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I am working on an privately owned apartment complex in LA with 750 apartments that was built before 1991. The client went to The Building Department and they did not know, so and they sent him to the disability office and they said they are required. After going back and forth with a few people on the subject, I need to know... What is the code for braille signs at the apartment door? I think I get new construction and publicly funded projects but need to get some clarification.
I know it's safe to just do the signs in braille as I believe in the idea of universal design, but when competing with other sign shops on code signage throwing out differing views (and estimates), I need to know what the code really is and the people who are supposed to be inspecting it do not know!
Thanks Sharon,
I have read in other sites about the confusion...
This project is part of a series of projects being done, probably in the realm of 4-6,000 apartments in various locations, some have already been designed (like the project in question) others I am designing.
These particular apartment signs are ceramic or limestone tile signs with a mosaic and outer limestone surround with an etched/blasted graphic and numbers. To add braille and tactile they would have to drill braille into limestone. The price for modifying the sign to acrylic or drilling braille into the stone far exceeds the normal process. Which is why the issue came up.
The project is going out to bid by a general contractor and quite a few "required" signs did not make it in the package. I requested that the contractor or client send a request in to the fire department about the Title 19 signs to make sure all the bases were covered when the issues of the braille signs on the apartments came up during the bidding process. I also requested they go to the building department on the issues of the apartment signs since they are the enforcing agency.
On the 11A code issue I have this particular note..
[b]1102A.2 Existing buildings. The building standards contained in
this chapter do not apply to the alteration, repair, rehabilitation or maintenance of Group R Occupancies constructed for first occupancy
prior to March 13, 1991.[/b]
Housing which is publicly funded as defined in Chapter 2 of this code
is subject to provisions of the Division of the State Architect
(DSA─AC). See Section 1111.B.5.
[b]Covered multifamily dwellings shall be maintained in compliance
with the accessibility standards in effect at the time of construction. Apartments constructed prior to March 13, 1991 shall be maintained
in compliance with the accessibility standards in effect at the time
of construction.[/b]
Additions to Group R occupancies shall be subject to the requirements
of this chapter, provided the addition, when considered alone, meets
the definition of a covered multifamily dwelling, as defined in this
chapter. New common use spaces serving existing covered multifamily dwellings shall be subject to the requirements of this chapter.
As you know, the code also says the following on enforcement.
109.1.4.3 The building department of every city, county, or city
and county within the territorial area of its city, county, or city
and county, where private funds are utilized. “Building department”
means the department, bureau or officer charged with the
enforcement of laws or ordinances regulating the erection or
construction, or both the erection and construction, of buildings.
Someone went to the city and was bypassed to the Disability division and was told that they need braille and tactile per the 11A requirements. I do not know if they went to the Building Division. With multiple bids going on, I estimate 30-50k difference in costs, making braille signs that may not be "required",multiply that by 6 similar projects and that is a large amount to deal with. The client knows they need to be compliant when it is required, they just want to know what needs to be compliant before making a policy.
I actually think, now that you describe it, that I got a call about these. It wasn't you, was it? It sounds like the same project. The person said, however, that he was a tile contractor. I asked him to send me a drawing of the sign he described, and i told him I thought I could come up with an economical and attractive way to do this. I talked to him about the standards that have already been used in California for what I call "combo" signs. He said the visual numbers were fairly large -- about 1 1/2 inches high, incised into the center tile and he planned to color fill with a good contrasting color. I suggested that I could design a clear piece of acrylic, very small, perhaps with clear tactile numbers and braille, that sould be mounted below the decorative tile sign. He didn't seem to get my point and described something I did not think would be as attractive, and did not send me the sketch.
The problem that I see here if there is a decision that these signs are required, or if someone sues, is that it sounds as if the visual signs are pretty expensive. The question would be, then why can't you afford to also provide something accessible?
I do think that there should be a fairly inexpensive way to do this, which will not intrude too much on the aesthetic quality. I wonder if they could be molded of clear plastic, given the quantity? The point is, of course, that if you are already providing a visual sign that works for the majority of people with vision impairments, then the tactile sign does not need contrast, can be very small (5/8 inch letters are fine, but they should be a very "open" typeface -- not condensed or bold), and can even be shiny. We did signs for the PDC on matte clear acrylic that were black for the show windows. They were very unobtrusive, but showed up just fine and were very readable both by touch and visually. You might even use a small contrasting letter on clear if that's easier, or a color that matches the background of the wall.
There is one more point on these apartment signs. Signs have a special caveat: They are considered elements in and of themselves. When you change out a sign or put in a new sign, you are actually supposed to comply with the most recent code, not the code in effect originally. That goes even if no permit is required. The Access Board staff told me this was the case long ago, and it is written into the general section for signs in 11B. I'll have to check 11A, but generally, the sign section in 11A refers to 11B, and the intent is to have them match.
I don't think you can really make a case that the sign design is somehow "grandfathered" in since you are designing new signs. If tactile signs are required, I think the new design has to reflect that. However, as I said in my slightly earlier post, I think you might do something creative to solve it that will not be too expensive and will also be fairly unobtrusive.
It wasn't me... I would have told you it was me Sharon, I used to work for you. :D
I have suggested several ways to get the braille on and samples may be done including the ideas you suggested. There are other issues I am dealing with with this particular project. The only issue they need to know is, are they actually required by code?
If they are not, then the client does not have to worry about a lawsuit or the expense.
The big issue for my client is a sign or general contractor bidding on this does not have to worry about bidding against someone who is not adding braille and tactile, there is a substantial difference in price with the amounts of signs they are dealing with.
I am drafting a letter with all the information after I get confirmation from the Building Department and some clarification from the State Architect to have the client make a policy about these signs and do them all the same.
I think the exclamation point confused me! I thought it was you, but answered first and then checked and of course realized I was correct. Probably the person who called me was bidding, because the sign sounded exactly the same.
I did send an email both to the Division of the State Architect and the DGS with the exact text of your post, stating that I received questions like this weekly -- I do -- and need some kind of definitive answer. As a matter of fact, we did discuss this, and I think it was left up in the air -- not unusual. I think it confuses everyone and no one really wants to take a stand. Also, lawsuite about the ADA don't have to "match" buiding codes or even ADAAG. There was one where a judge in northern California ruled that strip malls had to have company names like Burger King in braille and raised letters next to their exterior doors! Judges don't have to know anything about the ADA or building codes.
I'll try to get some kind of an answer. We might want to contact the HCD rather than the DSA, since HCD has authority over housing.
Rick, do you know someone who needs a job as a production manager? Finding someone in the ADA field who can meet my persnickity standards is always tough. I don't know how many such people actually exist. If there is anyone else on this forum, please contact me.
Sharon Toji
htoji@cox.net
When they changed the message board over someone snagged my name so I added the --->!
On the "GRANDFATHERING" clause, I could not get it in writing but it was told to me that the code I referenced above falls into that with the apartment unit signage. It was also relayed to me that the other signage had too comply to Federal ADA 28 C.F.R., Part 36 regardless of that 1102A.2 says since the Fed ADA is more stringent.
On the issue of signage or grandfathering I could not find any mention of ADA signs in relation to 1102A.2
Maybe that will help get some resolution.. but probably not in time for my current dilemma.
Thanks for your answers, I will keep an eye out for anyone looking for a job with that kind of knowledge. I still need to find time to visit too.
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I know that everyone depends on me for clear answers, but frankly, apartments have always stumped me! I get answers from HUD (fair housing) and other sources, and then they get contradicted. I was just at the two day meeting of the committee I'm on, and we chiefly went over housing requirements, and tactile signs are certainly there in 11A, but I'm still not clear if fuinding plays a part. When there is public funding, then I know that the signs are required, and I've heard that there is "hidden" public funding that could make a difference, like a concession made to the building owner on taxes.
There's also the topic of commercial use. Very often, a recreation room may get used in a way where the public is invited. Then it may require identification signs. What about the signs along corridors leading to such rooms? Is there a leasing office on site? Is there a manager's office where someone can go to fill out an application? And of course I believe that tactile exit signs and tactile signs for elevators are required everywhere.
As you say, the safest way out is just to suggest accessible signs, and that certainly is the path to universal design. And if there is a tenant who makes an ADA complaint, saying they have a hard time finding the Manager's office or maybe a neighbor they want to visit, could not having the signs be an ADA violation even if state code doesn't require the signs? So -- that's another reason just to suggest having the signs, which usually don't cost that much more than non-compliant signs. Sometimes they might even cost less!
I will try to get an answer that relies on the last code passed, although I never expect a totally clear answer, even from HCD, which has jurisdiction here.
Sharon Toji