Thread Subject: Re: Re;Productswithnarrowdelineated use -- Thermometers
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From: Hoffman, Allen
Date: Thu, Mar 29 2007 10:15 AM
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Just to follow up on David's great post:
Thermometers are used to acquire information and/or data, so are really
E&IT by this definition. HVAC, on the other hand do not "manipulate"
information or data, but "control" physical systems to change the
temperature of the environment.
By this definition a x-ray machine acquires information and/or data, so
is covered, while a controller to raise/lower the blinds would not be
By this definition a scanner to detect explosives would be acquiring
information and would be covered.
by this definition a workstation used to control a mail handler might
not be covered as it is a "controller" to just move mail, not gather
information and data about the mail.
By this definition a device to monitor a patient's vital signs and alert
someone about a specific set of changes would be covered, while the
system to electrically stimulate the heart might not be covered.
So, what if I use the monitoring device to record vitals to an external
system for later use--is it covered?
So, what if I attached the explosives device to a targeting system and
it only directs the direction of a gate to admit or deny someone--is it
then not covered as it is only a control mechanism?
Where I'm going with the hypothetical's here is, can we improve the
actual language for subpart A to identify more clearly where the
boundaries are, and provide guidance on what needs to be changed to make
these questions easier to figure out? I'm not so sure there is a lot
that can be done that isn't there if one reads it, but maybe we can
improve on it. Remembering that we are the "recommending body", not the
"final language pencil sharpeners", I think we need to focus less on
specific "accurate to the finest point" language and recommend what we
mean and let the drafters of final language take their crack at it. In
that vein, if we can provide the rationale for the recommendation, and
context for what needs to be said, it would help the next phase move
forward more easily without needing to be time traveling mind readers of
Allen hoffman -- 202-447-0303
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[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Baquis
Sent: Thursday, March 29, 2007 12:49 PM
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Subject: [teitac-subparta] Re;Productswithnarrowdelineated use --
When discussing coverage of medical equipment, please consider a couple
First, medical equipment is written as excepted in the definition of
E&IT. (Actually, it says where IT is integral to its operation.) This is
one of the items on the Access Board list of things that it wants the
TEITAC to discuss. It seems sweeping to exclude so much medical
equipment. If you clarify that some medical equipment is covered by the
508 standards, how will that determination be made? Is it possible for
medical equipment to have IT integral to its operation and also fit the
definition of E&IT? I think so. You can recommend a clarification of the
definition. This is not one of those things you can't touch.
Here is the full text of that definition:
"Electronic and information technology. Includes information technology
and any equipment or interconnected system or subsystem of equipment,
that is used in the creation, conversion, or duplication of data or
information. The term electronic and information technology includes,
but is not limited to, telecommunications products (such as telephones),
information kiosks and transaction machines, World Wide Web sites,
multimedia, and office equipment such as copiers and fax machines. The
term does not include any equipment that contains embedded information
technology that is used as an integral part of the product, but the
principal function of which is not the acquisition, storage,
manipulation, management, movement, control, display, switching,
interchange, transmission, or reception of data or information. For
example, HVAC (heating, ventilation, and air conditioning) equipment
such as thermostats or temperature control devices, and medical
equipment where information technology is integral to its operation, are
not information technology."
Second, when you consider any product for exclusion under 508, I
encourage you to go on the Internet and try to search for a more complex
variant of that product that might in fact clearly be E&IT. For example
see this Basal Thermometer and Ovulation Prediction Computer:
http://www.craigmedical.com/Ovulation_comp.htm. It is a digital
thermometer that stores and interprets data. Also, there is a software
and PC interface kit.
In the end, ask yourself if you are making life more difficult for
federal agencies if they would have to figure out whether 508 applies
based on an analysis of information such as who will use it, how many
they will get, and how it will be paid for. Currently, none of that
matters in the determination of whether a product is E&IT -- or in
claiming an exception. In large departments of thousands of people, this
information may not be readily available to all stakeholders possibly
involved in buying IT: procurement staff, IT shop, requiring officials
in program departments, etc. Please remember to consider the potential
burden/impact of the added effort you may recommend.
U.S. Access Board
1331 F Street, NW, #1000
Washington, DC 20004
800-USA-ABLE; (202) 272-0013 (voice)
www.access-board.gov; = EMAIL ADDRESS REMOVED = "Leading the way to
excellence in accessibility"
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