| Initiative | Advance Notice of Proposed Rulemaking (ANPRM) |
| Comment Number | OL-100587 |
| Status | Catalogued |
| Classification | Substantive |
| Submitted Type | CW Web Form |
| Commenter Type | Industry or Trade Association |
| Organization | Automatic Fire Alarm Association |
| Received | 05/31/2005 03:24:48 PM |
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| Pages | |
| Category | Standard Web Form |
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| Commenter |
| First Name | Last Name | State/Province |
| Thomas | Hammerberg | FL |
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| Comment Period Start | 9/30/2004 |
| Comment Period End | 5/31/2005 |
| Phase | Advance Notice of Proposed Rulemaking (ANPRM) |
| Comment Instructions | NEW ALTERNATIVE PROCESS AVAILABLE: As described in its Announcement of Alternative ADA ANPRM Comment Process, as of May 16, 2005, the Department permits commenters who wish to restrict access to their identity to send their comments to a special new mailing or electronic address. At this address, commenters’ business and personal names and addresses will be removed before their comments enter the comment processing system. Comments must initially include the sender’s name and address and must follow all of the instructions set forth in the announcement.
The Department of Justice (Department) is issuing this ANPRM in order to begin the process of adopting revised ADA standards consistent with Parts I and III of the revised guidelines implementing the Americans with Disabilities Act of 1990 (ADA) and the Architectural Barriers Act of 1968 (ABA), published by the Architectural and Transportation Barriers Compliance Board (Access Board) on July 23, 2004, at 69 FR 44083. You may submit electronic comments though this form or through www.regulations.gov. The Department strongly encourages you to read the ANPRM before submitting your comments. Unless you use the new alternative process, you may address all written comments concerning this ANPRM to P.O. Box 1032, Merrifield, VA. 22116-1032; please note that courier and overnight deliveries will not be accepted at this address. Unless you use the new alternative process, comments submitted in written or electronic form are available to the public in their entirety, including personal information.
Using this form: The fields for your full name and address, marked with asterisks, are required fields. You cannot proceed with your comment unless you fill in these fields. You may select one or more of the 54 questions posed by the Department in the ANPRM and type your answer to the question in the space provided. There are two ways to select a question: you may either enter the number of the question that you want in the box provided and click on the "Retrieve Question" button, or you may scroll through the questions listed by topic, click the question you want to select, and then click on the "Retrieve Question" button. In addition, you may choose to type a comment in the "General Comments" box provided below (4,000 characters available). You may also submit a comment as an attachment at the end of this form.
Inspection of Comments: All comments will be available throughout the comment period to the public online at WWW.ADAANPRM.ORG and, by appointment, during normal business hours, at the office of the Disability Rights Section, Civil Rights Division, U.S. Department of Justice, located at 1425 New York Avenue, Suite 4039, Washington, D.C. 20005. To arrange an appointment to review the comments, please contact the ADA Information Line at (800) 514-0301 (voice) and (800) 514-0383 (TTY). |
| Initiative Type | Federal Rulemaking |
| Agency | U. S. Department of Justice |
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| Initiative | Advance Notice of Proposed Rulemaking (ANPRM) |
| Subject | Advance Notice of Proposed Rulemaking (ANPRM) |
| Docket ID | CRT Docket No. 2004-DRS01 |
| Short Title | Nondiscrimination on the Basis of Disability in State and Local Government Services; Nondiscrimination on the Basis of Disability by Public Accommodations and in Commercial Facilities |
| Rule | Nondiscrimination on the Basis of Disability in State and Local Government Services; Nondiscrimination on the Basis of Disability by Public Accommodations and in Commercial Facilities |
| Rule Citation | 28 CFR Parts 35 and 36 |
| Published Info | September 30, 2004 View Announcement of Alternative ADA ANPRM Comment Process (HTML) View ANPRM (HTML)  View ANPRM (PDF) View Notice to Extend Comment Period (HTML) View Notice to Extend Comment Period (PDF) (Download Adobe Reader) |
| Description | Description??? |
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| Attachments | No Attachments |
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| File Name | OL-100587.htm |
| File Extension | .txt |
| File Size | 1981 |
| Comments | Answers to Specific Questions
General Comments As written: 215.3 Employee Work Areas. Where employee work areas have audible alarm coverage, the wiring system shall be designed so that visible alarms complying with 702 can be integrated into the alarm system. The problem: The current wording is not specific as to its intent and is too open-ended. It is not clear as to what the designer and installer must provide and therefore will lead to finger- pointing and cause contractual and enforcement problems. There are many open-ended questions that result from the existing wording, such as: - What is meant by a wiring system? - Where should the wiring terminate? - Are the wiring systems to include backboxes? Where should the backboxes be located? - What size wires are to be provided? - Does the wiring system intended also require equipment to be provided? Power supplies and notification appliance circuits? Space in the fire alarm control panel? - Should the wiring be shielded? - Do the other circuits in the same conduit have to be shielded? (This can be system equipment dependent) Note: as written, the current provision does not reduce the initial construction costs, it will increase them. Because of the unclear language, installers are forced to add "contingency" amounts because they do not know what is expected and what will be required. Requirements should, at least, allow for a consistent and fair way to provide installation pricing. Recommended wording: 215.3 Employee Work Areas. Where employee work areas have audible alarm coverage, the visible notification appliance circuits in the proximity of employee work areas shall be designed with a minimum of 15% spare capacity to account for the potential of adding visible appliances in the future to accommodate hearing impaired employee(s). Substantiation: The recommended wording accomplishes the original intent by providing capacity to expand, while making the requirement clear. |
| Version Date | 6/10/2005 |
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| File MIME Type | text/html |
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