Note: The output shown below is from the Communication Access Realtime Translation (CART) 

system used in the Communications Subcommittee Meeting #5 and is generally unedited. The 

CART system was used to provide an accommodation to persons with hearing loss and persons who 

are deaf, and was streamed in real-time and available to the public on the internet during the 

meeting. 

UNITED STATES ACCESS BOARD

Thursday, June 5, 2014

RVAAC Teleconference

Communications Subcommittee Meeting #5

>> Okay. This is Jim Pecht. Is there anybody else out there that needs the CART link that have not 

been able to connect or is everybody connected up now? 

Okay. Hearing silence, I'm assuming that everybody is connected and we will commence the 

meeting. I'll ask Rose to sort of call the roll of who's on the call. 

And we'll go from there. 

>> Okay. When I say your name, would you please say you're here and the organization you're with. 

I want to get a sense of the line volumes at the same time. 

Starting with Billy Altom. 

>> Here. With the Association of Programs for Rural Independent Living and my apologies, but I'll 

only be able to be with us for an hour this afternoon. 

>> Thank you. Melissa Shurland? 

>> I'm here. 

Hello? 

>> Yes. 
And David Nelson? 

>> This is David Nelson. I'm here. I'm jumping up and down. 

>> And that's David Nelson, Amtrak? 

>> And with Amtrak. 

>> And operator, can you boost the volume on David Nelson's line just one click on two. 

Marsha Mazz? 

>> I'm here, Rose. You're kind of low actually. 

>> Okay. I don't plan to speak. 

Blair Slaughter? 

>> I'm here with Amtrak. 

>> Janice Schacter. 

>> Here. Hearing Access Program. 

>> That's good. Frank Maldari? 

>> I'm here with MTA New York. Can you hear me? 

I'm here with MTA New York. 

>> Great and the line volume is good. Lise Hamlin. 

>> I'm here with the hearing loss association of America. 

>> Crystal Lyons? 

>> You'll want to press star 6 again to unmute your line. 

>> Here with Southwest Transit Association. 

>> Andrew Phillips? 

>> Hello. Andrew here and I'm with the National Association of the Deaf. 

>> Is that good if you have for you? 

And in the room I have Jim Pecht, Access Board. Paul Beatty, Access Board. Today's CART reporter 

is Sherry Knox. 

>> This is Jim Pecht with the Access Board. I want to apologize for not having an agenda on the 

web. We had a lot of glitches today and yesterday and a few other odds and ends and also our 
fearless leader, Terry Pacheco is swamped with real life stuff and hopes to join us hopefully around 2 

o'clock and she was planning on giving a presentation. But at this point in time what we're going to 

do is just going to continue with the list of sign types categories, trying to sort out scoping-wise 

whether we should -- and how we should cover them. 

We're getting a little bit behind with some of the work we need to do. The homework assignment, 

we had four responses, and we're going to go over some of them and basically I'm going to try to 

prod you guys along a little bit and sort of keep you out of the weeds and quite frankly dig the spurs 

in. So let's go to the list and the first thing up is the -- we have made determinations for directional 

signs and designation signs for spaces. 

The next on the list is designation signs for elements. These won't be things like Blair's examples he 

gave us was cups but it could include things like -- anyway, specific things like maybe a telephone if a 

telephone is provided or something like that. 

We had two responses from the homework assignment. Those both recommended that these signs 

not have any requirements, so let's go from there. And I'll throw that out and let you discuss that. 

>> Hello. This is Blair from Amtrak. 

I'm fine with it not having any particular requirements, but, you know, as I said before, if we reach a 

point where we think, you know, for our specific operations and things we may choose to do, you 

know, take the time for it to be more accessible for it not being a requirement. 

>> This is Jim. Let me just sort of make a statement here that if nothing is required that doesn't 

prohibit someone from doing something. They can go beyond -- I mean, the standard -- the 

guidelines are minimums. There's nothing that prevents you from going beyond that if you want to 

do, you know, braille and raised and have a specific location for these things, fine. 

But the question is for this committee what are you going to recommend to the full committee as to 

what these signs should be complying with. 
So I'm going to assume that that's three now voting for not required. 

Can I assume from the silence that you're all in agreement, that these should not be required to have 

any accessibility requirement, these types of signs? 

I can't hear heads nodding so please say something. 

>> This is Frank Maldari, MTA, I agree that it should be one of the comments that we have. 

>> Jim, this is Marsha. Is somebody monitoring the e-mail in case somebody on CART wants to 

weigh in? 

>> Paul is shaking his head. 

>> Yes or no? 

>> He's shaking his head yes. 

>> Thank you. 

>> This is Janet Schacter. For hearing loss, this is not necessary, but Terry Pacheco I'm concerned 

may need something for the blind and visually impaired community. Marsha, I don't know if you 

had any input on that, but I just don't want her not being there to leave something off the table 

because she's one of the more -- you know, I'm not sure how many people on the call are people with 

visual impairments. 

>> This is Marsha. I'm going to not weigh in on this. This really is for the advisory committee to 

recommend. I'll get my shot later. 

So I'll just have to bite my tongue and --

>> How about if you invite based on personal use because I'm concerned with Terry not here I don't 
want to not have something that she think is needed just because she's absent and I don't know 

enough on visual impairments to weigh in. 

>> Well, from a perspective of a person with low vision, I honestly don't think that I need a lot of 

signage in a rail car and not having some of the signs accessible really is okay with me as long as 

things like, you know, the sleeper car numbers and the, you know, the information that is not easy to 

glean just from the way people circulate and the way things are laid out is available. I'm fine with 

that. 

I'm not totally blind, and so I don't know what the perspective of a totally blind person would be. 

But just like with the ADA standards, we don't require -- currently require anything other than signs at 

rooms and spaces to be accessible in terms of raised letters and braille because directional signs, 

informational signs, things like that can appear just about anywhere and a person who is totally blind 

in particular is not going to have a real good shot at finding that sign without some kind of 

information that, you know, has them locate the sign and nobody is going to travel through a rail car 

or a building touching every wall and touching every surface looking for a sign. 

>> Makes sense. 

I guess we should just put a footnote that Sherry has input to that. I mean, I know at one point we 

discussed -- I'm not saying there should be. I just want to make sure Terry's voice is not left out. 

I know there was some discussion about whether or not there should always be a certain location, 

maybe like a menu place where you can find all the signs or something so that you are not searching 

and you always know when you go in the car it's always in that location. 

>> Janet, this is Jim. I also want to remind you and the committee that this is not going to be 

chiseled in stone. This is basically going to go to the full committee where if you like going to get 

another bite at the apple at that point when the discussions in the full committee are held. So it's 

not -- we're not putting anything to bed or setting anything in stone at this point. This is just sort of 
an idea where to go as far as the standards and the guidelines are concerned at this point in time. 

>> Perfect. I was just putting a place holder for Terry because I hope she would do the same for the 

hearing community if for some reason Andrew leaves and I was unable to be on the call. So I have 

no knowledge on this topic. 

>> Anyone else want to discuss? 

Okay. So if I don't hear any major objections, I'm going to put a big X under not required for 

designation signs for elements. 

Moving on, the next category is nonemergency informational signs. 

We had one vote to require these to meet the visual requirements and one of them to not to be 

required to meet any requirement. 

Discuss, please.

>> This is Frank Maldari, MTA. I'll start the discussion because on ours we put in not to have it and 

the reason for suggesting not to have it is primarily because these are among many signs that can be 

placed anywhere in the car and trying to find them when you can't see is not an easy thing to do and 

this is one of those things if you don't have a designated thing for it and considering cars have 

different vestibules, different seating arrangements and there's so many different aspects to try to 

identify a single location where you should be able to find this is not an easy thing to do. 

Therefore, requirement for having a sign meet the requirements is not a good thing to have. 

Additionally, the visual requirements add significantly to the size of the decals that we currently use. 

A lot of these informational signs that we put out with no smoking or other signs like that, they're 

limited in where they can be placed. You know, the rail car is made to transport people from one 

place to another. We got luggage and we got windows. And outside of the luggage and the 
windows we try to leave a little space for the color scheme to take effect. Even though we try to 

cover up as much as we can, there's some area of the car that's not covered and that's usually 

delegated to advertising. 

But the biggest point is unless you know where it is, having something there doesn't really help you 

out that much. 

>> Frank, this is Jim. Let me just remind you that if you're going to require only to meet the visual 

requirement, there is no designated requirement that comes along with that requirement. Only 

height range --

>> That's a good point. 

>> This is not a specific requirement. You can put no smoking signs on the window, on the door, on 

the side, anyway, as long as you got one sign in the -- you know, or in the sort of height range, the 

visual signs don't have a specific requirement that the tactile would. 

>> Right. But you still have a height range you have to place it within? 

>> Correct. 

>> And it's still 5/8 lettering even though it's not raised. Jim, what is the height tolerance on 

placement, do you know what that is off the top of your head? 

>> I can get that for you. Hang on a second. 

Visual character shall be 40 inches minimum, that's what the requirement is for buildings. So it's at 

least 40 inches off the ground. 

>> It can be as high as you want. I thought there was an upward bound. 

>> No, the higher up you go, the farther away it is and the larger the text would have to be. 
As far as visual signs it's the distance away from the sign that you are that sort of designates how 

large -- or how bigger -- how much bigger the sign has to be. 

>> Right. 5/8 is just a minimum assuming you can get up pretty close to it but then the further away 

you go, the larger the sign, lettering. 

>> If you can put it in a corridor that I can walk by and stick my nose up to it, then it can be the 

smallest of the minimum required. If you want to put it in a ceiling above a bunch of seats that 

maybe I'm going to be four feet away, then it's a bigger requirement --

>> Well, Jim, the maximum requirement goes up to 3 inches plus 1/8 inch per foot of viewing distance 

greater than 21 feet. 

>> Right. And I don't think we're going to have 21 feet in a rail car. 

>> Well, the length of the rail car is probably 21 feet. 

>> You'll get longer than that. Well, depending on the type of car, most of our equipment is about 

80 feet. 

>> But you're only going to put one sign that's going to be visible from the other end of the car. 

>> Well, you can walk up to it too. 

>> You still have 40 feet. So calculate three inches plus 1/8 inch for -- per foot of viewing distance 

greater than 21 feet so 19 times 1/8 plus 3 inches. 

>> But if you can walk up to the sign, does it have to meet that requirement? 

>> No. 

>> Okay. So usually you can walk the length of the car so you can cut down that distance. 

>> Which is what I was saying and mostly in most cars you're going to have multiple signs where you 

can walk up to and it's going to be smaller. You're not going to have one sign that you're going 

expect people to read from the other end of the car. That's probably not going to happen. 

>> Practically speaking you're not going to find people with low vision walking the full length of the 

car to find out what that glow is at the end of the car. 
>> David, I have got a question... So if a person is traveling with a wheeled mobility device and the 

sign is at their -- so like for me I can see a sign, but what about a person who's traveling in a wheeled 

mobility device and they have got low vision as well? 

You know, maybe they're sitting -- you know, they're sitting in a chair and I'm between them and the 

sign, is there a rule about that where they wouldn't be able to see, like a minimum guide for that? 

>> Generally we don't talk about obstructions with people when we're talking about signs. 

Where are you going to place it, what's the distance from it --

>> Well, that isn't exactly accurate. The sign does look to see how close a person with a vision 

impairment can -- I mean, the standard does look to see how close a person with a vision impairment 

can get to the sign and so if you were, for example, to put a sign behind a counter that you can't climb 

over or walk around, then you have to calculate from the standing position in front of the counter. 

But I think that David's point is more to the question of people with two disabilities. Currently the 

signage criteria in the standards are written for people with one disability, with a vision impairment. 

And it assumes, for example, for the reach for the tactile signs it allows you to go up as high as 60 

inches which is higher than you can do for reach range for a person in a wheelchair. So the short 

answer to your question, David is the standards for signage don't take into consideration multiple 

disabilities. They're written strictly for ease of use by persons with a primary disability of a low 

vision or blindness. 

>> Okay. Got it. No, I appreciate that. Thank you for the clarification. 

And your insight on that. 

So I can kind of think about that, that the guideline is written for basically the primary disability. 

>> Hello? 
>> We're here. 

>> That's right. 

>> This is Blair Slaughter from Amtrak. 

I just want to throw something out. One of the things that drove us working with the FRA to go into 

seat back cars like you find on aircrafts and this is more emergency and some general information. 

But we had traditionally had big signs on the bulkheads, they were very big signs that had all kinds of

information on them and what we came to realize is that was only useful to the folks in the first few 

seats, that the people in the middle of the car weren't getting information that you could argue was 

critical even or just general information that we were able to take care of with the cars. 

Unfortunately, that doesn't fall to this committee's work because as Chris Hart said, when you shake 

the cars, the cars would fall out. So always the viewing distance and the placement of signs is 

critical universally. So information that's relevant to one end of the car doesn't need to be seen 

from the extreme other end of the car and so I think, you know, we have to keep that kind of 

practicality in mind as we're going through this as well. 

>> So, Blair, what are you voting for having said that? 

>> Having said that, I'm just thinking about all the signs that we have on the cars now and to Frank's 

point, I get concerned that we'll be back to having really big signs that are of minimal benefit to 

folks...ah, let me think about that just a little bit more. I want it to be a logical statement when I 

make it. 

Haha. 

>> Anyone else? 

Please. 
>> Hey, guys, it's Chris. 

I've been somewhat working -- I just want to again offer if people want I can put together a 

presentation for MTA vehicle signage efforts and what we do as far as carrier and tactile rail and I 

think it may...some of the fears, but again I'm only going to --

>> This is Frank Maldari from the MTA again. I think I would be interested in seeing that. I just 

want to clarify what the concern of regulating the signs with lettering is. 

In the past sometimes regulations have unintended consequences, and once you require something 

to be done, installed or procedure to be followed, it's done with good intentions in mind in 

addressing an issue and further down the line somewhere you find out, gee. This is not the best 

thing for me to be doing. 

I hate to bring up an example, but it's one example that's bothered me over the year is the hand 

holds for using this as a side step that's supposed to be used at the end of the cars and years ago you 

wanted to to have that equipment there when you were pumping cars through yards. We had cars 

that were connected by a draw bar. We don't want people walking -- standing on the outside of the 

cars for those kind of drill moves. We feel it's unsafe. We still have to have the hand holds there 

because the law requires it. 

>> Frank, what is that term, some kind of hand hold? 

>> It's a safety appliance. It's a side -- it's an end of car hand hold. 

And I'm just saying it did not -- the law was written not recognizing that you can have permanently 

attached cars together which wouldn't need that type of device. The point I'm getting to is what I 

basically said before is when you look through the car and I put together a small like three pages that 

I wanted to -- that I sent out that we really never got a chance to discuss. And if you look at the 

decals that I sent on those pictures, you'll see that some of them are examples of decals that you 

really can't do and there are some other decals which we already make pretty big. 
So for the most part, you know, when we're making the signs, the amount of space that you have to 

put the sign is an important part of how big the sign eventually winds up being. 

On an end door, which has limited space, the handle. Whereas where you want to direct the people 

not to go through the train when the train is in motion. 

There's not a lot of space, there's not a lot of good real estate there because you have a window in 

the door, you have the door handle. There's not a lot of good real estate to put a sign with big 

lettering explaining that you don't want people moving between the cars when the train is in motion. 

So the lettering on that sign is, you know, it's on the order of a quarter inch, maybe 5/16ths. It's 

relatively small because the space that's available for that sign is small. And, you know, if you start 

requiring that every sign non -- you know, non -- we're talking about informational sign. Every 

informational sign cannot have lettering less than 5/8 of an inch. A lot of these decals are going to 

be unreasonably large. So, you know, having the decal gives you some information. Having the 

lettering small makes it harder to read, but ear still getting some information. Having the letters be 

5/8 of an inch is going to cause in some instances not having a decal anymore. 

Or an awkward looking decal which really is not providing the information in a manner which is 

appropriate. 

And, you know, unless it's something that a blind person needs to see, needs to see, needs to know 

about, a bathroom, a designation of a seat if you're trying to find a seat. We talked about 

emergency exit before. If the exit is identified -- I mean, those are the core items that if you're 

seeing impaired that you want to make sure you see. 

Outside of that, you know, typically the authorities are going to try to make the sign and the lettering 

as large as reasonably possible where it's possible. 

And, you know, knowing about the 5/8 of an inch now, I'm going to try to stick to that wherever 

possible. But if the law requires that I have to stick to it, it compromises my ability to put a sign 

where it's most appropriate and useful. 

So the idea is just because the law says -- doesn't force you to do it doesn't mean you're not going to 

do it when it makes sense. 
>> Frank, this is Jim. Can I ask a question. Is the size the only thing in the visual requirements that 

you're objecting to? 

I mean, do you have problems with, you know, finish, contrast, stroke height, et cetera? 

>> I mean, we use -- typically we use Helvetica which is a type of sensor. That's not an issue. 

Contrast is a good thing in either case. The height of 40 inches, I can only think of a few decals that 

that would be a problem with. 

I think some of the other ones in there are just good guideline to follow generally like you mentioned. 

>> So the question I would ask is, would you be more amenable to moving your vote from not 

required into the visual range if you could require most of the visual requirements but when it gets to 

height put in languages as for these types of signs you make the height where practicable? 

>> Yes. Yeah, I think that would be a good compromise if that was something we could do. 

>> What do other people think about that? 

>> Jim, this is Blair from Amtrak. I think that's a very reasonable approach. 

>> Anybody else want to weigh in, please? 

I can gravel? 

>> Jim, one thing I was thinking is I don't know how many people are not on the call. It would be 

good to invite and circulate... >> I'm sorry, Chris. What are you asking? 

>> I'm just saying whatever direction we want to go in, we might want to write it up and circulate it 

before it's a done deal. 

>> Actually, Chris, the entire committee report has to be balloted by the subcommittee. So these 
are just informal votes. These are not formal votes. This is just to enable Jim to move on. 

>> Okay. Got you. 

Terry, I totally forgot... 

>> Chris, would you like me to -- so Chris knows who's on the call. 

Chris, this is Rose Marie. 

(Reading names) 

>> Those are all the people on the call today. 

>> Okay. So --

>> Well, sometimes you're not. 

>> And sometimes the CART links just does not want to work. 

I'm glad... 

>> Okay. So I'm going to place a big X in the visual requirement with ans a tryst for -- asterisk and it 

will read size required where practicable unless I hear an outcry of indignations and objections. 

>> This is Chris. 

I will commit to putting together MTA...newest cars and what we have in our vehicles stats that 

we're... 

>> Sounds good. I'm sure Terry would love that. 

>> And I will share that with all of you. 

>>> You might want to send it in to us and let us distribute it. 

>> Yes. Obviously. 
>> Okay. Moving on to the next category, which is nonemergency operational signs. 

Again, we had one vote for visual and one vote for not required. 

Is this something we want to do the same thing to or what? 

What you guys think? 

>> This is Blair from Amtrak. 

I would say one exception. I would agree with that, Jim, to take that same course with the others 

with a possible exception of where there may be a latch or a lock and I'm thinking like a restroom 

door where someone's privacy might be compromised if they can't -- if they don't get the information 

to know how to lock the door perhaps. 

And I'll throw that out for discussion, but that would be, you know, one feature that I would be 

concerned about. 

>> And you would want those features to comply with what? 

>> Well, certainly with the visual and I would consider for our operation, I would consider visual and 

tactile for something as simple as a lock/unlock instruction by a restroom door. 

>> And this is David Nelson here. 

I completely agree with you, Blair. However, my problem -- I'm just thinking the type of locks that 

we have on some of the Amtrak bathroom doors, those locks are a little bit complicated and I'm just 

trying to imagine -- I can't even imagine how we would do the tactile instruction explaining how to 

work the lock. 
I think it would be -- I think it would be good if we had a sign for it but also we need to have them --

or refer them to another -- we need to refer this to another committee to come up with a better lock 

or something. 

>> This is Blair. And I'm thinking about the simpler locks where there is a slide -- where the latching is 

automatic. That doesn't require any instructions. But to slide another component for a lock one 

way or the other is just a simple function. But it may not be apparent or readily apparent to 

someone who's there. 

Or primarily to know, you know, are you pushing it the right way to unlock it. Maybe you think it's 

locked and really you just unlocked it, those kinds of things. I agree --

>> Yes, that happened to me too. That was my problem. 

I thought I pushed it all the way but it didn't lock. 

>> Sometimes that's a mechanical problem that has really nothing to do with the way the lock is 

supposed to function. It's just something maybe out of whack. 

>> This is Frank. 

There's times when everyone can't use the lock. 

( LAUGHTER ) 

>> But I think, you know, I think that's a good point, the point that Blair made. I would think that's a 

good idea. The nice thing about the restroom sign is location is identified. Typically it's right next 

to the handle. I mean, it's an obvious place that you would be looking for the information. What is 

a little bit difficult is saying move the red handle to the right. I mean, so you might have to have 

different wording on there if you really can't see. 

But, you know, I think it's a good idea to require that you do that. The question is how do you 

require to do that and not require all operational signs to have that feature? 

Maybe you just put it in the wording there. The restroom sign must have opening and locking 

instructions as a separate requirement. 
>> Thanks. That is Marsha. I don't know where I've seen this, but what I have seen are large 

graphics, the decals I guess they are that essentially show an arrow for the lock in unlock position and 

there are no words at all, which seem to me to be the best way to communicate something like that. 

Not only to people with low vision, but also to people with limited English proficiency and cognitive 

disabilities. 

>> Yeah, that's a good point. We have used decals like that. I guess the problem is when you can't 

see it, it's not all that obvious. 

>> No, if you can't see at all, a decal isn't going to do any good. 

>> I'm just thinking what do you put in the raised lettering and braille for the person who can't see. 

I don't know. Maybe you have an answer for that. It would have to be different than it would be 

for the seeing person. For the seeing person it's a sign with a graphic that's obvious. How do you 

make it obvious for the person who can't see? 

>> Frank, this is Jim. I don't think we need to worry about the content of the message. That's up 

to you guys who are building the train to pick up the best language to describe it verbally or visually 

or whatever. 

The question for this committee is do you want to have a specific sort of set aside specifically 

requiring where instructions at doors for the operation of latches and locks are provided, they shall 

meet the tactile and visual requirements and shall be placed in this location, be it to the side of the 

latch, above the latch or wherever so you can have a consistent location. That's how I would write 

that requirement if you were going to go that way. 

And not fully talk about how you actually get that across. 

Now, you want to say that if you provide a Pictogram, the Pictogram has to be accompanied by a 

tactile picture with raised braille like we do for a toilet room door. Again, I don't know if I would 

necessarily require the Pictogram where you put in there when it's required do this as well. If I were 
doing it, that's how I would do it. It's up to you guys. If you want to do a specific one just for doors 

instructions or all of them, that's up to you. 

>> I think a specific one for doors is good because you want to give information on how to operate 

the door. 

Whether you use a Pictogram or not, I think that should be optional. Like Blair said, you don't want 

somebody not to know how to lock the door in a bathroom. 

>> Frank, this is Marsha. I'll throw this out there and see what you think. Under the current 

standards, if you have a Pictogram, you need a verbal description. So if you had a Pictogram 

showing an arrow with a lock, you would need to then put a verbal descriptor in that says something 

like slide lock to the left -- or slide bar to the left to lock and slide it to the right to unlock. 

I guess what I'm suggesting for things like that and those types of things by the way are not covered 

in the current ADA standards. It's only where a Pictogram is used to designate a permanent space. 

So if you use a symbol on a restroom, you have to put in the word women. But if you have a lock on 

a toilet stall in a building, restroom with a Pictogram on it that says slide to the left or slide to the 

right there's no requirement. 

But if you wanted to impose a requirement, I think it would be possible for you to do something like a 

chart showing a variety of raised graphics that you might be able to use like we do for elevators right 

now. 

For some things, elevators, ATMs is another one. We use a raised X to mean cancel, that kind of 

thing. 

It seems to me that you might be able to think of a few standard graphics that you could standardized 

that would be raised that wouldn't require text. Because frankly I can't imagine someone standing 

at the bathroom door trying to see a long message in raised letters when they need to go. 

( LAUGHTER ) 

>> This is Blair from Amtrak. You make a very good point there. 
When you talk about doing something that has examples, I think, and correct me if I'm wrong, the 

Access Board isn't going to be doing that kind of information anymore. Is that -- am I correct with 

that, Jim? 

But I was just going to say that this can be one of those things that segways over to APTA and the 

APTA committees like they have done with a lot of the FRA rules where they have gone through and 

taken the complexity of some of the FRA language and put it into pictorial understandable 

information that that would be a really smart thing for the industry group to do to ease their -- the 

struggles and have recommended conditions and the nice thing about that is you get -- you can get 

more of the permeation of common information or common descriptions and icons and things 

through the industry by default without rule. 

>> I don't know exactly what you mean about we're not going to be doing examples. What we don't 

do anymore is include advisory text in the federal register. 

>> Okay. 

>> But if you were to develop standards -- in other words, if you were to say for a sliding locking 

device you show a raised arrow pointing, you know, left to open or right to close or whatever, you 

could certainly do that right now because that would be -- and then everybody would have to do a 

raised arrow pointing right, pointing left or pointing in the direction of close, pointing in the direction 

of open with the word "close" written beneath it and the word "open" written beneath it or you can 

say raised letters or braille or you could say both. Those are options that you can do right now. If 

you wanted to -- although I'm intrigued by your suggestion that APTA might take on that project and 

if they would and could before the rulemaking is over, that might generate for us a reference able

standard. 

>> Well, I obviously can't speak for APTA. There's no one on the call from APTA, but it would 

certainly seem a logical thing for the industry group to take up and they have done some of that in 

the past, sort of ahead of the curve with some activities, and once that's -- depending on what it is 
sometimes, you know, the FRA, if it's accepted within an industry group, it sort of becomes the rule. 

But you can get a lot more exposure to the authorities and to people that are in the graphics industry 

as well to help understand how some of those things can be done. 

I would say I think the concept of requiring the arrows and the information is probably good. I don't 

know if we're in a position today to go through that level of detail but maybe it's something we can 

come back to or mull over but agree that on the principle of this whole thing of requiring the visual 

attachment and tactile information for these kinds of situations and not for others. 

>> This is Frank. I agree with what Blair is saying. I think it's a good one to require it and not get 

into the details about what they are. I also think the standard is good for filling in the detail 

sometimes and as long as the rule is broad enough, you have an opportunity to fine tune it with an 

APTA standard and it is very useful, I've been on some of the committees and you do get a lot more 

input from the industry. It would be nice to have Marsha there to explain some more things that 

they have used in the past, which is possible too but for as far as we're going I think what you're 

saying is what needs to be said. You know, you have to provide information on operation of the 

handle and the lock and it has to be accessible and that's as far as we need to go right now I think. 

>> This is David Nelson here. I had a question. Somebody had mentioned -- when we were talking 

about the Pictograph, that they were required to have -- are they required to have audio? 

How would that work? 

>> This is Jim. There's currently no audible requirement for signage in any of the standards that I 

know of. 

That we do on accessibility issues. 

>> We're going to presume that a Deaf person can read the sign. 

>> Exactly. 

>> Yes, correct. I understand that. But I'm just thinking better educated for myself for others who 

might need it. So I'm trying to figure out if we are doing that, if it's going to be required to push a 

button that would be next to the Pictograph or what, but if you're saying it's not a required standard, 

would that be in the plan? 
>> What would be the purpose of that, David? 

>> Somebody mentioned earlier that when using a Pictograph you needed to have an audio 

description on how to use or by explaining of what the graphic said. That's what I thought. 

>> I wasn't following the CART, but there might be a translation -- what I said is that you need a text 

description of a Pictogram because a blind person can't read a picture, so the blind person would 

need -- for example, underneath the women's room sign where they use the international woman, 

they need to have the word "women" so that -- in raised letters in braille so that a blind person knows 

that this is the women's room because you can't raise a complex picture like the cut-out of a woman 

and expect a blind person to be able to read that tactilely. They need the word in place. 

>> Okay. Okay. Yeah, I just wanted -- I thought somebody had mentioned using the Pictograph on 

the latch like how to lock it. I thought somebody mentioned that, something about audio. Maybe 

I misunderstood. 

>> No audio at all. 

>> David, this is Jim. I probably said verbal which you may have misconstrued as an audible 

component and I meant a visual sign, words component. 

>> Okay. Yeah. I'm parting you this time, Jim. 

>> Okay. Let's get back to the door issue. Blair, I'm assuming you wouldn't want to require 

instruction at every single door latch. You just want to require where it's deemed necessary 

because of the complexity of the operation to put instructions, correct? 

>> Yes, Jim, most door latches are probably pretty intuitive when you come to the -- I mean, we have 

been guilty at the railroad of having some rather convoluted latches that are more like a puzzle than a 

latch. But the hope would be that if we're using latching systems that are not unusual for people to 

find in the rest of the world, that it's obvious when you find the handle, you know, it rotates or it 

slides or something. But where there is a privacy issue, that's where I would draw that line and say, 

okay, because you want to make extra sure that people understand how to -- they close the door and 

they should have the information to make sure they can lock the lock. And -- because there's not a 
lot of places on the train where you would lock a lock like that. Your bedroom maybe or a restroom 

and that's really going to be about it for a nonemergency situation. 

So all the other places I would say typically not. 

I think that most like end doors where you press a panel, yeah, some of those I know are just -- some 

of them are tactile now. Some are not. So that may be the -- you know, the other possible 

condition, but again those things often for people moving through trains who have been on the train 

at all realize that that's -- you know, you press that panel and you find it. 

However, I have seen people with no visual problems at all stand and push everything on the door 

except the panel that said push. 

( LAUGHTER ) 

>> Well, how many of us have pushed when we're supposed to pull a regular swinging door? 

( LAUGHTER ) 

>> Yes. 

>> You figure it out pretty quickly though. 

>> And then you look to see if anyone saw you do it. 

>> Exactly. 

( LAUGHTER ) 

>> This is Frank again. I think it's a good idea for the restroom and bedroom that directions if 

provided need to be in accessible which would mean tactile and visual. I don't know if you need to 

go much further than that. The door is troubling to me a little bit because even people who can see 

can't figure out how to use it sometimes. That doesn't mean that there shouldn't be something 

there to tell the person who is visually impaired that there is a button to push. So I would think if 

you're putting directions for operations of the door and if they're in writing that they should be 

accessible too. 
>> Irregardless of whether it's a complexity issue or a privacy issue, where the person is putting the 

sign up or deciding what signs to put up has chosen to put a sign for whatever reason about 

instructions, about how to operate that door, you're basically recommending that it meet the tactile 

and visual requirements? 

>> Yeah. What I'm saying is if you feel it's not obvious -- I mean, most of the doors like Blair is 

talking about is just basically to types of end doors and those are the only doors you have operating 

ability outside of the bedroom and restroom. Typically doors are a latch and there's no directions 

on there that tells you how to use it. The push button ones are maybe not so obvious to everybody 

and they do say push to open sometimes right on them and usually it's recessed lettering. I don't 

know how that works out but it's usually recessed lettering but I would think that if it's important 

enough for somebody to put the instructions in text that you would make it accessible. Most of the 

time I don't think you need to. But to me if you're going to put the instructions in text, why not 

make it accessible? 

>> You know, that makes sense, Frank. Because I'm thinking through it and, yeah, a lot of those 

signs -- this is Blair by the way -- a lot of those signs on the doors that are on the panels, the push 

panels are recessed and that probably does not have the effect that you want. But sometimes that 

door, it's not obvious and as you said -- and as I've seen, even though it said "push" on the thing that 

you push to open, I've seen people push everything else on that door including the door itself to try 

to make it work. 
( LAUGHTER ) 

>> And then I've just sort of walked up and pushed the button and then it opened up and then they 

turn red, so I just couldn't watch it any longer. 

But -- no, I think that's logical, that obviously people -- if you walk up -- if we use a situation...if you 

walk up and it's a manual hinged door and you reach where there should be a latch handle and you 

find a latch handle, okay that's the latch. You probably don't need anymore information than that. 

It's going to turn or push. But for a sliding door that is a push to open and it's a powered door, it 

probably makes a lot of sense to have -- and you have to put the written information, it makes sense 

to have it tactile as well. 

>> Yeah, this is Marsha. 

Can I ask a question about push to open or whatever types of devices that might be on the outside of 

a car. 

I know that this is common in buses, but I have never seen anything like that in a train. Are there 

trains where you would have to somehow open the door yourself? 

>> This is David here. The light rail is quite common in the light rail because not all light rail doors 

are opened unless you push the button in order to open it either from the exterior or the interior 

when the light rail is stopped at a station. 

>> Come to think of it, it was probably light rail where I got left on the platform in Boston. Because I 

didn't know -- I didn't know to push the button. This happened years ago. I don't remember 

where I was, so --

>> Oh, good. Let me be clear...in Boston several years ago we had a blue line that included push 

button open door. Keep in mind this is rail and the thinking was, you know, we're going up or on 

the ocean and we don't want to open every door every time. 

Keep in mind it has two doors per cart. So could not figure why it was such an issue, but it's still on 

the car but it was...because there was no way anyone who was visually impaired could 

identify...without getting very close to the edge of the platform and obviously not every door button 
but a beeping ATS. So while it is -- push to open buttons particularly light rail we were very clear 

and the ASP committee were pretty vocal, no way were we ever having us go without every day life 

with cars and for whatever reason I would submit that I would expect if we're going to hear that as 

time goes on that this committee is going to want us to be very clear that that is not allowed for that 

reason how you find the button on this side of the train and keep in mind that nothing is not 

quite...as you go through a tunnel in D.C. or Boston or New York, on the sides of the cars even if you 

washed them once a week. Not that they get washed once a week, you don't want to touch the 

sides of the cars. 

>> Well, there is a whole lot of stuff I don't want to touch. But I guess it's fair to say that having to 

push to open the door on a rail car does -- it is a communications issue if people with vision 

impairments or people with limited cognitive ability can't recognize what action needs to be taken 

and perform it. 

>> I think that's a good reason not to have those buttons on the outside of the train. I agree with 

what he was just saying because the last thing you want is people touching around the outside of a 

train that's going to be moving any minute. 

We had them, the push to release buttons on doors, on the exterior on our M-1 cars back in the late 

'60s and they were removed very quickly for the most part because people didn't know what they 

were there for. It's also not a good thing in general from a safety perspective to have anybody 

touching a vehicle that's going to be moving shortly. You don't want anybody doing that. There's 

a gap there that you're bringing closer to that you don't want to. So, you know, I think -- you know, 

there are places that use those type of features like a release button that if it stops, it's like a bus if 

you want to get on, you get on. But typically -- I mean, in northeast here in our environment we 

don't have anything like that. And it's a good thing that we don't and there's more than one reason 

not to have it that you point out. But, you know, if you make the rule written as we were talking 

about it, there's operational instructions provided on the door it has to be accessible, then I think that 

covers it. 
>> I would agree. It may discourage people from doing what you're saying isn't a good practice 

anyway. 

>> This is Blair. 

I think the Baltimore light rail uses buses on the --

>> They absolutely do. 

>> This is Jim. Can I make a sort of proposal that this issue be sort of shunted over to the circulation 

folks and maybe with the proviso that new cars, doors not be operated by people on the outside, that 

it be automatic. 

>> Jim, I think this is a communications issue and belongs in this committee. 

>> If a sign is provided, yes --

>> I'm not talking about signs. It is a communications issue, plain and simple. 

>> Not if the door is automatic or operated only Britain personnel. 

>> Right. But if someone has to find and push a button --

>> I understand that and I'm saying that maybe the committee on circulation wants to take this up to 

prohibit being used by the public -- >> The point is that it's within this committee's purview, Jim. 

They don't have to shunt it to another committee. 

>> This is Blair. 

Let me make a suggestion and -- because I think if we're not careful we'll wander off down a path that 

may prohibit, you know, some authorities and things -- from doing things that might be very 

appropriate in their communities and I would say that, okay, if -- because I can see where there's 

benefits in light rail and, you know, those type of situations where you're not threatened with falling 

off of a platform or something like that where maybe that's a good thing to have. But I would go 

back to what Frank said is that if it's there, then it needs an instruction to go with it. 

Now, the tricky part about mass transportation is always whether someone has a disability or not or a 

varying ability is learning the system and it's a thing that keeps people away from mass transit 

generally because they're scared they'll end up somewhere that they don't want to be, you know, 
miss a train and so much of it is about communications and you end up, if you go somewhere, you 

take a chance of using their transit system and you have never used it before. It's a little bit of an 

adrenaline rush because you just -- adrenaline rush because you just don't know what's going to 

happen. But at the same time in that learning process if someone is on a system regularly, they 

know how the system works. They know that button is there and what it does, it may be worth a lot 

to them to be able to position themselves in the same place that maybe everybody else isn't 

crowding and maybe they can push that button and get on the train. So I wouldn't want to take that 

away from any of the modes. 

We certainly don't do it on Amtrak and, you know, for a whole lot of reasons. 

But I wouldn't want to take it away from some of the other more intimate modes like light rail 

because just of having the discussion. But I would say that if it's there, it should have instructions to 

let people know how to use it. 

>> This is Gary. Can I say something and I'm on a train and apologize for the noise, but can I say 

something? 

I think push buttons on any train is just a bad idea for exactly what Chris said. You know, we got 

those full-length cars and we actually fought and were successful to get the buttons disconnected 

because that was their intended purpose and whether it's light rail, those were heavy rail, by the way. 

And whether it's light rail, heavy rail, inner city or whatever, you still have people with vision 

impairments or people who are blind they are trying to feel the side of a train that just can be such a 

dangerous situation. Not to mention what Chris bought up about the cleanliness. I mean, to me it 

has no place in American rail passenger service. That's all I wanted to share and again I apologize 

for the noise. 

>> This is Jim. Let me ask a question. We sort of got an idea about doors and those operational 

signs for those. 

Is there any other thing that would need instruction about how to operate it that should be placed in 

the tactile and visual category? 

>> Jim, this is Gary. Did you guys talk about the priority seating and things like that? 
>> No. 

>> I would suggest that the priority seating sign be accessible to all. 

>> Okay. Where would you put the sign so that it's in a consistent location in that if it's tactile and 

braille can be read? 

>> Typically you can put them on the wall adjacent to the seat or on the bulkhead that they sit next 

to. Typically your bulkhead -- excuse me, your accessible seating is closest to the restroom, closest 

to the exit and there's typically a bulkhead wall. So I would just require that there be some 

accessible signage that denote that is that's a priority seat. 

>> So on the closest adjacent wall to the seat? 

>> Yes, sir. 

>> Discussion on that? 

>> Well, when you say -- this is Frank again. 

When you say "accessible seating area," are you talking about the one for parking or are you talking 

about accessible seating for people with other disabilities? 

>> Yeah, accessible seating for anyone with a disability. 

It could be transfer seating. It cub the wheeled mobility, occupied wheeled mobility space, 

something like ta. Either one of those. 

>> On our equipment it's distinguished. You have the parking area that can be used for wheelchairs 

which basically has the wheelchair accessibility sign and then you have the priority seating for those 

other people who have other types of devices and it's usually a fixed seat but it's a priority area like 

you said that's near the door. 

On the one that's just a sign, that's just a sign, it's nothing else other than a Pictogram and I don't 

know that anything else needs to be there. 

>> I would disagree because often, you know, people don't really understand and sometimes they 
look right past the ISA, but usually if you have the ISA in appropriate text to let them know that that 

space is reserved, it often can help. 

I mean, that was our experience. 

>> Gary, this is Blair. 

I'm just curious. Lettering for the designated spaces. 

From a practical standpoint, if someone is visually impaired and isn't necessarily mobility impaired,

excuse my thinking, what's the thinking, what are the rules for spaces with people with visual 

impairment? 

(Lost internet connection)

>> ...the accessible signs, the purpose of those are for people who are visually impaired or blind. 

>> Gary, this is Marsha. I want to ask you about your recommendation. 

You said on some adjacent wall or on the bulkhead or whatever, if I'm totally blind and I'm looking for 

that sign, it occurs to me that I would not want to have to reach over people to touch the sign and 

read it.

So putting that sign on the window or on the wall adjacent to the seating, if someone's in that 

seating, that makes me have to poke around among people to find the sign. Can you think of a way 

to indicate that this is priority seating and maybe even using standardized tactile graphic, if it's raised 

or wireless that would give that indication rather than having people have to dust the walls looking 

for a sign. 

>> Yeah, no. That's a great question. I think, you know, to me the bulkhead behind the seating 

because you're typically only talking about seats that are adjacent to an exit. They're going to be 

the first seats that you come upon, that's where the priority seats typically are located. 

So, you know, often you'll have a bulkhead or you can do that directly above the seat but I think you 

raise a really great point. That doesn't necessarily mean that's the only place or the best place and I 
think your idea of the armrest is great. I know Chris and I had talked and it's one thing I would love 

to see us try like at Amtrak is to do even an embroidered ISA on the seat back, something like that 

where someone who's visually impaired or blind would be able to feel on the seat back if nobody's in 

it of course, but just to give you another means to identify where that seat is. It's one of the biggest 

problems I think the crews have especially on, you know, heavy rail you don't have crews. Light rail, 

you don't have crews and commuter rail you may have some and on inner city, you just don't have a 

lot of personnel. So you have people self-selecting and that's why identifying the space for their 

benefit is important but then identifying it so the person can independently locate that seat and use it 

if they choose to is equally as important. 

But I think it's a really great idea -- we had not tried to do anything like that on an armrest but I think 

it's a really good idea that if there is some space there you can do something with. 

>> Not every seat in that area has an armrest. This is Frank again. 

I think the problem with that sign and I can understand people using that area that shouldn't be using 

that area, but, you know, I think the majority of the people using that area that shouldn't be using 

that area can see just fine and just want to use that area anyhow and I can see you having problems 

with trying to get people to get up out of the seats when they're not supposed to be there, but for 

the occasional time when there is a blind person happens to be sitting in a seat that's reserved for a 

wheelchair or a mobility device, I would think that the crew or somebody else or even the person in 

the chair themselves can, you know, audibly say, please get up. This is a -- you know, this is a 

seating area. 

I understand that you don't want to have to wait for somebody to tell you, but, you know, it seems 

like most of the time even a person who can see just fine waits for somebody to tell them to get up 

and get out of that spot anyhow. I think the wheelchair parking area is very obvious and very clear 

what it's for because it's a big, open space and it's obvious that that is for a wheelchair or mobility 

device. And just the decal alone with the symbol is enough to tell people this is where it -- this is the 

purpose of this area. 

The sign that I was asking you about is the other one for the priority seating for people who can -- or 
are not in a chair or mobility device, but the elderly or other people with canes and walkers, those are 

fixed seats that are assigned for people for those uses and I find it a lot of people don't understand 

what that means. 

So, you know, we're starting to put additional verbiage on there like some other authorities have 

done to explain the purpose of those areas and I wasn't sure if you were talking about that sign or the 

one for the wheelchair parking area. But the problem with the wheelchair parking area that I have 

with putting a tactile version of the sign is basically what Marsha said, is wherever you put it may not 

be where you're expecting it to be and you may have to reach over somebody in order to find it. 

So I don't -- you know, I don't know that's a big problem. I think the biggest problem for keeping 

that space clear is keeping people with luggage and, you know, baby carts and people who just want 

to sit in that space because there's no other empty space to get those people out of there so you can 

get into your seat. I mean, in our operation they are not the most comfortable seats in the first 

place. So if there is an open fixed seat, you will sit there -- these are flip-down seats with a straight 

back and they're not very comfortable because they have to be very compact to allow for the 

necessary space. 

So I don't know...Gary, is the biggest problem that you have people who are using the space who 

shouldn't use it or is the biggest problem that you have, there are a bunch of blind people sitting 

there and they don't know that they can't use that space? 

>> Well, oh, my God. There is a lot to answer there. 

I would tell you with the clear space the biggest issue is that you get just the wrong stuff there, the 

bicycles, the baby carriages, the luggage and people with disabilities don't get the benefit. But the 

person who is blind and has luggage and wants to sit adjacent to their luggage that's a great place to 

put their stuff and be able to put it there so they don't know that's the space. I do agree that 

assigning that space is difficult than priority seating. The priority seating I believe by rule is not 

supposed to be flip. 

Down number one. Like I'm sitting in a transfer seat right now. My wheelchair is unoccupied and 

sitting in the wheelchair space which really technically it shouldn't be. It should just be in the 
adjacent space for my unoccupied wheelchair but there isn't one on this train. 

So the seat that I'm in now, my transfer seat, a person who's blind would have every opportunity, first 

come first serve to take this seat or take the seat adjacent to it and the idea would be that they would 

be able to self- find those seats. I think Marsha raises a good point. I'm not suggesting we want 

people reaching over anybody. I'm just saying if you're going to put a sign up and I think you are 

that says priority seats they ought to be accessible to people who are blind. That's my position. 

And on the other question as far as accessible space, you raise really great points. To me, if it's so 

important that we put a sign on it which I think it's critical we do that, I struggle with why we would 

not make the sign accessible. 

>> Gary, this is Blair. 

I was just looking through our sign manual and I find two fairly large signs that are reserved -- say 

reserved for passengers with disabilities and it has the international icon to one side, raised letters 

and braille --

>> Yeah, I have got one right next to me that's on paper and it's taped on to the wall adjacent to my 

priority seat. No ISA on it. It just says reserved for passengers with disabilities and then the official 

ones with the ISA are not raised character. There is a whole boat load of text on it that I don't know 

that there's anybody that can read it. 

>> What train are you on, Gary? 

>> I'm on the northbound Acela, 2168, something like that. 

>> I know there is a generational issue with some of that signage. So I would have to look at the 

Acela back. But the current signs as I just --

>> Yeah, if I could -- Blair, I tell you, you raise a great point. You know, our crews are trying to do 

what they can do and somebody just like taped the sign to the wall and the reason they did is 

because so many people just sit here because it's great space and to me that's where, you know, it's 
like well, why wouldn't we make that accessible and then a person who's blind would know hey, I'm 

closest to the exit and there's also call buttons here, so if that individual wanted something from the 

cafe car, something like that, then they would be able to push the button where no other seats on 

the train have the call button except the open space and the transfer seat. 

>> Right. I mean, on inner city where we have not just seats and windows and things, but we have 

luggage racks, we obviously have a surface where it's easier for us to consider putting something up 

on what often becomes sort of a guideway anyway for everybody to have a tactile sign. And a visual 

sign and it's within the range of the allowed space for tactile signs. That I know has been pointed 

out before is some of the tactile sign is getting it high enough off the floor. For example, where 

you're sitting right now Gary on the train is probably under 40 inches from the floor, which could be a 

problem for someone trying to read it. 

So --

>> Well, yes. If I could just comment on that, Blair. I think generally I think you're absolutely spot 

on. But because these are seats and you have luggage overhead, there's only that clear space right 

there so anybody that would be tactilely feeling for it, that's where they would go because that's the 

only place there is. 

>> The problem, Gary, when you start to get below 40 inches is that as you're pressing your hand 

against something to read and then your hand begins to drop below your waist, it wants to turn 

upside down and then you're reading upside down. 

So that's why the 40 inches is to keep that sign in a position where your hand remains up, not turned 

or down, and so a sign that gets much lower than 40 inches isn't very readable by a standing person 

with a vision impairment. 

>> Yeah, these are above the seat backs so, you know, they're right at your like high hip area so 

they're not like down where you would have to do something different with your hand. 

>> But, Gary, Gary, that's exactly where your hand starts to rotate as you press it against something in 

front of you. 

So it's very, very difficult to read a tactile sign down by your hip. 
>> No, that's not where these are. I'll measure it and I'll shoot you guys where they are. I can take 

a picture and show you exactly what the sign is. 

>> This is David Nelson here. 

There is a few things that I wanted to mention. Now, first of all where Gary is sitting, my opinion, 

the signage has already been too small to even notice that it is a reserved seat. 

You know, I think that's something that needs to be bigger and a little more clear. 

Now, I have a question, Gary, to you regarding priority signage with the T. 

Now, I'm surprised because if I understand correctly they say that people pretty much leave that seat 

empty for anybody who's blind -- anybody who needs it. 

What does the sign say exactly? 

And I mean, what's presented would you say 50% of the time it's usually always vacant even though 

the train is pretty almost full or what's that? 

>> David, this is Gary. You're asking about like the MBTA service or the inner city? 

>> The priority signage on the MBTA. 

>> Well, the priority signage basically say this space is reserved for people with disabilities and I 

believe we put in there by law. That's what the sign says. I'm not following the other part of it 

though. I apologize. 

>> Yeah, this is Chris Hart. 

We like to have data per se. It tracks the usage of priority seating. What I will say is that generally 

speaking most people are considerate enough to get up and move when they see someone that 

needs it or asks for it. Now, that said, David, I think it's important to note that the MBTA generally 

speaking has far more priority seating that is quote, unquote minimally required, so that also helps 

matters. I think it has to be a discussion a question as to whether you might want to figure out what 
the priority seat ratio is. 

. But ratio request for more priority seating rather than less. 

>> Yeah, this is Gary and I would add that the blind community was well involved in, you know, really 

behind us in our efforts when, you know, we approached them and asked them for, you know, their 

feedback on should it be accessible signage, you know, where should we put it, things like that. And 

I think they were very, very supportive of what we were doing there. 

>> You know, that's interesting to hear about because I don't -- I guess I don't see that happen here 

even on the Metro in D.C. 

I mean, we have got priority seating signage that is very clear but honestly I never, ever see anybody 

get up to get out of the way or whichever and so I'm surprised that MBTA, need to have a much 

more, you know, respect for others who might need that seat. 

>> And to be fair, we have also very robust courtesy trunk and you see this to remind people and...or 

a person with a disability or someone who's pregnant. 

Of course in Boston we are also... 

>> Well, for the decal -- Jim, correct me if I'm wrong, but currently the only decal required is the one 

for the priority seating area for people with disabilities other than the wheelchair, correct? 
>> There is a sign required, but the ISA is not currently required and the priority seating is the only 

requirement in the standard currently that has specific requirements for characters, width to height, 

there is a height 5/8 minimum and that's the only place where it comes into play. 

>> And that's the fixed seating area, it's not for the wheelchair area. 

>> It doesn't say fixed. It says each vehicle shall contain signs which indicate that certain seats are 

priority seats for persons with disabilities and that other passengers shall make such seats available to 

those who wish to use them. 

>> Right. But those seats have to be fixed seats, it can't be flip-up, right? 

>> It doesn't say that. 

>> There is no requirement for it? 

>> No. 

>> But it's not meant for the wheelchair parking area, is it? 

>> No. 

>> So one requirement is to have the sign designating the wheelchair parking area would be a new 

requirement, whether it's accessible or not is a second level of addition. 

>> And also whether or not you want to require the ISA or not. 

>> Right. 

>> This is Gary. Can I follow up on that. You're reading from the signage section. Isn't there a 

section in seating that talks about the priority seats can't be sprung up? 

>> Right now, I just have rapid rail up. That's what I read from. 

>> Yeah, I think it might be in DOT, there is a reference that they can't be sprung up. 

>> This is Chris. 

Quite frankly I think -- I'm pretty sure pass FTA compliance agencies for not signing their designated 
quote, unquote wheelchair spaces. It is not necessarily in the Access Board regs, but I'm pretty 

confident years ago MBTA was signing a report before I graduated college. 

>> This is Blair Slaughter. Just for clarification, looking at our category chart...would we consider 

this a designation sign for spaces? 

>> Hi, Blair. This is Gary. Yeah, I would think it is. 

>> Okay. Because, Jim, correct me if I'm wrong, didn't we already say that that was visual and tactile 

as well? 

>> Correct. Agree that designation signs for spaces should be visual and tactile. 

>> Okay. So we plowed that ground. We just need to come to some agreement I guess as to 

making sure they're where they can be, seen and also accessible so that since they're going to be 

visual and tactile, that they can be utilized as such. 

Which may mean that they occur more than once in a given vehicle depending on its arrangement. I

mean, I know that in our situations it really makes a lot of sense to have it twice because to avoid the 

issue of someone having to, as Marsha said, dust the wall trying to find, you know, read what's over 

there versus having it on a bulkhead or on a luggage rack or something. 

>> This is Gary. I completely agree with that, Blair, and I think that, you know, for most -- you know, 

for most applications, even light rail you're going to see that a lot of vehicles today, where they 

typically will put more than one just because, you know, it makes the space more identifiable and if 

you do make the sign accessible it gives people more of an option to be able to look and self- locate 

and independently identify that space. 
>> So, do we need to -- I'm just trying to figure out how we can sort of close in on this before Jim goes 

into panic mode -- (laughter) --

>> Not yet. 

>> -- do we designate the visibility aspect of it and I'll use visibility broadly and that it can be -- it can 

be read tactilely or seen when you approach the space. 

That might mean in some vehicles that you only need one and one will serve the purpose depending 

on the arrangement and in others it's going to mean that you're almost by default going to have it 

maybe twice or more, but at least twice. 

Just drying to think how we can leave it as defined enough to move on. 

>> Yeah, this is Gary. I think that's a good suggestion. 

One thing I would ask for consideration too is the ISA itself. Like, Blair, thank you so much. Your 

just sent out the one sign drawing and in that and one of the things that I've struggled with is when 

you don't have that as a raised character for someone who is visually impaired or blind, that would 

benefit in that typically in a lot of locations you won't see that. So it just seems to me here you 

won't be able to feel that, I mean. It just seems like that would be something else that the 

committee might -- the subcommittee might consider as, you know, tactile braille or raised tactile 

braille that that would include the ISA as well if it's used. 

>> Gary, this is Blair. 

One of the problems with an icon like that is -- and it was mentioned earlier, when you get to some 

level of complexity, reading that icon and understanding what it is can be tricky. 

I would suggest at the risk of creating yet another icon, I'll back up and let me preface something. 

From railroad history, a lot of times on the railroad there would be markings on the outside of rail 

cars that were bear and most people didn't know what they were, didn't care what they were. 
But they were signals to the railroad people about a certain consider of that consider or something 

that was on that car, so there might be a symbol that meant that there was a restroom on that car for 

a messenger back when they were messenger cars and the cue there was that the mechanical people 

would see that emblem and know that they needed to go and service that car a certain way. 

Now, is there any sanity in having a very simply identified, tactilely identifiable raised element that is 

readable regardless of orientation. So you're just going to have almost a circular arrangement so if 

you read it upside down, right side up, you would always know that you're reading a tactile element 

that tells you this is a designated place and something like that could be easily manufactured and 

applied. It could be an adhesive element. It could be applied to a seat. It could be applied to a 

luggage rack. It could be applied to almost anywhere that is in the range of where people would be 

looking without getting into a huge icon that is readable. 

>> This is David. You know what, never mind. I'm going to hold off on the comment. I want to 

hear the answer to that first. 

>> Okay. Well, folks, this is Jim. We're starting to run out of time. We have only got a few 

minutes left. Blair, I'm going to cut you off and sort of go into what I think is what we have been --

summarize what we have been talking about on this specific issue. So for nonemergency 

operational signs, the overall arching thing is they should be visual and the size should meet the 

requirement where practicable but then we're looking at a specific provision for where instructions 

for operating door latches and locks are provided, that they be tactile and visual with a specific 

location to be determined later, where Pictograms are provided to describe that they must have a 

braille underneath it. We have decided that the wheelchair space is a space designation and also 

the sign for that has to be raised in braille and visual. I'm assuming we want to require the ISA for 

those. 

The only thing I sort of have that's sort of up in the air is the priority seating. I assume you want to 

require the ISA. I assume you want to require the -- them to be tactile and visual. But as to where 

you want to require the location that is still to be determined. Is that sort of a summary of where 
we are? 

>> I think that's a good summary, Jim. The location is the one that's questionable to me that we 

have to try to figure out because finding a consistent location may be difficult. But I think you just 

said exactly where we're at. 

>> Yeah, this is Gary Talbot. That was really good. I agree 100%. 

Thank you. 

>> I concur. 

>> Jim, just to kind of provide...have we had the discussion of whether we're going to call it a quote, 

unquote wheelchair space or are we going to call it something else? 

>> No, Chris, we haven't had that discussion as to what we're going to physically call it. 

>> Again, I don't think that's a communication subcommittee issue. 

>> Okay. 

It will be a general issue. I'm sorry. Yeah. 

>> All right. Since I think we're sort of at the hour, and we are according to my lovely phone, I'm 

going to thank you all and hopefully you can go out and cogitate on this. Blair, I want you to go out 

and think about your tactile symbol that's easily readable for the chairs, et cetera. Maybe you can 

come up with something that's similar to, I don't know, the star designation in an elevator for the 

ground floor, entry level or something to that effect. 

And, everybody else, continue to look at the rest of these categories and hopefully send me your 

recommendations about where -- what you think those should do. Continue that home work 

assignment and we will see you next time. 

>> Thanks, Jim, for keeping us out of the weeds. 

>> Thanks, everybody. 

>> Next meeting is July 3rd I'm being told. 
>> Boy, who was the wonderful person that scheduled that one? 

I know I'll be there. 

>> The committee. 

>> Thank you, operator, for all your help today. We are adjourned. You may disconnect all lines. 

( End )