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

Panel 7: Next Steps - Guidelines (Earle Kennett, Moderator)

Earle Kennett. Introductory Comments

We have our last panel. And this kind of meshes into concluding thoughts. So we’re going to do this having a brief presentation by Kurt, and that will sort of lead into our final thoughts.

When we go into the talk, we’re going to put up a Microsoft Word blank sheet, basically, and keep a flow-point of concluding-the-way-forward thoughts – just to give us a virtual notepad to share and go with here.

Our panel, in no particular order, is Cheri Wiggs, Debra Babcock, Kurt Knight, Priscilla Rogers, Marsha Mazz and Patrick Fee. And we will begin with Kurt’s presentation. Kurt?

Kurt Knight: Development of VA Standards

I’m just going to give a little overview of VA’s standards website, a little discussion about how we go about developing the standards and implementing them, and a little about the issues involved relative to this particular subject.

Open Discussion (Earle Kennett, Moderator)

Comment and Question by Earle Kennett: Unless I’m mistaken, we didn’t have any other prepared remarks for this panel, but we will now open [the panel for discussion].

Issue 20: Why should we embark on a new guideline?

Kurt, you touched on one thing, and even though we’ve sat here and talked about this subject for two days now, and many have thought about it for years and very concentrated over the past couple weeks in preparation, we have to define the problem again maybe in our own group. Why do it? Why are we embarking on a new guideline? How can we define that as a need? When you go to your various leaderships, we have to take a step back from what we’ve actually talked about today and begin to add some definers of why we’re doing this.

Response by Kurt Knight: And VA is an easier sell because our average patient is older, has many more chronic conditions of mental health and alcohol and other psychological issues. Our typical patient is quite different than the private sector hospital. So from a safety perspective, and trust me, VA, safety, it drives you. It goes over the top. We’ve had a few suicides, and there’s been a series of mandated looks at all of our hospitals, everything imaginable that somebody could commit suicide doing, and there’s been changes in what you use in bathrooms and anything you can hang something on and a lot of direction and emphasis on that.

So I think it needs to be tied to safety. I think it needs to be tied to security and the energy issue, whether pro or con, whether it uses more or less, I mean, that can be debated and I am doing that but certainly those are issues that we could tie into, separate and apart from low vision. I mean, again, [in] this integrated approach, safety is a very strong issue. Security is a very strong issue. And, again, I think we can achieve [safety, and security while meeting] both energy and the range of issues.

Comment by [Participant]: You can anchor it, then, on your patient population because you’re VA.

Response by Kurt Knight: Yes. Because you can actually say our patient population is older, they’re injured, they’re here for care, and so low vision is an actual tangible percent population that we have to address. And I would say -- just to jump in, and then I’ll turn it over to you -- Social Security, the SSA has a mandate to bring people with disabilities into their workplace.

Response by Marsha Mazz: Every federal agency does. Every federal agency is mandated by an executive order to bring in people with disabilities, every single one.

Comment by Debra Babcock: It’s basically what I was going to say. There’s an executive order that mandates that federal agencies hire people with disabilities and veterans, and most federal agencies have disability initiatives, like you heard me discuss the IRS does, and I know this is going to sound cheesy but I feel very passionate about this subject, and one of the main reasons we should do this is because it’s the right thing to do.

As we hire these people and bring them into our agencies -- and we do a great job at the IRS recruiting them. We go to Alliance World. We have all these recruiting programs, and we bring them in, and then we do a horrible job of taking care of them once we bring them in. I mean, sometimes they sit there for six months waiting for assistive technology applications in order to do their jobs and they quit.

As I go around and interview these people, they’ve waited three, four, six months for an application for them to do their job and what have they been doing? They’ve been sitting there waiting and it’s horrible. It’s actually a crime, in my mind, and that’s why I feel so passionate about it. Because it’s great to say you have these hiring initiatives but if we don’t take care of these people with disabilities once we bring them in, or even our employees that develop disabilities, as Marsha has a wonderful little saying, that we all could develop a disability. Who’s going to take good care of us? Are we going to be sitting there for six months waiting for an application that will help us do our jobs? So, sorry y’all, I know I’m preaching to the choir, but –

Response by Marsha Mazz: I just wanted to say that there is a law and that law is the Rehabilitation Act of 1973, okay? And so for over 30 years the federal government has been required under section 501 to provide its employees with disabilities reasonable accommodations in order to do their work. I’m appalled to hear that people at IRS wait for months. I have several acquaintances who work for IRS at perhaps higher levels, and people and acquaintances with disabilities who haven’t [had] that experience, but I think that there is an issue with bringing in people at lower levels and then perhaps not seeing to their needs or maybe they’re not well-informed of their own rights.

But just because we talked about this the other day, the federal government has a nondiscrimination in employment policy. It isn’t a recommendation. It’s a law. And employees with disabilities have avenues to complain about these issues, and in fact there’s all kinds of recourse they have. So like the ADA, in the workplace, people have a right to accommodations. As we talk about improving the building, I think it would be a good idea to talk about improving the building perhaps in areas where you may have a less clear way to an accommodation.

You have a right to an accommodation to enable you to sit at your desk and do your job. If that means you need additional lighting, if that means you need assistive technology, then you should get it. I get mine within days. So I don’t know what the problem is at IRS. But you have a less clear right to be able to navigate the building, to be able to get lunch, to be able to socialize with staff or get to a meeting room. So maybe we should be looking at perhaps first providing guidance in the spaces where there is less support for the employee with a disability.

Comment by Debra Babcock: One thing I do want to add on to that is in headquarters, we have employees that get their applications right away. The locations I’m talking about are at the campuses, [where] they work at night and they receive even less support.

So some of the more obscure locations I think is really where my focus has been, and that’s why we developed the website in the first place so, even though they may not even have a computer, they may have a kiosk that they can go to and look up and try to find out facts. We have the JAWS applications on those computers and the zoom text. If you went into a lot of these federal headquarter buildings, I don’t think you’d see as much occurrence as you do in these more obscure locations out in the campuses and I think that would go for a lot of the service, federal agencies.

Comment and Question by [Participant]: So Marsha, from what you’re saying and what I’ve heard here at the table is that there is the germ of language in the current law that doesn’t exclude the issue of persons with limited sight. In fact, that could be the beginning of a foothold to say, well, those people are disabled and they should be accommodated for. Are we saying that there’s already the germ of some law –

Response by Marsha Mazz: No. I mean, it’s more than a germ. I mean, you know, it’s a full-blown infection. The law, the Rehabilitation Act of 1973 and the Architectural Barriers Act of 1968, ensured people certain rights. The ABA, the barriers act, is essentially, you know – operates like a building code. You build it, you mess with the building, you comply with the barriers act. And we write the standards, and we are to write the standards to benefit people with disabilities at reasonable cost and we always have to balance cost and benefit. And people with low vision are not excluded from the group of people that we are obliged to address in our guidelines and the resulting standards.

That said, that’s a generic accommodation that we would offer to a class of individuals. So for example, and I think I used this example and I apologize, yesterday, we say that for people who use wheelchairs, you design a ramp. You never exceed a 1 in 12 slope and if your ramp doesn’t exceed a 1 in 12 slope, then the ramp is compliant. But it may not meet certain people’s needs and we know that. We know that when we pick 1 in 12 that there are going to be outliers, people who will not be served. But on the whole, it serves a very broad range of individuals with mobility disabilities.

When that individual has his own unique needs which are not met, he has to then – he cannot file under the Architectural Barriers Act completely because the building is compliant. He has to go to his HR office and he has to say to the people in HR, I’ve got a problem, I can’t use this building that meets the standards and so I need you to develop an individual accommodation for me that meets my own unique specific disability-related needs.

So it’s the difference between building standards which address John Q. Public with a disability and an individual employee accommodation which addresses the unique special needs of John Jones, who is a real person, and so those two work together because the building standards give you a minimum level of accessibility that addresses a lot of people’s needs. But when they’re not met, you go to HR, you say, I need a reasonable accommodation. The reasonable accommodation might be for that guy who can’t get up that 1 in 12 ramp that we’re going to move your office so you don’t have to traverse the slope.

Issue 21: What additional education and training are needed for supervisors of employees with low vision?

Question by Vijay Gupta: So, Marsha, I’ve got a question. Are you saying that the chief architect’s space where I work, which I consider not accessible at all because there is no contrast, is that not in compliance? Is the office of the chief architect, which is a non-contrast environment, the old white on white on white environment not accessible?

Response by Marsha Mazz: Let’s take that specific case and figure out what possible things might happen. If you were to file a complaint with the U.S. Access Board, which enforces – that’s my agency – which enforces the Architectural Barriers Act, we would not – we would not make a finding in your favor because there is no violation of the Architectural Barriers Act accessibility standards. We would then refer you to your own section 502 HR folks, your own folks in GSA, and we would say to you, you may have a right to a reasonable accommodation under the section 502 of that act and this is the person you should contact in GSA.

You would go to that person in GSA and you would negotiate a solution that works for you. If you were assigned to the chief architect’s office and you said, I can’t navigate this office because of a lack of contrast, under reasonable accommodations and under employment law, they would have a variety of options. And one option might be to relocate your office to a place that you could function in, presuming you could still do your job with its relocation.

And most people with disabilities would object to being segregated from their – from the workforce. But I’m just telling you that I can reasonably anticipate that outcome. The other outcome, which is less likely, is that the chief architect will be instructed to paint contrast and build contrast into the space. You might also be asked for documentation of your medical condition and to document the need. We don’t have anything to document that there’s been a violation of a building standard. It’s a yes/no thing. The standard exists and it’s clear and it’s interpretable. So, is that 1 in 12 or is it not 1 in 12? If it’s not 1 in 12, we don’t care who brought the complaint because whether or not it interferes with their ability to negotiate the building is irrelevant. It’s a fact-based claim.

Comment by Dennis Siemsen: Okay, so let me see if I can summarize this. Let’s use Deb’s example here. So I’ve been hired by a federal agency. I go to work and for some reason I can’t do my work, whether I don’t have an accessible workstation because I have a vision impairment, materials aren’t printed in big print, I mean, whatever it is. And I could use Mayo Clinic as an example too, and again –

Response by Marsha Mazz: But they’re not federal, so let’s stick with federal.

But let’s say they were. They’re a big outfit and you’d think some place like Mayo Clinic would be – boy they’d be great. They’re really into employee – it’s one of the 10 best places in the nation to work, blah, blah, blah. But I come in and first of all I’m just tickled pink to have this job, because I’m disabled, and to get a job in the federal government with easy benefits and it’s stable, man, I am on cloud nine. For a veteran, there are no other jobs back [home] and I got a job with the VA? Man, what could be better. You think I’m going to go and start making waves here and say, gee, you know, I think I’ll file a complaint?

Response by Marsha Mazz: Many people do.

Okay, so that’s one thing. And then, let’s say [the employee goes] to the [Mayo] HR office but HR doesn’t really know anything about vision, because our employee health people don’t know anything about vision. Fortunately they had me around but they don’t always call me first. But let’s say the employee goes to the supervisor and the supervisor for whatever reason decides, I’m not going to do this. I’m going to just drag this out.

Comment by Debra Babcock: Maybe they’re new management.

Response by Dennis Siemsen: Who knows?

Comment by Debra Babcock: Right.

But it just doesn’t happen. I mean, shouldn’t there be like either an ombudsman or some –

Comment by Marsha Mazz: Yes, it’s called the U.S. Equal Opportunity Employment Commission.

Comment by Kurt Knight: But we have required training every six months, that if you as a new manager don’t know that it’s your responsibility to do these things, ultimately it’s going to come back on you that you’re not doing your job.

You could be held accountable. If you don’t help this employee and somebody finds out that it took weeks or months for this employee to get the accommodations, you know, then it could reflect badly on the supervisor.

Comment by Marsha Mazz: I didn’t mean to initiate a discussion of equal employment opportunity law and I don’t know how useful that is. All I meant to do was to say if we’re going to start out, a good starting place is in the areas of the building where an employee with a disability has less defined rights to influence changes in the building.

Like wayfinding within the building. The number one complaint we get from people with vision impairments is not that their workstation doesn’t work for them. It’s that they cannot find their way. They can’t get from the bus stop to the building entrance. They can’t get from the building entrance to their office. They can’t get from their office to the library to the cafeteria to whatever else needs to happen within any given daily routine, and so that’s the number one complaint we get from folks. It isn’t that when I’m sitting at my desk I can’t do my job.

Now, that may be just because of who we are. But I just am only suggesting that that the areas where you might have not only a greater impact but also areas where, as Kurt has suggested, you may be able to marry the low vision issue to the safety issue, because when you’re in an environment that is not your work space and you have to evacuate that building or you have to get out of that building, you know, quickly, then the factors that we’re talking about, you know, the ability to see the way, to identify that means of egress, to use this fixture as part of an easy egress becomes even more critical.

So if you’re going to marry the needs of individuals with low vision to the safety factors, I would think that in the general circulation within the building and within the public and common spaces within the building is the best starting point.

Let me just summarize. So what I’m getting at is, who acts as the advocate for the employee?

Comment by Debra Babcock: The manager. And that’s why I was asked to create the website. You summarized it perfectly. The commissioner said, you know what, this is an issue. We need to get a handle on it. We need to consolidate this information so the manager can say, I need this application, what are the steps, one, two, three.

So if the employee or somebody else identifies that there’s a problem – where are we going with this?

Question by [Participant]: Well, just to elaborate on what you were saying, in Vijay’s case, could the board help him in the negotiation to get the plant put back?

Response by Marsha Mazz: I won’t make that kind of commitment because we try not to interfere in an agency’s, you know, employment decisions and this is essentially the agency’s negotiation with Vijay. We might be able to provide Vijay information that will enable him to represent his needs better to his employer. But we would not intervene between an employer and his or her employee.

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.

Issue 23: Should design guidance for persons with low vision be prescriptive or performance based?

Comment by Marsha Mazz: I don’t know where we’re going with this because as we’ve said, time and time again, the issues of concern to this group here are not addressed by the standards. So educating people on the standards won’t be helpful.

Response by Earle Kennett: It’s probably the most helpful thing we’ll do.

Comment by Marsha Mazz: The only things that the standards require are certain accessible signs, okay, I’m trying to think, accessible ATMs. What else do we have? Well, first of all there’s no lighting standard at all, I mean, there’s none at all in the barriers act standards or in the IBC accessibility in chapter 11.

Response by Earle Kennett: You missed the whole point, Marsha. And here’s the point. You’ve got design teams, and it’s a matter of educating the project design teams in areas that they can bring their design expertise in. And it’s not a standard. In fact, the vast majority of design guys, the criteria are not cut and dry, black and white, yes and no. I think that’s where a big problem is: that the design teams don’t really look at accessibility across the board in the same sort of way as we’re looking at energy and green and areas like that. So there is a need I think to –

Comment by Marsha Mazz: If they’re interested in accessibility, they’d be looking at the standards.

Response by Earle Kennett: They’d be looking well-beyond the standards, well-beyond the standards. That’s the point that you’re missing.

Response by Kurt Knight: It’s not just missing the standards. It’s all of our standards, which in some cases are inadequate. There is no standard there [that A/E’s] had to deal with; we have to be careful. The word standards tends to be [misunderstood].

Comment by Marsha Mazz: You’re right. It is a significant problem, how do you get you’re A/Es and how do you follow up and do the review to make sure what they’re doing meets all of our requirements. And that is a major issue.

Comment by Jim Woods: I want to pose something here. I’ll probably get shot but I think we’re trying to put the square peg in a round hole. Part of what we’re talking about may be accessibility. But I don’t think the major issue of what we’re talking about, [which is] design to improve or recommendations to improve design for low vision persons, is necessarily something that we’re going to standardize.

Response by Earle Kennett: I agree, absolutely.

But we can have performance requirements, okay, and performance requirements can be put into standards.

Responses by [two Participants]: Or guidance. Yeah, like the VA documents, et cetera.

Response by Kurt Knight: Let’s call those guides. We’ve got to be careful in language here because standards mean something. We ought to talk in terms of guidance at this particular point.

Let’s talk about guidance. But the issue for me, fundamentally, is a lot of this discussion has gone along with ideas that “if you do this, it’s going to be permanent.” That thing is going to be there – if I put the sign on, it’s going to stay. Now, if I’m dealing with a lighting issue or a thermal or an acoustic issue, first of all, [it’s performance] doesn’t even start until the building’s occupied, because it depends on use patterns. So the use patterns have got to be put into the consideration.

The time of use is another situation. Is it going to be instantaneous? Is it steady-state? What are the dynamic implications? We’re dealing with a whole different realm of issues. I was trying to [describe] that this afternoon. So as we move forward, it seems to me that we’ve got to look at some kind of a dynamic approach that addresses the longevity of the occupant in the building and what’s going to happen with aging, what’s going to happen with the durability of the maintenance systems of the building itself. It’s going to change and we’ve got to accommodate people over time in a dynamic environment; we have not addressed that.

Comment by Fred Krimgold: I think that in picking up on that point that we’re not only looking at static physical solutions. But there’s an interaction of operational and management practices which make the system work and that’s where the flexibility enters in and where the judgment has to continue to be operative and that’s more complicated than prescriptive physical standards and it has to be taught and administered in a more subtle way. I understand the difficulty of the standard having to be something objective, incontrovertible and, objectively measured, and so on. But we’re really trying to improve the circumstances of people’s lives and that is a more comprehensive and complex activity than simply dimensioning or –

Response by Earle Kennett: And there can be many solutions to that.

Comments by Robert Lynch: Ladies and gentlemen, I don’t want to interrupt the flow of this conversation, but there’s a few points I’d like to make before we disperse today.

First of all, I’m reminded – and I don’t want to diminish the importance of a great old hymn called “Amazing Grace”, but I was lost and I was found eventually by people like Stephanie and a good friend of mine in the AIA, Syl Damianos. I wouldn’t be here today if they weren’t diligent in looking me up because I had moved to the sticks of Northern Virginia. But my three points I’d like to make, I am so grateful to be here. Vijay, who I didn’t know before today and all the others and you my colleagues who I’ve had a chance to maybe talk a little bit with, I am grateful for that and I look forward to a longstanding relationship as we work on this effort together.

But there are three points I’d like to make before we leave and if you forgive me, I’m going to read them so that I get it right.

1. Someone this morning mentioned that the ANSI A117 committee, should work on these standards and I agree. But we’re not qualified at the moment to do so. As an example to the contrary, the ANSI committee achieved good elevator standards and criteria over the years because we had strong participation by the elevator industry on the committee. They were always forthcoming.

   They were technically grounded and very persuasive in helping us to achieve good elevator standards. We need that sort of thing, that sort of participation on the ANSI committee. The International Association of Lighting Designers and the Illumination Engineering ought to be represented as professionals on that committee. We do have representation. As being a consensus committee, we do have representation from the disability community. But we need some good, strong technical people on that committee to get the job done. So I might say we might even have a volunteer here on this committee here today who might be willing to serve that way.

2. There’s another thing, a different tact that I think we may ultimately have to take. There’s a limit on what energy conservation can achieve. I mean, we are struggling. I mean, we hear things – like someone on high who probably doesn’t know enough about what they’re talking about says we’re going to have to achieve a 30 percent reduction in energy conservation standards over the next few years.

   It’s good to strive for ever greater efficiency and achieving better design and to attempt to meet an ever greater number of design goals while consuming an ever decreasing amount of energy. There will be a limit to this approach, however, and we may no longer be able to deliver ever better functioning buildings with ever diminishing amounts of energy. We may need to consider an alternate approach. That is we, our country, will probably eventually have to find a way to obtain more energy after all conservation efforts have been exhausted to meet more extensive, more sophisticated design goals.

3. My last point is very short and it has to do with energy conservation as an ultimate problem. The Department of Energy was instituted to solve energy conservation problems but I have a feeling that in the end-result or as we sit today, it might be the problem. So that’s all I have to say and I thank you for having me be with you today and yesterday.

Response by Marsha Mazz: Bob, as former chair of the ANSI A117 membership committee, and as a current member also of A117, I will say that anyone who applies for membership and has not ever attended a meeting is likely not to be accepted on the committee. So I would very strongly urge whoever is considering joining the committee to begin attending meetings.

We’re starting up a new cycle and to put in public proposals and come and defend those proposals and then ask to be on the committee because anybody can submit a proposal to A117 just like anybody can submit a proposal to the building codes. So although I strongly encourage professionals to step forward, I know that committee pretty darn well and the membership committee on which you also serve, always ask yourself whether this particular interest has ever participated or whether we can count on them to continue to participate once they’ve got their one issue solved.

Issue 24: What are the long-term and short-term targets for guidance?

Comment by Earle Kennett: Let’s go back to some of the things that are targets, long-term targets, short-term targets. We’ve talked a lot about the struggles of employee issues. We can spend days talking about that and we’d need to have a lawyer here to actually help us through that subject. But, where are we going? Fred talked about research. Kurt, you talked about, hey, we can put some of this stuff into action ASAP.

We need to create a tangible list of ways forward, long-term, short-term, middle term so that we know our mission going forward. I think as we near the end of our discussion, I would like to hear things rapidly go on a list.

Stairs, short-term list

I’ll put one up there, short-term, stairs. Stairs is a tangible safety issue and in fact the code has elements of some of the things that we’ve just described as better practices here for codes and guidelines that it’s easy to put our foot on and say that just needs to be enforced.

Response by Marsha Mazz: I think one of the things we can look at is the stair geometry and talking about is stair identification. Well, the tread and monitor Identification and identification of the stairs.

Response by [Participant]: But then again, stair safety would be legitimate for all of these.

Response by Kurt Knight: I think there’s been a number of presentations that have identified a number of issues and as we go through the presentations there’s a lot of consistency, to be quite honest with you, in some of the ideas presented of these shortterm safety type, easy to do solutions.

Contrast and wayfinding, short-term and long-term

Comment by Earle Kennett: You know, the whole contrast, wayfinding –

Response by Kurt Knight: Wayfinding.

But you know what’s really great about that and you know it was interesting. We went in to talk with Susan and you know she’d never even thought about that and we ended up talking an hour and it was very fun to sort of understand where her light bulb sort of started going off: it wasn’t a matter of new technologies or increased cost really. It was a matter of the design team relooking at a problem and coming up with design solutions; [to assure] that many of the decisions that they were making were not made to be barriers to people with low vision.

It just happened that way because they hadn’t thought about it; that if GSA can incorporate that into their criteria, it would be helpful not costly; you know, it clicked. The second thing that I think clicked on her, was this whole idea of changing demographics, because the low vision part, even though we understand it can be from birth, it can happen, as in Fred’s case, at a young age, but much of it happens as in an aging population. Quite frankly, the GSA staff demographics probably will be increasing over the years. All of us, or many of us here, that have not been completely successful in our 401s and pension programs may end up working a few more years.

Comment by Roberta Null: I was just thinking about with the aging there’s been a lot of work done and they’ve had a lot of money for doing this, fall prevention and it was USC and some of these others. I go to their presentations and they really do a good job of thinking about the demographics, aging and the two or three causes of fall. One is medication and that’s the medical and we can do all that and then another one is balance and they do a pretty good job of that with classes and different things like that.

Then they talk about architectural barriers. Well, of course stairs and things like that and they don’t think about it. I mean, they mention it but it’s just like, oh yeah, and then there are architectural barriers. I think that’s where we have a chance through the lighting people and the design people, the architects, you know, to really tap into something that’s already started. They have all kinds of funding and have done some really brilliant research in that area but architectural barriers, well, ‘we’ve got to get rid of the clutter and things like that.’ But I think it’s something that we can really contribute to.

Response by Marsha Mazz: I think if we decided, tomorrow, to start incorporating photo luminescent tread marking on all exit stairs, we would improve the ability of people with low vision and everyone else in the building.

Responses by [three Participant]: The majority of stairs in building are back of house. They’re really egress stairs. So they’re unfinished. They’re not painted, raw steel, the walls are not painted or anything, like the black stairs that Eunice showed in her presentation. So along with stair safety goes finishes, just paint the stupid things. Fifty cents a square foot. Leave the walls white because we can’t increase the lighting because the energy code doesn’t allow us. Give us some light-value finishes, voila we’ve lit the stairs.

Energy utilization, short-term and long-term

Comment and Questions by Cheri Wiggs: Just so I’m going along that point of forward thinking, because I have been thinking about this all along. This kind of guidance is going to help the general population, right. It’s not just a select group but it’s going to be all of us. So it’s wise to take this into account. All of us should be interested in this going forward.

I think I’m going to piggyback on a point that Marsha made earlier that really did resonate with me. I might sound a little contrarian, but this whole notion of the energy regulation, I’ve been hearing how difficult it’s going to make everything. But it is important.

I mean, it really is important for us to get a handle on how much energy we’re using. We’ve got a lot of intelligence in the room where we could say ‘look, this is going to happen and how much light we’re using is going to decrease and if that’s the case, it’s going to be difficult for all of us.’

Can we use this kind of intelligence to use smarter lighting? If they’re saying we can’t use as much, can we get some guidance here in terms of [how] this is going to be difficult? [Are there] ways you could do this in terms of paint colors? Where again, it’s going to be [for] all of us because we’re all going to be in a situation where the lighting is lower.

So it’s really thinking forward and it’s really attaching to what’s happening now. I’m not speaking as NIH here. I’m speaking as somebody who’s sort of been listening to the discussion here and I don’t know if that makes sense. But I also think it’s a lot more palatable if people [understand that] we’re not trying to fight against this. We know this is going to happen. But we could have some smart ways of dealing with this.

Response by [Participant]: We have taken action in that with the photoluminescence and setbacks on the lighting through service lighting systems for stairwells that glow 50 percent and, as soon as there’s motion, they’ll go up to 100 percent. So we’ve already done those types of things.

Research and its applications, medium-term and long term

Comment by Bob Massof: Well, just in two days of discussion I’ve been motivated of thinking how we would approach this from a research perspective. I think there’s a tremendous opportunity here to develop the [support] of this project with bringing together the expertise. I marvel at just the kind of expertise that’s out there and with bringing parties together, I think we can really build a project. So I just want to throw out some of the ideas that I’ve heard. I think first of all that there is a funding mechanism which is through the NIH for supporting these types of collaborations.

So I think it’s not pie-in-the-sky to talk about it. And there’s been some pretty spectacular collaborations, especially the one I’m developing, what’s called adaptive optic supply to the eye. That’s getting right down and seeing individual photoreceptors live through imaging and using technology that – the same type that’s used to look at galaxies thousands of light-years away by correcting for the averages in atmosphere. This corrects for the averages in the eye.

So that was literally pie-in-the-sky until this project started. So while that may sound like it’s too hard but I think the first step in just hearing a lot of the discussion about the regulations, like where do these things come from and what’s behind the recommendations and what’s behind the guidelines. It doesn’t sound like there’s an awful lot of data, and that some of it just is summary type of information. It’s not really getting down to a level of computational type of approach.

Comprehensive modeling of vision

So I think the first step would be to create a physics-based model of the environmental conditions so that you really can computationalize it in a database from any viewpoint of what the illumination of the environment is going to be. So, if I put my eye over here, this is what it’s going to look like. This is before you build anything, before you spend any money on actual hardware that this all can be part of the design phase to create a model that is a physics-based model.

On our side of the world, we’re already building physics–based models of retinal imaging and if you marry these two models together, the physics-based model of the environment becomes [integral] to the physics-based model of producing the image on the retina. What would have to be included in the model of the retina, which is very active research and we know people who are doing this type of research and we probably will be able to talk them into collaborating on this type of project, is some of the more subtle things that is very important to plan.

I think I mentioned yesterday the Stiles-Crawford Effect, which is the directional sensitivity of the photoreceptors. But there are physics-based models for that effect and that could be built into a computational model to handle scatter of light. So you can end up making measurements of fundus reflectance and things of that sort, build those parameters into the model. And so take the environmental, you put a glare source or a point source in the environment and we can look exactly at what would happen to the retinal imaging through those types of models.

The next step is to really fully characterize the population we’ve been talking about with respect to the parameters that we build consensus and support. People talk about contrast, play with color and illumination. So we really want to describe what the characteristics of not only the low vision population but the older population in general. Some of this John Brabyn showed to suggest that low vision is kind of in the eye of the beholder literally.

We can then have a description of the important vision parameters and there are unemployed psychophysicists I think we can put to work on that project and we have collaborative networks set up already to collect these data and we don’t need – well, John will know what I’m talking about – white bars and review systems to do this, that we can do it with equipment that readily can be put into a clinic out in the field and so we can gather rather large quantities of data in a reasonable period of time.

That then also gets added to on most of the people on this side really developing kind of a conceptual model of what are these constraints on the design. You’re bringing in legal requirements, you’re bringing in things that pose constraints on what you can do and so those should factor into whatever model we’re developing so that gets taken into consideration and limits your options.

Every modeling effort has to have constraints. They might as well come from the outside as well as those from the inside. And then, finally, there needs to be some qualitative research that’s done on the side dealing with the aesthetics and dealing with the functional usability both from the standpoint of the owners and from the standpoint of the people who are expected to use it so that if you have this tension between the artistic and the practical, you know, how do you place value on those two things, on those people who have a stake in it, and there are tools out there for doing that.

We’re always doing quality of life research in health care and so many of the concepts and many of the tools that are used for quality of life research could really get transferred over to these various kinds of questions more subjective types of measurements of subjective phenomena, the so-called latent barriers and that ought to be built in.

So by putting a collaboration together with all the appropriate expertise, working in parallel to create these pieces, you can kind of put a whole system together that would allow you to rather than having to build consensus among all parties really allow you to do something in a very quantitative and very objective way and then you’re not – we’re always saying in campaigns, you can have your own opinions but not your own facts. This puts all the facts under the control of something that we all agree to, something that’s all objective, and then now you can get down to making decisions without arguing over how we’re making decisions.

Comment by Fred Krimgold: Well, I just wanted to very strongly endorse what Bob has suggested because I think, you know, that given the expertise that’s been revealed in this room, the idea of developing parallel models of individual visual capability and the salient factors in the environment that influence the functioning of that individual visual system allows us to structure our understandings, our experience, the existing models, [and] the resources available in a way that allows them to interact in such a way that we can evaluate existing environments, we can evaluate hypothetical environments, we can evaluate potential policies.

It gives us a really powerful new tool for looking at this whole set of issues and it certainly qualifies as a serious area of applied research for both physical environment engineering architecture and on the medical ophthalmological side and it can then provide a basis which I think will be tremendously valuable to whatever application comes after it, be it a regulatory application. We have – we will then have an organized foundation for presenting those arguments and for again looking at costs and benefits, if that’s relevant, if that has to be dealt with. And it’s a very exciting possibility.

I think it’s the sort of thing if there is a funding source that would be appropriate for pulling together that kind of cross-disciplinary group -- and by cross-disciplinary I mean not just academic disciplines but practitioners, and -- that is, both medical practitioners and [design and operations] practitioners, we could do something that would be tremendously stimulating and valuable and it might well be done under the auspices of NIBS, which has the kind of relationship with federal agencies that could facilitate this kind of a collaborative effort.

Comment by Cheri Wiggs: What Bob was mentioning is actually a program announcement that is written specifically to encourage the type of collaboration that he described in bioengineering, and bioengineering is defined pretty broadly. So there’s actually a program announcement at NIH that specifically is meant to encourage that kind of research effort. So it exists.

Guidance Documents, short-term

Comment by [Participant]: I think Bob’s absolutely on the right track, and I think that’s one of the sort of things we should start on immediately that will have medium to long-term effect.

And it seems like another medium-term effort should be the things that have come up yesterday and today about the ANSI committees and Illumination Engineering Society committees. [They] are really closely related to this field and we could start developing input for those, which would eventually result in standards that were backed by facts and research and that kind of thing.

It seems like we should also think about maybe some short-term efforts in that some of the things that we’ve all discussed over the past couple of days are kind of so well-agreed upon and obvious that it might be a good idea to try to compile something almost immediately that everyone agrees on. And whether it’s a brochure put out by NIBS or whatever it is, it could be something that could be just used as examples or suggestions for good practices.

Comment by Roberta Null: I wanted to offer sort of a framework that we could start with and I just have – I wrote this book Universal Design. It was called Creative Solutions for ADA Compliance and it came out in ’96, and it’s out of print. But I’ve been working on a revision of that – and with best practices and things that are going on in a whole variety of areas related to universal design.

I just lost my publisher because it was somebody in interior design and very interested in the fluff, and not understanding universal design. I thought, well, I’ve got a lot of it done, so I could bring in the collaborative thing and it started out that way anyhow.

I certainly would be willing to work with anybody who’s interested in really having some examples of things right now. That would be something that I will offer as something that I think could be a solution because I think that I’ve done a good job so far and the book has received a lot of recognition.

I’ve never made a lot of money on it, but the people in Japan think it’s wonderful, because they’ve got this aging population, and of course in working with the elderly. I’m an advocator, and so it’s been written but it’s got a lot --. I’ve found it on Amazon and I can buy the used book. This was in a library someplace and nobody checked it out. So I could get it for $15.

But the other thing, when we were talking about stairs, I worked with a fellow called Jake Paul. He’s working on the international codes and things like that. But we could really bring in, you know, people who, I think the people in this group really recognize, lots of experts in different areas, and I think that that would be a good example because he’s really –

Response by Marsha Mazz: And Jake is on the ANSI A117 committee.

Comment by Jim Woods: I’m going to take a chance on something here and look at it shortterm, mid-term, long-term, and go back to some of the stuff that I used to deal with when I was teaching in the classroom, undergraduate and graduate levels. I’m going to propose three principles and see how far they fly:

• One is to design for health and well-being, not just to prevent disease or infirmity.

• The second is to design for the last day of occupancy, not the first day.

• The third is to minimize energy consumption, don’t build it; otherwise, optimize energy efficiency to achieve the design objectives.

I don’t know if that captures what we were talking about here or not but it gets across both the current situation, the energy issues, but it also, I think, attacks some of the health issues, and we can then start putting the low vision lighting and stuff like that within it. But it would lead us I think in the area of being able to support that with research.

Response by [Participant]: I like your first point, because I think that what Bob has suggested is a starting point on that, which can be supplemented with similar approaches to modeling this individual environment to fit at the same level of sophistication for other types of sensory and physical conditions. And then we have something to work with. I mean, we then have a basis for making rational recommendations and having reasonable answers to the skeptics.

Comment by Erin Schambureck: In the interest of giving ourselves some short-term goals to work on immediately and [to] have something to review, possibly when we consider getting together in three or four months here, would it be a positive thing to – and I’m willing to volunteer for this task – but to take all of the presentations and the notes and things that have been taken from this workshop and compile two lists?

One is a list that would go out on the site that would be the list of the identified problems – not the solutions yet, but the list of the identified problems that we’ve all talked about, and try and define them as we can. Maybe that’s a Google doc that people can access and modify or revise or update, still trying to keep that succinct.

We want it to be obvious what we’re talking about and not go into the hours of discussion that we’ve had here, but to create that list of identified problems, and then the second list to create a list of the proposed solutions to those problems.

So the second list might have that point that says we have a high-contrast strip at the top stair and the bottom stair of each stair section, you know, at each landing – simple solution, two sentence, something that then that second list is again user-friendly where it’s succinct but we’re solving problems or at least attempting to solve problems and creating something almost immediately that can be used at the VA, that can be used at the IRS, that can be used throughout GSA quickly.

[Editor’s Note: Erin has drafted the list: it is included as Appendix G.]

And then as part of the mid-term and long-term solutions, we’re backing that up with research and developing ways to turn that into more long-term implementable solutions, and I’m willing to do that, to cull through the information in my free time.

Responses from [five Participants]: Wow. And create those two lists so that we have a summary of what’s happened. Sold. This can become a living document in the short term. With data of items to move forward.

Comment by Bob Massof: Our deadline is November 16. That’s the deadline for an R-21 proposal to do an exploratory – kind of the equivalent of like a planning grant to put together this type of a collaborative project, and so the next window to do that is – the deadline is November 16, which if we could meet that – it’s a six-page proposal. It’s going to be denser than a New York bagel, but the earliest start date would be July 1.

Comment by Earle Kennett: So to some people who are interested in pursuing that type of thing, you know, raise your hand. We could really get started on this immediately and we’ll set up some conference calls and –

These can be completely parallel.

This is really kind of a framework for things that Kurt –

Response by Kurt Knight: Both are useful, I mean, absolutely.

Well, we can quote your problems in the beginning of the research project.

Comment from Marsha Mazz: Well, it’s kind of hard to hear over here what you’re exactly talking about and I can’t read your lips. So, if you could talk about what the research is again that you’re trying to do?

Response by Bob Massof: Well, the larger project, which is what would be two years preparatory window in terms of before you would actually engage in, there’d be a lot of preliminary groundwork to do: planning and pilot work to see what’s feasible and what direction you go and things of that sort.

So there’s two phases to it, and the first phase is this planning and feasibility phase, and there’s a program announcement within the NIH to support just that for these collaborations, and there are grant types that are called an R-21. It’s an exploratory grant. You don’t need preliminary data to show what you’re going to do. There’s no risk. So it gives you an opportunity to do some things a little wild and crazy.

So it’s providing funding to help people get together, provide funding to get some pilot data, provide funding to try some things out, see what’s going to work, what’s not going to work. And so if we wanted to get on that train, it leaves the station November 16, and we would be able to get started doing work. The earliest start date would be July 1.

And so there, what we would need is for people to basically identify themselves as being interested, wanting to participate and to help shape the larger project. It would involve, you know, conference calls – maybe if NIBS would be interested in hosting these kinds of meetings to help shape that out, then that might all get together on occasion to further refine and put this together, and probably bringing in other people as well who represent certain technical expertise that we may not have represented here. Like, if we’re going to do physics-based modeling, we want people who know how to do physics-based modeling. We want some optical people who do these rate tracing models, and these are kinds of people who design lenses and do things like that. You do that with helicopters, I know.

Comment by David Munson: I do that with architecture. I was one of the guys who invented it. And here’s the problem. Unless you’re doing 100 courtrooms and you’ve got a federal judge who wants to see 100 federal courtrooms, you can’t afford to do it because the cost to build the model is almost as much time as designing a real courtroom and getting the thing finalized. I’ve got a courtroom program right here. You can dial up how many people are on the jury, how many tables the defendants are going to have, what colors, is there skylights; and it will generate a three-dimensional model and you can walk around and you can grab a chair and you can put it over here and you can say, does all of the chairs see everybody’s chair because they’ve got eye heights, and can the judge see all the ones in the jury? And you can go through all the stuff and in the end it’s not very damned practical.

Response by Bob Massof: Well, you’re about 50 years ahead of my thinking.

Comment by David Munson: I was flying three-dimensional computers in 1983. We did raytracing, we did full radiocity calculations.

Response by Bob Massof: So this may never be useful. This is really designed to understand the problem. It’s still a research project. The idea is to create a research tool.

Comment by David Munson: Find five buildings that you find acceptable. Find five buildings that you find acceptable and say these guys work. Find five that don’t work. Publish just the pictures.

Interdisciplinary Communication and Vocabulary

Comment by Jim Woods: The thing that I think is so exciting about where he’s going with this is addressing a little bit of the gap analysis that we talked about yesterday, that the physics in terms of parameters that we can design with are not there, and you know, we’ve got some information on the perception which may or may not be valid. And so you’re starting to address those things at a research level that we can put some certainty to or look at least at the uncertainties to it and have a foundation to work from.

Response by Bob Massof: Research versus common design.

Comment by [Participant]: I don’t think in the end you’re going to get a specification that says this is what it looks like. And unless you’re ready to give an order to say this is what it looks like, you aren’t going to be able to [complete in] a two-year research-worthy project, and I’m exaggerating of course, but to solve these problems on every single project. What I think this is getting to do is to try to really focus [and] maybe to assist us common practitioners, small businesses, who have to solve problems every day with an eight-hour day, 40-hour week draftsman who gets paid a certain amount of money.

Comment by Jim Woods: A basic problem that has come up in the discussions in the last day-and-a-half is that a lot of you talked about the necessity of measurement in order to give instructions, in order to set standards, in order to define objectives, in order to support regulatory activity.

And what we’ve heard from both sides is that the measurements aren’t compatible now, that we don’t have a way of expressing in the physical description of the environment the factors that are relevant for the performance of the individual, and that’s what we have to find in this mutual modeling exercise. It’s not a trivial thing, because what we are trying to do is look at the interaction of two existing bodies of knowledge and two sets of phenomena, and if we arrive at that, then we have the basis for a lot of thinking and a lot of activities beyond specific design.

I think what you’re suggesting about the 10 pictures, five good and five bad, is immediately tangible, practical and something that you could use in terms of getting the job done quickly make sense. But what we’re trying to do with this in parallel to that -- and I think maybe that should be another short-term activity, but what we’re trying to do here is lay the foundation for coherent communication between two bodies of knowledge and to allow for the construction of interaction of an understanding of individual human capacity as it may change and is changing, and of dynamic environments which can be modified and can be supportive or less supportive depending on how they’re designed.

And by taking pictures of what’s out there and what’s worked, it’s a rough-and-ready summary of what combination of things happened to have worked but it’s kind of an artistic approach rather than one of trying to identify what those specific relationships are and what the mechanisms of relationship are which we were trying to approach in the modeling.

Response by Bob Massof: Where the differences are derived, the physics of the picture are very different from the physics of the environment. So to get this picture and use it, looking at the simulation [is only a start].

Comment by Vijay Gupta: I’ve been thinking that it’s [encouraging] that the medical community and the engineering and design community [are here] and I think that’s a good solution right there. We need the support of the medical community to meet Marsha’s needs, and not only Marsha’s needs but to meet other needs. So the medical community and architectural and engineering community needs to get to get together.

Response by [Participant]: And we need to begin that vocabulary list.

Comment by Jim Woods: I think we said that yesterday and I think that’s got to be on one of our big list items here. We don’t have a common vocabulary list, just the way of speaking a language together besides the research, so we can understand some of what you’re saying and you can understand, and we can begin to talk more fluently on the subject.

Comment by [Participant]: Well, a final project would support continuous interaction between representatives of each of the communities and that would be in itself –

Response by Bob Massof: And maybe that’s part of what goes into this planning grant. We need to develop a common language.

Response by [Participant]: From our perspective, we really need you guys to help us and I think this would be a perfect collaboration to provide both directions.