S-K Inst / RERC / Federal Register (re:audible signage)

Speaking Points before the Access Board
ATBCB Hearing Mar. 15, 1993
San Francisco, CA.

Currently, signage for the blind is restricted to tactile displays which require the individual to be at the location of the signs before he/she can identify the information it bears. Using such signage as an aid in locating and traveling to a telephone booth, bus stop, elevator, building entrance or exit, leads to the paradoxical effect of having to already be there before you know where it is. A central property of conventional signage for the sighted is that the information presented is accessible at a distance. It is therefore crucial that signs for those with visual or print-reading impairments also be accessible at a distance. Anyplace the accessibility rules address signage, such as buildings (see Questions 9 and 13) or street identification and pedestrian signage (see Questions 67 and 68), remotely accessible signage should be required. In addition, sec. 4.1.3(17) "public telephones" should include this provision so that public telephones be locatable on the street, from across the hotel lobby, or in an airport terminal. Signage appropriate for people who are visually impaired will not only alleviate considerable frustration and inefficiency, but is, in many cases, a necessity if these citizens are to function independently, safely and equitably within the society.

SPECIFIC RESPONSES TO THE QUESTIONS

Question #9:

In 1980, the Architectural and Transportation Barriers Compliance Board received information from Smith-Kettlewell's Rehabilitation Engineering Research Center relevant to drawing up signage guidelines for a barrier-free environment. The then, National Institute of Handicapped Research (now the National Institute on Disability and Rehabilitation Research) funded research at Smith-Kettlewell on this question of remote signage beginning in the early 1980s and has continued to fund its development up to the present time. These research findings have appeared in important journals in the field of rehabilitation research.

This infrared remote signage is being manufactured by Love Electronics as Talking Signs (TM) and has been chosen as the official accessible signage technology for the City of San Francisco "..because it provides the required 'path of travel' information as well as 'location'" according to Richard Skaff, coordinator of the Department of Public Works' Accessibility Advisory Task Force. Talking Signs is also endorsed in a resolution by the San Francisco Board of Supervisors on April 13, 1992 as the method for providing blind pedestrians with orientation and mobility information at street crossings within the downtown area.

The current prices are $150 for low-powered infrared remote signs (suitable for office doors and building labels) and $350 for high-powered signs such as the pedestrian signals at 5th and Market Streets in San Francisco. The receivers are currently priced at $200; however, the manufacturer anticipates substantial cost reductions in both transmitters and receivers afforded by a new design and high volume fabrication techniques.

The current design allows for messages of any length. Multi-message and menu selection strategies are currently under development. This system is flexible enough to provide the same range of information as conventional signage.

Question #13:

The Question refers specifically to Tactile signs for the identification of rooms or spaces. Infrared remote signage should also be considered for this application as it circumvents the problem of having to locate the tactile sign before the information can be read; room entrances opening onto a corridor or even onto a large, open area could be identified at a distance while the traveler is in motion -- in the same way a sighted traveler surveys the environment. Also, directional information is automatically a property of the "point-out-ability" of infrared transmission.

Question #67:

Tactile signage in large, unfamiliar areas leads to the paradoxical effect of the traveler having to already be there before he or she can tell where it is. Infrared remote signage allows the traveler to survey the environment for relevant information while standing in one location in the same way a sighted counterpart would. The "point-out-ability" or directionality of infrared remote signage also gives the traveler constant feedback as to his or her relative location to the goal as it is being approached.

The "smart intersection" technology referred to in this question is infrared in nature and the commercial research and development already going into projects such as this will have a synergistic benefit for those anticipating a more equitable access to public goods and services.

Question #68

Audible pedestrian systems which chirp and cuckoo are of very limited use to those with learning disabilities and/or mental retardation in that the sounds are a code linked to the direction of travel. Infrared remote signage of the type installed at pedestrian crossings in San Francisco, tells the disabled pedestrian -- in spoken words -- the direction of travel, the address of the street crossing and the condition of the traffic light (red, yellow or green). The shape of the infrared beam pattern also indicates to the pedestrian when he or she is moving outside the bounds of the crosswalk.

An additional feature of this system is that, since the receiver is a personal listening device, it conforms to Title V, sec. 501(d) of the ADA which stipulates that persons have the right not to accept special accommodation. This system is also unobtrusive to the public at large.

The needs of pedestrians who are both deaf and blind can be accomplished quickly and inexpensively by providing a way for the user to touch the miniature speaker of a standard infrared remote receiver. The speaker, acting as a tactor, would response to subaudible "tones" encoding the condition of the light (and other properties using Morse or other schemes) originating at the traffic signal transmitter. The subaudible code would be generated at the infrared transmitter and be simultaneously transmitted on the carrier with the speech information. (See Smith-Kettlewell Technical File Fall, 1991, for details.)

SUMMARY

Lack of access to signs is a serious barrier for the visually impaired. The National Health Interview Survey indicates that 7.6 % of Americans need assistance in activities in daily living as a result of visual impairments and eye disorders. In addition to the estimated 1.1 million people who are legally blind (Chiang, et al, "Federal Budgetary Costs of Blindness," Milbank Quarterly, Vol. 70, No. 2, 1992) and those low vision people who may not be able to see the print, there are many stroke, head-injured, or dyslexic persons who may not be able to assimilate printed language. Additionally, there are those who are retarded or have a learning disability. Remote signage is a way of telling people who are visually impaired the things they need to know about their surroundings. Implementation of a remote signage system would immediately increase the independence of a person with visual impairments in the following fundamental ways:

Accessible route would mean knowing in which direction the destination is located and being able to determine his/her current location.
Accessible telephone would mean that one could first locate it whether on a sidewalk or across the lobby of an airport.
Accessible public transportation would mean that the visually impaired could locate the bus loading area (bus stop) and be able to determine his/her arrival at the desired destination.
Accessible building entrance would mean that a blind person could find it.
Accessible buildings and malls would mean that one could independently and safely locate offices, shops, elevators and emergency exits within an otherwise homogeneous environment.

The language of the ADA, itself, is very specific and very radical in its call for equal advantage for all citizens. This right of the disabled citizen to participate in equal " ..good, service, facility, privilege, advantage, or accommodation.." is fundamental to the ADA. Insuring that visually impaired citizens have access to the same information as those of the general public is clearly an intent of the ADA.

For example, currently a blind person must seek the assistance of someone on the street to identify the bus numbers and seek the assistance of someone on the bus to identify the street names (see Questions 67 and 68). Sec. 4.30 "signage" should be enhanced to specify signs for the visually handicapped which are functionally equivalent to those for sighted (Title III, sec. 302(b)).

Infrared remote signage is a well-developed technology with significant participation of members of the target population in its design and implementation. Because infrared remote signage comes so close to providing an equivalence in function to conventional signage, we urge the board to specify simple rules requiring IR signage where conventional signage is appropriate for the efficient and safe conduct of public life.

William Gerrey,
Senior Electrical Engineer
Smith-Kettlewell Rehabilitation Engineering Center