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

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).