Ladies and gentlemen, thank you for standing by and welcome to the Americans with Disabilities Act (ADA) Audio conference titled "Permanent Rooms and Spaces: Accessible Signage." All participants are in a listen-only mode. Later we will be having a question and answer session, and at that time if you would like to ask a question, you may do so by pressing one on your touch-tone phone. As a reminder, this conference is being recorded today, June 20, 2006. I would like to turn the conference over to Robin Jones, Director of Great Lakes ADA.
Thank you. Good morning and good afternoon to those of you in different parts of the country. Thank you for joining us on this June day for our session related to accessible signage. In a minute I will get to the matters of the day and introduce our speaker, but first I will start by saying you are participating in a joint venture between the 10 regional Business and Disability Technical Assistance Centers, also known as ADA and Accessible Information Technology (IT) centers for this audio conference program, part of a 12-month series of programs on various topics under the ADA. This is the second topic in the architectural series this year. Last month we addressed issues related to playgrounds, and this month we are going to be addressing issues related to accessible signage. Individuals are connecting a variety of ways today, we have individuals who are connecting with us by telephone, individuals using streaming text on the Internet, and individuals using streaming audio. A transcript of this program will be available within 10 business days of its conclusion, posted on the website at www.ada-audio.org. Also, an audio recording will be available sooner than that, within four or five business days on the same site. If you are interested in recalling or referring it to someone, that would be one way to do that. We encourage you to fill out the evaluation which you hopefully downloaded from the site. It helps us get information about the quality of the program, what works, doesn''t work. We are also always soliciting ideas for additional sessions. Be sure you get that information to us. We will wrap up the 12-month series in a couple of months and be looking towards the future, and want to be sure we are meeting the needs of people. Today we are offering AIA credits as well as CRC credits for individuals who are interested in taking advantage of those designations, please make sure you submit the appropriate information, if you have questions ask. If you are at an individual site, the information has been provided to site coordinators, on the instruction sheets towards the bottom. You can always contact our office for further information or if you have questions. Contact Claudia Diaz at 312-413-9319 if you have questions about CRC or AIA credits. Without further adieu I will move forward and introduce the speaker. Mark has joined us in the past. And let me introduce Mark Derry, from the Eastlake, Derry and Associates in the eastern part of the U.S., Morgantown, West Virginia. He is well-known to people within the Disability and Technical Assistance arena as he did work as a technical assistance specialist and trainer for the Mid-Atlantic ADA and Accessible IT Center for a period of a few years, then started his own firm of Eastlake, Derry and Associates, specializing in accessibility, universal design, and ADA consultation and training. More recently Mark, and he may talk about it, some of the things he found in the work he''s doing for a number of companies, corporations, and communities, signage is a huge issue: The availability of accessible signage, the understanding of accessible signage, so he has also recently started a signage company, where he is a distributor of accessible signage, so that is another aspect of his business. We will give information about Mark towards the end of the program so you can contact him or his business if you are interested. Mark has worked as an architectural barriers consultant for Action For Independence, which is an independent living center in New York state, and served on the state access code board, and co-founded the committee in New York, so after the ADA obviously there was a great deal of need in that area. He also hosted a monthly radio talk show on disability, called "Making Waves," and served on the assistive technology advisory board at Westchester Institute for Human Development. He is active at state, local and national levels and is very active in advocacy issues. He has worked and been involved in transportation, and has received training from the Department of Justice and the U.S. Transportation Barriers Access Board, also known as the Access Board. He has most recently served as a member of the Public Rights of Way Committee for the Access Board, which is in the process of developing standards for accessibility of our public rights of way, which we hope at some point will be released, but under this current administration one never knows. He has also served on the national governing board of National Council on Independent Living. He has a lot of experience in a variety of different areas. I think you will find that the information he has to share with us today is very practical for hands-on and based on experiences in working with entities towards compliance in this arena. Without further adieu, I will turn the session over to Mark.
Thanks, Robin, I thought you had the short bio, thanks everybody for hanging in there for that. You know a lot about me. Let me talk a little bit with you about signage today. As Robin said, in my travels as an ADA surveyor one thing we see all the time, surveying for ADA accessibility, is a signage issue where signage is provided that doesn''t have one or more characteristics for accessible signage or not provided at all. In the few places in Americans with Disabilities Act Accessibility Guidelines (ADAAG) where it says you have to have them, so we are going over those kinds of issues on this call. Signs are how we find our way around, especially true if you are in a new or unfamiliar environment. Think about the last time driving in a new city. Desperately searching for the sign that matched the freeway exit you were looking for or rushing through the airport, looking at directional signage, telling you the direction to your gate, or more importantly, the location of the nearest restrooms. Requirements for accessibility in architectural signage, where provided, have requirements covered under the Americans with Disabilities Act of 1990, the ADA, which requires accessible features wherever signage is provided in all public accommodations, state and local government facilities, and other covered entities, to be in compliance with ADA accessibility guidelines referenced by the ADA. There are also requirements that I will briefly point to here and there, in building codes. The international building code references its accessibility standards, the International Code Council (ICC) American National Standards Institute (ANSI) 17 .1 document, the standard for accessibility under building codes and it has requirements for accessible signage, where it''s provided, in buildings as well. It''s an issue we see on our surveys, it''s an issue where accessible architectural signage when properly placed greatly aids in the way-finding ability of people in our community who are blind or low vision. The tactile features of these signs, along with their required Braille can be easily to felt and read by someone with a visual disability. Given the right information and directions on these signs, a person has a good start on navigating a facility or building. With the new manufacturing technologies in the signage industry the bar of standards has been raised recently. The new ADA Accessibility Guidelines, call for a domed or rounded shape for Braille, for instance, for all accessible signage, that wasn''t required before. Some Braille out there has flat tops, it''s now required to be round tops. The reason for that is your fingers can slide across those Braille dots a lot easier if they are rounded tops versus flat. If you get a chance, try this. You see Braille signs with flat tops, run your fingers across it and you feel all the edges as your fingers are going across the Braille. Already in the ICC ANSI 117, which is the applicable standard in most states'' model building codes, this has the same requirement. There''s also a requirement for Braille dots to have a specific height, space, specific proportions and a minimum of 3/8 from tactile characters and sign borders. The overall dimensions that the sign vendors, manufacturers, need to know when they are putting together accessible signage. We need to know these requirements when we are checking accessible signage and giving people advice on accessible signage. I will go through where to find the information, relay some of it to you as we go along and share some of the issues that come up as common error and omissions as we move through the call. We will look at current ADAAG requirements for permanent room and spaces, and share some info regarding the building code requirements; we will also touch on other signs that are referred to in the ADAAG, but concentrate on permanent room and spaces today. That''s where the questions come up all the time and where the most confusing requirements fall. With that, I am going to start talking about where are they required? We''ll take a break here in a few minutes, and see if anybody has questions as we roll into it. I don''t want to get too far along, but I will share where they are required. There are misconceptions that people believe that the ADA requires signs in every room. That''s not true. The signage has requirements for how it''s made up when it''s provided. There are only a few places in ADAAG, and I''m going to go over those now, where they are actually required. How would we define signage? In ADAAG 3.5, current ADAAG, signage in definitions is displayed verbal, symbolic, pictorial and tactile information. Talking about permanent rooms and spaces, there are signs typically placed at doorways, because doorways provide a tactile cue in locating the signs. If you have the ability to, or the opportunity, to tour a facility with a person with a visual disability who reads the raised letters or Braille, you will learn a lot. As you watch them go through the building, the doors are a cue for finding the signs. If a person is going down the hallway and they locate the door, they will locate the door first, they will locate the latch, where the lever handle is to open the door, and then probably reach out at about 60 inches above the floor on the wall on the latch side of the door looking for the sign. That door gives them a signal; this is a room, permanent room and space. If this place has signs it should be in this place each time. We are going to talk about placing our signs, but the door is a cue, there''s cues throughout the building for way-finding, and those doors are one of the major cues. The requirements for raised characters also apply to a room''s function, thus designation that''s not likely to change over time. Examples include signs labeling restrooms, exits, rooms and floors by number, or letter. Current ADAAG scoping, the scoping being the part of the ADAAG that tells us where we have to a apply these requirements, I ran through my ADAAG last night, as I was going through my last minute preparations, I found several sections that reference signage that I want to share with you. 4.1.2 Paragraph 7, accessible sites in exterior facilities, references building signage, talks about permanent rooms and spaces, informational directional signage, and elements and spaces that need to be identified by the international symbol of accessibility, the ISA symbol. A) Parking is one place that''s required. You need to have the ISA symbol on your parking spaces. B) Passenger loading zones need to be identified with the international so that that area is identified as the drop-off and pickup area of a facility if provided. C) Accessible entrances when all entrances are not accessible. D) Accessible toilet and bathing facilities when not all are accessible. As an example of when not all are accessible, at 4.1.6, alterations, you know when you are doing alterations you are supposed to follow new construction, come as close as you can to new construction requirements, but in paragraph 3 in 4.1.6, alterations they are talking about in 3e(iii), when existing toilet or bathing facilities are being altered and not made accessible, signage complying with 4.30.1, .2, .3, .5, .7, shall be provided indicating the location of the nearest accessible toilet or bathing facility, and I will share the requirements under 4.30 in a few minutes about what does it have to look like. That''s one place in ADAAG. But as you cruise through ADAAG, you see several other places signage is mentioned, as a requirement. 4.1.3, 8d talks about entrances that are not accessible shall have directional signage which indicates the location of the nearest accessible entrance. 4.1.3 9 talks about areas of rescue assistance where provided, they reference 4.3.11 paragraph 5 that requires identification of signage. We see that missing all the time, areas of rescue assistance. Then at 4.1.3 16, building signage, brings this again to permanent rooms and spaces being one piece and directional or informational signs, providing direction to or information about functional spaces of the building, referenced in B of 4.1.3 16, building signage. So you have A) permanent room and spaces as one kind of sign, and B) direction to or information about functional spaces as another kind of sign. Two different signs, one marking permanent room and spaces, definitely needs the tactile and Braille on the sign as well as the contrasting colors and other, not glossy finish, matte finish, things we will talk about in a minute in section 4.30. It''s not like b, which is an informational sign, you''ll see up on a wall with an arrow indicating the function of the space, direction to go to someplace, accessible route is a directional sign, and that''s not required to have the raised letters and Braille, but has to have contrasting colors and other things we find in 4.30 required here. In A they say the permanent rooms and spaces have to meet 4.30.1, 4, 5 and 6, we will talk about those in a minute; and B has to meet 4.30.1, 2, 3 4, and 5. The exception is signs that are temporary, like menus or building directories. They are not required to comply with these requirements, because they don''t fit into A or B. Then there''s other sections you see through ADAAG, like 4.1.3 17, telephones and the ones that have to have volume controls, they require a small sign on there that includes the symbol of accessible for the volume control phone, in 4.30.7. They also have plenty of requirements on elevators under 2 separate sections. 4.10 talks about raised and Braille characters on entrances, 4.10.12 talks to us about the elevator and car controls. So there are several places throughout ADAAG, as you flip through the book and I unfortunately spend a lot of time doing that where you see the requirements spelled out for signage, but they always come back to "where provided," except for those four areas: parking, passenger loading zones, accessible entrances when not all are accessible, and toilet and bathing facilities when not all are accessible. Your rule is, like many places in ADAAG, not so much this, this, and this sign is required. More, it is where provided these signs shall meet these requirements. So if you mark all your rooms in your building, have a hospital site, you mark all of your patient rooms, those are permanent rooms and spaces, and they need accessible signage. If you have overhead signs in the hospital pointing out the direction somewhere to a wing, that sign needs to meet requirements in ADAAG also, but not the same requirement as permanent rooms and spaces requiring the tactile and Braille requirements. So with that, I would like to, as soon as we take a few questions on the where are they required, and the scoping, I would like to take a few questions, then talk about 4.30 signage in ADAAG, and what the requirements are currently. I also, as we go through those want to highlight a little bit as far as the relationship to the new ADAAG, and the building code. So with that, if we have questions, I would love to address those now.
Ladies and gentlemen, we will now begin the question and answer session. If you have a question please press 1 on the telephone. If your question has been answered and you wish to withdraw the request, you may do so by pressing the pound key. Questions will be answered in the order they are received. One moment please for the first question. Your first question is from Ken. Please go ahead.
Thanks very much. Mark, on elevator control panels, often, the low vision people I am confronted with, two control panels in the car, both of them are low, and when the panel is low, it is difficult to read the Braille on it because they have to get the heel of their hand underneath and for somebody like me, I have to get down in a knee-bend to get close to it. How can we educate people to, if they put two control panels, there several categories of disabled people that need to use the panels?
Yes, great point. I am reminded of drinking fountains, totally unrelated, but we had that rule applied. A lot of people can''t use the lower fountain that''s "accessible". They can''t bend over that far to get a drink of water at 36 inches, so we have that 50% rule, leaving half on the floor at a higher height, the standard height, ends up being about 42 inches. On elevator signage, again, they put out the requirements, talked about standard reach ranges that met the general population requirements, but they don''t work for everybody. My advice would be to not wait for comment period. Normally I would say when the new ADAAG comes, for how many years have we worked on it, as the comment period comes out, these are the things we need to write to the Access Board, they really listen to our suggestions and comments. I would go ahead and write in that comment to the Access Board, because who knows, it might not be too late, or write to the Department of Justice, and ask when they are putting out the new ADAAG, and suggest they do that, if they''ve got two panels, split the heights. I think that''s a great idea.
Our next question is from Rick Edwards.
Did I correctly understand you when you said that signage, if it was marked, not necessarily a permanent room it does not need to be accessible, that''s contrary to what I understood.
Generally the room is going to be a permanent room or space that won''t change. A lot of times when I talk, some folks, especially in hospital environment, have tried to forego certain signs with raised characters and Braille because they said they were describing the room or a room that could change uses, or calling the room by the person who was in it or function of the room, it wasn''t permanent, could change, didn''t have to provide Braille. To me it was a way of saving a few bucks on Braille signs, because the Braille is a more expensive sign. If you are able to get a copy of the Access Board''s ADAAG manual, the Technical Assistance manual they put out in, I think it was 1994, there''s good verbage that talks about permanent rooms and spaces. I used some of it in my intro. You really need to drive home permanent room and space to people, don''t let them tell you it''s a temporary room and slide through the loophole.
You say permanent designated room would be, for example in a conference room, conference room C, that would be generally permanent?
Oh yeah. Conference room C would be permanent, with raised letters and Braille below, actually below is specified in later standards. Current ADAAG doesn''t say specifically where the Braille goes. Then typically have a slider to change for whoever the client is in the conference room. That''s how you meet the best of both worlds. If a person is there for a conference who happens to be blind or low vision, they won''t find it unless you have it marked with raised letters and Braille. We had conferences where we added Braille chips to the signs to make them more accessible. If they had raised letters but were missing Braille, rather than changing the whole sign we provided Braille chips, the chips being better than the old Braille tape. That used to work, too. Does that answer your question?
Yeah, thank you
Next question from Ilene. Please go ahead.
Hi, can you hear me?
Okay. I may be jumping ahead, but I have a question on stairwells. Is there any kind of guidance you can give me on numbering stairwells so somebody who is blind or visually impaired can know what level they are on? I would also like to get guidance on required exits and when you have multiple buildings in a complex, how would you go about identifying the individual building, where would you suggest we identify it?
I would suggest the signage is up on top of the building, big signage on the side of the building, designated requirements. However, the best way to provide good way-finding is to have signage at entrance door that meets the signage requirement for permanent rooms and spaces with the raised characters and Braille. Then you are marking the building. Unfortunately it doesn''t give you good clues from far away if you are relying on Braille and tactile for way-finding, but if you can go by sight way-finding, get yourself or a consumer to reach the building by way-finding according to site, I don''t mean s-i-g-h-t, I mean s-i-t-e. Once finding the building, the door and the sign will identify the building. Give me the first question again?
First question had to do with stairwells.
Okay. There''s not a requirement to mark the stairwells in ADAAG. There may very well be for the building designer under life safety requirements. The international building code around 101. There is in ADAAG, if signs in the stairwells are provided, they need to be tactile. And I just recently, two weeks ago the Access Board talked about that b/c it came up about something else we are doing. So as they do mark the stairwells, they need to be tactile.
Okay, and the last one had to do with required exits.
Can you send me that one in an e-mail? At ADAMarkD@aol.com, that''s a little more complicated and I want to go through it with you. I need more specifics.
OK thank you.
Your next question is from Jim, please go ahead.
Hi, this is Ilene; I am talking about the overhead signs. I know there are some that have transmitter receiver, where the visually impaired person would have a receiver, especially in large areas like airports, etc. so they know what direction to go in.
Yeah they''ve done it for tours and things to in places like San Francisco.
Right. And how is that? Is that part of an ADAAG or?
No, it is actually pro-active stuff going on in the community. We were looking at a lot of it through the public rights of way committee at the Access Board and there''s some great stuff on the Access Board''s website, access-board.gov. Under the Public Rights of Way Access Advisory Committee, PROWAAC links you will find documents on accessible pedestrian signals for instance. Those documents are great, and a lot of that stuff we saw in our meetings around the country, where venues had come up with that system of receivers and transmitters, and I think it''s wonderful. There isn''t a requirement in ADAAG yet.
That''s something that may come up, I work with visually impaired people are the time and that question comes up a lot about arenas and other large venues, directionals for crossing the street, etc.
If you send a letter to the Access Board, they would like to hear from you. Mention things that aren''t part of the research process now, they may take an interest in it like they have with acoustics and other things.
Your next question is from Diana, please go ahead.
At what point must a building be retro-fitted? If an owner says well my building pre-dates blah blah blah and I don''t have to do that. What''s the answer on that?
Well, he is probably going to tell you, I am grandfathered, this doesn''t apply. You can tell him the ADA was adopted, it doesn''t have grandparents; it''s an orphan so the grandfather clause doesn''t apply. But there isn''t a trigger for signage. There''s two places where it''s mentioned in readily achievable barrier removal, in 36.304 under readily achievable barrier removal they talk about, paragraph 6 and 18, two different things, almost a slam-dunk that it''s readily achievable barrier removal, elevator, raised markings under paragraph 6 and designated parking under paragraph 18 for readily achievable barrier removal. Beyond that, they leave it in the gray area of readily achievable barrier removal, what can the owner afford? And unfortunately, I mean the signs that are required, for instance restrooms, parking, loading zones if you''ve got them, those should be done, as far as readily achievable barrier removal, but there will not be a trigger to make him mark the permanent rooms and spaces. Once he does, then it triggers the requirements.
Your next question is from Diana, please go ahead.
I have a question concerning an art museum. They have, as permanent doorways, sliding glass doors. On the latch side of that door is where the sign should go? Not describing the room, but identifying it as a permanent room, but this art museum wants to put in a huge piece of artwork that would encroach into the space where the sign would go. Where should they put the sign?
Where they are putting the artwork. In building code and new ADAAG, there''s been a range attached to the mounting height of signage. In current ADAAG it''s 60 inches on center, absolute, it''s always been a problem. Its like an18-inch line on a toilet, you never make it. Signs are always off an inch. The 60 inches has been a problem. They attached a range to it in the new ADAAG, 48 to 60, depending on where you measure it and in ANSI for building code it''s 48 to 60. I would work with the numbers; see if you can fit it in the 48 to 60 range. Chances are, if someone raises an issue of it not being 60 inches on center, you can point them to the new ADAAG, tell them its going to be out in the spring, and point to building code, say you met both of these, and you shouldn''t have an issue. Maybe that will work with the artwork. But it has to go where they say it has to go.
OK, you want to keep going, Mark?
Yes, I need to talk a little more.
Great, then we''ll take questions again.
Terrific. OK, let''s get back into what I prepared for. Let''s get into 4.30, signage. Before, when I was talking about the scoping requirements, I referred to 4.1.3, paragraph 16 in ADAAG, building signage, to this paragraph that splits it between permanent rooms and spaces, direction to or about functional spaces, types of signs. We''ll call them directional or information signs. The permanent rooms and spaces references 4.30 and several sections, 1, 3, 4, 5 and 6. One is just general; it says all signage in scoping needs to comply with 4.30. Then beyond that you move into characteristics of the signage. 4.30.2 is character proportion, 4.30.3 is character height, 4.30.4 covers raised and Braille characters and pictorial signs, 4.30.5 is finishing contrast, and 4.30.6 covers mounting location and height. And so, under A) Building signage for permanent rooms and spaces, it has to meet the requirements for 4.30.1, 3, 4, 5, and 6. It will be general, but beyond that raised Braille characters it has to have, finishing contrast, matte finish, non-glare contrast. 4.30.6 is mounting location and height which we were just discussing. Under directional and informational signs that section says it has to meet 4.30.1, 3, 4, and 5, so it has to meet, directional and information signage only has to meet requirements for proportion, for character height, and for the finish and the contrast. Raised Braille characters don''t apply and mounting location and height is going to be, will be not the same as it would as referenced in 6 when they talk about the 60 inches on center. Let''s talk about the requirements a little bit. Letters and numerals, I provided a few slides for this call, and I will I will go through them; I numbered them 1 through 19. I will, refer to them as we go along. Number 2, the photo shows several kinds of sign pieces, raised letters, background the raised letters go on, sections of Braille, raised dots or domes that we are used to seeing and recognizing as Braille characters, all shown in the photo. Accessible signs are available in many styles and you will see a few of those in the slides provided. The third slide shows us a room sign, room 6101, with a slide bar underneath it showing the room is in use or not, and then a name plate for the room saying it''s the Rock Creek Room. It''s hard to see here, but underneath the 6101, which is raised lettering at the top of the sign, there''s Braille, in blue, hard to see under the 6101, but there is Braille under that room number. What they have done here is they have marked the permanent room or space, made sure it has raised and Braille characters, and then the room name could change, and they have left that in standard lettering without it being raised because the room number is going to stay the same. That''s the permanent piece. In this kind of environment, this is a hospital sign or a conference room sign, like we were discussing earlier. They marked the room signs, number signs, because the names are liable to change, but the room numbers won''t. On the fourth slide, here we reference on the ADA and ADA Accessibility Guidelines figure 703.2.5, height of raised characters. That is the figure shown in this slide. It is a sign for library. Shows a close-up of a couple of the letters, the "i" being the letter we are measuring. The height of the raised characters is 5/8 and 2 inches in new ADAAG, the minimum being 5/8 of an inch, the same as in current ADAAG. Letter and numerals are supposed to be raised 1/32nd of an inch, minimum. They should be uppercase, sans-serif or simple serif type, and should be accompanied by Grade 2 Braille. Grade 2 Braille is, if you ever wondered what Grade 2 Braille is, is contracted Braille with over 200 contracted or abbreviated words that are part of the Braille. So the Grade 2 Braille needs to be included and raised characters under ADAAG shall be at least 5/8 inches high, but no more than 2 inches. Pictograms need to be accompanied by equivalent verbal description directly below the pictogram. The border dimension of the pictogram shall be at least six inches minimum in height. The next talks about the depth of 1/32 inch and I''ve got a photo of one of our signs with raised letters, and Braille, its a restroom sign. From the view you have of the picture I hope you get the idea the 1/32 is raised off the background of the sign, and that''s the minimum thickness for raised letters. In the next slide I show another room sign, meeting requirements under current ADAAG and new ADAAG and building code. The requirements say you can have separate visual versus tactile characters. So the sign in the number six slide is a room sign for room 327. The top 327 is very contrasting, big letters, easy to read if you have 20/20 vision, and below that are tactile characters, and below that Braille. You will see 327 is redundant, and this is allowed under new ADAAG and current building code, and you will see that the 327 in the slide at the bottom, the tactile, is raised 1/32 of an inch, but is not painted, is not colored, is not contrasting. The contrasting is covered by the visual 327 above it, in the top part of the sign. And so this has become a popular option the sign companies are offering, where there''s a visual sign at the top with certain information, the permanent room or space is marked not only with that visual but with a tactile and Braille marking as well. The character proportion is addressed in ADAAG as well. Height must be sized using the 5/8, but the character proportion if you have very thick or thin characters, character strokes they can be difficult to read. While ADAAG doesn''t specify the character to use in calculating proportions in current ADAAG, it has been recommended that the "I" be used. It is referenced as the I and O being used for determining character proportions and those are covered in 4.30 2 and 3 in current ADAAG and in 703.2, .4, .5 in new ADAAG as well as .6 for stroke thickness in new ADAAG. The position of the Braille, the slide 7 I provided is a permanent room or space, the men''s room. This particular one has a man''s sign where the letters are raised, contrasting to background, and dark blue on light white background, with Braille beneath the word, and spelling out men. The position of the Braille wasn''t particularly called out for in current ADAAG, I don''t believe, but it is in future ADAAG and building code, as being below the tactile letters. Some surveys we''ve done you had to really look around for where they put it. Over and over when I give advice on signage, I tell them that uniformity is really key. Especially on things like the ranges given in the new standards, the 48 to 60, you can pick a number between 48 and 60, but when you do, you should make that the uniform height throughout the building. If you think back to the example I gave before where the person is making their way through a building, they are finding a door, finding a latch, going to 60 inches, and finding the sign. If the sign is stationed at 55 inches on all the signs, if they are all at 55 the person will reach out, hit it each time because of the uniformity throughout the building. So having some uniformity in heights of signs, as well as where the Braille is put is very important in way finding. And having it now, it has to be below the tactile characters is a good thing. It''ll always be in the same place for way finding. The next slide we''ve got shows a standard height, when we''re talking about height again, the first image is of a sign, number 389 I believe it is, an isolation room in a hospital we were surveying. We are measuring it to determine if its 60 inches on center above the floor. And we have discussed that point. The following slide shows figure 703.4 out of the ADA Architectural Barriers Act (ABA) accessibility guidelines, and shows height of tactile characters above finished floor or ground as being at range, 48 to 60. Bear in mind the 48 that, measuring the 48 to 60 is going to reference the bottom of the highest text or the top of the Braille, I believe, on the new ADAAG. And so the 60 inches goes away and we''re given a range, but do use uniformity in determining where to put signs throughout the building. Because that will be very important to folk''s ability to do good way-finding. The other issues on location, I demonstrate in the next slide, slide 11. Figure 703.4.2 out of the ADA ABA accessibility guidelines, the location of tactile signs at doors. The mounting location and height, when addressed in current ADAAG, under 4.30.6, talked about someone being able to approach the door, within 3 inches without getting hit by the door when it''s swung open, good description, but more gray area to interpret. The ICC ANSI, the 98 version started clarifying and continued through the 03 version and ADAAG guidelines, that you need an 18-inch box, shown in the slide, centered on the tactile characters of the sign, that 18-inch box is imaginary, somebody standing clear of the swing of the door, for obvious reasons. Somebody close to the sign because they happen to be low vision, needs to get close to the sign to read the letters or touch the letters or Braille, they have a clear area to be in, where they are not being hit by the door as it''s swung open. Again, latch side of door, 48 to 60 or 60 under current ADAAG, and 18-inch square imaginary square drawn on the floor in front of the sign is what we are going for. We didn''t have that much clarity before. Next slide that I reference has a sign in it called hospitality gift shop. And down below at the bottom there is a brown strip. The tan strip in the middle with brown strips on top and bottom, the bottom one has gift shop with tactile letters and Braille underneath, again not contrasting because the contrast is provided, the dark on light, is provided above in the hospitality gift shop lettering, and below is tactile lettering with raised lettering, 1/32 inch minimum and Braille directly below the tactile letters. The next slide is of a men''s room sign that shows the international symbol of accessibility. The ISA symbol is one of several that are referenced, in 4.30.7, symbols of accessibility. You are going to find them in the new ADAAG and in building code. There are several symbols that are common or that are used. That sign shows the international symbol of accessibility with a men''s room pictorial and "men" with raised letters and Braille at the bottom. This sign would be used to indicate a men''s restroom, and it would be used in a building where maybe we don''t have completely accessible restrooms, and this one would designate the accessible restroom because it has the ISA symbol on it. And there would be other restrooms and you would need signage for those restrooms indicating where this one is located. The next slide, we talk about the pictogram field being a minimum of six inches. Again, this slide is taken from the new ADAAG, 703.6.1. And in the new ADAAG there is a difference in that the pictogram field is supposed to be separate from your tactile letters, not allowed to encroach in the 6-inch minimum field. So that''s what we are showing here is that the men''s room pictogram is in its own 6-inch field and the Braille is below it. The next slide is figure 703.7.2.1, the ISA symbol. We talk about the ISA symbol, we talk about it all the time, it stands for international symbol of accessibility. And those slides show that symbol we all have known and gotten used to that symbol. The next shows the international symbol for TTY. The slide following that shows the symbol used for the volume control on volume control telephones; it''s shown in the new ADAAG in 703.7.2.3. In the existing ADAAG you will find those symbols in 430.7. The next slide is figure 703.7.2.4, the international symbol of access for hearing loss. The final slide is visual character height. I will get to that in a minute; I will talk about that more. The last slide, when it talks about height, I gave us this slide to look at to clarify a point. Heights of the visual characters, this applies to not only the heights that we''re talking about on permanent room and spaces, but there has been confusion in the past about overhead signs, information signs that fall under the contrasting colors, directional and informational requirements, not necessarily tactile and Braille requirements, but what height and what height letters to use has been a sticking point between old ADAAG and future ADAAG. To provide clarity, current ADAAG, it''s vague in that it says if you have a sign hanging in a corridor overhead has to be above 80 inches or it''s a protruding object. Anything that protrudes into the path below 80 inches that''s not cane detectible, you can bang your head on it. It''s a protruding object. The signs referenced in current ADAAG, they give the height of 80 inches, over 80 inches the letters need to be 3 inches tall on that sign. If you are standing in an emergency room of the hospital, looking down the corridor or just stepping out of elevator and 10 feet away is this great big overhead sign with three inch letters on it, yeah you''re going to see it, it will knock you over. The three inch letters tend to be overkill if you are right up on the sign like that. There''s a question about whether we really need them to be three inches if you are viewing them fairly close. Guidance has been given to us which I reference is 703.5.5, slide 19, where it talks to us about standard signs, 5/8-inch, plus 1/8 inch per foot of viewing distance above 72 inches. In the boxes below that, it starts talking about signs higher than that. If you have a sign less than 180 inches viewing distance, they call for 2-inch letters instead of 3-inch letters. Beyond 180 inches or greater, and its greater than 70 inches to less than 120 inches off the floor, 2 inches plus 1/8 inch for every foot of viewing distance. And if you are greater than 120 inches height wise and less than 21 feet away it''s 3 inches, more than 21 feet it gathers 1/8 inch for every foot. So there''s been given more ranges, where we didn''t have that before. Same as we see with the 48 to 60, we see with the visual, overhead signs we have more guidance to go by, as far as the character height of those signs. Other issues with the big character height was if you have a drop ceiling, trying to put overhead signs sometimes they didn''t fit in the space. That kind of covers the slides, hopefully to some extent I''ve covered the where are they required and what does it have to look like. So with that, before I talk about error and omissions we will turn it over for questions so I can let the questions direct this.
Ladies and gentlemen, we will now begin the question and answer session. If you have a question please press 1 on the telephone. If your question has been answered and you wish to withdraw the request, you may do so by pressing the pound key. Questions will be answered in the order they are received, one moment please for the first question.
Before any further telephone questions, I have some coming from other participants using the system. A question for you Mark, from our folks using streaming audio: The question is if modular furniture has been installed, with each space designated, for instance, cashier, and the name of individual at desk, John Doe. Do those signs need raised and Braille markings?
The person''s name would not have to be raised in Braille, and I am going to give an educated yes, the permanent room or space would be marked with a sign, tactile and Braille that may include the cashier. Again, it''s going to depend on the set-up, you know what Department of Justice always says, depends is their favorite answer. I will try not to do that. That''s a good question. It''s kind of like cubicles. In cubicles, are you marking as permanent space, or just marking them as the person''s name? The name could change. Someone could argue it''s changeable, not required to be tactile or Braille. If that cubicle got a name, that''s probably is not going to change, they need to make it, if they are going to sign it, it needs to be in tactile and Braille. So it kind of depends on the set-up of the cashier''s station, arguing it''s a permanent room or space, I would argue because the person needs to find the cashier to pay, if it''s a person that''s low vision or blind and needs that accessibility, you want them to know where to pay.
So, Mark, just for clarification, you are really making more of an argument, less a legal requirement. A cubicle is not an architectural element, it''s movable, it''s a temporary structure not part of the built environment. So it''s more of a customer service than legal argument here for what would be required under the law.
Right. It really has to be a permanent room or space that won''t change.
Correct. So a cubicle won''t qualify under that definition.
From a legal definition, In just want to make it clear that people understand what we are saying here, is that you are really talking about it more, from the fact that this is a customer service area, where people are going to be told by the receptionist, go to the cashier, the third opening on your left, something of that nature. Make an argument that there is a customer service issue to consider, providing that kind of tactile designation.
There''s been the argument that you have when you talk about fixed seating. There''s been the argument that if seating is fixed, never changes on the floor plan you need to provide access aisles and accessible seating. And if the floor plan, I don''t want to say plan-o-gram because they always change, but like you say, permanent architectural room or space, there''s very little question there. The cubicles, you''re right, technically it''s not an architectural feature and a good advocate will have some arguing to do.
Correct, you''re not going to be able to really make the legal argument. Unless, for example, let''s say it was a Title II entity, for programmatic access.
If I was asking, I would say how long have the cubes been here? But it''s not in ADAAG.
Right. And I just want to make sure people are clear about that issue. Another question I have sent to me by email is, they have a reference to slide 12, shows the picture of the gift shop. The question I think they are very correct in pointing out, you used to illustrate the sign itself, but the placement is incorrect because it''s not on the latch side of the door.
Good, Very good. Didn''t know if somebody would catch me or not.
So people are clear, you are using as an example of the sign, not of the placement.
Right, I was hoping somebody would catch me on that. Double doors are another one we get questions on a lot. Where do you put the sign on the double door? Latch side is in the middle. In the past it''s been a judgment call, to go to one side or the other or adjacent wall. New ADAAG, spell it out, needs to be the right side of the door or, I believe it''s stationary without looking it up. So look at the ADAAG because double doors are addressed now. We didn''t have that before. Good call on that.
So everyone is clear, the picture in number 12, that appropriate mounting for the sign would be on the latch side of the door.
OK, just so we are all clear.
If there''s no wall space on the latch side of the door you can put it on a side light if it''s a window. But a lot of times people, if they have a stationary side light near window, they don''t want the sign on there because they think it will be ugly, but you can put a blank on the other side of it and dress it up. It will be just fine on that stationary side light. If you don''t have the wall space, which you really should in new construction with 18-inch latch side pull side requirements, but if you don''t have the space you are allowed to go to an adjacent wall.
OK, we''ll go ahead then with the telephone questions.
Your first question is from Martha. Please go ahead.
Hi. I am curious about evacuation maps that are placed near elevator banks. What the requirement might be for that.
OK, the requirements for signage at elevator banks saying fire egress information are covered under NFPA life safety code, NFPA being National Fire Prevention Association, then NFPA 101 which is referenced in the new ADAAG, and actually spells out that that signage is required. In current ADAAG, I don''t believe there''s a reference to those signs. In new ADAAG, I believe there is. So you actually have a scoping requirement, as well as life safety code. Life safety code is going to, building code will give you requirements on egress signage, exit signs, life safety issues will be covered there, as well as standard building code.
Your next question is from Ken. Please go ahead.
I have a couple of comments that we talked about already to see if we agree on. The person that asked about the computer chip that communicates to receive by a blind person, that''s actually going to be discussed in the pro [inaudible] guidelines when they come out. The RIAS (Remote Infrared Audio Signal), being one company that has put in a lot of them, San Francisco has those, like in the city library and so forth in terms of way finding and information. And the question about signage within stairwells, seems to me it wasn''t specified, at least what we''re talking about. It''s important, identifying each floor as you move up and down the stairwell. It seems to me that that doorway is into a fixed permanent space, the hallway. For example, the fourth floor hallway, that''s a permanent space, therefore there should be a requirement to have that number four in accessible format at the door from the stairwell side.
There''s not a requirement in accessibility standards for the sign to be placed there. There is a requirement for exit signs at stairwells. There''s a requirement in building code, same building, depending on jurisdiction for the stairwell to be marked. So there is other code, life safety code that requires the stairwell to be marked. And once provided, now there is accessibility requirement, based on permanent rooms and spaces as you say, that are going to require that to have tactile and Braille.
What is meant by the stairwell being marked?
From floor to floor. A sign on the wall that says level 1, level 2, level 3.
Oh. You are saying that is required?
Yes, sir. By life safety code or building code, band then once installed because it''s required under those codes, then accessibility standard kicks in because you provided it, it''s a permanently marked room or space, so then it''s tactile that gets kicked in.
OK. And several times you used the phrase "in contrasting colors" and I hope you didn''t mean that, colors don''t work for a lot of us low vision people, we say visual contrast, light and dark.
OK, I appreciate that. Thank you,
Some renovated subway stations where they have a yellow nose on a gray step, that doesn''t work for us.
Oh, yeah. We went through that on the PROWAAC committee on detectible warnings.
And the icons for men''s room, women''s rooms, also don''t work very well for many of us low vision people, because it uses two colors, not light and dark, and the two ideograms are too similar. I proposed, you may have been in the meeting, PROWAAC where I was, the man''s shoulder''s be widened, the woman''s dress be widened, so you are looking at basically two triangles, one upside down from the other, in addition to having higher visual contrast. Any hope for that?
Great comment, I am glad you made it. Reminds me of the extra requirements in Title 24 California, where they have triangles and circles in addition to the shape and the sign.
Not high contrast, that''s the problem.
Your next question is from Ilene. Please go ahead.
We have a couple of questions. In the context of airport terminal, the viewing distance is the confusing thing; in a large space you could be viewing a sign from yards and yards away. If you followed even the new a ADAAG standards you could get gigantic letters, which makes no sense. That would be question 1, what are the limits on viewing distance, and how do you decide what the viewing distance ought to be. And then, if you have more than one language on directional signs do all of the languages have to be the same height, or if you have English, for instance, at 3-inch dimension can the other languages be smaller?
The second question, I don''t know, I would have to get the answer for you. If you know, Robin, jump in. On that one I would take an e-mail on and I will go get you the answer. The first question deals with the viewing distance and the 3-inch rule in the old ADAAG what makes sense. In the new ADAAG, how far away from you is it when you are viewing it, and they have, in slide 19, in the 703.5.5 in the new ADAAG, they have put a table in there that gives us different distances, height requirements for how far we are from it and how high it is, the directional signage. It tries to throw in degree of reasonableness for signs you are fairly close to, starting at 2 inches, and as you get farther away the letters are supposed to get bigger. As you get farther it gets to the 3-inch requirement. Then it will go beyond that. If you get farther away, it adds an eighth of an inch for each so many feet.
I understand that, but that doesn''t really answer the question of should you be able to read a sign from any distance, as soon as you see it?
Good question. ADAAG doesn''t address that. It gives us these measurements and makes us as designers make the call. Sorry, wish I had a better answer. Send me that other question on an e-mail at ADAmarkd@aol.com. I will be happy to try to get you an answer.
Just to go a little slower on that, its ADAmarkd@aol.com. So people have that if they are looking for it. Also, I will clarify, because it gets confusing with the language we use, and some of us are so used to throwing them around, we think everyone understands what we are talking about. Mark several times in the session you referred to old ADAAG and new ADAAG. Let me just clarify what you actually mean by that, so everyone is clear about that. When he is talking about old ADAAG, he means current, enforceable ADA accessibility guidelines, or ADAAG, not meaning no longer applicable. The current standard, put out in 1991, is the standard that is currently enforceable by the U.S. Department of Justice. It''s not old, it''s current. That is, again, the current enforceable standard. New ADAAG is a standard that was passed by the U.S. Access Board, the federal agency charged with the responsibility of developing the accessibility guidelines. They do not have enforcement authority for that under the ADA. So the U.S. Access Board undertook a five-year process of reviewing and updating the current ADAAG, and looking at changes, things needed. They finalized their version of that in 2004, July of 2004, and published it. It''s actually the ADA accessibility guidelines, as well as changes to Architectural Barriers Act, which is the standard for federal buildings and such. When he refers to new ADAAG, it''s not an enforceable document at this time, it''s the best guideline of the most accessible or current state-of-the-art practices and such, but they are not enforceable. They are adopted and finalized by the Access Board, but the U.S. Department of Justice is just beginning their process for reviewing those proposed, or current, Access Board versions, and the U.S. Department of Justice will make the final determination of what will be the enforceable standards. If changes are incorporated into the current ADAAG, those will come out of the U.S. Department of Justice and will then become the enforceable standard under Title 2 and 3. When one looks to or refers to the Access Board''s version, current version of the accessibility guidelines, recognize they are not enforceable, but they are the best guidelines we have on these issues, and in many cases provide a more stringent standard to address some of the problems we found in the current version of ADAAG not meeting the needs of people who are blind or visually impaired, low vision and such. Just to make that clarification, I want people to understand clearly what that issue is.
Can I add a little to that?
Hopefully without confusing. However, if you are looking, working, on a GSA site
Can you give us some clarification on GSA, people may not know.
Government services administration, in charge of certain federal buildings, has adopted it as enforceable. Robin is absolutely correct, and I stand corrected, current ADAAG has force of the law. New ADAAG not adopted by Department of Justice (DOJ). For Title II and Title III entities and for surveying, we have to do it under current ADAAG. Designers that are out there listening to the call today, Robin, I imagine are looking for what they ask all the time, what''s safe harbor? Recognizing that international building code is referenced in the ANSI, which is looking an awful lot like the upcoming ADAAG. Those two I tell people about a lot, and I refer to the ANSI in day to day activities, and I explain the differences between the ADAAG, and there''s a lot of confusion in the field right now. I don''t know, Robin you can answer this, I am asking the right person, what are the information centers telling architects when they call in and ask.
We are referring them to what is out there in the current ADAAG, as well as the proposed. Or the Access Board''s document, but we are making it clear they understand the difference between the enforceable standard that is currently in place, and also referring them to state codes that are in many situations more stringent. OK. Next question please.
Your next question comes from a captioner. Please go ahead.
I was asked to ask, what are Braille chips?
OK. In the process of trying to find readily achievable barrier removal for existing facilities, I came up with the idea of making available Braille chips. A person can order a whole new sign, that has raised characters and Braille on it and replace all of their signage at great expense. Or if they have a sign that can be modified we can make up an overlay or Braille chips. If they have raised letters, if all they are missing is Braille we can get a list of all the signs and make up Braille chips that will be put on the existing signs, with adhesive, to make them up to compliant. At a greatly reduced cost.
Next question, please.
Your next question comes from Jim. Please go ahead.
I wanted to ask about an. Let''s say I am a realtor, and I operate a realty office with 40 realtors in a two-story building. And at the time the building was built all of the numbers, rooms were numbered on the door and there were sliders to put different realtors'' names on the 40 different offices. I have an expense to move the signs that I don''t want to absorb. I have a receptionist and a security guard on the premises all the time, at the only entrance available to the public, most of the work being done in the office is in other people''s homes or the home they are attempting to buy, people very seldom come to visit realtor at the office. Would I be able to legitimately say I put in this alternative of having my receptionist or security guard be responsible to assist someone in finding locations in the building, and not go to the expense of doing signs?
It may be, I would call the Department of Justice to get an interpretation on it, get their feeling on it, to what degree your readily achievable barrier removal is. I have a feeling it may not be readily achievable. You need to look at your entity, does it apply to that work space? Does public come through there? Strictly work spaces? I would definitely call the Department of Justice for an interpretation. I have a feeling you are going down the right road. Robin, do you have anything to add?
No, I don''t think if you will get a more definitive answer from the Department of Justice''s TA line on that issue. You have to go down the analysis of readily achievable. There''s not a real firm formula, or anything that is used to assign what is readily achievable, you would still be looking at issues of what area, is the area open to public, what is the issue in regard to someone having access, and what would it actually take in terms of overall resources that that entity would have. Again, when you look at readily achievable barrier removal, under the priorities, signage falls under the fourth priority, not the first. That would be looked at in the context of overall for the facility, what are other issues the facility has related to barriers that need to be removed.
For instance, your parking signage, if you have accessible parking spaces, there is no doubt you need that signage. That''s a readily achievable barrier removal. However, replacing the entire graphics package in your building may very well not be readily achievable barrier removal.
It really depends on the entity. If you look at the Hyatt Corporation, all the hotels and such, it''s a mega-corporation, one would have a different analysis. Again, if I am talking about changing a 500 room hotel, and it''s got 500 plus rooms that need to be changed out, while it sounds simple, the cost of doing that can be quite expensive. You would need to work with FAS. Sometimes it''s easy for us to say, oh, signage can be changed out easily, it doesn''t always translate out to easily. But that doesn''t mean that over time, again, readily achievable barrier removal is an ongoing obligation. I can''t take a picture today and look at my resources today and say I can''t do it , I would need to look at a plan for a long-term approach and maybe look at every year I will change out high priority, the bathrooms, next maybe for life and safety, I am going to make a decision of exits. Something of that nature I think that definitely still would apply. May not be immediate barrier removal issue, but a plan for barrier removal is applicable under Title III.
Your next question is from Lynette. Please go ahead.
We are wondering about signage for accessible pathways. We recognize the entrance must be marked when not all entrances are accessible. But how much signage do you need to that entrance from them closest public walkway?
Sorry, usually when talking to folks about way finding, you are trying to find your way from your arrival point, to an entry, to your room you are going to as an orderly process. Anywhere a person stops along the way, and doesn''t have obvious direction, or indication of direction, if you have to stand there and wonder, that''s a good place for a directional sign. I highly recommend if you have a campus, or large site you are working on way-finding on, get a way-finding expert to do a survey specific to way-finding on your site and give you good recommendations.
There''s not clear guidance on this issue in the ADA accessibility guidelines. You know we look at issues like doors, having to make sure that if not all doors are accessible you mark those that are, and those that are not. Identifying where they are, where the accessible ones are located. That can get to path of travel issues as well. If the door is down a path not accessible to get to, or I am going to get all the way there and find that the door is not accessible, there is an argument to be made related to whether that signage to where signage where the accessible entrance is located should be when I approach the building so I know which path to take to access that particular facility, so there are some things that guide us, or at least direct us in the direction, but not real specifications related to actual pathways in the accessibility.
Just the actual entrance?
The entrance issues are addressed by requiring signage if not all entrances are accessible, directing me to put signage by drop-off points are or where parking might be or something of that nature, so I don''t have someone traveling all the way down nd finding they can''t even get close to the door and now they have expended all of that energy for nothing.
Right. OK. Thank you.
We are at the bottom of the hour. So our time is done, probably more questions, sessions like this tend to generate more questions than answers, there are so many intricacies to the issues not all things can be answered so they are black and white. If you have further questions, Mark gave you his contact information, I encourage you to contact your regional ADA and Accessible IT center, Business and Disability Technical Assistance Centers by calling our toll free number of 800-949-4232, which is available both voice and TTY. If you are not familiar with your center or if you are not sure which serves you, you can go on to the national website, www.adata.org and locate through a map on the website the center that services you specifically, with links. I invite you to join us next month, our session next month is our anniversary session which we hold on a regular basis, its on the 18th of July, it will be an ADA update from John Wodatch from the U.S. Department of Justice and Sharon Rennert from the Equal Employment Opportunity Commission, providing us with an update of where we have gone in the past year and what we can expect, this is the 16th anniversary of the Americans with Disabilities Act. We will be looking at where we are today and where we might be in the future. So I invite you to join us. Same time, same place. If you need more information about the session you can go to the website at www.ada-audio.org to get more information on registration and the session. Thank you for your time, Mark. You can be, there is more information on your website, go ahead.
That will get you to the signage information, correct?
Yes, a link from there to our e-commerce site, eastlakederry.com.
OK. A transcript of the session will be available in the next 10 days on the website and an audio recording within five days. That will be at the www.ada-audio.org website. Thank you very much, and I hope everyone has a good day.