Ohio Admin. Code 3304-6-10 - Vehicle structural modifications

[Comment: For dates of non-regulatory government publications, publications of recognized organizations and associations, federal rules, and federal statutory provisions referenced in this rule, see the "Incorporation by Reference" section at the end of rule 3304-6-01 of the Administrative Code.]

(A) Wheelchair flooring. Wheelchair flooring is a covering on the floor of the vehicle that promotes ease of use and safety in mobility of a wheelchair user.
(1) Performance requirements.
(a) On ribbed vehicle floors of non-lowered floor OEM vehicles, wheelchair flooring shall be constructed of exterior grade or better plywood with a minimum thickness of three-eighths inch or sheet steel of at least twenty gauge.
(b) On flat portions of floors adjacent to ribbed floor areas where wheelchair flooring has been installed, wheelchair flooring shall be constructed of exterior grade or better plywood or sheet steel of sufficient thickness for a smooth transition. Other materials may be acceptable as equivalent in structure to plywood or sheet steel, but their use shall be reviewed and approved by the RTSU of RSC OOD.
(c) Wheelchair flooring shall not perceptively sag under load into depressions in the vehicle floor.
(2) Installation of wheelchair flooring shall be designed to be permanent. The method of fastening may be bolts, rivets, spot welding, bonding, or other methods. However as part of the final inspection, RSC OOD or its representative may partially remove the flooring in order to verify compliance to this rule.
(a) If the work was performed according to specifications and RSC OOD removed it for inspection, RSC OOD will pay for reinstallation of the flooring.
(b) If RSC OOD removes the flooring and the work was not performed according to specifications, the vendor shall absorb the cost of reinstallation.
(3) The floor covering shall be commercial-grade carpet, indoor/outdoor carpet, or nonskid material such as RCA rubber. Carpet shall be unpadded, low-pile, fire-resistant, and it shall be attached all across the floor; perimeter tack strips shall not be used.
(B) Dropped floor. A dropped floor is a recessed area that allows a wheelchair to be lower relative to the windows than is possible with open flooring. This lowering is necessary to achieve a safe eye-height for a driver who is driving from a wheelchair. Dropped floors are considered radical modifications and, as such, should be used when the driver is unable to transfer from a wheelchair into a suitable driver's seat to achieve maximum visibility for the driver who is seated in a wheelchair. In passenger applications, dropped floors should be considered only as an exception when a less radical raised-top modification cannot assist in obtaining sufficient head height clearance for the passenger in a wheelchair.
(1) When a dropped floor is necessary on a 2004 or later full-size van, it shall be done only on vehicles with an independent frame (non unit body construction) and on a model which has not been specifically disapproved by the OEM for such a modification. The structural modifier shall submit a plan that demonstrates compliance with all applicable federal motor vehicle safety standards and regulations. Data verifying compliance with the following items shall be submitted to the RTSU of RSC OOD:
(a) If the structural modifier has tested the floor lowering to the satisfaction of the OEM for the model vehicle being modified, approval of the floor lowering on OEM signed letterhead shall be sufficient proof of compliance.
(b) If the structural modifier is using the NMEDA floor lowering plan as the method to demonstrate compliance, the structural modifier shall:
(i) Be accredited as NMEDA QAP structural modifier and be able to produce a copy of the relevant NMEDA QAP lowered floor guidelines manual for the vehicle being modified. The vehicle shall be inspected to assure compliance with that guideline;
(ii) Produce certification from the fuel tank manufacturer stating that the fuel tank has been tested and found to be in compliance with FMVSS 301, fuel system integrity, in a vehicle using the NMEDA QAP lowered floor guidelines for the vehicle being inspected; and
(iii) Produce certification that the fuel system as installed per the NMEDA QAP lowered floor guidelines and the fuel tank manufacturer's instructions meet all federal emissions standards.
(c) All structural modifiers who plan to independently demonstrate compliance with applicable federal motor vehicle safety standards and regulations shall submit documentation that:
(i) The structural modifier has been audited for a comprehensive quality control program (e.g., participation in the ford truck quality program or equivalent).
(ii) The modification complies with applicable federal motor vehicle safety standards 49 C.F.R. 571.101, 108, 114, 118, 135, 201 to 204, 207, 208, 214 and 225 that are not exempted by 49 C.F.R. 595, or evidence that the non-exempted part of the FMVSS is not relevant to the modification.
(iii) The modification complies with federal motor vehicle safety standards 49 C.F.R. 571.102 to 104, 106, 111, 113, 116, 124, 129, 205, 206, 209, 210, 212, 213, 216, 301 and 302, or evidence that the indicated FMVSS is not relevant to the modifications.
(iv) The modification is in compliance with federal emissions standards.
(v) The modifier has liability insurance as defined in paragraph (I)(1) of rule 3304-6-03 of the Administrative Code. Proof that such insurance remains in full force and effect shall be provided to RSC OOD on an annual basis. The structural modifier shall notify his/her insurance carrier(s) that RSC OOD shall be notified within thirty days of any reductions in coverage or cancellation. The
(vi) The structural modifier shall also supply an indemnification notice to RSC OOD stating that he/she shall indemnify and hold RSC OOD, its agents, employees, and consultants harmless from all claims, damages, suits or actions, including any judgment, costs, expenses, and legal fees arising from any modifications made by said structural modifier.
(d) All structural modifiers demonstrating compliance pursuant to paragraph (B) of this rule shall meet the following additional requirements and shall provide documentation to the RTSU of RSC OOD relative to compliance with these requirements:
(i) No part of the body shall be attached to the frame except in a manner consistent with the concept and design of the original attachment.
(ii) All requirements described in paragraphs (A) to (A)(3) of this rule shall apply to a dropped floor.
(iii) A dropped floor shall be a minimum of eleven-gauge fabricated steel.
(iv) A dropped floor shall have heat shielding over the catalytic converter, exhaust pipe and the muffler to prevent transmission of excess heat to the floor.
(v) All seams shall be waterproof and treated to prevent corrosion through application of a suitable sealant, primer and paint. An automotive grade undercoating shall be applied to the exterior surfaces of the dropped floor. Installation shall not leave gaps or holes of any kind between the original floor and the dropped floor.
(vi) Cutting and/or welding of the body for the lowered floor installation shall be performed by a certified welder. The methods used shall meet or exceed OEM recommendations and methods described in service and shop repair manuals for that model vehicle and shall conform to SAE welding standards and good engineering practice. There shall be no body-to-frame welding.
(vii) Cutting of the frame for the lowered floor installation shall be allowed only if the floor is to be lowered more than six inches.
(viii) If the body is raised in order to lower the floor by the needed amount, the modification shall comply with paragraphs (C)(1) to (C)(4) of this rule concerning raised bodies.
(ix) If the fuel system is modified to lower the floor, the modification shall comply with the fuel delivery system modifications described in rule 3304-6-11 of the Administrative Code.
(x) A quick release removable seat base shall be provided in all vans configured so that an individual can drive from a wheelchair. The removable driver's seat shall have a suitable restraint system pursuant to paragraph (B) of rule 3304-6-09 of the Administrative Code. During the approval process, the modifier shall notify the RTSU of RSC OOD whether or not the removable driver's seat can be moved to the passenger side if the floor is lowered on both sides and, if so, whether the air bags and other parts of the restraint system work properly in the alternate locations.
(2) Approval of the structural modification.
(a) All information provided by the structural modifier in paragraphs (B)(1)(a) to (B)(1)(d) of this rule shall be considered public information and subject to public information requests.
(b) The information shall be reviewed by a team of licensed engineers for approval. When a dropped floor is being considered, the review may include a visual inspection of the vehicle.
(c) All design changes to an approved structural modification shall be reported to the RTSU of RSC OOD. The information to be submitted for design change review is that indicated in paragraphs (B)(1)(a) to (B)(1)(d) of this rule. When the information previously provided in paragraphs (B)(1)(a) to (B)(1)(d) of this rule remains the same as the original design, the structural modifier shall provide a written statement to that effect in lieu of resubmitting the requested information. The RTSU of RSC OOD shall determine whether the design change is sufficient to warrant the need for approval as a new structural modification.
(d) RSC OOD shall not purchase design changes prior to notice, review and approval by the RTSU of RSC OOD.
(e) The RTSU of RSC OOD reserves the right to suspend or withdraw approval without prior notification to the manufacturer if the structural modifier's product is found to be in violation of these rules or is found to involve a significant risk to the consumer's safety.
(3) Floor lowering on 2003 or earlier full sized vans may not be possible due to the availability of fuel tanks and fuel systems which comply with FMVSS 301 and current federal emissions regulations. All bids shall be coordinated with the RTSU of RSC OOD.
(4) Any engine cover notch shall be sealed to prevent exhaust fumes from entering the van and shall be sufficient for footrest clearance.
(5) Notched fender wells for wheelchair footrests shall not restrict the travel of the vehicle's wheel in any direction.
(C) Raised body. If the body is raised to lower the floor more than the OEM design allows between the body and the frame in order to achieve consumer visibility needs, the following specifications shall be met:
(1) Body raise spacers shall be solid steel or other material with comparable characteristics, and no less in diameter than the existing base of the body mount. Any replacement bolts shall be minimum grade eight. Body supports shall be equal in number and similar in function to the OEM design. Locations shall be in accordance with the applicable NMEDA lowered floor guidelines manual unless the structural modifier is able to demonstrate compliance through independent crash test certification.
(2) For the radiator and fan shroud to remain in the same relationship to the engine as before modification, both shall be remounted to the vehicle body in a manner that retains the original fan-to-radiator relationship.
(3) To retain the steering column's original angle, the original entry hole shall be enlarged. If the existing rubber boot or seal will not cover the new opening, it shall be replaced with another boot or with a sheet metal plate conforming to the shape of the column. The plate shall be fastened to the dash panel above the entry point to cover the new opening. The entry point shall be sealed with a flexible sealant to assure that the juncture is watertight.
(4) Body raises shall not be completed in combination with roof raises that are of more than twelve inches.
(D) Raised roofs. Raised roofs are structural modifications to any vehicle that substitute an after-market roof for the original roof of the vehicle. The after-market roof is installed to increase vertical clearance inside the vehicle to facilitate entering, exiting, and maneuvering inside the vehicle. The principal objective of paragraphs (D)(1) to (D)(2)(c) of this rule is to prevent any unreasonable compromise to vehicle structural integrity by removal of the original sheet metal roof and reinforcing members and by substitution of a raised roof.
(1) Raised roofs shall be constructed of durable materials, suitably finished to resist the effects of sunlight, moisture, snow, ice, and temperature extremes. Any fixtures mounted in a roof such as windows, ventilators, antennas, etc. shall be designed to be air-and-moisture leak resistant. The exterior of the raised roof shall be painted to match the body color of the van to which it is affixed.

The roof interior shall be trimmed in a material and color to complement the vehicle's interior.

(2) Any raised roof conversion shall be provided with suitable reinforcement members. These members connect the sides of the vehicle body and preserve interior space in the event of a major collision or rollover. The raised roof shall meet the following specifications:
(a) Any van that has had the factory top removed shall have structural reinforcement added to restore rigidity to the van body. When possible, enough of the original roof shall be retained so that the original front roof support remains in place. The structural reinforcement shall be composed as follows:
(i) If the original front roof support remains in place, three cross-members shall be perpendicular to the sides of the van with one bar in front of the side doors, one to the rear of the side doors, and one in the rear of the van. If the original front roof support is removed, roof reinforcement must be done exactly as described in the NMEDA raised roof and doors guidelines with a total of five cross-members.
(ii) The cross-members shall be connected by three equally spaced bars (longitudinal members) running parallel to the sides of the van at the new roof line.
(iii) All bars shall be one-inch by two inch minimum one-eighth inch steel tubing, and shall be spaced to prevent slap against the top.
(iv) The bars shall be welded together and welded to a one-and-one-half inch by one-and-one-half inch eleven-gauge steel header installed along the top interior sides of the van to which reinforcement is attached (a) a steel header composed of tubing ( 1.5 inch by 1.5 inch by 11 gage thick), or (b) a steel attachment, plate as described by the NMEDA guidelines (75 mm by 100 mm by 4 mm thick), or (c) a steel base plate as described by SAE J1725, "Structural modification for personally licensed vehicles to meet the transportation needs of persons with disabilities',which ever option is compatible with the original vehicle design and/or the raised roof design.
(v) The horizontal bars shall be compatible with NMEDA and SAE gussetted to the side header to prevent front or rear shearing in rollover.
(vi) The structural reinforcement shall have one-half inch clearance from the raised roof.
(b) Neither water leaks under water hose pressure nor water collection points that could develop leaks shall be acceptable.
(c) The height of the roof shall be determined by the consumer's needs for safe and convenient entry and exit. RSC OOD shall not purchase a raised roof or reinforcement if the only reason for the increased height is to accommodate the addition of carpeting or padding. Further, RSC OOD shall not purchase a roof with vents or windows unless it costs the same or less than a ventless/windowless roof of comparable height. A label identifying the maximum exterior height shall be prominently displayed within the driver's view.
(d) Roof raises of more than twelve inches shall not be completed in combination with body raises.
(e) The raised roof shall comply with applicable portions of FMVSS 216, roof crush resistance.
(f) The raised roof shall have an interior shell or headliner to protect occupants from the structural reinforcement.
(i) Raised roof interiors shall comply with applicable sections of FMVSS 201 not excluded by 49 C.F.R. 595.
(ii) Interior shells or headliners shall comply with FMVSS 302.
(E) Modified doors. Any alteration to the OEM vehicle doors that necessitates changes to the door frame constitutes a modified door. These modifications may be accomplished to increase entry height or width, to accommodate a raised roof or wheelchair lift installation, or for other special needs.
(1) Extensions to doors to make them taller or wider shall be accomplished in such a manner as to preserve the original door strength and rigidity. Corresponding alterations to door pillars and frames shall also preserve the structural integrity of the original body member. Raised entry doors and door frames shall meet the following specifications:
(a) Extended doors and door frames shall be braced in a manner consistent in strength to the original door and door frame.
(b) Completed doors shall include rubber molding and shall be moisture-sealed to prevent moisture or water entry in the full-powered closed position so that the seal is at least equivalent to the manufacturer's original installation.
(c) When a lift has not been mounted inside the extended doors, the doors must comply with applicable sections of the FMVSS 206, door locks and door retention components. All OEM latches shall remain functional and comply with the FMVSS 205, glazing materials. Documentation of compliance with the FMVSS governing latching of doors shall be provided to the RTSU of RSC OOD.
(2) All body work shall be primed and painted in accordance with accepted standards of automotive practice, and shall be comparable to the original fit and finish. Trim of the interior of the modified door shall be comparable to the original trim of the door. Door modifications shall be free of exposed burrs or sharp metal edges.
(F) Bumper height. The bumper height shall not be altered from the original height unless (1) directed to by the original equipment manufacturer (OEM) during vehicle structural modification and, (2) the new bumper height configuration has been tested as directed by OEM or to a thirty mph frontal impact as described in FMVSS 208 and a five mph frontal impact no airbag deployment test. At no time shall the raised bumper violate the Ohio motor vehicle code.


Ohio Admin. Code 3304-6-10
Effective: 9/8/2014
R.C. 119.032 review dates: 06/23/2014 and 09/08/2019
Promulgated Under: 119.03
Statutory Authority: 3304.15(C)(1)
Rule Amplifies: 3304.15, 3304.17
Prior Effective Dates: 09/04/1990, 05/10/1995, 08/02/1999, 06/03/2002, 08/04/2008

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