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On-board Circulation and Seating Sub-Committee

to the U.S. Access Board’s Rail Vehicles Access Advisory Committee

Summary Recommendations Report, February 13, 2015

I. Doorway width, exterior (side doors)

Minimum clear doorway opening: 32 inches

This requirement is for all rail vehicles and all side doors that are on the path to accessible areas 

of a car or on cars that may provide the only exterior access to an accessible car that does not 

have side doors as in a car that might be coupled to an intercity diner.

II. Bi-parting doors

Bi-parting doors with individual leaves that provide less than 32” clear opening were raised as 

an issue particularly on rapid rail systems where, should a single leaf not open, the passenger 

may not be able to exit the train and be forced to the next station and beyond. The 

Subcommittee offers the following:

Possible recommendations:

a. Bi-parting doors should have at least one leaf that opens to a clear width of 32” 

b. Door leaves interlocked so that a functioning door always opens both leaves

c. Both leaves must have an emergency release feature in case one leaf is 

obstructed or damaged so that it cannot open

d. Communication method / device provided at the door area to alert the 

driver/operator to ensure passengers do not get stuck on the car because of 

inoperative doors. (Device location must comply with requirements for 

reachability of controls from a wheelchair.)

Discussion

1. The Subcommittee would like industry input from door and vehicle manufacturers to 

determine the most practical and reliable solution based on the issues listed below. 

2. The key issue of this issue is that passengers can get stuck on trains and carried to 

distant stations and returning to the intended station can be difficult and/or dangerous. 

Regulating the size of door components may not solve the problem since any door 

opening system can and will fail in time. The key to avoiding the problem of getting 

trapped is to have immediate communication available between the passenger and 

operator so that the passenger can be let out of the car and the door locked out until it 

can be serviced. The Subcommittee would like to solicit comment from industry 

representatives in order to make final recommendations.

III. Doorway width, between cars (end doors) 

Minimum clear doorway opening: 32 inches
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This requirement is for all rail vehicles except for the operator’s cab ends of transit cars such as 

subways, MU (Multiple-Unit) cars and commuter cars that have legitimate conditions that 

impact the end doorway. Those conditions are: system clearance, structural requirements, the 

operator having appropriate physical space and the operator’s safe field of vision. 

Proposed: The Cab ends of vehicles that may be used coupled within a train:

1. MU cars and Cab Cars, regardless of mode may have end doors of 30” if:

a. There is a legitimate issue for the vehicle operator having appropriate 

space and creating a wider path adversely impacts the operator’s safe 

field of vision. Agencies must demonstrate that restrictive clearance, 

structural requirements and operator ergonomics justify the use of the 

30” dimension as opposed to the 32” typical dimension.

b. Movement through this doorway shall not be necessary for an 

individual to get to accessible seating space.

c. The path to the door is less than 32” because of seating arrangements.

IV. Overlap of clear path between cars. 

Safety devices or appliances required for the safe operation of the train may overlap the 

clear path as follows:

1. Protrusions into the clear aisle /doorway between cars must be at least 34” 

above the floor of the vehicle and may protrude no more than 4” (See 

36CFR1191, appendix A, 404.2.3)

2. On cars where the doorway is 30” wide protrusions may overlap the path 

through the doorway by a maximum of 2” at or above 34” minimum from the 

floor.

3. Protrusions into the path may not continue for more than 12” longitudinally and 

may not occur simultaneously on the opposite side of the path. 

4. Protrusions must be separated longitudinally by a minimum of 20”. This assumes 

two coupled cars with the same end configuration

Discussion: Safety devices for use by railroad crews are often located at the ends of cars and in 

some cases such as lever type hand brakes, have geometric dimensions and locations that are 

critical to safe operation particularly during emergencies. One such device is the lever type 

hand-brake that has a maximum pivot height determined by other governing bodies. Agencies 

should be prepared to present legitimate reasons why such devices cannot or should not be 

located elsewhere. The dimensions of items 3 and 4 should be verified and revised if needed.

V. Clear width from door to mobility aid seating location

Minimum aisle width 32 inches

This requirement is for all rail vehicles 
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VI. Vestibule width

44 inches minimum

This applies to vehicles with vestibules, wind screens, modesty panels or other partitions that 

establish an entrance or “vestibule” area separate from the occupied passenger space. Vehicles 

that have defined walls that establish a “vestibule” separate from passenger occupied space 

should be 44” wide over the most restrictive protrusion where 90 degree or similar turns are 

required immediately upon entering the vehicle. If the vestibule is arranged to allow a freeflowing path into the passenger area or aisle leading to that area, then the most restrictive 

width of the vestibule near the door may be less than 44” but in no case can the unobstructed 

path to the accessible seating area be less than 32”. (An example would be a space defined by 

angled or rounded walls that provide a progressively broader path)

VII. Entrance width for cars without vestibules

44 inches minimum

Vehicles that do not have vestibules or otherwise physically defined separation between 

entrance areas and passenger occupied areas and require 90 degree or similar turn to reach the 

accessible seating space must have a clear path dimension across the vehicle free from panels 

or stanchions at least 44” wide. This path should be a straight line across the doorways on 

opposite sides of the vehicle. 

Discussion: The intent of this definition is to insure that people in mobility devices can quickly 

move onto the vehicle but at the same time not over defining vertical stanchions to the point 

that ambulatory safety is compromised.

The opinion expressed generally by community members is very much in favor of 

recommending the clear projected space 44” wide across the vehicle, assuming that the doors 

are directly across from each other as is most common. The most expressed concern is that 

during heavy loadings it can be difficult or impractical for passengers using wheelchairs to move 

into designated spaces or move off of the train efficiently. Stanchions (poles) that accumulate 

standees make maneuvering into the car very difficult. Unfortunately the courtesy that might 

be afforded to passengers in certain regions or communities cannot be predicted or relied 

upon. Regulation is often an unfortunate necessity to insure that what should be basic courtesy 

in civilized society is guaranteed, particularly when some people may not be able to exercise 

the options available to the general public. We have seen during the course of the RVAAC’s 

work that while one provider has found that removing or rearranging stanchions improved 

overall circulation other systems are concerned that safety may be compromised. While it is 

most likely that the subcommittee and full committee would recommend the clear 44” 

dimension across the car, perhaps the Access Board could best serve the community and 

providers by considering studies, modifications and procurements that are underway before 

generating the proposed rule for this situation. Often changes that seem impractical or 

inefficient create unintended positive consequences such as those experienced by the 

Washington, DC Metro. Other providers and builders are seeing a shift to reducing vertical 

stanchions in door areas to improve general passenger flow on and off of the cars.)
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Two particularly good comments during the 12-11-14 meeting were “Design can work against 

controversy” and “Defined positions encourage bad habits)

VIII. Clear space for mobility aid seating location

32” x 54”/32” x 59” minimum

32” x 54” minimum is required where the space is confined on no more than two sides. 

32” x 59” is required when the space is confined on 3 sides to insure adequate maneuvering 

space. The rules for the overlap of space by fixed objects apply to this dimension.

Discussion: The increase from the original ADA definition is to accommodate larger and 

differently configured mobility aids and ensure that space for maneuvering is provided.

IX. Overlap of seating clear space

This applies to all rail vehicles. The required Clear space for mobility aid seating location may be 

overlapped by a maximum of 6 inches at or above height of 12 inches above the floor.

X. Number of mobility aid seating positions

Minimum of 2

Additional Accessible Seating:

Some quantity of seats should be easily removable or convertible to temporarily accommodate 

groups of individuals using wheelchairs. 

Discussion: There should be some definition of the quantity of seats that should be removable 

per vehicle by mode. Removing or converting seats should not generate conflict with other 

requirements for accessibility and where conflict occurs the applicable requirement should be 

waived. Depending on the mode, convertible seats may have reduced functionality. This is 

especially true of more complex seats used in intercity trains where the added mechanical 

function interferes with other comfort features. The convertible seats will likely fall into the 

area where the seats need to be transfer seats. There should be language to address this 

possibility.

Operational practices are not part of the RVAAC responsibility, however by requiring 

removable or convertible seats there is an implied, if not defined, requirement for a provider to 

offer a seat removal plan and service. Depending on the mode or the nature of the operation, 

the impact to the provider could be substantial. In the absence of a policy for the provision of 

service, equipping vehicles is irrelevant. As an example, many but not all of Amtrak’s cars use 

a seat track system that allows for seats to be easily removed but the policy for removing seats 

for groups has not been consistent. In the case of Tier II trains the structural requirements for 

attaching seats makes removing seats especially difficult. In the case of transit systems where 

vehicle availability and seat volume is more time-of-day critical the logistical problems of 

managing a car with missing seats could dramatically impact the system’s ability to provide its 

service. Examples of what type of group movements should be reviewed and community and 

industry input solicited in order to craft more defined language for the NPRM. 
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XI. Handrails and stanchions

1. Size: 1.25 - 1.5 inches

2. Knuckle clearance: 1.5 inches minimum

3. Handrails, hand holds or similarly functional devices should be included on passenger 

seats. The purposes of such devices are:

a. Provide a discreet firm point for passengers to safely navigate to their seat or other 

amenities while the train is in motion.

b. Provide a safe condition for standees when other railings, loops or stanchions are 

unavailable.

c. Assist passengers in standing up from their seats.

4. Depending on the Mode, vertical stanchions should be included adjacent or as part of 

the seat at every other seat. Modes not subject to standee conditions as part of normal 

operation or where rotating or changeable seats are used are not required to include 

vertical stanchions.

5. Handholds, whether vertical or horizontal, provided adjacent to doors to aid boarding 

and alighting passengers whether in wheelchairs or ambulatory may be at the 32” 

minimum or 6” less than the clear door opening apart, whichever is greater.

6. Vertical handholds intended as boarding aids that project into the clear door opening 

should terminate no lower than 34” from the floor unless the device is intended as an 

aid to employees boarding from the ground or as an aid to passengers evacuating to the 

ground.

XII. Farebox guard

Required for light rail systems only

XIII. Maneuverability near doors 

See items IV, VI and VII. The intent of the referenced items is to insure that the space near the 

doors is preserved for maneuverability.

XIV. Maneuvering space at wheelchair seating locations

A 60” maneuvering circle must be provide at each Mobility Aid Seating Location. 

This requirement is for all rail vehicles to ensure that the passenger can maneuver the 

wheelchair into the seating location. The circle may overlap the aisle, Mobility Aid Seating 

Location and other maneuvering locations. The purpose of the maneuvering circle is to ensure 

that a passenger can turn to face their desired direction of travel and exit the Mobility Aid 

Seating Location toward the door in which they entered the vehicle.

XV. Service animal spaces

A minimum of two (2) spaces measuring 14”w x 38”l x 16”h must be provided for service 

animals. 

This requirement is for all rail vehicles. 
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Service Animal space may be overlapped by fixed objects by 6” at 12”H and 12” at 16”H. Service 

Animal Space may overlap other defined floor space by a maximum 6” longitudinally and 

transversely. 

Discussion: This should be reviewed physically to make sure that the measurements are 

appropriate. A short study involving live animals and their owners should be performed to 

make sure that the space is comfortable and safe for the animal and passengers. Likewise if the 

space is found to be oversized then the overlap dimensions might be increased.

XVI. Transfer seat details 

1. For all vehicles, seats considered transfer seats must have a seating surface that is at 

least 17”- 19” above the finished floor. Bolsters or other cushion features must not 

extend above19” to avoid hindering transfer.

2. For all vehicles, seats considered transfer seats with armrests must include armrest that 

rotate out of the way so as not to inhibit transfer. When rotated out of the way, the 

armrest must be at least 1⁄2 inch behind the surface of the seat back. Armrests must be 

designed to remain in the upright or down position during normal train motion.

3. For intercity rail vehicles only, seats in sleeping cars, food service cars and dining cars, or 

other seats intended for occupancy by persons who wish to transfer from a wheelchair,

must be at least 17”-19” above the finished floor. No portion of the seat frame or 

shrouds may extend beyond the passenger surfaces of the seat bottom or back.

XVII. Mode Details for Less Prevalent Rail Vehicles

1. Historical or Heritage vehicles are included in light rail. 

2. Replica and rehabilitated cars with a capacity of “x” or less are the same as light rail 

except for seating locations. Cars with a capacity of more than “x” are the same as light 

rail (Industry comment and recommendations are requested to generate a valid 

capacity and or vehicle size. This should include recommendation for loading definition 

such as normal, crush loading etc.)

3. Monorails in transit service are subject to the same requirements as light rail systems. 

Some exception may be needed for wheel intrusion on straddle beam vehicles.

4. Automated Light Rail Transit (ALRT), Automated Guideway Transit, (AGT), Skytrains, etc.

are subject to the same requirements as light rail systems. 

5. Cable Tramways services are subject to the same requirements as light rail systems.

6. Cog Railways are subject to the same minimum requirements as light rail systems

7. Incline planes / funiculars with 16 or fewer passenger must have one accessible seating 

location; vehicles with more than 16 passengers are subject to the same minimum 

requirements as light rail systems

8. Maglev (Magnetic levitation and propulsion) with capacity of more than 16 passengers 

and operation exceeding 60 MPH will comply with the requirements of intercity rail. 

Vehicles on systems with vehicle capacity of 16 passengers or less and /or operating less 

than 60MPH must comply with the requirements for Automated Guideway Transit

(AGT).

9. Personal Rapid Transit (PRT). Each car must be accessible with 32” entry doors and one 

accessible seating location. Otherwise PRT’s will comply with Light Rail requirements.
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XVIII. Intercity, High speed and Articulated Vehicle Restrooms

This applies to all vehicles that are required to or otherwise have accessible restrooms. 

Vehicles that are semi-permanently coupled or otherwise provide coupled diaphragm 

passageways that provide continuous floor surfaces and that create no vertical or lateral

shearing conditions found in conventional cars with individual diaphragms may be arranged so 

that only one of the vehicles contains an accessible restroom. Each car must have the required 

number of accessible seats. Further, only one of the cars must have a vestibule and side doors. 

In all conditions, the pathways between accessible spaces, vestibules and restrooms must meet 

the minimum requirements set forth for accessibility. (According to 42 USC 12162(a) (3) 

Intercity (Amtrak) coaches must have accessible seating spaces AND an accessible restroom. 

This does not eliminate the possibility of a car builder or Amtrak from applying for equivalent 

facilitation.)

XIX. Vertical Movement on Intercity Long-Distance Bi-Level Cars

Following are draft recommendation for vertical movement of passengers with disabilities

between the levels of new intercity (Amtrak) passenger cars.

APPLICABILITY:

This applies to new bi-level intercity lounge cars built for Amtrak and any bi-level equipment 

used by successors to an Amtrak route acquired by another operating entity or company as 

sanctioned under PRIAA. FURTHER, cars operated by private companies in scheduled intercity 

long distance service shall comply. Lounge means any car with a primary function that is to 

enhance the passenger experience beyond the purchased coach or sleeper accommodation and 

is so designed to enhance viewing from the second level. This requirement extends to any bilevel car, with or without food service, except diners, that has non-revenue seating available to 

all passengers on the train on a first come basis. 

Open platform observation areas that are accessible to passengers at no extra charge and those 

provided for an extra fare must be made accessible to passengers using mobility devices. Full 

service Diners with a lower level kitchen that is not designed for passenger use are not required 

to have built-in vertical access. 

While not considered true bi-level cars, single level cars traditionally known as “dome cars” that 

offer an elevated area designed for viewing scenery, with or without food service must have a 

number of accessible seating spaces and vertical access to reach the viewing level. Accessible 

spaces in the dome car may be convertible for use by other passengers when passengers using 

wheelchairs are not present.

Possible Additional Applicability: 

1. All bi-level Intercity Long Distance bi-level coaches. 

2. All bi-level Intercity Long Distance sleepers. (Key points are the number of rooms 

accessible per car, the type of room, upstairs and downstairs etc.)
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3. All bi-level Intercity Long Distance Diner cars. Accessible from the adjacent car or 

dining tables are provided in the Lounge car. (The entire lower level of the diners is 

consumed by the kitchen.)

GUIDING PRINCIPALS

1. Features providing access for people with disabilities must be equivalent to those 

provided others in terms of functionality and aesthetics, and must not segregate 

individuals with disabilities. 

2. Accessible features should be the norm for everyone. 

3. There may not be restrictions on using any facilities or features until the train is 

stopped.

4. Safety concerns must be balanced with the underlying civil rights principles of the ADA.

5. Establishing policy mandates will drive the development of improved generations of 

technology.

6. All train cars should be accessible.

7. Access Board guidelines should promote the development of technology, and not freeze 

current technology in place.

8. Every circulation path used by the public needs an accessible route.

9. We must consider the growing demographics (the graying of America) when we 

establish scoping for accessible features.

REQUIREMENTS

New intercity bi-level passenger trains have some means of transferring passengers using 

mobility aids, or who otherwise cannot negotiate stairs, between the levels. The goal is to 

expand the full rail travel experience for passengers who might otherwise miss out on key 

features of train travel. The following features and requirements apply:

1. All vertical load bearing features designed with a safety factor of three

2. Accessible path from the vehicle entrance to the lift device

3. Accessible path from the lower level accessible spaces, restrooms etc. to the lift device

4. Accessible path from the lift device to upper level accessible spaces.

5. Lift device shall not require backing in or backing out.

6. Lift must function with or without Head End Power and include a manual function in the 

case of total power loss.

7. Appropriate electrical and or mechanical safety devices to insure that the lift cannot 

operate unless the user is safely aboard the lift.

8. Gates, doors, guards, etc. must include interlocks to insure safe operation yet have 

sufficient tolerance and latitude to prevent system faults due to train motion and 

normal wear of components.

9. Lift platform shall be the same size as required for wayside and car borne lifts

10. The lift may be a vertical style or an inclined platform lift but the lift may not impede the 

stairway use.
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11. The lift must include a fold down seat and horizontal and vertical hand rails on at least 

one side of the lift “car”

12. If the lift does not allow for direct entrance then the dimensions for boarding the lift 

must be at least equal to the requirements for maneuvering a wheelchair into an alcove.

13. The lift must operate normally at the maximum track superelevation with the train 

stopped (approximately 7 degrees.

14. Lift must operate in emergency mode to within x degrees of the car’s rollover angle. 

(This must be studied to see how the movement within the car affects the vehicle’s 

center of gravity in extreme cases.) (The concept of this performance requirement is so 

that as long as a car is not on its side or in eminent danger of falling over that the lift can 

provide safe movement to the lower level)

15. The lift frame must be of sufficient strength or otherwise so designed and installed as to 

function when the car is at its maximum designed diagonal misalignment (end-to-end 

twist)

16. Gates, doors, guards, hand rails etc. must be designed to contain the maximum load 

required for the lift when subject to the FRA required loading of 4g vertical, 4g lateral 

and 8g longitudinal and remain functional after the event. (For FRA does this mean 

when the device is loaded to its maximum capacity?)

17. Emergency stop devices must be available on-board the device and on both levels.

18. The maximum travel time between levels is X seconds

19. The lift system should have soft starts and stops.

20. The lift system should have obstruction detection 

21. The lift must work reliably whether the train is in motion or not.

ANCILLARY REQUIREMENTS:

1. Cars with upper level restrooms must have an accessible restroom if the car includes 

vertical access or is available by design from a car with vertical access.

2. Cars with vertical access with restrooms on the lower level are not required to have 

upper level restrooms. (This is stated because PRIIA bi-level cars have non-ADA 

restrooms on the second level and a reduced number of restrooms on the lower level. 

The net number of toilets remains the same and seating is expanded on the lower level 

and reduced on the upper level. The reason for restrooms on the second level is that 

negotiating the stairs is a growing problem for ambulatory passengers primarily due to 

age. If the upper level and lower level must have the accessible restrooms then the 

primary function of the car as an enhancement to travel is greatly reduced because the 

number of passengers that can use the car is reduced.) 

3. The quantity of accessible spaces should be on one level or divided between levels but 

the final quantity should not be greater than cars without vertical access. Convertible 

seating should be used to maximize the available seating space when persons using 

wheelchairs are not present.
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ECONOMIC RISKS:

1. Applying vertical access to non-revenue cars has limited economic impact and may in 

fact encourage passengers who cannot use stairs to choose the train for travel. The 

primary costs are any extra cost for the equipment and maintenance over time.

2. Applying vertical access to revenue cars, i.e. coaches and sleepers will have a direct 

affect in lost revenue capacity. The physical impact and corresponding fiscal impact 

must be reviewed prior to NPRM.

3. There is a very real possibility that the economics will no longer justify building new bilevel Intercity Long Distance cars. The advent of bi-level cars on intercity long distance 

trains is driven by multiple economic goals. The enhancement of viewing due to the 

extra height was nice but the bi-level intercity car came about just before the number of 

airline passengers surpassed train passengers and railroad were trying to maintain 

service. Bi-level cars allowed the railroad to increase the number of passengers per car. 

The capital and operating investment per passenger on a higher capacity car is lower 

and thus the profit (or loss reduction) is greater. There is a huge risk that the economic 

efficiencies of bi-level intercity cars will be lost to accessible features. This comment 

does not apply to Lounge cars as defined at the front of this document. A proper study 

should be made.

4. The details governing the construction of lifts should be done with guidance from 

requirements in the built environment with full consideration that weight and space are 

big concerns for rail cars. This does not mean that safety or utility is compromised but 

following requirements for the built environment could unduly consume space or 

otherwise threaten the viability of the device in a rail car.

PHYSICAL RISK:

1. Dynamic factors during normal train operation will affect the operational reliability of 

the system. Unlike the built environment, railcars experience lateral, vertical, 

longitudinal and torsional movement. These movements can occur suddenly with no 

planning or warning.

2. The effects of train operation today at 90mph and at PRIAA specified speeds of 125mph 

on the integrity and safety of a lift system are not known.

3. The compact environment of a passenger car coupled with the dynamic effects 

may present challenges for independent operation that need to be resolved.