Risk and risk analysis when choosing a wheelchair.

This post is also available in: Nederlands (Dutch)

A life without adventure is likely to be unsatisfying, but a life in which adventure is allowed to take whatever form it will be short.
Bertrand Russell

There are several possibilities to move around medium distances as a wheelchair user. Wheelchair-connected drives, a wheelchair car or bus, a wheelchair taxi and public transport. These possibilities are important when choosing the wheelchair. A transfer to a seat in a taxi can’t be done by everyone. That has implications for safety.


New cars and buses must comply with quite a few European rules before the car is allowed on the road. Extensive crash tests are carried out to look at the risk of head and neck injuries. Seats must be equipped with well-fitting three-point belts, a headrest and airbags. As a driver or passenger, the chances of surviving a collision have increased considerably.
Nevertheless, there are still oldtimer cars allowed on the road with only a hip belt….

Wheelchair as a seat

A wheelchair space where you stay seated during the ride is no ordinary seat. In crash tests wheelchairs are tested with a dummy. It is comparable to an ‘average’ adult human being, in terms of movement pattern during such a crash.
People who use a wheelchair as a seat are sometimes more vulnerable than an ‘average’ person. Even if the wheelchair meets an ISO 7176/19 crash test, it is not predictable what the effects of a collision will be on head and neck injuries.
That’s why all the advice on wheelchair transport say: If you can switch to a standard seat, it’s safer.
If you can’t make that switch, you really don’t have a choice: staying home and avoiding risks is hardly an option. By making use of the possibilities for transport that exist and choosing a wheelchair that best meets your individual wishes and requirements, you can fully participate in the society. Taking the higher risk for granted.


When choosing a wheelchair, there are quite a few ergonomic requirements and possibilities to consider. This is an individual process together with occupational and physiotherapists, rehabilitation doctor, manufacturer and wheelchair supplier. And the municipality, UWV or care office as a provider. This often goes well (66%), but there are also situations where the outcome is a less optimal, even wrong wheelchair (17%). Source numbers:

Risk analysis

Making a risk analysis when providing a wheelchair, if it serves as a seat in transport, is important. Identify as many risks as possible for the wheelchair occupant and the other passengers. And take measures to reduce those risks. In very exceptional cases if safety is still inadequate, one will choose another wheelchair. Or individual transport as a solution.

Examples of guidelines:
from Australia (New South Wales) Transport Guidelines for People With a Disability and
(Western Australia) Vehicle and Transport Resources:
from England BPG1 Transportation of People Seated in Wheelchairs (chapter 7 ).

Wheelchair provision

In the Netherlands, unfortunately, a risk analysis is not common when providing a tailor-made transportable wheelchair. At least not as a follow-up to points (checklist) indicated by occupational or physiotherapists where a proposed wheelchair cannot strictly (no longer) meet ISO 7176/19.
In the wheelchair taxi, the VVR code was used to determine whether a wheelchair is ‘safely transportable’ or ‘transportable’. That determiniation is not really a core task for the taxi driver. If there is insufficient attention to safety during the provision, it is up to the driver who has to check that a wheelchair can be tied down safely.


A VVR code has now been drawn up by Social Mobility Fund (SFM). This Code imposes the requirement that a wheelchair, when used as a seat in taxi transport, must comply with the crash test (ISO 7176/19) from 1 July 2020. In the case of a a custom-made aid (wheelchair), only individual transport is allowed.

Some questions:

  • Is it right that well-transportable wheelchairs suddenly stand by the wayside?
  • What risk does this simplified Code cover? How is this in relation to the other risks in wheelchair transport? For the wheelchair occupant and the other passengers?
  • The result is suddenly more applications for wheelchairs that have met a crash test at the municipalities. Is that wheelchair ergonomically the right one for the user concerned?
  • Has there been an accident and risk analysis done under the new Code? And is this measure the most obvious to improve safety? Where groups of wheelchair users are disadvantaged.
  • Can we assess that analysis before such a stringent measure is implemented?
  • What interests play a role in this measure?
  • Why is the taxi driver the black man who gets to deliver this message, and has the individual wheelchair occupant to solve it?

Wheelchair users on the sidewalk?

In the case of the postponement of the introduction of this Code until July 2020 , Wim Faber put it this way in his edito at Passenger Transport No 3 of June 2019.:

“Fortunately, the introduction has not now been continued. But many parties, such as carriers (who leave wheelchair users on the doorstep just in case), municipalities and WMO organisations (who doubt and replace wheelchairs without the right sticker), now do not know (anymore) where they stand. For example, there is no good arrangement for users of wheelchairs custom-made, made by orthotic suppliers. But there are a few other loose ends.

Why don’t (the two) parties stick their heads together? After all, it is about the welfare and safe transport of wheelchair users. Or not? “

A further explanation

To avoid all misunderstanding. The intention is not to allow all wheelchairs that are can be tied-down at first sight, but after an analysis prove unsafe, to be allowed into transport. The consequences of this have already been shown in a 2013 German study on wheelchairs of schoolchildren: Sicherheit von Rollstuhlfahrern in Fahrzeugen .

Before they enter the market, wheelchairs in the EU must meet legal requirements and standards.
See also the CE flowchart from Firevaned that indicates when a wheelchair is a custom made wheelchair:


There are still quite a few wheelchairs, as a custom made or adapted aid, which do not strictly meet the crash test standard, in which the wheelchair user does want to participate in the transport. The number of wheelchairs and combinations of bases and orthotics on the market that meet the crash test standard is growing.
A crash test provides more certainty. A wheelchair that meets this is, if the other ergonomic requirements are also met, first choice and then preferable to a custom-made tool.
Responsible adjustments to a crashed wheelchair must be possible!
A custom-made wheelchair or a modified wheelchair does not have to be compromised in terms of safety. The ‘safety proof’ is only much harder to deliver.

The authors of ISO 7176 part 19 (2008), the crash test standard, have also seen that accessibility of transport is important :

“Finally, this part of ISO 7176 can be viewed in the totality of daily wheelchair use and the range of standards to which all wheelchairs are expected to comply. Wheelchairs are designed primarily to serve as effective mobility devices and, in that respect, they must first conform to the applicable requirements set forth in other parts of the ISO 7176 series. 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 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.”

Practice guidelines

As well as the authors of the International Best Practice Guidelines. (BPG1) Transportation of People Seated in Wheelchairs.

“Due to the individual nature of disability, prescribers may at times be faced with the need to request modification to a wheelchair or off-the-shelf seating system (Class 1 medical devices) in order to maximise medical benefits, and to address the postural and functional needs of a wheelchair occupant. In such cases access to transport should not be denied. Rather, necessary modifications should be undertaken and documented in line with relevant medical device legislation, and a risk management process should be followed before decisions are made about suitability of the system to be used as an occupied seat in a vehicle. There may be cases where in-spite of all efforts to enable transport, risks of occupant injury may be deemed unacceptable.”

Chapter 7 of the BPG1 Transportation of people in wheelchairs, is specifically about Risk Management.

In Australia, a tryout checklist has been used in a number of cases. This indicates where and why a wheelchair cannot strictly comply with the ISO 7176/19 in the case of a specific user. In these respects, a risk analysis is required to find a solution that provides sufficient safety.
In the presentation from Queensland exceptions to the rule are also discussed!

It is clear that in England and Australia the decision whether a wheelchair is safe, for use as a seat in transport, does not fall in the wheelchair taxi (bus). But already when measuring the wheelchair!

Conclusion and proposal

It seems sensible to base the decision on a sufficiently safe wheelchair on a thorough risk analysis on beforehand. So: when the wheelchair is provided.
A safe wheelchair should have hook symbols, which clearly indicate the tie-down points, for securing with a 4-point locking system (ISO 10542).

hook symbol for tie-down pointssnap hook symbol from ISO 7176/19 (2008)

The above applies to wheelchairs with CE label, as well as ‘customized aids’ and adapted crashed tested wheelchairs that have been deemed safe.
One problem is that adjustments to serially produced wheelchairs that are not permitted by the manufacturer are not allowed, according to the MDD. That limits the usability of wheelchairs considerably for a number of users! Especially if manufacturers don’t want to think about adjustments either. Liability risk is then considered more important than customer satisfaction.
In a wheelchair passport, the outcome of the risk analysis can be displayed along with any further instructions on seat belt use, and other details.

That gives the wheelchair taxi driver space. He no longer has to assess the safety of the wheelchair. He signals or refuses only in the exceptional cases where he does not trust it.

Linked to

Haven’t we forgotten somebody?

Custom work

Pièce de Résistance of the Code VVR


Firevaned. Firevaned CE Stroomdiagram Convenant En Crashtest. Firevaned, 2020, https://www.eengoedhulpmiddel.nl/firevaned/ce-stroomdiagram-convenant-en-crashtest.
Faber, Wim. “Edito.” Personenvervoer, vol. 3, no. 2019, June 2019, p. 5.
Montfoort, Pauline. “Heb jij de rolstoel die je wilde? Peiling onder Lezerspanel.” Support Magazine, no. 2 (2020), mei 2020, pp. 26–28.
Peters, A. Code VVR 2019-2020. A. Peters, 1 Jan. 2019, http://codevvr.nl.
Appleyard, Bob. BPG1 Transportation of People Seated in Wheelchairs 1st Revision 2019. 2019, https://www.pmguk.co.uk/resources/best-practice-guidelines/bpg1-2019-revision.
WA Travel Safe Interagency Working Party. “Vehicle and Transport Resources.” INDIGO, https://www.indigosolutions.org.au/resources/mobility-and-transport/vehicle-and-transport-resources. Accessed 9 June 2020.
Queensland Government. Vehicle Options to Transport a Person in a Wheelchair. https://www.health.qld.gov.au/__data/assets/pdf_file/0020/436412/recomm_wheelchair_seated_trans.pdf. MASS.
ISO. ISO 7176-19:2008 + A1:2015. Wheelchairs-Wheeled Mobility Devices for Use as Seats in Motorvehicles. ISO, 2008.
Transpot. Transport Safety Guidelines For People With a Disability. SPOT on DD, Sept. 2010, https://at-aust.org/items/4966.
Konrad, Tanja. “Sicherheit von Rollstuhlfahrern in Fahrzeugen | Der-Querschnitt.de.” Der Querschnitt, okrober 2013, p. 2, https://www.der-querschnitt.de/archive/10328.

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