Thread Subject: Re: Comments re: the proposed revisions to1194.23(k)
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From: Debbie Cook
Date: Mon, Mar 05 2007 1:45 PM
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K-1, K-1, and K-3 are appropriately hardware requirements. We did discuss
coverage of them In Closed, but this was prior to the expansion of the
desktop group to include all hardware. K-4 is interesting. It's a software
function, but as Paul points out it's a software function very specific to
telecomm and as such should probably be addressed and retained in this
----- Original Message -----
From: "Michaelis, Paul R. (Paul)" < = EMAIL ADDRESS REMOVED = >
To: < = EMAIL ADDRESS REMOVED = >
Sent: Sunday, March 04, 2007 3:22 PM
Subject: [teitac-telecom] Comments re: the proposed revisions to 1194.23(k)
It has been proposed that we move all four of the requirements under
1194.23(k) to Closed Products. I'm quite comfortable with the idea of
moving 1194.23(k)(1), (k)(2), and (k)(3), chiefly because I don't think
I've ever seen a phone that violates these requirements. 1194.23(k)(4)
is a different matter. I'm worried that moving it, without providing a
suitable replacement within the telecom section, is likely to cause a
tremendously important telecom accessibility function to be ignored by
vendors and by procurement officials.
1194.23(k)(4) says the following: "The status of all locking or toggle
controls or keys shall be visually discernible, and discernible either
through touch or sound." Okay, so what's the relevance to telecom?
Telephones of the sort commonly acquired by businesses and by government
agencies tend to present a tremendous amount of information visually.
In addition to caller ID, the visually presented information often
includes which lines are in use, which are on hold, whether there is new
voicemail, whether the phone is forwarded, whether "do not disturb" is
active, whether someone on hold has disconnected, and so on.
Job-specific information is also presented; for example, when used in a
contact center environment, the phones will display information such as
the number of calls in queue, the mean waiting time for callers on hold,
and the agent's "split assignment." In fact, in Avaya systems, the
status of over 240 different telephony functions may be displayed
visually by the telephone.
I have always interpreted 1194.23(k)(4) to mean that, if a telephone is
able to display information or the status of a function visually, it
must be possible for a blind or visually impaired user of that telephone
to obtain the same information via a non-visual mechanism. Going
forward, I believe that we must have an explicit statement within the
telecom section, requiring physical telephones to provide the same
information to visually impaired users that is provided to sighted
users. Without such a requirement, all but the simplest functions
provided by modern telephones will be inaccessible to users who cannot
see the telephones' displays.
I propose the following wording, as a way to retain a requirement
similar to 1194.23(k)(4) in the telecom section: "All of the
information that is presented visually by a telephone must be available
via a non-visual mechanism to blind or visually impaired users of that
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