No part of a bus or coach with no moving parts is usually as poorly thought out as the stepwell. Apart from brakes and tires, no single element of a bus or coach is as responsible for as much mayhem.

With a few artistic exceptions (spiral staircases and splayed bottom steps), every building’s stairwell contains regularly-shaped and regularly-spaced steps: Every step is a rectangle of the same size and proportions as the others. Each step lies the same distance away from the step above and below. And at least one side of the staircase contains a oblique, linear handrail parallel to (and roughly waist-high above) the imaginary line drawn through the outer edges of all the steps.

If a vehicle’s stepwell differs markedly from this configuration, the chances are good that an ascending or (more likely) descending passenger will eventually slip and fall while negotiating it. When this occurs, it may be the bus purchaser’s fault, the manufacturer’s fault, or both. Their respective exposure may hinge on a number of factors. But efforts to place the blame on, and assess damages to, someone other than the victim is a near-certainty in the inevitable lawsuit that follows.

Most new motorcoaches contain two stepwells – a front entrance stepwell for ambulatory passengers, and a rear door and “passive lift” to accommodate passengers using wheelchairs (and those using other mobility devices when drivers are enlightened enough to accommodate them this way). With the promise of faster full-coach boarding and alighting that “active lifts” hold (i.e., the lift platform can morph into a stepwell), this now-common transit innovation may start to appear in motorcoaches. As it is, many two-door buses are already being deployed in motorcoach service – particularly in commuter/express and, to a lesser degree, sightseeing service. For these reasons, the discussion below will encompass both front and rear stepwells.

Trade-offs and Variations

Stepwell configurations largely reflect the trade-offs between (a) the vehicle’s floor height, (b) its need for ground clearance, (c) its width, and (d) the space needed at the top of the stepwell – a space typically shared with the driver’s compartment. Because of the constraints involved in this complex trade-off, there are no formal requirements for tread depths or riser heights. Just as in buildings, these dimensions perform the “balancing act” in bringing the passenger from the ground level to the floor level (and vice versa) – presumably according to some coherent arrangement.

As one can see, these trade-offs are complex without even factoring in the doors themselves (see “Buying Tomorrow’s Buses Today, Part 3: Doors” in the May, 2006 issue of NBT). Many stepwells are poorly-designed even where the doors have no bearing on them. But some door formats can compound these difficulties, and the intricacies can spiral outward in further complexity, dragging safety and liability problems along with them. As an example, inward-opening jackknife doors may cut into the stepwell beyond the bottom step, rendering the second step up both smaller and irregularly-shaped. These problems, in turn, can undermine the handrails – especially their importance of mirroring the architectural principles of stairway construction noted above.

The more exotic the stepwell, the more likely it will contain aberrations. The low-floor ramp-extensions of transit buses – a mechanism that seems almost elementary in form and movement – provide an illustration:

• What “model passenger’s” right foot was this trap designed for?

[insert photos #3 and #4 – Hole in Stepwell]

• How alert need a passenger be to tiptoe over this trip-hazard and maintenance holocaust?

[insert photo #5 – Alignment Problem]

Stepwell Rules and Rhymes

As noted above, there are four cardinal principles of stairwell and stepwell design:

1. Every step must be the same size as every other step
2. Every step must be the same shape as every other step
3. Tread depths must the uniform from step to step
4. Riser heights must be uniform from step to step

Because most bus and coach passengers learn to climb stairs in buildings whose stairwells follow these principles, these passengers can become disoriented when they encounter something different – even when they recognize it before attempting to use it. Many will learn of these differences as they first begin using it. When their passengers suffer an injury as a result, bus operators and manufacturers get to spend increasing amounts of time with their attorneys.

Apart from style, alighting efficiency has occasionally been cited to justify variations like spiral stepwells. However, most new motorcoaches now contain wheelchair lift platforms. So, if you want to board and alight the passengers more quickly and more safely, seat the handful of passengers most in need of physical boarding and alighting assistance near the rear door, and board and alight them via the wheelchair lift – while the bulk of passengers not requiring such assistance board and alight at the front entrance stepwell. This approach reflects a fundamental principle of liability: When you buy a safety device, you may be held more accountable for failing to use it than had you not purchased it in the first place.

Running Boards, Step Extensions and Foot Stools

One solution to reducing bottom-step-to-ground heights thankfully falling out of favor is the retractable bottom step. The constant jarring from clearance conflicts knocks this device out-of-square. It then presents a slanted step surface – much less a step different in size and shape than the fixed bottom step just above it. Further, retractable steps usually present a significantly different riser height than the step above – a particular challenge for alighting passengers. In one incident I examined forensically, an elderly passenger tumbled out of the coach after trying to step over it.

A similar problem in van and minibus conversions is the running board – a device almost always too narrow for safe usage (particularly for alighting purposes), and often partly recessed (to avoid protruding from the body when the vehicle is in motion). Boarding passengers may catch their toes on the undersides of the recessed portion, while alighting passengers’ heels cannot use the sliver of the surface indented – further compromising the device’s already-limited tread depth. Some running boards may not even extend the full width of the door opening area – presenting an illusion to passengers who may step down onto an even narrower section of the board. In one incident I examined, (a) the position of the descending passenger and (b) the foot she stepped off with resulted in her missing the running board altogether.

These accoutrements are designed largely to compensate for (a) drivers failing to pull to the curb (although there may sometimes be no curbs), and/or (b) drivers failing to properly assist passengers onto (and particularly off of) the vehicle. These problems are acute in motorcoaches because their narrow stepwells are designed for the passage of a single person in only one direction. (In contrast, the typically wider entrance stepwells on transit buses, which permit passengers to simultaneously board and alight in opposite directions, provide room for drivers or attendants to physically assist passengers up and down the stepwell while stepping alongside them). To address the shortcomings of most existing motorcoach front entrance stepwells, I recommend the driver’s regular deployment of a sturdy, manually-deployed footstool designed for public transportation purposes (see www.safetystep.net) – and the driver’s physical provision of passenger assistance to those using it.

Ergonomics and Kneeling Features

Before kneeling features became common, the 12- to 14-inch drop from the bottom step to the ground surface below made pulling the bus or coach to the curb imperative – at least where curbs were present. The characteristics of low-floor buses and conversions mitigate this risk to a degree. Yet pulling to the curb is sound policy for even these vehicles. In contrast, engaging the kneeling feature of a high-floor bus or motorcoach is imperative when a curb is not present, or when the driver cannot pull the vehicle parallel and adjacent to it. Again it is sound policy to kneel the bus even at the curb – particularly for elderly and disabled passengers and small children.

As a liability matter, ergonomic analyses can often quantify the significant differences passengers experience in stepping down eight or nine inches, for example, compared to 14 or 15 inches – differences often significant insofar as a passenger’s likelihood of breaking a foot, ankle, leg or hip. For this reason, both low-floor buses and kneeling features have made significant contributions to passenger safety. But again, their availability can create exposure when the driver fails to use them.

Handrail Design

It is a stunning credit to modern America that, in our provision of public transportation services, we have striven to accommodate individuals who do not have two hands and two feet – among many even more-challenging problems. However, because most public transportation passengers do not possess such problems, where they place their hands is as important as where they place their feet. So, along with the four criteria for stepwells cited above, a fifth and equally-important criterion exists for handrails:

1. A linear, continuous handrail that lies along at least one side of the entire series of steps, parallel to and lying roughly waist- or fingertip-height (for an average adult) above the imaginary line drawn through the outer edges of all the steps

The basic dimensions of, and positions for, handrails are spelled out in both CFR 49 and the transit industry “White Book.” Largely because of their other irregularities, bus and coach manufacturers (compared to staircases manufacturers) would do well to install handrails meeting these criteria on both sides of the stepwell.

Anomalies and Enigmas

As simple as coherent handrails appear to be, the deviations on so many buses and coaches are puzzling:

• Some handrail configurations that facilitate boarding, yet are not reachable from the floor level (thus making them useless for alighting purposes), are installed in the rear stepwell – where passengers are often not supposed to even board, as a procedural matter.

[insert photo #7 – Rear Stepwell Ironing Board]

• In contrast, the same manufacturers typically install handrails useful for alighting purposes only in the front stepwell – a position where few of them alight and all of them are supposed to board.

[insert photo #8 – Front Stepwell Handrail]

To avoid such enigmas, manufacturers might follow a corollary to the criterion above:

1. Every handrail configuration should be designed to facilitate both boarding and alighting – irrespective of the stepwell or its proscribed usage (i.e., boarding versus alighting).

Mechanically-operated doors present another unusual challenge to both vehicle manufacturers and vehicle operators: Passengers tend to use the extension rods as handrails!

[insert photo #9 – Not a Handrail]

The use of these rods as handrails in both boarding and alighting presents a number of problems apart from their already-existing instability:

• Passengers can get their hands cut by nuts, bolts and other components, and may fall up or down the stepwell as they recoil from the pain
• The thin, movable rod lies on a poor angle for a handrail, and provides an irregular profile often difficult to grip
• Constant pushing and tugging on the rod deforms the mechanism, leading to a need for constant maintenance and constant vigilance
• The deformation of the rod compromises the locking feature of the door

The solution to these problems is to install an operable, visible, intuitive and genuine handrail – whose purpose as a handrail is obvious – over the door-opening mechanism. Similarly, I cannot understand the industry’s failure to design a handrail to bypass and surround the large conduit connecting a modern motorcoach door to its pneumatic power supply and control mechanism.

Dimensions, Headache Pads, Knee Skinners and Such

A few hints for further improving stepwell safety do not fall neatly into categories:

• Particularly if you serve large numbers of elderly and/or disabled passengers, and if you use the lift platform sparingly (i.e., only for wheelchair occupants), increasing the width of the front entrance stepwell is well worth considering. This modification will enable the driver or even fellow-passengers to physically assist elderly or disabled passengers on and off. Let the manufacturers’ engineers figure out how to squeeze the curb-side seats into the few inches less space in the passenger compartment this modification yields.
• While the ADA mandates minimum door-opening heights at lift platform entrances (56 inches for vehicles shorter than 22 feet long, and 60 inches for those longer), and while most non-lift-related entrance door heights are considerably greater, an occasional passenger may still bump his or her head getting on or off. A strip of thick, horizontal padding glued and stapled onto the upper edge may prevent a considerable number of minor injuries – although it may also involve additional maintenance from passengers pulling it off while using it as a hand-grip.
• In my opinion, some modern bus and coach flooring surfaces that are available are too abrasive: A passenger falling down on board could shred his or her kneecaps. However, this same profile would make excellent stepwell flooring – where passengers are far less likely to scrape them with other parts of their bodies, where they would presumably be used when the vehicle is not in motion, and where the importance of sound footing justifies the trade-off.

[insert photo #10 – Stepwell Tread Surface]

• Larger bottom steps are presumably designed to help alighting passengers “gather themselves” before stepping down from a position 14 or more inches above the ground level. This premise is naïve: Passengers cannot gather themselves when fellow-passengers are stepping down right behind them. Worse, larger bottom steps can be dangerous: They may induce passengers to pause while climbing or descending the stepwell. Worse still, they may induce passengers to ride in it.
• With all but pantographic or sliding doors, make sure the doors contain some form of cantilever. While or after they push open the doors, passengers may grab railings or handles on the doors themselves. Particularly when the doors open automatically or semi-automatically (i.e., by the driver triggering or engaging them), make sure that the doors cannot be opened further by the application of additional manual force.
• Where handles or grips are mounted to the inside of the door surface, extend them as far as possible toward the inner edge of the stepwell, meeting one or both stepwell handrails (depending on the door configuration) at the door hinge(s). And make these handles meet at an adult passenger’s waist level – providing a near-continuous extension of both handrails irrespective of how far the doors are opened.
• Do not mount handles or grips on the inside surface of doors as alternatives to continuous handrails. Isolated, non-continuous handrails or grips can become targets for passengers to lunge toward.
• Do not block the stepwell with a needlessly-oversized and poorly-positioned farebox, tour guide seat or anything else. Such objects can turn the stepwell into an obstacle course.

[insert photo #11 – Obstacle Course]

Tribulations and Trials

In a courtroom, no vehicle deficiency is as indefensible as a poorly-designed stepwell. For a vehicle owner, it may be hard to direct the blame for these deficiencies toward the vehicle manufacturer – just as it may be difficult to subsequently subrogate the damages against this party. After all, the purchaser had choices, and he or she chose (a) this bus and (b) that stepwell. Arguing that the plaintiff slipped can appear specious: If there were deficiencies in the stepwell, of course he slipped! (In more precise legal terminology, it was “reasonably foreseeable” that a passenger would.) As a practical matter, a defendant whose bus contained a poorly-designed stepwell may be forced to prove that the passenger would have slipped in a well-designed one. Particularly when the passenger is elderly or disabled, this task is challenging.

It is also hard to “blame it on the cue” (i.e., the vehicle manufacturer) where the defect is patent and obvious. To place the blame on, or subrogate a claim against, the manufacturer, the defect must generally be (a) “latent” (i.e., something not reasonably visible or easily recognized), and (b) something the purchaser did not knowingly choose. Certain types of stepwells are obviously available only with certain makes or models of vehicles. But when the stepwell is dysfunctional, the purchaser always has the option of selecting a different bus or coach altogether. These realities may not relieve a vehicle manufacturer from liability. But they can make it hard to pin all or most of the blame on one. In a courtroom, when vehicle defects are compounded by management and driver errors and/or omissions, both the manufacturer and the purchaser can sink together.

Don’ts and Do’s

While a bit over-simplistic, here are some general principles to follow in selecting stepwells:

1. Simple is better than fancy.
2. Choose steps that are all the same shape and size.
3. Choose steps that are all the same distance apart.
4. Install a linear handrail parallel to the steps’ outer edges on at least one side the stepwell – and consider installing one on both sides.
5. Extend the handrails’ length and height to be reachable from the ground, the floor and all points in between.
6. Make the stepwell as wide as possible – even if you have to squeeze a few rows of seats a bit closer together as a consequence.

Try to remember that good stepwells do not sell seats on the bus. But bad stepwells can land you a front-row seat at a long trial. The tickets for this seat can cost plenty even if you win.

Tough Love

In a courtroom, how does the astonishing sophistication of modern bus and coach features make your stepwells look if they are not designed according to principles at least 6000 years old? No palace constructed since the invention of the Jewish Calendar, the heyday of the Mesopotamian Empire, or the erection of the Great Wall of China ever contained an irregularly-configured staircase. Not Machu Picchu. Not the Pyramids. Not even the island village used as the set in “King Kong.”

Because these standards are so easy to meet, your choice of more complex stepwells may seem arbitrary and capricious, and may be interpreted as a reckless disregard for the obvious safety benefits which simpler and less-costly approaches would otherwise have presented. If and when this occurs, the redeeming value (such that it is) of your esoteric choices may be hard to justify.

The term “regular” is not just a digestion thing. It is a bus thing. But it can be both when your stomach starts churning as your turn to testify in defense of your vehicle selection and purchasing choices grows near. Try to imagine (or remember) that dry feeling in your throat the next time you purchase a bus or a motorcoach.

Whatever your operating objectives may be, think about simplifying your product choices when you start to feel the whim to make your bus too fancy and stylish. Instead, focus on the cornucopia of genuine safety features and dazzling technology at your disposal. Subsequent installments of this NBT series will identify plenty of them.

We already have enough handicapped bus and coach passengers. We should try hard to not make more. We should also try hard to not handicap the drivers.