In March, 2000, SHHH distributed the following notice urging people to contact the Access Board with their access issues. This article is a wonderful summary of important access issues for people with hearing loss. Our thanks to SHHH and USA-L News for this information.
For Access Board contact information, please visit the Access Board Listing in our Resource Directory.
In 1994, the Access Board started a review of the Americans with Disabilities Act of 1990. SHHH participated in that review process on the Two-Way Communications and Assistive Listening Devices Committees. The committees made recommendations that the Board reviewed, modified and now presents, as required by law, for public comment in the form of a NPRM.
The proposed rules are available on the Access Board web page. SHHH members should send in comments to ensure that the final rules reflect what is needed to maximize access in public places for people with hearing loss, based on personal experience.
Email comments will be considered only if they include the full name and address of the sender in the text and should be emailed to:docket@access-board.gov.
A public hearing was held in Los Angeles January 31, 2000. A second hearing will be held on March 13, 2000 at the Sheraton Crystal City in Arlington, Virginia. SHHH members are encouraged to attend the hearings to provide comments.
Provided here is an outline of the key provisions in the NPRM that are of concern to people who are hard of hearing. Overall, SHHH supports the proposed rules.
Assistive Listening Devices
The ADA does not give specific enough guidelines related to assistive listening devices and as a result people have been disappointed with the quality of ALDs in public places.
· Hearing Aid Compatibility
Rarely are appropriate attachments provided to link the receiver with hearing aids or cochlear implants. The revised guidelines require the provision of neckloops (25% of all receivers) and a standard 1/8-inch mono jack for linkage with an individual’s direct audio input hearing aid or cochlear implant cable.
· Removal of the Fixed Seating Requirement
This requirement in the original ADA was confusing and left out coverage for many facilities with movable chairs. The new rules would expand coverage to all assembly areas where communication is integral to the use of the space, providing an amplification system is in use. SHHH supports removing the fixed seating requirement but believes that all assembly areas should be covered even if no audio amplification system is in place. Otherwise library meeting rooms, senior center classrooms and auditoriums will be excluded because they often do not have an audio system installed. What is your experience with this?
· Overall Performance of ALDs
Up to now there has not been a standard for ALDs to perform to a minimum level of quality. The Access Board commissioned research by the Lexington Center for Hearing Enhancement in New York. They have developed a way to measure output performance of an ALD. SHHH supports the adoption of a standard for ALDs. If you have had experiences not being able to use a system because of the poor quality of sound be sure to relate this in your comments and support inclusion of the standard.
Telephones
· Public Phones
In response to our members, SHHH recommended an increase in the level of volume control from 18 to 20 dB. We are sure that you will support this proposal for increased boost. However, we were disappointed that a 100% requirement for volume control phones was not included. The scoping has remained the same at 25%. Given that volume control helps everyone as public phones are frequently in noisy places we think all phones should have volume control. The proposed rules waive the signage requirement if 100% of phones are fitted with volume control. Tell the Access Board of your experiences trying to locate a volume control phone when you need one.
Visual Alarms
A very important proposed rule is the strengthening of the visual alarm requirement in “transient lodging rooms” (that includes hotels/motels, dormitories, and homeless shelters). It requires at least 50% of all guest rooms have visual alarms permanently installed and connected to the central alarm system. This is a critical change in the regulations and one that will enhance the safety of people with hearing loss. In the past, portable alarms were often used and were only required in 4% of the rooms.
Portable alarms give a false sense of security as they are only triggered when smoke enters the room – by which time it is a little late for safety. So we urge you to strongly support this measure and relate experiences and how you feel when you take off your hearing aids in a hotel room at night and have no way to be alerted should there be a fire.
TTYs
More TTYs are to be provided in public places and more signage indicating the nearest TTY. Your experiences locating a public TTY will support the proposed rule.
Captioning
The Access Board needs to hear your views on what systems you want in place to provide captioning to movies. Open captioning of movies is not required by the ADA but rather periodic showings by theaters are suggested. This has in fact been happening in some cities across the country but only for a few films and at certain times and days. However, Rear Window and other closed captioned technologies offer the possibility for access faster because the technology is here and it being used already and could be considered an auxiliary aid and service under Title III of the ADA. The question of cost for the theater and whether it would constitute an undue burden has not yet been established.
SHHH’s position is that all movies should be accessible to hard of hearing people, at all show times, in all theaters. You need to request that the Access Board establish a requirement in the revised ADA to have access to movies using such methods as open captioning, closed captioning (e.g. Rear Window and other such technologies).
Transportation Facilities
So many of you have told us of your frustration in noisy airports and train stations where it is impossible to hear the information given out over the public address system. The ADA requires that the information given out to the public be made available to people with hearing loss. However, it does not state how this information should be provided. The NPRM is considering requiring a visual electronic method of relaying this information.
Be sure to relate your experiences and describe how you can benefit from the information being provided on a screen via electronic means in a visual format.
