Thread Subject: Re: Comments re: theproposed revisionsto 1194.23(k)

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From: Jagbell
Date: Tue, Mar 06 2007 3:45 AM

It needs to be very specific and clear because I too have encountered
similar issues. There cannot be an "escape hatch" for someone who
wants to avoid compliance.

Best,

Janice


On Mar 6, 2007, at 5:03 AM, David Poehlman wrote:

> We could put a clause in telecom pointing to hardware as covered?
>
> On Mar 6, 2007, at 4:48 AM, Tom Brett wrote:
>
> 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
> the product.
>
> Tom Brett
>
>
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Gregg
> Vanderheiden
> Sent: Tuesday, March 06, 2007 12:41 AM
> To: 'TEITAC Telecommunications Subcommittee'
> Subject: Re: [teitac-telecom] Comments re: the proposed revisionsto
> 1194.23(k)
>
> Everything in the hardware section would apply to telecom that is
> hardware.
> So you don't need to duplicate them.
>
>
> Gregg
> -- ------------------------------
> 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."
>>
>>
>>
>> Regards,
>>
>>
>>
>> Paul Michaelis
>>
>>
>>
>>
>> --------------------------------------------------------------
>> ------------------
>>
>>
>>

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