Proceedings of: Workshop on Improving Building Design for Persons with Low Vision

Issue 22: How is accessibility for persons with low vision assessed during the design review process?

Questions by Earle Kennett: I had a couple of questions for Tom. In the design process, [are you] the advocate for GSA for accessibility.

Response by Tom Williams: That’s right.

Are you part of every design review of every new facility?

Response by Tom Williams: There’s no way I could be.

So there’s only one of you, right?

Response by Tom Williams: No, there are 12 of us. We have a person in each region who has the responsibility to manage the [accessibility] program in his or her region.

And is one of them part of every design review process?

Response by Tom Williams: In a lot of regions, that depends on the managers they have.

Okay let me just ask one last question, then you can elaborate. And if you are lucky enough to be part of that process, do they listen to you?

Response by Tom Williams: Yes, because you can’t argue with what’s legally mandated. So if you show the [regional and project] managers that there is a federal law, which has governed our facilities since the first initial standards to implement that law were used by our agency, and you tell the manager that if they don’t understand that it’s the ADA instead of the barriers act, you tell them, no, it’s the wrong law. [If they] don’t know the difference, you tell them you have a standard. The standard is implementing this law and the law was passed by Congress. You have to do this, whether you like it or not. You can’t cherry-pick what you will or will not comply with because you [will] violate the law, you’re opening our agency up to lawsuits. Don’t want to go there.

Or the enforcing agency of the barriers act, the barrier board, can then stop funding on a project until we fix it. They have, by law, the right to do that. That’s a big stick. That makes people very nice and conforming if they know; and a lot of these managers don’t know that.

Getting back to a point, I was starting to say, I got an e-mail from someone in the central office who had the responsibility for coordinating projects on a grievance. [That person mistakenly] told me that it was the manager, not the regional accessibility officer, who decided whether they wanted to review projects for accessibility or not.

I e-mailed back and said, no, it’s not the manager’s decision. I said, this is a federal requirement under the law Congress passed. A manager can’t selectively make a decision whether a regional officer reviews a project or not. He didn’t like that answer.

So they do have the responsibility but a lot of our regional management doesn’t get it, after all of these years, and they think they can cherry-pick what they do or don’t comply with.

Comment by Earle Kennett: I’ve seen a number of courthouses out there, GSA courthouses, and I’ve seen new courthouses who don’t meet certain accessibility standards; I wondered how that happened.

Response by Tom Williams: Well, the way it happened is because you have someone working in this position in a region that has to report to somebody else. [If] that person doesn’t give [the regional officer] the project to review, or [doesn’t] tell [the regional officers] this project needs review, then [the regional officer doesn’t] review it. [The regional officers] don’t even know necessarily that [the project] exists.

Question by Earle Kennett: Kurt, how does the VA handle it? I know you have your accessibility headquarters. Are there regional or are there vision advocates?

Response by Kurt Knight: No, the accessibility at headquarters is about it. We don’t have a specific person identified or we don’t have regions per se. The VA designs to those standards but we don’t have an individual person identified to ensure that’s adequate.

Comment and Question by [Participant]: Let me build off of that. You represent a part of the authority having jurisdiction. How well-versed are the project managers who bring these projects to you on the issues of accessibility and this particular accessibility issue which is for low vision?

Response by Tom Williams: Well, first of all, this is not right now an accessibility issue. As Marsha has already explained, the chief architect’s office basically conforms, as far as I know, to the [ABA]. We have an accessible program in the chief architect’s office, and for that reason, even though they have messed with [the issue], they haven’t complied with any current standard. You can’t go to almost any [standard], it’s just not there.

Response by Kurt Knight: In the VA’s case, our standards stipulate that they have to be accessible and because we have so many handicapped patients that have wheelchairs and other methods, then it is a common issue at VA hospitals. Our engineering people address it all the time. So when they renovate something, it’s always meeting the criteria, partly because it’s just we have too many people that are in that status that need it.

Question and Comment by [Participant]: To create an understanding of these men, do we need to educate project management people at the design and construction end of the various federal agencies to make them aware, and sensitive to, this issue in order to lay the groundwork for what we’re talking about as adaptation to the standards? People aren’t going to be able to evaluate what they can’t see or what they don’t understand.

Response by Tom Williams: Correct. We already have a program. Basically we have done it nationally. I’ve gone to Chicago and had training classes there on accessibility with project managers. The regions individually ask us for training and we do that, but the problem is we can train the project managers, but the project manager is under pressure, he’s got to meet all of these different [requirements] and whatever it is; green building is the big buzzword right now, sustainability, all of these things.

They’ve got so many balls they have to juggle in the air to get a project done that some things get dropped, that just don’t get done because of time and budget. So accessibility is probably one of the things that gets dropped more often the most. Our AEs should know this. They should know that. We have mandates. The facility standard basically is incorporated into the contracts with the AEs and it says you have to follow this standard. But nevertheless, I can give you a case in point where I’ve been asked to review projects that should have been reviewed in the region but for whatever reason they weren’t. That can be a management issue.