Georgia Tech Research Institute
 

1194.25(j)

Products which are freestanding, non-portable, and intended to be used in one location and which have operable controls shall comply with the following:

(1) The position of any operable control shall be determined with respect to a vertical plane, which is 48 inches in length, centered on the operable control, and at the maximum protrusion of the product within the 48 inch length. (See Figure 1)


Figure 1

(2) Where any operable control is 10 inches or less behind the reference plane, the height shall be 54 inches maximum and 15 inches minimum above the floor.

(3) Where any operable control is more than 10 inches and not more than 24 inches behind the reference plane, the height shall be 46 inches maximum and 15 inches minimum above the floor.

(4) Operable controls shall not be more than 24 inches behind the reference plane. (See Figure 2)


Figure 2

Why is this standard important to people with disabilities?

These standards are important for people with disabilities because following these standards will ensure that people using wheelchairs or other assistive devices will be able to reach controls and view displays on the product. This includes individuals with low vision who may need to lean in close to or into the machine to read a label. These standards are also particularly important for those who have limited reach capability or don't have full arm extension.

The populations addressed by this guideline includes users with the following impairments: upper mobility (strength limitations, tremors, limited reach), lower mobility, and low vision (color blindness, blurred vision, obscured vision).

Determining if this standard applies to a product

Standards 1194.25(j)(1) through (4) apply to the physical characteristics of office equipment, particularly reach ranges and the physical accessibility of controls and features. These standards apply to products such as copiers, kiosks, and free standing printers. These standards do not apply to devices that are not freestanding, non-portable, and are intended to be used in one location or that do not have operable controls.

(Source: Access Board's "Guide to the Section 508 Standards for Electronic and Information Technology: Self Contained, Closed Products")

How this standard can be met

Provide optional stands and drawer configurations to give users the option of a device that will meet the height standards; it is fine to provide other configurations for those who are not restricted by height issues. All controls should be at a height of 15 inches or greater. If the controls are 10 inches or less behind the reference plane, they should be no higher than 54 inches; if they are between 10 and 24 inches behind the reference plane, they should be no higher than 46 inches. No controls should be more than 24 inches behind the reference plane.

Assessing whether this standard has been met

Item 1194.25(j)(1) is not a regulation in and of itself, and cannot be evaluated on a pass/fail basis. This item sets the conditions for the remaining items in 1194.25(j). Items 1194.25(j)(2), 1194.25(j)(3), and 1194.25(j)(4) should be evaluated on a pass/fail basis as described below.

1194.25(j)(2) In order to determine if the device controls are within the allowable ranges, perform the following steps:

  1. Review product documentation and become familiar with the product through interaction with the various components.
  2. Identify the location of all controls.
  3. Using a tape measure, measure and document the height of all controls or control panels.
  4. Determine the location of the reference plane.
  5. Using a tape measure, measure and document the distance (depth) from the reference plane to the furthest position on the control panel or to the activation point (likely the center) of a single control.

If the device is not freestanding, non-portable, and intended to be used in one location or does not have operable controls, this item will be rated as not applicable. If the controls are greater than 10 inches behind the reference plane, this item will be rated as not applicable. If the controls are 10 inches or less behind the reference plane, and the height of those controls is between 15 and 54 inches, the device is considered to PASS this standard; if the height is less than 15 inches or greater than 54 inches for any control, the device is considered to FAIL this standard.

1194.25(j)(3) In order to determine if the device controls are within the allowable ranges, perform the following steps:

  1. Review product documentation and become familiar with the product through interaction with the various components.
  2. Identify the location of all controls.
  3. Using a tape measure, measure and document the height of all controls or control panels.
  4. Determine the location of the reference plane.
  5. Using a tape measure, measure and document the distance (depth) from the reference plane to the furthest position on the control panel or to the activation point (likely the center) of a single control.

If the device is not freestanding, non-portable, and intended to be used in one location or does not have operable controls, this item will be rated as not applicable. If the controls are less than 10 inches or more than 24 inches behind the reference plane, this item will be rated as not applicable. If the controls are between 10 and 24 inches behind the reference plane, and the height of those controls is between 15 and 46 inches, the device is considered to PASS this standard; if the height of any control is less than 15 inches or greater than 46 inches, the device is either considered to FAIL this regulation.

1194.25(j)(4) In order to determine if the device controls are within the allowable ranges, perform the following steps:

  1. Review product documentation and become familiar with the product through interaction with the various components.
  2. Identify the location of all controls.
  3. Determine the location of the reference plane.
  4. Using a tape measure, measure and document the distance (depth) from the reference plane to the furthest position on the control panel or to the activation point (likely the center) of a single control.

If the device is not freestanding, non-portable, and intended to be used in one location or does not have operable controls, this item will be rated as not applicable. If all controls are within 24 inches of the reference plane, the device is considered to PASS this regulation. If any controls are more than 24 inches from the reference plane, the device is considered to FAIL this regulation.

Common misconceptions about this standard

Below are some common misconceptions regarding 1194.25(j), and clarification on these misconceptions.

Misconception: These standards apply to all product controls.

Clarification: These standards only apply to controls related to normal daily operation. Determining which controls are related to normal daily operation should be determined by human judgment. The intended use of the product will aid in determining what is characterized as normal daily operation. Product vendors and user manuals/documentation are good resources to consult to determine which activities are user activities versus maintenance activities. Note that controls necessary for user monitoring functions are considered controls used for daily operation. (Source: Accessibility Forum's "Quick Reference Guide to Section 508 Resource Documents")

Misconception: When evaluating a product, only the controls on one reference plane need be considered.

Clarification: No. A product may have controls in more than one vertical location, and thus there will be more than one reference plane. Ensure that you evaluate the controls in reference to all reference planes. (Source: Accessibility Forum's "Quick Reference Guide to Section 508 Resource Documents")

Misconception: A copier with a document feeder that is within the technical specifications but has platen glass outside the reach range specified by this standard is still compliant with this standard. As long as one mode of placing paper on the copier is accessible, the product will be considered accessible.

Clarification: No, such a copier would not comply with this standard. In order to comply with this standard, the copier must allow for access to both means of placing paper onto the copier. The reason for this is there are some types of paper that cannot be run through a paper feed. (Source: Access Board's "Guide to the Section 508 Standards for Electronic and Information Technology: Self Contained, Closed Products")

Misconception: The trays for storing paper do not need to be reachable.

Clarification: When these standards refer to "operable controls", they are referring to controls such as mechanically operated controls, input and output trays, card slots, keyboards, and keypads. These standards do not apply when a product is being used for maintenance, repair, or monitoring, or during initial setup/configuration, adding and replacing parts, and service tasks. These standards apply to products in their normal operation. (Source: Access Board's "Guide to the Section 508 Standards for Electronic and Information Technology: Self Contained, Closed Products")

Although the Access Board considers replacing paper to be a maintenance function and not a normal daily operation, under some circumstances (for example, when the copier runs out of paper and the person responsible for copier maintenance is not available, or when a print job requires the use of special paper) it is reasonable to expect that a user should be able to add paper to the copier. For this reason, at least one paper drawer should be accessible.

Additional information

These standards are based on the Americans with Disabilities Act Accessibility Guidelines (ADAAG 4.2 Space Allowance and Reach Ranges). New ADA design guidelines were released in July 2004, but have not yet been adopted as part of Section 508. The details of these new guidelines are available at http://www.access-board.gov/ada-aba/index.htm. While these new guidelines have not been adopted under Section 508, it may be wise to design with them in mind; they are stricter than Section 508 currently, and if they are adopted under 508, it would be advantageous to already be in conformance with them. The specifics that will impact Section 508, if implemented, are as follows (from http://www.access-board.gov/ada-aba/final.cfm):

308.2 Forward Reach

308.2.1 Unobstructed

Where a forward reach is unobstructed, the high forward reach shall be 48 inches (1220 mm) maximum and the low forward reach shall be 15 inches (380 mm) minimum above the finish floor or ground.

A side view is shown of a person suing a wheelchair reaching toward a wall. The lowest vertical reach point is 15 inches (380 mm) minimum and the highest is 48 inches (1220 mm) maximum.
Figure 308.2.1
Unobstructed Forward Reach

308.2.2 Obstructed High Reach

Where a high forward reach is over an obstruction, the clear floor space shall extend beneath the element for a distance not less than the required reach depth over the obstruction. The high forward reach shall be 48 inches (1220 mm) maximum where the reach depth is 20 inches (510 mm) maximum. Where the reach depth exceeds 20 inches (510 mm), the high forward reach shall be 44 inches (1120 mm) maximum and the reach depth shall be 25 inches (635 mm) maximum.

Figure (a) shows a person seated in a wheelchair reaching a point on a wall above a protrusion, such as a wall-mounted counter, which is 20 inches (510 mm) deep maximum. The maximum reach height is 48 inches (1220 mm). In figure (b), the obstruction is more than 20 inches (510 mm) deep, with 25 inches (635 mm) the maximum depth. The maximum reach height is 44 inches (1120 mm).
Figure 308.2.2
Obstructed High Forward Reach

308.3 Side Reach

308.3.1 Unobstructed

Where a clear floor or ground space allows a parallel approach to an element and the side reach is unobstructed, the high side reach shall be 48 inches (1220 mm) maximum and the low side reach shall be 15 inches (380 mm) minimum above the finish floor or ground.

The drawing shows a frontal view of a person using a wheelchair making a side reach to a wall. The depth of reach is 10 inches (255 mm) maximum. The vertical reach range is 15 inches (380 mm) minimum to 48 inches (1220 mm) maximum.
Figure 308.3.1
Unobstructed Side Reach

Exception 1: An obstruction shall be permitted between the clear floor or ground space and the element where the depth of the obstruction is 10 inches (255 mm) maximum.

Exception 2: Operable parts of fuel dispensers shall be permitted to be 54 inches (1370 mm) maximum measured from the surface of the vehicular way where fuel dispensers are installed on existing curbs.

308.3.2 Obstructed High Reach

Where a clear floor or ground space allows a parallel approach to an element and the high side reach is over an obstruction, the height of the obstruction shall be 34 inches (865 mm) maximum and the depth of the obstruction shall be 24 inches (610 mm) maximum. The high side reach shall be 48 inches (1220 mm) maximum for a reach depth of 10 inches (255 mm) maximum. Where the reach depth exceeds 10 inches (255 mm), the high side reach shall be 46 inches (1170 mm) maximum for a reach depth of 24 inches (610 mm) maximum.

Obstructed High Side Reach. The drawing shows a frontal view of a person using a wheelchair making a side reach to a wall. The depth of reach is 10 inches (255 mm) maximum. The vertical reach range is 15 inches (380 mm) minimum to 54 inches (1370 mm) maximum.
Figure 308.3.2
Obstructed High Side Reach

Exception 1: The top of washing machines and clothes dryers shall be permitted to be 36 inches (915 mm) maximum above the finish floor.

Exception 2: Operable parts of fuel dispensers shall be permitted to be 54 inches (1370 mm) maximum measured from the surface of the vehicular way where fuel dispensers are installed on existing curbs.

Additional references

For more information, see the following references: