[nfbmi-talk] a d a policy

joe harcz Comcast joeharcz at comcast.net
Sat Nov 12 00:54:15 UTC 2011


Hi Jeff and All:

The following is a Great Lakes Technical Assistance Center transcript of the 
signage issue both for those who are legally blind/vissually impaired and 
others with other disabilities.

It would be great to give these to the ADA/504 coordinator for your school 
district if they have one which they are supposed to have. Regardless again 
let me know your district for I have the right to attend events and to visit 
your district as an adult member of the public. I as a blind person have the 
right to know where a restroom is and whether it is male or female. I have 
the right to go to a basketball game in your districts premises on the same 
conditions as anyone else and to know where the rooms are that I can go in 
or cannot.

I've fought for these rights of blind parents, let alone blind students in 
the built and communications environment.

I am again so outraged at the ignorance and the total deliberate 
indifference over ADA/504 basics, not by you but by the so-called educated 
and funded personnell of our public schools that I could just spit.

The rights under the Americans with Disabilities Act and of Section 504 go 
well beyond those rights afforded under the IDEA. In fact once again they 
are civil rights given under the constitution of the United States of 
America for one and all from cradle to the grave.

How absure it is for a school district not to even lable its restrooms let 
alone other permanent rooms for those who are blind? How outragious this is!

Anyway here is a relevent albeit long transcript on this issue and again the 
scoundrels should be sued if for anything else to protect the citizens of 
this country and we who are blind against utterly stupid public officials 
who haven't got a lick of common sense, let alone decency.

Joe

Permanent Rooms and Spaces: Accessible Signage - Great Lakes A D A and 
Accessible I T Center



Great Lakes ADA & Accessible IT Center



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Disability and Business Technical Assistance Centers



Permanent Rooms and Spaces: Accessible Signage

Mark Derry,

Eastlake, Derry and Associates

June 20, 2006



Presentation Materials:

List of 2 items

. Accessible Signage Presentation (PDF)

. Accessible Signage Presentation Outline (Word)

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Supplemental Materials:

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. ADAAG Section 4.30 (PDF)

. ADAAG Section 4.30 (Word)

. ADAAG/ABA Section 703 (PDF)

. ADAAG/ABA Section 703 (Word)

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Audio Transcript



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Operator: Ladies and gentlemen, thank you for standing by and welcome to the 
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.



Robin Jones: 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

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.



Mark Derry: 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 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 ICC 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.



Operator: 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.



Caller: 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?



Mark Derry: 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.



Operator: Our next question is from Rick Edwards.



Caller: 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.



Mark Derry: 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.



Caller: You say permanent designated room would be, for example in a 
conference room, conference room C, that would be generally permanent?



Mark Derry: 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?



Caller: Yeah, thank you



Operator: Next question from Ilene. Please go ahead.



Caller: Hi, can you hear me?



Mark Derry: Yes.



Caller: 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?



Mark Derry: 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?



Caller: First question had to do with stairwells.



Mark Derry: 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.



Caller: Okay, and the last one had to do with required exits.



Mark Derry: Can you send me that one in an e-mail? At ADAMarkD at aol.com, 
that's a little more complicated and I want to go through it with you. I 
need more

specifics.



Caller: OK thank you.



Mark Derry: Thank you.



Operator: Your next question is from Jim, please go ahead.



Caller: 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.



Mark Derry: Yeah they've done it for tours and things to in places like San 
Francisco.



Caller: Right. And how is that? Is that part of an ADAAG or?



Mark Derry: 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.



Caller: 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.



Mark Derry: 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.



Caller: Thanks.



Operator: Your next question is from Diana, please go ahead.



Caller: 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?



Mark Derry: 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.



Operator: Your next question is from Diana, please go ahead.



Caller: 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?



Mark Derry: 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.



Caller: Got you.



Robin Jones: OK, you want to keep going, Mark?



Mark Derry: Yes, I need to talk a little more.



Robin Jones: Great, then we'll take questions again.



Mark Derry: 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 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.



Operator: 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.



Robin Jones: 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?



Mark Derry: 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.



Robin Jones: 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.



Mark Derry: Right. It really has to be a permanent room or space that won't 
change.



Robin Jones: Correct. So a cubicle won't qualify under that definition.



Mark Derry: True.



Robin Jones: 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.



Mark Derry: 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.



Robin Jones: 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.



Mark Derry: If I was asking, I would say how long have the cubes been here? 
But it's not in ADAAG.



Robin Jones: 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.



Mark Derry: Good, Very good. Didn't know if somebody would catch me or not.



Robin Jones: So people are clear, you are using as an example of the sign, 
not of the placement.



Mark Derry: 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.



Robin Jones: So everyone is clear, the picture in number 12, that 
appropriate mounting for the sign would be on the latch side of the door.



Mark Derry: Correct.



Robin Jones: OK, just so we are all clear.



Mark Derry: 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.



Robin Jones: OK, we'll go ahead then with the telephone questions.



Operator: Your first question is from Martha. Please go ahead.



Caller: Hi. I am curious about evacuation maps that are placed near elevator 
banks. What the requirement might be for that.



Mark Derry: 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.



Operator: Your next question is from Ken. Please go ahead.



Caller: 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.



Mark Derry: 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.



Caller: What is meant by the stairwell being marked?



Mark Derry: From floor to floor. A sign on the wall that says level 1, level 
2, level 3.



Caller: Oh. You are saying that is required?



Mark Derry: 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.



Caller: 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.



Mark Derry: OK, I appreciate that. Thank you,



Caller: Some renovated subway stations where they have a yellow nose on a 
gray step, that doesn't work for us.



Mark Derry: Oh, yeah. We went through that on the PROWAAC committee on 
detectible warnings.



Caller: 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?



Mark Derry: 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.



Caller: Not high contrast, that's the problem.



Mark Derry: Yeah.



Caller: Thanks.



Operator: Your next question is from Ilene. Please go ahead.



Caller: 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?



Mark Derry: 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.



Caller: 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?



Mark Derry: 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 at aol.com. I will 
be happy to try to get you an answer.



Robin Jones: Just to go a little slower on that, its ADAmarkd at 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.



Mark Derry: Can I add a little to that?



Robin Jones: Sure.



Mark Derry: Hopefully without confusing. However, if you are looking, 
working, on a GSA site



Robin Jones: Can you give us some clarification on GSA, people may not know.



Mark Derry: 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 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.



Robin Jones: 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.



Operator: Your next question comes from a captioner. Please go ahead.



Caller: I was asked to ask, what are Braille chips?



Mark Derry: 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.



Robin Jones: Next question, please.



Operator: Your next question comes from Jim. Please go ahead.



Caller: 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?



Mark Derry: 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?



Robin Jones: 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.



Mark Derry: 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.



Robin Jones: 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.



Operator: Your next question is from Lynette. Please go ahead.



Caller: 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?



Mark Derry: 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.



Robin Jones: 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.



Caller: Just the actual entrance?



Robin Jones: 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.



Caller: Right. OK. Thank you.



Robin Jones: 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.



Mark Derry: www.adaderry.com.



Robin Jones: That will get you to the signage information, correct?



Mark Derry: Yes, a link from there to our e-commerce site, 
eastlakederry.com.



Robin Jones: 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.

Last Updated on: Thu Jun 29, 2006

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Great Lakes ADA & Accessible IT Center (MC 728) · Room 405· 1640 W. 
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The contents of this website were developed under a grant from the U.S. 
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endorsement by the Federal government. The contents are solely the 
responsibility of the Great Lakes ADA & Accessible IT Center and do not 
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----- Original Message ----- 
From: "jeff crouch" <jeffanel at gmail.com>
To: "NFB of Michigan Internet Mailing List" <nfbmi-talk at nfbnet.org>
Sent: Friday, November 11, 2011 6:30 PM
Subject: [nfbmi-talk] a d a policy


> Hello
> Just a question.
>
> Is there a policy in the a d a that states that doors have to be
> marked with some way for a blind person to know what the door is for.
> If so, do schools have to comply with this, and how do i present this
> to my school, a set of rest rooms are not marked, a hand fool of class
> rooms are not marked, I have walked in to rong classes because of
> this. Can any one help? I would be happy.
>
> happy haladay
>
>
> -- 
> jeff crouch
>
> _______________________________________________
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