Final Regulatory Assessment and Final Regulatory Flexibility Analysis Final Rule - Nondiscrimination on the Basis of Disability by Public Accommodations - Movie Theaters; Movie Captioning and Audio Description

In addition to the acquisition, installation, and replacement of equipment, the rule requires staff to be able to provide patrons with captioning and audio description devices and to direct patrons on the devices’ use.  This requirement can most easily be met by expanding the training for those employees who will already be on-site to manage or oversee overall operations or the exhibition of the movies.  In addition, staff already distributes assistive listening devices (devices required under the current ADA 2010 Standards) when requested by patrons and directs such patrons on the use of those devices.  It is reasonable to assume that the same staff members would provide assistance with the captioning and audio description devices as well.  Separate staff with ADA expertise is not required.  Because the operational requirements of this rule apply to all digital auditoriums and not just those purchasing captioning and audio description as a direct result of this rulemaking, the Department’s estimate of training costs includes the training costs for movie theaters already equipped to provide closed movie captioning and audio description.
Figure 2-4 shows how additional training time is monetized using the hourly employment cost for movie theater employees.  The data and assumptions used to estimate training costs are outlined in Section 3.7.

Figure 2-4 : Employee Training Calculation