Thread Subject: Re: Basic questions

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From: Jim Tobias
Date: Wed, Nov 15 2006 11:45 AM

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From: = EMAIL ADDRESS REMOVED = [mailto: = EMAIL ADDRESS REMOVED = ]
Sent: Wednesday, November 15, 2006 11:03 AM
To: TEITAC self contained/closed products subcommittee
Subject: Re: [teitac-closed] Basic questions



TEITAC Self-contained Closed Committee,

Real World Considerations:

While certainly the offerings of large office multifunction devices that
copy, print, fax, scan, etc. outnumber standalone copiers- as was previously
mentioned, manufacturers do not have control over how customers actually use
them once purchased. In some cases, these devices are never connected to
the network. This is sometimes because the customer does not have a network
drop where they want to place the machine OR due to security concerns.
Security is a major concern of the federal government and we should not
assume that all agencies will want to put these machines on the network.

The agency bears the burden of 508. Regarding where they put the product or
how they connect it, they are not supposed to be entirely free of
accessibility concerns. For example, they could not put the only copier in
an inaccessible room, or install it against a wall in such a way that a
person in a wheelchair could not approach it for operation. But those are
their responsibilities, not the manufacturer's.

Also, if the accessibility of these multifunction devices is to be provided
remotely through a PC- this requires the additional purchase of a PC for
each machine + the AT software.

The intention is not to require anything additional. If it's on the network
or attached to a single user's PC, it would be controlled by the user's PC,
presumably already equipped with AT for all the other things that user is
doing on the PC. There remains the case where an employee with a disability
does not have a PC. But

I agree that this is a convenient solution, but not all of our federal and
state customers (who have adopted 508) will want to incur this expense. We
cannot assume that it is practical to connect the multifunction device to
their users workstation. It is possible that the user with a disability's
work area is on the other side of the department from the multifunction
device- so purchasing a dedicated PC is often the best solution for remote
access. Though again, expensive.

In the cases I'm familiar with, such as talking printer/copiers, the
solution is much more expensive than even the most expensive version of an
additional workstation and AT, something on the order of $1500 for a
screen-reader-equipped product. Yet nothing I'm proposing would disallow
manufacturers from offering or agencies from purchasing such a product.

Due to Equivalent Facilitation (Subpart A 1194.5), manufacturers have been
able to design copiers/multifunctional devices to meet the 508 standards
through the machine itself OR by providing the accessibility remotely. We
can decide based on our customers preferences, and both are worthy
advancements. Speech guidance and recognition can also be provided directly
from the copier/multifunction device. It's available now and can be more
widely so in the future. Let's not hinder this progress by requiring remote
access.

It's the intent of the straw man to expand the potential for progress by
allowing agencies to purchase (to simplify by using your example) either a
talking printer or a non-talking printer that's controlled from an
AT-equipped workstation.

One of the flaws of the "talking printer" scenario is that blindness isn't
the only disabling condition. An employee who uses an alternative input
system doesn't benefit from a talking printer. The advantage of driving the
product from the user's workstation is that the "right" interface will
already be in place.

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