SEP 29 1992

The Honorable Scott Klug Member, U.S. House of Representatives 16 North Carroll Street Madison, Wisconsin 53703 Dear Congressman Klug: This letter is in response to your inquiry on behalf of Matt Logan, seeking clarification of sign requirements under the Americans with Disabilities Act (ADA). The ADA authorizes the Department of Justice to provide technical assistance to individuals and entities that are subject to the Act. Therefore, this letter provides informal guidance to assist you in responding to your constituent. However, this technical assistance does not constitute a legal interpretation by the Department and it is not binding on the Department. Mr. Logan's questions relate to the requirements of section 4.30.4 of the ADA Accessibility Guidelines for Buildings and Facilities, as applied to pictograms (pictorial symbol signs) that are used to identify permanent rooms and spaces, such as restrooms. Section 4.30.4 requires that "pictograms shall be accompanied by the equivalent verbal description placed directly below the pictogram," and that "the border dimension of the pictogram shall be 6 inches minimum in height." This means that the field used for the pictogram must be 6 inches in height and that the verbal description must be placed below the 6 inch field. Based on our discussions with staff from the Architectural and Transportation Barriers Compliance Board, we understand that the Society for Environmental Graphic Design interprets these requirements in the same way. Section 4.30.4 further requires the raised letters and numerals used in the verbal description below the pictogram to be a minimum of 5/8 inches in height and to be accompanied by Grade II Braille. cc: Records; Chrono; Wodatch; Lusher; McDowney; FOIA; MAF :udd:mercado:congressional.letters:lusher.klug.logan 01-01572​ -2The Department is unable to certify or to endorse products as complying with the requirements of the ADA. However, based on

the photocopy of the sign we received, it does not appear that your constituent's product complies with the requirement that the border dimension of the pictogram be a minimum of 6 inches in height, since the measurement from the top of the sign to the top of the characters is approximately 5 1/4 inches (see attached). I hope that the information we have provided is helpful to you and your constituent. If you or Mr. Logan have questions about this letter, please feel free to contact Ruth Lusher of my staff at (202) 434-9300. Sincerely, John R. Dunne Assistant Attorney General Civil Rights Division Enclosure 01-01573 (Form) RESTROOMS 01-01574​ Sterling Rogers Keane August 29, 1992 Hon. Scott Klug Member of Congress 16 North Carroll St. Room 600 Madison, WI 53703 Dear Scott: I would like to take this opportunity to thank your office for your prompt response to my inquiry of August 26. It's not so much that we're having difficulties with the ADA it's that we're having trouble understanding the application of the code as interpreted by the Society for Environmental Graphic Design that put out a white paper on the subject. I fully believe that our signs are in compliance and will provide great benefit to the visually impaired of our country. I would like to get this confirmed through your office as quickly as possible so that we can continue our market introduction. The signs were developed around an industry standard 5x7 size that met the 6" minimum height requirement as we read it (Sec. 4.30.4 Raised and Brailled Characters and Pictorial Symbol Signs). I believe these signs will allow the Newell

small business owner to comply with the ADA's sign requirements without unnecessary cost. Thanks again for your attention to this matter during the busy "election season" that is underway. Sincerely, Matt Logan Product Manager 01-01575