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

703 Signs

Requirements for signs provide specifications for raised characters (703.2), braille characters (703.3), the height and location of signs with tactile characters (703.4), visual characters (703.5), pictograms (703.6), and symbols of accessibility (703.7). This section has been reorganized and simplified in the final rule. Substantive changes include:

• reorganizing and simplifying criteria for signs required to provide both tactile and visual access (703.2)

• revising specifications for raised characters that cover height (703.2.5), stroke thickness (703.2.6), and spacing (703.2.7)

• modifying specifications for braille (703.3 and 703.4.1)

• recognizing elevator car controls in specifications for the height of visual characters (703.5.6)

• revising the location of text descriptors of pictograms (703.6.3)

Scoping requirements for signs in section 216 cover room designations, which are required to be tactile, and directional and informational signs which are not required to be tactile but must meet requirements for visual access. The proposed rule specified that tactile signs, where required, meet specifications for both tactile and visual characteristics. The proposed rule also applied specifications based on whether the requirements were met with one sign or separately through two signs. There were some differences between the requirements for combined tactile-visual signs and those provided separately, which represented slight compromises in the desired level considered necessary for signs providing both tactile and visual access. The proposed rule provided criteria where characters are both tactile and visual (703.2) and criteria for tactile characters (703.3) and visual characters (703.4) that are provided separately.

Scoping requirements for signs in section 216 cover room designations, which are required to be tactile, and directional and informational signs which are not required to be tactile but must meet requirements for visual access. The proposed rule specified that tactile signs, where required, meet specifications for both tactile and visual characteristics. The proposed rule also applied specifications based on whether the requirements were met with one sign or separately through two signs. There were some differences between the requirements for combined tactile-visual signs and those provided separately, which represented slight compromises in the desired level considered necessary for signs providing both tactile and visual access. The proposed rule provided criteria where characters are both tactile and visual (703.2) and criteria for tactile characters (703.3) and visual characters (703.4) that are provided separately.

Comment. Commenters considered the section on signs to be unduly complex and redundant and urged the Board to simplify the signage criteria.

Response. The repetition and complexity of the signage section stemmed from detailing requirements separately for signs where one set of character forms meet the tactile and visual specifications and for signs where such criteria are met separately through two set of character forms. Many of the specifications were the same for both types of signs. In the final rule, the Board has simplified the section and removed repetitive specifications while preserving most of the substance of the requirements as proposed. As reorganized, signs required to provide tactile and visual access must meet criteria for tactile characters (703.2), braille (703.3), mounting height and location (703.4), and visual characters (703.5). However, where access is provided through one set of characters, not all the requirements for visual access must be met. This is clarified in an exception which, consistent with the proposed rule, applies only the specifications for finish and contrast to tactile characters that are also visual (703.5, Exception).

Specifications for raised characters in section 703.2 address the depth, case, style or font type, character proportion and height, stroke thickness, and character and line spacing. The proposed rule, consistent with the original ADAAG, specified a character height between e inch and 2 inches. However, the proposed rule provided a tighter specification (½ to ¾ inch) for raised characters on signs where visual access is provided on a separate sign face because it is believed that smaller characters can be easier to read tactually. Since the specification for combination signs acknowledges that 2 inch characters are readable tactually, setting a different maximum seems unnecessary. The final rule retains the specified range of e to 2 inches, but an exception allows a ½ inch minimum where the same information is provided separately on a visual sign (703.2.5).

In the proposed rule, specifications for stroke thickness were based on the type of character cross section on signs providing both tactile and visual access (703.2.3.5). For characters with rectangular cross sections, a stroke thickness of 10% to 15% of the character height was specified (based on the uppercase "I"). For those with non-rectangular cross sections, the stroke thickness was specified to be 15% maximum of the character height (measured at the top of the cross section) and 10% to 30% (measured at the base). Where tactile and visual characters are provided on separate signs, the proposed rule specified that the stroke thickness of tactile characters be no greater than 15% of the character height (703.3.2.5).

Comment. Comments, including those from the signage industry, considered the specification based on the type of cross section to be unnecessarily complicated. Some comments pointed out that measurement and tactile reading of characters occur at the face, regardless of the cross section shape. Distinctions based on the cross section may be difficult to distinguish and enforce with respect to characters that are raised 1/32 inch, according to commenters. They advised that a single specification would facilitate compliance while having little effect on access.

Response. The Board has simplified the requirement for stroke thickness by relying solely on the specification that was included in the proposed rule for signs with tactile characters only. This specification requires a stroke thickness that is 15% of the character height (based on an uppercase "I"), regardless of the type of cross section (703.2.6).

As with stroke thickness, the proposed rule specified character spacing based on the type of cross section where signs provide both tactile and visual characters (703.2.4). A space of c inch to d inch was specified for characters with rectangular cross sections. For those with non-rectangular cross sections, this range applied to the top of the cross section and a range of 1/16 inch to d inch was permitted at the base. Where visual characters are provided on a separate sign, the proposed rule required spacing of c inch to ¼ inch between characters (703.3.3).

Comment. Comments advised that this specification was too restrictive and did not take into account increased spacing for larger size characters (the permitted range allows heights up to 2 inches). It was recommended that spacing based on the stroke thickness of characters will provide proper spacing for tactile recognition and facilitate compliance. Some commenters pointed out that good practice may include varying the space between characters for optimum visual legibility. Some comments recommended a spacing range that was at least as wide as the stroke thickness and no more than four times this width.

Response. In the final rule, the Board has revised the specification for character spacing (703.2.7). As recommended by commenters, the specified spacing range has been broadened to allow spacing up to four times the stroke width of raised characters. The Board has retained the minimum spacing requirements of the proposed guidelines and the distinction between characters with rectangular cross sections (c inch minimum) and those without (c minimum measured at the top and 1/16 minimum measured at the base).

Section 703.3 provides specifications for braille, including the dimensions and position.

Comment. Braille is to be located below the corresponding text. Commenters noted that it is common practice to locate braille next to the text on some signs, such as room numbers. These comments urged the Board to revise this specification to allow braille placement adjacent to text, as is permitted on elevator car controls.

Response. The Board believes that a uniform location facilitates the use of braille. No changes have been made to the specified position below corresponding text.

Braille does not include different upper and lower case letters. Instead, a character symbol is used to indicate capitalization. In the final rule, the Board has clarified that indication of uppercase letters is to be used only before the first word of sentences, proper nouns and names, individual letters of the alphabet, initials, and acronyms (703.3.1). A similar clarification has been included in the new ANSI A117.1 standard.

The proposed guidelines specified that braille be separated at least ¼ inch from other tactile characters and at least d inch from raised borders and other decorative elements (703.3.2). In the final rule, the Board has revised the minimum separation between braille and tactile characters from ¼ inch to d inch for consistency with the ANSI A117.1 standard.

Section 703.4 covers the mounting height and location of signs with tactile characters. Such signs are to be mounted so that the tactile elements (raised characters and braille) are between 48 to 60 inches high, measured to the baseline of characters.

Comment. The proposed rule specified a range of height of 48 to 60 inches for raised characters and a range of 40 to 60 inches for braille. Commenters considered the 40 inch specification too low, as research suggests that braille mounted below 48 inches can be difficult to read. Further, comments noted that the minimum 40 inch height did not correlate with the minimum specified for raised characters.

Response. The Board combined the height and location requirements for raised and braille characters into one section (703.4) for clarification and simplicity. As a result, the height of braille and raised characters are held to the same range: 48 to 60 inches above the floor or ground (703.4.1).

Tactile signs are required to be located alongside the latch side of doors so that clear floor space at least 18 by 18 inches, centered on the tactile characters, is provided outside the door swing (703.4.2). At double doors with two active leafs, signs are to be located on the right-hand side or, if no wall space is available, on the nearest adjacent wall. Signs are permitted on the push side of doors with closers and without hold-open devices.

Comment. A commenter advised that the specification should address double doors with only one active leaf.

Response. The Board has added a provision for double doors with one active leaf which requires the location of signs on the inactive leaf (703.4.2)

Section 703.5 provides specifications for visual characters which address finish and contrast, case, style, character proportions and height, height, stroke thickness, and character and line spacing. As part of the reorganization of the signage requirements, the Board has added an exception, consistent with the proposed rule, which applies only the specifications for finish and contrast (703.5.1) where tactile and visual access are provided through the same characters. Where signs provide tactile and visual access separately, visual characters must comply with all applicable specifications in section 703.5.

Visual characters are required to be located at least 40 inches high (703.5.6). For consistency with specifications for elevators in section 407, the Board has added an exception noting that the 40 inch minimum does not apply to visual characters indicating elevator car controls (703.5.6, Exception).

Section 703.6 contains requirements for pictograms. This section applies to those pictograms, where provided, that are used to label permanent interior rooms and spaces. The specifications of 703.6 do not apply to other types of pictograms, including those specified in section 703.7 to label various accessible elements and spaces. Under 703.6.3, text descriptors with raised and braille characters are required below pictograms. The proposed rule allowed alternative placement adjacent to pictograms. The Board has removed this alternative in the final rule to enhance uniformity in the location of tactile text descriptors.