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5-3-94 PORTABLE SANITATION ASSOCIATION INTERNATIONAL 7800 METRO PARKWAY, SUITE 104 BLOOMINGTON, MINNESOTA 55425 1-800-822-3020 (612) 854-8300 FAX: (612) 854-7560 June 16, 1993 Mr. John Wodatch Chief, Public Access Division Civil Rights Division U.S. Department of Justice PO Box 66738 Washington, DC 20035-6738 Dear Sir, The mission of the Portable Sanitation Association International (PSAI) is "To expand and improve portable sanitation services and facilities worldwide and to be recognized as the preeminent authority within our industry." In the spirit of our mission statement, members of our industry have been providing the disabled with accessible portable restroom facilities prior to the enactment of the Americans with Disabilities Act of July 26, 1990. On May 21, 1993 a delegation of members from our industry, including manufacturers of portable restrooms and portable sanitation service company operators, met with representatives of the Access Board in Washington, DC. Based on the outcome of this meeting there are no portable restrooms currently being utilized by the disabled community that are in compliance with Title III of the ADA. This is not to say that, in the opinion of the Portable Sanitation Association International, portable sanitation facilities currently in use by the disabled are not adequate to meet their needs. Portability, clear floor/ground space, transportation and set-up are the reasons existing accessible portable restroom facilities were designed and why they have been used for twenty years without objection. However, based on the ADA requirements and recommendations from the Access Board, the manufacturers are in the process of
reviewing the ADA standards to develop portable sanitation facilities that will meet the requirements of the ADA. The problem in existence now is when the portable sanitation service companies are asked to provide a portable accessible restroom that meets the ADA requirements they are unable to do so, because they do not exist. 01-03080
Page 2 The Portable Sanitation Association International requests that the manufacturers of portable restroom facilities be granted a 24 month research and development period to provide the disabled accessible portable restrooms that meet the requirements of the ADA. In addition we request that the portable restroom service companies receive grandfathering to allow continued use of the accessible portable restrooms currently being used in their rental fleet. This period of time should be long enough to allow these companies to change their existing equipment to the new equipment through normal attrition of their current fleet. As you can understand, this issue is time sensitive and needs to be resolved as quickly as possible. Please do not hesitate to contact me regarding this matter. Sincerely,
William F. Carroll Executive Director WC/sw