Reading by Touch

    By James Smith, JD, Regulations Compliance Manager, HotelSigns.com

    The California Visual Impairment Accessibility Standard

    Accessibility signage in the hospitality industry serves to accommodate guests with visual impairments. Whether a guest is blind or has low vision, the state of California mandates accessibility requirements based on the 2010 ADA Standards for Accessible Design, a product of federal regulations. California, however, provides an overall higher standard of accessible design requirements than those of federal law. Although accessibility standards cover nearly every aspect of the built environment, sign requirements occupy only a small but crucial portion. This article clarifies important technical points to offer a better understanding of what must be crafted by hoteliers to meet the accessibility needs of their guests.

    Minimum Standards Set by the ADA

    In the historical context, the Americans with Disabilities Act (ADA) was signed into law on July 26, 1990, by president George H.W. Bush. Although in practice it serves to accommodate Americans with disabilities, it also represents one of our nation’s most sweeping pieces of civil rights legislation to date. The ADA covers a host of physical disabilities and applies to both the public and private sectors. Specifically, hotels fall within the scope of Title III Public Accommodations and Commercial Facilities. By enacting the ADA, Congress intended to provide a clear and comprehensive federal mandate for the elimination of discrimination against individuals with disabilities and provide broad coverage (42 USC § 12101(a)(1)). Except for a few enumerated exceptions, the ADA is indeed broad in its scope; it covers essentially any physical or mental circumstance that disrupts an individual’s daily life. While the general Act covers such things as Findings, Purpose, and Definitions, the Department of Justice has been tasked with enforcing the ADA. Therefore, the 2010 ADA Standards for Accessible Design (SfAD) are found within the Code of Federal Regulations, specifically 28 CFR part 36 subpart D (Title III), and 36 CFR part 1191, appendices B and D (the 2004 ADAAG combined with Title III make up the SfAD).

    Just like the ADA, California’s accessibility criteria applies to public accommodations, but the technical signage requirements as amended are found within the California Building Code at Chapter 11B, Division Seven, Section 11B-703. A detailed companion guide to California’s accessibility requirements may be found in the 2019 California Access Compliance Advisory Reference Manual, which falls within the managing authority of the Division of State Architect. The general purpose of the Code establishes minimum requirements to safeguard the public health, safety, and general welfare of the built environment. Therefore, while most of the substantive requirements are identical to the ADA, necessarily there are a couple of California specifics important to discuss.

    California-Specific Accessibility Design Criteria

    Notwithstanding the fact that tactile text must always be raised from its background, text format is one of the most critical issues that California addresses. Section 11B-703.2.9 states, “Text shall be in a horizontal format.” While simple in its mandate, this affirmative requirement removes all doubt as to whether tactile accessibility signage may have vertical text, something not addressed by the ADA. Such a rule of text formation complies with the English writing system in so far as it follows a horizontal, left to right format. California applies a stricter benchmark to its braille requirements as well. Both federal and state manuals require Grade 2, contracted braille, but similar to text formatting, the ADA is also silent on particular braille specifications. In its effort to provide a distinct standard, California has amended the positional and dimensional rules concerning braille. Section 11B-703.3.2 mandates “…a horizontal format, flush left or centered.” Further, under the dimensional measurements of Table 11B-703.3.1, the spacial distance provided between two dots in the same cell or corresponding dots in adjacent cells are fixed, unlike its federal counter part, which allows for minimum and maximum variations. The effort here assures greater clarity for those who rely on the presence of braille within the built environment.

    Understanding the Purpose of Tactile Accessibility Design

    The primary purpose of vision-based accessibility design seeks the removal of barriers that prevent the visually disabled from full and equal enjoyment of the built environment. In order to provide full and equal enjoyment of hospitality services several accommodations are presented: (1) consistency in physical installation of the sign; (2) adherence to a common language system; and (3) horizontal raised text and braille. Conversely, if a sign lends itself more to an abstract ornamental design concept, it may unwittingly do so at the expense of visually impaired guests. Those of us who read by sight take for granted signs that convey information such as room numbers and wayfinding directionals, but this presumed niche area of accessibility law is one of the most important aspects of the built environment. Interior accessibility signage makes all the difference in the world as tactile signs will be how the visually impaired interact with your establishment.

    James Smith, JD is the Regulations Compliance Manager at HOTELSIGNS.com and may be reached at jamessmith@hotelsigns.com or 423.697.6348. Since 2018, he has advised the company on all signage regulations as it relates to the built environment, including ADA standards, fire codes, building codes, or any local ordinance pertaining to interior signage. An U.S. Navy veteran, he enjoys spending time with his wife and daughter and is an avid runner.

    HOTELSIGNS.com is a major provider of ADA-compliant hospitality signage with over 30 years of experience. Since 1987, it has provided signage for both leading hotel chains and independent hotels. Its SignStars© Rewards Club is free to join and allows hoteliers to enjoy free shipping and 5 percent off on all web orders within the continental U.S.