Over $3.25 Million Paid by Greyhound to Individuals in Disability Settlement

greyhound legal ada settlement

Disability Settlement Greyhound

The Department of Justice today announced payments by Greyhound Lines, Inc. totaling $2,966,000 to over 2,100 individuals who experienced disability discrimination while traveling or attempting to travel on Greyhound. The payments were part of a broader settlement from 2016 resolving the Department’s complaint that Greyhound, the nation’s largest provider of intercity bus transportation, engaged in a nationwide pattern or practice of violating the Americans with Disabilities Act (ADA) by failing to provide full and equal transportation services to passengers with disabilities.  The $2,966,000 amount is in addition to $300,000 paid by Greyhound in 2016 to specific individuals identified by the Department, bringing the total distributed to individuals to over $3,250,000. To read the press release regarding this event, click here. For more information about the ADA, call the Department’s toll-free ADA Information Line at 800-514-0301 (TDD 800-514-0383) or access the ADA website at www.ada.gov.

What accessibility looks like 30 years after the ADA passed

Excerpt from The Denver Post May 2019

It is also a reminder of why it’s important to keep the pressure on government and private entities to make public places accessible to all.

“The sort of run-of-the mill storefronts, restaurants, retail store, those really should be accessible now and a lot are but too many still are not,” said Kenneth Shiotani, senior staff attorney for the National Disability Right Network, which is based in Washington, D.C.

He said outdoor spaces, such as beaches and trails, pose more challenges than man-made structures when it comes to accessibility and for that reason, new guidelines were set for them in 2013. But Meridian Hill Park, which boasts of having the largest cascading fountain in the country, seems much more structured than other outdoor spaces, he said.

“I think the wedding party had reasonable expectations that 30 years later [after the ADA was passed] a federal park would be accessible,” Shiotani said. “It’s a public park, it’s paid for by public dollars, it should ultimately be accessible for everybody.”

How Your Company To Prevent ADA Website Accessibility Lawsuits

Excerpt from Search Engine Journal May 2019

Every day, websites and mobile apps prevent people from using them. Ignoring accessibility is no longer a viable option.

How do you prevent your company from being a target for a website accessibility ADA lawsuit?

Guidelines for websites wanting to be accessible to people with disabilities have existed for nearly two decades thanks to the W3C Web Accessibility Initiative.

A close cousin to usability and user experience design, accessibility improves the overall ease of use for webpages and mobile applications by removing barriers and enabling more people to successfully complete tasks.

We know now that disabilities are only one area that accessibility addresses.

Most companies do not understand how people use their website or mobile app, or how they use their mobile or assistive tech devices to complete tasks.

Even riskier is not knowing about updates in accessibility guidelines and new accessibility laws around the world.

Investing in Website Accessibility Is a Wise Marketing Decision

Internet marketers found themselves taking accessibility seriously when their data indicated poor conversions. They discovered that basic accessibility practices implemented directly into content enhanced organic SEO.

Many marketing agencies include website usability and accessibility reviews as part of their online marketing strategy for clients because a working website performs better and generates more revenue.

Adding an accessibility review to marketing service offerings is a step towards avoiding an ADA lawsuit, which of course, is a financial setback that can destroy web traffic and brand loyalty.

Convincing website owners and companies of the business case for accessibility is difficult. One reason is the cost.  Will they see a return on their investment?

I would rather choose to design an accessible website over paying for defense lawyers and losing revenue during remediation work.

Another concern is the lack of skilled developers trained in accessibility. Do they hire someone or train their staff?

Regardless of whether an accessibility specialist is hired or in-house developers are trained in accessibility, the education never ends.

Specialists are always looking for solutions and researching options that meet guidelines. In other words, training never ends.

Many companies lack an understanding of what accessibility is and why it is important. They may not know how or where to find help.

Accessibility advocates are everywhere writing articles, presenting webinars, participating in podcasts, and writing newsletters packed with tips and advice.

ADA lawsuits make the news nearly every day in the U.S. because there are no enforceable regulations for website accessibility. This is not the case for government websites.

Federal websites must adhere to Section 508 by law. State and local websites in the U.S. are required to check with their own state to see what standards are required.

Most will simply follow Section 508 or WCAG2.1 AAA guidelines.

If your website targets customers from around the world, you may need to know the accessibility laws in other countries. The UK and Canada, for example, are starting to enforce accessibility.

In the U.S., there has been no change in the status of ADA website accessibility laws this year.

Some judges have ruled that the lack of regulation or legal standards for website accessibility does not mean that accessibility should be ignored.

Read complete article at Search Engine Journal May 2019

US Access Board News for March/April 2019

Access Currents

News from the U.S. Access Board  •  March/ April 2019


Access Board to Hold Town Hall Meeting and Training in Indianapolis on May 21

Indianpolis skylineThe Access Board will hold a town hall meeting in Indianapolis on the afternoon of May 21 at Bankers Life Fieldhouse. The event will provide an open forum where members of the public can pose questions to the Board or share comments or concerns about accessibility for people with disabilities. There also will be panel discussions with area speakers on accessible recreation and outdoor environments, the Indiana AgrAbility Project, and local compliance initiatives under the Americans with Disabilities Act (ADA).

The event will take place in the Pacers Square Room at Bankers Life Fieldhouse from 2:00 pm to 4:30 pm. Registration is not required. An assistive listening system, computer assisted real-time transcription (CART), and sign language interpreters will be available. Attendees are requested to refrain from using perfume, cologne, and other fragrances for the comfort of all participants. The meeting will not be streamed online, but there will be a call-in option and streaming CART.

Earlier in the day, the Board will also offer free training sessions on the ADA Accessibility Standards at the town hall site. There will be a program on how to apply the standards and common sources of confusion (9:00 am – 10:30 am). This will be followed by a session on recreation facilities and outdoor sites (10:45 am – 12:15 pm). Advance registration is not required, and participants can attend either or both sessions. Qualified attendees can earn continuing education credits (1.5 per session) from the American Institute of Architects.

For further information, contact Dave Yanchulis at [email protected], (202) 272–0026 (v), or (202) 272–0027 (TTY).

Bankers Life Fieldhouse logoU.S. Access Board Training and Town Hall Meeting, May 21
Pacers Square at Bankers Life Fieldhouse
125 S. Pennsylvania Street, Indianapolis, IN

Training Session on the ADA Accessibility Standards (free)
• 8:00 – 9:00 Registration & Welcome
• 9:00 – 10:30 Application of the Standards & Common Sources of Confusion
• 10:30 – 10:45 Break
• 10:45 – 12:15 Recreation Facilities & Outdoor Sites

Town Hall Meeting
• 2:00 – 2:15 Opening Remarks
• 2:15 – 3:30 Panel Discussions
• 3:30 – 4:30 Overview of the Access Board & Open Forum

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Karen Tamley Elected Access Board Chair

Board Chair Karen Tamley and Vice Chair Lance RobertsonAt its March meeting, the Board unanimously elected Board Member Karen Tamley as its new Chair. Tamley just completed a term as Vice Chair of the Board and has served as the Commissioner of the Chicago Mayor’s Office for People with Disabilities since 2005.

“I am honored to serve as the Chair of such a dedicated agency that is a true force for change and that has done so much to advance accessibility both in the U.S. and abroad,” she stated after the vote. “I look forward to working with Board members and staff in the year ahead.”

Tamley joined the Board in 2015 as a public member. As head of the Mayor’s Office for People with Disabilities, she leads numerous disability policy and compliance initiatives in transportation, city infrastructure, emergency preparedness, housing, schools and technology, and other areas. She also oversees the delivery of independent living services to city residents.

She succeeds Lance Robertson who represents the U.S. Department of Health and Human Services (HHS) on the Board and who was named Vice Chair by acclamation. He serves as Assistant Secretary for Aging at HHS and heads its Administration for Community Living and previously was Director of Aging Services at the Oklahoma Department of Human Services.

Board officers serve for a term of one year. The Board is structured to function as a coordinating body among Federal agencies and to directly represent the public, particularly people with disabilities. Half of its members are representatives from most of the Federal departments. The other half is comprised of members of the public appointed by the President.

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Upcoming Board Webinars

laptop with Access Board seadEnsuring that public streets and sidewalks are accessible to people with disabilities can be a challenge, especially since accessibility guidelines for public rights-of-way have yet to be finalized. The next webinar in the Board’s free monthly series will take place June 6 from 2:30 – 4:00 (ET) and will be devoted to answering the various questions that come up in addressing access to sidewalks and street crossings, pedestrian signals, on-street parking, roundabouts, transit stops and other components of public rights-of-way as well as shared use paths. Board Accessibility Specialists will answer questions submitted in advance or during the live webinar and offer guidance, solutions, and best practices based on guidelines the Board proposed for public rights-of-way. Attendees are encouraged to submit their questions in advance.

Visit www.accessibilityonline.org for more information or to register for the webinar. Webinar attendees can earn continuing education credits. The webinar series is hosted by the ADA National Network in cooperation with the Board. Archived copies of previous Board webinars are available on the site.

Section 508 Best Practices Webinar
The Board also offers a free webinar series on its Section 508 Standards for ICT in the federal sector. The next webinar in this series will be held May 28 from 1:00 to 2:30 (ET) and will review the Trusted Tester for Web and highlight significant updates. Developed by Department of Homeland Security’s (DHS) Office of Accessible Systems and Technology in coordination with other agencies, the Trusted Tester Process provides a scalable, repeatable, accurate process for evaluating web and software products for conformance with the 508 Standards.

Representatives from the Board and DHS will review the latest edition (Version 5) which supports the revised Section 508 Standards and the Web Content Accessibility Guidelines (2.0). Trusted Tester 5.0 improves the format, flow, and construction of the evaluation process and test conditions. Presenters will discuss the new testing tool, the Accessible Name and Description Inspector (ANDI), and how it aids testers with code inspection-based testing. They will also cover the availability of DHS online training and certification. Questions can be submitted in advance of the session or can be posed during the webinar.

Visit the webinar site for further information or to register. The Section 508 Best Practices Webinar Series is made available by the Accessibility Community of Practice of the CIO Council in partnership with the Board. Prior webinars can be accessed on the site.

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Poland Creates Entity Modeled after the U.S. Access Board

National Symbol of PolandThe Polish government has established an agency to promote accessibility that is modeled after the U.S. Access Board. Created in December, the Accessibility Council is responsible for reviewing laws and regulations and making recommendations to the government on implementing a sweeping new law to advance accessibility nationwide. The Council is comprised of 50 members representing ministries and government bodies, disability groups, and academia and meets quarterly. The Council will play a lead role in implementing the Accessibility Plus Program, an new measure that aims to make Poland a leader in accessibility by eliminating barriers in architecture, transportation, education, health care, digital and other services.

Poland’s Minister of Investment and Development Jerzy Kwieciński, who heads the Accessibility Council, credits the work of the U.S. Access Board and a speaking tour by Board Executive Director David Capozzi as the inspiration for the new entity. At the Council’s inaugural meeting in February, he recognized the Access Board’s influence and stated, “I believe that now Poland will become a model for other countries.” He supports a study tour of the U.S. for Council staff, including further consultations with the Board.

Capozzi travelled throughout Poland in 2017 as part of State Department’s speaker program to share the American experience in ensuring accessibility for people with various disabilities. During his weeklong stay in Warsaw, Gdynia, Gdańsk, and Kraków, he met with national and local authorities, advocacy groups, and other representatives, some of whom were instrumental in creating the Council. Capozzi discussed achievements and challenges of ensuring accessibility in the U.S. and shared lessons learned. He participated in dialogues on different aspects of accessibility, including the built environment, information and communication technology, employment, enforcement, and the important role standards play, among other topics.

“It was an honor to travel to Poland on behalf of the State Department and our embassy to meet with those leading the effort to make the country a model for accessibility,” states Capozzi. “The Board looks forward to learning more about their efforts and achievements and exploring how we can further advance accessibility in both our countries.”

In Warsaw, Board Executive Director David Capozzi (right) met with Senate Member Jan Filip Libicki and others.

David Capozzi with Senate Member Jan Filip Libicki

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Congressional Measures Address Airline Accessibility

airplaneLegislation was recently introduced in Congress to supplement the Air Carrier Access Act (ACAA) which prohibits discrimination in air transportation. Congressman Jim Langevin (D-RI) and Senator Tammy Baldwin (D-WI) submitted bills in the House (H. R. 1549) and Senate (S. 669) to amend the ACAA to further improve access at airports and on aircraft. The bills would create accessibility standards for new airplanes, require removal of barriers on existing airplanes where readily achievable, strengthen enforcement mechanisms, including establishment of a private right of action and enhance safety.

Under these measures, the Access Board would be responsible for issuing standards for aircraft and equipment for boarding and deplaning, including seating accommodations, lavatories, stowage of assistive devices, announcements, and in-flight entertainment and video displays. The standards also would address airports, including ticketing counters, gates, customer service desks, audible announcements, kiosks, and websites. The bills were referred to the appropriate House and Senate committees for consideration.

In addition, under a law passed last year, the Department of Transportation (DOT) began reporting data on the number of passenger wheelchairs and scooters that are damaged or mishandled by airlines on a monthly basis. A total of 701 (2.18%) wheelchairs and scooters were damaged last December, an average of more than 25 a day, as reported in DOT’s monthly Air Travel Consumer Report (February issue). The total for January was 681 (2.06%) and for February was 593 (1.7%).

In a statement, Senator Tammy Duckworth (D-IL), who authored the law said, “Every airline passenger deserves to be treated with dignity and respect, but too often they aren’t. Travelers should be able to find out if certain airlines have high rates of breaking wheelchairs and other equipment that people depend on, just like we can find out if certain airlines have high rates of flight delays or cancellations.”

Further information on this reporting is posted on DOT’s website.

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Guidelines for Voting Systems Available for Public Comment

Election Assistance Commission sealFederal guidelines for voting systems implemented under the Help America Vote Act are currently available for public comment. Issued by the U.S. Election Assistance Commission (EAC), the Voluntary Voting System Guidelines (VVSG) provide principles and criteria for assessing the basic functionality, accessibility, and security of voting equipment.

The EAC released the document, referred to as VVSG 2.0, on February 28 for a 90-day comment period, as indicated in a notice published in the Federal Register. The VVSG 2.0 updates guidelines first issued in 2005 and revised in 2015 and features a new streamlined structure comprised of high-level system design goals with broad descriptions of the functions that make up voting systems. The proposal also includes moving technical requirements and test assertions to separate documents that detail how voting systems can meet the new Principles and Guidelines in order to obtain certification. Those requirements and test assertions will be made available for public comment at a later date. The EAC seeks comments on all sections of the Principles and Guidelines including the proposed restructuring. Comments are due May 29.

For further information, visit the EAC’s website or contact Ryan Macias at (301) 563-3931 or [email protected].

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Updated VPAT Now Available from the IT Industry Council

Information Technology Industry Council logoThe Information Technology Industry Council (ITI) maintains a free reporting tool known as the Voluntary Product Accessibility Template (VPAT) to help determine whether information and communication technology products and services satisfy accessibility requirements, including the Section 508 Standards. ITI recently released revised editions of the VPAT (2.3) based on the Board’s revised 508 Standards (VPAT 2.3 508), including the referenced Web Content Accessibility Guidelines (WCAG 2.0). It also offers VPATs for WCAG 2.1 (VPAT 2.3 WCAG), the European Union’s ICT requirements (VPAT 2.3 EU), and another based on all three (VPAT 2.3 INT).

Visit the ITI’s website for further information or send a message to [email protected].

Lawsuits targeting business websites over ADA violations are on the rise

Smart City ADA Accessibility

Originally published on LA Times

The boutique Avanti Hotel is known for its poolside, dog-friendly rooms. Yet its website uses the valuable opening page not to highlight the Palm Springs inn’s amenities, but to explain, in stark black letters on a plain white background, that the Avanti violated the Americans with Disabilities Act.

Like thousands of other businesses in the United States, the 10-room hotel on East Stevens Road has been sued because it hasn’t fully complied with the 1990 law that requires public places — hotels, restaurants and shops — to be accessible to people with disabilities.

In 2010, the Justice Department began to draft formal regulations for websites to meet ADA goals. But last December, the agency announced it was withdrawing its “rulemaking process,” at a time when the Trump administration was calling for a rollback of federal regulations.

The department said it was killing the regulations because it was “evaluating whether promulgating regulations about the accessibility of web information and services is necessary and appropriate.”

In a June 20 letter, 103 members of Congress — Republicans and Democrats — urged then-Atty. Gen. Jeff Sessions to adopt website regulations, saying the absence of such regulations “only fuels the proliferations of these suits.”

Lawyers who defend ADA lawsuits say the Justice Department’s actions to pull the plug on adopting new regulations may have instigated the latest surge in lawsuits.

Business owners who are sued under the ADA complain that the law allows plaintiffs to demand huge payouts in damages without first giving the business owner the opportunity to fix the websites.

Read full article as originally published on LA Times

A Smart City Is an Accessible City

Smart City ADA Accessibility

Originally published on The Atlantic

A new breed of accessibility apps can make life easier for people with disabilities. They can also make it harder.

Excerpt:

A group gathers on a Nashville street corner, some rolling in wheelchairs and others walking. They have arrived holding their smartphones and make friendly chatter while a coordinator helps them log in to an app. Dispersing in small groups, they examine restaurants, cafes, and shops, looking for features signaling that disability is welcome there: a parking sign with the International Symbol of Access, a wheelchair ramp, an automatic front door, a wide bathroom stall with grab bars, braille text, low-flicker lighting, glare-free floors, scent-free soap. The groups use the app to document and rate these features. Once submitted, the information accumulates in a database that others can use to find accessible locations.

Excerpt:

But even if all these problems were solved, digital-accessibility apps still pose one final threat to disability advocacy in urban environments. Apps can make cities more navigable, but they do not change the material features of that environment. Most of the time, they record the current conditions in the built environment rather than advocate for better ones. Before apps came on the scene, disability activists used mapping to catalog injustices and to imagine alternative futures: new environments in which accessibility was the norm, rather than the exception. Contemporary projects should incorporate that lesson, too. By incorporating knowledge from broad groups of people with disabilities, digital mapping could do more than just record the world as it is today. It could also drive political, design, and policy improvements. After all, to deserve the name, a smart city ought to be a better city, not just a more technological one.

Whitepaper – Voice Recognition and Speech Command Technology as an Assistive Interface

The Use of Voice Recognition and Speech Command Technology as an Assistive Interface for ICT in Public Spaces.

Voice RecognitionA whitepaper published by Peter W Jarvis (Senior Executive VP, Storm Interface) and Nicky Shaw (Operations Manager North America).

September 2018.

Introduction.

The emergence and increasing use of smart speakers (AI) in the home environment has delivered significant benefits for those with mobility, sensory, cognitive or dexterity impairment. For millions of disabled people voice recognition and speech command technology, allied with audible confirmation and presentation of requested information, permits more informed decision making and personal control of their immediate environment.

This improved access to information and control opens a new world of communication, entertainment, education and opportunity for those who are unable to see, read or interact with content presented on a display screen and for those who lack the mobility or dexterity to manipulate tactile system interface devices (such as keyboards, trackballs or touch screens etc.). Speech Command Technology creates significant new opportunities for independent living.

This improved accessibility also creates unique challenges for system designers, legislating authorities and those concerned about privacy and misuse of personal data. As Voice Recognition and Speech Command technology moves beyond the domestic environment into public spaces and the urban infrastructure we will need new guidelines to increase public awareness and new regulation to protect the general population against the misuse of recorded information.

This whitepaper explores the implementation and integration of Speech Command technology within ICT kiosks and self-service applications. It is intended to provide a framework for a proposed Code-of-Practice. This CoP to be drafted for public consultation and possible adoption by the Kiosk Manufacturer Association (KMA) as an addendum to its Accessibility Guidelines.

To illustrate certain devices or technologies there are some references in this document to products manufactured by Storm Interface. These are intended as exemplars only. Other brands and products are available.

1. Who’s Listening

1.1 When a private citizen purchases a connected smart speaker device for home use, he/she makes an informed decision to install that device into their home environment. Before connecting their new device to the manufacturer’s cloud-based AI applications new customers are required to agree and accept many terms and conditions of service. By doing so they make a decision to accept a listening device into their home; albeit with an option to mute that device or switch it off at any time. The customer knows where the device is located, what its connected status is and how to switch it off.

1.2 However, to overcome the latency (delay) inherent in delivering cloud-based AI services to a device that has just been switched on, these devices (by default) usually remain in a powered and connected configuration. Amazon have referred to this default configuration as “Always on, always ready”. This configuration is sometimes referred to by more cynical commentators as “Always on, always listening”. The device needs to be configured in this way to operate as an effective ‘hands free’ Voice Recognition and Speech Commanded information system.

2. In a Public Environment.

2.1 Speech Command and Voice Recognition technology will provide an effective and valuable improvement in accessibility to public ICT systems. Applications such as public transport ticketing and airline check-in terminals would be typical examples.

2.2 As part of a multi-modal approach to accessibility, Speech Command will provide an additional option for those with disabilities (and those without) to confirm their biometric identity and to interface with the kiosk’s application software. The kiosk user will be able to choose from a combination of tactile, audible or visual interface devices to best meet their specific accessibility needs.

2.3 However, it will be essential that all kiosk users and those members of the public in proximity to the kiosk be made aware that the terminal includes Voice Recognition and/or Speech Command technology and that the Speech Command facility is “on and listening”. This awareness is essential for two reasons:

2.3.1 To inform the kiosk user that Speech Command / Voice Recognition technology is available for their use and convenience.

2.3.2 To warn members of the public (in proximity) that their conversations may/will be picked up by the Speech Command / Voice Recognition facility and may be transmitted to a remote server for analysis, processing and possible retention.

2.4 This awareness must be provided for members of the public who are sighted, partially sighted, non-sighted or hearing impaired.

3. A Universal Symbol

3.1 It is proposed that a universally recognized symbol for Speech Command functionality be adopted by the Kiosk and Self Service industry.

3.2 The symbol’s purpose is to indicate the presence of Voice Recognition or Speech Command technology.

3.3 Storm Interface have designed a high contrast, highly visible and tactilely discernible symbol that can be easily applied to the kiosk. During the development of this logo, Storm Interface worked closely with the UK’s Royal National Institute of Blind People (RNIB). Feedback received from the RNIB has influenced the logo design. This to aid recognition and ease of use, and to ensure that all contours and edges are rounded to make it comfortable to the touch.

3.4 As with any new logo, but in particular tactile logos, people will need to learn its meaning. This highlights the importance of introducing a standard logo which can be used across all kiosks and sectors to ensure that blind people need only learn one symbol.

3.5 When Voice Recognition or Speech Commanded services are activated the symbol will be illuminated with bright white LEDs.

3.6 The applied symbol should be positioned such that it can be easily seen or tactilely located as a user approaches or addresses the kiosk.

3.7 When the kiosk is in home screen or screen saver mode, with no detected user activity, an audible signal or statement to indicate the presence of an activated Voice Recognition or Speech Command facility should be played periodically. Alternatively, a proximity sensing device could be used to un-mute a VR or SC device only when a kiosk user approaches the kiosk interface zone.

3.7.1 Similar audible indicators of a functioning Voice Recognition or Speech Command technology should also be given when such a facility is activated (switched on or un-muted) after a period of non-functionality.

3.8 A proposed specification for the symbol is reproduced below. Storm Interface and the RNIB propose to make this symbol available as a “free-to-use” graphic device. Storm Interface propose to offer a physical, manufactured version of the graphic device, in the form of an illuminated tile, for sale to and use by kiosk manufacturers, specifiers or operators.

Figure 1: Images courtesy of Keymat Technology Ltd. All rights recognized.

Coice Recognition Symbol

4. Hardware

4.1 Microphones

4.1.1 Kiosks that offer Speech Command or Voice Recognition technology must support and provide the means for voice input.

4.1.2 This should be by provision of a suitable standard connection point for an audio headset or ear piece (equipped with its own microphone) and by provision of a suitable microphone (or microphone array) permanently installed as a fixture of the kiosk.

4.1.3 In many public kiosk locations or applications it will be necessary to employ advanced noise cancelling and beam focusing technology to enable effective operation of the Speech Command or Voice Recognition technology.

4.1.4 Connection of a headset or assistive hearing device (equipped with its own integrated microphone) should be detected by the host kiosk and the functionality of any permanently installed microphone (or microphone array) should be automatically adjusted to accommodate and allow correct functioning of the headset or hearing aid device

4.1.5 To facilitate reliable and continued functionality, provision and installation of audio device connection points and/or permanently installed microphone devices should accommodate requirements for regular sanitation (wash-down) procedures and should resist the hard use and abuse associated with ICT installations in public spaces. As a minimum requirement, water and dust resistance in accordance with IP54 (or equivalent) should be achieved. A minimum impact resistance of 10J should be achieved.

Figure 2. Beam array microphone for outdoor or unsupervised public environments. Other brands and products are available.

Beam Array Microphone

4.2 Speakers

4.2.1 Kiosks that offer Speech Command or Voice Recognition technology must support and provide the means for audible reproduction of sound or speech.

4.2.2 This should be by provision of a suitable connection point for an audio headset or earpiece and by provision of a suitable amplified speaker system permanently installed as a fixture of the kiosk.

4.2.3 In many public kiosk locations or applications it will be necessary to employ sound directing or sound focusing technology to prevent noise pollution or irritation to those in the local vicinity of the kiosk.

4.2.4 Connection of a headset or assistive hearing device (equipped with its own integrated speakers) should be detected by the host kiosk and the functionality of any permanently installed amplified speakers should be automatically adjusted to accommodate and allow correct functioning of the headset or hearing aid device.

4.2.5 Tactile discernable sound volume controls must be easily accessible to those using assistive headsets, earpieces or hearing aid devices. Tactile sound volume controls should be accessible and functioning throughout the kiosk user session. Wherever possible tactile discernible controls should be suitably shaped to enable function with headsticks or assistive easy grip styli.

Figure 3. Tactile discernable sound volume controls must be easily accessible to those using assistive headsets, earpieces or hearing aid devices and those using headsticks or easy-grip styli.

Volume Control

4.2.6 To facilitate reliable and continued functionality, provision and installation of audio device connection points and/or permanently installed amplified speakers should accommodate requirements for regular sanitation (wash-down) procedures and should resist the hard use and abuse associated with ICT installations in public spaces. A minimum requirement for water and dust resistance in accordance with IP54 (or equivalent) should be achieved. A minimum impact resistance of 10J should be achieved.

4.3 Wireless Devices

4.3.1 For those kiosk users who prefer to use wireless headsets, earbuds or implants in preference to wired devices with a cable and jack-plug connector, it should be possible to connect a personal wireless transponder (powered by a button cell battery) into the jack-plug socket. These personal devices provide encrypted communication between the transponder and a paired personal headset. The transponder would be removed and retained by the kiosk user when the kiosk session is completed.

Figure 4: Compact wireless transponder. These devices can be paired with a wireless headset or earpiece to provide a private listening capability. The transponder can be plugged directly in to the kiosk’s audio jack socket. Other brands and types of transponder are available.

wireless transponder

5. Conclusions:

The emergence of Voice Recognition as a means of biometric confirmation of identity, coinciding with the profound impact of AI on speech commanded ICT, will drive adoption of speech command technology in public spaces and applications. Whereas this presents many challenges and risks to privacy and protection of personal data, it will lead to a new era of equality in access to information, freedom and independence for those with disabilities. It will be necessary for accessibility mandates, regulation and standards to be adapted in support of this revolutionary change in the way humans interface with the digital world. Speech Command Technology creates significant new opportunities for independent living.


Copyright Peter W Jarvis 2018. All rights retained.
Contact: Peter Jarvis: [email protected]
Nicky Shaw: [email protected]

We welcome any comments and feedback which can assist us in evaluating this proposed framework.

Website ADA – QSR website access suits surge

By Brian Cole/Employment litigation lawyer 

Brian Cole

Over the past year, the number of website disability access lawsuits has surged across all industries, but the problem is particularly intense in the food service industry and QSR sector suits are well represented. In short, being in this business today means knowing the law and its requirements when it comes to website accessibility, lest you leave your brand highly susceptible to a court case.

First off, understand that website disability access lawsuits or web access lawsuits allege that a consumer-facing website is discriminatory because it contains certain barriers that prevent access to individuals with visual, auditory or other disabilities. This type of action is brought under Title III of the Americans with Disabilities Act (ADA), as well as under the stipulations of any state’s non-discrimination laws, like the Unruh Civil Rights Act in California.

The costs associated with these lawsuits can be significant, as plaintiffs seek legal remedies that will bring inaccessible sites into compliance, along with any number of attorneys’ fees. Additionally, certain state non-discrimination laws — like the Unruh Act — also add minimum statutory penalties.

Read the full article on QSRWeb

News from the U.S. Access Board – May/ June 2018

Access Board logoAccess Currents 
News from the U.S. Access Board  •  May/ June 2018

Access Board Holds Town Hall Meeting in Phoenix

Board members and staff at the Phoenix town hall meetingThe Access Board held a town hall meeting in Phoenix on May 23 that featured presentations by local speakers on various topics and a public “open mic” forum. It was held at Ability360, a Center for Independent Living. Board Vice Chair Karen Tamley and Executive Director David Capozzi opened the meeting with introductions and an overview of the Board and its work.

The first two speakers addressed access for people with heightened sensitivites to chemicals and electromagnetic fields. Dr. Ann McCampbell, Co-Chair of the Multiple Chemical Sensitivities Task Force of New Mexico, described the debilitating physical reactions experienced by those with an acute sensitivity to various chemicals in the environment, aslo known as Multiple Chemical Sensititvites (MCS). These include chemicals used in fragrances, personal care products, deodorizers, cleaners, pesticides, wall and floor coverings, and building materials. Dr. McCampbell, who has had MCS for almost 30 years, also called attention to sensitivity to electromagnetism from cell phones, security equipment, utility meters, florescent lighting, and other sources. She noted that the prevalence of Electromagnetic Hypersensitivity (EHS) appears to be increasing.

Susan Molloy, M.A., an advocate for people with MCS and environmental illness for 35 years, discussed design recommendations that can improve access for people with MCS. These include installing fresh-air ventilation systems and operable windows, allowing more natural light, avoiding carpet, and pesticide-free landscaping. To improve access for people with EHS, smart meters should be avoided or shielded. Molloy called attenion to an earlier project on indoor environmental quality that was conducted by the National Institute of Building Sciences with funding from the Access Board. She outlined findings and recommendations from the project, which are provided in a report that is avaialble on the Board’s website.

The following presentations addressed ADA compliance in the cities of Phoenix and Tempe. Phoenix ADA Coorindator Peter Fischer reviewed recent initiatives by the city to enhance accessibility under its ADA Compliance Program. He noted that the city regularly surveys facilities for compliance with the ADA and that transition plans are continuously updated to reflect city projects and programs. Several Phoenix tranportation departments have undertaken transition plans, including a city-wide program to install curb ramps and accessible pedestrian signals. Last year, over 2,000 curb ramps were replaced. Other city initiatives include a new committee on integrating accessibility in emergency planning and response, an annual awards accessibility showcase, and a “Save Our Space” campaign that enlists volunteers to help enforce accessible parking.

Michele Stokes, an ADA Compliance Specialist with the Tempe Office of Strategic Management and Diversity, noted an online resource the city has launched to collect data on accessibility issues on city property for self-evaluations and tranisiton planning. It includes a newly launched interactive map with data from digital surveys of sidewalks, curb ramps, cross walks, bus stops and pedestrian signals that will help city planners with transition planning. The surveys collect data on running and cross slopes, changes in level, such as joint heavings, surface gaps, and other features along with geographic coordinates. The city also allows the public to report access issues online and offers other resources on local accessibility.

The final speaker, Bob Hazlett of the Maricopa Association of Governments, addressed autonomous vehicles and opportunities they may offer people with disablitities, including those with vision impairments. He noted that a lot of testing of driverless vehicles is done in Arizona which is becoming known as the place “where self-driving vehicles go to learn.” While it is not known when autonomous vehicles may fully take to the road, the potential impacts on public policy and planning at the local level are being assessed, including those pertaining to parking, infrastructure, public transportation, and cybersecurity, among others.

During the public forum that followed, members of the public raised areas where more needs to be done for accessibility. Many urged action to address access for people with MCS and EHS and described how exposure to certain commonly-used chemicals and to elemtromagnetic fields jeopardize their health, limit access to health care, housing, and other services, and lead to isolation. Some commenters submitted information on the subject and endorsed the work of organziations such as the National Center for Environmental Health Strategies.

Other issues noted included the need for entrance doors to be automated, hotel beds that are too high for transfer, access to casinos, and the lack of electronic shopping carts. The Board was urged to do more outreach and training on access to medical care equipment which remains problematic despite new standards the Board issued last year for medical disagnostic equipment.

In addition, concerns were raised about access for people who are deaf or hard of hearing. Several comments focused on the sound quality and availability of assistive listening systems in meeting spaces. They also addressed connectivity issues that impact video remote sign language interpretation in hospitals and the lack of communication access in pharmacies to instructions for taking medications.

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Board to Host Information Meeting on Assembly Areas September 6

assembly iconOn September 6 the Access Board will hold a public forum on accessibility and assembly areas. The day-long event will focus on accessibility issues related to the design of such facilities, including movie theaters, dinner theaters, performing arts centers, lecture halls, grand stands, stadiums, arenas, and other assembly venues. It will offer an open dialogue to review design challenges and identify potential solutions.

“Our goal is to bring everyone together to find ways of resolving accessibility issues that are unique to different types of assembly spaces,” states Board Executive Director David Capozzi. “The Board will use this information to enhance the technical assistance and training it provides to the public.”

Persons with disabilities, advocacy groups, designers and architects, trade groups, codes organizations, industry, and other interested parties are welcome to attend. Registration is not required. Additional details, including the agenda, will be posted in coming weeks. This event will be in-person only and will not be streamed online. Direct any questions to Dave Yanchulis at [email protected] or (202) 272-0026 (v), or (202) 272-0027 (TTY).

Information Meeting on Assembly Area Accessibility 
September 6, 9:30 – 5:00 (ET)
Access Board Conference Center
1331 F Street, NW, Suite 800
Washington, D.C.
Note: For the comfort of all participants and to promote a fragrance-free environment, attendees are requested not to use perfume, cologne, or other fragrances.

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Bill Botten Named Board’s Coordinator of Training and Technical Assistance

Bill BottenBill Botten, a long-time Board Accessibility Specialist, has been appointed Training and Technical Assistance Coordinator. In this dual role, he will oversee both the agency’s training program and its provision of technical guidance to the public. The Board regularly provides training on its accessibility guidelines and standards upon request at various events and conferences across the county. It also conducts a monthly webinar series in partnership with National Network of ADA Centers. Botten will field training requests, coordinate educational sessions and webinars, and assign Board staff.

In addition, Botten will manage the Board’s technical assistance program. The Board regularly provides technical guidance on its accessibility guidelines and standards and accessible design through its toll-free help line and by email. Accessibility specialists are available to answer questions on accessibility as it relates to the built environment, outdoor sites, streets and sidewalks, transportation vehicles and vessels, information and communication technology, and medical diagnostic equipment.

Botten has served as an Accessibility Specialist at the Board for 18 years and was active in the development of new guidelines and guidance documents for outdoor developed areas and for recreation facilities. He has trained extensively in these and other areas and is a top-rated and highly-requested presenter.

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Upcoming Board Webinars

laptop with Access Board sealThe next webinar in the Board’s free monthly series will take place July 12 from 2:30 – 4:00 (ET) and will review requirements in the ADA and ABA Accessibility Standards for transportation facilities. Presenters will cover provisions for bus stops and shelters, rail stations, and train stations.

The following webinar on August 2 will feature an open question and answer session. Questions are welcome on the Board’s accessibility guidelines and standards, including those issued under the ADA and ABA, as well as other topics related to the Board’s work.

Visit www.accessibilityonline.org for more information or to register for the webinars. Questions can be submitted in advance of the session or can be posed during the webinar. Webinar attendees can earn continuing education credits. The webinar series is hosted by the ADA National Network in cooperation with the Board. Archived copies of previous Board webinars are available on the site.

Section 508 Best Practices Webinar
The Board also offers a free webinar series on standards issued under Section 508 of the Rehabilitation Act which requires access to information and communication technology in the federal sector. The next webinar in this series is scheduled for July 31 from 1:00 to 2:30 (ET) and will address how federal agencies can update policies for the revised 508 Standards. For more details or to register for this or other sessions, visitwww.accessibilityonline.org/cioc-508/schedule. The Section 508 Best Practices Webinar Series is made available by the Accessibility Community of Practice of the CIO Council in partnership with the Board.

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Next Access Board Meeting to Take Place July 11

The Access Board will hold its next meeting July 11 from 1:30 – 3:00 (ET) at the Board’s conference space in downtown Washington, D.C. The public is welcome to attend in person or through a live webcast of the meeting.

A public comment period will be held during the final 15 minutes of the meeting. Those interested in making comments in person or by phone should send an email to Rose Bunales at [email protected] by July 5 with “Access Board meeting – Public Comment” in the subject line. Please include your name, organization, state, and topic of your comment in the body of the message.

Meeting of the U.S. Access Board 
July 11, 1:30 – 3:00
Webcast link: www.access-board.gov/webcast
Access Board Conference Center
1331 F Street, NW, Suite 800
Washington, D.C.
Note: For the comfort of all participants and to promote a fragrance-free environment, attendees are requested not to use perfume, cologne, or other fragrances.

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DOJ Rules for Movie Theater Captioning and Audio Description Take Effect

DOJ sealAs of June 2, movie theaters showing digital movies must provide a means for delivering closed captioning and audio description underrules issued under the ADA by the Department of Justice (DOJ). Issued 18 months ago, the rules supplement provisions in DOJ’s ADA regulations on provision of auxiliary aids and services. Movie theaters that show digital movies equipped with closed captions and audio description must acquire and maintain equipment for displaying captions and transmitting audio description.

Closed captions are displayed individually to patrons with hearing impairments at their seats. Open captioning displayed on the movie screen is not required. Audio description provides additional narration of a movie’s visual elements to patrons with vision impairments and is typically transmitted by infrared or FM systems to wireless headsets. The rule specifies the minimum number of closed captioning and audio description devices that must be provided based on the number of auditoriums in a theater. The rule does not apply to theaters showing analog movies only, nor does it require such theaters to convert to digital projection systems. For further information, visit DOJ’s website or contact its ADA hotline at (800) 514-0301 (v) or (800) 514-3083 (TTY).

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W3C Releases Updated Web Content Accessibility Guidelines

W3C logoOn June 5, the World Wide Web Consortium (W3C) released an update of its Web Content Accessibility Guidelines (WCAG) 2.0, a globally recognized, technology-neutral accessibility standard for web content. WCAG 2.1 builds upon guidance developed by W3C’s Web Accessibility Initiative by expanding coverage of mobile device accessibility and enhancing access for people with low vision and who have cognitive or learning disabilities.

“The Board applauds the progress made by the W3C Accessibility Guidelines Working Group in its release of the WCAG 2.1,” said Board Executive Director David Capozzi. “The efforts to broaden the range of disability needs currently addressed by WCAG 2.0 will benefit many individuals who still encounter barriers to accessing the web.”

The Board’s updated Section 508 Standards for information and communication technology in the federal sector reference the WCAG 2.0 and apply it to websites, electronic content, and software. In developing WCAG 2.1, the Accessibility Guidelines Working Group ensured backwards capability so that content meeting WCAG 2.1 also satisfies WCAG 2.0.

W3C’s Web Accessibility Initiative works with organizations around the world to promote accessibility of the Web. It helps ensure that web technologies support access, develops accessibility guidelines and related resources, and promotes harmonization of international standards. For further information, visit www.w3.org/WAI/ or contact Amy van der Hiel, W3C’s Media Relations Coordinator at [email protected] or (617) 253-5628.

Accessibility ADA Committee Formed by Kiosk Manufacturers

KIOSK ADA COMMITTEE & WORKING GROUP

Kiosk Accessibility & Kiosk ADA Committee & ADA Working Group

Kiosk ADA Committee
Meeting with US Access Board – from right – David C., Mike James, Peter and then a bit of Laura (behind Peter)

To assist in formulating some agreed upon kiosk accessibility guidelines and understandings, and also to communicate those guidelines to the appropriate standards body we have an ADA Advisory Board and also an ADA Working Group.  Here is the writeupfrom our Kiosk ADA Committee meeting with the U.S. Access Group in Washington, DC in November 2017.

Our Kiosk ADA Committee Advisory Board includes:

  • Olea Kiosks
  • KIOSK Information Systems
  • Frank Mayer and Associates, Inc.
  • KioWare
  • iPadKiosks
  • TurnKey Kiosks
  • Storm Interface
  • Peerless AV
  • DynaTouch

Our ADA Working Group:

  • Lilitab
  • Olea Kiosks
  • KioWare
  • iPadKiosks
  • Storm Interface
  • Turnkey Kiosks
  • DynaTouch
  • Frank Mayer and Associates, Inc.
  • KIOSK Information Systems
  • Assistra Technology
  • URway Holdings
  • Contributor – ATMIA
  • Contributor – ETA
  • Contributor – Taylor Mounts
  • Contributor – NCR Dundee

Current Agenda:  Reviewing pertinent sections and providing feedback and comments before we meet with US Access Board in November

kiosk accessibility
kiosk accessibility comes in many forms

Kiosk Accessibility Standards:

Here are the sections 402 and 407. Comments appreciated.  Full doc is here. ADA-2017-00395

402 Closed Functionality

402.1 General. ICT with closed functionality shall be operable without requiring the user to attach or install assistive technology other than personal headsets or other audio couplers, and shall conform to 402.

402.2 Speech-Output Enabled. ICT with a display screen shall be speech-output enabled for full and independent use by individuals with vision impairments.

EXCEPTIONS: 1. Variable message signs conforming to 402.5 shall not be required to be speech-output enabled.

2. Speech output shall not be required where ICT display screens only provide status indicators and those indicators conform to 409.

3. Where speech output cannot be supported due to constraints in available memory or processor capability, ICT shall be permitted to conform to 409 in lieu of 402.2.

4. Audible tones shall be permitted instead of speech output where the content of user input is not displayed as entered for security purposes, including, but not limited to, asterisks representing personal identification numbers.

5. Speech output shall not be required for: The machine location; date and time of transaction; customer account number; and the machine identifier or label.

6. Speech output shall not be required for advertisements and other similar information unless they convey information that can be used for the transaction being conducted.Start Printed Page 5838

402.2.1 Information Displayed On-Screen. Speech output shall be provided for all information displayed on-screen.

402.2.2 Transactional Outputs. Where transactional outputs are provided, the speech output shall audibly provide all information necessary to verify a transaction.

402.2.3 Speech Delivery Type and Coordination. Speech output shall be delivered through a mechanism that is readily available to all users, including, but not limited to, an industry standard connector or a telephone handset. Speech shall be recorded or digitized human, or synthesized. Speech output shall be coordinated with information displayed on the screen.

402.2.4 User Control. Speech output for any single function shall be automatically interrupted when a transaction is selected. Speech output shall be capable of being repeated and paused.

402.2.5 Braille Instructions. Where speech output is required by 402.2, braille instructions for initiating the speech mode of operation shall be provided. Braille shall be contracted and shall conform to 36 CFR part 1191, Appendix D, Section 703.3.1.

EXCEPTION: Devices for personal use shall not be required to conform to 402.2.5.

402.3 Volume. ICT that delivers sound, including speech output required by 402.2, shall provide volume control and output amplification conforming to 402.3.

EXCEPTION: ICT conforming to 412.2 shall not be required to conform to 402.3.

402.3.1 Private Listening. Where ICT provides private listening, it shall provide a mode of operation for controlling the volume. Where ICT delivers output by an audio transducer typically held up to the ear, a means for effective magnetic wireless coupling to hearing technologies shall be provided.

402.3.2 Non-private Listening. Where ICT provides non-private listening, incremental volume control shall be provided with output amplification up to a level of at least 65 dB. A function shall be provided to automatically reset the volume to the default level after every use.

402.4 Characters on Display Screens. At least one mode of characters displayed on the screen shall be in a sans serif font. Where ICT does not provide a screen enlargement feature, characters shall be 3/16 inch (4.8 mm) high minimum 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.

402.5 Characters on Variable Message Signs. Characters on variable message signs shall conform to section 703.7 Variable Message Signs of ICC A117.1-2009 (incorporated by reference, see 702.6.1).


407 Operable Parts

407.1 General. Where provided, operable parts used in the normal operation of ICT shall conform to 407.

407.2 Contrast. Where provided, keys and controls shall contrast visually from background surfaces. Characters and symbols shall contrast visually from background surfaces with either light characters or symbols on a dark background or dark characters or symbols on a light background.

407.3 Input Controls. At least one input control conforming to 407.3 shall be provided for each function.

EXCEPTION: Devices for personal use with input controls that are audibly discernable without activation and operable by touch shall not be required to conform to 407.3.

407.3.1 Tactilely Discernible. Input controls shall be operable by touch and tactilely discernible without activation.

407.3.2 Alphabetic Keys. Where provided, individual alphabetic keys shall be arranged in a QWERTY-based keyboard layout and the “F” and “J” keys shall be tactilely distinct from the other keys.

407.3.3 Numeric Keys. Where provided, numeric keys shall be arranged in a 12-key ascending or descending keypad layout. The number five key shall be tactilely distinct from the other keys. Where the ICT provides an alphabetic overlay on numeric keys, the relationships between letters and digits shall conform to ITU-T Recommendation E.161 (incorporated by reference, see 702.7.1).

407.4 Key Repeat. Where a keyboard with key repeat is provided, the delay before the key repeat feature is activated shall be fixed at, or adjustable to, 2 seconds minimum.

407.5 Timed Response. Where a timed response is required, the user shall be alerted visually, as well as by touch or sound, and shall be given the opportunity to indicate that more time is needed.

407.6 Operation. At least one mode of operation shall be operable with one hand and shall not require tight grasping, pinching, or twisting of the wrist. The force required to activate operable parts shall be 5 pounds (22.2 N) maximum.

407.7 Tickets, Fare Cards, and Keycards. Where tickets, fare cards, or keycards are provided, they shall have an orientation that is tactilely discernible if orientation is important to further use of the ticket, fare card, or keycard.

407.8 Reach Height and Depth. At least one of each type of operable part of stationary ICT shall be at a height conforming to 407.8.2 or 407.8.3 according to its position established by the vertical reference plane specified in 407.8.1 for a side reach or a forward reach. Operable parts used with speech output required by 402.2 shall not be the only type of operable part complying with 407.8 unless that part is the only operable part of its type.

407.8.1 Vertical Reference Plane. Operable parts shall be positioned for a side reach or a forward reach determined with respect to a vertical reference plane. The vertical reference plane shall be located in conformance to 407.8.2 or 407.8.3.

407.8.1.1 Vertical Plane for Side Reach. Where a side reach is provided, the vertical reference plane shall be 48 inches (1220 mm) long minimum.

407.8.1.2 Vertical Plane for Forward Reach. Where a forward reach is provided, the vertical reference plane shall be 30 inches (760 mm) long minimum.

407.8.2 Side Reach. Operable parts of ICT providing a side reach shall conform to 407.8.2.1 or 407.8.2.2. The vertical reference plane shall be centered on the operable part and placed at the leading edge of the maximum protrusion of the ICT within the length of the vertical reference plane. Where a side reach requires a reach over a portion of the ICT, the height of that portion of the ICT shall be 34 inches (865 mm) maximum.

407.8.2.1 Unobstructed Side Reach. Where the operable part is located 10 inches (255 mm) or less beyond the vertical reference plane, the operable part shall be 48 inches (1220 mm) high maximum and 15 inches (380 mm) high minimum above the floor.

407.8.2.2 Obstructed Side Reach. Where the operable part is located more than 10 inches (255 mm), but not more than 24 inches (610 mm), beyond the vertical reference plane, the height of the operable part shall be 46 inches (1170 mm) high maximum and 15 inches (380 mm) high minimum above the floor. The operable part shall not be located more than 24 inches (610 mm) beyond the vertical reference plane.

407.8.3 Forward Reach. Operable parts of ICT providing a forward reach shall conform to 407.8.3.1 or 407.8.3.2. The vertical reference plane shall be centered, and intersect with, the operable part. Where a forward reach allows a reach over a portion of the ICT, the height of that portion of the ICT shall be 34 inches (865 mm) maximum.

407.8.3.1 Unobstructed Forward Reach. Where the operable part is located at the leading edge of the maximum protrusion within the length of the vertical reference plane of the ICT, the operable part shall be 48 inches (1220 mm) high maximum and 15 inches (380 mm) high minimum above the floor.

407.8.3.2 Obstructed Forward Reach. Where the operable part is located beyond the leading edge of the maximum protrusion within the length of the vertical reference plane, the operable part shall conform to 407.8.3.2. The maximum allowable forward Start Printed Page 5839reach to an operable part shall be 25 inches (635 mm).

407.8.3.2.1 Operable Part Height for ICT with Obstructed Forward Reach. The height of the operable part shall conform to Table 407.8.3.2.1.

Table 407.8.3.2.1—Operable Part Height for ICT With Obstructed Forward Reach

REACH DEPTHOPERABLE PART HEIGHT
Less than 20 inches (510 mm)48 inches (1220 mm) maximum.
20 inches (510 mm) to 25 inches (635 mm)44 inches (1120 mm) maximum.

407.8.3.2.2 Knee and Toe Space under ICT with Obstructed Forward Reach. Knee and toe space under ICT shall be 27 inches (685 mm) high minimum, 25 inches (635 mm) deep maximum, and 30 inches (760 mm) wide minimum and shall be clear of obstructions.

EXCEPTIONS: 1. Toe space shall be permitted to provide a clear height of 9 inches (230 mm) minimum above the floor and a clear depth of 6 inches (150 mm) maximum from the vertical reference plane toward the leading edge of the ICT.

2. At a depth of 6 inches (150 mm) maximum from the vertical reference plane toward the leading edge of the ICT, space between 9 inches (230 mm) and 27 inches (685 mm) minimum above the floor shall be permitted to reduce at a rate of 1 inch (25 mm) in depth for every 6 inches (150 mm) in height.