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

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From: Hoffman, Allen
Date: Thu, Mar 29 2007 10:50 AM

I think we are not intending "personal use" or "low cost" items really,
but rather we know there are, for example, talking calculators that can
be purchased, but not everyone should need one, same for talking
thermometers, scales, and other items--hey I have a talking air pressure
tire gauge and a talking pedometer too!

I think we mean that when the industry has developed "good" reasonable
alternatives we should just provide those to people who need them as
opposed to making a big deal out of it. Or, let reasonable
accommodations have their role in some situations where that works best.
Getting that common sense in to anything precise enough to disallow
abuse is a real hurdled however.


I think we mean:

When accessible versions of items which have limited or narrowly defined
uses exist, and are relatively cost neutral to the overall purchase,
accessible substitutes can be provided for a limited set of the whole
set of purchases. (yeah plain as mud me thinks).

If we use something like this however, I'm afraid it will be applied in
a more broad sense than intended.

Another way to overcome this may be:

When accessible versions of items which have limited or narrowly defined
uses exist in the commercial marketplace, and are relatively cost
neutral to the overall purchase, accessible substitutes can be provided
for a limited set of the whole set of purchases. Such substitutes must
be purchased at the same time as the nonaccessible items, and made
available to a subset containing end-users with disabilities as needed.

Defining the "best value" or "most sensible" analysis for when to apply
this substitution concept is the hard thing to write.

Allen hoffman -- 202-447-0303

-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Gregg
Vanderheiden
Sent: Thursday, March 29, 2007 1:29 PM
To: 'TEITAC Subpart A Subcommittee'
Subject: Re:
[teitac-subparta]SubpartA-Draft-(g)Productswithnarrowdelineated use,Add
Personal Use to front

Hmmm.

All the examples are personal use items. I see what you are saying
though.

* Do you have examples of things that are not personal use that fit in
here?


* Also, what does "low cost" mean? That could be a good measure.
I'm
thinking that the kind of thing a manager can purchase easily would be
under
$500. What did you have in mind?


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



> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Diane
> Golden
> Sent: Thursday, March 29, 2007 10:17 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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