DOCUMENT 9 ResearchFOI 24/25-0889paper
OFFICIAL For Internal Use Only
Bariatric wheelchairs and transport safety
The content of this document is OFFICIAL.
Please note:
The research and literature reviews collated by our TAB Research Team are not to be
shared external to the Branch. These are for internal TAB use only and are intended to
assist our advisors with their reasonable and necessary decision-making.
Delegates have access to a wide variety of comprehensive guidance material. If
Delegates require further information on access or planning matters, they are to call the
TAPS line for advice.
The Research Team are unable to ensure that the information listed below provides an
accurate & up-to-date snapshot of these matters
Research question/s:
What are the guidelines/ standards /laws for bariatric power wheelchair and crash testing?
Is there an evidence base that recommends how to clinically determine the safe working load for a participant?
How is a maximum safe working load of a power wheelchair determined?
If a power wheelchair has been crash tested to a maximum of 75kg what recommendations have been provided on how to best to safeguard people who are over the weight of 75kg should they be in a crash? Is this safe?
Date: 19/05/2022 Requestor: Brigid [[s47F - personal privacy](/foi-library/releases/759e22e37354-foi-24-25-0593-decision-document/release-materials/material-001__s47f-personal-privacy/)](/foi-library/releases/759e22e37354-foi-24-25-0593-decision-document/release-materials/material-001__s47f-personal-privacy/) Endorsed by (EL1 or above): Yuemei s47F - pers Researcher: Aaron s47F - personal privacy Cleared by: Stephanie s47F - personal privacy
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- Contents
Bariatric wheelchairs and transport safety ……………………………………………………………………… 1
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Contents ……………………………………………………………………………………………………….. 2
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Summary ………………………………………………………………………………………………………. 2
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Relevant Australian Standards, legislation and guidelines …………………………………….. 2
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Safe working load …………………………………………………………………………………………… 3
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Crash testing ………………………………………………………………………………………………….. 5
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Reasonable and necessary ……………………………………………………………………………… 6
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Australian wheelchair standards ……………………………………………………………………….. 8
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Correspondence …………………………………………………………………………………………… 12
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References ………………………………………………………………………………………………….. 13
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Version control ……………………………………………………………………………………………… 14
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Summary
I was not able to find any standards, guidelines or laws that pertain to bariatric power wheelchairs over and above what is required for standard power wheelchairs. There does not appear to be any legal requirement for wheelchairs to be crash-tested to the Australian standards, though this is to be preferred if available.
It is unclear how safe working load is determined for each model of wheelchair, though a variety of non-structural considerations are likely to apply including commercial factors. Australian standards do specify best practice for testing strength and stability of wheelchairs.
These conclusions are preliminary and further investigation may be useful. It may be especially useful to further investigate decision making frameworks for equipment that does not meet Australian standards but for which there is no alternative.
- Relevant Australian Standards, legislation and guidelines
Australian standards describe minimum safety and quality requirements for products, systems and services. Some are formalised in state, territory or federal legislation. They can also be incorporated as conditions in private contracts (Standards Australia, n.d.).
There are at least 31 Australian Standards relating specifically to wheelchair design and use. Refer to 7. Australian wheelchair standards for the full list.
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There do not appear to be any specific requirements set out in Australian standards for bariatric power wheelchairs beyond what is required for standard power wheelchairs.
From my research it appears that no Australian standards related to wheelchair design and use has been endorsed in legislation. Discrimination laws apply when wheelchair users wish to travel on public transport and some regulations specific to wheelchair accessible taxis ensure that driver’s assist the wheelchair user safely. There does not appear to be any legislated restrictions in any jurisdiction on the type of wheelchair that can be used on public transport.
Also, unless a specific exemption is sought, general transport and road safety laws still apply. For example, when traveling in a vehicle, wheelchair users should still where a seat belt conforming to Vehicle Standard (Australian Design Rule 4/05 – Seatbelts) 2012.
The nationally applicable Disability Standards for Accessible Public Transport 2002 do not specify types of wheelchairs permitted on public transport. Paragraph 1.22 of the guidelines for this standard point out that the Disability Standard assumes that the wheelchair is stable enough to travel in a vehicle and that passengers will ensure their wheelchairs are safe to travel (Disability Standards for Accessible Public Transport Guidelines 2004, (Cth)).
The West Australian guidelines for wheelchair passengers state that a wheelchair user should:
ensure their wheelchair is capable of being restrained correctly get their own advice about what type of wheelchair is most appropriate be familiar with the right way to secure their wheelchair and themselves (Department
of Transport, 2022).
The NSW government’s factsheet on travelling with a wheelchair notes that a wheelchair can be secure even if it does not have specific transit options in place. However, if the chair has these options, then they must be used (EnableNSW, 2016). This factsheet also specifies features that do not meet minimum standards for safe transport. These include wheelchairs with:
low backs single pole seats insufficient base / frame to attach tie downs (if no other transit options in place) no headrest.
RES 216 Safety of front versus second or third row vehicle conversion for wheelchairs, contains more general information on safely travelling with a wheelchair.
- Safe working load
Safe working load can be defined as:
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The steady or unsteady load against which a component or structure is designed for normal operation. It is lower than that which would cause failure by buckling, fracturing, or yielding, so as to accommodate uncertainty, possible fault or accident conditions (Escudier & Atkins, 2013, safe working load).
Safe working load may also be described as rated load, manufacturer’s rated load or working load limit (Hanifan, 2014). In the context of wheelchair documentation, safe working load may be described in other ways depending on the wheelchair provider or manufacturer. Some providers or manufacturers might refer to safe working load, weight capacity, weight limit, maximum user weight, maximum recommended user weight. Australian standards refer to safe working load (AS/NZS 3695.1), intended occupant mass (AS/NZS 3695.2) or maximum occupant mass (AS/NZS 7176.8). 3695.1 states that a manufacturer should label the wheelchair with the safe working load in kilograms. AS/NZS 3695.2 states that the manufacturer should provide documentation indicating characteristics of the intended occupant including their mass and functional capacity.
The Australian Standards describe methods for testing strength and stability of wheelchairs and wheelchair accessories such as restraints and fittings. AS/NZS 7176.8 specifies any anthropomorphic test device (ATD) used should equal the maximum occupant mass defined by the manufacturer. AS/NZS 3696.19 allows for an ATD to represent a range of weights when conducting a frontal impact test in a vehicle. For example, an ATD of 75 kg represents occupant weight range of 75 kg – 136 kg (more detail in 5. Crash Testing). AS/NZS 3695.2 specifies that where a human test occupant is used for any test, they should equal the maximum occupant mass +/- 5kg. Tests for static strength of arm and foot supports also require maximum occupant mass to determine force applied in the test conditions.
There do not appear to be additional requirements for bariatric wheelchair testing beyond what is standard for all wheelchairs. However, several testing parameters specify using maximum mass values to calculate force. In the case of testing static strength of arm and foot supports, where the maximum occupant mass exceeds 125kg then AS/NZS 7176.8 still recommends using 125kg to calculate the force required for testing. Similarly, when testing for upward forces on arm and foot supports, the standard recommends using no more than 100 kg to calculate force even if the ATD (and therefore intended maximum occupant mass) exceeds 100 kg.
The Australian Standards assume that maximum occupant mass is specified by the manufacturer. I have not been able to find any guidelines describing how a wheelchair manufacturer initially determines the intended weight limit. However, correspondence with a provider suggests that several factors contribute to determining the intended weight limit including the intended user, the intended purpose of the wheelchair and other market considerations. From this advice it appears the provider determines the needed or desired occupant mass using non-structural decision and then confirms this is structurally appropriate for the design of the chair according to the appropriate standard (refer to 8. Correspondence). If this is representative of other provider’s practice, it means that the weight limit defined for a
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particular model of wheelchair is the weight limit that the device was successfully tested to. The device might be safe to use under a greater weight but tests have not been completed to confirm it.
- Crash testing
Crash testing is the way that manufacturers make sure that a wheelchair is likely safe for travel (SPOT, 2010). Three Australian standards cover requirements for crash testing of wheelchairs and restraint systems are: AS/NZS 3696.19-2009, AS/NZS 10542.1:2009 and AS/NZS 10542.2:2009.
AS/NZS 3696.19-2009 Wheelchairs - Part 19: Wheeled mobility devices for use as seats in motor vehicles describes methods of crash testing for wheelchairs intended for use as seats in vehicles. It is a modified version of International Standard ISO 7176-19:2008 Wheelchairs — Part 19: Wheeled mobility devices for use as seats in motor vehicles. This international standard has been superseded by ISO 7176-19:2022 - Wheelchairs — Part 19: Wheelchairs for use as seats in motor vehicles. However, AS/NZS 3696.19-2009 remains the endorsed Australian standard.
For frontal impact testing, AS/NZS 3696.19 specifies that an ATD should be selected based on the intended occupant weight according to the following table:
Table 1 ATD size and weight by intended occupant weight range. Source: AS/NZS 3696.19 Annex A, method for frontal impact test
Occupant weight range (kg) ATD size Approx. mass of ATD (kg)
18 - 27 6-year-old child 22.5
27 – 43 10-year-old child 35
43 – 57 Small adult female 47
57 – 75 Small adult female, weighted 59
75 – 136 Midsize adult male 76.3
Over 136 Large adult male 102
Note: where an ATD is weighted, this means additional weighting material are added to a figure to achieve the desired weight.
According to this table, for wheelchair users over 136 kg an ATD of 102 kg is sufficient to meet the conditions of the standard for frontal impact testing.
Where possible, wheelchairs should be selected to meet AS/NZS 3696.19-2009 (EnableNSW, 2016; SPOT, 2010). However, it is not always possible to ensure that a wheelchair has been
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crash-tested. For example, in some cases there may be no wheelchair available that suits the user’s height or weight. In these cases, AS/NZS 3696.19 notes failure to comply with the standard “cannot be used to limit access to, and availability of, motor vehicle transportation for wheelchair users” (p.v).
Guidelines note that crash testing is completed under specific test conditions and may not indicate that the wheelchair can withstand forces of a crash (EnableNSW, 2016; SPOT, 2010).
- Reasonable and necessary
When determining whether a request for a wheelchair is reasonable and necessary, delegates need to have a good idea that the wheelchair is safe to use. NDIA’s Assistive Technology guideline says:
We need to know that the assistive technology:
is the right item for your needs is safe for you to use and meets Australia’s safety standards, where this is
possible will help you do all the things you need it to will work in all the places that you need to use it. (Our Guidelines – Assistive
Technology)
In some cases, it is not possible for wheelchairs to comply with the relevant Australian standards. The AT guidelines states that we will need to know that the piece of equipment meets Australian standards, where possible. However, it does not say how a delegate should make a decision if meeting Australian standards is not possible. This will likely depend on conditions specific to the participant and their context.
Moreover, AS/NZS 3696.19 indicates what to do if its own conditions are not met:
Transportation is only one of many daily activities that introduce unique circumstances and requirements that wheelchairs and wheelchair occupants may experience. Wheelchair products that comply with this part of ISO 7176 [or 3696 in Australia] will have additional features that provide increased levels of occupant security and safety whilst their occupants are riding in motor vehicles. However, a wheelchair’s failure to comply with this part of ISO 7176 cannot be used to limit access to, and availability of, motor vehicle transportation for wheelchair users (p.v).
Wheelchairs that have been crash-tested to AS/NZS 3696.19 should be preferred with the understanding that in many cases it may not be possible to find an appropriate wheelchair that meets these standards. Moreover, even where these standards are met, this may not ensure safety in a crash. As was shown in 5. Crash Testing, frontal impact testing occurs with an ATD that represents a certain weight range. If a wheelchair manufacturer indicates that the wheelchair meets AS/NZS 3696.19 (or equivalent standard) this means it would have been
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tested using one of the six typical ATD designs. If the manufacturer indicates a model has been crash tested to, for example, 135 kg, then this may mean it has been tested using an ATD of 76 kg.
Delegates should also keep in mind that transportation is only one activity that the wheelchair is used for and so crash testing according to AS/NZS 3696.19 is relevant to the wheelchair’s use in specific activities. However, the safe working load is a relevant safety consideration during all activities.
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- Correspondence
From: Glide Support xxxxxxx@xxxxx.xxx.xx
Sent: Friday, 20 May 2022 1:44 PM To: s47F - personal privacy Aaron <Aaron.s47F - personal privacy @ndis.gov.au>
Subject: RE: Determining safe working load for wheelchairs [SEC=OFFICIAL]
Good Morning Aaron
Hope you are well and thank you for your email below regarding determining safe working load of wheelchairs.
Please see answers below highlighted in red.
Please be advised new pricing effective from 1st February 2022
Kind Regards
s47F - personal privacy
PRODUCT SUPPORT OFFICER
NDIS Registered Provider +s47F- personal privacy | www.glide.com.au
25 Ledgar Road | Balcatta | Western Australia 6021
Office Hours | Monday to Friday | 8:30am to 4:30pm WST
From: s47F - personal privacy Aaron <Aaron.s47F - personal privacy @ndis.gov.au>
Sent: Wednesday, 18 May 2022 9:18 AM
To: Glide Support xxxxxxx@xxxxx.xxx.xx
Subject: Determining safe working load for wheelchairs [SEC=OFFICIAL]
Good morning
I am hoping you can assist with an inquiry regarding the safe working load for wheelchairs.
I am a researcher for the National Disability Insurance Agency. I’ve been asked to get a bit of information around how manufacturers determine the safe working load of their wheelchairs. I’ve hit a wall and was hoping that as an Australian wheelchair manufacturer you could assist. The information I’m after is for research purposes only. Any information you provide will not directly impact NDIA’s relationship with any provider.
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I have been reading through a handful of Australian Standards (in particular 7176.8, 7176.19, 3695.1 and 3695.2). These standards seem to assume that the manufacturer sets the maximum occupant mass before testing and they also state that the safe working load of a wheelchair needs to be made evident to customers.
So my questions are:
How is the maximum occupant mass determined for a model of wheelchair? There
are a number of factors that are looked at in determining what user weight is set. We
look at the market, the type of user and where it is to be used. How is the safe working load determined for a model of wheelchair and does this
differ from method for determining maximum occupant mass? It does not differ. We
then look at the standard and choose the weight that we think will match the
information gleaned from the information researched. Remember that some chairs
are tested to two different standards. AS3696.8 (strength and durability eg 175kg
user weight) and AS3696.19 (crash testing up to a maximum if 159kg user weight –
limited by the test dummy size at the test facility). So what this is saying is that the
chair can be used for general use for user up to 175kg, however it is only compliant
up to 159kg user weight when used as a seat in a vehicle. Is the SWL determined by testing the completed product or by testing or calculating
for each component? It is done as a complete product If each component is tested separately, how is safe working load for the piece of
equipment as a whole determined from the individual components?
Thanks very much for your help and all the best Aaron [[s47F - personal privacy](/foi-library/releases/759e22e37354-foi-24-25-0593-decision-document/release-materials/material-001__s47f-personal-privacy/)](/foi-library/releases/759e22e37354-foi-24-25-0593-decision-document/release-materials/material-001__s47f-personal-privacy/)
Research Officer
National Disability Insurance Agency Phone s47F - personal privacy Email aaron.s47F - personal privacy @ndis.gov.au
- References
Department of Transport. (2022). Transport for people with a disability. Government of Western Australia. https://www.transport.wa.gov.au/On-demandTransport/transporting- people-with-disability.asp.
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Disability Standards for Accessible Public Transport 2002. (Cth). https://www.legislation.gov.au/Details/F2011C00213#:~:text=%20Disability%20Standar ds%20for%20Accessible%20Public%20Transport%202002,provide%20equivalent%20a ccess%20by%20direct%20assistance.%20More%20
Disability Standards for Accessible Public Transport Guidelines 2004. (Cth). https://www.legislation.gov.au/Details/F2005B01059/0d42e6f5-72ea-406a-a9ac- b311077b840c
EnableNSW. (2016) Travelling in a wheelchair in a vehicle. HealthShare: NSW Government. https://www.enable.health.nsw.gov.au/__data/assets/pdf_file/0009/334854/Fact_Sheet_ Travelling_in_a_wheelchair_in_a_vehicle.pdf
Escudier, M., & Atkins, T. (2013). A dictionary of mechanical engineering. Oxford University Press.
Hanifan, R. (2014). Concise dictionary of engineering: A guide to the language of engineering. Springer International Publishing.
Speech Pathologists, Occupational Therapists and Physiotherapists on Developmental Disabilities (SPOT). 2010. Transport safety guideline for people with a disability. https://disabilityspot.org.au/wp-content/uploads/pdf/TranSPOT_SafetyGuide.pdf.
Standards Australia. (n.d) Developing Australian Standards. https://www.standards.org.au/StandardAU/Media/SA- Archive/OurOrganisation/Documents/Developing-Australian-Standards.pdf.
Standards Australia. (2009). Wheelchairs - Part 19: Wheeled mobility devices for use as seats in motor vehicles (AS/NZS 3696.19-2009).
Standards Australia. (2011). Wheelchairs, Part 1: Requirements and test methods for manual wheelchairs (AS/NZS 3695.1).
Standards Australia. (2015). Wheelchairs, Part 8: Requirements and test methods for static, impact and fatigue strengths (AS/NZS 7176.8).
Standards Australia. (2019). Wheelchairs, Part 2: Requirements and test methods for electrically powered wheelchairs (including mobility scooters) (AS/NZS 3695.2).
Vehicle Standard (Australian Design Rule 4/05 – Seatbelts) 2012. (Cth). https://www.legislation.gov.au/Details/F2019C00042
- Version control
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Version Amended Brief Description of Change Status Date by
0.1 Aaron Initial draft of research paper looking into Draft 19/05/2022 s47F - personal privacy standards, laws and guidelines for determining safe working load and crash testing / transport safety for bariatric wheelchairs.
0.2 SJP131 Review Draft 20.5.22
0.3
1.0
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