Thread Subject: Re: Comments re: the proposedrevisionsto 1194.23(k)
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From: Tom Brett
Date: Tue, Mar 06 2007 2:50 AM
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I do not agree. Many developers or requiring officials will state that if
the provision is not listed for the category of product that I am working on
then the provision does not apply. This has occurred many times in the
past. While not duplicating the provisions would seem to be the most
efficient way to show the provisions for knowledgeable individuals, these
standards should be written for those who only have a passing interest or
need. When the supervisor directs the Grade 4 clerk to purchase a EIT item,
the clerk is going to take the path of least resistance. Not all agencies
use the GSA Buy Accessible Wizard that would enumerate the standards &
provisions and there needs to be a comprehensive list of
standards/provisions that someone can look at to evaluate the conformance of
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Gregg
Sent: Tuesday, March 06, 2007 12:41 AM
To: 'TEITAC Telecommunications Subcommittee'
Subject: Re: [teitac-telecom] Comments re: the proposed revisionsto
Everything in the hardware section would apply to telecom that is hardware.
So you don't need to duplicate them.
Gregg C Vanderheiden Ph.D.
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of
> Debbie Cook
> Sent: Monday, March 05, 2007 2:40 PM
> To: TEITAC Telecommunications Subcommittee
> Subject: Re: [teitac-telecom] Comments re: the proposed
> revisions to 1194.23(k)
> 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 group.
> ----- 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 telephone."
> Paul Michaelis
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