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T. 4/15/92 SBO:MF:NM:hb DJ# 192-180-03447 The Honorable Alan J.

Dixon United States Senate 331 Hart Building Washington, D.C. 20510-1301 Dear Senator Dixon:

APR 20 1992

This is in response to your letter requesting an update on the Department of Justice's review of the requirements for permanent signs under the Americans with Disabilities Act (ADA) and the Department of Justice regulations promulgated thereunder. To assist in an understanding of the signage requirements at present, I have enclosed a copy of our recently issued title III technical assistance manual. In the manual the Department has defined "permanent signs" in a restrictive manner. The only signs subject to the raised letter requirement are men's and women's rooms, room numbers, and exit signs (see page 59 of the manual). Engraved letters are permitted on all other types of signs. The Architectural and Transportation Barriers Compliance Board (Board) is currently drafting accessibility guidelines for title II of the ADA, which covers State and local governments. At my request, the Board agreed to include specific questions concerning appropriate standards for signage in the preamble to that proposed rule. This action, which is a direct response to previous Congressional inquiries, will enable the engraving industry to formally present to the Board its views on engraved lettering. I strongly encourage representatives of the engraving industry to submit comments on the proposed title II guidelines so that the Board will have the necessary information to make a wise decision on the issue. The Board will carefully consider all comments received and determine whether the guidelines should permit engraved lettering on permanent signs in State and local cc: Records; CRS; Oneglia; Friedlander; Milton; hkb McDowney: 01-00593 -2facilities. If the comments received indicate that such a determination is appropriate, I will recommend to the Board that

the title III guidelines, covering places of public accommodation and commercial facilities, should likewise be revised to permit engraved letters. I hope this information has been helpful to you. Sincerely, John R. Dunne Assistant Attorney General Civil Rights Division Enclosure 01-00598

December 2, 1991 Senator Alan J. Dixon Hart Senate Office Building Room 331 Washington, D.C. 20510 Re: The Americans with Disabilities Act Regulations. The Federal Register, Vol.56, No.144, July 26, 1991. Part III, Dept of Justice, Office of

Attorney General, 28 CFR Part 36, Appendix A, Nondiscrimination on the basis of disability by public accommodations and in commercial facilities. Signage, section 4.30-1 through 4.30-6. Dear Senator Dixon: The regulations promulgated by the Architectural and Transportation Barriers Compliance Board with respect to above mentioned act requires that certain signs in public buildings be made with 1/32" raised letters. Accordingly, this will preclude the use of engraved signs for these applications when the regulations become effective January 26, 1992. It has been demonstrated that blind people can read an engraved sign as well as raised letters. Engraved signs are in very common use, very economical to produce and are the products of principally many small businesses throughout the country. Aside from having a very negative impact on many small engraving businesses, a raised letter sign will cost substantially more to produce, thus adding a substantial, unnecessary cost to build a large new commercial building. The engraving industry was not consulted with or informed by the Architectural and Transportation Barriers Compliance Board that these regulations were being issued. Being an industry of small businesses, there are no resources to monitor legislation affecting the industry or to lobby on it's behalf. As a member of the engraving industry, I respectfully request your help to get these regulations changed to include engraved signs. This legislation effects blind people but also the mere existence of many small businesses. Let's be fair to both. Thank you. Sincerely, Jeanne Brommer President 01-00599 December 10, 1991 Senator Alan J. Dixon Hart Senate Office Building Room 331 Washington, DC 20510 Re: The Americans with Disabilities Act Regulations. The Federal Register, Vol. 56, No 144 July 26, 1991. Part III, Dept. of Justice, Office of Attorney General, 28 CFR Part 36, Appendix A, Nondiscrimination on the basis of disability by public accommodations and in commercial facilities. Signage, sections 4.30-1 through 4.30-6.

Dear Senator Dixon: The regulations promulgated by the Architectural and Transportation Barriers Compliance Board with respect to above mentioned act requires that certain signs in public buildings be made with 1/32" raised letters. Accordingly, this will preclude the use of engraved signs for the applications when the regulations become effective on January 26, 1992. It has been demonstrated that blind people can read an engraved sign as well as raised letters. Engraved signs are in very common use, very economical to produce and are the products of principally many small business throughout the country. Aside from having a very negative impact on many small engraving business, a raised letter sign will cost substantially more to produce, thus adding a substantial, unnecessary cost to build a large new commercial building. The engraving industry was not consulted with or informed by the Architectural and Transportation barriers compliance Board that these regulations were being issued. being an industry of small businesses, there are no resources to monitor legislation affecting the industry or lobby on it's behalf. Thank you in advance for considering this matter. I would like to hear what your feelings are concerning this issue. Sincerely, Thomas K. Denson President

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