-facing passive compartmentalization approach are being studied by wheelchair-oriented research bodies for possible new ANSI/ISO standards. Research, demonstration and testing of these new technologies in the transportation arena has been very limited in the U.S., but interest is being spurred by the development of bus rapid transit services, where speed and efficiency of boarding are critical. However, it should be noted that the operator can simply elect not to have a mandatory securement policy. Another potential design alternative is the improvement of space and maneuverability by using rear (second) door boarding, instead of front door boarding. However, little or no research and development has occurred on this topic.
Education and dissemination of available resources

Information regarding WC19 wheelchair options is not well disseminated for consumers and prescribing health care professionals, and even wheelchair dealers (end vendors). Transit accessibility information, including policies, is inconsistently communicated to customers and the public. Information regarding wheelchair accommodations and policies of transit systems varies greatly from city to city, and is not available at all in many places. Some, but not all, transit agencies have mandatory securement policies. Knowledge of auxiliary securement aids, such as wheelchair marking and tether strap programs, is limited, not all systems have been tested to meet basic safety standards, and guidelines or specific standards are lacking.
Best Practices
Auxiliary securement aids, such as wheelchair marking and tether strap programs can promote safe and fast securement and are offered by a number of transit providers and disability service organizations. Transit orientation programs (travel training and/or vehicle orientation sessions for wheelchair users) and marketing materials are good ways to train passengers on how to board vehicles and to know what to expecting terms of securement and other safety aspects. Appendix G provides examples of helpful informational brochures.
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Recommendations
For the industry:
Additional research Examination of barriers to making transit-safe mobility devices available to transit users, including regulations and policies of healthcare funding programs and agencies. Activities Development of guidelines for transit providers on how/why to address rider choice in their policy for securement, including analysis of how civil rights (ADA) objectives relate to safety and liability issues (common carrier standard of care, tort liability, etc.), as well as how to enforce and educate customers regarding mandatory securement policy. It is recommended that U.S. DOT counsel be involved in this effort. Increased coordination of various regulations that affect mobility device accessibility. A short-term measure could be creation of an index on the FTA Web site (and for use in related documents) that itemizes the locations of various regulations, guidance, and interpretations related to mobility aid accessibility in public transit.
Appendix
Appendix A: Project Methodology Appendix B: Annotated List of Documents Reviewed Appendix C: Survey Tool Appendix D: Statistical Results of Survey Appendix E: Summary Issues from the Perspective of Consumers Appendix F: Links to Relevant Regulatory Sources Appendix G: Samples of Informational Brochures
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Appendix A: Project Methodology

Each of the methodological approaches used for this study is described in this appendix. The findings of the research are synthesized in Chapters 2 through 5.
Literature Review
The purpose of this task was to review existing relevant literature and current materials and practices in order to inventory the following types of information: Civil rights and safety rules and regulations Transportation industry policies, practices, and customer/public information Wheelchair and health-care industry policies, practices, and consumer information Technical research and knowledge Examinations of overall issues, policies, and experience/attitudes, including disability advocacy perspectives The types of materials reviewed included Transit Cooperative Research Program (TCRP) reports, agency practices, U.S. Department of Transportation (DOT) and Federal Transit Administration (FTA) publications and documents sponsored by research and disability advocacy organizations. A database was compiled that includes document name, publication date, methodology, reason for the study, a brief summary, and specific findings, best practices, or issues identified. The information from this database may be found in Appendix B. The issues identified in these documents are synthesized in the key issues listed in Chapters 2 through 5 of this report. Following is a brief listing of the sources used in the literature review: Regulations U.S. ADA regulations and related guidance for transportation services and vehicles U.S. Highway safety regulations for vehicles (passenger lifts/ramps, occupant restraints, etc.) Industry Standards American National Standards Institute (ANSI) standards for transit safe wheelchairs and transportation vehicle wheelchair tie-down and occupant restraint systems (WTORS) of ANSI/ Rehabilitation Engineering and Assistive Technology Society of North America (RESNA) Ride Safe brochure and www.travelsafer.org Web site by Rehabilitation Engineering Research Center on Wheelchair Transportation Safety (RERC-WTS) at the University of Michigan, describing wheelchair transportation safety and standards; also WC19/Your Ticket to Ride info at http://www.rercwts.pitt.edu/WC19 Public transportation industry policies, practices and information Individual transit system riders guides, Web site descriptions, brochures, and policy statements concerning mobility aid accommodations Transit industry training program materials related to mobility aid accommodations, including programs of the National Safety Council, National Transit Institute, and Community Transportation Association of America, and securement equipment manufacturers Wheelchair Industry Information Manufacturersproduct literature showing wheelchair model specifications that include dimensions, weight and turning radius, and availability of transit or transport equipment (such as WC-19compliant)
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Technical Research
Transit IDEA Project 38: Assessment of Rear Facing Wheelchair Accommodation on Bus Rapid Transit, Oregon State University (Transportation Research Board), 2005 Standards and Anthropometry for Wheeled Mobility, State University of New York, Buffalo, 2005 (with funding from the U.S. Access Board) TCRP Synthesis 5 : Use of Rear-Facing Position for Common Wheelchairs on Transit, Transit Cooperative Research Program (Transportation Research Board), 2003 Wheelchair Users Injuries and Deaths Associated with Motor Vehicle Related Incidents, National Highway Traffic Safety Administration, 1997 Tri-Wheeled Scooters Transported on Buses and Vans: Assessment of Securement Restraint Issues, Volpe National Transportation Systems Center (Federal Transit Administration), 1995 The Development of an Independent Locking Securement System for Mobility Aids on Public Transportation Vehicles, Oregon State University (Federal Transit Administration), 1992
Issue Syntheses and Status Reports Wheelchair Access: Improvements, Standards, and Challenges, Douglas J. Cross (conference proceedings of American Public Transportation Association), 2006 State-of-the-ScienceWorkshop on Wheelchair Transportation Safety, Final Report, Rehabilitation Engineering Research Center on Wheelchair Transportation Safety (National Institute on Disability and Rehabilitation Research), 2005 The Current State of Transportation for People with Disabilities in the United States, National Council on Disability, 2005 Riding a Bus While Seated in a Wheelchair: A Pilot Study of Attitudes and Behavior Regarding Safety Practices, Universities of Pittsburgh, Louisville, and Colorado; Rehabilitation Engineering Research Center on Wheelchair Transportation Safety (National Institute on Disability and Rehabilitation Research), 2005 (survey of 283 wheelchair users about their experiences on public, fixed-route buses) Oversized/Overweight Mobility Aids: Status of the Issue, Easter Seals Project ACTION, 2004 Synthesis of Securement Device Options and Strategies, National Center for Transit Research, University of South Florida (Florida Department of Transportation), 2002 Progress in Wheelchair Securement: Ten Years After the Americans with Disabilities Act, Oregon State University (Transportation Research Board), 2001
Stakeholder Interviews
The consulting team conducted 22 key stakeholder interviews that were customized to reflect the area of expertise of the interviewee, and were intended to identify key issues, solicit input for dissemination of information on the subject, and generate ideas for further research. The following list illustrates the diversity of perspectives that were solicited as part of this process. Key findings from these interviews are included in the issues discussion in Chapters 2 through 5. Interviews were held with the representatives of the entities listed in the following table.
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Figure A 1: Stakeholder Interview Participants

Transit Providers MTA New York City Transit Metro Transit, Minneapolis, Minn. Utah Transit Authority, Salt Lake City, Utah Link Transit, Wenatchee, Wash. Paratransit Providers Paratransit, Inc., Sacramento, Calif. MV Transportation(which also provides contracted fixed-route transit operations) Wheelchair Manufacturer Pride Mobility Wheelchair Vendor Grandmar, Inc. (Emeryville, Calif.) Vehicle Manufacturer El Dorado National (paratransit) Daimler-Chrysler Commercial Buses (primarily fixed-route buses, but also paratransit-type vehicles) Wheelchair Tie-down and Occupant Restraint System Manufacturer Sure-Lok, Inc. Transit Seating Manufacturer American Seating (AMSECO) Lift/Ramp Manufacturer Ricon Corp. Research Organization ANSI/RESNA COWHAT and RERC-WTS (University of Michigan) National Center for Accessible Transportation (NCAT) /Oregon State University Disability Advocacy Organization Paralyzed Veterans of America California Foundation for Independent Living Centers Federal Regulatory Agency U.S. Access Board U.S. DOT Transit & Paratransit Trade Association American Public Transit Association (APTA) Accessibility Standards Task Force Community Transportation Association of America (CTAA) State and Federal Health Care Funding/Regulatory Agencies State of Washington Medicaid State Department of Transportation Michigan DOT
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Consumer Survey
Survey Development
The objectives of the consumer survey were to engage a cross-section of mobility device users of public and private transportation to: 1) Document experiences and attitudes related to boarding and riding in transit vehicles, including using wheelchair tie-downs and occupant restraint systems (WTORS); 2) Identify usability information that may not be incorporated in current product designs; and 3) Identify training issues The team that was assembled to develop the survey included: ADA policy and practice experts The Director of the National Center for Accessible Transportation A mobility device engineering research and development expert A consultant who is the chair of the American Public Transportation Associations Wheelchair User Issues Subcommittee and who was also a former transit agency accessibility and paratransit manager The team developed a draft version of the survey that was sent out for review and comment by key informants in the disability community. Besides ensuring survey validity, we hoped to build a commitment to distribution of the survey and promote interest in using the resulting report. The draft survey was sent to key informants in the following organizations: National MS Society National Council on Disability U.S. Access Board ADAPT Disability Rights Education and Defense Fund National Independent Living Council American Association of People with Disabilities Paralyzed Veterans of America United Spinal Association Based on comments from team members and key informants, Easter Seals Project ACTION staff, and the Project Manager, the survey was revised, adjusted for the appropriate readability level, and tested. The final survey was composed of 28 multiple-choice, check-all-that-apply, or open-ended questions that allowed for additional comments from respondents. The survey yielded both quantitative and qualitative data to questions addressing barriers, problems, attitudes, knowledge and experiences regarding the use of mobility devices on public and social services transportation.
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Survey Deployment and Recruitment

The final version of the survey was converted for Web presentation using HTML to ensure Web accessibility (the survey tool may be found in Appendix C). An accessible survey template from the Center for Accessible Media was used, and the HTML version of the survey was placed on an Internet server by Nelson\Nygaard. An Action Alert announcement that contained the survey link was sent to key informants and stakeholders in the previously listed disability organizations and disability oriented listservs, and was linked to disability-oriented bulletin boards. The notice was also sent directly to several hundred members of the CATEA Consumer Network Registry (CCN)a national registry of people with disabilities who have agreed to participate in research. Advocacy and stakeholder organizations were asked to post the link on their Web sites and send the Action Alert to their member networks asking mobility device users of public transit to respond to the short survey. The Web link was active for 30 days between Oct. 24-Nov. 24, 2006. The statistical results of the survey are attached as Appendix D and the key findings from this survey are presented in Appendix E.
Appendix B: Annotated List of Documents Reviewed
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1. AC Transit Wheelchair Marking and Tether Strap Program Performing Organization: Alameda-Contra Costa Transit District (AC Transit, Oakland, California) Date: 2002 Reason for Study: Provide information on the AC Transit wheelchair marking and tether strap program. Summary: The primary public information on this program is a brochure (and web site, http://www. actransit.org/pdf/securement.pdf) that explains how the program works. Objectives are increased accessibility of AC Transit buses to individuals using all types of mobility aids, and support for bus operators in performing safe and proper wheelchair securement. 2. Accommodating Mobility Aids on Canadian Low Floor Buses Using the Rear Facing Position Design: Experience, Issues, and Requirements Performing Organization: Rutenberg Design, Inc. Sponsoring Organization: Canadian Urban Transit Association Date: 2000 Reason for Study: To report current experience with the rear facing wheelchair position design in both European and Canadian transit agencies, explore a variety of implementation issues, and identify requirements and conceptual design considerations for further implementation. Methodology: Case studies and interviews were conducted through Canadian and European transit agencies currently using the rear facing securement position. Summary: Rear facing securement originated in Europe and affords the same level of safety to passengers in wheel chairs as is provided to all other passengers, allows for complete independence, adapts to most wheelchair and scooter types and sizes, and does not require the assistance of the driver. Passengers surveyed generally preferred rear facing securement due to the independence given to them. 3. ANSI/RESNA WCT/Volume 4Wheelchairs and Transportation Performing Organization: Rehabilitation Engineering and Assistive Technology Society of North America (RESNA) Date: 2004 (for sections completed; other sections currently under development) Reason for Study: Volume 4, when completed, will contain product standards, including WC18 (wheelchair tie-down and occupant restraint systems, or WTORS), WC19 (wheelchairs, and WC2 (wheelchair seating systems), plus related documents. Summary: This volume of US voluntary industry standards addresses the design, testing, performance and labeling of wheelchairs when they are used as seats in motor vehicles. It also covers Wheelchair Tie-down and Occupant Restraint Systems (WTORS) for use in motor vehicles. The most commonly used method of securing a wheelchair to the floor of the vehicle is a 4-point, strap type tie-down system. The document reviews standards for wheelchair securement points on the mobility device, occupant safety belt placement, user instructions, and product labeling with warnings, reports of performance testing, etc.
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4. Carriage of Mobility Scooters on Public TransportFeasibility Study Performing Organization: MVA LTD, London Sponsoring Organization: Department for Transport (UK) Date: 2006 Reason for Study: Research is required to establish whether the Departments current policy (prohibiting the carriage of scooters) is reasonable and should continue, or whether it should be relaxed so that guidance can be given to operators to permit certain models of scooter to be carried, and if so, what characteristics those models must have. Methodology: A database was developed to catalog the most popular mobility scooters used in the UK, Public transport operators in the UK were contacted to find their current scooter policies, and a literature review of international and domestic documents was conducted Summary: The research highlighted a lack of information both nationally and internationally about the carriage of scooters on public transport. A key recommendation is for further study of limited user trials to inform policy decisions. 5. Current State of Transportation for People with Disabilities in the United States Sponsoring Organization: National Council on Disability Date: 2005 Reason for Study: Identify transportation barriers, promising practices and models, to develop recommendations for expanding mobility options for people with disabilities on public and private transportation. Methodology: Literature review of studies and documents related to fixed route transportation, paratransit, private transportation, other publicly funded transportation and historic reports; Extensive interviews with 3 groups of stakeholders (disabled riders who regularly use public transit, transportation providers and consultants, officials from federal transportation agencies); Review of relevant research studies that are national in scope; Review of primary sources concerning specific transportation programs; Focus group discussions with stakeholders in the disability community Summary: While significant progress has been made in terms of transportation accessibility since the passage of the ADA, gaps remain due to the chronic lack of funding. This is particularly true for mobility options of people with disabilities in rural areas or those who live far from fixed-route bus systems. In other sectors, such as accessible taxis, a lack of requirements has meant very uneven progress. 6. Department of Transportation Disability Law GuidanceUse of Segways on Transportation Vehicles (as displayed on FTA web site: WWW.FTA.gov/Civil Rights and Accessibility/Americans with Disabilities Act/ADA Technical Assistance/DOT Disability Law Guidance) Performing Organization: Federal Transit Administration (FTA), US DOT Date: 2005 Reason for Study: Discussion and guidance on whether transportation entities should permit the Segway personal transportation device to be used on transportation vehicles when used as a mobility device by people with disabilities. The Segway is a two-wheeled, gyroscopically stabilized, battery-powered personal transportation device. It is not designed primarily for use by individuals with disabilities, but some such individuals may use a Segway as a personal mobility aid, in lieu of more traditional devices like a wheelchair or scooter. Methodology: This guidance was approved through the DOTs Disability Law Coordinating Council as representing the official views of the Department on this matter.
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Summary: The Departments ADA rule (49 CFR Part 37, 37.3) defines a wheelchair as a mobility aid belonging to any class of three or four-wheeled vehicles, designed for and used by individuals with mobility impairments.... By this definition, a Segway is not a wheelchair. However, when used as a mobility device, it is part of the broad class of mobility aids that are intended to be accommodated (similar to canes, walkers, etc.), and must be allowed on board buses and trains. Even though specific ADA regulations on lift and securement use for wheelchairs do not apply to Segways, they must be permitted to use the lift if necessary to enter a vehicle. 7. The Development of an Independent Locking Securement System (ILS) for Mobility Aids on Public Transportation Vehicles (DOT-T-93- 8) Author: Katherine Hunter-Zaworski & Joseph Zaworski Performing Organization: Transportation Research Institute, Oregon State University Sponsoring Organization: Office of Technical Assistance, Federal Transit Administration Date: 1992 Reason for Study: Primary objective was to design, build, and test a wheeled mobility aid securement system that would operate with all mobility aids in common use on fixed route transit vehicles. Methodology: Docking securement system was designed and tested in two phases. Phase 1: pilot tests conducted in the laboratory at OSU and Phase 2: field tests conducted at Lane Transit District in Eugene, OR. Summary: The pilot testing was used to determine how easily passengers could use the system and finds bugs in testing protocol. In Phase 2 a real bus was used to determine ease of use and to determine acceleration, deceleration, and turning forces on the ILS system. A scooter and manual wheelchair were used in both phases. An ILS system could maximize mobility aid user independence, minimize transit vehicle operator involvement, minimize securement and release time, and satisfy all the proposed securement standards and guidelines. 8. ISO 7176-19 Wheeled Mobility Devices for Use in Motor Vehicles Performing Organization: International Organization for Standardization Date: 2001 Reason for Study: Establishes international standards that can be applied to wheelchair securement in motor Vehicles (note: this is an international standard that has a comparable and coordinated part in the related US standard, ANSI/RESNA VOLUME 4, as described above.) Methodology: Requirements based on well documented motor vehicle crash statistics Summary: Section 19 of ISO 7176 specifies wheelchair design and performance requirements and associated test methods. The requirements are designed to be secured by any type of wheelchair tie-down in accordance with ISO 1 542-1 and any other applicable parts of the ISO 1 542 series.
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9. Oversized/Overweight Mobility Aids: Status of the Issue Author: Amy Pass & Ken Thompson Sponsoring Organization: Easter Seals PROJECT Action Date: 2004 Reason for Study: To present a snapshot of the current status of issues around safe transport of passengers using oversized and overweight mobility aids. Methodology: Informal surveys of groups with different perspectives (i.e. transit authorities, research organizations, regulatory bodies, standards groups, and others) showed that several problems are at the core of this issue. Survey participants were also asked what resources would best meet their information needs as they deal with these issues. Summary: This is an overview that discusses the issues on the use of oversize or overweight mobility devices by passengers on transit. Research groups and standard-setting bodies continue to investigate the situation and may propose strategies or policy recommendations in the future. 10. PASS - Passenger Service and Safety CertificationTraining Program Performing Organization: Community Transportation Association of America (CTAA) Sponsoring Organization: Community Transportation Association of America (CTAA) Reason for Study: The PASS Certification program was developed to train drivers in proper passenger assistance techniques and sensitivity issues in serving persons with disabilities, primarily in paratransit services. Summary: The PASS program is designed as a three-day Train-the-Trainer course to certify trainers who can then train drivers or as a two-day driver training program in which PASS instructors train an agencys drivers. 11. Policies for Segways on Public Transit Vehicles Author: John Acosta, Senior Deputy General Counsel Performing Organization: TriMet (Tri-County Metropolitan Transportation District of Oregon) Portland, Oregon Date: 2006 Reason for Study: Clarification of US DOT Disability Law Guidance entitled Use of Segways on Transportation Vehicles, vis--vis the ability of public transit providers to adopt reasonable policies, such as those adopted by TriMet, to regulate transport of two wheeled devices, including Segways, on public transit vehicles when used by people with disabilities as mobility aids. Methodology: Review of FTA regulations and background on Segway devices including the evolution of TriMets Segway/Two-Wheeled Mobility Device Policy; testing on TriMet vehicles. Summary: TriMet established a final policy based on testing done with Segways on board both buses and light rail vehicles. The policy was codified as TriMet Administrative Rules for the Transport of a Two-Wheeled Mobility Device on TriMet Vehicles, January 3, 2 5, and can be found at, http://trimet. org/pdfs/code/TriMet_Administrative_Rules_Mobility_Device.pdf. The TriMet policy requires that individuals seeking to transport Segways first receive authorization based on an application, medical certification, attendance at an orientation session, and display of a special identification sticker on the device. Visitors may transport such two-wheeled devices, provided that they have documentation from their home transit system to confirm that they have a disability requiring the use of a mobility device.
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12. Progress in Wheelchair Securement: Ten Years After the Americans with Disabilities Act (Paper # 1-2159) Author: Katharine Hunter-Zaworski and Joseph Zaworski Performing Organization: Oregon State University Sponsoring Organization: Transportation Research Board Date: 2001 Reason for Study: The ADA requires that wheelchairs be secured so they will not move more than 50 mm. This document reviews background on securement and current status of wheelchair securement on public transit as well as presenting recommendations for speeding up acceptance of advanced securement technologies. Methodology: Review of current materials on the subject Summary: Oregon State University has completed a thorough review of securement systems since the passage of the ADA. Docking provided fast, easy securement without driver assistance. The document provides a description of RESNA and SAE agreed standards for belt securement and securement testing parameters. Flexible systems mostly use belts to secure. A four point tie down is the most common example. Belts overwhelmingly used throughout country since easy to adapt to any device. Rigid types include clamps. The clamp type system is more expensive but can prevent motion in all directions if attached to a properly designed attachment point. 13. The Public Service Vehicles Accessibility Regulations 2000 Guidance (Disability Discrimination Act 1995) Performing Organization: Department for Transport (United Kingdom) Date: 2000 Reason for Study: Provide guidance for the public transport manufacturing and operating industries on meeting requirements of regulations to ensure that public service vehicles are accessible for people with disabilities. Summary: The document reviews the legal language presented in the regulations and provides explanations of each, as well as various best practices. The regulations apply to public service vehicles for 22 passengers and above providing local or scheduled service. Varieties of practices are discussed within sections on specific design and feature guidelines. 14. Question & Answers Concerning Common Wheelchairs on Public Transit Federal Transit Administration, ADA Information, Published by the Office of Civil Rights, Volume 1. (as displayed on FTA web site, www.FTA.gov/Civil Rights and Accessibility/Americans with Disabilities Act/ADA Technical Assistance/FTA bulletins) Author: Federal Transit Administration- Office of Civil Rights Performing Organization: Federal Transit Administration, US DOT Reason for Study: To answer common questions transit operators ask about the ADA Summary: Presented in question-and-answer format.
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15. Riding a Bus While Seated in a Wheelchair: A Pilot Study of Attitudes and Behavior Regarding Safety Practices. Assistive Technology. 19(4): 166179. Author: Buning, M.E., Getchell, C.A.(nee Armstrong), Bertocci, G.E. & Fitzgerald, S.G. Performing Organization: Rehabilitation Engineering Research Center on Wheelchair Transportation Safety (RERC-WTS), University of Pittsburgh, Department of Rehabilitation Science and Technology Sponsoring Organization: National Institute on Disability and Rehabilitation Research, US Department of Education Date: 2007 Reason for Study: To examine the real life usage patterns of wheelchair transportation safety equipment such as wheelchair securement systems and occupant restraint systems on disabled passengers. Methodology: A total of 283 wheelchair-using bus riders responded to a 35-item web-based survey investigating their experiences on public, fixed-route buses across the US. Summary: The survey addressed usage of four-point, strap-type wheelchair tie-downs and occupant restraint systems (WTORS), the attitudes and behaviors of wheelchair users toward the use of this equipment and the overall transit experience. 16. Ride Safe Brochure Author: University of Michigan, Transportation Research Institute Performing Organization: Rehabilitation Engineering Research Center on Wheelchair Transportation Safety Sponsoring Organization: University of Michigan Transportation Research Institute, University of Michigan Health System, and the RERC on Wheelchair Transportation Safety Date: 2005 Reason for Study: The purpose of the Ride Safe brochure is to give wheelchair users, therapists, families/caregivers, and transportation providers information on how to provide a safe transportation for wheelchair-seated travelers through effective wheelchair securement, proper use of occupant restraints (seatbelts), and the use of crash tested, WC19 compliant wheelchairs. Summary: Brochure summarizes best practices on securing wheelchairs and occupants all types of transportation vehicles.
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17. Securement of Wheelchairs and Other Mobility Aids on Transit Vehicles Author: Dale Daucher, P.E. Performing Organization: United States Architectural and Transportation Barriers Compliance Board Web site, http://www.access-board.gov/research/WheelchairSecurement/report.html Date: 1990 Reason for Study: Create a brochure to assist transit authorities with information on successful policies and equipment that two transportation authorities developed over ten years. In considering the many types of mobility devices and buses/vans, as well as the variety and sizes of lifts, there is no single solution to accessibility on mass transit vehicles. Methodology: In 1987, Southern California Rapid Transit District (SCRTD) tested 14 wheelchairs/ mobility devices on 6 different lift/bus types. Four criteria were evaluated: length, maneuverability, securement on the lift, and securement in the travel area. Seattle Metro assessed needs and established policies using a subjective approach beginning in 1978. Information came from meetings with the Elderly and Handicapped Task Committee, a citizens task committee, and a task group of bus drivers. Summary: This brochure provides information on the successful ADA policies and experience of SCRTD and Seattle Metro. 18. State of the Science Workshop on Wheelchair Transportation Safety Author: Multiple authors Performing Organization: Rehabilitation Engineering Research Center (RERC) on Wheelchair Transportation Safety (WTS), University of Pittsburgh, Department of Rehabilitation Science and Technology Sponsoring Organization: National Institute on Disability and Rehabilitation Research (NIDRR) Date: 2005 Reason for Study: Review and document the status of wheelchair transportation safety to identify deficiencies and formulate, discuss, and prioritize recommendations for the future. Methodology: RERC staff identified four focus areas and wrote white papers to highlight the status and issues in each area. Focus groups were used to help each participant to generate ideas/responses to various questions. Once ideas and questions had been recorded, group members ranked the ideas. Summary: The RERC-WTS sponsored a State-of-the-Science workshop in January 2005. Approximately 45 people attended, including researchers, disability advocates, wheelchair and transit manufacturers, transit and school bus industry representatives, government policy staff, and health care/rehabilitation professionals.
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19. Synthesis of Securement Device Options and Strategies Author: Jennifer Hardin, Chandra Foreman, and Linda Callejas Performing Organization: National Center for Transit Research (NCTR), University of South Florida Sponsoring Organization: Florida DOT and US DOT, Office of Research and Special Programs Date: 2002 Reason for Study: The transit industry has concerns about the wide variety of mobility devices used by passengers. Efforts to address these concerns have consisted of developing standards for securement devices and for mobility devices used as seats in motor vehicles. Many in the transit industry feel that until these issues are resolved, the safe securement of mobility devices will continue to be a challenge. Methodology: In 2001, surveys were sent to 129 paratransit providers and 22 transit operators in Florida. In addition, 70 non-Florida transit agencies were surveyed. 95 agencies responded in total. Summary: The study discusses the scope and magnitude of wheelchair securement issues facing transit agencies, and presents the results of a survey on securement devices and strategies used throughout Florida and the US. 20. TCRP Report 24Guidebook for Attracting Paratransit Patrons to Fixed Route Services Author: John N. Balog, KETRON Division of the Bionetics Corporation Performing Organization: Transit Cooperative Research Program (TCRP, of the Transportation Research Board, National Research Council) Sponsoring Organization: Federal Transit Administration (US DOT) and the Transit Development Corp. Date: 1997 Reason for Study: The guidebook seeks to develop methods to attract paratransit patrons and others with disabilities to fixed-route transit. Methodology: The guidebook reflects the findings of rider and non-rider surveys, targeted at providing fixed-route transit systems with step-by-step instructions on how to attract individuals with disabilities and other potential riders to fixed route services. Summary: Chapter 5 of the guidebook focuses on developing driver training, with segments on lift operation and wheelchair securement, as well as recognizing and assisting with specific disabilities. Chapter 6 focuses on programming accessible bus stop improvements. Other chapters are about a variety of topics not directly related to wheelchair accessibility and accommodation.
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21. TCRP Synthesis 5 : Use of Rear-Facing Position for Common Wheelchairs on Transit Buses (A Synthesis of Transit Practice) Author: Uwe Rutenberg (Rutenberg Design, Inc.) and Brendon Hemily (Toronto, Ontario, Canada) Performing Organization: Transit Cooperative Research Program (TCRP), Transportation Research Board (of the National Academies) Sponsoring Organization: Federal Transit Administration (US DOT) and the Transit Development Corp. Date: 2003 Reason for Study: To describe the state of the practice of using rear-facing position for accommodating common wheelchairs on large urban transit buses and to identify issues related to its transferability to the United States Methodology: The report provides a synthesis of information from a literature review, surveys and case studies of Canadian transit systems that have adopted the rear-facing position, investigation of manufacturer perspectives, and interviews with experts in other countries: UK, France, Germany, Sweden, and Australia. Also reviewed was the experience of AC Transit in Oakland, Calif., the first US transit agency to use a rear-facing wheelchair position design. Summary: The synthesis identified common design elements for successful implementation of the rearfacing design approach. A preliminary review of ADA requirements indicates that the rear-facing position can be used by US transit systems, provided that certain conditions are met. The benefits associated with this approach make it particularly attractive for Bus Rapid Transit (BRT) systems, given the short dwell times and other needs of high capacity services. However, further study is needed concerning specific system design elements, based on transit system experience and future research on dynamic forces and effective/appropriate design requirements. 22. Transit IDEA Project 38: Assessment of Rear Facing Wheelchair Accommodation on BRT Author: Katharine Hunter-Zaworski and Joseph Zaworski Performing Organization: Oregon State University Sponsoring Organization: Transportation Research Board Date: 2005 Reason for Study: To evaluate the comfort and safety of rear facing securement areas in bus rapid transit operations Methodology: Acceleration and deceleration forces were evaluated using rear and side facing securement on 6 different bus models (30 low floor, 35 low floor, 40 low floor, 40 high floor, 40 doubledecker bus, and 60 articulated bus) in Eugene, Oregon under normal and extreme operating conditions. Three different wheelchair types were used in testing - manual wheelchair, power wheelchair, and a 3-wheeled scooter; in three different positions - backrest only rear facing, side facing with forward wall only, and rear facing with backrest, sidewall, and aisle side armrest. A 50 percentile male dummy with its chest strapped to the backrest of the wheelchair was used in all scenarios. A survey was also conducted of current and potential bus users to determine their opinions on rear facing securement. Summary: The study showed that wheelchair movement was strongly dependent on wheelchair type. Under normal driving, the manual chair would rotate during turns, the scooter would tip over during stronger turns, and the power chair was stable throughout. Under extreme conditions, all three could be made to tip over if provided with only a backrest and a wall on only one side. Survey results show 70% of respondents enthusiastic about rear facing securement, 10% had no opinion, and 20% did not want to use the method. Under normal conditions, scooter and manual users must expect some level of movement with their mobility aid.
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23. Tri-Wheeled Scooters Transported on Buses and Vans: Assessment of Securement Restraint Issues Author: David Spiller Performing Organization: US DOT - Research and Special Programs Administration, Volpe National Transportation Systems Center Sponsoring Organization: US DOT - Federal Transit Administration Date: 1995 Reason for Study: Transit systems are required under the ADA to accommodate all common wheelchairs and mobility aids, including tri-wheeled scooters, provided they meet the size limits (3 x48, etc.) therein defined. Agencies have responded with concerns over the safety of transporting these devices. This report provides an assessment of securement and restraint issues related to the transport of tri-wheeled scooters and their occupants on buses and vans used in public transit service. Methodology: An extensive review of research, test reports, and expert opinions of the technical community was performed to evaluate securement issues with tri-wheeled scooters. Summary: Actual and potential problems were identified, including crash-related issues such as inability to restrain the battery in a crash impact, shearing or fracture of the seat pedestal, large forces that exceed the restraining force of seat designs, and occupant injury from contact with the steering tiller. Non-crash issues include inaccessible and structurally inadequate attachment points, and the proliferation of scooter models that are incompatible with securement systems. Issues that pertain to both categories are the rollover or tipping instability of the device and spillage of battery fluid, unless of the dry or gel-type. The mobility aid user, vehicle, securement devices, and occupant restraints comprise a complex system. Failure to address this can have unintended consequences, including potential injury to the mobility aid user and other passengers. The vast majority of accidents and incidents involving mobility aid users are not crash-related, and result from excessive braking or sharp cornering, or involve lift operations. 24. US Public Transportation RegulationsAmericans with Disabilities Act EXCERPTS related to wheelchair accessibility (from: http://www.fta.dot.gov/ada/adaregs.html and http://www.fta.dot.gov/legal/regulations/us_dot/56 1_56 8_ENG_HTML.htm) TITLE 49 TRANSPORTATION, SUBTITLE A--OFFICE OF THE SECRETARY OF TRANSPORTATION PART 38 - Americans with Disabilities Act (ADA) Accessibility Specifications For Transportation Vehicles, Subpart B: Buses, Vans, and Systems; Sec. 38.23 - Mobility aid accessibility. Sec. 38.29 Interior circulation, handrails and stanchions. Appendix to Part 38--Guidance Material: I. Slip Resistant Surface--Aisles, Steps, Floor Areas Where People Walk, Floor Areas in Securement Locations, Lift Platforms, Ramps III. Handrails and Stanchions TITLE 49TRANSPORTATION, Subtitle A--Office of the Secretary of Transportation PART 37_TRANSPORTATION SERVICES FOR INDIVIDUALS WITH DISABILITIES (ADA) Sec. 37.3 Definitions (excerpt): Wheelchair means a mobility aid belonging to any class of three or four-wheeled devices, usable
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indoors, designed for and used by individuals with mobility impairments, whether operated manually or powered. A common wheelchair is such a device which does not exceed 30 inches in width and 48 inches in length measured two inches above the ground, and does not weigh more than 600 pounds when occupied. Subpart G_Provision of Service 37.161 Maintenance of accessible features: General. 37.163 Keeping vehicle lifts in operative condition: Public entities. 37.165 Lift and securement use. Sec. 37.167 Other service requirements. 37.173 Training requirements. Appendix D to Part 37--Construction and Interpretation of Provisions of 49 CFR Part 37 (INTERPRETIVE APPENDIX) Subpart G--Provision of Service Section 37.161 Maintenance of Accessible Features--General Section 37.163 Keeping Vehicle Lifts in Operative Condition--Public Entities Section 37.165 Lift and Securement Use Section 37.167 Other Service Requirements Section 37.173 Training Final Rule Adopting New Accessibility Standards -- Effective November 29, 2006 SUMMARY: The Department is amending its Americans with Disabilities Act (ADA) regulations to adopt, as its regulatory standards, the new Americans with Disabilities Act Accessibility Guidelines (ADAAG) recently issued by the Access Board, including technical amendments the Access Board subsequently made to the new ADAAG. In adopting the new ADAAG as its standards, the Department is making minor modifications to some of the Guidelines and is providing further guidance concerning its newlyadopted standards. DATES: This rule is effective November 29, 2006. 49 CFR PART 37 Appendix A (editors note: as amended as noted above) (http://www.access-board.gov/ada-aba/final.htm#Facilities) 810 Transportation Facilities 810.2 Bus Boarding and Alighting Areas. 810.3 Bus Shelters. 810.4 Bus Signs.
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25. Wheelchair Access: Improvements, Standards, and Challenges (proceedings of 2006 APTA Bus and Paratransit Conference) Author: Doug Cross, Douglas J. Cross Transportation Consulting Sponsoring Organization: American Public Transportation Association (APTA) Date: 2006 Methodology: Synthesis of existing issues currently facing transit agencies and wheelchair users Summary: This report shows that wheelchair access on transit buses and paratransit is getting more complicated as service providers are faced with accommodating more passengers with an everincreasing diversity of mobility aids. The report also suggests emerging solutions for future study. 26. Wheelchair Access: Issues and Options for the 2000s (proceedings of 2004 APTA Bus and Paratransit Conference) Author: Doug Cross, Douglas J. Cross Transportation Consulting Sponsoring Organization: American Public Transportation Association (APTA) Date: 2004 Methodology: Synthesis of issues currently facing transit agencies and wheelchair users, with examination of new design approaches and industry standards as potential solutions. Summary: The synthesis covers issues rear and mid-door ramps on low floor buses, rear facing securement with backrest, wheelchair marking and tether straps programs, activities related to standards such as ANSI/RESNA WC19 Wheelchairs Used as Seats in Motor Vehicle. 27. Wheelchair Securement on Bus and Paratransit Vehicles Author: Virginia Dong & Robert Smith Performing Organization: California Department of Transportation (CalTrans) Date: 1981 Reason for Study: This report represents the second phase of an ongoing study to evaluate needs for a safe, reliable and easy-to-operate wheelchair securement system. The initial report published the results of 42 tests. Methodology: 59 physical sled tests at various velocity and deceleration levels were performed on a 50th percentile male dummy (165 lbs) in both manual and electric wheelchairs in the forward and side facing positions Summary: Tests on wheelchair securement systems that revealed a wheelchair and its occupant can survive a 200mph/100g crash if properly secured. This definition requires the securement system to symmetrically grip the wheelchair in at least two places and be designed to remain secure at the imposed loads. The occupant should also be restrained with an upper torso belt and a lap belt.
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28. SAE Recommended Practice J2249Wheelchair Tie-down and Occupant Restraint Systems for Use in Motor Vehicles (NOTEthis voluntary industry standard has subsequently been coordinated with and included under ANSI/RESNA Volume 4 standards, as described above) Performing Organization: SAE (Society of Automotive Engineers) Sponsoring Organization: SAE (Society of Automotive Engineers) Date: 1997 Reason for Study: To establish standards for design requirements, test methods, and performance and labeling requirements for wheelchair tie-down occupant restraint systems (WTORS). Methodology: The standard established test methods and performance criteria for a 48-kph, 20-g sled impact test. Summary: This effort established minimum design requirements, performance requirements and associated test methods, and requirements for product labeling and manufacturer instructions and warnings for WTORS. 29. Wheelchair Users Injuries and Deaths Associated with Motor Vehicle Related Incidents (NHTSA Research Notes) Author: Delmas Johnson and Gayle Dalrymple Performing Organization: National Highway Traffic Safety Administration (NHTSA), US DOT Date: 1997 Reason for Study: Conducted to determine the extent to which non-vehicle crash related reasons (improper securement, lift/ramp problems, and related actions) were involved in injury or death to wheelchair users in motor vehicle incidents. Methodology: National Center for Statistics and Analysis (NCSA) examined data from the Consumer Product Safety Commissions (CPSC) National Electronic Injury Surveillance System (NEISS) on cases of injuries or death of wheelchair users involving motor vehicles from 19911995. Summary: Data on non-crash related activity associated with injury or death to wheelchair users were examined to determine the extent to which improper securement or related actions were involved. Activities were classified into five categories: 1) Improper or no securement in the motor vehicle, 2) Collision between a wheelchair and a motor vehicle, 3) Wheelchair lift malfunction (lift fell, did not reach the ground, or person was thrown from the lift), 4) Transferring to or from a motor vehicle and, 5) Falling onto or off of a ramp.
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Appendix C: Survey Tool

Experience of Wheelchair Users on Public Transportation Survey
Easter Seals Project ACTION is surveying the experiences of mobility device users of public and social service transportation (including paratransit) vehicles. Easter Seals Project ACTION is a federally funded research and demonstration program to improve access to public transportation for people with disabilities. Your responses will help clarify ways that public transportation and wheelchair manufacturers can remove barriers to the use of public and social service transportation and improve accommodations for mobility device users. Family members and personal care assistants may also participate in the survey. You should complete this survey if you or the person you care for travels with a wheeled mobility device and uses regular public transportation, paratransit, taxis, and/or medical/social service transportation. This survey will be available until Nov. 24, 2006. The survey will to take approximately 1015 minutes to complete. Your responses will be kept completely confidential: no information obtained through this study will be attributed to you by name. If you have questions about this survey, please contact: RL Grubbs, MA., M.Ed. Georgia Institute of Technology/Wheeled Mobility RERC Principal Investigator for the Project ACTION Study Phone: 404-385-0475 Email: rl.grubbs@coa.gatech.edu
Manual Wheelchair
Power Wheelchair
Wheelchair SecurementSystem
Occupant Restraint (Seat Belt) System
Questionnaire for Mobility Device Users of Public Transit

Please respond to each question on the survey to the best of your knowledge and experience.
Key Definitions
Wheelchair: in this survey, the word wheelchairis often used to identify both manual wheelchairs, power wheelchairs, scooters and other types of wheeled mobility devices. Wheelchair securement system: The four-point tie-down, wheel clamps, or docking type system that anchors a wheelchair to the vehicle floor or rear facing containment. Occupant restraint system: The lap and/or shoulder belt, either mounted to the wheelchair or to the motor vehicle that acts as a seat belt. Occupant restraints are not the same as the positioning belts found on some wheelchairs that are intended for postural support.
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Background
Q1. What is your relationship to the mobility device user? I am the mobility device user I am a family member I provide personal assistant services to a mobility device user Q2. Do you now use any of the following equipment for people with mobility impairments? How long have you used this equipment? (Check all that apply) Less than 1 yr Do not use any Cane Crutches Walker Manual wheelchair Power wheelchair Scooter Lower extremity prosthesis O ther _________________ 1-5 years 6-1 years 11-15 years 16+ years
Q3. What types of accessories/items do you carry onboard when you use regular public transportation, paratransit, taxis, or medical/social service transportation? (Check all that apply) Where do you carry the items? In Back Backpack L aptop computer/ briefcase L uggage/suitcase G rocery/shopping bags S hopping carts/ baskets P ortable oxygen V entilator R eacher O rthopedic baby stroller S ervice animal O ther (specify)______ In Front On the Sides Underneath
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Q4. Do wheelchair securements and occupant restraints (seat belts) cause problems with any part or portion of your wheelchair or any of the above items? Y es N o D ont know
If yes, please briefly describe the problem caused by the securements and/or restraints and what was done to solve the problem. What are the dimensions of the item(s) (height, length, depth, weight, etc)?
_________________________________________________________________________________ _________________________________________________________________________________ _________________________________________________________________________________ Q5. Have you ever been denied transportation because your wheelchair and accessories were too wide or long or too heavy? Yes No Dont know If yes, please briefly describe the situation. What are the dimensions of your mobility device (height, length, width, weight, etc.) and why were you denied transportation? _________________________________________________________________________________ _________________________________________________________________________________ _________________________________________________________________________________
Transportation Usage
Q6. Check the types of transportation services you use and how often you typically use them. (Check all that apply) Daily At least At least Less than Never once per once per once per week month month Do not use any Fixed-route bus Light rail or streetcar Rapid transit or commuter rail ADA paratransit Medical/social service transportation Accessible Taxi Other (specify)______________
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Q7. What problems do you experience boarding the vehicles you checked above? (Check all that apply) Do not have any problems Operators/ drivers do not kneel the vehicle Operators/drivers/gate agents do not help me up/ down boarding ramps Ramps are too steep Ramps are too narrow for my wheels Ramps are slippery, my wheels spin on the ramp when boarding Ramp corners are too high, I cannot roll over ramp corners onto the ramp Ramp edges cause damage to my casters/tires/push rims Ramps do you fold out properly Lifts do not operate Operator/driver says that the lift will not work/wont use lift Lift has malfunctioned while in use Operators/drivers dont allow enough space to approach the lift Operators/drivers/gate agents do not fold up seats to clear the space for my wheelchair My casters get stuck in the space between the train platform and the door of the train Other (please specify) ______________________________________ Q8. What problems do you experience using the fare payment system onboard the bus and/or train? Do not have any problems Cannot reach the card swipe Cannot insert fare due to obstructions Cannot maneuver wheelchair/scooter around the fare payment stand Cannot use fare payment systems due to dexterity limitations Other (please specify) ______________________________________ Q9. What problems do you experience moving between the vehicle door and the securement area? Do not have any problems There is not enough space to turn my wheelchair around The vehicle seats block the area The seat belts get tangled in my wheels I have to maneuver around luggage, bags and baby carriages Other (please specify) ______________________________________
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Q10. When you board a public transit bus, how often is your wheelchair or scooter secured to the floor of the bus? Never Less than half of the times I ride the bus More than half of the times I ride the bus All of the time Other (please specify) _____________________________________________ Q11: How is your wheelchair or scooter usually secured or stabilized? (Check all that apply) It is not secured I put my wheelchair brakes (wheel locks) on I turn the power off I use the seat (lap) belt I use the shoulder belt in addition to the lap belt The frame of my wheelchair is secured with floor tie-downs I use a rear facing containment area Other (please specify) _____________________________________________
Q12: Do you feel your wheelchair or scooter is secure enough using the methods you checked above?
Yes No Q13. If your wheelchair or scooter is not secured, what are some reasons why? (Check all that apply) Operator/driver doesnt know how to secure my wheelchair properly Operator/driver didnt offer or seems unwilling to take the time I prefer not to be secured I use on the postural belts that are attached to my wheelchair Im in a hurry and dont want to take the time myself I dont trust the reliability of the securement and restraint belts The equipment doesnt fit me and /or my wheelchair very well (e.g. armrests, seating system components get in the way) I dont feel that securing my wheelchair or putting on the seat belt is very important I feel that securing my wheelchair or putting on the seat belt is unsafe for me I dont want the bus driver getting so close to me and my equipment Im embarrassed because it takes so long to secure my wheelchair and put on the seatbelts Other (please specify) _____________________________________________
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Q14. If your wheelchair or scooter is secured, what are some reasons why? (Check all that apply) I feel that I will be more protected in the event of a crash I feel that Im safer and more stable in regular bus travel I feel that others around me are safer if my wheelchair is secured The occupant restraint system provides me with more postural support Transit provider/operator makes me have my mobility device secured Other (please specify) _____________________________________________ Q15. When you ask for assistance in securing your wheelchair or scooter, how often does the operator/driver provide such assistance? Always Sometimes Never I never ask Q16. How well do securement systems work with your wheelchair, scooter or other mobility device? Very well With some difficulty Very difficult Dont Know Other (please specify) _____________________________________________ Q17. How well do passenger safety belt systems in buses generally fit you? Usually fit well and are comfortable Usually dont fit me very well Dont know Never use them Other (please specify) _____________________________________________ Q18: Have you ever been in a bus, train, van, or taxi incident where your wheelchair or scooter moved too much or tipped over? No Yes (please provide a brief description, including vehicle/service type, whether your wheelchair was secured and how?) _________________________________________________________________________________ _________________________________________________________________________________ _________________________________________________________________________________
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Q19. How would you describe operator/driver attitudes about transporting people using wheelchair, scooters or other mobility equipment? (Check only one) Generally positive and willing to do whatever it takes to ensure that Im as safe as possible Positive and helpful if they arent in a hurry, but negative and unhelpful if they are in a hurry Generally negative and uninformed about my safety and the safety of my mobility equipment Varies greatly depending on who the operator/ driver is Dont know Other (please specify) _____________________________________________ Q20. How would you describe other passengers attitudes about the time it takes to be secured? (Check only one) Generally patient and understanding Generally impatient Generally negative and uninformed about my safety and the safety of my mobility equipment Dont know Other (please specify) _____________________________________________ Q21. Are you aware that transportation regulations in the Americans with Disabilities Act (ADA) allow transportation providers to provide service to wheelchairs only of a limited size or weight? Yes No Q22. Are you aware that transportation regulations in the Americans with Disabilities Act (ADA) require transit providers to offer securement of wheelchair and occupants, with equipment complying with standards described in the ADA? Yes No Q23. Are you aware that transportation regulations in the Americans with Disabilities Act (ADA) allows transportation providers to make securement of wheelchairs mandatory for passengers, including the use of lap/shoulder belts in cases when everyone else on the vehicle is required to wear them (it is optional on buses and trains where all seats are not equipped with the belts)? Yes No Q24. Are you aware that some wheelchair manufacturers now offer a transit option consisting of permanent brackets or loops for the attachment of vehicle tie-down equipment? Yes No
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Q25: If you were purchasing a new wheelchair, would you be interested in getting this feature on your new wheelchair? Yes, if yes, why? _________________________________________________________________ _________________________________________________________________________________ _________________________________________________________________________________ No, if no, why? __________________________________________________________________ _________________________________________________________________________________ _________________________________________________________________________________ Q26: Please rank your most important information sources for information about transportation safety and wheelchair/mobility devices use. Rank the following from 1 (most important) to 10 (least important). ____ Transit providers ____ Other wheelchair users ____ Vendors (local durable medical equipment sales and service people) ____ Healthcare professionals (doctors, therapists) ____ Health insurance or other sources of funding ____ Vocational rehabilitation counselors ____ Disability/advocacy organizations ____ Magazines, catalogs and other print media ____ TV and radio advertising ____ Internet and Web sites ____ Other (please specify)_______________________________________
DEMOGRAPHICS
Please enter the following information about your gender and age Q27. Gender/Sex Female Male Q28. Year of birth: ___________ Please email me a summary of the report from this survey. My email address is__________________________________________
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Appendix D: Statistical Results of Survey

Q1. What is your relationship to the Use% I am a family member 7 I am the mobility device user 108 I provide personal assistant services to a mobility device 2 user TOTAL 117 Q2. What type of Less than equipment do you use? 1 Year Cane 0 Crutches 2 Walker 3 Prosthesis 0 Manual Wheelchair 5 Power Wheelchair 3 Scooter TOTAL Q3. What types of accessories/ items do you bring with you on public transportation? Backpack Laptop computer/Briefcase Luggage/suitcase Grocery/Shopping Bag Shopping Carts/Baskets Portable Oxygen Ventilator Reacher Orthopedic baby stroller Service animal Other TOTAL 3 16 In Back 73 23 18 27 3 1 0 5 0 0 1 151
6.0% 92.3% 1.7%
1 to 5 years 6 1 6 1 13 16 5 48 In Front 10 19 14 22 10 0 0 2 0 0 7 84
6 to 10 years 3 0 5 0 14 15 8 45 On the Sides 6 3 1 9 0 0 0 9 0 6 4 38
11 to 15 years 4 2 3 1 7 9 6 32 Underneath 5 3 1 2 0 0 0 0 0 0 0 11
16+ years 6 6 5 6 33 28 4 88
Total 19 11 22 8 72 71 26 229
Do not use 74 77 72 80 29 34 66 432
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Q2. What type of other accessories/items do you bring with you? Cane Crutches Lap Tray Purse Tools TOTAL Q4. Do wheelchair securements and occupant restraints cause problems with any part or portion of your wheelchair or any of the above items? Dont Know No Yes TOTAL Q5. Have you ever been denied transportation because your wheelchair and accessories were too wide or long or too heavy? Yes No TOTAL Q6. What types of transportation services do you use and how often? Fixed Route Light rail or streetcar Rapid transit or commuter rail ADA paratransit Medical/social service transportation Accessible taxi Other TOTAL
Responses 2 1 1 7 1 12
Responses
10 78 30 118 Responses 20 95 115 Daily 16 5 3 15 0 0 8 47
8.5% 66.1% 25.4%
% 17.4% 82.6% At least once per week 15 3 8 16 6 1 1 50 At least once per month 8 4 4 18 11 9 1 55 Less than once per month 27 16 21 30 22 39 3 158 Total Excluding Never 66 28 36 79 39 49 13
Never 40 67 63 30 59 51 0 310
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Q6. OtherWhat types of transportation services do you use and how often? Airplane Airport Shuttle Amtrak Drive Self Friend Drives Me TOTAL Q7. What problems do you experience boarding the vehicles you checked above? J. Lifts do not operate L. Lift has malfunctioned while in use K. Operator says that the lift will not work/wont use lift A. Do not have any problems M. Operators/ drivers dont allow enough space to approach the lift Other D. Ramps are too steep F. Ramps are slippery, my wheels spin on the ramp when boarding I. Ramps do you fold out properly O. My casters get stuck in the space between the train platform and the door of the train N. Operators/ drivers/ gate agents do not fold up seats to clear the space for my wheelchair C. Operators/drivers/gate agents do not help me up/down boarding ramps H. Ramp edges cause damage to my casters / tires / push rims B. Operators/drivers do not kneel the vehicle E. Ramps are too narrow for my wheels G. Ramp corners are too high, I cannot roll over ramp corners onto the ramp
Responses 2 1 1 8 1 13 Yes 44 40 37 34 27 27 26 17 17 15
Q8. What problems do you experience using fare payment Responses systems onboard the bus and/ or train? A. Do not have any problems 72 E. Cannot use fare payment systems 17 due to dexterity limitations D. Cannot maneuver wheelchair/ scooter around the fare payment 16 stand B. Cannot reach the card swipe 15 C. Cannot insert fare due to 11 obstructions Other 5 Q9. What problems do you experience moving between the vehicle door and Responses the securement area? A. Do not have any problems 48 B. There is not enough space to turn 44 my wheelchair around E. I have to maneuver around 24 luggage, bags and baby carriages C. The vehicle seats block the area 16 Other 16 D. The seat belts get tangled in my 12 wheels
14 12 10 8 7 4
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Q10. When you board a public transit bus, how often is your wheelchair or scooter secured to the floor of the bus? Never Less than half of the times I ride the bus More than half of the times I ride the bus All the time Other TOTAL Q11. How is your wheelchair or scooter usually secured or stabilized? F. The frame of my wheelchair is secured with floor tie-downs C. I turn the power off B. I put my wheelchair brakes (wheel lock) on D. I use the seat (lap) belt E. I use the shoulder belt in addition to the lap belt A. It is not secured Other G. I use a rear facing containment area Q12. Do you feel that your wheelchair or scooter is secure enough using the methods you checked above? Yes No TOTAL
Responses 14 18 16 45 7 100 Responses 73 58 50 37 34 12 10 5 Responses 69 37 106
% 14.0% 18.0% 16.0% 45.0% 7.0%
% 65.1% 34.9%
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Q13. If your wheelchair or scooter is not secured, what are some reasons why? A. Operator/driver does not know how to secure my wheelchair properly B. Operator/driver did not offer or seems unwilling to take the time C. I prefer not to be secured
G. The equipment doesnt fit me and/or my wheelchair very well (e.g. armrests, seating system components get in the way)
Responses 46 38 15
15
E. Im in a hurry and dont want to take the time myself 8 F. I dont trust the reliability of the securement and restraint belts 3 J. I dont want the bus driver getting so close to me and my equipment 3 D. I use the postural belts that are attached to my wheelchair 2 H. I dont feel that securing my wheelchair or putting on the seat belt is 2 very important I. I feel that securing my wheelchair or putting on the seat belt is unsafe 2 for me Q14. If you want your wheelchair or scooter secured, what are some Responses reasons why? A. I feel that I will be more protected in the event of a crash 73 C. I feel that others around me are safer if my wheelchair is secured 64 B. I feel that Im safer and more stable in regular bus travel 61 E. Transit provider/operator makes me have my mobility device secured 27 D. The occupant restraint system provides me with more 20 postural support Other 4 Q15. When you ask for assistance in securing your wheelchair or Responses scooter, how often does the operator/driver provide such assistance? Always 60 Sometimes 24 Never 1 I never ask 20 TOTAL 105 Here, only 5 percent of responses state that the securement systems are very difficult. Q17. How well do passenger safety belt systems in buses generally fit you? Usually fit well and are comfortable Usually dont fit me very well Dont know Never use them Other TOTAL Responses 33 29 8 24 7 101
% 57.1% 22.9% 1.0% 19.0%
% 32.7% 28.7% 7.9% 23.8% 6.9%
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Q18. Have you ever been in a bus, train, van, or taxi incident where your wheelchair or scooter moved too much or tipped over? Yes No TOTAL Q19. How would you describe operator/driver attitudes about transporting people using wheelchair, scooters or other mobility equipment? Generally positive and willing to do whatever it takes to ensure that Im as safe as possible Positive and helpful if they arent in a hurry, but negative and unhelpful if they are in a hurry Generally negative and uninformed about my safety and the safety of my mobility equipment Varies greatly depending on who the operator/driver is Dont Know Other TOTAL Q20. How would you describe other passengers attitudes about the time it takes to be secured? Generally patient and understanding Generally impatient Generally negative and uninformed about my safety and the safety of my mobility equipment Dont know Other TOTAL
Responses 50 61 111 Responses 42 14 6 43 3 1 109 Responses 64 22 10 8 2 106
% 45.0% 55.0%
% 38.5% 12.8% 5.5% 39.4% 2.8% 0.9% % 60.4% 20.8% 9.4% 7.5% 1.9%
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Q21. Are you aware that transportation regulations in the Americans with Disabilities Act (ADA) allow transportation providers to provide service to wheelchairs only of a limited size or weight? Yes No TOTAL Q22. Are you aware that transportation regulations in the Americans with Disabilities Act (ADA) require transit providers to offer securement of wheelchair and occupants, with equipment complying with standards described in the ADA? Yes No TOTAL Q23. Are you aware that transportation regulations in the Americans with Disabilities Act (ADA) allows transportation providers to make securement of wheelchairs mandatory for passengers, including the use of lap/ shoulder belts in cases when everyone else on the vehicle is required to wear them (it is optional on buses and trains where all seats are not equipped with the belts)? Yes No TOTAL Q24. Are you aware that some wheelchair manufacturers now offer a transit option consisting of permanent brackets or loops for the attachment of vehicle tie-down equipment? Yes No TOTAL Q25. If you were purchasing a new wheelchair, would you be interested in getting this feature on your new wheelchair? Yes No TOTAL
Responses 55 58 113 Responses 87 25 112
% 48.7% 51.3%
% 77.7% 22.3%
Responses
77 36 113 Responses 51 62 113 Responses 82 26 108
68.1% 31.9%
% 45.1% 54.9% % 75.9% 24.1%
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Q26. Please rank your most important information sources for information about transportation safety and wheelchair/mobility device use. Rank the following from 1 (most important) to 10 (least important). Other wheelchair users Disability/Advocacy organizations Vendors (local durable medical equipment sales and service people) Transit providers Internet and Web sites Healthcare professionals (doctors, therapists) Vocational rehabilitation counselors Magazines, catalogs and other print media Health insurance or other sources of funding TV and radio advertising Other Q27. Gender/Sex Female Male TOTAL Q28. Year of birth 65 and Up 55 to 64 45 to 54 35 to 44 25 to 34 24 and under TOTAL
Responses 270 278 360 434 441 481 502 509 584 640 25 Responses 55 53 108 Responses 10 23 34 15 18 6 106
Rank 1 2 3 4 5 6 7 8 9 10 % 50.9% 49.1% % 9.4% 21.7% 32.1% 14.2% 17.0% 5.7%
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Appendix E: Summary Issues from the Perspective of Consumers

This appendix of the report provides the results of the survey referred to in Appendix A. Statistical details of survey findings may be found in Appendix D. While the survey sample was not intended to statistically represent a cross-section of transit riders with disabilities, the findings do present a sampling of the range of issues and experiences of mobility device users.
Participation and Demographics

Almost all the 118 survey respondents (92 percent) were mobility device users, 6 percent were family members and 2 percent provided personal assistance to mobility device users. Respondents represented a mix of mobility device use. The two most common devices were power wheelchairs (68 responses) and manual wheelchairs (67 responses), followed by scooter users (23 responses). Further analysis indicated that 4 of 118 respondents used both a power and a manual wheelchair, 42 used only a manual wheelchair and 31 used only a power chair. Besides the majority of respondents using multiple devices, we also found that the majority used both fixed-route and paratransit services. Unfortunately due to the limited sample size and the need to limit the survey length, we were not able to distinguish between the experiences of those who primarily use fixed-route or paratransit, or primarily use manual or power chairs. Respondents represented a mix of experience with mobility devices. Just over half (53 percent) of manual wheelchair respondents reported using a manual wheelchair for more than 11 years. Just under half of power chair respondents (48 percent) reported 11 years or more power chair use. Scooter users were somewhat less experienced. The majority of scooter users (79 percent) reported using a scooter for less than 11 years. Respondents were almost evenly split between females (51 percent) and males (49 percent). The following table reports age distribution for the sample (106 respondents provided date of birth information). Figure 1 Age Category 65 and Up 55 to 64 45 to 54 35 to 44 25 to 34 24 and Under Totals Age Distribution of Respondents # of % Respondents Percent 1 9 23 22 34 32 15 14 18 17 6 6 106 100*
* Sub-totals have been rounded up, resulting in more than 100 percent
The largest group of respondents was between the ages of 45 and 54. This sample most likely underrepresents elders (65+) and older adults with disabilities. The disproportionate presence of younger persons with disabilities may be due in part to the use of a Web-based survey available online.
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Key Findings
Transportation Service Usage Survey respondents reported using a variety of public and private transportation services. Seventynine respondents (79) reported utilizing ADA paratransit services, and 66 used fixed-route bus service. Almost half of respondents used accessible taxis (49). Thirty-nine used medical/social services transportation, 36 used rapid transit or commuter rail and 28 used light rail or streetcar. For paratransit riders, 19 percent were daily riders, 20 percent rode weekly, 23 percent rode and 38 percent rode less than once per month. A total of 76 respondents (65 percent) used some form of fixed-route transportation (fixed-route buses, light rail/streetcar or rapid transit/commuter rail) at least monthly. Even in such a small sample size, it appears that mobility device users are taking advantage of a wide variety of public and private transportation choices. This finding appears to reflect the trend of increased transit ridership by wheeled mobility device users. Boarding and Maneuvering Seventeen percent of respondents indicated that they were not able to ride public and/or private transportation services because their mobility device could not be accommodated. Some report being denied because of a lack of space, but it is unclear from the small sample of comments whether their mobility devices in fact could not fit in the available space or whether the driver simply stated no, it is over the regulatory limit. Reports of denials included vehicles that would not stop or that stopped, but would not pick up mobility device users. One mobility device user reported being denied service because, I have too many packages. Without extra details, it is difficult to determine whether this was or was not a legitimate denialthere are bona fide limits on carrying packages in public transportation. On the other hand, some drivers may use this as an excuse to avoid providing transportation to a wheelchair user, or be uncertain about agency policies. Given the variety of reasons provided for refusing service to survey respondents, more research and clarification seems warranted. Respondents also encountered mechanical problems while boarding vehicles. Of those who reported encountering mechanical problems, the most often reported boarding problems were: Lifts that did not operate (41 percent) Lifts that malfunctioned while in use (37 percent) Operators who appeared not to be able to operate lifts (34 percent) Once on the vehicle, 41 percent of respondents reported that there was not enough space to turn the wheelchair around. Respondents reported that this was a significant problem because lack of space for turning required the device user to back onto the vehicle and/or into the space. Backing up a wheeled mobility device is a very difficult task and respondents reported doing damage to their mobility device while trying to back into a lift or wheelchair space. Personal Accessories and Equipment The survey responses also reinforced the fact that riders frequently carry a variety of personal items during transit. Respondents were asked about the personal items, accessories and equipment that they typically travel with when riding public and private transportation. Eighty percent of respondents reported carrying a backpack, 51 percent carried grocery or shopping bags, 41 percent carried a laptop computer or a briefcase and 29 percent carried luggage. Fewer respondents reported carrying reaching tools (14 percent) or shopping carts/baskets (11 percent). Five percent traveled with a service animal. One person reported traveling with portable oxygen.
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Most respondents carried backpacks on the back of their mobility device. Shopping bags were carried on the back (45 percent) or front (37 percent) or on the sides (15 percent) of the mobility device. Laptops and briefcases were carried on the back (48 percent) and front (40 percent), or sides (6 percent) or, in some cases, underneath (6 percent) the device. Mobility device users carried with them a variety of personal accessories. This finding provides some evidence of important usability information that needs to be considered in the design of transportation systems and warrants further investigation and research. For more than 25 percent of respondents, current wheelchair tie-downs and occupant restraint systems (WTORS) caused problems with the mobility device and/or with the personal accessories and equipment being carried. Some of the examples cited include: driver secures the restraints on movable parts of the wheelchair such as leg rests, restraints bend the wheelchair arms and seat posts, my large lap tray creates problems with occupant restraints, straps get stuck between the tires and the frame and have to be cut up, occupant restraint gets me in the neck. These cited problems also underscore the need for properly trained transit personnel, in this case, specific training in the attachment of securements. Securement Issues Mobility device users on public transit are generally aware of their own safety and the safety of passengers around them. Sixty-two percent of respondents wanted their device secured to protect themselves in the event of a crash. Respondents reported varying degrees and combinations of usage of wheelchair tie-down and occupant restraint systems (WTORS). A majority of respondents (54 percent) stated that they secure their wheelchairs because they believe that this leads to greater safety for other passengers. Even with this awareness of personal safety, only 45 percent of respondents reported having their device secured to the floor on every bus ride. Fourteen percent of bus riders never have their devices tied down. Vehicle operator error was the most-reported reason for non-use of WTORS. Respondents reported that operators didnt know how to secure the mobility device or that the operator didnt offer or seemed unwilling to take the time to secure their device. It is important to note that about 20 percent of the time respondents never ask operators to secure their device, primarily because of the potential for embarrassment and the rider is in a hurry. Support for WC19 and Informing Users of this Option A significant finding of the survey was the overwhelming support respondents gave the ANSI/RESNA WC19 standard. The standard was described to respondents as a transit optionconsisting of permanent brackets or loops on mobility aids for the attachment of vehicle tie-down equipment. Fortyfive percent of respondents reported being aware of WC19equipped wheelchairs. Seventy-six percent of respondents indicated they would obtain this feature with the purchase of a new wheeled mobility device. Respondents were asked to rank their most important source of information about transportation safety and mobility device use. Other wheelchair users were ranked as the most important source of this information, followed by disability/advocacy organizations and vendors. This finding may suggest that innovation permeates through the disability community differently than in other more traditional consumer product markets. Mobility device manufacturers and transit providers might find it useful to target peer-to-peer networks in the disability community to get the word outabout new and innovative products and standards.
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Training Several training needs emerged from analysis of survey data. Survey respondents linked non-use of WTORS to lack of competency of vehicle operators who dont know how to secure their device or who are unwilling to do so. Sometimes operators wouldnt secure a wheelchair even when the rider asked to be secured. Moreover, 39 percent of respondents indicated that the attitudes of vehicle operators toward transporting mobility device users varied greatly, which reflects a broader problem with driver training that has a particular impact on riders with disabilities. The issue of adequacy of training is a complex problem and requires content input from a variety of experts. Not only do operators need the skills to safely deploy lifts and WTORS, they also need to understand why this is important. It appears that vehicle operators would benefit from competency-based training that is designed to improve attitudes and knowledge as well as provide proficiency in required skills. Survey Conclusions The survey documented three areas of significant issues and problems from the consumersperspective: 1) Boarding and maneuvering problems 2) Problems with mobility device securement and occupant restraint 3) Training issues and needs Survey results indicated broad acceptance of recently developed securement standards that included attachment points on mobility devices, known as the ANSI/RESNA WC19 Transit Option. Establishing peer-to-peer networks within the disability community is an important means of promulgating information about transit options. The common wheelchairenvelope may need to be revisited to understand how variations from it affect wheelchair usersability to ride transit vehicles, and what other approaches may be useful. These approaches could include better defining the needed space within vehicles, and possibly increasing the minimum size and/or weight requirements for mobility aid accommodations. When revisions are explored in response to the current request for comments from the Access Board, they should take into account the maneuverability of various devices. Finally, survey results seem to indicate that for the purpose of transportation system design, anthropometric measures of mobility device users should incorporate measures not only of the person and the device, but appropriate elements of the context of use, specifically what users are carrying during typical rides.
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Appendix F: Links to Relevant Regulatory Sources

Federal Transit Administration ADA Web pages:
http://www.fta.dot.gov/civilrights/civil_rights_236 .html You are here: Home Civil Rights & Accessibility Americans with Disabilities Act Americans with Disabilities Act The Americans with Disabilities Act of 1990 (ADA) prohibits discrimination and ensures equal opportunity and access for persons with disabilities. The Federal Transit Administration works to ensure nondiscriminatory transportation in support of our mission to enhance the social and economic quality of life for all Americans. The FTA Office of Civil Rights is responsible for civil rights compliance and monitoring to ensure non-discriminatory provision of transit services. ADA Technical Assistance DOT Disability Law Guidance FTA Bulletins Toll-Free Assistance Line File an ADA Complaint with FTA National Transit Institute (NTI) ADA Course Offerings Transit Cooperative Research Program (TCRP) Synthesis Projects Federal Highway Administration (FHWA) Guidance on Pedestrian Access for Persons with Disabilities FTA ADA Compliance ADA Compliance Review Final Reports (NOTEthere is extensive discussion of lift maintenance in these reports) Letters of Finding According to Regulatory Section Memorandum of Understanding with the U.S. Department of Justice Results of Recent Collaboration with U.S. Department of Justice: City of Detroit Settlement Order ADA Links
Appendix F: Links to Relevant Regulatory Sources
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Easter Seals Project ACTION DisabilityInfo.gov U.S. Department of Justice ADA Home Page Access for Persons With Disabilities ADA Regulations, Guidance, and Procedures The Americans with Disabilities Act of 19900 PreambleTransportation for Individuals with Disabilities [September 6, 1991] Part 27Nondiscrimination on the Basis of Disability in Programs and Activities Receiving or Benefiting From Federal Financial Assistance Part 37Transportation Services for Individuals with Disabilities Final Rule Adopting New Accessibility StandardsEffective November 29, 2006 Americans with Disabilities Act Accessibility Guidelines (ADAAG) Part 38Accessibility Specifications for Transportation Vehicles Americans with Disabilities ActFull Regulatory History -
[Code of Federal Regulations] [Title 49, Volume 1] [Revised as of October 1, 2005] [CITE: 49CFR37] TITLE 49TRANSPORTATION Subtitle AOffice of the Secretary of Transportation PART 37_TRANSPORTATION SERVICES FOR INDIVIDUALS WITH DISABILITIES (ADA)
Appendix G: Samples of Informational Brochures Get Hooked on VTA and Ride Safe Brochure (following pages)
Get Hooked on VTA!

VTAs securement policy is mandatory, but the option to have mobility devices marked and/or have tethers installed is voluntary. Passengers are encouraged to take advantage of this program so that coach operators and/or attendants can quickly identify where to attach securement hooks. Marking mobility devices involves applying removable colored vinyl tape on areas where hooks can easily be attached and tethers for hooks can be easily installed. Trained VTA employees will: Examine the mobility device to determine the best four points for securement. Affix colored tape to the best securement points on the mobility device. Yellow Tape indicates where securement hooks will be attached. Blue Tape indicates where tethers will be placed.
To Reach Us...
To schedule an appointment to mark and tether mobility devices call VTAs Accessible Services Department at (408) 952-4249.
Effective January 1, 2007
For trip planning or other route information, contact:

VTA Customer Service Call Center . . . . . (408) 321-2300 From 650 area code and South Santa Clara County toll area . . . (800) 894-9908
Listen to recorded route and schedule information

- 24 hours a day - English, Spanish and Vietnamese
nt me r ure Sec nts fo w e e N irem ices ev qu Re lity D bi Mo
Speak with an Information Service Representative

- Weekdays: 6 a.m. 7 p.m. - Saturday: 7:30 a.m. 4 p.m.
Hearing Impaired (TDD only) . . . . . . . (408) 321-2330 VTA Website . . . . . . . . . . . . . . . . . . www.vta.org VTA Downtown Customer Service Center
Were Coming to Your Neighborhood!

Passengers with mobility devices can drop-in to pre-designated sites to have their mobility devices pre-marked for securement. Please call VTAs Accessible Services department at (408) 952-4249, or TDD only at (408) 321-2330.
Practice Boarding at your Leisure!

Passengers with mobility devices who have never used the bus or have not used it in a while will now have the opportunity to practice maneuvering on and off a coach. To schedule an appointment call VTAs Accessible Services department.
2 N. First St., San Jose, CA 95113 Weekdays: 9 a.m. 6 p.m. Closed weekends and most holidays
VTA River Oaks Administrative Offices 3331 N. First St., San Jose, CA 95134 Weekdays: 8 a.m. 4:30 p.m. Closed weekends
Your safety is our priority!
Upon request, this brochure is available in an accessible format: large print, Braille or audio tape.
ON VTA BUSES ONLY
Rehabilitation Engineering Research Center on Wheelchair Transportation Safety University of Michigan Health System University of Michigan Transportation Research Institute Initially funded through a grant from the FRIENDS of the University of Michigan Hospitals
2005
Get Hooked on VTA!

VTAs securement policy is mandatory, but the option to have mobility devices marked and/or have tethers installed is voluntary. Passengers are encouraged to take advantage of this program so that coach operators and/or attendants can quickly identify where to attach securement hooks. Marking mobility devices involves applying removable colored vinyl tape on areas where hooks can easily be attached and tethers for hooks can be easily installed. Trained VTA employees will: Examine the mobility device to determine the best four points for securement. Affix colored tape to the best securement points on the mobility device. Yellow Tape indicates where securement hooks will be attached. Blue Tape indicates where tethers will be placed.
To Reach Us...
To schedule an appointment to mark and tether mobility devices call VTAs Accessible Services Department at (408) 952-4249.
Effective January 1, 2007
For trip planning or other route information, contact:

VTA Customer Service Call Center . . . . . (408) 321-2300 From 650 area code and South Santa Clara County toll area . . . (800) 894-9908
Listen to recorded route and schedule information

- 24 hours a day - English, Spanish and Vietnamese
t n e m e r r u c o f e S ts n w Ne ireme ices v u e q Re lity D bi o M
Speak with an Information Service Representative

- Weekdays: 6 a.m. 7 p.m. - Saturday: 7:30 a.m. 4 p.m.
Hearing Impaired (TDD only) . . . . . . . (408) 321-2330 VTA Website . . . . . . . . . . . . . . . . . . www.vta.org VTA Downtown Customer Service Center
Were Coming to Your Neighborhood!

Passengers with mobility devices can drop-in to pre-designated sites to have their mobility devices pre-marked for securement. Please call VTAs Accessible Services department at (408) 952-4249, or TDD only at (408) 321-2330.
Practice Boarding at your Leisure!

Passengers with mobility devices who have never used the bus or have not used it in a while will now have the opportunity to practice maneuvering on and off a coach. To schedule an appointment call VTAs Accessible Services department.
2 N. First St., San Jose, CA 95113 Weekdays: 9 a.m. 6 p.m. Closed weekends and most holidays
VTA River Oaks Administrative Offices 3331 N. First St., San Jose, CA 95134 Weekdays: 8 a.m. 4:30 p.m. Closed weekends
Your safety is our priority!
Upon request, this brochure is available in an accessible format: large print, Braille or audio tape.
ON VTA BUSES ONLY
06/08-5639
New Securement Requirements for Mobility Devices on VTA Buses

Effective January 1, 2007, all mobility devices must be secured on VTA buses. Please take a few minutes to read this brochure to learn about the new securement policy and the mobility device marking and tether strap program. How does the securement equipment work? VTA uses a four-point securement system for mobility devices on all buses. This means that a mobility device must be secured with two hooks in the front and two hooks in the back. The hooks are connected to straps that are attached to the floor of the bus. The securement system is self-tightening to prevent any slack in the straps which will keep the mobility device stationary. Will passengers be late to where they want to go? No. Passenger safety is our first priority. VTA coach operators have been trained to secure mobility devices safely, effectively, and quickly to prevent schedule delay. Passengers can contact VTA to have their mobility devices marked and/or have tethers installed, making securing the mobility device even quicker. What if the mobility device cannot be secured? Operators will make every effort to secure mobility devices but if devices cannot be secured, passengers will be allowed to travel to their final destinations.
Get the Facts!

Is it a violation of the ADA to require a passengers mobility device to be secured? No. In accordance with Federal Transit Administration regulations, transit agencies can require mobility devices to be secured as long as the agency has established such a policy. What is the ADA requirement for mobility device securement? Transit vehicles are built in accordance with the guidelines of the Americans with Disabilities Act of 1990 (ADA). Ramps, lifts and mobility device spaces are designed to accommodate a common wheelchair. A common wheelchair is defined as a mobility aid belonging to any class of three or four-wheeled devices, usable indoors, designed for and used by individuals with mobility impairments, whether operated manually or powered. A common wheelchair does not exceed 30 inches in width and 48 inches in length measured two inches above the ground, and does not weigh
more than 600 pounds when occupied. Other types of mobility devices that meet the specifications of a common wheelchair must be treated as common wheelchairs.
What to Expect
Passengers mobility devices must be secured every time they ride a VTA bus. Bus operators are responsible for ensuring that mobility devices are properly secured, even if the passengers attendant secures the device.
A service animal or guide dog can accompany a person with a disability on a VTA bus.
Each bus operator must secure mobility devices, or verify proper securement (secured to the floor) if performed by a passenger or attendant.
VTA also recommends, but does not require, the use of lap belts and shoulder harnesses.
Guide dogs or service animals on VTA buses and light rail Service animals (and animals in training) are permitted to ride onboard VTA buses and light rail. Service animals are specially trained animals that assist persons with disabilities. Service animals must be within the care, custody and control of their owners. This means that the animal is properly restrained by leash, harness or carrier and is not roaming the coach and barking or growling.
Rehabilitation Engineering Research Center on Wheelchair Transportation Safety University of Michigan Health System University of Michigan Transportation Research Institute Initially funded through a grant from the FRIENDS of the University of Michigan Hospitals
2005
!!!
When traveling in a motor vehicle, it is generally safest for wheelchair users

to transfer to a vehicle seat and use the vehicle seatbelt system or a child safety seat that complies with federal safety standards. The wheelchair should then be stored and secured in the vehicle.
If transferring is not feasible, it is very important to secure the wheelchair to the vehicle facing forward and to use crash-tested seatbelts for the wheelchair-seated rider.
START WITH THE RIGHT EQUIPMENT

The Wheelchair
! It is best if you have a wheelchair that has been designed and tested for use as a seat in motor vehicles, often referred to as a WC19 wheelchair or a transit wheelchair. These wheelchairs comply with ANSI/RESNA WC19, a voluntary standard developed by safety and rehabilitation experts. Wheelchairs that meet the design and performance requirements of this standard will be labeled to show that they comply with WC19. ! Most importantly, a WC19 wheelchair has four, crash-tested securement points where tiedown straps and hooks can be easily attached. These points are clearly marked with a hook symbol. ! If a WC19 wheelchair is not available, the next best choice is a wheelchair with an accessible metal frame where tiedown straps and hooks can be attached at frame junctions.
The Wheelchair Tiedown and Occupant Restraint System (WTORS)

! It is important to use a complete WTORS to secure the wheelchair and provide the wheelchair occupant with a properly designed and tested seatbelt system. ! Always use a WTORS that has been crash tested and labeled as complying with SAE J2249, a voluntary standard developed by safety and rehabilitation experts. The most common type of wheelchair tiedown uses four straps to secure the wheelchair to the vehicle. Although it requires someone other than the wheelchair rider to secure and release the wheelchair, this tiedown can secure a wide range of WC19 and non-WC19 wheelchairs. ! To protect the rider during a crash or sudden braking, and to minimize the likelihood of injury caused by contact with the vehicle, a seatbelt system with both pelvic and upper torso belts must be used.
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SECURE THE WHEELCHAIR

Four-Point Tiedowns
! Always position the wheelchair and rider facing forward in the vehicle. ! When securing a WC19 wheelchair, attach the four tiedown straps to the securement points provided on the wheelchair. Tighten the straps to remove all slack. ! If you do not have a WC19 wheelchair, it is best to attach the tiedown straps to welded junctions of the wheelchair frame or to other structural areas where the frame is fastened together with hardened steel bolts indicated by six raised lines or bumps on the bolt head. ! Do not attach tiedowns to adjustable, moving, or removable parts of the wheelchair such as armrests, footrests, and wheels. ! When securing non-WC19 wheelchairs, choose structural securement points as close to the seat surface as possible to provide greater wheelchair stability during travel. It is best if the rear securement points are high enough to result in angles of the rear tiedown straps between 30 and 45 degrees to the horizontal. ! If you have a non-WC19 wheelchair with a tilt seat, make sure to attach both the front and rear straps to either the seat frame or to the base frame. Mixing wheelchair securement points between the seat and base can result in the tiedown straps becoming slack if the angle of the seat changes during a crash. ! It is best if floor anchor points for rear tiedown straps are located directly behind the rear securement points on the wheelchair. If possible, the front tiedown straps should anchor to the floor at points that are spaced wider than the wheelchair to increase lateral stability during travel.
Other Methods of Wheelchair Securement

! In addition to securing wheelchairs using a four-point tiedown, wheelchairs can also be secured using a docking tiedown device. This method is primarily used in private vehicles since it requires the addition of adaptor hardware to the wheelchair frame that will engage with the docking tiedown device in the vehicle. Docking securement devices allow the wheelchair rider to secure and release the wheelchair without assistance. ! If you plan to secure your wheelchair with a docking tiedown device, you should check with the WTORS or wheelchair manufacturer to ensure that your wheelchair model has been successfully crash tested with their system. ! Clamp-type securement devices are not recommended since they do not provide effective wheelchair securement in frontal crash testing.
!!! 3 PROTECT THE WHEELCHAIR RIDER

! In addition to securing the wheelchair, it is very important to provide effective restraint for the wheelchair user with a crash-tested lap and shoulder belt or with a child restraint harness. Postural support belts attached to the wheelchair are not strong enough to withstand the forces of a crash and are usually not positioned correctly to restrain the occupant safely in a crash. ! The lap belt should be placed low across the front of the pelvis near the upper thighs, not high over the abdomen. When possible, the lap belt should be angled between 45 and 75 degrees to the horizontal when viewed from the side. Some wheelchair features, like armrests, can interfere with good belt fit. To avoid placing the lap belt over the armrest and to keep the lap belt low on the pelvis, it may be necessary to insert the belt between the armrest and the seatback, or through an opening under the armrest. ! A diagonal shoulder belt should cross the middle of the shoulder and the center of the chest, and should connect to the lap belt near the hip of the wheelchair rider. The upper shoulder-belt anchor point or D-ring guide should be anchored above and behind the top of the occupants shoulder, so that the belt is in good contact with the shoulder and chest while traveling. ! Newer WC19 wheelchairs offer the option of a crash-tested lap belt that is anchored to the wheelchair frame. If the wheelchair has an onboard crash-tested lapbelt, complete the belt system by attaching the lower end of a shoulder belt to the lap belt. Crashtested wheelchair-anchored lap belts will be labeled to indicate that they comply with with ANSI/RESNA WC19.
Other Important Points

" Read and follow all manufacturers instructions. " It is best to ride with the wheelchair backrest positioned at an angle of 30 degrees or less to the vertical. If a greater recline angle is needed, the shoulder belt anchor point should be moved rearward along the vehicle sidewall so the belt maintains contact with the riders shoulder and chest. " Maximize the clear space around the rider to reduce the possibility of contact with vehicle components and other passengers in a crash. Cover vehicle components that are close to the rider with dense padding. " Check WTORS equipment regularly and replace worn or broken components. Keep anchorage track free of dirt and debris. " If a WTORS and wheelchair have been involved in a vehicle crash, check with the manufacturers to determine if the equipment needs to be repaired or replaced. " If possible, remove hard trays and secure them elsewhere in the vehicle to reduce the chance of rider injury from contact with the tray. Consider the use of foam trays instead of rigid trays during transit. If it is not possible to remove a hard tray, place dense padding between the rider and the tray and make sure that the tray is securely attached to the wheelchair so it will not break loose and cause injury to other occupants in a crash. " A properly positioned headrest can help protect the neck in a rear impact. " If it is necessary to use a head and neck support during travel, soft neck collars are safer than stiff collars or head straps which could cause neck injury in a crash. The soft collar should not be attached to the seating system. " Secure medical and other equipment to the wheelchair or vehicle to prevent it from breaking loose and causing injuries in a crash.
!!!
RESOURCES
Organizations
Rehabilitation Engineering and Research Center on Wheelchair Transportation Safety www.rercwts.pitt.edu University of Michigan Transportation Research Institute www.umtri.umich.edu University of Pittsburgh www.wheelchairnet.org Society of Automotive Engineers www.sae.org RESNA Rehabilitation Engineering Society of North America www.resna.org National Highway Traffic Safety Administration www.nhtsa.dot.gov National Mobility Equipment Dealers Association www.nmeda.org The Association for Driver Rehabilitation Specialists www.driver-ed.org
A Helpful Publication
School Bus Transportation of Students in Wheelchairs A manual of procedures and practices used by the Washtenaw Intermediate School District for providing effective wheelchair securement and occupant restraint. Washtenaw Intermediate School District 734-994-8100 www.wash.k12.mi.us
Wheelchair Manufacturers (Ask for Frames and/or Seating Products that Comply with WC19)
Convaid www.convaid.com; 800-266-8243 Freedom Designs www.freedomdesigns.com; 800-331-8551 GOVAN + wheelchair and docking system www.smd-abitech.com; 204-975-3004 Invacare www.invacare.com; 800-333-6900 Mulholland Postioning Systems www.mulhollandinc.com; 800-543-4769 Otto Bock www.ottobock.com; 800-328-4058 Permobil www.permobil.com; 800-736-0925 Pride Mobility www.pridemobility.com; 800-800-8586 Sammons Preston www.sammonspreston.com; 800-323-5547 Sunrise Medical www.sunrisemedicalonline.com; 800-333-4000
Wheelchair Seating Manufacturers (Ask for Products that have been Tested to WC19)
Adaptive Engineering Lab www.aelseating.com; 800-327-6080 Adaptive Equipment Systems www.aesys.com; 800-237-2370
Wheelchair Tiedown and Occupant Restraint Manufacturers (Ask for Products that Comply with SAE J2249)
Creative Controls www.creativecontrolsinc.com; 800-539-7237 EZ-Lock www.ezlock.net; 225-214-4620 Orthosafe www.orthosafe.com; 609-587-9444 QStraint www.qstraint.com; 800-987-9987 SureLok www.sure-lok.com; 866-787-3565
!!!
GLOSSARY OF TERMS
Anchor point: The location on a vehicle, wheelchair, or wheelchair tiedown where a belt-restraint or wheelchair-tiedown anchorage is attached. ANSI-RESNA WC19 (officially, SECTION 19 ANSI/RESNA WC/VOL. 1 Wheelchairs for use in Motor Vehicles): A voluntary standard for wheelchairs designed for use when traveling facing forward in a motor vehicle. NOTE: ISO 7176/19 is an international transit wheelchair standard that specifies similar design and performance requirements as ANSI/RESNA WC19. Belt: A length of energy-absorbing webbing material used in occupant restraint systems. Docking tiedown: A method for securing wheelchairs where portions of the wheelchair frame, or add-on components fastened to the wheelchair frame, engage with a securement device anchored to the vehicle. Four-point strap-type tiedown: A method for securing a wheelchair where four straps are attached to the wheelchair at four separate securement points and attached to the vehicle at four separate anchor points. Occupant restraint: A system or device designed to restrain a motor vehicle occupant in a crash by keeping the occupant in the vehicle seat and minimizing contact with the vehicle interior, other occupants, or objects outside the vehicle. Postural support: A padded component and/or belt used to help maintain a person in a desired position during normal wheelchair use. In general postural supports are not designed to provide effective occupant restraint in a motor vehicle crash. SAE Recommended Practice J2249 (officially, SAE J2249 Wheelchair Tiedowns and Occupant Restraints for Use in Motor Vehicles): A Society of Automotive Engineers Recommended Practice that specifies design and performance requirements for wheelchair tiedown and occupant restraint systems. NOTE: ISO 10542 is an international WTORS standard that specifies comparable design and performance requirements as SAE J2249. Securement points: Specific structural points on the wheelchair base or seat frame that are designed for attachment of wheelchair tiedowns. Strap: A length of webbing material used in wheelchair tiedown systems. WC19 wheelchair: A crash-tested wheelchair with four clearly identified securement points that meets the design and performance requirements of ANSI-RESNA WC19 Wheelchairs Used as Seats in Motor Vehicles, and is sometimes called a transit wheelchair. Wheelchair tiedown and occupant-restraint system (WTORS): A complete system for use by wheelchair-seated occupants comprised of a system or device for securing the wheelchair and a belttype restraint system for limiting occupant movement in a motor vehicle crash.
Regents of the University of Michigan

David A. Brandon, Ann Arbor; Laurence B. Deitch, Bingham Farms; Olivia P. Maynard, Goodrich; Rebecca McGowan, Ann Arbor; Andrea Fischer Newman, Ann Arbor; Andrew C. Richner, Grosse Pointe Park; S. Martin Taylor, Grosse Pointe Farms; Katherine E. White, Ann Arbor; Mary Sue Coleman (ex officio) The University of Michigan, as an equal opportunity/affirmative action employer, complies with all applicable federal and state laws regarding nondiscrimination and aff i r m a t i v e action, including Title IX of the Education Amendments of 1972 and Section 504 of the Rehabilitation Act of 1973. The University of Michigan is committed to a policy of nondiscrimination and equal opportunity for all persons regardless of race, sex, color, religion, creed, national origin or ancestry, age, marital status, sexual orientation, disability, or Vietnam-era veteran status in employment, educational programs and activities, and admissions. Inquiries or complaints may be addressed to the University's Director of A ffirmative Action and Title IX/Section 504 Coordinator, at the Office of Multicultural Community, 2072 Administrative Services Building, Ann Arbor, Michigan 48109-1432, 734-763-0235, T T Y 734-647-1388. For other University of Michigan information, call 734-764-1817.
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Easter Seals Project ACTION 1425 K Street, NW Suite 200 Washington, D.C. 20005

Wheelchair

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Status Report on the Use of Wheelchairs and Other Mobility Devices on Public and Private Transportation

About Easter Seals Project ACTION

Project Advisory Committee

How to use this document

Using the ramp of a low-floor bus

How to Use this Document 

Issue area Transit Vehicle and Equipment Design

Issue area Wheelchair Design, Purchasing, Usage and Prescription

Issue area Transit Operations and Training

Issue area Regulation and Policy

About the Study

Power Wheelchair (rear wheel drive)

Power Wheelchair (mid wheel drive)

Chapter 2. Transit Vehicle and Equipment Design

Description of the Issues

Lift and Ramp Boarding

Example of a poorly placed shoulder belt in a securement system

Chapter 2. Transit Vehicle and Equipment Design

Chapter 3. W  heelchair Design, Purchasing, Usage and Prescription

Description of the Issues

Non-Wheelchair Mobility Aids

Other Items Carried with Mobility Devices

Chapter 3. Wheelchair Design, Purchasing, Usage and Prescription

Chapter 4. Transit Operations and Training

Description of the Issues

Transit Personnel Proficiency and Awareness

Chapter 4. Transit Operations and Training

Training standards and monitoring of service performance

Training Program Elements

Wheelchair with tether strap (front) and markings (rear)

Chapter 4. Transit Operations and Training

Transit System Performance Monitoring

Chapter 5. Regulation and Policy

Description of the Issues

Chapter 5. Regulation and Policy

Elements of Federal Guidance

Education and dissemination of available resources

Chapter 5. Regulation and Policy

Appendix A: Project Methodology

Appendix A: Project Methodology 

Figure A 1: Stakeholder Interview Participants

Appendix A: Project Methodology 

Survey Deployment and Recruitment

Appendix B: Annotated List of Documents Reviewed 

Appendix B: Annotated List of Documents Reviewed

Appendix B: Annotated List of Documents Reviewed 

Appendix B: Annotated List of Documents Reviewed 

Appendix B: Annotated List of Documents Reviewed 

Appendix B: Annotated List of Documents Reviewed 

Appendix B: Annotated List of Documents Reviewed 

Appendix B: Annotated List of Documents Reviewed 

Appendix C: Survey Tool

Occupant Restraint (Seat Belt) System

Questionnaire for Mobility Device Users of Public Transit

Appendix C: Survey Tool 

Appendix C: Survey Tool 

Appendix C: Survey Tool 

Appendix C: Survey Tool 

Appendix D: Statistical Results of Survey

6.0% 92.3% 1.7%

6 to 10 years 3 0 5 0 14 15 8 45 On the Sides 6 3 1 9 0 0 0 9 0 6 4 38

Do not use 74 77 72 80 29 34 66 432

Appendix D: Statistical Results of Survey

How to Use this Document

Chapter 2. Transit Vehicle and Equipment Design

Chapter 3. W heelchair Design, Purchasing, Usage and Prescription

Chapter 3. Wheelchair Design, Purchasing, Usage and Prescription

Chapter 4. Transit Operations and Training

Chapter 4. Transit Operations and Training

Appendix A: Project Methodology

Appendix A: Project Methodology

Appendix B: Annotated List of Documents Reviewed

Appendix B: Annotated List of Documents Reviewed

Appendix B: Annotated List of Documents Reviewed

Appendix B: Annotated List of Documents Reviewed

Appendix B: Annotated List of Documents Reviewed

Appendix B: Annotated List of Documents Reviewed

Appendix B: Annotated List of Documents Reviewed

Appendix C: Survey Tool

Appendix C: Survey Tool

Appendix C: Survey Tool

Appendix C: Survey Tool

Appendix D: Statistical Results of Survey

Appendix D: Statistical Results of Survey

Appendix D: Statistical Results of Survey

Appendix D: Statistical Results of Survey

Appendix E: Summary Issues from the Perspective of Consumers

Appendix E: Summary Issues from the Perspective of Consumers

Appendix F: Links to Relevant Regulatory Sources