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

Comment. In order to accommodate people with hearing or speech impairments, the proposed guidelines specified that the emergency communication system not rely solely on voice communication (407.2.13 in the proposed rule). The Board sought information and product literature on emergency communication devices and communication technologies that provide two-way communication in a manner accessible to people who are deaf and others who cannot use voice communication (Question 22). Comments, particularly those from groups representing persons who are deaf or hard of hearing, strongly supported such a requirement. They considered some form of interactive communication similar to that available through TTYs essential for providing equivalent access in emergencies. However, these comments did not specifically mention any technologies that are currently available to provide such access within elevator cars.

Response. Additional requirements for emergency communication systems are not included in the final rule. Further, the Board has removed specifications concerning the method of communication since the referenced elevator safety standard contains analogous provisions. Under such provisions, emergency communication systems cannot rely solely on voice communication. The ASME A17.1 code (section 2.27) requires provision of a push button labeled "HELP" which, when activated, initiates a call for help and establishes two-way communication. A visual signal is required on the same panel as the "HELP" button to notify persons with hearing impairments that the call for help has been received and two-way communication has been established. Voice (or other audible systems) with a visual display that provides information on the status of a rescue will meet this requirement. Clearly labeled visual displays can be as simple as lighted jewels that indicate that the call for help has been activated and that the message has been received. The visual signal is also required to indicate termination of the two-way communication link.