T.  5-3-94
                       PORTABLE SANITATION ASSOCIATION INTERNATIONAL
                              7800 METRO PARKWAY, SUITE 104
                               BLOOMINGTON, MINNESOTA 55425
                              1-800-822-3020  (612) 854-8300
                                   FAX: (612) 854-7560

June 16, 1993

Mr. John Wodatch
Chief, Public Access Division
Civil Rights Division
U.S. Department of Justice
PO Box 66738
Washington, DC 20035-6738

Dear Sir,

The mission of the Portable Sanitation Association International (PSAI) 
is "To expand and improve portable sanitation services and facilities 
worldwide and to be recognized as the preeminent authority within our 
industry."

In the spirit of our mission statement, members of our industry have 
been providing the disabled with accessible portable restroom 
facilities prior to the enactment of the Americans with Disabilities 
Act of July 26, 1990.

On May 21, 1993 a delegation of members from our industry, including
manufacturers of portable restrooms and portable sanitation service
company operators, met with representatives of the Access Board in
Washington, DC.

Based on the outcome of this meeting there are no portable restrooms
currently being utilized by the disabled community that are in 
compliance with Title III of the ADA. This is not to say that, in the 
opinion of the Portable Sanitation Association International, portable 
sanitation facilities currently in use by the disabled are not adequate 
to meet their needs.

Portability, clear floor/ground space, transportation and set-up are 
the reasons existing accessible portable restroom facilities were 
designed and why they have been used for twenty years without 
objection. However, based on the ADA requirements and recommendations 
from the Access Board, the manufacturers are in the process of 
reviewing the ADA standards to develop portable sanitation facilities 
that will meet the requirements of the ADA.

The problem in existence now is when the portable sanitation service
companies are asked to provide a portable accessible restroom that 
meets the ADA requirements they are unable to do so, because they do 
not exist.

01-03080






Page 2

The Portable Sanitation Association International requests that the
manufacturers of portable restroom facilities be granted a 24 month
research and development period to provide the disabled accessible
portable restrooms that meet the requirements of the ADA.
                  
In addition we request that the portable restroom service companies 
receive grandfathering to allow continued use of the accessible 
portable restrooms currently being used in their rental fleet.  This 
period of time should be long enough to allow these companies to change 
their existing equipment to the new equipment through normal attrition 
of their current fleet.

As you can understand, this issue is time sensitive and needs to be 
resolved as quickly as possible.  Please do not hesitate to contact me 
regarding this matter.


Sincerely,



William F. Carroll
Executive Director

WC/sw
























01-03081