Long.  Shows complexity of standardization issues.


Date:    Sat, 19 Feb 2000 21:26:16 -0500
From:    Angela Van Etten <[log in to unmask]
Subject: Re: JFA -- DREDF Action Alert: ADAAG Revised Completely (II)

Randy:

The source for my reference to 300,000 wheelchair users with limited
upper
body
movement (i.e. 20% of 1.5 million)
is the Federal Register during the initial ADAAG rulemaking in 1991 and
1992.

Source: July 26, 1991 Fed. Reg. comments (56 FR 35408, 35430); May 6,
1992
Fed.
Reg. comments (57 FR 19472); Sept. 8, 1992 Fed. Reg. comments (57 FR
41006)
of
disability groups.

I tried to go back on the net to pull the exact quotation from the July
26,
1991
and May 6, 1992 Fed Reg, but unfortunately the Fed Reg is only on line
as
far
back as 1995.  However, I do have an electronic file of the Sept. 8,
1992
Fed
Reg as shown below:

"Research sponsored by the [Access] Board in the 1980's tested the reach
of
wheelchair users in both laboratory and field conditions and found that
more
than 20% of the persons tested could not reach devices above 48 inches
with
the
exception of devices that required a flat hand push or finger push and
1.5
lb.
or less force to operate. E. Steinfield, "Hands-On Architecture" Volume
3,
Part
II, 9(1986)." Source: 57 FR 41006 (September 8, 1992)

"Human engineering data compiled by Henry Dreyfuss Associates shows that
from a
parallel approach, a short female wheelchair user (58.3 inches height)
can
reach
53 inches vertically and 48.5 inches over a 12 inch obstruction and a
tall
male
wheelchair user (73.6 inches height) can reach 71.2 inches vertically
and
67.7
inches over a 12 inch obstruction. Henry Dreyfuss Associates,
"Humanscale 1,
2,
3" Selector 3a (1974). Henry Dreyfuss Associates notes that these
maximum
reaches are valid only for wheelchair users who are capable of full arm
movement
and estimates this group to be 42% of all wheelchair users. Id at 26.
Henry
Dreyfuss Associates recommends a "handy reach zone" between 36 inches
and 48
inches above the floor as accommodating a larger percentage of
wheelchair
users." Source: 57 FR 41006 (September 8, 1992)


  Randy Fisher

   -----Original Message-----
   From: Angela Van Etten [SMTP:[log in to unmask]]
   Sent: Wednesday, February 16, 2000 8:59 PM
   To:   [log in to unmask]
   Subject:      Re: JFA -- DREDF Action Alert: ADAAG Revised Completely
(II)

   I just received the DREDF Action Alert on the ADAAG Revisions and
support
[1]   DREDF'S position that we appeal to the Access Board to lower the
   unobstructed side reach range from 54" to 48".

   I write from the perspective of an individual with dwarfism (also
known
as
   a
   Little Person) and stand at 3 feet 4 inches. Little People share an
access
   problem with many wheelchair users. Sitting or standing the effect is
the
   same
   -- more than 300,000 of us can't reach 54." Indeed 80% of individuals
with
   dwarfism can't reach 54" and I'm told that 20% of the individuals who
use
   wheelchairs -- i.e. those with limited upper body movement -- are
being
   denied
   access to many critical elements in public facilities.

   This means that we are denied equal access to ATMs, elevators, public
   phones,
   credit card readers at gas pumps, vending machines, and automatic
ticket
   dispensers. You name it, we can't reach it!

   Because the Access Board is seeking public comments on its proposal
to
   revise
   ADAAG, we have a rare opportunity to submit comments that the agency
is
   obliged
   to consider. We need to persuade the Access Board that the
unobstructed
   side
   reach of 54" (ADAAG 308.3.1) is inaccessible for both wheelchair
users
and
   Little People and should be lowered to 48."

   Please be encouraged by the experience of LPA as a delegate on the
   ICC/ANSI
   A117.1 Committee on Accessible and Usable Buildings and Facilities.
   Against all
   odds, LPA proposed and successfully advocated lowering the
unobstructed
   side
   reach range from 54" to 48" in the ANSI standard that was published
in
   1998.
   Long time ANSI Committee members report that this is the biggest
change
in
   ANSI
   in more than 20 years! A change of this magnitude does not come
easily,
   but it
   is possible.

   However, I regret to advise that LPA was unsuccessful in persuading
the
   Access
   Board to propose 48" in its Notice of Proposed Rulemaking. The Access
   Board is
   proposing a 54" side reach range despite the recommendation of its
   Advisory
   Committee that the side reach should only be 48." LPA is convinced,
   therefore,
   that if there is to be any hope of persuading the Access Board to
lower
   the side
   reach to 48" lots of comments favoring 48" need to come from
individuals
   with
   other disabilities, especially from wheelchair users. If LPA stands
alone
   on the
   issue of the 48" side reach range, we believe that the Access Board
will
   continue to disregard the access concerns of Little People. Our
   constituency is
   simply "too small" to stand against the powerful lobby of the
banking,
   building,
   and oil industries.

   Because LPA believes that lowering the side-reach range to 48" not
only
   benefits
   Little People, but hundreds of thousands of other people with
   disabilities, we
   join DREDF in asking you to PLEASE TAKE TIME OUT TO WRITE TO THE
ACCESS
   BOARD
   BEFORE MARCH 15TH i.e. the comment closing date. Mail letters to the
   Office of
   Technical and Information Services, Architectural and Transportation
   Barriers
   Compliance Board, 1331 F Street, NW., Suite 1000, Washington, DC
   20004-1111, OR
   e-mail comments to [log in to unmask], but only if you include
your
   full
   name and address in the message text, OR fax comments to (202)
272-5447.

   For those still with me and preparing to write to the Access Board,
please
   allow
   me to share some reasons why the unobstructed side reach should be
48"

   1. It would meet Congress ADA goal with regard to individuals with
   disabilities
   of "assuring equality of opportunity, full participation, independent
   living,
   and economic self-sufficiency . . ." (42 U.S.C. 12101(a)(8));

   2. It would increase independent use of public facilities by the
estimated
   300,000 wheelchair users with limited upper body movement (i.e. 20%
of
1.5
   million);

   3. It would provide uniformity in access codes across the country
i.e.
   providing
   the same access standard in both federal (ADAAG) and state codes
(i.e.
in
   states
   adopting ICC/ANSI A117.1-1998 or other model codes), Confusion and
   inconsistent
   enforcement could be eliminated.

   4. It would follow the recommendation of the Access Board Federal
Advisory
   Committee that the side reach range be changed to 48" based on its
   understanding
   that this height is preferable for people who use wheelchairs and
   necessary to
   be within reach of Little People.

   5. Forty-eight inches is technically feasible since industry has 23
years
   experience meeting a 48" standard (both ADAAG and ANSI currently
require
   48" for
   a forward reach);

   6. The Access Board does not dispute that 48" is the most accessible
   height for
   the unobstructed side reach range (see Preamble to the NPRM); and

   7. The banking industry has been on notice since ADAAG was published
in
   1991
   that a 54" side reach is not readily accessible to and usable by
thousands
   of
   wheelchair users. They have known since 1993 that a 48" side reach is
   needed by
   Little People. Just because industry has chosen not to use the last
eight
   and a
   half years to come up with an accessible solution, does not mean that
the
   Access
   Board should continue to delay imposing an accessible standard.

   LPA invites you to join with us in advocating for a 48" side reach
   standard i.e.
   a standard that accommodates the access needs of people with
disabilities
   rather
   than the profit margins of big business.

   Angela Van Etten
   LPA Delegate to the ICC A117.1 Committee on Accessible and Usable
   Buildings and
   Facilities
   [log in to unmask]; (561) 781-6153 phone; (561) 781-9179 fax

   P.S.

   Please send a copy of your letter to your congressional
representative
and
   U.S.
   Senator. Be sure that the Access Board knows you have done this, by
adding
   cc:
   next to their names at the bottom of the letter. (You will find their
   names in
   the blue pages or government section of the phone book or at the
public
   library.) If you have time, please consider hand-delivering a copy of
your
   letter to your local Senator or Congressional representative. Ask
them
to
   call
   the Access Board to remind them of their obligation under the ADA to
   provide
   access for all!



  _____

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