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

216 Signs

Scoping requirements for signs cover room designations (216.2) and directional and informational signs (216.3). The guidelines also include provisions specific to certain elements and spaces, including parking, entrances, means of egress, and toilet and bathing rooms. In the proposed rule, these requirements were located at the scoping or technical sections covering the elements and spaces. In the final rule, all scoping requirements specific to signs have been localized in section 216.

Section 216.1 exempts certain types of signs, including building directories, menus, building names, temporary signs, and signs provided in non-public use spaces of prisons and jails. In the proposed rule, these exceptions were listed separately among provisions for room designations and directional or informational signs. For simplicity, they have been relocated as exceptions to the general scoping provision (216.1) which exempts them from this section entirely. In addition, the final rule includes new exceptions for:

  • seat and row designations in assembly areas (Exception 1)
  • occupant names (Exception 1)
  • company names and logos (Exception 1)
  • signs in parking facilities (Exception 2)

The Board included exceptions for occupant names, and company names and logos, which is consistent with its interpretation of the original ADAAG provisions and the intent of the proposed rule. These added exceptions clarify that the names of stores in shopping malls, building names, and similar types of signs are exempt from these requirements. A new exception exempts signs in parking facilities from compliance with the signage provisions of section 216 except those covering means of egress (216.4) and designation of accessible parking spaces (216.5).

Comment. Commenters requested that seat and row designations in assembly areas be exempt from the requirements for signage. It was also suggested that an exemption be provided for signs in parking facilities which are intended for use by vehicle drivers.

Response. An exception has been included in the final rule for seat and row designations and signs in parking facilities.

Comment. Comments requested clarification on what constitutes a "temporary" sign.

Response. The Board has interpreted this reference, which is included in the original ADAAG, as pertaining to signs that are posted for a short duration. For greater clarity, the Board has described temporary as "seven days or less" in the final rule.

Section 216.2 covers designations of permanent rooms and spaces, including pictograms provided as part of such signs. These types of signs are required to be tactile through the provision of braille and raised characters. This provision has been editorially revised and simplified in the final rule, though its application remains basically unchanged. For example, the term "permanent" as a descriptor of the types of designations covered has been removed as unnecessary since opposite types ("temporary") are exempted.

Comment. Some comments considered the scoping provision for room designations difficult to understand.

Response. In the final rule, requirements for designations in section 216.2 have been simplified without substantive change.

Information and directional signs are addressed by 216.3. These types of signs are not required to be tactile but are subject to requirements for visual legibility and contrast. Signs providing direction to or information about interior spaces and facilities are required to comply. In the final rule, the Board has removed "permanent" as a descriptor of the type of rooms and facilities covered in this provision.

Various signage requirements specific to certain spaces and elements have been relocated for simplicity and ease of reference to section 216. These provisions include:

  • 216.4 Means of Egress (from 207.3, 410.7, 410.8)

  • 216.5 Parking (from 208.3)

  • 216.6 Entrances (from 206.4.8)

  • 216.7 Elevators (from 407.5.7)

  • 216.8 Toilet Rooms and Bathing Rooms (from 213.2.2 and 213.2, Exception 4)

  • 216.9 TTYs (from 217.4.9)

  • 216.10 Assistive Listening Systems (from 219.4)

  • 216.11 Check-Out Aisles (from 227.2.1)

  • 216.12 Amusement Rides (incorporated from guidelines previously issued for recreation facilities)

Substantive changes have been made to provisions for means of egress, parking, assistive listening systems, and check-out aisles.

Section 216.4 provides specific requirements for means of egress, including exit doors, areas of refuge, and directional signs. The proposed rule required tactile signs at exit doors and provided specific requirements for areas of refuge and directional signs. These specifications are substantively revised in the final rule. The requirement for exit doors (216.4.1) has been clarified as applying to "doors at exit passageways, exit discharge, and exit stairways." In the final rule, scoping requirements for means of egress and areas of refuge have been revised to reference provisions in the International Building Code (IBC) as discussed above in section 207. Corresponding changes have been made to signage requirements for areas of refuge (216.4.2) and directional signs (216.4.3) which now reference the respective IBC signage specifications for scoping. Such signs must be provided where required by the IBC but are subject to technical specifications in these guidelines at section 703.

Accessible parking spaces are required to be designated by the International Symbol of Accessibility according to 216.5. This provision was located at 208.3 in the proposed rule. Exemptions are provided for small lots (Exception 1) and spaces individually assigned to residential dwelling units (Exception 2). Under the first exception, accessible spaces in lots with four or fewer spaces are not required to be identified as accessible (i.e., reserved solely for use by people with disabilities). This exception is intended to mitigate the impact of a reserved space in very small lots and stems from model building codes. In the final rule, the scope of this exception was revised by changing the maximum lot size eligible for it from five to four. The exception for residential dwelling unit spaces has not been changed.

Comment. The proposed rule removed a requirement that the access designation for van parking include the term "van accessible" to clarify that both car and van drivers can use such spaces, as was the original intent of ADAAG. Many comments strongly opposed this change. While some may have misinterpreted it as removal of the requirement for van accessible spaces, others considered this designation important in encouraging car drivers to use other accessible spaces over those designed to accommodate vans.

Response. The final rule restores the requirement for van spaces to be designated as "van accessible," which is provided in the technical criteria for parking (502).

Comment. Signs are required to indicate the availability of assistive listening systems, which are required in certain assembly areas (216.10). In the proposed rule, such signs were required at ticket offices and windows. Comments pointed out that some assembly areas subject to this requirement may not have ticket offices or windows.

Response. In the final rule, the requirement has been revised to require signs for assistive listening systems at each assembly area required to provide an assistive listening system, but an exception allows such signs to be located at a ticket office or window instead, where provided.

Comment. Section 216.11 requires identification of accessible check-out aisles. The proposed rule required that this identification be placed in the same location as the identifying number or type of check-out aisle. Commenters noted that not all check-out aisles are distinguished by numbers. They recommended that the guidelines should be revised to ensure access to each type of aisle serving a different function, such as express aisles or cash-only aisles.

Response. The requirement for identification of check-out aisles has been revised to require that accessible designations be located in the same area as the number, letter, or function identifying the check-out aisle. The proposed rule required that accessible designations are not required where "all check-out aisles in the facility are accessible." This provision, which is reformatted as an exception in the final rule, has been revised to apply where "all check-out aisles serving a single function" are accessible.


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