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Wheelchair
Securements and
Passenger Restraints
Best Practices of Securing Wheelchairs and Restraining
Passengers as defined by SAE J2249.
Steve Oss
March 2011
Updated September 2011
WHEELCHAIR SECUREMENTS AND PASSENGER
RESTRAINTS
The goal of this training is to assist individuals and transit organizations to be aware of and to be in
full compliance of:
CFR TITLE 49 – TRANSPORTATION (03 – 01 – 11 Edition)
Subtitle A - OFFICE OF THE SECRETARY OF TRANSPORTATION
Part 37 - TRANSPORTATION SERVICES FOR INDIVIDUALS WITH DISABILITIES
(ADA); by understanding, implementing and training to proficiency the “Best Practices” identified
in SAE J2249.
WHAT THE ADA SAYS
PART 37 – TRANSPORTATION SERVICES FOR INDIVIDUALS WITH DISABILITIES
(ADA)
Subpart A – General
Sec. 37.3 Definitions
Wheelchair means 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'' 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.
*This was changed in June of 2011 to: if the wheelchair fits in the securement area without
blocking the aisle, it must be transported.
Subpart G – Provision of Service
Sec. 37.163 Keeping vehicle lifts in operative condition: Public entities
(b) The entity shall establish a system of regular and frequent maintenance checks of lifts sufficient
to determine if they are operative.
(c) The entity shall ensure that vehicle operators report to the entity, by the most immediate means
available, any failure of a lift to operate in service.
(d) Except as provided in paragraph (e) of this section, when a lift is discovered to be inoperative,
the entity shall take the vehicle out of service before the beginning of the vehicle's next service day
and ensure that the lift is repaired before the vehicle returns to service.
(e) If there is no spare vehicle available to take the place of a vehicle with an inoperable lift, such
that taking the vehicle out of service will reduce the transportation service the entity is able to
provide, the public entity may keep the vehicle in service with an inoperable lift for no more than
five days (if the entity serves an area of 50,000 or less population) or three days (if the entity
serves an area of over 50,000 population) from the day on which the lift is
discovered to be inoperative.
(f) In any case in which a vehicle is operating on a fixed route with an inoperative lift, and the
headway to the next accessible vehicle on the route exceeds 30 minutes, the entity shall promptly
provide alternative transportation to individuals with disabilities who are unable to use the vehicle
because its lift does not work.
37.165 Lift and securement use.
(a) This section applies to public and private entities.
(b) All common wheelchairs and their users shall be transported in the entity’s vehicles or other
conveyances. The entity is not required to permit wheelchairs to ride in places other than
designated securement locations in the vehicle, where such locations exist.
(c)(1) For vehicles complying with part 38 of this title, the entity shall use the securement system to
secure wheelchairs as provided in that Part.
(2) For other vehicles transporting individuals who use wheelchairs, the entity shall provide and
use a securement system to ensure that the wheelchair remains within the securement area.
(3) The entity may require that an individual permit his or her wheelchair to be secured.
(d) The entity may not deny transportation to a wheelchair or its user on the ground that the device
cannot be secured or restrained satisfactorily by the vehicle’s securement system.
(e) The entity may recommend to a user of a wheelchair that the individual transfer to a vehicle
seat. The entity may not require the individual to transfer.
(f) Where necessary or upon request, the entity’s personnel shall assist individuals with disabilities
with the use of securement systems, ramps and lifts. If it is necessary for the personnel to leave
their seats to provide this assistance, they shall do so.
(g) The entity shall permit individuals with disabilities who do not use wheelchairs, including
standees, to use a vehicle’s lift or ramp to enter the vehicle. Provided, that an entity is not required
to permit such individuals to use a lift Model 141 manufactured by EEC, Inc. If the entity chooses
not to allow such individuals to use such a lift, it shall clearly notify consumers of this fact by
signage on the exterior of the vehicle (adjacent to and of equivalent size with the accessibility
symbol).
37.167 Other service requirements.
(e) The entity shall ensure that vehicle operators and other personnel make use of accessibility-
related equipment or features required by part 38 of this title.
(g) The entity shall not refuse to permit a passenger who uses a lift to disembark from a vehicle at
any designated stop, unless the lift cannot be deployed, the lift will be damaged if it is deployed, or
temporary conditions at the stop, not under the control of the entity, preclude the safe use of the
stop by all passengers.
(h) The entity shall not prohibit an individual with a disability from traveling with a respirator or
portable oxygen supply, consistent with applicable Department of Transportation rules on the
transportation of hazardous materials (49 CFR subtitle B, chapter 1, subchapter C).
(i) The entity shall ensure that adequate time is provided to allow individuals with disabilities to
complete boarding or disembarking from the vehicle.
(j)(1) When an individual with a disability enters a vehicle, and because of a disability, the
individual needs to sit in a seat or occupy a wheelchair securement location, the entity shall ask
the following persons to move in order to allow the individual with a disability to occupy the seat or
securement location:
(i) Individuals, except other individuals with a disability or elderly persons, sitting in a location
designated as priority seating for elderly and handicapped persons (or other seat as necessary);
(ii) Individuals sitting in or a folddown or other movable seat in a wheelchair securement location.
(3) The entity is not required to enforce the request that other passengers move from priority
seating areas or wheelchair securement locations.
(4) In all signage designating priority seating areas for elderly persons and persons with
disabilities, or designating wheelchair securement areas, the entity shall include language
informing persons sitting in these locations that they should comply with requests by transit
provider personnel to vacate their seats to make room for an individual with a disability. This
requirement applies to all fixed route vehicles when they are acquired by the entity or to new or
replacement signage in the entity’s existing fixed route vehicles.
[56 FR 45621, Sept. 6, 1991, as amended at 58 FR 63103, Nov. 30, 1993]
37.173 Training requirements.
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, with appropriate attention to the difference
among individuals with disabilities.
English Dictionary. proficiency – noun pro.fi.cien.cy
1. high degree of ability or skill. a high degree of ability or skill in something
PART 38_AMERICANS WITH DISABILITIES ACT (ADA) ACCESSIBILITY
SPECIFICATIONS FOR TRANSPORTATION VEHICLES
Subpart B_Buses, Vans and Systems
Sec. 38.23 Mobility aid accessibility.
(a) General. All vehicles covered by this subpart shall provide a level-change mechanism or
boarding device (e.g., lift or ramp) complying with paragraph (b) or (c) of this section and sufficient
clearances to permit a wheelchair or other mobility aid user to reach a securement
location. At least two securement locations and devices, complying with paragraph (d) of this
section, shall be provided on vehicles in excess of 22 feet in length; at least one securement
location and device, complying with paragraph (d) of this section, shall be provided on
vehicles 22 feet in length or less.
(b) Vehicle lift--(1) Design load. The design load of the lift shall be at least 600 pounds. Working
parts, such as cables, pulleys, and shafts, which can be expected to wear, and upon which the lift
depends for support of the load, shall have a safety factor of at least six,
based on the ultimate strength of the material. Nonworking parts, such as platform, frame, and
attachment hardware which would not be expected to wear, shall have a safety factor of at least
three, based on the ultimate strength of the material.
(11) Boarding direction. The lift shall permit both inboard and outboard facing of wheelchair and
mobility aid users.
(12) Use by standees. Lifts shall accommodate persons using walkers, crutches, canes or braces
or who otherwise have difficulty using steps. The platform may be marked to indicate a preferred
standing position.
(d) Securement devices—(1) Design load. Securement systems on vehicles with GVWRs of
30,000 pounds or above, and their attachments to such vehicles, shall restrain a force in the
forward longitudinal direction of up to 2,000 pounds per securement leg or clamping mechanism
and a minimum of 4,000 pounds for each mobility aid. Securement systems on vehicles with
GVWRs of up to 30,000 pounds, and their attachments to such vehicles, shall restrain a force in
the forward longitudinal direction of up to 2,500 pounds per securement leg or clamping
mechanism and a minimum of 5,000 pounds for each mobility aid.
(2) Location and size. The securement system shall be placed as near to the accessible entrance
as practicable and shall have a clear floor area of 30 inches by 48 inches. Such space shall adjoin,
and may overlap, an access path. Not more than 6 inches of the required clear
floor space may be accommodated for footrests under another seat provided there is a minimum of
9 inches from the floor to the lowest part of the seat overhanging the space. Securement areas
may have fold-down seats to accommodate other passengers when a wheelchair or mobility aid is
not occupying the area, provided the seats, when folded up, do not
obstruct the clear floor space required.
(3) Mobility aids accommodated. The securement system shall secure common wheelchairs and
mobility aids and shall either be automatic or easily attached by a person familiar with the system
and mobility aid and having average dexterity.
ABREVIATIONS
ADA: Americans with Disabilities Act
ANSI: American National Standards Institute
CFR: Code of Federal Regulations
ISO: International Standardization Organization
NIDRR: The National Institute on Disability and Rehabilitation and
Research
RERC: Rehabilitation Engineering Research Center
RESNA: Rehabilitation Engineering and Assistive Technology Society of North America
SAE: Society of Automotive Engineers
WTORS: Wheelchair Tiedown and Occupant Restraint Systems
WTS: Wheelchair Transportation Safety
ANSI/RESNA/ISO
Since the early 1980’s ANSI, RESNA and ISO have collaborated together to develop uniform and
meaningful standards and measurements in regards to wheelchairs. ANSI and RESNA have had
more concentrated efforts in items such as how a wheelchair is measured and tested. ISO has
focused on minimum and maximum attributes of wheelchairs; i.e. mass to weight ratio, durability
going over curbs repeatedly, braking power and ability to hold, etc.
SAE J2249
SAE J2249 is a Report by the Society of Automotive Engineers
(1996) on “Best Practices” for safe wheelchair securements and
passenger restraints. This has become to be known as WTORS
which is a voluntary but recommended Best Practice using four –
point anchors and securements on wheelchairs and three point restraints for the passenger during
transportation. The key elements are as follows:
• It specifies design requirements, test methods, and performance requirements for WTORS,
requirements for manufacturer’s instructions in installers and users, and requirements for
product marking and labeling.
• It specifies test procedures and performance requirements for a 30-mph (48-kph), 20-g
frontal impact.
• It specifies test procedures and performance requirements for webbing slippage at
adjustment devices of strap-type wheelchair tiedowns, and for partial but ineffective
engagement of wheelchair tiedowns and tiedown components.
• It applies to WTORS used with forward-facing wheelchair-seated adults and children from
age six.
• It applies to passengers and drivers of personally licensed motor vehicles as well as to
passengers of motor vehicles used in public and school transportation.
• It applies to all types of WTORS, including those that use docking type wheelchair
tiedowns.
• It applies to components and subassemblies of WOTRS that manufacturers may want to
certify as being in compliance with SAE J2249.
WTORS
When complying with a WTORS system and proper
securement is achieved, it is presently the most secure
method of transportation for an occupant on a wheelchair.
However even the best system has its disadvantages:
• Invasion of personal space.
• Lengthy securement times.
• Requires operator/attendant for securement.
• Securement straps easily soiled or damaged.
• Proper securement points undefined.
• Extensive training/retraining to keep drivers proficient to most current standards.
WC19-COMPLIANT WHEELCHAIRS
WC 19 is a voluntary industry standard for designing, testing and
labeling a wheelchair that is ready to be used as a seat in a motor
vehicle. A WC19 wheelchair has:
• Four permanently attached and labeled securement points that
can withstand the forces of a 30 mph, 20 g impact.
• Specific securement point geometry that will accept a
securement strap or hook.
• Securement point locations that allow easy access to aisle side and wall side securement
points.
• A clear path of travel that allows proper placement of vehicle mounted occupant safety belts
next to the hip/pelvic area on the body.
• Anchor points for an optional wheelchair anchored pelvic safety belt that is
designed to withstand a 30 mph, 20 g impact that has a standard interface on it that allows
it to connect to a vehicle-anchored shoulder belt.
INTEGRATED SEATBELT DESIGN
Another technology that is the target of innovation and
research is seatbelt design. Recent studies have shown
that seatbelts are rarely used properly on passengers
seated in wheelchairs. In addition, seatbelts are often
insufficiently adjustable for a range of individuals seated in
a wheelchair. Seatbelts or wheelchair occupant restraints
are only effective if they are positioned well and snug on the individual's pelvis and upper body
(crossing the sternum and mid area of the collar bone). Tests have shown that integrating both
good belt fit and proper location of the belts on the upper body and pelvis achieve a ride as safe
as a passenger not seated on a wheelchair. A wheelchair with an integrated seatbelt offers a
consistent custom fit that is properly snug. Additionally the person
who uses a wheelchair with an integrated seatbelt is no longer
dependent on an attendant for proper placement and fit of vehicle-
anchored occupant restraints.
Many individuals who use a wheelchair already use some type of
pelvic belt or chest strap for postural support. These postural
supports are often mistakenly relied upon during motor vehicle
travel, which can result in occupant injury during a motor vehicle impact when a postural support
breaks loose from the wheelchair frame. In some cases, a wheelchair integrated occupant
restraint system could replace postural chest straps or pelvic straps, and thereby provide
occupant protection as well as postural support during transportation. Replacing the function of a
postural belt with a safety restraint would need to be individually evaluated by a clinical expert.
Wheelchair integrated occupant restraints would also require knowledge of the user's ability to
independently buckle or unbuckle a seatbelt. When transporting a small child, it is desirable to
have a seatbelt buckle that can only be operated by a caregiver. User studies and design efforts
are ongoing to re-design the user interface of buckles and fittings to keep them safe, as well as
easier to use for individuals with limited hand function.
AUTOMATED WHEELCHAIR DOCKING
Automated docking technology to secure wheelchairs in vehicles may be a part of future
innovations. This type of wheelchair securement gives the
passenger seated in a wheelchair the freedom of independent
securement. Due to the fact that there is only one way to dock a
wheelchair into a docking
securement system, it will be
hard for the passenger seated in a wheelchair to make a
mistake. If the individual cannot dock the wheelchair
independently, it will be easier and less time consuming for a
driver or caregiver to secure the wheelchair. The need for
driver training on how to secure a wide variety of wheelchairs can almost be eliminated.
REAR FACING WHEELCHAIR CONTAINMENT
Another innovation that has been slowly entering the U.S. market is rear-
facing wheelchair containment. This technology can only be used on large
transit vehicles and is not safe for school buses or smaller para-transit
vehicles. Here is how it works. The person using a wheelchair boards in the
typical manner but then maneuvers into an area on the left or right side of the bus and backs up
against a padded barrier, facing towards the rear of the bus. In this location, no other securement
device is required, except a vertical floor to ceiling post or flip-down armrest-type barrier, located
on the aisle side of the wheelchair space. In addition, vehicle-mounted occupant restraints are not
required. The key advantage of this non-invasive, wheelchair containment arrangement is that it
allows the user to enter and exit the vehicle independently without any intervention by the bus
operator. Furthermore, any present-day wheelchair can use this technology and no additional
hardware is needed on wheelchairs. A standard providing guidelines for testing and designing this
technology is nearing completion.
There are a couple of reasons that this innovation only works in large transit buses. In general,
transit buses are a very safe means of people transport for both seated and standing passengers.
They are usually the largest (heaviest) vehicle on the street and travel at relatively low speeds.
This means, for example, that if you are a rider in a frontal collision on a large versus a small
transport vehicle, assuming that all other factors are the same, you will experience lower injury
producing forces acting on your body. The barrier behind the rear-facing wheelchair is designed
to limit forward movement of the wheelchair and the occupant's upper torso and head. Sideways
movement of the wheelchair is minimized by the lateral barriers such as an aisle-side post and
the vehicle wall. Rebound movement is minimized by the energy absorption of the barrier and the
wheelchairs brakes.
INJURIES TO INDIVIDUALS OCCUPYING WHEELCHAIRS DURING VEHICLE
TRANSPORTATION:
A few recent studies have focused directly on injuries to individuals who use wheelchairs as seats
in motor vehicles. In one cross-sectional study, 596 wheelchair users were interviewed about their
involvements in motor-vehicle crashes and injuries they may have sustained (T. Songer et al.,
2004). The screening interviews for the 596 subjects were followed by more in-depth surveys of
336 participants who used their wheelchair as a seat in a public or private vehicle, or both (Songer
et al., 2005). More than one-quarter of the respondents (28.7%) reported sustaining at least one
injury while using motor-vehicle transportation in the previous three years. Crash involvement was
reported by 14.9% of the study population at an estimated rate of 10.6 events per 100,000 miles
traveled. Of 65 respondents who reported being involved in at least one crash, 55 provided further
details about their crash experience. Of these, 38% reported being injured in a crash, and two-
thirds of the injured occupants required medical attention. Thus, 6% of the 336 occupants
reported being injured while traveling seated in their wheelchair, which amounts to 3.6 injury
events per 100,000 miles traveled. This is 45 times higher than the injury rate for the general
automotive population of 0.08 injuries per 100,000 miles traveled (NHTSA, 2009)
Recent studies provide increasing evidence that a large percentage of injuries and fatalities to
wheelchair-seated travelers are being caused in non-collision events, such as abrupt vehicle
turning maneuvers and hard braking (Frost & Bertocci, 2007, 2009a). The evidence further
indicates that these injuries are due to the lack of proper wheelchair securement that result
in the wheelchair moving within the vehicle or tipping over, and/or non-use or improper use
of belt restraints by wheelchair passengers that result in the wheelchair occupant coming out
of the wheelchair seat, resulting in injuries from contact with the vehicle interior (Frost & Bertocci,
2009b). Most wheelchair users have limited ability to stabilize their wheelchair or their position in
the wheelchair by bracing or by grabbing vehicle components with their hands during these low-g,
non-collision events, and therefore often sustain serious or fatal injuries in events where
other passengers are uninjured (Fitzgerald et al., 2007). Songer et al. (2005) reported that
non-crash injuries were most frequently reported to have occurred during entering and exiting
vehicles (15.8% of respondents; 43.1 events per 100,000 miles traveled). However, injuries
resulting from sudden vehicle maneuvers were reported with a similar frequency by 15.7% of
respondents or at a rate of 31.8 events per 100,000 miles traveled. Most non-crash injuries arose
from sudden braking (50%) or sharp turning (33.3%), which resulted in the wheelchair tipping over
(33%), securement failure (22%), or the occupant falling out of the wheelchair seat (15.3%). While
these studies are some of the first to report on frequencies and causes of injuries sustained by
wheelchair users in motor vehicle transportation, the study populations represents a convenience
sample and selection bias and the ability of participants to accurately report on past events may
influence the results. However, the results document the general types and characteristics of
injury events that are occurring to wheelchair-seated travelers, and raise concerns about the
relatively high risk of injuries to occupants seated in wheelchairs.
REDUCING OR ELIMINATING SECUREMENT ERRORS
All stakeholders in the transportation of wheelchairs; passengers, drivers, attendants, supervisors,
and the entities need to understand their role in providing the safe riding option.
• Passengers need to understand the need to transfer out of non – compliant WC 19
wheelchairs when they are able to. They need to keep their wheelchairs/scooters clean
and securement points accessible. They need to use both seatbelt and shoulder belt
options for the safest option.
• Drivers need to make sure that the securement task is completed to standard each and
every time. That they take the time necessary to complete the securement and the
passenger is accommodated.
• Attendants need to assist in their capacity as a caregiver.
• Supervisors need to make sure that drivers are complying with the standards. They also
need to make sure that sufficient time is allotted to accommodate the passengers so that
the drivers do not feel as though they need to rush.
• Entities need to provide the resources necessary to accomplish the safe securements and
restraints of wheelchairs and the passengers. Assist in educating the public and drivers,
encouraging the passengers to transfer out of non WC19 wheelchairs, and enforcing
policies, i.e. size and weight that support safe transportation for all passengers.
THE BENEFITS OF SUPPORTING THE USE OF WHEELCHAIRS DESIGNED
TO FUNCTION AS A MOTOR VEHICLE SEAT
Transportation providers should encourage the purchase of wheelchairs designed for use as a
motor vehicle seat by regular users of their services to increase driver efficiency and to reduce
driver effort, errors, and injury potential. These wheelchairs will facilitate ease and proper use of
WTORS, which will improve best practice and reduce overall liability.
Recognizing the value of using and paying for wheelchairs designed to function as a motor vehicle
seat requires greater knowledge among many stakeholders; consumers, rehabilitation/seating
clinicians, rehabilitation counselors, suppliers, manufacturers, transportation agencies, driver
educators, payers and policy makers. Creating equivalent safety for individuals who ride seated in
wheelchairs extends to them the “equal protection” demanded by law, reduces human suffering
and loss of life that may result from not exercising reasonable caution, and promulgates best
practice supported by peer-reviewed research. RESNA encourages all of those in leadership
positions involved in the wheelchair transportation community to do the right thing and influence
the broader recognition and use of products designed to improve safety for those who use
wheelchairs as seats during transportation.
RESOURCES
ANSI – AMERICAN NATIONAL STANDARDS INSTITUTE
ISO – INTERNATIONAL STANDARDIZATION ORGANIZATION
NTI – NATIONAL TRANSIT INSTITUTE
NIDRR – THE NATIONAL INSTITUTE ON DISABILITY AND REHABILITATION AND
RESEARCH
RERC – REHABILITATION ENGINEERING RESEARCH CENTER
RESNA – REHABILITATION ENGINEERING AND ASSISTIVE TECHNOLOGY SOCIETY
OF NORTH AMERICA
SAE – SOCIETY OF AUTOMOTIVE ENGINEERS

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SAE j2249 with pictures and ADA and 38

  • 1. Wheelchair Securements and Passenger Restraints Best Practices of Securing Wheelchairs and Restraining Passengers as defined by SAE J2249. Steve Oss March 2011 Updated September 2011
  • 2. WHEELCHAIR SECUREMENTS AND PASSENGER RESTRAINTS The goal of this training is to assist individuals and transit organizations to be aware of and to be in full compliance of: CFR TITLE 49 – TRANSPORTATION (03 – 01 – 11 Edition) Subtitle A - OFFICE OF THE SECRETARY OF TRANSPORTATION Part 37 - TRANSPORTATION SERVICES FOR INDIVIDUALS WITH DISABILITIES (ADA); by understanding, implementing and training to proficiency the “Best Practices” identified in SAE J2249. WHAT THE ADA SAYS PART 37 – TRANSPORTATION SERVICES FOR INDIVIDUALS WITH DISABILITIES (ADA) Subpart A – General Sec. 37.3 Definitions Wheelchair means 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'' 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. *This was changed in June of 2011 to: if the wheelchair fits in the securement area without blocking the aisle, it must be transported. Subpart G – Provision of Service Sec. 37.163 Keeping vehicle lifts in operative condition: Public entities (b) The entity shall establish a system of regular and frequent maintenance checks of lifts sufficient to determine if they are operative. (c) The entity shall ensure that vehicle operators report to the entity, by the most immediate means available, any failure of a lift to operate in service.
  • 3. (d) Except as provided in paragraph (e) of this section, when a lift is discovered to be inoperative, the entity shall take the vehicle out of service before the beginning of the vehicle's next service day and ensure that the lift is repaired before the vehicle returns to service. (e) If there is no spare vehicle available to take the place of a vehicle with an inoperable lift, such that taking the vehicle out of service will reduce the transportation service the entity is able to provide, the public entity may keep the vehicle in service with an inoperable lift for no more than five days (if the entity serves an area of 50,000 or less population) or three days (if the entity serves an area of over 50,000 population) from the day on which the lift is discovered to be inoperative. (f) In any case in which a vehicle is operating on a fixed route with an inoperative lift, and the headway to the next accessible vehicle on the route exceeds 30 minutes, the entity shall promptly provide alternative transportation to individuals with disabilities who are unable to use the vehicle because its lift does not work. 37.165 Lift and securement use. (a) This section applies to public and private entities. (b) All common wheelchairs and their users shall be transported in the entity’s vehicles or other conveyances. The entity is not required to permit wheelchairs to ride in places other than designated securement locations in the vehicle, where such locations exist. (c)(1) For vehicles complying with part 38 of this title, the entity shall use the securement system to secure wheelchairs as provided in that Part. (2) For other vehicles transporting individuals who use wheelchairs, the entity shall provide and use a securement system to ensure that the wheelchair remains within the securement area. (3) The entity may require that an individual permit his or her wheelchair to be secured. (d) The entity may not deny transportation to a wheelchair or its user on the ground that the device cannot be secured or restrained satisfactorily by the vehicle’s securement system. (e) The entity may recommend to a user of a wheelchair that the individual transfer to a vehicle seat. The entity may not require the individual to transfer.
  • 4. (f) Where necessary or upon request, the entity’s personnel shall assist individuals with disabilities with the use of securement systems, ramps and lifts. If it is necessary for the personnel to leave their seats to provide this assistance, they shall do so. (g) The entity shall permit individuals with disabilities who do not use wheelchairs, including standees, to use a vehicle’s lift or ramp to enter the vehicle. Provided, that an entity is not required to permit such individuals to use a lift Model 141 manufactured by EEC, Inc. If the entity chooses not to allow such individuals to use such a lift, it shall clearly notify consumers of this fact by signage on the exterior of the vehicle (adjacent to and of equivalent size with the accessibility symbol). 37.167 Other service requirements. (e) The entity shall ensure that vehicle operators and other personnel make use of accessibility- related equipment or features required by part 38 of this title. (g) The entity shall not refuse to permit a passenger who uses a lift to disembark from a vehicle at any designated stop, unless the lift cannot be deployed, the lift will be damaged if it is deployed, or temporary conditions at the stop, not under the control of the entity, preclude the safe use of the stop by all passengers. (h) The entity shall not prohibit an individual with a disability from traveling with a respirator or portable oxygen supply, consistent with applicable Department of Transportation rules on the transportation of hazardous materials (49 CFR subtitle B, chapter 1, subchapter C). (i) The entity shall ensure that adequate time is provided to allow individuals with disabilities to complete boarding or disembarking from the vehicle. (j)(1) When an individual with a disability enters a vehicle, and because of a disability, the individual needs to sit in a seat or occupy a wheelchair securement location, the entity shall ask the following persons to move in order to allow the individual with a disability to occupy the seat or securement location: (i) Individuals, except other individuals with a disability or elderly persons, sitting in a location designated as priority seating for elderly and handicapped persons (or other seat as necessary); (ii) Individuals sitting in or a folddown or other movable seat in a wheelchair securement location. (3) The entity is not required to enforce the request that other passengers move from priority seating areas or wheelchair securement locations.
  • 5. (4) In all signage designating priority seating areas for elderly persons and persons with disabilities, or designating wheelchair securement areas, the entity shall include language informing persons sitting in these locations that they should comply with requests by transit provider personnel to vacate their seats to make room for an individual with a disability. This requirement applies to all fixed route vehicles when they are acquired by the entity or to new or replacement signage in the entity’s existing fixed route vehicles. [56 FR 45621, Sept. 6, 1991, as amended at 58 FR 63103, Nov. 30, 1993] 37.173 Training requirements. 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, with appropriate attention to the difference among individuals with disabilities. English Dictionary. proficiency – noun pro.fi.cien.cy 1. high degree of ability or skill. a high degree of ability or skill in something PART 38_AMERICANS WITH DISABILITIES ACT (ADA) ACCESSIBILITY SPECIFICATIONS FOR TRANSPORTATION VEHICLES Subpart B_Buses, Vans and Systems Sec. 38.23 Mobility aid accessibility. (a) General. All vehicles covered by this subpart shall provide a level-change mechanism or boarding device (e.g., lift or ramp) complying with paragraph (b) or (c) of this section and sufficient clearances to permit a wheelchair or other mobility aid user to reach a securement location. At least two securement locations and devices, complying with paragraph (d) of this section, shall be provided on vehicles in excess of 22 feet in length; at least one securement location and device, complying with paragraph (d) of this section, shall be provided on vehicles 22 feet in length or less. (b) Vehicle lift--(1) Design load. The design load of the lift shall be at least 600 pounds. Working parts, such as cables, pulleys, and shafts, which can be expected to wear, and upon which the lift depends for support of the load, shall have a safety factor of at least six,
  • 6. based on the ultimate strength of the material. Nonworking parts, such as platform, frame, and attachment hardware which would not be expected to wear, shall have a safety factor of at least three, based on the ultimate strength of the material. (11) Boarding direction. The lift shall permit both inboard and outboard facing of wheelchair and mobility aid users. (12) Use by standees. Lifts shall accommodate persons using walkers, crutches, canes or braces or who otherwise have difficulty using steps. The platform may be marked to indicate a preferred standing position. (d) Securement devices—(1) Design load. Securement systems on vehicles with GVWRs of 30,000 pounds or above, and their attachments to such vehicles, shall restrain a force in the forward longitudinal direction of up to 2,000 pounds per securement leg or clamping mechanism and a minimum of 4,000 pounds for each mobility aid. Securement systems on vehicles with GVWRs of up to 30,000 pounds, and their attachments to such vehicles, shall restrain a force in the forward longitudinal direction of up to 2,500 pounds per securement leg or clamping mechanism and a minimum of 5,000 pounds for each mobility aid. (2) Location and size. The securement system shall be placed as near to the accessible entrance as practicable and shall have a clear floor area of 30 inches by 48 inches. Such space shall adjoin, and may overlap, an access path. Not more than 6 inches of the required clear floor space may be accommodated for footrests under another seat provided there is a minimum of 9 inches from the floor to the lowest part of the seat overhanging the space. Securement areas may have fold-down seats to accommodate other passengers when a wheelchair or mobility aid is not occupying the area, provided the seats, when folded up, do not obstruct the clear floor space required. (3) Mobility aids accommodated. The securement system shall secure common wheelchairs and mobility aids and shall either be automatic or easily attached by a person familiar with the system and mobility aid and having average dexterity. ABREVIATIONS ADA: Americans with Disabilities Act
  • 7. ANSI: American National Standards Institute CFR: Code of Federal Regulations ISO: International Standardization Organization NIDRR: The National Institute on Disability and Rehabilitation and Research RERC: Rehabilitation Engineering Research Center RESNA: Rehabilitation Engineering and Assistive Technology Society of North America SAE: Society of Automotive Engineers WTORS: Wheelchair Tiedown and Occupant Restraint Systems WTS: Wheelchair Transportation Safety ANSI/RESNA/ISO Since the early 1980’s ANSI, RESNA and ISO have collaborated together to develop uniform and meaningful standards and measurements in regards to wheelchairs. ANSI and RESNA have had more concentrated efforts in items such as how a wheelchair is measured and tested. ISO has focused on minimum and maximum attributes of wheelchairs; i.e. mass to weight ratio, durability going over curbs repeatedly, braking power and ability to hold, etc. SAE J2249 SAE J2249 is a Report by the Society of Automotive Engineers (1996) on “Best Practices” for safe wheelchair securements and passenger restraints. This has become to be known as WTORS which is a voluntary but recommended Best Practice using four –
  • 8. point anchors and securements on wheelchairs and three point restraints for the passenger during transportation. The key elements are as follows: • It specifies design requirements, test methods, and performance requirements for WTORS, requirements for manufacturer’s instructions in installers and users, and requirements for product marking and labeling. • It specifies test procedures and performance requirements for a 30-mph (48-kph), 20-g frontal impact. • It specifies test procedures and performance requirements for webbing slippage at adjustment devices of strap-type wheelchair tiedowns, and for partial but ineffective engagement of wheelchair tiedowns and tiedown components. • It applies to WTORS used with forward-facing wheelchair-seated adults and children from age six. • It applies to passengers and drivers of personally licensed motor vehicles as well as to passengers of motor vehicles used in public and school transportation. • It applies to all types of WTORS, including those that use docking type wheelchair tiedowns. • It applies to components and subassemblies of WOTRS that manufacturers may want to certify as being in compliance with SAE J2249. WTORS When complying with a WTORS system and proper securement is achieved, it is presently the most secure method of transportation for an occupant on a wheelchair. However even the best system has its disadvantages: • Invasion of personal space. • Lengthy securement times. • Requires operator/attendant for securement. • Securement straps easily soiled or damaged. • Proper securement points undefined. • Extensive training/retraining to keep drivers proficient to most current standards. WC19-COMPLIANT WHEELCHAIRS
  • 9. WC 19 is a voluntary industry standard for designing, testing and labeling a wheelchair that is ready to be used as a seat in a motor vehicle. A WC19 wheelchair has: • Four permanently attached and labeled securement points that can withstand the forces of a 30 mph, 20 g impact. • Specific securement point geometry that will accept a securement strap or hook. • Securement point locations that allow easy access to aisle side and wall side securement points. • A clear path of travel that allows proper placement of vehicle mounted occupant safety belts next to the hip/pelvic area on the body. • Anchor points for an optional wheelchair anchored pelvic safety belt that is designed to withstand a 30 mph, 20 g impact that has a standard interface on it that allows it to connect to a vehicle-anchored shoulder belt. INTEGRATED SEATBELT DESIGN Another technology that is the target of innovation and research is seatbelt design. Recent studies have shown that seatbelts are rarely used properly on passengers seated in wheelchairs. In addition, seatbelts are often insufficiently adjustable for a range of individuals seated in a wheelchair. Seatbelts or wheelchair occupant restraints are only effective if they are positioned well and snug on the individual's pelvis and upper body (crossing the sternum and mid area of the collar bone). Tests have shown that integrating both good belt fit and proper location of the belts on the upper body and pelvis achieve a ride as safe as a passenger not seated on a wheelchair. A wheelchair with an integrated seatbelt offers a consistent custom fit that is properly snug. Additionally the person who uses a wheelchair with an integrated seatbelt is no longer dependent on an attendant for proper placement and fit of vehicle- anchored occupant restraints. Many individuals who use a wheelchair already use some type of pelvic belt or chest strap for postural support. These postural supports are often mistakenly relied upon during motor vehicle
  • 10. travel, which can result in occupant injury during a motor vehicle impact when a postural support breaks loose from the wheelchair frame. In some cases, a wheelchair integrated occupant restraint system could replace postural chest straps or pelvic straps, and thereby provide occupant protection as well as postural support during transportation. Replacing the function of a postural belt with a safety restraint would need to be individually evaluated by a clinical expert. Wheelchair integrated occupant restraints would also require knowledge of the user's ability to independently buckle or unbuckle a seatbelt. When transporting a small child, it is desirable to have a seatbelt buckle that can only be operated by a caregiver. User studies and design efforts are ongoing to re-design the user interface of buckles and fittings to keep them safe, as well as easier to use for individuals with limited hand function. AUTOMATED WHEELCHAIR DOCKING Automated docking technology to secure wheelchairs in vehicles may be a part of future innovations. This type of wheelchair securement gives the passenger seated in a wheelchair the freedom of independent securement. Due to the fact that there is only one way to dock a wheelchair into a docking securement system, it will be hard for the passenger seated in a wheelchair to make a mistake. If the individual cannot dock the wheelchair independently, it will be easier and less time consuming for a driver or caregiver to secure the wheelchair. The need for driver training on how to secure a wide variety of wheelchairs can almost be eliminated. REAR FACING WHEELCHAIR CONTAINMENT Another innovation that has been slowly entering the U.S. market is rear- facing wheelchair containment. This technology can only be used on large transit vehicles and is not safe for school buses or smaller para-transit vehicles. Here is how it works. The person using a wheelchair boards in the
  • 11. typical manner but then maneuvers into an area on the left or right side of the bus and backs up against a padded barrier, facing towards the rear of the bus. In this location, no other securement device is required, except a vertical floor to ceiling post or flip-down armrest-type barrier, located on the aisle side of the wheelchair space. In addition, vehicle-mounted occupant restraints are not required. The key advantage of this non-invasive, wheelchair containment arrangement is that it allows the user to enter and exit the vehicle independently without any intervention by the bus operator. Furthermore, any present-day wheelchair can use this technology and no additional hardware is needed on wheelchairs. A standard providing guidelines for testing and designing this technology is nearing completion. There are a couple of reasons that this innovation only works in large transit buses. In general, transit buses are a very safe means of people transport for both seated and standing passengers. They are usually the largest (heaviest) vehicle on the street and travel at relatively low speeds. This means, for example, that if you are a rider in a frontal collision on a large versus a small transport vehicle, assuming that all other factors are the same, you will experience lower injury producing forces acting on your body. The barrier behind the rear-facing wheelchair is designed to limit forward movement of the wheelchair and the occupant's upper torso and head. Sideways movement of the wheelchair is minimized by the lateral barriers such as an aisle-side post and the vehicle wall. Rebound movement is minimized by the energy absorption of the barrier and the wheelchairs brakes. INJURIES TO INDIVIDUALS OCCUPYING WHEELCHAIRS DURING VEHICLE TRANSPORTATION: A few recent studies have focused directly on injuries to individuals who use wheelchairs as seats in motor vehicles. In one cross-sectional study, 596 wheelchair users were interviewed about their involvements in motor-vehicle crashes and injuries they may have sustained (T. Songer et al., 2004). The screening interviews for the 596 subjects were followed by more in-depth surveys of 336 participants who used their wheelchair as a seat in a public or private vehicle, or both (Songer et al., 2005). More than one-quarter of the respondents (28.7%) reported sustaining at least one injury while using motor-vehicle transportation in the previous three years. Crash involvement was reported by 14.9% of the study population at an estimated rate of 10.6 events per 100,000 miles traveled. Of 65 respondents who reported being involved in at least one crash, 55 provided further details about their crash experience. Of these, 38% reported being injured in a crash, and two- thirds of the injured occupants required medical attention. Thus, 6% of the 336 occupants reported being injured while traveling seated in their wheelchair, which amounts to 3.6 injury
  • 12. events per 100,000 miles traveled. This is 45 times higher than the injury rate for the general automotive population of 0.08 injuries per 100,000 miles traveled (NHTSA, 2009) Recent studies provide increasing evidence that a large percentage of injuries and fatalities to wheelchair-seated travelers are being caused in non-collision events, such as abrupt vehicle turning maneuvers and hard braking (Frost & Bertocci, 2007, 2009a). The evidence further indicates that these injuries are due to the lack of proper wheelchair securement that result in the wheelchair moving within the vehicle or tipping over, and/or non-use or improper use of belt restraints by wheelchair passengers that result in the wheelchair occupant coming out of the wheelchair seat, resulting in injuries from contact with the vehicle interior (Frost & Bertocci, 2009b). Most wheelchair users have limited ability to stabilize their wheelchair or their position in the wheelchair by bracing or by grabbing vehicle components with their hands during these low-g, non-collision events, and therefore often sustain serious or fatal injuries in events where other passengers are uninjured (Fitzgerald et al., 2007). Songer et al. (2005) reported that non-crash injuries were most frequently reported to have occurred during entering and exiting vehicles (15.8% of respondents; 43.1 events per 100,000 miles traveled). However, injuries resulting from sudden vehicle maneuvers were reported with a similar frequency by 15.7% of respondents or at a rate of 31.8 events per 100,000 miles traveled. Most non-crash injuries arose from sudden braking (50%) or sharp turning (33.3%), which resulted in the wheelchair tipping over (33%), securement failure (22%), or the occupant falling out of the wheelchair seat (15.3%). While these studies are some of the first to report on frequencies and causes of injuries sustained by wheelchair users in motor vehicle transportation, the study populations represents a convenience sample and selection bias and the ability of participants to accurately report on past events may influence the results. However, the results document the general types and characteristics of injury events that are occurring to wheelchair-seated travelers, and raise concerns about the relatively high risk of injuries to occupants seated in wheelchairs. REDUCING OR ELIMINATING SECUREMENT ERRORS All stakeholders in the transportation of wheelchairs; passengers, drivers, attendants, supervisors, and the entities need to understand their role in providing the safe riding option.
  • 13. • Passengers need to understand the need to transfer out of non – compliant WC 19 wheelchairs when they are able to. They need to keep their wheelchairs/scooters clean and securement points accessible. They need to use both seatbelt and shoulder belt options for the safest option. • Drivers need to make sure that the securement task is completed to standard each and every time. That they take the time necessary to complete the securement and the passenger is accommodated. • Attendants need to assist in their capacity as a caregiver. • Supervisors need to make sure that drivers are complying with the standards. They also need to make sure that sufficient time is allotted to accommodate the passengers so that the drivers do not feel as though they need to rush. • Entities need to provide the resources necessary to accomplish the safe securements and restraints of wheelchairs and the passengers. Assist in educating the public and drivers, encouraging the passengers to transfer out of non WC19 wheelchairs, and enforcing policies, i.e. size and weight that support safe transportation for all passengers. THE BENEFITS OF SUPPORTING THE USE OF WHEELCHAIRS DESIGNED TO FUNCTION AS A MOTOR VEHICLE SEAT Transportation providers should encourage the purchase of wheelchairs designed for use as a motor vehicle seat by regular users of their services to increase driver efficiency and to reduce driver effort, errors, and injury potential. These wheelchairs will facilitate ease and proper use of WTORS, which will improve best practice and reduce overall liability. Recognizing the value of using and paying for wheelchairs designed to function as a motor vehicle seat requires greater knowledge among many stakeholders; consumers, rehabilitation/seating clinicians, rehabilitation counselors, suppliers, manufacturers, transportation agencies, driver educators, payers and policy makers. Creating equivalent safety for individuals who ride seated in wheelchairs extends to them the “equal protection” demanded by law, reduces human suffering and loss of life that may result from not exercising reasonable caution, and promulgates best practice supported by peer-reviewed research. RESNA encourages all of those in leadership positions involved in the wheelchair transportation community to do the right thing and influence
  • 14. the broader recognition and use of products designed to improve safety for those who use wheelchairs as seats during transportation. RESOURCES ANSI – AMERICAN NATIONAL STANDARDS INSTITUTE ISO – INTERNATIONAL STANDARDIZATION ORGANIZATION NTI – NATIONAL TRANSIT INSTITUTE NIDRR – THE NATIONAL INSTITUTE ON DISABILITY AND REHABILITATION AND RESEARCH RERC – REHABILITATION ENGINEERING RESEARCH CENTER RESNA – REHABILITATION ENGINEERING AND ASSISTIVE TECHNOLOGY SOCIETY OF NORTH AMERICA SAE – SOCIETY OF AUTOMOTIVE ENGINEERS