[Code of Federal Regulations]
[Title 36, Volume 3]
[Revised as of July 1, 2001]
From the U.S. Government Printing Office via GPO Access
[CITE: 36CFR1193.51]
[Page 480-496]
TITLE 36--PARKS, FORESTS, AND PUBLIC PROPERTY
CHAPTER XI--ARCHITECTURAL AND TRANSPORTATION BARRIERS COMPLIANCE BOARD
PART 1193--TELECOMMUNICATIONS ACT ACCESSIBILITY GUIDELINES--Table of Contents
Subpart D--Requirements for Compatibility With Peripheral Devices and
Specialized Customer Premises Equipment
Sec. 1193.51 Compatibility.
When required by subpart B of this part, telecommunications
equipment and customer premises equipment shall be compatible with
peripheral devices and specialized customer premises equipment commonly
used by individuals with disabilities to achieve accessibility, and
shall comply with the following provisions, as applicable:
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(a) External electronic access to all information and control
mechanisms. Information needed for the operation of products (including
output, alerts, icons, on-line help, and documentation) shall be
available in a standard electronic text format on a cross-industry
standard port and all input to and control of a product shall allow for
real time operation by electronic text input into a cross-industry
standard external port and in cross-industry standard format. The cross-
industry standard port shall not require manipulation of a connector by
the user.
(b) Connection point for external audio processing devices. Products
providing auditory output shall provide the auditory signal at a
standard signal level through an industry standard connector.
(c) Compatibility of controls with prosthetics. Touchscreen and
touch-operated controls shall be operable without requiring body contact
or close body proximity.
(d) TTY connectability. Products which provide a function allowing
voice communication and which do not themselves provide a TTY
functionality shall provide a standard non-acoustic connection point for
TTYs. It shall also be possible for the user to easily turn any
microphone on and off to allow the user to intermix speech with TTY use.
(e) TTY signal compatibility. Products, including those providing
voice communication functionality, shall support use of all cross-
manufacturer non-proprietary standard signals used by TTYs.
Appendix to Part 1193--Advisory Guidance
Introduction
1. This appendix provides examples of strategies and notes to assist
in understanding the guidelines and are a source of ideas for alternate
strategies for achieving accessibility. These strategies and notes are
not mandatory. A manufacturer is not required to incorporate all of
these examples or any specific example. Manufacturers are free to use
these or other strategies in addressing the guidelines. The examples
listed here are not comprehensive, nor does adopting or incorporating
them guarantee an accessible product. They are meant to provide a useful
starting point for evaluating the accessibility of a product or
conceptual design and are not intended to inhibit innovation. For a more
complete list of all of the published strategies to date, as well as for
further information and links to on-going discussions, the reader is
referred to the National Institute on Disability and Rehabilitation
Research's Rehabilitation Engineering Center on Access to
Telecommunications System's strategies Web site (http://trace.wisc.edu/
world/telecomm/).
2. This appendix is organized to correspond to the sections and
paragraphs of the guidelines in this part to which the explanatory
material relates. This appendix does not contain explanatory material
for every section and paragraph of the guidelines in this part.
Subpart A--General
Section 1193.3 Definitions
Readily Achievable
1. Section 255 defines ``readily achievable'' as having the same
meaning as in the Americans with Disabilities Act (ADA). However, the
ADA applies the term to the removal of barriers in existing public
accommodations. Not all of the factors cited in the ADA or the
Department of Justice (DOJ) implementing regulations (July 26, 1991) are
easy to translate to the telecommunications context where the term
applies to telecommunications equipment and customer premises equipment
which is designed, developed and fabricated after February 8, 1996, the
effective date of the Telecommunications Act of 1996.
2. It may not be readily achievable to make every product accessible
or compatible. Depending on the design, technology, or several other
factors, it may be determined that providing accessibility to all
products in a product line is not readily achievable. The guidelines do
not require accessibility or compatibility when that determination has
been made, and it is up to the manufacturer to make it. However, the
assessment as to whether it is or is not readily achievable cannot be
bypassed simply because another product is already accessible. For this
purpose, two products are considered to be different if they have
different functions or features. Products which differ only
cosmetically, where such differences do not affect functionality, are
not considered separate products.
3. Below is a list of factors provided as interim guidance to
manufacturers to assist them in making readily achievable assessments.
The factors are derived from the ADA itself and the DOJ regulations and
are presented in the order in which they appear in those sources.
Ultimately, the priority or weight of these factors is a compliance
issue,
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under the jurisdiction of the Federal Communications Commission (FCC).
Factors applicable to a determination of whether an action is readily
achievable include: the nature and cost of the action needed to provide
accessibility or compatibility; the overall resources of the
manufacturer, including financial resources, technical expertise,
component supply sources, equipment, or personnel; the overall financial
resources of any parent corporation or entity, only to the extent such
resources are available to the manufacturer; and whether the
accessibility solution results in a fundamental alteration of the
product.
a. One factor in making readily achievable assessments is the nature
and cost of the action needed to provide accessibility or compatibility.
The term readily achievable means that an action is ``easily
accomplishable and able to be carried out without much difficulty or
expense.'' The nature of the action or solution involves how easy it is
to accomplish, including the availability of technology and expertise,
and the ability to incorporate the solution into the production process.
Obviously, knowing about an accessibility solution, even in detail, does
not mean it is readily achievable for a specific manufacturer to
implement it immediately. Even if it only requires substituting a
different, compatible part, the new part must be ordered and integrated
into the manufacturing process. A more extreme implementation might
require re-tooling or redesign. On the other hand, a given solution
might be so similar to the current design, development and fabrication
process that it is readily achievable to implement it virtually
overnight.
b. Another factor in making readily achievable assessments is the
overall resources of the manufacturer, including financial resources,
technical expertise, component supply sources, equipment, or personnel.
The monetary resources of a manufacturer are obviously a factor in
determining whether an action is readily achievable, but it may be
appropriate to consider other resources, as well. For example, a company
might have ample financial resources and, at first glance, appear to
have no reason for not including a particular accessibility feature in a
given product. However, it might be that the company lacks personnel
with experience in software development, for example, needed to
implement the design solution. One might reason that, if the financial
resources are available, the company should hire the appropriate
personnel, but, if it does, it may no longer have the financial
resources to implement the design solution. One would expect that the
company would develop the technical expertise over time and that
eventually the access solution might become readily achievable.
c. Another factor in making readily achievable assessments is the
overall financial resources of any parent corporation or entity, only to
the extent such resources are available to the manufacturer. Both the
ADA statutory definition of readily achievable and the DOJ regulations
define the resources of a parent company as a factor. However, such
resources are considered only to the extent those resources are
available to the subsidiary. If, for example, the subsidiary is
responsible for product design but the parent company is responsible for
overall marketing, it may be appropriate to expect the parent company to
address some of the marketing goals. If, on the other hand, the
resources of a parent company are not available to the subsidiary, they
may not be relevant. This determination would be made on a case-by-case
basis.
d. A fourth factor in making readily achievable assessments is
whether the accessibility solution results in a fundamental alteration
of the product. This factor, derived by extension from the ``undue
burden'' criteria of the ADA, takes into consideration the effect adding
an accessibility feature might have on a given product. For example, it
may not be readily achievable to add a large display for low vision
users to a small pager designed to fit in a pocket, because making the
device significantly larger would be a fundamental alteration of the
device. On the other hand, adding a voice output may not involve a
fundamental alteration and would serve both blind and low vision users.
In addition, adding an infrared port might be readily achievable and
would allow a large-display peripheral device to be coupled to it. Of
course fundamental alteration means a change in the fundamental
characteristic of the product, not merely a cosmetic or esthetic change.
Subpart B--General Requirements
Section 1193.23 Product Design, Development and Evaluation
Paragraph (a)
1. This section requires manufacturers to evaluate the
accessibility, usability, and compatibility of telecommunications
equipment and customer premises equipment and incorporate such
evaluation throughout product design, development, and fabrication, as
early and consistently as possible. Manufacturers must develop a process
to ensure that products are designed, developed and fabricated to be
accessible whenever it is readily achievable. Since what is readily
achievable will vary according to the stage of development (i.e., some
things will be readily achievable in the design phase which may not be
in later phases), barriers to accessibility and usability must be
identified throughout product design and development,
[[Page 483]]
from conceptualization to production. Moreover, usability can be
seriously affected even after production, if information is not provided
in an effective manner.
2. The details of such an evaluation process will vary from one
company to the next, so this section does not specify its structure or
specific content. Instead, this section sets forth a series of factors
that a manufacturer must consider in developing such a process. How, and
to what extent, each of the factors is incorporated in a specific
process is up to the manufacturer.
3. Different manufacturers, or even the same manufacturer at
different times, have the flexibility to tailor any such plan to its own
particular needs. This section does not prescribe any particular plan or
content. It does not require that such a process be submitted to any
entity or that it even be in writing. The requirement is outcome-
oriented, and a process could range from purely conceptual to formally
documented, as suits the manufacturer.
4. The goal is for designers to be aware of access and incorporate
such considerations in the conceptualization of new products. When an
idea is just beginning to take shape, a designer would ask, ``How would
a blind person use this product? How would a deaf person use it?'' The
sooner a manufacturer makes its design team cognizant of design issues
for achieving accessibility; and proven solutions for accessibility and
compatibility, the easier this process will be.
Paragraph (b)(1)
Market Research
1. The guidelines do not require market research, testing or
consultation, only that they be considered and incorporated to the
extent deemed appropriate for a given manufacturer. If a manufacturer
has a large marketing effort, involving surveys and focus groups, it may
be appropriate to include persons with disabilities in such groups. On
the other hand, some small companies do not do any real marketing, per
se, but may just notice that a product made by XYZ Corporation is
selling well and, based on this ``marketing survey'' it decides it can
make a cheaper one. Clearly, ``involvement'' of persons with
disabilities is not appropriate in this case.
2. A manufacturer must consider how it could include individuals
with disabilities in target populations of market research. It is
important to realize that any target population for which a manufacturer
might wish to focus a product contains individuals with disabilities,
whether it is teenagers, single parents, women between the ages of 25
and 40, or any other subgroup, no matter how narrowly defined. Any
market research which excludes individuals with disabilities will be
deficient.
Paragraph (b)(2)
Product Design, Testing, Pilot Demonstrations, and Product Trials
1. Including individuals with disabilities in product design,
testing, pilot demonstrations, and product trials will encourage
appropriate design solutions to accessibility barriers. In addition,
such involvement may result in designs which have an appeal to a broader
market.
Paragraph (b)(3)
Working Cooperatively With Appropriate Disability-Related Organizations
1. Working cooperatively with appropriate disability-related
organizations is one of the factors that manufacturers must consider in
their product design and development process. The primary reason for
working cooperatively is to exchange relevant information. This is a
two-way process since the manufacturer will get information on barriers
to the use of its products, and may also be alerted to possible sources
for solutions. The process will also serve to inform individuals with
disabilities about what is readily achievable. In addition,
manufacturers will have a conduit to a source of subjects for market
research and product trials.
2. Manufacturers should consult with representatives from a cross-
section of disability groups, particularly individuals whose
disabilities affect hearing, vision, movement, manipulation, speech, and
interpretation of information.
3. Because of the complex interrelationship between equipment and
services in providing accessibility to telecommunications products,
coordination and cooperation between manufacturers and service providers
will be beneficial. Involving service providers in the product
development process will encourage appropriate design solutions to
accessibility barriers and permit the exchange of relevant information.
Paragraph (b)(4)
Making Reasonable Efforts to Validate Unproven Access Solutions
1. Manufacturers must consider how they can make reasonable efforts
to validate any unproven access solutions through testing with
individuals with disabilities or with appropriate disability-related
organizations that have established expertise with individuals with
disabilities. It is important to obtain input from persons or
organizations with established expertise to ensure that input is not
based merely on individual preferences or limited experience.
2. This input should be sought from representatives from a cross-
section of disability groups, particularly individuals whose
disabilities affect hearing, vision,
[[Page 484]]
movement, manipulation, speech, and interpretation of information.
Subpart C--Requirements for Accessibility and Usability
Section 1193.33 Information, Documentation, and Training
Paragraph (a)
1. This section requires that manufacturers provide access to
information and documentation. The information and documentation
includes user guides, installation guides, and product support
communications, regarding both the product in general and the
accessibility features of the product. Information and documentation
should be provided to people with disabilities at no additional charge.
Alternate formats or alternate modes of this information is also
required to be available. Manufacturers should also encourage
distributors of their products to establish information dissemination
and technical support programs similar to those established by the
manufacturer.
Alternate Formats and Alternate Modes
1. Alternate formats may include, but are not limited to, Braille,
ASCII text, large print, and audio cassette recording. Alternate modes
may include, but are not limited to, voice, fax, relay service, TTY,
Internet posting, captioning, text-to-speech synthesis, and video
description.
2. In considering how to best provide product information to people
with disabilities, it is essential that information be provided in an
alternate format or mode that is usable by the person needing the
information. For example, some individuals who are blind might require a
manual in Braille to understand and use the product effectively. Other
persons who are blind may prefer this information on a computer disk.
Persons with limited reading skills may need this information recorded
on audio cassette tape so they can listen to the manual. Still other
persons with low vision may be able to read the text version of the
manual if it is provided in a larger font. Likewise, if a tutorial video
is provided, persons who are deaf may require a captioned version so
that they will understand how to use the product effectively. Finally,
individuals who rely on TTYs will need direct TTY access to a customer
service line so they can ask questions about a product like everyone
else.
3. This portion of the appendix explains how to provide information
in alternate formats (Braille, ASCII text, large print, audio cassette)
to persons with disabilities.\1\
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\1\ This information was provided by the American Foundation for the
Blind.
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Braille
4. Some persons who are blind rely on the use of Braille in order to
obtain information that is typically provided in print. These persons
may need Braille because of the nature of their disability (such as
persons who are deaf-blind) or because of the complexity of the
material. Most large urban areas have companies or organizations which
can translate printed material to Braille. On the other hand,
manufacturers may wish to consider producing Braille documents ``in
house'' using a personal computer, Braille translation software, and a
Braille printer. The disadvantage is the difficulty in ensuring quality
control and accuracy. Software programs exist which can translate common
word processing formats directly into Braille, but they are not always
error free, especially if the document contains special characters,
jargon, graphics, or charts. Since the typical office worker will not be
able to proofread a Braille document, the initial apparent cost saving
may be quickly lost by having to re-do documents. The Braille
translation software costs approximately $500 and most Braille printers
sold range from $2,000 to $5,000, however some Braille printers,
depending on the speed and other features, do cost more. Depending on
the quality of Braille to be generated, a Braille printer in the $4,000
range should be adequate for most users. By using automatic translation
software, individuals who do not have knowledge of Braille or who have
limited computer skills may be able to produce simple Braille documents
without much trouble. If the document is of a complex format, however,
such as a text box over multiple columns, a sophisticated knowledge of
Braille translation software and formatting will be required.
Electronic Text
5. People who are blind or have low vision and who have access to
computers may be able to use documents in electronic form. Electronic
text must be provided in ASCII or a properly formatted word processor
file. Using electronic text allows this information to be transmitted
through e-mail or other on-line telecommunications. Blind or low vision
persons who have access to a personal computer can then read the
document using synthetic speech, an electronic Braille display, a large
print computer monitor, or they can produce a hard copy in large print
or Braille.
6. Documents prepared for electronic transmission should be in
ASCII. Documents supplied on disk should also be provided in either
ASCII or a word processor format usable by the customer. Word processing
documents should be properly formatted before distribution or conversion
to ASCII. To be correctly
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formatted, the document should be in Courier 10 point size and formatted
for an 80 character line. Tables should be converted to plain text.
Graphics or text boxes should be deleted and explained or described in
text format. This will allow the reader to understand all of the
documentation being presented. Replace bullets () with ``*'' or
``-'' and convert other extended ASCII characters into text. When
converting a document into ASCII or word processor formats, it is
important to utilize the appropriate ``tab key'' and ``centering key''
rather than using the space bar. This is necessary because Braille
translation software relies on the proper use of commands to automate
the formatting of a Braille document.
Large Print
7. Persons with low vision may require documentation to be provided
in large print. Large print documents can easily be produced using a
scalable font from any good word processing program and a standard laser
printer. Using the document enlargement option on a photocopier will
usually yield unsatisfactory results.
8. To obtain the best results follow these guidelines:
a. It is preferable to use paper that is standard 8\1/2\ x 11
inches. Larger paper may be used, but care should be taken that a
document does not become too bulky, thus making it difficult to read.
Always use 1 inch margins. Lines longer than 6\1/3\ inches will not
track well for individuals who must use a magnifier.
b. The best contrast with the least glare is achieved on very pale
yellow or cream-colored non-glossy paper, such as paper that is used for
photocopying purposes. To produce a more aesthetic looking document, an
off-white paper may be used and will still give good contrast while
producing less glare than white. Do not use dark colors and shades of
red. Double-sided copying (if print does not bleed through) will produce
a less bulky document.
c. Remove formatting codes that can make reading more difficult. For
example, centered or indented text could be difficult to track because
only a few words will fit on a line. All text should begin at the left
margin. Use only left margin justification to maintain uniform spacing
across lines. Right margin justification can produce uneven spacing
between letters and words. Use 1\1/4\ (1.25) line spacing; do not double
space. Replace tabs with two spaces. Page numbering should be at the top
or bottom left. Avoid columns. If columns are absolutely necessary, use
minimum space between columns. Use dot leaders for tabular material. For
those individuals who are able to read graphics (via the use of a
magnifier or other assistive device) graphics should be included, but
placed on a separate page from the text. For those individuals with low
vision who are unable to read graphics, tables, and charts this material
must be removed from the document and an accurate description of this
material should be included in a text format.
d. There is no standard typeface or point size. For more universal
access, use 18 point type; anything larger could make text too choppy to
read comfortably. Use a good strong bold typeface. Do not use italics,
fine, or fancy typefaces. Do not use compressed typefaces; there should
be normal ``white space'' between characters.
e. Use upper and lowercase letters.
f. Using these instructions, one page of print (11-12 point type)
will equal approximately three pages of large print (14-18 point)
depending on the density of the text.
Cassette Recordings
9. Some persons who are blind or who have learning disabilities may
require documentation on audio cassettes. Audio materials can be
produced commercially or in-house. Agencies sometimes record material
in-house and purchase a high speed tape duplicator ($1,000-2,000) which
is used to make cassette copies from the master. The cost of a
duplicator can be higher depending upon the number of copies produced on
a single run, and whether the duplicator can produce standard speed two-
sided copies or half-speed four-sided copies. Although unit costs can be
reduced by using the four-track, half-speed format, this will require
the reader to use a specially designed playback machine. Tapes should be
produced with ``tone indexing'' to allow a user to skip back and forth
from one section to another. By following a few simple guidelines for
selecting readers and creating recordings, most organizations will be
able to successfully record most simple documents.
10. Further guidance in making cassette recordings includes:
a. The reader should be proficient in the language being recorded.
b. The reader should be familiar with the subject. Someone who is
somewhat familiar with the technical aspects of a product but who can
explain functions in ordinary language would be a logical person to
record an audio cassette.
c. The reader should have good diction. Recording should be done in
a conversational tone and at a conversational pace; neither too slow nor
too fast.
d. The reader should be familiar with the material to minimize
stumbling and hesitation.
e. The reader should not editorialize. When recording a document, it
should be read in full. Graphic and pictorial information available to
sighted readers should be described in the narrated text. Tables and
charts whose contents are not already contained in text
[[Page 486]]
should be converted into text and included in the recording.
f. The reader should spell difficult or unusual words and words of
foreign origin.
g. At the beginning of the tape, identify the reader, i.e., ``This
document is being read by John Smith.''
h. On each side of the tape, identify the document and the page
number where the reader is continuing, i.e., ``tape 2, side 1, Guide to
Barrier Free Meetings, continuing on page 75.''
i. For blind users, all cassettes should be labeled in Braille so
that they can easily be referenced in the appropriate order.
Alternate Modes
11. Information is provided increasingly through a variety of means
including television advertisements, Internet postings, information
seminars, and telephone. This portion of the appendix explains how to
provide information in some alternate modes (captioning, video
description, Internet postings, relay service, and TTY).
Captioning
12. When manufacturers of telecommunications equipment or customer
premises equipment provide videos with their products (such as tutorials
or information explaining various components of a product) the video
should be available with captioning. Closed captioning refers to
assistive technology designed to provide access to television for
persons with hearing disabilities that is visible only through the use
of a decoder. Open captions are visible at all times. Captioning is
similar to subtitles in that the audio portion of a television program
is displayed as printed words on the television screen. Captions should
be carefully placed to identify speakers, on-and off-screen sound
effects, music and laughter. Increased captioning was made possible
because of the Television Decoder Circuitry Act which requires all
television sets sold in the United States with screens 13 inches or
larger to have built-in decoder circuitry.
13. Although captioning technology was developed specifically to
make television and video presentations accessible to deaf and hard of
hearing people, there has been widespread interest in using this
technology to provide similar access to meetings, classroom teaching,
and conferences. For meetings, video-conferences, information seminars,
and the like, real-time captioning is sometimes provided. Real-time
captioning uses a stenographic machine connected to a computer with
translation software. The output is then displayed on a monitor or
projected on a screen.
Video Description
14. Just as manufacturers of telecommunications equipment and
customer premises equipment need to make their videos accessible to
persons who are deaf or hard of hearing, they must also be accessible to
persons who are blind or have low vision. This process is known as video
description. Video description may either be a separate audio track that
can be played simultaneously with the regular audio portion of the video
material (adding description during pauses in the regular audio), or it
can be added to (or ``mixed'' with) an existing soundtrack. The latter
is the technique used for videotapes.
Internet Postings
15. The fastest growing way to obtain information about a product is
through use of the Internet, and specifically the World Wide Web.
However, many Internet users with disabilities have difficulty obtaining
this information if it is not correctly formatted. This section provides
information on how to make a World Wide Web site more accessible to
persons with disabilities \2\. Because of its structure, the Web
provides tremendous power and flexibility in presenting information in
multiple formats (text, audio, video, and graphic). However, the
features that provide power and elegance for some users present
potential barriers for people with sensory disabilities. The
indiscriminate use of graphic images and video restrict access for
people who are blind or have low vision. Use of audio and non-captioned
video restrict access for people who are deaf or hard of hearing.
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\2\ This information is based on the document ``Writing HTML
Documents and Implementing Accessibility for the World Wide Web'' by
Paul Fountaine, Center for Information Technology Accommodation, General
Services Administration. For further information, see http://
www.gsa.gov/coca.
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16. The level of accessibility of the information on the Web is
dependent on the format of the information, the transmission media, and
the display system. Many of the issues related to the transmission media
and the display system cannot be affected by the general user. On the
other hand, anyone creating information for a Web server has control of
the accessibility of the information. Careful design and coding of
information will provide access to all people without compromising the
power and elegance of the Web site.
17. A few suggestions are:
a. Every graphic image should have associated text. This will enable
a person using a character-based program, such as Lynx, to understand
the material being presented in the graphical format. It also allows
anyone
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who does not want to wait for graphics to load to have quick access to
the information on the site.
b. Provide text transcriptions or descriptions for all audio output.
This will enable people who are deaf or hard of hearing to have access
to this information, as well as individuals who do not have sound cards.
c. Make any link text descriptive, but not verbose. For example,
words like ``this'', ``here'', and ``click'' do not convey enough
information about the nature of the link, especially to people who are
blind. Link text should consist of substantive, descriptive words which
can be quickly reviewed by the user. Conversely, link text which is too
long bogs down efficient browsing.
d. Provide alternate mechanisms for on-line forms. Forms are not
supported by all browsers. Therefore, it is important to provide the
user with an opportunity to select alternate methods to access such
forms.
e. All Web pages should be tested using multiple viewers. At a
minimum, pages should be tested with the latest version of Lynx to
ensure that they can be used with screen reader software.
Telecommunications Relay Services (TRS)
18. By using telecommunications relay services (TRS), it has now
become easier for persons with hearing and speech disabilities to
communicate by the telephone. TRS links TTY users with those who do not
have a TTY and use standard telephones. With TRS, a TTY user
communicates with another person with the help of a communications
assistant who is able to talk on the telephone and then communicate by
typing the message verbatim, to the TTY user. The communications
assistant also reads the message typed by the TTY user, or the TTY user
may speak for him or herself using voice carry over.
19. There are now TRS programs in every state. Although TRS is very
valuable, it does have limitations. For example, relay calls take
longer, since they always involve a third party, and typing words takes
longer than speaking words.
Text Telephones (TTYs)
20. A TTY also provides direct two-way typed conversations. The cost
of these devices begins at approximately $200 and they can be operated
by anyone who can type.
21. The following information is excerpted from the brochure ``Using
a TTY'' which is available free of charge from the Access Board:
a. If the TTY line is also used for incoming voice calls, be sure
the person who answers the phone knows how to recognize and answer a TTY
call. You will usually hear silence, a high-pitched, electronic beeping
sound, or a pre-recorded voice message when it is a TTY call. If there
is silence, assume it is a TTY call.
b. TTYs should be placed near a standard telephone so there is
minimal delay in answering incoming TTY calls.
c. To initiate a TTY call, place the telephone headset in the
acoustic cups of the TTY adapter. If the TTY unit is directly connected
to the phone line, there is no need to put the telephone headset in the
acoustic cups. Turn the TTY on. Make sure there is a dial tone by
checking for a steady light on the TTY status indicator.
d. Dial the number and watch the status indicator light to see if
the dialed number is ringing. The ring will make a long slow flash or
two short flashes with a pause in between. If the line is busy, you will
see short, continuous flashes on the indicator light. When the phone is
answered, you will see an irregular light signal as the phone is picked
up and placed in the cradle. If you are calling a combination TTY and
voice number, tap the space bar several times to help the person on the
other end identify this as a TTY call.
e. The person who answers the call is the first to type. Answer the
phone as you would by voice, then type ``GA''.
f. ``GA'' means ``I'm done, go ahead and type''. ``HD'' means hold.
``GA or SK'' means ``Is there anything more, I'm done''. ``SK'' means
stop keying. This is how you show that the conversation is ended and
that you will hang up. It is polite to type good-bye, thank you for
calling, or some other closing remark before you type ``SK''. Stay on
the line until both parties type SKSK.
22. Because of the amount of time it takes to send and receive
messages, it is important to remember that short words and sentences are
desired by both parties. With some TTY calls it is often not possible to
interrupt when the other person is typing. If you get a garbled message
in all numbers or mixed numbers and letters, tap the space bar and see
if the message clears up. If not, when the person stops typing, you
should type, ``Message garbled, please repeat.'' If the garbled messages
continue, this may mean that one of the TTYs is not working properly,
there is background noise causing interference, or that you may have a
bad connection. In this case you should say something like, ``Let's hang
up and I'll call you back.''
23. The typical TTY message will include many abbreviations and
jargon. The message may also include misspelled words because, if the
meaning is clear, many callers will not bother to correct spelling since
it takes more time. Also, some TTY users communicate in American sign
language, a language with its own grammar and syntax. English may be a
second language. Extend the same patience and courtesy to TTY callers as
you do to all others.
[[Page 488]]
Paragraph (b)
1. This paragraph requires manufacturers to supply a point of
contact for obtaining information about accessibility features of the
product and how to obtain documents in alternate formats. This could be
the name of a specific person, a department or an office. Supplying a
telephone number, and preferably a separate TTY number, is the most
universal method. Web site and e-mail addresses are also desirable, but
should not substitute for a telephone number since many more people have
access to a telephone than have e-mail or Internet access. Of course,
the means for requesting additional accessibility information must,
itself, be accessible.
2. Automated voice response systems are not usable by deaf and hard
of hearing persons. An approach to consider is to augment an automated
voice response system with an automated TTY response system that also
detects whether a caller is using voice or TTY.
3. The phone number should be prominently displayed in product
literature. Ideally, it should be displayed on the outside of the
package so that a potential buyer can obtain information about the
accessibility before purchase. In addition, manufacturers should
acquaint their distributors with this information so that they can
assist customers with disabilities, such as a blind person unable to
read the package information.
Paragraph (c)
1. This paragraph requires manufacturers to consider including
information on accessibility in training a manufacturer provides to its
staff. For example, if technical support staff are trained on how to
provide good technical support, such a program should be expanded to
include information on accessibility features of the manufacturer's
products and peripheral devices that are compatible with them. Such
staff should also have basic information on how to handle TTY and relay
calls. Personnel who deal directly with the public, including market
researchers, should be trained in basic disability ``etiquette.''
Section 1193.35 Redundancy and Selectability [Reserved]
1. Although this section is reserved, manufacturers of
telecommunications equipment and customer premises equipment are
encouraged to provide redundancy such that input and output functions
are available in more than one mode.
2. Alternate input and output modes should be selectable by the
user.
3. Products should incorporate multiple modes for input and output
functions so the user is able to select the desired mode.
a. Since there is no single interface design that accommodates all
disabilities, accessibility is likely to be accomplished through various
product designs which emphasize interface flexibility to maximize user
configurability and multiple, alternative and redundant modalities of
input and output.
b. Selectability is especially important where an accessibility
feature for one group of individuals with disabilities may conflict with
an accessibility feature for another. This potential problem could be
solved by allowing the user to switch one of the features on and off.
For example, a conflict may arise between captioning (provided for
persons who are deaf or hard of hearing) and a large font size (provided
for persons with low vision). The resulting caption would either be so
large that it obscures the screen or need to be scrolled or displayed in
segments for a very short period of time.
c. It may not be readily achievable to provide all input and output
functions in a single product or to permit all functions to be
selectable. For example, switching requires control mechanisms which
must be accessible and it may be more practical to have multiple modes
running simultaneously. Whenever possible, it is preferable for the user
to be able to turn on or off a particular mode.
4. Some experiments with smart cards are showing promise for
enhancing accessibility. Instead of providing additional buttons or menu
items to select appropriate input and output modes, basic user
information can be stored on a smart card that triggers a custom
configuration. For example, insertion of a particular card can cause a
device to increase the font size on a display screen or activate speech
output. Another might activate a feature to increase volume output,
lengthen the response time between sequential operations, or allow two
keys to be pressed sequentially instead of simultaneously. This
technology, which depends on the issuance of a customized card to a
particular individual, would allow redundancy and selectability without
adding additional controls which would complicate the operation. As more
and more functions are provided by software rather than hardware, this
option may be more readily achievable.
5. The increasing use of ``plug-ins'' allow a product to be
customized to the user's needs. Plug-ins function somewhat like
peripheral devices to provide accessibility and there is no fundamental
problem in using plug-ins to provide access, as long as the
accessibility plug-ins are provided with the product. For example, at
least one computer operating system comes packaged with accessibility
enhancements which a user can install if wanted. In addition, modems are
typically sold with bundled software that provides the customer premises
equipment functionality.
[[Page 489]]
A compatible screen reader program, for example, could be bundled with
it. At least one software company has developed a generalized set of
accessibility tools designed to be bundled with a variety of software
products to provide access. As yet, such developments are not fully
mature; most products are still installed by providing on-screen visual
prompts, not accompanied by meaningful sounds.
Section 1193.41 Input, Controls, and Mechanical Functions
Paragraph (a)
Operable Without Vision
1. Individuals who are blind or have low vision cannot locate or
identify controls, latches, or input slits by sight or operate controls
that require sight. Products should be manufactured to be usable
independently by these individuals. For example, individuals who cannot
see must use either touch or sound to locate and identify controls. If a
product uses a flat, smooth touch screen or touch membrane, the user
without vision will not be able to locate the controls without auditory
or tactile cues.
2. Once the controls have been located, the user must be able to
identify the various functions of the controls. Having located and
identified the controls, individuals must be able to operate them.
3. Below are some examples of ways to make products accessible to
persons with visual disabilities:
a. If buttons are used on a product, make them discrete buttons
which can be felt and located by touch. If a flat membrane is used for a
keyboard, provide a raised edge around the control areas or buttons to
make it possible to locate the keys by touch. Once an individual locates
the different controls, he or she needs to identify what the keys are.
If there is a standard number pad arrangement, putting a nib on the
``5'' key may be all that is necessary for identifying the numbers. On a
QWERTY keyboard, putting a tactile nib on the ``F'' and ``J'' keys
allows touch typists to easily locate their hands on the key.
b. Provide distinct shapes for keys to indicate their function or
make it easy to tell them apart. Provide Braille labels for keys and
controls for those who read Braille to determine the function and use of
controls.
c. Provide large raised letters for short labels on large objects.
Where it is not possible to use raised large letters, a voice mode
selection could be incorporated that announces keys when pressed, but
does not activate them. This would allow people to turn on the voice
mode long enough to explore and locate the item they are interested in,
then release the voice mode and press the control. If it is an
adjustable control, voice confirmation of the status may also be
important.
d. Provide tactile indication on a plug which is not a self-
orienting plug. Wireless connections, which eliminate the need to orient
or insert connectors, also solve the problem.
e. Avoid buttons that are activated when touched to allow an
individual to explore the controls to find the desired button. If touch-
activated controls cannot be avoided (for example, on a touch screen),
provide an alternate mode where a confirm button is used to confirm
selections (for example, items are read when touched, and activated when
the confirm button is pressed). All actions should be reversible, or
require confirmation before executing non-reversible actions.
f. Once controls have been located and users know what the functions
are, they must be operable. Some types of controls, including mouse
devices, track balls, dials without markings or stops, and push-button
controls with only one state, where the position or setting is indicated
only by a visual cue, will not be usable by persons who are blind or
have low vision. Providing a rotational or linear stop and tactile or
audio detents is a useful strategy. Another is to provide keyboard or
push-button access to the functions. If the product has an audio system
and microprocessor, use audio feedback of the setting. For simple
products, tactile markings may be sufficient.
g. Controls may also be shaped so that they can easily be read by
touch (e.g., a twist knob shaped like a pie wedge). For keys which do
not have any physical travel, some type of audio or tactile feedback
should be provided so that the individual knows when the key has been
activated. A two-state key (on/off) should be physically different in
each position (e.g., a toggle switch or a push-in/pop-out switch), so
the person can tell what state the key is in by feeling it.
h. If an optional voice mode is provided for operating a product, a
simple ``query'' mode can also be provided, which allows an individual
to find out the function and state of a switch without actually
activating it. In some cases, there may be design considerations which
make the optimal mode for a sighted person inaccessible to someone
without vision (e.g., use of a touch screen or mouse). In these cases, a
primary strategy may be to provide a closely linked parallel method for
efficiently achieving the same results (e.g., keyboard access) if there
is a keyboard, or ``SpeedList'' access for touch screens.
Paragraph (b)
Operable With Low Vision and Limited or No Hearing
1. Individuals with low vision often also have hearing disabilities,
especially older individuals. These persons cannot rely solely
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on audio access modes commonly used by people who are blind. Tactile
strategies are still quite useful, although many older persons may not
be familiar with Braille. The objective, therefore, is to maximize the
number of people who can use their residual vision, combined with
tactile senses, to operate a product.
2. Strategies for addressing this provision may include the
following: a. Make the information on the product easier to see. Use
high-contrast print symbols and visual indicators, minimize glare on the
display and control surfaces, provide adequate lighting, position
controls near the items they control to make them easy to find, and use
Arabic instead of Roman numerals.
b. The type-face and type-spacing used can greatly affect
legibility. The spacing between letters should be approximately 1/16 the
height of uppercase letters and the spacing should be uniform from one
label to the next. Also, symbols can sometimes be used which are much
more legible and understandable than fine print.
c. Where the display is dynamic, provide a means for the user to
enlarge the display and to ``freeze'' it. In addition to making it
easier to see, there are strategies which can be used to reduce the need
to see things clearly in order to operate them.
d. A judicious use of color-coding, always redundant with other
cues, is extremely helpful to persons with low vision. These cues should
follow standard conventions, and can be used to reduce the need to read
labels (or read labels more than the first time). In addition, all of
the tactile strategies discussed under section 1193.41 (a) can also be
used here.
Paragraph (c)
Operable With Little or No Color Perception
1. Many people are unable to distinguish between certain color
combinations. Others are unable to see color at all.
2. Strategies for addressing this provision include:
a. Eliminate the need for a person see color to operate the product.
This does not eliminate the use of color completely but rather requires
that any information essential to the operation of a product also be
conveyed in some other fashion.
b. Avoid color pairs such as red/green and blue/yellow, that are
indistinguishable by people with limited color perception.
c. Provide colors with different hues and intensity so that colored
objects can be distinguished even on a black and white screen by their
different appearance. Depending upon the product, the manufacturer may
also be able to allow users to adjust colors to match their preferences
and visual abilities.
d. Avoid colors with a low luminance.
Paragraph (d)
Operable Without Hearing
1. Individuals who are deaf or hard of hearing cannot locate or
identify controls that require hearing. Products that provide only audio
prompts cannot be used by individuals who are deaf or hard of hearing.
For example, a voice-based interactive product that can be controlled
only by listening to menu items and then pressing buttons is not
accessible. By addressing the output issues under section 1193.43(d)
many accessibility problems that affect input under this section can be
solved.
2. Some strategies include:
a. Text versions of audio prompts could be provided which are
synchronized with the audio so that the timing is the same.
b. If prompts are provided visually and no speech or vocalization is
required, most problems associated with locating, identifying, and
operating controls without hearing will be solved.
Paragraph (e)
Operable With Limited Manual Dexterity
1. Individuals may have difficulty manipulating controls on products
for any number of reasons. Though these disabilities may vary widely,
these persons have difficulty grasping, pinching, or twisting objects
and often have difficulty with finer motor coordination. Some persons
may use a headstick, mouthstick, or artificial limb.
2. Below are some strategies which will assist in designing products
which will meet the needs of these persons:
a. Provide larger buttons and controls, or buttons which are more
widely spaced, to reduce the likelihood that a user will accidentally
activate an adjacent control.
b. Provide guard bars between the buttons or near the buttons so
that accidental movements would hit the guard bars rather than
accidentally bumping switches.
c. Provide an optional mode where buttons must be depressed for a
longer period of time (e.g., SlowKeys) before they would accept input to
help separate between inadvertent motions or bumps and desired
activation.
d. Where two buttons must be depressed simultaneously, provide an
option to allow them to be activated sequentially (e.g., StickiKeys).
e. Avoid buttons which are activated merely by touch, such as
capacitance switches. Where that is difficult to do (e.g., with
touchscreens), provide a ``confirm'' button which an individual can use
to confirm that the item touched is the desired one. Also, make all
actions reversible, or request confirmation before initiating non-
reversible actions.
f. Avoid latches, controls, or key combinations which require
simultaneous activation
[[Page 491]]
of two or more buttons, or latches. Also, avoid very small controls or
controls which require rotation of the wrist or pinching and twisting.
Where this is not possible, provide alternate means for achieving the
same functions.
g. Controls which have non-slip surfaces and those that can be
operated with the side of the hand, elbow or pencil can be used to
minimize physical activity required. In some cases, rotary controls can
be used if they can be operated without grasping and twisting (e.g., a
thin pie slice shape control or an edge control). Providing a concave
top on buttons makes them easier to use.
h. Make it easier to insert cards or connectors by providing a bevel
around the slot or connector, or use cards or connectors which can be
inserted in any orientation or which self-center or self-align. Placing
the slot or connector on the front and near a ledge or open space allows
individuals to brace their hands or arms to make use of the slot or
connector easier.
i. For some designs, controls which pose problems for individuals
with disabilities may be the most efficient, logical or effective
mechanism for a majority of users. In these cases, provide alternate
strategies for achieving the same functions, but which do not require
fine manipulation. Speech input or voice recognition could be provided
as an alternate input, although it should not be the only input
technique.
Paragraph (f)
Operable With Limited Reach and Strength
1. Some individuals may have difficulty operating systems which
require reach or strength. The most straight-forward solution to this
problem is to place the controls where they can be easily reached with
minimal changes to body position. Many products also have controls
located on different parts of the product.
2. When this is the case, the following strategies may be used:
a. Allow the functions to be controlled from the keyboard, which is
located directly in front of the user.
b. Allow voice recognition to be used as an option. This provides
input flexibility, but should never be the only means for achieving a
function.
c. Provide a remote control option that moves all of the controls
for the product together on a unit that can be positioned optimally for
the individual. This allows the individual to operate the product
without having to move to it. If this strategy is used, a standard
communication format would be important to allow the use of alternate
remote controls for those who cannot use the standard remote control.
d. Reduce the force needed to operate controls or latches and avoid
the need for sustained pressure or activity (e.g., use guards rather
than increased strength requirements to avoid accidental activation of
crucial switches).
e. Provide arm or wrist rests or supports, create short cuts that
reduce the number of actions needed, or completely eliminate the need to
operate controls wherever possible by having automatic adjustments.
f. Section 4.34.3 of the Americans with Disabilities Act
Accessibility Guidelines (ADAAG) also contains specific information
concerning reach ranges. ADAAG gives specific guidance concerning access
to the built environment. Section 4.34.3 indicates the reach ranges for
a front or parallel approach to equipment for individuals using a
wheelchair. This information may prove useful for those
telecommunications manufacturers whose equipment is stationary, such as
an information kiosk.
Paragraph (g)
Operable Without Time-Dependent Controls
1. Many persons find it very difficult to operate time-dependent
controls.
2. Some strategies which address this problem include:
a. Avoid any timed-out situations or provide instances where the
user must respond to a question or moving display in a set amount of
time or at a specific time (e.g., a rotating display).
b. Where timed responses are required or appropriate, allow the user
to adjust them or set the amount of time allotted to complete a given
task. Warn users that time is running out and allow them to secure
extended time.
c. If the standard mode of operation would be awkward or
inefficient, then provide an alternate mode of operation that offers the
same functions.
Paragraph (h)
Operable Without Speech
1. Many individuals cannot speak or speak clearly. Products which
require speech in order to operate them should also provide an alternate
way to achieve the same function.
2. Some strategies to achieve this include:
a. Provide an alternate mechanism for achieving all of the functions
which are controlled by speech. If a product includes speech
identification or verification, provide an alternate mechanism for this
function as well.
b. Include individuals who are deaf or who have speech disabilities
in the subject populations that are used to develop voice recognition
algorithms, so that the algorithms will better accommodate a wider range
of speech patterns.
[[Page 492]]
Paragraph (i)
Operable With Limited Cognitive Skills
1. Many individuals have reduced cognitive abilities, including
reduced memory, sequence tracking, and reading skills. This does not
necessarily prevent these persons from using a telecommunications
product or feature.
2. The following strategies are extensions of techniques for making
products easier for everyone to learn and use:
a. Use standard colors and shapes and group similar functions
together. On products which have some controls that are used by everyone
and other controls which would only be used by advanced users, it is
generally good practice to separate the two, putting the more advanced
features behind a door or under a separate menu item.
b. Products which read the contents of the display aloud, or
controls which announce their settings, are easier for individuals who
have difficulty reading.
c. Design products that are self-adjusting to eliminate additional
controls which must be learned, and reduce the visual clutter.
d. On products which have sign-in procedures, allow user settings to
be associated with them when they sign in or insert their identification
card. The system can then autoconfigure to them. Some new ``smart
cards'' are being designed with user preferences encoded on the card.
e. Where a complex series of steps is required, provide cuing to
help lead the person through the process. It is also helpful to provide
an ``undo'' or back up function, so that any mistakes can be easily
corrected. Most people will find this function helpful.
f. Where functions are not reversible, request some type of
confirmation from the user before proceeding. On labels and
instructions, it is helpful to use short and simple phrases or
sentences. Avoid abbreviations wherever possible. Eliminate the need to
respond within a certain time or to read text within a certain time.
Section 1193.43 Output, Displays, and Control Functions
Paragraph (a)
Availability of Visual Information
1. Just as persons with visual or cognitive disabilities need to be
able to operate the input, controls, and mechanical functions of a
product, they must also have access to the output functions.
2. The following are strategies for addressing this provision:
a. Provide speech output of all displayed text and labels. For
information which is presented in non-text form (e.g., a picture or
graphic), provide a verbal description unless the graphic is just
decorative. When speech output is provided, allow for the spoken message
to be repeated if the message is very long. Also, if the information
being provided is personal in nature, it is recommended that headphones
be provided in order to assure privacy. A message for stepping through
menus is also helpful.
b. Providing Braille labels for controls is an extremely effective
mechanism for those individuals who read Braille.
c. Large raised print can also be used but is generally restricted
to rather large objects due to the size of the letters.
Paragraph (b)
Availability of Visual Information for Low Vision Users
1. Individuals with low vision often also have hearing disabilities,
especially older individuals. These persons cannot rely solely on audio
access modes commonly used by people who are blind. Tactile strategies
are still quite useful. Many people who have low vision can use their
vision to access visually presented information on a product.
2. Strategies for meeting this provision involve:
a. Provide larger, higher contrast text and graphics. Individuals
with 20/200 vision can see lettering if they get close to it, unless it
is very small or has very poor contrast. Although 14 or 18 point type is
recommended for visual displays, it is usually not possible to put this
size text on small products.
b. Make the lettering as large and high contrast as possible to
maximize the number of people who can use the product.
c. On displays where the font size can be varied, allow the user to
increase the font size, even if it means that the user must pan or move
in order to see the full display.
Paragraph (c)
Access to Moving Text
1. Moving text can be an access problem because individuals with low
vision, or other disabilities may find it difficult or impossible to
track moving text with their eyes.
2. Strategies to address this requirement may include the following:
a. Provide a mechanism for freezing the text. Thus, persons could
read the stationary text and obtain the same information.
b. Provide scrolling to display one full line at a time, with a
pause before the next line replaces it.
c. Provide the same information in another type of display which
does not move. The right-to-left scrolling text on a TTY does not
usually present a problem because it can be controlled by asking the
sender to type slower or pause at specified intervals.
[[Page 493]]
Paragraph (d)
Availability of Auditory Information
1. Individuals who have hearing disabilities are unable to receive
auditory output, or mechanical and other sounds that are emitted by a
product. These sounds are often important for the safe or effective
operation of the product. Therefore, information which is presented
auditorial should be available to all users.
2. Some strategies to achieve this include the following:
a. Provide a visual or tactile signal that will attract the person's
attention and alert the user to a call, page, or other message, or to
warn the user of significant mechanical difficulties in the product.
b. In portable products, a tactile signal such as vibration is often
more effective than a visual signal because a visual signal may be
missed. An auxiliary vibrating signaler might be effective if it is not
readily achievable or effective to build vibration into a portable
product.
c. For stationary products, a prominent visual indicator in the
field of vision (e.g., a screen flash for a computer, or a flashing
light for a telephone) is effective. To inform the user of the status of
a process (e.g., line status on a telephone call, power on, saving to
disk, or disconnected), text messages may be used. It is also desirable
to have an image or light that is activated whenever acoustic energy is
present on a telephone line.
d. Speech messages should be portrayed simultaneously in text form
and displayed where easily seen by the user. Such captions should
usually be verbatim and displayed long enough to be easily read. If the
product provides speech messages and the user must respond to those
messages (e.g., interactive voice response and voice mail), a TTY
accessible method of accessing the product could be provided.
e. TTY to TTY long distance and message unit calls from pay
telephones are often not possible because an operator says how much
money must be deposited. Technology exists to have this information
displayed on the telephone and a test installation is currently
operating at the Butler plaza on the Pennsylvania Turnpike. In addition,
if the product provides interactive communication using speech and
video, it would be helpful to provide a method and channel for allowing
non-speech communication (e.g., text conversation) in parallel with the
video.
f. Certain operations of products make sounds that give status
information, although these sounds are not programmed signals. Examples
include the whir of an operating disk drive and the click of a key being
pushed. Where sounds of this type provide information important for
operating the product, such as a ``beep'' when a key is activated,
provide a light or other visual confirmation of activation.
Paragraph (e)
Availability of Auditory Information for People Who Are Hard of Hearing
1. People who are hard of hearing but not deaf can often use their
hearing to access auditory information on a product.
2. Strategies for addressing this requirement may include the
following:
a. Improve the signal to noise ratio by making the volume
adjustable, between 18-25 dB, increasing the maximum undistorted volume,
and minimizing background noise by such methods as better coupling
between the signal source and the user.
b. Alerting tones are most likely to be heard if they involve
multiple tones, separated in frequency, which contrast with the
environment.
c. Occasionally, varying tones may be preferred for attracting
attention. If speech is used, it is best to test its intelligibility
with individuals who are hard of hearing to maximize its clarity and
ease of understanding. Provide the ability for the user to have any
messages repeated or to repeat the message if no response is received
from the user.
d. For essential auditory information, the information might be
repeated and an acknowledgment from the user requested.
e. The intelligibility of the output can also be maximized by the
location of the speakers and by keeping the speakers away from noise
sources. However, visual displays are often more desirable than loud
prompts or alerts, because the latter reduce privacy and can annoy
others unless the amplified signal is isolated by means of a headphone,
induction coupling, direct plug-in to a hearing aid, or other methods.
f. The use of a telephone handset or earcup which can be held up to
the ear can improve intelligibility without disturbing others in the
area. If a handset or earcup is used, making it compatible with a
hearing aid allows users to directly couple the auditory signal to their
hearing aids. If the microphone in the handset is not being used,
turning it off will also reduce the amount of background noise which the
person hears in the earpiece. Providing a headphone jack also allows
individuals to plug in headphones, induction loops, or amplifiers which
they may use to hear better.
Paragraph (f)
Prevention of Visually-Induced Seizures
1. Individuals with photo-sensitive epilepsy can have a seizure
triggered by displays which flicker or flash, particularly if the flash
has a high intensity and within certain frequency ranges.
[[Page 494]]
2. Strategies to address this requirement involve reducing or
eliminating screen flicker or image flashing to the extent possible. In
particular, the rates of 2 Hz or lower or 70 Hz or higher are
recommended. This recommendation reflects current research data on
people with photosensitive epilepsy which indicates that the peak
sensitivity for these individuals is 20 Hz and that the sensitivity then
drops off in both directions.
3. The chance of triggering seizures can also be reduced by avoiding
very bright flashes which occupy a large part of the visual field
(particularly in the center of the visual field) in order to minimize
the impact on the visual cortex.
Paragraph (g)
Availability of Audio Cutoff
1. Individuals using the audio access mode, as well as those using a
product with the volume turned up, need a way to limit the range of
audio broadcast.
2. If an audio headphone jack is provided, a cut-off switch can be
included in the jack so that insertion of the jack would cut off the
speaker. If a telephone-like handset is used, the external speakers can
be turned off when the handset is removed from the cradle.
Paragraph (h)
Non-Interference With Hearing Technologies
1. Individuals who are hard of hearing use hearing aids and other
assistive listening devices but these devices cannot be used if a
telecommunications product introduces noise into the listening aids
because of stray electromagnetic interference.
2. Strategies for reducing this interference (as well as improving
hearing aid immunity) are being researched. The most desirable strategy
is to avoid the root causes of interference when a product is initially
designed. If the root sources of interference cannot be removed, then
shielding, placement of components to avoid hearing aid interference,
and field-canceling techniques may be effective. Standards are being
developed to limit interference to acceptable levels, but complete
elimination for some technologies may not yet be practical.
3. In April 1996, the American National Standards Institute (ANSI)
established a task group (ANSI C63) under its subcommittee on medical
devices to develop standards to measure hearing aid compatibility and
accessibility to digital wireless telecommunications. The C63.19 task
group is continuing to develop its standard, C63.19-199X, American
National Standard for Methods of Measurement for Hearing Aid
Compatibility with Wireless Communications Devices. When the standard is
completed, the Board intends to reference it in this appendix.
Paragraph (i)
Hearing Aid Coupling
1. Many individuals who are hard of hearing use hearing aids with a
T-coil (or telecoil) feature to allow them to listen to audio output of
products without picking up background noise and to avoid problems with
feedback, signal attenuation or degradation.
2. The Hearing Aid Compatibility (HAC) Act defines a telephone as
hearing aid compatible if it provides internal means for effective use
with hearing aids and meets established technical standards for hearing
aid compatibility.
3. The technical standards for HAC telephones are specified in ANSI/
EIA-504-1989, ``Magnetic Field Intensity Criteria for Telephone
Compatibility with Hearing Aids,'' ANSI/TIA/EIA-504-1-1994, ``An
Addendum to EIA-504,'' which adds the HAC requirements, and the FCC
regulations at 47 CFR 68.317 (a).
4. A good strategy for addressing this requirement for any product
held up to the ear would be to meet these same technical requirements.
If not readily achievable to provide built-in telecoil compatibility,
other means of providing the electro-magnetic signal is the next
strategy to be considered.
Subpart D `` Requirements for Compatibility With Peripheral Devices and
Specialized Customer Premises Equipment
Section 1193.51 Compatibility
Paragraph (a)
External Electronic Access to All Information and Control Mechanisms
1. Some individuals with severe or multiple disabilities are unable
to use the built-in displays and control mechanisms on a product.
2. The two most common forms of manipulation-free connections are an
infrared connection or a radio frequency connection point. Currently,
the Infrared Data Association (IrDA) infrared connection point is the
most universally used approach.
3. The Infrared Data Association together with dominant market
players in the cellular and paging industries, Ericsson, Matsushita/
Panasonic, Motorola, NEC, Nokia, NTT DoCoMo, Puma, and TU-KA Phone
Kansai, announced on April 25, 1997 a proposed set of standards that
will empower wireless communication devices, such as cellular phones,
pagers and personal computers to transfer useful information over short
distances using IrDA infrared data communication ports. Because the
proposed standard is designed to be scalable, it is easy-to-adopt by a
wide range of wireless devices from pagers to more enhanced
communications tools such as smart phones. (See http://www.irda.org).
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4. Adding an infrared connector to the serial port of a peripheral
device or specialized customer premises equipment will make these
products more compatible with each other and with customer premises
equipment.
5. An infrared link can provide a mechanism for providing access to
smaller, more advanced telecommunication devices and provide a safety
net for products which are unable to incorporate other technologies.
There is a joint international effort to develop a Universal Remote
Console Communication (URCC) protocol which would achieve this
functionality. (See http://trace.wisc.edu/world/urc/).
Paragraph (b)
Connection Point for External Audio Processing Devices
1. Individuals using audio peripheral devices such as amplifiers,
telecoil adapters, or direct-connection into a hearing aid need a
standard, noise free way to tap into the audio generated by a product.
2. Individuals who cannot hear well can often use products if they
can isolate and enhance the audio output. For example, they could plug
in a headphone which makes the audio louder and helps shut out
background noise; they might feed the signal through an amplifier to
make it louder, or through filters or frequency shifters to make it
better fit their audio profile. If they are wearing a hearing aid, they
may directly connect their hearing aid to the audio signal or plug in a
small audio loop which allows them to couple the audio signal through
their hearing aid's built-in T-coil.
3. Devices which can process the information and provide visual and/
or tactile output are also possible. The most common strategy for
achieving this requirement is the use of a standard 9 mm miniature plug-
in jack, common to virtually every personal tape player or radio. For
small products, a subminiature phone jack could be used.
Paragraph (c)
Compatibility of Controls With Prosthetics
1. Individuals who have artificial hands or use headsticks or
mouthsticks to operate products have difficulty with capacitive or heat-
operated controls which require contact with a person's body rather than
a tool. Individuals who wear prosthetics are unable to operate some
types of products because they either require motions that cannot easily
be made with a prosthetic hand, or because products are designed which
require touch of the human skin to operate them (e.g., capacitive
touchscreen kiosks), making it impossible for individuals with
artificial arms or hands to operate, except perhaps with their nose or
chin. Some individuals who do not have the use of their arms use either
a headstick or a mouthstick to operate products. Controls and mechanisms
which require a grasping and twisting motion should be avoided.
Paragraph (d)
TTY Connectability
1. Acoustic coupling is subject to interference from ambient noise,
as many handsets do not provide an adequate seal with TTYs. Therefore,
alternate (non-acoustic) connections are needed. Control of the
microphone is needed for situations such as pay-phone usage, where
ambient noise picked up by the mouthpiece often garbles the signal. For
the use of voice carry-over, where the person can speak but not hear,
the user needs to be able to turn the microphone on to speak and off to
allow them to receive the TTY text replies.
2. A TTY can be connected to and used with any telecommunications
product supporting speech communication without requiring purchase of a
special adapter, and the user is able to intermix speech and clear TTY
communication. The most common approach today is to provide an RJ-11
jack. On very small products, where there may not be room for this large
jack, a miniature or subminiature phone-jack wired as a ``headset'' jack
(with both speaker and microphone connections) could be used as an
alternate approach. In either case, a mechanism for turning the phone
mouthpiece (microphone) on and off would reduce garbling in noisy
environments, while allowing the user to speak into the microphone when
desired (to conduct conversations with mixed voice and TTY). For
equipment that combines voice communications, displays, keyboards and
data communication functions, it is desirable to build in direct TTY
capability.
Paragraph (e)
TTY Signal Compatibility
1. Some telecommunications systems compress the audio signal in such
a manner that standard signals used by a TTY is distorted or attenuated
preventing successful TTY communication over the system. A TTY can be
used with any product providing voice communication function.
2. The de facto standard of domestic TTYs is Baudot which has been
defined in ITU-T Recommendation V.18. Although the V.18 standard has
been adopted, products are not yet available which meet its
requirements.
3. This provision can be addressed by ensuring that the tones used
can travel through the phones compression circuits undistorted. It is
even more desirable to provide undistorted connectivity to the telephone
line in the frequency range of 390 Hz to 2300 Hz (ITU-T Recommendation
V.18), as
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this range covers all of the TTY protocols known throughout the world.
Although it may not be achievable with current technology, an alternate
strategy might be to recognize the tones, transmit them as codes, and
resynthesize them at the other end. In addition, it should be possible
for individuals using TTYs to conduct conversations with mixed voice and
TTY, and to control all aspects of the product and receive any messages
generated by the product.