Comments To: CAAS Ground Vehicle Standard 2015 (GVS 2015), Released October 1, 2014

Comments to: CAAS Ground Vehicle Standard 2015 (GVS 2015), released October 1, 2014

Provided by: James D. Green, Safety Engineer, NIOSH, November 21, 2014

I am providing these comments in Tabular form referenced by Page and Paragraph to expedite their submission.

Page / Paragraph / Comment
4 / A.4.1 / Delete statement 4. “Safety, comfort, and avoidance of aggravation of the patient’s injury or illness.” These qualities don’t define the characteristics of an ambulance though they certainly might be goals during the provision of care.
5 / A.4.1 / “(Note: Stretcher vans are not included in this definition)” What is a stretcher van? Shouldn’t this be highlighted in another section that defines which vehicles are covered? Perhaps in Section C.1?
6 / B.1 / Delete the reference to AMD 003. It has been replaced by SAE J3043. J3043 has been appropriately called out for the oxygen cylinder retention test later in the document. I could not find another reference to AMD 003 in the document but it would be worth another look during editing.
7 / B.1 / Near top of page; the SAE Inc. should be SAE International – I believe
7 / B.2 / RR-C-901C….Steel Dot 3aa, should this be Steel DOT for Dept. of Transportation??
7 / B.2 / 29 CFR 1910.1030 “Blood bourne” I believe this should be one word “Bloodbourne”
9 / C.1.5 / Configuration of Patient Compartment: The statement as written eliminates innovation. It does not seem to allow for a side load or rear load ambulance. Both of these offer advantages for the patient and the side load also offers advantages for the workers. I recommend this paragraph be deleted as it doesn’t value to the document and stymies innovation.
9 / C.3 / 2nd line in paragraph needs the word “not” added as follows: “new materials NOT produced from recovered materials.”
10 / C.4.4 / At the end of this entry is the statement “normal ambient conditions.” This should be defined with a temperature range as I don’t know what “normal” is. Also, I believe there is a specific AMD test for this. If so, it should be referenced here.
10 / C.4.5 / Again, the term “normal ambient conditions” is used. I believe there is also an AMD acceleration test. If so, it should be referenced.
11 / C.4.7 / Fording: Is there a test for this? Is there a maximum depth or only a minimum? Who does this test?
12 / C.5.3 / The last paragraph references Figures 1 and 2 however, Figure 2 is identified first. Either the Figures need to be reordered in the back so that Figure 1 becomes Figure 2 or the paragraph needs to be rewritten. Either way the Figure references should appear in order in the Standard.
14 / C.6.5.3 / Is there a test for this? If so, it should be referenced. If not, it should probably be deleted. Otherwise, how do I know what amount of “whipping” or “vibrating” is acceptable? Is this a test of the natural frequency of the system through the speed range?
14 / C.6.5.5 / This sounds like a requirement until we say it isn’t: (“unless not furnished by the OEM’s AVSC system.”) I’m assuming AVSC is a reference to stability control. If so, stability control and differential slip or two different systems. I think we decide if we want traction control or limited slip differentials. If we do and a particular OEM doesn’t offer it, their vehicle is no longer an option. We don’t put in a requirement and then exempt a particular manufacturer from complying. That doesn’t make sense – and I do like Stability Control.
14 / C.6.5.6 / “Components shall have a rated capacity in excess of the load imposed”. Do we want to express this in terms of a “minimum” of 10% or perhaps 20% of rated load imposed” Saying “in excess of” could be simply 0.001% above load imposed.
15 / C.6.6 / Delete: “The OEM ‘s standard” and leave this simply stated as follows: Power assisted steering shall be furnished. This eliminates non powered steering vehicles. Are concerned about after-market editions to the vehicle?
15 / C.6.10 / Delete “OEM” from this requirement.
15 / C.6.11 / Delete “The OEM” from this requirement.
15 / C.7.1 (4) / Delete: Item 4: “Other specified accessory wiring.” If there are other items to be called out as minimums then they should be listed as this is identifying minimum items for the ambulance.
16 / C.7.1 (9) / “shall be immune from interference from radio transmissions.” Is this 100% possible? Is there a test for this?
16 / C.7.1.1 (2) / Either we have a requirement for door open alert for the drivers or we don’t. We can’t say “when available from the OEM.” If this is a requirement and a particular OEM does not offer it then their chassis is not an option for an ambulance.
16 / C.7.1.1 (3) / I don’t think adding “etc.” works. This is a minimum standard. We need to spell out all “required minimum items” We could say “Any and all extended devices that should not otherwise be extended while in transit.”
16 / C.7.1.1 (4) / Lights will be on in the interior of the ambulance every time a patient is transported. Do we want this on the drivers panel as a warning light?
16 / C.7.7.1 / Final paragraph: Should we talk to a minimum font height for narrative warnings in lieu of a warning light? Should we talk about light output to ensure the narrative message is “at least as visible”? Are all warning lights rated for visibility at a certain distant and in a certain background lighting condition? How do we “certify” that a warning light or narrative message passes or fails? What’s the criteria?
16 / C.7.2 (7) / Why not have accessory manufacturers comply with the wire color coding scheme? Are these color codes part of a national electrical coding system? Should we simply say the wiring must comply with NEC XXX?
16 / C.7.2 (13) / Is there a minimum standard to use as a measuring stick for these items? How does an inspector know what the “minimum” or “rating” should be?
17 / C.7.3.1 / “If module is isolated from chassis, FSAM to provide radio frequency (RF) grounding and minimize potential interference with OEM’s computers….” Is this in conflict with C.7.1 (9) that says ambulance to be “immune from interference from radio transmissions.”? Using the word “minimize” is by itself concerning as I have no idea what to measure to be sure I met this requirement.
18 / C.7.4 / Again, we are making an exception to a requirement. Do we require a minimum generating capacity of 14V? If so, we can’t add “when available from the OEM? If an OEM doesn’t offer it then he isn’t an OEM for this market.
18 / C.7.4 / There are three paragraph below the list of 1-10 items that I think should be standalone requirements to improve clarity.
18 / C.7.4.1 / 2nd paragraph, 1st sentence, add to end of sentence: “and parking brake applied.”
19 / C.7.4.2 / Modify sentence as shown: “,,,visual warning in case of the low voltage to persons in the ambulance to alert them of an impending electrical system failure…”
20 / C.7.6.3 (3) / Delete: this statement doesn’t add a requirement
20 / C.7.6.3 (4) / Delete: this statement doesn’t add a requirement
22 / C.7.7 / What is “easy normal reach” Ask NIST for a measured distance and reference point.
22 / C.7.7 / Revise this statement “…the specified controls…” What are the “specified controls” If we don’t list them how does a builder comply? Are we talking wipers and lights or do we include gear shift, radio, and cab mounted computer or navigational system?
22 / C.7.8 / What is “normal reach of the seated EMSP” Ask NIST for a measured distance and reference point. Is this 5ht female, 50th male, 95th male?
22 / C.7.9 / These font sizes seem very small for use in a moving vehicle. Are these values from a standard or perhaps recommended by NIST?
23 / C.8.2.1 / Revise sentence as follows: Alternate approved lighting systems are shall be either NFPA 1901 or SAE J2498 compliant.” Should we pick only one reference? Which is actually a “minimum” requirement? How do we get “alternate lighting” approved??
25 / C.8.3 / See suggested changes in red: A light switch will shallbe located inside by the rear door and to activate the rear load lights. A light switch will shallbe located inside by the patient compartment side door to activate the curbside load lights.
25 / C.8.4 / How do we measure glare? “Lighting shall be designed and located so that no glare is reflected into the driver’s eyes or his line of vision, from switch control panels or other areas that are illuminated while the vehicle is in motion.”
26 / C.9.1 / “There shall be a console convenient to the driver…” How do we measure “convenient”?
27 / C.9.5 / Recommended Enhancement: This should really be a requirement. Electronic interior control of mirrors is practically a minimum standard now. We should make it so here.
28 / C.10.1 / This section needs more definition to describe minimums. What is “sufficient”. We can’t measure “sufficient.” Perhaps NIST has some minimum recommendations. If not, perhaps this paragraph should be deleted?
28 / C.10.2 / This paragraph and the Recommended Enhancement appear to contradict one another. Are we “requiring” a locking partition window or door to prevent patient from reaching driver OR are we encouraging a walk through to improve the ability of the driver to quickly get to the back in an emergency??
29 / C.10.3 / Add: “The seating locations shall be specified by the purchaser.”
29 / C.10.4 / I think we need to specify a minimum dimension for the walkway. A “clear aisle walkway” could be 3 inches wide if not defined.
29 / RE / Suggest deleting the Recommended Enhancement and roll dimension into C.10.4
29 / C.10.5 / No definition for min radius so this requirement is not measureable. Also the AMD 001 body integrity test does allow deformation of the body structure during loading. The key is doors still need to be able to be opened. This paragraph needs to be rewritten.
29 / C.10.6 / Need to add static tests for occupant restraint anchors (think bench seat restraint systems). Like the AMD 004 test for the antler, there are FMVSS tests for the seating and restraint anchorages.
29 / C.10.6 / This is a long paragraph with a lot of comments. It would read much more easily if it were broken up.
30 / C.10.8.2 / Is there a minimum rating for slip resistance and is anyone inspecting it. I know there are defined measurement methods but we make know reference here.
31 / C.10.10.5 / Is there a requirement here? Is there a test to be used to determine if it the ambulance is adequately insulated against hear and cold?
32 / RE / The statement that, “a maximum 1” from the surface is permitted.” sounds like a requirement not a Recommended Enhancement.
32 / C.11.1.1 / Add the following sentence: “If purchaser intends to leave equipment outside of the cabinets, the purchaser must identify desired location for each so the manufacturer can place appropriate structure in the vehicle to provide support for such an installation.
32 / C.11.1.2 / Two things need to be added to this paragraph – perhaps one is already implied though I can’t tell for sure. (1) the sharps container must have a locking system that will remain closed in a crash – a spring loaded or hinged door alone will not get the job done. (2) any sharps container mounted alone (outside a cabinet) must be tested in accordance with SAE 3043.
33 / C.11.3.1. / Do we need to add “maximum of 1” from the surface is permitted.”
33 / C.11.4 / Add: “All patient compartment seating shall have no less that a Type II (3- point restraint system) installed.”
33 / C11.4.1 / Change title to “Patient Compartment Seating” rather than “Patient Seating”
33 / C.11.4.1 / Change as follows: “…seat backs shall be a minimum of 18” wide by “43” high tall.” Making any statement that a seatback only be 7” high is ridiculous and is written to allow a window – and thus the very low back. We can and should do better.
33 / C.11.4.1 / Add: “All seating and restraint systems shall be tested in accordance with the requirements specified in SAE J3026, Ambulance Patient Compartment Seating Integrity and Occupant Restraint.”
33 / C.11.4.5 / Add: “All patient compartment seating shall have no less that a Type II belt (3- point restraint system) installed at each seating location and shall meet the requirements of SAE J3026, Ambulance Patient Compartment Seating Integrity and Occupant Restraint.”
35 / C.12.2.7 / Add this new requirement: “If device is 3 lb. or greater, mount system must meet the requirements of SAE J3043, Ambulance Equipment Mount Device or Systems”
35 / C.13.1 / The following statement located in mid paragraph lacks definition of what constitutes “high volume” and “low velocity”. “The air systems will be high volume capacity with low velocity delivery for minimum draft circulation.”
35 / C.13.2 / The first sentence lacks definition for the maximum amount of time allowed to completely change the air in the cab or patient compartment. Shouldn’t this be a performance requirement? Is there a test in place to ensure this occurs or is it a simple calculation for the sizing of the ventilation system?
36 / C.13.3 / 2nd Sentence says, “Switches and controls shall be accessible to the EMSP when seated and restrained.” Should this statement include a definition of “reachable”? Example – 45 inches from seat “H” point. Perhaps NIST has a value that can be used?
36 / RE / This statement seems very important – temperature control for storage of meds. Should this statement become a requirement rather than a Recommended Enhancement?
37 / C.15.1.1 / Add the following: Fire extinguishers shall be mounted and tested in accordance with the requirements of SAE J3043, Ambulance Equipment Mount Device or Systems”
38 / C.18.15 / Add subparagraph 15 as follows: Certification for components meeting SAE J3026, SAE J3027, and SAE J3043.
41 / D.6.1 / This section should also include any required FMVSS testing such as FMVSS 207 and 210. Fred Schimmel at AEV or perhaps Steve Spata at NTEA should be consulted to help ensure this list is complete.
42 / E.1 / Question regarding this statement: “A response will be provided for all submissions.” Will there be a response timeline? Is there anything in ANSI requirements that say a response must be provided within 60 or 90 days?
42 / E.2 / Same timeline question applies to final sentence in this section: “Notification of approved interpretations will be sent in writing to the requester.”
43 / E.3 / Last sentence of the first paragraph needs to be rewritten as follows: “…the specific section of the standard in question, the requester’s understanding of the section …”
50 / 2.C.2 / Perhaps add to the list of required information regarding mounts to say, “…its dimensions (LxWxH), and the mount footprint or attachment hole pattern”