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

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)