Section 508 Reference Guide
1194.25 Self-Contained, Closed Products
Overview
By definition, a self-contained, closed product is a device unto itself. The Section 508 technical standards for this category apply to products that generally have embedded software and are commonly designed in such a fashion that a user cannot easily attach or install AT. Examples of these products include copiers, printers, fax machines, calculators, and information kiosks.
If a product falls into this category, no interoperability capabilities are mandated for it. However, there are some specific requirements that have implications for AT. For example, if a printer is to be integrated with an external computer and driver software, the software interface to the printer and its drivers would be considered subject to the provisions of 1194.21 Software Applications and Operating Systems.
The standards require that alternative access features be built into the product so users do not have to attach an assistive device to it. Other specifications address mechanisms for private listening (handset or a standard headphone jack), touchscreens, auditory output and adjustable volume controls, and location of controls in accessible reach ranges.
Remember that…
- If a coordinator does not have the required technical skills, tools and/or knowledge to determine compliance (e.g., 1194.25(f)), the easiest and most effective way to evaluate a product is to read the user manual or call the manufacturer. Since the manufacturer has already stated that the product is compliant, they should have no trouble explaining exactly how it complies with the standard. It is highly recommended that the coordinator take note of the manufacturer's explanations and make them part of the official procurement documentation.
- Compliance for some standards is required only if a certain condition exists. For example, 1194.25(h) is only applicable if the product has adjustable color and contrast settings. If the product does not offer the adjustments, then the standard does not apply.
- Products in this category provide all required accessibility as standalone units without the support of external AT.
- Satisfying these requirements does not involve interoperability with AT.
- Interoperability that occurs internally, between the components of a self-contained, closed product, is beyond the scope of Section 508.
References
1194.25(a) "Self-contained products shall be usable by people with disabilities without requiring an end-user to attach assistive technology to the product. Personal headsets for private listening are not assistive technology."
In other words…
Self-contained products must be usable by people with disabilities. Products cannot require the attachment of AT for their use.
Note: Personal headsets for private listening do not fall under this standard; hence there is no conflict with 1194.25(e) below.
Determining Compliance
- Important functional keys must be logically designed (e.g., the on/off key is large and tactilely discernible).
- Important functional keys should be easy to use (e.g., requesting a number of copies to be printed).
- All important auditory information should have a visual equivalent, and vice versa.
Identify all product functions.
- Where does the product warn the user of problems (i.e., at the product and/or at the individual's PC)? Many vendors provide an on-screen message that warns the user of functional problems (e.g., paper jam or out of paper). This works well if the user is at their PC before going to the product. However, how does the vendor alert the user of a problem once the user is at the product?
Notes
- Providing an industry standard connection point to allow AT to interface with an otherwise self-contained product does not result in a violation of 1194.25(a), neither is it a case for equivalent facilitation.
- A PDA is not necessarily a self-contained, closed product. Non-closed products are increasingly being used as PDAs.
1194.25(b) "When a timed response is required, the user shall be alerted and given sufficient time to indicate more time is required."
In other words…
Alert the user whenever a time-critical action is required on their part. The user must be given enough time to extend the response time.
Note: Assume that informed individuals can reasonably and consistently judge the amount of time they need and indicate that more time is needed.
Determining Compliance
This standard applies to any product that automatically resets to "0" or a default setting after a specific length of time where there is no input (e.g., copiers, kiosks). For each product or function that requires a response within a specific amount of time:
- The user must be warned before the response time has elapsed.
- The product must provide sufficient time for the user to indicate that more time is required.
- The user must be able to extend the response time to allow sufficient time for the user to complete the function.
Notes
- If the response time is not limited, this standard is not applicable.
- Although not required, it is good programming practice to use non-destructive timeouts.
- This standard is parallel to standards 1194.22(p) for web-based information and applications and 1194.23(d) for telecommunication products.
1194.25(c) "Where a product utilizes touch-screens or contact-sensitive controls, an input method shall be provided that complies with §1194.23(k)(1) through (4)."
In other words…
An input method other than touch-responsive controls is required for devices using touchscreens or touch-operated (i.e., non-mechanic) controls.
Note: This provision does not prohibit the use of touchscreens and contact-sensitive controls, but requires a redundant set of controls that can be used by persons who have access problems with touch controls.
Determining Compliance
For all normal system functions, the product must provide a set of controls that is not touch-sensitive and that conforms to the following standards under 1194.23 Telecommunications Products.
- (k)(1) Controls and keys must be tactilely discernible.
- (k)(2) Controls and keys must be operable with one hand without great difficulty.
- (k)(3) If key repeat is available, then repeat delay and repeat rate must each be adjustable to two seconds.
- (k)(4) The status of locking and toggle controls must be discernible visually, and through touch or sound.
Note
- The terms "touch-screen" and "contact-sensitive control" do not necessarily imply touch by the human body. Contact with objects such as mouthsticks, styluses, or pencils is also included.
- This standard is parallel to standard 1194.26(b) for desktop and portable computers.
1194.25(d) "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."
In other words…
If a system uses biometrics for identification (e.g., retinal scanning or fingerprint identification) or for system operation, the system must also provide a means of equivalent, alternative access independent of any particular biological feature (e.g., entering a password).
Term
Determining Compliance
- Determine all user identification or controls that require particular user biometrics.
- Provide an alternative means for user identification or operation of a control. This can often be done through the implementation of passwords.
Notes
1194.25(e) "When products provide auditory output, the audio signal shall 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."
In other words…
If a product provides an audio output signal, it must meet specific requirements that allow for private listening.
Note: Assume that an informed person is able to determine what a standard signal level (e.g., volume) would be for a product.
Term
- Auditory output: In the context of this requirement, any voice output, including synthesized voice.
Determining Compliance
If a product provides auditory output:
- There must be a standard audio connection point.
- If in a public area, the audio output must be powerful enough to be audible.
- There must be controls for audio interrupt, pause, and restart.
Notes
- If a product does not have auditory output, then this standard does not apply.
- Industry standard audio connection points are 2.5 mm or 3.5 mm jacks. The larger 3.5 mm jack is the connection point typically used by persons with visual disabilities.
- Industry standard signal levels for digital wireless phones are specified in TIA/EIA-TSB121 - Cellular Subscriber Unit Interfaces for TDD.
- Satisfying this requirement supports interoperability with AT by allowing the use of hearing aids, cochlear implants, and assistive listening devices.
1194.25(f) "When products deliver voice output in a public area, incremental volume control shall be provided with output amplification up to a level of at least 65 dB. Where the ambient noise level of the environment is above 45 dB, a volume gain of at least 20 dB above the ambient level shall be user selectable. A function shall be provided to automatically reset the volume to the default level after every use."
In other words…
When a product has voice output and it will be used in a public area, it must have incremental volume control for the user to increase voice output above the ambient level. The product must be able to automatically reset the volume to its default level after every use.
Terms
Determining Compliance
It is hard to ensure complete compliance without reading the user manual, consulting the manufacturer, or using specialized audio testing equipment. However there are several practical methods for initial testing. If the product has voice output and is in a public area:
- The product must provide incremental volume control to amplify the volume so that the voice output can be heard over the ambient background noise.
- The volume control must conform to 1194.23(k)(1), (2), (3), and (4).
- The product must be able to automatically reset the volume to the default level after every use.
Note
- Location of the product is an important consideration for this requirement. If two units are located next to each other in an otherwise quiet room, their 65 dB output will raise the ambient noise level above 45 dB.
- This standard is comparable to standards 1194.23(f) and (g) for telecommunications products.
1194.25(g) "Color coding shall not be used as the only means of conveying information, indicating an action, prompting a response, or distinguishing a visual element."
In other words…
Color should never be the only means to identify functions, visual elements or information.
Determining Compliance
For all product features that use color-coding, an alternate means of identification that does not rely on color must be provided. Also, because of standard (a) above, the alternate means must be accessible without attaching AT to the product.
For example, if a lighted button performs one function when it is green and a different function when it is red, then the status of the button should be evident through another means, e.g., through sound or touch. Distinct patterns of light would technically satisfy this standard, but would not satisfy standard (a) or 1194.23(k)(4).
- Methods for determining how color-coding is used to convey information include observation of the product interface and review of the product documentation (e.g., user manuals plus online help).
- If the product includes a color display, the images on the display may convey meaning with color. This is acceptable if equivalent information is provided through an accessible means, e.g., through visual text plus auditory output. If the display has a black-and-white or monochromatic setting, activate it and verify that all information is still conveyed.
- Critical or special controls may be distinct colors, but should also be distinct sizes or shapes that are easy to locate, and may be labeled with text.
- All uses of color-coding for normal operation (which excludes maintenance and setup) are included in the set of functions covered by this requirement.
Note
- This standard is parallel to standards 1194.21(i) for software applications and operating systems and 1194.22(c) for web-based information and applications.
1194.25(h) "When a product permits a user to adjust color and contrast settings, a range of color selections capable of producing a variety of contrast levels shall be provided."
In other words…
A variety of color selections and contrast levels should be provided when a product allows the user to change contrast or color settings. If the product does not feature adjustable color or contrast settings, then the standard does not apply.
Determining Compliance
When a product allows the adjustment of color or contrast settings:
- Verify that the product allows color adjustment to foreground, background, or other elements.
- Verify that the product provides a range of colors. For example, Microsoft allows at least 30 variations. At a minimum, the product should include the selection of the eight primary colors for both the foreground and background.
- While observing contrast levels, adjust the display to full-color and monochrome settings.
Notes
- There should be a combination that will provide a soft background, low contrast color scheme as well as combinations that provide a high contrast color scheme.
- Avoid reds and greens together. White on black, black on white, and yellow on black are examples of high contrast settings.
- Lighthouse International provides guidelines for effective color contrast on their web site at http://www.lighthouse.org/color_contrast.htm.
- Color combinations should be observed on a video display, not in printed material.
- This standard is parallel to standard 1194.21(j) for software applications and operating systems.
1194.25(i) "Products shall be designed to avoid causing the screen to flicker with a frequency greater than 2 Hz and lower than 55 Hz."
In other words…
If a product includes one or more visual display screens, it should be designed so that flicker on the screens is nonexistent, or very slow (e.g., one flicker per second), or very fast (at least fifty-five flickers per second).
Terms
Determining Compliance
It is best to avoid products that flash or blink. If a product has a visual display screen:
- While exercising all product features that affect the screen, look for any flickering or blinking images. Also check product documentation for references to flickering, flashing or blinking images.
- Special tools are required to accurately measure the screen flicker rate. Check the user manual for the flicker/blink rate. If it is not listed, call the manufacturer for information.
- Because 2 Hz is relatively slow, it is possible to use visual observation to determine whether the blink rate is greater than 2 Hz. Ideally, the blink rate should not be greater than 1 Hz, i.e., one blink per second. If no timing device is available, you may approximate a one-second interval by speaking the words "one thousand one".
Notes
- If there are multiple images or screens that are flickering simultaneously in the same visual space, the cumulative effect should be considered.
- Processor speeds and graphic cards can affect the flicker rate, so each product model should be checked. If a product has multiple screens, each one should be checked.
- LEDs and illuminated buttons are not covered by this requirement.
- This standard is parallel to standards 1194.21(k) for software applications and operating systems and 1194.22(j) for web-based information and applications.
1194.25(j)(1) "Products which are freestanding, non-portable, and intended to be used in one location and which have operable controls shall comply with the following: The position of any operable control shall 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)."
d
In other words…
When a product is intended to be a free-standing, permanent installation (e.g., an information kiosk), each operable control must be within reach. Before verifying conformance to the reach ranges in standards (j)(2), (j)(3), and (j)(4) below, it is necessary to establish a reference plane for each control.
Term
Determining Compliance
It is always possible to define a reference plane for each operable control.
- To locate every operable control, inspect the product and review the product documentation.
- From a natural angle of operation, visualize a horizontal line that extends outward from the control. This is the "centerline".
- Visualize a solid rectangle that is perpendicular to the centerline: two vertical edges that are 24 inches from the control on either side of it; the bottom edge is on the floor; the top edge is 54 inches above the floor.
- Without changing the orientation of the rectangle or the point at which it intersects the centerline, slide the rectangle outward until it no longer touches the product. This rectangle is the reference plane.
Notes
- A product may have controls in more than one location, resulting in more than one reference plane.
- All controls for normal operation and monitoring (which excludes maintenance and setup) are included in the set of controls covered by this requirement.
1194.25(j)(2) "Products which are freestanding, non-portable, and intended to be used in one location and which have operable controls shall comply with the following: Where any operable control is 10 inches or less behind the reference plane, the height shall be 54 inches maximum and 15 inches minimum above the floor."
In other words…
When a product is intended to be a free-standing, permanent installation, each operable control must be within reach. Each control that is proximal (within 10 inches of its reference plane) must be between 15 and 54 inches from the floor.
Term
Determining Compliance
- For a quick but inaccurate test:
- Sit in front of the product in a chair with a seat height of 23.75 inches (the seat height of a wheel chair).
- Verify that you can reach the controls easily.
- For an accurate test:
- Check the product documentation for information about control height and depth.
- Use standard (j)(1) above and a measuring device to establish the reference plane for each operable control.
- Use the measuring device to verify that each control that is within 10 inches of its reference plane is 15 to 54 inches above the floor.
1194.25(j)(3) "Products which are freestanding, non-portable, and intended to be used in one location and which have operable controls shall comply with the following: Where any operable control is more than 10 inches and not more than 24 inches behind the reference plane, the height shall be 46 inches maximum and 15 inches minimum above the floor."
In other words…
When a product is intended to be a free-standing, permanent installation, each operable control must be within reach. Each control that is recessed (farther than 10 inches from its reference plane, but within 24 inches) must be between 15 and 46 inches from the floor.
Term
Determining Compliance
- For a quick but inaccurate test:
- Sit in front of the product in a chair with a seat height of 23.75 inches (the seat height of a wheel chair).
- Verify that you can reach the controls easily.
- For an accurate test:
- Check the product documentation for information about control height and depth.
- Use standard (j)(1) above and a measuring device to establish the reference plane for each operable control.
- Use the measuring device to verify that each control that is greater than 10 inches but within 24 inches from its reference plane is 15 to 46 inches above the floor.
Notes
- The maximum height in this standard is 8 inches lower than the maximum height in standard (j)(2) above. So, for example, controls that are recessed only slightly more than 10 inches are required to be significantly lower in height.
- Manufacturers may attempt to make a case for equivalent facilitation if this transition in height in relation to depth is more gradual. For example, a control that is 17 inches behind the reference plane and 50 inches above the floor does not conform to this standard, but is probably within the reach of most users.
1194.25(j)(4) "Products which are freestanding, non-portable, and intended to be used in one location and which have operable controls shall comply with the following: Operable controls shall not be more than 24 inches behind the reference plane (see Figure 2)."
d
In other words…
When a product is intended to be a free-standing, permanent installation, each operable control must be within reach. Controls may not be recessed more than 24 inches.
Term
Determining Compliance
- For a quick but inaccurate test:
- Sit in front of the product in a chair with a seat height of 23.75 inches (the seat height of a wheel chair).
- Verify that you can reach the controls easily.
- For an accurate test:
- Check the product documentation for information about control height and depth.
- Use standard (j)(1) above and a measuring device to establish the reference plane for each operable control.
- Use the measuring device to verify that every control is within 24 inches of its reference plane.
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