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

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From: Jagbell
Date: Sun, Mar 18 2007 6:45 PM

I want to make sure that I am reading this correctly. Calculators
and cell phones would not have to be accessible since they are a
personal use item?


On Mar 18, 2007, at 3:02 PM, Gregg Vanderheiden wrote:

> A desk phone is not what I would think of as "Personal use item
> that can be
> bought out of office funds". They are expensive and have to be
> part of the
> overall system. Also, people use more that just the phones on
> their own
> desks. The use them in common areas, meeting rooms, and even other
> offices.
>
>
>
> I thought this was meant to apply to things like 'calculators' and
> other
> small personal use items.
>
> Maybe we should first make a list of things that people think are
> and are
> not in this new category that we are thinking of creating an
> exception for.
> Then figure out how to describe it. And whether it is a good
> idea. I
> think it is a good idea - if we can write it so that it can't be
> misapplied
> easily.
>
> I would think of things in this category as including/excluding
>
>
> THINGS THAT ARE IN THE EXCEPTION
> - calculators
> - personal printer (under $300) (if everyone has a different one on
> their
> desk).
> - cell phones if people are allowed to pick their own (but not if
> they have
> to use one from a pool or all get the same one)
> - PDA if people are allowed to pick their own (but not if they have
> to use
> one from a pool or all get the same one)
>
> THINGS THAT ARE NOT
> - personal workstations
> - shared devices like
> -- fax
> -- copier
> -- printers
> -- Cell phones - if everyone has the same type
>
>
> Huh, interesting exercise. I'm not coming up with too many
> things for
> examples for the exception and it seems to depend on whether it is
> common
> practice for people to get their own type - or whether the
> management and
> perhaps IT system and support requires / wants everyone to use the
> same
> type.
>
>
> Other people, take a crack. What would your lists of examples
> look like.
>
>
>
> Gregg
> -- ------------------------------
> Gregg C Vanderheiden Ph.D.
>
>
>
>> -----Original Message-----
>> From: = EMAIL ADDRESS REMOVED =
>> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of
>> Debbie Cook
>> Sent: Saturday, March 17, 2007 4:12 PM
>> To: TEITAC Subpart A Subcommittee
>> Subject: Re: [teitac-subparta] Subpart A- Draft -
>> (g)Productswithnarrowdelineated use, Add Personal Use to front. and
>>
>> I'm having some difficulty with all of this. My concern is
>> that we cannot deligate budgetary items although in technical
>> guidance we could certainly use it as an example. Is a desk
>> phone a personal use item or not? Some would certainly argue
>> not though it remains on one desk. Likewise, if the
>> calculators are purchased in bulk and employees aren't
>> individually selecting them are they really personal use?
>> Could anything in the procurement process from the FAR be
>> used to help distinquish this?
>> ----- Original Message -----
>> From: "Gregg Vanderheiden" < = EMAIL ADDRESS REMOVED = >
>> To: "'TEITAC Subpart A Subcommittee'"
>> < = EMAIL ADDRESS REMOVED = >
>> Sent: Thursday, March 15, 2007 9:09 PM
>> Subject: Re: [teitac-subparta] Subpart A- Draft - (g)
>> Productswithnarrowdelineated use, Add Personal Use to front. and
>>
>>
>> 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 'personal use calculator'.
>>
>>
>>
>> 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
>> "personal use" to the front of the exception - 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, "from standard office supplies budget"
>> 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 'personal use' 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 "from standard
>> office supplies
>> budget". But it doesn't 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: = 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
>> -conference rooms,
>> auditoriums, etc.
>>
>>
>>
>> -----Original Message-----
>> From: = EMAIL ADDRESS REMOVED =
>> [mailto: = 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 "personal use" 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
>> "personal use" will address the issue.
>>
>>
>>
>> The suggestion to add "from standard office supplies budget"
>> 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: = 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 - 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 "small personal items" issue.
>>
>>
>>
>>
>> Two EDITS
>>
>>
>>
>>
>> 1) I think it needs to have "personal use" added to the front
>> so it reads
>> "Personal use product with narrow..etc" .
>>
>> Shared or public products should not get pushed into this category.
>>
>> "Narrow use" by itself is not clear enough and is undefined.
>> I thought it
>> meant 'not multipurpose" but could also be construed to mean
>> only used by
>> people in a group or office or floor or..
>>
>>
>>
>> 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 - so
>> nothing happens. To make sure this isn't misapplied to
>> things beyond
>> the ability of departments to buy easily lets add "from
>> standard office
>> supplies budget" 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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