The 2010 ADA Standards for Accessible Design has a section 217 which tells us which telephones are required to comply with the standards.  The ones listed are coin-operated public pay telephones, coinless public pay telephones, public closed-circuit telephones, public courtesy phones, or other types of public telephones.

Most people assume the ones that are required to comply are “pay” telephones

But there are many others that are required to comply that we don’t always think about.  As the list above explains, not just pay telephones, but also courtesy phones, and “other types”.  Other types will also include emergency calling devices.

this is a courtesy phone that is required to be mounted within reach. This one is higher than 48″ a.f.f.

This is an emergency calling device that will require compliance

The ADA section 217 states that the telephones and calling devices that are required to comply should follow section 704

Section 704 tells us the following:

1) At least one of the telephones must be designed for the use by people who are in wheelchairs.

a) A 30″x48″ clear floor space must be provided.  The clear floor or ground space shall not be obstructed by bases, enclosures, or seats

the clear floor space to approach this phone is less than 36″ wide

There is a fixed seat in front of this telephone

The emergency phone was located over the landscaping next to the concrete pad. This is not considered having a “clear floor space”

This phone is located behind the planter. Even though the planter is not fixed, technically the phone does not have a clear floor space to approach it.

The phone is located behind a table

b) If the clear floor space is positioned for a parallel approach, it should be located as shown in the figure below

c) If the clear floor space is positioned for a forward approach, it should be located as shown in the figure below

c) Operable parts shall comply with 308 and  309. Telephones shall have push-button controls where such service is available.

The operable part on this phone (the push buttons) were mounted higher than 48″ a.f.f.

The button to call the police was mounted higher than 48″  a.f.f.

d) The cord from the telephone to the handset shall be 29 inches (735 mm) long minimum.

This phone had a cord that was 26″ long

2. The telephones should also be designed for the hearing impaired to have the ability to use it.  Some telephones are required to provide volume control and TTY (An abbreviation for teletypewriter)

a) All public telephones are required to have volume controls.  Volume controls shall be equipped with a receive volume control that provides a gain adjustable up to 20 dB minimum. For incremental volume control, provide at least one intermediate step of 12 dB of gain minimum. An automatic reset shall be provided.

This phone had a volume control device built in on the handset

Most pay phones have volume controls on the cabinet

b) TTYs required at a public pay telephone and shall be permanently affixed within, or adjacent to, the telephone enclosure. Where an acoustic coupler is used, the telephone cord shall be sufficiently long to allow connection of the TTY and the telephone receiver.

some TTY phones are placed on a shelf that is provided on the phone cabinet

Emergency calling devices are not specifically scoped in the 2010 ADA Standards.  Some have considered these emergency calling devices to be subject as a two-way communication element if they only allow communication between the called and one party. The standards only address two-way communication systems under 230 and 708 where admittance to a building or restricted space is dependent on the two-way communication system.  The closest similar device for these emergency calling devices is a “closed circuit telephone” per the definition section of the standards.

Closed circuit telephones must also comply with the requirements listed above and in section 704.  But volume control is not a common feature for these devices.  The use of the variance process in Texas is the only way you can achieve compliance.  In the ADA there is no variance process and therefore when providing devices that are not fully compliant, you can use “equivalent facilitiation” to achieve compliance and documenting this within the owner’s organization.

The telephones that are required to comply are not just the public pay phones that we are used to seeing in public buildings.  There are many more types of telephones that are provided in different facilities that require compliance.  Airports, Hotels, schools and other places of public accommodations will provide a “courtesy” or “emergency” phones and will also require compliance with the ADA Standards so that persons with different disabilities can also communicate.