Consultant Michele Ohmes answers your Americans with Disabilities Act (ADA) questions.

Q: Regarding detectable warnings, you use the word "street." What about parking lots? And are drive islands [that separate driveways in parking garages or other parking lot structures] considered streets? I've also used them when trash enclosures are behind the sidewalk, at drive-thru lanes, and in parking lots where there's a row of handicap parking spaces with zero-inch curbs. I place them at all places where you could get hit by a car.

A: There's a reason for stating "street," and that is to prevent overuse. Detectable warnings are for actual street crossings, with the small exception of commercial driveways with traffic control devices. According to detectable warning surfaces advisory R221 from the Access Board's: 2005 Public Rights of Way Accessibility Guidelines (PROWAG), overuse of detectable warning surfaces should be avoided to maintain message clarity.

The below pictures are examples of detectable warning overkill. One location shows trash bins where refuse vehicles collect trash. Detectable warnings aren't needed in this situation because the trucks have backup alarms, which warn people with vision impairments that a large vehicle is present. Plus, there's usually at least two people manning the vehicle - the passenger jumps out and guides the driver. That person can either assist or warn a pedestrian not to cross the driveway at that time.

According to the R221 detectable warning surfaces advisory from PROWAG 2005, detectable warning surfaces are required where curb ramps, blended transitions, or landings provide a flush pedestrian connection to the street. Overuse, as shown above, should be avoided.

These detectable warnings aren't needed where refuse vehicles back in to collect trash. The trucks have backup alarms, and there's usually at least two people manning the vehicle. The passenger jumps out and guides the driver, and can either assist pedestrians or warn them away.

At strip malls, detectable warnings can be placed at crosswalks in front of large stores. Beyond that, I wouldn't be too worried. A person with severe vision impairments isn't driving, and will usually be assisted by another person.

Sidewalk crossings of residential driveways shouldn't have detectable warnings since the pedestrian right of way continues across most driveway aprons.

I've heard that some city inspectors and planning departments are requiring detectable warnings at multiple non-street locations. Please do your best to convince them that overuse only causes confusion for the visually impaired, who understand that the warnings indicate a street crossing. Overuse also creates great discomfort for those with different disabilities. For example, wheelchair users have to bounce over the bumpy detectable warnings, and those who live with chronic pain must step on them.

Thank you and keep those questions coming! I am thrilled with the number of responses this column receives. Don't forget that I can also help with building facilities, employment, policies, etc., related to ADA compliance.

Happy New Year!

- Michele S. Ohmes ([email protected]) is an ADA specialist who works with public works departments, facility managers, and contractors. Her design manual, ADA and Accessibility: Let's Get Practical, is available on CD-ROM through the American Public Works Association's Web site. Author's note: Michele & Associates does not render legal advice and has no enforcement authority regarding the ADA or other federal disability-rights legislation.

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