Remote Signage and the Americans With Disabilities Act of 1990:

What is Remote Signage?

Imagine finding your way in a city with no street signs, searching for an invisible public telephone or guessing which corner might be a bus stop. Most of us do not have to endure such an absurd condition in the conduct of our day-to-day lives. Remote signage is a way of telling visually impaired people things they need to know about their surroundings. The Remote Signage technology developed at Smith-Kettlewell is named "Talking Signs" and works much like the infra-red remote control of our television sets. However, in this case, the speech information stored in the "sign" is transmitted by an infra-red beam to a hand-held receiver which "speaks" the message to the user. Smith-Kettlewell has, in collaboration with the City of San Francisco and Love Electronics, Inc., installed these "Talking Sign" units in several traffic lights on Market Street.

Why is Remote Signage so important to the visually impaired citizens?

According to the 1988 report to the National Institute on Disability and Rehabilitation Research titled, "Data on Disability from the National Health Interview Survey, 1983-1985" 7.6 % of Americans need assistance in activities in daily living as a result of visual impairments and eye disorders (LaPlante, Mitchell P., 1988). Listed below are some of the important ways access to signs by way of Remote Signage would impact upon the lives of the visually impaired.

Accessible routes for a person with visual impairments should mean knowing in which direction the destination is located and being able to determine his current location.

Access to the telephone should mean that one can first locate it- whether on a sidewalk or across the lobby of an airport.

Access to public transportation should mean that a visually impaired persons can locate the bus loading area (bus stop) and be able to determine their arrival at the desired destination.

Access to a building entrance should mean that a blind person can find it.

The right of the disabled citizen to participate in equal "..good, service, facility, privilege, advantage, or accommodation.." [Sec. 302(b1Aii) of ADA] is obviously within the scope of the Act. Remote Signage would turn those "shoulds" into "doeses"!

What is the history of Remote Signage in the ADA?

The "Introduction to the Proposed Rules" (published in the Federal Register) contains 60 questions which seek advice as to the way certain rules should be written. The question which relates directly to the issue of Remote Signage is number 13 (quoted below). Smith-Kettlewell's RERC staff has offered both oral and written testimony to the Architectural & Transportation Barriers Compliance Board (ATBCB) regarding our answer to this question. (The ATBCB issued guidelines to the Dept. of Justice in establishing accessibility standards). The fact that this question was raised in such a central forum as the ATBCB's request for comments indicates the level of importance that Remote Signage holds.

Question 13: The Board seeks information regarding additional types of signage that are necessary for individuals with vision impairments to participate in integrated environments and that should comply with the technical specifications for raised and Brailled characters (4.30.4), and mounting location and height (4.30.6). The Board is considering requiring informational and directional signage to comply with those technical specifications, particularly where it may affect the usability of the building or facility such as signage indicating the location of an information desk, auditorium or gymnasium; specifying rules of conduct; or alerting the public to certain hazards. In areas where overhead signage is typically provided such as conference centers and bus stations, how can information on these signs be made accessible to persons who use raised and Brailled characters? Section 4.30.6 requires signs to be mounted between 54 and 66 inches, and signs that provide permanent identification of rooms and spaces must be installed on the wall adjacent to the latch side of the door. In large open areas such as an indoor atrium there may be no wall or doorway in proximity to overhead signage. Are there other technologies such as audible signs that may be more usable than requiring signage to comply with the technical specifications for raised and Brailled characters (4.30.4), and mounting location and height (4.30.6). The Board seeks information regarding the benefits and costs of these requirements and alternative technologies.

How, specifically, is Signage defined by the ATBCB and what is the scope of Signage as was written into the ATBCB's guidelines?

Section 4.30 Signage. Displayed verbal, symbolic, tactile, and pictorial information.

4.30.1* General. Signage required to be accessible by 4.1 shall comply with 4.30. Each entrance which does not comply with 4.14 shall have signage which complies with 4.30 indicating the location of the nearest accessible entrance(s).

4.30.2* Character Proportion. Letters and numbers on signs shall have a width-to-height ratio between 3:5 and 1:1 and a stroke-width-to-height ratio between 1:5 and 1:10.

4.30.3 Character Height and Letter Spacing. Characters and numbers on signs shall be sized according to the viewing distance from which they are to be read. The minimum height is measured using an upper case X .


	Height Above				Minimum  

	Finished Floor			        Character Height



        



	Mounted above 66 in or                    

   	suspended/projected			3 in (75 mm) minimum



	overhead in compliance 

	with 4.4.2         







	Wall mounted within			1 in (25 mm) minimum      

 	66 in of the floor              







 	Building Directories			5/8 in (16 mm) minimum   

	mounted at any height

The spacing between letters shall be wide by industry practice; generally, the space between letters shall be 1/16 the height of upper case letters.

4.30.4* Raised and Brailled Characters and Pictorial Symbol Signs (Pictograms). Letters and numerals shall be raised 1/32 in, upper case, sans serif or simple serif type and shall be accompanied with Grade 2 Braille. Raised characters shall be at least 5/8 in (16 mm) high, but no higher than 2 in (50 mm). Pictograms shall be accompanied by the equivalent verbal description placed directly below the pictogram. The border dimension of the pictogram shall be 6 in (152 mm) minimum in height.

4.30.5* Finish and Contrast. The characters and background of signs shall be eggshell (11 to 19 degree gloss on 60 degree glossimeter). Characters shall be light on a dark background (or dark on a light background) and contrast with their background by at least 70 percent. Contrast in percent shall be determined by:

	

	Contrast    [(B 1  - B 2 )/B 1 ] x 100     



	where B 1 = light reflectance value (LRV) of the lighter area



and  



	B 2 = light reflectance value (LRV) of the darker area.

4.30.6 Mounting Location and Height. Where permanent identification is provided for rooms and doorways, signs shall be installed on the wall adjacent to the latch side of the door. Mounting height shall be between 54 and 66 in. Mounting location for such signage shall be such that a person may approach within 3 in of signage without encountering protruding objects or standing within the swing of a door.

4.30.7 Symbols of Accessibility. Accessible facilities required to be identified by 4.1 shall use the international symbol of accessibility. The symbol shall be displayed as shown in Fig. 43(a).

Telephones required to be accessible by 4.1.3(17)(b) shall be identified by a sign containing a depiction of a telephone handset with radiating sound waves. Telephones required to be accessible by 4.1.3 (17)(c) shall be identified by the international TDD symbol (Fig 43(c)). Where TDDs are required, directional signage indicating the location of the nearest TDD telephone shall be placed adjacent to all single user or banks of telephones which do not contain a TDD. Such directional signage shall include the international TDD symbol.

4.30.8 Illumination Levels. Illumination levels on the sign surface shall be in the 100 to 300 lux range (10 to 30 footcandles) and shall be uniform over the sign surface. Signs shall be located such that the illumination level on the surface of the sign is not significantly exceeded by the ambient light or visible bright lighting source behind or in front of the sign.

What is the relationship between the ATBCB and the Dept. of Justice?

A rule of thumb as to how the ADA rule-making gets divided up between the ATBCB and Dept. of Justice is "whatever is left in a building after you pick it up and shake it is the responsibility of the ATBCB. Whatever falls out is the responsibility of Justice." That is, the Dept. of Justice covers everything in the ADA not falling to the ATBCB. After ATBCB wrote its rules, they were adopted into Dept. of Justice rules. This occurred because:

		

	1) Enforcement - The ATBCB has no regulatory authority, Justice does.







	2) Coherency and completeness of regulations avoids fragmentation

	and inconsistency among agencies.

The ATBCB and the Dept. of Justice were in the position to write in a remote signage specifications at the time the rules were established. The relative merits of competing technologies are known (see enclosed review to the ATBCB by Gerrey), a significant number of tests of the Talking Signs technology have been made, and these results have been published in reputable journals within the field of rehabilitation engineering.

What is the current status of the Remote Signage rules?

The final Rules and Regulations regarding the ADA were published in the Federal Register on July 26, 1991. The document states,

" Comment. ..... The NPRM also requested information on available technologies such as audible signs for overhead and remote signage. Comments from individuals with disabilities and their organizations regarding additional types of signage that should be tactile were scattered with no clear consensus of opinion that would be useful for purposes of establishing guidelines. Technical information was submitted by Love Electronics regarding infrared signage."

and

"Response. Although technology is available for making overhead and remote signage accessible, the Board plans to further study this issue to determine where and in what types of buildings and facilities such technology may be necessary for future revisions of the guidelines."

Need for future action by the ATBCB and the Justice Department relating to the implementation of Remote Signage.

The stated intent of the ATBCB to make recommendations as to future revisions of the guidelines relating to remote signage and the continuing need for the Department of Justice to ensure that the law as stated in the ADA is enforced, can provide a framework for ensuring that all citizens will have access to the information necessary for independent and safe transit.

The language of the ADA, itself, is very specific and very radical in its call for equal advantage for all the citizens:

ADA, Sec. 302. Prohibition of Discrimination by Public Accommodations.

Sec. 302b.A(ii) Participation in Unequal Benefit. - It shall be discriminatory to afford an individual or class of individuals, on the basis of a disability or disabilities of such individual or class, directly, or through contractual, licensing, or other arrangements with the opportunity to participate in or benefit from a good, service, facility, privilege, advantage, or accommodation that is not equal to that afforded to other individuals.

Access to a building entrance should mean that a blind person can find it. That is, access to an entrance is more than just making a door wide enough for a wheelchair to pass through. The limited scope of the signage requirement for entrances in Sec. 4.1.2(7) leaves it to chance that a blind person happens upon the entrance. Only then does the ATBCB's interpretation of the ADA kick in to give the citizen an opportunity to identify it by Braille or raised symbols.

Accessible routes for a person with visual impairments should mean knowing in which direction the destination is located; indeed, no one could implement a route of travel without this knowledge, yet Access Routes (Sec. 4.3) deals only with issues like slopes and head room.

Access to the telephone should mean that one can first locate it- whether on a sidewalk or across the lobby of an airport. However, the relevant rule (Sec. 4.31, Telephones) does not specify any signage. Section 4.30 (Signage) only specifies signs for telephones which indicate functions for the hearing impaired.

It is apparent from the above that the ATBCB views its mandate as removing physical barriers rather than removing functional barriers (except for the hearing impaired). Perhaps it is left to the Department of Justice to ensure that functional barriers are removed. Access to information which remote signage can provide to the visually impaired should be viewed as being central to equitable enjoyment of public life; it is an important and necessary component for fulfilling the requirements of the Americans With Disabilities Act.