CHLA Lodging News July/August 2021

12 CALIFORNIA LODGING NEWS www.calodging.com Reading by Touch The California Visual Impairment Accessibility Standard By James Smith, JD, Regulations Compliance Manager, HotelSigns.com 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