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ADA Requirements for Vending Machines

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#1
mission vending

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A webinar hosted by NAMA:





ADA Requirements for Vending Machines

Join us for a Webinar on March 21
ADA Requirements for Vending Machines - approximately 30 minute presentation with question and answer session. The Webinar is limited to the first 100 participants, so please register as soon as possible.
Title: American's With Disabilities Act Requirements for Vending Machines
Date: Wednesday, March 21, 2012
Time: 2:00 pm - 2:30 pm EDT
After registering you will receive a confirmation email containing information about joining the Webinar
System Requirements
PC-based attendees
Required: Windows® 7, Vista, XP or 2003 Server

Macintosh®-based attendees
Required: Mac OS® X 10.5 or newer

Space is limited.
Reserve your Webinar seat now at:
https://www4.gotomee...ister/217484359


#2
Shauna

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Registered. It'll be interesting to see what is going on...

#3
mission vending

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Registered. It'll be interesting to see what is going on...


Cool, was hoping someone would. I couldn't participate. Would love to hear about afterwards if you don't mind.

#4
Shauna

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Cool, was hoping someone would. I couldn't participate. Would love to hear about afterwards if you don't mind.


I'll take notes and post them on the forum.

#5
caserri

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I'll take notes and post them on the forum.


Fantastic! Thanks Shauna.

Sent from my Android using Tapatalk.

#6
Vendors Tech

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I registered as well. Looking forward to finding out how the latest attack on small businesses will affect us vendors. I hear that the new law "requires" that things as insignificant as the coin insert will have to be located at a certain degree level. Can you imagine the money vendors will have to spend to upgrade or replace machines to meet just that condition alone????

#7
Shauna

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I registered as well. Looking forward to finding out how the latest attack on small businesses will affect us vendors. I hear that the new law "requires" that things as insignificant as the coin insert will have to be located at a certain degree level. Can you imagine the money vendors will have to spend to upgrade or replace machines to meet just that condition alone? ???


From what I have read, currently placed machines will be grandfathered for the new ADA requirements. But any remodelling of the company your machine is placed in will necessitate you upgrading your machine to a ADA-compliant machine. I guess we'll find out more on the webinar.

#8
Vendors Tech

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From what I have read, currently placed machines will be grandfathered for the new ADA requirements. But any remodelling of the company your machine is placed in will necessitate you upgrading your machine to a ADA-compliant machine. I guess we'll find out more on the webinar.


That makes a LITTLE more sense.

#9
mission vending

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From what I have read, currently placed machines will be grandfathered for the new ADA requirements. But any remodelling of the company your machine is placed in will necessitate you upgrading your machine to a ADA-compliant machine. I guess we'll find out more on the webinar.


That;s the way i understand it as well. when we did the City of San Antonio contract a number of years ago it was a requirement that all machines meet current ADA guidelines. As for the remodeling, sometimes it will and sometimes it won't, there is a threshold (have no idea what it is) that has to be crossed to trigger ADA compliance.

#10
Shauna

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That;s the way i understand it as well. when we did the City of San Antonio contract a number of years ago it was a requirement that all machines meet current ADA guidelines. As for the remodeling, sometimes it will and sometimes it won't, there is a threshold (have no idea what it is) that has to be crossed to trigger ADA compliance.


You're right. I'd have to go back and see what the percentage of upgrades or remodeling would trigger the need for a new or updated machine.

#11
Technivend

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The problem with the ADA laws is that they written very openly. Technically the machine is not a permanent structure so in most instances should be exempt (they use the analogy that if you take the building and tip it upside down if it falls it is exempt). There is also the interpretation that if you replace a motor you have modified the machine then you are required to be within compliance. now all machines would not need to be compliant if you have doubles. For example, if you have two beverage machines as long as all the product is duplicated only one needs to be in compliance.

Technically any carousel machine unless the product has been duplicated on the bottom selections has not been compliant for years. Most old machines once a validator is installed are not compliant. Again this is all up to the interpretation of your location. Don't try arguing ADA laws as you will lose. You can try "thats interesting I didn't see that anywhere in the uses can you point that out to me?" approach but it will usually fail.

The wording is to ambiguous for a law and leaves to much room for interpretation.

Bottom line is this. If the location tells you they want ADA machines you need to give them ADA machines. Be prepared that some large chains may want to be in compliance even though they do not need to be. So to keep the location you will need to comply.

#12
Shauna

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Here are my notes from the call today. Once I receive a copy of the slideshow, I'll post that as well...

American's With Disabilities Act Requirements for Vending Machines
The 2010 Standards
Barbara Elkin
Attorney-Advisor
US Department of Justice
New Regs 9/15/2010
Same presentation at the Nama OneShow last year

compliance with revised standards required as of March 15, 2012
side reach range changed to 15 - 48 inches
compliance required for new installation, replacements or alterations to an existing machine
if the machine is "fixed" it must comply with the ADA standards
"fixed" is generalized as being built into the structure or building, attached to the wall or floor (not freestanding)
ADA uses the upside down test (not legal), if the building was turned upside down, if it falls to the bottom, it is not condsidered fixed

a machine is not "fixed" by virtue of plugging it into the wall
attaching a machine to the wall by bolt constitutes "fixed"
coffee machines that are plumbed into the building water system constitutes "fixed" (any type of water access will make the machine "fixed")

alteration: change to a machine that will affect the usability of the machine
remodeling, renovation or changes or rearrangements of structural parts
i.e. adding a bill acceptor
need to meet the standards

fixed machines compliant with 1991 requirements are not required to be modified until they alter or replace the machine due to the "safe Harbor" clause

multiple machines on one location: at least one of each type of vending machines shall comply with ADA standards
different products in machines indicate different type of machine (requires same access to all products in any machine)
different floors will need at least one compliant machine per floor
entire operable part must be within reach range

www.ada.gov
replacement of a machine is considered putting in a new machine
civil penalties for non compliance
up to $55,000 for the first violation

non-fixed machines are suggested to follow guidelines, but not required
covered entities are the businesses where vending machines are located


If anyone has any questions, I'll try to answer them the best I can based on what I heard.

#13
Shauna

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Here is the slideshow from the call this afternoon, just in case anyone wants to look at it.




And thanks to Technivend for this FAQ on ADA regs.

Attached Files



#14
Vendors Tech

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I missed the webinar, had to catch up on serving my route. I tried to make it back to the office in time, but didn't. Thank you for posting notes...

#15
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Here is more from the Vending Times quoting a DOJ official:

http://www.vendingti...CE06ECA4F5502B0

#16
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Here is some more stuff from Automatic Merchandiser:

http://www.vendingma...ow-in-las-vegas