Presentation to the US. Architectural and Transportation Barriers Compliance Board
2/21/91

The Smith-Kettlewell Eye Research Institute
Rehabilitation Engineering Research Center

1. Response to Question 13, regarding Signage for the blind and visually impaired.

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 impairments also be accessible at a distance. For example, sec. 4.1.3(17) "public telephones" should include this provision so that public telephones be locatable from across the hotel lobby or airport terminal. Signage appropriate for the visually handicapped will not only alleviate considerable frustration and inefficiency, but is, in many cases, a necessity if these citizens are to function independently and equitably within the society. 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. In summary, 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)).

A well developed technological solution to this need already exists in the form of a product called "Talking Signs", available from Love Electronics of Goldendale, Washington. This remote indicating signage system is based upon transmission of information over an infrared "light beam" in much the same way as the remote control of a television. An example of this system specifically designed to enhance both the orientation and mobility of the visually handicapped is currently installed at the corner of Fifth and Market Streets in San Francisco. A light beam transmitter mounted in the traffic light sends location information (e.g. " Facing East - Fifth and Market"). This is interspersed with the traffic light status broadcast on a narrow beam which is only received in 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.

2. Response to Question 35, regarding Accessibility to "automatic teller machines" and other public computerized equipment.

In addition to visual displays on such machines, all visual "prompts" and display information crucial to their operation must be retrievable electronically. We propose that sec. 4.34.4 specify the Consumer Electronics Bus (CEBus) of the Electronics Industries Association (EIA) as the method manufacturers of this type of public access electronic equipment communicate with the "outside world". This standard has evolved with substantial input from the disabled community. It has the added advantage of a high potential for deep penetration into the conventional consumer electronics markets such as home appliances (which provides additional benefits to the disabled). One of the communication modes specified by the CEBus standard is the infrared (wireless) interaction with remote controllers; in the case of the visually impaired, blind, or deaf-blind users, a "access box" could present visual display information in large, brightly lit lettering, speech, or Braille, respectively. The critical parameter is that display information be present on this bus.

3. Response to lack of attention to Telecommunications for the visually impaired.

The Proposed Rules are silent on the issue of the substantial barriers to equitable access to information afforded the visually handicapped as transmitted by telecommunications. Indeed, within the Rules, "telecommunications" becomes "telephone" and, much like Title IV "telecommunications", the Rules address the functional barrier of deafness and excludes the functional barrier of blindness. Just as the deaf should not be required to "participate in unequal benefit" (Title IV, sec. 302) ,nor should the visually handicapped. The growing use of the Nation's telecommunications systems to transmit digitized, graphical information such as fax has added an additional barrier to print access among the visually impaired. An Interpretive service (such as those now in existence for the deaf) may be a cost-efficient way to overcome this newly created barrier; blind and visually impaired people could resend faxed documents or send printed documents to sighted readers who would then read them back over the phone. We propose that sec. 4.31 include the hardware provisions for the transmission of printed documents over the telecommunications system so that the visually handicapped can have access to the information contained within these documents. Telephone equipment design includes more and more liquid crystal displays. For example, PBX and CENTREX systems have visual displays which present information critical to the operation of such "switchboards". Indeed, visual displays on individual telephones will present information requiring responses -- just to use the telephone. These displays (unlike a simple row of lighted buttons) are inaccessible to the print handicapped. As with automated teller machines, we propose that the CEBus be included on telephone equipment and that display information be present on that bus.

William Gerrey
Rehabilitation Engineer

William Crandall, Ph.D.
Associate Scientist