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Federal Transit Administration

Assessment of Fixed Route Bus

Wheelchair Lift Maintenance & Reliability

This assessment tool is designed to assist transit agencies and the Federal Transit Administration in determining if accessibility equipment, particularly wheelchair lifts, on fixed route bus systems are operating reliably. It also is meant to assist in assessing lift cycling and maintenance, and related service policies. Guidance is provided on getting input in the review process from local disability organizations and customers, on selecting vehicles to be reviewed, and on conducting actual on-street observations of lift cycling, operation, and maintenance practices. Guidance is also provided on administrative follow-up issues related to promoting and implementing a policy for successful lift maintenance and operation.

Revised 1 June 2006

Regulatory Requirements

Maintenance (for all types of entities and services)

General equipment maintenance requirements, which pertain to all types of entities and services are contained in 49 CFR §37.161. Lifts, ramps, securement systems, public address systems, and other access-related equipment must be maintained in operating condition. If damaged or out of order, this equipment must be repaired promptly. When equipment is out of order, reasonable steps must also be taken to accommodate riders who would otherwise use the equipment.

Maintenance (for public entities only)

In addition to the general maintenance provisions described above that apply to all transportation providers, 49 CFR §37.163 requires public transportation providers to institute regular and frequent maintenance checks of lifts. Drivers are required to report lift failures as soon as possible. Every effort must be made to repair lifts before the next day of service. If the lift cannot be repaired before the next day of service, the vehicle can be placed back in operation only if a spare is unavailable. Vehicles with inoperable lifts can be kept in service for no more than three days (if the entity serves an area of over 50,000 population) or five days (if the entity serves an area of 50,000 or less population).

Preparing to Review Fixed Route Bus Lift Maintenance and Reliability

Following the directions below for preparing for a review of lift reliability and maintenance, complete the "Preparation Checklist" on the following pages.

Scheduling the Review, Requesting Information about Lift Maintenance, Policies, and Standards

FTA will notify the transit system that FTA is planning a review of lift maintenance and reliability. Actual on-site days should be picked to not include holidays or other atypical days. FTA will send a letter to the transit agency indicating the dates of the on-site visit, information needed in advance of the visit, and information that should be available at the time of the visit. The letter should confirm a previously discussed opening and closing meeting with appropriate staff (i.e., the General Manager or designee, Director of Operations, ADA Coordinator, etc.).

The following information would be requested in advance:

Several copies of the most recent system route map.
A complete set of current detailed route schedules.
Identification of which routes are operated in-house and which are operated by a private contractor.
Identification of which routes/areas are served by each garage.
Identification of transfer points and locations where different routes share a common line.
Bus fleet inventory identifying year, make, bus garage, and accessibility of each bus, including whether the system uses low-floor buses and to what extent.
A description of lift maintenance practices identifying the location and party performing lift maintenance.
Current Fixed Route Operator Manual/s, notices, bulletins, memoranda, or other documentation informing vehicle operators of lift operation and maintenance policies.
Reports, memoranda, or other documentation regarding lift operation and maintenance monitoring activities and findings.
A list of complaints related to lift operations in the past year. The list should include customer's name, trip origin, date and type of complaint, carrier, and resolution (any corrective actions requested and taken).

Documentation of Current Policies

In advance of the on-site visit, review the fixed route Operator Manual (or manuals if there are different documents for different types of service or different operators) to see if and how policies and instructions for lift cycling and reporting lift malfunctions are explained to operators. Based on the manual and also on conversations with the transit agency staff, develop a general understanding of how lift cycling and maintenance is handled. Specifically:

Are lifts cycled each day?
Who is responsible for cycling the lifts (drivers, starters, mechanics, etc.)?
When and where does the lift cycling take place?

Complaints on File

Review any current complaints or past complaints related to fixed route bus lift maintenance and reliability that are on file with the FTA Office of Civil Rights. For any past complaints, review the file to determine the final outcome-any corrective actions requested and taken. Also note from any complaint files which routes, areas, types of vehicles, or operators were the subject of the complaint(s).

Contact with Local Disability Organizations

Prior to the on-site review, contact local disability organizations and any past complainants (or a few selected complainants if there are a large number on file). Complaints may have been filed with the assistance of local organizations, which will help identify possible agency contacts. Other possible approaches for identifying appropriate local agencies include contacting the National Organization on Disability (NOD) State Contact.

At a minimum the there should be an attempt made to contact the following organizations:

Centers for Independent Living
Paralyzed Veterans of America
ADAPT
Rehabilitation agencies and centers

When contacting each local agency, ask first to speak to the agency director. Explain the purpose of the call and inquire whether fixed route bus lift reliability and maintenance have been or are a concern. If yes, determine if there is any documentation of problems and/or attempts to work on the issue with the transit agency (letters, local complaints not filed with FTA, etc.).

From any past complainants, ask if the situation has improved and if any required corrective actions have been taken.

Arrange with either a staff person of a local organization or a complainant (the selected person should be a person who uses a wheelchair) to meet while on-site to jointly assess selected routes.

Schedule for On-Site Review of Lift Reliability and Maintenance

The review team coordinator should develop an on-site task schedule for each reviewer for each day. The on-site review will consist of the following tasks:

An opening meeting with agency staff.
Observing lift cycling (if applicable) at representative garage(s).
Examining lift maintenance records at these same garages or at a contract maintenance location.
Riding selected accessible routes with a person who uses a wheelchair.
Interviewing drivers about policies regarding lift malfunctions.
Interviewing administrative staff about operator training, internal monitoring, follow-up to internal monitoring, and complaint records.
A closing meeting with agency staff.

For a typical review, it is recommended that observations of lift cycling take place in the early morning (at pullout) on the first day of the review. Two team members should be assigned to each garage/yard being reviewed. Depending on the size of the operation and the number of team members, this may need to be done on the morning of the second day as well. The examination of maintenance records will typically happen late morning, immediately following the observation of lift cycling. Drivers would also be interviewed at the garages in the late morning as they come in for breaks. Riding the system with a person who uses a wheelchair could then be done in the afternoon(s). While one team member is riding the system, other members could interview administrative staff. The closing meeting would then take place on the last day of the on-site visit.

If lifts are cycled at times other than the morning pullout, or if lift maintenance is done off-site, this typical schedule would need to be revised.

To develop the schedule, select garage/yard locations for observing lift cycling and examining maintenance records. Consider:

Observing lift cycling by all operating entities (in-house and contractors), to some degree.
Observing cycling and maintenance at garages in various parts of the service area, to some degree.
Focusing on certain garages if there is evidence from complaints or conversations with local agencies that certain parts of the system (or types of vehicles that may be at certain garages) need more intensive review.

Also, select routes to be reviewed. The above considerations regarding coverage of all operators, areas, and key routes mentioned by customers would apply to this selection as well.

The coordinator for the on-site effort should then develop a detailed daily schedule for each person involved. Copies of detailed route maps and schedules for selected routes should then be provided to each team member.

Overall On-Site Schedule

Finally, the review coordinator should develop a schedule for the overall on-site visit. The first two or three days should involve on-street observations and interviews. The last day should include final interviews and data collection and a closing meeting with administrative staff.

On-Site Review Activities

Observing lift cycling: For each garage visited, have two team members arrive about 15-30 minutes before the first pullout is scheduled. Upon arriving, the team will introduce themselves to the depot management. It is expected that management will allow the team to interact with drivers without interference, and will assist in coordinating access to drivers. As drivers arrive and prepare to pullout, ask them if they will be cycling the lift. If they say they did not plan to do this, ask them to please cycle the lift. Record if the driver planned to do this without a special request. Observe the cycling and record the working condition of the lift. Also, ask the driver to test the kneeler (if applicable) and the PA system (if applicable). Record the condition of this equipment. Under "Comments," note observations such as the driver's familiarity with the equipment operation. Finally, if the lift does not function properly, note how the driver reports this and whether the vehicle is replaced with a spare, sent out on the route anyway, etc.

Examining lift maintenance records: After observing the lift cycling, ask to speak with the chief mechanic at the garage. Ask to see the log of reported breakdowns and equipment failures (every system should have some type of log of needed repairs). Scan the log for the past few months and record information about needed repairs on lifts on the "Lift Maintenance and Repair Summary Form." Note on this form the bus number, the date the breakdown was reported, and the date the repair was completed. If there was a lengthy delay (3-5 days) before the repair was completed for any entries, ask for the "pullout sheet" for that day. Check to see if that bus was operated on a route during the time that the lift was not operable. Also, determine if spare accessible vehicles were available that day. Record this information in the last column of the "Lift Maintenance and Repair Summary Form."

Riding selected accessible routes with a person who uses a wheelchair: Meet the customer who volunteered to assist with the review and travel on several accessible routes. Record equipment and driver performance on the "Fixed Route On-Board Service Review Form." Although the primary purpose of the review is to check lift reliability and operator performance, record any other observations that may occur during travel, such as assistance provided to other passengers, stop announcements, etc. (as indicated on the form).

Preparation Checklist for Review of Lift Maintenance and Reliability

Name of Transit Agency:_________________________________________________________

City and State:_________________________________________________________________

Form Completed by:_____________________________________________________________

? Obtain a fleet inventory by garage.

? Obtain a sufficient number of copies of system maps and schedules for several accessible routes that are candidates for assessment efforts.

When, where, and by whom is lift cycling performed?__________________________________

______________________________________________________________________________

Identify Garages, Maintenance Activities, and Fixed Route Bus Contractors below. Asterisk those to be visited for lift cycling and maintenance records.

Bus/Maintenance Garage Name and Address

Area/Routes Served

Contractor(s) Using the Facility

Number and Types of Buses at Facility

Lift Maintenance Performed There?

? Check FTA complaint records. Are there any current or past complaints related to fixed route bus lift maintenance and reliability?

? Yes ? No

If Yes, how many complaint summaries are attached:_________________________

Summarize complaints below (attach additional sheets as necessary).

Complaint Number:___________________ Date of Complaint:_________________

Issue:________________________________________________________________

_____________________________________________________________________

Resolution/Corrective Actions:____________________________________________

_____________________________________________________________________

Are any particular routes/areas/vehicle types/operators/ identified that should be assessed?