Good afternoon, and welcome to the ADA distance learning program. This is a special session today, it''s 90 minutes. We''re going to talk with Mark Derry. Hi Mark.
Hi there.
What''s wrong with this picture? We billed this particular session with the use of technology in mind and it is going to be viewed as a slide show that is currently posted to the Great Lakes web site at www.adagreatlakes.org. We have a frames version and non-frames version. There are about 25 different graphics, so it might take a couple minutes, especially if you''re on a slower connection for all of the graphics to load, but if you can just be patient they will eventually pop up. Mark we''re excited to have you with us today. Through this program we''ve had a number of presenters talk on the accessibility guidelines under the Americans With Disabilities Act, and so we''re excited to kind of move one step beyond the ADA accessibility guidelines and look at some of the common perceptions and misperceptions when interpreting the accessibility standards. Mark is a consultant with Eastlake, Derry and Associates where he specializes in accessibility, universal design, ADA consultation and training. Prior to starting his own firm Mark was a technical assistant specialist and trainer for the Mid-Atlantic technical assistance center. He''s has worked as an architectural barrier consultant for Action Towards Independence, an independent living center in New York state. Mark has served on the Public Rights-of-way Access Advisory Committee for the U.S. Access Board and last summer he was elected to the board of directors for the National Council on Independent Living. Thanks for coming on board with us today.
Glad to be here. I accepted this role you understand because you agreed to back me up.
Yes, I did.
We''re looking at a pop quiz kind of format today and I wanted everyone to know that Jennifer is as welcome on the hot seat as I am.
We''ll also let people know that typically what we''ve done in these sessions is given a half an hour or so presentation and based on the content what we wanted to do is break more periodically through the slide presentation to give people an opportunity to ask questions.
We''ll probably stop around the 10th slide.
Around the 10th slide, so if you have questions as we move along on certain slides then we''ll give an invitation for you to ask those questions.
Yes. We''re also going to be taking kind of the angle to this thing that a lot of us have already been in ADA training sessions and have listened to a few teleconferences and are ready to talk about reality, the real world, what we''re seeing out there and the best practices when we''re looking at different aspects of accessibility. One of the reasons that I wanted to use part of my what''s wrong with this picture show, which is the name of the slide show we''ll be using pieces of today, for this session is it helps to explain the "why" behind accessibility. A lot of times as I travel around doing trainings with architect text and building officials I''m finding that when you explain the "why" to accessibility, why a wheelchair space is 30 by 48, because that''s usually the length and width of an average wheelchair, then they understand why that particular measurement is applied to a particular aspect of accessibility, and all of a sudden it clicks. You can hear it in a room of architects where all of a sudden it clicks and everyone says "ah ha" and that number sticks in your mind. I''ve had real good luck with this particular slide show. It developed from years ago when I was working in up state New York at a center for independent living. I developed a slide show with a fellow by the name of Charlie Fisher and later on massaged the show with a person named Andrea Haenlin Mott from the ADA Disability and Business Technical Assistance Center in Region 2. It has transpired far and beyond even those days because everywhere I go I carry a camera with me and take pictures of things I see. You''ve all seen things I''m talking about where you stare at it and say I can''t believe somebody designed this or I can''t believe I''m looking at what I''m looking at. That''s when I pull out my camera and take a picture of it and I use those pictures at this slide show and to try to show people the "why" behind accessibility. So with Jennifer''s help today, we''re going to go through some of the slides that I use for this shows. I''ve got about a thousand different images over time that we''ve put together, but we''ve got about 24-25 here today that we''re going to look at. As we do this we''re going to look and use the priorities that the DOJ has established for looking at accessibility. If you''re looking at a facility under ADA or the Architectural Barriers Act or whatever the particular law is that''s requiring accessibility... today we''re talking about ADA... the accessibility requirements are broken down into four major priorities by the Department of Justice. Those priorities go like this: the first priority, of course, is getting approach and entrance to the building or facility. You need to be able to park your car and get there and get in the building in order to access the goods and services. We''ll get into that more in just a minute as we roll into the slides but I just want to give you the other priorities as we get this thing started. Priority 2 would be access to goods and services. Once you gain access to the building then you''re there for a reason. You want to gain access to the goods and services and several things can affect that, your path of travel or your accessible route through the building, your access to goods and services, say at a counter or in reach ranges. We''ll talk about those things as well. The third priority is access to restrooms. If you''re in a facility that offers restroom use to the general public and you''re accessing goods and services and the restrooms are part of that, they should be accessible for everyone to use. Then priority 4 according to the Department of Justice covers a general category, one of those miscellaneous things and they say all other measures necessary. Basically, all the things that are necessary to be accessible so that the facility or goods and services are as accessible to people with disabilities as they are to everyone else. So with that in mind let''s roll into priority 1 and we''ll go through a few of these slides.
Mark, I''m sorry. I didn''t mean to interrupt here I just did want to remind people that the session is currently being real-time captioned on the Great Lakes web site as well. So we have Robin Jones the project director for Region 5 logged into the chat room right now so if people would like to ask questions when we get to those breaking points they can also submit those questions on line.
Terrific. Okay. With that, I''m going to go through a few of these slides that are up on the web site. I''m going to describe them for folks who don''t have access to them. They''re basically just a slide to illustrate what I''m talking about, and I''m going to be talking about the general points of accessibility. I''m told I do a pretty good job at description on my slides. The first slide that we have is just my company logo, which is Eastlake Derry and Associates, which is my outfit. Later on we''ll give you my e-mail address should anybody need to send me questions or what have you regarding this session today. The next slide is what I comically call rural accessible parking and it is basically a picture of a parking lot I found in West Virginia, where I live, where they have set up their accessible parking in a rather unique manner by simply taking a concrete block and an accessible sign on a one-foot stump and thrown it on a gravel parking lot and said this is accessible parking. Of course I''m kidding with all of this and we all know that in order to be accessible under Priority 1 we need to have an accessible parking set up that has a surface that isn''t this loose gravel that everything is going to sink down into or bog down into but a firm, stable surface. We also need to have the layout of our parking spaces that''s required by ADAAG and we need to check our local codes. As I talk about these accessibility features today bear in mind, depending on what your role is with accessibility, you''re going to need to be not only proficient in the ADAAG and in accessibility as it pertains to the ADA, but you might, depending on your involvement, want to look into local building codes and be real proficient on what your local or state code is in regards to accessibility. Many times, especially these days as we get closer to harmonizing as they call it between building codes and the ADA accessibility standard, which is the ADAAG that we know that''s incorporated into the ADA regulations. With a harmonization the two accessibility standards are getting closer and closer. Basically what I''m saying is make sure and check all of your information when you''re trying to give people advice on accessibility. There might be a small new nuance in local code that could really be useful. But in the parking we know we''re going to be looking for the access aisle adjacent to the parking space, it''s going to be very important. It''s going to need to be a five foot or eight foot access aisle. What I do a lot is go through the process of looking at accessibility with a tool in my hand. I usually have an accessibility checklist or something to reference at all times so that I''m checking things in a order that keeps me organized so that I''m not forgetting things. The last thing I want to do is tell a business owner about one specific problem and then have someone else come along and point out three or four that I missed. So using a checklist will always keep you safe on that note. Moving through our slides, once we have our accessible parking, we have a sign marking the accessible parking, you need an accessible route going to the building. In slide 3 we''ve got an example of bad access that we''ve seen a lot, where a parking accessible route to the store or business from the parking gets blocked by just a mere coincidence of bad design, if nothing else. In slide 3 we''re showing where... this is a very old picture of Ron Mace who passed away a few years ago, he''s known as the father of universal design. In this slide he''s shown how he has come out of a store towards his car and he is actually parked two cars over and the car that we''re looking at in the slide is sitting in the access aisle, blocking his curb ramp down to the parking area. This happens a lot and it can be avoided. Something that isn''t required in ADAAG but it is a great suggestion to folks in the design community and store owners that are restriping parking lots and have a problem with access aisles is creating or installing a ballard out at the end of the access aisle to keep people from parking in the access aisle and blocking it. This is a common problem and a lot of times you can eliminate it by doing that. It won''t keep the shopping carts or motorcycles out of there necessarily but it will help a bit with keeping full-sized cars out of there. In slide 4 it''s another example of our accessible route being blocked, coming from our parking space. Our slide shows a person using a wheelchair, and they are trying to move along the accessible route, which is the sidewalk to the entrance of the business, and there''s a car that''s overhanging the sidewalk and blocking the accessible route. A lot of times when you''ve got this kind of scenario it can be avoided by suggesting that the parking lot owner install these stop blocks at the front of the parking space, so that it keeps the car back a bit off of the sidewalk so that it can''t overhang and interrupt the accessible route. Slide 5 in this session of slides in priority 1 demonstrates... the next couple of slides talk about a couple of things that I want to point out that shouldn''t be part of that accessible route. In slide 5 we''ve got a picture of a power wheelchair that is trying to make its way through some pretty heavy gravel and I referred to that in our rural parking slide earlier, that any surface that is not firm and stable, not only wheelchairs, but mobility devices like canes or crutch tips will sink down and get bogged down in and people will have a much more difficult time crossing that kind of texture. In the next slide in slide 6 there''s another obstacle barrier to access that we see in accessible routes all the time in the form of a water grade, a drainage grate. If you have a drainage grate water is important to be removed from the surfaces, we know that, but in design we try to avoid having the grates along our accessible route. If they have to be along the accessible route the holes in the grate should be half inch maximum and should be cross the line of travel of the accessible route. It should be perpendicular to the direction of the holes and they shouldn''t be more than half inch. In this picture it shows what happens if a wheelchair goes across a grate that has holes that are tied. The front wheels drop down into the grate, the foot boards hang up and the person stops immediately. In slide 7 you see another problem that a person using a wheelchair or a person using a walker or mobility device would find very dangerous. We have here a picture of a curb ramp that is built into the side of a sidewalk with very steep side flares on it. I like to call them ears. These are very steep and drop off quickly and so what happens is a person walking along the sidewalk doesn''t necessarily see them or isn''t watching or is having a conversation with someone else and they go off this edge and they''re over and into the parking lot before they knew what happened. Here they need to have gentler slopes on this curb ramp and those of you who are watching that are astute will also notice that there''s no flat landing at the top of the curb ramp. They kind of are trying to fool us with the paint but the angle of that curb ramp flows all the way to the top of the sidewalk and there''s no way to turn on a level landing at the top. Slide 8 reminds us of a similar situation, where you''ve got a telephone pole planted in the middle of a curb ramp. I couldn''t believe somebody did this. This you just can''t make up. You have to take a picture of it when you see it. This telephone pole is somewhere in Maryland, I won''t say exactly where, but the design here, this is actually a new curb ramp that was poured around this telephone pole and yes telephone poles do not belong in the accessible route. Moving on to slide 9 we see another thing that comes up all the time on existing structures. You''re providing an accessible route up to the entrance and in this slide we''re showing a person who is using a wheelchair, he''s gone from the parking out of his car up towards the building and there''s three steps blocking his way to the front entrance. He has no idea which a way to go next. If there had been a sign put there showing him where the nearest accessible entrance were or better yet, back a little farther before he even got to these steps so he had a constant route without having to turn around and go back that would be very, very important to this person trying to find the accessible entrance. So wherever you have an entrance that is inaccessible you should have signage indicating the nearest accessible entrance. Slide 10, before we take a break for some questions, is one of my favorites a friend sent me from Florida while she was on vacation. Again, you just can''t make this stuff up, folks. And if any of you have pictures, please send them to me. This slide shows a section off of a boardwalk in Florida where my friend was vacationing and they have a lovely ramp down to the ocean and you get down near the ocean and it ends with a set of seven or eight steps down to the beach. You can almost get there, but not quite. With that, I think I''ll turn it over for some questions if we have questions on priority 1 and our route of travel and our accessible approach and entrance, I think we''ll take those now.
Janis Peterson of Superior Alliance. I''m looking at the curb cut from parking space to sidewalk and I wonder if you could explain that again, I missed it. I''m not sure about the flat landing at the top.
Okay. If you look at your ADAAG under curb ramps it will show you that wherever you plan a curb ramp you need to make sure that there is space for approaching and turning on to it and actually at intersections it''s very important to have a flat space at the top of the curb ramp so that people can maneuver, push the accessible pedestrian button to get the intersection light to change for them to cross the street. All of these things take a flat landing at the top so that you''re not fighting your mobility device going down the ramp into the street. In this particular slide, they''re showing a sidewalk where basically the sidewalk crosses the curb ramp and there''s no way for you to... it all comes up on you too fast and you''re tipping into the street. The bad thing about stuff on sidewalks and curb ramps when it''s wrong is it usually tilts towards the street so you''ve got a double jeopardy thing there. You not only tip over in your power wheelchair but you end up getting dumped out in the street and here comes the Greyhound bus to run over you.
So where would the flat surface be or should it be?
With this curb ramp they should have had the slopes be gentler on the sides of it. They should have also had the top of the ramp be flat that was level with the rest of the sidewalk. If they couldn''t do it at this particular location with the perpendicular curb ramp, they could have either increased the pad at the top of the ramp into that planting area behind it or they could have located the curb ramp in a different area so they had more room to work all the features in that need to be there.
Hi. I just had a comment on the parking next to the grate. I am in a wheelchair myself and I''m in the design profession and I just wanted to mention that too many times I go to get out of my vehicle and into my wheelchair and unless my brakes are locked appropriately my wheelchair I sometimes find out in the middle of the road. The slope sometimes is greater than what it should be and also, I''ve also found that I''ve also got out into mud puddles that are up to four inches deep which will get my feet wet.
Way bad. That''s one thing that I mention a lot when I''m training and doing training where I have much more time to talk about it is that level landing. The level parking area should be two percent or less in all directions and the reason for that is just like you just said. If somebody forgets to set their brakes off goes the wheelchair and it''s so annoying to have to chase your wheelchair down and start the whole process over again. Another thing I''ve had happen with those grates especially when they''re near a parking space I''ve actually dropped my keys down in the grate one time.
I just wondered if you were aware of that situation and have seen that before.
Yes.
Thank you.
Thank you. Also, a lot of times in a parking environment... people ask me a lot of times if you''ve got a gravel parking lot what do you do. Technically you''re supposed to for your accessible parking pore a bad or concrete pad. I''ve seen only in instances where you were out in the woods working with the Forest Service or something like that where you could use a crusher type material that''s like a gravel with a concrete mix in it. I really wouldn''t tell anybody it''s okay to use that unless they''re out in the woods. You really need to have that firm, stable surface at your parking space that''s level in all directions.
That''s exactly right, Mark we were just talking about that earlier is that people have such difficulty when it comes to picking out surface applications because of the subjective nature of firm, stable and slip resistant.
And now it''s coming up hugely in play areas.
In playgrounds. But fortunately in play areas the new standard will have an objective measure so especially in the work I''ve been doing in recreation we tell people you really need to look to the case law and the complaints and how the investigating agencies have fallen one way or another for a particular surface. And gravel in and of itself and with some of the agencies that DOJ has assigned to investigate these complaints, gravel is one of them that definitely those investigating agencies have said no, gravel is not an accessible surface, same thing with pea gravel.
Kelly of Woodrow Wilson Rehab. Actually we have two. The first one is do you have suggestions for being able to communicate accessibility needs to care takers of historical properties. That''s the first one.
And where are they located? Williamsburg Virginia.
Two things: Get in touch with your local ADA information center by calling (800) 949-42332. For suggestions or e-mail me and I''ll try to track down specific people for you to talk to in that part of the country. Generally on historic properties you probably know this but I''ll state it for the group, if you''ve got a property that is on the register of historic places, be it national or state, generally you''re dealing with something where you''ve got a lot of folks who are talking to you about history which is very passionate to them, almost as passionate as access is to us. So we have to reach some common ground. We do not do anything to a building that affects the historic significance of the building, in other words what makes that building historic, but we do still address access on the building. So that can be a process and you need to call in local people from historic societies and others to be a member of that conversation because it will only serve to help you through finding the right solutions. I don''t know if that answers your question or totally confuses it.
Chuck Jones of Hoffman Estates actually we have a two fold question. Number 1 is how often in a public sidewalk in a downtown area of a village would you need to have the curb cuts and two, along with that, if you have differing heights in an antiquated village over a 100 years old, different heights of existing structures, how would you address that with the sidewalk?
Okay. The first thing I would tell you to do is go to the Access Board web site because the Public Rights-of-way Access Advisory Committee, PROWAC committee. I don''t know how we got that name. I serve on that committee and we just finished work on accessibility recommendations for sidewalks and the public right-of-way and there''s a lot of helpful guidance in the latest publications from the Access Board along those lines. To get to your questions, it kind of depends. You''re need to look at a lot of different factors in deciding how many, where, and when. I would hesitate to tell you without being there. You know you need to address the path of travel or the circulation path or the accessible route or as we just named it at the Access Board the pedestrian accessible route, the PAR, we were going for a bunch of different names for that one, and see where the path goes, where people go. As a Title II entity they would have to make sure that they had access to all their programs and services and work their way out from there. But it''s going to totally depend on the environment as far as the location. What was the second part of that?
How often, and the elevation-different heights?
Oh yeah, the different height thing. As you get involved with that, look at the publications by the Access Board because some of that is addressed by them and it all depends on how much public right-of-way space you have or can buy because a lot of times there''s not enough space to do perfect accessibility in the existing environment and the guidelines are written for new construction, a sidewalk in the middle of a corner field and then you try to come as close to that as you can. We''ve got towns in hilly environments in the U.S. that this is a real problem and a lot of times they''re trying to, while they do the sidewalks, meet the needs of their buses and come up to the level of each door at a store, and a lot of times that is an architectural and engineering nightmare, but it can be done using a lot of little tricks as far as different platforms to the sidewalks and things like that. Some of it is doable in existing structures, some of it is only doable, you know, in the new environment.
Thanks Mark. We should also let people know that this rulemaking on public rights of way, that that was something that was in the works and shelved out when chapters 11 and 12 were issued
14 actually. When they first published 14 there was all kinds of problems with towns and counties and road departments and the transportation research board. Nobody had enough information yet, so they yanked chapter 14 and said we need to establish it in our federal way a committee to research this. And that''s how the public rights of way committee like other committees at the Access Board, playgrounds, recreation, passenger vessels, all of that, if they don''t have enough information they form a committee to study it and give recommendations and that becomes part of the rulemaking process that eventually gives us our guidelines. Not that that makes it any clearer.
Exactly. However it is much more clearer than it used to be and that report from the committee is now up on the Access Board''s web site and it probably does provide more guidance than we''ve had in this area before.
We''re very proud of it. On-line Question: What are your thoughts on further amendments and/or changes being made to the current ADA laws on the books.
That''s a law question. What are my feelings?
Do you want the serious answer or the tongue in cheek one? That''s kind of a tough one.
See, I manage to stay free of a lot of legal questions by being a structural kind of guy and as far as the ADAAG goes, the Access Board is working fast and furiously to put out a final, if you will, issue of the updated ADAAG that we just saw last year for open for comment for four months or so. And they are all concentrating on getting that together, which I''m looking very much forward to. Part of the work of several committees they have been waiting on to be done so that they could incorporate it in that, ours being one of them with the public rights of way committee. So I''m really looking forward to the updates. How soon, when? I''d advise you to call your local ADA information center, your Disability and Business Technical Assistance Center and they can probably bring you as up to speed on it as I am because they have the inside track on that stuff.
Mark, did you want to go ahead and move on and we''ll open it up for questions at our next break.
Let''s see. Let''s move through priority 2. We''ve made our way from the parking lot up towards the building and into the door hopefully. We need access to goods and services. That can include a lot of things. You have to be able to gain entry to the building. Slide 11 shows an old picture that''s a classic that a lot of us use in talking about accessibility. It''s another photo of Ron Mace. Ron has made his way all the way up through the building and is going in for his appointment at the office and can''t get there because one of these two doors that are shown in this slide, neither one provides at least 32 inches of clearance and that''s one of the things we''re looking for as we''re looking at our accessible route inside a building to obtain goods and services to go to an appointment with our lawyer, go to our doctor appointment, you need to get through the door. Horizontal circulation is going to include all public spaces and they should be on an accessible route of travel. When you''re looking at doorways like this slide illustrates you need at least 32 inches of clear width. One of the things I tell existing structure owners, existing building owners, store owners and those I''m trying to work with to give them ideas for accessibility on doors is if they have a door that''s close I suggest offset or swing clear hinges and a lot of time that will save them from having to replace the whole door and frame of a door that would be otherwise inaccessible. Other things we look at lever handles for operating the doors, we look at how much poundage an interior door has. Again, you should be checking as you''re coming in the building. If you''re in Florida for instance your building code is going to have a requirement eight and a half max poundage on your outside doors as well. ADAAG doesn''t have that. They reserved the poundage on doors because they had so much trouble getting it to match with blow open force for fire code and things like that. So it was reserved, however accessibility is still required, you don''t necessarily see power doors pointed out as a requirement in ADAAG but accessibility is required so power doors may be one of the options you need to look at for access if you''ve got door problems. Other things you need to be looking at as far as priority 2 goes are emergency egress. If you''ve got fire alarms inside the building you should have the right alarms with the flashing strobe lights, as well as the audible signals. Signage for goods and services. If you''re providing directional signage it should be very contrasting colors, it shouldn''t be real shiny, it should be more of a mat or eggshell finish. If you''re marking rooms in a building and providing permanent signage to individual rooms, you would be concerned with accessible signage to the point of making sure you included Braille and tactile raised letters on the signs so that someone who is blind or visually impaired can navigate the built environment. These things are very, very important to someone who''s trying to navigate an environment. This can be included on your and seen on your requirements in elevators as well. The hoist ways should be marked with appropriate signage for the floors, as well as the equipment inside the elevator. Access to the goods and services, one thing that we''re seeing a lot of problems with in a lot of areas are counter heights and if you''ve got a counter where people are expected to sign a check or there''s a cash register or there''s something that needs to be signed, you need to definitely have a lowered section of the counter for people to use both who are short of stature or who may have a mobility impairment, but we''re seeing that in a lot of places, even in new construction. An example of that would be hotels that don''t do a drop down section to their check-in desk. Another place we''re seeing it is in large department stores, the accessible cash wrapped counters they''re called where you take your goods and pay for them are many times located or built so they''re 40 or 42 inches high and they make it very difficult for many people to use, both with and without disabilities. So there''s a lot of things that you need to look at under priority 2 in obtaining the goods and services that are offered by that entity and moving through the facility as it''s offered to the general public.
Mark, when we go through priority 2 and actually getting into the door, there is this new wave of revolving doors that are actually the swing doors inside are actually larger in scope, a lot of them are automatic, they automatically move so you don''t have to push them.
And they cost about $270,000 a piece.
And there is a great big blue wheely guy-we call them now, the international symbol for accessibility that says it''s wheelchair accessible but a lot of people don''t realize what the actual standard is.
The actual standard is if you''ve got one of those revolving doors, in addition to that you have to have a swing door next to it, so that someone with a disability can use the accessible entrance. Generally historically those revolving doors have been inaccessible to people with disabilities and in fact can be rather dangerous to some people using certain mobility devices that can get in them. The latest rage are these new ones that Jennifer mentions. I''ve seen several at major hotels, for example and in fact found out that one I inquired about cost the entity $275,000 and I mean, you could drive a golf cart through the thing. It may very well be fairly accessible to people with disabilities, but it''s a new animal and as far as the regulations go, it''s not recognized in the accessible route yet. And if I was an architect doing a design with that door I would always include the swing door for many reasons besides just accessibility, it''s good have. But those doors, they''re like a lot of other products you see, it will have a sticker on the side that says "ADA compliant" or "you need to buy this in order not to get sued!" Believe me folks, don''t believe those stickers. There''s no such thing as a certification process. There isn''t any kind of a test like a UL test as a product to be "certifiable" under ADA. So on to our interior route. Actually I''m at a pretty good point for questions if we want to stop.
It does bring up a really good point though, while we''re waiting for Cathy to queue in and if people want to ask their next question about so many products and the marketing of so many products one of our other pet peeves is that special I''m sure going to talk about that special lavatory that cost an extra $200 with a goose neck faucet.
Is that what they cost now? Oh my goodness that''s on my next session on restrooms.
My name is Karen. I got a call about two weeks ago from the Indianapolis Motor Speedway talking about Braille signage, what is required? They''re wanting to take current signage and add Braille to it in regards to the type of permanent Braille, you know, may take a Braille.
So in other words, can they put the tape on there, do they have to do permanent signage?
Right.
That''s a good question for the Access Board. I''ll stop here in a second and give Jennifer a chance to harp in if she has something more to add. I don''t know of any requirement that says in an existing structure if you''re trying to make it more accessible, as long as it''s adequate. If it would peel off, if it would not be as readable as a new sign or something like that, I might have a problem with it, but if it''s as good it may be considered equivalent facilitation on an existing structure. I''m not necessarily agreeing with that for new construction. Jennifer?
Well, I would just add on there to really look at the population of people that are going to be using that facility and having familiarity with that facility and the high volume of people coming in there to just put that tape on ther-hat tape does have potential for vandalism and peeling off and that problem. I would probably recommend that they go more towards a sign that the Braille was a structural component of the sign rather than just adding the tape.
Yeah, because maintenance is also an issue under the ADA, under the civil rights law maintenance has to be maintained on accessible features, I would find it pretty easy to argue that they have a problem with their signage if a year down the road that stuff starts peeling or wearing out. And it''s going to in a high use area like that.
Kelly Foley of the Woodrow Wilson rehab. The question is: What suggestions do you have for small businesses or buildings concerning the need for two accessible entrances or exits for safety?
Okay. Are they requiring... well, it''s always a good idea anyway. The ADA accessibility standards address it as 50 percent of your entrances and exits, or a number equal to what''s required by local fire code for egress. So you''re going to need to have the same number as required anyway. I would always suggest it, of course, it''s just a good idea, but a lot of times on the fire stuff your local fire codes are going to be more stringent, and as far as the advocates out there that are looking for the laws to use, fire code can be a very, very powerful tool.
Thank you.
Great. Do you want to pick up with our next priority?
Sure. Priority 3 as it''s stated by the DOJ, we''ve already gotten to the building, parked our car, gotten into the building, we''re obtaining goods and services, another thing to think about is the use of restrooms. In slide number 12 I have a picture that I''m showing of a lavatory set up in a men''s room. There''s a person in the picture who''s using a wheelchair rolling up to it and you see him in the mirror. I will tell everyone as far as what''s wrong with this picture we do have the mirror there and I''ll tell you it''s 40 inches above the floor, so it''s legal to the reflective surface and the counter top height is at 34 and I''ve got 29 inches in knee clearance and I''ve got a lever so that I can operate the sink with a closed fist. Whenever I''m checking lavatories or any kind of operating mechanism I try to operate it with a closed fist and that''s how I can tell it''s accessible or not, that''s my test. Here we have all that in this slide. What''s wrong with this picture, and it''s such an easy thing to fix, is that they haven''t wrapped or insulated the pipes under the sink so that you''re protecting at least the drain pipe, the waste line as they call it in plumbing language and the feed line where the water comes in underneath. The hot and the drain line are the ones that are required to be covered. Usually the kits that you can now buy come with all three pieces and you just wrap all the plumbing and it does a nice job of preventing people from getting any kind of burns, scrapes, bumps and bruises from the plumbing underneath. If you do a skirt like an angled skirt, flat board, if you will, on the front of the apron of the lavatory, you may not have to wrap the pipes because you''re protecting it by that cabinetry that you put in, that panel. But it would have to be angled back so that it still provided enough knee clearance for someone using a wheelchair. In our next slide as we''re rolling through our restrooms at this facility I''ve got my slide of what I call the tacky toilet stall. This was at a conference that a lot of us at the Disability and Business Technical Assistance Centers were at in Las Vegas because it was cheap off season and this tacky bathroom is actually pretty good for accessibility. When people ask me what''s wrong with this picture I tell them it''s the tacky tile, but the bathroom is set up pretty good. I''ll tell you that the toilet is at the accessible height. It''s about 18 and a half, it''s just under the max. It looks a little low in this picture. It''s also a wall mounted toilet versus a floor mounted toilet. You''ll have a couple of three inches difference in your requirements for the size of your stall depending on whether that toilet''s mounted on or water closet as people like to call them is mounted on the wall or on the floor. I mention that because it can be important if someone is squeezed for space on an architectural design, those inches can make a big difference, so that''s something that''s a nuance in the ADAAG but those of you who are designers out there might want to look at. Here we''re also showing our grab bars on the wall that are required. In our next slide you see a nightmare of grab bars in slide 14. This picture shows basically a grab bar salesman gone amiss. It was at a hotel that I was at and it was in the accessible room. In fact it was in a hotel that had that $275,000 revolving door, this was the bathroom in the accessible sleeping room and I think what happened here was they weren''t too sure exactly where to put a particular grab bar so they bought many and threw them everywhere. I couldn''t resist sitting on this toilet grabbing the side bars and yelling up, up and away. It looks like it''s ready to fly at any time. In slide 15, this slide I call the elbow breaker because it''s a picture of a grab bar. It''s actually a towel bar that someone decided would be a grab bar. Unfortunately, it provides about four inches behind it, 4 to 4/12 inches behind it, between the bar and the wall. So what happens is if you''re using this bar to transfer on or off a toilet and your hand slips, your hand goes down behind the bar, you fall on the floor and your elbow can break immediately. This is not allowed under ADAAG, it should be an inch and a half bar with an inch and a half behind the bar. The inch and a half behind the bar is an absolute. We need that so that people cannot have their arm get behind the bar and have that scenario. In slide16, it is another hazard that I''ve seen here lately. Of course we have this new wave happening with toilet paper dispensers and we can''t get people who change our toilet paper to change it on time so instead of firing the people we buy bigger toilet paper dispensers that hold these giant rolls of toilet paper. This slide shows one that''s been mounted just above the grab par in a toilet stall, which also happens to be missing the back grab bar behind the toilet. But I show this slide so you can see what can happen, when you mount one of these especially a model like this one shown in the slide, which has a very sharp, serrated toothy edge to it like you need that to rip toilet paper, that is right in the line of fire for your a.m.as you use the grab bar. This was mounted way too close to the top of the grab bar. It''s supposed to be underneath the grab bar. There''s a consideration in the changes to ADAAG to allow within a certain area above the grab bar, but you would have to maintain space so that you don''t run into this situation where you can, as you use the grab bar actually get cut by one of these units. I can''t imagine, but it''s actually happened to one or two people I know. In slide 17 we''ve finally gotten out of the toilet stall and we''re working our way through the rest of this tacky men''s room. Again we have the tacky tile and this slide is to remind me to talk to you about urinals. We also have to have at least one lowered urinal. The rim at the front of the elongated bowl should be no more than 17 off the floor. I''ve seen them all over at 18 and at 19, it''s something that gets written up on almost every survey I do, I don''t know why, but it is something that we need to incorporate into accessibility. It''s part of the requirements. The next slide is of a drinking fountain and at that point I think I''m going to take a break and take some questions on restrooms. Oh, and I have to talk about our sink yet.
Our $200 extra sink. Mark let''s talk about that toilet paper dispenser again. The big toilet paper dispenser, that doesn''t mean that we can''t have the large toilet paper dispensers in the other stalls of the restroom.
Correct.
We might just want to look at using the smaller roll type dispenser in the accessible stall.
And it depends on the unit you''re buying. There are larger ones made that are still useable. The problem you run into is when you take a giant one and put it underneath the grab bar. Now you''ve got the outlet where the paper comes out so low that it doesn''t meet the requirements for being 19 inches off the floor. And a lot of times these don''t meet a requirement that''s very important to me and that''s the one, Jennifer, that requires the paper to be free flowing and not rip at every seam of the sheets.
Exactly. And you know what, I just found the reason behind that because I''ve been working with several members of the regulatory negotiating committee that have been working on the outdoor developed areas and they have been very specific about the continuous flow of the toilet paper from the dispenser. It wasn''t until a couple weeks ago that I was working with a couple architects from the federal land management agencies that have remote restroom facilities in their parks that I learned that the dispensers that do not allow for the free continuous flow of paper are installed on purpose for the exact reason of avoiding vandalism. So that''s definitely an issue between program issues and accessibility issues that they''re trying to work out that situation. On-line question: Why don''t you create a an accessible bathroom which operates on the voice command of someone, like a talking toilet?
Cool. Actually, there is quite a bit of work being done along those lines, of course it''s all experimental at this point and it''s part of different projects such as smart houses and things like that that are being looked at in regard to doing home modification and things like that. There''s also quite a bit of work being done in the area of portable toilets where you''ve got a toilet for instance I recently saw several in San Francisco where there was a public toilet out on the sidewalk and you pay a quarter and you enter this little oval shaped building that is in itself a restroom and there are all of these automatic features to it that I thought was fairly cool. And there is work being done quite a bit as far as seeing how we can do with voice activated systems in restrooms as well as home stuff. The $200 sink or lavatory that Jennifer is referring to is one that we see all the time on commercial properties and it''s usually the result of one of those well intentioned or not salesmen selling us a unit that they say is "ADA certifiable" and "it meets all the requirements of ADA for accessibility." And it''s one of those sinks you''ve probably all seen them that is the "special sink" for people with disabilities to use and it sticks out off the wall 27 or more inches and has great big pad will handles for the controls and a large goose neck pipe that comes up for the faucet. I''ve actually seen one of those pipes tied into a not once and those handles are used by surgeons when they operate them with their elbows to keep their hands from getting germs on them, but for people with disabilities especially somebody using a wheelchair, to wheel up to that sink you''re so far back now from the wall and the controls, you can''t reach them. There are requirements for lavatories in ADAAG and those sinks that they''re selling as " accessible" sinks are in fact fairly inaccessible so by all means, please hit the ADAAG and get some advice from your local Disability and Business Technical Assistance Center before putting in your order for sinks for your projects.
This is Jean from Montana Independent Living Project. I''ve done a lot of ADA surveys and am sort of at a quandary when you come to doors that have push bars I kind of call them crash bars.
Yeah.
I have been measuring from the edge of that to the jam.
Yeah, you''re not letting it interfere with your clear width right.
Right.
That''s the way to measure it.
I was just talking with a gentleman this morning too that was given a different interpretation that if there''s a panic bar that you would not measure from the start of the panic bar that you would still measure from the start of the door. I think that that''s a really important point to point out that you could in a lot of those standards, get multiple interpretations.
Yeah. I''ve been contradicted a couple of times and ate humble pie and I''d be glad to on that one and you may get more than one interpretation when you call the Department of Justice, but generally if you''re looking at a clear width or a clear space or a maneuvering clearance at a doorway, top to bottom space is what you''re looking at. Whenever we''re looking at accessible routes we''re not only looking at that 36 inch wide accessible route on interior accessible routes that we''re used to looking at. But we also have to think of that whole envelope the 80 inch height to it too. If you can imagine carrying a 3 ft wide door slab through a building, that''s exactly the space you need, 3 ft wide by 80 inches tall. So anywhere that you can carry that door is the area that would be accessible. That''s the kind of envelope to think about when you are thinking about accessibility. That envelope will play into it as well as reach ranges and all of those numbers you will find are repeated through the accessibility standards.
Thanks Mark.
Okay. An existing facility I''ve seen bathrooms with parallel bars.
One of my favorite questions. Go ahead.
And there''s no turn around space but I believe it''s within the ADA guidelines in an existing facility.
Let me explain that to you, you''re talking about alternate stalls. Talking about one or two things. Either they have used an alternate stall in an existing structure saying oh well, it''s infeasible to put in a standard stall in this renovation because we just don''t have room or if we pull the toilet next to it in order to double our stall size now we''ve dropped the building below the number of required toilet fixtures we''re supposed to have according to local plumbing code. What can we do? Let''s use this alternate stall that''s allowed. Unfortunately you''re seeing those alternate stalls in new construction which is totally not allowed. That was not the intent. It was simply to use... and in fact a lot of local building code doesn''t allow that alternate stall. So. . .
Ours does. I believe ours does because this is the building that houses the building inspector.
Oh dear. And you may have more than one issue there under ADA. The alternate stalls that''s a thing to stress over and over and over again with folks is never new construction, its only allowed in existing structures, only allowed where it''s infeasible. And if I''m a citizen under this civil rights law who can prove that it could be done another way who knows, I might have standing for a suit.
Thing is is that it is not accessible for...
Right. You can''t do a side transfer.
Also on an access site I did I saw a flusher on the ground, the toilet flusher.
On the ground?
Yeah, where you could step on it. And I''m wondering if there''s any regulations for where that toilet flusher should be?
Actually there is. The valve is required to be within reach ranges. The control valve is supposed to be on the open side of the toilet rather than the closed side of the wall side or the tight side. It''s supposed to be on the open side that you would approach the toilet from. Like urinals, it''s supposed to be 44 inches or below without looking. If it was something you could step on it''d be tough to work if you were using a power chair or had a mobility disability that didn''t let you use your foot.
Okay. And with the urinals you don''t need any bars around them, do you.
Technically they''re not required. I''ve heard from several people where they were very useful for them. A couple of amputees I know have asked me why the Access Board didn''t require them. No they haven''t been required and I don''t think they have been suggested in the new ADAAG, but then again if you''re talking to a facility that you use all the time or office that you work at and you''re talking about a reasonable accommodation with your boss for the restroom or something like that where it''s specific to a person, you could request it. It''s not necessarily required, but it''s something to talk about maybe.
Okay. Thank you and one more question while I have you about the water fountain which is coming up. You need to have four feet in front of that water fountain? Let''s say if it was a perfectly beautiful water fountain that slanted back and had a 34 inch spout, in order to do a front approach you would need four feet in front of if.
Actually, you''re supposed to have 30 by 48 front or side approach on a fountain.
Oh.
It kind of depends on the set up of the fountain sometimes, as far as how that approach space is going to be addressing the fountain.
Okay. Thank you.
A lot of times the big thing to watch out is like this slide I''ve got coming up where the fountain''s recessed in an alcove and you can''t get to it.
Do you want to take one more question?
Chuck Jones of Hoffman Estates. Is a full length mirror allowed on the backside of a door on a bathroom and if so should it be tempered and how far off the floor should it be?
Hmmm. Let''s see. We have requirements for a mirror where the reflective surface is supposed to be under 40 of course and a lot of times we''ll put in a full length mirror but there''s nothing in ADAAG as far as requirement off the floor for the full length or safety features. There might be something in local code or OSHA.
Okay. Thank you. On-line Question: What would happen to institutions of higher education that didn''t meet regulations of ADA like bathrooms without accessible urinals.
Let''s see. There''s another legal question. It depends, that''s what the Department of Justice likes to say to answer those questions. It depends, you know, if you''re an institution of higher education there''s a couple of different kinds of those you''re either going to fall under Title II or III probably or maybe Section 504 regulations depending on how your money flows. In any of those scenarios you could have responsibility for providing accessible urinals as part of your program accessibility or as part of your accessibility on site of your buildings. On your new construction, absolutely, it''s got to have an accessible urinal, there''s no question. As far as degree of liability, amount of risk. Whew I''m touching that with a ten-foot pole. I would say it''s less liability on a urinal than it is not having an accessible stall, but I didn''t say that either.
Why don''t you go on to our next priority.
Okay. Priority 4. We''ve made it through all of the big 3 I like to call them that we think about when we''re thinking about accessibility and accessing goods and services that are available to us in the community. The fourth priority that DOJ talks about is additional access, and it''s for items that are not required for basic access, necessarily, in the first three priorities, but covers amenities such as water fountains and the public telephones, if they''re provided and other features above and beyond the first three priorities that we talked about. In our slide show I''ve got a slide coming up that is number 18 that has a drinking fountain that''s very inaccessible. This is a particularly bad one because they have got an older style unit that runs almost all the way to the floor so there''s no knee clearance and they have recessed in an alcove so that even if you tried to pull up to it sideways and use that 30 by 48 inch space sideways in front of it you would have to be a Para-Olympian to turn around and jam yourself into the alcove enough to get a drink. There are requirements for drinking fountains. There are in new construction, requirements that half the fountains are at an accessible height for a lower height for people who use wheelchairs or are short in stature and there is the other 50 percent that''s actually required to be higher for other folks who may not be able to bend over because of a disability of a nature of a back or something like that, where they have trouble bending. So the new construction requirements are for a 50/50 set up on the fountains. A lot of times you''ll hear on existing structures people trying to use... I mean, it''s passable but not comfortably accepted by people with disabilities to use the dixie cup dispenser next to a taller fountain or a water cooler is a possibility. In new construction you really need to address it with high/low fountains or two fountains at separate heights and whenever you can in existing structures it''s better to go with a high/low set up or two different fountains. One of the others may be equivalent facilitation, but it may not. You may have a maintenance issue with the dixie cups, for instance. Other things to consider as we''re looking at other things under priority 4 are access to any controls. In slide 19 we see a woman who''s trying to reach for something that''s just a bit out of accessible reach ranges, anything that is operable by the customer or by the general public at the facilities should be operable by everyone. Where we run into problems with this is on things that people don''t want the kids touching and unfortunately you have to find a happy medium between security on the kids and accessibility for everyone. In slide 20 we look at an inaccessible telephone that''s at a very high height for somebody who happens to be using a wheelchair and she''s having trouble reaching the highest operable part of the phone, which is supposed to be at 48 inches or below, to the highest operable part. That usually to me being the little thingy you flip at the top to see if anybody''s left any money in the phone or the coin slot to make your call. Slide 21 is something that gets forgotten an awful lot of times that I need to talk about today and I call this slide Excederin Headache Number 24, I had to pay this guy extra to do this for us. No really this is the slide we got from the Center for Universal Design actually, I believe, demonstrating what happens when a person who''s using a cane to navigate the environment isn''t given a cane detectable warning when approaching something that interferes with that 80 inch overhead space I was talking about for accessibility. Here the person is walking along under a open stairwell and doesn''t see the stairwell coming because he''s using a cane to navigate, the person happens to be low vision or blind and runs head long into the bottom of the stairs because they don''t detect it with a cane. On existing structures you''ll see an easy fix for this a lot of times is having a built in wall underneath there or a planter box section or something like that so that you have a cane detectable barrier or warning for a person who''s walking toward that dangerous position. In slide 22 another thing that''s part of the miscellaneous category in our fourth priority is the maintenance of accessible features. We were talking about that, taking it to another level with the Braille tape at the Indianapolis Speedway before but here''s a real good example in this slide. It shows a ramp that''s snow covered. This came from up state New York where this is a pretty common reality is that you build the ramp to provide access to the store and then you must maintain it as part of the requirements. If you don''t maintain the accessibility it isn''t useable. We have this happen a lot with platform lifts that are used in existing structures to provide access. The entity doesn''t maintain it, they don''t always use it every day and if they don''t get regular use and maintenance a lot of times they won''t work when you go to use them and that''s a problem. So maintenance is a very important part of accessibility. As we wrap up the miscellaneous section the next slide, 23, shows my little Bible, those of you who are religious will forgive me of that. The Code of Federal Regulations, 28 CFR part 36 is the little gray and white book that is available through the Department of Justice or through your Disability and Business Technical Assistance Center and that is the regulation for Title III of the ADA that has the ADAAG incorporated into it as the accessibility standard for the ADA. And that is the book that you should always have, please get one. They are very good glove box size and I carry mine with me wherever I go because I always run into someone who, upon knowing what I do for a living says the ADA says this or that and I can get out my little book and we can go through it together and at the end I give them another one out of my trunk for his very own and from then on he too can answer people''s questions. So with that in mind what other questions do we have that we can go over today. On-line Question: Can you please address house phones, emergency phones, pay phones things of that nature pertaining to heights and how many would be needed. Is it every phone would need to be accessible, certain number by floor, etc?
Okay. And you need to go to your ADAAG and look at your requirements for telephones, because there are several. If you go to the requirements in ADAAG under section 4.1.3 for new construction in paragraph 17 they''ll talk about public telephones. And this may change with the new ADAAG. There maybe more stringent requirements coming along in terms of requirements for TTY units, which are text telephone units with keyboards for talking rather than speaking, and there are more requirements for those as well as accessible phones in the new requirements possibly. Right now one of the givens is for instance any hospital, emergency room, mall has to have a TTY unit if they have a pay phone. There are requirements for banks of phone. You need to have one accessible. There are requirements if you have three or more for a shelf in an outlet for somebody to use a TTY. There''s additional requirements for phones for in the hotels sections for your requirements pertaining to transient lodging and so you really need to look at it according to the entity you''re looking at and then with the book in hand say okay we need to plan for this, this, this and this.
Eric of Blue Water center. We were just having an access team meeting prior to this and one of the things that came up during our access team is, is there a reference guide that would explain some of the definitions, some of the language that disability advocates would use to the layperson like if we go to a hotel and we''re saying do you have a roll in shower do you have a tub bench they wouldn''t know what that means so we could give them that.
Yeah. The best bet for you is to see if your local DBTAC has any ADAAG manuals left. Have you gotten those yet? They are the technical assistance manual that goes along with the ADAAG and kind of explains the "why" behind accessibility and I use that will a lot. What I''ll do is when I''m talking to hotel owner or whoever about accessibility, I''ll quote them out of ADAAG 4.this and 4.that. I''ll tell them by section number what the requirements are but then so that I make sure he really understands it and gets it and that I haven''t missed anything as far as explaining it, I''ll go to the same section in the ADAAG manual and actually read them what''s in the ADAAG manual, which will explain, you know, why that piece of accessibility is there. The big thing with the hotels is getting them to look at the table in ADAAG to make sure they understand that the roll-in showers and the hearing impaired equipment rooms are in addition to the table that points out how many accessible rooms they have to have. Also I was going to tell him dispersement of rooms is important too. If they have got suites. A good flavor of all the accessible kinds of room is required to be accessible not just the numbers.
For those of you not familiar with the technical assistance manual that the Access Board has put together. It has a 1998 publication date I believe and it has a relatively short shelf life as the Access Board continues to work on updating the ADA and Architectural Barriers Act, but it''s a great document because it has all new diagrams and right next to the technical provisions it includes the elaboration from the Access Board on the interpretation and so it''s become one of those documents that many times we go to before we go to ADAAG itself.
It''s based on technical assistance questions that the Access Board got over the years and has maintained a database and kept track of questions and issues that have come up and that''s what they used as folder to write this book. And so it''s very, very helpful, the ADAAG manual. You can call (800) 949-4232 for the DBTAC and hopefully your local one will still have some left. Like Jennifer says, they were published in limited quantity because they knew the new ADAAG was coming along. The principals will remain the same, the numbers will change between the two ADAAGs, the old one and new one. Just as we were all getting used to 4. this and 4. that they''re going to change the numbering system to reflect what building officials use in building code which is a little bit different. So we''ll have to get used to that. But the principals will be the same and this ADAAG manual has really been wonderful for me as someone who has to explain the why behind accessibility.
Regarding emergency egress from upper floors can you please address what is required?
Thought I was going to get to skate on that one. On egress from higher floors, what is required and what is recommended are two very different things. As far as I''m concerned, not enough is required. They don''t require areas of rescue or refuge, depending on what the phrase de jour is for today but basically areas of rescue assistance are not required in fully monitored sprinklered building. That doesn''t mean if you''ve got a sprinklered building that just has sprinklers all around it that you don''t have to have an area of refuge, the system is supposed to be a monitored system so in other words if your building goes on fire the fire department knows about it and if you have one of those type of sprinkler systems in a big commercial building you are excused from areas of refuge. You''re also excused in areas of refuge on alterations. Egress is much more thoroughly addressed in fire code and again, before I think I referenced to using your fire officials as buddies because they take their fire code very, very seriously and the ADA in more than one place tells you to refer to your local fire marshals or authorities for advice for things such as evacuating buildings and things like that. I''m sorry to throw more gray area on it, but there isn''t a great answer that satisfies me because I don''t think it does enough. The requirements are a lot less than what I think could be done. They are a lot less than what you''ll get if you include the fire marshal in the conversation.
My name is Cathy and I''m calling from Department of Human Services. I have a question regarding family assist restrooms. If you see at airports and other places, are they required in the new ADAAG or not?
They are not required yet. There''s talk in new plumbing code and building code about requiring them and possibly rather down the road in ADAAG but I''m saying today they aren''t required. In places like airports and huge places, concert halls, anyplace that has a lot of bathrooms they''re becoming very, very popular and for good reason. There are people with personal assistance of the opposite sex these days or family members are using other family members of the opposite sex that they don''t want to take into the public bathroom. It''s just an easier set up for many different people with children and so it''s really becoming popular. They aren''t a requirement yet that I know of, but I can tell you I can see a trend towards family restrooms because they''re really popular where they have been used.
Mark we have about time for about one or two additional questions and then some closing comments from you.
Okay.
Rob of ADA technical assistance. Under slide 8 under curb ramps 4.7, I''ve looked all through the ADAAG here and I see nothing in the ADAAG that requires a 48 inch long level landing at the top of a curb ramp. I know it''s recommended, of course, but nothing close to it. The only thing I have here is where the space at the top is less than 48 inches, side flares must have a maximum slope of one and 12.
Okay. And I have to read up on it to talk through it with you. If so, I stand corrected. If not we can chat and my e-mail is on this slide show and please, anything that I''ve brought up today that we need to go into more, I''m happy to go back and forth with with folks on e-mail. That was a really important piece of the stuff we were working on at the PROWAC committee. That and things like the big arguments over detectable warnings and other bridges we''ve needed to cross. So I may have been referring to some of the stuff we did in PROWAC but I''ll go back and hit the books. Thank you. Robin Jones: I think the thing that needs to be looked at you still need to maintain your accessible path of travel with no greater than 2 percent cross slope. Take away from the curb ramp coming from the access aisle but looking at it from the context of that being a perpendicular path of travel, you no longer have your minimum clear space that is minimum of 2 percent cross slope there for a accessible path across. Not using the curb ramp but the actual path itself in that particular slide 7 that would be problematic there.
He was talking about that telephone pole in the middle of the side flare. And we were talking about the landing in the one before that tool, you''re right. It''s all a matter of maneuvering and being able to set yourself up for using that intersection or curb ramp and that''s where these flat areas come into play and are very, very important, both at the top and in the new guidelines you''ll see requirements for flat landings at the bottom and a lot more specifics on curb ramps in difficult positions where you use something like bringing a sidewalk down to the level of the street on both sides of the corner before you ever get there. Then having the whole corner on the same level as the street with something to block trucks from running people over. But it''s one way to do a curb ramp to the street where you haven''t got room for a level landing necessarily right on the corner for a perpendicular curb ramp.
Mark, we''re coming up on the close of our session today so I''ll turn it back to you for final closing comments. I think one of the things though that the last couple of questions really illustrate and especially for all of us that have been working with the standards for so long, that no one should every be expected to remember those standards right off the top of their head. But, you know, to really know that they exist and where to go for clarification like the disability business technical assistance centers, the Access Board and DOJ and so forth. For those of you again I would really highly recommend the technical assistance manual for ADAAG from the Access Board.
Well, I appreciate the bail, however, I agree and I would never profess to be a walking fountain of information on statistics without my little gray and white book with me that I mentioned before. And whenever I''m on a site I''m using a checklist for that very reason because nobody can remember everything or pull it out of their hat on a seconds notice. So the checklist and the manuals are our greatest resource for protecting our own credibility.
Well, we would like to thank you so much for taking time out of your day to spend with us. This is a topic that we could spend days on and if there are those of you out there that are standard geeks like Mark, Robin and I, we could just talk about this for days but we hope that we addressed some of the issues that are out there, some of the common problems that we often see and I''m sure that there are a lot of you out there that have additional questions. Please do call your regional Disability and Business Technical Assistance Center, ask to find out if they have an additional technical assistance manual for ADAAG, if they still have those in stock and also ask for their most recent list of publications because there are several additional guidance materials that were developed under grants and so forth that you might want to keep as part of your desktop library. So Mark, thanks for joining us today.
My pleasure. Everyone has my e-mail it''s ADAmarkD@aol.com.
We hope to have all of you back for our next session. Next week February 27th we have another special 90-minute session on the ABCs of the Workforce Investment Act and the Work Incentives Improvement Act. We have Ken McGill from the Social Security Administration and Tom Dillisio from the Department of Labor talking about the regulations of those two pieces of legislation. In March we have Kim McDonald Wilson from the Center for Psychiatric Rehab at Boston University joining us to talk about accommodating employees with psychiatric disabilities. So we''d like to thank all of you for joining us today. If you have additional questions again please feel free to contact your regional Disability and Business Technical Assistance Center at (800) 949-4232.