EV Charging ADA Considerations – a Kiosk Perspective

EV Charging ADA KIosk Considerations

EV Charging KIosk ADA

From the KMA.Global FAQ October 2021

Short Answer — Yes

Long Answer — Technically all of the regulations mandated today apply to any form of unattended self-service. In the case of some there may not be a touchscreen per se but interaction with the terminal whether via mobile or transponder still shares those regulations. Accessing a large smart city interactive screen with a mobile phone proxy is interaction without any direct physical touching of the terminal for example. In the definition of a kiosk we point out how legal sanctions often become part of the defining process. For example, in normal like we may not consider a burrito a sandwich right? However, when it comes to nutrition and food safety the FDA considers a burrito the same, legally, a sandwich. Sounds silly for sure but it illustrates equivalents.

One of the biggest challenges for EV Charging is simply location. They tend to be on existing curbs where there are no ramps

The liability is two-part:

that which the DOJ has basis to file interest (typically using ADA2010)
and that which you still might be sued for (hot coffee wasn’t regulated until suit was brought e.g.)

We think the more relevant current laws will be regarding mounting and placement. The USPS Postal Buddy kiosks are perfectly accessible, however, they were sometimes installed in less-than-accessible locations/areas. The usual height dimensions were fine.

Here are the specific regs that come into play (as referenced in the KMA Code of Practice)

3.1.1.1. 305 – Maneuvering and More ADA2010
3.1.1.2. 306 – Depth and Clearance ADA 2010
3.1.1.3. 303 – Changes in level ADA2010 (generally not permitted)
3.1.1.4. Protruding Objects ADA2010 [refers to 307]
3.1.1.5. [Suggestion] Kiosks must be visually and tactilely identifiable to users as accessible (e.g., an international symbol of accessibility affixed to the front of the device
3.1.1.6. General Reach Ranges — ADA2010 – [reach ranges specified in 508 Guidelines and Operable Parts and included in 407.8 — refer to those]
3.1.1.7. Operable Parts — ADA2010 [refer to Section 508 for complete most current]
305.7.1 Maneuvering Clearance in Alcove ADA2010
403 Clear Width — ADA2010
404 Maneuvering Clearances — ADA2010
902.3 Work Surfaces, Countertop, Table Top, Voting

Under Section 508 review
3.1.2.1. 402 – Closed Functionality — Section 508 Final Rule
3.1.2.2. 407 – Operable Parts — Section 508 Final Rule
And for reference Audio is more often than most the largest litigated accessibility issue.

EV Charging ADA KIosk Considerations

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