University of Manitoba, Transport Institute


Report for:

Manitoba Taxicab Board

Evaluation of Accessible Taxicab
and Handicab Van Safety Requirements

The consultant would acknowledge the ready assistance provided by all those interviewed, by George Orle - Chairman and the Taxicab Board, by Glen Cochrane - Board Secretary, Gary Lang and other members of the Department of Highways and Transportation, and by Dr. John Heads and Debbie Fiorucci of the University of Manitoba Transport Institute.

Paul Murphy
Research Associate
University of Manitoba, Transport Institute

Executive Summary

Objective of the Project

The objective of the project is to evaluate the appropriateness and effectiveness of the accessible taxicab and handi-cab van vehicle safety requirements contained in the Taxicab Regulation. It is to provide recommendations to the Manitoba Taxicab Board on whether the regulation should be amended and if so, how it can be improved.

Research Methods for Project

The consultant contacted members of the manufacturing industry, providers of the transportation services, and consumers.

In the first two cases, questionnaires were produced and distributed to provide a basis for discussion. These discussions were carried out between December 1995 and January 1996In the third case, the consultant, at random, contacted consumers, recognized advocates, and leaders of advocacy organizations for Winnipeg's mobility challenged and generated a discussion around Winnipeg's accessible vehicle standards and how it related to the quality of service.

Background

The Canadian Standards Association guideline CAN3 -- D 409 -- M84, entitled "Motor Vehicles for the Transportation of Physically Disabled Persons," is a recommended minimum safety standard for motor vehicles designed, manufactured, or converted for the purpose of transporting persons with physical disabilities. This standard, originally developed and published in 1984 at the request of the "Canadian Council of Motor Transport Administrators" (CCMTA), was revised in 1992, now entitled the CAN/CSA D 409 -- 92

In 1991, the Manitoba Taxicab Board adopted the D 409 by reference in a regulation under the Taxicab Act -- 209/91, as one of the licensing requirement's for accessible taxicab and handicab van vehicles. The vehicles in service prior to incorporation of D 409 into the Taxicab Regulation are not required to meet the standard.

They were required to meet the now entitled, Manitoba Highway Traffic Act Regulation 75/94)

It is important to remember that the D 409 standard, and subsequent amendments were originally written, with the strong involvement of manufacturers of accessible vehicles. Therefore, this standard is largely based on industry standards and practices.

Comments, Recommendations, and Options

Although the service industry in Winnipeg was supportive of this project, they had reservations as to whether there would be useful action on the project. Many comments were presented to this effect.

Stories were presented about the Board's and its inspectors' "uneven" implementation and "differing interpretations" of the Taxicab Act regulations. An extreme view was that, "the Board will do what it feels like and the opinions of the industry just do not matter".

Criticism of a regulator in terms like this is never unusual and may even be seen as comfirming the regulator's independence. Neverthelss, the following recomendation should be considered; .

RECOMMENDATION

That the Taxicab Board, and its staff, need to review its programs of industry notification of new regulation implementation, plus its enforcement of taxi regulations as a whole.

RECOMMENDATION

If the standard is implemented under the Highway Traffic Act, a method of inspection to confirm compliance must then be established.

RECOMMENDATION

That manufacturers/converters present their products for yearly or two yearly inspections to an identified authority to establish their compliance to the D 409, or alternate standard. This would allow them to present their documentation for viewing as required.

RECOMMENDATION

The Board needs to incorporate specific inspection criteria within its regular inspection practices to insure that components used in these vehicles are in safe working conditions.

RECOMMENDATION

If a standard is maintained within the province, it must to some extent cover used vehicles with reason.

RECOMMENDATION

The Board may want to maintain a membership in, or refer to NMEDA, the National Mobility Equipment Dealers Association. This is a resource center and international information

Any questions or comments should be directed to:

NATIONAL MOBILITY EQUIPMENT DEALERS ASSOCIATION
909 E. SKAGWAY AVE.
TAMPA, FL 33064
1-800-833-0427
FAX 1-813-931-4683
E-MAIL: ACCESSUNL@AOL.COM

RECOMMENDATION

The standard does need to be amended.

RECOMMENDED IMPLEMENTATION OPTIONS

Option 1:

The Board could leave all as it stands and deal with the compliance issues as they arise and rely on what the manufacturer, or operator supplies as confirmation of compliance.

It is the expectation that at some point a jurisdictional issue would be presented challenging which standard held precedence, the D 409 or the 75/94.

Option 2:

The opposing alternative would be to remove both the D 409 from the Taxicab Act and the 75/94 found in the Highway Traffic Act.

This would allow the industry to provide what it felt the market would accept. Ultimately the market would establish the industry standard by using the service it most desired.

Although the Board and the Department have no legal obligation to continue with or replace the D 409 or 75/94 standard with one equal or greater, it does have a moral responsibility to maintain some form of standard to protect the public.

Option 3:

The Board could remove the D 409 from the taxicab act and recognize the 75/94 found in the Highway Traffic Act.

The 75/94 does not directly address the needs of the accessible taxi industry, and would require some amendment to provide for increased standards for restraints.

Option 4:

The Board and the Department could implement a new standard that would be covered under the Highway Traffic Act. This would allow an even application of rules for accessible transportation throughout the province.

This standard would be designed so as to encompass all the industry concerns and needs and serve to clarify what is presently a confused situation.

The standard would not move far from the spirit of the D 409, but would allow for some flexibility and recognition of the different class's of vehicles needed to meet the market needs.

The Board and the Department would then amend the regular safety inspections to include and recognize specific features that would be incorporated in these vehicles to maintain safety standards.


CONTENTS

FIRST SECTION
Page 2 Objectives of the Project
Page 3 Background

SECOND SECTION
Page 4 Consultation with Service Providers

THIRD SECTION
Page 11 Consultation with Manufacturers/Converters

FOURTH SECTION
Page 18 Viewpoint of Clients

FIFTH SECTION
Page 19 Comments, Recommendations, and Options

SIXTH SECTION
Page 24 Proposed Replacement Standard
Page 69 Recommended Compliance Inspection Report
Page 74 Safety Inspection Amendments

SEVENTH SECTION - APPENDIX
Page 75

DUE TO THE SIZE OF THIS SECTION, IT IS AVAILABLE FOR VIEWING OR COPYING AT THE MANITOBA TAXICAB BOARD. IT IS RECOMMENDED BY THE CONSULTANT THAT IT BE REVIEWED PRIOR TO READERS INTERPRETATIONS OR CONCLUSIONS

A) Vehicle Examples and Related Costs

B)

1) CSA D 409 92 "Motor Vehicles for the Transportation of Persons with Physical Disabilities"
1a) CSA Z 605 "MASOR"
2) Taxicab Act, Taxicab Regulation 209/91
3) Manitoba Highway. Traffic Act Regulation 75/94
4) Quebec Highway Safety Code "Road Vehicles Adapted for the Transportation of Handicapped Persons", R.S.Q., c. C-24.2, section 621, paragraph 2.1
5) B.C. Transit - "Mobility Aid Lift-Equipped Custom Transit Vans"
6) Highway Traffic Act Regulation 76/94

First Section

Objective of the Project

The objective of the project is to evaluate the appropriateness and effectiveness of the accessible taxicab and handi-cab van vehicle safety requirements contained in the Taxicab Regulation. It is to provide recommendations to the Manitoba Taxicab Board on whether the regulation should be amended and if so, how it can be improved.

Background

The Canadian Standards Association guideline CAN3 -- D 409 -- M84, entitled "Motor Vehicles for the Transportation of Physically Disabled Persons," is a recommended minimum safety standard for motor vehicles designed, manufactured, or converted for the purpose of transporting persons with physical disabilities. This standard, originally developed and published in 1984 at the request of the "Canadian Council of Motor Transport Administrators" (CCMTA), was revised in 1992, now entitled the CAN/CSA D 409 -- 92. (Append. 1)

In 1991, the Manitoba Taxicab Board adopted the D 409 by reference in a regulation under the Taxicab Act -- 209/91 (append. 2), as one of the licensing requirement's for accessible taxicab and handicab van vehicles. The vehicles in service prior to incorporation of D 409 into the Taxicab Regulation are not required to meet the standard.They were required to meet the now entitled, Manitoba Highway Traffic Act Regulation 75/94. (Append. 3)

It is important to remember that the D 409 standard, and subsequent amendments were originally written, with the strong involvement of manufacturers of accessible vehicles. Therefore, this standard is largely based on industry standards and practices. It was the understanding that the manufacturers and converters of these vehicles would be self-certifying in these standards, however, this became difficult to assure in practice and no methods or procedures of confirmation to compliance were entrenched by the implementing board of 1991.

Second Section

Consultation with Service Providers

A questionnaire with covering letters was developed and presented to the 7 accessible taxicab and handicab van industry registered companies, as well as a section of independent operators, throughout the city of Winnipeg. The goal of the questionnaire was to assist in fostering discussion about the D 409 standard and its implementation.

Independent telephone interviews were held between the research associate and 5 representatives of the Winnipeg service providers. The general tone was positive towards a project that would clarify the confusion around the D 409 standard, its implementation, and its implications to the industry.

All persons interviewed expressed concern relating to the economic impact that such a standard could have on their industry. It was made clear that economic considerations as well as safety were included in this report.

At the date of completion of this project, the accessible taxi industry had 23 vehicles in service. This breaks down into the following:

The eight Chevy Astrovans are not within compliance of the D 409 92 standard, established through a "test" inspection in February 1994, and confirmed by their owners at a meeting held at the Taxicab Board May 10, 1994.

Areas in particular question were:

N.B. THE ABOVE REGULATIONS ARE FOUND IN THE D 409 92, AS RECOGNIZED UNDER THE TAXICAB ACT.

In relation to the handivans, and at the date of project completion, there are 65 handivans licensed in Winnipeg. This breaks down to:

N.B. THE ABOVE NUMBERS AND DISTRIBUTIONS MAY VARY.

There is a mix of Ford, GMC/Chevy, and Chrysler/Dodge full sized short, standard, and maxi wheelbase vans.

At the time of completion of this report, none of the handivans complied with the D 409 92 standard. It must be noted that several of the handivan operators have taken some steps toward compliance, by adding raised tops and raised doors to their vehicles. In virtually every case, however, these operators are using wheelchair restraining systems that would not pass the CSA D 409 or the Z605 requirements. Further, these systems would not pass the Manitoba Highway Traffic Act Regulation 75/94.

It is concerning to note that some operators are either ignoring, or ignorant of the fact that the D 409 standard is required under the Taxicab Act.

In other cases, it was represented to the consultant that because the status of D 409 is unclear to the industry, that it is therefore not required.

An interesting example can be found in a recent inspection of a handivan. It was found that it not only failed to pass the D 409 standard, but failed the M.H.T.A.R. 75/94.

Fax contact list, accessible vehicle operators/owners

Unicity Taxi Ltd.
340 Hargrave Place
Winnipeg, Mb.R3C 0X5
Phone 204-925-3131
fax 204-956-5736
Attn:Brian Falco, Mgr.

Gurdev Singh, Board # 134
Balwant Khaira, Bd. # 013
Satish Kumar, Bd. # 216
Kamaljit Johal, Bd. # 463
Sumernam Gosal, Bd. # 408

Blueline Taxi and Handi-Helper Transit
754 Logan Ave.
Winnipeg, Mb.R3E 1M9
Phone 204-774-6047
Fax 204-774-3800
Attn: Victor Kumar, V.P.

Anish Vij Bd. # 826, 718
Diomedes Valdez Bd. # 757
David Crundwell Bd. # 734

Vital Transit Service Ltd.
1850 Selkirk Ave.
Winnipeg, Mb.R2R 0N6
phone 204-633-2022
fax 204-697-1232
Attn: Gary Paull

First Class Transportation/Messenger Service Inc.
68 Juno Street
Winnipeg, Mb.R3A 1H9
phone 204-774-6881
fax 204-786-5454
Attn: Greg Dickens, G.M.

Spring Taxi
880 Logan
Winnipeg, Mb.R3E 1N8
phone 204-783-0538
fax 204-774-6232
Attn: Tom Springman, Pres.

Arrow Wheel-Chair Transportation Inc.
48 Ostafiew Farm Rd.
Winnipeg, Mb.R2R 1G1
phone; 204-943-9324
fax 204-956-7462
Attn: Sam Troia

Gull Wing Transit Services Ltd.
204-165 Stafford St.
Winnipeg, Mb.R3M 2W9
phone 204-475-7979
Attn: Ken Brown

Transport Institute

Accessible Transportation Industry -- Service Providers

Questionnaire

DATE: ________

COMPANY:__________________________________________________

CONTACT:________________________________TITLE: ___________

PHONE: _________________ FAX: _________________

NUMBER OF YEARS                               NUMBER OF ACCESSIBLE
PROVIDING ACCESSIBLE                          TAXI VANS IN SERVICE
SERVICE:______________                        ________________

NUMBER OF HANDIVANS                           NUMBER METER
IN SERVICE                                    EQUIPPED______________
________________                                

NUMBER UNDER CONTRACT SERVICE________________

PLEASE PROVIDE THE FOLLOWING DETAILS ON EACH VEHICLE IN SERVICE: 

MAKE: _______________     YEAR: ________      MODEL: WINDOW/CARGO

DATE VEHICLE PLACED IN SERVICE: __________

IF PLACED INTO SERVICE AFTER SEPTEMBER 1991, DOES VEHICLE COMPLY WITH D 409 92 STANDARD

DID YOU HAVE CONVERSION DONE TO VEHICLE, OR WAS THE VEHICLE CONVERTED WHEN PURCHASED.

IF POSSIBLE PLEASE CONFIRM IF THE VEHICLE WAS CONVERTED AS A *NEW VEHICLE OR AS A USED ONE.

( * = ALTERED PRIOR TO, OR AT TIME OF FIRST REGISTRATION)

IF MODIFIED AS A NEW VEHICLE, IS A COMPLIANCE LABEL FROM THE CONVERSION COMPANY LOCATED ON THE DRIVERS DOOR PILLAR

(PROVIDE CONVERTER NAME AND VEHICLE CONVERSION DATE)

IF MODIFIED AS A USED VEHICLE, DID THE CONVERSION COMPANY PROVIDE WRITTEN CONFIRMATION THAT THE VEHICLE MEETS THE REQUIREMENTS OF THE D 409 92 STANDARD.

(IF POSSIBLE PLEASE PROVIDE A COPY OF THIS DOCUMENT AND/OR THE CONVERSION COMPANIES NAME AND PHONE NUMBER )

TYPE OF WHEELCHAIR RESTRAINT DEVICES USED IN YOUR VEHICLES

ARE SEATBELTS INCLUDED AND AVAILABLE FOR ALL WHEELCHAIR PASSENGERS, AND AMBULATORY SEATING POSITIONS

(IF POSSIBLE PLEASE PROVIDE A COPY OF MANUFACTURER DOCUMENTATION AND/OR THE COMPANIES NAME AND PHONE NUMBER)

IS VEHICLE LIFT EQUIPPED OR IS A RAMP USED. SIDE OR REAR WHEELCHAIR ENTRY TYPES OF TRAINING PROVIDED TO DRIVERS

Questionnaire Guidelines

It is recognized that you may not wish to answer all questions. However, it would be most useful, and greatly appreciated, if you would complete as much as possible.



Third Section

Consultation with Manufacturers/Converters

"Manufacturer" means a person engaged in the business of manufacturing motor vehicles;

"Manufacture" includes the process of assembling or altering a motor vehicle in order to complete that motor vehicle for the purpose of sale of that motor vehicle to the first purchaser at the retail level;

A questionnaire was presented to the accessible taxicab and handicab van manufacturing industry located throughout Canada. The goal of the questionnaire was to assist in fostering discussion about their experiences applying the D 409 standard, while meeting the primary goal of compliance to the CMVSS.

Telephone interviews were held between the research associate and nine companies identified from a Transport Canada manufacture and converter list of accessible taxicab and handicab van manufacturers. These companies were chosen considering the following criteria:

  1. proven track record of compliance, and/or

  2. involvement in supplying to the Winnipeg industry

Eight of the companies identified themselves as "Final Stage Manufacturers", their primary business being modification of new vehicles. A final stage manufacturer is a company that alters a vehicle that has been completed and certified by an OEM, or has been provided with "incomplete vehicle documents" with the understanding that the vehicle is being completed and certified "prior to the first purchaser".

All the manufacturers interviewed market vehicles that they claim to meet the D 409 92 standard. It is the researcher's opinion that these vehicles do meet this standard, but final confirmation of documentation and visual inspection is required to verify this.

Only one company identified itself as being primarily a modifier of used vehicles, identified in the industry as being a "Custom Converter". This is a company that alters vehicles after they have been purchased, registered, and used for a period of time prior to conversion, or alteration. (Custom converters can also modify new vehicles, but the costs can be quite high due to certification costs.)

The best clarification of a used vehicle would be one that has been purchased from the first purchaser or, driven for a significant number of kilometers. The original intent of the new vehicle purchase should not have been to alter the vehicle.

In every interview there was positive interest in the project and review. In the case of the manufacturers, all of which market their vehicles interprovincially and into the U.S., there was particular concern about additional or radically altered requirements for their vehicles. They all cited the uneven levels of standards, beyond the CMVSS, that they must deal with between the provinces.

An ideal example of this is the fact that the Province of Ontario still recognizes the original D 409 M84 standard under its Highway Traffic Act. This in itself makes it difficult for manufacturers to produce vehicles, while each jurisdiction in Ontario interprets parts of the standard differently. (i.e. door opening sizes)

They all shared in the frustration of not having available a third party to confirm compliance to D 409, and the wide variations in interpretation, not only between the provinces that recognize either form of the D 409, but between inspectors within each province.

They were all supportive of the Manitoba desire to review the standard and develop some clarification of the standards intent.

All the manufacturers pointed out that the D 409 standard was originally written, including subsequent amendments, with the strong involvement of manufacturers of bus-styled accessible vehicles. Therefore this standard is largely based on industry standards and practices for large vehicle manufacturer, (i.e. Handi Transit styled vehicles) it does not properly recognize or allow for the difficulties of the standard to altering full size vans and mini-vans. In every interview it was expressed that this concern be considered and that, in addition, provisions be made to review new technologies within any clarification or alteration of the standard.

In the case of minivan-based accessible taxi manufacturers, they identified and discussed the greater difficulty they have in meeting the D 409 standard. Although in almost every case they seem to have met the requirements, they identified small alterations or amendments that could decrease the capital costs to the operator significantly, but not jeopardize safety.

A common example used was the emergency exit dimension requirement of 45" x 32". The common vehicles used in this industry is the Chrysler mini-van. Its clear opening size on the side emergency door is 44" x 29". It may be reasonable to consider reducing the standard to these dimensions, as the cost to meet the greater opening size,(a reported average of $5,000.00), is considerable, with minimum overall gain.

A proposal was presented to all the manufacturers asking if they were willing to present yearly or two yearly independent engineering reports, or their products for inspection so as to verify compliance for sale in Manitoba.

The idea of presenting their documentation exclusively was not well received, citing concern for confidentiality primarily. The notion was also presented as to who would hire the independent engineer to review compliance. If it were up to the manufacturer, it would not be an independent report, and if it was the province, who would be responsible for costs incurred from the inspection?

The manufacturers were clearly supportive of the second alternative. They are willing to present their products for yearly or two yearly inspections, to an identified authority, to establish their compliance to the D 409, or alternate standard. This would allow them to present their documentation for viewing as required.

Manufactures List

Dynamic Specialty Vehicles Ltd.                     Shawn Francis
18550 96th Ave                                      604-882-9333
Surrey, B.C.                                        604-882-3555 (fax)
V4N 3P9                 Handivans, Chrysler

Creative Carriage Ltd.                              Bob Nunn
330 Sheldon Drive                                   519-740-4801
Cambridge, On.                                      519-740-2751 (fax)
N1T 1A9                 Chrysler minivan taxi, raised roof-side entry

Freedom Motors                                      Tony Collenbrander
3190 Ridgeway Drive, Unit 8                         905-828-1996
Mississauga, On                                     905-828-4112 (fax)
L5L 5S8                 Chrysler minivan taxi
                        a) Low floor side entry
                        b) rear entry low floor, (compliance questionable)

Bahn Mobility Corp.                                 Andrew Bayer or Vernon Hahn
8 Grand Avenue                                      519-744-8754
Kitchener, On.                                      519-744-6861 (fax)
N2K 1B3                 Handivans

A Girardin Inc.                                     Sylvain Girardin
Route Trans Canadienne                              819-477-3222
Drummondville, Pq.                                  819-477-9339 (fax)
J2B 6V4                 Mini busette,

Ricon Canada                                        Pierre Charlebois
14750 Ouest Boul Gouin                              514-990-8705
Pierrefonds, Pq.                                    514-696-6319 (fax)
H9H 1B2                 Handivans, Chrysler minivan taxi

Professional Components                             David Smith,
                                                    Eng.-Bruno Sutter
P.O. Box 2175                                       604-656-6165
Sydney, B.C.                                        604-655-4334 (fax)
V8L 3S6                 Handivans, Ford, Chrysler, GMC/Chevrolet

Care Transportation International                   Lynnwood Farr
5810 Cote De Liesse                                 800-665-5587
Mount Royal, P.Q.                                   514-343-5181 (fax)
H4T 1B1                 Low Floor Chrysler minivan taxi

Custom Coach Works (1979) Inc.                      Bill Chester
1365 Border St.                                     204-633-4243
Winnipeg, Mb.                                       204-633-4243 (fax)
R3B 0N5                 Custom converter, limited compliance ability

Transport Institute

Accessible Transportation Industry

Manufacturers/Converters

Questionnaire

DATE: ________

COMPANY: _______________________________________________________ CONTACT: _____________________________ TITLE: _______________ PHONE: _________________ FAX: _________________ IS YOUR COMPANY A: FINAL STAGE MANUFACTURER ____________ (NEW VEHICLES PRIMARILY ) CUSTOM CONVERTER ____________ (USED VEHICLES PRIMARILY ONE OFF'S ) PLEASE PROVIDE INFORMATION ON TYPES OF VEHICLES ALTERED: MINI-PARATRANSIT,(.HANDIVANS): ________________________ ACCESSIBLE TAXI-VANS: ________________________ INCLUDING CONFIRMATION ON COMPLIANCE TO: A) CSA D 409 92 B) CMVSS ( AS APPLICABLE ) PLEASE PROVIDE CONFIRMATION OF PRODUCT LIABILITY COVERAGE AND VALUES: NUMBER OF COMMERCIAL ACCESSIBLE VEHICLES IN SERVICE IN: MANITOBA: ________________ WINNIPEG: ________________

TYPE OF WHEELCHAIR RESTRAINT DEVICES USED IN YOUR VEHICLES

ARE SEATBELTS PROVIDED AND/OR AVAILABLE FOR ALL WHEELCHAIR PASSENGERS AND AMBULATORY SEATING POSITIONS

TYPES OF TRAINING PROVIDED TO DRIVERS

IS YOUR COMPANY WILLING TO HAVE PRODUCTS INSPECTED ON A YEARLY, OR TWO YEAR BASIS TO CONFIRM COMPLIANCE TO CSA D 409 92 STANDARD

OR

IS YOUR COMPANY ABLE TO PROVIDE A YEARLY, OR TWO YEAR INDEPENDENT ENGINEERS, OR TECHNOLOGISTS REPORT CONFIRMING COMPLIANCE TO CSA D 409 92 STANDARD

Questionnaire Guidelines

It is recognized that you may not wish to answer all questions. However, it would be most useful, and greatly appreciated, if you would complete as much as possible.



Fourth Section

Viewpoint of Clients

The consultant took the opportunity during the research to approach many consumers, recognized advocates, and leaders of advocacy organization for Winnipeg's mobility challenged. This generated a discussion around Winnipeg's accessible vehicle standards and how it related to the quality of service.

The primary concern heard in all discussions was that of safety and equality. It is important to understand the meaning of equality in this context, however.

Equality, meant that the vehicles do not need to meet a higher standard than other "for hire" vehicles. Equality also meant that as paying clients, they have access to vehicles that are of the same class level of service as passenger cars.

An example presented for discussion was based on fire extinguishers and first aid kits. If other cabs within the industry do not require such equipment, then why should accessible vehicles in the "for hire" industry?

As early as the J.S. Merrett report: "Review of Cost of Operations Viability, Policies and Regulation, Respecting the Wheelchair Taxi Industry in Winnipeg, Part 2, Impact of Policy and Changes," prepared for Highways and Transportation and presented in July 1987, the consumers identified the need to improve vehicle standards to meet the needs of an active mobility challenged clientele. Greater interior headroom, higher door openings, and less steep access ramps were specifics highlighted at the time to meet the needs of the larger and heavier electric wheelchairs, as well as respirator equipped devices.

When asked specific questions or opinions about the technical aspects of the D 409 92 standard, all those interviewed declined to answer. All felt they did not have the technical understanding of the standard, or its structure.



Fifth Section

Comments, Recommendations, and Options

Although the service industry in Winnipeg was supportive of this project, they had reservations as to whether there would be useful action on the project. Many comments were presented to this effect.

Stories were presented about the Board's and its inspectors' "uneven" implementation and "differing interpretations" of the Taxicab Act regulations. An extreme view was that, "the Board will do what it feels like and the opinions of the industry just do not matter".

Criticism of a regulator in terms like this is never unusual and may even be seen as comfirming the regulator's independence. Neverthelss, the following recomendation should be considered;

RECOMMENDATION

That the Taxicab Board, and its staff need to review its programs of industry notification, of new regulation implementation, plus its enforcement of taxi regulations as a whole.

It was the original expectation that the manufacturers and converters of these vehicles would be self-certifying in these standards. However, this became difficult to insure in practice and the board had limited methods and procedures of confirmation to compliance entrenched by the implementing board of 1991. The only alternative would be a process called "type approval", commonly used in European countries for vehicle compliance. The manufacturers were supportive of this alternative.

RECOMMENDATION

If the standard is implemented under the Highway Traffic Act, a method of inspection to confirm compliance must then be established.

RECOMMENDATION

That manufacturers/converters present their products for yearly or two yearly inspections, to an identified authority, to establish their compliance to the D 409, or alternate standard. This would allow them to present their documentation for viewing as required.

A standard of this nature is not unique to Manitoba. B.C. uses a design spec. guideline for vehicles used in its Handi-Dart program (append. 5), Quebec has a standard entrenched in its Highway Safety Code -- R.S.Q., c. C - 24.2, s. 621, par. 2.1 (append. 4), Ontario recognizes the CSA D 409 M84 under its Highway Traffic Act, and Nova Scotia has identified the D 409 92 with amendments.

It was found during random viewing of some accessible vehicles that restraint systems were worn and in poor working condition.

RECOMMENDATION

The Board needs to incorporate specific inspection criteria within its regular inspection practices to insure that components used in these vehicles are in safe working conditions.

In the past, a common practice by some manufacturers/converters was to have a client purchase a new vehicle, insure it, and then bring it for alteration. This practice would establish the vehicle as "used" and therefore compliance to CMVSS would not be required.

Transport Canada altered its interpretation of a new vehicle to consider the "intent of the purchase" to protect against this practice.

In a recent court proceeding held in western Canada, a converter was charged under the act for not certifying their vehicles. The converter asserted that the clients had purchased the vehicles, then brought them to the shop for conversion. Transport Canada determined that the vehicles had been purchased with the intent of conversion, and therefore were subject to vehicle compliance. Transport Canada's interpretation was upheld by the court, and the converter was found guilty.

The best clarification of a used vehicle would be one that has been purchased from the first purchaser or driven for a significant number of kilometers. The original intent of the new vehicle purchase should not have been to alter the vehicle.

Although you cannot "certify" a used vehicle to meet CMVSS, you can ensure that the vehicle is altered using the same practices and procedures used in altering new vehicles. This would ensure that the vehicle was in its safest form.

RECOMMENDATION

If a standard is maintained within the province, it must to some extent cover used vehicles with reason.

The concern of cost is regularly presented, primarily by the handivan industry. However, safety and well-being of passengers, drivers, and the public at large must be the highest priority. The costs of altering a used vehicle, can be in the range of $6,000.00, to $10,000.00, used vehicles meeting the D 409 standard can start at $15,000.00, and new vehicles are between $35,000.00 to $48,000.00. (30 to 50% of the two latter are GST/PST exempt, 65-75% of the first is also.) Further clarification and confirmation of this information can be found in the appendix.

RECOMMENDATION

The board may want to maintain a membership in, or refer to NMEDA, the National Mobility Equipment Dealers Association. This is a resource center and international information clearinghouse.

Based in Florida, N.M.E.D.A. is a non-profit international association of adaptive vehicle modifiers and other rehab professionals whose goal is to promote public awareness of current adaptive transportation and safe vehicle modifications. N.M.E.D.A. offers to any consumer or agency who calls, information on:

N.M.E.D.A. publishes a quarterly newsletter called the "Circuit Breaker" that is available by subscription.

Any questions or comments should be directed to:

NATIONAL MOBILITY EQUIPMENT DEALERS ASSOCIATION
909 E. SKAGWAY AVE.
TAMPA, FL 33064
1-800-833-0427 FAX
1-813-931-4683
E-MAIL: ACCESSUNL@AOL.COM

This organization has an estimated 400 members and is presently establishing a Canadian chapter. It is preparing generic testing documentation on common accessible configurations to provide to its members so as to make compliant accessible transportation more cost effective. This organization has the growing attention and support from U.S. and Canadian Federal agencies.

It is the recommendation that the standard does need to be amended. The following is a proposed standard for discussion.

RECOMMENDED IMPLEMENTATION OPTIONS

Option 1:

The board could leave all as it stands and deal with the compliance issues as they arise and rely on what the manufacturer, or operator supplies as confirmation of compliance.

It is the expectation that at some point a jurisdictional issue would be presented challenging which standard held precedence, the D 409 or the 75/94.

Option 2:

The opposing alternative would be to remove both the D 409 from the Taxicab Act and the 75/94 found in the Highway traffic act.

This would allow the industry to provide what it felt the market would accept. Ultimately the market would establish the industry standard by using the service it most desired.

Although the board and the department have no legal obligation to continue with or replace the D 409 or 75/94 standard with one equal or greater, it does have a moral responsibility to maintain some form of standard to protect the public.

Option 3:

The board could remove the D 409 from the taxicab act and recognize the 75/94 found in the Highway traffic act.

The 75/94 does not directly address the needs of the accessible taxi industry, and would require some amendment to provide for increased standards for restraints.

Option 4:

The Board and the Department could implement a new standard that would be covered under the Highway Traffic Act. This would allow an even application of rules for accessible transportation throughout the province.

This standard would be designed so as to encompass all the industry concerns and needs and serve to clarify what is presently a confused situation.

The standard would not move far from the spirit of the D 409, but would allow for some flexibility and recognition of the different classes of vehicles needed to meet the market needs.

The Board and the Department would then amend the regular safety inspections to include and recognize specific features that would be incorporated in these vehicles to maintain safety standards.



Sixth Section

Proposed Replacement Standard

Manitoba Specialized Motor Vehicle Safety Standard

Commercial Vehicles for the Transportation of Mobility Challenged Passengers Et All

For vehicles under 10,000 GVWR ?75/96

For vehicles over 10,000 GVWR D 409 92

Contents                                        2 - 9

Preface                                          10

1.5 	Scope 						11

2.      Definition                                      11

3. 	Reference Publication 				11

4. 	General requirements 				15
4.1 	General
4.2 	Modifications
4.3 	variances
4.4 	Type of Vehicle
4.5 	Securement of Devices
4.6 	Portable Support Equipment
 5. Vehicle Chassis                                     16
5.1 	Battery (All Vehicles)
5.1.2 	Battery Compartments
5.3 	Bumpers(All Vehicles)
5.3.1 	Front Bumper 	
5.3.2 	Rear Bumper
5.6 	Exhaust System (All Vehicles)
5.6.1 	Location
5.6.2 	Direction
5.6.3 	Clearance
5.7 	Frame(ALL Vehicles)
5.7.1 	Modifications
5.7.2 	Holes
5.10 	Cross Vehicle Weight (All Vehicles)		17
5.14 	Openings(All Vehicles)
5.16 	Spare Tire(All Vehicles)
 6. Vehicle Body 					18
6.1 	Identification(All Vehicles 
	Unless Precluded by Regulation)
6.1.1 	Location of Symbol
6.1.2 	Appearance of Symbol
6.4 	Bumpers (ALL Vehicles)
6.4.1 	Front Bumper
6.4.2 	Rear Bumper
6.5 	Insulation(All Vehicles)
6.5.1 	General
6.5.2 	RValue
6.6 	Windows(All Vehicles)
6.8 	Service Entrances
6.8.1 	Service Doors(ALL Vehicles) 			19
6.8.2   Steps                                           20
6.9 	Emergency Exits (All Vehicles)
6.9.1 	General
6.9.2 	Securement During Unloading
6.9.4 	Restrainment/Securement Devices
6.10 	Lighting (ALL Vehicles)				21
6.11 	Inside Height
6.12 	Floor(ALL Vehicles)
6.12.1 	General
6.12.2 	Static Coefficient of Friction
6.12.3 	Strength
6.13 	Passenger Seating and Seats
	(All Vehicles)
6.13.1 	Mobility Aid Passenger Seating
6.13.2 	Ambulatory Passenger Seating			22
6.13.3 	All Passenger Seating
6.14 	Grab Bars/Handles (All Vehicles)		23
6.14.1 	Location
6.14.2 	Diameter/Width
6.14.3 	Strength
 6.15 Projections and Padding (All Vehicles)
6.15.1 	Projections
6.15.2 	Padding
6.15.3 	Physical Properties of Padding
6.16 	Rearview Mirrors 				24
6.16.1 	All Vehicles
6.16.2 	Vehicles, Convex Mirrors
6.18 	Heater(All Vehicles)
6.18.1 	Type of Heater
6.18.2 	Combustion Type Heaters
6.18.3 	Capabilities of Heating System
6.18.4 	Heater Lines
6.24 	Wiring (ALL Vehicles) 				25
6.24.1 	General
6.24.2 	Circuits
6.24.4 	insulation and Protection
6.24.5 	Fastening and Joining
6.25 	Rollover Protection
6.26 	Warning
 7. Mobility Aids (All vehicles)                        26
7.1 	Space Requirements
7.1.1 	Floor Space
7.1.2 	Fixed Vehicle Structures
7.2 	Securement
7.2.1 	Securement Devices
7.2.2 	Anchorage Points
7.3 	Mobility Aid Occupant Restraint
7.3.1 	Occupant Restraint Systems
7.3.2 	Seat Belts
7.3.3 	anchorage Points
7.4 	Simultaneous Loading
 8. Lifts (All Vehicles)                                27
8.1 	Securement to Vehicle
8.1.1 	Vehicle interface Test 	
8.2 	Platform Dimensions
8.3 	Capacity
8.3.1 	Minimum Load
8.3.2 	Static Load test
8.4 	Platform Construction
8.4.1 	Surface
8.4.2 	Guards
8.4.3 	Roll Stop
8.4.4   Handrail                                        28
8.4.5 	Restraining Device
8.5 	Guarding of Moving Parts
8.6 	Operating Conditions
8.7 	Rated Speed
8.8 	Controls
8.8.1 	General
8.8.2 	Number of Controls 				29
8.8.3 	Interlock Device
8.8.4 	Manual Override
8.8.5 	Override Speed
8.8.6 	Powered Closing Platform
8.9 	Reliability and Durability
8.9.1 	General
8.9.2 	Accelerated Life Cycle Test
8.10    Cautions                                        30
8.10.1 	Caution
8.10.2 	Appearance
 9. Service Ramp (ALL Vehicles)                         31
9.1 	Gradient
9.2 	Construction
9.2.1 	Ramp Surfaces
9.2.2 	Guards
9.3 	Capacity
9.4 	Power Operated Ramps
9.4.1 	Guarding of Moving Parts
9.4.2 	Operating Conditions
9.4.3 	Controls
9.5     Securement                                      32

MINIMUM REQUIREMENTS FOR
CONSTRUCTION AND EQUIPMENT
OF SPECIAL MOTOR VEHICLES                               35

N.B. in the case of vehicles manufactured/converted for transporting ambulatory passengers exclusively, sections 7,8,and 9 are to be excluded, inclusive of sub-section 6.13.1

Preface

This Standard is based on the second edition of CSA Standard D 409 92 (now CAN/CSA-D 409 92), Motor Vehicles for the Transportation of persons with Physical Disabilities.

It is intended that this Standard be applied to motor vehicles operated for, or on behalf of, any person, club, agency, or organization that provides a transportation service for persons with physical disabilities, for compensation or otherwise.

This Standard makes reference to several Canada Motor Vehicle Safety Standards (CMVSS) contained in Federal Regulations,

Notes:

(1) Use of the singular in this Standard does not excluded the plural, (and vice versa) when the sense allows.

(2) Although the intended primary application of this Standard is stated in its Scope, it is important to note that it remains the responsibility of the users of the Standard to judge its suitability for their particular purpose.

(3) Standards are subject to periodic review, and suggestions for their improvement will be referred to the appropriate department.

(4) All inquiries regarding this Standard, including requests for interpretations, should be addressed to;

( TO BE INCLUDED WHEN DETERMINED ).

Requests for interpretation should;

(a) define the problem, making reference to the specific clause, and, where appropriate, include anillustrative sketch;

(b) provide an explanation of circumstance surrounding the actual field conditions; and

(c) be phrased where possible to permit a specific "yes" or "no" answer.

1. Scope

1.1

this Standard applies to motor vehicles other than passenger cars (as defined in Section 2 of the Canada Motor Vehicle Safety Act) designed and manufactured, or converted, for the purpose of transporting persons with Mobility Impairments.

Note:

"Passenger car" Is defined in the Canada Motor Vehicle Safety Act as a vehicle having a designated seating capacity of 10 or less, but does not include an all-terrain vehicle, competition car, multipurpose passenger vehicle, antique reproduction vehicle, motorcycle, truck, or trailer.

1.2

This Standard specifies the design, manufacture, and/or conversion of the vehicle, lifts, and ramps.

1.3

The values given In SI (metric) units are to be considered the standard. The values given in parentheses are for information only.

2. Definition

2.1

The following definition applies in this Standard:

Person with a mobility impairment -- a person who, because of a mobility and or agility impairment, requires the use of a specialized transportation vehicle.

3. Reference Publications

3.1

This Standard refers to the following Publications and where such reference is made It shall be to the edition listed below, including all amendments published thereto:

CSA Standards

01Z1-M1978, Douglas Fir Plywood;

Z604 transportable Mobility Aids

Z605, Mobility Aid Securement and Occupant Restraint Systems for Motor Vehicles.

ASTM Standards

8117-90, Method of Salt spray (Fog) testing;

D412-87, Test Methods for Rubber Properties in Tension;

D1056-85, Specification for Flexible Cellular Materials -- Sponge or Expanded Rubber;

D1667-76(81991), Specification for Flexible Cellular Materials -- Vinyl Chloride Polymers and Copolymer Closed-Cell Vinyl);

D2047-82(R1988),Test Method for Static Coefficient of Friction of Polish coated Floor Surfaces as Measured by the James Machine

D3574-86, Method of Testing flexible Cellular Materials -- Slab, Bonded, and Molded Urethane Foams.

CGSB Standard

1-GP-12C·1965, Standard Paint Color, Part I -- Color Identification and Selection.

CMVSS

105-CRC 1978 C1078; 501(/79-374; SOR/8O-637; SOR 86-683; 508/86-976; SOR/91-144 ,Hydraulic Brake Systems;

121-080 1978, SOR/78-351; SOR/79-547; SOR/79-940 SOR/80-638, Air Brake Systems;

207-CRC 1978,Seat Anchorage;

209-CRC 1978, SOR/78-910, SOR/87-154. Belt Assembly;

210-CRC 1978, SOR/90-588. Belt Anchorage:

217-CRC 1978 C1038; SOR/80-159; SOR/86-978; SOR/87-176, Bus Window Retention Release and emergency Exits;

220-CRC 1978 01038; SOR/79-840, Rollover Protection;

222-CRC 1978 C1038; SOR/80-161; SOR/86-453; SOR/91-593. School Bus Passenger Seating and Crash Protection.

FMVSS

Code of Federal Regulations, Title 49. Part 571,125-1981. Warning Devices.

SAE' Standards, Recommended Practices. information Reports 120e-1988, Coolant System hoses;

J377-1987 Performance of vehicle Traffic horns

J544-1988, Electric Starting Motor Test Procedure;

J537-1986, Storage Batteries;

J588-1984, Turn Signal Lamps for Use on Motor Vehicles less than 2032 mm in Overall Width.

SBMI

School Bus design Objectives, May 1990.

US Military Standards

Mil-P-12420C-1991, Plastic Material, Cellular, Elastomeric;

MIL-P-15280H-1988. Plastic Material, Unicellular (Sheets and tubes).

American Society for Testing and Material.

Canadian General Standard Board.

Canada motor vehicle Safety Standards (Canada Motor Vehicle Safety Act).

Federal Motor Vehicle Safety Standards (USA).

Society of Automotive Engineers.

School Bus Manufacturers Institute.

4. General Requirements

4.1 General

The complete vehicle shall conform to the Regulations of the Canada Motor Vehicle Safety Act in effect no earlier than the date of manufacture of the original base vehicle and no later than the actual date of completion of the vehicle.

4.2 Modifications

It is the responsibility of the party making any modification to the vehicle for any purpose, after its initial manufactured certification, to assure the compliance with all the provisions outlined in the appropriate CMVSS.

4.3 Variances

Where this Standard is at variance with the Regulations of the Canada Motor Vehicle Safety act, the Regulations shall preempt the varying CSA provisions.

4.4 Type of Vehicle

The vehicle shall be one or a combination of the following types:

(a) equipped with a lift(s) that complies with Clause 8;

(b) equipped with a service ramp(s) that complies with Clause 9:

(c) equipped with a system to lower the vehicle floor to permit loading and unloading persons with physical disabilities;

(d) equipped to transport only ambulatory passengers.

4.5 Securement of Devices

Securement of devices and other pieces of equipment supplied with the vehicle that are not an integral part of the vehicle shall be in accordance with Clause 4.6.

4.6 Portable Support Equipment

Portable support equipment or special accessory items shall be secured at the mounting location to withstand a pulling force of 20 times the weight of the item in any direction, or shall be retained in an enclosed and secured latched compartment which is capable of withstanding a pulling force of 20 times its weight with the contents inside.

5. Vehicle Chassis

5.1 Battery (All Vehicles)

5.1.2 Battery Compartments

All battery compartments shall be ventilated to the exterior of the vehicle.

5.3 Bumpers(All Vehicles)

5.3.1 Front Bumper IF ALTERED FROM OEM

The bumper shall extend beyond the forward-most part of the body and to the outer edge of the front body panels to ensure fender and body protection.

5.3.1.2

The bumper, except breakaway bumper ends, shall be of sufficient strength to permit pushing another equivalent vehicle of equal gross weight on level ground at rated GVWR without major permanent distortion to bumper, chassis, or body.

5.3.2 Rear Bumper

Note: See Clause 6.1.2.

5.6 Exhaust System (All Vehicles) IF ALTERED FROM OEM

5.6.1 Location

The exhaust pipe, muffler, and tail pipe shall be outside the passenger compartment.

5.6.2 Direction

The exhaust shall be directed away from the body and loading areas.

5.6.3 Clearance

Adequate clearances or heat protection shall be provided between the exhaust system and fuel tanks, fuel lines, flexible brake lines and hoses, and other flammable material, to prevent ignition and/or heat deterioration.

5.7 Frame(All Vehicles)

5.7.1 Modifications

Modifications of frame lengths resulting in the altering of the wheelbase by other than chassis manufacturers are not permissible unless modifications are approved by the chassis manufacturer.

5.7.2 Holes

Holes in top or bottom flange of the frame side rails shall not be permitted except as provided in the original chassis frame.

5.10 Gross Vehicle Weight (All Vehicles)

5.10.1

The gross axle and gross vehicle weights of the loaded vehicle shall not exceed the manufacturer's statement of compliance for gross axle and vehicle weight ratings.

5.10.2

In determining the gross vehicle weight, the total maximum passenger weight shall be based on the following:

(a) 70 kg (150 LB) for the driver:

(b) 70 kg (150 LB) for each passenger not in a mobility aid; and

(c) 150 kg (330 LB) for each mobility aid position.

5.14 Openings(All Vehicles)

All openings in the floor or fire wall between the chassis and passenger-carrying compartment, such as those for the gear shift lever and the parking brake lever, shall be sealed against water, dust, and fumes.

5.16 Spare Tire (All Vehicles)

If a spare tire is mounted inside the passenger compartment, it shall be secured as per Clause 4.6.

6. Vehicle Body

6.1 Identification (All Vehicles Unless Precluded by Regulation)

6.1.1 Location of Symbol

The vehicle shall be identified by an accessibility symbol, as shown in Figure 5, on the rear left of center, right front, and body sides just behind the driver's station.

6.1.2 Appearance of Symbol

The symbol shall Comply with the following:

(a) it shall be a minimum size of 150 x150 mm (6 x 6 in); and

(b) The symbol shall be white on a blue background with the following color numbers specified in CGSB Standard 1-GP-12c:White -- 513-301; andBlue -- 502-104.

6.4 Bumpers (All Vehicles)

6.4.1 Front Bumper (See Clause 5.3.1.)

6.4.2 Rear Bumper IF ALTERED FROM OEM

A rear bumper(s) shall be furnished and attached directly to the chassis frame with provisions for removal. It shall extend beyond the rearmost part of the body surface at least 25 mm (1 in) measured at the floor line. It shall be of sufficient strength to permit the vehicle to be pushed by another vehicle on level ground at rated GVWR without major permanent distortion.

6.5 Insulation(All Vehicles)

6.5.1 GeneralThe ceiling and walls shall be insulated to deaden sound and vibration and to reduce heat transfer.

6.5.2 R Value

All insulating materials used for the reduction of heat transfer shall have an R value of at least 3.0.

6.6 Windows(All Vehicles)

The vehicle shall be provided with windows on both sides of the passenger compartment and be designed to open so as to provide ventilation.

6.8 Service Entrances

6.8.1 Service Doors (All Vehicles)

There shall be an ambulatory entrance door on the right side of the vehicle. Where only one mobility aid entrance is provided, it shall not be on the left side of the vehicle.

6.8.1.2

The locking and unlocking of all doors shall be under control of the driver from his/her normal seated position. Power operated doors/door locks shall permit manual operation in case of power failure.

6.8.1.5

The service door(s) shall be provided with a

(a) means to secure it against unintended closing during loading or unloading of passenger; and

(b) safety latch on the ambulatory door to prevent unintended closing if the door grab handles are used.

6.8.1.6

Where service door(s) openings are less than 1980 mm (78 in) in height, they shall be padded at the top interior edge.

6,8.1.7

There shall be a drip molding above each service door opening, to direct water to either side of the opening.

6.8.1.8

The minimum dimensions of the ambulatory entrance opening shall be a clear

(a) horizontal opening of at least 560 mm (23 in) at the widest point and 400 mm (16 in) at the narrowest point; and

(b) vertical opening of at least

(i) 1.38 m (4.5 ft) on vehicles

6.8.1.9

The minimum dimensions of the mobility aid clear entrance opening with lift/ramp installed shall be

(a) width -- 760 mm (30 in); and

(b) vertical --1400 mm (55 in).

6.8.2 Steps

6.8.2.1

All Vehicles

6.8.2.1.1

The static coefficient of friction of step covering material when measured in accordance with ASTM Standard D2047, under wet and dry conditions, shall be a minimum of 0.5.

6.8.2.1.2

There shall be a yellow or white stripe, not less than 38 mm (1.5 In) and not more than 75 mm (3 in) wide, on the leading edge of the horizontal surface of each step and the floor surface at the step entrance. 6.8.2.1.3

The dimensions of steps at the ambulatory entrance shall be as follows:

(a) the height of the first step from ground level -- maximum 380 mm (15 In);

(b) the height of steps in the vehicle -- maximum 230 mm (9 In);

(c) the variation in the height of steps in the vehicle -- maximum 25 mm (1 in);

(d) the depth of steps (front to back)-- minimum 164.5 mm (6.5 in): and

(e) the width of steps (side to side)-- minimum 400 mm (16 in).

6.8.2.1.4

All steps shall be a constant depth except for auxiliary steps.

6.8.2.1.5

Step nosing (overhang) shall not exceed 10 mm (3/8 in).

6.8.2.1.6

The nosing at the floor level shall be flush with the floor.

6.9 Emergency Exits

6.9.1 General

Each vehicle shall be provided with an emergency exit with a minimum width of:

i) 800 mm (32 in) and a minimum height of 1125 mm (45 in). for full size vans.

ii) 725 mm (29 in) and a minimum height of 1100 mm (44 in) for minivans

A)

i) It shall allow the unobstructed passage of a rectangular parallelepiped that measures 1118 mm (44 in.) in height, 800 mm (32 in.) in width perpendicular to the sides of the vehicle, and 610 mm (24 in.) in depth parallel to the sides, the bottom of which remains within 25 mm (1 in.) of the floor at all times during its passage through the opening for full size vans

ii) It shall allow the unobstructed passage of a rectangular parallelepiped that measures 1092 mm (43 in.) in height, 737 mm (29 in.) in width perpendicular to the sides of the vehicle, and 610 mm (24 in.) in depth parallel to the sides, the bottom of which remains within 25 mm (1 in.) of the floor at all times during its passage through the opening for minivans

( parallelepiped = solid body of which each face is a parallelogram )

B) It shall be on a different wall of the vehicle than the service door

C) and shall be accessible without obstructions by any seats and/or other objects which would require the use of tools for removal.

6.9.1.1

There shall be no more than two seat systems and/or objects removed in order to provide clear passage, and there shall be no more than one release action required to remove that seat/object that is readily accessible from the emergency exit.

6.9.1.2

In the case of vehicles for the exclusive use of transporting ambulatory passengers;

i) there shall be at least one rear emergency door that opens outward and is hinged on either side.

ii) one push out side window that:

a) provides a minimum opening clearance of 400 mm (16 in.) high and 1016 mm (40 in.) wide.

b) is capable of being released of not more than two mechanisms that are located at the bottom of the window and they do not have to be operated simultaneously and,

c) allow manual release of the mechanism by an occupant using a low- force application of not more than 90 N (20 pounds) in a rotational or linear direction

6.9.1.3 (ALL Vehicles)

Every push-out window or other emergency exit shall, for the purposes of identification and operation,

a) be identified with a label located within 150 mm (6 inches) of its release mechanism bearing words in both official languages or an approved symbol that identifies the emergency exit, and followed by concise operation instructions in both official languages.

(The marking on every label shall be legible to an occupant with corrected visual acuity corresponding to a Snellen ratio of 20/40.

b) have concise operating instructions describing the motions and, if applicable, sequence of motions necessary to unlatch and open the emergency door or exit, in letters at least 9.5 mm (3/8 in.) high of a color that contrasts with its background, located within 150 mm (6 in.) of the release mechanism on the inside surface.

6.9.2 Securement During Unloading

Emergency exits shall be provided with a means to secure them against unintended closing during unloading of passengers.

6.9.4 Restrainment/Securement Devices

Fastening of any passenger restraining or mobility aid securement device to emergency exits is prohibited.

6.10 Lighting(All Vehicles)

Vehicles shall be equipped with a light

(a) at the lift door automatically operated when the door opens, which will illuminate the lift area; and

(b) above or beside each passenger access door to illuminate the steps. Such lights shall be automatically actuated when the door opens.

6.11 Inside Height

The inside body height shall be a minimum 1442 mm (57 in), measured at any point on the longitudinal center line from the front vertical bow to the rear vertical bow, and no lights or other fixtures may intrude into this zone.

6.12 floor (All Vehicles)

6.12.1 General

The floor in the passenger-carrying area shall have an overlay of at least an 11 mm (1/2 in) covering of 5-ply plywood which equals or exceeds the properties of select sheathing grade "C improved" for underlay in compliance with CSA Standard 0121, or any other equivalent durable covering of commensurate strength and insulating properties. OEM metal floor accepted. Chipboard and loose composite board shall not be permitted.

6.12.2 Static Coefficient of Friction

The static coefficient of friction of the flooring material, when measured in accordance with ASTM Standard D2047, under wet and dry conditions, shall be a minimum of 0.5.

6.12.3 Strength

The floor shall be designed to support a load of 226 kg (500 LB) at any wheelchair position without permanent deformation.

6.13 Passenger Seating and Seats (All Vehicles)

6.13.1 Mobility Aid Passenger Seating

Mobility aid seating shall be forward or rearward facing.Note: See CSA Standard Z605.

6.13.2 Ambulatory Passenger Seating IF ALTERED FROM, OR ADDED TO, OEM BASE VEHICLE

6.13.2.1

The distance from the front of each seat back to the back of the seat ahead, measured on a horizontal plane at the center of the seat cushion surface, shall be a minimum of 685 mm (27.0 in).

6.13.2.2

The minimum rump width (space per person) shall be 380 mm (15 in).6.13.2.3The height of a seat cushion above the floor shall be between 400 and 480 mm (16 and 19 in).6.13.2.4The depth of the seat (front to back) shall be between 380 and 430 mm (15 and 17 in).

6.13.2.5

Seats shall be level or slope downwards towards the back.

6.13.2.6

Seat backs shall be a minimum of 380 mm (15 in) in height.

6.13.3 All Passenger Seating

6.13.3.1

Where a passageway is required for movement of a mobility aid, there shall be a minimum clear width of 760 mm (30 in) between fixed objects.

6.13.3.2

For each seat designated for use by a person with a disability, there shall be, as a minimum, a Type 1 seat belt assembly provided.

6.14 Grab Bars/Handles (All Vehicles)

6.14.1

LocationGrab bar(s)/handle(s) shall be provided at each

(a) seat designated for use by a person with a disability; and

(b) side of the entrance used by persons with disabilities, accessible from ground level, and so arranged that they are inside the vehicle when the doors are closed and

(c) be a contrasting color

6.14.2 Diameter/Width

The maximum diameter/width of grab bars/handles, including padding, shall be 75 mm (3 in).

6.14.3 Strength

Grab bars/handles shall be capable of withstanding a pull of at least 450 N (100 Ibf) in any direction without permanent deformation.

6.15 Projections and Padding (All Vehicles)

6.15.1 Projections

The interior of the vehicle shall be free of all unnecessary projections likely to cause injury, and there shall be an interior lining on the ceiling and walls.

6.15.2 Padding

Any of the following structures that could be contacted by passengers in their seated position shall be padded in accordance with Clause 6.15.3:

(a) stanchions

(b) grab bars/handles, except those at the vehicle entrance;

(c) guard rail; and

(d) exposed stationary parts of lift and ramps.

6.15.3 Physical Properties of Padding

Padding shall be a closed-cell urethane foam, rubber, or vinyl type of material minimum 5 mm (0.26 in) thick, and having as a minimum the physical properties specified in Table 1 or 2. As an alternative, structures (a). (b), and (c), under Clause 6.15.2 may be padded with extruded polyvinyl chloride (PVC) tubing having a minimum nominal thickness of 13 mm (0.5 in), or the equivalent.

Note: Consideration should be given to the effects of hazard In passengers contacting projections during

(a) loading and unloading;

(b) normal travel (en route); and

(c) accident or emergency conditions

6.16 Rearview Mirrors

6.16.1 All Vehicles

Rearview mirrors shall be located inside and outside of the vehicle and shall conform to the following:

(a) the interior mirror shall

(i) have rounded corners and edges and be designed to reduce danger of injury upon impact; and

(ii) be untinted and, if made of glass, it shall be safety glass, and shall provide the operator with a continuous view of the passenger compartment;

(b) the outside mirrors shall

(i) be located on each side of the vehicle forward of the driver's seat and the reflecting surface shall not be obscured; and

(ii) have adjustable mounts.

6.16.2 Vehicles, Convex Mirrors

A convex mirror shall be mounted adjacent to the flat-surfaced outside rearview mirror on the right side to provide an additional close-in field of vision.

6.l8 Heaters(All Vehicles)

There shall be front and rear heaters

6.18.1.1 Type of Heater, Front

It shall be a fresh air or combination fresh air and recirculating type.

6.18.1.2 Type of heater, Rear

It shall be of the recirculating type.

6.18.2 Combustion Type Heaters

All combustion type heaters shall be approved by a recognized testing agency.

6.18.3 Capabilities of Heating System

The heating system shall be capable of maintaining the inside air temperature at a minimum of 16 C (60 F) when the outside temperature is -18 c (60 F) with the engine idling and the ambient air velocity at a maximum of 5 km/h (3 mph). The temperature shall be measured at 400-450 mm (16-18 in) above the floor level at the center of the bus.

6.18.4 Heater Lines

Heater lines shall comply with the following requirements:

(a) they shall be supported to guard against chafing due to vibration;

(b) the lines shall not rub against the chassis or sharp edges and shall not interfere with or restrict the operation of any engine function;

(c) where hoses are used, they shall conform to SAE Standard J20e; and

(d) heater lines inside the passenger compartment shall be shielded to prevent scalding of the driver or passengers and to provide protection in case of lines bursting.

6.24 Wiring (All Vehicles)

6.24.1 General

All wiring shall comply with the current standards of the Society of Automotive Engineers.

6.24.2 Circuits6.24.2.1

Wiring shall be arranged in circuits so as to be compatible with the chassis wiring.

6.24.4 Insulation and Protection

All wires within the body shall be insulated and, where accessible to the passengers, shall be covered with a protective loom (or the equivalent) that will protect them from external damage and minimize danger from short circuits. Whenever wires pass through a body member, protection against abrasion shall be provided.

6.24.5 Fastening and Joining

Wires that cannot be enclosed within the body shall be fastened securely. All joints shall be soldered or joined by equally sufficient Connectors.

6.25 Rollover Protection

All vehicles shall comply with CMVSS 220.

6.26 Warning

Wording such as the following must be shown adjacent to the mobility aid entrance of the vehicle:

DO NOT PARK WITHIN 5 METRES.

7. Mobility Aids (All Vehicles)

7.1 Space Requirements

7.1.1 Floor Space

The average floor space for each mobility aid shall be taken as 685 x 1115 mm (27 x 44 in). The 1115 mm length shall be parallel to the vehicle's longitudinal centerline. (Or as amended in CSA Z605)

7.1.2 Fixed Vehicle Structures

There shall be no fixed vehicle structure at a mobility aid position, except for Mobility Aid Securement and Occupant Restraint System (MASORS) components, within the zones shown in Figure 1, where a Type 2 seat belt assembly is provided and in Figure 2, where a Type 1 seat belt assembly is provided.

7.2 Securement7.2.1 Securement Devices

The mobility aid securement device(s) shall conform to CSA Standard Z605.

7.2.2 Anchorage Points

Anchorage points for the mobility aid securement system shall each be separated by a minimum center-to-center distance of 300 mm as shown in Figure 3(b), and shall withstand a forward and rearward static loading of 1600 kg (3520 LB) applied in accordance with Figure 3(a).

Note: The applied load of 1600 kg is compatible with CMVSS 207 substituting, for the seat, a mobility aid having a weight of 80 kg (176 LB)

7.3 Mobility Aid Occupant Restraint

7.3.1 Occupant Restraint Systems

Type 2 occupant restraint system(s) shall conform to CSA Standard Z605.

7.3.2 Seat Belts

A type 2 seat belt assembly shall be provided at each outboard mobility aid position. A Type 1 or Type 2 seat belt assembly shall be provided at each inboard mobility aid position. All seat belt assembly components shall meet the requirements of CMVSS 209.

Note: Refer to CMVSS 209 for definition of Type 1 end Type I seat belt assembly. It is recommended that scooter-type mobility aids be transported only in a position where a type 2 seat belt is provided.

7.3.3 Anchorage Points

Anchorage points for the occupant restraint system shall meet the strength requirements of CMVSS 210. The upper torso anchorage point shall be located within the zone shown in Figure 4 (with zone extended upwards).

7.4 Simultaneous Loading

If mobility aid securement and occupant restraint system Share common anchorage points, the loading requirements of 7.2.2 and 7.3.3 shall be met simultaneously.

8. Lifts (All Vehicles)

8.1 Securement to Vehicle

The lift should be secured in accordance with the lift manufacturer's instructions.

8.1.1 Vehicle Interface Test

This test shall be conducted on a lift installed on an actual vehicle model being purchased using this document for its procurement. A static load of 408 kg (900 LB) shall be applied through the centroid of a test pallet placed at the centroid of the platform when the platform is positioned at its railed position. The length and width dimension of the test pallet shall be 610 x 610 mm (24 x 24 in). The load shall remain on the platform not less than 2 min.

8.2 Platform Dimensions

Lift shall have the following minimum dimensions:

(a) width -- 760 mm (30 in): and

(b) length --1115 mm (44 in).

8.3 Capacity8.3.1 Minimum Load

Each lift shall be designed to have a minimum lifting capacity of 275 kg (600 LB).

8.3.2 Static Load Test

There shall be no evidence of fracture when a static load test is conducted, as follows, with the lift attached to a rigid test fixture:

(a) A load of 10 000 N (2400 lbf) hall be applied through the centroid of a test pallet placed at the centroid of the platform when the platform is positioned at the equivalent to the vehicle floor level; the pallet shall be 610 mm x 610 mm (24 x 24 in);

(b) the load shall remain on the platform for a minimum of 2 min; and

(c) after the load has been removed, an inspection shall be made to determine if any fractures have occurred.

8.4 Platform Construction

8.4.1 Surface

The platform shall have a skid-resistant surface.

8.4.2 guards

The sides of the platform shall be fitted with guards that are 25-50 mm (1-2 in) in height and which extend the full length on each side of the platform. The outside of the guards shall be clearly marked with yellow and black reflective diagonal strips (to indicate the presence of the unfolded platform).

8.4.3 RollStop

The platform shall be equipped with a roll stop at the outer edge. This roll stop shall be approximately in the vertical position when the platform is in the lifting and lowering mode and shall be retractable when the platform reaches the lower limit of travel. The roll stop shall be a minimum of 100 mm (4 in) in height in the raised position

8.4.4 Handrail

Where the lift platform extends outside the vehicle body, the platform shall be equipped with a handrail on each side that is 635-865 mm (25-34 in) from the platform and shall remain at a constant height while in operation. Each handrail shall be capable of withstanding a horizontal force of 450 N (100 lbf) concentrated at any point.

8.4.5 Restraining Device

Where the lift platform extends outside the vehicle body, the platform shall be equipped with a restraining device that shall be positioned 635-865 mm (25-34 in) above the platform when the platform is in the operating position, to prevent the mobility aid and its occupant from rolling off the platform.

8.5 Guarding of Moving Parts

Exposed moving parts, such as chains, sprockets, and gears, shall be guarded against hazards inherent in moving machinery.

8.6 Operating Conditions

Lifts shall be capable of functioning in an ambient temperature of -40 to +40 C (-40 to +104).

8.7 Rated Speed

The rated speed for lowering and raising the platform shall be a minimum of 0.06 m/s (12 ft/min) and a maximum of 0.13 m/s (25 ft/min) from a rated load condition to a no load condition.

8.8 controls

8.8.1 General

The control(s) shall be located so as to enable the operator to stand anywhere around the edge of the platform when operating the lift, shall be operable using one hand only and shall be a continuous pressure operation.

8.8.2 Number of Controls

There shall be only one control and it shall be designed to prevent accidental operation of the lift. Provision shall be made for safe storage of the control device when not being used by the operator.

8.8.3 Interlock Device

The vehicle shall be equipped with an interlock device that is designed to prevent operation of the lift if the parking brake is not engaged, and/or the transmission gear shift secured in the "park" position.

8.8.4 Manual Override

The lift shall be equipped with a manual override to enable the operator to raise and lower the platform, with or without load, in case of power failure, and to enable the operator to return the lift to the stowed position. The override device shall be accessible for use by the operator. A notice in English or French, or English and French, outlining detailed step-by-step instructions for the hand-moving procedure shall be posted along side the hand-moving actuation point.

8.8.5 Override Speed

The lift shall be so designed that, in the event of primary power supply failure, the average speed of descent of the platform in the manual override mode, with rated load, will be not more than the maximum rated speed (see Clause 8.7).

8.8.6 Powered Closing Platform

A powered closing platform shall fold only when it is in the "up" position and shall not fold with more than 34 kg (75 LB) on the center of the platform.

8.9 Reliability and Durability

8.9.1 General

There Shall be no evidence of failures or creation of hazardous conditions during the accelerated life cycle test In Clause 8.9.2. Electrical components and wiring, hydraulic components, drive components, and fasteners shall be considered as integral parts of the lift system for the purposes of the test.

8.9.2 Accelerated Life Cycle Test

An accelerated life cycle test shall be performed on a test fixture by repeating the lift use cycle 4400 times in an ambient temperature of 10-32'C (50-90 F) as follows:

(a) the time between each cycle shall be between 6 and 7 min;

(b) alternating cycles of loaded and unloaded platform shall be simulated by applying a load of 2670 N (600 lbf for 100 cycles and then removing the load for 100 cycles; the lift shall be folded and unfolded during each cycle of the unloaded test;

(c) a visual inspection shall be made without disassembly of the lift at intervals of 500 cycles, and changes In alignment, component wear, and loosening of fasteners shall be recorded; and

(d) preventative maintenance shall be performed during the test in accordance with the manufacturer's instructions.

8.10 Cautions

8.10.1 Caution

A notice such as the following shall be shown on the lift:

CAUTION -- STAND CLEAR.

8.10.2 Appearance

The lettering specified in Clause 8.10.1 shall be

(a) a minimum of 25 mm (1 in) in height;

(b) in English and French;

(c) in a color that contrasts with the background; and

(d) readily visible.

9. Service Ramps (All Vehicles) Note: The following requirements do not apply to emergency exit ramps.

9.1 Gradient

The maximum gradient of the ramp shall be 1 in 4. If the vehicle is equipped with a kneeling feature, the 1 in 4 requirement shall be calculated in the kneeling mode.

9.2 Construction

9.2.1 Ramp Surfaces

The surface of the ramp shall be made of skid-resistant material and shall be a minimum width of 760 mm (30 in) for full size vans, and 734 mm (29 in.) for mini-vans.

9.2.2 Guards

The sides of the ramp shall be fitted with guards that are 25-50 mm (1-2 in) in height. The outside of the guards shall be clearly marked with yellow and black reflective diagonal strips (to indicate the presence of the unfolded ramp).

9.3 Capacity

The ramp shall be designed for a load of 340 kg (750 LB) distributed evenly over a length of 1100 mm (42 in) and the full width of the ramp half-way up the ramp.

9.4 Power Operated Ramps

9.4.1 Guarding of Moving Parts

Exposed moving parts, such as chains. sprockets, and gears, shall be guarded against hazards inherent in moving machinery.

9.4.2 Operating Conditions

Ramps shall be capable of functioning in an ambient temperature of -40 to +40 c (-40 to +104f).

9.4.3 Controls

9.4.3.1

There shall be only one control for each ramp and it shall be designed to prevent accidental operation. Provision shall be made for safe storage of the control when not being used by the operator.

9.4.3.2

The vehicle shall be equipped with an interlock device designed to prevent operation of the ramp if the parking brake is not engaged.The ramp shall be equipped with a manual override to enable the operator to raise and lower the ramp, and to enable the operator to return the ramp to the stowed position in case of power failure. The override device shall be accessible for use by the operator. A notice in English and French, outlining detailed step-by-step instructions for the hand-moving procedure shall be posted alongside the hand-moving actuation point.

9.5 Securement

If the ramp is stored in the passenger compartment, it shall be secured as per Clause 4.6. 10. Manuals(All Vehicles)

10.1

An operator manual(s) and a maintenance guide shall be supplied with each vehicle.



MINIMUM REQUIREMENTS FOR CONSTRUCTION

AND

EQUIPMENT OF SPECIAL MOTOR VEHICLES

GENERAL

OBJECTIVE

1.1.

To establish standards for the alteration and modification of vehicles to ensure that the vehicle meets standards described in the Highway Traffic Act and its regulations and the Canadian Motor Vehicle Safety Standards.

DEFINITIONS

2.1

Special Motor Vehicles + --passenger vehicles, trucks and buses which are intended for use on public highways, The term "Special Motor Vehicle" shall include the following types:

TYPE 1 Vehicles that retain their original body configuration with changes made to the steering, brakes, power train or suspension systems.

TYPE 11 Vehicles changed from the recognized vehicle manufacture's original body configuration or a reproduction thereof but which retains the general appearance, including changes to the body chassis or engine of the original vehicle. This type may also include changes and modifications to engine, chassis, brake system, power train, steering and suspension systems.

TYPE 111 All special vehicles that are custom built with fabricated parts, or parts taken from existing vehicles excluding Type 1 and Type 11 vehicles.

2.3

S.A.E.--Society of Automotive Engineers.

2.4

C.M.V.S.S.--Canada Motor Vehicle Safety Standards.

2.5

Certification of Compliance - The alterations and modifications done to a motor vehicle shall be certified for compliance by a Qualified Mechanic (Automotive).

2.6

"Used Vehicle"; one that has been purchased from the first purchaser or driven for 8,000 kms. (5,000 mi.)

Although you can not "certify" a used vehicle to meet CMVSS, the vehicle must be altered by a Provincially recognized manufacturer/converter using the same practices and procedures used in altering new vehicles.

2.7

"Final Stage Manufacturer",

a) a company that alters a vehicle that has been completed and certified by an OEM, or

b) An "incomplete vehicle" with the understanding that the vehicle is being completed and certified "prior to the first purchaser."

2.8

"Manufacturer" means a person engaged in the business of manufacturing motor vehicles;

2.9

"Manufacture" includes the process of assembling or altering a motor vehicle in order to complete that motor vehicle for the purpose of sale of that motor vehicle to the first purchaser at the retail level;

3.0

"Recognized Manufacturer" Manufacturer means a person engaged in the manufacturing. assembly or importation of a Special Motor Vehicle intended for use on the Public Highways, or for distribution and sale in the Province,

Statement of Compliance

6. (1) Subject to subsections (2) to (6) and (10), and as a condition of the use of the national safety mark on a vehicle, a label bearing, in clear and in indelible lettering a statement of compliance that is lettered by indenting, embossing or in a colour that contrasts with the background of the label shall be permanently affixed by the manufacturer of the vehicle to the same surface of the vehicle as that to which the national safety mark is affixed, and the lettering of that label shall state, in block capitals and numerals not less than 2 mm in height,

(a) the name of

(i) the company that manufactured the vehicle, if it was manufactured by a company, or, if it was manufactured by a partnership or individual, the usual name under which the partnership or individual carries on business, or

(ii) the company authorized to affix the national safety mark to the vehicle, if a company is so authorized, or, if a partnership or individual is so authorized, the usual name under which the partnership or individual carries on business;

(b) the month and year during which work on the vehicle was completed at the place of main assembly;

(c) that the vehicle conforms to all applicable federal motor vehicle safety standards in effect on the date of its manufacture;

(d) the vehicle identification number;

(e) in the case of a passenger car, multipurpose passenger vehicle, truck, bus, chassiscab, trailer, trailer converter dolly or motorcycle,

(i) the gross vehicle weight rating of the vehicle expressed in kilograms, and

(ii) the gross axle weight rating for each axle of the vehicle expressed in kilograms and identified in order from front to rear.

(f) the type of vehicle, namely, all-terrain vehicle, bus, bus trailer, chassis-cab, competition motorcycle, heavy hauler trailer, limited-speed motorcycle, load divider dolly, motorcycle, motor home, multipurpose passenger vehicle, passenger car, restricted-use motorcycle, school bus, trailer, trailer converter dolly, truck or truck tractor;

(g) in the case of a vehicle other than a passenger car, the information required by subsection 120(12) of Schedule IV, unless such information is listed on a separate label pursuant to subsection 120(14);

(h) in the case of a C-dolly, the mounting height of the coupling when the C-dolly is not loaded; and

(i) in the case of a trailer that is designed to tow a C-dolly, the mounting height of the coupling when the trailer is not loaded.

(2) The gross vehicle weight rating and the gross axle weight ratings shall be clearly identified as such on the statement of compliance by the words "Gross Vehicle Weight Rating" and "Gross Axle Weight Ratings" or "Poids nominal brut du véhicule" and "Poids nominal brut sur l'essieu", or by the abbreviations "GVWR" and "GAWR" or "PNBV" and "PNBE".

(4) In the case of a chassiscab or a truck tractor not fitted with a fifth wheel coupling,

(a) in lieu of the lettering referred to in paragraph (1)(c), the lettering shall state that the vehicle conforms to the applicable federal motor vehicle safety standards in effect on the date of its manufacture and shall list the standards numbers of the standards to which the vehicle conforms in full; and

(b) the statement of compliance label referred to in subsection (1) or a similar document

(i) shall be temporarily affixed,

(ii) shall be affixed so as to be easily readable,

(iii) shall be protected against any weather conditions to which it may be exposed, and

(iv) need not be affixed adjacent to the location at which the national safety mark is to be affixed.

(5) A statement of compliance label that incorporates the national safety mark need not bear the statement referred to in paragraph (1)(c).

(6) In the case of a limitedspeed motorcycle, the label referred to in subsection (1), or a separate label permanently affixed to the vehicle in a conspicuous position, shall also state that the use of the vehicle may be restricted by provincial authorities to certain roads.

(9) For the purpose of paragraph (1)(e), the gross vehicle weight rating expressed in kilograms shall be not less than the sum of

(a) the unloaded vehicle mass;

(b) the rated cargo mass; and

(c) the product obtained,

(i) in the case of a school bus, by multiplying the seating capacity designated by the vehicle manufacturer by 55 kg (120 pounds), or

(ii) in the case of any vehicle other than a school bus, by multiplying the seating capacity designated by the vehicle manufacturer by 70 kg (150 pounds).

(10) In the case of a model of motor vehicle in respect of which the Governor in Council has made an exemption order pursuant to section 9.1 of the Act,

(a) the label referred to in subsection

(1) shall specify

(i) the safety standards by number and title in respect of which the exemption has been granted, and

(ii) the short title of the exemption order; and

(b) a label shall be securely affixed to the windshield or side window of the vehicle specifying

(i) the features of the vehicle and the safety standards by number and title in respect of which the exemption has been granted, and

(ii) the short title of the exemption order.

7. Where a manufacturer completes the manufacture of a vehicle from a chassiscab bearing the national safety mark or from a truck tractor, not fitted with a fifth wheel coupling, bearing the national safety mark, he shall

(a) comply with the requirements of the safety standards set out in Schedule IV that are applicable, in respect of the work carried out by him, to the vehicle so completed;

(b) permanently affix the statement of compliance label referred to in section 6, in respect of the completed vehicle, to the same surface of the vehicle as that to which the national safety mark is affixed and adjacent thereto;

(c) mark the statement of compliance label affixed by him pursuant to paragraph (b) with

(i) the vehicle identification number used by the manufacturer of the chassiscab or truck tractor on the statement of compliance label or similar document temporarily affixed by that manufacturer pursuant to paragraph 6(4)(b), and

(ii) notwithstanding paragraph 6(1)(b), a date of manufacture for the completed vehicle that is no earlier than the date of manufacture of the chassiscab and no later than the actual date of completion of the vehicle; and

(d) remove from the chassiscab or truck tractor and keep the statement of compliance label or similar document temporarily affixed by the manufacturer of the chassiscab or truck tractor pursuant to paragraph 6(4)(b).

7.1 Where a manufacturer alters a vehicle, other than a chassis-cab, that has previously been determined to be in compliance with these Regulations in such a manner that its stated weight ratings are no longer valid, or where the manufacturer alters the vehicle other than by the addition, substitution or removal of readily attachable components such as mirrors or tire and rim assemblies, or by minor finishing operations such as painting, the manufacturer shall

(a) ensure that the original statement of compliance label remains on the vehicle;

(b) comply with the safety standards set out in Schedule III that are applicable in respect of the alteration carried out by that manufacturer to the vehicle that has been altered; and

(c) affix to the vehicle an additional label of the type described in section 6 in the manner and form set out therein stating

(i) the name of the company that altered the vehicle, where it was altered by a company or, where the vehicle was altered by a partnership or individual, the usual name under which the partnership or individual carries on business,

(ii) the month and year during which the alteration of the vehicle was completed,

(iii) that the vehicle as altered conforms to the Canada Motor Vehicle Safety Standards related to the alteration in effect on the date of the alteration,

(iv) if the gross vehicle weight rating or any of the gross axle weight ratings of the vehicle as altered are different from those shown on the original statement of compliance label, the modified values therefor in the form described in section 6, and

(v) the type of vehicle, if the vehicle as altered is a different type from that shown on the original statement of compliance label.

Established by the CONSOLIDATED REGULATIONS OF CANADA, 1978

amended by

SOR/79940 6 December, 1979 pursuant to sections 4 and 7 of the Motor Vehicle Safety Act

Subsection 6(5).

SOR/81455 8 June, 1981 pursuant to section 9.2 of the Motor Vehicle Safety Act

Subsection 6(1) preceding paragraph (a); and subsection 6(10) is added.

SOR/82482 7 May, 1982 pursuant to sections 4 and 7 of the Motor Vehicle Safety Act, effective September 1, 1982

Paragraph 6(1)(e) preceding subparagraph (i); subsection 6(5); subsection 6(9); and section 7 preceding paragraph (a).

SOR/87660 19 November, 1987 pursuant to sections 4 and 7 of the Motor Vehicle Safety Act

Subsection 6(8) is revoked.

SOR/88-268 5 May, 1988 pursuant to sections 4 and 7 of the Motor Vehicle Safety Act

Subsection 6(1) preceding paragraph (a); subsection 6(3); effective September 1, 1988: paragraph 6(1)(e) preceding subparagraph (i); subsection 6(6); and subsection 6(7) is revoked.

PLEASE NOTE THAT THE MOTOR VEHICLE SAFETY ACT IS NOW CHAPTER M-10 OF THE REVISED STATUTES OF CANADA, 1985.

SOR/91-528 5 September, 1991 pursuant to section 4 of the Motor Vehicle Safety Act

Subsection 6(1) preceding paragraph (a), effective September 1, 1992; subsection 6(1) by adding paragraph (f), effective September 1, 1994; subsection 6(1) by adding paragraph (g), effective September 1, 1992; subsection 6(3) is revoked, effective September 5, 1991; section 7 by adding section 7.1, effective September 1, 1992.

SOR/93-146 23 March, 1993 pursuant to sections 4 and 7 of the Motor Vehicle Safety Act

Subsection 6(1) by adding paragraph (h) and (i).

3.1

Manufacturers/Converters will be self-certifying in these standards.

3.2

Manufacturers/Converters will present each of their commercial products for yearly (or two yearly) inspections, to (an identified authority), to confirm their compliance to the CMVSS and (D 409, or alternative) standard. Manufacturers/Converters must be prepared to present their documentation for viewing as required. Each commercial product will then be recognized for sale in the Province of Manitoba. It must remain in the configuration presented for inspection for the time Period stated above. Any alteration of the presented configuration must be presented for re-inspection. Any Manufacturer/Converter found supplying vehicles in(to) the province without inspection, or if altered from original inspection may be subject to fine.



Recommended Compliance Inspection Report and Safety Inspection Amendments

General Vehicle Compliance Inspection

Name of Owner/Manufacturer

_______________________________________
Address:
______________________________________________

______________________________________________

______________________________________________

Date: ____________________ Time: _____________________

Vehicle:

Year:__________ Make: _____________________

Type: ____________________________________________

Serial Number: ___________________________________

Plate: ___________________________________________

Board Number: ____________________________________

Inspected by: ___________________________________________

Pass Fail N/A

4. 	General requirements
4.1 	General
4.2 	Modifications
4.3 	variances
4.4 	Type of Vehicle
4.5 	Securement of Devices
4.6 	Portable Support Equipment 14

5. Vehicle Chassis 15
5.1 	Battery (All Vehicles)
5.1.2 	Battery Compartments
5.3 	Bumpers(All Vehicles)
5.3.1 	Front Bumper
5.3.2 	Rear Bumper
5.6 	Exhaust System (All Vehicles)
5.6.1 	Location
5.6.2 	Direction
5.6.3 	Clearance
5.7 	Frame(ALL Vehicles)
5.7.1 	Modifications
5.7.2 	Holes
5.10 	Gross Vehicle Weight (All Vehicles)
5.14 	Openings(All Vehicles)
5.16 	SpareTire(All Vehicles)

6. Vehicle Body
6.1 	Identification(All Vehicles 
	Unless Precluded by Regulation)
6.1.1 	Location of Symbol
6.1.2 	Appearance of Symbol
6.4 	Bumpers (ALL Vehicles)
6.4.1 	Front Bumper
6.4.2 	Rear Bumper
6.5 	Insulation(All Vehicles)
6.5.1 	General
6.5.2 	RValue
6.6 	Windows(All Vehicles)
6.8 	Service Entrances
6.8.1 	Service Doors(ALL Vehicles)
6.8.2 	Steps
6.9 	Emergency Exits (All Vehicles)
6.9.1 	General
6.9.2 	Securement During Unloading
6.9.4 	Restrainment/Securement Devices
6.10 	Lighting (ALL Vehicles)
6.11 	Inside Height
6.12 	Floor(ALL Vehicles)
6.12.1 	General
6.12.2 	Static Coefficient of Friction
6.12.3 	Strength
6.13 	Passenger Seating and Seats
	(All Vehicles)
6.13.1 	Mobility Aid Passenger Seating
6.13.2 	Ambulatory Passenger Seating
6.13.3 	All Passenger Seating
6.14 	Grab Bars/Handles (All Vehicles)
6.14.1 	Location 
6.14.2 	Diameter/Width
6.14.3 	Strength
6.15    Projections and Padding (All Vehicles)
6.15.1 	Projections
6.15.2 	Padding
6.15.3 	Physical Properties of Padding
6.16 	Rearview Mirrors
6.16.1 	All Vehicles
6.16.2 	Vehicles, Convex Mirrors
6.18 	Heater(All Vehicles)
6.18.1 	Type of Heater
6.18.2 	Combustion Type Heaters
6.18.3 	Capabilities of Heating System
6.18.4 	Heater Lines
6.24 	Wiring (ALL Vehicles)
6.24.1 	General
6.24.2 	Circuits
6.24.4 	Insulation and Protection
6.24.5 	Fastening and Joining
6.25 	Rollover Protection
6.26 	Warning

7. Mobility Aids (All vehicles)
7.1 	Space Requirements
7.1.1 	Floor Space
7.1.2 	Fixed Vehicle Structures
7.2 	Securement
7.2.1 	Securement Devices
7.2.2 	Anchorage Points
7.3 	Mobility Aid Occupant Restraint
7.3.1 	Occupant Restraint Systems
7.3.2 	Seat Belts
7.3.3 	anchorage Points
7.4 	Simultaneous Loading

8. Lifts (All Vehicles)
8.1 	Securement to Vehicle
8.1.1 	Vehicle interface Test
8.2 	Platform Dimensions
8.3 	Capacity
8.3.1 	Minimum Load
8.3.2 	Static Load test
8.4 	Platform Construction
8.4.1 	Surface
8.4.2 	Guards
8.4.3 	Roll Stop
8.4.4 	Handrail
8.4.5 	Restraining Device
8.5 	Guarding of Moving Parts
8.6 	Operating Conditions
8.7 	Rated speed
8.8	Controls
8.8.1 	General
8.8.2 	Number of Controls
8.8.3 	Interlock Device
8.8.4 	Manual Override
8.8.5 	Override Speed
8.8.6 	Powered Closing Platform
8.9 	Rated Speed
8.8 	Controls Reliability and Durability
8.9.1 	General
8.9.2 	Accelerated Life Cycle Test
8.10 	Cautions
8.10.1 	Caution
8.10.2 	Appearance

9. Service Ramp (ALL Vehicles)
9.1 	Gradient
9.2 	Construction
9.2.1 	Ramp Surfaces
9.2.2 	Guards
9.3 	Capacity
9.4 	Power Operated Ramps
9.4.1 	Guarding of Moving Parts
9.4.2 	Operating Conditions
9.4.3 	Controls
9.5 	Securement

10. Manuals (ALL Vehicles)

                               PASS    FAIL    N/A



Accessible Taxi and Handivan Inspection form

and

the Certificat of Motor Vehicle Inspection form

(need to be amended to include inspection for accessibility features safety compliance.)


Wheelchair Restraints

Grab Handles in place

Markings on Steps

Quick Release seats functional

Ramp/Lift in safe working order

Emergency exit windows functional, (if installed)

All required Logos intact and in place, (interior and exterior)

Running boards secure, (if installed)



Seventh Section

Appendix

DUE TO THE SIZE OF THIS SECTION, IT IS AVAILABLE FOR VIEWING OR COPYING AT THE MANITOBA TAXICAB BOARD. IT IS RECOMMENDED BY THE CONSULTANT THAT IT BE REVIEWED PRIOR TO READERS INTERPRETATIONS OR CONCLUSIONS

A) Vehicle Examples and Related Costs

B)

1) CSA D 409 92 "Motor Vehicles for the Transportation of Persons with Physical Disabilities"

1a) CSA Z 605 "MASOR"

2) Manitoba Highway. Traffic Act Regulation 75/94

3) Taxicab Act, Taxicab Regulation 209/91 4) Quebec Highway Safety Code "Road Vehicles Adapted for the Transportation of Handicapped Persons", R.S.Q., c. C-24.2, section 621, paragraph 2.1

5) B.C. Transit - "Mobility Aid Lift-Equipped Custom Transit Vans"

6) Highway Traffic Act Regulation 76/94,


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