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Outline of Major Revisions to Americans with Disabilities Act Accessibility Guidelines (ADAAG)

This document is archived as it is no longer timely and may be only of historical value.

For information on current issues see the Public Policy and Policy Research section.



This document provides a brief description of the proposed changes to the Americans with Disabilities Act Accessibility Guidelines (ADAAG) of particular interest to people who are blind or visually impaired. The full text of the proposed revision can be found at http://www.access-board.gov/ada-aba/guidenprm.htm. Additionally, the full text of the current ADAAG can be found at http://www.access-board.gov/bfdg/adaag.htm.

Comments on the proposed changes due May 15, 2000, should be submitted to the Access Board at:

Office of Technical and Information Services
Architectural and Transportation Barriers Compliance Board
1331 F Street, NW., Suite 1000
Washington, DC 20004-1111

E-mail comments should be sent to docket@access-board.gov. Comments sent by e-mail will be considered only if they include the full name and address of the sender in the text. Comments will be available for inspection at the above address from 9:00 am to 5:00 pm on regular business days.

The Americans with Disabilities Act of 1990 (ADA) (42 U.S.C. 12101 et seq.) recognizes and protects the civil rights of people with disabilities and is modeled after earlier landmark laws prohibiting discrimination on the basis of race and gender. The ADA requires that buildings and facilities be accessible to and usable by people with disabilities. The ADA establishes accessibility requirements for new construction and alterations of State and local government facilities under Title II and places of public accommodation and commercial facilities under Title III. The law requires that the Access Board issue minimum guidelines to assist the Department of Justice (DOJ) and the Department of Transportation (DOT) in establishing accessibility standards under Titles II and III. These standards must be consistent with the Access Board's guidelines.

Although there are a variety of issues of interest to people who are blind or visually impaired in ADAAG, topics treated below have been grouped into three major issue areas: Automatic Teller Machines and Fare Machines; Detectable Warnings; and Signs. The proposed ADAAG sections outlined below are of two types: ADA Scoping requirements which define and describe what is and is not covered by the rules; and ADA Technical Requirements which describe in detail the methods and architectural specifications to be used to meet the scoping requirements. Major blindness-related ADAAG revisions to both scoping and technical requirements are set forth below, along with questions that the Access Board is asking commenters to specifically address. The sections highlighted below make substantial use of cross references both within each section and among sections, and readers are encouraged to consult ADAAG directly via the web addresses provided above. Commenters are also encouraged to provide favorable comment to the Access Board regarding those revisions appreciated by commenters, as well as critical comments on provisions that commenters disfavor. Note that, in several instances, ADAAG provisions are labeled "advisory," meaning that they do not enjoy a mandatory status. Commenters should refer specifically to these advisory provisions and comment on whether such provisions should be made mandatory. Sections labeled "NOTE" below are offered to provide further suggestions for commenters.

Topic 1: Automatic Teller Machines and Fare Machines

ADA Scoping. Section 220. Automatic Teller Machines and Fare Machines

Although this provision specifically requires automatic teller machines to be accessible, this provision now addresses "fare vending, collection, or adjustment machines," which have heretofore only been addressed by ADAAG where they are provided in transportation facilities. This revised section reads as follows:

220 Automatic Teller Machines and Fare Machines

220.1 General. Where automatic teller machines or self-service fare vending, collection, or adjustment machines are provided, at least one machine of each type at each location where such machines are provided shall comply with 707. [omission]

NOTE: Commenters may wish to provide feedback regarding the widening of this scoping requirement to include fare collection and other machines. Additionally, commenters will want to give attention to question 31 below.

ADA Technical Requirements. Section 707. Automatic Teller Machines and Fare Machines

New specifications are provided so that access to input and output devices is provided for people with vision impairments. These requirements provide clearer guidance than ADAAG 4.34.5 which requires instructions and all information for use to be "accessible to and independently usable by persons with vision impairments." Arrangement and tactile qualities are standardized for uniformity to facilitate use by people with little or no vision. The revised section reads as follows:

707 Automatic Teller Machines and Fare Machines

707.1 General. Automatic teller machines and fare machines required to be accessible shall comply with 707.

Advisory 707.1: If farecards have one tactually distinctive corner they may be inserted with greater ease. Token collection devices that are designed to accommodate tokens which are perforated can allow a person to distinguish more readily between tokens and common coins. Place accessible gates and fare vending machines in close proximity to other accessible elements when feasible so the facility is easier to use. [end of advisory]

[omission]

707.3 Operable Parts. Operable parts shall comply with 309. Each operable part shall be able to be differentiated by sound or touch without activation.

EXCEPTION: Drive-up only automatic teller machines shall not be required to comply with 309.2 and 309.3.

707.4 Input. Input devices shall comply with 707.4.

707.4.1 Privacy. The opportunity for the same degree of privacy of input shall be available to all individuals utilizing the equipment.

707.4.2 Key Surfaces. All keys used to operate a machine shall be tactually discernible. Key surfaces shall be raised above the surrounding surface by 1/25 inch (1 mm) minimum. The outer edge of key surfaces shall have a radius of 1/50 inch (0.5 mm) maximum.

EXCEPTION: The touch areas of video display screens shall not be required to be tactually discernible.

707.4.3 Separation Between Keys. Any key surface shall be separated from other key surfaces by 1/8 inch (3.2 mm) minimum. Function keys shall be separated from numeric keys by a distance that is not less than three times greater the distance between the numeric keys.

707.4.4 Numeric Keys. Where provided, numeric keys shall comply with 707.4.4.1 and 707.4.4.2.

707.4.4.1 Arrangement. Numeric keys shall be arranged in a 12-key telephone keypad layout with the number one key in the upper left hand corner.

707.4.4.2 Marking. The number five key shall have a single raised dot.

707.4.5 Function Keys. Where provided, function keys shall comply with 707.4.5.

707.4.5.1 Arrangement. Function keys shall be arranged in the order of enter, clear, cancel, add value and decrease value horizontally from left to right or vertically from top to bottom. Where provided, add value and decrease value function keys shall be grouped with other function keys.

707.4.5.2 Marking. Function keys shall be marked with tactile characters as follows: Enter or proceed key: raised circle; Clear or correct key: raised vertical line or bar; Cancel key: raised ex; Add value key: raised plus sign; Decrease value key: raised minus sign.

707.4.5.3 Color Coding. Where function keys are color coded, they shall be colored as follows: Enter or proceed key: green; Clear or correct key: black; Cancel key: red; Add value key: blue; Decrease value key: yellow.

707.5 Output. Output devices shall comply with 707.5.

Advisory 707.5: Speech output should be supplied for all displayed text and labels. For information which is presented in non-text form (e.g., a picture or graphic), consider using a verbal description unless the graphic is just decorative. When speech output is utilized, allow for the spoken message to be repeated if the message is very long. [end of advisory]

707.5.1 Privacy. The opportunity for the same degree of privacy of output shall be available to all individuals utilizing the equipment.

707.5.2 Transaction Prompts. All transaction prompts within each operation shall be provided.

707.5.3 Input Verification. Verification of all user inputs shall be provided.

Advisory 707.5.3: An audible beep may be used to indicate that personal identification numbers have been entered. [end of advisory]

707.5.4 Operating Instructions. Machines shall provide visual and audible instructions for operation. Visual and audible instructions shall include all information required by 707.5.4.

707.5.4.1 Initiation. Instructions shall be able to be initiated by the user of the machine.

707.5.4.2 Expedited Process. After initiation, instructions shall be available for the experienced user to expedite the transaction.

707.5.4.3 Orientation. Orientation and assistance for unfamiliar users to the physical features of the machine, operational options, and details for each function shall be provided.

707.5.5 Audible Instruction. Audible instructions shall be provided through a standard audio mini jack, a telephone handset, a wireless transmission system or another mechanism that is readily available to all customers.

707.5.6 Video Display Screen. The video display screen shall comply with 707.5.6.

Advisory 707.5.6: For video display screens required to be accessible, the screen should be visible and usable by persons standing and sitting. [end advisory]

707.5.6.1 Visibility. The screen shall be visible from a point located 40 inches (1015 mm) above the center of the clear floor space in front of the machine.

EXCEPTION: This requirement shall not apply to drive-up only automatic teller machines.

707.5.6.2 Characters. Characters displayed on the screen shall be in a Sans Serif font. Characters shall be 3/16 inch (4.8 mm) minimum in height based on the uppercase letter "I." Characters shall contrast with their background with either light characters on a dark background or dark characters on a light background.

707.5.7 Dispensing of Bills. Machines that dispense paper currency shall dispense the currency in descending order with the lowest denomination on top.

707.5.8 Receipts and Verification. Where a receipt is available and is requested, the following options shall be provided: a printed receipt, audible presentation of the transaction information provided on the receipt, or both.

NOTE: Commenters may wish to provide input on the frequent Advisory notes in section 707 above, especially 707.5 regarding speech output. Additionally, commenters should address the following question directly.
Question 31: While section 707 specifically addresses "automatic teller machines" and "fare vending machines," the Board is considering covering all types of interactive transaction machines, such as point-of-sale machines and information kiosks, among others. Information is requested on any possible design conflicts between the requirements of this section and any specific types of interactive transaction machines. The final rule may be modified to specifically address unique characteristics of certain types of interactive transaction machines.
NOTE: In addressing this question, commenters may wish to provide comment on the Access Board's consideration of coverage for this wide range of equipment.

NOTE: In addition, commenters may wish to provide the Access Board with input on a related issue. Although other types of interactive equipment, such as laundry equipment and vending machines generally are covered by ADAAG and must be compliant with reach range and other accessibility requirements, such equipment is not similarly required to be made accessible to and usable by people who are blind or visually impaired through the use of tactile or differentiated controls and/or audible prompts.

Question 34: The Board seeks comment on whether ATM manufacturers or banks intend to provide customers who need audio output receivers for accessing audible output [as written]. In addition, the Board seeks to know if customers would or currently do carry receivers or if they view providing their own receivers as an unreasonable expectation.
NOTE: This question addresses the responsibility to provide headsets or other devices to be used with machines complying with the new rules. Commenters may wish to address whether they believe customers should bear this burden.

Topic 2: Detectable Warnings

ADA Technical Requirements Section 406, Curb Ramps

In 1996 the Access Board and the Departments of Justice and Transportation extended the suspension of the detectable warning requirements at intersections to July 26, 1998, to allow the Board's ADAAG Review Advisory Committee to conduct its review of ADAAG and to make recommendations for revising and updating the document. The suspension has been extended to July 26, 2001. The advisory committee recommended that the requirement for detectable warnings at platform edges in transportation facilities be retained.

ADA Technical Requirements Section 705, Detectable Warnings

The technical criteria for detectable warnings are consistent with those in ADAAG 4.29 and those required on the boarding platforms of transit stations in ADAAG 10.3.1(8). Provisions have been added concerning boarding platforms that generally recognize alternative tactile surfaces equally detectable underfoot or other designs or technologies that provide equal or superior drop-off warning. The revised section reads as follows:

705 Detectable Warnings

705.1 General. Detectable warnings required on platform edges shall comply with 705.2, 705.3, or 705.4.

705.2 Truncated Domes. A 24-inch (610 mm) wide truncated dome surface complying with 705.2 shall be provided on the walking surface at the platform edge.

705.2.1 Dome Size. Domes shall have a diameter of 0.9 inch (23 mm), a height of 0.2 inch (5 mm) and a center-to-center spacing of 2.35 inches (60 mm).

705.2.2 Contrast. The truncated dome surface shall contrast visually with adjoining walking surfaces either light-on-dark, or dark-on-light. The material used to provide contrast shall be an integral part of the truncated dome surface.

705.2.3 Interior Locations. Detectable warnings in interior locations shall differ from adjoining walking surfaces in resiliency or sound-on-cane contact.

705.3 Equivalent Tactile Surface. A 24-inch (610 mm) wide tactile surface shall be provided on the walking surface at the platform edge. The tactile surface shall provide equivalent detectability underfoot to that provided by 705.2.1 and shall provide contrast in accordance with 705.2.2.

705.4 Equivalent Detectability. Equivalent detectability of the platform edge by other construction, technology, or means that will ensure equivalent or superior and reliable communication of the impending change to pedestrians who are blind or visually impaired shall be permitted. The information to be communicated must include 24 inches (610 mm) of advance warning of the platform edge and the precise orientation of the platform edge in relation to the pedestrian.

NOTE: Commenters may wish to offer their sense of the adequacy of these provisions to ensure safety for blind and visually impaired pedestrians.

Topic 3: Signs

ADA Scoping. Section 216. Signs

This provision retains the substance of scoping for exterior and interior signs in ADAAG 4.1.2(7) and 4.1.3(16). Several editorial changes are included for clarification. Scoping for tactile signs is modified to apply to "permanent" room or space designations in order to clarify coverage of signs that are not likely to change. The Board has added an exception stating that signs designating building addresses or names are not required to meet requirements for tactile signs.

216.1 General. Signs shall be provided in accordance with 216 and shall comply with 703.

EXCEPTION: In detention and correctional facilities, signs not located in public use areas shall not be required to comply.

216.2 Permanent Designations. Where exterior signs are provided as permanent designations of permanent interior rooms and spaces at the door to the space they serve, the signs shall be tactile and shall comply with 703.2. Where interior signs are provided as permanent designations of permanent interior rooms and spaces, the signs shall be tactile and shall comply with 703.2. Where pictograms are provided as permanent designations of permanent interior rooms and spaces, the pictograms shall comply with 703.6 and shall have tactile text descriptors complying with 703.2.

Advisory 216.2: "Permanent designations" label interior rooms or spaces where the designation is not likely to change over time. Examples include, interior signs labeling restrooms, room and floor numbers or letters, and room names. Tactile text descriptors are required for pictograms that are provided to label or identify a permanent room or space. Pictograms that provide information about a room or space, such as "no smoking," occupant logos, and accessibility designations, are not required to have text descriptors. [end advisory]

EXCEPTION: This requirement shall not apply to signs used to designate building addresses or building or facility names.

216.3 Directional and Informational Signs. Signs that provide direction to or information about permanent interior spaces and facilities of the site shall comply with 703.4.

Advisory 216.3: Information about a permanent room or space includes rules of conduct, occupant load, and similar signs. Signs providing direction to permanent rooms or spaces include those that identify egress routes. [end advisory]

EXCEPTION: Building directories, menus, and temporary signs are not required to comply with 703.4.

216.4 Exit Doors. Exit doors shall be identified by tactile signs complying with 703.2. ADA Technical Requirements Section 703, Signs.

NOTE: Commenters may want to address the advisory section 216.2 above in that, for the first time, the requirements for sign accessibility would be extended to signs bearing room names. Based upon an old opinion letter issued by the Department of Justice, only signs bearing room numbers were deemed to be required to be accessible. This advisory provision, if made mandatory, would change the effect of that opinion and provide greater access.

ADA Technical Requirements. Section 703. Signs

703.1 General. Signs required to be accessible shall comply with 703.

703.2 Characters that are Both Tactile and Visual. Characters required to be tactile shall comply with 703.2. Tactile characters shall be duplicated in braille complying with 703.5.

EXCEPTION: Tactile characters shall be permitted to comply with 703.3, where separate visual characters complying with 703.4 provide the same information.

703.2.1 Finish and Contrast. Characters and their background shall have a non-glare finish. Characters shall contrast with their background with either light characters on a dark background or dark characters on a light background.

703.2.2 Tactile Characters. Tactile characters shall be raised 1/32 inch (0.8 mm) minimum above their background. Raised borders and decorative elements that are not required shall be separated 3/8 inch (9.5 mm) minimum from tactile characters.

703.2.3 Character Forms. Fonts shall have characters complying with 703.2.3.

703.2.3.1 Case. Characters shall be uppercase.

703.2.3.2 Style. Characters shall be Sans Serif. Characters shall not be italic, oblique, script, highly decorative, or of other unusual forms.

703.2.3.3 Width. Character width shall be 55 percent minimum and 110 percent maximum the height of the character with the width based on the uppercase letter "O" and the height based on the uppercase letter "I."

703.2.3.4 Height. Character height measured vertically from the baseline of the character shall be 5/8 inch (16 mm) minimum and 2 inches (51 mm)maximum based on the uppercase letter "I."

703.2.3.5 Stroke Thickness. For characters with rectangular cross sections, the stroke thickness of the uppercase letter "I" shall be 10 percent minimum and 15 percent maximum of the height of the character. For characters with other cross sections, the stroke thickness of the uppercase letter "I" shall be 10 percent minimum and 30 percent maximum of the height of the character measured at the base of the cross section. Stroke thickness at the top of the cross section shall be 15 percent maximum of the height of the character.

703.2.4 Character Spacing. Character spacing shall be measured between the two closest points of adjacent characters within a message, excluding word spaces. Where characters have rectangular cross sections, spacing between individual characters shall be 1/8 inch (3 mm) minimum to 3/8 inch (10 mm) maximum. Where characters have other cross sections, spacing between individual characters shall be 1/16 inch (2 mm) minimum to 3/8 inch (10 mm) maximum at the base of the cross sections and 1/8 inch (3 mm) to 3/8 inch (10 mm) maximum at the top of the cross sections.

703.2.5 Line Spacing. Spacing between the baselines of separate lines of characters in a sentence or paragraph shall be 135 percent minimum and 170 percent maximum of the character height.

703.2.6 Mounting Height. Characters shall be located 48 inches (1220 mm) minimum and 60 inches (1525 mm) maximum above the adjacent floor or ground surface measured from the baseline of the characters.

EXCEPTION: This requirement shall not apply to elevator car controls.

703.2.7 Mounting Location. Where a sign containing tactile characters is provided at a door, the sign shall be located alongside the door at the latch side. Where a tactile sign is provided at double doors, the sign shall be located to the right of the right hand door. Where there is no wall space at the latch side of a single door or to the right side of double doors, signs shall be located on the nearest adjacent wall. Signs containing tactile characters shall be located so that a clear floor space of 18 inches (455 mm) minimum by 18 inches (455 mm) minimum, centered on the sign, is provided beyond the arc of any door swing between the closed position and 45 degree open position.

EXCEPTION: Signs shall be permitted on the push side of doors with closers and without hold-open devices.

703.3 Tactile Characters. Where tactile characters are required and separate tactile and visual characters with the same information are provided, tactile characters shall comply with 703.3 and visual characters shall comply with 703.4. Tactile characters shall be duplicated in braille complying with 703.5.

703.3.1 Tactile Characters. Tactile characters shall be raised 1/32 inch (0.8 mm) minimum above their background. Raised borders and decorative elements that are not required shall be separated 3/8 inch (9.5 mm) minimum from tactile characters.

703.3.2 Character Forms. Fonts shall have characters complying with 703.3.2.

703.3.2.1 Case. Characters shall be uppercase.

703.3.2.2 Style. Characters shall be Sans Serif. Characters shall not be italic, oblique, script, highly decorative, or of other unusual forms.

703.3.2.3 Width. Character width shall be 55 percent minimum and 110 percent maximum the height of the character with the width based on the uppercase letter "O" and the height based on the uppercase letter "I."

703.3.2.4 Height. Character height measured vertically from the baseline of the character shall be ½ inch (13 mm) minimum and 3/4 inch (19 mm) maximum based on the height of the uppercase letter "I."

703.3.2.5 Stroke Thickness. Stroke thickness of the uppercase letter "I" shall be 15 percent maximum of the height of the character.

703.3.3 Character Spacing. Character spacing shall be measured between the two closest points of adjacent character within a message, excluding word spaces. Spacing between individual characters shall be 1/8 inch (3 mm) minimum to 1/4 inch (6 mm) maximum.

703.3.4 Line Spacing. Spacing between the baselines of separate lines of characters within a message shall be 135 percent minimum and 170 percent maximum of the character height.

703.3.5 Mounting Height. Characters shall be located 48 inches (1220 mm) minimum and 60 inches (1525 mm) maximum above the adjacent floor or ground surface, measured from the baseline of the characters.

EXCEPTION: This requirement shall not apply to elevator car controls.

703.3.6 Mounting Location. Where a tactile sign is provided at a door, the sign shall be located alongside the door at the latch side. Where a tactile sign is provided at double doors, the sign shall be located to the right of the right hand door. Where there is no wall space at the latch side of a single door or to the right side of double doors, signs shall be located on the nearest adjacent wall. Signs containing tactile characters shall be located so that a clear floor space of 18 inches (455 mm) by 18 inches (455 mm) minimum, centered on the sign, is provided beyond the arc of any door swing between the closed position and 45 degree open position.

EXCEPTION: Signs shall be permitted on the push side of doors with closers and without hold-open devices.

703.4 Visual Characters. Visual characters required to be accessible shall comply with 703.4.

703.4.1 Finish and Contrast. Characters and their background shall have a non-glare finish. Characters shall contrast with their background with either light characters on a dark background or dark characters on a light background.

Advisory 703.4.1: Signs are more legible for persons with low vision when characters contrast with their background by approximately 70 percent. Contrast in percent can be determined by: contrast =[(B1-B2)/B1] x 100 where B1=light reflectance value (LRV) of the lighter area and B2=light reflectance value (LRV) of the darker area. Note: in any application both white and black are never absolute; thus B1 never equals 100 and B2 is always greater than zero. [end advisory]

703.4.2 Character Forms. Fonts shall have characters complying with 703.4.2.

703.4.2.1 Case. Characters shall be uppercase or lowercase or a combination of both.

703.4.2.2 Style. Characters shall be conventional in form. Characters shall not be italic, oblique, script, highly decorative, or of other unusual forms.

703.4.2.3 Width. Character width shall be 55 percent minimum and 110 percent maximum the height of the character with the width based on the uppercase letter "O" and the height based on the uppercase letter "I."

703.4.2.4 Height. Minimum character height measured from the baseline of the character shall comply with Table 703.4.2.4 based on the height of the characters above the finished floor of the viewing location and the minimum viewing distance. Character height shall be based on the uppercase letter "I." Minimum viewing distance shall be measured as the horizontal distance where an obstruction prevents further approach towards the sign.

Table 703.4.2.4 Visual Character Dimensions

  • Height of Floor to Baseline of Character: Minimum Viewing Distance; Minimum Character Height
  • Less than 40 inches (100 mm)(not permitted except in elevators)
  • 40 inches (100 mm) to less than or equal to 70 inches (1780 mm): less than 6 feet (1830 mm); 5/8 inch (16 mm)
  • 40 inches (100 mm) to less than or equal to 70 inches (1780 mm): 6 feet (1830 mm) and greater; 5/8 inch (16 mm), plus 1/8 inch (3.2 mm) per foot (305 mm) of viewing distance above 6 feet (1830 mm)
  • 70 inches (1780 mm) to less than or equal to 120 inches (3050 mm): less than 15 feet (4570 mm); 2 inches (51 mm)
  • 70 inches (1780 mm) to less than or equal to 120 inches (3050 mm): 15 feet (4570 mm) and greater; 2 inches (51 mm), plus 1/8 inch (3.2 mm) per foot (305 mm) of viewing distance above 15 feet (4570 mm)
  • Greater than 120 inches (3050 mm); less than 21 feet (6400 mm): 3 inches (75 mm)
  • Greater than 120 inches (3050 mm); 21 feet (6400 mm) and greater: 3 inches (75 mm), plus 1/8 inch (3.2 mm) per foot (305 mm) of viewing distance above 21 feet (6400 mm) (End of Table 703.4.2.4)
703.4.2.5 Stroke Thickness. Stroke thickness of the uppercase letter "I" shall be 10 percent minimum and 30 percent maximum of the height of the character.

703.4.3 Character Spacing. Character spacing shall be measured between the two closest points of adjacent characters, excluding word spaces. Spacing between individual characters shall be 10 percent minimum and 35 percent maximum of character height.

703.4.4 Line Spacing. Spacing between the baselines of separate lines of characters shall be 135 percent minimum and 170 percent maximum of the character height.

703.4.5 Mounting Height. Visual characters shall be located 40 inches (1015 mm) minimum above the floor of the viewing position. Mounting heights shall comply with Table 703.4.2.4 based on the size of the characters on the sign.

703.5 Braille. Tactile characters shall be accompanied by Grade II braille complying with Table 703.5 and 703.5. Braille dots shall have a domed or rounded shape.

Table 703.5 Braille Dimensions

  • Measurement Range: Minimum in Inches; Maximum in Inches
  • Dot base diameter: 0.059 (1.5 mm); 0.063 (1.6 mm)
  • Distance between two dots in the same cell (measured center to center): 0.090 (2.3 mm); 0.100 (2.5 mm)
  • Distance between corresponding dots in adjacent cells (not permitted except in elevators): 0.241 (6.1 mm); 0.300 (7.6 mm)
  • Dot height: 0.025 (0.6 mm); 0.037 (0.9 mm)
  • Distance between corresponding dots from one cell directly below (not permitted except in elevators): 0.395 (10 mm); 0.400 (10.2 mm) (End Table 703.5)
703.5.1 Location. Braille shall be located below the corresponding text. If text is multi-lined, Braille shall be placed below the entire text. Braille shall be separated 1/4 inch (6.4 mm) minimum from any other tactile characters.

EXCEPTION: Braille provided on elevator car controls shall be separated 3/16 inch (4.8 mm) minimum and shall be located either directly below or adjacent to the corresponding tactile characters or symbols.

703.5.2 Raised Borders and Decorative Elements. Raised borders and decorative elements that are not required, shall be separated 3/8 inch (9.5 mm) minimum from braille.

703.5.3 Height. Braille shall be located 40 inches (1015 mm) minimum and 60 inches (1525 mm) maximum above the floor measured from the baseline of the braille cells.

EXCEPTION: This requirement shall not apply to elevator car controls.

703.6 Pictograms. Where pictograms are required to be accessible, they shall comply with 703.6.

703.6.1 Pictogram Field. Pictograms shall have a field height of 6 inches (150 mm) minimum. Characters or braille shall not be located in the pictogram field.

703.6.2 Finish and Contrast. Pictograms and their field shall have a non-glare finish. Pictograms shall contrast with their field with either a light pictogram on a dark field or a dark pictogram on a light field.

703.6.3 Text Descriptors. Where text descriptors for pictograms are required, they shall located directly below or adjacent to the pictogram and shall comply with 703.2.

NOTE: Section 703.5 above provides specific criteria for braille. In the current ADAAG, the criteria for braille is located in the appendix which is only advisory in nature. Commenters may wish to address the inclusion of these specifications here. Additionally, the mounting height for signs containing braille has been changed from 60 inches off the finished floor to the center line of the sign to 40 to 60 inches off the finished floor to the baseline of the braille cells on the sign, providing greater flexibility and wider range for the placement of accessible signs.

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