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

309 Operable Parts

Specifications for operable parts address clear floor space, height, and operating characteristics. Operable parts are required to be located with the reach ranges specified in 308. In addition, they must be operable with one hand and not require tight grasping, pinching, twisting of the wrist, or more than 5 pounds of force to operate.

Comment. The proposed rule included an exception from the height requirements in 309.3 for special equipment and electrical and communications systems receptacles. This exception’s coverage of various operable parts was considered to be too broad.

Response. This exception has been revised to specifically cover operable parts that are "intended for use only by service or maintenance personnel," "electrical or communication receptacles serving a dedicated use," and "floor electrical receptacles." However, since such equipment may merit exception from other criteria for operable parts besides the height specifications, this exception has been recast as a general exception from section 309 and has been relocated to the scoping requirement for operable parts in Chapter 2 (see section 205.1, exceptions 1, 2, and 4).

Comment. Gas pump manufacturers indicated that the safety requirements for the operation of gas pump nozzles effectively preclude a maximum operating force of 5 pounds.

Response. An exception has been added to 309.4 that permits gas pump nozzles to have an activating force greater than 5 pounds.

Comment. The Board sought comment on whether the maximum 5 pounds of force was appropriate for operating controls activated by a single finger, such as elevator call and control panel buttons, platform lift controls, telephone key pads, function keys for ATMs and fare machines, and controls for emergency communication equipment in areas of refuge, among others. Usability of such controls also may be affected by how far the button or key must be depressed for activation. Specifically, the Board asked whether a maximum 3.5 pounds of force and a maximum 1/10 inch stroke depth provide sufficient accessibility for the use of operable parts activated by a single finger (Question 18) and whether there were any types of operable parts that could not meet, or would be adversely affected by such criteria (Question 19). The few comments received on this issue were evenly divided on the merits of adding these specifications. Comments noted that they would pose problems for fare machines and interactive transaction machines designed to withstand vandalism and misuse, various types of plumbing products, dishwashers and laundry machines, and amusement games and attractions. The elevator industry indicated that the noted specifications would not pose a problem in the design of elevators.

Response. Due to the limited support expressed and the potential impacts raised by commenters, a maximum 3.5 pounds of force and a maximum 1/10 inch stroke depth for operable parts activated by a single finger has not been included in the final rule.