Accessible Public Telephone Installations as Defined by the ADA
Richard Acree
Public telephone installations in Title II and Title III facilities are required to comply with the Americans with Disabilities Act (ADA). This article will discuss the ADA scoping and technical requirements for accessible telephones in State and local government facilities, public accommodations, and commercial facilities. 2010 ADA Standard 217 covers scoping requirements for telephones and Standard 704 covers technical requirements for signs; however, the word “telephone” can be found 121 times in the 2010 ADA Standards. The graphic above is representative of the symbol for a telephone with volume control.
General Telephone Requirements
2010 ADA Standard 217.1, [Telephones] General, states, “Where coin-operated public pay telephones, coinless public pay telephones, public closed-circuit telephones, public courtesy phones, or other types of public telephones are provided, public telephones shall be provided in accordance with [Standard] 217 for each type of public telephone provided. For purposes of this section, a bank of telephones shall be considered to be two or more adjacent telephones.” So if no public telephones are provided, no ADA accessible phones are required.
2010 ADA Standard 217.3, [Telephones] Volume Controls, states, “All public telephones shall have volume controls complying with [Standard] 704.3.” So any and all public telephones must have volume control, whether wheelchair accessible or not.
2010 ADA Standard 704.3, [Telephones] Volume Control Telephones, states, “Public telephones required to have volume controls shall be equipped with a receive volume control that provides a gain adjustable up to 20 dB [decibel] minimum. For incremental volume control, provide at least one intermediate step of 12 dB of gain minimum. An automatic reset shall be provided.” Amplifiers on public phones are located in the base or the handset or are built into the telephone. Most are operated by pressing a button or key. The photo on the right is representative.
These requirements above apply to all types of public telephones including courtesy phones at airports and rail stations that provide a free direct connection to hotels, transportation services, and tourist attractions.
Wheelchair Accessible Telephones
2010 ADA Standard 217.2, [Telephones] Wheelchair Accessible Telephones, states, “Where public telephones are provided, wheelchair accessible telephones complying with [Standard] 704.2 shall be provided in accordance with Table 217.2.” An exception for this Standard is that drive-up only public telephones shall not be required to comply with Standard 217.2. Table 217.2 is shown below.
2010 ADA Standard 704.2.1, [Telephones, Wheelchair Accessible] Clear Floor or Ground Space, states, “A clear floor or ground space complying with [Standard] 305 shall be provided. The clear floor or ground space shall not be obstructed by bases, enclosures, or seats.”
2010 ADA Standard 704.2.1.1, [Telephones, Wheelchair Accessible] Parallel Approach, states, “Where a parallel approach is provided, the distance from the edge of the telephone enclosure to the face of the telephone unit shall be 10 inches (255 mm) maximum.” The graphic below is a plan view representative of the clear space for a parallel approach to a wall mounted telephone.
2010 ADA Standard 704.2.1.2, [Telephones, Wheelchair Accessible] Forward Approach, states, “Where a forward approach is provided, the distance from the front edge of a counter within the telephone enclosure to the face of the telephone unit shall be 20 inches (510 mm) maximum.” The graphic below is a plan view representative of the clear space for a forward approach to a wall mounted telephone.
Because clear floor and ground space is required to be unobstructed, telephones, enclosures and related telephone book storage cannot encroach on the required clear floor or ground space and must comply with the provisions for protruding objects. The graphic below is representative of a wall mounted telephone that is compliant with the Standards for protruding objects.
In the graphic above, if the telephone or telephone enclosure is mounted 27 inches or less above the finished floor (AFF), it is allowed to project out into the circulation path more than 4 inches.
Other requirements for wheelchair accessible public telephones include:
Operable parts shall comply with Standard 309 [704.2.2]
Telephones shall have push-button controls where such service is available [704.2.2]
Telephone directories, where provided, shall be located in accordance with Standard 309 for reach ranges [704.2.3]
The cord from the telephone to the handset shall be 29 inches long minimum [704.2.4]
TTY Machines
Teletypewriter (TTY) phones are special electronic machines that transmit conversations as text over telephone lines. TTY machines incorporate a keyboard, small screen, and a special modem to allow people who are deaf, hard of hearing or speech-impaired to use the telephone to communicate with those who hear and speak without issues, or with other hearing-impaired individuals. The photo above is representative of a TTY machine.
2010 ADA Standard 217.4, [Telephones] TTYs, states, “TTYs complying with [Standard] 704.4 shall be provided in accordance with [Standard] 217.4.”
ADA requirements in Standard 217.4 for TTY machine locations are based on the number of public pay telephones provided at a bank of telephones, within a floor, a building, or on a site.
Signage for TTY devices is covered in Standard 216. 2010 ADA Standard 216.9.2, Directional Signs, states, “Directional signs indicating the location of the nearest public TTY shall be provided at all banks of public pay telephones not containing a public TTY. In addition, where signs provide direction to public pay telephones, they shall also provide direction to public TTYs. Directional signs shall comply with [Standard] 703.5 and shall include the International Symbol of TTY complying with [Standard] 703.7.2.2. The graphic on the left is representative.
Although pay telephones are becoming obsolete inside a building, they do still happen. If your facility has public pay telephones inside or outside the building, it is important that you comply with 2010 ADA Standard 217.4 for TTY installations.
SUMMARY
Public telephone installations in Title II and Title III facilities are required to comply with the Americans with Disabilities Act (ADA). Accessible public telephones shall be provided in accordance with the ADA Standards for each type of public telephone provided. All public telephones shall have volume controls. Wheelchair accessible telephones and TTY devices have specific requirements for locations and features.
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