EWG:Draft July 18
From TEITAC
Editorial Working Group > Working Draft for July 16-18
TEITAC Working Draft - July 16-18, 2007.
This draft has been replaced by the August 17 drafts
This page is the working draft with the latest versions of the work of the TEITAC. It contains all updates since the July 6 Draft, including work during the July 16-18 plenary.
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. Information included in () was added at the July pelary meeting and needs resolution if it will be kept.
Proposed updates and other comments for this section
Section 1194.1 Purpose
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.
Status: Done
Source: {508}1194.1, no change
Section 1194.2 Application
In general, this section applies only to the (consideration, provisions or determination- need to determince which word to be used) of accessibility in the process of developing, procuring, maintaining, or using electronic and information technology.
Status: In Progress
Source: New
Discussion or Rationale: This is additional language to clarify that all of the regulations in this section that impact agency procurement procedures, apply only to the consideration of accessibility and does not provide regulatory direction regarding consideration of other factors such as business and technical needs. Some subcommittee members indicated that this limitation was sufficiently provided via § 1194.1 Purpose and the new language was not necessary. No agreement on if the notes should be included or not.
Work in Progress:
- See notes in A.2.B - subcommittee asked to go back and summarize discussions
1194.2- A - Product and Services Covered
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 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.
Status: Done
Source: {508}1194.2
Discussion or Rationale: Aligns wording of regulation with statute language.
1194.2- B - Procurement
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.
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.
Status: In Progress
Source: {508}1194.2
Discussion or Rationale: 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.
Rationale for the additional text: Provides 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. 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.
From the July plenary meeting: General agreement to not include the addition of the "Note for Procurements".
Work in progress:
- Subcommittee asked to go back and summarize issues.
- Change "product" to "E&IT"
1194.2- C - Application to E&IT
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.
Status: Done
Source: {508}1194.2, no change
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 - 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
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. (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. (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.
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 agency's specified product requirements or business need.
Status: In Progress
Source: {508}1194.3
Discussion or Rationale: 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.
1194.3 - F - Service Areas
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.
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)
Status: In Progress
Source: {508}1194.3
Discussion or Rationale: Additional wording attempts to restrict this exception to products that are not only 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.
Some TEITAC members and subcommittee members recommend the entire exception should be deleted and all products should conform regardless of location and use.
Others want to keep May 30 language
1194.3 - G - 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 users with disabilities.
Status: In Progress
Source: {508}1194.3
Discussion or Rationale: To eliminate the application of all functional performance and technical standards to these types of products which results in purchase of one product with multiple unwanted and sometimes conflicting access features.
Some TEITAC members suggested this might be described as a “product line” approach and could be expanded to clearly include this concept.
Some subcommittee members also voiced the opinion this new exception is not needed.
Section 1194.4 Definitions
The following definitions apply to this part:
Ad Hoc Addition
Addition by user without requiring system administrator intervention
Text from: Telecommunications
Discussion or Rationale: There may be the need to limit the "ad hoc addition" requirement to public or shared-use phones rather than personal workstation phones although people often share common desks or desks at remote offices etc.
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.
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: In Progress
Text from: Subpart A
Discussion or Rationale: Added language clarifying that assistive technology includes web based and integration services.
- Subcommittee could not reach consensus on suggestion to add list of required AT to the defintion (one subcommittee member dissented because a list of AT was not included.) Support for an AT list was to ensure more ready access to items on the list. Many subcommittee members were opposed to an AT list due to concerns with lists becoming too long, outdated, misapplied as absolutes, etc. An alternative suggestion was for technical assistance that would reference AT resource lists such as the federal CAP listing of assistive technology used in accommodations (http://www.tricare.mil/cap/acc_sol/Assistive_Technology.cfm) or the Assistive Technology Act federally funded National Public Website on Assistive Technology (http://assistivetech.net). Another alternative suggestion was for the Access Board to recommending that each agency compile a list of the AT typically used in that agency.
Authoring Tools
- Text coming from Web and Software Subcommittee
Captions
Captions are synchronized text equivalents for audio information. Captions are similar to subtitles in that they convey the content of spoken dialogue, 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
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, or policy limitation.
NOTES:
- 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.
Status: In Progress
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 defintion 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.
Work in Progress
- Put this back in application section. Laura will build a group to work on this (exact mechanism to be determined)
- Diane will draft proposed text
Content
- Text coming from Web and Software Subcommittee
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
- Contrast ratios can range from 1 to 21 (commonly written 1:1 to 21:1).
- For dithered colors, use the average values of the colors that are dithered (average R, average G, and average B).
- Text can be evaluated with anti-aliasing turned off.
- 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.
- 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
Decorative Animation
- Text coming from Web and Software Subcommittee
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
General Flash and Red Flash Thresholds
A sequence of flashes or rapidly changing image sequences where all three of the following occur:
- There are more than three flashes within any one-second period; and
- The flashing is below 50 Hz; and
- 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
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: Progress
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: In Progress
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.
Should this be "physically operable controls" so it is more specific - and change this term in the provisions. Hardware to take and resolve.
Other Services To Cooperate With Assistive Technologies
- Text coming from Web and Software Subcommittee
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 (was Accessibility Services)
Services provided by a platform enabling interoperability with assistive technology simetimes in the form of accessibility APIs (application programming interfaces)
Status: Done
Text from: Web/Software
Platform Software
- Text coming from Web and Software Subcommittee
Product
Electronic and information technology.
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
Pure Decoration
- Text coming from Web and Software Subcommittee
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
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.
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.
Status: Done
Text from: Audio-Video
Web Content
- Text coming from Web and Software Subcommittee
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
1.1 Functional Performance Criteria
Status: in Progress See discussion page
1.1-A - Without Vision
At least one mode must be provided that allows comparable access to product without using vision, directly or via AT.
1.1-B - With Limited Vision
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.
1.1-C - With Color Vision Deficits
At least one mode must be provided that allows comparable access to product with color vision deficits.
Work in progress:
- 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.
1.1-D - Without Hearing
At least one mode must be provided that allows comparable access to product without using hearing, directly or via AT.
1.1-E - With Limited Hearing
Where audio information is important for the use of a product, at least one mode must be provided that allows comparable access to product with enhanced audio, directly or via AT.
1.1-F - Without Speech
At least one mode must be provided that allows comparable access to product without using speech, directly or via AT.
1.1-G - With Limited Reach, Strength, or Manipulation
At least one mode must be provided that allows comparable access to product with limited reach and strength and without simultaneous actions, directly or via AT.
Discussion or Rationale: Adds AT option.
1.1-H - With No Reach or Touch
(provision text still being written)
Status: In Progress
Source: New
Discussion: This provision is proposed to addess 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 issue, but we haven't yet figured out wording that we can reach consensus on.
The Self-Contained/Closed group suggests that we start this item with the words "Except for Closed products,..."
1.1-I - With Cognitive, Language or Learning Limitations
(provision text still being written)
Status: In Progress
Source: New
Discussion or Rationale: This provision is here as a placeholder. The general group identified the following issues and questions in trying to move this forward.
1.2 General Technical Requirements
Updates and discussion for provisions in this section
1.2-A - Closed Products and Functions
If any product functionality is closed, then individuals with disabilities must have comparable 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 provision AUDIO CONNECTION is not considered assistive technology.
Status: Done
Source: {508}1194.25(a)
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).
Status: In Progress
Source: {508}1194.21(k) 1194.22(j) 1194.25(i), and {255}1193.43(f)
Work in Progress:
- The hardware portion of this provision is still under development.
1.2-C - Biometric ID
If biometric forms of user identification or control are used, an alternative form of identification or activation must also be provided unless all people can use the biometric device.
Status: In Progress See discussion page
Source: General
Discussion or Rationale: This would allow biometric systems in the future that are based on circulatory system or other characteristics common to all people.
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 communication 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 & real-time text) that are standard for that technology platform without distortion or error beyond 1%.
Only phones that are passing text signals onto another device, e.g. TTY, would be subject to this provision.
Discussion: for PSTN this would be TIA/EIA 825 Baudot.
Status: In Progress (Updated status July 30, 2007)
Source: Telecommunications
1.2-E - Audio information
All information provided in audio form must also be available in visual form.
Status: Done
Source: Self-Contained/Closed
1.2-F - Visual Information
All information provided in visual form must also be available in audio form and, where appropriate, in tactile form.
Status: Done
Source: Self-Contained/Closed
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.
Status: In Progress
Source: {508}1194.25(g) and 1194.21(i)
Work in Progress
- Harmonize with Color (Web)
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.
Status: In Progress
Source: Self-Contained/Closed
Discussion or Rationale: To match ADAAG - Characters
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.
2. Hardware Aspects of Products
Updates and discussion for provisions in this section
2.1 All Products with Hardware
This section has been reordered, with the concurrence of SC chair, and 2.2-A has been incorporated into this section, eliminating section 2.2
2.1-A - Contrast for displays
This is a placeholder for a provision still being written to define contrast for LCD hardware.
Status: In Progress
Source: {508} 1194.26(b); {508} 1194.25(c) (in July 6 was 2.1-D)
Discussion: 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.
2.1-B - Contrast for labels
This is a placeholder for a provision still being written.
Status: In Progress
Source: {508} 1194.26(b); {508} 1194.25(c) (in July 6 was 2.1-E)
Discussion: Define contrast and set limits relative to contrast is necessary if it is the only means of conveying intent
2.1-C - Mechanical Controls
All mechanically operated controls and keys:
- Must be tactilely discernible without activating the controls or keys.
- 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.
- 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.
- The status of all locking or toggle controls or keys must be visually discernible, and discernible either through touch or sound.
Status: In Progress
Source: {508} 1194.26(a); 1194.23(k) (in July 6 was 2.2-A)
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).
Work in progress:
- Suggestion to change 5 lbs to 1lb, but push-back on durability.
- Discussion of an advisory note to have one flat surface: a good guideline, but not necessarily a good regulation -- have to take into account mobile uses of products.
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 - Proposed at Meeting - If a product utilizes touch screens or touch-operated controls, a FUNCTIONALLY equivalent means of input/interaction/control must be provided. ANY MECHANICAL CONTROLS EMPLOYED IN THE EQUIVALENT INPUT/INTERACTION/CONTROL MUST COMPLY WITH THE Mechanical Controls provision.
Status: In Progress
Source: {508} 1194.26(b); {508} 1194.25(c) (in July 6 was 2.1-A)
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 capacitve 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.
Work in Progess:
- Rob to take action item to clarify version 2 language.
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 using industry standard protocols for that type of input or output.
Status: In Progress
Source: {508} 1194.26(d) (in July 6 was 2.1-C)
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.
A second debate regarding who is responsible for "adapters" was not resolved.
Need language to cover Closed.
Suggestion: an adaptor from a proprietary to standard form factor connector would be acceptable.
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.
Action Item: Create task force that includes telcom, starting from the EWG version.
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).
Status: In Progress
Source: {508} 1194.25 j(1-4) (in July 6 was 2.1.B)
Discussion or Rationale: Need to add "freestanding" to the definitions. (Hardware will work on it)
Should apply "as installed and operated" - so this is also a requirement for the agency to not only procure, but install accessible
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.
(Peter Korn) Concerns about height requirement in some server contexts. Doesn't want to invoke fundamental alteration for those situations.
2.2 If the Product has Speech Output or Throughput
This section was 2.3 in July 6)
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: 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 See discussion page
Source: {508}1194.23(h), {255}11943.43(i)
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.
Discussion: This comes from Telecom SC and must be reconciled Hardware SC
Suggestion: (from Mary B) 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.
Status: In Progress See discussion page
Source: {508}1194.23(i), {255}11943.43(h)
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."
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 (Mary B): where are volumes set? that's where you measure from. Does this overlap with 2.3.E
2.2-E - Volume (Gain)
For incoming voice signals:
- Analog line-powered telecommunications products, wireline, and all cordless telephones (wireline or VoIP) must comply with FCC regulation §68.317 for volume control
- All cellular phones - TBD
- 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 provisions of the FCC regulation §68.317 for volume control. The volume at the normal unamplified level setting must also meet the requirement in FCC regulation 68.317.
Status: In Progress
Source: {508}1194.23(f)
Work in Progress:
- Language for cellular phones pending outcome of ATIS Study Group 11 work
- Further research needed for 20 dB requirement
- Review telecoms/communications to be sure requirement is inclusive.
2.2-F - Volume Reset
If the product allows a user to adjust the receive volume to a level greater than 18 dB above normal unamplified level, a function must be provided to automatically reset the volume to a level not greater than 18 dB above normal unamplified level after every use. A manual override control may be provided to prevent the automatic reset, subject to the conditions specified in FCC Memorandum Opinion and Order DA 01-578. This applies to products with transducers held against the ear which are neither headsets nor headphones
Status: Done (Updated status July 30, 2007) See discussion page
Source: {508{1194.23(g)
3. Software & General Behavior Provisions
Proposed updates and other comments for this section
3.1 All products
3.1-A - Disruption of Access Features
Applications must not, except by specific user request, disrupt the features of the platform that have an accessibility usage in the platform developer documentation.
Status: Done
Source: {508}1194.21(b)
3.1-B - Timing
For each time limit that is set by the software, at least one of the following must be true:
- Turn off: the user is allowed to turn off the time limit before encountering it; or
- Adjust: the user is allowed to adjust the time limit before encountering it over a wide range that is at least ten times the length of the default setting; or
- Extend: the user is warned before time expires and given at least 20 seconds to extend the time limit with a simple action (for example, "hit any key"), and the user is allowed to extend the time limit at least ten times; or
- Real-time Exception: the time limit is a required part of a real-time event (for example, an auction), and no alternative to the time limit is possible; or
- Essential Exception: the time limit is part of an activity where timing is essential and time limits can not be extended further without invalidating the activity.
Status: In Progress
Source: {508}1194.25(b)
Work in Progress
- In Adjust, issue with "before encountering"
- In Essential Exception, still discussing the suggestion to add something about data integrity.
- "Sufficient time" is not objectively testable. There are other acceptable strategies for addressing the needs of users who need more time.
Discussion: The recommended change is harmonized with both the ISO Software Accessibility standard and WCAG 2.0.
3.1-C - Software as platform and application
Software that is both a 'platform', and an 'application' running on another platform must:
- expose the underlying platform's color, contrast, and other individual display settings to applications running within its platform, so that these applications can meet the User Preferences provision.
- define, expose, and translate accessibility service information between applications running within its platform and the underlying platform - so that those applications can meet the AT Interoperability provision.
- provide mechanisms for:
- moving the keyboard focus into and out of an application, and
- addressing central conflicts between keyboard mnemonics in the application and the host platform.
Discussion or Rationale: Still to be done is to look at ISO 9241-171 provisions around platform requirements to ensure no harmonization issues.
3.2 If the Product has Visual Output or Display
3.2-A - Contrast
When a product permits a user to adjust color and contrast settings, at least one color selection capable of producing a minimum luminosity contrast ratio of 7:1 must be provided.
- TBD: Add a requirement addressing default contrast.
- TBD: Add something to address unavailable elements.
Discussion or Rationale: The existing provision in Section 508 is ineffective as all software passes it. If software doesn't permit the user to adjust the settings, it passes. If it does permit adjustment, it also passes because "a variety of color selections capable of producing a range of contrast levels shall be provided." is too subjective to determine failure. The recommended provision is harmonized with WCAG 2.0.
3.2-B - Animation
When an informational animation is displayed that will last for more than three seconds, software must give the user a means to pause and restart the animation. When a decorative animation is displayed that will last for more than three seconds, software must give the user a means to stop the animation.
Discussion or Rationale: If animations can be implemented such that they meet the requirements of the standard, static alternatives are not needed. If they can't meet the requirements of the standard, static alternatives can be provided as equivalent facilitation. Even for accessible animations though, users need a way to pause and restart them because they might not be able to take in the information as fast as it is being displayed. Decorative animations don't need to be restarted because they are not conveying information. Stopping decorative animations is sufficient for users who are distracted by them and can't focus on other features of the application.
3.2-C - User Preferences
Applications must utilize user selected contrast and color selections and other individual display attributes when the availability of those selections are developed and documented according to industry standards.
Discussion or Rationale: Subcommittee is still working on this one to define "other individual display attributes" and address the issue of "documented according to industry standards. "Other display attributes" is vague. Need to clarify.
EWG suggested rewording If a function, developed and documented according to industry standards, makes user preferences for contrast, color and other display attributes available, applications must use those selections.
3.3 If the Product has Standard Keyboard or Keyboard Interface
3.3-A - Keyboard
All functionality of the product operable through the user interface must be operable through a keyboard interface without requiring specific timings for individual keystrokes, except where the underlying function requires input that depends on the path of the user's movement and not just the endpoints.
- Note: This exception relates to the underlying function, not the input technique. For example, if using handwriting to enter text, the input technique (handwriting) requires path dependent input but the underlying function (text input) does not.
- Note: This does not forbid and should not discourage providing mouse input or other input methods in addition to keyboard operation.
Discussion or Rationale
- The phrase "textually discernible" is an issue because it is interpreted differently by different people.
- Harmonized with WCAG 2.0 and ISO 9241 part 171.
- Note: in first sentence, verb "is" has been replaced with "must be" - marked with emphasis - for editorial consistency.
3.4 If Software runs on platform with Operating System with AT Support
3.4-A - AT Interoperability
Software that provides user interface objects must either use the accessibility services provided by platform software or other services to cooperate with assistive technologies when such services allow the software to meet the accessibility provisions of this standard. Using such services, software must:
- provide assistive technology with object information including but not limited to:
- role, state(s), boundary, name, and description
- any table row & column, and row & column headers (if the object is in a table)
- current value and any minimum or maximum (if the object represents one of a range of values)
- relationship this object has as a label for another, or being labeled by another
- parent or containing element, and any children objects
- text contents, text attributes, and the boundary of text rendered to the screen
- provide assistive technology with a list of actions that can be executed on an object and allow assistive technology to programmatically execute any of those actions;
- allow assistive technology to track and modify focus, text insertion point, and selection attributes of user interface objects;
- provide assistive technology with notification of events relevant to user interactions, including but not limited to changes in the object's state(s), value, name, description, or boundary
Note: This provision applies to forms in the software.
Discussion or Rationale: The current provisions in Section 508 that address interoperability with AT are 1194.21(c), 1194.21(d) and 1194.21(f). "Sufficient information" in 1194.21(d) is not testable and the three requirements together are insufficient to meet the needs of assistive technology. The proposed provision is much more comprehensive. It details what type of object information must be provided and includes event notification which is critical for assistive technology interoperability. It is also harmonized with ISO 9241 part 171 and is supported by the major accessibility APIs on desktop operating systems. The phrase beginning "or other services to cooperate with assistive technologies" is provided to allow for other methods of cooperating with assistive technology where platforms and APIs are insufficiently mature to support the necessary functions.
3.4-B - Bitmap Icons
When bitmap images are used to identify controls, status indicators, or other programmatic elements, the meaning assigned to those images must be consistent throughout an application's performance.
Discussion or Rationale: No change recommended to this existing Section 508 provision. Although it is not needed if the AT interoperability provision is met, assistive technology vendors strongly advocated to keep this requirement to support their workarounds.
EWG sugggested rewording An application must assign a consistent meaning to any bitmap images used to identify controls, status indicators, or other programmatic elements.
3.4-C - Focus Indicator
Software must provide a visual indication of which user interface object currently has the keyboard focus. If the object is a text entry field, a visual indication of the text insertion point must be provided, and is sufficient.
- TBD: TEITAC action item for the visual indication to be well-defined or highly visible. Looking at ISO 9241-171 for testable criteria and harmonization.
Discussion or Rationale: The requirement that the keyboard focus be programmatically exposed is covered by the AT interoperability provision. The proposed provision clarifies that for a text input field, a text input cursor or caret is sufficient and that an outline cursor is not also needed for text input fields.
NEW (Gregg V): TEITAC action item for the visual indication to be well-defined or highly visible. Looking at ISO 9241-171 for testable criteria and harmonization.
NEW Suggestion to move this provision to 3.2-If Product Has Display This provision used to cover BOTH a VISIBLE focus indicator AND a Software awareness of indicator, because it now is only about VISIBILITY of focus indicator. So it is no longer about AT access. (Software awareness of indicator is now covered by 3.4A)
4. Additional Provisions for Audio-Visual Players or Displays
Updates and discussion for provisions in this section
4-A - Caption Playback
Analog television, digital television and tuners, computer equipment, and other equipment must provide closed and open captions:
| Equipment of this type… | Uses this standard… | To provide these functions… |
|---|---|---|
| CEA 608 | Receive, decode and display signals from
|
| CEA 708 | Receive, decode and display signals from
OR
|
| CEA 708 or functional equivalent |
OR
|
4-B - Supplemental Audio Playback
Television tuners, including tuner cards for use in computers, must support video description:
- Analog-signal tuners must be equipped with secondary audio program playback circuitry
- Digital-signal tuners must be equipped with ancillary audio program playback circuitry
Discussion or Rationale Edited for clarity
4-C - Play Control (Audio)
The product must provide the ability to interrupt, pause, and restart the audio at anytime.
5. Additional Provisions for Real-time Voice Conversation Functionality
5-A - Accessibility Configuration
In complying with this subpart, each agency must:
- Activate accessibility features and configure telecommunications products so that they are accessible to and usable by people with disabilities.
- Ensure access to and use of all telecommunications relay services as approved by the Federal Communications Commission pursuant to its authority under 47 U.S.C. Sec. 225, for incoming and outgoing calls, as needed to achieve functionally equivalent communication access by people with disabilities.
Status: In Progress
Source: New
Discussion: The first provision addresses agency requirements, not procurement. It may need to be moved to another section (Recommendations for Agency Requirements) and/or made into a general requirement applying to all products and services.
Suggest striking "telecommunications products" from the first bullet, so this applies to all products. (GreggV) - Possibly move to Section 1.2?
5-B - Real-time Text Reliability
There are 2 proposed versions, not settled within Telecom SC:
Version 1: Systems that support real-time voice communication must support at least one standard (for the system) means for real time text communication that is supported by all terminal, router, gateway and other products on that system, and that meets the following requirements:
- Provides transmission of characters with less than 1 second delay from entry;
- Provides transmission with less than 1% Total Character Error Rate under peak non-crisis network traffic;
- Support alternating speech and text in both directions on non-packet based systems and simultaneously speech and text in both directions on packet based systems.
- IP systems cannot rely upon audio channels for transmission of real-time text. {can delete 5 if interop provision and peak traffic clause are retained.
Version 2 (Trace Alternate Proposal): Real-time voice communication systems must support at least one means for real-time text communication that:
- Is standard for the system and supported by all terminal, router, gateway and other products on that system; and
- Provides transmission of characters with less than 1 second delay from entry; and
- Provides transmission with less than 1% Total Character Error Rate under peak non-crisis network traffic; and
- Supports intermixing of speech and text in both directions (simultaneously if and only if IP based); and
- If it is an IP based system, does not rely upon audio signals for transmission of real-time text.
Status: In Progress
Source: New
Discussion: A system may be standard or proprietary but it includes all products that use that system. This version allows use of audio channel for text data
5-C - Real-Time Text Interoperability
There are 3 proposed provisions, not settled within Telecom SC:
Version 1 Products that provide real-time text conversation functionality must do so in the standard format that is supported for that transport medium.
- Products that connect directly to the PSTN must support TIA 825 Baudot where they interface to the PSTN;
- Products that connect directly to the Internet via SIP must support RFC 4103 where they interface to the Internet via SIP;
- All other Products (including PBX, cellular, and peer to peer Internet phones) that do not connect to PSTN or use SIP over the Internet must support the standard real-time text format for that system. These systems only need to support TIA 825 Baudot at the juncture to the PSTN (if any) and only need to support RFC 4103 at the point where they connect to public SIP systems (if any).
Version 2 (Trace Proposal); Products that provide real-time text conversation functionality must
- provide real-time text functionality in the standard real-time text format that is specified for that system
- use TIA 825 Baudot where they interface to the PSTN
- support both RFC-4103 and RFC-4351 where they interface to other VoIP systems or to the Internet via SIP
Note: Closed systems, where the real-time text format of all the components is controlled and identical, may use any real-time text format that meets provisions for (Real-time Text Reliability) and (Real-time Text Interoperability).
Version 3 (TIA Proposal): Products that provide real-time text conversation functionality must do so in the standard format that is supported for that transport medium and provide level of service that does not exceed 1% Total Character Error Rate under normal network conditions.
- Products that connect directly to the PSTN, including packet based systems, must support TIA 825 Baudot where they interface to the PSTN.
- Packet based systems must support real-time text communication between text capable terminals.
Status: In Progress
Source: New
5-D - VOIP Terminals and Real-Time Text
The user interface of IP terminals that provide real-time voice communication must meet the following provisions:
- IP terminal user interfaces that have a multiline display must display any real-time text that is received in the standard format for that platform.
- IP terminal user interfaces that have the ability to generate text must allow sending real-time text in the standard real-time text format for that platform.
- Such real time text send and receive capabilities must be synchronized with voice as part of the same communication session.
Status: In Progress
Source: New
5-E - Voice Terminals without Real-Time Text
There are 3 proposed provisions, not settled within Telecom SC:
Version 1: Telecommunications terminals and other terminals capable of providing real-time voice communications which do not themselves provide TTY or other real-time text conversation functionality must comply with the following:
- All analog and TDM-digital wired terminals must support the connection of a TTY in the same location and with the permissions for use as the telephone. This must be accomplished by:
- Providing an RJ-11 jack on the telephone, or
- For an analog telephone, by the use of a Y-adapter that allows both the analog telephone and the TTY to be plugged into the same line outlet, or
- Having built-in capability to support an RJ11 module that can provide a connection point for TTYs.
- Other types of terminals covered by this section must support the connection of real-time text capable devices in conjunction with the voice call capability in the same location and the same permissions for use as the terminal.
- These products must either:
- Be capable of allowing simultaneous speech and text conversation without interference or
- Its microphone must be capable of being turned on and off to allow the user to intermix speech with text use.
Version 2 (NEW TIA PROPOSAL): Telecommunications products or systems [terminals and other terminals capable of providing real-time voice communications which do not themselves] provide TTY or other real-time text conversation functionality must comply with the following:
- All analog and TDM-digital wired terminals must support the connection of a TTY in the same location and with the permissions for use as the telephone. This may be accomplished by:
- Providing an RJ-11 jack on the telephone, or
- For an analog telephone, by the use of a Y-adapter that allows both the analog telephone and the TTY to be plugged into the same line outlet, or
- By having built-in capability to support an RJ11 module that can provide a connection point for TTYs.
- Packet based telecommunication systems must support the addition of terminals and terminal peripheral equipment that support real-time text functionality in conjunction with the voice call functionality in the same location and with the same permissions for use as the terminal.
- These products must either:
- Be capable of allowing simultaneous speech and text conversation without interference, or
- Its microphone must be capable of being turned on and off to allow the user to intermix speech with text use.
Version 3 (TRACE PROPOSAL): Terminals capable of providing real-time voice communications that do not themselves provide TTY or other real-time text conversation functionality shall comply with the following:
- All analog and TDM-digital wired terminals shall support the connection of a TTY in the same location and with the permissions for use as the telephone. This may must be accomplished by providing an RJ-11 jack on the telephone, or, in the case of an analog telephone, by the use of a Y-adapter that allows both the analog telephone and the TTY to be plugged into the same line outlet, or by having built in capability to support an RJ11 module that can provide a connection point for TTYs;
- Packet based telecommunication All other real-time voice communication systems shall support the ad hoc addition of terminals and terminal peripheral equipment that support real-time text functionality in conjunction with the voice call functionality in the same location andwith the same permissions for use as their voice terminal.
- Shall be capable of allowing simultaneous speech and text conversation without interference or its microphone shall be capable of being turned on and off to allow the user to intermix speech with text use.
Status: In Progress
Source: {508}1194.23(a)
5-F - IVR, Auto-Attendant and Messaging
Voice mail, messaging, auto-attendant, and interactive voice response telecommunications systems must provide access in the following manner:
- All functions that are accessible to voice users must also be directly accessible to users of real-time text.
- Use the ITU-T G.711 recommendation for encoding and storing audio information. If an audio encoder other than G711 is employed, the vendor must provide evidence that the intelligibility is equal to or better than that provided by G.711;
- Provide full player controls that allow users to pause, rewind, slow down and repeat all messages and prompts;
- Provide prompts (either as provided by the vendor, or by the agency or customer) without any background sounds that would reduce intelligibility.
NOTE: Relay services are not considered to be "directly accessible".
Status: In Progress
Source: {508}1194.23(c)
Work in progress:
- Telecommunications will provide an advisory note about Baudot and TTY.
5-G - Caller and Status Information
Products with visual interfaces that display telecommunications status information (such as caller identification and similar telecommunications functions) must also make this information available for:
- Users of TTYs,
- Users of other text conversation systems, and
- Users who cannot see displays.
These products must also meet all accessibility provisions for software and content.
Status: Done (Updated status July 30, 2007)
Source: {508}1194.23(e)
5-H - Video Support
Telecommunications products or systems which have the capacity to transmit video, text, and voice communications must support internet protocol text and voice communications in X format, and they must have sufficient transmission bandwidth capacity to support video communication such as video relay and point to point video communications.
Status: In Progress
Source: New
Discussion: "X format" remains undefined; comments were received regarding whether this should be applied to 255 in addition to 508.
6. Electronic Content Provisions
6.1 If Web Content or Web Applications
The Web/Software Subcommittee is working on a reorganization of this section. Please see the following working pages:
- Web and Software: Reorganized Web and Software provisions
- Web and Software: Merging_Analysis
- Web and Software: Analysis of impact to harmonization with WCAG 2.0 and ISO
- Meeting schedules
6.1-A - Color (Web)
Web pages must be designed so that all information conveyed with color is also available without color, for example from context or markup.
Status: In Progress
Source: {508}1194.25(g) and 1194.21(i)
Discussion or Rationale: Subcommittee debating harmonization with WCAG 2.0. That text reads: Any information that is conveyed by color differences is also simultaneously visually evident without the color differences.
6.1-B - Contrast (Web)
Text (and images of text) have a contrast ratio of at least 5:1, except if the text is pure decoration. Larger-scale text or images of text can have a contrast ratio of 3:1.
Status: Done
Source: New
Discussion or Rationale Harmonization with WCAG 2.0.
6.1-C - Timing (Web)
For each time limit that is set by the content, at least one of the following must be true:
- Turn off: the user is allowed to turn off the time limit before encountering it; or
- Adjust: the user is allowed to adjust the time limit before encountering it over a wide range that is at least ten times the length of the default setting; or
- Extend: the user is warned before time expires and given at least 20 seconds to extend the time limit with a simple action (for example, "hit any key"), and the user is allowed to extend the time limit at least ten times; or
- Real-time Exception: the time limit is a required part of a real-time event (for example, an auction), and no alternative to the time limit is possible; or
- Essential Exception: the time limit is part of an activity where timing is essential and time limits can not be extended further without invalidating the activity.
Status: In Progress
Source: New (incorporates {508}1194.22(p) and {508}1194.23(d) and {255}1193.41(g)
Discussion or Rationale: The recommended change is harmonized with both the ISO Software Accessibility standard and WCAG 2.0.
Work in progress:
- "Sufficient time" is not objectively testable. There are other acceptable strategies for addressing the needs of users who need more time.
- TBD: In Adjust, issue with "before encountering"
- TBD: In Essential Exception, still discussing the suggestion to add something about data integrity.
6.1-D - Flashing (Web)
Web content and applications do not contain anything that flashes more than 3 times in any one second period, unless the flashing is below the general flash and red flash thresholds.
Status: Done
Source: {508}1194.21(k) 1194.22(j) 1194.25(i), and {255}1193.43(f)
Discussion: This provision is a subset of 1.2.B - Flashing
6.1-E - Non-text Content
Non-text Content: All non-text content has a text alternative that presents equivalent information, except for the situations listed below.
- Controls-Input: If non-text content is a control or accepts user input, then it has a name that describes its purpose. (See also User Interface Components provisions)
- Media, Test, Sensory: If non-text content is multimedia , live audio-only or live video-only content, a test or exercise that must be presented in non-text format , or primarily intended to create a specific sensory experience , then text alternatives at least identify the non-text content with a descriptive text label. (For multimedia, see also Audio and/or Video provisions)
- CAPTCHA: If the purpose of non-text content is to confirm that content is being accessed by a person rather than a computer, then text alternatives that identify and describe the purpose of the non-text content are provided and alternative forms in different modalities are provided to accommodate different disabilities.
- Decoration, Formatting, Invisible: If non-text content is pure decoration, or used only for visual formatting, or if it is not presented to users, then it is implemented such that it can be ignored by assistive technology.
Status: Done
Source: {508}1194.22(a)
Discussion or Rationale Both the existing Section 508 provision 1194.22(a) and WCAG 1.0 guideline 1.1 require alternatives for non-text content but give no testable criteria for appropriate alt text. 508 should leverage the extensive work done in WCAG and adopt this provision.
6.1-F - Repeated Blocks
A mechanism must be available to bypass blocks of content that are repeated on multiple Web pages.
Status: Minor Edits
Source: {508}1194.22(o)
Work in progress
- "bloc