36 CFR Parts 1190 and 1191 ADA and ABA Accessibility Guidelines - Preamble (Discussion of Comments and Changes)

407 Elevators

Section 407 covers passenger elevators, including destination-oriented elevators and existing elevators. This section also requires compliance with the industry safety code, ASME/ANSI A17.1- 2000 Safety Code for Elevators and Escalators. The Board has revised the rule to reference the most recent edition of this code (105.2.2).

The requirements for elevators have been extensively revised and reformatted. In the proposed rule, different types of elevators were covered by separate subsections: standard elevators (407.2), destination-oriented elevators (407.3), limited-use/limited-application elevators (407.4), and existing elevators (407.5). In addition, residential elevators were addressed in a separate chapter covering residential facilities (11). Since there was considerable redundancy in the specifications between some types of these elevators, the Board has integrated into one section (407) the requirements for standard, destination-oriented, and existing elevators. Basically, this revised section tracks the requirements for standard elevators in 407.2 of the proposed rule, but the provisions have been renumbered and formatted. Various exceptions specific to destination-oriented and existing elevators have been incorporated into this section to preserve the substance of differing specifications. Requirements for limited-use/limited-application (LULA) elevators and residential elevators are provided in sections 408 and 409, respectively.

Comment. The proposed rule applied requirements specifically to "new" elevators, including destination-oriented and LULA types, and to "existing" elevators. However, substantive differences between requirements for "new" and "existing" elevators applied only to standard elevators. Comments recommended that references to "new" be removed for consistency with the rest of the document.

Response. The Board has removed references to "new" in the requirements for elevators in sections 407 and 408 for consistency with the scoping of the guidelines. The requirements of these sections apply to existing elevators that are altered, consistent with the basic application of the guidelines. Provisions specific to "existing" elevators in section 407 address certain allowances permitted in the alteration of standard elevators.

Substantive changes made to requirements for elevators in section 407 include:

• revision of the height of call controls (407.2.1.1)

• removal of a specification concerning objects located below hall call buttons (407.2.2 in the proposed rule)

• modification of specifications for audible hall signals (407.2.2.3) and audible car position indicators (407.4.8.2)

• revision of the height of tactile floor designations at hoistways (407.2.3.1)

• addition of an exemption for destination-oriented elevators from the requirements for door and

• signal timing (407.3.4)

• addition of a new exception for the height of car controls (407.4.6.1, Exception 1)

• modification of requirements for keypads (407.4.7.2)

• clarification that requirements for operable parts in 309 apply to call controls (407.2.1) and car controls (407.4.6)

• removal of redundant specifications for emergency communication systems (407.4.9)

• relocation of requirements for existing elevator cars to be labeled by the International Symbol of Accessibility, unless all cars are accessible, to the signage scoping section (216.7)

Section 407.2 provides specifications for elevator halls and lobbies. In the final rule, this provision has been editorially revised to refer to elevator "landings," consistent with the ANSI A117.1‒2003 standard.

Comment. The proposed rule specified that call buttons be located 35 to 48 inches above the floor (407.2.2). These controls should be held to the basic reach range specifications in section 308 like any other operable part, according to commenters.

Response. In the final rule, call controls are required to be located within one of the reach ranges specified in section 308 (407.2.1.1). In addition, the Board has removed a requirement that objects mounted beneath hall call buttons protrude no more than 4 inches into the clear floor space. Such protrusions are adequately addressed by requirements for clear floor space in 305 and for protruding objects in section 307.

Comment. Audible hall signals must indicate the direction of a responding car by the number of sounds (once for up and twice for down) or by verbal announcements (407.2.2.3). The proposed rule included a maximum frequency (1,500 Hz) for audible signals. The Board sought comment on whether a frequency band width should be specified for verbal annunciators (Question 21). Specifically, the Board asked whether a band width of 300 to 3,000 Hz for hall signals would be appropriate. Information on the availability and cost of products meeting this specification was also requested. Comments from the elevator industry indicated that hall signals currently fall within this range.

Response. The Board has added a requirement in the final rule that hall signal verbal annunciators have a frequency of 300 Hz minimum and 3,000 Hz maximum. For consistency, a similar requirement is specified for verbal car position indicators (407.4.8.2.3). In the proposed rule, these verbal annunciators were subject to a maximum frequency of 1,500 Hz. In addition, the Board has modified hall signal verbal annunciators by requiring that they "indicate the direction of elevator car travel," instead of specifying the content ("up," "down") as required in the proposed rule.

Comment. The proposed rule specified a decibel range of 20 to 80 decibels for hall signals and annunciators (407.2.3.1) and car position annunciators (407.3.4.2). Comments recommended that the minimum be changed to 10 decibels above the ambient noise level for consistency with the ANSI A117.1‒2003 standard.

Response. The minimum decibel range for hall and car position signals has been changed to 10 decibels above ambient. In addition, the provision for audible indicators (407.4.8.2) has been revised to require floor announcement when the car is about to stop, instead of when it has stopped, consistent with the ANSI A117.1 standard.

The proposed rule specified that tactile floor designations at the hoistway be 60 inches above the floor, measured from the baseline of the characters (407.2.4). In the final rule, this specification, now located at section 407.2.3.1, applies the mounting height generally required for other types of tactile signs by 703.2 (48 to 60 inches above the floor). The Board felt that there was little reason to hold hoist way signs to a more restrictive location than that specified for other types of tactile signs.

Comment. Section 407.3.1 recognizes acceptable types of elevator doors. The proposed rule recognized horizontal sliding doors. A comment indicated that other door types recognized by the elevator code should be recognized, such as vertical sliding doors.

Response. In the draft of the final guidelines, the Board had included a reference to vertical sliding doors permitted by the elevator safety code (ASME A17.1) in response to this comment. A similar change was not approved for the ANSI A117.1 standard due to concerns about such doors posing a tripping hazard to persons with vision impairments. For consistency, the Board has removed the reference to vertical sliding doors in the final rule.

Section 407.3.4 specifies door and signal timing. This provision helps ensure that elevator doors remain open long enough for persons with disabilities to travel from call buttons to the responding car and is based on a travel speed of 1 ½ feet per second. Destination-oriented elevators may have call buttons located outside elevator landing areas and have enhanced programming features for the response time of cars. In recognition of this, the Board has included in the final rule an exception from the door and signal timing requirements for destination-oriented elevators (407.3.4, Exception 2).

Comment. Comments recommended that the height of elevator car controls be harmonized with the ANSI A117.1 standard. Specifically, the ANSI standard specifies a maximum reach height of 48 inches for forward or side reaches. It also provides an exception that allows a maximum height of 54 inches for elevators with more than 16 openings where a parallel approach to the car controls is provided. The advisory committee also recommended lowering the maximum height for control buttons from 54 to 48 inches, consistent with its recommendations for reach ranges generally. The advisory committee recognized a potential adverse impact of a lower maximum height on elevators with panels that must have a large number of buttons in a limited amount of space and recommended an exception that would allow the 54 inch maximum height for elevators with more than 16 stops.

Response. As discussed above in section 308, the Board lowered the maximum side reach height from 54 to 48 inches. This height is the same as that specified for forward reaches. Elevator car controls are required to be within these reach ranges (407.4.6.1). Consequently, the Board has included an exception, consistent with the ANSI A117.1 standard and the advisory committee’s recommendation, that allows a maximum height of 54 inches where the elevator serves more than 16 openings and a parallel approach is provided (407.4.6.1, Exception 1).

Comment. The proposed rule, in addressing elevator car controls, required that telephone-style keypad buttons, where provided, be identified by raised characters centered on the keypad button (407.2.11.2), comments indicated that tactile characters for each button are not needed on such keypads. Support was expressed for making this requirement consistent with the ANSI A117.1‒1998 standard which requires a standard keypad arrangement with a raised dot on the number 5 key which is held to specifications for braille dots and a base diameter of 0.118 to 0.120 inch. Raised characters are not required.

Response. The Board has revised the requirements for elevator keypads, now located at 407.4.6.3 and 407.4.7.2, that are consistent with the ANSI A117.1 standard. The final rule requires a standard telephone keypad arrangement with the number 5 key identified by a raised dot that complies with specifications for the base diameter and specifications for braille dots in section 703.3.1. In addition, the Board has included a requirement that the characters provided on buttons comply with visual characteristics specified in section 703.5, which covers finish and contrast, character proportion and height, stroke thickness, and other criteria.

Section 407.4.9 provides criteria for emergency two-way communication systems in elevator cars which address the height of operable parts and identification by tactile characters. The proposed rule included requirements for the cord length of provided handsets and instructions. It also required that emergency signaling devices not be limited to voice communication. These requirements have been removed in the final rule because the referenced elevator safety code (ASME A17.1), as revised, adequately addresses these features or makes them unnecessary. For example, the ASME code prohibits the use of handsets since they are easily subject to vandalism, which obviates the need for specifications concerning the cord length.

Comment. Comments recommended that the guidelines address emergency communication systems located in a closed compartment and apply the specifications for operable parts in section 309 to compartment door hardware.

Response. The Board had included such a requirement in the draft of the final guidelines (407.4.9.6). In the final rule, the Board has removed this requirement since the ASME A17.1 safety code no longer permits emergency communication systems to be located within a closed compartment. However, the Board has retained provisions it had included that clarify the application of requirements for operable parts in 309.4 to call controls (407.2.1) and car controls (407.4.6).

Comment. In order to accommodate people with hearing or speech impairments, the proposed guidelines specified that the emergency communication system not rely solely on voice communication (407.2.13 in the proposed rule). The Board sought information and product literature on emergency communication devices and communication technologies that provide two-way communication in a manner accessible to people who are deaf and others who cannot use voice communication (Question 22). Comments, particularly those from groups representing persons who are deaf or hard of hearing, strongly supported such a requirement. They considered some form of interactive communication similar to that available through TTYs essential for providing equivalent access in emergencies. However, these comments did not specifically mention any technologies that are currently available to provide such access within elevator cars.

Response. Additional requirements for emergency communication systems are not included in the final rule. Further, the Board has removed specifications concerning the method of communication since the referenced elevator safety standard contains analogous provisions. Under such provisions, emergency communication systems cannot rely solely on voice communication. The ASME A17.1 code (section 2.27) requires provision of a push button labeled "HELP" which, when activated, initiates a call for help and establishes two-way communication. A visual signal is required on the same panel as the "HELP" button to notify persons with hearing impairments that the call for help has been received and two-way communication has been established. Voice (or other audible systems) with a visual display that provides information on the status of a rescue will meet this requirement. Clearly labeled visual displays can be as simple as lighted jewels that indicate that the call for help has been activated and that the message has been received. The visual signal is also required to indicate termination of the two-way communication link.