Thread Subject: Re: SubpartA-Draft-(g)Productswithnarrowdelineated use,Add Personal Use to front

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From: tom brett
Date: Thu, Mar 29 2007 8:30 AM

We would be saying that the definition of EIT is in clinger - cohen with the
specific exceptions of:

1) products that are relatively low in cost
2) products that are readily available and easily substituted that can
deliver a full range of access features in discreet "packages"

This makes sense but the next question that would be asked is what does
relatively low cost mean? Although I am not a fan of the Micro purchase
exception, wouldn't it be easier to recommend to the Access Board that the
micro purchase exemption be re instated?

Defining what is mean by "readily available", "low cost" and "range of
access feature" is relative to the agency budget, the agency program and the
type of work being done.




Tom Brett, ATACP
Section 508/Section 255 Specialist,
888.896.8579
Voice/TTY: 301.942.9768
TCS Associates, an Abacus-N-Bytes, Inc. Company
8(a)/MBE Certified
GSA Schedule GS-35F-0512L
www.tcsassociates.com
Fax: 301.942.9110


-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Deborah Buck
Sent: Thursday, March 29, 2007 10:14 AM
To: 'TEITAC Subpart A Subcommittee'
Subject: Re: [teitac-subparta]
SubpartA-Draft-(g)Productswithnarrowdelineated use, Add Personal Use to
front

I like the factors or benchmarks you've identified versus focusing on
personal use which will mean different things to different people. What is
the groups reaction to using these benchmarks 1) the product is relatively
low in cost and 2) products are readily available and easily substituted
that can deliver a full range of access features in discreet "packages" as
the determining factors for an exemption?

-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Diane Golden
Sent: Thursday, March 29, 2007 11:17 AM
To: 'TEITAC Subpart A Subcommittee'
Subject: Re: [teitac-subparta]
SubpartA-Draft-(g)Productswithnarrowdelineated use, Add Personal Use to
front

I'm not convinced we should be so focused on "personal use" of closed
products as an upfront discriminating factor. It seems the much more
critical characteristics are 1) the product is relatively low in cost and 2)
products are readily available and easily substituted that can deliver a
full range of access features in discreet "packages". Those two
characteristics allow the agency to purchase a device with the access
features needed by one or more individuals instead of buying only a product
with multiple access features that can actually decrease overall access for
a particular individual (e.g. the calculator that has large keys which
impedes effective touch key input for a blind person.)

Diane

-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ]On Behalf Of Deborah
Buck
Sent: Thursday, March 29, 2007 9:31 AM
To: 'TEITAC Subpart A Subcommittee'
Subject: Re: [teitac-subparta]
SubpartA-Draft-(g)Productswithnarrowdelineated use, Add Personal Use to
front


It seems that we have two issues
1) Definition of E&IT:
The definition of E&IT currently does not include medical devices. As such
they would be modified or adapted on an as needed basis in line with the
federal government's obligations under the ADA and 504. The group would
need to decide if they want to make a recommendation to the Access Board to
change the definition of E&IT to include medical devices, HVAC and any
device that now or in the future stores and transmits information. This
approach would also extend to AT. Would this also apply to what is currently
considered back office equipment? Part of the challenge with this is that no
manufactures of those types of devices, with the exception of AT, have been
engaged in the discussions to date. Industry representatives from those
groups have not been brought to the table. The workgroups have also been
tasked with looking at the cost benefits of the changes to the standards
(although I'll admit I'm still at a loss as to how to do this) this
recommendation would result in a major change to the scope of 508 and its
impact on industry outside of the generally accepted IT companies. The
concept of commercial nonavailiability would have to be maintained because
the scope of application would be expanded and while many products in the IT
arena have caught up to the 508 standards we're talking about a broader
expansion to manufacturers that will be starting at square 1 who will not
even know what 508 is let alone how to modify their products to conform to
the standards.
2) One-Offs
The discussion started with the suggestion for an added exemption for the
acquisition of products that meet the definition of closed products, but
that are "personal use" devices. The best example so far has been talking
calculators, but it seems that as discussions go on the scope of products
gets broader. The initial suggestion was to make a recommendation for an
exemption to the standards that would apply to a narrow scope of products
that can be defined as personal use. While I have concerns about defining
items as personal use we have not come up with a logical way to identify
these products so that everyone has an understanding of the limited
application of the exemption. The cost benefit issue of requiring all
products to conform was raised by one of the workgroups.


-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of David Poehlman
Sent: Thursday, March 29, 2007 7:23 AM
To: TEITAC Subpart A Subcommittee
Subject: Re: [teitac-subparta] SubpartA-
Draft-(g)Productswithnarrowdelineated use, Add Personal Use to front. and

Somewhere, it was suggested that a provision be made to deal with
this in much the same way as alternate forrmats are dealt with., on
an as needed basis. I fear that if something is not put into the
standards to cover this type off information bearing and gathering
equipment, some willl likely loos or not be aable to do the work that
require the devices. I would say that the standards need to be there
and a manufacturer needs to demonstrate the ability to deliver on the
standards a product which if required can meet this need. And, yes,
the crux of this is that since they are going digital and storing and
transmitting information in addition to just displaying it that this
is electronic because it uses that power and information ttechnology
because it utillizes, stores, sends and sometimes receives
information. Tough? Yes, needed? Yes.

On Mar 28, 2007, at 7:39 PM, Deborah Buck wrote:

No, all computers are not equipped with screen readers, but then
neither is
a copier - it must be accessible without the attachment of AT (screen
reader). It goes back to the discussion of calculators and must all
calculators be talking calculators- it's a closed product. If you
were to
consider medical/research devices as E&IT wouldn't many be considered
closed
products and required to have accessibility built-in?

Medical devices and Heating, ventilation and air conditioning devices
(HVAC)
are currently not included under the definition of E&IT? Are you
suggesting
that we make a recommendation to the Access Bd to change the
definition of
E&IT to include medical devices? And if medical devices are
considered E&IT,
what about HVAC?


-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of David
Poehlman
Sent: Wednesday, March 28, 2007 6:42 PM
To: TEITAC Subpart A Subcommittee
Subject: Re: [teitac-subparta] SubpartA-
Draft-(g)Productswithnarrowdelineated use, Add Personal Use to front.
and

are all computers equipped with a screen reader?

On Mar 28, 2007, at 4:55 PM, Deborah Buck wrote:

So on the low end of this - all digital ear thermometers that are
purchased
for use at Walter Reed Hospital as a federal facility would have to be
talking digital thermometers and on the other end all spectographs or
other
devices that measure light, sound, masses, etc. would have to be
accessible?

-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of David
Poehlman
Sent: Wednesday, March 28, 2007 4:39 PM
To: TEITAC Subpart A Subcommittee
Subject: Re: [teitac-subparta] SubpartA-
Draft-(g)Productswithnarrowdelineated use, Add Personal Use to front.
and

I agree with this. It might be prudent to flesh this out into a
category in order to keep it in play. If cell phones and pagers can
be inccludeed, digital medical devices and point of ssale devices
certainly can.

On Mar 22, 2007, at 2:19 AM, Debbie Cook wrote:

Digital medical products would probably be E&IT.

And the cash register introduces an entirely different concept. Now, in
addition to exempting the calculators et al, we're now talking about
exempting big items. (Some per centage of the copiers etc.) So I'm
wondering
if it leaves a little band in the middle and where are the lines?
I've been
very in favor of legitimizing some of what goes on already in the
name of
defining and ultimately limiting it, but now we're working both ends.
And
this worries me a lot. Why then should all of anything be accessible? If
we're only going to buy a couple of the accessible ones, who is going to
make them? What will it be worth to them? If there's no mass
production, the
accessible ones will cost too much. And they won't be there when needed.
I haven't been inclined to be an extremest, but I would move that way
rather
than to exempt everything except computer hardware and software.
----- Original Message -----
From: "Gregg Vanderheiden" < = EMAIL ADDRESS REMOVED = >
To: < = EMAIL ADDRESS REMOVED = >; "'TEITAC Subpart A Subcommittee'"
< = EMAIL ADDRESS REMOVED = >
Sent: Wednesday, March 21, 2007 11:08 PM
Subject: Re: [teitac-subparta] SubpartA-
Draft-(g)Productswithnarrowdelineated use,Add Personal Use to front. and


Hmmmm
Are these E&IT?

The cash registers is a good one to discuss.
But thermometers and glucometers and stethescopes?

Are we talking about the cash register as an item for exemption
category we
have been discussing for personal calculators?


Gregg
-- ------------------------------
Gregg C Vanderheiden Ph.D.



> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of
> Diane Golden
> Sent: Wednesday, March 21, 2007 3:56 PM
> To: 'TEITAC Subpart A Subcommittee'
> Subject: Re: [teitac-subparta] Subpart A-
> Draft-(g)Productswithnarrowdelineated use, Add Personal Use
> to front. and
>
> I think we're a bit too stuck in the "office environment"
> trying to identify the kinds of products that need the
> "narrow use - readily substitutable"
> exception. We have issues in state government with things
> like cash registers, do we need to buy all of them with
> speech output options, large visual display screens, etc.?
> Same with small medical products like thermometers and
> glucometers (do they all need to talk)? Do all stethescopes
> need to be amplified? I'm sure there are many similar
> examples in other "non-office" type environments that are
> part of government agencies.
>
> Diane Golden
> NASCIO
>
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ]On Behalf Of
> Debbie Cook
> Sent: Monday, March 19, 2007 2:22 PM
> To: TEITAC Subpart A Subcommittee
> Subject: Re: [teitac-subparta] Subpart A-
> Draft-(g)Productswithnarrowdelineated use,Add Personal Use to
> front. and
>
>
> Thismay come down to someting like electronic office
> supplies. Calculators may abe about all that come into it
> frankly. Most agencies have contracts for cell phones, even
> small printersetc. The key would be user selectable if it
> exists. In my office we don't even get to select the
> calculators except from a particular group. Common practice
> is that employees routinely select these and in this case
> they would not all have to be accessible or could have
> different accessibility. But if procurement is tightly
> controlled, thn no prodeucts including the calculator would
> fly on this. So maybe the key is not the type of product as
> much as how procurement decisions are made.
> ----- Original Message -----
> From: "Gregg Vanderheiden" < = EMAIL ADDRESS REMOVED = >
> To: "'TEITAC Subpart A Subcommittee'"
> < = EMAIL ADDRESS REMOVED = >
> Sent: Sunday, March 18, 2007 12:02 PM
> Subject: Re: [teitac-subparta] Subpart A- Draft
> -(g)Productswithnarrowdelineated use,Add Personal Use to front. and
>
>
> 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.
>
>

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