Transcript Document

Occupant Restraint Upper Anchorage Requirement for Wheelchair
Locations in M2 and M3 Passenger Vehicles (Minibuses and Buses)
Unwin Safety Systems has been frequently asked about the legal requirement for upper torso
restraint anchorage for wheelchair seated passengers in M2 and M3 passenger vehicles. The
questions are more frequently asked by converters or manufacturers of M2 minibuses, that are
intended to provide passenger transport for a mix of vehicle and wheelchair seated passengers.
This document is the outcome of a study of the forthcoming Type Approval requirements for M2
and M3 vehicles due to come into effect at the end of October 2014.
Vehicle Type Approval requirements for M2 and M3 passenger vehicles are set to change when
UK law, in the form of Road Vehicle (Approval) Regulation 2009, SI 2009 No. 717 comes into
effect effective for all passenger vehicles registered post 29th October 2014.
There are three ‘routes’ to Type Approval, similar to those for M1 Category vehicles which are
now well known. The routes for M2 and M3 vehicles are as follows,
European Whole Vehicle Type Approval,
National Small Series Type Approval,
Individual Type Approval
EWVTA – no limits on numbers or market
NSSTA – 250 off, to be sold in the UK only
IVA – No limits on numbers, UK only
Technical requirements for wheelchair seated passengers in Buses and Coaches for all three
routes to Type Approval refer to the provisions in UNECE Reg. 107.02
SI 717 gives the requirements in Paragraph 52 of the tables below, especially clause 3 under
Column 1 Requirement.
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Clarification of Class I and Class A or B Vehicles
Classifications are given in UNECE Regulation 107, and are shown below:
Wheelchair occupant restraint upper anchorage requirement will be of particular interest to
manufacturers/converters of vehicles with less than 22 seats and of the Class B definition, as
given in 2.1.2.2 above.
Either Class A or B the same requirements apply, those being Annex 8 of UNECE Reg. 107.02
These requirements are the same for both NSSTA and IVA routes.
Generally, the maximum number of vehicle seated passengers in an M2 Category vehicle is 16 or
17 seats. The addition of a wheelchair position is likely to reduce that maximum number to 12 or
less. The addition of a passenger lift platform to enable wheelchair access will take the GVW of
the vehicle very close to the upper limit for M2 vehicles of 5 tonne.
Vehicles that are intended to carry more than 22 passengers, as given in 2.1.1, are most likely to
be of mass greater than 5 tonne, and therefore be of M3 Category. Class I and Class II vehicles
(M3) that allow standing passengers, will likely have a rearward facing wheelchair station, the
technical requirements of which are given further on in Annex 8 of Reg. 107, in clauses 3.8.4.
The exception would be a Class III vehicle, such as a coach.
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UNECE Reg. 107.02 states that if a bus (including Class A or B minibus)
has occupant restraint systems fitted to the vehicle seats for
non-disabled passengers, then the same type of occupant restraint
system shall be provided for wheelchair seated passengers.
See in particular – Clause 3.8.2.2 below.
This means that if vehicle seated passengers have a 3 point lap and diagonal seat belt then so
should the wheelchair user.
If the vehicle seated passengers have a 2 point lap belt then so should the wheelchair user.
This is also in line with Equalities in the provision of crash protection.
A 3-point occupant restraint system has - by definition – a lap section and a diagonal section
with the upper anchorage located above and behind the shoulder of the occupant. This
requirement is to prevent downward spine loading of the passenger.
The definitions are given within UNECE Reg. 14 for seat belt anchorages and UNECE Reg. 16 for
seatbelts.
This is backed up when Annex 8 of UNECE Reg. 107.02 requires vehicle converters and
manufacturers (in clause 3.8.3.6.2) to test seatbelt anchorages following the test method given
in UNECE Reg. 14 – which can only be conducted with either a 2 point lap belt or a 3 point lap
and diagonal with an upper anchorage.
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Who decides if the vehicle seats have 2 or 3 point occupant restraint systems?
The number of seatbelt anchorages required in a vehicle will depend on vehicle size and type.
This will be a decision made by the vehicle builder, converter or manufacturer.
UNECE Reg. 16 states the minimum number of seatbelt anchorages required in different vehicle
types and sizes in Annex 16 of the Regulation.
Seatbelt anchorage requirement may be generally summarised as follows,
Passenger vehicles of M2 Category, less than 3500kg GVW must have 3 point lap and diagonal
occupant restraint systems.
Passenger vehicles of M3 or M2 or Category greater than 3500kg GVW, may have 3 lap and
diagonal or 2 point lap only occupant restraint systems.
BUT – if the vehicle is going to have 2 point lap belts only then the manufacturer has to prove
that for head contact with a seat back or structure (such as a hand rail) in front of a seat position
will not cause injury to a seated occupant in the event of a crash event.
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Further details are given in clause 8.1.7 of UNECE Regulation 16, which in turn relate to energy
absorptions requirements given in UNECE Regulation 80.
It is important to remember that in M3 Class I and Class II vehicles, wheelchair seated
passenger accommodation is likely to be achieved by the rearward facing option given in
3.8.4 of Annex 8 of UNECE Regulation 107.
Class III vehicles are likely to be long distance type coaches when all passengers are seated,
with no standing passengers. Wheelchair seated passengers will require at least the same
type of occupant restraint as seated passengers, and if in an exposed position where
satisfaction of the energy absorption requirements of UNECE Regulation 80 are not possible,
then a 3 point lap and diagonal restraint system will be required.
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