Note

This archival content is maintained by WebAIM and NCDAE on behalf of TEITAC and the U.S. Access Board . Additional and up-to-date details on the updates to section 508 and section 255 can be found at the Access Board web site.

EWG:Draft Oct 26

Editorial Working Group > October 26 Draft

This draft is "locked" and released for review from October 29 - November 12 (2 weeks) and will be used at the November plenary meeting

Related Pages

  • Status Spreadsheet - an overview of the status of the work
  • The Sandbox (The Updates Page) - Any updated text, comments (and minority report comments) and suggested text for provisions are collected on a single page, and cross-linked from each affected provision.

Contents

Subpart A

Section 1194.1 Purpose

(This section has alternate versions. All rationale text is at the end of this section.)

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 including communication that are as timely, accurate, complete, and efficient as 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 including communication that are as timely, accurate, complete, and efficient as 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

Notes:
(This explanatory material is recommended for inclusion with both versions)

  • 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 requirements specified in Subpart X. It should be noted that the determination of timely, accurate, complete, and efficient will not be a quantifiable measure.

Rationale: Federal procurement officials and other subcommittee members requested the addition of information to help guide them in determining when access to data and information for individuals with disabilities was "comparable" to that available for individuals without disabilities. The subcommittee relied on information from Office of Civil Rights decisions regarding comparable access to identify the critical concepts of "timely, accurate, complete and efficient". The explanatory note was developed to assist in assuring understanding and consistency in application. The subcommittee added the word "communication" to "information and data" to clarify that communication is part of information and data. While this information has been infused into the Purpose section, it could alternatively be added as a new section under Application. 

Discussion of Work in Progress
* EWG needs to insert Subpart name.

Section 1194.2 Application

(This section has alternate versions for some paragraphs. Rationales are listed at the end of the section)

Current provision:

(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: Recommended New Introduction:

In general, this section applies only to the consideration of accessibility in the process of developing, procuring, maintaining, or using electronic and information technology.

Version 2: Alternatives for Paragraph (a)(2) and Paragraph (b)

(a)(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, maintenance, 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 that meet all of the standards are not commercially available the agency must procure the product that best meets the applicable access standards, given the agency's business needs.

Version 3: Alternative for Paragraph (b)

(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.


Rationales:

  • Rationale for Version 1: Recommended New Introduction: 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.
  • Rationale for Version 2: paragraph (a)(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 Version 2: 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 Version 3: paragraph (b): Defer 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.

Recommendation to the Access Board: Develop supplemental materials to assist in determining what is and is not E&IT.

Section 1194.3 General Exceptions

See additional proposals for these provisions to incorporate 255

See new exception proposed for Inherently Visual EIT Assets

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: Done
  • Text from Subpart A Subcommittee
  • Source: {508}1194.3(a), no change

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: In Progress, no consensus reached
  • Text from Subpart A 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
  • Text from Subpart A Subcommittee
  • Source: {508}1194.3(b), 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.

Rationale: The subcommittee has determined this provision is clear as written and does not need any changes

  • Status: Done
  • Text from Subpart A Subcommittee
  • Source: {508}1194.3(c), 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
  • Text from Subpart A Subcommittee
  • Source: {508}1194.3(d), no change

1194.3 - E - Fundamental Alteration

(This section has alternate versions. Rationales are listed at the end of the section.)

Version 1
This part shall not be construed to require a fundamental alteration in the nature of the E&IT, or its components, given the agency's specified product requirements, or business need.

Version 2 (Current Provision)
This part shall not be construed to require a fundamental alteration in the nature of a product or its components.

Rationale for Version 1: This proposed language specifically reminds agencies that their implementation of Section 508 must support both the agency's mission as well as their responsibilities under Section 508. This version also links the fundamental alteration to the agency's 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).

Rationale for Version 2: Some TEITAC members indicated the additional language in version 1 is not needed as it is implicit. They recommend keeping the provision as it currently is.

1194.3 - F - Service Areas

(This section has alternate versions. Rationales are listed at the end of the section.)

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 and whose controls or interfaces can be executed solely from these spaces are not required to comply with this part. This part does apply to E&IT designed for spaces frequented only by service personnel, but whose controls or interfaces can be executed externally or remotely.

Version 2
Remove the provision entirely.

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.

Rationale for Version 2: 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.

1194.3 - NEW - Narrow, Delineated Use

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: Much discussion has transpired regarding the need to address situations where conformance to the technical and performance standards creates access barriers by loading up a single product with multiple access features. For example, requiring all calculators to have speech output, large visual display, enlarged keys, and other access features built-in actually creates access barriers depending on the functional limitations of individuals with disabilities. While some committee members are supportive of creating an exception to address this problem, other do not support pursuing this idea. While much discussion has taken place and alternatives have been explored, such as identifying products as "personal-private" that could be considered as part of a product line (see proposed personal-private definition), consensus has not been reached on a viable approach to addressing the problem.

Section 1194.4 Definitions

The following definitions apply to this part:

See proposed added definitions from Section 255/FCC

  • Customer premises equipment
  • Interconnected Voice over Internet Protocol (VoIP) Product
  • Interconnected Voice over Internet Protocol (VoIP) Service
  • Manufacturer
  • Peripheral devices
  • Readily achievable
  • Specialized customer premises equipment
  • Telecommunications equipment
  • Telecommunications service
  • Usable

Agency

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

Status: Done
Text from: Subpart A

Application Software

Software which runs on and makes use of services provided by platform software. This includes "desktop" software bundled with an operating system, personal productivity applications, development tools, Web browsers, and other non-OS software.

Status: Done
Text from: Web and Software Subcommittee.

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 and information technology.

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

Note: Abbreviated as "AT"

Status: Done
Text from: Subpart A

Authoring Tools

Any software intended to create or modify content for publication.

  • Note: This is intended to include only tools where the software is able to create or modify content in that format for publication, and the format is enabled to support compliance with the user interface and content provisions.

editorial suggestion for the note: This definition covers authoring tools which are able to create or modify content in a format that supports compliance with the user interface and content provisions.

Status: Done
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

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: Done See comment in sandbox page
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 See notes in sandbox page
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.

Explanatory Note
This definition is derived from Clinger-Cohen and cannot be changed. 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

Status: Done See notes in sandbox page
Text from: Subpart A
Source: Clinger-Cohen

Free-Standing 

Discussion of Work in Progress
* The subcommittee is requesting input on whether this should be defined 
  since it is used in other parts of the ADA regulations and could have impacts there.

Status: In Progress
Text coming from Hardware


Functional equivalent to TV closed captions

User-controllable features equivalent to CEA 708 display of caption text must comply with 3.B (Contrast), 3.E (Color Adjustment), and 1.2.J (Text size) directly or through assistive technology in order to provide a functional equivalent of the primary FCC user-controllable features.

Status: Done
Text from Audio/Visual

General Flash and Red Flash Thresholds

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

  1. There are more than 3 General Flashes and/or more than 3 Red Flashes within any one-second period; and
  2. The flashing is below 50 Hz; and
  3. The combined area of flashes occurring concurrently occupy an area of 0.006 steradians or more of any 10 degrees of visual field on the screen (25% of 10 degrees of visual field) at typical viewing distance, and where:
    • A General 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; where an "a pair of opposing changes" is an increase followed by a decrease, or a decrease followed by an increase, and
    • A Red Flash is defined as any pair of opposing transitions involving a saturated red.

Exception: The flashing is a fine balanced alternating pattern such a white noise or a checkerboard-like pattern with ‘squares’ smaller than 0.5 degree on a side (area less than .000125 steradians).


Note 1: For general software or 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 (e.g. 15-17 inch screen at 22-24 inches). (Higher resolutions yield smaller and safer images so lower resolutions are used to define the thresholds.)

Note 2: The current working definition of 'opposing transitions involving a saturated red' is where, for either or both states involved in each transition, R/(R+ G + B) >= 0.8, and the change in the value of (R-G-B)x320 is > 20 (negative values of (R-G-B)x320 are set to zero) for both transitions. R, G, B values range from 0-1 as specified in “relative luminance” definition. (Harding and Binnie 2002)

Note 3: Tools are available that will carry out analysis from video screen capture.

Note 4: No tool is necessary to evaluate for this condition if flashing is less than or equal to 3 in any one second or greater than 50Hz. Content automatically passes (see #1 and #2 above)

Note 5: 50Hz is used to coincide with the AC line frequency in Europe and other countries. However almost half of the population is susceptible to 50Hz flashing whereas only 15% are susceptible to 60Hz. 75Hz or higher is recommended where possible.


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

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 See notes in sandbox page
Text from: Telecommunications
Source: HFES 200

Non-text Object

Any object that is not a sequence of characters that can be programmatically determined or where the sequence is not expressing something in human language

  • Note: This includes, but is not limited to, ASCII Art (which is a pattern of characters), emoticons, leetspeak (which is character substitution), and images representing text.

Status: Done
Text from: Web/Software

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

Platform Accessibility Services

Services provided by a platform enabling interoperability with assistive technology, commonly 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, and that provides a set of software services to applications which allows them to be isolated from the underlying software or hardware layer.

  1. Note: For our purposes, it is those software components/services provided to applications for the creation or manipulation of user interfaces and user input - that impact accessibility - which are of concern for whether something is a platform or not. An application offering a compute service, such as a 3d rendering engine where a requesting application isn't using the software components/services to create a user interface and interact with the user, should not be considered a "platform".
  2. Note: If applications typically connect directly to the underlying layer, rather than relying solely on the platform software components and services, then it is likely that the software components in the middle are not acting as 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.
  3. Note: 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.

Status: Done
Text from: Web/Software

Programatically Determinable

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 See notes in sandbox page
Text from: Telecommunications

Relative Luminance

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

Notes:
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

Notes on the formulas

  • The "^" character is the exponentiation operator. (Formula taken from [sRGB] and [IEC-4WD]).
  • 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.
  • For dithered colors, use average values of the colors used (average R, average G, and average B).
  • Tools are available that automatically do the calculations when testing contrast and flash.
  • A MathML version of the relative luminance definition is available.

Status: Done
Text from: Web/Software

Synchronized Media

Audio or video displayed at the same time as other time-based content that is required for understanding of the complete presentation. The other content that the audio or video is synchronized with to meet this definition does not include equivalents such as captions, subtitles, or video description.

Status: Done
Text from: A/V

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 and/or software 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: Done
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.

Rationale 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. This definition should not conflict with these guidelines

Status: Done
Text from: Audio-Video
External Reference: Guidelines (draft) from the Described and Captioned Media Program (U.S. Department of Education)

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.

Rationale: The subcommittee has determined this provision is clear as written and does not need any changes

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

Technical Provisions

1. Requirements for All Product and Services

1.1 Functional Performance Criteria

The functional performance criteria have three roles:

  1. If any of the technical provisions are not met, the Functional Performance Criteria can be used to see if access is provided in another way (i.e. through equivalent facilitation).
  2. The Functional Performance Criteria can be used to see if the technical provisions cover all aspects needed to provide access to the product. (i.e overall evaluation)
  3. The Functional Performance Criteria can be used to help identify and report functions (of a partially conforming product) that would not meet the Functional Performance Criteria (and would therefore not work with employees and/or public users with disabilities) so that agency can evaluate the importance of lack of access to those functions to the intended use of the product.


1.1-A - Without Vision

Products must provide at least one mode that allows access to all functionality of the product without using vision. This access may be provided directly or through assistive technology.

  • Status: Done See proposed updates to this provision
  • Text from General
  • Source: {508}1194.31(a), {255}1193.31
  • Impact:
  • External Reference:
  • Testability: Expert evaluation
  • Metadata
    • Disabilities: Blindness
    • User Activities: All
    • Product Characteristics: All
    • Product Types: All

1.1-B - With Limited Vision

Products must provide at least one mode that allows access to all functionality of the product visually without requiring visual acuity greater than 20/70. This access may be provided directly or through assistive technology.

  • Status: Done See proposed updates to this provision
  • Text from General
  • Source: {508}1194.31(b), {255}1193.41(b)
  • Impact:
  • External Reference:
  • Testability: Expert evaluation
  • Metadata
    • Disabilities: Low vision
    • User Activities: All
    • Product Characteristics: All
    • Product Types: All

1.1-C - With Color Vision Deficits

Products must provide at least one mode that allows access to all functionality of the product for people with color vision deficits.

Note: This provision can be met by meeting the color and contrast requirements below.

  • Status: Done See proposed updates to this provision
  • Text from General
  • Source: new
  • Impact:
  • External Reference:
  • Testability: Expert evaluation
  • 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 to all functionality of the product without using hearing. This access may be provided directly or through assistive technology.

  • Status: Done See proposed updates to this provision
  • Text from General
  • Source: {508}1194.31(c), {255}1193.41(d)
  • Impact:
  • External Reference:
  • Testability: Expert evaluation
  • 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 to all functionality of the product with enhanced audio. This access may be provided directly or through assistive technology.

  • Status: Done See proposed updates to this provision
  • Text from General
  • Source: {508}1194.31(d), {255}1193.41(b)
  • Impact:
  • External Reference:
  • Testability: Expert evaluation
  • 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 to all functionality of the product without user speech. This access may be provided directly or through assistive technology.

  • Status: Done See proposed updates to this provision
  • Text from General
  • Source: {508}1194.31(e), {255}1193.41(h)
  • Impact:
  • External Reference:
  • Testability: Expert evaluation
  • 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 to all functionality of the product for people with limited reach and strength, and that does not require simultaneous actions. This access may be provided directly or through assistive technology.

  • Status: Done See proposed updates to this provision
  • Text from General
  • Source: {255}1193.41(e)
  • Impact:
  • External Reference:
  • Testability: Expert evaluation
  • Metadata
    • Disabilities: Dexterity, Mobility
    • User Activities: All
    • Product Characteristics: All
    • Product Types: All

1.1-H - Without Physical Contact

Products must provide at least one mode that allows access to all functionality of the product without requiring any physical contact with the product beyond initial connection and setup of a special interface device. This access may be provided directly or through assistive technology.

Note: While it is preferable that no contact at all be required, the use of a standard physical connection such as a USB would meet this provision.

Explanatory Notes

  • Use of cameras to monitor user movement to control input would meet this provision.
  • Allowing users to control the product using their own communication or control via a universal wireless connection would also meet this provision.
    • ANSI/INCITS URC standard would be one
    • Wireless USB would be another solution
  • A connection is allowed since it may be necessary. Individuals could have a companion or bystander connect them and still allow them privacy in completing the transaction. Methods not requiring any contact or assistance of course are preferred.

Rationale: A large population of people with physical disabilities cannot reach out to touch a product or cannot reach out long enough to actually operate a product physically. The Forrester Study by Microsoft cited people with physical disabilities as being second only to blindness and low vision as providing difficulties in using computers.

  • Status: In Progress See proposed updates to this provision'
  • Text from General
  • Source: new
  • Impact:
  • External Reference:
  • Testability: Expert evaluation
  • Metadata
    • Disabilities: Dexterity, Mobility
    • User Activities: All
    • Product Characteristics: All
    • Product Types: All

1.1-I - With Cognitive, Language or Learning Limitations

This provision need different language from others in this section, and decisions about inclusion and language have not been made yet.

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

1.2 General Technical Requirements

1.2-A - Accessibility Configuration

In complying with this subpart, each agency must activate accessibility features and configure products so that they are accessible to and usable by people with disabilities.

  • Status: Done See proposed updates for this provision
  • Text from Telecommunications
  • Source: new
  • Impact:
  • External Reference:
  • Testability:
  • Metadata
    • Disabilities: All
    • User Activities: All
    • Product Characteristics: All
    • Product Types: All

1.2-B - Accessible Content

Go to the text proposal created at the November plenary

In complying with this subpart, each agency must operate software in a manner such that output from the software that is distributed or archived by the agency is made accessible to people with disabilities.

Rationale:

  • Status: Done
  • Text from Web/Software
  • Source: new
  • Impact:
  • External Reference:
  • Testability:
  • Metadata
    • Disabilities: All
    • User Activities: All
    • Product Characteristics: All
    • Product Types: All

1.2-C - Closed Functionality

If any functionality of a product is closed for any reason including policy constraints or technical limitations then that closed functionality must be made available to and operable by people with disabilities within the product itself and the following provisions would not apply to that functionality:

  • 2.1-E - Connector or Connection Language
  • 3-F - All Non-Text Objects
  • 3-G - Human Language
  • 3-H - Language of Parts
  • 3-N - Link Purpose
  • 3-O - Information and Relationships
  • 3-P - User Interface Components
  • 3-U - AT Interoperability
  • 3-W - Accessibility Services

Rationale:

  • Status: Done - updated 19 Oct (was 1.2-B in Sept 14 draft) See proposed updates for this provision
  • Text from Self Contained, Closed
  • Source: {508}1194.25(a)
  • Impact:
  • External Reference:
  • Testability: Expert evaluation
  • Metadata
    • Disabilities: All
    • User Activities: All
    • Product Characteristics: All
    • Product Types: All


1.2-D - Biometric ID

If a product uses a biometric form of user identification which relies on a person possessing one unique biological characteristic that some people may not have, an alternative form of identification must also be provided.

Agencies must provide an alternate, biometric or non-biometric, means of access for anyone who can not use the provided biometrics-based form of identification.

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.

Note: Fingerprints and iris patterns are two examples of “unique biological characteristics that some people may not have.”

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

  • Status: Done See minority report comments
  • Text from: General
  • Source: {508}1194.25(d), {508}1194.26(c)
  • Impact:
  • External Reference:
  • Testability: Inspection
  • Metadata
    • Disabilities: All (that could be caused by loss body part or function)
    • User Activities: All
    • Product Characteristics: All
    • Product Types: All

1.2-E - 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.

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%.

Rationale:

  • Status: Done See proposed updates to this provision
  • Text from Telecommunications
  • Source: {508}1194.23(j), {255}1193.37
  • Impact:
  • External Reference:
  • Testability: Inspection
  • Metadata
    • Disabilities:
    • User Activities:
    • Product Characteristics:
    • Product Types:

1.2-F - 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.

Note: Audio content that includes spoken content and that is closed due to DRM such that it cannot be rendered in visual form by AT and other players must include an visual form that can be.

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

1.2-G - 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.

Note: Visual content that includes text and that is closed due to DRM such that it cannot be rendered in audio form by AT and other players must include an audio form that can be.

  • Status: Done - updated 19 Oct See proposed updates
  • Text from Self-Contained/Closed
  • Source: {255}1194.43(a)
  • Impact:
  • External Reference:
  • Testability: Expert evaluation
  • Metadata
    • Disabilities: Blind, Low Vision
    • User Activities: All
    • Product Characteristics: Visual display with text, Visual display with graphics
    • Product Types: All

1.2-H - 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.

Note: This provision is harmonized with 3.A

Rationale:

  • Status: In Progress
  • Text from Web/Software
  • Source: {508}1194.25(g) and 1194.21(i)
  • Impact:
  • External Reference: Harmonized with WCAG 2.0 and ISO 9241.171
  • Testability: Expert evaluation
  • Metadata
    • Disabilities: Color deficiency/Colorblindness
    • User Activities: All
    • Product Characteristics: Uses Color (on keys, labels, displays, indicators, anywhere etc.)
    • Product Types: All

1.2-I - Text size

There must be at least one mode where all information that is required for product use and is provided in text is readable by people with 20/20 vision at 3.5 times their typical viewing distance. This mode must be the default mode unless the activation method for that mode can be done at 3.5 times the typical viewing distance or the product automatically sets itself to that mode for users who require it.

Note: Providing text in an accessible file on a device meets this requirement for information that is not location specific (e.g. labels are location specific).

Rationale:

  • This is harmonized with the measurements for 3-U (focus cursor size), but neutral to the size of screen. For text on screen, this measurement might be sufficient, or this note can be incorporated:
    • "A focus cursor that is visually locatable by people with unimpaired vision at 2.5 meters when software is displayed on a 38 cm (15 inch) diagonal screen at 1024 x 768 pixels resolution, without moving the cursor is sufficient." 
 Work in Progress
 * The SC has asked a vision scientist for input on how to word this 
   provision, and is waiting for his reply.
  • Status: In Progress See proposed updates
  • Text from Self-Contained/Closed
  • Source: {255}1193.43(b)
  • Impact:
  • External Reference:
  • Testability: Inspection
  • Metadata
    • Disabilities: Low vision
    • User Activities: All
    • Product Characteristics: Visual display with text
    • Product Types: All

2. Hardware Aspects of Products

2.1 All Products with Hardware

2.1-A - Luminance Contrast Ratio for Display

Version 1:
For displays on products, at least one mode must exist where the contrast ratio between the luminance at light state compared to luminance at dark state shall be 5:1.

  • Note: Light (or high) state typically refers to the lighter condition for the display. For example, white content/background on an LCD. Dark (or low) state typically refers to the darker condition for the display. For example, black content/background on an LCD.

Version 2:
Remove this provision since display technologies have changed.

Rationale:

  • Status: In Progress See work in progress list
  • Text from Hardware
  • Source: {508} 1194.26(b); {508} 1194.25(c)
  • Impact:
  • External Reference:
  • Testability: Formal test method
  • Metadata
    • Disabilities:
    • User Activities:
    • Product Characteristics:
    • Product Types:

2.1-B - Reflectance Contrast for Legends and Passive Displays

If the legend or instructions on the device are the only means of conveying information, then the luminance contrast shall be at least 3:1.

Note: If other means of conveying the information in the label or instructions exists (e.g. uniquely tactilely discernible though shape), then the luminance contrast requirement does not apply.

Note: This requirement excludes product information labels, such as the regulatory labels, where information can be found in other sources associated with the product either in hard- or soft copy format.

Note: Reflectance contrast (RC) is calculated in the following manner RC = (R(h) +0.02)/(R(l)+0.02) where R(h) = Reflectance of high (bright) element; R(s) = Reflectance of low (dark) element. Where the reflectance is always a value between 0 and 1.

Note: Additionally, I think we need to convey at least for computers that there are different levels. E.G the alphanumeric labels are the primary labels and should meet this convention; however, the secondary functions (such as the blue numbers on an embedded numpad on a notebook) should not meet this convention as they are infrequently used and in the case of the numpad may add to visual clutter and additional confusion relative to the keyboard interaction.

Rationale:

  • Status: In Progress See work in progress list
  • Text from Hardware
  • Source: {508} 1194.26(b); {508} 1194.25(c)
  • Impact:
  • External Reference:
  • Testability: Formal test method
  • Metadata
    • Disabilities:
    • User Activities:
    • Product Characteristics:
    • Product Types:

2.1-C - Flashing

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

  • Flashing created by software or content is under the general flash and red flash threshold provisions in Section 3.
  • Flashing created by hardware is either:
    • less than YYY candelas; or
    • less than 20 candelas/sq meter and contiguously occupies more than a total

of 0.006 steradians or more within any 10 degrees of visual field (25% of any 10 degree visual field).


  • Status: In Progress (was 1.2-C in Sept 14 draft)
  • Text from (General transfer to Hardware and Web/Software)
  • Source: {508}1194.21(k) 1194.22(j) 1194.25(i), and {255}1193.43(f)
  • Impact:
  • External Reference:
  • Testability: Inspection
  • Metadata
    • Disabilities: All
    • User Activities: All
    • Product Characteristics: All
    • Product Types: All

2.1-D - 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.

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

  • Status: Done See work in progress list
  • Text from Hardware
  • Source: {508} 1194.26(a); 1194.23(k)
  • Impact:
  • External Reference:
  • Testability: Inspection
  • 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-E - Touch Operated Controls

Version 1
If a product utilizes touch screens or touch-operated controls then the product must provide, without requiring user-speech:

  1. A functionally equivalent, alternate means of operation that uses Mechanical Controls and does not require vision.
  2. A functionally equivalent, alternate means of operation that does not require fine motor control.

Note: This provision should not discourage the provision of control via user speech in addition to the above methods.

Version 2 (proposal from plenary)
 If a product uses touch screens or touch-operated controls, it must provide a functionally equivalent alternative means of operation that meets the requirements for Mechanical Controls. This alternative must not require either vision or fine motor control.

Note: A product may also provide control via user speech in addition to the above methods.

Rationale: This language addresses the issues associated with touch-based controls (including biophysical, accidental activation and vision) by requiring a redundant interaction method without assigning the control type.

  • Status: In Progress See work in progress list
  • Text from Hardware
  • Source: {508} 1194.26(b); {508} 1194.25(c)
  • Impact:
  • External Reference:
  • Testability: Inspection
  • 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 - Standard Connection

If users can access and control the user interface of a product through a non-standard user connection, they must also be able to control that functionality through a standard user connection using standard protocols for that type of input or output. If an adapter is required to convert a non-standard user connection on an E&IT device into a standard user connection, it shall be the responsibility of the E&IT vendor to offer such adapter.

Note: "Standard Connection" shall be deemed to be a connection that has been readily adopted by industry and is in common and current use. For example, while a serial port with a DB25 connector used for mouse input was a standard connection many years ago, it is no longer in common and current use on modern computers, and would no longer be considered a standard connection.

Rationale: The change to the word "connection" allows for wireless

  • Status: Done See work in progress list
  • Text from Hardware and Telecommunications
  • Source: {508} 1194.26(d)
  • Impact:
  • External Reference:
  • Testability: Inspection
  • 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-G - Installed or Free-Standing Products

Architecturally installed or free-standing non-portable products intended to be used in one location must have any operable controls positioned within reach.

Note: The Access Board should insert the appropriate reach-range ADAAG requirements at time of adoption.

Rationale: This provision should be coordinated with the ADAAG, which is currently the process of being updated.

  • Status: Done
  • Text from Hardware
  • Source: {508} 1194.25(j)
  • Impact:
  • External Reference: ADAAG
  • Testability: Inspection
  • 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

Products that deliver output with an audio transducer that 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 does not apply to headphone, headset, OR other accessories that plug into a jack on the product.

Advisory Note: Cellular and PCS handsets that meet a minimum of M3 or M4 and T3 or T4 measurement rating per ANSI C63.19 (2007) will meet this requirement for "lowest possible level." Devices in other frequency bands (700 MHz, AWS) are not yet included in this standard, but may be included at a later time. Digital wireline cordless devices that meet TIA-1083 will meet the “lowest possible level” standard for those types of devices.

Rationale:

  • Status: Done See work in progress list
  • Text from Hardware and Telecommunications
  • Source: {508}1194.23(h), {255}11943.43(i)
  • Impact:
  • External Reference: ANSI C63.19 (2007), TIA-1083
  • Testability: Formal test method
  • Metadata
    • Disabilities:
    • User Activities:
    • Product Characteristics:
    • Product Types:

2.2-B - Interference with Hearing Device

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.

NOTE: Cellular and PCS handsets that meet a minimum of M3 or M4 and T3 or T4 measurement rating per ANSI C63.19 (2007) will meet this requirement for “lowest possible level.” Devices in other frequency bands (700 MHz, AWS) are not yet included in this standard, but may be so at a later time. Digital wireline cordless devices that meet TIA-1083 will meet the “lowest possible level” standard for those types of devices.

Rationale:

  • Status: In Progress See work in progress list
  • Text from Hardware and Telecommunications
  • Source: {508}1194.23(i), {255}1193.43(h)
  • Impact: minimal
  • External Reference: (see note above)
  • Testability: Formal test method
  • Metadata
    • Disabilities: Hearing, Hard of Hearing
    • User Activities:
    • Product Characteristics:
    • Product Types:

2.2-C - Audio Connection

Version 1:

When products provide auditory output beyond simple tonal feedback or signaling, the audio signal must be provided at a standard signal level through an industry standard connection that will allow for private listening.

  • If the product is a public-shared product then the connection must be via a standard 2.5mm or 3.5mm audio jack.
  • If the product is personal-private product then the connection can be wired or wireless as long as a 2.5mm or 3.5mm phone jack adapter is available from the manufacturer.

Alternate wording for clarity

  • Public-shared products must provide the connection via a standard 2.5mm or 3.5mm audio jack.
  • Personal-private products may provide either a wired or wireless connection. A wired connection must be via a standard 2.5mm or 3.5mm audio jack. A wireless connection may be used as long as a 2.5mm or 3.5mm phone jack adapter is available from the manufacturer.

Version 2, posted to plenary email Oct 19, 2007:

When products provide auditory output beyond simple tonal feedback or signaling, the audio signal must be provided through an industry standard connection that will allow for private listening.

  • Public-shared products must provide the connection via a standard 2.5mm or 3.5mm phone jack or RCA audio jack.
  • Personal-private products must provide either a 2.5mm or 3.5mm phone jack or a wired or wireless connection that has a 2.5mm or 3.5mm phone jack adapter that is commonly available.

Version 3, posted to plenary email Oct 20, 2007:

When products provide auditory output beyond simple tonal feedback or signaling, one of the following must be true:

  1. Conforming Handset: Auditory output is available via audio transducer that is designed to be held up to the ear that meets 2.2-A (Magnetic Coupling), 2.2-B (Interference with Hearing Device), and 2.2-E (Volume - gain) and product does not require simultaneous use of keyboard; or
  2. Phone Jack: A standard 2.5mm or 3.5mm audio jack for headphones/headsets is provided or
  3. Any Connection with Adapter avail: Product is a not designed to be located in a public location and an adapter from the product's audio output format to a 2.5mm or 3.5mm phone jack is commonly available or available from the manufacturer.
  4. Public Display only: Product is designed for public audio or audio-video display only and there is a standard audio output on the product-system (which can be but does not need to be accessible to the public).
  • Note: RJ-9, RCA, USB, and Bluetooth connections all have commonly available adapters. Products (not designed for public locations) with these or other forms of audio connection that have adapters would meet 2.2-C-(c)
  • Note: Public Display systems need to meet other provisions in the guidelines including the ability to display captions and supplemental audio.


Rationale:

  • Status: In Progress See work in progress list
  • Text from Hardware
  • Source: {508} 1194.25(e); {255} 1193.51(b) & (g)
  • Impact:
  • External Reference:
  • Testability: Inspection
  • 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 auditory output beyond simple tonal feedback or signaling 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 located in a public place, the maximum volume level must be at least 80 dB SPL RMS, measured at xx centimeters from the device at maximum volume setting [possible without XXX distortion].
  • 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.

Rationale:

  • Status: In Progress See work in progress list
  • Text from Self-Contained/Closed
  • Source: {508}1194.25(f), {255}1193.43(e)
  • Impact:
  • External Reference:
  • Testability: Formal test method
  • 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. Users must be able to adjust the audio output level.
  2. All telecommunications products powered solely from analog telephone lines and having an audio transducer normally held to the ear, and all cordless telephones, must comply with FCC regulation §68.317 for volume control.
  3. All cellular telephones – TBD.
  4. All other products that provide a voice communication function via an audio transducer normally held to the ear must comply with FCC regulation §68.317 for volume control. In addition, they must provide built-in gain of at least 15 dB above the normal unamplified level when measured as specified in FCC regulation §68.317.

NOTE: Headsets and earphones are not subject to this provision as long as they use industry standard connectors that allow specialized headsets, earphones and coupling cables for assistive listening devices to be used in their place. 3.5mm phone, 2.5mm phone, and RJ-10 are all examples of industry standard connectors that meet this requirement.

Rationale: The following notes are to be included either within the provision or advisory notes. Location is to be determined by EWG.

NOTE 1: The provision of volume control gain is not particularly related to whether the voice communication is carried by an analog signal, digital encoding, packet technology (e.g., VoIP), etc. It does, however, depend on the power available to the amplifier providing the gain function. This distinction has been taken into account in specifying the volume control gain requirements. For example the requirements for a battery-powered cordless telephone applies whether the product uses analog, digital or VoIP technology.

NOTE 2: FCC regulation §68.317 requires both analog and digital telephones to provide between 12 and 18 dB of gain at the maximum volume control setting relative to their volume at the normal unamplified level. The gain is allowed to exceed 18 dB if it is automatically reset to the nominal level when the telephone goes back on hook. [The FCC also has a procedure described in Memorandum Opinion and Order DA 01-578 for waiving the automatic reset requirement for telephones specifically designed for use by hard of hearing persons, provided adequate warnings are placed on the telephone.] In addition, the volume at the normal unamplified level has to meet requirements specified in industry standards ANSI/EIA-470-A-1987 (for analog telephones) and ANSI/EIA/TIA-571-1991 (for digital telephones).

NOTE 3: FCC regulation §68.317 makes reference to older industry standards in specifying how to measure the receive acoustic loudness and determine compliance with requirements for both gain and loudness at the normal unamplified level. Clause 15.2 of TIA TSB-31-C, Telecommunications – Telephone Terminal Equipment – Rationale and Measurement Guidelines for U.S. Network Protection, provides guidance on how to apply these requirements to test methods specified in current standards, including measurement procedures for analog, digital, and VoIP telephones.

NOTE 4: Other products or systems that provide a voice communication function, including products and systems that do not have an audio transducer that is normally held to the ear, such as speakerphones, should provide at least 15 dB of volume control range above the normal unamplified listening level. In these cases of speakerphones, it is desirable for the volume control to provide at least 15 dB of gain above the normal unamplified level, but there is no agreed upon specification as to what constitutes the normal unamplified level.

NOTE 5: Volume (gain) on cellular and PCS handsets is currently the focus of review and study in Working Group 11 of the ATIS Incubator program which is expected to be available no later than June 2008. It is recommended that no recommendation be made at this time by the TEITAC, but rather, the recommendations from the study can be given to the Access Board.

  • Status: In Progress