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Interpretation ID: Maxon9759

    S.Lafferty, Manager, Engineering
    Maxon
    16205 Distribution Way
    Cerritos, CA 90703


    Dear Mr.Lafferty:

    This responds to your letter in which you raised several questions regarding Federal motor vehicle safety standard (FMVSS) No.403, Platform lift systems for motor vehicles.Your letter raised issues with the control illumination, attachment hardware, and interlock requirements of the standard.I have addressed each issue below.

    By way of background, the agency established FMVSS Nos.403 in order to protect individuals that are aided by canes, walkers, wheelchairs, scooters, and other mobility devices and rely on platform lifts to enter/exit a motor vehicle.FMVSS No.403 is an equipment standard that specifies minimum performance requirements for platform lifts designed for installation on motor vehicles.The agency also established the companion standard FMVSS No.404, Platform lift installations in motor vehicles, which specifies requirements for vehicles equipped with platform lifts.

    Illumination of Lift Controls

    S6.7.6.2 of FMVSS No.403 requires that platform lift controls on a public use lift must be illuminated according S5.3 of FMVSS No.101, Controls and displays.In part FMVSS No.101 requires that the illumination of controls must be adjustable to provide at least two levels of brightness, one of which is barely discernible to a driver who has adapted to dark ambient roadway conditions.The low level of illumination is to minimize the impact of the illumination on a drivers night vision.

    In your letter, you stated that the controls on the lifts manufactured by your company, Maxon, are not located in the driver compartment.As such, you stated that there is no need for a dual level of illumination as specified in FMVSS No.101.

    The illumination requirement in FMVSS No.403 is applicable to all controls, regardless of location.An amendment to this requirement would have to be accomplished through the agencys rulemaking procedure.

    Attachment Hardware

    S6.3.1 of FMVSS No.403 requires that a lift manufacturer provide all of the attachment hardware necessary to install a lift on a vehicle.In your letter you stated that some installations may require longer bolts than that provided or that bolts may be lost during installation.You asked if Maxon would be permitted to specify attachment hardware by "grade, size, plating etc and allow substitute hardware" in those instances.

    S6.13.1 requires a lift manufacturer to specify, either by make and model or by design elements, the vehicles on which the lift is designed to be installed.The attachment hardware provided must permit the installation of a lift on these vehicles.If a vehicle is listed under S6.13.1 that requires a longer bolt, then a longer bolt must be provided.

    With regard to hardware lost during the installation process, we recognize that lift installers may need to obtain replacement hardware.Nothing in the standard prohibits a lift manufacturer from providing the hardware specifications in conjunction with the actual hardware.

    Interlock requirements

    Your letter correctly states that under S6.10.2.2 of FMVSS No.403, an interlock must prevent operation of a platform lift from a stowed position until forward and rearward motion of a vehicle is inhibited.You then asked what is required if during lift operation there is a failure of the interlock: should lift operation cease or continue in the event of such a failure?

    FMVSS No.403 does not specify how a lift must operate in the event of an interlock failure.Therefore, it is up to the individual manufacturer to determine an appropriate default status.

    I hope you find this helpful.If you have any additional questions, please contact Mr.Chris Calamita of my staff at (202) 366-2992.

    Sincerely,

    Jacqueline Glassman
    Chief Counsel

    ref:403#404
    d.2/2/05