# 35

III-7.5165

September 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.

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