The ADA and Public Schools

The American Foundation for the Blind's (AFB) ADA Solution
Center provides information about the Americans with
Disabilities Act (ADA) to persons who are visually impaired, to
businesses, and to governmental organizations required to comply
with the ADA.

Recently, the center has received a number of inquiries from
teachers of visually impaired students about how the ADA applies
to public schools. The most frequent questions have been about
whether every school building in a district must provide ramps
and widened doorways to accommodate wheelchairs and whether
school districts are required to provide braille and raised
print signs.

It is important to keep in mind that the ADA's impact on public
schools is broad based and encompasses far more than buildings
and facility design. School districts have responsibilities as
employers, under ADA Title I, and as providers of government
programs and services, under ADA Title II. Many of these
responsibilities are complex, especially when considered with
other laws and regulations, such as IDEA (Individuals with
Disabilities Education Act), the Rehabilitation Act of 1973, and
local laws.

Varied opinions about school districts' obligations have been
offered; however, the ultimate decisions will probably have to
come from the legal system.

ADA Title I requires employers to provide "reasonable
accommodations" for employees who are visually impaired. The
type of reasonable accommodation is determined on a case-by-case
basis, and reasonable accommodations must be effective in
affording equal employment opportunity.

ADA Title II included requirements for school districts to make
their programs, facilities, and services accessible to people
with disabilities. These requirements cover facility design as
well as "auxiliary aids and services," such as information in
accessible formats and sighted guide assistance. For example,
school districts would be responsible for providing accessible
information to parents who are visually impaired or to others
with visual impairments who participate in events that take
place at schools.

Facility Design

The ADA Accessibility Guidelines (ADAAG) for Title II, which
include facility design specifications for public buildings,
have been proposed. (At press time, the guidelines were not
issued in their finalized form.) The ADAAG documents that is
familiar to most vision teachers is the Title III ADAAG and
applies to places of public accommodations and commercial
facilities. Until a Title II ADAAG is issued, schools may adopt
the Title III ADAAG but are not obligated to do so. In the
interim, however, schools are obligated to be accessible in
conformance with Title III ADAAG or the Uniform Federal
Accessibility Standards (UFAS).

In addition, the ADAAG specifications for public buildings will
not cover children's environments. The U.S. Architectural and
Transportation Barriers Compliance Board (the Board) plans to
publish a proposed set of rules for children's environments in
1995.

Teachers of visually impaired students and orientation and
mobility instructors have a wealth of knowledge and experience
to contribute to this rule-making process. They can communicate
their input to the Board when the proposed ADAAG rule for
children's environments is published. Individuals can request to
be placed on the Board's mailing list to receive copies of the
proposed rule when it is issued by calling (202) 272-5434. A
free listing of all the Access Board's publications is also
available by dialing the same number.

Braille and Raised Letter Signs

So what if the role of teachers of visually impaired students
and orientation and mobility (O&M) instructors when a school
district administrator asks for input about installing braille
and raised letter signs? Vision teachers and O&M instructors are
not experts who are qualified to provide answers to the tough
questions about ADA implementation that have yet to be resolved
through the legal system. They can, however, provide valuable
input about the placement of braille and raised letter signs,
the sign text, and the correctness and quality of the braille
once a school district has made a decision to install tactile
signage. Teachers should also be aware that their school
district or local municipal government is required to designate
an ADA coordinator who is responsible for developing and
disseminating the district's plan for removal of barriers as
required by the ADA and for processing ADA-related complaints or
grievances.

Teachers can also suggest that school districts provide braille,
raised-letter, and large-print signs as an "auxiliary aid or
service." Although tactile signage is not a typical example of
an auxiliary aide, teachers who would like to encourage
districts to promote such signage can suggest this option.
Unlike the ADAAG, the requirements for auxiliary aids and
services do not specify how an accommodation is to be made, but
allow for flexibility. Auxiliary aids and services, however,
must communicate information effectively, accurately, clearly,
and in a timely manner.

Tactile and large-print signs can be purchased from vendors.
When used as an auxiliary aid or service, the signs do not need
to be placed at 60 inches to the center line of the sign, as
specified by Title III ADAAG. (Many teachers have observed that
such placement would put signs out of reach of many young
children.) Nevertheless, it is important to follow the ADAAG
specifications for locating signs on the latch side of a door
away from the swing of a door and protruding objects and for
placing tactile signs at double doors alongside the right door
jamb. (Tactile signs should never be placed on doors.) In
addition, signs provided as auxiliary aids and services should
be durable enough to withstand regular use by children and to
preserve the integrity of the tactile message.

The AFB National Access Initiative, through its ADA Consulting
Group, provides consultation (for a fee) to organizations
requesting technical assistance in developing a tactile and
large-print signage system. It also provides technical
assistance to organizations seeking to comply with the ADA. The
AFB ADA Consulting Group offers a Sign Analysis Report Service
and maintains a directory of manufacturers of tactile signage
whose products have been reviewed by AFB. It can be reached at
(212) 502-7600. The AFB ADA Solution Center can be reached at
(212) 502-7658.

Elga Joffee, Chairperson, AFB ADA Consulting Group
11 Penn Plaza, Suite 300
New York, NY 10001