Thread Subject: Re: Subpart A- Draft - (g) Productswithnarrowdelineated use, Add Personal Use to front. and

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From: Jagbell
Date: Fri, Mar 16 2007 3:50 AM

We didn't shift to hearing aids but used hearing aids as something
that would not be covered. The key is to ensure that people who
required AT are included and when AT is applied to someone who needs
HAC that there is a provision for them in the rules. This is a
segment that is overlooked because very few people understand it or
know about it.

Janice





On Mar 16, 2007, at 12:09 AM, Gregg Vanderheiden wrote:

> I'm not sure how this provision shifted to hearing aids.
>
>
>
> This discussion started out talking about providing an exception
> where non-conformant E&IT could be purchased under the supposition
> that a person with a disability could be provided with a different
> accessible version in the future if the need came up (e.g. they
> were hired into a department or promoted into a job that required
> the inaccessible equipment.) the example given was a âpersonal use
> calculatorâ.
>
>
>
> 1) That is a great example but the way the provision was written
> it could be used to purchase anything. The provision did not
> mention personal use products so presumably the provision could
> apply to small copiers, fax machines and many other things. This
> problem could be fixed by adding âpersonal useâ to the front of the
> exception â and that is the suggested fix. That would keep shared
> E&IT from being purchased under this exception that was designed
> for personal use devices (like calculators, cell phones, etc.)
> Note that this provision has nothing to do with adaptive equipment
> or AT. It is an exception from the rules for mainstream E&IT that
> needs to be constrained to only those products it is meant to
> provide an exception for.
>
>
>
> 2) The second part, âfrom standard office supplies budgetâ stems
> from the biggest concern I have heard from consumers. That
> exceptions like this are made, and then when they go to ask for an
> accessible version they are told that there is no money from the
> purchase left to pay for it and there is no money in the budget.
> Their supervisor is perfectly willing but there is no money for
> it. For small items that would fit into the standard office
> budget this is not a problem. For larger items it can be. One
> could decide that office computer workstations fit under this
> provision (even with the âpersonal useâ clause. But that might be
> larger than an office manager could pay for. Some means for
> limiting this to small, personal things is needed. The
> suggestion would be to add âfrom standard office supplies
> budgetâ. But it doesnât have to be that.
>
>
>
> Does someone have other suggestion(s) to keep this limited to
> small, and personal use items?
>
>
>
> Thanks
>
>
>
> Sorry to not be clear.
>
>
> Gregg
> -- ------------------------------
> Gregg C Vanderheiden Ph.D.
>
>
>
>
>
> From: = EMAIL ADDRESS REMOVED = [mailto:teitac-
> = EMAIL ADDRESS REMOVED = ] On Behalf Of Deborah Buck
> Sent: Thursday, March 15, 2007 5:26 PM
> To: 'TEITAC Subpart A Subcommittee'
> Subject: Re: [teitac-subparta] Subpart A- Draft - (g) Products
> withnarrowdelineated use, Add Personal Use to front.
>
> In some circumstances they are personal items- particularly for
> individuals who have cognitive disabilities, auditory processing
> disorders, etc. In other circumstances they are available for
> general use âconference rooms, auditoriums, etc.
>
>
>
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED = [mailto:teitac-
> = EMAIL ADDRESS REMOVED = ] On Behalf Of Jagbell
> Sent: Thursday, March 15, 2007 2:49 PM
> To: TEITAC Subpart A Subcommittee
> Subject: Re: [teitac-subparta] Subpart A- Draft - (g) Products
> withnarrowdelineated use, Add Personal Use to front.
>
>
>
> We need to be very careful. While I agree that hearing aids are
> personal items, Assisitive Listening Devices or FMs are not.
>
>
>
>
>
>
>
> On Mar 15, 2007, at 11:37 AM, Deborah Buck wrote:
>
>
>
> I shared my concerns with the TEITAC Co-chairs on the discussion on
> use of the term âpersonal useâ and wanted to share it with this
> workgroup.
>
>
>
> (g) was proposed because 2 workgroups identified this issue as
> problematic- indicating to me that the current language does not
> suffice and does not provide enough guidance to be implemented
> consistently and with confidence.
>
>
>
> I'm not sure that classifying devices as "personal devices" or
> "standard devices" is the best approach. Unless very clearly
> defined I could see broad and inconsistent interpretations of these
> terms and as result legitimate complaints from employees. From a
> procurement perspective I would think this would be quite
> challenging to determine what constitutes a personal device versus
> a standard device.
>
>
>
> Hearing aids, wheelchairs, etc. are considered "Personal devices"
> and we should be careful not to mix the two- devices used in the
> office by an individual to complete their job responsibilities and
> devices that are used by the individual in all environments- not
> exclusive to the work environment. In addition, once you tie the
> purchase to the individual and their individual needs doesn't it
> become an accommodation, not a 508 procurement. Agencies have the
> requirement to provide alternate means of access when conforming to
> 508 constitutes an undue burden. I would very much like to hear
> from 508 coordinators on whether labeling an item âpersonal useâ
> will address the issue.
>
>
>
> The suggestion to add âfrom standard office supplies budgetâ so it
> reads
>
> which can and will be purchased from the standard office supplies
> budget to meet individual needs
>
> I think that level of specificity goes beyond the scope of the
> TEITAC and the Access Board. Its not an appropriate for standards
> to dictate what budget or cost accounting code agencies use for
> purchases.
>
>
>
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED = [mailto:teitac-
> = EMAIL ADDRESS REMOVED = ] On Behalf Of Gregg Vanderheiden
> Sent: Wednesday, March 14, 2007 8:56 PM
> To: 'TEITAC Subpart A Subcommittee'
> Subject: Re: [teitac-subparta] Subpart A- Draft - (g) Products with
> narrowdelineated use, Add Personal Use to front.
>
>
>
> First â thanks for pulling all this together. Lots of work.
>
>
>
>
>
> RE:
>
>
>
> (g) Products with narrow delineated use, no operating system or
> software, no capacity for assistive technology to be attached to
> the product, such as personal use calculators, for which an agency
> can readily document the availability of specialized products, just
> as a talking calculator or calculator with large visual display,
> which can and will be purchased to meet individual needs, are not
> required to comply with this part.
>
>
>
>
>
> In general I think this is good. I wondering if it is really
> needed. I think it is covered by the old language. But it is suble
> and this can help people get past the âsmall personal itemsâ issue.
>
>
>
> Two EDITS
>
>
>
> 1) I think it needs to have âpersonal useâ added to the front so it
> reads âPersonal use product with narrowâ¦.etcâ .
>
> Shared or public products should not get pushed into this category.
>
> âNarrow useâ by itself is not clear enough and is undefined. I
> thought it meant ânot multipurposeâ but could also be construed to
> mean only used by people in a group or office or floor orâ¦.
>
>
>
> 2) The biggest concern I've heard raised about this (other than no
> inadvertantly creating a loophole that can be expanded to cover
> Mack trucks) was that agencies say they are willing but it isn't in
> their budget â so nothing happens. To make sure this isn't
> misapplied to things beyond the ability of departments to buy
> easily lets add âfrom standard office supplies budgetâ so it reads
>
> which can and will be purchased from the standard office supplies
> budget to meet individual needs
>
>
>
>
>
>
> Gregg
>
> ------------------------
>
> Gregg Vanderheiden
>
>
>
>

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