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LIGHT RAIL VEHICLES & SYSTEMS
Technical Assistance Manual
October, 1992
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Table of ContentsIntrodu ction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1Regulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5Vehicles Covered . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6Wheelchair and Mobility Aid Standards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
Minimum Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6Periodic Revisions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7How These Man uals ar e Organ ized . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7Other Publications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 71192.1 Purp ose. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 81192.2 Equivalent facilitation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 81192.3 Definitions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 91192.4 Miscellaneou s instru ctions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 121192.71 General. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 141192.73 Doorway s. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
(a) Clear width. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17(b) Signage. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18(c) Signa ls. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19(d) Coordination with boarding platform. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
(1) Requirem ents. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19(2) Exception. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20(3) Exception. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21(4) Exception. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21
1192.75 Priority seating sign s. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 221192.77 Interior circulation, han d rails and stanch ions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 231192.79 Floors, steps an d th reshold s. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 251192.81 Lighting. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 261192.83 Mobility aid accessibility. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
(a)(1) General. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27(2) Exception. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
(b) Vehicle lift. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29(1) Design load. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29(2) Controls. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29(3) Emergency operation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31(4) Pow er or equ ipm ent failure. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32(5) Platform barriers. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32(6) Platform surface. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34(7) Platform gap s. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35(8) Platform entrance ramp. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35(9) Platform deflection. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36(10) Platform movement. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36(11) Boarding direction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37(12) Use by stan dees. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37(13) Han dr ails. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37
(c) Vehicle ramp or brid ge plate. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39(1) Design load. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39
(2) Ramp surface. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39(3) Ramp th resh old . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40(4) Ramp barriers. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40(5) Slope. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40(6) Attachmen t. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42(7) Stowage. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42(8) Ha nd rails. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42
1192.85 Betw een-car barr iers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 431192.87 Public information system . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44
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Introduction
This technical assistance docum ent is one of a series provided to he lp in un derstand ing
the background and und erlying rationale of the Americans with Disabilities Act Accessibility
Guidelines for Tran sportation Vehicles (Vehicle Guid elines ) and how the gu ide lines m ay app ly
in a p articular case. The docum ents in this series are:
o Buses, Vans & Systems
o Rapid Rail Vehicles & System s
o Light Rail Vehicles & System s
o Comm uter Rail Cars & System s
o Intercity Rail Cars & System s
o Over-th e-Road Buses & System s
o Automated Guideway Transit Vehicles & Systems
o High-Speed Rail Cars, Monorails & Systems
o Trams, Similar Vehicles & Systems
The information in th is docum ent is based o n the p ream ble p ublished with th e Vehicle
Guidelines, augmented with material developed in response to questions wh ich hav e been
posed to t he Archi tect ura l an d Trans porta tion Bar rie rs C om plian ce Boar d (Acces s Boar d) sin ce
publ icat ion o f t he guidel ines. The Depa rtment of Transpor ta tion (DOT) has issued st andard s
for vehicles based on th e Guidelines. The guid ance in th is docum ent d oes not constitute a
determin ation of compliance with the DOT standard s or with you r right s or resp onsibilities
und er the ADA and is not binding on DOT.
BackgroundThe Am erican s w ith Disa bilit ies Act (ADA ) [P.L. 101-336, 42 U.S.C. 12101, et seq], signed
into law by Pres ident Bush on July 26, 1990, is land mark l egisla tion to extend civ il rights
protection to people w ith disabil it ies. The ADA p rohibits discrimination on the basis of
dis ability in employm ent, State an d local gov ernment services, pu blic transp ortation, pu blic
accom mod ations, comm ercial facilitie s, an d telecommunication s.
Title II of the ADA p rohibits d iscrimination on th e basis of disability in serv ices,
program s, an d act ivit ies p rovid ed by public ent ities, in cluding u nits o f Stat e an d local
govern men t and the N ationa l Railroad Passenger Corporation (Amtrak). Title II addr esses
pu blic transp ortation and contains provisions specifically add ressing the following typ es oftransit systems: fixed route bus, rap id rail, light ra il, comm uter rail, and intercity rail. Und er
title II, transit systems of these types which are owned or operated by p ublic entities, and
persons und er contrac t with such ent it ies , must be mad e read ily access ible to and u seab le by
individu als with disabilities, includ ing individu als who use w heelchairs. With respect to
pu bl ic enti ties, t itle II requires that :
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New Vehicles. New vehicles pu rchased or leased after August 25, 1990, must be accessible.
Used Vehicles. If used veh icles are purchased or leased afte r August 25, 1990, good faith
efforts must be made to o btain accessible vehicles.
Remanufactured Vehicles. If vehicles are reman ufactu red after Au gust 25, 1990, to extend
their useful life for 5 years or more in th e case of buses and rapid and light rail vehicles, or for
10 years in the case of commu ter and intercity rail cars, then the vehicles must be made
accessible to the maximum extent feasible.
"One-Car-Per-Train" Rule. At least one vehicle or car in each train of two or more cars must be
accessible a s soon as p racticable bu t in no event later than July 26, 1995, in the case of rap id,
light, commuter, and intercity rail system s.
Demand Responsive Systems. New vehicles purchased or leased after August 25, 1990, for use
in a deman d respon sive system operated by a public entity, or by a person unde r contract with
such an entity, must be accessible unless the system, when viewed in its entirety, provides to
individu als with d isabilities a level of service equivalent to that provided to oth er mem bers of
the gene ral p ublic.
Title III of the ADA p roh ibits d iscrimination on t he basis of d isabilit y in pu blic
accommo dations an d services provid ed by p riva te en tities. Und er title III, public
transportati on services (other than by aircraft) provided by p rivate entities must also be mad e
readily accessible to and usable by ind ividu als with disabilities, including ind ividuals wh o use
wheelchairs. Under title III, the following r equirements apply to private entities that are
prim ar ily eng aged in th e bu sin ess of tr an sp ortin g p eop le and who se opera tions affect
commerce:
New Vehicles. New veh icles pu rchased or leased after Au gust 25, 1990, must be a ccessible
unless the vehicle is to be used solely in a dem and responsive system that, when viewed in its
entirety, provid es to ind ividu als with disabilities a level of service equivalent to that provided
to other members of the general public. This requirement does not apply to automobiles, vanswith a seating capacity of less than 8 passeng ers, or over-the-road b uses.
Vans. New vans with a seating capacity of less than 8 passengers pu rchased or leased after
Februar y 25, 1992, must be a ccessible, unless th e system for w hich the van is being p urch ased
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or leased , when v iew ed in its ent irety, pr ovides to ind ivid uals w ith disabilit ies a level of service
equivalen t to that p rovid ed to other m embers of the gen era l public.
Rail Cars. New rail pa ssenger cars purchased or leased after February 25, 1992, must be
accessible. Rail passenger cars rem anufa ctured afte r Febru ary 25, 1992, to extend their u sefu l
life for 10 year s or more mu st b e mad e accessib le to the maximum extent feas ible.
For private entities not primarily engaged in the busines s of transporting people but
wh ose operations affect commerce, such as hotels, shopping centers, and recreational facilities
wh ich operate shuttle service for customers or patrons, title III requires that:
New Vehicles for Fixed Route Systems. New veh icles w ith a seat ing cap acity of m ore th an 16
passenge rs purchased o r leased af te r August 25, 1990, for use in f ixed route systems must b e
accessible. This requirement d oes not apply to over-the-road buses. New vehicles with a
seating cap acity of 16 passeng ers or less p urchased or leased after Au gust 25, 1990, for use in a
fixed route system mu st also be accessible unless the system, when view ed in it s entirety,
pro vides to ind ividu als with disabi lit ies a level of service equivalen t to tha t pr ovided to other
mem ber s of the gen era l pu blic.
New Vehicles for Demand Responsive Systems. New vehicles with a seating capacity of
more than 16 passengers, purchased or leased after August 25, 1990, for use in a demand
respon sive system mu st be accessible unless the system, w hen viewed in its entirety , provid es
to indi viduals with di sabilities a level of service equi valent to that provided to othe r mem bers
of th e genera l public.
Operation of Demand Responsive Systems. Deman d r esponsive systems mus t be ope rated in
such a man ner that after July 26, 1990, the system, when viewed in its entirety, provides to
individu als with d isabilities a level of service equivalent to that provided to oth er mem bers of
the general public.
Over-the-Road Buses. Title III specifically addresses over-the-road buses operated by private
entiti es. The Office of Technology Assessment (OTA) is responsible und er title III of the ADA
for studying the access needs of individuals with d isabilities to over-the-road buses and themost cost-effective method s for prov iding such access. In view of this ma nd ated stud y, over-
the-road b uses covered by tit le III are not requ ired to be accessible t o whee lchair or m obility aid
users u ntil July 26, 1997, for small prov iders an d July 26, 1996, for other p rovid ers. Over-the-
road buses p urch ased or leased after Jan uar y 26, 1992, bu t befor e July 26, 1996 or 1997 m ay be
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required to include accessibility features wh ich do not involve stru ctural changes or use of
board ing d evices.
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1The req uiremen ts for the size of platform lifts an d minimu m door he igh t for bu ses over 22feet in length a pp ly to solicita tions closin g on or after Jan uar y 26, 1992. See 49 CFR 37.13 andthe De cember 9, 1991, Federal Register(56 FR 64214).
5
Regulations
The Depa rtment of Transp ortation is respon sible for issuing regu lations to implem ent
the transp ortation prov isions of the ADA, including accessibility standard s for transportation
vehicles. The ADA required the Access Board to d evelop guidelines to provide guidan ce to
DOT on estab lishing th e accessibility stand ard s for tran spor tation v ehicles. DOT published
interim stand ard s on October 4, 1990 (55 FR 40762). Those standa rd s app ly to vehicles
purch ased aft er A ugu st 26, 1990, b ut befor e Oct ober 7, 1991.
The Access Board p ublished its minimum guidelines, known as the ADA Accessibility
Guid elines for Transportation Vehicles on September 6, 1991, in the Federal Register(56 FR
45530). The provisions for lifts, ramp s, and securemen t devices were daw n pr imarily from a
series of guidelines d eveloped a s part of a pr oject sponsored by th e Federal Transit
Admin istration (FTA), formerly th e Urban Mass Tran sportation Admin istration (UMTA), in
1986: Guide line Specifications for Passive Wheelcha ir Lifts, Guide line Sp ecifications for Active
Wheelchair Lifts, Guid eline Specifications for Wheelchair Ramps and Guideline Specifications
for Wheelchair Securement Dev ices. Provisions from the Guide line Specifications were
supp lemented with add itional materia l derived from common accessibility standards, such as
the Uniform Federal Accessibility Stand ards (UFAS) and the Am erican Na tional Stand ards
Inst itute (ANSI) A117.1-1980 specifications, research sponsored by the Access Board , and
ind ustry practice. Some p rovisions for Aut omated Guidew ay Transp ortation (AGT) "peop le
movers" and rapid rail systems were derived from Los Angeles Downtown People Mo ver:
Hand book on Accessibility for the Elderly and Hand icapped (UMTA, November 1980). In
ad dition, the guid elines incorpo rated provisions of 49 CFR Part 609 for bu ses, light rail and
rapid rail systems pu blished by UMTA in 1976.
These guidelines, codified at 36 CFR Part 1192, are no t, in and of themselves, thestandard s for vehicles but rather form the minimu m requirements for standards issued by
DOT. DOT has adopted the s ubstance of the guidelines (with minor editoria l differences) as
the accessibility stand ard s for tran spor tation v ehicles. The final DOT regu lation estab lishes
effective da tes for the accessibility stand ard and add ress when the stan dard s are to be ap plied
to veh icles for w hich a solicita tion closes after October 6, 1991.1 See 49 CFR 37.7. The man ua ls
in this series w ill deal only w ith the requ irements for vehicles procured after this d ate.
Vehicles Covered
The Board's Vehicle Guidelines p rimarily add ress new and remanu factured vehiclesinstead of existin g vehicles sin ce the ADA does n ot necessar ily requir e veh icle retrofit. Existing
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buses, for example, a re not required to be r et rofitted to meet the s tandard s o f Par t 38 of the
DOT regu lation. Even com plia nce w ith the "one-car-per-train rule" and the mobility aid seating
requirements for intercity rail cars can be met by the purchase of new vehicles. How ever, some
entities wh ich do not plan to pu rchase a sufficient num ber of new vehicles before the
compliance date for the "one-car-per-train" rule may choose to retrofit existing vehicles. For
these entities, th e Board has inclu ded p rovisions in the a pp ropriate general sections concernin g
such retrofitted vehicles.
Operations
The Vehicle Guidelines cover the design, manu facture and alteration of vehicles, not
their operation. Operational requirements are within the purv iew of DOT, not the Board, and
are cove red by Part 37 of the DOT rule, especia lly subpart s B and G. Except for the possibility
of operational procedures allowed u nd er the equivalent facilitation provision, discussed below,
the Board 's statu tory m anda te is to ensure accessibility of th e built enviro nm ent, includin g
instan ces in wh ich opera tional procedu res migh t fail. For examp le, the Board canno t assum e
that the strength, agility and a ttention of a driver will be sufficient to p revent a heavy
wh eelchair from rolling off a lift. Thu s, the Board h as included a requiremen t for lift platform
barr iers. Neither i s i t app ropriate, as one transit operator su ggested, to assume th at fellow
pa ssen ger s w ill h av e th e str en gth or s kill t o as sist pe rso ns with disab ilities to b oar d veh icles. It
is just as inapp ropriate to exp ect oth er p assengers to lift a w heelchair use r into a v ehicle as it is
to assume others should lift a wh eelchair over a curb or carry someone up a flight of stairs to
enter a build ing. Therefore, specific vertical and horizon tal gaps for rail vehicles are specified.
Wheelchair and Mobili ty Aid StandardsNeith er the A DA, nor a ny oth er statu te, confers up on th e Board the au thor ity to set
stand ard s or min imum req uirements for w heelchairs an d mobility aids. The ADA does,
how ever, p rovid e a clear m and ate to th e Board to set the m inimum req uiremen ts for vehicles.
The Board has attempted to carry ou t this charge in the fairest, most cost effective mann er
possible consis ten t with the stat ute .
Minimum Req uiremen ts
It shou ld be noted that these Vehicle Guidelines, and the DOT standard s based on them,
are minimum requirements. Standard s or specifications which provide greater access arepe rm itted . In ad dit ion, ther e are section s w hich expr essly p erm it alte rn ativ es (e.g., rear -facing
securement). The word "may" is used wh ere alternatives are permitted and shou ld not be
con str ued as a req uiremen t. Also, an ap pend ix has b een includ ed in th e gu idelines w hich
contains non-ma nd atory, advisory gu idance to assist in applying th e rule. The ma terial from
that app endix has been generally incorporated into the d iscussion material in this document.
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Periodic Revisi ons
The Board intends to con du ct period ic upd ates and r evision of the Vehicle Guidelines so
that future technologies and p ractices can b e incor porated into th em. As noted in th e follow ing
discussions, the Board feels th at add itional data an d stu dy are n eeded in regard to certain
issues and it intend s to further revise and mod ify these guidelines based on its review of
collected d ata an d stu dy results. Also, some variations deter mined to p rovide equivalent
facilitation m ay be explicitly incorporated in future up dates.
In addition, the Board plans to revise and up date these techn ical manu als as new
inform ation or techno logy su rfaces or as the Vehicle Gu idelin es th emselv es are ch anged . In
some places in these man uals, notation is mad e of drafting errors or sections where the
regu lation itself is unclea r. Several non-substantive ch anges in the regulation may be m ade in
the future a nd these chan ges will be reflected in revised editions of these m anu als.
How These Manuals are Organized
Each of these manu als deals w ith a sep arate tr ansportation mod e or vehicle type, based
on a particular su bpa rt of the final reg ulation (e.g., subp art B - Buses, Vans an d Systems;
subp art C - Rapid Rail Vehicles and Systems; etc.). However, since su bpart A ap plies to all
vehicles, it is included at the beginning of each man ual. Each manu al is se lf-contained so that
reference to oth er manu als is not necessary. Where th e provisions of the Vehicle Guidelines
refer to other mod es, or where the DOT regulation requires one type of vehicle to comply with
the requirem ents of another type, th e relevant sections are rep eated.
The portions of this docum ent which ap pear in boldare the provisions as they appear
in the fin al Vehicle Gu idelines. The text immediately follow ing is a d iscussion of the rationa le.
For purpo ses of this docu men t, the section nu mbers correspon d to the p rovisions a s theyappea r in Title 36 of the Cod e of Federal Regulation s. The nu mb ering system of DOT's
regu lat ion follow s th e same for mat with the exception o f the p refix nu mber (i.e., 1192.23(b)(6)
is substantive ly identi cal to 38.23(b)(6), etc.). Some of the prov isions, particularly the
requiremen ts for horizon tal gaps and vertical disp lacement betw een vehicles and platforms,
mu st be read in conjun ction w ith the station desig n requ irem ents in 36 CFR Pa rt 1191, wh ich
are included as Ap pend ix A of the DO T reg ulation at 49 CFR Part 37.
Other Publications
The Access Board ha s also made avai lable a checklist based on its ADA AccessibilityGuide lines (ADAAG) for Build ings and Facilities. ADAAG con tains requirements for tr ansit
facilities, in cludin g bu s stop s an d term inals, fixed facilit ies a nd sta tions , and airpor ts. The
Board al so publi shes technical bu lletins on certain sect ions in ADAAG . These publi cations are
ava ilable from the A ccess Board.
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Subpart A -- General
1192.1 Purpose.
This part provides minimum guidelines and requirements for access ibil ity standards
to be issu ed by the D epartment of Transportation in 49 CFR Part 37 for transportation
vehicles required to be accessibl e by the Ame ricans w ith Disabilities Act (ADA) of 1990,
42 U.S.C. 12101 et seq.
This section merely sets forth the pu rpose of the guidelines which is to establish the
minimu m requ irements for standards issued by DOT. Section 504 of the ADA requires the
Access Board to issue minimu m gu idelines and requirements for vehicles and facilities. In turn ,
DOT must issue standard s which are consistent with these guidelines. The DOT standard s
cou ld be m ore strict th an the gu idelines bu t cou ld no t provid e a le sser d egr ee of accessibility .
This format i s simi lar to that und er the Arch itectural Barriers Act of 1968 in which the Board
issued the Minimum Guidelines and Requirements for Accessible Design w hich sets the
baseline for th e Uni form Fe de ra l Access ibi lity Standard s (UFAS). As discussed p reviously, the
sta nd ard s th emselv es h ave been issu ed by DOT an d are cod ified at 49 CFR Pa rt 38.
1192.2 Equivalent facilitation.
Depa rtures from particular technical and scoping requirements of these guide lines
by use of o ther desi gns and technologi es are permitted where the al ternative designs and
technologie s used will prov ide s ubstantially equivalen t or greater access to and usabil ity of
the v ehicle. D epartures are to be consid ered on a case-by-case basis by th e D epartment of
Trans portation under the procedure set forth in 49 CFR 37.7.
The Board and DOT agree that there is a need for some flexibility to address uniq ue and
spec ial circumstances and to facilitate the appl ication of new technologies. There fore, an
"equivalent facilitation" provision has been included that is similar to the provision in the
buildings and facilities guidel ines . DOT has es tabl ished p rocedures und er which an entity
(e.g., transit agencies, providers, etc.) may pu rsue a lternative means of providing accessibility
with resp ect to specific requiremen ts of the standard . The FTA or Federal Railroad
Admin istration (FRA) Adm inistrator will determine on a case-by-case basis w hether equ ivalentfacilitation is p rovid ed. See 49 CFR 37.7 for the d etailed procedu res which m ust be follow ed as
part of an app licat ion to the Adm inistrator for an equivalent fac ilitat ion determ inat ion. DOT
inten ds to consult w ith the Board in mak ing determ ination s of equ iva len cy.
The Board wishes to p oint out tha t equ ivalent facilitation d oes not constitute a w aiver
from any accessibility requirement and is not a lesser standard of accessibility. Alternate
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designs and technologies may be used only where th ey will provide su bstantially equivalent or
greater access to, an d u sability of, a vehicle. The Board encou rages that, when consid ering
alternative designs and tech nologies, entities consult with in dividuals with disabilities and
their organiza tions at the ear liest possib le stage of the process. The Board is avai lable to
provid e technical assistance regarding equ ivalent facili tation.
In developing an equivalent facilitation proposal, an entity should consider th e intent of
the gu ideline or stand ard requ irement. For example, large buses are requ ired to h ave a
doorwa y heigh t of 5'8" from the ra ised lift platform . This height, althou gh it accomm odates
only about 70% of the adult male popu lation, is intended to prov ide some minimu m head
clearance for sta nd ees.
This clearance is especially imp ortant wh ere a standee wou ld be positioned outside the
vehicle door w hen the lift is d own b ut is m oved u p an d th rough the door as the lift is raised .
Other mod els of lifts do not mo ve the stand ee throu gh the door, but the individu al wou ld need
to p ass th rou gh the d oor after the lift is raised . While it is n ot p racticable to p rovid e clea rance
for the 90th percentile stand ee, it is desir able to provid e as m uch h ead room as possible, since
du cking to clear the door way may be m ore difficult for persons w ith ambulat ory disabilities
than for other m embers of the general pop ulation . A greater h eight w as not sp ecified becau se
information supp lied by vehicle manufacturers indicated that this height was consistent with
that needed to accommod ate overh ead door open ing m echanism s and roof lines.
How ever, some lifts are designed such that th e motion is entirely vertical ("elevator"
type lifts) and a stand ee is positioned at the full inboard edge and is raised fully within the
vehicle, clear of the door lintel. In this case, the FTA Adm inistrator has determined th at the
intent of the doorw ay height requ irement is being met by the particular lift configuration,
pro vided the location of th e han dr ails i s such tha t the fu ll inboard stand ing p osi tion is viable.
1192.3 Defini tions.
Access iblemeans, with respect to vehicles cove red by this part, compliance with the
provisi ons of this part.
Aut omat ed guidew ay transit (AGT)sys tem means a fixed-guide way transportation
system w hich ope rates w ith automated (driverless) ind ividual vehicles or multi-car trains.
Service may be on a fixed schedul e or in respo nse to a passenger-activated call b utton. Suchsystems using small, slow moving vehicles, often ope rated in airports and amuse ment
parks, are somet imes called "people movers".
Busmeans any of several types of se lf-propelled veh icles, other than an over-the-road
bus, generally rubber tired, intended for use on ci ty streets, highways, and busways,
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includin g but not l imited to minibuses, forty- and thirty-foot transit bus es, articulated buses ,
doubl e-de ck buses, and electric pow ered trolley buses, used to provide designated or
specifie d publ ic transportation services. Sel f-propel led, rubber tire vehicles desig ned to loo k
like antiqu e or vintage trolleys o r street cars are considered buses .
Common w heelchairs and mobility aidsmeans belonging to a class of three or four
wheeled dev ices, usab le indoors, desig ned for and used by persons w ith m obility
impairments w hich do not exceed 30 inches in width and 48 inches in length, measured 2
inches above the ground, and do not weigh more than 600 pounds when occupied .
Commuter rail carmeans a rail passeng er car obtained by a commuter authority (as
define d by 49 CFR 37.3) for use in comm uter rail transportation.
Commuter rail tra nsportat ionmeans short-haul rail passenger service operating in
metropol itan and suburban areas, operated by a commu ter authority whe ther w ithin or
across the geographical boundaries of a state, usually characterized by reduced fare, multipl e
ride , and commutation tickets and by morning and eve ning peak period operations. This
term does not include li ght or rapid rail transportation .
Demand respons iv e sy st emmeans any system of transporting individuals, including
the p rovisio n of desig nated publi c transportation service by p ublic entitie s and the
provision of transportation service by private enti ties, including but not limited to specified
publi c transportation service , whi ch is not a f ixed route sys tem.
Designated public transpor ta tion means transpo rtation provided by a publ ic entity
(other than public school transportation) by bus, rail, or other conveyance (other than
transportation by aircraft or intercity or commuter rail transportation) that provides the
gene ral publ ic w ith general or special se rvice, includi ng charter servi ce, on a regular and
continuing ba sis.
Fixed rout e sy st emmeans a system of transpo rting individuals (other than by
aircraft), inc luding the provis ion of designated public transportation service by public
entitie s and the provis ion of transportation service by p rivate entiti es, includi ng but notlimi ted to specified public transpo rtation service , on which a ve hicle is operated along a
prescribed route according to a fixed schedule.
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High s peed rai lmeans an interci ty-type rai l service w hich operates primari ly on a
dedicated gui dew ay or track not use d, for the most part, by f reight, includi ng, but not
limited to, trains on w elded rail, magne tical ly levitated (maglev) vehicles on a special
guideway, or other advanced technology veh icles, designed to travel at speeds in excess of
those possible on other types of railroads.
Intercit y rail passenger carmeans a rail car intended for use by revenue passengers
obtained by the National Railroad Passenger Corporation (Amtrak) for use in intercity rail
transportation.
Intercit y ra il transpor tation means transportation provided by Amtrak.
Li ght ra ilmeans a s treetcar-type v ehicl e railw ay operated on city streets , sem i-priv ate
rights-of-way, or exclusive private right s-of-way. Service may be provided by step-entry
vehicles or by level-boarding.
New vehiclemeans a vehicle w hich is offered for sale or lease af ter manufacture
without any prior use.
Ov er-the-road busmeans a vehicle characterized by an elevated passenger deck
located ove r a baggage compartment.
Ra pi d railmeans a subw ay-type transit veh icle railw ay op erated on excl usive private
right s-of-way wi th h igh-level p latform stations. Rapid rail may als o operate on elev ated o r
at-grade leve l track separated from other traffic.
Remanufactured v ehiclemeans a vehicle whi ch has been structurally restored and has
had new or rebui lt major compo nents instal led to extend its se rvice life .
Sp ecified public transporta tion means transportation by bus, rail, or any other
convey ance (other than aircraft) provided by a private entity to the general public, w ith
gene ral or special se rvice (includi ng charter servi ce) on a regular and co ntinu ing basis.
Trammeans any of several types of motor vehicles cons isting of a tractor unit, wi th or
without passeng er accommo dation s, and o ne or more passe nger trailer units, including but
not limi ted to vehicles provid ing shu ttle service to remote parking areas, be tween hotels and
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othe r public accommodations, and betwee n and withi n amu sement parks and other
recreation areas.
Used vehiclemeans a vehicle with prior use.
The definitions in this section are consistent w ith the de finitions included in the DOT
final rule. This set of d efinitions, h owever, does not inclu de some terms which are included in
the DOT rule, primarily those which concern operational issues not add ressed by the
guidel ines. Notice that the term "accessible" means compliance with the pr ovisions of the
guidelines (or the DOT standards in 49 CFR Part 38) wh ich includ es any determ inations of
equ iva lent facilitation.
1192.4 Misce llaneo us ins tructions.
(a) Dimensional conventions. Dimensions that are not noted as minimum or
maximum are absolute.
(b) Dimensional tolerances. All dimensions are subject to conventional
engineering tolerances fo r material properties and fie ld condi tions, includi ng normal
anticipated w ear not exceeding accepted i ndustry-wide s tandards and practices.
(c) Notes. The text of these guidelines does not contain notes or footnotes.
Addi tional info rmation, e xplanation s, and advisory materials are located in the Appendix.
(d) General terminology. The terms used in this part shall have the following
meanings:
(1) Comply wit hmeans meet one or more specification of these guidelines.
(2)If, or if...t hendenotes a specification that applies only when the conditions
described are present.
(3)May denotes an option or alternative.
(4)Shalldenotes a mandatory specif ication or requireme nt.
(5)Shoulddeno tes an advisory specifi cation or recommendation and is used only in
the appendi x to thi s part.
This section contains sev era l provision s desig ned to r edu ce som e con fusion which
became evident in th e responses to the original prop osed regulation. It contains miscellaneous
instr uctions, includ ing dimen sional conv entions an d tolera nces, an d genera l term inology. Anapp end ix was also added to the final guidelines that contains additional information,
explanations, and a dvisory materials. That material is summ arized in the discussion sections of
this d ocum ent, w here ap propriate.
With respect to dimensional tolerances, certain materials expand or contract due to
variations in temperatur e or durin g the process of "curing " or dryin g. As a result, even close
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tolerances du ring constru ction or manu facture cannot insu re continu ed conforman ce to a given
standard . For example , a cable-driven historic inclined system has been modified to be
genera lly accessible. How ever, the cable is sub ject to un controllable stretch ing durin g the d ay,
especially in hot weather. The cars generally provide level entry in the morning, but may be
significantly out of alignmen t by the end of the day. Such variation , even in a n ew system,
resu lting from material var iation s beyon d the con trol of the op erat or wou ld not be deem ed in
viola tion of the guide lines. Furthermore, u nlike bu ildin gs an d facilities w hich are essentially
stationary objects, vehicles move and h ave dyna mic as w ell as static "envelop es". Springs lose
their elasticity, steel rails and wh eels wear d own , and sup posedly "fixed" objects settle du e to
dynam ic stress. The allow ance for normal w ear, how ever, is onlyto b e ap plied in accor dan ce
with accep ted indu str y stan dards and practices , notsimply an agency p olicy. If the industry,
includ ing designer s, engineers, manu facturers, operators, and recognized p rofessional
associations agree th at a sp ecific ad herence can be a chieved above that allow ed by an agency
po licy or prac tice, it is th e i ndus try s tandard which i s t o be app li ed , n ot the agency po licy.
Reliance on dim ensiona l tolerances, how ever, is not an excuse for improp er or d eferred
mainten ance, or poor design or construction method s. For example, the claim of "dimensional
tolerances" could not be mad e for a lift which fails to meet the vehicle floor within the limits
specified in these gu ide lines, sim ply becau se an ad justm ent w hich could have been reas onably
mad e to a control system or limit switch was not made. Neither could a rail operator be
excused from compliance because it accepted vehicles from a m anu facturer w hich did n ot meet
the op erator's bid specification. Nor could a group of manu facturers, op erators or designers,
for exam ple, sim ply get together to ad opt a low er "standa rd " solely for th e pu rpose of relaxing
compliance. Such a change w ould need to be acknowledged by a significant segment of the
indu stry to constitute an "accepted indu stry standard or p ractice." Moreover, dimensionaltolerances ap ply to the construction, m anu facture or op era tion o f a sy stem, not to th e desig n.
An entity cannot issue vehicle specifications which ar e less stringent than those required by the
guidelines; nor could it justify a w ider h orizont al gap as being w ithin d imensional tolerances
because it did not spec ify its veh icles to be wi th in achievable limi ts for sway o r s tabi lity .
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Subpart D -- Light Rail Vehicles and Systems
1192.71 General.
(a) New , used and remanufactured light rail vehicles , to be considered accessib le by
regulations issued by the Department of Transportation in 49 CFR Part 37, shall comply with
this subpart.
The Americans with Disabilities Act (ADA) requires new or used vehicles that are
pu rchased or leased after Aug ust 25, 1990, to be accessible . A pu blic enti ty may p urchase or
lease a used l ight rail vehicle for use on its system that is no t readily accessible to and usable by
individuals with disabil ities, if after maki ng demonstr ated good faith ef forts to obtain an
accessible v ehicle, it is un able to d o so. See 49 CFR 37.87(c) for a d escr iption of wha t
constitutes good faith efforts. Vehicles that a re remanu factured after th is date to exten d their
usable life for 5 years or more are also required to be accessible, to the extent it does not
comprom ise the structural integrity of the vehicle. On October 4, 1990, the U.S. Departmen t of
Transp ortation (D OT) issued an inter im set of requ irem ents for such v ehicles.
The g uidelines discussed in this technical assistance d ocum ent are s ubstantively
identi cal to standard s issued by DO T on September 6, 1991, at 49 CFR Part 38 and r eplace the
interim ru les. The DO T rule at 49 CFR Par t 37 further ou tlines th e applicability an d effective
dates of these requiremen ts. Questions as to w hether certain vehicles are subject to these
sta nd ard s and specific effectiv e d ates sh ould be directed to D OT.
(b)(1) Vehicles intended to be operated so lely in light rail sys tems confined entirely
to a dedicated right-of-w ay, and for which all stations or stops are desi gned and co nstructed
for revenue service after the eff ective date of standards fo r desi gn and cons truction issued
pursuant to subp art C of 49 CFR Part 37, shall provid e lev el boarding and s hall comp ly w ith
1192.73(d)(1) and 1192.85.
This provision requires that newly d esigned and constru cted light rail systems
operating on d edicated rights-of-way provid e level boarding. Level boarding p rovides the
most accessibility for the maximum num ber of people and is opera tionally sup erior to
dep loying b oarding d evices such as lifts, ram ps, or brid ge plates. It can significan tly red uce
station d well times required for p assenger board ing an d aligh ting. In new constru ction, levelboarding can be ach ieved in some cases wh en grading th e s ite by piling the d ir t f ill next to the
track an d p lacing a concrete slab on top to coordin ate with th e level of the train floor. In other
cases, it may be n ecessary to construct a h igh-level platform . The vehicles of such system s mu st
be coord inated with the boa rd ing p latform a s specified by section 1192.73(d)(1) and eq uip ped
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with betw een-car barriers that prevent or w arn persons from accidently stepping off the
plat form bet ween cars acco rd ing to section 1192.85.
It is important that op erators review subp art C of DOT's rule for the effective date of
standard s for design and construction of transit facilities, including light rail stations. In its
rule, DOT explains that the r equirement tha t new facilities be accessible "is keyed to
constru ction which 'begins' after January 25, 1992. The regu lation d efines 'begin' to m ean w hen
a notice to proceed has been issued . This term has a standard m eaning in th e construction
indu stry as an instruction to the contractor to proceed with the w ork." Thus, regardless of the
design work w hich preceded it, the issuan ce of a notice to proceed with construction on or after
January 26, 1992, triggers th e req uirem ents for new stations. See also 49 CFR Part 37, Ap pend ix
A.
(2) Vehicles desig ned fo r, and operated on, pe destrian malls, city streets, or other
areas where l evel boarding is not practicable shal l provide waysi de or car-borne lif ts, mini-
high platforms, or other means of access in compliance with 1192.83(b) or (c).
This provision takes into account th at level boarding is not easily provided at stops
along city streets or on ped estrian malls. Often, there is no space at such sites for platforms for
level boarding. The "other areas w here level boa rd ing is not pra cticable" wou ld includ e any
oth er stop location s lackin g space for platfor ms. It is imp ortant in the d evelopm ent of light rail
systems that consideration be given to the selection of stop locations. A new system that
operated on both a ded icated right-of-way and p edestrian ma lls or city streets would not be
required to provide level boardin g according to p aragraph (b)(1) since that p rovision per tain s
to systems "confined entirely to a d edicated right-of-way." How ever, the Board recommend sthat, in such systems, level boarding be provided at a ll stops where it is feasible to do so.
(c) If portions of the vehicle are modifi ed in a way that affects or could affe ct
accessibi lity, each such po rtion shall compl y, to the extent practicable, w ith the applicable
provisions of this subpart. This provision does not requi re that inaccessible vehic les be
retrofit ted with lift s, ramps or other boarding devices.
This provision is similar to existing requirements of common accessibility codes and
should be viewed a s an "opportunity" clause. That is, when modifications are mad e for anyreason , the opp ortunity m ust be explored to prov ide th e maxim um access feasible. When a
vehicle is modified, each element that is part of the mod ification should be brought into
compliance with the app licable sections of these requirements . For examp le, if a vehicle's floor
is resurfaced and its electrical system rewired, the new floor surface must be slip resistan t at
aisles and ar eas used by standees and mob ility aid use rs. If existing audible signals a re
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replaced or rewir ed, the installation of audibl e and visu al alarms would als o be requ ired as pa rt
of the m odification pr oject. The intent of this provision is t o en sure th at elem ents of a vehicle
will be mad e accessible when the oppo rtunity to d o so exists in t he regu lar cou rse of m odifying
or up grad ing vehicles. How ever, those elements of the vehicle not affected by th e mod ification
plan wou ld no t have to be brought i nto conformance wi th these requ irements . Unde r any
mod ification plan, the installation of a lift, ramp , bridge plate or other board ing device is not
required, even if the entra nce of a vehicle is mod ified.
(d) Existing vehicles retrofitted to comply w ith the "one-car-per-train rule" at 49 CFR
37.93 shall comply with 1192.75, 1192.77(c), 1192.79(a) and 1192.83(a) and shall have, in new
and key stations, at least one door which complies with 1192.73(a)(1), (b) and (d). Vehicles
previou sly designed and manuf actured in accordance w ith the accessibi lity requirements o f
49 CFR Part 609 or Department of Transportation regu lations implementing section 504 of
the Rehabi litation Act of 1973 that were in effect before October 7, 1991 and which can be
entered and us ed from s tations in w hich they are to be operated, may be used to satisfy the
requirements of 49 CFR 37.93.
The ADA requires that at least one car in each train of two or more cars be accessible by
1995. Some op erators w ill choose to m ake existing cars accessible in ord er to me et th is
requirement. In such situations, this provision requires only that vehicles conform to the
following:
REQUIREMEN TS FOR RETROFITTED CARS
Priority sea tin g sign s an d signs desig nating w heelchair/ mobility aid locations (if su ch
locations are p rovided)
Clear floor space (so that a route 32 inches wide leading to an area that can
accommo date tw o wh eelchair spa ces each 30 by 48 inches in size is p rovid ed)
Slip resistan t floor surfaces
Board ing d evices (lift, ramp or bridge plate) w here level en try is not prov ided
One accessible door that in new and key stations:
- provides 32 inches o f clear width ;
- is designat ed by th e In te rnational Sym bol of Accessibility ; and
- is coordinated with the p latform so th at the horizon tal gap does not exceed 4
inches and the veh icle floor is within plu s or minu s 2 inches of the platform
height when th e vehicle is loaded to 50% of its capaci ty
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Existing vehicles that meet previous accessibility standard s can also be used to meet the
"one-car-per-train" rule without an y retrofit, provided they can be entered an d u sed from the
stations or stops at wh ich they ar e to be used . Specifically, these standa rds include those issu ed
by the FTA, vehicles obtained w ith FTA funds, and those issued by DOT un der Section 504 of
the Rehabilitation Act of 1973, which cover transit system s receiving Federal fund s. Further
inform ation on these stand ard s can be o btain ed from DOT.
1192.73 Doorways.
(a) Clear width. (1) All passenger doorways on vehic le sides shal l have minimum
clear openings of 32 inches when open.
This provision for a clear opening w idth of 32 inches has been in effec t since 1976 for
FTA-fun ded v ehicles and sho uld be met eas ily. The d oor w idt h specified is n ot design ed solely
to accommodate wh eelchair users. Rather, the dimension is d esigned to pr ovide space for
crutch-tip -to-crutch-tip d istance of a typical crut ch user. Also, the requ iremen t is for a "clear
opening." The provision of a wide doorway with a vertical stanchion in the center does not
meet the requirement.
(2) If doorways connecting adjoining cars in a multi-car train are provided, and if
such doorway is connected by an aisl e w ith a min imum clear w idth of 30 inches to on e or
more spaces where whe elchair or mobility aid users can be accommodated, then such
doorway shall have a mini mum clear open ing of 30 inches to permit wheelchair and
mobili ty aid users to be e vacuated to an adjoin ing veh icle in an emergency.
This requirement applies only to new vehicles equipped w ith end doors that can be
rea ched by a whe elchair or m obility aid user. This mean s th at w here there is a r oute at lea st 30
inches w ide lead ing from the area contain ing accessible spaces to the end d oor, then the end
doors mu st provide a minim um of 30 inches clear width . Since the clear area in w hich mobility
aid u sers can position themselves is usually located at the en ds of cars, the en d d oors will most
likely be in close proximity to accessible spaces. This requ iremen t does n ot apply to vehicles
that are desig ned with a route leading to the end door s that is less than 30 inches wide at any
point or th at is inaccessible in any other asp ect (e.g., s teps). How ever, this provision should not
be v iew ed as a n excuse to ar bit ra rily place stanch ion s or ar rang e sea ts t o p reclude a 30-in chwid e passa ge to avoid having to specify 30-inch wide end doors.
These guidelines do not address evacuation procedures or require that end doors be
used in em ergencies or that they be part of an evacuation route. For a variety of reasons, the
end do ors m ight n ot be used by a tran sit sys tem 's evacuation plan. In ad dit ion, a transit
system 's evacuation plan tha t requir es the use of side d oors w ould n ot be pr eclud ed by th is
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pro vision. Fur th er, the evacu ation ro ute lead ing from the tra in itself is often ina ccessible,
especially in the case of rapid rail where n arrow w alkways, catwalks, and escape ladders are
pa rt of ev acu ation rou tes fro m t un nels . Non eth eless, th e en d d oors of new veh icles can easily
be designed to be funct iona lly accessible (i.e., have 30 inches of clear width) and s hould be
accessible in caseth ey m ay serve as a n a ccessible mean s of egr ess. In limited emerg encies, such
as w hen t he side d oor s of a car fail, accessible end doors w ould be the on ly mean s of exit.
Addit iona lly, the Board recognizes that th is provision d oes not gu arantee access in to ad joining
cars sin ce existing cars ma y not have end doors w ith 30 inches of clear w idth. H owever, as old
cars are r eplaced over time and the num ber of accessible cars on each train increases, the
cha nces of pro vid ing an accessible connection b etw een cars will be greater.
Existing cars or cars r etrofitted un der the "one-car-per -train " rule are n ot su bject to th is
requirement.
(b) Signage. The International Symbol of Access ibil ity shall be displayed on the
exterior of each veh icle operating on an accessible light rail system unless all vehicles are
accessible and are no t marked by th e access symbol . (See Fig. 6)
Under this requ irement, all new vehicles must be
designated by the International Symbol of Accessibility
(access symbol) show n in Figure 6 below. H owever,
new veh icles acqu ired for a light ra il system in w hich
all vehicles are accessible and w hich are n ot designated
by t he s ym bol d o no t h ave to be de sign ated . In fully
accessible systems, consist ency is importan t, so th at ifexisting accessible vehicles are designated, n ew
vehicles should be design ated as wel l. Still, the Board
considers the access symbol to be at times subject to
over-use and thus recommends that transit operators
rem ove symbo ls w hen a ll cars are accessib le. Since
cars are u sually d esignated by d ecals, w hich even tually
wear and m ust be replaced, operators may opt to
sim ply not rep lace them.
The p lacem ent of the access symb ol is no t sp ecified by these gu idelines. It isrecom mend ed th at th e sym bol be placed a t each accessible p assen ger d oor of an a ccessible
veh icle. How ever , if the clear floor area for w heelchair or m obility aid users is prov ided a t only
one end of a ca r, then o nly those p assen ger doors at th at location sho uld be d esignated .
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(c) Signals. Auditory and visual w arning signals shal l be provided to alert
passe ngers of clos ing doo rs.
Audible sign als ar e req uired by exist ing FTA regu lation s, in effect since 1976. Audible
signals usually activate before the doors begin to close and th us provide advan ce warning that
the doors are about to close. Without visua l signals, persons w ith hearing impairm ents are not
afford ed an y equivalen t advan ce wa rning an d can on ly detect closin gs as the d oors actually
begin to close. According to inform ation received du ring th e dev elopm ent of th ese guid elines,
the ad dition of audible and visual w arning signals for auto matically-operated doors of new
vehicles is feasible and r epresen ts only a m odest cost increase for a chime, light, and asso ciated
electrical con trols at each d oorw ay. These signals are not requir ed to be provid ed on existing
vehicles or th ose that are retrofitted. Since proposed requirements for door closing force and
speed hav e been removed, the Board considers the provision of audible and visual indicators to
be o f eve n g rea ter importance .
The term "passengers" means persons within the trans it system including th ose who are
on the train and those waiting to board. Therefore, warning signals should be visible from both
inside and outsid e the veh icle. This can be achieved by equipp ing th e entra nces of new
vehicles with both an inte rior and exterior ligh t ind icator. Also, it is con ceivable that a single
light ind icator , by either its illu min ation level, design, or placement ma y be specified so th at it
is visible both inside and o utside the vehicle. Either m ethod of addr essing this requirement is
acceptable so long as it provides a visua l warning that door s are about to close. Further, vis ual
indicators should be synchronized with au dible signals so that equivalent advance notification
of door closu re is prov ided to all person s, including those w ith hea ring or visual impairm ents.
(d) Coordination with boarding platform. - (1) Requirements. The design o f leve l-
entry vehicle s shall be coordinated w ith the boarding platform or mini-high platform design
so that the horizontal gap betw een a veh icle at rest and the pl atform shall be no greater than
3 inches and the he ight of the veh icle floor shal l be w ithi n plus or minus 5/8 inch of the
platform height. Vertical ali gnment may be accomplished by vehicle air suspensi on,
autom atic ramps or lif ts, or any combin ation .
This provision an d the exceptions that follow outline the maximum hor izontal gap and
vertical tolerance allowed. How ever, vehicles should be sp ecified to be level with the platformedge and as close to it horizontally as possible, so that un der norm al passen ger cond itions these
maximu m levels are not exceeded . These tolerances, even w hen sp ecified in the acquisition of
new veh icles, m ay not be ach ieved und er a ll con ditions throu ghout th e ve hicle lifetime. The
requirements are based on norm al passenger cond itions. It is incumben t on the op erator not
only to specify the correct floor height w hen ordering v ehicles (and to accept them only if they
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meet th e sp ecification) bu t also t o correctly specify the ra il-to -platform he igh t for ne w sta tions .
Thus, it is impor tant to keep in mind t hat the ho rizontal gap and ver tical tolerance are
dep end ent not on ly on the vehicle specifications but also the d esign and construction of station
plat fo rms. Those requirements , inc luding gap r equi rements and the ra il-to -plat fo rm he ight , are
provid ed at 49 CFR Pa rt 37, Ap pen dix A.
In those instances where a n ew ligh t rail system could n ot meet these ga p requirem ents,
the op erator w ould be able to p ursu e alternative means of reducing g aps u nd er the procedu re
for equivalent facilitation contained in DOT's rule (see 49 CFR 37.7). Also, the Board recognizes
that close tolerances du rin g con str uction o r manu facture ca nnot insu re continu ed conform ance
to a given standard . Variations, such as those resulting from norm al wear or materia l
variations wou ld not be d eemed violations of the guidelines. How ever, only those variations
within the limits of accepted indu stry practices or tolerances are allowed. (See Subp art A at the
beginning of this manual for further d iscussion o f dimensional to lerances .) Adequate
maintenan ce must be performed to ensu re the vehicles remain with in acceptable tolerances.
(2) Exception. N ew vehicles operating in existing stations may have a f loor height
within plus or minus 1-1/2 inches of the platform height. At key stations , the horizontal gap
between at least one d oor of each such vehi cle and the platform shall be no greater than 3
inches.
The ability to closely align new vehicles with exis ting station platfo rms is limited by the
rail-to-platform heig ht an d the v ertical distan ce betw een the track and t he p latform. Existing
stations are not requ ired to be altered un der th e ADA , unless they ar e a "key" stat ion. This
pro vis ion allow s new vehicles serving exist ing stations, includ ing key sta tions, a great ervertical toleran ce since the existing p latform heigh t may m ake the 5/ 8 inch tolerance infeasible.
Nev ertheless, the g oal is for the veh icle floor and platform to be at th e same h eight. The great er
allow ance und er this p rovision is not an excuse to cre ate unn ecessar y barriers.
A consistent horizontal gap along all vehicles of a train may not be feasible due to the
design of existing stations, such as those that h ave curved platforms. (This, however, is more
pert inen t t o commu ter and rapid r ai l s ta tions). In view of t his, the three-inch h or izon ta l gap
requirement has been limited only to key sta tions, wh ich are req uir ed to be made accessible
un der the ADA, and does n ot apply to other existing sta tions. Further, only one door of a new
vehicle is requ ired to m eet the 3 inch g ap req uiremen t since, in the case of cu rved sta tions, aun iform gap cannot be achieved along the entire side a veh icle. A transit system could, as one
transit operator h as suggested, designate one location wh ere such tolerances are achieved along
a portion of a curved station p latform. N ew veh icles could be or dered with a slight sill
pro tru sion to red uce the h orizont al gap in station s wh ere a w ider ga p cur rently exists .
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(3) Exception. Retrofit ted vehicles shall be coordina ted with the platform in new and
key stati ons such th at the horizontal gap shall be n o greater than 4 inches and the he ight of
the v ehicle f loor, under 50% pass enger load, shall be w ithi n plus or minus 2 inches of the
platform height.
This exception p ertains to exist ing vehicles t hat are m ad e accessible u nd er t he "one-car-
per- train" ru le . Genera lly, ex isting vehicles cannot be coordinated w ith the plat fo rm to the
degree that new vehicles can. Even if feasible, retro fitting existing vehicles to meet the
requiremen ts for new vehicles, could be ver y expensive. Consequ ently, this exception allows a
greater and more easily achievable horizontal gap and vertical tolerance. These veh icles need
to be aligned with the p latform at new stations or key stations so that the h orizont al gap does
not exceed 4 inches and the vertical tolerance is less than 2 inches. While the Board does not
consider such a gap to be ind ependen tly negotiable by m any wh eelchair user s, such vehicles
will eventu ally be p hased ou t as new veh icles are ad ded to t he system .
HORIZON TAL AND VERTICA L TOLERAN CES
NEW
STATIONS
KEY (EXISTING)
STATIONS
NEW VEH ICLES 3" hori zontal gap
5/ 8" vertical toleran ce
3" hor izontal gap (1 door )
1-1/ 2" vertical tolerance*
RETROFITTED
VEHICLES
4" horizontal gap
2" vertical toleran ce
4" hor izontal gap (1 door )
2" vertical toleran ce
* Also app lies to new vehicles opera ting at existing stations, not only key stations.
(4) Exception. Where it is not operationally or structurally practicabl e to m eet the
horizontal or vertical requirements of paragraphs (d)(1), (2) or (3) of this section , platform or
vehicle devices complying w ith 1192.83(b) or platform or vehicle mounted ramps or bridge
plates comply ing wi th 1192.83(c) shall be provided.
This exception acknowledges that, in man y systems, high platforms are n ot
operationally feasible and p ertains to those system s that are not requ ired to p rovided levelboard ing. Such system s are requ ired to p rovid e access from low p lat forms w ith car-born e,
plat fo rm-mounted , or port ab le lifts in acco rdance wi th the s pecifications for l ifts . Access may
also be provided by ram ps or bridge plates meeting the applicable requirements. Such ramp s
or brid ge plates m ay be au tomatically or man ually d eployed .
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1192.75 Priority seating sign s.
(a) Each vehi cle shall contain sign(s) w hich in dicate that certain se ats are priority
seats fo r persons w ith d isabilities , and that other passengers sh ould make such seats
available to those who wis h to use them.
The content of signs is not specified by th is requirement an d is left up to the d iscretion
of transit operators. At a minimu m, the sign should indicate which seats are int end ed for u se
by p ersons w ith d isabil ities.
(b) Where designated w heelchair or mobil ity aid seating l ocations are prov ided, signs
shall indicate the location and advise other passenge rs of the need to permit wheelchair and
mobility aid users to occupy them.
This requirement p ertains to vehicles that p rovide specific locations for wh eelchair or
mobility aid users. Sometimes, these areas are accessed by folding up a regular seat. Operators
should tak e into accoun t how one accesses and uses su ch locations in d etermining the content
of signs. This provision is not inten ded to suggest that specified areas o r "bays" be provid ed.
(c) Characters on signs required by paragraphs (a) or (b) of this section shall have a
width-to-he ight ratio be tween 3:5 and 1:1 and a strok e w idth-to-he ight ratio between 1:5 and
1:10, with a mi nimu m character height (using an upper case "X") of 5/8 inch, w ith "wide"
spacing (gen erally , the space b etwee n letters shall be 1/16 the he ight of upper case l etters),
and s hall contrast with the backgroun d, ei ther light-on-dark or dark-on-lig ht.
These requirem ent s for the characte r height an d p roportion are based on existing
Fed era l requ irem ents for b uilding and facilit y sign age, au gmen ted by the resu lts of research
sponsored by the Board. Contrast can be provided ei ther with light characters on a dark
backgrou nd or d ark cha racters on a light backg rou nd . How ever, light-colored cha racters
against a dark backgrou nd are p referred since st ud ies have show n that th is type of cont rast is
more read able for persons w ith low vision. A minimu m level or percentage o f contrast
betw een char acters and the ba ckgrou nd of the sign is n ot specified. Research, how ever,
indicates that signs are more legible for persons with low vision when characters contrast with
their background by at least 70 percent. Contrast in percent is determined by:Contra st = [(B1- B2)/ B1] x 100
wh ere B1= light reflectance valu e (LRV) of the light er area and B2= light reflectance value (LRV) of the d arker a rea.
Note t ha t in an y applica tion b oth w hite an d black are never absolu te;thus, B1ne ver equ als 100 and B2is alw ays gr eat er than 0.
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Although not requ ired, it is also recomm end ed that the characters and background of
signs should be eggshell, matte, or other non -glare finish. An eggshell finish (11 to 19 degree
gloss on 60 d egr ee g lossimeter) is preferr ed .
1192.77 Interior circulation , handrails and stanchions.
(a) Handrail s and stanchions shall be sufficient to permit safe boarding, on-board
circulation, seating and standing assistance, and alighting by persons w ith disabilities.
This provision is written a s a general performance requir ement in order to allow as
man y options as possible in the d esign of accessible vehicles. Hand rails and stanch ions must
be placed near t he d oors an d alon g the p ath of en tran ce into the v ehicle for those usin g crutch es
or walkers, among others. However, they shoul d not interfere or restrict the necessary
clearance at doors or along an accessible route leading to accessible spaces as requi red by the
following p rovision.
(b) At entrances equipped wi th steps, handrail s and stanchions shall be provided in
the e ntrance to the veh icle in a configu ration w hich allow s pas sengers to grasp such ass ists
from outside the vehicle while starting to board, and to continue using such handrails or
stanchions throughout the boarding process. Handrails shal l have a cross-sectional diameter
between 1-1/4 inches and 1-1/2 inches or shall provide an equiv alent grasping surface, and
have ease d edges w ith co rner radii of not l ess than 1/8 inch. Handrails s hall be placed to
provide a minimum 1-1/2 inches knuckle clearance from the nearest adjacent surface. Where
on-board fare coll ection devices are used, a horizontal passeng er assist sh all be l ocated
between boarding passengers and the fare collection device and shall prevent passengersfrom sustaining in juries on the fare collection device or windshield in the event of a sudden
deceleration. Without res tricting the vestibule space, the ass ist shall provide support for a
boarding passenger from the d oor through the boarding p rocedure. Pass engers shall be able
to lean against the assist fo r security w hile payi ng fares.
Stepped entran ces are required to be equipped with hand rails and stanchions that can
be r each ed by th e p ass en ger from th e ou tsid e be fore act ually stepping in to t he veh icle. Such
hand rails and stanchions must be placed so that passengers can use them at all stages of the
boarding p athw ay . This par t of t he req uiremen t is d erived from 49 CFR Pa rt 609, in e ffect s ince1976. This w ould in clude a horizontal rail in fron t of any fare collection de vice, which not only
prov ides s uppo rt whil e paying fa re s but can he lp prevent so meon e from fa lling ag ai ns t the fa re
box or wind shield du ring a sud den stop.
Most car han drails ar e mad e of pipe. In th e buildin g indu stry , pip e size typically
specifies insid e diameter so th at a 1-1/ 2 inch p ipe h andr ail actu ally h as a larger ou tsid e
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diam eter, sometim es up to 2 inches. Such h and rails have not p osed a ny kn own prob lem. Thus,
the 1-1/ 2 inch diam eter requ irement can resu lt in a hand rail of approximately 2 inches u nd er
current bu ild ing in du str y practices.
(c) At all d oors on level-entry vehicles , and at each entrance accessibl e by l ift, ramp,
bridge plate or other suitable means, handrai ls, stanchions, pass enger seats, veh icle driver
seat platforms, and f are boxes, if appli cable, shall b e located so as to allo w a route at l east 32
inches w ide s o that at least two w heelchair or mobil ity aid users can enter the vehicle and
posi tion the w heelchairs or mobi lity aids in areas, each havin g a minimum clear space of 48
inches by 30 inches, whi ch do not undu ly restrict movement of othe r passengers. Space to
accommodate wheelchairs and mobili ty aids may be provided wi thin the normal area used
by standees and designation of s pecific spaces i s not required. Particular attention shall be
given to ensu ring maximu m maneuverabili ty imm ediately insi de doors. Amp le vertical
stanchions from ceiling to se at-back rails shall be provided. Vertical stanchio ns from ceili ng
to fl oor shall not i nterfere wi th whe elchair or mobi lity aid circulation and shall be kep t to a
minimum in the vicini ty of accessible doors.
Designating a ccessible spaces for wheelchair or mobility aid users is not r equired.
During th e development of these guidelines, it was apparent tha t some trans it operato rs
ass um ed th at "bays" or "be rths" wou ld have to be p rovid ed in ord er t o meet this requirement.
Such accommod ations are not required or recomm ended. All that must be provided is enough
clear floor space so that two w heelchair or mobility aid users can board and position
themselves on the veh icle. The 30 by 48 inch dimen sion is based on the stand ard space
allowance for a person in a wh eelchair. The clear floor area where per sons with disab ilities canposi tion themselves mus t be connec ted t o the doors by a ro ute wi th at leas t 32 inches o f clear
width . The clear floor space that is typically provided for standees is usually large enough to
meet this requirement.
Hand rails or stanchions must be placed so that t he required clear floor spaces and
routes are not obstru cted. It is also recommen ded , but n ot requ ired, th at consideration be given
to th e proximity of h andr ails or stanchion s to th e area in w hich wheelchair or mobility aid
users may position themselves. When id entifying the clear floor space where a w heelchair or
mobility aid user can be accom mod ated, it is suggested that at least one such area be a djacent
to, or in close proximity to a hand rail or stanchion. Of course, such a han drail or stanchioncann ot encroach up on the req uired 32 inch w idth requ ired for th e doorw ay or th e rou te lead ing
to the clear floor space which mu st be at least 30 by 48 inches in size. This recomm end ation
should not be interpret ed as a requirement that t he area where wheelch air or mobility aid users
can position themselves be designated at a specific location. It is importan t that whee lchair and
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mobility aid u sers have as many op tions as possible in positioning them selves in view of the
crow ding t hat can take p lace an d the lim ited tim e allowed to ent er o r exit th e vehicle.
There is no requ irem ent for secu rem ent sy stem s or tie-d own d evices. P rev iou s re sea rch
conducted for DOT and comments received du ring th e development of these guid elines
indicate that such d evices are not need ed on light rail vehicles because of the low acceleration
and deceleration forces.
1192.79 Floo rs, s teps and thresholds.
(a) Floor surfaces on aisles, step treads, places for standees, and areas where
wheelchair and mobil ity aid users are to be accomm odated shall be slip-resi stant.
A sp ecific measur e, or static coefficient of friction , has not been specified for slip-
resista nce . Slip r esistance is ba sed on the frictiona l force necessary to keep a shoe h eel o r crutch
tip from slipp ing on a w alking su rface und er co nd itions likely to be found on the su rface.
While the dyn amic coefficient of friction d uring w alking varies in a complex and n on-uniform
wa y, the static coefficient of friction, wh ich can be m easured in several w ays, prov ides a close
ap proximation of the slip resistan ce of a su rface. Contrary to commo n b elief, some slippage is
necessary for walk ing, esp ecially for persons w ith res tricted gaits. A truly "non -slip " sur face
cou ld not be n ego tiated .
The Occupational Safety and Health Ad ministration r ecommend s that w alking surfaces
hav e a static coefficient of friction of 0.5. A research project spon sored by the Board cond ucted
tests with persons with d isabilities and concluded that a higher coefficient of friction was
need ed by such p ersons. A static coefficient of friction of 0.6 is recommen ded for steps, floors,and lift p latforms an d 0.8 for r amps.
The coefficient of friction varies considerably due to the presen ce of contamin ants,
water, floor finishes, and other factors not under the con trol of transit prov iders and may be
difficult to measu re. Nevertheless, many common m aterials suitable for flooring are now
labeled w ith information on the static coefficient of friction. While it may not be p ossible to
compare on e pr oduct d irectly w ith another, or to gu arantee a con stan t measure, transit
operators or vehicle designers and m anufacturers are encouraged to specify materials with
app ropriate valu es. As more p roducts includ e information on slip resistance, imp roved
un iformity in m easuremen t and specification is likely to develop. The Board has pu blished abrochure, "Slip Resistant Surfaces," available at no cost , wh ich provides ad ditional information
and adv isory guidelines on slip resistant sur faces.
A variety of commo n m ater ials u sed on t ransit vehicle floor s can provid e ad equ ate slip
resistance. Comm on rubberized matting may be slip resistant depend ing on the orientation of
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the grooves. Carpet is more variable depend ing on pile and weave and should probabl y be
tested before it is specified.
(b) All thres holds and step edges shal l hav e a band of colo r(s) running the ful l w idth
of the step or threshold which contrasts from the step tread and riser or adjacent floor, either
light-on-dark or dark-on-light.
The band of contrasting color required by this provision must span the full width of the
threshold and steps along the n osing. However, a minimu m w idth for the band itself is not
specified. The Board recommen ds a minim um of three inches, although the actual size is left to
the d iscretion of operators. Althou gh a m inimu m level of contra st for this ban d is not specified,
it is recommend ed th at th e follow ing form ula be used in determin ing the cont rast level:
Contra st = [(B1- B2)/ B1] x 100
wh ere B1= light reflectance valu e (LRV) of the light er area and B2= light reflectance valu e (LRV) of the d arker a rea.
Note t ha t in an y applica tion both w hi te an d black are never absolu te;thus, B1ne ver equ als 100 and B2is alw ays gr eat er than 0.
1192.81 Lighting.
(a) Any step well o r doorway w ith a l ift, ramp or bridg e plate immediately adjacent to
the driver shall have, when the door is open, at leas t 2 footcandles of il lumination measured
on the step tread or lift platform.
This requirement is based on existing FTA requ irements for light rail vehicles and
pert ain s on ly to th e in ter ior ligh tin g p rovid ed at en tran ces eq uipped with boa rd ing d evices.
The r equirement only pertains to open d oors so th at th e light w ill not reflect off the w ind shield
wh ile the vehicle is moving. The measurem ent pertains to all step treads of the entrance or to
the lift platform at floor level. While a maximum light ing level is not specified, h igh leve ls may
increase the time necessary for th e vision of exiting p assen gers to ad just to a d arker, nighttime
environment.
(b) Other stepw ells, and doorways w ith lifts, ramps or bridge plates, shall have , at all
times, at least 2 footcandles o f ill umination measured on the step tread or lift or ramp, whe n
deployed at the vehicle floor level.
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This p rovision requir es th e sam e level of light ing in ot her do orways w ith board ing
devices and stepwells of the vehicle. Since such stepwell lighting would n ot interfere with the
operator's visibility, the minimu m level is requ ired at all times.
(c) The doorways of vehic les not operating at lighted station platforms shall have
outside lights w hich provide at least 1 footcandle of illumination on the station platform or
street surface for a distance of 3 fe et perpendicular to all points on the bottom step tread.
Such lights shall be located below window level and shiel ded to protect the eyes of entering
and exiting passengers.
This p rovision is also based on an exist ing FTA
requirements and specifies that the 3 foot distance is to be
measu red perpend icularly from th e step tread, as shown in
the figure. The m eaning of "3 feet p erpend icular to all
poin ts on th e bottom step tr ead outer edge" is to define a
rectang le on the groun d out side the veh icle do or w hich is
three feet d eep an d as w ide as th e door lower st ep. In most
cases, the actual area illuminated w ill be a semi-circular
pat tern. Such a p attern wou ld m eet the ab ove requ iremen t
as long as the sp ecified rectangle wer e illumin ated.
This requirement pert ains only to vehicles that serve
un lighted stations. While t hese guide lines p ertain only to v ehicles, n ot station s, it is
recommended th at stations be lighted to serve both those passengers wa iting at stati ons andthose passengers entering or exiting veh icles. If stations are lighted , vehicle doorw ays do n ot
have to be illuminated .
1192.83 Mobility aid accessibility.
(a)(1) General. Al l new light rail vehicles, other than level entry vehicles, covered by
this sub part shall provide a l evel -change me chanis m or boarding d evice (e.g., lift, ramp or
bridge plate) comply ing w ith either paragraph (b) or (c) of thi s section and suff icient
clearances to p ermit at least two wheel chair or mobili ty aid users to reach areas, each w ith aminimu m clear floor space of 48 inches b y 30 inches , whi ch do not unduly restrict passeng er
flow . Space to accommodate w heelchairs and mobility aids may be provided withi n the
normal area used by s tandees and des ignation of specifi c spaces i s not required.
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This requirement for board ing devices applies only to light rail systems tha t do n ot
pr ovid e level b oar din g. This w ou ld a pp ly to t he v ehicles o f new syste ms wher e level b oar din g
is provided at some but n ot all stops. The clearances required for access to seating locations
wou ld include th ose for doorways (section 1192.73) and for interior circulation (section
1192.77).
(2) Exception. If lif ts, ramps or bridge plates meet ing the requi rements of this section
are provid ed on station platforms or other stops, or mini -high p latforms c omplying with
1192.73(d) are provid ed, at stations or stops required to be accessib le by 49 CFR Part 37, the
vehicle is not required to be equ ipped w ith a car-borne device . Where each new vehicle is
compatible w ith a sin gle pl atform-mou nted access sys tem or dev ice, addi tional s ystems or
devices are not required for each vehicle provided that the sing le dev ice coul d be used to
provide access to each new vehicle if passe ngers usi ng w heelchairs or mobili ty aids could
not be accommodated on a single vehicle.
New , no n-level en try ca rs a re n ot r equired to b e eq uipped with boa rd ing d evices if s uch
devices ar e pr ovid ed at station pla tform s or m ini-high pla tform s are provid ed. To meet th is
exception, boarding devices or mini-high platforms would h ave to be provided at all stations
and stops required to be accessible. However, transit operators should consider wh ich option
(board ing devices on cars or at stations) offers the m ost accessibility in d eterm ining their course
of action.
The Board received som e comment s from operators of light rail sy stem s who currently
use platform-moun ted (waysid e) lifts or mini-high platforms with w hich the ope rator aligns
one door of the v ehicle. The operators su ggested that the second vehicle shou ld not be requiredto be accessible so that a second lift or mini-high platform w ould not be need ed to serve the
second vehicle in the train. The ADA, how ever, is explicit that, except for specific provisions
for intercity rail cars, all new vehicles mu st be accessible. Therefore, th e final gu idelines r equ ire
that every new vehicle be able to be entered and used an d accommod ate at least two
wh eelchair or mobility aid users. The current req uiremen t does not requ ire the provision of
add itional lifts or platforms at a station if other vehi cles of the train which are required to be
accessible are com patible with, an d can be serv ed by, the lift or p latform if position ed prop erly.
In practical terms, the dr iver w ould a lign the d oor o f the first car with the lift or mini-
high platform and allow all passengers using wh eelchairs or mobility aids to board. If all thewaiting passengers wh o need the lift or platform can be accomm odated on the first car, the
train w ould n ot n eed to m ove t o allow boarding of the secon d ca r. The tran sit agency should,
therefore, carefully assess th e interior layou t of its cars to ensure tha t sufficient clear floor area
is p rov ided to accom mod ate all th e an ticip ated w heelchair and mobility aid users for a trip . If a
larger num ber of such passengers presented th emselves at a stop, and a second car were n ot
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full, it may be discriminatory un der the DO T rule not to mov e the train to allow those
pass en ge rs to b oa rd the second ca r. Thi s po tent ial s itu at ion is one of the re asons why the Board
strongly urges pl anners and desi gners to provide level boarding from full length high
platform s wh erever p racticable.
(b) Vehicle lift. - (1) Design lo ad. The desi gn load of the lift shall be at least 600
pounds. Working parts, such as cables, pul leys, and shafts , which can be expected to w ear,
and upon which the lif t depend s for support of the load, shall have a safety factor of at least
six, based on the ultimate strength of