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Subject:
From:
Jamal Mazrui <[log in to unmask]>
Reply To:
Jamal Mazrui <[log in to unmask]>
Date:
Wed, 10 May 2000 21:48:19 -0400
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From the web page
http://www.afb.org/grg/adaagmem.html

American Foundation for the Blind

Outline of Major Revisions to Americans with Disabilities Act
Accessibility Guidelines of Interest to People Who Are Blind or
Visually Impaired

This document provides a brief description of the proposed
changes to the (ADAAG) of particular interest to people who are
blind or visually impaired. The full text of the proposed
revision can be found at
http://www.access-board.gov/ada-aba/guidenprm.htm. Additionally,
the full text of the current ADAAG can be found at
http://www.access-board.gov/bfdg/adaag.htm.

**The deadline for comments on the proposed changes has been
extended to May 15**, and should be submitted to the Access
Board at:

Office of Technical and Information Services
Architectural and Transportation Barriers Compliance Board
1331 F Street, NW., suite 1000
Washington, DC 20004-1111

E-mail comments should be sent to [log in to unmask]
Comments sent by e-mail will be considered only if they include
the full name and address of the sender in the text. Comments
will be available for inspection at the above address from 9:00
a.m. to 5:00 p.m. on regular business days.

The Americans with Disabilities Act of 1990 (ADA) (42 U.S.C.
12101 et seq.) recognizes and protects the civil rights of
people with disabilities and is modeled after earlier landmark
laws prohibiting discrimination on the basis of race and gender.
The ADA requires that buildings and facilities be accessible to
and usable by people with disabilities. The ADA establishes
accessibility requirements for new construction and alterations
of State and local government facilities under title II and
places of public accommodation and commercial facilities under
title III. The law requires that the Access Board issue minimum
guidelines to assist the Department of Justice (DOJ) and the
Department of Transportation (DOT) in establishing accessibility
standards under titles II and III. These standards must be
consistent with the Access Board's guidelines.

Although there are a variety of issues of interest to people who
are blind or visually impaired in ADAAG, topics treated below
have been grouped into three major issue areas: Automatic Teller
Machines and Fare Machines; Detectible Warnings; and Signs. The
proposed ADAAG sections outlined below are of two types: ADA
Scoping requirements which define and describe what is and is
not covered by the rules; and ADA Technical Requirements which
describe in detail the methods and architectural specifications
to be used to meet the scoping requirements. Major
blindness-related ADAAG revisions to both scoping and technical
requirements are set forth below, along with questions that the
Access Board is asking commenters to specifically address. The
sections highlighted below make substantial use of cross
references both within each section and among sections, and
readers are encouraged to consult ADAAG directly via the web
addresses provided above. Commenters are also encouraged to
provide favorable comment to the Access Board regarding those
revisions appreciated by commenters, as well as critical
comments on provisions that commenters disfavor. Note that, in
several instances, ADAAG provisions are labeled "advisory",
meaning that they do not enjoy a mandatory status. Commenters
should refer specifically to these advisory provisions and
comment on whether such provisions should be made mandatory.
Sections labeled "NOTE" below are offered to provide further
suggestions for commenters.

Topic 1: Automatic Teller Machines and Fare Machines

ADA Scoping. Section 220. Automatic Teller Machines and Fare
Machines

Although this provision specifically requires automatic teller
machines to be accessible, this provision now addresses "fare
vending, collection, or adjustment machines," which have
heretofore only been addressed by ADAAG where they are provided
in transportation facilities. This revised section reads as
follows:
     220 Automatic Teller Machines and Fare Machines

     220.1 General. Where automatic teller machines or
     self-service fare vending, collection, or adjustment
     machines are provided, at least one machine of each
     type at each location where such machines are provided
     shall comply with 707. [omission]
NOTE: Commenters may wish to provide feedback regarding the
widening of this scoping requirement to include fare collection
and other machines. Additionally, commenters will want to give
attention to question 31 below.

ADA Technical Requirements. Section 707. Automatic Teller
Machines and Fare Machines

New specifications are provided so that access to input and
output devices is provided for people with vision impairments.
These requirements provide clearer guidance than ADAAG 4.34.5
which requires instructions and all information for use to be
"accessible to and independently usable by persons with vision
impairments." Arrangement and tactile qualities are standardized
for uniformity to facilitate use by people with little or no
vision. The revised section reads as follows:
     707 Automatic Teller Machines and Fare Machines

     707.1 General. Automatic teller machines and fare
     machines required to be accessible shall comply with
     707.

     Advisory 707.1: If farecards have one tactually
     distinctive corner they may be inserted with greater
     ease. Token collection devices that are designed to
     accommodate tokens which are perforated can allow a
     person to distinguish more readily between tokens and
     common coins. Place accessible gates and fare vending
     machines in close proximity to other accessible
     elements when feasible so the facility is easier to
     use. [end of advisory]

     [omission]

     707.3 Operable Parts. Operable parts shall comply with
     309. Each operable part shall be able to be
     differentiated by sound or touch without activation.

     EXCEPTION: Drive-up only automatic teller machines
     shall not be required to comply with 309.2 and 309.3.

     707.4 Input. Input devices shall comply with 707.4.

     707.4.1 Privacy. The opportunity for the same degree
     of privacy of input shall be available to all
     individuals utilizing the equipment.

     707.4.2 Key Surfaces. All keys used to operate a
     machine shall be tactually discernible. Key surfaces
     shall be raised above the surrounding surface by 1/25
     inch (1 mm) minimum. The outer edge of key surfaces
     shall have a radius of 1/50 inch (0.5 mm) maximum.

     EXCEPTION: The touch areas of video display screens
     shall not be required to be tactually discernible.

     707.4.3 Separation Between Keys. Any key surface shall
     be separated from other key surfaces by 1/8 inch (3.2
     mm) minimum. Function keys shall be separated from
     numeric keys by a distance that is not less than three
     times greater the distance between the numeric keys.

     707.4.4 Numeric Keys. Where provided, numeric keys
     shall comply with 707.4.4.1 and 707.4.4.2.

     707.4.4.1 Arrangement. Numeric keys shall be arranged
     in a 12-key telephone keypad layout with the number
     one key in the upper left hand corner.

     707.4.4.2 Marking. The number five key shall have a
     single raised dot.

     707.4.5 Function Keys. Where provided, function keys
     shall comply with 707.4.5.

     707.4.5.1 Arrangement. Function keys shall be arranged
     in the order of enter, clear, cancel, add value and
     decrease value horizontally from left to right or
     vertically from top to bottom. Where provided, add
     value and decrease value function keys shall be
     grouped with other function keys.

     707.4.5.2 Marking. Function keys shall be marked with
     tactile characters as follows: Enter or proceed key:
     raised circle; Clear or correct key: raised vertical
     line or bar; Cancel key: raised ex; Add value key:
     raised plus sign; Decrease value key: raised minus
     sign.

     707.4.5.3 Color Coding. Where function keys are color
     coded, they shall be colored as follows: Enter or
     proceed key: green; Clear or correct key: black;
     Cancel key: red; Add value key: blue; Decrease value
     key: yellow.

     707.5 Output. Output devices shall comply with 707.5.

     Advisory 707.5: Speech output should be supplied for
     all displayed text and labels. For information which
     is presented in non-text form (e.g., a picture or
     graphic), consider using a verbal description unless
     the graphic is just decorative. When speech output is
     utilized, allow for the spoken message to be repeated
     if the message is very long. [end of advisory]

     707.5.1 Privacy. The opportunity for the same degree
     of privacy of output shall be available to all
     individuals utilizing the equipment.

     707.5.2 Transaction Prompts. All transaction prompts
     within each operation shall be provided.

     707.5.3 Input Verification. Verification of all user
     inputs shall be provided.

     Advisory 707.5.3: An audible beep may be used to
     indicate that personal identification numbers have
     been entered. [end of advisory]

     707.5.4 Operating Instructions. Machines shall provide
     visual and audible instructions for operation. Visual
     and audible instructions shall include all information
     required by 707.5.4.

     707.5.4.1 Initiation. Instructions shall be able to be
     initiated by the user of the machine.

     707.5.4.2 Expedited Process. After initiation,
     instructions shall be available for the experienced
     user to expedite the transaction.

     707.5.4.3 Orientation. Orientation and assistance for
     unfamiliar users to the physical features of the
     machine, operational options, and details for each
     function shall be provided.

     707.5.5 Audible Instruction. Audible instructions
     shall be provided through a standard audio mini jack,
     a telephone handset, a wireless transmission system or
     another mechanism that is readily available to all
     customers.

     707.5.6 Video Display Screen. The video display screen
     shall comply with 707.5.6.

     Advisory 707.5.6: For video display screens required
     to be accessible, the screen should be visible and
     usable by persons standing and sitting. [end advisory]

     707.5.6.1 Visibility. The screen shall be visible from
     a point located 40 inches (1015 mm) above the center
     of the clear floor space in front of the machine.

     EXCEPTION: This requirement shall not apply to
     drive-up only automatic teller machines.

     707.5.6.2 Characters. Characters displayed on the
     screen shall be in a sans serif font. Characters shall
     be 3/16 inch (4.8 mm) minimum in height based on the
     uppercase letter "I". Characters shall contrast with
     their background with either light characters on a
     dark background or dark characters on a light
     background.

     707.5.7 Dispensing of Bills. Machines that dispense
     paper currency shall dispense the currency in
     descending order with the lowest denomination on top.

     707.5.8 Receipts and Verification. Where a receipt is
     available and is requested, the following options
     shall be provided: a printed receipt, audible
     presentation of the transaction information provided
     on the receipt, or both.
NOTE: Commenters may wish to provide input on the frequent
Advisory notes in section 707 above, especially 707.5 regarding
speech output. Additionally, commenters should address the
following question directly.
     Question 31: While section 707 specifically addresses
     "automatic teller machines" and "fare vending
     machines," the Board is considering covering all types
     of interactive transaction machines, such as
     point-of-sale machines and information kiosks, among
     others. Information is requested on any possible
     design conflicts between the requirements of this
     section and any specific types of interactive
     transaction machines. The final rule may be modified
     to specifically address unique characteristics of
     certain types of interactive transaction machines.
NOTE: In addressing this question, commenters may wish to
provide comment on the Access Board's consideration of coverage
for this wide range of equipment.

NOTE: In addition, commenters may wish to provide the Access
Board with input on a related issue. Although other types of
interactive equipment, such as laundry equipment and vending
machines generally are covered by ADAAG and must be compliant
with reach range and other accessibility requirements, such
equipment is not similarly required to be made accessible to and
usable by people who are blind or visually impaired through the
use of tactile or differentiated controls and/or audible
prompts.
     Question 34: The Board seeks comment on whether ATM
     manufacturers or banks intend to provide customers who
     need audio output receivers for accessing audible
     output [as written]. In addition, the Board seeks to
     know if customers would or currently do carry
     receivers or if they view providing their own
     receivers as an unreasonable expectation.
NOTE: This question addresses the responsibility to provide
headsets or other devices to be used with machines complying
with the new rules. Commenters may wish to address whether they
believe customers should bear this burden.

Topic 2: Detectible Warnings

ADA Technical Requirements Section 406, Curb Ramps

In 1996 the Access Board and the Departments of Justice and
Transportation extended the suspension of the detectable warning
requirements at intersections to July 26, 1998, to allow the
Board's ADAAG Review Advisory Committee to conduct its review of
ADAAG and to make recommendations for revising and updating the
document. The suspension has been extended to July 26, 2001. The
advisory committee recommended that the requirement for
detectable warnings at platform edges in transportation
facilities be retained.

ADA Technical Requirements Section 705, Detectable Warnings

The technical criteria for detectable warnings are consistent
with those in ADAAG 4.29 and those required on the boarding
platforms of transit stations in ADAAG 10.3.1(8). Provisions
have been added concerning boarding platforms that generally
recognize alternative tactile surfaces equally detectable
underfoot or other designs or technologies that provide equal or
superior drop-off warning. The revised section reads as follows:
     705 Detectable Warnings

     705.1 General. Detectable warnings required on
     platform edges shall comply with 705.2, 705.3 or
     705.4.

     705.2 Truncated Domes. A 24-inch (610 mm) wide
     truncated dome surface complying with 705.2 shall be
     provided on the walking surface at the platform edge.

     705.2.1 Dome Size. Domes shall have a diameter of 0.9
     inch (23 mm), a height of 0.2 inch (5 mm) and a
     center-to-center spacing of 2.35 inches (60 mm).

     705.2.2 Contrast. The truncated dome surface shall
     contrast visually with adjoining walking surfaces
     either light-on-dark, or dark-on-light. The material
     used to provide contrast shall be an integral part of
     the truncated dome surface.

     705.2.3 Interior Locations. Detectable warnings in
     interior locations shall differ from adjoining walking
     surfaces in resiliency or sound-on-cane contact.

     705.3 Equivalent Tactile Surface. A 24 inch (610 mm)
     wide tactile surface shall be provided on the walking
     surface at the platform edge. The tactile surface
     shall provide equivalent detectability underfoot to
     that provided by 705.2.1 and shall provide contrast in
     accordance with 705.2.2.

     705.4 Equivalent Detectability. Equivalent
     detectability of the platform edge by other
     construction, technology, or means that will ensure
     equivalent or superior and reliable communication of
     the impending change to pedestrians who are blind or
     visually impaired shall be permitted. The information
     to be communicated must include 24 inches (610 mm) of
     advance warning of the platform edge and the precise
     orientation of the platform edge in relation to the
     pedestrian.
NOTE: Commenters may wish to offer their sense of the adequacy
of these provisions to ensure safety for blind and visually
impaired pedestrians.

Topic 3: Signs

ADA Scoping. Section 216. Signs

This provision retains the substance of scoping for exterior and
interior signs in ADAAG 4.1.2(7) and 4.1.3(16). Several
editorial changes are included for clarification. Scoping for
tactile signs is modified to apply to "permanent" room or space
designations in order to clarify coverage of signs that are not
likely to change. The Board has added an exception stating that
signs designating building addresses or names are not required
to meet requirements for tactile signs.
     216.1 General. Signs shall be provided in accordance
     with 216 and shall comply with 703.

     EXCEPTION: In detention and correctional facilities,
     signs not located in public use areas shall not be
     required to comply.

     216.2 Permanent Designations. Where exterior signs are
     provided as permanent designations of permanent
     interior rooms and spaces at the door to the space
     they serve, the signs shall be tactile and shall
     comply with 703.2. Where interior signs are provided
     as permanent designations of permanent interior rooms
     and spaces, the signs shall be tactile and shall
     comply with 703.2. Where pictograms are provided as
     permanent designations of permanent interior rooms and
     spaces, the pictograms shall comply with 703.6 and
     shall have tactile text descriptors complying with
     703.2.

     Advisory 216.2: "Permanent designations" label
     interior rooms or spaces where the designation is not
     likely to change over time. Examples include, interior
     signs labeling restrooms, room and floor numbers or
     letters, and room names. Tactile text descriptors are
     required for pictograms that are provided to label or
     identify a permanent room or space. Pictograms that
     provide information about a room or space, such as "no
     smoking," occupant logos, and accessibility
     designations, are not required to have text
     descriptors. [end advisory]

     EXCEPTION: This requirement shall not apply to signs
     used to designate building addresses or building or
     facility names.

     216.3 Directional and Informational Signs. Signs that
     provide direction to or information about permanent
     interior spaces and facilities of the site shall
     comply with 703.4.

     Advisory 216.3: Information about a permanent room or
     space includes rules of conduct, occupant load, and
     similar signs. Signs providing direction to permanent
     rooms or spaces include those that identify egress
     routes. [end advisory]

     EXCEPTION: Building directories, menus, and temporary
     signs are not required to comply with 703.4.

     216.4 Exit Doors. Exit doors shall be identified by
     tactile signs complying with 703.2. ADA Technical
     Requirements Section 703, Signs.
NOTE: Commenters may want to address the advisory section 216.2
above in that, for the first time, the requirements for sign
accessibility would be extended to signs bearing room names.
Based upon an old opinion letter issued by the Department of
Justice, only signs bearing room numbers were deemed to be
required to be accessible. This advisory provision, if made
mandatory, would change the effect of that opinion and provide
greater access.

ADA Technical Requirements. Section 703. Signs
     703.1 General. Signs required to be accessible shall
     comply with 703.

     703.2 Characters that are Both Tactile and Visual.
     Characters required to be tactile shall comply with
     703.2. Tactile characters shall be duplicated in
     Braille complying with 703.5.

     EXCEPTION: Tactile characters shall be permitted to
     comply with 703.3, where separate visual characters
     complying with 703.4 provide the same information.

     703.2.1 Finish and Contrast. Characters and their
     background shall have a non-glare finish. Characters
     shall contrast with their background with either light
     characters on a dark background or dark characters on
     a light background.

     703.2.2 Tactile Characters. Tactile characters shall
     be raised 1/32 inch (0.8 mm) minimum above their
     background. Raised borders and decorative elements
     that are not required shall be separated 3/8 inch (9.5
     mm) minimum from tactile characters.

     703.2.3 Character Forms. Fonts shall have characters
     complying with 703.2.3.

     703.2.3.1 Case. Characters shall be uppercase.

     703.2.3.2 Style. Characters shall be sans serif.
     Characters shall not be italic, oblique, script,
     highly decorative, or of other unusual forms.

     703.2.3.3 Width. Character width shall be 55 percent
     minimum and 110 percent maximum the height of the
     character with the width based on the uppercase letter
     "O" and the height based on the uppercase letter "I".

     703.2.3.4 Height. Character height measured vertically
     from the baseline of the character shall be 5/8 inch
     (16 mm) minimum and 2 inches (51 mm) maximum based on
     the uppercase letter "I".

     703.2.3.5 Stroke Thickness. For characters with
     rectangular cross sections, the stroke thickness of
     the uppercase letter "I" shall be 10 percent minimum
     and 15 percent maximum of the height of the character.
     For characters with other cross sections, the stroke
     thickness of the uppercase letter "I" shall be 10
     percent minimum and 30 percent maximum of the height
     of the character measured at the base of the cross
     section. Stroke thickness at the top of the cross
     section shall be 15 percent maximum of the height of
     the character.

     703.2.4 Character Spacing. Character spacing shall be
     measured between the two closest points of adjacent
     characters within a message, excluding word spaces.
     Where characters have rectangular cross sections,
     spacing between individual characters shall be 1/8
     inch (3 mm) minimum to 3/8 inch (10 mm) maximum. Where
     characters have other cross sections, spacing between
     individual characters shall be 1/16 inch (2 mm)
     minimum to 3/8 inch (10 mm) maximum at the base of the
     cross sections and 1/8 inch (3 mm) to 3/8 inch (10 mm)
     maximum at the top of the cross sections.

     703.2.5 Line Spacing. Spacing between the baselines of
     separate lines of characters in a sentence or
     paragraph shall be 135 percent minimum and 170 percent
     maximum of the character height.

     703.2.6 Mounting Height. Characters shall be located
     48 inches (1220 mm) minimum and 60 inches (1525 mm)
     maximum above the adjacent floor or ground surface
     measured from the baseline of the characters.

     EXCEPTION: This requirement shall not apply to
     elevator car controls.

     703.2.7 Mounting Location. Where a sign containing
     tactile characters is provided at a door, the sign
     shall be located alongside the door at the latch side.
     Where a tactile sign is provided at double doors, the
     sign shall be located to the right of the right hand
     door. Where there is no wall space at the latch side
     of a single door or to the right side of double doors,
     signs shall be located on the nearest adjacent wall.
     Signs containing tactile characters shall be located
     so that a clear floor space of 18 inches (455 mm)
     minimum by 18 inches (455 mm) minimum, centered on the
     sign, is provided beyond the arc of any door swing
     between the closed position and 45 degree open
     position.

     EXCEPTION: Signs shall be permitted on the push side
     of doors with closers and without hold-open devices.

     703.3 Tactile Characters. Where tactile characters are
     required and separate tactile and visual characters
     with the same information are provided, tactile
     characters shall comply with 703.3 and visual
     characters shall comply with 703.4. Tactile characters
     shall be duplicated in Braille complying with 703.5.

     703.3.1 Tactile Characters. Tactile characters shall
     be raised 1/32 inch (0.8 mm) minimum above their
     background. Raised borders and decorative elements
     that are not required shall be separated 3/8 inch (9.5
     mm) minimum from tactile characters.

     703.3.2 Character Forms. Fonts shall have characters
     complying with 703.3.2.

     703.3.2.1 Case. Characters shall be uppercase.

     703.3.2.2 Style. Characters shall be sans serif.
     Characters shall not be italic, oblique, script,
     highly decorative, or of other unusual forms.

     703.3.2.3 Width. Character width shall be 55 percent
     minimum and 110 percent maximum the height of the
     character with the width based on the uppercase letter
     "O" and the height based on the uppercase letter "I".

     703.3.2.4 Height. Character height measured vertically
     from the baseline of the character shall be 1/2 inch
     (13 mm) minimum and 3/4 inch (19 mm) maximum based on
     the height of the uppercase letter "I".

     703.3.2.5 Stroke Thickness. Stroke thickness of the
     uppercase letter "I" shall be 15 percent maximum of
     the height of the character.

     703.3.3 Character Spacing. Character spacing shall be
     measured between the two closest points of adjacent
     character within a message, excluding word spaces.
     Spacing between individual characters shall be 1/8
     inch (3 mm) minimum to 1/4 inch (6 mm) maximum.

     703.3.4 Line Spacing. Spacing between the baselines of
     separate lines of characters within a message shall be
     135 percent minimum and 170 percent maximum of the
     character height.

     703.3.5 Mounting Height. Characters shall be located
     48 inches (1220 mm) minimum and 60 inches (1525 mm)
     maximum above the adjacent floor or ground surface,
     measured from the baseline of the characters.

     EXCEPTION: This requirement shall not apply to
     elevator car controls.

     703.3.6 Mounting Location. Where a tactile sign is
     provided at a door, the sign shall be located
     alongside the door at the latch side. Where a tactile
     sign is provided at double doors, the sign shall be
     located to the right of the right hand door. Where
     there is no wall space at the latch side of a single
     door or to the right side of double doors, signs shall
     be located on the nearest adjacent wall. Signs
     containing tactile characters shall be located so that
     a clear floor space of 18 inches (455 mm) by 18 inches
     (455 mm) minimum, centered on the sign, is provided
     beyond the arc of any door swing between the closed
     position and 45 degree open position.

     EXCEPTION: Signs shall be permitted on the push side
     of doors with closers and without hold-open devices.

     703.4 Visual Characters. Visual characters required to
     be accessible shall comply with 703.4.

     703.4.1 Finish and Contrast. Characters and their
     background shall have a non-glare finish. Characters
     shall contrast with their background with either light
     characters on a dark background or dark characters on
     a light background.

     Advisory 703.4.1: Signs are more legible for persons
     with low vision when characters contrast with their
     background by approximately 70 percent. Contrast in
     percent can be determined by: contrast =[(B1-B2)/B1] x
     100 where B1=light reflectance value (LRV) of the
     lighter area and B2=light reflectance value (LRV) of
     the darker area. Note: in any application both white
     and black are never absolute; thus B1 never equals 100
     and B2 is always greater than zero. [end advisory]

     703.4.2 Character Forms. Fonts shall have characters
     complying with 703.4.2.

     703.4.2.1 Case. Characters shall be uppercase or
     lowercase or a combination of both.

     703.4.2.2 Style. Characters shall be conventional in
     form. Characters shall not be italic, oblique, script,
     highly decorative, or of other unusual forms.

     703.4.2.3 Width. Character width shall be 55 percent
     minimum and 110 percent maximum the height of the
     character with the width based on the uppercase letter
     "O" and the height based on the uppercase letter "I".

     703.4.2.4 Height. Minimum character height measured
     from the baseline of the character shall comply with
     Table 703.4.2.4 based on the height of the characters
     above the finished floor of the viewing location and
     the minimum viewing distance. Character height shall
     be based on the uppercase letter "I". Minimum viewing
     distance shall be measured as the horizontal distance
     where an obstruction prevents further approach towards
     the sign.

     Table 703.4.2.4 Visual Character Dimensions
       * Height of Floor to Baseline of Character: Minimum
         Viewing Distance; Minimum Character Height
       * Less than 40 inches (100 mm)(not permitted except
         in elevators)
       * 40 inches (100 mm) to less than or equal to 70
         inches (1780 mm): less than 6 feet (1830 mm); 5/8
         inch (16 mm)
       * 40 inches (100 mm) to less than or equal to 70
         inches (1780 mm): 6 feet (1830 mm) and greater;
         5/8 inch (16 mm), plus 1/8 inch (3.2 mm) per foot
         (305 mm) of viewing distance above 6 feet (1830
         mm)
       * 70 inches (1780 mm) to less than or equal to 120
         inches (3050 mm): less than 15 feet (4570 mm); 2
         inches (51 mm)
       * 70 inches (1780 mm) to less than or equal to 120
         inches (3050 mm): 15 feet (4570 mm) and greater; 2
         inches (51 mm), plus 1/8 inch (3.2 mm) per foot
         (305 mm) of viewing distance above 15 feet (4570
         mm).
       * Greater than 120 inches (3050 mm); less than 21
         feet (6400 mm): 3 inches (75 mm)
       * Greater than 120 inches (3050 mm); 21 feet (6400
         mm) and greater: 3 inches (75 mm), plus 1/8 inch
         (3.2 mm) per foot (305 mm) of viewing distance
         above 21 feet (6400 mm). (End of Table 703.4.2.4)

     703.4.2.5 Stroke Thickness. Stroke thickness of the
     uppercase letter "I" shall be 10 percent minimum and
     30 percent maximum of the height of the character.

     703.4.3 Character Spacing. Character spacing shall be
     measured between the two closest points of adjacent
     characters, excluding word spaces. Spacing between
     individual characters shall be 10 percent minimum and
     35 percent maximum of character height.

     703.4.4 Line Spacing. Spacing between the baselines of
     separate lines of characters shall be 135 percent
     minimum and 170 percent maximum of the character
     height.

     703.4.5 Mounting Height. Visual characters shall be
     located 40 inches (1015 mm) minimum above the floor of
     the viewing position. Mounting heights shall comply
     with Table 703.4.2.4 based on the size of the
     characters on the sign.

     703.5 Braille. Tactile characters shall be accompanied
     by Grade II Braille complying with Table 703.5 and
     703.5. Braille dots shall have a domed or rounded
     shape.

     Table 703.5 Braille Dimensions
       * Measurement Range: Minimum in Inches; Maximum in
         Inches
       * Dot base diameter: 0.059 (1.5 mm); 0.063 (1.6 mm)
       * Distance between two dots in the same cell
         (measured center to center): 0.090 (2.3 mm); 0.100
         (2.5 mm)
       * Distance between corresponding dots in adjacent
         cells (not permitted except in elevators): 0.241
         (6.1 mm); 0.300 (7.6 mm)
       * Dot height: 0.025 (0.6 mm); 0.037 (0.9 mm)
       * Distance between corresponding dots from one cell
         directly below (not permitted except in
         elevators): 0.395 (10 mm); 0.400 (10.2 mm) (End
         Table 703.5)

     703.5.1 Location. Braille shall be located below the
     corresponding text. If text is multi-lined, Braille
     shall be placed below the entire text. Braille shall
     be separated 1/4 inch (6.4 mm) minimum from any other
     tactile characters.

     EXCEPTION: Braille provided on elevator car controls
     shall be separated 3/16 inch (4.8 mm) minimum and
     shall be located either directly below or adjacent to
     the corresponding tactile characters or symbols.

     703.5.2 Raised Borders and Decorative Elements. Raised
     borders and decorative elements that are not required,
     shall be separated 3/8 inch (9.5 mm) minimum from
     Braille.

     703.5.3 Height. Braille shall be located 40 inches
     (1015 mm) minimum and 60 inches (1525 mm) maximum
     above the floor measured from the baseline of the
     Braille cells.

     EXCEPTION: This requirement shall not apply to
     elevator car controls.

     703.6 Pictograms. Where pictograms are required to be
     accessible, they shall comply with 703.6.

     703.6.1 Pictogram Field. Pictograms shall have a field
     height of 6 inches (150 mm) minimum. Characters or
     Braille shall not be located in the pictogram field.

     703.6.2 Finish and Contrast. Pictograms and their
     field shall have a non-glare finish. Pictograms shall
     contrast with their field with either a light
     pictogram on a dark field or a dark pictogram on a
     light field.

     703.6.3 Text Descriptors. Where text descriptors for
     pictograms are required, they shall located directly
     below or adjacent to the pictogram and shall comply
     with 703.2.
NOTE: Section 703.5 above provides specific criteria for
Braille. In the current ADAAG, the criteria for Braille is
located in the appendix which is only advisory in nature.
Commenters may wish to address the inclusion of these
specifications here. Additionally, the mounting height for signs
containing Braille has been changed from 60 inches off the
finished floor to the center line of the sign to 40 to 60 inches
off the finished floor to the baseline of the Braille cells on
the sign, providing greater flexibility and wider range for the
placement of accessible signs.

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End of Document


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