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

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).