General April survey-report
From TEITAC
I. Material which can be described as “Changes to Existing Provisions”
- Modification – Material which modifies existing provisions.
- Rationale – Why is this change suggested?
| Current provision | Keep current language | Change Group? | Modification | Rationale: Why is this change suggested? | Cost Impact |
|---|---|---|---|---|---|
| 1194.26 (c) When biometric forms of user identification or control are used, an alternative form of identification or activation, which does not require the user to possess particular biological characteristics, shall also be provided. | Yes | Came here from Hardware | No | No impact. | |
| {508} S 1194.31 (a) At least one mode of operation and information retrieval that does not require user vision shall be provided, or support for assistive technology used by people who are blind or visually impaired shall be provided. {255}S 1193.41 (*)(a) Operable without vision. Provide at least one mode that does not require user vision. | No | No | At least one mode shall be provided that allows full use of product without using vision, directly or with users' AT. | Fixes 3 problems. 1- full use required for direct or AT, 2 - functions might be mixed (direct & AT) 3 - in order to be accessible via AT it must be AT users' have. (We have not specified which users). | No impact. Text clarified which would cause minor decrease in implementation costs. |
| {508} S 1194.31 (b) At least one mode of operation and information retrieval that does not require visual acuity greater than 20/70 shall be provided in audio and enlarged print output working together or independently, or support for assistive technology used by people who are visually impaired shall be provided.
| No | No | At least one mode shall be provided that allows full use of product without requiring visual acuity greater than 20/70, and that allows audio and enlarged text output to work together or independently, directly or with users' AT. | Fixes same 3 problems | No impact. Text clarified which would cause minor decrease in implementation costs. |
| {508}S 1194.31 (c) At least one mode of operation and information retrieval that does not require user hearing shall be provided, or support for assistive technology used by people who are deaf or hard of hearing shall be provided. {255} S 1193.41 (*)(d) Operable without hearing. Provide at least one mode that does not require user auditory perception. S 1193.43 (*)(d) Availability of auditory information. Provide auditory information through at least one mode in visual form and, where appropriate, in tactile form. | No | No | At least one mode shall be provided that allows full use of product without using hearing, directly or with users' AT. | Fixes same 3 problems | No impact. Text clarified which would cause minor decrease in implementation costs. |
| {508} S 1194.31 (d) Where audio information is important for the use of a product, at least one mode of operation and information retrieval shall be provided in an enhanced auditory fashion, or support for assistive hearing devices shall be provided.
| No | No | Where audio information is important for the use of a product,At least one mode shall be provided that allows full use of product with enhanced audio, directly or with users' AT. | Fixes same 3 problems | No impact. Text clarified which would cause minor decrease in implementation costs. |
| {508} S 1194.31 (e) At least one mode of operation and information retrieval that does not require user speech shall be provided, or support for assistive technology used by people with disabilities shall be provided.
| No | No | At least one mode shall be provided that allows full use of product without using speech, directly or with users' AT. | Fixes same 3 problems | No impact. Text clarified which would cause minor decrease in implementation costs. |
| {255}S 1193.31 (*)(e) Operable with limited manual dexterity. Provide at least one mode that does not require user fine motor control or simultaneous actions. S 1193.41 (*)(f) Operable with limited reach and strength. Provide at least one mode that is operable with user limited reach and strength. | No | No | At least one mode shall be provided that allows full use of product with limited reach and strength and without simultaneous actions, directly or with users' AT. | Fixes same 3 problems PLUS adds AT in a way that works (since good for some parts but not for others) | Adds AT option. Should potentially reduce cost to companies by giving additional options - and increase productivity and employment by people with disabilities. So this would decrease costs and increase benefits. |
| {508} NONE {255}S 1193.41 (*)(i) Operable with limited cognitive skills. Provide at least one mode that minimizes the cognitive, memory, language, and learning skills required of the user. | No | No | At least one mode shall be provided that accommodates cognitive, language or learning impairments, directly or with users' AT. | To cover cognitive, language and learning aspects. | This is one of the largest or the largest group of people with disabilities in the government. The cost in increased productivity can be great. Even simplification act has talked about using plain language. And GSA reports that there is some guidance there to use plain language. The cost to learn to write plainly though is not known or other aspects of this. The benefits are believed to outweigh costs in the end however so a net decrease in cost is believed. |
| {508}"S 1194.21 (k) Software shall not use flashing or blinking text, objects, or other elements having a flash or blink frequency greater than 2 Hz and lower than 55 Hz.
| No | At LEAST needs to be 50 HZ should be changed to limit to flashing no more than 3 per 1 second period that are larger that is greater 25% of the central 10 degrees of vision. (that can be made simpler by assuming viewing distance) That will eliminate worrying about small indicators or areas of the screen. Haven't worked on this yet. NOTE: Keeping flashing to less than 3 per 1 second period would meet the above spec. | General since it can be hardware, software, Media, Content. @@ should add text to indicate that is is to avoid seizures not distraction. | Should lower costs by allowing removing Flash restrictions from things that are not problems. |
II. Entirely New Provisions
| New provision | Rationale: What issue does this provision address? |
|---|---|
III. Other Material
A. Recommendations on organization of the provisions
Can't use 508 organization - that is mixed product domains, characteristics and applications. And we can't use committee structure because some committees are product function (telecom) while some are characteristics (closed, involve hardware) and some are mixed (have software with an OS + content).
Recommend a linear sortable presentation of the provisions that does not try to organize them by technology or disability. This listing can then be sorted or filtered to show which would apply to different domains, product types, applications or disabilities. This would also facilitate incorporation into an updated "buy accessible" tool.
The best organization we have now is the one that grew out of the blended approach.
- Current Proposed Linear Sortable Format
- this is also the organization you get from the Preliminary Filter Tool
LINEAR SORTABLE FORMAT
Linear Sortable Format
NOTE: All bulletted items are just short names for provisions that are being worked on by the different working groups. They are placeholders used for showing structure - not final wording of anything.
1 Overall Functional Performance Criteria
- Full use without Vision - in at least one mode (direct or via AT)
- Full use with Low Vision without Audio - in at least one mode (direct or via AT)
- Full use without Hearing - in at least one mode (direct or via AT)
- Full use with Enhance Audio - in at least one mode (direct or via AT)
- Full use without Speech - in at least one mode (direct or via AT)
- Full use with limited reach, strength or dexterity - in at least one mode (direct or via AT)
- Full use with cognitive, language or learning disabilities - in at least one mode (direct or via AT)
2. Don't block use (both if direct access or access via AT)
- If speaker held to the ear minimize hearing aid interference
- Have no more than 3 flashes in one second above thresholds (Seizure)
- Provide Alternative to biometric ID
- Pass through non-proprietary Access signals
3. Build Accessibility Into Product
General - All products
- If not operable by users AT (for any group), make product fully usable by that group without AT
- No interference with Built in Access Features
- Consistent use of images for controls, status, etc
- All visual information (printed or displayed) in Auditory form in 1 mode
- Impose No Time limitations or make time limit adjustable
- If IVR (e.g.Voicemail, Auto-attend, Voice menus,,etc.) no time limit pr time limit adjustable. (subset of above?)
- Make Any Key Repeat Delay & Rate Adjustable & Turn off (2 sec)
Input Devices
All Products with input devices
- Provide Visual and either audio or tactile key status indicators
- If touchscreen or touch control then provide non-touch alternate [and softkeys ?]
- Make controls compatible with prosthetics
If the Product has Physical Controls
- Controls meet ADAAG approach and Reach Specs
- Controls meet ADAAG control specs.
- Tactilely Discernable without activation
- No require pinching, twisting of the wrist, or tight grasping.
- If Keyrepeat then adjustable
- Status of locking and toggle keys visual and auditory or tactile
If the Product has Standard Keyboard or keyboard interface
- Make Product Operable Using Only Input to Standard Keyboard interface (or Keyboard equivalent)
Output Devices
If the Product has Visual Output or Display
- Variety of Color & Font settings for Contrast
- Information not provided in color alone.
- At least 1 non-animated version available
- Moving text available static in 1 mode
- No override of display settings {if this includes audio then can't go here}
If the product has Audio Output
- If speaker held to the ear provide hearing aid compatible coupling
- Provide amplification for products in public places
- Provide Voice amplification for Telecom
- Loud volume auto reset (+indicator + override)
- Standard Connector available for Audio Output
If product provides real-time voice conversation functionality
- - ( Proposed text conversation Provisions would go here when finalized. )
If product (hardware or software) plays or displays AudioVideo material
- Caption decode and Display supported
- Players/Displays support Audio Descriptions
4. Make product work with adaptive assistive technology
Provide Software support for adaptive AT
- All info and control avail to INTERNAL AT
- Provide Text through API / OS Text tools
- Focus Indicator Avail to AT (+clearly visible covered above)
Allow connection of external alternate presenters, controllers, and displays
- Standard ports
- Support connection of alternate interfaces
- If product provides for real-time conversation then it must meet provisions
- If not providing function itself then provide direct connect of standard real-teim Text Terminal& mic toggle
- Support for standard text conversation signals
- Voicemail, Auto-attend, & IVR work with Standard realtime text formats
- Caller ID etc accessible to Blind & realtime text users
5. Content
General - all content
- Alternate Text for all non-text elements
- Documents readable without style sheets
- Image map redundant links
- Use Client-side image maps (w/ alt text)
- Content provides Skip over navigation links
- Accessible Electronic Forms
- Headers provided on data tables
- Table markup associates cells and headers
- Link to conformant Plug-in provided
- Frames have titles
- Text alternative for scripts
- Text-only page [ alternate accessible page ] -- (only if only way)
Audio and/or Video content
- Provide synchronized alternatives to synchronized audio and video
- AV Material is Captioned (Open or closed) {using format for that media}
- Provide Audio description of video {using format for that media}
- Captions & Audio Description User selectable unless Embedded in Video
6. Documentation, help, and support services
Documentation and help
- Information and documentation is accessible ( +Web?)
- Description of accessibility features avail
Support services
- Accessible product support phone services
- Contact information avail for access info
- Accessible Product Training
7. Product Development & Installation Process & Tools
Process guidance
- Include PWD throughout process (4 parts)
- Changes shall not decrease access
- Include access in design, devel, & fabrication
Authoring tools
(placeholder for any authoring tool guidelines that might be developed that aren't just software access which would be covered above)
B1 . Issues this subcommittee has not yet addressed, but which should be addressed.
- how to phrase the provisions so their coverage is clear
- how to deal with provisions where there is a general overall one but some specific sub items
- how to incorporate 'sufficient techniques' idea
- bios questions
- issues for cognitive language and learning
- whether there is something to be done in allergy area
- A method shall be provided to stop any blinking or movement that lasts more than 3 seconds. This is a first pass and needs work. Also check to be sure it isnt too broad. 1194.21(h) covers this for animation in software. Is this the only technology (thus should this go to software/web??)
- Relationship of functional performance to closed?
B2. Issues this subcommittee is not addressing, but which should be addressed.
- review of other standards to determine provisions that need to be added
- to make up for gaps in this standard
- to cover new aspects not there or clear last time around
- to increase quality of the standard
- Cooperation between AT. (Should we even be talking about what AT should do? It is an adaptation to E&IT not an E&IT)
(some of this is being done in some other groups )
