"Note from the U.S. Department of Justice: U.S. DOJ created this .TXT version of the public comment as an alternative for those who have difficulty reviewing the PDF of this same comment. The text layer associated with the PDF version is of poor quality, because the original image of the public comment was also of poor quality. To rectify this problem, we have corrected the errors in this text-based version, so that the comment can be more accessible and can be read more accurately (e.g., by screen readers)." Helene Karpiel P.O. Box 40337 Pittsburgh, PA 15201-0337 412-344-7373 August 15, 2008 I, Helene Karpiel, wish to submit this list of recommendations to the ADA Compliance for Home and Apartment residents who are handicapped to varying degrees, which should enable more handicapped residents to move from residence to residence more efficiently and with less expense and stress. Furthermore, these suggestions could make it much easier for residents to maintain their homes and apartments with greater independence and/or complete independence ... something which is of great importance for a handicapped person to make them feel of total worth. Also, for rental properties, these recommendations should prove to be far more economic, in the long run (please do contact me 24/7/365 for any clarification and please do let the telephone ring at least twelve [12] times and if I do not answer, please do call back when I am available.) In addition, please consider the transportation suggestions as it is truly an adventure each and every time a handicapped person must choose public transportation to go to the hospital, doctor, shopping, visiting, etc. and many times these experiences are most unpleasant, to say the least. And, with regard to motor scooters, all companies should be required to make good solid systems that can withstand a 500 pound weight limit because even smaller people need to use these scooters for grocery shopping and canned goods weigh a lot. The batteries should be guaranteed to last for at least 100 miles and have gears that can be set to climb hills with ease (Pittsburgh does not have flat sidewalks). And these motor scooters should be female friendly. I wish to apologize for not submitting this document on the appropriate forms but, unfortunately, I was not able to obtain the necessary forms that were mentioned on the recording. Truly, I did try and all without efforts proved unsuccessful. My present apartment does not meet most of my needs and it is a nightmare in the kitchen and bathroom. I constantly burn myself in the kitchen and break my appliances and other items because the cabinets above the counters and sink are so very low. There is no counter space to work on. The HACP employees admitted that left over scraps and cabinets from the other apartments and seconds were used to build the kitchen which is totally useless except for people who just eat TV dinners, fast food, and do not do home cooking as I must do for my diets. Please excuse the typographical errors but I am having much difficulty typing this document because this laptop that I have borrowed has a large number of glitches to it and maybe even a virus. ADA COMPLIANCE RECOMMENDATIONS FOR HOMES AND APARTMENTS A. ENTIRE HOUSE and/or APARTMENT 1. Should be painted with white semi-gloss enamel (water based) for easy maintenance and for one to be able to see what is soiled and what is not. The white paint does not absorb the light as much as other paints do and this in combination with the "Full Spectrum" blue daylight bulbs make living in a lighted space a much more pleasant experience. 2. All floors should be even and very easy to maintain and keep dean. All walls behind baseboards and otherwise should be free of holes so that no debris from inside the walls can come through and contaminate the living quarters (especially where disease and germs may have gathered from leaks from the outside roof where birds and other animals may have been). The floors should be constructed of a type of tile that will endure the daily wear and tear of a wheelchair and be easy to maintain There are very good and relatively inexpensive ceramic floor tiles with matching ceramic tiles for baseboards. The color should be white or white marble that would match any kind of furniture and that would enable one to see, quickly, where something has fallen. Seniors and many of the handicapped residents may have significant vision problems. No floors should be carpeted unless the residents want such. Residents in manual wheelchairs with heart problems find it extremely difficult to push oneself on carpeted floors and it is extremely exhausting. 3. Track lighting should be throughout the house or apartment (ceiling and/or walls or both). Many handicapped residents have special needs that cannot be satisfied successfully with everyday conventional lighting systems. Track lighting also permits better distribution of light rays. Lights behind glass build up heat creating a dangerous situation and the lighting is obscured. With track lighting, light can be directed into the areas where desired. 4. Telephone jacks should be in every room of a handicapped resident's home or apartment. Not all tenants can afford cell phones and they just are not appropriate for all residents. A telephone or a computer or whatever can be connected in a bedroom or where the handicapped person needs to use a piece of communications equipment. Sometimes a resident is confined to a bed and cannot get up to use the telephone or computer or whatever. Being told to purchase 50 foot cords is asking for trouble and leads to very serious accidents. 5. Special security systems are required for the handicapped residents and the electronic doors must be supported by a deadbolt system that cannot be opened with the same electronic system, if the resident requests this. With the electronic system intact and the door locked, I was able to enter my apartment within three (3) seconds with just a small piece of plastic from a milk carton. Also, will I only an electronic system, anyone with access to the locking system (when dealing with notorious landlords), can gain access into a handicapped resident's apartment within one (1) or (2) seconds. This can be an extremely dangerous situation. A handicapped person should be able to enter a special night code that no one can break to assure that no one can enter when the resident is asleep or when the resident is out and then is surprised by the intruder when the resident returns home. B. KITCHEN 1. Except for the kitchen sink (which should be a double stainless steel sink with a surrounding lip that is large enough to prevent water from spilling over onto the floor), refrigerator and stove, nothing should be bolted onto the walls or the floors. Unless there is a spring-loaded counter that is attached to the wall (which I shall explain later). 2. Where desired, a spring-loaded type of counter with triangular supports extending out from the wall underneath this counter, with the wide end from the wall, that flip out ... one to the left and one to the right, should be installed at the height of an average folding banquet table. This would enable the resident to be able to sit and eat, cook, bake, etc. without constantly hitting a table leg with their wheelchair/motor scooter/power chair. No cabinets should be above tins area to obstruct the setting up of larger appliances which may be needed for whatever project the resident must place on this counter. These counters should always be of Formica which are easy to keep clean and will not bum or melt if a hot pot should be placed on it; nor will it stain if something is spilled onto it. These counters could be operated with an angular hydraulic cylinder anchored to the center of the counter, between the two flip-out support bars. This would prevent accidents that could be caused by a sudden drop or flipping up of these counters. White would be the best color because one would be able to see where to clean. 3. All cabinets should be on structurally sound rollers/wheels that can each be locked where and whenever necessary. Sometimes all rollers do not and cannot be locked at the same time. The movable cabinets make for easier cleaning and flexibility of the placement of kitchen appliances, tableware, pots-n-pans, and many other kitchen items. All cabinets should be of white laminated/durable surface which are easy to keep clean. They would blend into the walls and would appear to even be a part of the wall for esthetic purposes which would make for a more pleasant living situation. Movable cabinets can be moved around as a resident's situation changes. Something this could be because of permanent health changes or sometimes this could be because a resident believes that moving some cabinet to a different location might suit their temporary physical impairment better or whatever. 4. All cabinets should have pull out shelves/drawers that extend halfway out and that are securely supported from beneath them This enables the wheelchair resident to easily gain access to the items that are on the shelves and assists in preventing accidents. There are cabinets that open from the front and from the side. There are drawers that open from tile front and side and can be easily moved (when on rollers) to various parts of the kitchen for easy access to the items needed. These cabinets should have deep shelves and/or drawers that measure approximately twenty-our (24) inches deep and/or approximately up to at least 30" wide. For example, such a cabinet, with a Formica top, should be placed between the stove and the refrigerator so that items from the refrigerator can be placed on this counter cabinet (with drawers that are deep to the depth of the stove with each drawer about nine inches or twelve inches(9" or 12")high. Large drawers in this area are needed to keep large utensils, pot holders, a can of baking soda, dish towels, dish cloths, and other large items. Again, the cabinet should be on sturdy rollers that can lock and the cabinet can be rolled out to clean under, around and in back of it. There are such nice white laminated cabinets on the market. They have them for all areas of the home and can be used effectively in all rooms where large bulky furniture would take up much room (e.g. bedroom sets which provide small storage areas but take up a tremendous amount of space. There are even book shelves that measure up to fourteen and one-half inches (14 1/2 ") deep and come in all heights and widths and styles. There are even short cabinets thirty inches (30") to thirty-six inches (36") high with drawers and/or pull-out shelves for storage areas where one can place lamps, plants, and whatever on top. 5. Some cabinets could have drawers that are on a carrousel in a cabinet behind a door or two (2) doors. These drawers could be secured with a locking system that releases as it turns a comer. The locking system would prevent the drawer from tipping forward or backward and it could be easily installed. I can just picture it. This could be a manual or an electrical device and would depend on the handicapped resident. 6. There should be a telephone jack near the kitchen in the event that there is an accident or one bums oneself and so forth. An area easy to crawl to. 7. Sinks must be double for washing and rinsing and with a surrounded slanted down lip to prevent water from spilling onto the floor. The sinks should be equipped with a high spout similar to those in hospitals that loop down and can be turned at the base from left to right. 8. The refrigerator should have a large freezer and refrigerator area because the handicapped Resident, on a fixed income, must purchase in bulk the sale items in order to be able to have enough food to cat, especially when they have to be on a diabetic, low sodium, low fat, low acid and/or any other special diet. The racks and storage bins should not be made out of polystyrene nor glass nor any other type of fragile material as these materials become even more brittle when cold. All racks should be heavy duty wire racks and the storage bins should be of heavy duty nylon type of plastic or metal. 9. All oven doors should open to the right or left but not down in front as it is much too difficult to reach into the oven without burning oneself. C. BATHROOM 1. All bathrooms should have a double-roll bathroom tissue holder for a backup. This can be a most difficult situation for handicapped residents. 2. All bathrooms should have cabinets on rollers. 3. All cabinets should be of a white laminated surface for easy maintenance/cleaning with a material that will welcome a moist environment and not warp or become mold ridden. 4. All cabinets should have pull out drawers/shelves and be free from attachment to any walls in the event it is necessary to create a larger movement area. 5. All commode tanks should have a flat top surface so that items can be placed on the tank top without them falling over and onto the floor or onto a residents foot. 6. All commodes should have lids that sustain the weight of each resident so that, if necessary, the resident may sit upon the lid in an emergency to rest or whatever. They should be of shatterproof plastic if not wood. 7. All bathrooms should have deep sinks with an attached counter that residents can use to place their medical supplies on and work from without having these items constantly fall to the floor. The sink/counter area should have a slanted down area around the raised/rounded edges to prevent water from spilling over onto the floor. 8. Grab bars should be installed to suit the needs of each individual resident and high enough above the commode for a spare roll of bathroom tissue to be placed on the tank top. A solution would be what the hotels do and that is they have shorter tanks. 9. The sink faucet must be high and looping down like those in hospitals and be able to turn from left to right as needed. 10. The tub or shower must have a lever that can be moved from left to right for hot to cold settings (e.g. a stick on a wheel). 11. The shower head on a flexible hose should have the ability to set the amount of pressure and Temperature as a handicapped resident or senior citizen cannot get up to make these adjustments from where they are sitting because they could fall and seriously injure themselves. 12. Light fixtures should not be opaque. They should be of clear glass and shining down from above a mirror or ceiling to give off more light. Many accidents occur in bathrooms because of poor vision and lighting. D. BEDROOM 1. There should be a telephone jack where the resident's bed is to be situated in the bedroom so that the resident can have the telephone on a night stand with a drawer where emergency numbers, supplies, etc. can be kept. The system where one pulls a strin for help is only all right for additional convenience but cannot be the solution in a true emergency where time is of the essence. One must have immediate access to one's physician, emergency police/fire/ambulance services and the telephone is the only answer. Without this necessary telephone equipment, one could lose their life. E. CLOSETS 1. All closets should be installed with adjustable shelves and rods to suit all types of individuals from the very short to the very tall. Tall people need space to hang their dresses, coats, skirts, suits, robes, etc. without these items hanging on the floor. ADA COMPLIANCE RECOMMENDATIONS FOR PUBLIC TRANSIT SYSTEMS A. LOCK-IN SYSTEMS FOR MANUAL WHEELCHAIRS, MOTOR SCOOTERS, and POWER CHAIRS. 1. No lock system should require a handicapped passenger 10 be placed so that the passenger is facing backwards. This is an extremely uncomfortable position with regard to the motion issue and could and will cause passengers to vomit. An embarrassment for the passenger and a dirty clean-up job for the bus driver not to mention health issues and an extremely unpleasant situation for the other passengers. 2. The best system I tried was the front facing pneumatic lock-in system where the handicapped passenger is totally independent and does not have to ask the bus driver nor anyone else for anything. 3. Hand bars should be placed along the entire wall of the vehicle where the handicapped equipment will be stationed so as to accommodate anyone silting anywhere in the designated areas. 4. The ramps should be eliminated because they are difficult for manual wheelchairs to use and because in many cases one ruins their motor scooters when the ramp is too steep in the event that a curb is not accessible. The previous lift system was much better as it could pick up a anyone directly from the street or curb. 5. ADA COMPLIANCE RECOMMENDATIONS FOR MOTOR SCOOTER MANUFACTIJRERS A. MANUFACTIJRING 1. Manufacturers should be required to develop and manufacture motor scooters that meet the following requirements: a. The motor scooter should be "Female Friendly" and come apart in at lease five (5) to six (6) pieces, snapping apart easily and snapping back together, again, without requiring the assistance of another individual. b. Scooters with a 500 pound limit should be built small enough for a smaller framed and lighter weight individual because these individuals would like to purchase a motor scooter so that they can do their grocery shopping using a three-wheeled scooter. This would provide true independence as para-transit is very costly and only permits one to carry two little bags On board. What a joke. e. Should come in basic colors like white metallic, black metallic, silver metallic, navy blue metallic, without any extra charge because it is embarrassing enough to have to use one. So, to make them in colors like red, bright green, bright blue, or any other flashy color should be special ordered. But to charge extra for the aforementioned colors is ridiculous. d. There should be stabilized metal equipment that folds out in tile back for places to put ones groceries that will hold securely and not break. e. There should be a place in the front for one's purse and other small packages. f. All motor scooters should come with solid tires that do not go flat and that grab well enough to travel on ice, snow and slippery surfaces. g. All motor scooters should have water proof controls on the stirring column and be manufactured so that water cannot enter the electrical component areas nor the battery areas when it rains. h. All motor scooters should have a re-charger like power chairs do to re-charge the battery as it is in use. There should also be an indicator panel that shows exactly how much energy is left in the battery.