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 Architec-
tural 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​ -2-
The 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 Newell

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
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