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Building Codes and Inspections/Room ID signs - What needs Braille

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QUESTION: 1. For a room ID sign that displays the room number and the room name (i.e. "302 Staff Office"), can the Braille apply to the room number only, or does the Braille have to apply to both the room number and room name?

2. Could that room name be in vinyl (visual) without Braille?

3. If the room name and number are both tactile, is Braille required for the room name?

4.  If the room name is a paper insert, does it require a Braille translation?

ANSWER: According to the U.S. Access Board, only one of the methods of identification needs to be tactile including both raised characters and braille. That could be either the room number OR the room "function." Normally, if it's a restroom (and for an exit door), you should always use the name or function, even if it is numbered as well. Otherwise, it is too confusing for a person who is blind, who would read a number and think that it was an office, and not expect it to be a restroom or an exit door.

On the other hand, numbered rooms are easier to find for offices or classrooms, as long as the numbering system is logical.

In the case of an office with a number and a function or name, the function or name can be completely visual, including using vinyl, screen printing, or even a paper insert in case there may be a change in function.

As far as accompanying tactile characters with braille, it doesn't apply to all tactile characters. You might want them for decorative purposes, for instance. You might want them to be upper and lower case, but raised because of the fabrication method you are using. As long as the room number is raised and has braille, and as long as the visual name follows the rules for readable type (can be upper and lower case, can be serif, but cannot be decorative type face and must have high dark/light contrast and be non-glare), and is at least 5/8 inches high -- preferably a bit larger for visual readability -- you can use any method of making them you wish, raised or not.

And no, as I said above, visual portions of signs that also have the permanent identification (probably a room number) correctly raised and accompanied by braille, do not need braille translations.

I hope this explains it fully.

Now -- an extra!  There is a new section of the code that also allows you to provide the identification in separate visual and tactile sections. In other words, you could have large visual numbers, say 3 inches in height, and using a serif font, and accompany that with a much smaller tactile set of numbers and braille. Those could be "invisible," with no contrast to the background. The person with some vision would be able to read the large contrasting number, and the person with no vision would search and find the tactile portion, and would not care that it had no contrast.

This gives designers a lot of great new options, and also provides better access for the two types of legally blind persons -- those with usable vision, and those without. They have very different needs in signs, and this solves that problem.

Sharon Toji
The "ADA Sign Lady"

---------- FOLLOW-UP ----------

QUESTION: Hi, Sharon,

So I relayed your responses to The Lighthouse for the Blind. Apparently they have consulted with you on occasion as well. Greg disagrees with your interpretation, and insists that if the room number and room name are both tactile and the room number is brailled, then the room name must be brailled, too. Essentially he is saying that if you use tactile text that complies with 703.2, then it must have braille below it as well.

So I can use vinyl letters for the room name, and no braille is required. But as soon as you raise those letters 1/32", then you have to put braille below them. Obviously, to reduce cost, we will switch to vinyl lettering to avoid having to braille the room name. This seems silly to me. I would think that having tactile letters with no braille would still be preferable to visual (vinyl) letters only.

Greg Kehret's response is below. What say you?

“Raised characters shall comply with 703.2 and shall be duplicated in braille complying with 703.3” seems unequivocal. Sharon is saying when you have two sets of identifying information - a number and a function or name - according to the Access Board, only one is required to be raised and in braille. But by including both as raised, MoAD is obligated to include both as braille. The area for interpretation seems to be if function or name is a “fabrication style” (i.e. visual only), then no braille is needed, but raised characters that meet ADA and CBC guidelines for accessibility can’t be considered “a fabrication style”. So, you do either tactile and braille room number and visual only name, or you do tactile and braille room number and tactile and braille name.

Answer
I think we may be in one of those "unintended consequences"areas here. When we first wrote this, back in the ANSI Sign Task Force, we had long discussions about this. We wanted to make sure NOT to use the word "sign" exactly so that what Greg is insisting would not happen. Little did we know that the Gregs of the world would come along and be so literal! There are raised characters that are raised only for reasons that do not relate to accessibility. Sometimes, everything on a sign is raised merely because it is easier and less expensive to raise everything on the sign, including company names, logos, etc. Sometimes text is raised because the designer likes the look of raised text and the way it throws shadows on the plaque. They find no reason to follow any of the rules, and that text might be in a more decorative font, be higher than the raised text (making it actually more difficult to read by touch, etc.)

So, we wanted it to be clear that only text that was required to be raised was going to be checked against the standards for raised text. Other text, if informational or directional, would be checked against visual standards only. The Access Board has said clearly that only one element on the sign serves as the permanent identification of the room. For most rooms, that is the room number, if one is provided. However, exits and restrooms, according to them, are best identified by their functions. Their purpose is to provide the best access for the public. Again, there is nothing to say that you can't raise more portions of the text, and if they extend the identification into the informational portion, and the designer and owner wish to make those portions accessible, then that's fine. Also, someone could decide that the informational portion of the identification, or what we often call the "function," such as "Library," "Cafeteria" would be more meaningful to the public and to emergency responders, they might choose to leave off the number, or make it visual only, and permanently identify the room by the function.

But I can tell you that in no way was there an intent to say that any time you use a dimensional letter on a room sign it has to follow the standard for raised characters, which includes corresponding braille. That means that it might need to be too small, use uppercase characters that would not be as visually readable, etc. That can actually be counterproductive to anyone other than the very small proportion of the visually impaired community. The great majority of the visually impaired community are not functionally blind and do not read by touch. And to be blunt, to my sorrow, very few people who read by touch read braille. We need to keep that well in mind, with all deference to Greg.

I'll try to squeeze in a question to Marsha about this, since I am together with her here at the ANSI meeting. Or, maybe I'll send you the question. But I can tell you clearly what the intent was, because I participated in writing the item.



Sharon Toji

Building Codes and Inspections

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Sharon Toji

Expertise

I have special expertise in the subject of accessibility codes and guidelines (ADA), and most specifically in the field of signage. If you have a question that is not about the ADA or about signs, I suggest you try the following excellent site: Naffa International BCDG (Building Code Discussion Group). The website address is http://bcodes.infopop.cc/eve/ You do have to register, but it's free. You will find discussions here on all kinds of Building Code Q & A topics. You go to the forum that sounds as if it's close to your topic, check out some of the posts and see if it sounds like a fit. Then pose your question. With luck, you may get some really good answers. You can email some of the experts individually by clicking on the headings of their posts. When you ask a question, of me, or of someone on the above site, tell them your state, and maybe your city if it's a large city. That is crucial for answering code questions. Sharon Toji

Experience

I am a voting delegate to the American National Standards Institute that writes accessiblity standards used by the International Building Code and are the basis for the ADA Accessibility Guidelines (ADAAG). I am also a member of the Access Advisory Committee to the California State Building Standards Commission, among other positions.

Publications
Signs and the ADA (a manual I have written that is used across the country), and articles in many trade journals.

Education/Credentials
BA, Reed College Graduate work, University of Munich (Germany) and University of California, Irvine

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