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

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).