American Seating Company, John Adelsperger
January 16, 2009 [email]



Dennis, attached please find American Seatings response to the second draft. I think that the second draft is pretty good from a restraint system supplier viewpoint, with one exception.

Please confirm receipt by return email.

Thanks

John Adelsperger
Director of Engineering
Transportation Products Group
American Seating Company
Phone 616-732-6468
Fax 616-732-6851
e-mail johna@amseco.com


Mr. Dennis Cannon
U.S. Access Board
Washington, D.C.

January 16, 2009

Response to: Second Draft Revisions to the ADA Accessibility Guidelines for Buses and Vans

Response from: John Adelsperger
(john.adelsperger@amseco.com)
Director of Engineering
American Seating Company
401 American Seating Center
Grand Rapids MI 49504

We appreciate having the opportunity to respond to the second draft in advance of the rule making. From a seating and restraint system supplier viewpoint, there is one major area that we feel must be addressed. That falls under the section entitled T403.3 Movement. You have provided no specific performance requirements. Under your advisory for this section, you note that normal operating conditions are specific to the provider. Vehicles that operate in a hilly terrain or on winding roads will have more severe constraints than those on flat streets. We work with a vast majority of the city transit operators in the United States. It is not reasonable to expect that they have the capabilities of determining what forces would be in effect for their terrain, without spending significant funds to hire outside consultants. It is also unreasonable to expect that American Seating or other restraint system suppliers are going to conduct studies across the nation to determine what the forces are in effect. It is also unreasonable to expect that American Seating and other restraint system suppliers are going to create systems with wide variations in the performance. Complexity increases cost and room for error. Please take this into consideration. We feel that it is just as important and defining the load requirements for the devices to hold the mobility aid.

We believe there are several areas of the current ADA regulations that should be addressed and we were pleased to find that some of those were in your draft. I have listed below our comments to the specific paragraph. A general comment that I would make is that the industry needs specific performance requirements, not generic statements that are in the previous document and in this document in a few instances. Examples would be slip resistant or emergency driving conditions. There are ISO or RESNA standards that are either final or in process that have been developed by knowledgeable people in the industry that could be used. If there are no test methods stated, the performance requirement should be removed.



Click here to see the attached file.