Board Holds Meetings on Vehicles and Communication Access
August 29, 2006, Updated October 20, 2006
On July 25th the Board held public meetings as an initial step in upcoming efforts to update its ADA guidelines for transportation vehicles and to develop supplementary guidelines on communication access. The meetings provided an opportunity for interested parties to advise the Board on key issues or subjects that should be addressed in these initiatives.
Participants
American Bus Association
American Seating Company
Community Transportation Association of America
Council of Citizens with Low Vision International
Disability Rights Advocates for Technology
Mid-Atlantic ADA&IT Center
National Easter Seal Society Southeastern Pennsylvania Transportation Authority
Taxicab, Limousine and Paratransit Association
Paralyzed veterans of America
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Meeting on the ADA Accessibility Guidelines for Transportation Vehicles
The Board’s guidelines for transportation vehicles covered by the ADA address buses, vans, various types of rail cars, and other modes of transportation. The Board plans to review these guidelines, which were published in 1991, and to propose any revisions or additions as necessary, including coverage of new or convergent technologies. Meeting participants included transportation providers, manufacturers, and representatives from disability groups and trade associations.
Many comments called attention to the advances made in the design of mobility aids over the past 15 years, which have led to a wider array of manual and mechanized devices of varying sizes and capabilities. A growing number of mobility aids are larger and heavier than the standard manual wheelchair upon which many access specifications are based. The Board was urged to revise criteria in the guidelines so that access is ensured for a broader range of mobility aids now in use. Some commenters cautioned the Board about the potential impacts of such changes to the design of vehicles, particularly boarding devices, such as lifts, and seating space. This discussion also touched on accommodation of new mobility technologies, such as Segways, that have been developed for general use but are beneficial for some people with walking impairments.
Recommendations also addressed securement devices and restraint systems, the reliability and quality of on-board announcements of stops and other passenger information, signage, level boarding at rail cars, minimum gaps between vehicles and boarding platforms, industry standards for wheelchairs and mobility aids, coverage of new transportation technologies, such as bus rapid transit, and accessible restrooms on buses. The Board will hold another meeting on this topic during its September meeting in Las Vegas.
Issues Raised:
- The definition of “common wheelchair” should be changed to include new technology (e.g., Segway) and to increase the size and weight because wheelchairs are getting bigger.
- The “footprint” of a common wheelchair should not be changed because the space available in a bus is limited and bus size is largely fixed by external constraints (e.g., lane width).
- A wider footprint would likely eliminate minivans as an option for accessible taxis and paratransit.
- Guidelines should specify how the size and weight should be determined.
- Guidelines should require or encourage wheelchair manufacturers to comply with WC 19 standard.
- If the size is changed, existing buses should be “grandfathered” in.
- Definition of a common wheelchair should not be used as a means to exclude wheelchairs that can be accommodated.
- Some belt securement systems can secure a Segway; wheel clamps can’t.
- Wheel clamps do not work for many wheelchairs.
- Guidelines should better specify padded barrier for rear facing securement, including loading (e.g., Canadian specifications).
- If a rear-facing securement is used, some regular seats should also face rearward.
- Guidelines should clarify “normal operating conditions” for determining the maximum movement allowed for a secured wheelchair.
- Guidelines should more clearly define clear floor space for wheelchairs (e.g., a 48-inch long wheelchair will not fit in a 48-inch space that is confined on three sides).
- Clarify maneuvering space from entrance to securement location.
- Clarify the extent of the securement device instructions to be displayed at the securement location.
- Discontinue the requirement for a continuous overhead handrail and allow seatback handholds.
- Require the bus identification number to be displayed in accessible formats in a standard location inside the bus (e.g., on the back of the driver partition).
- Guidelines should address bus rapid transit.
- Ramp slope for low floor buses is too steep.
- Accommodating Segues on over-the-road bus lifts would be a problem because of height of raised lift (5 feet or more above ground) and low door height.
- One “common wheelchair” displaces 6 seats on an over-the-road bus; a bigger wheelchair might displace more.
- Require on-board lavatories on over-the-road buses.
- Minimize gaps between lift and bus floor.
- Level boarding should be required for rail systems.
- Minimize gaps between rail cars and platforms.
- Ask operators for statistics on prevalence of over-size wheelchairs.
- Continue current mode-specific format of guidelines.
Participants
American Association of People with Disabilities
American Council of the Blind
Communication Services for the Deaf
ENDependence Center of Northern Virginia, Inc.
Hearing Loss Association of America
Honeywell
International Code Council
Maryland State Department of Education
National Association of the Deaf
National Fire Protection Association
Northern Virginia Resource Center for Deaf and Hard of Hearing Persons
Smith-Kettlewell Eye Research Institute
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Meeting on Communication Access Issues
In response to previous feedback from the public, including in comments the Board received in the update of its guidelines for facilities, plans are being made for a new rulemaking initiative focused on communication accessibility. This effort will explore areas where access for people with vision or hearing impairments has been problematic, including kiosks, point of sales and other interactive transaction machines, drive-through communication devices, public address systems, signage, and alarms. The Board’s recent meeting on this topic sought input on key issues and considerations that should be addressed in this rulemaking. Attendees included representatives from disability groups, code organizations, research entities, and manufacturers.
Participants identified areas where access has been most challenging or where further information is needed. These included access for people with vision impairments at kiosks and point of sales machines, various types of alarms, including carbon monoxide detectors, acoustics, telephone volume control, drive-through communication devices, and public address systems. Some commenters high-lighted the need for research in various areas or called attention to new or emerging technologies for improved access, such as vibrating alarms, directional sound alarms, and audible or “talking” signs and wayfinding cues.
Issues Raised:
- Conduct research to determine what potential emergencies might disproportionately affect building occupants who are deaf or hard of hearing and what possible alternative alerting technologies could be provided to address their needs
- Research the potential for vibro-tactile and portable devices such as PDAs, cell phones and other mobile devices as alternatives to visual or audible alarms and public address announcements to provide equivalent effective alerts for building occupants who are deaf or hard of hearing
- Where provided, ensure the effectiveness of visual and audible alerting technologies, particularly audible alarms in the asleep mode for sleeping rooms and, where verbal announcements are provided, provide a means of effective communication for building occupants that cannot hear audible announcements
- Adjust requirements for audible alarms to reflect research that supports the findings that lower frequencies are more effective for all building occupants, including those who are hard of hearing
- Conduct research before undertaking rulemaking to adjust frequency levels or loudness requirements for audible alarms because changes to the current requirements may present insurmountable manufacturing challenges or costs
- Consider guidelines requiring informational signs to be accessible to people who are blind or who have low vision that include remote infrared audible signs that will also provide a wayfinding system in more complex environments
- Consider guidelines that include remote infrared audible signs as a means to make signs on buses indicating the destination and number accessible to individuals who are blind or who have low vision. Such signs also would be a way to identify the next arriving bus for people standing at a bus stop or station
- Require businesses and other entities to install remote infrared audible signs containing their street addresses and pertinent information about their services and products so that individuals who are blind or who have low vision can elect to receive that information as they travel from point-to-point within a community
- Through rulemaking, enable those who are blind or who have low vision attending cultural events, museums, educational institutions, etc. to obtain audible descriptive information, including detailed information about artifacts or live events
- Consider requiring directional sound alerting technologies to capture building occupant’s attention and to aid in directing people to exits, particularly those with vision impairments, thereby expediting evacuation times. Directional sound is a technology first developed in the United Kingdom in 1995 using broadband sound in frequencies additional to those used by horn strobes or notifications devices on existing fire alarm systems. Occupants could benefit from the added audible cues to exits in conjunction with required alarm systems and exit signs
- Initiate rulemaking regarding interactive transaction machines (ITM’s), not just ATM’s and fare vending machines, to ensure their accessibility. Require ITM’s and other point-of-sales machines, particularly airline ticket kiosks, to be accessible to people who are blind or have low vision by providing, at a minimum, audible output because, increasingly, personnel are unavailable to provide assistance. Ensure equivalent privacy of information for customers and address the needs of individuals with cognitive impairments. Also, ensure that publicly owned ITM’s and information kiosks, including maps displayed on them are accessible.
- Revise the Board’s accessibility guidelines so that flat panel displays on appliances and ITM’s are tactually discernable
- Supplement the Board’s public TTY requirements with requirements for video multiple purpose phones that allow for audio and video communications allowing deaf and hard of hearing people to communicate in American Sign Language, which for many is their native language and ensure that the device can connect to video relay services
- Implement the ANSI/ASA S12.60-2002, Acoustical Performance Criteria, Design Requirements and Guidelines for Schools in the Board’s accessibility guidelines and extend coverage to other facilities, such as senior facilities
- Address issues related to appliances and displays for people with cognitive impairments. In particular, ensure that text output contains plain language
- Ensure that business’ websites are accessible to individuals who are blind or have low vision
Require captioning for movies and all television and video available in public places such as shopping malls, restaurants, and hotels
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