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2/26/2012. DJ Cross Transp. Consulting . 2. ADA Transportation Service Requirements . 49 CFR Sec. 37.165 Lift and securement use Must use ADA-compliant equipment (Part 38)May require mandatory securementMay not deny wheelchairs that can't be securedTransit personnel must assist securementMay not mandate transferring to regular seatsInterpretive Appendix - Background as to purpose FTA
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1. 3/3/2012 DJ Cross Transp. Consulting 1 Developing a Wheelchair Marking and Tether Strap Program DOUG CROSS
Douglas J. Cross Transportation Consulting
www.douglasjcross.com OAKLAND
2. 3/3/2012 DJ Cross Transp. Consulting 2 ADA Transportation Service Requirements 49 CFR Sec. 37.165 Lift and securement use
Must use ADA-compliant equipment (Part 38)
May require mandatory securement
May not deny wheelchairs that can’t be secured
Transit personnel must assist securement
May not mandate transferring to regular seats
Interpretive Appendix - Background as to purpose
FTA “Questions and Answers” bulletin
All devices meeting “common” definition
must be accommodated
Transit providers must have a policy
in order to require securement
May also have a policy that securement
is at passenger’s option
Occupant restraints can be mandatory only if
for all passengers in vehicle
Typical wheelchair styles when the ADA was passed >>>
3. 3/3/2012 DJ Cross Transp. Consulting 3 Diversity of Mobility Aids Today
4. 3/3/2012 DJ Cross Transp. Consulting 4 Wheelchair Securement Issues and Solutions A common problem is not being able to identify, or reach, where to attach tie downs on wheelchairs and scooters
Most new wheelchair designs do not have frame joints that tie-down systems were originally designed for, and most do not yet come with the new industry standard (WC-19) “transit option”
To help this situation, transit systems and disability organizations offer marking and/or tether straps
The first component is markings for appropriate attachment points on customers’ chairs with color-coded tape, stickers, wire ties, etc.
If there is no good place for attachment of belts or hooks, a fabric webbing “tether strap” can be installed
5. 3/3/2012 DJ Cross Transp. Consulting 5 Wheelchair Standards US voluntary standard No. WC-19: (ANSI/RESNA) –
Tie down loops accept hooks or Y-belts
“Ride Safe” brochure: www.travelsafer.org
Only some wheelchair models are available with WC-19 “Transit Option” loops
“Market demand”/ education needed
6. 3/3/2012 DJ Cross Transp. Consulting 6 Listing of Products with WC-19 “Transit Option” (available at: www.rercwts.pitt.edu) “CRASH TESTED Products”:
Wheelchairs Marketed with the WC19 Transit Option as of February 19, 2006
Use the link to the manufacturer's website to learn more about the listed mobility or seating product.
Manufacturers: Please contact the manager of this page to have newly crash-tested products added to this page.
Accufast Inc: www.smd-abitech.com/
Contact: Don LoganE-mail: nonePhone: 866-222-8366
Wheelchair Name and Model
Occupant Weight Limit (lb)
A WC19 Compliant Wheelchair Anchored Lap Belt is available*
GOVAN+
250
No (uses vehicle mounted safety belt)Total # of WC19 compliant products1
7. 3/3/2012 DJ Cross Transp. Consulting 7 Actual WC-19 equipped wheelchairs
8. 3/3/2012 DJ Cross Transp. Consulting 8 Wheelchair Markings and Tether Straps
9. 3/3/2012 DJ Cross Transp. Consulting 9 Markings and Tether Straps Require Careful Implementation Tether straps should be used only when no places for markings (incl. WC-19 “transit option” loops)
Some wheelchairs/scooters don’t have adequate installation points even for tether straps
Only those familiar with BOTH wheelchairs and bus equipment should install markings/straps
Liability often precludes installation by organizations outside transit systems
Several lengths of straps are needed
Records, photos, customer sign-offs are needed
Training and education for customers and staff
10. 3/3/2012 DJ Cross Transp. Consulting 10 Program Components & Responsibilities Permanent one-time installation by staff vs. on-board or by customer (or outside organizations)
Free of charge or for fee
Convenient locations throughout community
Consultation with affected staff and consumer advisory groups, incl. legal/risk concurrence
Coordination with adjacent transit systems, paratransit providers, travel trainers, etc.
Marketing tools – brochures, website, posters, in-vehicle postings appointment phone lines
Technical training guidelines/SOP, sample wheelchairs
11. 3/3/2012 DJ Cross Transp. Consulting 11 Guidelines for Wheelchair Marking/Tether Straps Bring needed materials and tools
Greet the customer, explain what you will be doing
Determine where tiedowns will fit directly and install markings
12. 3/3/2012 DJ Cross Transp. Consulting 12 If markings are not feasible, install tether straps Mark the installation location with alternate color
Determine the proper length of strap to use, resulting in loop of approx. 3 inches
Install straps and test using sample tiedowns
Make sure tether straps will not drag on the ground or wheels/other parts of wheelchair
13. 3/3/2012 DJ Cross Transp. Consulting 13 Tether straps can be imperfect (or bad) solutions
14. 3/3/2012 DJ Cross Transp. Consulting 14 Three wheeled scooter – tether placement
15. 3/3/2012 DJ Cross Transp. Consulting 15 Wrap-up and documentation Explain installation; invite questions & suggestions
Measure the effective securement length. If it falls outside transit system/ADA guidelines, discuss solutions
Inform customer of alternatives to deal with any problems
Explain responsibilities and fill out the form; provide customer with signed copy
Take 2 or 3 digital photos, include customer’s name/date
16. 3/3/2012 DJ Cross Transp. Consulting 16 Interesting issues with wheelchairs and scooters