Wheelchair PDF

Status Report on the Use of
Wheelchairs and Other Mobility Devices

on Public and Private Transportation
%ASTER3EALS Easter Seals Project ACTION

1425 K Street, NW Suite 200
R
Washington, D.C. 20005

About Easter Seals Project ACTION
The United States Congress established Easter Seals Project ACTION (ESPA) in 1988 to promote
and facilitate cooperation between transportation providers and people with disabilities. ESPA receives
funding through a cooperative agreement with the U.S. Department of Transportation, Federal Transit
Administration, and is administered by Easter Seals Inc.
Easter Seals Project ACTION—the acronym stands for Accessible Community Transportation In
Our Nation—strives to make the Americans with Disabilities Act work for everyone in both worlds,
extending resources to all that are free of charge. These include technical assistance and a toll-free
number (800-659-6428 between 9 a.m.-5 p.m., Eastern Time, Monday through Friday), Web site (www.
projectaction.org), and training activities at meetings and conferences. Easter Seals Project ACTION
was established in 1988.
ESPA also offers more than 100 print, video and audio resources from a physical and online
clearinghouse. We are pleased to add this “Status Report on the Use of Wheelchairs and Other Mobility
Devices on Public and Private Transportation” to the collection.
Easter Seals Project ACTION

1425 K Street NW Suite 200
www.projectaction.org
(202)347-3066
(800)659-6428
(202) 347-7385 (TDD) (202)737-7914 (Fax)
March 2008
Status Report on the Use of Wheelchairs and Other
Mobility Devices on Public and Private Transportation
Prepared for Easter Seals Project ACTION by Nelson/Nygaard Consulting Associates

San Francisco, California
Project Advisory Committee

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

This report represents a “snapshot” of current issues and promising practices regarding
the Use of Wheelchairs and Other Mobility Devices on Public and Private Transportation.
A goal of this study is for the findings to serve as a practical tool and guidance for the following
types of groups:
• Transportation provider agencies and related organizations/associations
• Disability advocacy and service organizations
• Consumers
• Manufacturers (of mobility devices, vehicles, securement equipment, etc,)
• Government transportation regulatory and funding agencies
• Government and private health care funding agencies
Consistent with this goal, this report includes a listing of
topics for development of potential new best practices,
educational/training materials, research and demonstration,
or policy guidance. It is intended to serve as a catalyst for
advancing the ability of providers to serve their riders with
disabilities more effectively and safely, and for riders to make
the best use of the services available to them. It is also
intended as an advocacy tool to encourage manufacturers
to design safely transportable mobility devices as well as
to design vehicles and equipment that can accommodate a
greater variety of devices. Using the ramp of a low-floor bus
Executive Summary
Wheelchair usage on fixed-route transit has increased dramatically in recent years as improvements
have been made to vehicle design, and wheelchair users become more active in the community. Some
transit agencies report more than 10,000 annual wheelchair boardings on their buses. Despite these
ridership trends, changes in wheelchair designs are often at odds with improvements in transit vehicles
and securement equipment that have occurred since the passage of the Americans with Disabilities act.
Many, if not most, new power wheelchairs and scooters do not provide adequate securement points to
ensure they can be safely accommodated on public transit. Standards that were developed to include
attachment points on mobility devices (“WC19”) are not well known by consumers and their support
services, and the new designs are available on only a fraction of wheelchair models. Other challenges
include transit equipment design, transit operations and training, and regulatory and policy issues.
How to Use this Document 5
In response to concerns within the transportation industry and the disability community on this
important topic area, Easter Seals Project ACTION (ESPA) selected Nelson\Nygaard Consulting
Associates to prepare a comprehensive national report on the status of the current use of wheelchairs
and other mobility devices on public and/or private fixed-route and paratransit vehicles. The Nelson\
Nygaard team included:
• ADA policy and practice experts
• The Director of the National Center for Accessible Transportation
• A mobility device engineering research and development expert
• A consultant who is the chair of the American Public Transportation Association’s Wheelchair User
Issues Subcommittee and who was also a former transit agency accessibility and paratransit manager
In addition, report findings were reviewed by a 12-member advisory committee representing a broad
range of perspectives, including those of the transit industry, the disability advocacy community, and
wheelchair and vehicle manufacturers. In addition to report review, committee members provided
significant input into the report content.
Four approaches were adopted to complete this report:
• Review of more than 50 documents that address pertinent regulations, industry standards, public
transportation industry policies and practices, wheelchair industry information, technical research and
synthesis reports
• Interviews with key stakeholders representing diverse perspectives: those of advocates, transit
agencies, wheelchair and vehicle manufacturers
• Web-based survey of more than 100 wheelchair users
• Policy roundtable conference call with key stakeholders
The report synthesizes the results of these research efforts by identifying the key issues, documenting
current best practices in the field, and identifying areas that require further research or greater guidance
to transportation providers and riders with disabilities. The research methodology, an annotated
bibliography, and survey results are detailed in appendices to the report.
The report highlights key issues in the following areas:
Example of a non-traditional wheelchair
• Oversized wheelchairs
• Space and maneuvering onboard vehicles
• Lift and ramp boarding
• Issues with oversized wheelchairs
• Non-wheelchair mobility aids
• Other items carried with mobility devices
• Securement issues
• Transit personnel proficiency and awareness
• Training standards and monitoring of service performance
• Progress in making “transit-safe” wheelchairs available
• Clarification needed in federal guidance
• Research and development to support industry-wide standards and new design approaches
• Education and dissemination of available resources
The report then provides a distillation of the best practices identified through the team’s research and
concludes with a series of topics for development of potential new best practices, educational/training
materials, research and demonstration, or policy guidance, as summarized in the following table:
Issue area Issues Recommendations

Transit Vehicle and Space and maneuvering on board For manufacturers and mobility-
Equipment Design vehicles—constrained spaces related industries:
Lift and ramp boarding—steep • Develop industry standards
angles and reliability or guidelines for wheelchair
space layouts, aisle clearances,
placement of securement
equipment, etc.; to be used by
both vehicle purchasers and
manufacturers/designers.
• Increase development and
“real-world” (in transit service
environment) demonstration of new
technologies.
For transit providers:
• Encourage standardized
wheelchair securement equipment
by retrofitting older vehicles with
updated equipment, and increase
or improve maintenance programs
for older wheelchair lifts.
• Routinely involve advisory
committee members and drivers
in the selection of new and
replacement vehicles.
Executive Summary 7

Wheelchair Design, Oversized wheelchairs–increasing For wheelchair users:
Purchasing, Usage number of chairs that don’t fit into • Learn about the dimensions
and Prescription minimum ADA vehicle standards
established for wheelchair space
Non-wheelchair mobility aids— aboard transit vehicles
segways, strollers
For vendors and prescribers:
Other items carried with mobility
devices–oxygen, large backpacks • Be cognizant of the dimensions
established for wheelchair space
aboard transit vehicles, clearly
including this aspect in dealings
with wheelchair users
For wheelchair manufacturers:
• Develop guidelines for
manufacturers to use in making
information about “transit
friendliness” of mobility devices
accessible and available to
prospective purchasers
Transit Operations Securement issues— For the industry:
and Training customer preferences, variety • Development of a “template” type
of devices, securement policies,
ergonomics, time of document that can be used
by transit systems to educate
Transit personnel proficiency customers of accessibility features
and awareness—sensitivity, and more
securement skills
• Development and dissemination
Training standards and monitoring
of service performance— of model training program elements
inconsistent, little direct monitoring • Development of “best-practice”
policies and guidelines for
accommodating Segways and
other non-traditional mobility
devices
• Development of guidelines on how
to implement wheelchair marking
and tether strap programs
• Dissemination of best practices
or guidelines for monitoring transit
system performance regarding
mobility aid accommodations

Regulation and Policy Progress in making WC19- For the industry:
compliant wheelchairs available– Additional research
limited outreach
to users • Examination of barriers to making
Education and dissemination of WC19-compliant mobility devices
available resources–limited and available to transit users.
inconsistent Activities:
• Development of guidelines for
transit providers on how/why to
choose “mandatory” vs. “optional”
rider choice policy for securement.
• Increased coordination of various
regulations that affect mobility
device accessibility and design.
Chapter 1. Background
Problem Statement
About the Study
Problem Statement
The need to accommodate travel by passengers with disabilities on various transportation modes has
increased dramatically in recent years, with some transit agencies reporting more than 100,000 annual
wheelchair boardings on their buses. Fixed-route ridership is increasing as wheelchair users become
more active in the community, the nation’s fixed-route transit bus fleet nears 100 percent accessibility, and
transit agencies implement more accurate ADA paratransit eligibility screening processes, thereby shifting
a portion of paratransit ridership to fixed-route service.
Wheelchairs and scooters have evolved into a wide range of varied and complex designs, often
without traditional frame joints that can accept vehicle tie-down devices. This has been exacerbated
by the development of newer securement systems to promote less cumbersome, faster securement
performance. The newer systems tend to utilize hooks instead of the older buckle or clasp closures,
sometimes resulting in less flexibility for attaching to non-traditional wheelchair frame geometries.
In April 2000, “WC19 Wheelchairs Used as Seats in Motor Vehicles” was approved by the American
National Standards Institute (ANSI) and the Rehabilitation Engineering and Assistive Technology
Society of North America (RESNA) as a U.S. standard. Wheelchairs that meet the design and
performance requirements of this voluntary standard are labeled to show that they comply with WC19.
A WC19 wheelchair has four crash-tested securement points where tie-down straps and hooks can be
easily attached so the chair can be effectively secured to the vehicle. Although an increasing number
of wheelchair models are being designed and tested to be WC19-compliant, many mobility devices on
the market, especially scooters, are not available with this option. Moreover, for a variety of reasons, the
percentage of WC19-compliant mobility devices in actual use is much lower than the number of models
that can be purchased with this important feature.
But WC19 standards are not well known by consumers and their support services. It is not uncommon
for third-party funding sources, which cover most of the costs of most mobility devices, to deny
coverage for WC19-compliant features, forcing the end-user to either pay for these features out of
pocket, or skip them.
An increasing number of mobility aids are also too large or difficult to maneuver in order to board transit
vehicles. Several research and development projects are under way to improve the situation. Some
of these projects are being conducted within the Rehabilitation Engineering Research Center (RERC)
on Wheelchair Transportation Safety, funded by the National Institute for Disability and Rehabilitation
Research (NIDRR), and include testing of innovative new securement designs, evaluating existing
securement devices, occupant restraints and crash testing requirements, and investigating new universal
“docking” and rear-facing “compartmentalization” solutions. However, these are long-term prospects, and
could require significant change in federal regulations to implement. Meanwhile, there is a fast-growing
need to find a way for wheelchair users, manufacturers, dealers and medical funding agencies to offer
and use devices that are more readily compatible with securement systems used on various modes of
public transportation. In short, the most immediate and significant progress for both safety and usability
can be achieved by increasing the number of WC19 wheelchairs available and in use.
Dialogue on wheelchair (and other mobility aids) usage on vehicles is needed to determine priority
topics of concern, the kinds of standards that are needed, and how existing standards can be more
effectively implemented. Education is needed for wheelchair users, manufacturers, securement
equipment and vehicle suppliers, transit managers, and medical funding and regulatory entities
on the benefits of proper securement and “WC19” wheelchairs.
Chapter 1. Background 11
About the Study

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

Space and Maneuvering on Board Vehicles
Lift and Ramp Boarding
Best Practices
Recommendations
Space and Maneuvering on Board Vehicles

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

DOT ADA regulations require transit personnel to
provide boarding assistance as necessary, which can
include pushing a manual wheelchair up a ramp. This
includes situations in which either a manual or power
wheelchair user attempts to navigate a ramp that is
too steep. The steeper the ramp, the more likely it is
that boarding assistance will be necessary, so transit
operators should have an incentive to ensure the
lowest slope possible.
Problems persist with the reliability of accessibility
equipment such as bus lifts, which are sometimes
related to maintenance issues with older equipment.
Various generations of older securement equipment
are still in use alongside newer, more modern
Example of a poorly placed shoulder belt in a securement system
devices, resulting in a confusing array of equipment
Chapter 2. Transit Vehicle and Equipment Design 15
that bus operators and customers must understand and use. While lifts are sometimes replaced and
rehabilitated, they are not always given high priority in relation to other maintenance needs even though
there are requirements concerning lift maintenance under DOT ADA regs.
Best Practices
• Size the wheelchair lift, ramp, aisle way, and securement location dimensions to provide for
accommodation of at least the “common wheelchair” dimensions, as well as maneuverability and
ability to reach and use securement equipment.
• When buses are in early stages of procurement, test wheelchair layouts via a “configuration audit.”
Along with consumer/disability advisory involvement, a surrogate common wheelchair is sometimes
used in place of or in addition to a sample wheelchair, sometimes referred to as the “box test”
(although the latter can have technical limitations).
• Have the “first article” prototype tested by mobility aid users at the transit system. This is also helpful
toward identifying any outstanding issues before general production begins. (NOTE: Some systems
are testing a rear facing securement approach, especially in BRT—bus rapid transit–applications.)
• Pilot the new, innovative boarding approaches such as double-folding ramps (to minimize the angle
that may cause difficulty boarding where the surface is not close to the bus floor), and rear-door ramp
entry (to minimize difficulty maneuvering to securement locations).
Recommendations
For the industry:

• Develop industry standards or guidelines for wheelchair space layouts, aisle clearances, placement
of securement equipment, etc., to be used by both vehicle purchasers and manufacturers/designers.
Included could be the development of surrogate wheelchairs or other methods for testing maneuvering
clearances, as well providing for consumer/ disability advisory input.
• Increase development and “real-world” (in transit service environment) demonstration of new
technologies for innovative securement solutions and entry designs, including evaluation of approaches
such as rear door entry.
For transit providers:
• Encourage standardized wheelchair securement equipment and increase or improve maintenance
programs for older wheelchair lifts. Approaches could include technical assistance, joint purchasing
programs, and prioritization by funding sources.
• Routinely involve advisory committee members and drivers in the selection of new and
replacement vehicles.
Chapter 3. W
heelchair Design, Purchasing, Usage and Prescription

Oversized Wheelchairs
Non-wheelchair Mobility Aids
Other Items Carried with Mobility Devices
Best Practices
Recommendations
Oversized Wheelchairs
Oversized wheelchairs, meaning devices that are larger and/or heavier than the ADA’s “common
wheelchair” definition, are being encountered by transit providers. (In some cases, even common
wheelchairs are encountering difficulties due to failure on the part of vehicle manufacturers to provide
“adequate clearance” as required under DOT ADA regs). Agencies have difficulty transporting large or
heavy wheelchair/user combinations. Larger and heavier power wheelchairs and scooters, combined
with passenger size, cannot always be accommodated within existing transportation vehicles. For
example, there may be an inability to maneuver into or out of lifts, ramps and securement areas;
damage may be caused to lifts; and weight distribution may be a problem on smaller vehicles.
Significant customer service and operational problems and confusion also exist, such as how to determine
when a mobility aid actually cannot or should not be accommodated as opposed to merely falling outside
the ADA “common wheelchair” parameters, and how to determine whether there are viable alternatives
for such customers. Fixed-route transit providers have varying responses to carrying oversized mobility
aids, ranging from allowing whatever will fit on vehicles, to denying service to any mobility aid/user
combinations that exceed the ADA definition.
Some paratransit agencies are “screening out” oversized or overweight wheelchairs during the
ADA eligibility certification process. While they are not necessarily finding the applicants ineligible,
the effect in some instances where the applicant has no alternative device is to make it impossible
for them to ride paratransit.
Non-Wheelchair Mobility Aids

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

People may carry backpacks, shopping bags, oxygen tanks or other devices onto the bus, or attached
to their wheelchairs. This may exacerbate problems of maneuverability and access to securement
points on the mobility device, and can also block the aisles for other passengers, especially in fixed-
route bus services.
There is limited guidance on how best to accommodate these devices, such as if/how oxygen tanks
should be secured.
Chapter 3. Wheelchair Design, Purchasing, Usage and Prescription 19
Best Practices
• Manufacturers’statements of model specifications that include dimensions, weight, and turning
radius, aa• “Ride Safe” brochure and “www.travelsafer.org” Web site by RERC-WTS at University of
Michigan, describing wheelchair transportation safety and standards;
• “WC19–Your Ticket to Ride” in, including a list of WC19-compliant wheelchairs at the RERC WTS
Web site http://www.rercwts.org/WC19
• Floor demonstration models at wheelchair dealers that are equipped with “Transit” or “Transport”
equipment (such as “WC19”-compliant)
• Checklists used for evaluation of wheelchair purchasers’needs in order to configure the most
appropriate device, including whether they will take public transportation. This can be provided by
prescribers, health care insurers/funders, or wheelchair vendors, especially those with training and
certification such as RESNA-certified Assistive Technology Suppliers (“ATS”).
• WTORS manufacturers’training materials, including training videos
Recommendations
For wheelchair users:

• Learn about the benefits of “transit-safe” mobility devices.
For vendors and prescribers
• Increase coordinated efforts to educate wheelchair users about the benefits of WC19-compliant
mobility devices. An example is broad promotion of materials such as the current “Ride Safe” brochure
and “www.travelsafer.org” Web site by RERC-WTS at University of Michigan, describing wheelchair
transportation safety and standards, but tailored more for educating people involved in mobility device
purchasing decisions (see Appendix E).
For wheelchair manufacturers
• Development of guidelines for manufacturers to use in making information about “transit friendliness”
of mobility devices accessible and available to prospective purchasers
For funding entities
• Extend coverage eligibility to include WC19-compliant options/equipment [NOTE: Insurers/CMS/other
3rd parties will argue that WC19-complilant equipment is unnecessary for “in the home” use; however,
it may be very essential for transportation to medical appointments, etc.]
Chapter 4. Transit Operations and Training

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

Some consumers report that drivers are not sensitive to their needs, and don’t listen to how devices
should be secured, or say they can’t do it or don’t know how to. This is part of a larger issue that includes
ongoing problems such as wheelchair users being passed by at bus stops, inoperative lifts on vehicles,
and other barriers to using fixed-route transit services.
It is required under 49 CFR 37.173 that each public or private entity which operates a fixed-route or
demand-responsive system shall ensure that personnel are trained to proficiency, as appropriate to their
duties, so that they operate vehicles and equipment safely and properly assist and treat individuals with
disabilities who use the service in a respectful and courteous way….
Chapter 4. Transit Operations and Training 23
Training standards and monitoring of service performance

Training and disability awareness of transit provider personnel is variable and sometimes inadequate or
inconsistent concerning mobility aid accommodations, resulting in ongoing problems.
Transit provider training on proper boarding and securement procedures is not standardized among
various national “train-the-trainer” programs, and
can be highly variable at the local transit system
level. Such training is sometimes not given to agency
personnel who may need it, such as managers and
customer service personnel who handle passenger
issues, risking a position of violating the requirement
cited above.
Diligent monitoring of transit drivers will help to ensure
proper performance and reduce the incidence of
anecdotal reports and customer complaints. Some
transit systems use “secret rider” or other type of
Wheelchair securement policy posting on fixed-route bus.
monitoring, sometimes in conjunction with monitoring
of ADA announcements.
Best Practices
Transit System Policy Statements and Educational Information

• Service guides, including print and alternate formats, should describe system accessibility features
and policies. Availability on a Web site will help meet accessibility needs.
• Policies with clear statements of transit system responsibilities/limitations, as well as customer
responsibilities, should include:
• Statement of assistance that will be provided by vehicle operators
• Size limitations of vehicle mobility aid accommodations
• Policy on securement (mandatory or optional)
• “Caveat” language re: transporting mobility aids that cannot be secured or if securement
equipment is missing or broken
• Statements recommending (but not mandating) transferring to a regular seat
• Use of occupant restraints (including “optional” on fixed-route)
• Special policies and procedures for Segways
• Instructions on stowage of portable oxygen, walkers, shopping carts, and other non-
wheelchair items (also how “orthopedic strollers” will be treated)
• Posting of wheelchair securement policies in conspicuous locations in vehicle interiors, such as by
decals, advertising-type cards, posters, or other signage
• Wheelchair securement policy posting on fixed-route bus
• Auditory and visual message board announcements on transit vehicles explaining securement policies.
This has been especially useful to transit systems instituting new policies, such as moving from
“optional” to “mandatory” securement.
• Offering of “orientation” to vehicle features for transit customers, especially new wheelchair users.
This can be part of traditional “travel training” programs, or offered separately, and can be encouraged
by the use of “courtesy cards” handed out by vehicle operators when they encounter a passenger
having difficulty.
• Transit system participation in disability conferences and product expositions, ideally with both
educational materials and actual vehicle demonstrations
• Press releases and news coverage of improvements such as new bus securement equipment,
training programs, wheelchair marking/tether strap programs, etc.
Training Program Elements

• “How-to” guides that use pictures and/or videos to demonstrate technical issues of securement
(including some videos that show what can happen when securement is not done properly)
• Using a variety of types of wheelchairs and scooters in hands-on practicum sessions, especially on
each type of vehicle in use
• Visiting local wheelchair dealers, either to understand wheelchair features or to actually do training
such as for wheelchair marking/tether straps
• Inviting wheelchair-using transit customers and disability advocates to participate in training.
• Incorporating wheelchair boarding and securement into simulated
driving practice throughout new driver training, instead of relegating it to
a single “class”
• Addressing proper use and placement of seatbelts, not just wheelchair
securement, in training materials
• Sign-off sheets that both trainees and trainers sign to document
successful proficiency and understanding of procedures
Wheelchair with tether strap (front)
• Use of quiz-type tests to gauge proficiency in classroom information and markings (rear)
• Wheelchair securement as a component of “roadeo” driving skill competitions
• Tips on proper ergonomic practices to minimize risk of injury while performing securement
• Vehicle operators should be periodically evaluated on their ability to safely and effectively secure
wheelchair users
• Staff in addition to vehicle operators receive training in accessibility accommodations and disability
awareness (including supervisors, managers, and customer service staff)—again, in compliance with
49 CFR 37.173.
Auxiliary Aids
• Wheelchair securement-point marking and securement-loop programs
• Auxiliary straps or other devices for securing oxygen tanks, Segways, or other non-wheelchair items
• A “boarding belt,” which is used by some paratransit providers to secure the passenger to their
wheelchair and to provide extra safety and comfort during lift boarding
• Kneeling pads, reaching tools and other equipment to aid in use of securement equipment
by vehicle operators
• Ergonomic reviews of existing transit vehicle interiors to identify space and equipment issues
that may need to be addressed in order to provide training instructions or equipment replacement/
retrofit guidelines
Chapter 4. Transit Operations and Training 25
Transit System Performance Monitoring

• Use of “secret rider” programs or professional monitors to observe mobility aid boarding and
securement performance, both on a random basis and targeted based on specific complaints
• Tracking of complaints in detailed categories that include mobility aid boarding and securement in
order to track trends and identify issues. Statistics should be shared with all interested parties–transit
system management staff, policy boards, disability advisory committees, and the public. Stakeholder
perspectives varied on whether this information should be made universally available, or whether it
should initially (or only) be provided to transit agency staff, boards and advisory committees. Reports
would in any case be available to the public through open records legislation (“sunshine laws”), but
limiting their initial distribution could ensure that limited staff resources could be assigned to correcting
deficiencies rather than responding to media inquiries.
Recommendations
For Public Transportation Providers

• Development of a “template” type of document that can be used by transit systems to explain:
• Mobility aid accessibility features on vehicles and at transit facilities, including what to know
about how various sizes, weights, maneuvering capabilities, and baggage/medical devices
can be accommodated
• Policies and procedures for boarding and securement
• Information about the benefits of “transit-safe” mobility devices
• Availability of transit vehicle orientation and/or travel training for mobility aid users
• Information on auxiliary aids such as wheelchair marking and tether strap programs
This information can be used in rider’s guides, accessible services guides, Web sites, brochures,
posters (including onboard vehicles). Photos, diagrams, and other graphic presentation methods
should be used to illustrate features and concepts as much as possible.
• Development and dissemination of model training program elements
• Development of “best practice” policies and guidelines for accommodating Segways and other
non-traditional mobility devices
• Development of guidelines on how to implement wheelchair marking and tether strap programs,
including ensuring that participation is voluntary on the part of riders and that operating personnel
must perform securement appropriately for those who choose not to participate
• Dissemination of best practices or guidelines for monitoring transit system performance regarding
mobility aid accommodations
Chapter 5. Regulation and Policy

Progress in making “Transit-safe” wheelchairs available
Elements of Federal Guidance
Best Practices
Recommendations
Progress in Making “Transit-safe” Wheelchairs Available

Use of wheelchairs with specific securement attachment points, such as WC19-compliant wheelchairs,
can improve safety during transportation and make securement easier and faster, but so far there is
little industry implementation or consumer/public understanding of this “voluntary industry standard”
type of approach.
Wheelchair manufacturers include information about “transit options” or “transportation features” in product
literature about models that have these features available, but the information is often difficult to find. The
“WC19–Your Ticket to Ride” Web page of the Rehabilitation Engineering Research Center on Wheelchair
Transportation Safety (RERC WTS) Web site (www.rercwts.org) contains a list of available models
equipped with these features. At the same time, it should also be noted that custom seating configurations
may affect the availability of OEM (original equipment manufacturer) WC19 features, if such features were
designed into the OEM seating instead of the base.
There is a general belief that education is needed for consumer, transit providers, third-party payers,
and government agencies regarding the costs vs. benefits of “transit-safe” wheelchairs, and that
transportation safety should be included as a basic feature of wheelchairs. There is some belief that
“voluntary” industry standards are not enough, and that some type of mandatory requirements will be
necessary. However, it is not clear which sector(s) should have such mandates applied to them, which
agencies would issue and regulate such guidelines, and how they would be applied in the end, since
one cannot unilaterally declare all current mobility devices unsuitable for transit.
Wheelchair manufacturers have not seen a “market demand”
for “transit-safe” features, and voluntary industry standards
carry less weight when viewed beside allowances under
insurance and other funding guidelines (such as CMS
coding). Issues such as the Medicare “in-home limitation”
present significant barriers.
The use of wheelchairs as seats in motor vehicles has
not historically been addressed through the specifications
issued for purchasing wheelchairs by major purchasers such
as Veterans Administration and Centers for Medicare and
Medicaid Services/CMS. Also, many people with disabilities
have specific seating requirements that dictate custom
seating systems from after-market specialists such as Motion
Concepts, and care would be needed to ensure that the
need for a high-end seating system would not somehow
remove transportation from the user’s list of
Example of a securement point
daily activities. The transportation industry must remember
that the inside of a transit bus should not be regarded as
the native environment for mobility equipment, and that the seating, above all else, must be compatible
with the individual user’s specific requirements. Addressing this issue and including WC19 features in
wheelchair specifications would provide a significant incentive to manufacturers to develop “transit-safe”
wheelchairs.
Most wheelchair manufacturers, including those with products that comply with WC19, do not advertise
or mention the availability and importance of purchasing WC19 products for people who travel while
seated in their wheelchairs. Consequently, consumers are less likely to be aware of WC19 wheelchairs.
Chapter 5. Regulation and Policy 29
Most transit providers and some vehicle and equipment manufacturers

agree that some type of “certification” of wheelchairs and scooters
compatible with use of transit should be mandatory. Such certification
would include size, maneuverability, and “secure-ability.” However,
consumer advocates are justifiably concerned about the use of this
certification as the basis for denying access to non-certified devices,
and none of the federal entities with ADA-related responsibilities have
the statutory authority to regulate the design or use of medical devices
such as wheelchairs
There appears to be a great need for solutions to be sought through
processes that include all relevant stakeholders in a coordinated
WC19 attachment point placement.
manner, which does not seem to have been done in the past. For
example, full participation in discussions regarding WC19 wheelchairs
by CMS and other health care funding agencies has not yet been a priority.
Elements of Federal Guidance

From the customer’s perspective, inconsistency of optional vs. mandatory securement policies from
community to community may also be confusing: She may be accustomed to having the option of riding
unsecured on her home system, and face service denial on another city’s transit system if she attempts
to exercise this option.
The U.S. Access Board is currently updating guidelines for buses and vans.
The updated guidelines were released in draft form for public comment in April 2007.
The draft revisions have not been integrated into this document, but may be reviewed
on the Access Board Web site along with the comments received through the following
Web page: http://www.access-board.gov/news/vehicle-comments.htm.
The existing ADA vehicle specifications require a combination of design and performance criteria for
tie-down and occupant restraint devices (in order to prevent wheelchairs from moving about inside the
vehicle). Some stakeholders indicated confusion regarding how wheelchairs should be expected to fit
or maneuver into vehicles based on the ADA vehicle specifications. For example, the minimum required
wheelchair parking space is the same as the maximum wheelchair size that must be accommodated.
The requirement for “sufficient clearances to permit a wheelchair or other mobility aid user to reach a
securement location” (38.23 [a]–“General”) does not say how this should be measured, as opposed to
detailed treatment of this issue in the architectural requirements of the ADAAG.
It is also placed apart from the section on the required location and size of the securement space (38.23
[d]7–“Securement devices”), even though the latter section also discusses proximity to the vehicle
entrance. (NOTE–this issue is being addressed in the proposed Access Board revision.)
Research and Development to Support Industry-Wide

Standards and New Design Approaches
Voluntary industry standards and ADA vehicle requirements are not in harmony, and the result
can be less-than-ideal vehicle configurations. The ideal securement system for large urban buses
may not be the best approach for small vehicles. For example, the defacto “standard” (actually just
a common practice in terms of equipment design) of four-point tie-downs is not uniformly agreed upon
or followed. In some cases, such as on busy urban routes, the time and ergonomics involved
in securing a customer’s wheelchair may not seem feasible to a transit operator.
Transit managers have expressed the desire for a more universal, automatic, and less physically
complicated and demanding system for securing wheelchairs. Historically, however, the transit
provider segment of the industry has not been very involved in developing standards, and has relied
mainly on “ADA compliance” as its guide, rather than seeking out best practices that may exceed ADA
requirements.
Potential alternative securement technologies, such as “docking” and the European/Canadian
rear-facing “passive compartmentalization” approach are being studied by wheelchair-oriented
research bodies for possible new ANSI/ISO standards. Research, demonstration and testing of
these new technologies in the transportation arena has been very limited in the U.S., but interest
is being spurred by the development of “bus rapid transit” services, where speed and efficiency of
boarding are critical. However, it should be noted that the operator can simply elect not to have a
mandatory securement policy.
Another potential design alternative is the improvement of space and maneuverability by using rear
(second) door boarding, instead of front door boarding. However, little or no research and development
has occurred on this topic.
Education and dissemination of available resources

Information regarding WC19 wheelchair options is not well disseminated for consumers and prescribing
health care professionals, and even wheelchair dealers (end vendors).
Transit accessibility information, including policies, is inconsistently communicated to customers and the
public. Information regarding wheelchair accommodations and policies of transit systems varies greatly
from city to city, and is not available at all in many places. Some, but not all, transit agencies have
“mandatory” securement policies.
Knowledge of auxiliary securement aids, such as wheelchair marking and tether strap programs, is
limited, not all systems have been tested to meet basic safety standards, and guidelines or specific
standards are lacking.
Best Practices
• Auxiliary securement aids, such as wheelchair marking and tether strap programs can promote
safe and fast securement and are offered by a number of transit providers and disability service
organizations.
• Transit orientation programs (“travel training” and/or vehicle orientation sessions for wheelchair users)
and marketing materials are good ways to train passengers on how to board vehicles and to know
what to expecting terms of securement and other safety aspects.
• Appendix G provides examples of helpful informational brochures.
Chapter 5. Regulation and Policy 31
Recommendations
For the industry:
Additional research
• Examination of barriers to making “transit-safe” mobility devices available to transit users,
including regulations and policies of healthcare funding programs and agencies.
Activities
• Development of guidelines for transit providers on how/why to address rider choice in their policy
for securement, including analysis of how civil rights (ADA) objectives relate to safety and liability
issues (common carrier standard of care, tort liability, etc.), as well as how to enforce and educate
customers regarding “mandatory” securement policy. It is recommended that U.S. DOT counsel be
involved in this effort.
• Increased coordination of various regulations that affect mobility device accessibility. A short-term
measure could be creation of an index on the FTA Web site (and for use in related documents) that
itemizes the locations of various regulations, guidance, and interpretations related to mobility aid
accessibility in public transit.
Appendix
Appendix A: Project Methodology

Appendix B: Annotated List of Documents Reviewed
Appendix C: Survey Tool
Appendix D: Statistical Results of Survey
Appendix E: Summary Issues from the Perspective of Consumers
Appendix F: Links to Relevant Regulatory Sources
Appendix G: Samples of Informational Brochures
Appendix A: Project Methodology

Each of the methodological approaches used for this study is described in this appendix. The findings of
the research are synthesized in Chapters 2 through 5.
Literature Review
The purpose of this task was to review existing relevant literature and current materials and practices in
order to inventory the following types of information:
• Civil rights and safety rules and regulations
• Transportation industry policies, practices, and customer/public information
• Wheelchair and health-care industry policies, practices, and consumer information
• Technical research and knowledge
• Examinations of overall issues, policies, and experience/attitudes, including disability advocacy
perspectives
The types of materials reviewed included Transit Cooperative Research Program (TCRP) reports,
agency practices, U.S. Department of Transportation (DOT) and Federal Transit Administration (FTA)
publications and documents sponsored by research and disability advocacy organizations. A database
was compiled that includes document name, publication date, methodology, reason for the study, a brief
summary, and specific findings, best practices, or issues identified. The information from this database
may be found in Appendix B.
The issues identified in these documents are synthesized in the key issues listed in Chapters 2
through 5 of this report. Following is a brief listing of the sources used in the literature review:
Regulations
• U.S. ADA regulations and related guidance for transportation services and vehicles
• U.S. Highway safety regulations for vehicles (passenger lifts/ramps, occupant restraints, etc.)
Industry Standards
• American National Standards Institute (ANSI) standards for “transit safe” wheelchairs and
transportation vehicle wheelchair tie-down and occupant restraint systems (WTORS) of ANSI/
Rehabilitation Engineering and Assistive Technology Society of North America (RESNA)
• “Ride Safe” brochure and “www.travelsafer.org” Web site by Rehabilitation Engineering
Research Center on Wheelchair Transportation Safety (RERC-WTS) at the University of Michigan,
describing wheelchair transportation safety and standards; also “WC19/Your Ticket to Ride” info at
http://www.rercwts.pitt.edu/WC19
Public transportation industry policies, practices and information
• Individual transit system rider’s guides, Web site descriptions, brochures, and policy statements
concerning mobility aid accommodations
• Transit industry training program materials related to mobility aid accommodations, including
programs of the National Safety Council, National Transit Institute, and Community Transportation
Association of America, and securement equipment manufacturers
Wheelchair Industry Information
• Manufacturers’product literature showing wheelchair model specifications that include
dimensions, weight and turning radius, and availability of “transit” or “transport” equipment
(such as “WC-19”’compliant)
Appendix A: Project Methodology 35
Technical Research
• “Transit IDEA Project 38: Assessment of Rear Facing Wheelchair Accommodation on Bus
Rapid Transit,” Oregon State University (Transportation Research Board), 2005
• “Standards and Anthropometry for Wheeled Mobility,” State University of New York, Buffalo,
2005 (with funding from the U.S. Access Board)
• “TCRP Synthesis 5 : Use of Rear-Facing Position for Common Wheelchairs on Transit,”
Transit Cooperative Research Program (Transportation Research Board), 2003
• “Wheelchair Users Injuries and Deaths Associated with Motor Vehicle Related Incidents,”
National Highway Traffic Safety Administration, 1997
• “Tri-Wheeled Scooters Transported on Buses and Vans: Assessment of Securement Restraint
Issues,” Volpe National Transportation Systems Center (Federal Transit Administration), 1995
• “The Development of an Independent Locking Securement System for Mobility Aids on Public
Transportation Vehicles,” Oregon State University (Federal Transit Administration), 1992
Issue Syntheses and Status Reports
• “Wheelchair Access: Improvements, Standards, and Challenges,” Douglas J. Cross (conference
proceedings of American Public Transportation Association), 2006
• “State-of-the-Science—Workshop on Wheelchair Transportation Safety,” Final Report, Rehabilitation
Engineering Research Center on Wheelchair Transportation Safety (National Institute on Disability
and Rehabilitation Research), 2005
• “The Current State of Transportation for People with Disabilities in the United States,” National Council
on Disability, 2005
• “Riding a Bus While Seated in a Wheelchair: A Pilot Study of Attitudes and Behavior Regarding
Safety Practices,” Universities of Pittsburgh, Louisville, and Colorado; Rehabilitation Engineering
Research Center on Wheelchair Transportation Safety (National Institute on Disability and
Rehabilitation Research), 2005 (survey of 283 wheelchair users about their experiences on public,
fixed-route buses)
• “Oversized/Overweight Mobility Aids: Status of the Issue,” Easter Seals Project ACTION, 2004
• “Synthesis of Securement Device Options and Strategies,” National Center for Transit Research,
University of South Florida (Florida Department of Transportation), 2002
• Progress in Wheelchair Securement: Ten Years After the Americans with Disabilities Act, Oregon State
University (Transportation Research Board), 2001
Stakeholder Interviews
The consulting team conducted 22 key stakeholder interviews that were customized to reflect
the area of expertise of the interviewee, and were intended to identify key issues, solicit input for
dissemination of information on the subject, and generate ideas for further research. The following
list illustrates the diversity of perspectives that were solicited as part of this process. Key findings from
these interviews are included in the issues discussion in Chapters 2 through 5. Interviews were held
with the representatives of the entities listed in the following table.
Figure A 1: Stakeholder Interview Participants

Transit Providers
• MTA New York City Transit
• Metro Transit, Minneapolis, Minn.
• Utah Transit Authority, Salt Lake City, Utah
• Link Transit, Wenatchee, Wash.
Paratransit Providers
• Paratransit, Inc., Sacramento, Calif.
• MV Transportation(which also provides contracted fixed-route transit operations)
Wheelchair Manufacturer
• Pride Mobility
Wheelchair Vendor
• Grandmar, Inc. (Emeryville, Calif.)
Vehicle Manufacturer
• El Dorado National (paratransit)
• Daimler-Chrysler Commercial Buses (primarily fixed-route buses, but also paratransit-type vehicles)
Wheelchair Tie-down and Occupant Restraint System Manufacturer
• Sure-Lok, Inc.
Transit Seating Manufacturer
• American Seating (AMSECO)
Lift/Ramp Manufacturer
• Ricon Corp.
Research Organization
• ANSI/RESNA COWHAT and RERC-WTS (University of Michigan)
• National Center for Accessible Transportation (NCAT) /Oregon State University
Disability Advocacy Organization
• Paralyzed Veterans of America
• California Foundation for Independent Living Centers
Federal Regulatory Agency
• U.S. Access Board
• U.S. DOT
Transit & Paratransit Trade Association
• American Public Transit Association (APTA) Accessibility Standards Task Force
• Community Transportation Association of America (CTAA)
State and Federal Health Care Funding/Regulatory Agencies
• State of Washington Medicaid
State Department of Transportation
• Michigan DOT
Appendix A: Project Methodology 37
Consumer Survey
Survey Development
The objectives of the consumer survey were to engage a cross-section of mobility device users of public
and private transportation to:
1) Document experiences and attitudes related to boarding and riding in transit vehicles, including using
wheelchair tie-downs and occupant restraint systems (WTORS);
2) Identify usability information that may not be incorporated in current product designs; and
3) Identify training issues
The team that was assembled to develop the survey included:
• ADA policy and practice experts
• The Director of the National Center for Accessible Transportation
• A mobility device engineering research and development expert
• A consultant who is the chair of the American Public Transportation Association’s Wheelchair User
Issues Subcommittee and who was also a former transit agency accessibility and paratransit manager
The team developed a draft version of the survey that was sent out for review and comment by
key informants in the disability community. Besides ensuring survey validity, we hoped to build a
commitment to distribution of the survey and promote interest in using the resulting report. The draft
survey was sent to key informants in the following organizations:
• National MS Society
• National Council on Disability
• U.S. Access Board
• ADAPT
• Disability Rights Education and Defense Fund
• National Independent Living Council
• American Association of People with Disabilities
• Paralyzed Veterans of America
• United Spinal Association
Based on comments from team members and key informants, Easter Seals Project ACTION staff, and
the Project Manager, the survey was revised, adjusted for the appropriate readability level, and tested.
The final survey was composed of 28 multiple-choice, check-all-that-apply, or open-ended questions that
allowed for additional comments from respondents. The survey yielded both quantitative and qualitative
data to questions addressing barriers, problems, attitudes, knowledge and experiences regarding the use
of mobility devices on public and social services transportation.
Survey Deployment and Recruitment

The final version of the survey was converted for Web presentation using HTML to ensure Web
accessibility (the survey tool may be found in Appendix C). An accessible survey template from the
Center for Accessible Media was used, and the HTML version of the survey was placed on an Internet
server by Nelson\Nygaard.
An “Action Alert” announcement that contained the survey link was sent to key informants and
stakeholders in the previously listed disability organizations and disability oriented “listservs,” and
was linked to disability-oriented bulletin boards. The notice was also sent directly to several hundred
members of the CATEA Consumer Network Registry (CCN)—a national registry of people with
disabilities who have agreed to participate in research. Advocacy and stakeholder organizations were
asked to post the link on their Web sites and send the Action Alert to their member networks asking
mobility device users of public transit to respond to the short survey. The Web link was active for 30
days between Oct. 24-Nov. 24, 2006.
The statistical results of the survey are attached as Appendix D and the key findings from this survey
are presented in Appendix E.
Appendix B: Annotated List of Documents Reviewed 39
Appendix B: Annotated List of Documents Reviewed
1. AC Transit Wheelchair Marking and Tether Strap Program

Performing Organization: Alameda-Contra Costa Transit District (AC Transit, Oakland, California)
Date: 2002
Reason for Study: Provide information on the AC Transit wheelchair marking and tether strap program.
Summary: The primary public information on this program is a brochure (and web site, http://www.
actransit.org/pdf/securement.pdf) that explains how the program works. Objectives are increased
accessibility of AC Transit buses to individuals using all types of mobility aids, and support for bus
operators in performing safe and proper wheelchair securement.
2. Accommodating Mobility Aids on Canadian Low Floor Buses Using the Rear Facing Position
Design: Experience, Issues, and Requirements
Performing Organization: Rutenberg Design, Inc.
Sponsoring Organization: Canadian Urban Transit Association
Date: 2000
Reason for Study: To report current experience with the rear facing wheelchair position design in both
European and Canadian transit agencies, explore a variety of implementation issues, and identify
requirements and conceptual design considerations for further implementation.
Methodology: Case studies and interviews were conducted through Canadian and European transit
agencies currently using the rear facing securement position.
Summary: Rear facing securement originated in Europe and affords the same level of safety to
passengers in wheel chairs as is provided to all other passengers, allows for complete independence,
adapts to most wheelchair and scooter types and sizes, and does not require the assistance of the
driver. Passengers surveyed generally preferred rear facing securement due to the independence given
to them.
3. ANSI/RESNA WCT/Volume 4—Wheelchairs and Transportation
Performing Organization: Rehabilitation Engineering and Assistive Technology Society
of North America (RESNA)
Date: 2004 (for sections completed; other sections currently under development)
Reason for Study: Volume 4, when completed, will contain product standards, including WC18
(wheelchair tie-down and occupant restraint systems, or WTORS), WC19 (wheelchairs, and WC2
(wheelchair seating systems), plus related documents.
Summary: This volume of US voluntary industry standards addresses the design, testing, performance
and labeling of wheelchairs when they are used as seats in motor vehicles. It also covers Wheelchair
Tie-down and Occupant Restraint Systems (WTORS) for use in motor vehicles. The most commonly
used method of securing a wheelchair to the floor of the vehicle is a 4-point, strap type tie-down system.
The document reviews standards for wheelchair securement points on the mobility device, occupant
safety belt placement, user instructions, and product labeling with warnings, reports of performance
testing, etc.
4. Carriage of Mobility Scooters on Public Transport—Feasibility Study

Performing Organization: MVA LTD, London
Sponsoring Organization: Department for Transport (UK)
Date: 2006
Reason for Study: Research is required to establish whether the Department’s current policy (prohibiting
the carriage of scooters) is reasonable and should continue, or whether it should be relaxed so that
guidance can be given to operators to permit certain models of scooter to be carried, and if so, what
characteristics those models must have.
Methodology: A database was developed to catalog the most popular mobility scooters used in the UK,
Public transport operators in the UK were contacted to find their current scooter policies, and a literature
review of international and domestic documents was conducted
Summary: The research highlighted a lack of information both nationally and internationally about the
carriage of scooters on public transport. A key recommendation is for further study of limited user trials
to inform policy decisions.
5. Current State of Transportation for People with Disabilities in the United States
Sponsoring Organization: National Council on Disability
Date: 2005
Reason for Study: Identify transportation barriers, promising practices and models, to develop
recommendations for expanding mobility options for people with disabilities on public and private
transportation.
Methodology: Literature review of studies and documents related to fixed route transportation,
paratransit, private transportation, other publicly funded transportation and historic reports; Extensive
interviews with 3 groups of stakeholders (disabled riders who regularly use public transit, transportation
providers and consultants, officials from federal transportation agencies); Review of relevant research
studies that are national in scope; Review of primary sources concerning specific transportation
programs; Focus group discussions with stakeholders in the disability community
Summary: While significant progress has been made in terms of transportation accessibility since the
passage of the ADA, gaps remain due to the chronic lack of funding. This is particularly true for mobility
options of people with disabilities in rural areas or those who live far from fixed-route bus systems. In
other sectors, such as accessible taxis, a lack of requirements has meant very uneven progress.
6. Department of Transportation Disability Law Guidance—Use of “Segways”
on Transportation Vehicles
(as displayed on FTA web site: WWW.FTA.gov/Civil Rights and Accessibility/Americans with Disabilities
Act/ADA Technical Assistance/DOT Disability Law Guidance)
Performing Organization: Federal Transit Administration (FTA), US DOT
Date: 2005
Reason for Study: Discussion and guidance on whether transportation entities should permit the
“Segway” personal transportation device to be used on transportation vehicles when used as a
mobility device by people with disabilities. The Segway is a two-wheeled, gyroscopically stabilized,
battery-powered personal transportation device. It is not designed primarily for use by individuals with
disabilities, but some such individuals may use a Segway as a personal mobility aid, in lieu of more
traditional devices like a wheelchair or scooter.
Methodology: This guidance was approved through the DOT’s Disability Law Coordinating Council
as representing the official views of the Department on this matter.
Summary: The Department’s ADA rule (49 CFR Part 37, §37.3) defines a “wheelchair” as “a mobility
aid belonging to any class of three or four-wheeled vehicles, designed for and used by individuals with
mobility impairments...”. By this definition, a Segway is not a wheelchair. However, when used as
a mobility device, it is part of the broad class of mobility aids that are intended to be accommodated
(similar to canes, walkers, etc.), and must be allowed on board buses and trains. Even though specific
ADA regulations on lift and securement use for wheelchairs do not apply to Segways, they must be
permitted to use the lift if necessary to enter a vehicle.
7. The Development of an Independent Locking Securement System (ILS) for Mobility Aids
on Public Transportation Vehicles (DOT-T-93- 8)
Author: Katherine Hunter-Zaworski & Joseph Zaworski
Performing Organization: Transportation Research Institute, Oregon State University
Sponsoring Organization: Office of Technical Assistance, Federal Transit Administration
Date: 1992
Reason for Study: Primary objective was to design, build, and test a wheeled mobility aid securement
system that would operate with all mobility aids in “common use” on fixed route transit vehicles.
Methodology: Docking securement system was designed and tested in two phases. Phase 1: pilot
tests conducted in the laboratory at OSU and Phase 2: field tests conducted at Lane Transit District in
Eugene, OR.
Summary: The pilot testing was used to determine how easily passengers could use the system
and finds bugs in testing protocol. In Phase 2 a real bus was used to determine ease of use and to
determine acceleration, deceleration, and turning forces on the ILS system. A scooter and manual
wheelchair were used in both phases. An ILS system could maximize mobility aid user independence,
minimize transit vehicle operator involvement, minimize securement and release time, and satisfy all the
proposed securement standards and guidelines.
8. ISO 7176-19 Wheeled Mobility Devices for Use in Motor Vehicles
Performing Organization: International Organization for Standardization
Date: 2001
Reason for Study: Establishes international standards that can be applied to wheelchair securement
in motor Vehicles (note: this is an international standard that has a comparable and coordinated part
in the related US standard, ANSI/RESNA VOLUME 4, as described above.)
Methodology: Requirements based on well documented motor vehicle crash statistics
Summary: Section 19 of ISO 7176 specifies wheelchair design and performance requirements and
associated test methods. The requirements are designed to be secured by any type of wheelchair
tie-down in accordance with ISO 1 542-1 and any other applicable parts of the ISO 1 542 series.
9. Oversized/Overweight Mobility Aids: Status of the Issue

Author: Amy Pass & Ken Thompson
Sponsoring Organization: Easter Seals PROJECT Action
Date: 2004
Reason for Study: To present a “snapshot” of the current status of issues around safe transport of
passengers using oversized and overweight mobility aids.
Methodology: Informal surveys of groups with different perspectives (i.e. transit authorities, research
organizations, regulatory bodies, standards groups, and others) showed that several problems are
at the core of this issue. Survey participants were also asked what resources would best meet their
information needs as they deal with these issues.
Summary: This is an overview that discusses the issues on the use of oversize or overweight mobility
devices by passengers on transit. Research groups and standard-setting bodies continue to investigate
the situation and may propose strategies or policy recommendations in the future.
10. PASS - Passenger Service and Safety Certification—Training Program
Performing Organization: Community Transportation Association of America (CTAA)
Sponsoring Organization: Community Transportation Association of America (CTAA)
Reason for Study: The PASS Certification program was developed to train drivers in proper
passenger assistance techniques and sensitivity issues in serving persons with disabilities,
primarily in paratransit services.
Summary: The PASS program is designed as a three-day “Train-the-Trainer” course to certify trainers
who can then train drivers or as a two-day driver training program in which PASS instructors train an
agency’s drivers.
11. Policies for Segways on Public Transit Vehicles
Author: John Acosta, Senior Deputy General Counsel
Performing Organization: TriMet (Tri-County Metropolitan Transportation District of Oregon) Portland, Oregon
Date: 2006
Reason for Study: Clarification of US DOT Disability Law Guidance entitled “Use of Segways on
Transportation Vehicles”, vis-à-vis the ability of public transit providers to adopt reasonable policies,
such as those adopted by TriMet, to regulate transport of two wheeled devices, including Segways, on
public transit vehicles when used by people with disabilities as mobility aids.
Methodology: Review of FTA regulations and background on Segway devices including the evolution of
TriMet’s Segway/Two-Wheeled Mobility Device Policy; testing on TriMet vehicles.
Summary: TriMet established a final policy based on testing done with Segways on board both buses
and light rail vehicles. The policy was codified as “TriMet Administrative Rules for the Transport of a
Two-Wheeled Mobility Device on TriMet Vehicles”, January 3, 2 5, and can be found at, http://trimet.
org/pdfs/code/TriMet_Administrative_Rules_Mobility_Device.pdf.
The TriMet policy requires that individuals seeking to transport Segways first receive authorization
based on an application, medical certification, attendance at an orientation session, and display of a
special identification sticker on the device. Visitors may transport such two-wheeled devices, provided
that they have documentation from their “home” transit system to confirm that they have a disability
requiring the use of a mobility device.
12. Progress in Wheelchair Securement: Ten Years After the Americans

with Disabilities Act (Paper # 1-2159)
Author: Katharine Hunter-Zaworski and Joseph Zaworski
Performing Organization: Oregon State University
Sponsoring Organization: Transportation Research Board
Date: 2001
Reason for Study: The ADA requires that wheelchairs be secured so they will not move more than
50 mm. This document reviews background on securement and current status of wheelchair
securement on public transit as well as presenting recommendations for speeding up acceptance of
advanced securement technologies.
Methodology: Review of current materials on the subject
Summary: Oregon State University has completed a thorough review of securement systems since the
passage of the ADA. Docking provided fast, easy securement without driver assistance. The document
provides a description of RESNA and SAE agreed standards for belt securement and securement
testing parameters. Flexible systems mostly use belts to secure. A four point tie down is the most
common example. Belts overwhelmingly used throughout country since easy to adapt to any device.
Rigid types include clamps. The clamp type system is more expensive but can prevent motion in all
directions if attached to a properly designed attachment point.
13. The Public Service Vehicles Accessibility Regulations 2000 Guidance
(Disability Discrimination Act 1995)
Performing Organization: Department for Transport (United Kingdom)
Date: 2000
Reason for Study: Provide guidance for the public transport manufacturing and operating industries on
meeting requirements of regulations to ensure that public service vehicles are accessible for people
with disabilities.
Summary: The document reviews the legal language presented in the regulations and provides
explanations of each, as well as various best practices. The regulations apply to public service vehicles
for 22 passengers and above providing local or scheduled service. Varieties of practices are discussed
within sections on specific design and feature guidelines.
14. Question & Answers Concerning Common Wheelchairs on Public Transit
Federal Transit Administration, ADA Information, Published by the Office of Civil Rights, Volume 1.
(as displayed on FTA web site, www.FTA.gov/Civil Rights and Accessibility/Americans with Disabilities
Act/ADA Technical Assistance/FTA bulletins)
Author: Federal Transit Administration- Office of Civil Rights
Performing Organization: Federal Transit Administration, US DOT
Reason for Study: To answer common questions transit operators ask about the ADA
Summary: Presented in question-and-answer format.
15. Riding a Bus While Seated in a Wheelchair: A Pilot Study of Attitudes and Behavior
Regarding Safety Practices.
Assistive Technology. 19(4): 166–179.
Author: Buning, M.E., Getchell, C.A.(nee Armstrong), Bertocci, G.E. & Fitzgerald, S.G.
Performing Organization: Rehabilitation Engineering Research Center on Wheelchair Transportation
Safety (RERC-WTS), University of Pittsburgh, Department of Rehabilitation Science and Technology
Sponsoring Organization: National Institute on Disability and Rehabilitation Research,
US Department of Education
Date: 2007
Reason for Study: To examine the real life usage patterns of wheelchair transportation safety equipment
such as wheelchair securement systems and occupant restraint systems on disabled passengers.
Methodology: A total of 283 wheelchair-using bus riders responded to a 35-item web-based survey
investigating their experiences on public, fixed-route buses across the US.
Summary: The survey addressed usage of four-point, strap-type wheelchair tie-downs and occupant
restraint systems (WTORS), the attitudes and behaviors of wheelchair users toward the use of this
equipment and the overall transit experience.
16. Ride Safe Brochure
Author: University of Michigan, Transportation Research Institute
Performing Organization: Rehabilitation Engineering Research Center on Wheelchair Transportation Safety
Sponsoring Organization: University of Michigan Transportation Research Institute, University of
Michigan Health System, and the RERC on Wheelchair Transportation Safety
Date: 2005
Reason for Study: The purpose of the Ride Safe brochure is to give wheelchair users, therapists,
families/caregivers, and transportation providers information on how to provide a safe transportation for
wheelchair-seated travelers through effective wheelchair securement, proper use of occupant restraints
(seatbelts), and the use of crash tested, WC19 compliant wheelchairs.
Summary: Brochure summarizes best practices on securing wheelchairs and occupants all types
of transportation vehicles.
17. Securement of Wheelchairs and Other Mobility Aids on Transit Vehicles

Author: Dale Daucher, P.E.
Performing Organization: United States Architectural and Transportation Barriers Compliance Board
Web site, http://www.access-board.gov/research/WheelchairSecurement/report.html
Date: 1990
Reason for Study: Create a brochure to assist transit authorities with information on successful policies
and equipment that two transportation authorities developed over ten years. In considering the many
types of mobility devices and buses/vans, as well as the variety and sizes of lifts, there is no single
solution to accessibility on mass transit vehicles.
Methodology: In 1987, Southern California Rapid Transit District (SCRTD) tested 14 wheelchairs/
mobility devices on 6 different lift/bus types. Four criteria were evaluated: length, maneuverability,
securement on the lift, and securement in the travel area.
Seattle Metro assessed needs and established policies using a subjective approach beginning in 1978.
Information came from meetings with the Elderly and Handicapped Task Committee, a citizens’ task
committee, and a task group of bus drivers.
Summary: This brochure provides information on the successful ADA policies and experience of SCRTD
and Seattle Metro.
18. State of the Science Workshop on Wheelchair Transportation Safety
Author: Multiple authors
Performing Organization: Rehabilitation Engineering Research Center (RERC) on Wheelchair
Transportation Safety (WTS), University of Pittsburgh, Department of Rehabilitation Science
and Technology
Sponsoring Organization: National Institute on Disability and Rehabilitation Research (NIDRR)
Date: 2005
Reason for Study: Review and document the status of wheelchair transportation safety to identify
deficiencies and formulate, discuss, and prioritize recommendations for the future.
Methodology: RERC staff identified four focus areas and wrote white papers to highlight the status
and issues in each area. Focus groups were used to help each participant to generate ideas/responses
to various questions. Once ideas and questions had been recorded, group members ranked the ideas.
Summary: The RERC-WTS sponsored a “State-of-the-Science” workshop in January 2005.
Approximately 45 people attended, including researchers, disability advocates, wheelchair and transit
manufacturers, transit and school bus industry representatives, government policy staff, and health
care/rehabilitation professionals.
19. Synthesis of Securement Device Options and Strategies

Author: Jennifer Hardin, Chandra Foreman, and Linda Callejas
Performing Organization: National Center for Transit Research (NCTR), University of South Florida
Sponsoring Organization: Florida DOT and US DOT, Office of Research and Special Programs
Date: 2002
Reason for Study: The transit industry has concerns about the wide variety of mobility devices used by
passengers. Efforts to address these concerns have consisted of developing standards for securement
devices and for mobility devices used as seats in motor vehicles. Many in the transit industry feel that
until these issues are resolved, the safe securement of mobility devices will continue to be a challenge.
Methodology: In 2001, surveys were sent to 129 paratransit providers and 22 transit operators in
Florida. In addition, 70 non-Florida transit agencies were surveyed. 95 agencies responded in total.
Summary: The study discusses the scope and magnitude of wheelchair securement issues facing
transit agencies, and presents the results of a survey on securement devices and strategies used
throughout Florida and the US.
20. TCRP Report 24—Guidebook for Attracting Paratransit Patrons to Fixed Route Services
Author: John N. Balog, KETRON Division of the Bionetics Corporation
Performing Organization: Transit Cooperative Research Program (TCRP, of the Transportation
Research Board, National Research Council)
Sponsoring Organization: Federal Transit Administration (US DOT) and the Transit Development Corp.
Date: 1997
Reason for Study: The guidebook seeks to develop methods to attract paratransit patrons and others
with disabilities to fixed-route transit.
Methodology: The guidebook reflects the findings of rider and non-rider surveys, targeted at providing
fixed-route transit systems with step-by-step instructions on how to attract individuals with disabilities
and other potential riders to fixed route services.
Summary: Chapter 5 of the guidebook focuses on developing driver training, with segments on lift
operation and wheelchair securement, as well as recognizing and assisting with specific disabilities.
Chapter 6 focuses on programming accessible bus stop improvements. Other chapters are about a
variety of topics not directly related to wheelchair accessibility and accommodation.
21. TCRP Synthesis 5 : Use of Rear-Facing Position for Common Wheelchairs on Transit Buses
(A Synthesis of Transit Practice)
Author: Uwe Rutenberg (Rutenberg Design, Inc.) and Brendon Hemily (Toronto, Ontario, Canada)
Performing Organization: Transit Cooperative Research Program (TCRP), Transportation Research
Board (of the National Academies)
Sponsoring Organization: Federal Transit Administration (US DOT) and the Transit Development Corp.
Date: 2003
Reason for Study: To describe the state of the practice of using rear-facing position for accommodating
“common wheelchairs” on large urban transit buses and to identify issues related to its transferability to
the United States
Methodology: The report provides a synthesis of information from a literature review, surveys and
case studies of Canadian transit systems that have adopted the rear-facing position, investigation of
manufacturer perspectives, and interviews with experts in other countries: UK, France, Germany, Sweden,
and Australia. Also reviewed was the experience of AC Transit in Oakland, Calif., the first US transit
agency to use a rear-facing wheelchair position design.
Summary: The synthesis identified common design elements for successful implementation of the rear-
facing design approach. A preliminary review of ADA requirements indicates that the rear-facing position
can be used by US transit systems, provided that certain conditions are met.
The benefits associated with this approach make it particularly attractive for Bus Rapid Transit (BRT)
systems, given the short dwell times and other needs of high capacity services. However, further study
is needed concerning specific system design elements, based on transit system experience and future
research on dynamic forces and effective/appropriate design requirements.
22. Transit IDEA Project 38: Assessment of Rear Facing Wheelchair Accommodation on BRT
Author: Katharine Hunter-Zaworski and Joseph Zaworski
Performing Organization: Oregon State University
Sponsoring Organization: Transportation Research Board
Date: 2005
Reason for Study: To evaluate the comfort and safety of rear facing securement areas in bus rapid
transit operations
Methodology: Acceleration and deceleration forces were evaluated using rear and side facing
securement on 6 different bus models (30’ low floor, 35’ low floor, 40’ low floor, 40’ high floor, 40’ double-
decker bus, and 60’ articulated bus) in Eugene, Oregon under normal and extreme operating conditions.
Three different wheelchair types were used in testing - manual wheelchair, power wheelchair, and
a 3-wheeled scooter; in three different positions - backrest only rear facing, side facing with forward
wall only, and rear facing with backrest, sidewall, and aisle side armrest. A 50 percentile male dummy
with its chest strapped to the backrest of the wheelchair was used in all scenarios. A survey was also
conducted of current and potential bus users to determine their opinions on rear facing securement.
Summary: The study showed that wheelchair movement was strongly dependent on wheelchair type.
Under normal driving, the manual chair would rotate during turns, the scooter would tip over during
stronger turns, and the power chair was stable throughout. Under extreme conditions, all three could
be made to tip over if provided with only a backrest and a wall on only one side. Survey results show
70% of respondents enthusiastic about rear facing securement, 10% had no opinion, and 20% did not
want to use the method. Under normal conditions, scooter and manual users must expect some level
of movement with their mobility aid.
23. Tri-Wheeled Scooters Transported on Buses and Vans: Assessment of Securement

Restraint Issues
Author: David Spiller
Performing Organization: US DOT - Research and Special Programs Administration, Volpe National
Transportation Systems Center
Sponsoring Organization: US DOT - Federal Transit Administration
Date: 1995
Reason for Study: Transit systems are required under the ADA to accommodate all common
wheelchairs and mobility aids, including tri-wheeled scooters, provided they meet the size limits (3 x48”,
etc.) therein defined. Agencies have responded with concerns over the safety of transporting these
devices. This report provides an assessment of securement and restraint issues related to the transport
of tri-wheeled scooters and their occupants on buses and vans used in public transit service.
Methodology: An extensive review of research, test reports, and expert opinions of the technical
community was performed to evaluate securement issues with tri-wheeled scooters.
Summary: Actual and potential problems were identified, including crash-related issues such as inability
to restrain the battery in a crash impact, shearing or fracture of the seat pedestal, large forces that
exceed the restraining force of seat designs, and occupant injury from contact with the steering tiller.
Non-crash issues include inaccessible and structurally inadequate attachment points, and the
proliferation of scooter models that are incompatible with securement systems. Issues that pertain to
both categories are the rollover or tipping instability of the device and spillage of battery fluid, unless of
the dry or gel-type.
The mobility aid user, vehicle, securement devices, and occupant restraints comprise a complex system.
Failure to address this can have unintended consequences, including potential injury to the mobility aid
user and other passengers. The vast majority of accidents and incidents involving mobility aid users are
not crash-related, and result from excessive braking or sharp cornering, or involve lift operations.
24. US Public Transportation Regulations—Americans with Disabilities Act
EXCERPTS related to wheelchair accessibility
(from: http://www.fta.dot.gov/ada/adaregs.html and http://www.fta.dot.gov/legal/regulations/us_dot/56
1_56 8_ENG_HTML.htm)
TITLE 49 — TRANSPORTATION, SUBTITLE A--OFFICE OF THE SECRETARY OF
TRANSPORTATION
PART 38 - Americans with Disabilities Act (ADA) Accessibility Specifications For Transportation
Vehicles, Subpart B: Buses, Vans, and Systems;
Sec. 38.23 - Mobility aid accessibility.
Sec. 38.29 Interior circulation, handrails and stanchions.
Appendix to Part 38--Guidance Material:
I. Slip Resistant Surface--Aisles, Steps, Floor Areas Where People Walk,
Floor Areas in Securement Locations, Lift Platforms, Ramps
III. Handrails and Stanchions
TITLE 49—TRANSPORTATION, Subtitle A--Office of the Secretary of Transportation
PART 37_TRANSPORTATION SERVICES FOR INDIVIDUALS WITH DISABILITIES (ADA)
Sec. 37.3 Definitions (excerpt):
“Wheelchair means a mobility aid belonging to any class of three or four-wheeled devices, usable
indoors, designed for and used by individuals with mobility impairments, whether operated manually
or powered. A “common wheelchair’’ is such a device which does not exceed 30 inches in width and
48 inches in length measured two inches above the ground, and does not weigh more than 600 pounds
when occupied.”
Subpart G_Provision of Service
37.161 Maintenance of accessible features: General.
37.163 Keeping vehicle lifts in operative condition: Public entities.
37.165 Lift and securement use.
Sec. 37.167 Other service requirements.
37.173 Training requirements.
Appendix D to Part 37--Construction and Interpretation of Provisions of 49 CFR Part 37
(“INTERPRETIVE APPENDIX”)
Subpart G--Provision of Service
Section 37.161 Maintenance of Accessible Features--General
Section 37.163 Keeping Vehicle Lifts in Operative Condition--Public Entities
Section 37.165 Lift and Securement Use
Section 37.167 Other Service Requirements
Section 37.173 Training
Final Rule Adopting New Accessibility Standards -- Effective November 29, 2006
SUMMARY: The Department is amending its Americans with Disabilities Act (ADA) regulations to adopt,
as its regulatory standards, the new Americans with Disabilities Act Accessibility Guidelines (ADAAG)
recently issued by the Access Board, including technical amendments the Access Board subsequently
made to the new ADAAG. In adopting the new ADAAG as its standards, the Department is making
minor modifications to some of the Guidelines and is providing further guidance concerning its newly-
adopted standards.
DATES: This rule is effective November 29, 2006.
49 CFR PART 37 Appendix A (editor’s note: as amended as noted above)
(http://www.access-board.gov/ada-aba/final.htm#Facilities)
810 Transportation Facilities
810.2 Bus Boarding and Alighting Areas.
810.3 Bus Shelters.
810.4 Bus Signs.
25. Wheelchair Access: Improvements, Standards, and Challenges

(proceedings of 2006 APTA Bus and Paratransit Conference)
Author: Doug Cross, Douglas J. Cross Transportation Consulting
Sponsoring Organization: American Public Transportation Association (APTA)
Date: 2006
Methodology: Synthesis of existing issues currently facing transit agencies and wheelchair users
Summary: This report shows that wheelchair access on transit buses and paratransit is getting more
complicated as service providers are faced with accommodating more passengers with an ever-
increasing diversity of mobility aids. The report also suggests emerging solutions for future study.
26. Wheelchair Access: Issues and Options for the 2000s
(proceedings of 2004 APTA Bus and Paratransit Conference)
Author: Doug Cross, Douglas J. Cross Transportation Consulting
Sponsoring Organization: American Public Transportation Association (APTA)
Date: 2004
Methodology: Synthesis of issues currently facing transit agencies and wheelchair users, with
examination of new design approaches and industry standards as potential solutions.
Summary: The synthesis covers issues rear and mid-door ramps on low floor buses, rear facing
securement with backrest, wheelchair marking and tether straps programs, activities related to
standards such as ANSI/RESNA WC19 Wheelchairs Used as Seats in Motor Vehicle.
27. Wheelchair Securement on Bus and Paratransit Vehicles
Author: Virginia Dong & Robert Smith
Performing Organization: California Department of Transportation (CalTrans)
Date: 1981
Reason for Study: This report represents the second phase of an ongoing study to evaluate needs for
a safe, reliable and easy-to-operate wheelchair securement system. The initial report published the
results of 42 tests.
Methodology: 59 physical sled tests at various velocity and deceleration levels were performed on a
50th percentile male dummy (165 lbs) in both manual and electric wheelchairs in the forward and side
facing positions
Summary: Tests on wheelchair securement systems that revealed a wheelchair and its occupant can
survive a 200mph/100g crash if properly secured. This definition requires the securement system
to symmetrically grip the wheelchair in at least two places and be designed to remain secure at the
imposed loads. The occupant should also be restrained with an upper torso belt and a lap belt.
28. SAE Recommended Practice J2249—Wheelchair Tie-down and Occupant Restraint Systems
for Use in Motor Vehicles
(NOTE–this voluntary industry standard has subsequently been coordinated with and included under
ANSI/RESNA Volume 4 standards, as described above)
Performing Organization: SAE (Society of Automotive Engineers)
Sponsoring Organization: SAE (Society of Automotive Engineers)
Date: 1997
Reason for Study: To establish standards for design requirements, test methods, and performance and
labeling requirements for wheelchair tie-down occupant restraint systems (WTORS).
Methodology: The standard established test methods and performance criteria for a 48-kph, 20-g sled
impact test.
Summary: This effort established minimum design requirements, performance requirements and
associated test methods, and requirements for product labeling and manufacturer instructions and
warnings for WTORS.
29. Wheelchair Users Injuries and Deaths Associated with Motor Vehicle Related Incidents
(NHTSA Research Notes)
Author: Delmas Johnson and Gayle Dalrymple
Performing Organization: National Highway Traffic Safety Administration (NHTSA), US DOT
Date: 1997
Reason for Study: Conducted to determine the extent to which non-vehicle crash related reasons
(improper securement, lift/ramp problems, and related actions) were involved in injury or death to
wheelchair users in motor vehicle incidents.
Methodology: National Center for Statistics and Analysis (NCSA) examined data from the Consumer
Product Safety Commission’s (CPSC) National Electronic Injury Surveillance System (NEISS) on cases
of injuries or death of wheelchair users involving motor vehicles from 1991–1995.
Summary: Data on non-crash related activity associated with injury or death to wheelchair users
were examined to determine the extent to which improper securement or related actions were
involved. Activities were classified into five categories: 1) Improper or no securement in the motor
vehicle, 2) Collision between a wheelchair and a motor vehicle, 3) Wheelchair lift malfunction (lift fell,
did not reach the ground, or person was thrown from the lift), 4) Transferring to or from a motor vehicle
and, 5) Falling onto or off of a ramp.
Appendix C: Survey Tool
Experience of Wheelchair Users on Public Transportation Survey

Easter Seals Project ACTION is surveying the experiences of mobility
device users of public and social service transportation (including
paratransit) vehicles. Easter Seals Project ACTION is a federally
funded research and demonstration program to improve access to
public transportation for people with disabilities. Your responses
will help clarify ways that public transportation and wheelchair
Manual Wheelchair Power Wheelchair
manufacturers can remove barriers to the use of public and social
service transportation and improve accommodations for mobility
device users. Family members and personal care assistants may also
participate in the survey. You should complete this survey if you or the
person you care for travels with a wheeled mobility device and uses
regular public transportation, paratransit, taxis, and/or medical/social
service transportation.
This survey will be available until Nov. 24, 2006.
Wheelchair Occupant Restraint
The survey will to take approximately 10–15 minutes to complete. SecurementSystem (Seat Belt) System
Your responses will be kept completely confidential: no information

obtained through this study will be attributed to you by name.
If you have questions about this survey, please contact:
RL Grubbs, MA., M.Ed.
Georgia Institute of Technology/Wheeled Mobility RERC
Principal Investigator for the Project ACTION Study
Phone: 404-385-0475
Email: rl.grubbs@coa.gatech.edu
Questionnaire for Mobility Device Users of Public Transit

Please respond to each question on the survey to the best of your knowledge and experience.
Key Definitions
Wheelchair: in this survey, the word ‘wheelchair’is often used to identify both manual wheelchairs,
power wheelchairs, scooters and other types of wheeled mobility devices.
Wheelchair securement system: The four-point tie-down, wheel clamps, or docking type system that
anchors a wheelchair to the vehicle floor or rear facing containment.
Occupant restraint system: The lap and/or shoulder belt, either mounted to the wheelchair or to the
motor vehicle that acts as a seat belt. Occupant restraints are not the same as the positioning belts
found on some wheelchairs that are intended for postural support.
Appendix C: Survey Tool 53
Background
Q1. What is your relationship to the mobility device user?

❑ I am the mobility device user
❑ I am a family member
❑ I provide personal assistant services to a mobility device user
Q2. Do you now use any of the following equipment for people with mobility impairments? How long
have you used this equipment? (Check all that apply)
Less than
1-5 years 6-1 years 11-15 years 16+ years
1 yr
❑ Do not use any
❑ Cane ❑ ❑ ❑ ❑ ❑
❑ Crutches ❑ ❑ ❑ ❑ ❑
❑ Walker ❑ ❑ ❑ ❑ ❑
❑ Manual wheelchair ❑ ❑ ❑ ❑ ❑
❑ Power wheelchair ❑ ❑ ❑ ❑ ❑
❑ Scooter ❑ ❑ ❑ ❑ ❑
❑ Lower extremity
❑ ❑ ❑ ❑ ❑
prosthesis
❑O ther
_________________ ❑ ❑ ❑ ❑ ❑
Q3. What types of accessories/items do you carry onboard when you use regular public
transportation, paratransit, taxis, or medical/social service transportation? (Check all that apply)
Where do you carry the items?

In Back In Front On the Sides Underneath
❑ Backpack ❑ ❑ ❑ ❑
❑L aptop computer/
❑ ❑ ❑ ❑
briefcase
❑L uggage/suitcase ❑ ❑ ❑ ❑
❑G rocery/shopping
❑ ❑ ❑ ❑
bags
❑S hopping carts/
❑ ❑ ❑ ❑
baskets
❑P ortable oxygen ❑ ❑ ❑ ❑
❑V entilator ❑ ❑ ❑ ❑
❑R eacher ❑ ❑ ❑ ❑
❑O rthopedic baby
❑ ❑ ❑ ❑
stroller
❑S ervice animal ❑ ❑ ❑ ❑
❑O ther (specify)______ ❑ ❑ ❑ ❑
Q4. Do wheelchair securements and occupant restraints (seat belts) cause problems with any part or
portion of your wheelchair or any of the above items?
❑Y
es
❑N
o
❑D
on’t know
If yes, please briefly describe the problem caused by the securements and/or restraints and what was
done to solve the problem. What are the dimensions of the item(s) (height, length, depth, weight, etc)?
_________________________________________________________________________________
_________________________________________________________________________________
_________________________________________________________________________________
Q5. Have you ever been denied transportation because your wheelchair and accessories were too
wide or long or too heavy?
❑ Yes
❑ No
❑ Don’t know
If yes, please briefly describe the situation. What are the dimensions of your mobility device (height,
length, width, weight, etc.) and why were you denied transportation?
_________________________________________________________________________________
_________________________________________________________________________________
_________________________________________________________________________________
Transportation Usage
Q6. Check the types of transportation services you use and how often you typically use them. (Check
all that apply)
Daily At least At least Less than Never
once per once per once per
week month month
Do not use any ❑ ❑ ❑ ❑ ❑
Fixed-route bus ❑ ❑ ❑ ❑ ❑
Light rail or streetcar ❑ ❑ ❑ ❑ ❑
Rapid transit or commuter rail ❑ ❑ ❑ ❑ ❑
ADA paratransit ❑ ❑ ❑ ❑ ❑
Medical/social service transportation ❑ ❑ ❑ ❑ ❑
Accessible Taxi ❑ ❑ ❑ ❑ ❑
Other (specify)______________ ❑ ❑ ❑ ❑ ❑
Q7. What problems do you experience boarding the vehicles you checked above? (Check all that apply)
❑ Do not have any problems
❑ Operators/ drivers do not kneel the vehicle
❑ Operators/drivers/gate agents do not help me up/ down boarding ramps
❑ Ramps are too steep
❑ Ramps are too narrow for my wheels
❑ Ramps are slippery, my wheels spin on the ramp when boarding
❑ Ramp corners are too high, I cannot roll over ramp corners onto the ramp
❑ Ramp edges cause damage to my casters/tires/push rims
❑ Ramps do you fold out properly
❑ Lifts do not operate
❑ Operator/driver says that the lift will not work/won’t use lift
❑ Lift has malfunctioned while in use
❑ Operators/drivers don’t allow enough space to approach the lift
❑ Operators/drivers/gate agents do not fold up seats to clear the space for my wheelchair
❑ My casters get stuck in the space between the train platform and the door of the train
❑ Other (please specify) ______________________________________
Q8. What problems do you experience using the fare payment system onboard the bus and/or train?
❑ Cannot reach the card swipe
❑ Cannot insert fare due to obstructions
❑ Cannot maneuver wheelchair/scooter around the fare payment stand
❑ Cannot use fare payment systems due to dexterity limitations
Q9. What problems do you experience moving between the vehicle door and the securement area?
❑ There is not enough space to turn my wheelchair around
❑ The vehicle seats block the area
❑ The seat belts get tangled in my wheels
❑ I have to maneuver around luggage, bags and baby carriages
Q10. When you board a public transit bus, how often is your wheelchair or scooter secured
to the floor of the bus?
❑ Never
❑ Less than half of the times I ride the bus
❑ More than half of the times I ride the bus
❑ All of the time
❑ Other (please specify) _____________________________________________
Q11: How is your wheelchair or scooter usually secured or stabilized? (Check all that apply)
❑ It is not secured
❑ I put my wheelchair brakes (wheel locks) on
❑ I turn the power off
❑ I use the seat (lap) belt
❑ I use the shoulder belt in addition to the lap belt
❑ The frame of my wheelchair is secured with floor tie-downs
❑ I use a rear facing containment area
Q12: Do you feel your wheelchair or scooter is secure enough using the methods you checked above?
❑ Yes
❑ No
Q13. If your wheelchair or scooter is not secured, what are some reasons why? (Check all that apply)
❑ Operator/driver doesn’t know how to secure my wheelchair properly
❑ Operator/driver didn’t offer or seems unwilling to take the time
❑ I prefer not to be secured
❑ I use on the postural belts that are attached to my wheelchair
❑ I’m in a hurry and don’t want to take the time myself
❑ I don’t trust the reliability of the securement and restraint belts
❑ The equipment doesn’t fit me and /or my wheelchair very well (e.g. armrests, seating system components
get in the way)
❑ I don’t feel that securing my wheelchair or putting on the seat belt is very important
❑ I feel that securing my wheelchair or putting on the seat belt is unsafe for me
❑ I don’t want the bus driver getting so close to me and my equipment
❑ I’m embarrassed because it takes so long to secure my wheelchair and put on the seatbelts
Q14. If your wheelchair or scooter is secured, what are some reasons why? (Check all that apply)
❑ I feel that I will be more protected in the event of a crash
❑ I feel that I’m safer and more stable in regular bus travel
❑ I feel that others around me are safer if my wheelchair is secured
❑ The occupant restraint system provides me with more postural support
❑ Transit provider/operator makes me have my mobility device secured
Q15. When you ask for assistance in securing your wheelchair or scooter, how often does the
operator/driver provide such assistance?
❑ Always
❑ Sometimes
❑ Never
❑ I never ask
Q16. How well do securement systems work with your wheelchair, scooter or other mobility device?
❑ Very well
❑ With some difficulty
❑ Very difficult
❑ Don’t Know
Q17. How well do passenger safety belt systems in buses generally fit you?
❑ Usually fit well and are comfortable
❑ Usually don’t fit me very well
❑ Don’t know
❑ Never use them
Q18: Have you ever been in a bus, train, van, or taxi incident where your wheelchair or scooter
moved too much or tipped over?
❑ No
❑ Yes (please provide a brief description, including vehicle/service type, whether your wheelchair was
secured and how?)
_________________________________________________________________________________
_________________________________________________________________________________
_________________________________________________________________________________
Q19. How would you describe operator/driver attitudes about transporting people using wheelchair,
scooters or other mobility equipment? (Check only one)
❑ Generally positive and willing to do whatever it takes to ensure that I’m as safe as possible
❑ Positive and helpful if they aren’t in a hurry, but negative and unhelpful if they are in a hurry
❑ Generally negative and uninformed about my safety and the safety of my mobility equipment
❑ Varies greatly depending on who the operator/ driver is
❑ Don’t know
Q20. How would you describe other passengers’ attitudes about the time it takes to be secured?
(Check only one)
❑ Generally patient and understanding
❑ Generally impatient
❑ Generally negative and uninformed about my safety and the safety of my mobility equipment
❑ Don’t know
Q21. Are you aware that transportation regulations in the Americans with Disabilities Act (ADA)
allow transportation providers to provide service to wheelchairs only of a limited size or weight?
❑ Yes
❑ No
Q22. Are you aware that transportation regulations in the Americans with Disabilities Act (ADA)
require transit providers to offer securement of wheelchair and occupants, with equipment complying
with standards described in the ADA?
❑ Yes
❑ No
Q23. Are you aware that transportation regulations in the Americans with Disabilities Act (ADA) allows
transportation providers to make securement of wheelchairs ‘mandatory’ for passengers, including the
use of lap/shoulder belts in cases when everyone else on the vehicle is required to wear them (it is
optional on buses and trains where all seats are not equipped with the belts)?
❑ Yes
❑ No
Q24. Are you aware that some wheelchair manufacturers now offer a ‘transit option’ consisting of
permanent brackets or loops for the attachment of vehicle tie-down equipment?
❑ Yes
❑ No
Q25: If you were purchasing a new wheelchair, would you be interested in getting this feature
on your new wheelchair?
❑ Yes, if yes, why? _________________________________________________________________
_________________________________________________________________________________
_________________________________________________________________________________
❑ No, if no, why? __________________________________________________________________

_________________________________________________________________________________
_________________________________________________________________________________
Q26: Please rank your most important information sources for information
about transportation safety and wheelchair/mobility devices use.
Rank the following from 1 (most important) to 10 (least important).
____ Transit providers
____ Other wheelchair users
____ Vendors (local durable medical equipment sales and service people)
____ Healthcare professionals (doctors, therapists)
____ Health insurance or other sources of funding
____ Vocational rehabilitation counselors
____ Disability/advocacy organizations
____ Magazines, catalogs and other print media
____ TV and radio advertising
____ Internet and Web sites
____ Other (please specify)_______________________________________
DEMOGRAPHICS
Please enter the following information about your gender and age…
Q27. Gender/Sex
❑ Female
❑ Male
Q28. Year of birth: ___________
Please email me a summary of the report from this survey.

My email address is…__________________________________________
Appendix D: Statistical Results of Survey
Q1. What is your relationship to the Use%

I am a family member 7 6.0%
I am the mobility device user 108 92.3%
I provide personal assistant
services to a mobility device 2 1.7%
user
TOTAL 117
Q2. What type of Less than 1 to 5 6 to 10 11 to 15 16+ Do not
Total
equipment do you use? 1 Year years years years years use
Cane 0 6 3 4 6 19 74
Crutches 2 1 0 2 6 11 77
Walker 3 6 5 3 5 22 72
Prosthesis 0 1 0 1 6 8 80
Manual Wheelchair 5 13 14 7 33 72 29
Power Wheelchair 3 16 15 9 28 71 34
Scooter 3 5 8 6 4 26 66
TOTAL 16 48 45 32 88 229 432
Q3. What types of accessories/
In On the
items do you bring with you on In Back Underneath
Front Sides
public transportation?
Backpack 73 10 6 5
Laptop computer/Briefcase 23 19 3 3
Luggage/suitcase 18 14 1 1
Grocery/Shopping Bag 27 22 9 2
Shopping Carts/Baskets 3 10 0 0
Portable Oxygen 1 0 0 0
Ventilator 0 0 0 0
Reacher 5 2 9 0
Orthopedic baby stroller 0 0 0 0
Service animal 0 0 6 0
Other 1 7 4 0
TOTAL 151 84 38 11
Appendix D: Statistical Results of Survey 61
Q2. What type of other

accessories/items do you bring Responses
with you?
Cane 2
Crutches 1
Lap Tray 1
Purse 7
Tools 1
TOTAL 12
Q4. Do wheelchair securements
and occupant restraints cause
problems with any part or portion Responses %
of your wheelchair or any of the
above items?
Don’t Know 10 8.5%
No 78 66.1%
Yes 30 25.4%
TOTAL 118
Q5. Have you ever been denied
transportation because your
Responses %
wheelchair and accessories were
too wide or long or too heavy?
Yes 20 17.4%
No 95 82.6%
TOTAL 115
Q6. What types of At least At least Less than Total
transportation services Daily once per once per once per Never Excluding
do you use and how often? week month month “Never”
Fixed Route 16 15 8 27 40 66
Light rail or streetcar 5 3 4 16 67 28
Rapid transit or commuter rail 3 8 4 21 63 36
ADA paratransit 15 16 18 30 30 79
Medical/social service
0 6 11 22 59 39
transportation
Accessible taxi 0 1 9 39 51 49
Other 8 1 1 3 0 13
TOTAL 47 50 55 158 310
Q6. Other—What types of Q8. What problems do you

transportation services do Responses experience using fare payment
Responses
you use and how often? systems onboard the bus and/
Airplane 2 or train?
Airport Shuttle 1 A. Do not have any problems 72
Amtrak 1 E. Cannot use fare payment systems
17
due to dexterity limitations
Drive Self 8
D. Cannot maneuver wheelchair/
Friend Drives Me 1
scooter around the fare payment 16
TOTAL 13 stand
Q7. What problems do you B. Cannot reach the card swipe 15
experience boarding the vehicles Yes
C. Cannot insert fare due to
you checked above? 11
obstructions
J. Lifts do not operate 44
Other 5
L. Lift has malfunctioned while in use 40
Q9. What problems do you experience
K. Operator says that the lift will not moving between the vehicle door and Responses
37
work/won’t use lift the securement area?
A. Do not have any problems 34 A. Do not have any problems 48
M. Operators/ drivers don’t allow B. There is not enough space to turn
27 44
enough space to approach the lift my wheelchair around
Other 27 E. I have to maneuver around
24
D. Ramps are too steep 26 luggage, bags and baby carriages
F. Ramps are slippery, my wheels C. The vehicle seats block the area 16
17
spin on the ramp when boarding Other 16
I. Ramps do you fold out properly 17 D. The seat belts get tangled in my
12
O. My casters get stuck in the space wheels
between the train platform and the 15
door of the train
N. Operators/ drivers/ gate agents do
not fold up seats to clear the space 14
for my wheelchair
C. Operators/drivers/gate agents do
12
not help me up/down boarding ramps
H. Ramp edges cause damage to my
10
casters / tires / push rims
B. Operators/drivers do not kneel the
8
vehicle
E. Ramps are too narrow for my
7
wheels
G. Ramp corners are too high, I
cannot roll over ramp corners onto 4
the ramp
Q10. When you board a public transit bus, how often is

Responses %
your wheelchair or scooter secured to the floor of the bus?
Never 14 14.0%
Less than half of the times I ride the bus 18 18.0%
More than half of the times I ride the bus 16 16.0%
All the time 45 45.0%
Other 7 7.0%
TOTAL 100
Q11. How is your wheelchair or scooter usually
Responses
secured or stabilized?
F. The frame of my wheelchair is secured with
73
floor tie-downs
C. I turn the power off 58
B. I put my wheelchair brakes (wheel lock) on 50
D. I use the seat (lap) belt 37
E. I use the shoulder belt in addition to the lap belt 34
A. It is not secured 12
Other 10
G. I use a rear facing containment area 5
Q12. Do you feel that your wheelchair or scooter is secure
Responses %
enough using the methods you checked above?
Yes 69 65.1%
No 37 34.9%
TOTAL 106
Q13. If your wheelchair or scooter is not secured,

Responses
what are some reasons why?
A. Operator/driver does not know how to secure my wheelchair properly 46
B. Operator/driver did not offer or seems unwilling to take the time 38
C. I prefer not to be secured 15
G. The equipment doesn’t fit me and/or my wheelchair very well (e.g.
15
armrests, seating system components get in the way)
E. I’m in a hurry and don’t want to take the time myself 8
F. I don’t trust the reliability of the securement and restraint belts 3
J. I don’t want the bus driver getting so close to me and my equipment 3
D. I use the postural belts that are attached to my wheelchair 2
H. I don’t feel that securing my wheelchair or putting on the seat belt is
2
very important
I. I feel that securing my wheelchair or putting on the seat belt is unsafe
2
for me
Q14. If you want your wheelchair or scooter secured, what are some
Responses
reasons why?
A. I feel that I will be more protected in the event of a crash 73
C. I feel that others around me are safer if my wheelchair is secured 64
B. I feel that I’m safer and more stable in regular bus travel 61
E. Transit provider/operator makes me have my mobility device secured 27
D. The occupant restraint system provides me with more
20
postural support
Other 4
Q15. When you ask for assistance in securing your wheelchair or
Responses %
scooter, how often does the operator/driver provide such assistance?
Always 60 57.1%
Sometimes 24 22.9%
Never 1 1.0%
I never ask 20 19.0%
TOTAL 105
Here, only 5 percent of responses state that the securement systems are “very difficult.”
Q17. How well do passenger safety belt systems in buses generally
Responses %
fit you?
Usually fit well and are comfortable 33 32.7%
Usually don’t fit me very well 29 28.7%
Don’t know 8 7.9%
Never use them 24 23.8%
Other 7 6.9%
TOTAL 101
Q18. Have you ever been in a bus, train, van, or taxi incident where
Responses %
your wheelchair or scooter moved too much or tipped over?
Yes 50 45.0%
No 61 55.0%
TOTAL 111
Q19. How would you describe operator/driver attitudes about
transporting people using wheelchair, scooters or other mobility Responses %
equipment?
Generally positive and willing to do whatever it takes to ensure that
42 38.5%
I’m as safe as possible
Positive and helpful if they aren’t in a hurry, but negative and
14 12.8%
unhelpful if they are in a hurry
Generally negative and uninformed about my safety and the safety
6 5.5%
of my mobility equipment
Varies greatly depending on who the operator/driver is 43 39.4%
Don’t Know 3 2.8%
Other 1 0.9%
TOTAL 109
Q20. How would you describe other passengers’ attitudes about the
Responses %
time it takes to be secured?
Generally patient and understanding 64 60.4%
Generally impatient 22 20.8%
Generally negative and uninformed about my safety and the safety
10 9.4%
of my mobility equipment
Don’t know 8 7.5%
Other 2 1.9%
TOTAL 106
Q21. Are you aware that transportation regulations in the Americans with
Disabilities Act (ADA) allow transportation providers to provide service to Responses %
wheelchairs only of a limited size or weight?
Yes 55 48.7%
No 58 51.3%
TOTAL 113
Q22. Are you aware that transportation regulations in the Americans
with Disabilities Act (ADA) require transit providers to offer securement
Responses %
of wheelchair and occupants, with equipment complying with standards
described in the ADA?
Yes 87 77.7%
No 25 22.3%
TOTAL 112
Q23. Are you aware that transportation regulations in the Americans with
Disabilities Act (ADA) allows transportation providers to make securement
of wheelchairs ‘mandatory’ for passengers, including the use of lap/
Responses %
shoulder belts in cases when everyone else on the vehicle is required
to wear them (it is optional on buses and trains where all seats are not
equipped with the belts)?
Yes 77 68.1%
No 36 31.9%
TOTAL 113
Q24. Are you aware that some wheelchair manufacturers now offer a
‘transit option’ consisting of permanent brackets or loops for the attachment Responses %
of vehicle tie-down equipment?
Yes 51 45.1%
No 62 54.9%
TOTAL 113
Q25. If you were purchasing a new wheelchair, would you be interested in
Responses %
getting this feature on your new wheelchair?
Yes 82 75.9%
No 26 24.1%
TOTAL 108
Q26. Please rank your most important information sources for information
about transportation safety and wheelchair/mobility device use. Rank the Responses Rank
following from 1 (most important) to 10 (least important).
Other wheelchair users 270 1
Disability/Advocacy organizations 278 2
Vendors (local durable medical equipment sales and service people) 360 3
Transit providers 434 4
Internet and Web sites 441 5
Healthcare professionals (doctors, therapists) 481 6
Vocational rehabilitation counselors 502 7
Magazines, catalogs and other print media 509 8
Health insurance or other sources of funding 584 9
TV and radio advertising 640 10
Other 25
Q27. Gender/Sex Responses %
Female 55 50.9%
Male 53 49.1%
TOTAL 108
Q28. Year of birth Responses %
65 and Up 10 9.4%
55 to 64 23 21.7%
45 to 54 34 32.1%
35 to 44 15 14.2%
25 to 34 18 17.0%
24 and under 6 5.7%
TOTAL 106
Appendix E: Summary Issues from the Perspective of Consumers

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

Almost all the 118 survey respondents (92 percent) were mobility device users, 6 percent were
family members and 2 percent provided personal assistance to mobility device users. Respondents
represented a mix of mobility device use. The two most common devices were power wheelchairs
(68 responses) and manual wheelchairs (67 responses), followed by scooter users (23 responses).
Further analysis indicated that 4 of 118 respondents used both a power and a manual wheelchair,
42 used only a manual wheelchair and 31 used only a power chair. Besides the majority of respondents
using multiple devices, we also found that the majority used both fixed-route and paratransit services.
Unfortunately due to the limited sample size and the need to limit the survey length, we were not able
to distinguish between the experiences of those who primarily use fixed-route or paratransit, or primarily
use manual or power chairs.
Respondents represented a mix of experience with mobility devices. Just over half (53 percent) of
manual wheelchair respondents reported using a manual wheelchair for more than 11 years. Just under
half of power chair respondents (48 percent) reported 11 years or more power chair use. Scooter users
were somewhat less experienced. The majority of scooter users (79 percent) reported using a scooter
for less than 11 years.
Respondents were almost evenly split between females (51 percent) and males (49 percent).
The following table reports age distribution for the sample (106 respondents provided date of birth
information).
Age Distribution of
Figure 1
Respondents
Age # of %
Category Respondents Percent
65 and Up 1 9
55 to 64 23 22
45 to 54 34 32
35 to 44 15 14
25 to 34 18 17
24 and Under 6 6
Totals 106 100*
* Sub-totals have been rounded up, resulting in more than 100 percent
The largest group of respondents was between the ages of 45 and 54. This sample most likely under-
represents elders (65+) and older adults with disabilities. The disproportionate presence of younger
persons with disabilities may be due in part to the use of a Web-based survey available online.
Appendix E: Summary Issues from the Perspective of Consumers 69
Key Findings
Transportation Service Usage

Survey respondents reported using a variety of public and private transportation services. Seventy-
nine respondents (79) reported utilizing ADA paratransit services, and 66 used fixed-route bus service.
Almost half of respondents used accessible taxis (49). Thirty-nine used medical/social services
transportation, 36 used rapid transit or commuter rail and 28 used light rail or streetcar.
For paratransit riders, 19 percent were daily riders, 20 percent rode weekly, 23 percent rode
and 38 percent rode less than once per month. A total of 76 respondents (65 percent) used some
form of fixed-route transportation (fixed-route buses, light rail/streetcar or rapid transit/commuter rail)
at least monthly.
Even in such a small sample size, it appears that mobility device users are taking advantage of a wide
variety of public and private transportation choices. This finding appears to reflect the trend of increased
transit ridership by wheeled mobility device users.
Boarding and Maneuvering
Seventeen percent of respondents indicated that they were not able to ride public and/or private
transportation services because their mobility device could not be accommodated. Some report being
denied because of a lack of space, but it is unclear from the small sample of comments whether their
mobility devices in fact could not fit in the available space or whether the driver simply stated “no, it is
over the regulatory limit.”
Reports of denials included vehicles that would not stop or that stopped, but would not pick up mobility
device users. One mobility device user reported being denied service because, “I have too many
packages.” Without extra details, it is difficult to determine whether this was or was not a legitimate
“denial”–there are bona fide limits on carrying packages in public transportation. On the other hand,
some drivers may use this as an excuse to avoid providing transportation to a wheelchair user, or be
uncertain about agency policies. Given the variety of reasons provided for refusing service to survey
respondents, more research and clarification seems warranted.
Respondents also encountered mechanical problems while boarding vehicles. Of those who reported
encountering mechanical problems, the most often reported boarding problems were:
• Lifts that did not operate (41 percent)
• Lifts that malfunctioned while in use (37 percent)
• Operators who appeared not to be able to operate lifts (34 percent)
Once on the vehicle, 41 percent of respondents reported that there was “not enough space to turn
the wheelchair around.” Respondents reported that this was a significant problem because lack of
space for turning required the device user to back onto the vehicle and/or into the space. Backing
up a wheeled mobility device is a very difficult task and respondents reported doing damage to their
mobility device while trying to back into a lift or wheelchair space.
Personal Accessories and Equipment
The survey responses also reinforced the fact that riders frequently carry a variety of personal items
during transit. Respondents were asked about the personal items, accessories and equipment that
they typically travel with when riding public and private transportation.
Eighty percent of respondents reported carrying a backpack, 51 percent carried grocery or shopping
bags, 41 percent carried a laptop computer or a briefcase and 29 percent carried luggage. Fewer
respondents reported carrying reaching tools (14 percent) or shopping carts/baskets (11 percent).
Five percent traveled with a service animal. One person reported traveling with portable oxygen.
Most respondents carried backpacks on the back of their mobility device. Shopping bags were
carried on the back (45 percent) or front (37 percent) or on the sides (15 percent) of the mobility
device. Laptops and briefcases were carried on the back (48 percent) and front (40 percent), or sides
(6 percent) or, in some cases, underneath (6 percent) the device. Mobility device users carried with
them a variety of personal accessories.
This finding provides some evidence of important usability information that needs to be considered
in the design of transportation systems and warrants further investigation and research.
For more than 25 percent of respondents, current wheelchair tie-downs and occupant restraint
systems (WTORS) caused problems with the mobility device and/or with the personal accessories
and equipment being carried. Some of the examples cited include: “driver secures the restraints on
movable parts of the wheelchair such as leg rests,” “restraints bend the wheelchair arms and seat
posts,” “my large lap tray creates problems with occupant restraints,” “straps get stuck between the
tires and the frame and have to be cut up,” “occupant restraint gets me in the neck.” These cited
problems also underscore the need for properly trained transit personnel, in this case, specific
training in the attachment of securements.
Securement Issues
Mobility device users on public transit are generally aware of their own safety and the safety
of passengers around them. Sixty-two percent of respondents wanted their device secured to
protect themselves in the event of a crash. Respondents reported varying degrees and combinations
of usage of wheelchair tie-down and occupant restraint systems (WTORS). A majority of respondents
(54 percent) stated that they secure their wheelchairs because they believe that this leads to
greater safety for other passengers. Even with this awareness of personal safety, only 45 percent of
respondents reported having their device secured to the floor on every bus ride. Fourteen percent of
bus riders never have their devices tied down.
Vehicle operator error was the most-reported reason for non-use of WTORS. Respondents reported
that operators didn’t know how to secure the mobility device or that the operator didn’t offer or seemed
unwilling to take the time to secure their device. It is important to note that about 20 percent of the
time respondents never ask operators to secure their device, primarily because of the potential for
embarrassment and the rider is in a hurry.
Support for WC19 and Informing Users of this Option
A significant finding of the survey was the overwhelming support respondents gave the ANSI/RESNA
“WC19” standard. The standard was described to respondents as a ‘transit option’consisting of
permanent brackets or loops on mobility aids for the attachment of vehicle tie-down equipment. Forty-
five percent of respondents reported being aware of WC19–equipped wheelchairs. Seventy-six percent
of respondents indicated they would obtain this feature with the purchase of a new wheeled mobility
device. Respondents were asked to rank their most important source of information about transportation
safety and mobility device use. Other wheelchair users were ranked as the most important source of
this information, followed by disability/advocacy organizations and vendors. This finding may suggest
that innovation permeates through the disability community differently than in other more traditional
consumer product markets. Mobility device manufacturers and transit providers might find it useful to
target peer-to-peer networks in the disability community to ‘get the word out’about new and innovative
products and standards.
Appendix E: Summary Issues from the Perspective of Consumers 71
Training
Several training needs emerged from analysis of survey data. Survey respondents linked non-use of
WTORS to lack of competency of vehicle operators who don’t know how to secure their device or who
are unwilling to do so. Sometimes operators wouldn’t secure a wheelchair even when the rider asked
to be secured. Moreover, 39 percent of respondents indicated that the attitudes of vehicle operators
toward transporting mobility device users varied greatly, which reflects a broader problem with driver
training that has a particular impact on riders with disabilities. The issue of adequacy of training is a
complex problem and requires content input from a variety of experts. Not only do operators need the
skills to safely deploy lifts and WTORS, they also need to understand why this is important. It appears
that vehicle operators would benefit from competency-based training that is designed to improve
attitudes and knowledge as well as provide proficiency in required skills.
Survey Conclusions
The survey documented three areas of significant issues and problems from the consumers’perspective:
1) Boarding and maneuvering problems
2) Problems with mobility device securement and occupant restraint
3) Training issues and needs
Survey results indicated broad acceptance of recently developed securement standards that included
attachment points on mobility devices, known as the ANSI/RESNA WC19 “Transit Option.” Establishing
peer-to-peer networks within the disability community is an important means of promulgating information
about transit options.
The ‘common wheelchair’envelope may need to be revisited to understand how variations from it affect
wheelchair users’ability to ride transit vehicles, and what other approaches may be useful. These
approaches could include better defining the needed space within vehicles, and possibly increasing
the minimum size and/or weight requirements for mobility aid accommodations. When revisions are
explored in response to the current request for comments from the Access Board, they should take into
account the maneuverability of various devices.
Finally, survey results seem to indicate that for the purpose of transportation system design,
anthropometric measures of mobility device users should incorporate measures not only of the person
and the device, but appropriate elements of the context of use, specifically what users are carrying
during typical rides.
Appendix F: Links to Relevant Regulatory Sources
Federal Transit Administration ADA Web pages:

http://www.fta.dot.gov/civilrights/civil_rights_236 .html
You are here: Home →Civil Rights & Accessibility → Americans with Disabilities Act
Americans with Disabilities Act
The Americans with Disabilities Act of 1990 (ADA) prohibits discrimination and ensures equal
opportunity and access for persons with disabilities.
The Federal Transit Administration works to ensure nondiscriminatory transportation in support of our
mission to enhance the social and economic quality of life for all Americans. The FTA Office of Civil
Rights is responsible for civil rights compliance and monitoring to ensure non-discriminatory provision of
transit services.
ADA Technical Assistance
• DOT Disability Law Guidance
• FTA Bulletins
• Toll-Free Assistance Line
• File an ADA Complaint with FTA
• National Transit Institute (NTI) ADA Course Offerings
• Transit Cooperative Research Program (TCRP) Synthesis Projects
• Federal Highway Administration (FHWA) Guidance on Pedestrian Access for Persons with Disabilities
• FTA ADA Compliance
• ADA Compliance Review Final Reports (NOTE–there is extensive discussion of lift maintenance
in these reports)
• Letters of Finding According to Regulatory Section
• Memorandum of Understanding with the U.S. Department of Justice
• Results of Recent Collaboration with U.S. Department of Justice: City of Detroit Settlement Order
• ADA Links
Appendix F: Links to Relevant Regulatory Sources 73
Easter Seals Project ACTION

• DisabilityInfo.gov
• U.S. Department of Justice ADA Home Page
• Access for Persons With Disabilities
• ADA Regulations, Guidance, and Procedures
• The Americans with Disabilities Act of 19900
• Preamble—Transportation for Individuals with Disabilities [September 6, 1991]
• Part 27—Nondiscrimination on the Basis of Disability in Programs and Activities Receiving or
Benefiting From Federal Financial Assistance
• Part 37—Transportation Services for Individuals with Disabilities
• Final Rule Adopting New Accessibility Standards—Effective November 29, 2006
• Americans with Disabilities Act Accessibility Guidelines (ADAAG)
• Part 38—Accessibility Specifications for Transportation Vehicles
• Americans with Disabilities Act—Full Regulatory History
——————————————————-
[Code of Federal Regulations] [Title 49, Volume 1] [Revised as of October 1, 2005] [CITE:
49CFR37]
TITLE 49—TRANSPORTATION
Subtitle A—Office of the Secretary of Transportation
PART 37_TRANSPORTATION SERVICES FOR INDIVIDUALS WITH DISABILITIES (ADA)
Appendix G: Samples of Informational Brochures Get Hooked on VTA

and Ride Safe Brochure (following pages)
Get Hooked on VTA! Effective January 1, 2007

To Reach Us...
nt
VTA’s securement policy is mandatory, Trained VTA employees will: To schedule an appointment to
me
but the option to have mobility devices • Examine the mobility device to mark and tether mobility devices
ure
marked and/or have tethers installed is call VTA’s Accessible Services
r
determine the best four points for
Sec nts fo
voluntary. Passengers are encouraged to securement. Department at (408) 952-4249.
take advantage of this program so that
• Affix colored tape to the best For trip planning or other route information, contact:
e w e
N irem ices
coach operators and/or attendants can
quickly identify where to attach secure- securement points on the mobility VTA Customer Service Call Center . . . . . (408) 321-2300
qu ev
ment hooks. device. From 650 area code and
Re lity D
South Santa Clara County toll area . . . (800) 894-9908
Yellow Tape indicates where secure-
bi
Marking mobility devices involves apply-
• Listen to recorded route and schedule information
Mo
ing removable colored vinyl tape on ment hooks will be attached.
- 24 hours a day
areas where hooks can easily be
Blue Tape indicates where tethers will - English, Spanish and Vietnamese
attached and tethers for hooks can be
easily installed. be placed. • Speak with an Information Service Representative
- Weekdays: 6 a.m. – 7 p.m.
- Saturday: 7:30 a.m. – 4 p.m.
We’re Coming to Your Practice Boarding at Hearing Impaired (TDD only) . . . . . . . (408) 321-2330
Neighborhood! your Leisure! VTA Website . . . . . . . . . . . . . . . . . . www.vta.org
Passengers with mobility devices can Passengers with mobility devices who VTA Downtown Customer Service Center
drop-in to pre-designated sites to have have never used the bus or have not 2 N. First St., San Jose, CA 95113
their mobility devices pre-marked for used it in a while will now have the Weekdays: 9 a.m. – 6 p.m.
securement. Please call VTA’s Accessible opportunity to practice maneuvering Closed weekends and most holidays
Services department at (408) 952-4249, on and off a coach. To schedule an VTA River Oaks Administrative Offices
or TDD only at (408) 321-2330. appointment call VTA’s Accessible 3331 N. First St., San Jose, CA 95134
Services department. Weekdays: 8 a.m. – 4:30 p.m.
Closed weekends Rehabilitation Engineering Research Center
Your safety is our priority! on Wheelchair Transportation Safety
Upon request, this brochure is available ON VTA BUSES ONLY
in an accessible format: large print, University of Michigan
Braille or audio tape. Health System
University of Michigan
Transportation Research Institute
Initially funded through a grant from the FRIENDS

of the University of Michigan Hospitals
2005
Get Hooked on VTA! Effective January 1, 2007
To Reach Us...
VTA’s securement policy is mandatory, Trained VTA employees will: To schedule an appointment to
nt
but the option to have mobility devices • Examine the mobility device to mark and tether mobility devices
m e
marked and/or have tethers installed is determine the best four points for call VTA’s Accessible Services
ur e r
voluntary. Passengers are encouraged to securement. Department at (408) 952-4249.
Se c fo
take advantage of this program so that
w n ts
Ne ireme ices
coach operators and/or attendants can • Affix colored tape to the best For trip planning or other route information, contact:
quickly identify where to attach secure- securement points on the mobility VTA Customer Service Call Center . . . . . (408) 321-2300
ment hooks. device. From 650 area code and
qu ev
Re lity D
South Santa Clara County toll area . . . (800) 894-9908
Yellow Tape indicates where secure-
bi
Marking mobility devices involves apply-
• Listen to recorded route and schedule information
o
ing removable colored vinyl tape on ment hooks will be attached.
M
- 24 hours a day
areas where hooks can easily be
Blue Tape indicates where tethers will - English, Spanish and Vietnamese
attached and tethers for hooks can be
easily installed. be placed. • Speak with an Information Service Representative
- Weekdays: 6 a.m. – 7 p.m.
- Saturday: 7:30 a.m. – 4 p.m.
We’re Coming to Your Practice Boarding at Hearing Impaired (TDD only) . . . . . . . (408) 321-2330
Neighborhood! your Leisure! VTA Website . . . . . . . . . . . . . . . . . . www.vta.org
Passengers with mobility devices can Passengers with mobility devices who VTA Downtown Customer Service Center
drop-in to pre-designated sites to have have never used the bus or have not 2 N. First St., San Jose, CA 95113
their mobility devices pre-marked for used it in a while will now have the Weekdays: 9 a.m. – 6 p.m.
securement. Please call VTA’s Accessible opportunity to practice maneuvering Closed weekends and most holidays
Services department at (408) 952-4249, on and off a coach. To schedule an VTA River Oaks Administrative Offices
or TDD only at (408) 321-2330. appointment call VTA’s Accessible 3331 N. First St., San Jose, CA 95134
Services department. Weekdays: 8 a.m. – 4:30 p.m.
Closed weekends
Your safety is our priority!
Upon request, this brochure is available ON VTA BUSES ONLY
in an accessible format: large print,
Braille or audio tape.
06/08-5639
more than 600 pounds when occupied.
New Securement Requirements for Mobility Devices on VTA Buses Other types of mobility devices that
meet the specifications of a common
Effective January 1, 2007, all How does the securement wheelchair must be treated as common
mobility devices must be secured on equipment work?
Get the Facts! wheelchairs.
VTA buses. VTA uses a four-point securement system Is it a violation of the ADA to
Please take a few minutes to read this for mobility devices on all buses. This require a passenger’s mobility
brochure to learn about the new secure- means that a mobility device must be device to be secured?
ment policy and the mobility device secured with two hooks in the front and No. In accordance with Federal Transit
marking and tether strap program. two hooks in the back. The hooks are Administration regulations, transit agen-
connected to straps that are attached to cies can require mobility devices to be
the floor of the bus. The securement sys- secured as long as the agency has
What to Expect tem is self-tightening to prevent any slack established such a policy.
in the straps which will keep the mobility
Passengers’ mobility devices must be device stationary.
secured every time they ride a VTA bus. What is the ADA requirement for
Bus operators are responsible for ensur- mobility device securement?
Will passengers be late to where
Transit vehicles are built in accordance A service animal or guide dog can accompany
ing that mobility devices are properly they want to go? a person with a disability on a VTA bus.
secured, even if the passengers’ atten- with the guidelines of the Americans with
dant secures the device. No. Passenger safety is our first priority. Disabilities Act of 1990 (ADA). Ramps,
VTA coach operators have been trained lifts and mobility device spaces are Guide dogs or service animals on
to secure mobility devices safely, effec- designed to accommodate a “common VTA buses and light rail
tively, and quickly to prevent schedule wheelchair.” Service animals (and animals in training)
delay. Passengers can contact VTA to are permitted to ride onboard VTA buses
have their mobility devices marked A “common wheelchair” is defined as and light rail. Service animals are spe-
and/or have tethers installed, making a mobility aid belonging to any class of cially trained animals that assist persons
securing the mobility device even quicker. three or four-wheeled devices, usable with disabilities. Service animals must be
indoors, designed for and used by within the care, custody and control of
Each bus operator must secure mobility devices, What if the mobility device individuals with mobility impairments, their owners. This means that the animal
or verify proper securement (secured to the floor)
cannot be secured? whether operated manually or powered. is properly restrained by leash, harness
if performed by a passenger or attendant.
or carrier and is not roaming the coach
Operators will make every effort to
A “common wheelchair” does not and barking or growling.
VTA also recommends, but does not secure mobility devices but if devices
cannot be secured, passengers will be exceed 30 inches in width and
require, the use of lap belts and shoulder
allowed to travel to their final 48 inches in length measured two inches
harnesses.
destinations. above the ground, and does not weigh
Rehabilitation Engineering Research Center
on Wheelchair Transportation Safety
Health System
Transportation Research Institute
Initially funded through a grant from the FRIENDS

of the University of Michigan Hospitals
2005
!!!
When traveling in a motor vehicle, it is generally safest for wheelchair users
to transfer to a vehicle seat and use the vehicle seatbelt system or a child safety seat that
complies with federal safety standards. The wheelchair should then be stored and secured in the vehicle.
If transferring is not feasible, it is very important to secure the wheelchair to the vehicle facing forward
and to use crash-tested seatbelts for the wheelchair-seated rider.
1 START WITH THE RIGHT EQUIPMENT

The Wheelchair
! It is best if you have a wheelchair that has been designed and
tested for use as a seat in motor vehicles, often referred to as a WC19
wheelchair or a transit wheelchair. These wheelchairs comply with
ANSI/RESNA WC19, a voluntary standard developed by safety and
rehabilitation experts. Wheelchairs that meet the design and
performance requirements of this standard will be labeled to show
that they comply with WC19.
! Most importantly, a WC19 wheelchair

has four, crash-tested securement points
where tiedown straps and hooks can be
easily attached. These points are clearly
marked with a hook symbol.
! If a WC19 wheelchair is not available,

the next best choice is a wheelchair with an
accessible metal frame where tiedown straps
and hooks can be attached at frame
junctions.
The Wheelchair Tiedown and

Occupant Restraint System (WTORS)
! It is important to use a complete WTORS to secure

the wheelchair and provide the wheelchair occupant
with a properly designed and tested seatbelt system.
! Always use a WTORS that has been crash

tested and labeled as complying with SAE J2249,
a voluntary standard developed by safety and
rehabilitation experts. The most common type of
wheelchair tiedown uses four straps to secure the
wheelchair to the vehicle. Although it requires someone
other than the wheelchair rider to secure and release
the wheelchair, this tiedown can secure a wide range of
WC19 and non-WC19 wheelchairs.
! To protect the rider during a crash or sudden

braking, and to minimize the likelihood of injury caused
by contact with the vehicle, a seatbelt system with both
pelvic and upper torso belts must be used.
!!!
2 SECURE THE WHEELCHAIR
Four-Point Tiedowns
! Always position the wheelchair and rider facing forward in the vehicle.
! When securing a WC19 wheelchair, attach the four tiedown straps to the securement points
provided on the wheelchair. Tighten the straps to remove all slack.
! If you do not have a WC19 wheelchair, it is best to attach

the tiedown straps to welded junctions of the wheelchair frame
or to other structural areas where the frame is fastened together
with hardened steel bolts indicated by six raised lines or bumps
on the bolt head.
! Do not attach tiedowns to adjustable, moving, or removable parts of

the wheelchair such as armrests, footrests, and wheels.
! When securing non-WC19 wheelchairs,

choose structural securement points as close to the seat surface as
possible to provide greater wheelchair stability during travel. It is best
if the rear securement points are high enough to result in angles of the
rear tiedown straps between 30 and 45 degrees to the horizontal.
! If you have a non-WC19 wheelchair with a tilt seat, make sure to

attach both the front and rear straps to either the seat frame or to the
base frame. Mixing wheelchair securement points between the seat
and base can result in the tiedown straps becoming slack if the angle
of the seat changes during a crash.
! It is best if floor anchor points for rear tiedown straps are located
directly behind the rear securement points on the wheelchair. If
possible, the front tiedown straps should anchor to the floor at points
that are spaced wider than the wheelchair to increase lateral stability
during travel.
Other Methods of Wheelchair Securement
! In addition to securing wheelchairs using a four-point

tiedown, wheelchairs can also be secured using a docking
tiedown device. This method is primarily used in private vehicles
since it requires the addition of adaptor hardware to the
wheelchair frame that will engage with the docking tiedown
device in the vehicle. Docking securement devices allow the
wheelchair rider to secure and release the wheelchair without
assistance.
! If you plan to secure your wheelchair with a docking

tiedown device, you should check with the WTORS or
wheelchair manufacturer to ensure that your wheelchair model has been successfully crash tested with
their system.
! Clamp-type securement devices are not recommended since they do not provide effective
wheelchair securement in frontal crash testing.
!!!
3 PROTECT THE WHEELCHAIR RIDER
! In addition to securing the wheelchair, it is very important to provide effective restraint for the
wheelchair user with a crash-tested lap and shoulder belt or with a child restraint harness.
Postural support belts attached to the wheelchair are not strong enough to withstand the forces of a
crash and are usually not positioned correctly to restrain the occupant safely in a crash.
! The lap belt should be placed low across the front of the pelvis
near the upper thighs, not high over the abdomen. When possible, the
lap belt should be angled between 45 and 75 degrees to the horizontal
when viewed from the side. Some wheelchair features, like armrests,
can interfere with good belt fit. To avoid placing the lap belt over the
armrest and to keep the lap belt low on the pelvis, it may be necessary
to insert the belt between the armrest and the seatback, or through an
opening under the armrest.
! A diagonal shoulder belt should

cross the middle of the shoulder and the center of the chest, and
should connect to the lap belt near the hip of the wheelchair rider.
The upper shoulder-belt anchor point or
D-ring guide should be anchored above and behind the top of the
occupant’s shoulder, so that the belt is in good contact with the
shoulder and chest while traveling.
! Newer WC19 wheelchairs offer the option of a crash-tested lap

belt that is anchored to the wheelchair frame. If the wheelchair has
an onboard crash-tested lapbelt, complete the belt system by
attaching the lower end of a shoulder belt to the lap belt. Crash-
tested wheelchair-anchored lap belts will be labeled to indicate that
they comply with with ANSI/RESNA WC19.
Other Important Points

" Read and follow all manufacturers’ instructions.
" It is best to ride with the wheelchair backrest positioned at an angle of 30 degrees or less to the vertical.
If a greater recline angle is needed, the shoulder belt anchor point should be moved rearward along the
vehicle sidewall so the belt maintains contact with the rider’s shoulder and chest.
" Maximize the clear space around the rider to reduce the possibility of contact with vehicle components and
other passengers in a crash. Cover vehicle components that are close to the rider with dense padding.
" Check WTORS equipment regularly and replace worn or broken components. Keep anchorage track free
of dirt and debris.
" If a WTORS and wheelchair have been involved in a vehicle crash, check with the manufacturers to
determine if the equipment needs to be repaired or replaced.
" If possible, remove hard trays and secure them elsewhere in the vehicle to reduce the chance of rider injury
from contact with the tray. Consider the use of foam trays instead of rigid trays during transit. If it is not
possible to remove a hard tray, place dense padding between the rider and the tray and make sure that the
tray is securely attached to the wheelchair so it will not break loose and cause injury to other occupants in
a crash.
" A properly positioned headrest can help protect the neck in a rear impact.
" If it is necessary to use a head and neck support during travel, soft neck collars are safer than stiff collars
or head straps which could cause neck injury in a crash. The soft collar should not be attached to the
seating system.
" Secure medical and other equipment to the wheelchair or vehicle to prevent it from breaking loose and
causing injuries in a crash.
!!!
RESOURCES
Organizations
Rehabilitation Engineering and Research Center on RESNA Rehabilitation Engineering Society of North
Wheelchair Transportation Safety America
www.rercwts.pitt.edu www.resna.org
University of Michigan Transportation Research Institute National Highway Traffic Safety Administration
www.umtri.umich.edu www.nhtsa.dot.gov
University of Pittsburgh National Mobility Equipment Dealer’s Association
www.wheelchairnet.org www.nmeda.org
Society of Automotive Engineers The Association for Driver Rehabilitation Specialists
www.sae.org www.driver-ed.org
A Helpful Publication
School Bus Transportation of Students in Wheelchairs
A manual of procedures and practices used by the Washtenaw Intermediate School District for providing effective
wheelchair securement and occupant restraint.
Washtenaw Intermediate School District
734-994-8100
www.wash.k12.mi.us
Wheelchair Manufacturers
(Ask for Frames and/or Seating Products that Comply with WC19)
Convaid Otto Bock
www.convaid.com; 800-266-8243 www.ottobock.com; 800-328-4058
Freedom Designs Permobil
www.freedomdesigns.com; 800-331-8551 www.permobil.com; 800-736-0925
GOVAN + wheelchair and docking system Pride Mobility
www.smd-abitech.com; 204-975-3004 www.pridemobility.com; 800-800-8586
Invacare Sammons Preston
www.invacare.com; 800-333-6900 www.sammonspreston.com; 800-323-5547
Mulholland Postioning Systems Sunrise Medical
www.mulhollandinc.com; 800-543-4769 www.sunrisemedicalonline.com; 800-333-4000
Wheelchair Seating Manufacturers

(Ask for Products that have been Tested to WC19)
Adaptive Engineering Lab Adaptive Equipment Systems
www.aelseating.com; 800-327-6080 www.aesys.com; 800-237-2370
Wheelchair Tiedown and Occupant Restraint Manufacturers

(Ask for Products that Comply with SAE J2249)
Creative Controls Q’Straint
www.creativecontrolsinc.com; 800-539-7237 www.qstraint.com; 800-987-9987
EZ-Lock SureLok
www.ezlock.net; 225-214-4620 www.sure-lok.com; 866-787-3565
Orthosafe
www.orthosafe.com; 609-587-9444
!!!
GLOSSARY OF TERMS
Anchor point: The location on a vehicle, wheelchair, or wheelchair tiedown where a belt-restraint or
wheelchair-tiedown anchorage is attached.
ANSI-RESNA WC19 (officially, SECTION 19 ANSI/RESNA WC/VOL. 1 Wheelchairs for use in Motor
Vehicles): A voluntary standard for wheelchairs designed for use when traveling facing forward in a
motor vehicle. NOTE: ISO 7176/19 is an international transit wheelchair standard that specifies similar
design and performance requirements as ANSI/RESNA WC19.
Belt: A length of energy-absorbing webbing material used in occupant restraint systems.
Docking tiedown: A method for securing wheelchairs where portions of the wheelchair frame, or add-on
components fastened to the wheelchair frame, engage with a securement device anchored to the
vehicle.
Four-point strap-type tiedown: A method for securing a wheelchair where four straps are attached to
the wheelchair at four separate securement points and attached to the vehicle at four separate anchor
points.
Occupant restraint: A system or device designed to restrain a motor vehicle occupant in a crash by
keeping the occupant in the vehicle seat and minimizing contact with the vehicle interior, other
occupants, or objects outside the vehicle.
Postural support: A padded component and/or belt used to help maintain a person in a desired position
during normal wheelchair use. In general postural supports are not designed to provide effective
occupant restraint in a motor vehicle crash.
SAE Recommended Practice J2249 (officially, SAE J2249 Wheelchair Tiedowns and Occupant
Restraints for Use in Motor Vehicles): A Society of Automotive Engineers Recommended Practice that
specifies design and performance requirements for wheelchair tiedown and occupant restraint systems.
NOTE: ISO 10542 is an international WTORS standard that specifies comparable design and
performance requirements as SAE J2249.
Securement points: Specific structural points on the wheelchair base or seat frame that are designed
for attachment of wheelchair tiedowns.
Strap: A length of webbing material used in wheelchair tiedown systems.
WC19 wheelchair: A crash-tested wheelchair with four clearly identified securement points that meets
the design and performance requirements of ANSI-RESNA WC19 Wheelchairs Used as Seats in Motor
Vehicles, and is sometimes called a transit wheelchair.
Wheelchair tiedown and occupant-restraint system (WTORS): A complete system for use by
wheelchair-seated occupants comprised of a system or device for securing the wheelchair and a belt-
type restraint system for limiting occupant movement in a motor vehicle crash.
Regents of the University of Michigan

David A. Brandon, Ann Arbor; Laurence B. Deitch, Bingham Farms; Olivia P. Maynard, Goodrich; Rebecca McGowan, Ann Arbor; Andrea Fischer
Newman, Ann Arbor; Andrew C. Richner, Grosse Pointe Park; S. Martin Taylor, Grosse Pointe Farms; Katherine E. White, Ann Arbor; Mary Sue
Coleman (ex officio)
The University of Michigan, as an equal opportunity/affirmative action employer, complies with all applicable federal and state laws regarding
nondiscrimination and aff i r m a t i v e action, including Title IX of the Education Amendments of 1972 and Section 504 of the Rehabilitation Act of
1973. The University of Michigan is committed to a policy of nondiscrimination and equal opportunity for all persons regardless of race, sex,
color, religion, creed, national origin or ancestry, age, marital status, sexual orientation, disability, or Vietnam-era veteran status in employment,
educational programs and activities, and admissions. Inquiries or complaints may be addressed to the University's Director of A ffirmative Action
and Title IX/Section 504 Coordinator, at the Office of Multicultural Community, 2072 Administrative Services Building, Ann Arbor, Michigan
48109-1432, 734-763-0235, T T Y 734-647-1388. For other University of Michigan information, call 734-764-1817.
%ASTER3EALS Easter Seals Project ACTION
1425 K Street, NW Suite 200
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Status Report on the Use of

Wheelchairs and Other Mobility Devices

%ASTER3EALS Easter Seals Project ACTION

Washington, D.C. 20005

Easter Seals Project ACTION

Prepared for Easter Seals Project ACTION by Nelson/Nygaard Consulting Associates

Project Advisory Committee

How to use this document

Issue area Issues Recommendations

Issue area Issues Recommendations

Issue area Issues Recommendations

About the Study

Power Wheelchair (rear wheel drive) 3-wheeled scooter 4-wheeled scooter

Segway Power Wheelchair (mid wheel drive)

Description of the Issues

Description of the Issues

Space and Maneuvering on Board Vehicles

Lift and Ramp Boarding

For the industry:

Description of the Issues

Description of the Issues

Non-Wheelchair Mobility Aids

Other Items Carried with Mobility Devices

For wheelchair users:

Description of the Issues

Description of the Issues

Example of a mobility device that is difficult to secure.

Transit Personnel Proficiency and Awareness

Training standards and monitoring of service performance

Transit System Policy Statements and Educational Information

Training Program Elements

Transit System Performance Monitoring

For Public Transportation Providers

Description of the Issues

Description of the Issues

Progress in Making “Transit-safe” Wheelchairs Available

Most transit providers and some vehicle and equipment manufacturers

Elements of Federal Guidance

Research and Development to Support Industry-Wide

Education and dissemination of available resources

For the industry:

Appendix A: Project Methodology

Appendix A: Project Methodology

Figure A 1: Stakeholder Interview Participants

Survey Deployment and Recruitment

Appendix B: Annotated List of Documents Reviewed

1. AC Transit Wheelchair Marking and Tether Strap Program

4. Carriage of Mobility Scooters on Public Transport—Feasibility Study

9. Oversized/Overweight Mobility Aids: Status of the Issue

12. Progress in Wheelchair Securement: Ten Years After the Americans

17. Securement of Wheelchairs and Other Mobility Aids on Transit Vehicles

19. Synthesis of Securement Device Options and Strategies

23. Tri-Wheeled Scooters Transported on Buses and Vans: Assessment of Securement

25. Wheelchair Access: Improvements, Standards, and Challenges

Appendix C: Survey Tool

Experience of Wheelchair Users on Public Transportation Survey

Your responses will be kept completely confidential: no information

Questionnaire for Mobility Device Users of Public Transit

Q1. What is your relationship to the mobility device user?

Where do you carry the items?

❑ No, if no, why? __________________________________________________________________

Please email me a summary of the report from this survey.

Appendix D: Statistical Results of Survey