Making AV Accessible
The idea behind the ADA is that people with disabilities should be given access to the same experience as an able-bodied user of a facility, including those that make use of AV systems.
The Americans With Disabilities Act of 1990 (ADA) has been law since it took full effect in 1992. The guidelines we use today were published in 1994, and are one evolution of the primordial, eight-page, ANSI standard 177.1 established some 30 years earlier. Some aspects of the 90-plus page “ADA Standards for Accessible Design” (also sometimes referred to as the “ADA Accessibility Guidelines,” or ADAAG) remain unchanged from that original document. However, other sections have been added, modified, and updated since that time.
The idea behind the ADA is that people with disabilities should be given access to the same experience as an able-bodied user of a facility, including those that make use of AV systems. Although it is relatively easy to accommodate both groups, this doesn’t mean everyone must use the same equipment. A simple system with a wall-mounted control system may include an additional, small, wireless touchscreen for disabled users, or the wall-mounted touchscreen must be mounted within mandated, accessible dimensional requirements. A lectern for a standing presenter may have a flip-out shelf with movable or wireless touch-screen for control from a wheelchair.
Annals of Accessibility
The ADA’s lineage is complicated in some respects, and the related laws that make it confusing or ambiguous for many of its users as well as the responsible agencies in the federal government. Take ADA’s near twin, the Architectural Barriers Act of 1968 (ABA), as an example. Besides having a similar acronym, the guidelines used for design under the ABA are very similar to the ADA.
The accessibility standards document for the ABA is commonly referred to as UFAS, which is the Uniform Federal Accessibility Standard, adopted in 1984 and largely unchanged since then.
The differences between the ADA and ABA have to do with the accessibility standards themselves and how they are applied. The application of each depends on the type of facility involved. The ADA applies to the construction and alteration of places of public accommodation and commercial facilities, often referred to as Title III facilities under Justice Department regulations, and state and local government facilities, often referred to as Title II facilities.
The ABA applies to facilities designed, built, or altered with federal money or leased by federal agencies, such as the General Services Administration, the U.S. Postal Service, and the departments of Defense and Housing and Urban Development. The Transportation Department has its own set of guidelines specifically for transportation facilities.
Sound confusing? It is. Making it even more complicated in the short term is the transition to a newer revision of the guidelines. The ADAAG is published by the U.S. Access Board, and is then adopted by other agencies as regulations or codes. There are two versions: one from 1994 and an updated version published in 2004.
The idea is that, eventually, all agencies will adopt the 2004 version, so that the ABA and ADA design guidelines will be the same across all facilities that these laws cover.
As of this writing, the 1994 ADAAG still applies under the ADA. The General Services Administration and the Postal Service officially use the updated 2004 ADAAG under the ABA. However, the departments of Defense and Housing and Urban Development use the 1984 UFAS standard as regulated, but the Defense Department has adopted a policy to use the new 2004 ADAAG on many facilities in the meantime.
That’s not all. The International Building Code (IBC) that is developed by the International Code Council (ICC) incorporates many of the same requirements as the ADAAG and UFAS documents, yet there are differences documented in a 500-page PDF available on the Access Board Web site. The ICC is the official ANSI secretary responsible for the still-referenced and updated ANSI 117.1 design guide that is now used within the IBC. The current version of the ANSI standard is the 2003 edition, which is mostly in line with the 2004 ADAAG. The next revision of the ANSI standard will be released in 2008.
What role does AV play in complying with all of these different standards? Let’s take a look at some of the most important design considerations involved in common AV installations.
Accessibility for AV
Most accessibility standards apply to the architectural, interior, and signage components of building design. These primarily affect AV in terms of facility layout and physical access to rooms, seating, and presenter capabilities. This translates into floor plans with wheelchair access to accessible spaces, seating layouts that accommodate wheelchair seating, and the design of lecterns that can accommodate presenters in wheelchairs.
The mostly architecturally driven criteria in the guidelines also affect AV electronic device installation so that wall- and ceiling-mounted devices in public circulation areas must adhere to mandated dimensions. End-user-accessed AV devices, such as control interfaces, DVD players, and document cameras, must also be within certain reach dimensions that can affect lectern design and rack layouts.
A few of the guidelines are specifically electronic in nature. The most notable for AV providers are the assistive-listening device requirements for hearing impaired patrons in places of assembly. AV design and integration often includes furniture when equipment is to be installed in lecterns, consoles, conference tables, and user equipment cabinets.
Accessibility requirements apply where AV is to be accessed by the public or in places of assembly. The ADA and other related or similar accessibility laws include requirements on forward and side reach from a wheelchair under various circumstances.
Side reach assumes that a person in a wheelchair can maneuver so that the chair is parallel to a user-accessed device. In this case, user equipment, for example, must be installed between 15 inches and 48 inches above the finished floor (AFF) for unobstructed side or forward reach under the 2004 ADAAG (Section 308). Obstructions up to 10 inches deep below the accessible items are allowed for this range in side reach conditions.
The 1994 ADAAG is the same for forward reach, but unobstructed side reach access is allowed between 9 inches and 54 inches (Section 4.2.6) — and no obstructions are allowed. This would mean user-accessed wall-or rack-mounted equipment, such as DVD players, control interfaces, and user AV jacks would need to be mounted within this vertical range.
In the case of a credenza, console, or other cabinetry with AV devices requiring access above it, the top of the furniture must be less than 34 inches AFF and less than 24 inches (side reach) or 25 inches (forward reach over a counter) maximum depth to the accessible device —and the equipment to be accessed can’t be more than 44 inches, 46 inches, or 48 inches AFF, depending on the condition as shown in Figures 1 and 2, below.
In addition, where there are consoles, counters, and desks, other sections of the ADAAG call for toe and knee clearances to be maintained. The 1994 guidelines are fairly simple, with minimum clearance of 27 -inch AFF high, 30-inch wide and 19 inches deep to be provided under the work surface (Section 4.32). The 2004 guidelines are a bit more complicated (Section 306), separating toe clearance from knee clearance. For toes, obstructions below 9 inches AFF must provide between 17 inches and 25 inches deep clear under a counter or desk surface. The knee space (considered to be between 9 inches and 27 inches AFF) must be at least 11 inches deep at 9 inches AFF, and 8 inches deep at 27 inches AFF with sloping allowances in between. Take a look at the 2004 ADAAG for more details on these requirements.
Under the ADA, the only AV electronics specifically called for are assistive listening devices, designed to aid the hearing impaired in listening to AV presentations. They come in the three primary forms of transmission: infrared (IR), radio frequency (RF), and induction loop. While the first two are familiar to even the AV novice, the third is a bit out of the mainstream. Induction loops are an older form of assistive listening transmission that use a wire loop antenna installed around a room. The electromagnetic transmission from this loop can be picked up by hearing aids designed to receive and amplify the signal.
Assistive listening devices are required in “assembly areas where audible communications are integral to the use of the space,” under the 1994 Section 18.104.22.168.b, which states that a permanently installed assistive listening system (ALS) is required in spaces that:
(1) Accommodate at least 50 persons, or have audio amplification, and
(2) Have fixed seating. This would include concert halls, theaters, houses of worship, and lecture halls or any listening space with fixed seating. Note that rooms with less than 50 fixed seats are also required to have a permanent system if there is an audio amplification system.
The 1994 ADAAG also states that: “For other assembly areas, a permanently installed assistive listening system or an adequate number of electrical outlets or other supplementary wiring necessary to support a portable assistive listening system shall be provided.” Therefore, rooms without fixed seating of less than 50 could be provided with either a permanent ALS or support for a portable ALS. Technically, the wording only requires electrical outlets for these other spaces. Any of the three transmission technologies may be used for the ALS, and signage indicating the availability of receivers is required. The number of receivers to be provided varies with the size of the spaces with a minimum of “4 percent of the total number of seats, but in no case less than two” be provided per space.
Both the 2004 ADAAG and the IBC call for similar quantities of receivers. The new ADAAG adds language that calls for at least 25 percent of the receivers to be hearing-aid compatible, meaning that they consist of or incorporate neckloops that are essentially wearable induction loops. Both newer guidelines also specifically state that rooms of any size without amplification (except for courtrooms) do not require assistive listening systems, and that buildings with multiple rooms under one management may use the sum of all seats in the multiple rooms to calculate the required number of receivers as long as they all work in all rooms. Under the new guidelines, rooms with induction loops are explicitly exempt from being required to provide any receivers.
Regardless of accessibility, most building codes have some basic dimensional requirements that must be met. One of the most common is that any overhead protrusions must clear a minimum of 80 inches AFF. This is part of both the old and new accessibility guidelines. The standards are required to be followed for both vertical and horizontal clearances in circulation paths, defined as: “An exterior or interior way of passage provided for pedestrian travel, including but not limited to, walks, hallways, courtyards, elevators, platform lifts, ramps, stairways, and landings.” This would also include aisles in audience seating areas and the area around a conference room table in some cases.
According to the both the old and new standards, wall-mounted items in a circulation path that are between 27 inches and 80 inches AFF must not protrude more than 4 inches from the wall (Figure 3 above). If the lower edge of a wall-mounted item extends below 27 inches AFF, then it (and items directly above it) can extend further out from the wall as long as the upper items do not extend out further than the lower ones. In addition, the protrusion must not reduce the passageway to less than minimum clearances, reducing the available width in a hallway or aisle to below minimum clearances, for example.
In the 1994 ADAAG, these same dimensions also apply to objects mounted from poles, columns, and pylons. In the newer ADAAG and the IBC, the allowable protrusion is extended to 12 inches for posts and pylons. Some examples of the implications of these dimensions for AV are:
- Ceiling-mounted video monitors, projectors, loudspeakers, and other overhead devices must have 80 inches clear to the floor underneath.
- Wall-mounted video monitors and loudspeakers must not protrude more than 4 inches from the surrounding wall surface, unless the bottom of the device and its support assembly is closer than 27 inches to the floor or 80 inches above it in a circulation path. This means that a flat-panel display with a wall mount that protrudes more than 4 inches from the wall is not allowed in an accessible hallway. In spaces that are employee-only, such as most control rooms, these requirements would not apply.
- Two back-to-back flat panel displays that are less than 28 inches wide could be mounted on a 4-inch diameter post with the bottom of the displays below 80 inches AFF.
There are three key questions to answer that determine if and how accessibility requirements are applied to a particular area:
1. Which standard applies to the situation? If the project is in the United States, then the accessibility requirements could be the 1994 ADAAG, the 2004 ADAAG, the IBC, or a local code that is more stringent than any of these for a particular parameter or in a particular type of facility. Local codes generally override state and federal requirements, unless the local codes are less stringent.
2. Is the area an employee area or not? Many employee areas, including conference rooms, lounges, and cafeterias, are also accessible to visitors and must therefore follow accessibility guidelines. In employee-only work areas, ADA requirements do not apply except if the entry is off of an accessible circulation path. Then, access and egress requirements apply, meaning that wheelchair access must be provided to get into and out of the room (but maneuvering about the room and consoles do not need to meet ADA requirements).
3. Is the area a circulation path? In a building with public access to presentation rooms and corridors, it is easy to determine what is a circulation path into, out of, and between accessible spaces in the building. In these areas, the ADA or ABA would apply. Once you get inside an employee work space, such as a closed office that is clearly not for circulation, then the regulations would not apply.
Some grey areas would include conference rooms, where areas around the conference table may be considered a circulation path in and out of the room. This would only apply, however, if the conference room was used by outside visitors and not just internal employees. Control rooms and data centers often raise questions about accessibility. For most organizations, an AV control room and a data center would be considered employee-only spaces.
This means that within the space racks, consoles, counters, and clearances would not have to adhere to the ADAAG. However, if the entrance to such space is not employee-only, then the entrance and egress to the space would require accessibility. This means that most AV projection and control rooms that are at the back of an auditorium would require accessibility into and out of the room, but that’s it. A ramp might be required up to the doorway if it’s raised above the surrounding floor, and clearances would need to be provided just inside and outside the door for wheelchair access, but the rest of the projection room would not require ADA/ABA dimensioning.
An alternative to a ramp into an employee-only control room would be to provide an employee-only corridor or storage space between the control-room door and the public area.
In this case, the entrance into the buffer space would need to be accessible, but a ramp would not be required inside the buffer space for the control entrance. This may take less space than a ramp when the control room is, say, 36 inches above the surrounding floor area.
The ADAAG calls for maximum 1-inch rise per 12-inch run for ramps plus a 5-foot landing at least every 30 feet and at the top of the run, so the ramp for this condition would be 36 feet long plus the 5-foot intermediate landing and top landing for a total length of 46 feet with minimum 36-inch clear width (a minimum total of 138 square feet). This might not be practical, or even possible, particularly in some renovations.
Enforcing the Law
The ADA and the ABA are not policed by the government, except as might be addressed in local permitting processes for new construction or renovation. The law is enforced when a complaint is registered either with the Equal Employment Opportunity Commission or the Justice Department.
Most offenses are settled with an agreement with the government calling for the owner to rectify the ADA or ABA deficiencies, but some can go further. A good site that tracks and documents many of these settlements is the ADA Document Portal (www.adaportal.org). There, you’ll find many cases have to do with assistive listening devices as well as other issues.
The bottom line is that when designing or installing AV in a facility where brick-and-mortar construction is to take place, it is important for the AV provider to coordinate with the building owner, the architect, and the AV system users to discuss how accessibility may affect the AV systems, the furniture configuration, or the architecture around it.
In some cases, there may be resistance to complying with the accessibility requirements. If so, there may be a legitimate hardship that is an allowable exception to the law. This should be reviewed with Equal Employment Opportunity Commission or the Justice Department to find out if this is the case.
FOR MORE INFORMATION
US Access Board: www.access-board.gov; (800) 872-2253 (voice); or (800) 993-2822 (TTY)
ADA and IT Technical Assistance Centers: www.adaportal.org
Justice Department’s ADA Homepage: www.usdoj.gov/crt/ada/
Justice Department’s Technical Assistance: 800-514-0301 (voice); 800-514-0383 (TDD)
International Code Council (for the International Building Code): www.iccsafe.org
Also, keep in mind that you may get different answers depending on who you talk to. Otherwise, in cases such as the common owner complaint of too many assistive listening receivers being required, it behooves the AV provider to send a letter stating that they have recommended the required items but the owner has refused to comply, and talk to your lawyer about it.
Tim Cape is a contributing editor to Pro AV magazine, the principal consultant for Atlanta-based technology consulting firm Technitect LLC and co-author of “AV Best Practices,” published by InfoComm International. He’s chairman of InfoComm’s ICAT consultant’s council, and an instructor and presenter in AV technology design and management. Contact him at [email protected]