With numerous articles circulating about the new ADA (Americans with Disabilities Act) regulations, IADs may be feeling overwhelmed finding the time to create a plan and budgeting for the costs required to bring their ATMs into full compliance.
You might be wondering how difficult it might be to become fully ADA compliant in time for the deadline on March 15, 2012. The good news is creating a plan is probably much simpler than you think.Fortunately, a significant share of ATMs in the field are already or near ADA compliant, mostly because ATM manufacturers began to produce ATMs many years ago that met this new standard.
Therefore, the first step is to determine which ATMs within your portfolio are, and are not, compliant. Once you’ve determined this, there may be less upgrading and changes than you originally thought. I’ve found many great resources within the ATM industry that are available to assist in analyzing the ADA status of ATMs within a portfolio and implementing any changes necessary. I have listed these below with links to their resource guides.
Under federal law, IADs have until March 15, 2012 to make necessary upgrades to ATMs before enforcement is implemented. Any ATMs that don’t meet ADA standards by the 2012 deadline could result in a civil penalty of up to $55,000 for a first offense and double that amount for subsequent offenses.
Although cost will most-likely be involved in order to meet these new regulations, planning ahead and implementing upgrades efficiently could save you quite a bit of money and prevent you from a major and costly lawsuit in the future.
When it comes to the new ADA regulations, compliance standards appear to be divided into (but not exclusive to) two main parts: physical access and communication.
Physical access
The majority of IADs likely already have ATMs compliant with physical access. However, IADs still need to evaluate the following in each location to ensure their ATMs are either already compliant or if they require possible changes or upgrades.
• Height and Reach. The controls for the ATM machine need to be within reach ranges, including a height not exceeding 48 inches and no lower than 15 inches.
• Accessibility. The ATM must be accessible based on earlier guidelines for buildings and facilities and will need to be free from obstructions.
• Floor Space. The space around an ATM needs to be sufficient, excluding drive-up ATMs. Clear floor or ground space needs to be 48 inches out from the ATM and 30 inches wide.
Communication
Most of the new ADA requirements are focused on communication. Therefore, more attention will need to be directed toward the following communications elements on your ATMs.
• Speech. ATMs need to be speech enabled to assist individuals with vision impairments.
• Input Controls. Controls need to be tactilely discernible for each function.
• Numeric Keys. The number keypads need to be arranged in 12-key ascending or descending telephone keypad layout.
• Function Keys. Function keys will need to contrast visually from background surfaces.
• Display Screen. The display screen needs to be visible 40 inches above the floor space.
• Braille. Braille instructions to begin speech mode will need to be included.
Another important aspect to consider is that if you have a location with multiple ATM machines, only one ATM needs to be ADA accessible and compliant.
It is also important to note that there is no grandfathering of currently deployed machines. Therefore, there may be cases where you need to upgrade or replace entire machines (generally older ATM models) in order to be compliant.
In that case, make sure that the ATM you purchase, especially if it’s used or refurbished, is fully compliant. New machines that are shipped from ATM manufacturers come fully ADA compliant.
When putting your strategic plan together, I suggest creating a plan that systematically brings your entire portfolio into compliance by March 15, 2012. You can do this by first identifying the older ATM models in your portfolio, since these will need the most upgrades. After a full evaluation of all ATMs, next is planning how you will implement these changes and figuring in the cost. To make the upgrade process simpler for IADs, major retail manufacturers have recently started offering ADA kits.
Consulting with a legal advisor and with ATM vendors such as ATMequipment.com, can help you fine tune and implement your plan by helping you figure out which of your ATMs will need to be upgraded and the most cost-effective solution to help bring these ATMs into compliance.
Suggested Resource Guides:
• Guide to 2010 ADA Accessibility Standards by Kahuna ATM Solutions
• Summary of New 2010 Americans with Disabilities Act (ADA) ATM Standards by First Data
• 2010 ADA Standards for Accessible Design by the U.S. Department of Justice
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