Buying iPad Kiosks? Ignoring the new ADA requirements could cost you big.

Kiosks and the new ADA Standards

The newly-updated ADA Standards for Accessible Design have had a far-reaching effect on all every part of American life, including kiosks. Compliance with these new standards was required by Federal Law on March 15, 2012.

What is ADA?

ADA stands for the Americans with Disabilities Act of 1990. It’s a civil rights law that gives all Americans equal access to employment, local government facilities, public transportation, public accommodations, telecommunications, plus any other major life activity.

ADA prohibits discrimination based on disability. It’s been compared to the Civil Rights Act of 1964 which prohibits discrimination based on race, religion, sex, national origin and other characteristics.

The law is intended to keep people with disabilities in the mainstream of America life.

What are the Penalties for Non-Compliance?

Failure to comply with the new standards is significant. The first offense can cost you up to $55,000, and subsequent offenses could cost double that amount.

What are ADA Standards for Accessible Design?

To help us build an accessible environment for everybody, the Department of Justice has published the ADA Standards for Accessible Design. This document contains the scope and technical requirements for accessibility and is broken down into four main sections:

Section 1. Introduction
Section 2. Standards for Local Government Facilities: Title II
Section 3. Standards for Public Accommodations and Commercial Facilities: Title III
Section 4. Standards for Titles II and III Facilities: 2004 ADAAG

You’ll want to become very familiar with Section 4. It contains specific technical requirements for Public Accommodations and Commercial Facilities. It consists of several chapters from the 2004 Access Board’s ADA Accessibility Guidelines, plus the many, many brand new revisions.

These standards are a list of “advisories” describing requirements for everything from wheelchair spaces, to saunas, to miniature golf, to drinking fountains, telephones and checkout aisles.

Download the document here.

So What are the Rules for Kiosks?

Kiosks are identified as “Interactive Transaction Machines” (ITMs) and need to follow the general standards for all physical elements. (ATM and Fare Machines are in their own class of kiosks and must comply with Advisory 707.  If your kiosk has functionality that emulates an ATM or transportation ticket machine, you may want to study Advisory 707 in detail.)

First of all, you’ll need to provide proper wheelchair access to your kiosks. A wheelchair-seated user must be able to position the wheelchair in front of each kiosk so that it is clear of “circulation paths” (walkways) and doesn’t overlap another wheelchair space. See Advisory 802.1 Wheelchair Spaces.

Whether your kiosks are wall mounted, freestanding or countertop, you have a number of Advisories that address the user’s reach and height limits. Accessibility is discussed in terms of “Forward Reach” (Advisory 308.2) and “Side Reach” (Advisory 308.3).


High and Low

You’ll need to position the kiosk so that the highest operable control (or touchpoint on a touchscreen) is no higher than 48”, and the lowest access area is no lower than 15”. If you’ve got a low printout chute or coin dispenser, make sure that it is higher than 15”. See Advisory 308.2 Unobstructed (Forward Reach) and Advisory 308.3.1 Unobstructed (Side Reach).

 Figure 308.2.1  Unobstructed Forward Reach

 Figure 308.2.1
Unobstructed Forward Reach

Figure 308.3.1 Unobstructed Side Reach Figure 308.3.1
Unobstructed Side Reach

“Forward reach” is when the wheelchair directly faces the kiosk as seen in Figure 308.2.1.

“Side Reach” is when the wheelchair comes alongside the kiosk, and the user must swivel in his seat to face the kiosk. See Figure 308.3.1.

(Note in Figure 308.3.1 that a 10” obstruction is permitted when the kiosk is accessible from the side.)

Protruding Wall Kiosks

If your wall-mounted kiosk is in a circulation path and it’s higher than 27” from the floor, it’s not allowed to protrude more than 4” from the wall. This protects a blind or visually-impaired person who is using a cane from running into the wall kiosk.

If the wall-mounted kiosk is not in a circulation path, there is no depth restriction.

See Advisory 307.2 Protrusion Limits.

Figure 307.2 Limits of Protruding Objects

Figure 307.2
Limits of Protruding Objects

 

Houston, we have a problem.

If our touchscreen can’t be more than four feet from the floor, we’re going to have to angle it up so that the average American adult (5’ 7.5”) can see and interact with the kiosk without stooping over or getting on their knees.

There’s no way we can keep it vertical down at 48”.

As soon as you angle it up, we lose our 4” maximum. We’re going to be at 8”-16” or more depending on the size of our screen.

The bottom line is that we just can’t put a touchscreen wall kiosk in a walkway unless we put a heavy potted plant or something else below it!

 

 

Obstructions

If there is an obstruction in front of your countertop or desk-style freestanding kiosk, you’ll need to provide clear floor space below, or design the kiosk and surrounding area to permit Side Reach, as described in the following section.

If you need a 48” height, you are limited to an obstruction of 20” in a forward Reach situation. If your obstruction extends out to 25”, the maximum height is reduced to 44”. The obstruction is not allowed to protrude more than 25”

Remember, these protrusions are only permitted in a non-circulation path area.

 

Figure 308.2.2 Obstructed High Forward Reach

Figure 308.2.2
Obstructed High Forward Reach

 

 

Most freestanding and countertop kiosks will use the reach ranges detailed in Advisory 308.3.2 Obstructed High Reach as most modern kiosks tilt the LCD screen back to allow direct viewing by users of various heights.

The 48” maximum height reach will work if there is an obstruction of 10” or less. However if there is a deeper obstruction, up to 24”, the max reach height falls to 46”.

Obstructions greater than 24” are not permitted.

 Figure 308.3.2 Obstructed High Side Reach

Figure 308.3.2
Obstructed High Side Reach


 

So Now What?

So what do we do? Design kiosks any old way and hope we don’t get caught? Or make sure our kiosks comply with the new ADA requirements?

I say our kiosks should alwyas comply. This approach has got a lot going for it:

First of all, we’ve protected or customers (and ourselves) from legal liability.

Second, our kiosks are going to be a little bit smaller than they were before March 2012. This means less material for fabrication, less transportation costs, and less space taken up in the landfill 20 years from now. Wow. We just got a little bit greener.

And last, but not least, this gives us a chance to serve ALL of our customers, not just most of them.

 

 

Copyright 2011-2012 by Kiosk Group, Inc. All rights reserved. This material may not be used without the copyright-holder’s written permission.

About Mike James

Mike James is a pioneering, 31-year veteran of the kiosk industry, a serial entrepreneur, and is founder and president of Kiosk Group, Inc.
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