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

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