Article written by Jonathan Hansen, Draftsman at ADACC an ICC Certified Accessibility Inspector/Plans Examiner.
If a summer blockbuster reverberates throughout a movieplex and no one is around to hear it, does it
still make a sound? Conversely, suppose that it doesn’t make a sound at all. A few years back, in 2011, The Artist was released in theaters and attracted audiences across the globe. Critics received it well, in spite of the fact that it was a French-made, black-and-white silent film. Well, mostly silent. Almost the entire movie is silent, but that didn’t keep moviegoers from giving this film a try. Not only was it a box-office success, but it won numerous accolades as well. After it won Best Picture at the Academy Awards, I recall a local talk radio show playing “clips” from the movie throughout the program, which were 10-15 second intervals of complete silence. Some listeners failed to grasp the humorous intent and called in to the radio program, trying to tell them that something was wrong with their clips because all they could hear was silence.
What if this was typical of your movie-going experience; not being able to hear the inflection or pitch of the actor’s voice, the rise of the orchestral score, or the funny song that makes the scene laugh-out-loud funny? It’s not a hypothetical question for the thousands of people who have partial or complete hearing loss. And that leads us to these questions: what are the CBC accessibility requirements for movie theaters, and what accommodations can be made for disabled patrons who enjoy the big screen experience?
1.) Exterior Path of Travel. First and foremost, an accessible path of travel must always be provided to your facility, meaning a compliant, 48” wide, unobstructed accessible route from the accessible parking spaces in your parking lot, accessible passenger loading zones, and even the public sidewalk (See our blog focusing on “Site Arrival Points“)
2.) Ticket Counters. Unless they’ve printed out tickets at home, most patrons still line up to purchase their tickets at the box office. These sales counters need to be accessible, requiring a counter surface that is 36” long (min.) and 34” high (max.) above the finish floor for parallel approach. A counter with a forward approach requires the same surface length and height, but must also provide knee clearance that it at least 27” high, 30” wide and 19” deep. The clear floor or ground space is the typical 30” (min.) by 48” (min.) unobstructed, level floor. If the counters have security glazing, a method to facilitate voice communication must be provided. Compliant assistive listening devices can facilitate voice communication at counters or ticket windows. Where assistive listening devices are installed, compliant signage should be in place to identify those facilities which are so equipped.
3.) Interior Path of Travel. Make sure that there is an unobstructed path between all interior accessible elements and spaces that can be negotiated by a person with a disability using a wheelchair and that is safe and usable by persons with other disabilities. Common focus points would be: concession areas, drinking fountains, hallways, and last-but-not-least, accessible multi-accommodation restrooms (which we are often grateful for, after a 2-hour long movie!).
4.) Designated Aisle and Semi-Ambulant Seats. At least 5% of the total number of AISLE seats provided shall be “designated aisle seats”, located closest to accessible routes. When armrests are provided on seating in the immediate area, folding or retractable armrests shall be provided on the aisle end of the seat. Each designated aisle seat shall be identified by a sign or marking with the ISA symbol. At least 1% of the total number of seats, and no fewer than 2, shall be semi-ambulant seats which provide at least 24” clear leg space between the front of the seat to the nearest obstruction or seat immediately in front. The inclusion of both of these types of seats is essential, because they accommodate people who have a mobility disability but who wish to use a seat that is not in a wheelchair space location.
5.) Wheelchair Spaces and Companion Seats. We all know that it can be tricky just to find a good seat in a crowded theater. Consider what a person using a wheelchair might experience, if a space was not available to him. Wheelchair spaces, which consist of the typical 30” (min.) by 48” (min.) clear and level floor space are an important requirement to take note of. Where 2 adjacent wheelchair spaces are provided, each space may be 33” wide (min.). Where a wheelchair space can only be entered from the side, that space shall be 60” deep (min.). Theaters must include and designate these spaces on risers or cross-aisles in such a way that the spaces adjoin accessible routes. The required number of wheelchair spaces differs based on the total number of seats that the theater provides. A theater with 150 seats, for example, must have at least 4 wheelchair spaces, whereas a theater with only 50 seats must have 2 (see Table 11B-184.108.40.206 included).
These wheelchair spaces must either be located within the rear 60% of the provided seats OR they must be located at a part of the theater in which the vertical viewing angles (measured to the top of the screen) are from the 40th to the 100th percentile of vertical viewing angles for all seats as ranked from the seats in the first row (1st percentile) to seats in the back row (100th percentile). These wheelchair spaces shall provide spectators with choices of seating locations and viewing angles that are substantially equivalent to, or even better than, the seating locations and viewing angles available to all other spectators. Theaters with more than 300 seats must disperse wheelchair spaces at varying distances from the screen, still providing compliant viewing angles. A line of sight must be provided to users of wheelchair spaces that allows them to see the screen over the head of seated spectators who are sitting in the first row in front of the wheelchair spaces. Or, where spectators are provided lines of sight over the shoulders and between the heads of spectators in the first row in front of their seats, spectators in wheelchair spaces shall be afforded lines of sight over the shoulders and between the heads of seated spectators in that first row in front of those spaces.
Lastly, at least 1 “companion seat” shall be provided for each wheelchair space. In row seating, companion seats shall be located to provide shoulder alignment with adjacent wheelchair spaces. This alignment point shall be measured 36” from the front of the wheelchair space. The floor surface of the companion seat shall be at the same elevation as the floor surface of the wheelchair space. Companion seats may be movable, but they must provide equivalent facilitation, having the same size, quality and comfort as other seating in the immediate area.
6.) Assistive Listening System (ALS). As I hope I implied earlier, people who have suffered hearing loss still want to be able to attend the showing of any movie in any theater at any time, enjoy the experience with their family or friends, and have equal access to the movie content through high quality captioning that is readable and readily available. An ALS is a permanently-installed amplification system utilizing transmitters, receivers, and coupling devices to bypass the acoustical space between a sound source and a listener. Assembly areas, such as movie theaters, are required to provide ALS complying with CBC Section 11B-706 and shall provide compliant signage informing patrons of the availability of the ALS (preferably at the ticket windows, posted in a prominent place). Such signage shall include wording that states “Assistive-Listening System Available” and shall also include the compliant ISA for Hearing Loss. It would be unfortunate to have a great system that nobody even knows about! Ensure that your patrons know what features are available to provide them the best movie-going experience! It is helpful to identify the location or person to contact for obtaining the system.
Now on to the receivers, themselves. The MINIMUM number of receivers provided shall be at least 4% of the total number of seats, but in no case less than 2. And 25% MINIMUM of those receivers provided, but no fewer than 2, must be hearing-aid compatible in compliance with CBC Section 11B-706.3. We’re skipping the more technical aspects of the ALS, but should you require more information on the subject, the federal Access Board has published technical assistance on assistive listening devices and systems. One last side note: as a theater-owner, it is good practice to ensure your staff checks the batteries of these devices (and headphones if that applies) to ensure that the devices are in good, clean, working order. Some prefer to bring their own headphones (or neckloops, see below), but it is good business practice to clean all usable equipment after each use.
Many people now have neckloops which are essentially personal listening accessories worn around the neck and that connect to a sound source. The neckloop converts the input sound signal to electromagnetic waves which radiate from the wire loop. Hearing aids equipped with telecoils, or “t-coils” will pick up these signals and act as little speakers in the listener’s ears. Inductive neckloops can plug into any device that has a headphone jack. Are your receivers compatible with the use of a neckloop? Time to check on them!
7.) Captioning. We really need to mention captioning, because people who have severe or complete hearing loss may not be able to utilize the ALS. Captioning is known to most of us and sometimes goes by another name, “Subtitles”, especially if we’re utilizing that particular feature of a Blu Ray or DVD. This is the text of dialogue, music, or can also be the descriptive text associated with a movie scene, all in realtime. Those of us accustomed to watching foreign-made movies have utilized this function on many occasions because we don’t understand the languages being spoken in certain movies. Or perhaps we miss a word or can’t comprehend a sentence that was uttered, so we switch this feature on while enjoying a movie at home. It’s a handy feature!
But what about enjoying that same feature on the big screen? There are many advocates for including captioning on all movies that come to the big screen, and there are essentially two kinds of captioning: 1.) Closed Captioning is type of captioning that can be turned on and off by the viewer. 2.) Opening Captioning is captioning that is always on the screen, in view, that cannot be turned off. There are a mix of advantages and disadvantages to each form, and the problem with the 2010 ADA was that it did not explicitly state that captioning must be provided, or in what form. Perhaps setting a precedent, however, in 2010 the 9th Circuit Court of Appeals (Arizona regional court) ruled that closed-captioning would need to be provided by theaters. Later, in July of 2010, the US Department of Justice (DOJ) released an Advanced Notice of Proposed Rulemaking that made it clear closed captioning of movies would be considered a reasonable accommodation. Since then, numerous theaters have upgraded their systems to digital formats that provide captioning services for new movies coming to the big screen. This technology is amazing and keeps seeing new innovation.
The Rear Window Captioning system made its way into many theaters, providing closed captioning services without displaying such captions to the entire audience. This service doesn’t require special film prints or separate screenings since the captions are not on the film itself.
Other breakthrough technology provides closed captioning systems transmitted by infrared broadcasts straight to a seat-mounted display or (and this one is my favorite) even straight to the user’s custom eyewear/glasses provided by the theater, similar to 3-D glasses but specifically for captioning. Some new movies viewed with this eyewear are even accompanied by accessible, embedded audio tracks that describe the action on the screen (descriptive narration) for the sight-impaired or blind. We applaud theaters across California, and the rest of the US, that have taken the initiative and stepped up to incorporate these innovations into their theaters, making advances in accessibility that will allow more and more disabled patrons to fully enjoy the movie-going experience.
Are you ready for the next blockbuster to hit your screen? Have a great summer and save me some popcorn!