Strollers, Carts, and Other Large Items on Buses and Trains (2011)

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16 CHAPTER THREE WHEELCHAIRS LITERATURE REVIEW ON WHEELCHAIRS AND WHEELCHAIR ACCOMMODATION POLICIES Of the large items that buses and trains carry in the United States, wheelchairs have the clearest and most universal guidelines for accommodation on vehicles. The U.S. govern- ment has codified specific measurements for all components of various public transport vehicles in conjunction with requirements resulting from passage of the Americans with Disabilities Act (ADA) of 1990 (Code of Federal Regulations 2007). In Canada, policies are established in some cases by provincial governments or in transit system bylaws. Transit agencies continue to struggle with many issues related to wheelchair sizes and securements. A comprehen- sive overview of these issues is found in the 2008 document prepared for Easter Seals Project ACTION, Status Report on the Use of Wheelchairs and Other Mobility Devices on Pub- lic and Private Transportation. Table 4 from the Executive Summary gives a snapshot of the issues (Nelson\Nygaard Consulting Associates 2008). The difficulty of nonstandard securements is echoed in the report “A Universal Securement/Restraint System for Wheeled Mobility Aids on Public Transportation Vehi- cles—The Oregon State University Securement System.” This report documents the steps taken to develop a standard “mobility aid securement system” that met a lengthy set of design objectives. The standard requires a mobility aid in the “forward-facing position” and “is made up of two major parts: a capture mechanism which is mounted to the floor of the transit vehicle and an interface unit (trailer hitch) attached to the back of the mobility aid.” The 2003 update notes that the Oregon State University standard is not being manufactured, but is still in use in Anchorage, Alaska. Of importance is the acknowledgment that “a major challenge in using this system is that the product requires a standard interface and manufacturers aren’t producing mobility aids with this standard interface” (Hunter-Zaworski 2003). Another document, Discussion Paper: Characteristics of Accessible Bus Rapid Transit, addresses accessibility issues from physical, operational, and system performance perspec- tives specifically related to BRT (2010). A focus on intelligent transportation systems (ITS) applications in BRT notes that vehicle assist and automation technologies (VAA)—preci- sion docking and vehicle guidance—could render BRT trips smoother and more secure for wheelchair users. The authors of a TCRP Synthesis examine rear-facing securements and note that “[t]he benefits associated with this approach make it par- ticularly attractive for [BRT] systems, given the short dwell times and other needs of high capacity services” (Rutenberg and Hemily 2003). The World Bank has also produced a report on this topic citing practices worldwide for accessible BRT systems, and recommends that a “cutout of a plan view of a reference wheelchair, to scale with a plan of the bus interior and adjacent stop, should be used to assure an accessible travel path into the bus and then into the securement area.” The report suggests that “securement areas must be longer than the refer- ence wheelchair to allow for turning motions as the wheelchair is positioned in the securement area” (Rickert 2006). Compounding the securement and maneuverability issues is the issue that Americans are becoming bigger and so are their wheelchairs. The U.S.DOT defines the “common wheel- chair” as any class of mobility aid “of three or four-wheeled devices” that 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” (Questions and Answers Concerning Common Wheelchairs and Public Transit 2010). However, more overweight Amer- icans will lead to an increased use of larger mobility aids, which will challenge existing ADA specifications and regula- tions. The report Oversized/Overweight Mobility Aids: Status of the Issue notes that some transit agencies have begun to install larger-capacity lifts, and raises questions over intrave- hicle maneuverability (Pass and Thompson 2004). Typically, rail cars feature smoother rides than buses, have easy access and egress, and do not have wheelchair secure- ments. Instead, the issues with rail include maneuverability in the cars and level boarding access. Rail Transit Capac- ity provides a comprehensive overview, noting calculation methods and synthesizing standards and practices across a variety of transit agencies. The report states, However, it is not the size of the chair that is a concern as much as the maneuvering and stowage space. Typically a chair occupies the space of a double seat whose seat squab folds up. Restraints and seat belts may be provided but the smoothness of the ride allows most rail transit systems to omit these. In certain vehicle layouts additional seats have to be removed to allow access to the designated wheelchair location.

17 An example of retrofitting existing vehicles to create level boarding for wheelchairs is the Dallas Area Rapid Transit (DART) car refurbishment and rebuilding project, designed to coincide with the progressive opening of the new Green Line from late 2009 to late 2010. Super Light Rail Vehicles are being created by inserting new low-floor center sections at the articulation joints of the 115 existing Light Rail Vehicles. These new spaces will be level with newly-raised platforms (DART 2010). Unlike the United States, many other countries do not have legislated requirements to accommodate wheelchairs In optimum designs wheelchair space occupancy should be assigned as the space of a double seat—0.8 m2 (8.6 sq ft) with a 50% increase considered as an upper limit— 1.2 m2 (13 sq ft). No further allowance is necessary for maneuvering space as this will be occupied by standing passengers when circumstances dictate. In several rail transit vehicle designs, capacity has actually increased with the removal of seats to provide a designated space for wheelchairs, or, selectively, bicycles. Where the designated space does not involve a fold-up seat the empty space is frequently used by standing passengers or to store baggage, baby strollers etc. Providing locations to store such potential obstacles away from doorways and circulation areas can assist in reducing dwell times (Parkinson and Fisher 1996). TABLE 4 FINDINGS FROM STATUS REPORT ON THE USE OF WHEELCHAIRS AND OTHER MOBILITY DEVICES ON PUBLIC AND PRIVATE TRANSPORTATION Issue area Issues Recommendations Transit Vehicle and Equip- ment Design Space and maneuvering on board vehicles—constrained spaces Lift and ramp boarding—steep angles and reliability For manufacturers and mobility-related industries: • Develop industry standards or guidelines for wheelchair space layouts, aisle clearances, placement of securement equipment, etc.; to be used by both vehicle purchasers and manufacturers/designers • Increase development and “real-world” (in transit service environment) demonstration of new technologies For transit providers: • Encourage standardized wheelchair securement equipment by retrofitting older vehicles with updated equipment, and increase or improve maintenance programs for older wheelchair lifts • Routinely involve advisory committee members and drivers in the selection of new and replacement vehicles Wheelchair Design, Pur- chasing, Usage, and Prescription Oversized wheelchairs—increasing number of chairs that do not fit into minimum ADA vehicle standards Non-wheelchair mobility aids—Seg- ways, strollers Other items carried with mobility devices— oxygen, large backpacks For wheelchair users: • Learn about the dimensions established for wheelchair space aboard transit vehicles For vendors and prescribers: • Be cognizant of the dimensions established for wheelchair space aboard transit vehicles, clearly including this aspect in dealings with wheelchair users For wheelchair manufacturers: • Develop guidelines for manufacturers to use in making information about “transit friendliness” of mobility devices accessible and available to prospective purchasers Transit Operations and Training Securement issues— customer pref- erences, variety of devices, secure- ment policies, ergonomics, time Transit personnel proficiency and awareness—sensitivity, securement skills Training standards and monitoring of service performance— inconsistent, little direct monitoring For the industry: • Development of a “template” type of document that can be used by transit systems to educate customers of accessibility features and more • Development and dissemination of model training program elements • Development of “best-practice” policies and guidelines for accommodating Segways and other nontraditional 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-compliant wheelchairs available—limited out- reach to users Education and dissemi- nation of available resources—lim- ited and inconsistent For the industry: • Additional research: • Examination of barriers to making WC19-compliant mobility devices available to transit users • Activities: • Development of guidelines for transit providers on how/why to choose “mandatory” vs. “optional” rider choice policy for securement • Increased coordination of various regulations that affect mobility device accessibility and design

18 As shown in Figure 4, responses were generally split between agencies that considered wheelchairs to be either not an issue or somewhat of an issue (both 33%). The median response among both medium and large agencies was “somewhat important”; the median response of small agencies was that boarding a vehicle with a wheelchair was an “unimportant/minor issue.” FIGURE 4 Indicate whether bringing a wheelchair on your vehicles is considered an issue/concern/challenge for your agency. Of the agencies that indicated wheelchairs are a very important or somewhat important concern, 14 (61%) noted that the delay incurred by the boarding and alighting of wheelchairs onto transit vehicles was a concern (Figure 5). Generally, respondents are also concerned with the limited capacity to accommodate wheelchairs and problems associ- ated with this inadequate capacity—such as the safety of the disabled passenger, the inability of the vehicle to pick up the rider when at capacity, and passenger crowding. FIGURE 5 If you indicated that wheelchairs are a very important or somewhat important concern, why is it a concern for your agency? Specific comments revealed other, non-vehicle-based complexities that affect a transit agency’s ability to success- fully handle wheelchair-bound passengers. Even in a large metropolitan area, one agency commented, “a lot of stops do not have sidewalks, concrete pads, or cut outs” that facili- on transit vehicles. For example, instructions to passengers in Göteborg, Sweden, say that wheelchairs may be carried if there is sufficient space, but connections are not guaran- teed. Similarly, in Aalborg, Denmark, there is space for one wheelchair on its low-floor buses “if the space is not already occupied by a pram [or baby carriage].” However, the tourist information notes that buses in most Danish cities, except for Odense, are low-floor or are equipped with a ramp. And in Norrköping, Sweden, all commuter trains and commuter train stations are equipped with ramps for wheelchairs, and passengers are encouraged to ask train hosts if they need assistance. In Helsinki, Finland, “A passenger in a wheel- chair and one companion are entitled to free travel on public transport in the Helsinki metropolitan area if the passen- ger has the required pass. Elsewhere in Finland, on Van- taa’s internal transport services, all disabled persons using wheelchairs are entitled to travel without tickets on low-floor vehicles. Mobility scooters with separate handlebars are not transported on buses, trams or the metro” (Conditions for Travel with Västtrafik 2010). Despite the lack of legislation, countries such as Nor- way are sensitive to the issue of accessibility. In a paper produced by the Norland Research Institute titled Disabil- ity and Transport—Experience with Specialised Transport in Norway, the authors comment that most user organiza- tions in Norway agree on the concept of universal design. However, they admit that universal design—public trans- portation accessible to everyone—is a “long-term project,” starting with the transition from conventional to low-floor buses (Solvoll and Armunssveen 2003). SURVEY RESULTS Challenges and Concerns Respondents were asked to rate to what extent bringing a wheelchair on board a transit vehicle was an issue, concern, or challenge. Before exploring general trends among survey responses, it is worth noting that some respondents may have been confused by an apparent negative connotation of the term “concern.” This issue became apparent during the data collection phase of the survey outreach, when one agency sought to clarify the question’s aims because the agency saw itself as accomplished in dealing with wheelchairs, and thus was not “concerned” with the issue. On the survey itself, one agency clarified its “not an issue” response, citing that “wheelchairs are governed by law.” Another large agency replied that all “buses are wheelchair accessible” and therefore, despite making the accommoda- tion of wheelchairs a priority, the agency does not consider wheelchairs an “issue/concern/challenge.” In the United States, policies on wheelchair accommodation are also gen- erally buttressed by the ADA.

19 tate wheelchair boarding. Similarly, a midsized agency also noted that “many areas in [the] community are not acces- sible for those using wheelchairs.” Another agency acknowl- edged the issue of the reliability of the ramp used to bridge the gap between a bus stop and the vehicle. Overview of Agency Policies Although one might assume all transit agencies have a writ- ten policy regarding the accommodation of wheelchairs on transit vehicles, the survey found that some agencies rely on ADA guidelines and do not adopt a formal policy for the agency’s non-paratransit vehicles. Thirty-four of 42 agencies surveyed (81%) have a policy in place regarding the accom- modation of wheelchairs on transit vehicles; the other eight do not (Table 5). Although not all Canadian agencies operate accessible vehicles, four Canadian agencies included as part of the study all have wheelchair policies in place for regular buses and trains, as well as paratransit vehicles. Among the smallest agencies in the survey sample, only eight of 14 said that they have an official wheelchair policy. All of the large agencies surveyed have a wheelchair policy. TABLE 5 POLICIES: WHEELCHAIRS ABOARD TRANSIT VEHICLES (REGULAR BUSES AND TRAINS) Size Yes No Small Agencies 8 6 Medium Agencies 10 2 Large Agencies 16 0 81% (34) 19% (8) n = 42. Size and Weight Limits Of the agencies that have a policy regarding wheelchairs aboard regular transit vehicles, 18 of 28 (64%) said that their policy does not limit the size of wheelchairs that can be accommodated, and 18 of 29 (62%) said that their policy does not limit the weight of a wheelchair that can be accom- modated (Tables 6 and 7). Only one agency that operates both bus and rail service indicated that wheelchair size and weight restrictions apply only on buses and that no restric- tions exist on rail. TABLE 6 POLICY LIMITS WHEELCHAIR SIZE Yes 36% (10) No 64% (18) n = 28. TABLE 7 POLICY LIMITS WHEELCHAIR WEIGHT Yes 38% (11) No 62% (18) n = 29. Of the 10 agencies that indicated size limitations, all but three have limits that correlate with the ADA definition of “common wheelchair” not to exceed 30 in. in width and 48 in. in length and not to weigh more than 600 lb when occu- pied. Of the other three not using the “common wheelchair” definition, one specified that the size as “must fit in the vehi- cle doorway,” one indicated a small wheelchair standard of 28½ in. wide by 40 in. long, and the third allows for a wider wheelchair of 32 in. wide by 48 in. long. With one exception, all of the agencies with weight policies match the ADA standard of 600 lb, although one agency allows for an occupied chair of up to 650 lb. One agency indicated that no official policy exists, but it will limit passengers in wheel- chairs to a combined 800 pounds, the capacity of its lifts. Wheelchair Position on Vehicles Unlike some of the other large items reviewed in this synthe- sis, most policies define where wheelchairs must be placed on buses. Twenty-seven of 34 responding agencies (79%) require wheelchairs to be placed in certain locations on regular tran- sit buses (Table 8). Only two of the 14 responding agencies that operate both buses and rail have a designated location on rail vehicles that must be used by persons with wheelchairs; many of the agencies that operate rail, including BART, have designated areas on trains for wheelchairs but do not require wheelchairs to use them. Likewise, none of the rail operators require wheelchairs to be secured aboard the train, whereas wheelchairs must be secured on almost all of the buses. TABLE 8 POLICY REQUIRES SPECIFIC WHEELCHAIR PLACEMENT Yes 79% (27) No 21% (7) n = 34. Because most buses have a limited number of locations where wheelchairs can be secured, most agencies that oper- ate buses limit the number of wheelchairs allowed per bus. Twenty-four of 30 agencies that operate buses (80%) have policies that limit the number of wheelchairs allowed on board a bus at one time. Presumably, other agencies also have limits, but these are not codified in their policies. For most agencies, the vehicle size and configuration dictates the num-

20 Unlike some of the other items being reviewed in this syn- thesis (e.g., bicycles, strollers, carts), wheelchairs are always a mobility device. As a result, and owing to ADA require- ments for the accommodation of wheelchairs and people who use them, many agencies favor wheelchairs over other large items in the event of space constraints on a vehicle. When passenger loads are high on a transit vehicle (bus or trolley), not all agencies have a policy that requires operators to pick up all wheelchair/mobility device users, even when the wheelchair space is available. As shown in Table 9, 20 of 29 agencies (69%) with wheelchair policies expect driv- ers to pick up passengers when space is available for wheel- chairs to be secured. Five of 29 agencies (17%) do not expect drivers to accommodate wheelchairs on a full vehicle. Four small agencies do not have an expectation regarding accom- modation of wheelchairs on full vehicles. TABLE 9 DRIVERS EXPECTED TO PICK UP ALL WHEELCHAIR/ MOBILITY DEVICE USERS WHEN THE WHEELCHAIR SPACE IS AVAILABLE, EVEN WITH A FULL BUS Yes 69% (20) No 17% (5) N/A 14% (4) n = 29. N/A= not available. In dealing with a full bus, a few agencies indicated that wheelchair users have priority in boarding and that other customers will be asked to move back if possible. According to one agency’s policy, other passengers may be required to exit a vehicle for the wheelchair to board and then be allowed to reboard if space is available. For trains, one agency indicated that operators are not instructed to ask ambulatory passengers to deboard in order to allow a person in a wheelchair to get on the train. Accord- ing to the agency, “when trains are full, everyone waits— including wheelchair users.” Although a full transit vehicle can make it difficult for any passenger to board, a bus or trolley with designated wheel- chair spaces that are occupied typically means that another wheelchair user cannot board. Transit agencies were asked to define what is required of operators when the wheelchair space is occupied but another individual in a wheelchair wants to board (Figure 8). Several agencies (8 of 23) always dispatch another vehicle, usually a paratransit vehicle, to pick up the passenger in a wheelchair. Others may dispatch another vehicle depending on the anticipated arrival time of the next scheduled bus. ber of wheelchairs that can be secured (ranging from two to four tie-downs, depending on the vehicle type, with two tie- downs being most common) (Figure 6). Only one of 33 agen- cies (3%) requires wheelchairs to be inspected and approved before use on transit buses. Although only one other agency indicated that inspection and approval is required in the event of questions about size or weight, it is assumed that many transit agencies will require inspection if questions exist about whether the wheelchair conforms to standards. Only one agency, with a fleet that is not fully accessible, indicated that wheelchairs are disallowed on certain routes. FIGURE 6 Common wheelchair (left) and a large stroller occupy space at the front of a bus (courtesy: CTA). Driver Assistance Among agencies that operate buses, most (20 of 31, or 65%) require their drivers to provide assistance to secure wheel- chairs (where applicable). The other 11 of 31 (35%) instruct their drivers that they may provide assistance if requested or needed. In addition to extending the ramp or using the lift (expected of all operators) and securing passengers, oper- ators at 12 of 31 (36%) agencies may assist passengers in stowing their belongings (Figure 7). FIGURE 7 Wheelchairs: Which of the following types of assistance may operators provide (buses) (n = 31)?

21 FIGURE 9 How effective do you think the agency’s wheelchair policy is (n = 29)? TABLE 10 POLICIES REGARDING WHEELCHAIRS CONSIDERED, BUT NOT IMPLEMENTED Yes 17% (6) No 83% (30) n = 36. One agency noted that wheelchair securement on the bus is currently optional, but it is considering making secure- ment mandatory “to enhance safety for the rider and other passengers” and to prevent “tip overs.” Another agency considered a policy that would require seated passengers to vacate the wheelchair position for a wheelchair, but the agency determined that “this was an unrealistic requirement to make of operators.” Three agencies described their concerns about accommo- dating nonstandard, oversized, or overweight wheelchairs. All agencies had considered new policies explicitly denying these but failed to enact policies with these provisions. One agency purchased larger lifts and does not currently deny service. One agency representative noted “[the agency] is not confident that [we could limit large wheelchairs] without opening ourselves up for a possible lawsuit.” Another survey respondent expressed concerns about the structural integ- rity and transportability of wheelchairs in general: “They simply are not built for being placed in a moving vehicle…. Most will fall apart in a serious accident, but the ADA laws require we transport them.” ONE AGENCY’S EXPERIENCE: TRIMET, PORTLAND, OREGON—REVISITING WHEELCHAIR POLICIES Portland’s TriMet is one of few agencies that makes the securement of wheelchairs or other mobility devices optional. The policy was developed with significant input from TriMet’s Committee on Accessible Transportation (CAT), a citizens’ committee created in 1985 with a critical role for providing input on policies and programs for people with disabilities. The optional securement policy has been in place for several years, but owing to concerns about passen- FIGURE 8 What are operators instructed to do when the wheelchair space is occupied, but another individual in a wheelchair wants to board (n = 23)? Wheelchairs Boarding Rail Vehicles Most rail cars operated by North American transit agen- cies can accommodate a larger number of wheelchairs than buses. Transit agencies that operate rail vehicles indi- cated that trains can carry between four and eight wheel- chairs per car. Most rail operations are much more flexible than bus operations regarding wheelchair size or weight restrictions, designated spaces for wheelchairs, or operator assistance requirements. For four of the agencies that operate commuter rail trains, passengers in wheelchairs require a higher level of assistance than for those agencies that have platform-level boarding. These agencies require personnel or train conduc- tors to activate bridge plates, gap fillers, or ramp extenders for boarding and alighting. In many cases, wheelchair users must notify agency staff to provide assistance and to notify the train operator where they intend to alight. In most other cases, rail staff (operators or agents) may have less interac- tion with wheelchair users than their counterparts operating buses: rail does not typically require securement, and trains that offer platform-level boarding generally allow wheel- chair users to enter or exit through any door. Wheelchair Policy Effectiveness Transit agency representatives were asked to indicate how effective they consider their wheelchair policies to be. As shown in Figure 9, most deemed their policies to be quite effective, with 25 of 29 respondents (86%) ranking their policy a 4 or 5 on a scale, with 5 being “very effective” and 1 being “not at all effective.” All agencies, regardless of whether they have a policy gov- erning wheelchairs on transit vehicles, were asked whether they had considered implementing any specific policies about wheel- chairs but not done so. Only 36 of the 42 agencies responded to this question, and only six (17%) indicated that they had consid- ered policies that were not implemented (Table 10).

22 • Order new buses with securement options that allow people with disabilities to have the maximum amount of autonomy over their securement process. Procedures for Buses Unable to Accommodate People in Wheelchairs The use of securement space also has impacted whether passengers with wheelchairs can board transit vehicles. The agency’s policy is that priority is given to people who are supposed to occupy the priority seating area, includ- ing wheelchairs and other mobility devices. Although in some cases oversized and double strollers have occupied these spaces, making it difficult to load a wheelchair, these spaces are generally used only by mobility devices. Never- theless, owing to the potential that all wheelchair secure- ment positions could be occupied by wheelchairs when another person using a wheelchair wants to board a bus, TriMet developed a set of comprehensive procedures for operators to follow: If there is no way to board the person due to crush load or all wheelchair securement areas being occupied: 1. Stop and explain the situation to the customer. 2. If the following bus is less than 30 minutes behind, tell the customer when the next bus will arrive, notify dispatch, and resume service. 3. If it is more than 30 minutes before the next bus arrives: a. Collect all information needed to arrange for transport: • Get the customer’s name. • Get the customer’s destination. • Ask the customer, “Can you use a regular cab or do you require a vehicle with lift equipment?” b. Notify dispatch and remain with customer. c. Follow dispatch instructions (dispatch will arrange for alternative transportation). d. Inform waiting customer of transportation arrangements and schedule. e. Resume service. This procedure was updated last in 2008 but is simi- lar to procedures that have been in place since the 1980s. The TriMet service area has grown and services have been enhanced, so few routes today have headways greater than 30 min. Although it is rare that a rider might be waiting more than 30 min, TriMet’s operators are trained to follow this specific procedure. ger safety and some instances of wheelchairs tipping over, the agency plans to revise the policy by early 2011 to make securement mandatory. Many of the details presented here were shared by the TriMet manager of procedure develop- ment in a telephone interview on April 8, 2010 (T. Fuentes, TriMet, personal communication, Apr. 8, 2010). The revision has the support of the CAT, which originally sought to make securement optional in an effort to be sensi- tive to riders using wheelchairs, allowing them to maintain their dignity and feel independent. In requesting the revi- sion to the policy, TriMet conducted a review of 32 months of accident data. During that period, 152 incidents involv- ing mobility devices occurred. Forty-six of these incidents involved the wheelchair tipping over or the person using the device being shifted forward in the securement area, leading to their own injury or injuring another customer. TriMet cal- culated an accident rate of about 1.4 per month. According to staff, accidents with mobility devices have not translated into a major fiscal burden for TriMet, but they are a signifi- cant ongoing safety concern. Drivers Are Instructed to Ask the Customer if He or She Needs Assistance The current policy requires operators to ask passengers in wheelchairs or other mobility devices if they would like to be secured, but the decision is up to the passenger. If a wheel- chair user declines to be secured, the driver is instructed to send a note to the transit dispatcher. Some CAT members and staff members have expressed concern that because secure- ment is optional and has been so for several years, operators may be neglecting to ask whether riders wish to be secured. Second Time Around Securement was initially required on the buses but then was made optional. Based on the high number of accidents and concerns about passenger safety and agency liability, TriMet’s Executive Committee recommended—and the CAT endorsed—the mandatory securement of wheelchairs and other mobility devices. CAT members identified several issues to be addressed before the forthcoming mandatory securement policy is implemented: • Train operators to ensure consistency and sensitivity and include persons with disabilities in the training process. • Ensure that appropriate and safe equipment is available on all buses. • Address concerns about the time it takes to secure on tightly scheduled runs. • Carry out education and outreach efforts to drivers and mobility device users before implementation. • Make securement straps available to mobility device users as part of the eligibility certification or recertifi- cation process.