ADA Compliance for Kiosks
Self-Service Kiosk
The word “kiosk” is found one time in the 1991 ADA Standards and nowhere in the 2010 ADA Standards. The single reference in the 1991 ADA Standards is with respect to assistive listening systems. Therefore, kiosks are not regulated directly by the Americans with Disabilities Act (ADA). An example of a self-service kiosk is shown on the right.
As was recently reported by Seyfarth Shaw, the U.S. Access Board (USAB) recently issued an Advanced Notice of Proposed Rulemaking (“ANPRM”) for Fixed Self-Service Transaction Machines (“SSTMs”) (a.k.a. self-service kiosks). The USAB is requesting public comment on proposed accessibility requirements for self-service kiosks. In other words, kiosks are not directly regulated by the ADA but they will be in the future.
In the meantime, a best practice for kiosk compliance is by looking at ADA requirements for similar installations. Self-service kiosks can present significant barriers to individuals who have limited vision or who approach the kiosk using mobility devices.
The U.S. Department of Justice (“DOJ”) made clear in a recent Statement of Interest (“SOI”) that public accommodations have a duty to ensure effective communication for the goods and/or services offered through self-service kiosks. This can be done by providing an accessible kiosk that people with disabilities can use independently, or with employee assistance that provides an equivalent experience.
The accessibility of similar equipment is already covered in non-public accommodation contexts. For example, the design and functionality of self-service kiosks in U.S. post offices, covered under the Architectural Barriers Act (ABA), must comply with accessibility requirements that apply to federal agencies employing such devices under Section 508 of the Rehabilitation Act of 1973 (“Section 508”). Similarly, regulations under the federal Air Carrier Access Act (ACAA) already cover the accessibility of airport kiosks that allow customers to independently print boarding passes, check luggage, receive essential information about their flights, change seat locations, and pay various fees.
Using these requirements as guidelines, and existing ADA requirements for operable parts found in section 309 of the 2010 ADA, reasonable requirements for an accessible kiosk would include an accessible route to the kiosk(s), a 30X48 inch clear space at the kiosk, and operable parts on the kiosk that do not require tight grasping, pinching or twisting of the wrist to operate. Furthermore, depending on the type of approach to the kiosk, parallel or forward, a maximum height above the finished floor to the operable parts should be established. This height is usually 44-48 inches, depending on the approach.
Other considerations that should be taken into account for accessible design of kiosks include:
Speech output requirements, privacy considerations (i.e. headset/audio jack), and user ability to change volume, interrupt and/or repeat audible content;
Numeric keys and other controls that are discernable by touch/tactile sense, and their format and organization;
Display screen requirements, character/font size, and visibility;
Braille instructions on the devices.