Use of Rear-Facing Position for Common Wheelchairs on Transit Buses (2003)

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27 CHAPTER FOUR EXPERIENCE AND ISSUES RELATED TO THE REAR-FACING SYSTEM CUSTOMER ACCEPTANCE In Europe, rear-facing systems have existed for more than a decade, especially in Germany, the United Kingdom, and France. Consumers who have used the system appreciate the independent use of public transit buses. Contrary to the North American situation, where, in the 1980s, large transit buses were equipped with lifts for passengers using wheel- chairs, European and Canadian transit systems avoided de- ployment of lift technology, and transportation for people in wheelchairs was provided primarily by specialized tran- sit. The introduction of low-floor buses with a rear-facing system represented the necessary acceptable technological step forward for making public transit on conventional buses accessible for passengers with wheelchairs. Interviews with bus operators in Germany, England, and France indicated that the rear-facing position is primarily occupied by standees, persons with strollers, and passen- gers with large baggage. Use by passengers with wheel- chairs is minimal. It has also been observed that rear-facing systems are designed and applied differently in several cit- ies; some European transit systems have provided only an open space with a padded bar at both ends, without a back panel, and some bus operators do not insist that passengers face to the rear in the compartment. According to observa- tions by bus operators, the majority of passengers in wheelchairs are those who use manual and sports chairs— persons who therefore have good upper body strength and are able to hold onto the handrails in the compartment while riding the bus. In Canada, rear-facing systems are relatively new; the first pilot programs began in the end of the 1990s in Ham- ilton, Kitchener, Montréal, and Victoria. The following in- formation was received from transit systems as part of the discussions with their accessibility committees and from discussions with focus groups. Initial reaction from consumers was often skeptical, es- pecially from those passengers who had not yet used the system but believed that they could not travel facing to- ward the rear. Because wheelchair users are used to being secured with several straps on specialized transit service, some voiced concern about the proper level of safety. Many transit systems have helped to overcome skepticism among wheelchair users by holding open houses in their facilities for potential passengers to familiarize them with the use of ramps, interior maneuvering spaces, and the rear-facing position. Doing so has helped many consumers not only to get to know the systems, but also to confirm whether their mobility aid and personal skills and abilities would actually make access to a low-floor bus possible. Consumer reaction, as related by transit system staff, has been positive. Initial concerns about facing toward the rear and safety generally appear to disappear once indi- viduals use the system and experience firsthand the greater independence that the system provides • The survey did not reveal any strong feedback re- ceived by transit system staff once the system was deployed. • In BC Transit, on buses where both forward- and rear-facing options exist with the combi design, bus operators report that the rear-facing position is gener- ally occupied first, indicating a preference by wheel- chair passengers. • BC Transit staff have also received positive personal comments about the rear-facing position on double- decker buses. • Some systems that initially started with the forward- facing system (e.g., BC Transit and Grand River Transit) have successfully adopted the rear-facing system. The research did not identify any transit sys- tems that have abandoned the rear-facing system in favor of the forward facing system. Some users feel singled out by being the only passen- gers facing to the rear. This perception can be minimized if there are other seats in the bus facing to the rear, as is typi- cal in rail transit and in European bus models. Rear seats have started to appear in some low-floor bus models being used in North America (e.g., Montréal, BC Transit, and new AC Transit buses). The rear-facing regular seats are typically positioned over the wheel wells to counter the re- duction in seat capacity inherent in low-floor buses. Some wheelchair users are still concerned about lateral stability and various approaches to allay these concerns are being explored. Contrary to the situation among consumers in Europe, there appears to be a larger percentage of consumers in Canada who use scooters. Also, with an increasingly eld- erly population, this percentage will probably grow. At the same time, new four-wheel scooter designs are becoming longer and heavier, and they require a larger turning radius,

28 thus creating a challenge for transit buses. However, the rear-facing design generally offers greater flexibility to ac- commodate noncommon wheelchairs. TRANSIT SYSTEM EXPERIENCE As stated previously, the rear-facing system is now the norm for most transit systems across Europe, including Germany, the United Kingdom, France, Poland, Austria, Spain, the Czech Republic, Sweden, and Belgium. It is ex- pected to be used in the future by most European countries. The system is currently being deployed in Australia as well. As of 2002, six transit systems in Canada had imple- mented the system in their low-floor buses, with at least one other large system (i.e., Edmonton) adopting it in its next bus order. It is anticipated that, with the publishing of the CSA D435 standard, more systems will adopt the rear- facing system. There are a number of advantages for wheelchair pas- sengers and the transit system, as identified through the survey, case studies, and discussions with transit staff. The advantages for wheelchair passengers include • Independent and dignified use of the system, without, for most wheelchair passengers, the need for assis- tance by others; • Faster boarding and alighting, causing less embar- rassment with respect to other bus passengers; • Little need for physical contact with other persons; • Adaptation to most commonly used wheelchairs and scooters, and even some noncommon wheelchairs, without the need for attachment points; and • Less damage to the mobility aid from the securement system. Advantages for the transit system include • Reduction of dwell times at stops (under 1 min, as compared with more than 3 min with the forward- facing design), • Little involvement of the bus operator, • No injuries to or awkward working position for bus operators, • Reduced maintenance cost for the system, and • No maintenance of straps and hooks or need for re- placement. The primary disadvantages identified through the re- search are the following: • The wheelchair passenger cannot see or identify the upcoming stop. • The wheelchair passenger is facing toward the rear. This situation creates an image problem if he or she is the only passenger facing to the rear. In addition, there is a concern that some passengers may have dif- ficulty facing this direction because of motion sick- ness, although no specific cases were identified dur- ing the research. • The position may not prevent tip-overs of three- wheel scooters under severe braking, sharp turns, and curb hopping. SAFETY EXPERIENCE AND APPROACHES TO PREVENT TIPPING UNDER SEVERE CONDITIONS To provide uniform standards and guidelines throughout the European Union, Guideline 2001/85/EG was intro- duced in November 2001. It requires that all member states develop their own implementation guidelines by 2003. The main challenge relates to the prevention of wheelchairs from tipping under severe conditions. To prevent wheel- chairs from tipping or moving into the aisle, transit sys- tems in Europe have used three different approaches. 1. A fixed aisle stanchion (United Kingdom), 2. A wall-mounted retractable strap at waist height that can be attached to the wheelchair frame or armrest by placing it over the passenger’s lap (Germany), and 3. A pivoting armrest or extending rail attached to the back panel’s vertical support (France and United Kingdom). Interviews with European experts indicate that the armrest and extending rail are sometimes structurally unreliable. Stanchions are preferred but tend to protrude into the bus aisle, impeding passenger movement. In Canada, transit systems have expressed no significant safety concerns, according to the survey conducted for this project. They consider the rear-facing approach safe, pro- vided that there are proper means installed to prevent wheelchairs and scooters from tipping into the aisle. Sev- eral approaches are being used. • A fixed aisle stanchion (Montréal), or a stanchion in combination with other means (BC Transit, Ottawa, etc.); • Two straps that are hooked together across the mobil- ity aid, or attached directly to the mobility aid, with one strap positioned at the rear, seat height at aisle side, and the other on the wall in front of the chair (Victoria and municipal BC Transit systems); and • A wall-mounted strap to be attached to the wheel- chair or scooter (Ottawa). All approaches have advantages and disadvantages. • The aisle stanchion works well for manual, sports, and power chairs, but its location may interfere with

29 • Application of brakes on manual chairs; and the passenger flow in the aisle and restrict maneuver- ing space for wheelchairs getting into and out of the rear-facing position. For three-wheel scooters it does not provide good protection, because the geometry of the scooter allows for easy sideways tipping, and the position of the fixed stanchion cannot prevent this. • Turning off the power for scooters and power chairs, which will automatically apply their brakes. A number of additional issues have been identified in the course of this research, as discussed in the following para- graphs. • Hooking two retractable straps together seems to pre- vent the scooter from tipping or moving, but this approach is currently used by only one transit system, and results to date are limited. The disadvantage of this system is that, if requested by the passenger, it has to be applied by the bus operator, who must get out of his or her seat to attach and/or detach the straps if the passenger cannot do so independently. Because the straps supplement aisle stanchions, their use is not mandatory. Maneuvering Space and Location of Stanchions One of the most challenging aspects for wheelchair access in a low-floor bus is to provide the necessary maneuvering space for the wheelchair or scooter to get into and out of the traveling position. Ideally, maneuvering in and out should be accomplished in one or two movements. The narrower the space, the more movements are required, the longer is the time spent to get into or out of the position, and the higher is the risk for interference with other pas- sengers; for example, contact with the wheelchair and roll- ing over another passenger’s toes. In addition, the location of stanchions creates a particular challenge; stanchions have proven valuable in limiting wheelchair tipping; how- ever, if placed in ways to maximize wheelchair maneuver- ing space, they may impede the flow of other passengers in the aisle. • The use of a wall-mounted retractable strap is not mandatory, and many passengers in a wheelchair or scooter may not be able to attach and/or detach the strap themselves, thus requiring operator involve- ment. In addition, the strap may not be correctly at- tached, rendering it ineffective. Experiments were carried out by one transit system to use a pivoting armrest that would be attached to the verti- cal support of the back panel’s aisle side. Although it seemed to prevent tipping with the armrest down parallel to the scooter’s armrest, it presented a problem primarily for the passengers who had difficulty in reaching behind to move the armrest from its vertical stored position into the horizontal protecting position and vice versa. In addition, the transit system staff felt that this component could be misused or could create a hazard for other passengers. Loss of Seating Capacity and Design of Flip Seats The loss of seating capacity on accessible buses presents a concern for the transit system. To minimize seat loss, many transit systems have installed two or three flip seats in the wheelchair area along the wall, or even a flip seat in the back panel of the rear-facing position. However, a flip seat located in the back panel may prevent the passenger from getting his or her back sufficiently close to the back panel. Tests should be carried out to verify the design. In some cases, it will be necessary to choose aisle-facing flip seats instead, to allow for sufficient traffic flow and maneuver- ing space for the wheelchair. Prevention of the mobility aid from tipping remains a challenge. At this point, there does not appear to be a solu- tion in use that would both prevent tipping and not involve assistance by the bus operator or by an attendant or com- panion for some passengers. However, it should be reiterated that, notwithstanding this concern, no serious safety incidents directly linked to rear-facing systems have been reported in Canada or in Europe. That is the case, although thousands of buses have now been operating with rear-facing positions—in many instances for more than a decade. Dimensions and Position of Back Panel There is still a diversity of approaches being used to di- mension and position the back panel as seen in Table 3. The padded back panel should be dimensioned and posi- tioned in such a way that it allows for close contact with the passenger’s back. This requires that enough space on both sides and underneath the panel is available to clear the handles and large wheels of manual and sports chairs, as well as the rear ends of scooters and power chairs. A typi- cal problem for scooters is that they may have bags or bas- kets attached to the rear that prevent the person from get- ting close to the back panel. Still, it is important that the OTHER ISSUES For the appropriate use of the rear-facing position, several conditions should be met whenever possible: • Proximity of a passenger’s back to the back panel, which requires wheelchair wheels and handles to be able to straddle the backrest;

30 TABLE 3 DIMENSIONS FOR BACK PANELS IN SOME CANADIAN TRANSIT SYSTEMS BC Transit Montréal STM Ottawa OC Transpo Total vertical panel height 1295 mm (51 in.) 1346 mm (53 in.) 1370 mm (54 in.) Panel orientation 100% vertical, but with jump seat 100% vertical 100% vertical Panel’s floor clearance 355 mm (14 in.) 457 mm (18 in.) 420 mm (16.5 in.) Panel width 305 mm (12 in.) 305 mm (12 in.) 305 mm (12 in.) Panel thickness 76 mm (3 in.) 76 mm (3 in.) 76 mm (3 in.) back panel act as the primary barrier for absorbing accel- eration forces. It will be necessary to further review the ideal dimensions of the backrest after more practical activ- ity has been experienced. THE REAR-FACING POSITION AND THE ADA The ADA and related guidelines and requirements issued by the Architectural and Transportation Barrier Compli- ance Board define a large number of requirements for ac- commodating and integrating persons with disabilities into society by providing accessible transportation (1). Several of these affect the use of the rear-facing position on U.S. transit buses. In 2001, the FTA’s Office of Civil Rights published a document on ADA Information (30) that identifies “Ques- tions and Answers Concerning Common Wheelchairs and Public Transit.” Some of the interpretation of the ADA is pertinent to the discussion of the rear-facing position. • Securement Equipment to Be Provided—“Section 38.23 (d) of the DOT’s ADA regulations requires all ADA-compliant vehicles to have a two-part securement system, one to secure the common wheelchair, and a seatbelt and shoulder harness for the wheelchair user. Section 38.23 (a) requires vehicles over 22 feet in length to have enough securement locations and devices to secure two common wheelchairs.” [In addition, one of the two positions must be forward facing.] • Local Policy Concerning Securement—“Transit op- erators may adopt a policy that allows common wheelchairs to ride unsecured. If the rider wishes his or her wheelchair to be secured, however, the opera- tor’s personnel must provide the required assistance.” • Common Wheelchairs That Are Difficult to Accom- modate—“Section 37.165 (d) states that transit op- erators cannot refuse to accommodate a common wheelchair because the wheelchair cannot be secured to the driver’s satisfaction.” • Acceleration Force Requirements of Securement Sys- tem—“Securement systems on vehicles with GVWRs of 30,000 pounds or above, and their at- tachments to such vehicles, shall restrain a force in the forward longitudinal direction of up to 2,000 pounds per securement leg or clamping mechanism and a minimum of 4,000 pounds for each mobility aid. Securement systems on vehicles with GVWRs of up to 30,000 pounds, and their attachments to such vehicles, shall restrain a force in the forward longitu- dinal direction of up to 2,500 pounds per securement leg or clamping mechanism and a minimum of 5,000 pounds for each mobility aid” [49CFR 38.23 (d)]. In other words, for transit buses weighing more than 13 600 kg (30,000 lb), securement for mobility aids must withstand an acceleration force of 6.7 g (4,000 lb for a 600-lb combination of wheelchair and wheel- chair passenger). An assessment of these requirements would suggest that a rear-facing position can be provided under the ADA if the following conditions are met: • The transit system establishes a policy stating that securement is not required in the rear-facing position. Alternatively, if it does not have a mandatory se- curement policy already in place, it may opt to not establish any policy. • There must be two wheelchair positions, one of which must be forward facing. • Both wheelchair positions must be equipped with ADA-compliant securement and occupant restraint equipment to accommodate the request of a passen- ger who wishes to be secured. Inclusion of an ADA- compliant securement system in a rear-facing posi- tion would be done to comply with the ADA, but without necessarily adding a safety benefit, because these systems have been designed for forward facing and most users will likely not use them. Thus, the transit system must provide the equivalent of a Combi 2 design, as discussed earlier, but include ADA- compliant securement equipment for both positions. How- ever, to date ADA-compliant systems have all been de- signed for use in forward-facing positions, not for rear- facing positions, and adapting them involves compromises among conflicting objectives. There should be further re- view of the rear-facing design from a systems point of view, based on transit system experience as well as on fu- ture research concerning dynamic forces, appropriate de- sign requirements, and effective system designs. However, based on experiences elsewhere, it is likely, that many, if

31 not most, wheelchair passengers will independently use the rear-facing position of the combi design without the se- curement straps. One of the potential benefits of the rear- facing position will be to accommodate common wheel- chairs that are difficult to secure with strap systems. DYNAMIC FORCES AND REQUIREMENTS The forward-facing securement system in use today by U.S. transit operators complies with the ADA by requiring that two rear and two front tie-downs be attached to the wheelchair by the bus operator, who is responsible for the correct attachments. The securement guidelines and re- quirements issued by the Architectural and Transportation Barrier Compliance Board were developed based on re- search carried out by Battelle in the mid-1980s (31). Inter- views with experts involved in this research indicated that the basis for evaluating the acceleration forces that the se- curement system would need to resist was based on work carried out by the NHTSA on school buses, on the re- quirements established for passenger car restraints systems (designed for deceleration forces of 20 g), and on the original Canadian CSA D409 Standard for Motor Vehicles for the Transportation of Persons with Physical Disabilities (32), designed for vehicles under 7000 kg (15,500 lb). There did not exist at the time any data related to the de- celeration forces experienced by large transit buses. This situation led to the ADA requirement of a 4,000-lb (or 6.7-g) force mentioned previously. The securement sys- tems designed to meet this stringent requirement are com- plex, involving separate securement straps for the wheel- chair, plus restraint belts for the wheelchair occupant. Although very secure in protecting the occupant, when properly used their design has created practical challenges for transit agencies and for wheelchairs users, as discussed. A growing body of research has been emerging over the last decade that explores the actual deceleration forces ex- perienced on large buses. It is not surprising that this re- search indicates that standard buses, with their large mass, experience substantially lower deceleration forces than do smaller lighter-weight vehicles. First, the German research (12), outlined in chapter two, found that deceleration forces for transit buses under nor- mal operating conditions were in the order of 0.24 g. The French research conducted for COST 322 used decelera- tion forces of 0.4 to 1 g as part of their securement system testing (17,18). Subsequent research in Ontario was conducted by the Ministry of Transportation of Ontario (33). The tests in- volved operating a 12-m (40-ft) low-floor bus at speeds up to 50 km/h, and in maneuvers involving severe accelera- tion, severe braking, and lane changing. Maximum dy- namic forces recorded were 0.65 g in straight-line braking at 50 km/h and 0.3 g for evasive maneuvering. Most recently, a major new initiative on transportation for individuals with disabilities has been sponsored by the U.S. Department of Education’s National Institute of Dis- ability and Rehabilitation Research, through the creation of the Rehabilitation Engineering Research Center (RERC) on Wheelchair Transportation Safety. One of the recent re- search efforts carried out by the RERC has focused on wheelchair protection in buses, involving a comprehensive review of existing research on bus safety. The various pre- liminary findings of the RERC study (34) included the fol- lowing: • There is very little published information on transit bus safety and crash environment. There is no infor- mation to suggest that wheelchair passengers face undue risks aboard transit buses. The focus of most reported wheelchair incidents has been on noncollision events in which an inappropriately secured wheelchair passenger or unrestrained rider was injured. • The few reports of severe bus passenger injury, cou- pled with no reports of severe wheelchair passenger injury, suggest that severe bus crashes are uncom- mon. Because there are very few wheelchair passen- gers relative to other passengers, it is not surprising that severe bus crashes involving wheelchair passen- ger injuries have not been reported. Despite serious deficiencies in bus crash reporting systems, it is very unlikely that there have been substantial numbers of wheelchair passengers injured in bus crashes. • Much more information was found for more com- monly occurring noncollision incidents. Noncollision incidents have been the focus of research efforts de- signed to characterize the g-levels associated with vehicle motion in normal operation and during eva- sive maneuvers. Reported deceleration and accelera- tion levels range from 0.3 to 0.8 g. • This study found little justification for the ADA- mandated level of frontal impact protection in regard to published data on crashes and injuries. There were no reported analyses of actual crashes, nor reports of severe crashes equivalent to the 32-km/h, 8- to 10-g frontal barrier crash that formed the basis for the ADA Wheelchair Tiedown and Occupant Restraint System requirements. • The results of the RERC study indicated that protec- tion at the 1 g level is more justifiable than at the ADA- implied 8- to 10-g level. However, further investigation of the rare transit bus crashes that exceed 1 g is warranted. Such information would facilitate the development of an improved system that would better balance the need for occupant protection with the needs for efficiency, convenience, user acceptance, and cost.

32 The findings from these various studies need to be compared with the requirements with respect to accelera- tion forces found in different regulations or standards. • ADA (1990), 6.7 g; • France (1992), 0.5 g; • UK (2000), 0.75 g; • European Union (2001), 1 g; • CSA D435 (2002), 3 g; and • Australia (2002), No requirement with respect to deceleration forces. It is clear that significant differences underlie these re- quirements. Europeans tend to view the topic as one of providing safety to the wheelchair passenger under severe operating conditions, but equivalent to the levels of safety provided to other passengers (particularly standees). The ADA requirement provides a high level of confidence of the wheelchair passenger’s survival in a frontal crash situa- tion, but it uses a safety standard that far exceeds levels of safety for other passengers. As revealed in the interview with Alan Little, Manager, Conventional and Custom Fleet, BC Transit, and member of the CSA D435 Technical Committee, the CSA requirement is a compromise between these two perspectives. It sets a requirement for accelera- tion forces that is lower than those in the ADA, in recogni- tion of the lower acceleration forces of large buses. How- ever, it provides a somewhat higher safety margin than those required in Europe. The requirement can still be met relatively simply and accommodates the flexibility offered by the rear-facing position. Research has yet to determine what are the acceleration forces experienced by transit buses in freeway operation or in crash situations. APPLICATION TO BUS RAPID TRANSIT The FTA has been actively encouraging transit systems to consider implementation of BRT systems, in particular as an alternative to light rail. However, BRT systems involve high-frequency, large-capacity vehicles, operating in tight corridors; expectations of high levels of service reliability; and short dwell times. Current securement practice using the complex four-strap system is likely to be a source of disruption to BRT systems. The rear-facing system may offer a number of potential benefits with respect to transit systems implementing BRT, including the following: • Significantly decreased dwell times when boarding and positioning a wheelchair passenger (from more than 3 min in a majority of cases to less than 1 min in a majority of cases); • The ability to accommodate in a more timely manner those common wheelchairs that are difficult to accommodate, or even noncommon wheelchairs (these represent the greatest source of dwell time); • The ability to better accommodate passengers with large objects, such as parcels, strollers, and bicycles, and in a timelier manner—the rear-facing position in Europe is more commonly used by persons with strollers than with wheelchairs; • Increased service reliability resulting from the elimi- nation of the spikes in dwell times caused by the aforementioned sources of delay; and • Reduced need for the bus operator to have to leave his or her seat—an even more significant benefit in BRT service that is anticipating the use of articulated buses carrying large numbers of people. Transit systems that have high-capacity service with heavy loadings (e.g., Germany and Montréal) have typi- cally positioned the wheelchair position(s) across from the rear door. Doing so greatly increases maneuverabil- ity for the wheelchair passenger who does not have to make the sharp turns and tight maneuvers required in a front-door access and passage between the front wheel wells. A rear-door access and location for the wheelchair thus decreases dwell time required for boarding and posi- tioning. This may be very attractive to meet BRT system requirements and is the approach being adopted by AC Transit. However, it raises three considerations for U.S. BRT systems: • Is the design of the BRT system such that rear-door access by wheelchairs is easily achieved? Systems that are being designed with rail-type standards (e.g., precision docking, high platforms, and level board- ing) may be more easily able to fulfill this require- ment than is arterial-based service, in which parallel approaches to stations may be hindered by illegally parked cars. Cooperation of local authorities respon- sible for street design and strict enforcement of no- parking regulations will become essential in the latter case. • The distance that the bus operator must walk for rear- door access and wheelchair position will be greater if the consumers request assistance to position them- selves, thus increasing dwell times. • Fare collection from wheelchair passengers using a rear-door access may pose a challenge.