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

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.