Other Issues

Door Hardware

The Board sought comment on the mounting height of door hardware. The CAH study recommended that door hardware be mounted 30 to 34 inches high for children with disabilities, instead of the 48 inch maximum specified by ADAAG 4.13.9 (Door Hardware). The proposed rule asked whether this height would serve adults adequately (Question 25).

Comment. Support was expressed for a height up to 34 inches but several designers considered this below the standard mounting height for adults, which is within a range of 36 to 42 inches.

Response. An alternative height for door hardware based on children's dimensions is not provided in the final rule. ADAAG 4.13.9 permits hardware to be mounted below 48 inches.

Signage

Tactile signs are required by ADAAG 4.30.6 (Mounting Location and Height) to be mounted 60 inches from the floor measured to the sign centerline. Since this is above the reach height of children, the Board sought comment on whether tactile signs should be provided to serve children as well as adults and, if so, whether there was an alternative mounting height that would adequately serve both (Question 28).

Comment. A majority of comments indicated that signage is usually intended for use by adults. There was little consensus among commenters supporting an alternative height that would serve children and adults.

Response. An alternative mounting height for tactile signage is not included in the final rule.

Protruding Objects

ADAAG 4.4 (Protruding Objects) specifies that elements mounted on walls such as phones and light fixtures not project more than 4 inches from the wall surface if the leading edge is above 27 inches from the floor. It also specifies that free-standing objects on posts and pylons may overhang 12 inches maximum if the leading edge is above 27 inches from the floor. The 27 inch height is based on the cane sweep of people with vision impairments and range of detection. The cane sweep of children with vision impairments is typically lower. The proposed rule reduced the 27 inch height to 12 inches based on recommendations from the CAH study. This requirement was intended to apply to routes serving facilities or portions of facilities constructed according to children's dimensions and anthropometrics.

Comment. The proposed rule sought comment on whether the proposed requirement for protruding objects should apply only to routes serving facilities or portions of facilities or whether it should also apply to routes leading only to an element designed for children (Question 2). Most comments recommended that the requirement should not apply to routes leading to single elements designed for children. An organization representing people with vision impairment opposed projections with leading edges below 12 inches since children are not as skilled as adults in using canes. The proposed rule also asked about the cost impact of the proposed requirement since it would generally require elements with required knee and toe clearance, such as drinking fountains, to be located in alcoves or to be protected by walls, partitions, or other features. Few commenters provided information in response to this question. Several comments suggested costs between $200 to $500 for wing walls or partitions at a fixture. One commenter recommended that the proposed requirement not apply to those elements required to provide knee clearance.

Response. The final rule has been revised to more clearly focus on elements designed for use primarily by children. Modified specifications for protruding objects however would apply to other elements, including those designed for adult use, along circulation paths. The application of the proposed specification would be difficult to determine or be a source of confusion. Further, an organization representing people with vision impairments suggested that further study in this area may be advisable. Specifications for protruding objects based on children's dimensions are not included in the final rule.

Urinals

The CAH study recommended that urinal rims be 14 inches high maximum and that flush controls be 30 inches high maximum above the floor instead of the 17 inch rim height and the 44 inch flush control height specified by ADAAG 4.18 (Urinals).

Comment. The proposed rule asked whether product or design solutions are available that meet these specifications and code requirements (Question 26). Some comments stated that they were not aware of complying products but suggested design solutions for the mounting height of flush controls. These included mounting the flush control on the floor or next to the urinal on the wall, automatic or electric sensors, or push button controls.

Response. The Board considers additional information on design alternatives necessary before issuing specifications for urinals based on children's dimensions.

Clear Floor Space and Accessible Routes

The CAH study recommended wider widths for clear floor space and accessible routes since a child's upper body strength and maneuvering skill is not as developed as those of an adult. The study recommended a minimum clear floor space width of 36 inches instead of 30 inches and a minimum clear width for accessible routes of 44 inches instead of 36 inches.

Comment. The proposed rule asked whether these recommendations should be included in the final rule (Questions 21 and 22). A slight majority of comments opposed both these recommendations. Of the few comments providing a reason for support or opposition, most addressed cost and space impacts. Some considered the impact to be minimal while others considered it to be significant.

Response. Alternate specifications for clear floor space and accessible routes are not included in the final rule.

Classroom Acoustics

Comment. Organizations representing people who are hard of hearing as well as audiological and acoustical trade associations and consultants recommended that the final rule provide acoustical performance standards for classrooms. These commenters recommended specifications for background noise levels, reverberation time, and the signal to noise ratio.

Response. Acoustical standards have not been included in the final rule because none had been proposed and made available for public comment. While acoustics is an important consideration not only in classrooms but other spaces as well, it has not been addressed at this time.

Technical Assistance

The Access Board provides technical assistance and training for entities covered under the Americans with Disabilities Act. The Access Board's toll-free number allows callers to receive technical assistance and to order publications. The Access Board conducts in-depth training programs to advise and educate the general public, as well as architects and other professionals on the accessibility guidelines and requirements. In addition, the Access Board is developing a manual for use by both technical and general audiences. The general manual on ADAAG requirements will be a useful tool in understanding ADAAG whether for purposes of compliance or as a reference for accessible design.