EWG:Draft Aug 17

Editorial Working Group > Working Draft created August 17

TEITAC Working Draft - August 17, 2007.

This draft has been updated by the September 3 Working Draft. 

This page is the working draft with the latest versions of the work of the TEITAC. It contains all updates since the July 18 Draft. This is the draft people should review for use at the September 4-6, 2007 plenary meeting.

To make reading easier see the August 17 draft without metada.

Contents 1 Subpart A 1.1 Section 1194.1 Purpose 1.1.1 Version 1 1.1.2 Version 2 1.2 Section 1194.2 Application 1.2.1 Version 1 1.2.2 Version 2 1.3 Section 1194.3 General Exceptions 1.3.1 1194.3 - A - Intelligence Or Security Systems 1.3.2 1194.3 - NEW - Emergency, Field and First Response Use 1.3.3 1194.3 - B- Incidental To A Contract 1.3.4 1194.3 - C - Employees Not Individuals With Disabilities 1.3.5 1194.3 - D - Access By Public 1.3.6 1194.3 - E - Fundamental Alteration 1.3.6.1 Version 1 1.3.6.2 Version 2 1.3.6.3 Version 3 1.3.6.4 Version 4 1.3.6.5 Version 5 1.3.7 1194.3 - F - Service Areas 1.3.7.1 Version 1 1.3.7.2 Version 2 1.3.7.3 Version 3 1.3.8 1194.3 - G - Narrow, Delineated Use 1.3.8.1 Version 1 1.3.8.2 Version 2 1.4 Section 1194.4 Definitions 1.4.1 Agency 1.4.2 Alternate Formats 1.4.3 Alternate Methods 1.4.4 Application Software 1.4.5 Assistive Technology 1.4.6 Authoring Tools 1.4.7 Auto-updating 1.4.8 Captions 1.4.9 Closed Product Functionality 1.4.10 Comparable Access 1.4.11 Content 1.4.12 Content Format 1.4.13 Contrast Ratio 1.4.14 Decoration 1.4.15 Electronic and Information Technology 1.4.16 Freestanding 1.4.17 General Flash and Red Flash Thresholds 1.4.18 Information Technology 1.4.19 Informational Animation 1.4.20 Interactive Elements 1.4.21 Large Scale Text 1.4.22 Menu 1.4.23 Operable Controls 1.4.24 Other Services To Cooperate With Assistive Technologies 1.4.25 Peak Non-crisis Network Traffic 1.4.26 Personal-Private 1.4.27 Platform Accessibility Services (was Accessibility Services) 1.4.28 Platform Software 1.4.29 Product 1.4.30 Programatically Determined 1.4.31 Real-time Text 1.4.32 Relative Luminance 1.4.33 Shared-Public 1.4.34 Telecommunications 1.4.35 Terminal 1.4.36 TTY 1.4.37 Undue Burden 1.4.38 Video Description 1.4.39 Web Content 1.4.40 Web Page 1.4.41 World Wide Web 1.5 Section 1194.5 Equivalent Facilitation 2 Technical Provisions 2.1 1. Requirements for All Product and Services 2.1.1 1.1 Functional Performance Criteria 2.1.1.1 1.1-A - Without Vision 2.1.1.2 1.1-B - With Limited Vision 2.1.1.3 1.1-C - With Color Vision Deficits 2.1.1.4 1.1-D - Without Hearing 2.1.1.5 1.1-E - With Limited Hearing 2.1.1.6 1.1-F - Without Speech 2.1.1.7 1.1-G - With Limited Reach, Strength, or Manipulation 2.1.1.8 1.1-H - With No Reach or Touch 2.1.1.9 1.1-I - With Cognitive, Language or Learning Limitations 2.1.2 1.2 General Technical Requirements 2.1.2.1 1.2-A - Closed Products Functions 2.1.2.2 1.2-B - Flashing 2.1.2.3 1.2-C - Biometric ID 2.1.2.4 1.2-D - Pass Through 2.1.2.5 1.2-E - Audio information 2.1.2.6 1.2-F - Visual Information 2.1.2.7 1.2-G - Color 2.1.2.8 1.2-H - Text size 2.1.2.9 1.2-I - Contrast 2.2 2. Hardware Aspects of Products 2.2.1 2.1 All Products with Hardware 2.2.1.1 2.1-A - Contrast for displays 2.2.1.2 2.1-B - Contrast for labels 2.2.1.3 2.1-C - Mechanical Controls 2.2.1.4 2.1-D - Touch Operated 2.2.1.5 2.1-E - Standard Connection 2.2.1.6 2.1-F - Free-Standing 2.2.2 2.2 If the Product has Speech Output or Throughput 2.2.2.1 2.2-A - Magnetic Coupling 2.2.2.2 2.2-B - Interference with Hearing Device 2.2.2.3 2.2-C - Audio Connection 2.2.2.4 2.2-D - Volume 2.2.2.5 2.2-E - Volume (Gain) 2.2.2.6 2.2-F - Volume Reset 2.3 3. User Interface and Electronic Content Provisions 2.3.1 3-A - Color 2.3.2 3-B - Contrast 2.3.3 3-C - Non-text content 2.3.4 3-D - Human Language 2.3.5 3-E - Language of Parts 2.3.6 3-F - Pausing 2.3.7 3-G - Flashing 2.3.8 3-H - Consistent Identification 2.3.9 3-I - Size, shape, location 2.3.10 3-J - Audio Turnoff 2.3.11 3-K - Reading Sequence 2.3.12 3-L - Repeated Blocks 2.3.13 3-M - Link Purpose 2.3.14 3-N - Information and Relationships 2.3.15 3-O - User Interface Components 2.3.16 3-P - User Preferences 2.3.17 3-Q - Color Adjustment 2.3.18 3-R - Disruption of Access Features 2.3.19 3-S - Timing 2.3.20 3-T - Keyboard Operation 2.3.21 3-U - Focus Cursor 2.3.22 3-V - AT Interoperability 2.3.23 3-W - Both platform and Application 2.3.24 3-X - Advisory Notes 2.3.24.1 1. Suppression of unneeded function 2.3.24.2 2. Writing guidelines 2.3.24.3 3. Interaction guidelines 2.4 4. Additional Provisions for Audio-Visual Players or Displays 2.4.1 4-A - Caption Playback 2.4.2 4-B - Supplemental Audio Playback 2.5 5. Additional Provisions for Real-time Voice Conversation Functionality 2.5.1 5-A - Accessibility Configuration 2.5.2 5-B - Real-Time Text Reliability and Interoperability 2.5.3 5-C - Voice Terminal Hardware and Software 2.5.4 5-D - IVR, Auto-Attendant and Messaging 2.5.5 5-E - Caller and Status Information 2.5.6 5-F - Video Support 2.6 6. Audio and/or Video Content 2.6.1 6-A - Synchronized Alternatives 2.6.2 6-B - Captions and Transcripts 2.6.3 6-C - Video Description 2.6.4 6-D - Open or Closed Captions/Descriptions 2.6.5 6-E - Interactive Elements 2.7 7. Information, Documentation and Support 2.7.1 7.1 Product Documentation and Help 2.7.1.1 7.1-A - Accessible Documentation and Features 2.7.1.2 7.1-B - Keyboard Shortcuts 2.7.1.3 7.1-X - Advisory Notes 2.7.1.3.1 1. Context-sensitive help 2.7.1.3.2 2. Text descriptions 2.7.1.3.3 3. User interface descriptions 2.7.2 7.2 Support and E&IT related services 2.7.2.1 7.2-A - Support Services 2.7.2.2 7.2-X - Advisory Notes 2.7.2.2.1 1. Remote assistance 2.8 8. Content Format and Authoring Tools 2.8.1 8.1 If a Content Format 2.8.1.1 8.1-A - Non-text Objects 2.8.1.2 8.1-B - Multimedia (Format) 2.8.1.3 8.1-C - Reading Order 2.8.1.4 8.1-D - Table Headers 2.8.1.5 8.1-E - Complex Table Headers 2.8.1.6 8.1-F - Interactive Elements 2.8.1.7 8.1-G - Links 2.8.1.8 8.1-H - Embedded Comments 2.8.1.9 8.1-I - Images of Text 2.8.1.10 8.1-J - Dynamic Information 2.8.2 8.2 Additional requirements for Web Content Authoring Tools 2.8.2.1 8.2-A - Accessible Output 2.8.2.2 8.2-B - Preserve Accessibility Information 2.8.2.3 8.2-C - Prompts 2.8.2.4 8.2-D - Evaluation Support 2.8.2.5 8.2-E - Accessible Templates

Subpart A

The Subpart A subcommittee has a action item from the July 16-18 meetings to summarize all issues and concerns so they may be discussed at the next meeting for resolution.

Editorial notes

• For Subpart A only the current text is included, to facilitate discussion.
• For Subpart A only the metadata is omitted, as this subpart, by definition, applies to all.

Updates and discussion for provisions in this section

Section 1194.1 Purpose

There are two proposed new versions

Current Text
The purpose of this part is to implement section 508 of the Rehabilitation Act of 1973, as amended (29 U.S.C. 794d). Section 508 requires that when Federal agencies develop, procure, maintain, or use electronic and information technology, Federal employees with disabilities have access to and use of information and data that is comparable to the access and use by Federal employees who are not individuals with disabilities, unless an undue burden would be imposed on the agency. Section 508 also requires that individuals with disabilities, who are members of the public seeking information or services from a Federal agency, have access to and use of information and data that is comparable to that provided to the public who are not individuals with disabilities, unless an undue burden would be imposed on the agency.

Version 1

The purpose of this part is to implement section 508 of the Rehabilitation Act of 1973, as amended (29 U.S.C. 794d). Section 508 requires that when Federal agencies develop, procure, maintain, or use electronic and information technology, Federal employees with disabilities have access to and use of information and data THAT IS TIMELY, ACCURATE, COMPLETE AND EFFICIENT WHEN COMPARED to the access and use by Federal employees who are not individuals with disabilities, unless an undue burden would be imposed on the agency. Section 508 also requires that individuals with disabilities, who are members of the public seeking information or services from a Federal agency, have access to and use of information and data THAT IS TIMELY, ACCURATE, COMPLETE AND EFFICIENT WHEN COMPARED to that provided to the public who are not individuals with disabilities, unless an undue burden would be imposed on the agency.

Version 2

Insert provision to address comparable access in Section 1194.2 Application

Discussion or Rationale In either approach, it is recommended that new explanatory information be provided:

• Timely access means that individuals with disabilities have information and data available to them at the same time as individuals without disabilities, but that does not preclude captions that are slightly delayed or other reasonable differences in timing given individual situations.
• Accurate means that the information and data reflects the intended meaning especially when converted into another form or media.
• Complete means that all critical information and data is present when accessed by assistive technology or converted into another form or media.
• Efficient means that an individual with a disability exerts a reasonably similar or comparable amount of effort (given the capacity of current assistive technology) in using electronic and information technology as compared to an individual without a disability.

Access may be delivered via built-in access features or compatibility with assistive technology as described in the technical standards specified in XXX.)

• Status: Done
• Text from Subcommittee
• Source: {508}1194.1,
• Impact:
• External Reference:
• Testability:

Section 1194.2 Application

This provision has alternative versions. Each version and its rationale or justification are listed below.

Current Version
(a) Products covered by this part shall comply with all applicable provisions of this part. When developing, procuring, maintaining, or using electronic and information technology, each agency shall ensure that the products comply with the applicable provisions of this part, unless an undue burden would be imposed on the agency.

(1) When compliance with the provisions of this part imposes an undue burden, agencies shall provide individuals with disabilities with the information and data involved by an alternative means of access that allows the individual to use the information and data.

(2) When procuring a product, if an agency determines that compliance with any provision of this part imposes an undue burden, the documentation by the agency supporting the procurement shall explain why, and to what extent, compliance with each such provision creates an undue burden.

(b) When procuring a product, each agency shall procure products which comply with the provisions in this part when such products are available in the commercial marketplace or when such products are developed in response to a Government solicitation. Agencies cannot claim a product as a whole is not commercially available because no product in the marketplace meets all the standards. If products are commercially available that meet some but not all of the standards, the agency must procure the product that best meets the standards.

(c) Except as provided by §1194.3(b), this part applies to electronic and information technology developed, procured, maintained, or used by agencies directly or used by a contractor under a contract with an agency which requires the use of such product, or requires the use, to a significant extent, of such product in the performance of a service or the furnishing of a product.

Version 1

Add new Introductory statement:
In general, this section applies only to the (consideration, provisions or determination- need to determine which word to be used) of accessibility in the process of developing, procuring, maintaining, or using electronic and information technology.)

Rationale for Version 1 This additional language is intended to clarify that all of the regulations in this section that impact agency procurement procedures, apply only to the consideration of accessibility. The additional language is not intended to provide regulatory direction regarding how agencies consider other factors, such as business and technical needs and requirements, when making an acquisition. The FAR defines procurement parameters for a number of agencies and agencies need to determine how to address accessibility within the parameters of other required procurement considerations and processes. The workgroup has discussed the fact that there have been varying interpretations of how Section 508 should be applied when making an acquisition. In some cases there is the expectation that accessibility should trump agency business needs and other requirements. This language clarifies that accessibility must be determined within the parameters of Section 508, but does not purport to direct agencies as to how to make overall procurement decisions. Agencies are required to consider accessibility within the framework of other regulated procurement practices such as the FAR. Some subcommittee members indicated that this limitation was sufficiently provided via § 1194.1 Purpose and the new language was not necessary.

Version 2

(This would change only sub item #2 of paragraph (a), and paragraph (b).)

(2) When DEVELOPING, procuring, MAINTAINING, OR USING a product, if an agency determines that compliance with any provision of this part imposes an undue burden, the documentation by the agency supporting the DEVELOPMENT, procurement, MAINTANENCE, OR USE shall explain why, and to what extent, compliance with each such provision creates an undue burden.

(b) When procuring a product, each agency shall procure products which comply with the provisions in this part when such products are available in the commercial marketplace or when such products are developed in response to a Government solicitation. Agencies cannot claim a product as a whole is not commercially available because no product in the marketplace meets all the standards. If products are NOT commercially available that meet all of the standards, the agency must procure the product that best meets THE AGENCIES BUSINESS NEEDS AND the APPLICABLE ACCESS standards.

New Note for Procurements: To facilitate the determination of the product best meeting the provisions of this part, those provisions that apply for a given acquisition should be enumerated during the process of determining business and technical requirements.

Discussion or Rationale

• Rationale for changes to paragraph 2: Undue burden clause in prior regs only applied to procurement. Assumed oversight- revision to clarify the application of undue burden to development, maintenance and use in addition to procurement.

• Rationale for changes to paragraph b: Clarifies the use of “best meets” when products are not commercially available that comprehensively meet each and every standard, but might partially meet one or more individual standards or meet some but not all of the standards. Improves understanding of clause

• Rationale for the additional text: When attempting to clarify how 508 should be applied to determine accessibility the workgroup devised two approaches: (1)Adding the “In general” language preceding the Application section noted above and/or (2) Adding a notation to Procurement section of the Application Section. The note was intended to provide explanatory information regarding inclusion of accessibility provisions in the process of developing business and technical requirements. The subcommittee did not reach consensus on the inclusion of the note and at the July TEITAC plenary meeting there was general agreement to not include the addition of the "Note for Procurements".. Concerns were voiced that the Note was confusing and inconsistent with the addition of the introductory language.

• Some subcommittee members also voiced support for removing (b) in total and deferring all procurement decision-making procedures to the Federal Acquisition Regulations (FAR) and/or other governing procurement policies. The Access Board and FAR will be simultaneously considering the 508 regulations- this presents an opportune time for GSA and the Access Board to consider how to ensure best provide guidance for agencies to implement 508 within the procurement process.

• At the July meeting, the committee discussed changing "product" to "E&IT" throughout

• Status: In Progress
• Text from Subpart A
• Source: {508}1194.2
• Impact:
• External Reference:
• Testability:

Section 1194.3 General Exceptions

1194.3 - A - Intelligence Or Security Systems

This part does not apply to any electronic and information technology operated by agencies, the function, operation, or use of which involves intelligence activities, cryptologic activities related to national security, command and control of military forces, equipment that is an integral part of a weapon or weapons system, or systems which are critical to the direct fulfillment of military or intelligence missions.

Systems which are critical to the direct fulfillment of military or intelligence missions do not include a system that is to be used for routine administrative and business applications (including payroll, finance, logistics, and personnel management applications).

Status: In progress
Source: {508}1194.3

Work in Progress:

• Proposed addition to this section of "Physical prerequisites for personnel, also known as "fitness for duty", are not valid basis to meet national security or other exceptions in this part."

1194.3 - NEW - Emergency, Field and First Response Use

This part does not apply to any electronic and information technology operated by agencies in a field environment where the function, operation, or use is by a first responder, emergency, security, or law enforcement personnel. This exception does not apply to the agency systems administrative and business applications (including payroll, finance, logistics, and personnel management applications) or any application or system that is intended for use by members of the public.

Rationale Currently the national security exception directly addresses the accessibility exception for electronic and information technologies used as integral parts of weapons or weapons systems, in command-and-control, cryptological activities, and for direct support of intelligence and military missions. The underlying theme of that exception is often what might be considered emergency, or field conditions, and physical requirements as a prerequisite for employment. These same conditions are met in situations such as first responders, fire-fighters, law-enforcement personnel in the field, etc. Because of this similarity some Federal agencies such as Department of Homeland Security, Department of Justice, some portions of the Department of the Treasury, for example, encounter Section 508 acquisitions situations which mirror those in the national Security exception, but which are uncovered now. This requires that the agencies either apply fundamental alteration exception to such purchases, which is not always the most accurate fit, or conduct the market research and take accessibility requirements in to account during the process for items never to be used by people with disabilities. While Section 508 standards are intended to lower barriers to employment, they are not intended to remove all such barriers where disabilities and performing the job are in practice and reality mutually exclusive. Note, first responders in practice can be Federal employees or members of the public; however this exception is not based upon this status, rather the work to be performed and the location that work is performed.

• Impact:

Economic impact: Low This exception will lower the analysis level of Federal requiring officials by addressing this specific situation directly, and lower their potential market analysis workload as well. It will not impact industry negatively as it is not a requirement that they must change business practices or products to meet.

• External Reference:

Definition of "first responder": From Homeland Security Presidential Directive 8, (HSPD8), the term "first responder" refers to those individuals who in the early stages of an incident are responsible for the protection and preservation of life, property, evidence, and the environment, including emergency response providers as defined in section 2 of the Homeland Security Act of 2002 (6 U.S.C.101), as well as emergency management, public health, clinical care, public works, and other skilled support personnel (such as equipment operators) that provide immediate support services during prevention, response, and recovery operations.
Note: adoption of this provision will require reference of the Definition of First Responder in §1194.4 Definitions.

• Status: New: no consensus reached
• Text from Subcommittee
• Source: New

1194.3 - B- Incidental To A Contract

This part does not apply to electronic and information technology that is acquired by a contractor incidental to a contract.

Status: Done
Source: {508}1194.3, no change

1194.3 - C - Employees Not Individuals With Disabilities

Except as required to comply with the provisions in this part, this part does not require the installation of specific accessibility-related software or the attachment of an assistive technology device at a workstation of a Federal employee who is not an individual with a disability.

Status: Done
Source: {508}1194.3, no change

1194.3 - D - Access By Public

When agencies provide access to the public to information or data through electronic and information technology, agencies are not required to make products owned by the agency available for access and use by individuals with disabilities at a location other than that where the electronic and information technology is provided to the public, or to purchase products for access and use by individuals with disabilities at a location other than that where the electronic and information technology is provided to the public.

Status: Done
Source: {508}1194.3, no change

1194.3 - E - Fundamental Alteration

This provision has five alternative versions, with rationales provided below

Versions 1-4 are recommended with the intent to clarify that a fundamental alteration should apply only to those products and components that are required by the agency to meet their business needs and mission.

Current Provision
This part shall not be construed to require a fundamental alteration in the nature of a product or its components.

Version 1

This part shall not be construed to require a fundamental alteration in the nature of the E&IT, or its components, OR THE AGENCY'S SPECIFIED PRODUCT REQUIREMENTS.

Rationale for Version 1: Version 1 limits the exception to the nature of the E&IT or its components and those requirements “specified by the agency” (assuming they are constructed in accordance with standard procurement procedures). This is the version is the same as the July 6 draft.

Version 2

This part shall not be construed to require a fundamental alteration in the nature of the E&IT, OR THE AGENCY'S INTENDED BUSINESS NEED, or its components.

Rationale for Version 2 Version 2 limits the exception to the nature of the E&IT or that which meets the agency’s “intended business need”. This approach does not specify that it also applies to components, but may be viewed as more open with regard to allowing the agency to tie the exception to the business need even if the requirements are not specified up front. This is the version is the same as the May 30 version.

Version 3

This part shall not be construed to require a fundamental alteration in the nature of the E&IT, or its components, OR THE AGENCY'S BUSINESS NEED.

Rationale for Version 3 Version 3 amends Version 2 to incorporate E&IT components

Version 4

This part shall not be construed to require a fundamental alteration in the nature of the E&IT, or its components, OR THE AGENCIES SPECIFIED PRODUCT REQUIREMENTS OR BUSINESS NEED.

Rationale for Version 4 The authors recommend that the TEITAC adopt Version 4 of the proposed language specifically to remind agencies that their implementation of Section 508 must support both the agency’s mission as well as their responsibilities under Section 508. Version 4 demonstrates how the discussion has evolved to clarify that E&IT (previously referred to as “product”) and components are covered. Version 4 also links the fundamental alteration to the agencies specified requirements- if they are able to specify their requirements – or their business need if they are not able to specify the requirements up front.

Version 5

Retain current provision

Rationale for Version 5 Additional wording intended to clarify that agency’s specified product requirements (assuming they are constructed in accordance with standard procurement procedures) do not need to be altered. Some TEITAC members indicated this additional language is not needed, as it is implicit.

• Status: In progress: no consensus reached
• Text from Subcommittee
• Source: {508}1194.3
• Impact:
• External Reference:
• Testability:

1194.3 - F - Service Areas

This provision has alternative versions. Each version and its rationale or justification are listed below.

Current Provision
Products located in spaces frequented only by service personnel for maintenance, repair, or occasional monitoring of equipment are not required to comply with this part.

Version 1

Products DESIGNED FOR spaces frequented only by service personnel for maintenance, repair, or occasional monitoring of equipment ARE NOT REQUIRED TO MAKE CONTROLS OR INTERFACES THAT ARE OPERABLE SOLELY FROM THESE SPACES COMPLY WITH THIS PART.

Rationale for Version 1 Additional wording attempts to restrict this exception to products that are specifically designed to be located in areas frequented only by service personnel rather than covering all products by virtue of their location. It also makes clear that being able to support the system remotely is acceptable.

• Impact:
• External Reference:
• Testability:

Version 2

Products located AND OPERATIONS EXECUTED in spaces frequented only by service personnel for maintenance, repair, or occasional monitoring of equipment are not required to comply with this part. (May 30)

Rationale for Version 2 This version is an attempt to clarify and restrict this exception to products that are located in service areas, but whose controls and interfaces are only operable from the service area location, i.e. a remote interface is not available.

• Impact:
• External Reference:
• Testability:

Version 3

No Exception allowed - all products should conform

Rationale for Version 3 Some TEITAC members and subcommittee members recommend the entire exception should be deleted. This recommendation is based on the preference that all products should conform regardless of location and use.

• Impact:
• External Reference:
• Testability:

• Status: In progress: no consensus reached
• Text from Subpart A
• Source: {508}1194.3

1194.3 - G - Narrow, Delineated Use

This provision has alternative versions. Each version and its rationale or justification are listed below.

Version 1

Self-contained, closed products with narrow, delineated personal use (such as calculators, electronic dictionaries, and audio recorders) for which an agency can document readily available specialized products in the commercial marketplace that collectively meet the functional performance criteria (e.g. have features such as speech output available on one unit, large visual display available on another, large keys/buttons available on another, etc.) Are not required to comply with this part as a whole. Agencies must however provide specialized products with appropriate access features as necessary to meet the needs of end-users with disabilities.)

Rationale for Version 1 Some subcommittee members voiced the opinion this new exception is not needed

• Impact:
• External Reference:
• Testability:

Version 2

(Alternative approaches dependent upon recommendations of Closed Product Group)

• Impact:
• External Reference:
• Testability:

• Status: In progress: no consensus reached
• Text from Subpart A
• Source: New

Section 1194.4 Definitions

The following definitions apply to this part:

Agency

Any Federal department or agency, including the United States Postal Service.

Status: Done
Text from: Subpart A

Alternate Formats

• Text coming from Documentation Subcommittee.

Alternate Methods

• Text coming from Documentation Subcommittee.

Application Software

• Text coming from Web and Software Subcommittee.

Discussion information can be found on http://teitac.org/wiki/Web_and_Software:_Definitions.

Assistive Technology

Assistive technology is any item, piece of equipment, or system, whether acquired commercially, modified, or customized, that is commonly used to increase, maintain, or improve functional capabilities of individuals with disabilities. As used in this part, the term includes traditional assistive technology hardware and software along with (mainstream technology used as assistive technology,) virtual assistive technology delivered as a web service and integration of products into a system that provides assistive technology functions which allow individuals with disabilities to access electronic information technology.

Status: Done (status updated Aug 24, 2007)
Text from: Subpart A

Discussion or Rationale: Added language clarifying that assistive technology includes web based and integration services.

Authoring Tools

Any software used to create or modify content for publication.

• Note: This is not intended to apply to text editors like Notepad. Concern that this will be too broadly applied due to the definition of "content". Subcommittee still working on these concerns.

Status: In Progress
Text from: Web and Software

Auto-updating

Object whose appearance is modeling one or more data values, such as a status monitor, or stock ticker, and which is updated autonomously by software.

• Concern that there is no consideration for frequency here. Auto-updating at very slow frequencies like once per day is not a problem. Concern that this is too broad and will cause ARIA content to fail even when there is no problem.

Status: In Progress
Text from: Web and Software

Captions

Captions are synchronized text equivalents for audio information. Captions are similar to subtitles in that they convey the content of spoken dialog, but also include text for non-spoken information such as important sound effects, music, laughter, and speaker identification and location. Captions should not obscure or obstruct relevant or key information. In some countries captions are called subtitles.

Status: Done
Text from: Audio/Visual

Closed Product Functionality

Functionality of a product where assistive technology can not be used to achieve some or all of the functionality of the electronic user interface components for any reason including hardware, software, platform, license, or policy limitation.

• Products can be closed for one type of disability but not closed for another.
• Functionality is limited to "electronic UI components" because products are not considered ‘closed’ if mechanical devices like latches or lids cannot be operated by assistive technologies like screen readers. Mechanical devices such as keys that cause electronic input would however trigger “closed” designation if assistive technologies could not achieve the same functionality.
• A ‘product’ can consist of multiple devices some of which may be AT if the devices are all sold and kept together as a unit.
• Policy includes manufacturer, or vendor policies,etc. Agencies are responsibility for agency policies. If important to procurement agencies should reflect requirement as specifications in the RFP. (e.g. "Connection of user devices will not be allowed." or "All peripheral ports must be sealable.")

Status: Done
Text from: Self-Contained/Closed

Comparable Access

Comparable access means that individuals with disabilities have access to and use of information and data that is timely, accurate, complete, and efficient when compared to that available to individuals without disabilities.

• Timely access means that individuals with disabilities have information and data available to them at the same time as individuals without disabilities, but that does not preclude captions that are a millisecond or two delayed or other reasonable differences in timing given individual situations.
• Accurate means that the information and data reflects the intended meaning especially when converted into another form or media.
• Complete means that all critical information and data is present when accessed by assistive technology or converted into another form or media.
• Efficient means that an individual with a disability exerts a reasonably similar or comparable amount of effort (given the capacity of current assistive technology) in using electronic and information technology as compared to an individual without a disability.

Status: In Progress
Text from: Subpart A

Discussion or Rationale: Addition of comparable access definition at the request of federal procurement officials and other subcommittees to provide framework for application of functional performance standards.

Subcommittee could not reach consensus on including some or all of the explanatory information as part of the definition itself. It will be critical to expand on and explain the terms “timely, accurate, complete and efficient” to ensure understanding and consistency in application but the group could not reach consensus on where that explanation should occur. Not clear on how would test for this. Consumers do want measurable so don't have false access. “Reasonable accommodation” is different per Terry

Subcommittee also could not reach consensus on possible addition of the word “communication” to “information and data” to clarify that communication is part of information and data.

Content

information and sensory experience to be communicated to the user by means of software, including but not limited to: text, images, sounds, videos, controls and animations, as well as the encoding that defines the structure, presentation, and interactions associated with those elements.

Status: In Progress
Text from: Web and Software

Content Format

An encoding mechanism for storing information. Examples are HTML, JPEG, SMIL, PDF, etc.

Status: Done
Text from: Web/Software

Contrast Ratio

The relative luminance of the lighter of the foreground or background colors compared to the relative luminance of the darker of the foreground or background colors.

• (L1 + 0.05) / (L2 + 0.05), where
  • L1 is the relative luminance of the lighter of the foreground or background colors, and
  • L2 is the relative luminance of the darker of the foreground or background colors.

Notes

1. Contrast ratios can range from 1 to 21 (commonly written 1:1 to 21:1).
2. For dithered colors, use the average values of the colors that are dithered (average R, average G, and average B).
3. Text can be evaluated with anti-aliasing turned off.
4. Background color is the specified color of content over which the text is to be rendered in normal usage. If no background color is specified, then white is assumed.
5. For text displayed over gradients and background images, authors should ensure that sufficient contrast exists for each part of each character in the content.

Status: Done
Text from: Web/Software

Decoration

Sensory experience to be communicated to the user that does not convey relevant information, does not have a function, and is included only for aesthetic purposes.

Status: Done
Text from: Web and Software

Electronic and Information Technology

Includes information technology and any equipment or interconnected system or subsystem of equipment that is used in the creation, conversion, or duplication of data or information. The term electronic and information technology includes, but is not limited to, telecommunications products (such as telephones), information kiosks and transaction machines, World Wide Web sites, multimedia, and office equipment such as copiers and fax machines. The term does not include any equipment that contains embedded information technology that is used as an integral part of the product, but in which information technology is not the principal function of that product.

Status: Done
Text from: Subpart A

Discussion or Rationale: This definition cannot be changed, as it is derived from Clinger-Cohen. However, this is still an issue for agencies, and TEITAC might want to recommend that Access Board and GSA work together to create advisory notes to help them determine what is (and is not) E&IT

Freestanding

• Text coming from Hardware subcommittee

The subcommittee is requesting input from the plenary on if this should be defined since it is used in other parts of the ADA regulations and could have impacts there.

General Flash and Red Flash Thresholds

(Flashing frequency corrected from 50 to 55 Hz in bulleted list, update made Aug 28, 2007)

A sequence of flashes or rapidly changing image sequences where all three of the following occur:

1. There are more than three flashes within any one-second period; and
2. The flashing is below 55 Hz; and
3. The combined area of flashes occurring concurrently and contiguously occupies more than a total of .006 steradians (25% of any 10 degree visual field on the screen).

• For the general flash threshold, a flash is defined as a pair of opposing changes in relative luminance of 10% or more and the relative luminance of the darker image is below 0.80. An "opposing change" is an increase followed by a decrease, or a decrease followed by an increase.
• For the red flash threshold, a flash is defined as any transition to or from a saturated red.
• Note 1: For general Web content, using a 341 x 256 pixel rectangle anywhere on the displayed screen area when the content is viewed at 1024 x 768 pixels will provide a good estimate of a 10 degree visual field for standard screen sizes and viewing distances.

Status: Done
Text from: Web/Software

Information Technology

Any equipment or interconnected system or subsystem of equipment, that is used in the automatic acquisition, storage, manipulation, management, movement, control, display, switching, interchange, transmission, or reception of data or information. The term information technology includes computers, ancillary equipment, software, firmware and similar procedures, services (including support services), and related resources.

Status: Done
Text from: Subpart A

Informational Animation

An animation that conveys some information required for understanding content or functionality.

Status: Done
Text from: Web/Software

Interactive Elements

• Text coming from A/V Subcommittee

Since this term is used in multiple places, it really must be defined.

Large Scale Text

At least 18 point or 14 point bold

• Note 1: Fonts with extraordinarily thin strokes or unusual features and characteristics that reduce the familiarity of their letter forms are harder to read, especially at lower contrast levels.
• Note 2: Font size is the size when the content is delivered. It does not include resizing that may be done by a user.

Status: Done
Text from: Web/Software

Menu

Set of selectable options

Status: Done
Text from: Telecommunications
Source: HFES 200

Operable Controls

Any physical control that affects the operation of the product. Operable controls include, but are not limited to, mechanically operated controls, input and output trays, card slots, keyboards, keypads, keys, or buttons, including touch-screens.

Status: Done
Text from: Hardware

Discussion or Rationale: This draft adds individual keys and buttons, as I've inspected many devices that have only those features where the manufacture thought Section 508 didn't apply because it didn't have "a full keyboard".

There was an interesting exchange on the Listserv on this topic regarding full functionality and normal operation.

The question of if this should be "physically operable controls" so it is more specific was raised, but determined to not be needed.

Other Services To Cooperate With Assistive Technologies

A method, other than the platform accessibility services, used to interoperate with assistive technologies.

Status: Done
Text from: Web and Software

Peak Non-crisis Network Traffic

The peak measured network traffic excluding disasters and other crises, or the peak traffic the system is designed to handle.

Status: Done
Text from: Telecommunications

Personal-Private

• Text coming from Self-Contained/Closed.

Platform Accessibility Services (was Accessibility Services)

Services provided by a platform enabling interoperability with assistive technology sometimes in the form of accessibility APIs (application programming interfaces)

Status: Done
Text from: Web/Software

Platform Software

Collection of software components that runs on an underlying software or hardware layer, such that the platform creates a virtual environment in which to run applications in a manner which isolates the applications from the underlying layer.

• Note 1: If there is a direct route from the application to the underlying layer then the software components in the middle are not considered to be a "platform". For example, a program which hosts plug-in's is not a platform if the plug-in can directly access the underlying layer.
• Note 2: An application offering a compute service, such as a 3d rendering engine where a requesting application can directly access the underlying layer would also not be considered a "platform".
• Note 3: A particular software component may play the role of a platform in some situations and not in others. Platforms can include such things as Internet browsers, operating systems, plug-ins to internet browsers or other software applications, and under some situations, byte-code interpreted virtual environments, and other "programming within another programming" environments.
• TBD: Notes about bootloader programs and closed systems?

Status: In Progress
Text from: Web/Software

Product

The subcommittee recommends that this term be deleted and that the recommendations uses the term "E&IT" in place of "product" throughout.

Status: Done
Text from: Subpart A

Programatically Determined

Can be determined by software from data provided in a user-agent-supported manner such that various user agents including assistive technologies can extract and present this information to users in different modalities.

Status: Done
Text from: Web/Software

Real-time Text

Communications that employ the transmission of text wherein the characters are transmitted by a terminal within a maximum of 1 second of character input. This would typically be for conversational purposes but also may be used in voicemail, IVR and other similar applications.

Status: Done
Text from: Telecommunications

Relative Luminance

The relative perceived brightness of any point, normalized to 0 for black and 1 for maximum white

• Note 1: The relative luminance of an sRGB color is defined as L = 0.2126 * R + 0.7152 * G + 0.0722 * B where R, G and B are defined as:
  • if RsRGB <= 0.03928 then R = RsRGB/12.92 else R = ((RsRGB+0.055)/1.055) ^ 2.4
  • if GsRGB <= 0.03928 then G = GsRGB/12.92 else G = ((GsRGB+0.055)/1.055) ^ 2.4
  • if BsRGB <= 0.03928 then B = BsRGB/12.92 else B = ((BsRGB+0.055)/1.055) ^ 2.4 and RsRGB, GsRGB, and BsRGB are defined as:
    • RsRGB = R8bit/255
    • GsRGB = G8bit/255
    • BsRGB = B8bit/255
• The "^" character is the exponentiation operator. (Formula taken from [sRGB] and [IEC-4WD]).
• Note 2: Almost all systems used today to view Web content assume sRGB encoding. Unless it is known that another color space will be used to process and display the content, authors should evaluate using sRGB colorspace. If using other color spaces, see Understanding Success Criterion 1.4.3.
• Note 3: For dithered colors, use average values of the colors used (average R, average G, and average B).
• Note 4: Tools are available that automatically do the calculations when testing contrast and flash.
• Note 5: A MathML version of the relative luminance definition is available.

Status: Done
Text from: Web/Software

Shared-Public

• Text coming from Self-Contained/Closed.

Telecommunications

The transmission, between or among points specified by the user, of information of the user's choosing, without change in the form or content of the information as sent and received. (Telecommunications Act of 1996)

Status: Done
Text from: Telecommunications
Source: Telecommunications Act of 1996

Terminal

Device or devices with which the end user directly interacts and that provide the user interface.

NOTE: For some systems, the software that provides the user interface may reside on more than one device such as a phone and a server.

Status: Done
Text from: Telecommunications

TTY

An abbreviation for teletypewriter. Machinery or equipment that enables interactive text based communications through the transmission of frequency-shift-keying audio tones across the PSTN according to TIA-825-A (A Frequency Shift Keyed Modem For Use On The Public Switched Telephone Network). As used in this part, the term TTY includes devices for text-to-text communications along with voice and text intermixed communications such as voice carry over and hearing carry over. TTYs may include computers with special modems. TTYs are a subset of devices called text telephones.

Status: In Progress
Text from: Telecommunications

Undue Burden

Undue burden means significant difficulty or expense. In determining whether an action would result in an undue burden, an agency shall consider all agency resources available to the program or component for which the product is being developed, procured, maintained, or used.

Status: Done
Text from: Subpart A (no change)

Video Description

The insertion of verbal or auditory description(s) of on-screen visuals intended to describe important visual details that are not contained in, or that cannot be understood from, the main audio output alone. Video descriptions supplement the regular audio track of the program and are usually inserted between dialogue narration to provide information about actions, characters, and on-screen text that appear without verbalization. Video descriptions are a way to let people who are blind or have low vision know what is happening on screen.

Video description guidelines: The American Foundation for the Blind along with the National Center for Accessible Media at WGBH (NCAM), under contract from the Described and Captioned Media Program (U.S. Department of Education) administered by the National Association of the Deaf, is developing guidelines and best practices for authoring video description. As of August 2007, a first draft has been developed by an expert committee of academics, educators, producers, consumers and others. These guidelines should be completed by the end of 2008.

EWG recommendation: Change second paragraph to read: This definition should not conflict with the guidelines produced by the American Foundation for the Blind along with the National Center for Accessible Media at WGBH (NCAM), under contract from the Described and Captioned Media Program (U.S. Department of Education) administered by the National Association of the Deaf.

Status: Done
Text from: Audio-Video

Web Content

Content which is made available in the World Wide Web.

Alternate proposal: Remove as this is not used in any provisions.

Status: In Progress
Text from: Web and Software

Web Page

• Text coming from Web and Software Subcommittee.

Discussion information can be found on http://teitac.org/wiki/Web_and_Software:_Definitions.

World Wide Web

A very large set of hypertext-linked content files located on computers connected by the Internet.

Alternate proposal: Remove as this is not used in any provisions.

Status: In Progress
Text from: Web and Software

Section 1194.5 Equivalent Facilitation

Nothing in this part is intended to prevent the use of designs or technologies as alternatives to those prescribed in this part provided they result in substantially equivalent or greater access to and use of a product for people with disabilities.

Status: Done
Source: {508}1194.5, no change

Technical Provisions

1. Requirements for All Product and Services

Updates and discussion for provisions in this section

1.1 Functional Performance Criteria

Discussion or Rationale: There is a lot of ongoing discussion as to whether the Functional Performance Criteria should be moved to the end of the technical provisions and before the documentation/technical support provisions. There are questions regarding when the functional criteria should be used. There are also two proposals for an introductory paragraph for the section. These are not resolved at this time and are being discussed in the subcommittee and will be raised at the Sept plenary if necessary.

Version 1: If an E&IT product fails to meet one or more of the technical provisions above, meets it via equivalent facilitation, or if the technical provisions do not apply, the agency shall ensure that that the purpose of the technical provisions is met through the following functional performance criteria.

Version 2: After the technical requirements are applied, the following functional performance criteria must be applied to:
1) see if the technical provisions cover all aspects needed to provide access to the product,
2) check any equivalent facilitation, and
3) see if access can be provided in another way if any of the technical provisions are not met.

1.1-A - Without Vision

Products must provide at least one mode that allows [access] without using vision. This access may be provided directly or through assistive technology.

NOTE: The phrase "comparable access" or "access" is still being worked out.

• Status: In Progress
• Text from General
• Source: {508}1194.31(a), {255}1193.31
• Impact:
• External Reference:
• Testability:
• Metadata
  • Disabilities: Blindness
  • User Activities: All
  • Product Characteristics: All
  • Product Types: All

1.1-B - With Limited Vision

Version 1: At least one mode must be provided that allows [comparable access] to product without requiring visual acuity greater than 20/70. This mode must allow audio and enlarged text output to work together or independently, directly or via AT.

Version 2: Products must provide at least one mode that allows [access] without requiring visual acuity greater than 20/70. This mode must allow audio or enlarged text output to work together or independently, directly or through assistive technology."

Rationale for Version 2: The recommended edit is audio "or" enlarged text output. For small handheld products, it may be difficult to accommodate enlarged text in some cases and audio output may be the most practical alternative. This edit would allow more flexibility appropriate to a wider variety of products.

NOTE: The phrase "comparable access" or "access" is still being worked out.

• Status: In Progress
• Text from General
• Source: {508}1194.31(b), {255}1193.41(b)
• Impact:
• External Reference:
• Testability:
• Metadata
  • Disabilities: Low vision
  • User Activities: All
  • Product Characteristics: All
  • Product Types: All

1.1-C - With Color Vision Deficits

At least one mode must be provided that allows [comparable access] to product with color vision deficits.

Discussion or Rationale:

• Reword to ensure that this is a visual mode, and does not allow provisions for blindness to meet this provision.
• Is this covered by testable provisions, below.

NOTE: The phrase "comparable access" or "access" is still being worked out.

• Status: In Progress
• Text from General
• Source: new
• Impact:
• External Reference:
• Testability:
• Metadata
  • Disabilities: Color deficiency/Colorblindness
  • User Activities: All
  • Product Characteristics: All
  • Product Types: All

1.1-D - Without Hearing

Products must provide at least one mode that allows [access] without using hearing. This [access] may be provided directly or through assistive technology.

NOTE: The phrase "comparable access" or "access" is still being worked out.

• Status: In Progress
• Text from General
• Source: {508}1194.31(c), {255}1193.41(d)
• Impact:
• External Reference:
• Testability:
• Metadata
  • Disabilities: Deafness, Deaf-blindness, Other combined hearing/vision loss
  • User Activities: All
  • Product Characteristics: All
  • Product Types: All

1.1-E - With Limited Hearing

Where audio information is important for the use of a product, it must provide at least one mode that [allows] access with enhanced audio. This [access] may be provided directly or through assistive technology.

NOTE: The phrase "comparable access" or "access" is still being worked out.

• Status: In Progress
• Text from General
• Source: {508}1194.31(d), {255}1193.41(b)
• Impact:
• External Reference:
• Testability:
• Metadata
  • Disabilities: Hard of hearing,
  • User Activities: All
  • Product Characteristics: All
  • Product Types: All

1.1-F - Without Speech

Products must provide at least one mode that allows [access] without using speech. This [access] may be provided directly or through assistive technology.

NOTE: The phrase "comparable access" or "access" is still being worked out.

• Status: In Progress
• Text from General
• Source: {508}1194.31(e), {255}1193.41(h)
• Impact:
• External Reference:
• Testability:
• Metadata
  • Disabilities: Speech
  • User Activities: All
  • Product Characteristics: All
  • Product Types: All

1.1-G - With Limited Reach, Strength, or Manipulation

Products must provide at least one mode that [allows] access without for people with limited reach and strength, and that does not require simultaneous actions. This [access] may be provided directly or through assistive technology.

NOTE: The phrase "comparable access" or "access" is still being worked out.

Discussion or Rationale: Adds AT option.

• Status: In Progress
• Text from General
• Source: {255}1193.41(e)
• Impact:
• External Reference:
• Testability:
• Metadata
  • Disabilities: Dexterity, Mobility
  • User Activities: All
  • Product Characteristics: All
  • Product Types: All

1.1-H - With No Reach or Touch

Except for closed products, products must provide at least one mode that allows control through assistive technologies to allow [access] for people with no reach or ability to touch.

Discussion or Rationale: This provision is proposed to address a concern that without a provision for individuals who are unable to reach and touch the product, a large group of people will be left out.

On the other side there is a concern that we don't have good techniques for built-in access to products that will address the range reach and touch disabilities. Voice, eye gaze, and head pointing might work, but might not work well enough in the field, or even meet the full range of disabilities being addressed with this provision.

A second concern is around closed products and the fact that if you can't attach AT then you have to rely on a built in solution. Some suggested that we should try to figure out how to create a safe way to have "closed products" be open to AT and thus solve the problem that way.

There is consensus on the issues, but we haven't yet figured out wording that we can reach consensus on or whether it is covered elsewhere.

The Self-Contained/Closed group suggests that we start this item with the words "Except for Closed products,..."

NOTE: The phrase "comparable access" or "access" is still being worked out.

• Status: In Progress
• Text from General
• Source: new
• Impact:
• External Reference:
• Testability:
• Metadata
  • Disabilities: Dexterity, Mobility
  • User Activities: All
  • Product Characteristics: All
  • Product Types: All

1.1-I - With Cognitive, Language or Learning Limitations

Products provide at least one mode that accommodates cognitive, language or learning impairments, directly or with assistive technology.

Discussion or Rationale: This provision is here as a placeholder. The general group identified several issues and questions in trying to move this forward. The working group is looking for sufficient technical provisions to support the inclusion of a FPC.

• Status: In Progress
• Text from General
• Source: {255}1194.41(i)
• Impact:
• External Reference:
• Testability:
• Metadata
  • Disabilities: Cognitive language/learning
  • User Activities: All
  • Product Characteristics: All
  • Product Types: All

1.2 General Technical Requirements

1.2-A - Closed Products Functions

If any product functionality is closed, then individuals with disabilities must have access to that functionality without the use of any assistive technologies that must be attached or installed. A personal assistive listening device that connects to the standard audio connection required in the audio connection provision is not considered assistive technology.

Discussion or Rationale:

• Status: Done
• Text from Self Contained, Closed
• Source: {508}1194.25(a)
• Impact:
• External Reference:
• Testability:
• Metadata
  • Disabilities: All
  • User Activities: All
  • Product Characteristics: All
  • Product Types: All

1.2-B - Flashing

Products must not flash more than 3 times in any one second period, unless:

• Flashing created by software is under the general flash and red flash threshold.

• Flashing created by hardware is either:
  • greater than YYY candelas; or
  • greater than 20 candelas/sq meter and contiguously occupies more than a total of .006 steradians (25% of any 10 degree visual field).

Discussion or Rationale: The hardware portion of this provision is still under development.

• Status: In Progress
• Text from Self Contained, Closed
• Source: {508}1194.21(k) 1194.22(j) 1194.25(i), and {255}1193.43(f)
• Impact:
• External Reference:
• Testability:
• Metadata
  • Disabilities: All
  • User Activities: All
  • Product Characteristics: All
  • Product Types: All

1.2-C - Biometric ID

If a product uses biometric forms of user identification, control, or activation, which rely on a person possessing one unique biological characteristic, an alternative form of identification, control, or activation must also be provided. This alternative may use alternate biometric unique characteristics, use a biometric characteristic that all people have, or not use biometrics. Agencies must provide an alternate means of access for anyone who can not use the provided biometrics-based form of identification, control, or activation.

Explanatory note: People who do not have fingers, eyes, etc are not able to make use of biometrics-based E&IT simply because currently these solutions rely upon only one unique biometric measurement, such as a fingerprint. Allowing such solutions to accept alternative biometrics will greatly decrease the number of people who are unable to use such biometrics solutions, since people with multiple disabilities of this type are a smaller portion of the population. This, however, is only an interim step until biometric or nonbiometric alternatives are identified and integrated into security best practices that "all people" regardless of disability are able to use. For example, one potential solution may rely only upon circulation; if this is a characteristic of all people, it would be an accessible biometric.

Until non-biometric forms of identification, control or activation have been integrated into security best practices, such biometric-based systems must be developed to allow multiple biometrics to be used. Alternatively, until a biometric solution is identified that all people can use, biometrics systems that use multiple biometrics or non-biometrics must be employed. Fingerprints and retina patterns are just two examples. It is less likely for people to be missing fingerprints and retinas than either one alone. However, even when multiple biometrics are provided, alternate means of access must also be provided (in policy and implementation) for anyone who cannot use any of them. For example, if someone has neither retinas nor fingers, another procedure, which could involve physical assistance, is needed to provide comparable access.

We strongly recommended that the Access-Board direct research to identify nonbiometrics forms of identification, control or activation, or biometric alternatives that all people can make use of, to be integrated into security best practices and standards in the near future.

Discussion or Rationale: This would allow biometric systems in the future that are based on circulatory system or other characteristics common to all people.

• Status: In Progress
• Text from General
• Source: {508}1194.21(k) 1194.22(j) 1194.25(i), and {255}1193.43(f)
• Impact:
• External Reference:
• Testability:
• Metadata
  • Disabilities: All (that could be caused by loss body part or function)
  • User Activities: All
  • Product Characteristics: All
  • Product Types: All

1.2-D - Pass Through

Products that transmit or conduct information or communication must pass through cross-manufacturer, non-proprietary, industry-standard codes, translation protocols, formats or other information necessary to provide the information or communications in a usable format.

Technologies which use encoding, signal compression, format transformation, or similar techniques must not remove information needed for access, or must restore it upon delivery.

New language added:

Firewalls, routers,gateways and other products that pass real-time voice communication must also pass real-time text communication signals (including mixed voice and real-time text) that are standard in the United States for that technology platform without distortion or error beyond 1%.

Note: Only phones that are passing text signals onto another device e.g. TTY, would be subject to this provision

Discussion or Rationale: for PSTN this would be TIA/EIA 825 Baudot. There is also the question to be resolved: If this regulation were adopted, would products such as a simple voice-only office intercom system or basic voice-only walkie-talkie be regarded as non-compliant? Or would they be exempt because there is no text communication standard for those platforms?

• Status: In Progress
• Text from Telecommunications
• Source: {508}1194.23(j), {255}1193.37
• Impact:
• External Reference:
• Testability:
• Metadata
  • Disabilities:
  • User Activities:
  • Product Characteristics:
  • Product Types:

1.2-E - Audio information

All information that is needed for operation and use that is provided in audio form must also be available in visual form, either directly or via assistive technology.

• Status: Done
• Text from Self-Contained/Closed
• Source: {255}1194.43(d)
• Impact:
• External Reference:
• Testability:
• Metadata
  • Disabilities: Deaf, Hard of Hearing
  • User Activities: All
  • Product Characteristics: Sound output – speech, Sound output (other than speech)
  • Product Types: All

1.2-F - Visual Information

All information that is needed for operation and use that is provided in visual form must also be available in audio form and, where appropriate, in tactile form, either directly or via assistive technology.

• Status: Done
• Text from Self-Contained/Closed
• Source: {255}1194.43(a)
• Impact:
• External Reference:
• Testability:
• Metadata
  • Disabilities: Blind, Low Vision
  • User Activities: All
  • Product Characteristics: Visual display with text, Visual display with graphics
  • Product Types: All

1.2-G - Color

Color coding must not be used as the only means of conveying information, indicating an action, prompting a response, or distinguishing a visual element.

Discussion or Rationale: Harmonize with Color (Web)

• Status: In Progress
• Text from General
• Source: {508}1194.25(g) and 1194.21(i)
• Impact:
• External Reference:
• Testability:
• Metadata
  • Disabilities: Color deficiency/Colorblindness
  • User Activities: All
  • Product Characteristics: Uses Color (on keys, labels, displays, indicators, anywhere etc.)
  • Product Types: All

1.2-H - Text size

All information provided in text must be a minimum of 3/16 inch (4.8 mm) high, based on the uppercase letter "I" or, where the display size is not part of the product, 14 pt type.

Discussion or Rationale: To match ADAAG - Characters

• Status: In Progress
• Text from Self-Contained/Closed
• Source: {255}1193.43(b)
• Impact:
• External Reference:
• Testability:
• Metadata
  • Disabilities: Low vision
  • User Activities: All
  • Product Characteristics: Visual display with text
  • Product Types: All

1.2-I - Contrast

Contrast is currently split out between software and hardware. If this approach is successful, then this placeholder provision will be deleted.

• Status: In Progress
• Text from Hardware
• Source:
• Impact:
• External Reference:
• Testability:
• Metadata
  • Disabilities:
  • User Activities:
  • Product Characteristics:
  • Product Types:

2. Hardware Aspects of Products

Updates and discussion for provisions in this section

2.1 All Products with Hardware

2.1-A - Contrast for displays

This is a placeholder for a provision still being written to define contrast for LCD hardware.

Discussion or Rationale: LCD capabilities – define contrast

• For contrast ratios from hardware perspective for active displays (backlit displays such as an LCD) and passive displays.
• Does this apply to cell phones? Yes - need feedback from telecomms industry.

• Status: In Progress
• Text from Hardware
• Source: {508} 1194.26(b); {508} 1194.25(c)
• Impact:
• External Reference:
• Testability:
• Metadata
  • Disabilities:
  • User Activities:
  • Product Characteristics:
  • Product Types:

2.1-B - Contrast for labels

This is a placeholder for a provision still being written.

Discussion or Rationale: Define contrast and set limits relative to contrast is necessary if it is the only means of conveying intent

• Status: In Progress
• Text from Hardware
• Source: {508} 1194.26(b); {508} 1194.25(c)
• Impact:
• External Reference:
• Testability:
• Metadata
  • Disabilities:
  • User Activities:
  • Product Characteristics:
  • Product Types:

2.1-C - Mechanical Controls

All mechanically operated controls and keys:

1. Must be tactilely discernible without activating the controls or keys.
2. Must be operable with one hand and must not require pinching, twisting of the wrist, tight grasping, or simultaneous actions. The force required to activate controls and keys must be 5 lbs. (22.2 N) maximum.
3. If key repeat is supported, the delay before repeat must be adjustable to at least 2 seconds. The key repeat rate must be adjustable to 2 seconds per character.
4. The status of all locking or toggle controls or keys must be visually discernible, and discernible either through touch or sound.

Discussion or Rationale: Changes in this section were limited to the addition of the "Simultaneous controls" to the operability requirements and reordering requirements to align the adjective "tight" with "grasping".

This does not imply that a product must be entirely operable with one hand (eg, product could be placed on a surface).

• Status: Done
• Text from Hardware
• Source: {508} 1194.26(a); 1194.23(k)
• Impact:
• External Reference:
• Testability:
• Metadata
  • Disabilities: All
  • User Activities: Conversations, data analysis, document sharing and reviewing, media (audio/video) creation and editing.
  • Product Characteristics: Physical controls or connectors, touchscreen or touch sensitive buttons, color
  • Product Types: Hardware, telephone, telephone system, audiovisual equipment, public information terminal, desktop computer system, portable computer system, copier, printer, scanner, other similar peripherals

2.1-D - Touch Operated

Version 1 - If a product utilizes touch screens or touch-operated controls, an input method must be provided that complies with Mechanical Controls provision.

Version 2 - If a product utilizes touch screens or touch-operated controls, an equivalent means of input/interaction/control must be provided.

Version 2a - If a product utilizes touch screens or touch-operated controls, a functionally equivalent means of input/interaction/control must be provided. Any mechanical controls employs in the equivalent input/interaction/control must comply with the Mechanical Controls provision.

Discussion or Rationale: Need to finalize some language that addresses the intent of “redundancy” of controls beyond just requiring another set of mechanical controls. There has been a good debate on this one relative to how this impacts products and users. The major differentiation is in the product usage model of closed versus open.

The issue of touch controls has been discussed amongst the subcommittee. The challenge being the application of the original language and its requirement of redundant controls. Several points made include: What about touch controls that are replicated via SW (for example capaciitve media buttons when media can also be controlled via SW)?

This language addresses the issues associated with touch-based controls (specifically biophysical) by requiring a redundant interaction method without assigning the control type. If mechanical controls are required, by default they would have to meet the proposed language for mechanical controls.

Discussion points from meeting: What is "equivalent"?

• Keyboard controls that provide equivalent functionality are equivalent
• Touch screens can't always provide a 1:1 match of soft and mechanical controls.
• Is providing a USB port equivalent? Rob says "yes" and asks for language to cover it.
• Need to add to V2 that it's possible to operate these controls without the use of the touchscreen.
• What about speech or remote control software.
• Note that for some disabilities, touch screen is better
• This was originally part of closed products - there are differences between closed and open products. Final language must address this.

• Status: In Progress
• Text from Hardware
• Source: {508} 1194.26(b); {508} 1194.25(c)
• Impact:
• External Reference:
• Testability:
• Metadata
  • Disabilities: All
  • User Activities: Conversations, data analysis, document sharing and reviewing, media (audio/video) creation and editing
  • Product Characteristics: Physical controls or connectors, touchscreen or touch sensitive buttons
  • Product Types: Hardware, telephone, telephone system, audiovisual equipment, public information terminal, desktop computer system, portable computer system, copier, printer, scanner, other similar peripheral

2.1-E - Standard Connection

If a product has user interface connection capabilities, whether wired or wireless, at least one connection must comply with publicly available industry standards.

If users can control any product functionality through a non-standard connection, they must also be able to control that functionality through a standard connection for that type of input or output.

• If there are proprietary protocols in the terminal, so long as the protocols are over a standard physical connection, cooperation between E&IT vendors and AT vendors should make it possible for the device to be compatible with AT.

• If an adapter is required to convert a proprietary connector on an E&IT device into a standard connector, it must be the responsibility of the E&IT vendor to provide the adapter.

Discussion or Rationale: Comments about the need for proprietary connections (keeps product lines closed to competitors), and the related issue of not requiring AT to match many different proprietary connections.

There has been a large degree of conversation regarding this provision. The original language was from the Desktops and Portable section. In this revision, it has been applied across all projects. Attempts were made to create language that did not stifle innovation and allowed for proprietary connections. Care needs to be taken in any "guidelines" to ensure that the intent of this provision, to provided a means of connection is clear.

There has been discussion on the listserv relative to how this language addresses the responsibility of driver development, especially with KIOSK (closed) system interaction.

The context of the language relative to Hardware is that it is to ensure that the "the connection" can be made from the "physical" perspective.

One interpretation from the listserv of the language is:

• IF a company provides I/O functionality on a proprietary connector
• THEN it must provide same functionality on a std connector.
• This provision does not require that any AT drivers be provided.
• It doesn't require that any standard connector be provided. ( a wireless connection would suffice if standard)
• It doesn't require that any standard connection be provided UNLESS there are I/O functions on a proprietary connector.
• IF there is an I/O function on a proprietary connection, it DOES require a driver that provides I/O function on the standard connection.

• Status: In Progress
• Text from Hardware and Telecommunications
• Source: {508} 1194.26(d)
• Impact:
• External Reference:
• Testability:
• Metadata
  • Disabilities: All
  • User Activities: Conversations, data analysis, document sharing and reviewing, media (audio/video) creation and editing
  • Product Characteristics: Physical controls or connectors, touchscreen or touch sensitive buttons
  • Product Types: Hardware, telephone, telephone system, audiovisual equipment, public information terminal, desktop computer system, portable computer system, copier, printer, scanner, other similar peripheral

2.1-F - Free-Standing

Freestanding, non-portable products intended to be used in one location must have any operable controls positioned within reach.

The allowed position of any operable control must be determined with respect to a vertical plane, which is 48 inches in length, centered on the operable control, and at the maximum protrusion of the product within the 48 inch length (see Figure 1 of this part).

• If an operable control is 10 inches or less behind the reference plane, the height must be 54 inches maximum and 15 inches minimum above the floor.

• If an operable control is more than 10 inches and not more than 24 inches behind the reference plane, the height must be 46 inches maximum and 15 inches minimum above the floor.

• Operable controls must not be more than 24 inches behind the reference plane (see Figure 2 of this part).

Discussion or Rationale: Need to add "freestanding" to the definitions. - Decision made to not define it. Asking for input from plenary.

Point of discussion arose regarding the concept of "fixed" products such as ATMs. There is a consideration to change free-standing to "free-standing or built-in". Need clarification from access board as to correct term relative to "built-in".

These requirements are based on ADAAG requirements and have been left at the same level as the current ADAAG; not the draft as was originally proposed. Hence the change back to a max height of 54 inches.

• Status: Done
• Text from Hardware
• Source: {508} 1194.25(j)
• Impact:
• External Reference:
• Testability:
• Metadata
  • Disabilities: All
  • User Activities: Conversations, data analysis, document sharing and reviewing, media (audio/video) creation and editing
  • Product Characteristics: Physical controls or connectors, touchscreen or touch sensitive buttons
  • Product Types: Hardware, telephone, telephone system, audiovisual equipment, public information terminal, desktop computer system, portable computer system, copier, printer, scanner, other similar peripheral

2.2 If the Product has Speech Output or Throughput

2.2-A - Magnetic Coupling

Where a telecommunications product delivers output by an audio transducer which is normally held up to the ear, a means for effective magnetic wireless coupling to hearing technologies must be provided that allows the user of such technologies to effectively utilize the telecommunication product. This guideline shall apply to wireless, wireline, cordless and Bluetooth applications.

Discussion or Rationale: TIA alternate for last sentence: This guideline shall apply to wireline and wireless technologies.

EWG proposed edit for clarity Telecommunications products that deliver output with an audio transducer, which is normally held up to the ear, must provide a means for effective magnetic wireless coupling to hearing technologies that allows a user to effectively utilize the product. This guideline applies to wireless, wireline, cordless and Bluetooth applications. (or TIA alternate)

• Status: In Progress
• Text from Hardware and Telecommunications
• Source: {508}1194.23(h), {255}11943.43(i)
• Impact:
• External Reference:
• Testability:
• Metadata
  • Disabilities:
  • User Activities:
  • Product Characteristics:
  • Product Types:

2.2-B - Interference with Hearing Device

Version 1: Interference to hearing technologies (including hearing aids, cochlear implants, and assistive listening devices) must be reduced to the lowest possible level that allows a user of hearing technologies to utilize the telecommunications product.

Version 2: Potential sources of interference to hearing technologies (including hearing aids, cochlear implants, and assistive listening devices) must be reduced as much as possible to provide a more compatible environment for a user of hearing technologies to utilize the telecommunications product.

Version 3: Interference to hearing technologies (including hearing aids, cochlear implants, and assistive listening devices) must be reduced to the lowest possible level. The interface level must allow a user of hearing technologies to utilize the telecommunications product.

Discussion or Rationale: This comes from Telecom SC and must be reconciled Hardware SC. There are questions about testability of "to the lowest level" and "as much as possible".

• Status: In Progress
• Text from Hardware and Telecommunications
• Source: {508}1194.23(i), {255}11943.43(h)
• Impact:
• External Reference:
• Testability:
• Metadata
  • Disabilities: Hearing, Hard of Hearing
  • User Activities:
  • Product Characteristics:
  • Product Types:

2.2-C - Audio Connection

When products provide auditory output, the audio signal must be provided at a standard signal level through an industry standard connector (connection???) that will allow for private listening.

Discussion or Rationale: There is a broader issue here relative to open/closed or public/private... Need more freedoms at workstation/private level.

When products provide auditory output, the audio signal must be provided at a standard signal level through an industry standard connector that will allow for private listening. The product must provide the ability to interrupt, pause, and restart the audio at anytime.

Software or Firmware may be needed to address the "The product must provide the ability to interrupt, pause, and restart the audio at anytime."

• Status: In Progress
• Text from Hardware
• Source: {508} 1194.23(e); {255} 1193.51(b) & (g)
• Impact:
• External Reference:
• Testability:
• Metadata
  • Disabilities: All
  • User Activities: Conversations, data analysis, document sharing and reviewing, media (audio/video) creation and editing.
  • Product Characteristics: Physical controls or connectors, touchscreen or touch sensitive buttons
  • Product Types: Hardware, telephone, telephone system, audiovisual equipment, public information terminal, desktop computer system, portable computer system, copier, printer, scanner, other similar peripherals

2.2-D - Volume

All products with audio output must allow users to adjust the audio level. At peak volume output they must have less than 12 dB symmetrical clipping or a total harmonic distortion (THD) less than XXX dB

• For products used in a public place, the maximum volume level must be at least 80 dB SPL RMS
• For products that will not be used in public places or where the volume of the public place is controlled to be under 50 dBA SPL RMS, the maximum volume level must be at least 65 dB SPL RMS.

Discussion or rationale: Final level for THD still to be determined. Question about where are volumes set? Is that where you measure from? Does this overlap with 2.3.E?

• Status: In Progress
• Text from Self-Contained/Closed
• Source: {508}1194.25(f), {255}1193.43(e)
• Impact:
• External Reference:
• Testability:
• Metadata
  • Disabilities: Hard of hearing
  • User Activities: All
  • Product Characteristics: Sound output – speech, Sound output (other than speech)
  • Product Types: All

2.2-E - Volume (Gain)

For incoming voice signals:

1. Analog line-powered telecommunications products, wireline, and all cordless telephones (wireline or VoIP) must comply with FCC regulation §68.317 for volume control
2. All cellular phones - TBD
3. All other telecommunications products or systems that provide a function allowing voice communication must provide a gain adjustable from the normal unamplified level to at least 20 dB above the normal unamplified level as measured in accordance with the