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

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.