Compliance with the ADA for ITMs (Information / Transaction Machines: Kiosks, ATMs etc.).

Excerpts from the

Americans with Disabilities Act (ADA) Accessibility Guidelines (ADAAG). Published In The Federal Register, July 26, 1991 "Accessibility Guidelines for Buildings and Facilities".

.and excerpts from the

ADAAG Review Federal Advisory Committee, Final Report September 30, 1996 "Recommendations for a new ADAAG"

Compiled by the Trace Center, December 1997, Last Updated May 2001

For any questions regarding this compilation, please contact

Chris Law (info@trace.wisc.edu), or
Gregg Vanderheiden (gv@trace.wisc.edu).
Tel. [+1] (608) 262 6966

This project has been conducted by the Trace Research and Development Center, and is funded by the US Access and the National Institute on Disability and Rehabilitation Research (NIDRR) Board through grant number H133E30012 of NIDRR of the Department of Education. The opinions contained herein are those of the grantee and do not necessarily reflect those of the Department of Education.

Executive Summary - Compliance with the ADA for ITMs (Information / Transaction Machines: Kiosks, ATMs etc.).

The US Architectural & Transportation Barriers Compliance Board (ATBCB) or "Access Board" oversees the Americans with Disabilities Act and related matters such as compliance issues, clarification etc., This compilation of material was taken from publicly available information at the Access Board Website.

This document, produced by the Trace Research and Development Center, is a compendium of excerpts from the two Access Board documents, and is intended to assist interested parties in complying with the Americans with Disabilities Act (ADA): the ADA Accessibility Guidelines, (ADAAG), 1991 (the law); and the 'Recommendations for a new ADAAG', 1996 (not the law). The extensive ADAAG document, and its companion , have been examined and the relevant sections have been excerpted here as a general guide to complying with these documents for ITMs.

For both documents (the ADAAG, and the Recommendations for a New ADAAG), the full Table of Contents are supplied, and the sections that have relevance for Kiosks, ATMs, ITMs and Fare Machines are marked. The text of those sections are given in full, along with any accompanying figures, and explanatory text from the Appendices.

The ADAAG specifically mentions ATMs, but not Kiosks and ITMs. The question of whether the ADA and ADAAG covers Kiosks and ITMs, as well as ATMs is addressed. The conclusion is that they are covered under the ADA, and that the ADAAG is the best relevant guidance available.

The general legal requirements and issues relating to the ADAAG and ITMs are also given. These include: the route to the ITM; clear floor space in front of the ITM and reach; operating controls; and use by persons with vision impairments

Preamble

This document is a compendium of information from the US Access Board, and supporting information, which is intended to assist interested parties in complying with the Americans with Disabilities Act (ADA).

The rules (laws) which apply to ATMs, Kiosks, and ITMs are embedded within the ADA Accessibility Guidelines, (ADAAG), 1991.

The 'Recommendations for a new ADAAG', 1996 are not the law yet, but may become law through the revision process described in Access Currents Vol. 4#2, Mar/Apr 1998.

Both the ADAAG, and the Recommendations for a new ADAAG have been examined and the relevant sections have been excerpted in this document as a general guide to compliance for ITM manufactures / Suppliers.

Both documents have sections specifically relating to ATMs. These sections have been reproduced in full, along with any sections which are referenced by the ATM sections. Compliance with these sections is the priority for making accessible ATMs, Kiosks and ITMs. In addition, sections concerning space allowances and accessible routes have been included for kiosk / ATM providers who provide installation guidelines. Compliance with these sections might be debatable, or open to interpretation, depending on individual circumstances.

Notes:

The sections are presented in numerical order as they appear in the original documents.
General enforcement of the ADAAG is by the US Department of Justice.

Definitions

Kiosk

The ADAAG and Recommendations for a New ADAAG do not give a definition for the term 'Kiosk'. However, the term is used here to mean any interactive terminal intended for public use which accepts input from a user, displays information, and / or dispenses media (currency, receipts, stamps etc.).

Similar terms: Information Kiosk, Interactive Terminal, Public Information Kiosk.

ATM (Automated Teller Machine)

The ADAAG and Recommendations for a New ADAAG do not give a definition for the term 'ATM'. However, the term is used here to mean any interactive terminal intended for public use whose primary purpose is to conduct financial transactions (cash withdrawals, deposits, transfers, account inquiries etc.) through accepting input from a user and the display of information, and / or the dispensing of media (cash, receipts etc.).

Similar terms: Cash Machine, Automated Banking Machine, Automatic Teller Machine.

Fare Machine

The ADAAG and Recommendations for a New ADAAG do not give a definition for the term 'Fare Machine'. However, the term is used here to mean any interactive terminal designed for public whose primary purpose is to dispense tickets (fares) for transportation or otherwise through accepting input from a user and the display of information, and / or the dispensing of media (tickets, receipts etc.).

ITM (Information / Transaction Machine)

The ADAAG and Recommendations for a New ADAAG do not give a definition for the term 'ITM'. ITM is an 'umbrella' term for the class of devices which includes public use machines such as ATMs, ticket vending machines, computer kiosks, information kiosks, electronic building directories, fare machines, point-of-sale (POS) terminals etc.

Are ITMs covered by the ADA / ADAAG?

The ADAAG uses the term "Automated Teller Machine". The Recommendations for a New ADAAG uses the terms "Automatic Teller Machines and Fare Machines". Therefore a question arises - are kiosks and ITMs covered by the same legislation?

Section 1 of the ADAAG (Purpose) states:

This document sets guidelines for accessibility to places of public accommodation and commercial facilities by individuals with disabilities. These guidelines are to be applied during the design, construction, and alteration of such buildings and facilities to the extent required by regulations issued by Federal agencies, including the Department of Justice, under the Americans with Disabilities Act of 1990.

Therefore, the ADAAG is only a set of guidelines on how to enforce the provisions of the Americans With Disabilities Act (ADA). Two sections of the ADA, Title II "Public Services", and Title III "Public Accommodations and Services Operated by Private Entities", set out in broad terms the provisions of the ADA which relate to ITMs (a public service, or a service operated by a private entity). Under the provisions, of the ADA therefore, kiosks and ITMs are covered in the same way ATMs are. Even though the ADAAG does not specifically say that the ATM guidelines apply to kiosks at this time, it is the best guidance and the best ground to stand on in a legal dispute as to whether the kiosk or ITM is accessible, which it needs to be under the ADA.

Note: for reference, the full text of the ADA is available electronically at http://www.usdoj.gov/crt/ada/pubs/ada.txt.

General legal requirements and issues

In the simples terms, manufacturers and suppliers of ITMs should comply with section 4.34 of the ADAAG "Automated Teller Machines". The following gives an outline and commentary of the main provisions of the ADAAG and the Recommendations for a New ADAAG.

Route to the ITM

Determining if the user can actually get to the ITM along an accessible route is an important consideration in that without it, the ITM will be inaccessible to most people who use wheeled vehicles (wheelchair and scooter users).

It should be noted that the ADA compliant installation of ITMs requires a number of factors to work together:

ITM manufacturers producing guidelines on the installation of their ITMs to meet the ADAAG requirements;
The organization responsible for installation (usually the owner of the ITM) following these guidelines;
The installer him/her self being trained to follow the guidelines;
Checks being made that the installation is compliant (route, floor space, height etc.).

Clear Floor Space in front of the ITM and Reach

The ADAAG makes specifications of reach requirements (i.e. where interface elements can be positioned relative to the ground and the leading edge of the ITM) in terms of forward (front) approach and parallel (sideways) approach. Complying with these guidelines is a straightforward matter of designing components to be within the specified ranges in an installed ITM.

The data upon which the ADAAG was based has been questioned by other researchers (e.g. Center for Accessible Environments (CAE), London (1994) "First proposal for research into installation positions of ATMs to suit all users" - unpublished CAE document; Little People of America, 1996 "Obstructed reach range survey of adult dwarfs" - unpublished document). For example, the document "First proposal for research . etc." makes the following points:

Existing standards only use static anthropometry (and therefore does not include factors such as comfort or fatigue), whereas ATM use is a dynamic task;
Existing standards are two-dimensional, but people reach in three dimensions;
There is inconsistency among standards;
The side reach and front reach approaches are rarely used by wheelchair users; instead an angled approach is used (which is more comfortable, makes it easier to see and reach, and provides greater security for the user).

As a result, the proposed revision to the ADAAG, "Recommendations for a new ADAAG, 1996" has revised the guidelines to a lower height, and the CAE has commissioned research into the reach capabilities of people with disabilities in order to revise its guidelines for accessible ATMs ("Proposal for UK guidelines for improving access to ATMs and similar equipment"). When the results of the research that was commissioned by the CAE are published there could be important ramifications for the ADAAG in terms of clear floor space and reach requirements.

Operating controls

The provisions relating to operating controls state that the following should not be required of the user:

tight grasping,
pinching
twisting of the wrist.
A force required to activate controls greater than 5 lbf (22.2 N).

Use by persons with vision impairments

The ADAAG states under section 4.34 Automated Teller Machines, subsection 4.34.5 Equipment for Persons with Vision Impairments:

Instructions and all information for use shall be made accessible
to and independently usable by persons with vision impairments.

There has been some confusion over the implementation of this statement. Many manufacturers or suppliers have made claim that their machine(s) is (are) "ADA compliant", while ignoring this rule (i.e. they comply on the reach requirements etc., but they do not comply with those requirements for people with vision impairments).

The requirement is for "instructions" and "all information for use" to be accessible, and this would include labels, information on displays, location of keys etc. This "accurately reflects the intent of the provision" (David Yanchulis, US Access Board - communication to Gregg Vanderheiden, December 3, 1997).

The 1996 recommendations are substantially different in format and scope from the 1991 ADAAG. Regarding ATMs and vision impairments, the requirements have been embedded in numerous paragraphs (as opposed to in a single paragraph as with the 1991 document). Specific provisions are made as to the format in which input and output is given, some examples of which are given below. The reader is directed to section 707 Automatic Teller Machines and Fare Machines (and other appropriate sections) for the full set of requirements.

Each control or operating mechanism shall be able to be differentiated by sound or touch.
The opportunity for the same degree of privacy of input [and output] shall be available to all individuals utilizing the equipment.
All keys used to operate a machine shall be tactually discernible.
Function keys shall be marked with tactile characters
Machines shall provide visual and audible instructions for operation.
After initiation, instructions shall be available for the experienced user to expedite the transaction.
Verification of all user inputs shall be provided.
Audible instruction shall be provided through a standard audio mini jack
The screen shall be visible from a point located 40 inches (1015 mm) above the center of the clear floor space in front of the machine
Machines that dispense paper currency shall dispense the currency in descending order with the lowest denomination on top
Where a receipt is available and is requested, the following options shall be provided: a printed receipt, audible presentation of the transaction information provided on the receipt, or both.

Compilation 1: Americans with Disabilities Act (ADA) Accessibility Guidelines (ADAAG). "Accessibility Guidelines for Buildings and Facilities".

Compilation 2: Recommendations For A New ADAAG, 1996