Welcome ladies and gentlemen to the refresh of the 2010 Americans with Disabilities Act (ADA) standards: March 15 is just around the corner conference call. At this time all participants are in a listen only mode, later we will conduct a question-and-answer session and instructions will follow at that time. If you require assistance during the conference please press star then 0 and as a reminder this call is being recorded. I would now like to turn the conference over to your speaker, Peter Berg. Please go ahead.
Thank you very much. Welcome everyone to the January audio conference session. I hope all of you out there across the time zones are having a productive Tuesday afternoon. Today we are providing real-time captioning and the powerpoint presentation through the online elluminate webinar platform and then audio is available by telephone or audio streaming through the online webinar platform. For those of you that are participating by telephone we will give instructions when we get to the question and answer period as to when you can as to how you can ask questions for today''s session. For those of you that are joining us in the webinar platform, to access the captioning feature within the platform, go ahead and select the captioning icon located at the top of the page. And that can be sized to fit whatever your needs are. We -- you can submit questions in the chat area. So when we get to the question and answer period you can submit your questions in the chat area by hitting control M to get in to the chat area to submit your questions. For those of you in the elluminate platform who are using assistive technology you can follow along with the powerpoint presentation by using the key stroke function control slash. That will open up the activity window and allow you to follow along with the powerpoint presentation. We please ask those of you in the webinar room to please refrain from using the emotion icons as those can be distracting to the presenter as well as cause problems for individuals who are using assistive technology. Alrighty. So on to our session today. We are just a little under two months away from the compliance date with the 2010 standards which takes place on March 15th of 2012. And before I introduce our excellent speaker I just want to remind folks that the ADA audio conference series is a collaborative project of the ADA national network which is coordinated by the Great Lakes ADA center. The ADA national network is funded by the U.S. Department of Education and we provide you these monthly sessions on a wide range of ADA topics. Today we are very fortunate to have an outstanding presenter with us. We have Earlene Sesker who is an accessibility expert with the United States Access Board and she is going to provide us with a refresh, an overview of the 2010 standards. So at this point I will turn it over... I will say welcome to Earlene and turn it over to her.
Thank you Peter. Right now I am at slide 3. Just want to thank everyone for joining us today and to let you know what my intent today will be is to try to hit on those things that have changed. It is a very lengthy document. A lot of the things that are there are not necessarily changes, some of them are clarifications where we look back at the 1991 standard we found that there were questions that we kept getting continuously which would tell us that what we were saying was not clear. So what you are going to find in some of it is clarification. For again as I am saying today what I am going to try to hit on are those things that have actually changed within the document. Next. In looking at the new 2010 standard what we will find one of the most glaring things you find is that the whole formatting of the document has changed. And in looking at it we now have a document that contains 10 chapters or sections. We talk..we start out with number 1 which is your application and administration which is going to tell you give you all your definitions. Tell you what things are covered, talk to you about things like barrier removal, new construction alterations, and then you have your scoping which is no different from the scoping that you found in the previous document where it is going to tell you what things are required to be accessible and how many of those things. Then we have what we call the building blocks. What we try to do with things like knee clearance where you are going to need it under multiple items rather than in each chapter or section specify the same thing over continue to repeat that we put it all in one chapter, Chapter 3 which we call the building blocks, so all the accessibility features build off of those items found in chapter 3. Then we have all of our acceptable route requirements. So you are going to see your door requirements, your walking surface requirements, elevators, anything that is part of your accessible routes, your platform lifts. Then we have chapter 5 which has your general sighting elements, that is where you are going to your handrails, your parking and then in chapter 6 all of your plumbing elements are there. Then in 7 we talk about your communication features, so you are looking at your fire, the telephones, the TTY, everything that is a communication element, your signs, all of those will be found in Chapter 7. In 8 you will have your special rooms, your courtrooms, your assembly areas all of those type things that are special rooms that have special provisions that would not be scoped out or that are different in most instances from what you would find in your general provision will be in your special rooms elements and spaces, and then your build-in elements. You will be looking at your benches, your counters, your checkout aisles all of your built in features and then the biggest news that I believe in all the documents are the recreational facilities where we talk about your amusement parks, golf courses and boating and so forth. All of those are now going to be found in chapter 10. Next. In the 2010 standard there were reasons why -- it was time -- other than the fact that it had been years since it had been updated there were other things that we had to consider, such as providing better access. Many things had changed as far as technology and what can be done now from 1991 when it was first written to 2010 or 2004 actually when the department -- when the Access Board actually wrote the new guidelines and so we wanted to have better access and compliance now that more things were possible than the original document. We wanted to improve the format and the usability so that it is easier to use which is one of our major goals. We wanted to make it more consistent with your building codes and with your ADA guidelines which with your Architectural Barriers Act guidelines that are used for accessibility for federal buildings. In the past if you were a federal entity and a public building you had to comply with three different codes that did not always say the same thing. So what we are trying to do is to make it more consistent One document to get you to know what you need to do and that is as far as harmonizing with your local building codes also. We wanted to be consistent with the Federal requirements and to harmonize be more consistent with all your model building codes that are in place and industry standards. Next when we talk about the formatting one of the things that you will notice has changed is the numbering system. I know a lot of people are probably not happy, I was not too thrilled with that either when you had for years had been used to a particular numbering system now you have a learning curve where you are now having to learn new number system. There is no more 4.13 for doors, now you are looking at 4.04. So there are things that change as far as the numbering system but that numbering system will harmonize more with the building codes. New figures the figures now we hope are clearer. That our lines line up and so forth to tell you where you are measuring from but in addition to that what we have done is say figures are for informational purposes only. So now if there is something that we want you to do or something that is mandated that you are required to do no longer will you see something that says as shown in figure. Now anything that is mandated that is a requirement is in the text, the figures are provided for informational purposes only. All dimensions are stated in the text and we have new advisory. In the 1991 document what you were faced with it there was an asterisks besides the particular provision that you were looking at and what that asterisk was it would tell that there was additional advisory information in the back of the document, so then you would have to flip to the back of the document and look for that same numbered section in the back of the document and that would be the additional guidance. What we have done was provide new advisory information and tie it directly below the provision that it applies to. You will see a little gray or blue box depending on I guess the color of your printer and in that box will be the information, the new advisory information that goes with that specific technical. The advisory is nonmandatory. Just as the figures as for more information the advisory has been, still is just for additional information. Next. Here are the codes that we have tried to harmonize with are the International Code Council (ICC) American National Standards Institute (ANSI) A117.1-2003 and the IBC 2003. Now if you are more recent documents have come in to play since the writing although we refer you to those is what is in the new ones is more stringent, then feel free to use that. You are held to those that are actual -- that that we were harmonizing to and those that are referenced in the standards. Next. Now that is all of the before information as far as the history on it telling you what we have done, why we have done and what we are hoping to do and now we are going to be looking at actually getting in to and using the new standards. Next. The content of the new ADA standards. As I alluded earlier and mentioned it is based on guidelines that were written by the Access Board in 2004. In 2004 there was one document and that document had three different parts. What those parts were, were the scoping and applications for federal facilities, scoping and application for the ADA and - [background noise] - technical. The Access Board finalized that in 2004. Next, then in 2010 the Department of Justice because the Access Board only writes the guidelines, the Department of Justice is the enforcing agency and they have to adopt the standard or the guidelines that the Access Board has written to become part of the enforceable standard. On September 15 of 2010 the Department of Justice did adopt the guideline that was written by the Access Board, but they adopted only two parts. Of course, the Access - excuse me -- the Department of Justice does not enforce the Architectural Barriers Act. So what they adopted and what is enforceable within their standards is the ADA application and scoping, chapters 1 and 2 and then the common technical requirements that are found in chapters 3 through 10. So they excluded the ADA because they have no enforcement over the Architectural Barriers Act. Actually the Access Board enforces the Architectural Barriers Act they are the standard setting agency for that. We do not need to talk about that part today because what you are looking at is your effective date that is looming fast for March 15 and that is only going to be dealing with Department of Justice (DOJ)''s ADA standard which again is the ADA chapters 1 and 2 scoping and section chapters 3 through 10 of the technical that were found in the Access Board''s document. Next.
Earlene, I know we have got a lot of information to cover but if I could ask you to slow down a little bit for our captioner. Thanks.
Okay, I have that tendency that I do that I kind of get on a roll and speed right along. Okay, I will try to slow it down and so we should now be on slide 11. And when the Department of Justice adopted the standard, not only - they used the parts that apply to just the ADA but they adopted it and they made it for additional requirements and they looked at things like social service establishments, and so they wanted to be more specific about what is considered a social service establishment. So they made it clear that we are talking about halfway houses, shelters and group homes and to say that these type of facilities need to comply with the residential requirements and they went a step further to say if this were 25 beds more than 25 beds, 5 percent need to comply. Five percent of those beds need to accessible. And then if you have something more than 50 beds and you have a common use bathroom and at least one roll in shower with seat. Then you also have to have a transfer shower in there with a seat. Cannot be -- you can -- excuse me. You must have a roll in shower with a seat. You cannot use a transfer shower in lieu of that. And none of the exceptions that are granted for grab bar seats are applicable if you have a facility that has 50 beds or more with a common use bath. Then when they look at houses in places of education they wanted to differentiate because this is the first time, of course, we have had residential requirements in the guidelines along with the transient lodging. So they wanted to make clear that the social services looking at residential, houses in places of public accommodation. Now in places of education I am sorry. And what they are talking about with that are your dormitory. And they want to make it clear when you are dealing with a dormitory you are dealing with your transient lodging. On that same place of education If you have an apartment or townhouses that are rent the out like, maybe you have marriage family housing, or you have these other types of facilities they would be looking at your residential requirements and the kitchens would all be required turning space and accessible work surface and if you had multi bedrooms there needs to be an accessible route leading through that whole unit. For your assembly areas they added a dispersion requirement. For medical care they have also added dispersion requirement if it is a facility that does not specialize in treatment on mobility, And then with residential dwelling units they also gave specifics for those that are public housing entities whether it is through a public housing, whether designed or selling them or if it is through a special program. For detention and correctional facilities they actually upped the requirement in the original 2004 guideline. There was a requirement for 2 percent for detention and correct correctional facilities for the cells to actually be accessible and they made it up to 3 percent. And then with places lodging they actually went to explain how you could calculate if you had a site that had more than one building on that site, how would you calculate the number of rooms that were needed. The chart is still there, but it would be if you have a facility that has 50 or less of the rooms, if it is a multi room buildings on there and there is 50 or less rooms combined, then you can combine the total. And say this is how many accessible rooms I need looking at the chart. If there are more than 50 rooms then you have to look at each one of those facilities separately when you are calculating how many rooms are required. Next. DOJ''s standards, no different than the 1991 that we are looking at is that it is going to apply to new construction and alteration under Title II that would be a state or local government facility. Title III for places of public accommodation as well as Title III with your commercial facilities. Except transportation facilities which then adopted the standard with a few edits in 2006 and it is going to be with things like detectible warnings that we will be talking about later when we talk about the actual technical specific indications. Next. What we have done within the new standard is 1991 as in this one we have had reference standards when you look at things like elevators, doors and so forth we have always referenced another standard to say this is the standard you need to comply with. We have added a section in this book up front under the application where we are going to give you a list of all of the standards that are referenced throughout the document and letting you know where you could obtain that standard. Next. Earlier from 1998 through 2002 the Access Board wrote other supplements that they wrote as final, state and local government facilities which was published as a final for the Access Board in 1998 along with the children in 1998, play areas in 2000, and recreation in 2002. A lot of us have already been looking at these standards over the years and we have always advised people to use them as guidance but they were adopted as part of new 2010 standards without subject to change. So the things you have been looking at over the years and we have been telling you to use as guidance come March 15th will now become part of the enforceable standards, as they were written back then. There were no substantive changes made to those provisions. Next. Another thing that you will see which we hope will make it a lot easier as far as the usability in the document for the first time there is a subject index. There has always been a table of contents where you could look at what provision you are looking for if you wanted to do more or if you wanted lam to see where. Now in addition to that we have a subject index in the back of the document which will give you the exact page and anything you may be looking at in the reference, no matter how many times they are provisions for them, maybe a sign for the bathroom and so forth everything is included in the subject index and if there is something that you are looking for maybe recall something else but we know there are two different names that you may be looking for under we tell you what section to go to find that, so we hoping that will help with the usability. Next. Something else that we tried to clarify is that all areas unless there are specific exceptions or if it is something that is partially scoped and we talk about this there is a section within the new guidelines that gives you general exceptions. So unless you have something that is listed under the general exceptions or list as a work areas which is work area we talk about approach, entering and exit, so not the entire thing is required to be accessible or partially scoped. And what partially scoped means is there is something that multiple elements that the actual scoping provisions do not say all of those elements need to be accessible. So, unless you have something that falls in one of those three categories all area must comply. We would always have an issue where people would say wel we do not specifically address this, so it needs to comply. So what we have tried to do is clarified unless we say it does not for one of these particular reasons then it is required to comply with the new guidelines. Next. Moving on to parking. When we look at parking, what we have done with parking is the only real change with the parking is we have actually increased the number of van accessible spaces that are required. This does not increase the number of overall parking spaces. You would still be looking at how many parking spaces you have and then calculating from that how many accessible spaces that you are required to have and then based on how many accessible spaces you are required to have, you are still looking at how many are required to be van accessible. And there in the 1991 standards it was required that eight or excuse me 1 for every eight or a fraction there of. Now we say one for every six. We thought this would increase the availability of van accessible spaces because as you are aware van spaces are reserve, there is a sign there letting you know that are van accessible but cars can park in them where cars have a lot more spaces to park in, vans were more limited. So we figure with increasing that number that will actually help with the availability of the van accessible spaces. Next. The access aisle marking. First time we actually say the access aisle needs to be marked. The access aisle was always required. We never said how it needed to be marked. We are not very specific as far as -- we do not have anything to do with the color or how it is marked. We just say it should be marked in some way or the standards I should say should be marked in some way to discourage people from parking in them. The color and what type of marking is usually mandated more on a local level. Next. Parking sign. For the first time the standards now will be telling you where -- I mean in the 1991 standard what it told there should be a sign and that sign should not be obscured by a car parked in the space. We are now telling you which is what we meant so this is more of a clarification that that needs to be vertical sign. What we found there was a lot of confusion with well, it is not obscuring the space. Well, maybe if I put it towards the end of the space, the car, if they car pull all the way out they are not covering it. What was meant and what is now being clarified is you need a vertical sign. That sign should be 60 inches to the bottom of the sign, we talk about adding a van accessible sign to that sign and then there is an exception if you have a very small parking lot that only has a total four or fewer spaces then are you are not required to have a sign for van accessible spaces. Next. Passenger loading zone. In the 1991 standards we require one passenger loading zone. We are now replacing that to say that at least one for every 100 linear feet of loading zone space provided. This was is for facilities such as airport that may have one long continuous passenger loading zones and there before only required one and without, so you may have this long continuous one and we were only requiring one space. So in response to facilities such as that we are now basing it on the linear feet of the space to determine how are required to be provided and again this is where provided, not required. We are not requiring that you provide a passenger loading zone. But it is where they are provided it now needs to comply with this at least one for every 100 linear feet. Next. Passenger loading entrance, a canopy in 1991 standard for medical care facilities with the accessible interest there was a requirement for a canopy. That requirement has been removed from the new standard. It can still be provided it is just no longer required. Responsive to comments, with looking at canopy the only place it was required whats that accessible medical care. There are other accessible entrances. Never were they required. It was determined it was more of a comfort issue than accessibility issue so it is no longer a requirement. As I said, it can still can provided it is just not required any longer. Next. Opening doors. Exterior door opening are still not mandated. You will see that it is still reserved and the same issue, when you look at the closing force for building code because building code has to consider things in the area like the wind, getting air pressure, Hvac, energy conservation, when you look at what the building codes will require it usually exceeds the accessible resistance. So right now for opening force for exterior doors there is still not a requirement. GSA facilities are though within their own standard, own mo they are now requiring it for their building but it is not something that is required in the ADA 2010 standard. Right now it is a recommendation. We say if all possible we recommend that people do it but it is not a requirement. Next. Entrances, in the 1991 standard there was a requirement that 50 percent of all public entrances comply. That number has been increased to 60 percent and in addition to that if you had direct access from any parking facility, tunnel, elevated walkways, tenant spaces restricted or secured at least one of those needs to be also accessible in addition to that 60 percent that you are required. Excuse me that the ADA is requiring. Next. Secured entrances. So if you had a secured entrance, at that secured entrance they are the exception as far as the hardware not needing to comply, the closing speed or the opening force but it is important to note that at that security entrance must be under the sole control of a security person to be eligible for this exception. We cannot say or you cannot say that well, personnel is there all the time so security they can let the person where a disability in but everyone else is just coming in that door. Everyone has to be let in that door by the security personnel in order to get the exception for these. The only thing that they would have to comply with is if security door, secured entrance under total control of security personnel would be cutting out threshold requirement. Next. Maneuvering clearance in the 1991 standard there was a caveat that if you had an automatic door opener you are not required to comply with the maneuvering clearance. That no longer applies Now all doors are required to comply with the maneuvering clearance power assistance. The only out we have is Where you have an automatic door and gates that remain open in the power off condition, they are not required to have a maneuvering clearance and this is mainly because, you will hear me say this again, for the means of egress because we now refer you to the IBC which does allow these doors to be part of the means of egress. So what we are saying okay it is part of that means of egress. The only way that you are going to get out of having that maneuvering clearance is if it remains open. No one would have to maneuver to actually open that door. Next. Another place where we look at maneuvering clearance exception is if you have a hospital patient room. In the 1991 standards we had an exception that said if there was a larger door for acute care then you are not required to have that. That was taken away. Now we just look at that latch side clearance applicable, you do not have latch side clearance for hospital rooms. It only applies in hospital rooms. If you have a long term care facility you do not get this exception, it is only for hospital rooms. Next door surface, another thing we did with the door surface is for the first time we are looking at a kick plate on that door and we are required that between doors to have a smooth surface on the push side that extends the full width of the door. This is derived from an ANSI requirement and it is intended to permit the wheelchair foot rest to be used to open the door without danger of entrapment or actual damage to the door. Next. Another thing we are looking at is vision lights. Vision lights have always been something that was mentioned in the transportation facility portion of the guideline but not in your standard doors that may have vision lights. So what we are saying now is it if you have those vision lights beside the door and each one of those needs to be no higher than 43 inches from the floor to the bottom edge. Now if you had vision lights that are placed above 66 inches it is believed that they were not meant for anyone to see through so therefore no one would be looking through those. Exceptions so those are not required to be lowered. But those that are lower and it is clearly intent for people to actually be able to see those then you would have to have at least one of them with the bottom edge no higher than the 43 inches from the floor. Next. Break out openings. Again we are looking at your doors as your means of egress. Where doors and gates are without stand that are the clear means of egress the opening must be 32 inches. Again as I said earlier, not required to have that maneuvering but that door width needs to be 32 inches for a person to actually be able to get through. Where doors and gates without standby power are a part, now if it is, if they do have standby power or compliant manual doors, serves that same means of egress then you are exempted from that 32 inch clear break out opening. Next. Controls. For the first time we have mandated which people, we would always get the question for doors that have the automatic buttons where do we place the button. In our guidance usually talked about, well, we want it not too far from the door. We would talk about it having to meet the operating controls. But now we are actually specifying to that it also needs to be outside of the swing of the door. So that when you are pushing that button you are not getting hit by the door as the door is opening. Specific now has guidance that the wheelchair space needs to be situated outside the door of that control. Next. Accessible route we now have an in the past there has always been an elevator exemption for Title III facilities that said that if the facility is less than 3 floors or 3000 square feet they are not required to have an elevator or vertical access. And Title II facilities government where never given that exemption. In the Title II regs it always said they did not or they could use ADDAG or Uniform Federal Accessibility Standards (UFAS) whichever standard they use they did not get the elevator exception. Well for the first time in the new standards the Title II get the elevator exception. They have a facility that is two stories and the second story does not require public access with an occupancy of five or less, an example would be like a boat traffic tower, then not required to have that vertical access. Next. Another thing with accessible routes is we looked at press boxes that we started looking at when we did the Title II facilities that had been waiting to be adopted in to the standards that are now adopted and we have other vertical access exceptions. If you have a 500 square foot or less and it is facing a press box or if on bleaches that are entered at one level or if it is a free standing press box that is elevated 12 feet or more, they are not required to have the vertical access. Next. Additional clarifications that were made with the accessible route is that if there is not an accessible route if there is not a path -- if there is not a pedestrian then there is not a requirement for accessible route. So if you are not, If you never walk the only way to access this building is vehicular traffic it would be the same for everyone. With the circulation path you usually think you do not have to tell people this but the circulation path is interior the accessible route must be interior. You would be surprised how many people would say there is accessible route, they can go out of the building they can go around and go in the back door and it is accessible so we meet, it may be clear the circulation path that everyone else is on the interior of the building the accessible route also needs to be on the interior of the building. We also talk about mezzanines. You know that vertical access is not required to mezzanine if you are in a facility that is eligible for one of the elevator access. You get that exception for elevators If you have a facility maybe it is two stories and not required to have that elevator but maybe has a mezzanine in that facility, clarify that vertical is not required to that mezzanine. Additionally we have had requirements on accessible hand rails on stairs. we received a lot of questions say in a hospital corridor they had handrails. Are you saying those handrails need to comply and the answer used to be that if it was not steps then they were not required to comply? The only ones that we were requiring was the steps and the ramp. Now we have language that telling if you have handrails provided on walking surfaces then those hand rails must be accessible. Also we went a step further because always been and if you look at your accessible route requirements in the 1991 standard there were requirements that were allowing the accessible route to be reduced from the 36 inch mandated to 24 inches at periods, at intervals but there was nothing specific on how often that could be done. Or and so what we are saying, I am sorry, could be reduced from 36 to 22 excuse me 32, and what we have done and there is where I am getting the 24 confused. With the new standard we have said you can decrease that accessible route from 36 inches to 32 for a depth of 24 inches. But this cannot happen any closer together than 48 inches. So you do not want instance where okay we are going to reduce -- say you are walking down a sidewalk and someone decided to put a poll. So where this poll is now that accessible route is 32 inches. Then when you come passed that pole we do not want there be a bench immediately adjacent to that is going to again decrease that. So what we are saying is that there can be reduction and can be reduced to the 32 inches but those intervals cannot be closer together than 48 inches. Next so you your accessible means of egress what you will find in the new standard is reference to IBC. IBC we talk about the means of egress and the breakout opening. In addition to that they do allow platform to be part of a means of egress. What we have done is to say that if a platform that is part of a means of egress, there is a requirement for that platform to have standby power. Next. Detectible warnings. Detectible warnings is something that has gone back and forth for awhile. There was a requirement for detectable warning and then well after many suspensions it came back in to play as it was. Now we are faced with another change with the new 2010 standards. Next. What we -- what you will find or what you would not find in the 2010 standard is a requirement for detectible warnings on your standard curb ramp. As I said earlier Department of Transportation adopted the standard. They adopted it and when they adopted it they kept the requirement for the detectible warnings on curb ramps. So if you are a DOT facility there is still that requirement. The new standard and -- and on platform edges . The new standard no long provides it on curb ramps or has vehicular way. What is going on as I am sure you all are aware is the Access Board is in the middle of the rule making for public rights of way and in the public rights of way we are revisiting the whole makeup and design of detectible warnings. So there will as soon as this rule passes and is adopted and enforceable there will be a requirement for detectible warnings in the public right-of-way but that is not going to be on a site. If you are still looking at say your Wal-Mart store and have your curb ramp leading across over to the parking lot there is not going to be a requirement in new construction or alteration for detectible warnings to be on the site, it will only be in the public rights of way. Next. Employee work areas. The change -- there has been no change in the basic of smaller employee work areas where we always had requirement for approach enter and exit only. What we have done if you have a larger say greater than one thousand square foot work area, in addition to approach enter and exit we say there should be a circulation path leading through. Now in the 1991 standards sometimes you have a circulation path if there was a common use space within that employee work area. Then you would need, of course, an accessible route leading to that common use path. So what we are doing in addition to all that is if you have a very large work area or larger than 1,000 square feet then you are required to have a circulation path as well as an accessible means of egress and you are required to have, although, when we say approach or exit, none of the actual elements within the work area are required to be accessible. Now what we are saying, and that includes visual alarms, now we are saying that all appliance although the visual alarm does not have to be mounted at the time the wire connections need to be in place. So when and if under Title I an employee is hired that has a disability you will be able to just put the actual appliance up. We do not want an instance where you come back and say it is not reasonable to do that because we have to rewire, we have to tear up, so wiring is required at the onset. Next. When we look at approach enter and exit for the employee work area what we are speaking of is the door; you have to have that maneuvering clearance at the door, the door width needs to comply, all your hardware, your opening force, and a clear floor space at that door. All of those are what is required for your approach, enter and exit. We go a step further and would like to recommend, although it is not a requirement, that you do that on the interior of the door also. To allow someone to get back out. Right now the way it stands with approach, enter, and exit, it is really is to say that someone could get to the door and then have to back, back out at the door. So when the space is there we would actually recommend that there be a turnaround space within that room and interior maneuvering clearance for someone to actually get back out. Now of course if this were a common use space and work area, say you have your office where you see the general public then you be required to have that interior door clearance as well as your turning space because now it is no longer just an employee work space it is an employee work space plus a public use space. Next. With the work area we are looking at larger work area and the accessible circulation path that is leading through it. The exception, basically, of course, if it is a smaller area we would be back to approach, enter and exit so you would not be required to have that circulation path. If you have equipment that is actually part, like if you are going to computer mode, so the actual equipment is something that is needed in that space we do have exceptions as far as for the actual width of that accessible route and if you also have an exterior area. Say it is a stock yard that is actually work space do realize that fully exposed to the weather that you are not going to be able to have that accessible circulation path. You are probably not going to meet the firm and stable slip resistant and other such issues So these -- there are exceptions to that circulation path throughout the work area. Next. Now we are going to be looking at toilet rooms. Everyone''s favorite plumbing issue. Next, private toilet rooms this is something that has always been allowable we would say that originally all toilet rooms were required to be accessible. We would say if it was a private toilet room in a private office it was required to be adaptable. Now we get a little bit more specific on the adaptability. And we say when we talk about private it is important to note that it means private. In a person''s office, it is accessed only through that person''s office and only that person is using it. So if Mr. Smith and his secretary cannot be using it. It would only for the private occupant of that office only for their use, and so this has been clarified in the new standards. Next, private toilet rooms with the adaptability it was important to note also what is considered adaptability because when we say adaptable we did not get any specifics on what is considered adaptable and so what we are looking at here is that we talk about that we really do not get any out on the room size. Only things that you are getting out on are things like grab bars. We are saying they do not need to be put up but you have to have the blocking and reinforcement behind the wall that when the time comes and you need to put them up it is already there. You can have alternate seat heights in lavatories heights removable base caps and reach. The door can swing in to the fixture clearance as long as that door swing can be reversed when the time arrives that the swing needs to an accessible toilet. Next. Another, as you heard me mention earlier in the 1991 standards, 100 percent of your toilet room, public and common use toilet rooms are required to be accessible. Now we have given a cluster exception. For what we are saying that is that if have toilet rooms, single user toilet rooms that are clustered together in one location and what we talk about cluster we are talking about a group of single user toilet rooms within sight or adjacent to each other, and if they are clustered at one location, then you are allowed to have only 50 percent of those toilet rooms to be accessible and this is in response to areas such as doctor''s offices or you may have all the little rooms where you go in and change and do a urine sample. And so what we are saying for those facilities like that you only need 50 percent of those toilet rooms to be accessible. Now it is important to note you should - be required to round up, not down. So if you have an instance where you have five single user toilets rooms clustered together than 50 percent would give you two-and-a-half and would need three accessible toilet rooms there. Next, and this is just to show you what we are talking about when we are looking at clustering and that we are only looking at single user. On that diagram you will see multi and they are not highlighted there. We would be only looking at single user, they are the only one that get this is the actual cluster exception. Next. In the original Americans with Disabilities Act Accessibility Guidelines (ADAAG), I am sure you all are familiar with these diagrams where we show the actual direction, the little arrows showing the direction that you would be entering the bathroom and specify the clear floor space for the water closets and in those we had the dotted line with the little lav and we are getting rid of the first two that, see have the big Xs in there. They are no longer required. What you would be seeing now is going to be something that looks more like the third one there. Next. In using the other two the first two that we are now Xing out this is what you would end up with, a lavatory that was very close to the toilet which would not allow the person to actually do a parallel transfer on to the toilet, and in some instances it was allowing things like the grab bar was overlapping the lav or even if it was not as in this drawing what you would have a person using the lav to actually instead of grab bar to actually transfer on to the toilet which is not safe. It is not made to whole a person''s weight, so this design will no longer be permitted. Next what we would be looking is something like this now and this is some of the new drawings that you will see and this does allow a side transfer for persons to actually maneuver the chair to be beside the toilet to allow them to transfer without interfering with the use of the lav. So the lavs would no longer or no fixture is allowed to be in the clear floor space for another fixture. Next. We do have a design that does allow that if you have a space that the design allows you to recess the fixture like cutting out that the design allows to recess the fixture then you are allowed to do that because as you can see with that what happens with that is the clear floor space is overlapped but the lav is not actually in the clear floor space for the toilet. If you are using a design like we do have an exception where if you are recessing it and your design does not allow or permit the use of a 36 inch lav bar then you are allowed to use a 24 inch grab bar. Next. Additionally in the 1991 standard you are always told that the door would not swing in to the clear floor space that is required for the use of any fixture. We have gone a step further now to say that because, well one of the things that we used to get questions about, well if a single user rest room and I am the only one in there why does it matter because I am going to in there only one in there with the door locked and the door cannot swing in and hit me I am the only one in there it is a single user room being used and that is a valid point and we have heard that since 1991 to 2004. But in looking at it now there was an additional concern. And that is the fact that there are many people now that do have attendants so maybe they go in to the rest room or the toilet room themselves but they do need someone to come in there at some point. What the requirements are saying now is that the door is allowed to swing in to the clear floor space for the use of a fixture as long as there is a 30 by 48 space that provided outside the step of the door. Next. Another thing that changed is what we tried to do is to get away from a lot of the absolute dimensions, so we tried to get things as a range and so what you will find is toilet from the centerline to the closest wall was 18 inches. Now you will see it is a range of 16 to 18. And another thing is the flush control valve, we have changed that in the 1991 standard it said 44. Now what you are going to see is 48 max and that is getting back to our building blocks and when you are trying to state different things in different chapters you find sometimes that you vary a little. Here was 44 but in reach ranges you were saying maximum of 48. So in accordance with that and for consistency now you would see when you look at flush valve it is required to comply with the actual reach ranges which would be a maximum of 48 inches. Next. Grab bars. In looking at grab bars one of the questions we always had is, how close can something be above the grab bar for it to still be useable. You see the big toilet paper dispensers that people stick above the grab bar so in the new standards we actually specify that there should be nothing below the grab bar for an inch and a half allow the fingers and the actual grasp of the grab bar and so to allow the arm and everything to actually use the grab bar, we are saying 12 inch minimum above the grab bar. But now we do go -- have an exception and that is because one thing assign ANSI does require 18 inch vertical grab bar. People have been confused, that is not an ADA standard requirement that is an ANSI requirement. And with the placement of where they are showing that it would be within that 12 inches. So there is an exception within the ADA standards that allows shower controls, shower fittings and other grab bars to be within one and a half inch of the grab bar. Next. What you will see with grab bars, too is that we have changed the diameter now to a quarter -- inch and a quarter to an inch and a half and that is it no longer the outside perimeter, that we had said diameter and we found that we received a lot of calls saying that we would now require a special made handrail. So we have been giving a letter from 1991 to 2004 telling people if you use IP at piping we realize that would be piping inside diameter, well we fixed it. So it is now fixed in the new guideline and we also or the new standards or we also look at different shapes of grab bar, both circular and noncircular. Next with your urinal we now give you the 17 inch max height for your elongated rim but also give you new standards with the 13 and a half because as far as for the elongated, so we just talk about the 17 inch max to the top. Now we actually give you a depth for that and additionally in the scoping in the 1991 standard any time a urinal was provided if one was provided it needed to be accessible. If in the 2010 standard only if you provide more than one that at least one is required to be accessible. Next. Children''s toilet requirements, children they have been -- we have been giving them as guidance all this time, they are now adopted as part of the new standard. What you will find is that there are ultimate specifications. So you are going to find them in a section that just deals with children and it is nothing to say that you have to. What it is saying if you are designing for children than these are the dimensions that you are allowed to use. Everything is specified in a range, in the actual text. Next. In the advisory information is there is an actual chart that broken down with age group with the exception of your grab bar specs everything else is actually in text in a range. The grab bars are only shown in the advisory language. For instance, if you look at the actual technical language for the water closet what you are going to see is that for children it should be anywhere from 12 to 18. But then you look at this chart for advisory and unless you see ages 3 to 4 is 12 and ages 5 to 8, 12 to 15, ages 9 to 12 would be 15 to 18. Next. When we look at toilet stalls there is standard stalls, one of the things that we wanted to specify is that we do realize in some states the plumbing code, building code does not require that an accessible lav be in your accessible stall. So what we have done is to say that if you have a stall that has more than one plumbing fixture, then it needs to be treated as a toilet room. So you are going to be required to have turning space and everything in that room that you will also still be required to have an accessible lav outside in the regular toilet room because in essence what you would then be having is a toilet room within a toilet room. Next. Ambulatory stall is still required. If you have six or more stalls within a bathroom that is with the parallel grab bars, the width is an absolute dimension. The width as absolute, I am sorry. Now we are actually giving you a range of 35 to 37 and we are actually giving you a depth for the first time, because we have never given a depth. Next. We look at bathing facilities next. Next. In your transfer stall, we are specifying now that grab bars can be continuous, or split. And in all of the drawings in the 1991 standards it always showed a continuance. So we had lots of questions, can this be split into two grab bars and the answer to that is yes, so we do specify that in this. We do specify as I told you filled out drawings before and you could not see where those lines were and we got a lot of questions especially with the transfer stall as to where we were measuring that 36, so we have actually clarified that within the new guidelines and you see where that is actually measured. It states it in the text, no longer just trying to judge from the picture. Next. Rolling showers with no seat. One of the things with the new standard is there was a 36 inch minimum for the clear floor space, that clear floor space is 30 inch minimum. We do specify as it was shown in the drawings we clarify that the last 10 overlap the clear floor space but what we wanted to clarify was that if you have a roll-in shower that has a seat, that has controls in place where the seat is, where that lav is has to be on the opposite side as to where that seat is located and where those controllers are located. Next. Hand spray units, the new standards say there needs to be an on/off switch and we do give a water temperature a maximum with the water temperature for that. There is an exception on monitored facilities as there was in the original guidelines. Next, seats we are working with specific guidance on the actual shape of the seats. We have guidance on rectangular seats as well as the L shaped seats. Next. The bathtub we now talk about permanent seats within the bathtub and the clear floor space that is required. If you have a permanent seat we are not saying the seat has to be permanent but if you have a bathtub that has a permanent seat we are treating it as we did with the transfer shower, now that an additional 12 inches is required to allow them maneuver to be parallel for the transfer on the seat. Next. Now we look at the residential requirements for residential dwelling units because as I mentioned the earliest in the first time in the ADA we are looking at residential developments. The guidelines set forth are primarily for state or local government housing and public accommodations, for their services, for the building for their design. Fair Housing Act is still in place for privately owned multi family dwelling units. This does not override that in any way it is just that when you have public housing facilities as well as federal facilities, these facilities need a dwelling unit requirement. And so we have a residential requirement primarily for these type of facilities. It does not override the Fair Housing Act guidelines in any way. Next. With residential we look at 5 percent of them being wheelchair accessible. People with mobility impairments, 2 percent to provide communication. We recognize some of them will be Housing and Urban Development (HUD) there are exception for 15 or fewer and then we have units for sale by a government entity. Next. In your residential units we try to clarify so there is a specific difference so that there are definitions to let you know what is considered residential versus what is considered transient lodging. Next. Assembly areas, Next. When we look at your assembly areas we did lower the scoping for assembly areas with more than 500 seats. So that instead of having the 1 percent for 501 to 5,000 seats now you have one space for every 150. If you have more than 5,000 you are looking at 50 percent. Next. When you look at your assembly area we now for the first time talk about horizontal dispersion where we are looking side to side and there is exception that if you have less than 300 seats where the wheelchair space and companion seats are placed at the second and third quarter and not at the end then you do not have that horizontal dispersion requirement. Now it is important to note two wheelchair spaces can be paired but each one is still required to have a companion seat. Next. Now we look at the vertical dispersion, vertical we are talking front to back from the performance area and the dispersion should provide a choice of admission prices comparable to those provided by for others spectators. There is an exception if you are dealing with bleachers to say that the wheelchair spaces are only required at the point of entry for your bleacher seat. Next. We look at wheelchair spaces provided and compareable the lines of sight. You look at 2 instances, one if you are designing for a type of venue that will provide seating, say you are going to theater, dinner theater, where people are in all likelihood going to be seated. Then you would be when you are designing you are looking at to ensure that your wheelchair spaces provide lines of sight over seated people. Where next, if you are at an event, say a sports event where people are going to be jumping up and down then you would be looking at your lines of sights over standing spectators when you are designing. Next. For your fire alarms what we have done is referred to NFPA 72, 1999 or 2002. Our guideline is only going to actually require you to use 110 decibels. If there is anything else you would be looking to what the NFPA writes. Next. And what NFPA requires they mandate the flash rate and pulse duration as we used to, your location wall and ceiling, the minimum intensity, they talk about larger coverage with fewer appliances, something that we try to sum up in a bulletin that we had. They talk about many other spaces other than corridors and tell you how they can be covered with appliances and synchronizing multiple appliances. All of these things are covered by NFPA and they are the people with expertise in that so there was no reason to repeat or try to pair it with their requirements so for that reason we do refer you to NFPA for fire alarms. Next. Signs, no real changes there, we still have your raised characters your Braille your visual characters and your pictogram requirements. Next. If you have a sign that is for your designated permanent room or space, no difference it has to meet the tactile requirements. If you are dealing with directional informational then it has to meet your visual requirement. Then we have the same exemption for your temporary signs, for building signs, menus, your directories, company names and logos. Next. For the first time we actually talk to you about where the signs should be placed. We always talked about to you about the height of the sign from the floor, that has changed. We have new standards now where are looking at 48 to 60 height but we now also talk about the distance from the latch side of the door. That is something we had never specified before, so there are requirements showing that 18 inch minimum from the latch side of the door. Next. Telephones, we have -- we now require volume control on all public telephone although we probably do not see a lot of public telephones any more maybe in airports or some big transportation facility, but we do require volume control on all. We do -- we have revised the scoping for the TTY to show that when we talk about interior and exterior that the scoping requirements are netted up and set aside separately and not in the 1991 standard that said if you had more than a certain number interior and exterior. Now we wanted to clarify to be sure that it was clear that these two are looked at separately and there is exception if banks are located on the same floor within two feet of each other then both are not required to have TTY. Next. And when we look at your assistive listening or in your assembly area we are no longer triggering it by fixed seating or occupant load. And we have new technical criteria that talks about the sound pressure levels, the signal-to-noise ratio and your peat clipping. Courtrooms were not in the original guidelines. So we have specifications where they are required in courtrooms where audio amplification and where it is part of the integral use of the actual space. Next. ATMs and fare machines we are looking at access to one of each type at each location. And there has been a lot of questions already which Department of Justice is working on answers to. When you are talking about exterior and people are talking about drive through and how many of these requirements would be required on one with drive in versus inside one. But at this point basically it says one of each type. These would be two different types so we would be looking at speech output, your privacy input controls, your display screens, your Braille instructions or your speech mode. Next. Two-way communication if you have two-way communication at your entrances, important to note that it has to have audible and visual signals. Next. If you have questions, this is just giving you the information. If there are questions on the standards when you are looking at your effective date what is going to be and what is not going to be covered are there any real questions with that, these are things that should be answered by the Department of Justice. Anything you need to know about the technical criteria that is the information to actually contact the U.S. Access Board and I am finished with my presentation for today and I think that Peter will be coming back on and opening it up for questions. Thank you.
Thank you very much Earlene, lots of great information. Operator can I get you to come back on and give folks connected by telephone instructions on how to ask questions? For those of you in the webinar room using audio streaming or real time captioning you can submit your questions in the chat area and hit control M and you can submit your question that way. And operator if you can give instructions to telephone participants.
Absolutely. Ladies and gentlemen if you have a question or a comment on the phone please press star and then 1 on your touch tone. Again if you have a question or comment at this time please press star and then 1. First question or comment, please go ahead.
Go ahead
Thank you Peter. Thank you, Earlene. My first question was, actually had to do with overhead number 19 where you said on the parking spaces there was an exception for the sign not required with four or fewer spaces are provided. Are you talking four total spaces or four accessible spaces?
Four total spaces.
OK
So it would be a very small parking lot, a parking lot that thad no more than four spaces.
All right and then if I can on -- I am not sure which overhead this was. It is on page 21, but it has to do with the shower spray unit. You say there is a -- the new standard requires an on/off control for the hand-held shower. Are you saying that that on/off is in addition to the actual on/off of the water?
Yes.
So it has to be an on/off on the hand-held shower itself?
Yes.
Okay. Well, that is great. thank you.
Thank you.
And I had one other lady that had a question if I can.
Okay
Real quick.
Thank you. this is not related to a particular slide but in parking lots, where there is one facility that has many buildings is there anything that gives guidance as to the distance that must exist or not exist between buildings for it to be considered or not be considered a separate parking lot or facility?
No. There is nothing that actually specifies the distance. If you had multiple facilities and there is lots surrounding each one of those we would of course say each are a lot for that particular building, but there is nothing that gives you distance. Now if you say there are lots of areas surrounding those buildings, they are are not buildings that are connected to each one of those we do say that you can add up, you would have to add up your parking by lot but then they can be placed in a lot that is closest on that accessible route. What we say it needs to be the parking that is closest on the closest accessible route to the accessible entrance but there is not a specific distance specified.
Thank you. Thank you ma''am.
All right. Next question please.
Our next question.
I do have a who wishes to address some issues here. Yes. Hi. This does not pertain to one of the technical pieces. But I am curious about the notion the idea of safe harbor and the 2010. Is there time to speak to that explain it just briefly that.
Actually, that is something that really should be addressed in the Department of Justice.
Okay.
Sorry.
Earlene let me go to a question that was submitted by someone using the audio streaming feature and if you could clarify the application of the 2010 standards again with regards to what residential housing is covered by the 2010 standards.
Well, it is going to be if you have a housing project that is owned or run by state or local government entities, if it is a federal housing facility but anything that is privately owned, no government money involved at all in the ownership of that, they are covered under the Fair Housing Act and not by the ADA standards. It would only be something that is owned by the public -- state or federal state or local federal government. Now if they have funds that are involved in it that are not -- because you could have a privately owned facility that may maybe received HUD funds, HUD does not own, but what happens with that is that HUD then makes stipulations to what guidelines need to be adhered. Right now HUD is the only federal agency that has not adopted the new standards. So right now if you had your own facility, only if HUD says you need to use these standards which you need to as the proper for privately owned, the only ones that are specifically covered are if they have owned by a state or local government entity. It could be that they built and designed them for sale and maybe the state or local government is selling them to private individuals, but when they are building them they are held to the actual requirements when building or designing them or if they are actually part of a program that the state or local government, so there has to be some state or local government money involved in the programming or in the design and ownership.
Okay. Thank you and I will get one more question from the folks using participating online. Question wants to know if you have a rest room with multiple stalls say 25 are you required to have in additional standard stall and additional ambulatory stalls for six additional stalls?
No. With the requirement right now no matter what the size of the restroom or the toilet room you are required to have the one standard stall as then if you have six or more you are required to have one ambulatory. There is not a requirement to duplicate.
Ok excellent, operator do we have another question on the telephone?
At the moment I am showing no other questions on the phone.
All right. Why do we not get another question here? Earlene a question about the clear space, the clear surface on doors and that 10 inch clear surface requirement if it only applied to exterior doors or if that was interior doors as well?
That was interior doors.
Okay. And let us see, going through here. Get another question for you online if - let us see here. Okay. Someone wants a clarification of work areas what is the difference between exit and means of egress.
Well, okay. With the means of egress your fire code or building code will tell you how many means of egress that you actually need to have out of a facility. You can have an exit but if it is not a required means of egress, then it is not required to be accessible.
Okay. Then we have a question on slide 30, and showing the clear floor space at the automatic door and whether or not the clear floor space is required to be centered on the automatic door operator.
We do not say that it needs to be. I would recommend that it be. But there is nothing that says that it needs to be. Just that it needs to be outside of the swing of the door.
All right. And we had a question from someone wanting a clarification on what is meant by scoping when you talk about the 2010 standards.
Scoping basically tells you what things need to be accessible and how many of those. Say, for instance, the toilet room, where we say 50 percent of the toilet room. That is how we are scoping it. We are saying how many. All scoping tells how many of what needs to be accessible.
Okay. And question about what is the maximum knee clearance under a table? We are talking about the fixed tables.
We have a minimum knee clearance basically knee clearance is 27 inches. If we are talking about the height -- are we talking about the height or depth? If we are talking about the height the minimum is 27. Now the maximum top of that table is 34. So depending on your thickness of your table you have your 27 inch knee clearance so anywhere from the 27 to 34 that is the maximum height of that table depending on the thickness of the table you would actually get your maximum knee clearance.
All right. Do we have any other telephone questions?
At the moment I am showing no questions but if there are any questions on the phone please press star and then 1.
Okay. Someone had a question about the two-way communication and wants to know how a -- you had an entryway and there was an individual that was deaf that needed to be buzzed in, how would they notify folks that they needed to be buzzed in to the facility?
Well it could be a matter that there is a button that they push and that would let someone on the other end know that there is somebody who needs to be buzzed in and then maybe there is a light on the end of the person that is actually deaf or hard of hearing, a light that they will see to know that now it is okay to open the door. It does not have to be anything that is verbal, it could be something that is a light for someone to actually see.
Next question. Okay. Very good, and then someone if you want to really quick address this one, someone is asking about on street parking. You talked a little bit about the public right-of-way when you talked about detectible warnings.
Well yes in the actual 2010 standards right now there is not a requirement for on street parking just as there was not in the 1991. Basically we are talking about parking in a lot. But that is something that is being addressed under the public rights of way of guideline which is still under - we did at one point we had closed the comment period but it was reopened so it is still under review right now, but it is something we are actually giving measurements and signage specifications and passenger loading an so for in the public rights of guideline.
Very good. Just one -- are able to answer this one or if it is DOJ. Asking about the definition of transient lodging, difference between the transient lodging and falling in to residential housing.
Well, within these actual standards we do have definitions for the two and it is on I believe I have them on, on slide 67. Where basically what we are saying it is residential is long term in nature and used as a residence where transient lodging is more short term in nature and not used as a permanent residence. I mean if you have a -I know in some places there may be motel hotel type facilities where if they rent long term for people to actually live there and take up residence, then that could be covered under the residential but if talking about hotel, motel, where people are going in and staying a week or a couple of days at a time that is what we are looking at with transient. Where residential would be longer term in nature.
Someone has a question regarding toilet rooms in a cluster and whether or not one must be able to view both doors at the same time and the example they give you may have to put rooms that share a common wall where the plumbing fixtures are located. In there that instance would that fit in to that exception for clusters only requiring 50 percent of the toilet rooms to be accessible?
So you that they are back to back because they are sharing the same plumbing wall and we would say that is not, they are not viewed, you cannot view them all the same or looking for cluster. They are in the same adjacent area and you are standing there and you are seeing multiple rest rooms.
Ok very good. Let me check real quick and see if we have any telephone questions before we continue on with online questions.
Showing no questions at the moment.
Alright we have a question regarding where is tactile exit signage required? Is it required at all locations where there is a lighted exit sign or only at doors that actually lead to the outside?
Only at the door that actually leads to the outside. The other signs you are talking about the lighted ones leading through the building are directional signage we would need it where it is designated the permanent space, so at the actual exit door.
All right. Okay. And somebody had a question about how would the signage requirements apply to digital signage, so say you had a digital sign that was affixed to the wall.
If you have that -- depending on what that digital sign what type of information it is giving. If it is a digital sign that is giving information only, then it does need to meet all of the visual requirements and if that digital sign cannot then there needs to be duplication of sign somewhere that meets that that gives that information. Now if it digital sign designating a permanent room or space it needs to meet the tactile and most of the time I would say a digital sign is not, so you would need a duplicate sign somewhere that meets those requirements.
Okay. Very good. Let me see if we can get -- someone wanted a clarification on the exception for parking lots with four or fewer spaces. Not being required to have signage and the question wants to know how would someone identify or be able to see the accessible parking space in that scenario.
In that scenario what the intent is and what their assumption is if you have a parking lot that only has four spaces. That is the total number of spaces. That is not the accessible. Total number of spaces in that parking lot you are standing there and you are looking at those spaces it is not going to be that difficult when you only have four spaces that you are looking at to determine which one is the larger space.
Okay. And someone has a question about, section 8.10, 8.10.5.1 slopes on transit platforms, a slope shall not exceed one to 48 in any direction and they wanted a clarification if that was pertaining to only cross slope or would that also be running slope?
That is the running slope they are talking about there.
All right.
They are talking about both. They are talking about in all directions. So they are talking about the cross slope as well as the running slope.
All right. Let us see. We have time for one more here. Someone wanted to know if would fixed booth seating in a dining area need to comply with the bench requirements.
Not the bench requirements, no. The bench requirements are specified in document are only for the areas that are scoped so we are only looking at it and addressing and fitting a locker room. It does not apply to benches that are situated anyplace else.
And there is just a last question. Someone wants to know what the status was for the public rights of way guideline. I know that they are getting closer.
You are getting closer and the comments, we are still under comment period which will be closing at the end of this month. So hopefully after the comment period closes it will not be much longer. I do not know what kind of comments they have got at this point. So it is hard to say how much longer it is going to take after it closes but as I said we ended up extending the comment period for a couple more months. That kind of slowed things up a little bit more. But we are hoping that by the end of the month when it closes that it will not be much longer. I hesitate I want to say a couple of months but I hesitate to give that. But the status right now the comment period is still open until the end of the month.
Excellent. Well thank you very much for your presentation today and all of the great information that you shared. If you still have some questions out there, if you can contact your regional ADA center by calling 800-949-4232. I failed to mention at the beginning you can read Earlines bio at the www.ada-audio.org website and that is where you can also get information about our upcoming session on February 21st. Planning a trip what you need to know about hotel reservations and revised regulations that took effect last March contains some new requirements regarding hotel reservations and we will have a presentation on that next month and as I said you can get information and register for that session by visiting the www.ada-audio.org website and an archive of this session will be available on that website in approximately two weeks time and you will find the session materials along with the archive available there in the next couple of weeks. I want to thank everyone for joining us today by either telephone or through audio streaming or using the real-time captioning. For those of you in the webinar room you can exit the webinar platform by simply closing your Internet browser. Thanks again to everyone and we look forward to hearing from you in February. Thanks Have a great day.
Thank you ladies and gentlemen for joining today''s conference. That concludes the conference. You may now disconnect. Have a good day. Speakers please stand by.