Retailers Marketing Non-Compliant PMD as PMA - Falcon Mobility Singapore

Retailers Marketing Non-Compliant PMD as PMA

Non-Compliant vs Compliant PMA


Assoc Prof Muhammad Faishal Ibrahim, Chairman of the Active Mobility Advisory Council (AMAP), made this comment on Facebook yesterday:

“PMAs and PMDs are clearly meant for different users – the former helps the elderly or the handicapped gain mobility while PMDs, are used by able-bodied persons for commuting at higher speeds. Unfortunately, some retailers have been marketing non-compliant PMDs with seats as PMAs.”

I believe he is referring to the 3-wheelers being sold by some PMD sellers, which go at speeds of up to 25 km/h but weigh above 20 kg.

Why the Problem Exists

The root of the problem lies in the way the regulations are structured. Specifically, in the list of recommendations submitted by AMAP on 17 Mar 2016, we can refer to points number 9 to 11.

Physical Criteria for PMDs

Specifically, if you look at point No. 11, Personal Mobility Aids (PMA) are exempted from the physical criteria, because “these devices have a low maximum speed of between 6km/h and 10km/h”, which is the speed at which a person brisk walks or jogs.

This is the first problem, which is working on an assumption that all PMAs go at a maximum speed of 10 km/h or less. Yes, MOST do, but NOT ALL.

Now, PMA are categorised broadly into motorised wheelchairs and mobility scooters. In the Active Mobility Act, Part 1, Section 2, mobility scooters and motorised wheelchairs are defined as thus:

Quote "
“mobility scooter” means a vehicle that —
(a) has 3 or more wheels and a footboard supported by the wheels;
(b) is steered by handlebars;
(c) has a seat;
(d) is designed to carry an individual who is unable to walk or has difficulty in walking; and
(e) is propelled by a motor that forms part of the vehicle;
“motorised wheelchair” means a wheelchair that —
(a) is designed to carry an individual who is unable to walk or has difficulty in walking; and
(b) is propelled by a motor that forms part of the wheelchair;



And here-in lies the 2nd problem. If a PMD seller brings in a 3-wheeled scooter that goes at high speeds of up to 25 km/h and weighs above 20 kg, they can get away with it by calling it a “mobility scooter” rather than an e-scooter.

Technically, they have not flouted any of the regulations:
1. The product meets the definition of a mobility scooter, which is a PMA, and;-
2. PMA are exempted from the physical criteria

This is a loop hole in the current regulations that perhaps needs to be plugged.

How to Fix This?
While this seems like a big problem, the fix, I believe, is relatively easy and straight forward.

The current physical criteria apply ONLY to bicycles, PMDs and e-bikes, while exempting PMAs:
• Maximum device speed of 25km/h (for motorised devices only);
• Maximum width of 700mm; and
• Maximum un-laden weight of 20kg.

This can be replaced by a modified set of physical criteria, applied to UNIVERSALLY to ALL devices, including PMAs:
• Maximum device speed of 25km/h (for motorised devices only);
• Maximum width of 700mm (excluding wheelchairs); and
• Maximum un-laden weight of 20kg, OR maximum device speed of 10 km/h

This approach has the following advantages:

  1. The existing PMA users who use compliant devices that weigh above 20 kg but go slower than 10 km/h are not affected. This is the group that has genuine mobility problems and are not the ones causing a nuisance to other pedestrians. They should therefore not be penalized by any regulation change.
  2. It is simple and transparent, easy for the elderly to understand. From the enquiries we constantly receive, many of our elderly hear about the 20 kg weight limit imposed on e-scooters, and worry that it affects their existing mobility scooter, even though it is exempted. Having a universal set of criteria makes it easier for them to understand.
  3. It rides upon existing regulation and enforcement mechanisms. LTA enforcement officers are already using weighing scales to catch non-compliant PMDs. There is no need for further investment in equipment or manpower to catch non-compliant PMAs as well.
  4. It prevents high-speed, heavy motorised wheelchairs or mobility scooters from entering the market. Currently these devices do exist, but are not popular in Singapore due to high cost. However, they could still become popular in future if the cost of such devices drop.
  5. Wheelchairs need to be exempted from the maximum 700 mm width criteria to cater for bariatric wheelchairs. These are either manually propelled or motorised wheelchairs designed for patients with obesity problems, and they generally measure more than 700 mm in width.

I also suggest further, that sufficient time, such as 6 to 12 months, be given for the market to adjust to these changes.

This will give existing owners of such non-compliant PMAs a chance to go back to their vendors to get the speed tuned down, or even trade-in for PMAs that are already compliant.

Existing vendors will also have more time to plan their future stock purchases and adjust the top speed of their existing stock.

This will plug the loophole very quickly, without disrupting the lives of thousands of elderly and handicapped users, who are totally reliant on their compliant PMAs to get about with their daily lives.



Warren Chew
Managing Director
Falcon Mobility Pte. Ltd.


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