Download pdf of Request for Supporting Letters to ANSI and the ANSI Press Release.
Download pdf of comments submitted by several professional organizations to the Architectural and Transportation Barriers Compliance Board
The American National Standards Institute (ANSI) has released its long-awaited national standard on classroom acoustics, officially known as ANSI S12.60-2002 American National Standard Acoustical Performance Criteria, Design Requirements, and Guidelines for Schools.
This standard covers the last of the three environmental requirements in a classroom that are vital for an effective learning environment - air quality, lighting and acoustics. The first two have been covered by building codes for many years. Omission of acoustical standards for classrooms was a serious oversight long overdue to be resolved.
Three trade organizations have appealed to ANSI to have the standard withdrawn. These are: the Air-Conditioning & Refrigeration Institute, (ARI), the School Facilities Manufacturer's Association (SFMA), and the Modular Building Institute (MBI). Each asserts that the standard is not in the public's best interests. Misrepresentation of added costs for implementing the standard have also been included in the appeals.
In keeping with the dedication of you and your colleagues in support of the standard and/or your related activity in educational audiology or with the hearing-impaired or as parents of hard-of-hearing children, we ask that you help counter the campaign to withdraw the standard. Specifically, we are asking for your help in soliciting or writing a letter of support to ANSI refuting the claim that the standard is not in the public's best interests .or that it will cost too much It is clearly in the public interest that education of children remains a continuing priority for the US. Withdrawal of this standard would allow acoustical barriers to learning to remain in classrooms that have improper architectural acoustics design and lack adequate noise control.
A letter from the President of your respective professional organization or from administrative (e.g. - school superintendents) or facility design personnel in the education infrastructure you may know would be especially helpful.
Letters should be addressed
Ms. Anne Caldas
Secretary of the Board of Standards Review (BSR)
American National Standards Institute
25 West 43rd Street, 4th Floor
New York, New York 10036
with a cc to:
Acoustical Society of America
35 Pinelawn Road, Suite 114E
Melville, NY 11747-3177
A copy, bcc if you wish, to each of us would also be much appreciated.
For maximum impact, the letters should be received by the end of September or, at the very latest, by the end of January, 2003. This will allow more time to marshal supporting associates.
David Lubman Lou Sutherland
14301 Middletown Lane 27803 Longhill Dr.
Westminster, CA 926783 Rancho Palos Verdes, CA 90275-3908
about the need for the standard is contained in the following press release
from ASA about approval and publication of the standard.
For additional information
Susan B. Blaeser, Standards Manager
New ANSI Standard on Classroom Acoustics Now Available!
Melville, NY, August 13, 2002 - The Acoustical Society of America (ASA) announced today that the long-anticipated American National Standard on classroom acoustics is now available. The Standard, officially known as ANSI S12.60-2002 American National Standard Acoustical Performance Criteria, Design Requirements, and Guidelines for Schools, provides helpful guidance to design professionals, educational facilities planners, and the general public, as well. This is the first time an ANSI Standard has addressed the application of good acoustical design for classrooms.
"This Standard is in the best interest of the American public and American school children and teachers. The criteria, requirements, and guidelines of this Standard are keyed to the acoustical qualities needed to achieve a high degree of speech intelligibility in learning spaces. If followed, this Standard removes acoustical barriers to learning. It provides equal access to education for a sizable minority of school children in the United States who may have mild-to-moderate hearing, learning, or attention deficits, suffer frequent ear infections, have limited English language skills, or may otherwise suffer from a substandard acoustical environment. For teachers, working in a classroom that conforms to this Standard can reduce or eliminate voice strain and reduce stress," said Paul Schomer, ASA's Standards Director.
This Standard was developed by Accredited Standards Committee S12, Noise, under the American National Standards Institute (ANSI) approved operating procedures. These procedures assure that the Standard represents the consensus of opinion among experts in the field. The working group that assisted S12 in drafting the Standard was Co-chaired by David Lubman and Louis C. Sutherland, each of whom is a well-respected expert in the field of classroom acoustics. The working group, funded in part by the U.S. Access Board, was open to experts from all fields related to this subject and enjoyed wide participation. In fact, it was five times the size of a typical working group. As with all working groups in S12, the experts volunteered their time and talents to serve the public through this project.
The American National Standards Institute, Inc. (ANSI) is the national coordinator of voluntary standards development and the clearinghouse in the USA for information on national and international standards.
The Acoustical Society of America is a nonprofit organization, founded in 1929. It is the premier international scientific society in acoustics, dedicated to increasing and diffusing the knowledge of acoustics and promoting its practical applications.
The Standard is available
for $35.00 per copy at the ASA Standards Store at http://asa.aip.org - just
click the Standards Store button on the ASA Home Page. Search for Standards
using document number, keyword, standard category or other criteria. The ASA
Standards Store uses the latest Oracle technology to make online credit card
purchases of printed or electronic copies easy and secure. For bulk orders,
please contact Susan B. Blaeser, Standards Manager, at the number given above.
ARCHITECTURAL AND TRANSPORTATION BARRIERS COMPLIANCE BOARD
Washington, D.C. 20004
In the Matter of
Americans with Disabilities Act )
Accessibility Guidelines for ) Interim Final Rules
Buildings and Facilities; ) 36 CFR Part 1191
State and Local Government Facilities) Docket No. 92-2
ALEXANDER GRAHAM BELL ASSOCIATION FOR THE DEAF, INC.
AMERICAN SPEECH-LANGUAGE-HEARING ASSOCIATION
AUDITORY-VERBAL INTERNATIONAL INC.
NATIONAL CENTER FOR LAW AND DEAFNESS
NATIONAL CUED SPEECH ASSOCIATION
SELF HELP FOR HARD OF HEARING PEOPLE, INC.
The Alexander Graham Bell Association for the Deaf Inc., the American Speech-Language-Hearing Association (ASHA), Auditory-Verbal International Inc., the National Center for Law and Deafness, the National Cued Speech Association and Self Help for Hard of Hearing People Inc., (SHHH) submit these comments to the Architectural and Transportation Barriers Compliance Board (ATBCB) in response to its Interim Final Rule, Americans with Disabilities Act (ADA) Accessibility Guidelines for Buildings and Facilities; State and Local Government Facilities.
Properly designed architectural acoustics is fundamental to access to the communications process. A poor acoustical environment is an architectural barrier to people with hearing, speech, language and visual impairments every bit as much as a set of stairs might be considered to be a barrier for a person in a wheelchair. The removal of acoustical/communication barriers and/or designing acoustically accessible rooms often requires no structural changes but rather requires only the addition of acoustical sound-absorbing materials to correct the situation. Carpet, acoustical wall panels, acoustical baffles or acoustical ceilings are some of the corrective measures that easily can be employed. Frequently such measures do not involve significant financial commitment and may in fact be considered "cost effective" given the shear numbers that such measures accommodate.
The issue of Architectural acoustics, to enhance access to communication and minimize conditions which negatively impact or limit one's ability to hear, speak, and understand speech within a building has been omitted in the proposed ADAAG guidelines and we recommend its inclusion. Those modifications make for a better listening and less stressful environment for everyone, but also can make the difference between understanding and not understanding speech for people who are hard of hearing performing their duties as citizens and children in school trying to learn.
In the course of daily activities the variable affecting communication most frequently is the acoustical environment. Unfortunately, there is little understanding by those most frequently involved in building design and architecture with respect to how profoundly the acoustical environment impacts the ability to hear and the daily activities of people who are hard of hearing.
While poor room acoustics, have
a negative impact especially on people who are hard of hearing and people with
other types of communication impairments (speech, language) and disabilities
(learning, attention deficit disorders), people who have normal hearing frequently
have similar difficulties. (ASHA, 1992) (1) Poor acoustical environments have
a negative and discriminatory impact on far more people of all ages than is
thought to be the case.
Poor acoustics are a problem in the types of buildings covered by Title II of the ADA. Buildings that have been designed without proper attention to acoustics typically have a prevalence of sound reflective surfaces. It is not uncommon in many schools and courthouses for the floors, walls, ceilings, chairs, desks and other furniture to be made from hard sound reflective materials.
Every space in a building where
communication takes place will be impacted by the acoustical environment. The
two acoustic conditions present in most school classrooms, courtrooms, and civic
buildings that negatively impact speech understanding, are reverberation and
noise. Both significantly interfere with speech understanding for people with
hearing loss, especially for those who use hearing aids. Reverberation is the
persistence of reflected sound energy or the echo effect. It is exacerbated
in spaces with large volumes and minimal or no sound-absorbing finish materials.
This echo effect is measured as reverberation time. Technically, this is the
time, in seconds, that it takes for a sound to decrease 60 decibels (dB) after
it has been turned off in the room. The more reflective or reverberant the room,
the longer it takes for the sound to decrease 60 dB.
Examples of Reverberation Times (at 500/1000 Hz) include:
Studies have been done that show that children with hearing loss, even when wearing hearing aids, have significant difficulty hearing, and therefore learning, in an environment with a high reverberation time and perform poorer than hearing peers in this situation. (Crum, 1974; Crum & Matkin, 1976; Finitzo-Hieber, 1988; Finitzo-Hieber & Tillman, 1978; Flexer, 1989; Flexer, Millen & Brown, 1990) (2)
The second factor is background
noise or any unwanted sound from outside or inside the building that interferes
with the person's ability to understand speech. Outside noise can come when
a building is placed in an area of high vehicular traffic or aircraft activity,
or in the case of schools, from activities on playgrounds and sports fields.
Extraneous noise also can come from mechanical installations inside the building.
For example, air conditioning systems, heating and water installations, fluorescent
lamps, copiers, machines, and printers.
Though hearing aids help individuals to hear by amplifying sound, they do not restore normal hearing. One situation that is difficult for individuals with hearing loss is the presence of background noise because hearing aids amplify both the background noise and the speech signal. The comparison of the level of the noise to the level of the speech signal is called the signal-to-noise ratio. Research with children in school shows that to create the optimal listening environment the signal-to-noise ratio should be at least +15 dB and the reverberation time no greater than 0.2 seconds.
Both reverberation and background noise are major problems in state and local government buildings but both can be overcome or greatly reduced by the installation of sound absorbing materials on floors, walls, and ceilings. Care in the selection of the building location and orientation mitigates unwanted background noise. For example whenever possible, schools should be built on a large lot in a quiet district and classrooms should be situated away from noise sources such as sports fields and playgrounds.
Twenty eight million Americans have hearing loss. (3) Of those, more than 10 million are the result of noise exposure. The National Institutes of Health reports that hearing damage due to noise is a growing but avoidable problem. In a study done in the state of Tennessee, 3.8% of sixth grade children had significant hearing loss. Eleven percent of ninth and twelfth grade students failed hearing screenings at frequencies above 2000 Hz; 30.2% of 2,769 incoming freshmen (age 16-21) failed frequencies above 2000 Hz. To confirm this finding, a follow-up hearing screening of incoming freshmen the next year yielded 60.7% of 1,410 students failing frequencies above 2000 Hz. (Lipscomb, 1972) Patrick Brookhouser, otolaryngologist and director of Boys Town National Research Hospital, Institute for Communication Disorders, states that U.S. military services have had to lower their hearing standards in recruits because so many adolescents applying for induction had suffered noise-induced hearing loss.
Academic lags in excess of one year have been found in children with hearing loss in the range of 15 to 26 dB in the better ear. (Quigley, 1978) While elementary school children with moderate hearing loss (from about 40-55dB) perform an average of three years behind their normally hearing counterparts on academic achievement tests. This need not be. Given effective, consistent,and continuing auditory management, proper acoustical environments and amplification systems and support services, many hard of hearing children could function in a regular classroom similar to their normally-hearing peers. (Davis, 1977)
Children who are hard of hearing may be helped enormously by the use of assistive listening devices in the classroom. (Flexer, 1992) These systems should be incorporated in all educational settings.
Another crucial form of help that is nearly always overlooked is improved acoustical modifications to classrooms such as installing wall-to-wall carpet, acoustical ceiling tile, and sound-absorbing wall treatment. Successful functioning in the regular classroom may be dependent upon the acoustic nature of the classroom in which the child is placed because significant difficulty in discriminating speech in the classroom may be the most important factor affecting performance. (Davis and Hardick, 1981) A child who is hard of hearing has difficulty with auditory comprehension of connected speech under noisy conditions and shows significant breakdown compared to normally hearing peers. Carpeting, sound-absorbing ceiling tiles, and other sound-absorbing materials, greatly overcome the barriers to maximizing speech intelligibility for children who are hard of hearing in the classroom. Architects, educators, and school administrators need a better understanding of the impact of acoustics on people and their ability to learn. School administrators have the responsibility to ensure that buildings designed by their architects meet adequately the needs for all people. The facilities must support the teacher's ability to deliver and the student to receive clear and distinguishable instruction.
Hearing aids also are sensitive
to magnetic noise from sources such as transformers and some forms of lighting.
This magnetic noise can cause the hearing aid to pick up a hum that interferes
with speech understanding. This is particularly a problem when using a hearing
aid with a telephone coil. (T-coil) A T-coil is a magnetic induction pick up
coil mounted inside the hearing aid. It allows a person to use the hearing aid
with the telephone without interference from environmental sounds. Particular
care needs to be taken in the placement of public telephones. An evaluation
of the contemplated site needs to be made to check for sources of interference
and the presence of excessive background noise. If public telephones are located
close to sources of electromagnetic interference, hearing aid users will be
subjected to a loud hum and be unable to hear on the phone even using the T-coil.
If a telephone has to be located in a particularly noisy environment, it should
be carefully oriented and at least partially enclosed to minimize distracting
Our intent, through these comments, is to suggest that the Access Board includes in its ADA guidelines requirements for the design of new and altered buildings taking into consideration the acoustical and communication access environment. We would like to see ADA guidelines that set specific targets for reverberation time and noise levels. The targets we recommend are noise levels in unoccupied classrooms not exceeding 30 dB(A), and reverberation times (RT) not exceeding 0.4 seconds across frequencies. We urge that technical studies be reviewed if needed and/or authorized to provide the appropriate technical support for the inclusion of minimum architectural acoustics criteria for Title II buildings as part of 36 CFR Part 1191. Attached here for your reference are the American Speech-Language-Hearing Association (ASHA) Position Statement and Guidelines for Acoustics in Educational Settings, (1994) developed by the ASHA Subcommittee on Acoustics in Educational Settings of the Bioacoustics Standards and Noise Standards Committee, and related technical reports that document research to support acoustics criteria.
There is available the technical expertise to provide sufficient quality and quantity of acoustical materials to support and enhance the communication process. Without guidelines for architects and their clients to reference, architectural acoustics is a matter that all too frequently is overlooked.
Thank you for the opportunity to
comment on the interim final rule. We hope that you will give consideration
to our recommendations regarding architectural acoustics. These modifications
make communication in a building more accessible for everyone and significantly
impact the ability of individuals with hearing loss to understand spoken language.
Deputy Executive Director, SHHH
December 16, 1994
(1) American Speech-Language-Hearing Association (ASHA) (1992). Listening and Hearing: A Supplement to Technology in the Classroom. Rockville, MD: ASHA.
(2) American Speech-Language-Hearing Association, (in press). Position Statement and Guidelines for Acoustics in Educational Settings. Rockville, MD: ASHA.
(3) National Institute on Deafness
and Other Communication Disorders Advisory Board (1991). Research in Human Communication
(NIH Publication No. 92-3317). Annual Report. Bethesda, MD: NIDCD.
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Last updated on 06SEP02.