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

Detectable warnings are required to contrast visually from adjacent walking surfaces, either light-on dark or dark-on-light. The proposed rule required the material used to provide contrast be an integral part of the truncated dome surface (705.2.2). This specification was intended to preclude the painting of detectable warning surfaces to meet the contrast requirements since painted surfaces would not be adequately slip resistant. However, requirements for ground and floor surfaces in section 302, which require slip resistance, apply to those surfaces with detectable warnings as well. The Board believes that the requirement for slip resistance in section 302 effectively prevents the painting of detectable warning surfaces. Consequently, it has removed the specification that the material used to provide contrast be an integral part of the detectable warning surface.

Comment. The proposed rule specified that detectable warnings in interior locations differ from adjoining walking surfaces in resiliency or sound-on-cane contact (705.2.3). Commenters considered this provision to be of questionable usefulness and difficult to meet absent a recognized method of measuring resiliency or sound-on-cane contact.

Response. The requirement for contrast in resiliency or sound-on-cane contact between detectable warnings and adjoining walking surfaces in interior locations has been removed in the final rule.