Wheelchair

Securements and

Passenger Restraints

Best Practices of Securing Wheelchairs and Restraining

Passengers as defined by SAE J2249.

Steve Oss

March 2011

Updated September 2011

WH EE LCH AIR SEC UREM ENT S AN D P AS SE NGE R

R EST R AINT S

The goal of this training is to assist individuals and transit organizations to be aware of and to be in

full compliance of:

CFR TITLE 49 – TRANSPORTATION (03 – 01 – 11 Edit ion)

Subtit le A - OFFICE OF THE SECRETARY OF TRANSPORTATION

Part 37 - TRANSPORTATION SERVICES FOR INDIVIDUALS WITH DISABILITIES

(ADA); by understanding, implementing and training to proficiency the “Best Practices” identified

in SAE J2249.

WHAT THE ADA SAYS

PART 37 – TRANSPORTATION SERVICES FOR INDIVIDUALS WITH DISABILITIES

(ADA)

Subpart A – General

Sec. 37.3 Definit ions

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.

*This was changed in June of 2011 to: if the wheelchair fits in the securement area without

blocking the aisle, it must be transported.

Subpart G – Provision of Service

Sec. 37.163 Keeping vehicle l if ts in operative condit ion: Public entit ies

(b) The entity shall establish a system of regular and frequent maintenance checks of lifts sufficient

to determine if they are operative.

(c) The entity shall ensure that vehicle operators report to the entity, by the most immediate means

available, any failure of a lift to operate in service.

(d) Except as provided in paragraph (e) of this section, when a lift is discovered to be inoperative,

the entity shall take the vehicle out of service before the beginning of the vehicle's next service day

and ensure that the lift is repaired before the vehicle returns to service.

(e) If there is no spare vehicle available to take the place of a vehicle with an inoperable lift, such

that taking the vehicle out of service will reduce the transportation service the entity is able to

provide, the public entity may keep the vehicle in service with an inoperable lift for no more than

five days (if the entity serves an area of 50,000 or less population) or three days (if the entity

serves an area of over 50,000 population) from the day on which the lift is

discovered to be inoperative.

(f) In any case in which a vehicle is operating on a fixed route with an inoperative lift, and the

headway to the next accessible vehicle on the route exceeds 30 minutes, the entity shall promptly

provide alternative transportation to individuals with disabilities who are unable to use the vehicle

because its lift does not work.

37.165 Lift and securement use.

(a) This section applies to public and private entities.

(b) All common wheelchairs and their users shall be transported in the entity’s vehicles or other

conveyances. The entity is not required to permit wheelchairs to ride in places other than

designated securement locations in the vehicle, where such locations exist.

(c)(1) For vehicles complying with part 38 of this title, the entity shall use the securement system to

secure wheelchairs as provided in that Part.

(2) For other vehicles transporting individuals who use wheelchairs, the entity shall provide and

use a securement system to ensure that the wheelchair remains within the securement area.

(3) The entity may require that an individual permit his or her wheelchair to be secured.

(d) The entity may not deny transportation to a wheelchair or its user on the ground that the device

cannot be secured or restrained satisfactorily by the vehicle’s securement system.

(e) The entity may recommend to a user of a wheelchair that the individual transfer to a vehicle

seat. The entity may not require the individual to transfer.

(f) Where necessary or upon request, the entity’s personnel shall assist individuals with disabilities

with the use of securement systems, ramps and lifts. If it is necessary for the personnel to leave

their seats to provide this assistance, they shall do so.

(g) The entity shall permit individuals with disabilities who do not use wheelchairs, including

standees, to use a vehicle’s lift or ramp to enter the vehicle. Provided, that an entity is not required

to permit such individuals to use a lift Model 141 manufactured by EEC, Inc. If the entity chooses

not to allow such individuals to use such a lift, it shall clearly notify consumers of this fact by

signage on the exterior of the vehicle (adjacent to and of equivalent size with the accessibility

symbol).

37.167 Other service requirements.

(e) The entity shall ensure that vehicle operators and other personnel make use of accessibility-

related equipment or features required by part 38 of this title.

(g) The entity shall not refuse to permit a passenger who uses a lift to disembark from a vehicle at

any designated stop, unless the lift cannot be deployed, the lift will be damaged if it is deployed, or

temporary conditions at the stop, not under the control of the entity, preclude the safe use of the

stop by all passengers.

(h) The entity shall not prohibit an individual with a disability from traveling with a respirator or

portable oxygen supply, consistent with applicable Department of Transportation rules on the

transportation of hazardous materials (49 CFR subtitle B, chapter 1, subchapter C).

(i) The entity shall ensure that adequate time is provided to allow individuals with disabilities to

complete boarding or disembarking from the vehicle.

(j)(1) When an individual with a disability enters a vehicle, and because of a disability, the

individual needs to sit in a seat or occupy a wheelchair securement location, the entity shall ask

the following persons to move in order to allow the individual with a disability to occupy the seat or

securement location:

(i) Individuals, except other individuals with a disability or elderly persons, sitting in a location

designated as priority seating for elderly and handicapped persons (or other seat as necessary);

(ii) Individuals sitting in or a folddown or other movable seat in a wheelchair securement location.

(3) The entity is not required to enforce the request that other passengers move from priority

seating areas or wheelchair securement locations.

(4) In all signage designating priority seating areas for elderly persons and persons with

disabilities, or designating wheelchair securement areas, the entity shall include language

informing persons sitting in these locations that they should comply with requests by transit

provider personnel to vacate their seats to make room for an individual with a disability. This

requirement applies to all fixed route vehicles when they are acquired by the entity or to new or

replacement signage in the entity’s existing fixed route vehicles.

[56 FR 45621, Sept. 6, 1991, as amended at 58 FR 63103, Nov. 30, 1993]

37.173 Training requirements.

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, with appropriate attention to the difference

among individuals with disabilities.

English Dictionary. proficiency – noun pro.fi.cien.cy

1. high degree of ability or skill. a high degree of ability or skill in something

PART 38_AMERICANS WITH DISABILITIES ACT (ADA) ACCESSIBILITY

SPECIFICATIONS FOR TRANSPORTATION VEHICLES

Subpart B_Buses, Vans and Systems

Sec. 38.23 Mobil ity aid accessibi l ity.

(a) General. All vehicles covered by this subpart shall provide a level-change mechanism or

boarding device (e.g., lift or ramp) complying with paragraph (b) or (c) of this section and sufficient

clearances to permit a wheelchair or other mobility aid user to reach a securement

location. At least two securement locations and devices, complying with paragraph (d) of this

section, shall be provided on vehicles in excess of 22 feet in length; at least one securement

location and device, complying with paragraph (d) of this section, shall be provided on

vehicles 22 feet in length or less.

(b) Vehicle lift--(1) Design load. The design load of the lift shall be at least 600 pounds. Working

parts, such as cables, pulleys, and shafts, which can be expected to wear, and upon which the lift

depends for support of the load, shall have a safety factor of at least six,

based on the ultimate strength of the material. Nonworking parts, such as platform, frame, and

attachment hardware which would not be expected to wear, shall have a safety factor of at least

three, based on the ultimate strength of the material.

(11) Boarding direction. The lift shall permit both inboard and outboard facing of wheelchair and

mobility aid users.

(12) Use by standees. Lifts shall accommodate persons using walkers, crutches, canes or braces

or who otherwise have difficulty using steps. The platform may be marked to indicate a preferred

standing position.

(d) Securement devices—(1) Design load. Securement systems on vehicles with GVWRs of

30,000 pounds or above, and their attachments 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 longitudinal direction of up to 2,500 pounds per securement leg or clamping

mechanism and a minimum of 5,000 pounds for each mobility aid.

(2) Location and size. The securement system shall be placed as near to the accessible entrance

as practicable and shall have a clear floor area of 30 inches by 48 inches. Such space shall adjoin,

and may overlap, an access path. Not more than 6 inches of the required clear

floor space may be accommodated for footrests under another seat provided there is a minimum of

9 inches from the floor to the lowest part of the seat overhanging the space. Securement areas

may have fold-down seats to accommodate other passengers when a wheelchair or mobility aid is

not occupying the area, provided the seats, when folded up, do not

obstruct the clear floor space required.

(3) Mobility aids accommodated. The securement system shall secure common wheelchairs and

mobility aids and shall either be automatic or easily attached by a person familiar with the system

and mobility aid and having average dexterity.

ABREVIATIONS

ADA: Americans with Disabilities Act

ANSI: American National Standards Institute

CFR: Code of Federal Regulations

ISO: International Standardization Organization

NIDRR: The National Institute on Disability and Rehabilitation and

Research

RERC: Rehabilitation Engineering Research Center

RESNA: Rehabilitation Engineering and Assistive Technology Society of North America

SAE: Society of Automotive Engineers

WTORS: Wheelchair Tiedown and Occupant Restraint Systems

WTS: Wheelchair Transportation Safety

ANSI/RESNA/ISO

Since the early 1980’s ANSI, RESNA and ISO have collaborated together to develop uniform and

meaningful standards and measurements in regards to wheelchairs. ANSI and RESNA have had

more concentrated efforts in items such as how a wheelchair is measured and tested. ISO has

focused on minimum and maximum attributes of wheelchairs; i.e. mass to weight ratio, durability

going over curbs repeatedly, braking power and ability to hold, etc.

SAE J2249

SAE J2249 is a Report by the Society of Automotive Engineers

(1996) on “Best Practices” for safe wheelchair securements and

passenger restraints. This has become to be known as WTORS

which is a voluntary but recommended Best Practice using four –

point anchors and securements on wheelchairs and three point restraints for the passenger during

transportation. The key elements are as follows:

• It specifies design requirements, test methods, and performance requirements for WTORS,

requirements for manufacturer’s instructions in installers and users, and requirements for

product marking and labeling.

• It specifies test procedures and performance requirements for a 30-mph (48-kph), 20-g

frontal impact.

• It specifies test procedures and performance requirements for webbing slippage at

adjustment devices of strap-type wheelchair tiedowns, and for partial but ineffective

engagement of wheelchair tiedowns and tiedown components.

• It applies to WTORS used with forward-facing wheelchair-seated adults and children from

age six.

• It applies to passengers and drivers of personally licensed motor vehicles as well as to

passengers of motor vehicles used in public and school transportation.

• It applies to all types of WTORS, including those that use docking type wheelchair

tiedowns.

• It applies to components and subassemblies of WOTRS that manufacturers may want to

certify as being in compliance with SAE J2249.

WTORS

When complying with a WTORS system and proper

securement is achieved, it is presently the most secure

method of transportation for an occupant on a wheelchair.

However even the best system has its disadvantages:

• Invasion of personal space.

• Lengthy securement times.

• Requires operator/attendant for securement.

• Securement straps easily soiled or damaged.

• Proper securement points undefined.

• Extensive training/retraining to keep drivers proficient to most current standards.

WC19-COMPLIANT WHEELCHAIRS

WC 19 is a voluntary industry standard for designing, testing and

labeling a wheelchair that is ready to be used as a seat in a motor

vehicle. A WC19 wheelchair has:

• Four permanently attached and labeled securement points that

can withstand the forces of a 30 mph, 20 g impact.

• Specific securement point geometry that will accept a

securement strap or hook.

• Securement point locations that allow easy access to aisle side and wall side securement

points.

• A clear path of travel that allows proper placement of vehicle mounted occupant safety belts

next to the hip/pelvic area on the body.

• Anchor points for an optional wheelchair anchored pelvic safety belt that is

designed to withstand a 30 mph, 20 g impact that has a standard interface on it that allows

it to connect to a vehicle-anchored shoulder belt.

INTEGRATED SEATBELT DESIGN

Another technology that is the target of innovation and

research is seatbelt design. Recent studies have shown

that seatbelts are rarely used properly on passengers

seated in wheelchairs. In addition, seatbelts are often

insufficiently adjustable for a range of individuals seated in

a wheelchair. Seatbelts or wheelchair occupant restraints

are only effective if they are positioned well and snug on the individual's pelvis and upper body

(crossing the sternum and mid area of the collar bone). Tests have shown that integrating both

good belt fit and proper location of the belts on the upper body and pelvis achieve a ride as safe

as a passenger not seated on a wheelchair. A wheelchair with an integrated seatbelt offers a

consistent custom fit that is properly snug. Additionally the person

who uses a wheelchair with an integrated seatbelt is no longer

dependent on an attendant for proper placement and fit of vehicle-

anchored occupant restraints.

Many individuals who use a wheelchair already use some type of

pelvic belt or chest strap for postural support. These postural

supports are often mistakenly relied upon during motor vehicle

travel, which can result in occupant injury during a motor vehicle impact when a postural support

breaks loose from the wheelchair frame. In some cases, a wheelchair integrated occupant

restraint system could replace postural chest straps or pelvic straps, and thereby provide

occupant protection as well as postural support during transportation. Replacing the function of a

postural belt with a safety restraint would need to be individually evaluated by a clinical expert.

Wheelchair integrated occupant restraints would also require knowledge of the user's ability to

independently buckle or unbuckle a seatbelt. When transporting a small child, it is desirable to

have a seatbelt buckle that can only be operated by a caregiver. User studies and design efforts

are ongoing to re-design the user interface of buckles and fittings to keep them safe, as well as

easier to use for individuals with limited hand function.

AUTOMATED WHEELCHAIR DOCKING

Automated docking technology to secure wheelchairs in vehicles may be a part of future

innovations. This type of wheelchair securement gives the

passenger seated in a wheelchair the freedom of independent

securement. Due to the fact that there is only one way to dock a

wheelchair into a docking

securement system, it will be

hard for the passenger seated in a wheelchair to make a

mistake. If the individual cannot dock the wheelchair

independently, it will be easier and less time consuming for a

driver or caregiver to secure the wheelchair. The need for

driver training on how to secure a wide variety of wheelchairs can almost be eliminated.

REAR FACING WHEELCHAIR CONTAINMENT

Another innovation that has been slowly entering the U.S. market is rear-

facing wheelchair containment. This technology can only be used on large

transit vehicles and is not safe for school buses or smaller para-transit

vehicles. Here is how it works. The person using a wheelchair boards in the

typical manner but then maneuvers into an area on the left or right side of the bus and backs up

against a padded barrier, facing towards the rear of the bus. In this location, no other securement

device is required, except a vertical floor to ceiling post or flip-down armrest-type barrier, located

on the aisle side of the wheelchair space. In addition, vehicle-mounted occupant restraints are not

required. The key advantage of this non-invasive, wheelchair containment arrangement is that it

allows the user to enter and exit the vehicle independently without any intervention by the bus

operator. Furthermore, any present-day wheelchair can use this technology and no additional

hardware is needed on wheelchairs. A standard providing guidelines for testing and designing this

technology is nearing completion.

There are a couple of reasons that this innovation only works in large transit buses. In general,

transit buses are a very safe means of people transport for both seated and standing passengers.

They are usually the largest (heaviest) vehicle on the street and travel at relatively low speeds.

This means, for example, that if you are a rider in a frontal collision on a large versus a small

transport vehicle, assuming that all other factors are the same, you will experience lower injury

producing forces acting on your body. The barrier behind the rear-facing wheelchair is designed

to limit forward movement of the wheelchair and the occupant's upper torso and head. Sideways

movement of the wheelchair is minimized by the lateral barriers such as an aisle-side post and

the vehicle wall. Rebound movement is minimized by the energy absorption of the barrier and the

wheelchairs brakes.

INJURIES TO INDIVIDUALS OCCUPYING WHEELCHAIRS DURING VEHICLE

TRANSPORTATION :

A few recent studies have focused directly on injuries to individuals who use wheelchairs as seats

in motor vehicles. In one cross-sectional study, 596 wheelchair users were interviewed about their

involvements in motor-vehicle crashes and injuries they may have sustained (T. Songer et al.,

2004). The screening interviews for the 596 subjects were followed by more in-depth surveys of

336 participants who used their wheelchair as a seat in a public or private vehicle, or both (Songer

et al., 2005). More than one-quarter of the respondents (28.7%) reported sustaining at least one

injury while using motor-vehicle transportation in the previous three years. Crash involvement was

reported by 14.9% of the study population at an estimated rate of 10.6 events per 100,000 miles

traveled. Of 65 respondents who reported being involved in at least one crash, 55 provided further

details about their crash experience. Of these, 38% reported being injured in a crash, and two-

thirds of the injured occupants required medical attention. Thus, 6% of the 336 occupants

reported being injured while traveling seated in their wheelchair, which amounts to 3.6 injury

events per 100,000 miles traveled. This is 45 times higher than the injury rate for the general

automotive population of 0.08 injuries per 100,000 miles traveled (NHTSA, 2009)

Recent studies provide increasing evidence that a large percentage of injuries and fatalities to

wheelchair-seated travelers are being caused in non-collision events, such as abrupt vehicle

turning maneuvers and hard braking (Frost & Bertocci, 2007, 2009a). The evidence further

indicates that these injuries are due to the lack of proper wheelchair securement that result

in the wheelchair moving within the vehicle or tipping over, and/or non-use or improper use

of belt restraints by wheelchair passengers that result in the wheelchair occupant coming out

of the wheelchair seat, resulting in injuries from contact with the vehicle interior (Frost & Bertocci,

2009b). Most wheelchair users have limited ability to stabilize their wheelchair or their position in

the wheelchair by bracing or by grabbing vehicle components with their hands during these low-g,

non-collision events, and therefore often sustain serious or fatal injur ies in events where

other passengers are uninjured (Fitzgerald et al., 2007). Songer et al. (2005) reported that

non-crash injuries were most frequently reported to have occurred during entering and exiting

vehicles (15.8% of respondents; 43.1 events per 100,000 miles traveled). However, injuries

resulting from sudden vehicle maneuvers were reported with a similar frequency by 15.7% of

respondents or at a rate of 31.8 events per 100,000 miles traveled. Most non-crash injuries arose

from sudden braking (50%) or sharp turning (33.3%), which resulted in the wheelchair tipping over

(33%), securement failure (22%), or the occupant falling out of the wheelchair seat (15.3%). While

these studies are some of the first to report on frequencies and causes of injuries sustained by

wheelchair users in motor vehicle transportation, the study populations represents a convenience

sample and selection bias and the ability of participants to accurately report on past events may

influence the results. However, the results document the general types and characteristics of

injury events that are occurring to wheelchair-seated travelers, and raise concerns about the

relatively high risk of injuries to occupants seated in wheelchairs.

REDUCING OR ELIMINATING SECUREMENT ERRORS

All stakeholders in the transportation of wheelchairs; passengers, drivers, attendants, supervisors,

and the entities need to understand their role in providing the safe riding option.

• Passengers need to understand the need to transfer out of non – compliant WC 19

wheelchairs when they are able to. They need to keep their wheelchairs/scooters clean

and securement points accessible. They need to use both seatbelt and shoulder belt

options for the safest option.

• Drivers need to make sure that the securement task is completed to standard each and

every time. That they take the time necessary to complete the securement and the

passenger is accommodated.

• Attendants need to assist in their capacity as a caregiver.

• Supervisors need to make sure that drivers are complying with the standards. They also

need to make sure that sufficient time is allotted to accommodate the passengers so that

the drivers do not feel as though they need to rush.

• Entities need to provide the resources necessary to accomplish the safe securements and

restraints of wheelchairs and the passengers. Assist in educating the public and drivers,

encouraging the passengers to transfer out of non WC19 wheelchairs, and enforcing

policies, i.e. size and weight that support safe transportation for all passengers.

THE BENEFITS OF SUPPORTING THE USE OF WHEELCHAIRS DESIGNED

TO FUNCTION AS A MOTOR VEHICLE SEAT

Transportation providers should encourage the purchase of wheelchairs designed for use as a

motor vehicle seat by regular users of their services to increase driver efficiency and to reduce

driver effort, errors, and injury potential. These wheelchairs will facilitate ease and proper use of

WTORS, which will improve best practice and reduce overall liability.

Recognizing the value of using and paying for wheelchairs designed to function as a motor vehicle

seat requires greater knowledge among many stakeholders; consumers, rehabilitation/seating

clinicians, rehabilitation counselors, suppliers, manufacturers, transportation agencies, driver

educators, payers and policy makers. Creating equivalent safety for individuals who ride seated in

wheelchairs extends to them the “equal protection” demanded by law, reduces human suffering

and loss of life that may result from not exercising reasonable caution, and promulgates best

practice supported by peer-reviewed research. RESNA encourages all of those in leadership

positions involved in the wheelchair transportation community to do the right thing and influence

the broader recognition and use of products designed to improve safety for those who use

wheelchairs as seats during transportation.

RESOURCES

ANSI – AMERICAN NATIONAL STANDARDS INSTITUTE

ISO – INTERNATIONAL STANDARDIZATION ORGANIZATION

NTI – NATIONAL TRANSIT INSTITUTE

NIDRR – THE NATIONAL INSTITUTE ON DISABILITY AND REHABILITATION AND

RESEARCH

RERC – REHABILITATION ENGINEERING RESEARCH CENTER

RESNA – REHABILITATION ENGINEERING AND ASSISTIVE TECHNOLOGY SOCIETY

OF NORTH AMERICA

SAE – SOCIETY OF AUTOMOTIVE ENGINEERS