Since it was first published in 1935, the Manual on Uniform Traffic Control Devices (MUTCD) has evolved from a 166-page document to standardize road signs and pavement markings to an 1161-page guide that has been described as the bible of American road design. It prescribes what is–and isn’t–acceptable when it comes to signs, signals, markings, and other traffic control elements on public roadways.
Over time, what was intended only as a road sign and markings standard is now relied on by traffic engineers across the country as a guide to roadway design, public safety, and accessibility – functions it was not designed to fill.
The 11th edition of the MUTCD, published on December 19, 2023, takes a large step back from those roles, clarifying its role in standardizing traffic control devices and referring engineers to the Americans with Disabilities Act and Section 504 of the Rehabilitation Act of 1973 for guidance on accessibility.
In this article, we review the most significant changes in the 11th edition as they relate to pedestrian push buttons, delving into the reasoning behind the changes and the likely significance for intersection design. We then summarize each of the sections of the 11th edition that relate to crosswalk buttons, giving you a handy reference to find each of the requirements for accessible pedestrian signals, audible information devices, and standard crosswalk buttons.
Major changes from 2009
A review of 3 major changes between the 2009 and 11th editions that affect crosswalk buttons.
1. Removal of APS warrants
The most striking change related to pedestrian buttons in the 11th edition MUTCD is the excision of all language about when accessible pedestrian signals (APS) should be used.
The guidance to conduct an engineering study to determine if APS are required was removed. Proposed language from the draft 11th edition to recommend APS at every pedestrian signal was not included in the published manual.
Instead, Chapter 4K.01.01 contains this new statement:
“The decision of when to use accessible pedestrian signals is subject to requirements of the Americans with Disabilities Act and Section 504 of the Rehabilitation Act of 1973.”
The FHWA clarified their decision in the Federal Register Prologue:
“Upon consideration of all comments received, FHWA is removing all text from the MUTCD discussing when APS “should” be considered or provided. The decision of when to use APS is subject to requirements of the Americans with Disabilities Act and Section 504 of the Rehabilitation Act of 1973. Notably, since the 2009 edition of the MUTCD, multiple courts have recognized that the ADA and Rehabilitation Act require jurisdictions to make their pedestrian signals accessible. See Am. Council of Blind of Metro. Chicago v. City of Chicago, No. 19 C 6322, __F. Supp. 3d __, 2023 WL 2744596, at **6–8 (N.D. Ill. Mar. 31, 2023); Am. Council of Blind of New York, Inc. v. City of New York, 495 F. Supp. 3d 211, 232–38, 241–42 (S.D.N.Y. 2020); Scharff v. Cnty. of Nassau, No. 10 CV 4208 DRH AKT, 2014 WL 2454639, at *12 (E.D.N.Y. June 2, 2014). As with other sections of the MUTCD that address certain accessibility issues, FHWA refers users to the applicable ADA and Rehabilitation Act requirements and limits discussion of APS to technical specifications. The MUTCD does, however, include language in Support statements with information about the importance of APS in general and, in particular, at certain kinds of crossings.”
MUTCD Federal Register Prologue (part 4. Highway Traffic Signals – Accessible Pedestrian Signals Engineering Study Requirement). Emphasis added. Link to source >>>
The requirements the FHWA is referring to are these:
“No qualified individual with a disability shall, by reason of such disability, be excluded from participation in or be denied the benefits of the services, programs, or activities of a public entity, or be subjected to discrimination by any such entity.”
The Americans with Disabilities Act (ADA), Title II – 42 U.S.C. § 12132. Emphasis added. Link to source >>>
“No otherwise qualified individual with a disability in the United States… shall, solely by reason of her or his disability, be excluded from the participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance.”
Section 504 of the Rehabilitation Act – 29 U.S.C. § 794(a). Emphasis added. Link to source >>>
The courts have been extraordinarily clear, consistently finding the ADA requires accessible signals. Reviewing the three court cases cited by the FHWA above, the unanimity of decision is striking:
- “The act of installing and maintaining pedestrian crossing signals at crosswalks is a normal function of the County, and therefore falls within the scope of Title II and the Rehabilitation Act.” Scharff v. Cnty. of Nassau. Link to source >>>
- By failing to provide APS, NYC “failed to provide [pedestrians with vision disabilities] with meaningful access to its signalized intersections and the pedestrian grid, within the meaning of the ADA and Rehabilitation Act.” Am. Council of the Blind of New York, Inc. v. City of New York. Link to source >>>
NYC was ordered to equip 9,050 intersections with APS by 2031, and all remaining signalized intersections by 2036.
- Chicago does not provide pedestrians with vision disabilities “‘meaningful access’ to its network of pedestrian signals in violation of the ADA and the Rehabilitation Act.”
Council of the Blind of Metro. Chicago v. City of Chicago. Link to source >>>
Summary judgement against Chicago; remedial action not yet determined.
The legal precedent is clear: the courts have found Title II and Section 504’s prohibition of discrimination against people with disabilities is a positive requirement to make public facilities accessible, including pedestrian signals.
Conclusion: Pedestrian signals provided by a public entity, and/or funded with Federal financial assistance, are required by the ADA and Section 504 to be accessible to people with disabilities.
Note this requirement comes from the ADA Title II and Section 504 of the Rehabilitation Act, independent of the MUTCD and PROWAG, and is enforceable now. Two of the largest cities in the US were found in violation of this legal requirement before PROWAG was published, specifically because they had installed visual pedestrian signals that were not accessible to pedestrians with vision disabilities.
2. Changes to pedestrian signal head warrants
Leading pedestrian intervals (LPI) are a proven pedestrian safety measure, giving pedestrians a brief exclusive crossing time that gives them a head-start on turning vehicles and increases their visibility. §4D.02 now requires pedestrian signals at all intersections with LPI timing; these signals are necessary for pedestrians to know and take advantage of the extra time.
It has also been established that, without APS, LPI timing makes the crossing more dangerous for pedestrians with vision disability. Without the rush of parallel traffic to signal the beginning of the WALK phase, vision-disabled pedestrians are likely to miss the LPI and cross late, in the path of turning vehicles. Using APS at these crossings removes this hazard and allows pedestrians with low vision or blindness to enjoy the benefit of the LPI timing.
If all pedestrian signals must include APS, as we established in the previous section of this article; and now §4D.02 requires pedestrian signals at all intersections with LPI timing; then all intersections with LPI timing must have APS – making these crossings safer for all pedestrians, not just those with 20/20 vision.
Additionally, this section recommends pedestrian signals at all marked crossings with traffic signals. This new guidance, if followed, is likely to have a large positive effect on pedestrian safety by reducing conflicts with traffic at intersections where pedestrian facilities have until now been minimal.
3. Support for use of AID with warning beacons
The 2009 MUTCD had minimal support for audible information devices (AID), referring to them in the context of temporary traffic control zones only. The 11th edition greatly expands this, recommending AID at rectangular rapid flashing beacons (RRFBs), pedestrian-activated flashing beacons, and in-roadway warning lights.
Using AID instead of the standard inert crosswalk buttons at pedestrian warning lights makes these life-saving devices accessible to pedestrians with vision disabilities. It is not a perfect solution – the lack of a vibrating indication on the AID button means pedestrians who have both vision and hearing disabilities may not know the warning lights are on – but it is the best option currently available for these unsignalized crossings.
Section by section breakdown
A reference guide to the MUTCD 11 passages relevant to pedestrian push buttons.
CHAPTER 4D. DESIGN FEATURES OF TRAFFIC CONTROL SIGNALS
Section 4D.02 Provisions for Pedestrians (p.667)
SUMMARY: Was §4D.03. This section recommends pedestrian signal heads at all marked crossings with a traffic signal, and allows them elsewhere based on engineering judgment. It requires pedestrian signal heads at intersections with an exclusive pedestrian signal phase or a leading pedestrian interval (LPI), at signalized school crossings, and at certain high-risk pedestrian crossings.
MEANING: The requirement for pedestrian signals at every crossing with LPI timing, and the guidance that every marked crossing at a traffic signal have pedestrian signals, are both new. On its own, this is an incremental improvement in pedestrian safety; but taken with PROWAG’s requirement for accessible pedestrian push buttons at every pedestrian signal, this is a significant step forward.
CHAPTER 4I. PEDESTRIAN CONTROL FEATURES
Section 4I.05 Pedestrian Detectors (p.720)
SUMMARY: Was §4E.08. This section provides guidance on the placement and signage of “pedestrian detectors,” which can be buttons or passive pedestrian detection. It also gives reach ranges and clearances for pedestrian buttons.
MEANING: These placement guidelines reference those given in the 2010 ADA Accessibility Standards, and appear to be compatible with PROWAG. They clarify the ideal locations for pedestrian push buttons. A minor improvement from the 2009 edition.
Section 4I.06 Pedestrian Intervals and Signal Phases (p.725)
SUMMARY: Was §4E.06. Among other things, this section requires median-mounted pedestrian signals for long crossings, allows leading pedestrian intervals (LPIs) at high-conflict crosswalks, and supports using accessible pedestrian signals (APS) with median-mounted pedestrian signals and LPIs.
MEANING: Long crossings where pedestrians must cross to the median and then wait for a second WALK phase can strand vision-disabled pedestrians on the median unless an APS is present. Polara strongly recommends APS be installed at all median pedestrian signals.
LPIs are a proven pedestrian safety measure for the general population, but have significant drawbacks for people with low vision or blindness that can make crossing more dangerous for them. Having only visual signals and no rush of parallel traffic to signal the beginning of the WALK phase can lead vision-disabled pedestrians to cross in the path of turning vehicles. Using APS at these crossings removes this hazard. Polara strongly recommends APS be installed at all pedestrian signals where LPIs are used.
Section 4J. PEDESTRIAN HYBRID BEACONS
Section 4J.02 Design of Pedestrian Hybrid Beacons (p.729)
SUMMARY: Was §4F.02. Among other things, this section covers the placement of pedestrian hybrid beacons (PHBs). The new material adds support for using APS with PHBs.
MEANING: PHBs need pedestrian signal heads and APS for safe pedestrian crossing. While the MUTCD no longer offers guidance on when APS should be used, support passages like this one explain the role APS fills at these crossings.
CHAPTER 4K. ACCESSIBLE PEDESTRIAN SIGNALS AND DETECTORS
Section 4K.01 General (p.731)
SUMMARY: Was §4E.09. This section describes the functions of APS and the factors that make crossing the street difficult for pedestrians with vision disabilities. It requires APS be used with pedestrian signal timing, that APS be specific to each crossing and activated by the pedestrian button for that crossing, if any, and that APS be active 24/7.
This section allows APS to be activated by passive pedestrian detectors, for APS at pretimed signals to be activated by pedestrian buttons, and for the inclusion of Braille or raised character street names and/or tactile crosswalk maps.
MEANING: The MUTCD 11th edition now gives APS their own chapter. The most significant change in this section is the removal of the 2009 edition’s guidance to conduct engineering studies at difficult crossings to determine if APS is needed. Instead, the 11th edition refers engineers to the accessibility requirements established by the Americans with Disabilities act and Section 504 of the Rehabilitation Act of 1973.
We consider this a significant change for the reasons given earlier, and tantamount to an official recognition by the FHWA that existing federal accessibility laws require accessible pedestrian signals.
Section 4K.02 Location (p.732)
SUMMARY: Was §4E.10. This section clarifies that APS should be located as Section 4I.05 directs, requires median-mounted APS in crossings with a median landing and short pedestrian clearance time, and specifies required features for APS located within 10 feet of another APS.
MEANING: This section is reiterative of sections 4I.05, 4K.03, and 4K.05. The changes from the 2009 edition in this section appear to be clarifications only, and not substantive.
Section 4K.03 Walk Indications (p.732)
SUMMARY: Was §4E.11. This section specifies requirements for APS audible and vibrotactile walk indications, including when to use a speech message or percussive tone, the phrasing and language used in speech messages and the frequency for percussive tones, and standards for audio volume.
MEANING: Most of the changes in this section from the 2009 edition are for clarity. One change that should be noted is the removal of the option to transmit APS messages to a personal receiver; another is the requirement that if spoken walk messages in a language other than English are used, the message should first be spoken in English and then alternate between the two for the duration of the walk interval.
Section 4K.04 Vibrotactile Arrows and Locator Tones (p.734)
SUMMARY: Was §4E.12. This section requires high-visibility vibrotactile arrows on the APS push button, aligned with direction of travel on the crosswalk, and gives specific timing and volume requirements for locator tones. Locator tones may deactivate outside of the pedestrian walk and clearance phases, if passive pedestrian detection is present to activate the locator tone when a pedestrian approaches.
MEANING: The only new material here is the provision for passive detection deactivating the locator tone while pedestrians are not present. This may alleviate noise concerns in some situations.
The guidance “Push button locator tones should be audible 6 to 12 feet from the push button, or to the building line, whichever is less” was a standard in the 2009 edition. In our experience, most noise complaints derive from equipment that was set improperly loud; if 4K.03’s requirement that locator tones automatically adjust to be a maximum of 5dBA above ambient noise is followed, noise concerns should be minimal.
The language in this section on the design and placement of the vibrotactile arrow section is clearer than in the 2009 edition.
Section 4K.05 Extended Push Button Press Features (p.734)
SUMMARY: Was §4E.13. This section gives specifications and options for audible beaconing and information message activated by extended button presses.
MEANING: This section offers stronger support for audible beaconing than was present in the 2009 edition, and narrows the ways in which it may operate down to one: the tone should come from a speaker mounted 7-10 feet above the far end of the crosswalk.
CHAPTER 4L. RECTANGULAR RAPID FLASHING BEACONS
Section 4L.02 Design of Rectangular Rapid Flashing Beacons (p.736)
SUMMARY: Not present in 2009 edition. Among other things, this section requires an R10-25 sign if pedestrian buttons are used to activate rectangular rapid flashing beacons (RRFBs), recommends audible information devices (AID) be used with RRFBs for accessibility, and allows activation confirmation lights visible from the crosswalk.
MEANING: The 11th edition MUTCD supports the use of AID at unsignalized crossings where traditional crosswalk buttons would activate warning lights like RRFBs. Replacing traditional buttons with AID will make these beacons accessible to a much wider range of pedestrians.
Section 4L.03 Operation of Rectangular Rapid Flashing Beacons (p.738)
SUMMARY: Not present in 2009 edition. Among other things, this section requires AID to not have vibrotactile or percussive indications, and recommends the spoken message be “Warning lights are flashing”, rather than the “Yellow lights are flashing” message specified by the now-discontinued Interim Approval 21.
MEANING: This is not significantly different from IA-21. These RRFB provisions are a welcome improvement over the 2009 edition.
CHAPTER 4S. FLASHING BEACONS
Section 4S.03 Warning Beacon (p.752)
SUMMARY: Was §4L.03. Among other things, this section allows pedestrian- or bicyclist-activated flashing warning beacons to increase safety at crossings and elsewhere; recommends these warning beacons be activated with an AID whose speech message states “Warning lights are flashing” twice; and requires such AID to not have vibrotactile or percussive indications.
MEANING: Everything to do with AID in this section is new to the 11th edition; a strongly positive change. Replacing traditional buttons with AID will make these beacons accessible to a much wider range of pedestrians.
CHAPTER 4U. IN-ROADWAY WARNING LIGHTS
Section 4U.02 In-Roadway Warning Lights at Crosswalks (p.757)
SUMMARY: Was §4N.02. Among other things, this section recommends In-Roadway Warning Lights be activated with an AID whose speech message states “Warning lights are flashing” twice; and requires such AID to not have vibrotactile or percussive indications. It requires an R10-25 sign if a button rather than a passive pedestrian detector is used to activate the warning lights; and if the time the lights flash after activation is only long enough to walk to a media landing, a way to activate the lights again must be available in the median.
MEANING: Again here, all of the provisions relating to AID are new to the 11th edition. Functionally identical to the provisions for AID with flashing beacons and RRFBs, and our same comments apply here.
CHAPTER 6C. PEDESTRIAN AND WORKER SAFETY
Section 6C.02 Pedestrian Considerations (p.779)
SUMMARY: Was §6D.01. The provisions of this section that are related to pedestrian push buttons recommend, “when temporary pedestrian pathways in TTC zones are designed or modified”, that important route, sign, and signal information be communicated to people with vision disabilities, including through APS and AID.
MEANING: Temporary traffic control (TTC) zones pose particular hazards to pedestrians with low vision or blindness; communication of safe routes must be clear. While this section does not require audible information devices, it does support their use where appropriate. Paragraph 12 (support for the use of APS in TTC zones) is new to the 11th edition.
Section 6C.03 Accessibility Considerations (p.780)
SUMMARY: Was §6D.02. This section requires temporary pedestrian facilities to have equivalent accessibility to the closed facilities they replace, and that a cane-detectable barrier be placed across the closed facility. It recommends important route, sign, and signal information be communicated to people with vision disabilities, including through AID, cane-detectable barriers, and “tactile and/or vibrating surface devices.” (This phrase describes an APS, and is new to the 11th edition; the 2009 edition here said “accessible pedestrian signal” specifically.)
This section also recommends any button used to communicate with pedestrians with vision disabilities should have a locator tone to help them find the button- in other words, these buttons should be AID.
This section supports the use of AID as an accessible equivalent to visual signs, but recommends wherever possible establishing a channelized route detectable with a cane.
For further guidance on accessible temporary pedestrian facilities, this section of the 11th edition MUTCD now directs engineers to the Guidelines for Accessible Pedestrian Signals, the 2010 ADA Standards for Accessible Design, and the ADA.
MEANING: Support for APS and AID is notably increased over the 2009 version of this section. Support for personal receivers for audible sign information was weak in the 2009 edition; the 11th edition removed it from this section entirely. The paragraph 4 standard used to require the cane detectable barrier across a closed route only “[w]here pedestrians with visual disabilities normally use the closed sidewalk”; now cane detectable barriers are required across closed routes in all cases.
This section refers engineers to existing federal accessibility law and regulations; more evidence that the FHWA does not regard the MUTCD as the primary standard for accessibility, and further, that they acknowledge the ADA’s pre-existing requirement for equal access to public facilities and services.
CHAPTER 6L. OTHER TTC ZONE TRAFFIC CONTROL DEVICES
Section 6L.01 Temporary Traffic Control Signals (p.824)
SUMMARY: Was §6F.84. Among other things, this section adds support for the use of APS at crossings controlled by temporary traffic control signals (paragraph 5).
MEANING: Pedestrian crossings in work zones, where fencing and equipment may make pedestrians less visible and worksite noise may mask the sounds of traffic, can be more hazardous to pedestrians with vision disabilities than usual. Polara strongly recommends the use of APS at TTC zone crossings.