JUL 31 1992
T. 7/31/92
SBO:NM:kgf
DJ# 192-16i-00057



Thomas S. Mollet
Director of Marketing
GameTime
P.O. Box 121
101 Kingsberry Road
Fort Payne, Alabama 35967

Dear Mr. Mollet:

     This is in response to your letter concerning requirements
for playgrounds under the Americans with Disabilities Act (ADA).

     Title II of the ADA covers playgrounds owned and operated by
State and local government entities, and title III of the ADA
covers playgrounds that are privately owned and operated.

     Under title III, privately owned public accommodations and
commercial facilities must design facilities in accordance with
the title III accessibility guidelines, which appear as an
appendix to the Department of Justice's title III rule. Under
title II, public entities can choose to design facilities either
in accordance with the title III guidelines or in accordance with
the Uniform Federal Accessibility Standards. Neither of those
standards, however, contains specific sections on playgrounds.
Guidelines for recreational facilities are currently in the
process of being developed by the Architectural and
Transportation Barriers Compliance Board, an independent Federal
agency. Until such time as those guidelines are finalized,
playgrounds need not be built in compliance with any specific
design standards.

     I hope this information has been helpful to you.

                                   Sincerely,



                              Stewart B. Oneglia
                                    Chief
                         Coordination and Review Section
                              Civil Rights Division

:udd:milton:adaletters:mollet.playground
cc: Records, CRS, Friedlander, Milton


01-01098
GameTime
               P.O. BOX 121/101 KINGSBERRY ROAD/FORT PAYNE, ALABAMA 35967
               TELEPHONE - (205) 845-5610 * TELEX: 782-534 GAME TIME FTPY
                                FACSIMILE NUMBER: (205) 845-2649
                                        June 1, 1992

U.S. Department of Justice
Civil Rights Division
Ms. Stewart B. Oneglia  Chief
Coordination and Review Section
P.O. Box 66118
Washington, D.C. 20035-6118


Dear Ms. Oneglia:

I am writing to you for guidance and clarification of the A.D.A. regulations, 
especially as they pertain to playground and recreation equipment.

GameTime is one of the largest providers of park and playground equipment in
the world. We have been developing and building playground equipment for over
63 years, with 5 years of this effort being devoted to developing playground
events for the needs of disabled individuals. Obviously, we take a very keen
interest in the need to provide accessibility to play events for as many
children as is possible.

It is with great interest that I write to you to get clarification of the
A.D.A. rules that have been issued. Specifically, GameTime would like to know
what specific guidelines we have to build playground equipment to. We want to
make sure that we are building the safest, most affordable play equipment
possible.

Please feel free to contact me with any questions or ideas you might have. I
may be reached at 1-800-633-2394 ext. 5251.

Sincerely,



Thomas S. Mollet
Director of Marketing










               IMAGINEERED SCHOOL, PARK AND PLAYGROUND EQUIPMENT
01-01099