Thread Subject: Re: Re;Productswithnarrowdelineated use -- Thermometers
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From: Jim Tobias
Date: Sun, Apr 01 2007 7:20 AM
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Thanks, David, for this reminder and clarification -- TEITAC can re-define
EIT as long as it remains generally consistent with Clinger-Cohen.
It seems to me that one of the biggest changes in technology since
Clinger-Cohen has been the degree to which ICT components and techniques
have entered into products used for "non-EIT" purposes. (I'm using "ICT"
here to refer to the technology, and "EIT" to refer to the regulatory
category of what ICT is covered by 508.) For example, instead of
electromechanical thermostats, we have fully electronic ones that
use microprocessors and LCDs.
The dialogue we've been having is tied up in three issues:
1. The main area of expansion in the definition that I'm hearing has
to do with things like thermostats and glucometers: ICT not used for
currently-defined EIT purposes. We might choose to re-define EIT to
include all ICT products pertinent to the federal workplace in which
they are used, and to which federal employees are permitted access. By
this definition a thermostat that a non-disabled employee would be
allowed to set, should be accessible to disabled federal employees. This
definition would now apply 508 to the workplace as a whole, rather than
just to the EIT functions of the job. It would also rule out glucometers,
as personal medical devices unrelated to the federal workplace.
2. Because the "non-EIT" products use more or less standard ICT
components and techniques, some may assume that they can be
made more accessible easily. This may not be the case, as the
design is still "closed" and strictly limited to one function. (That's
why I am cc'ing this to the Closed subcommittee.)
3. On the other hand, if the product *does* use a platform or technology
that *is* capable of improved accessibility, then we may be free to
require it to meet the relevant provisions. For example, if an agency's
HVAC system will be controlled by computer, we may require that the computer
software used for monitoring it be accessible so that federal employees
with disabilities be able to control their local settings just as
employees can. (Note that 508 already would require that the overall
HVAC software be accessible, so that persons with disabilities could perform
HVAC administrative duties as part of their jobs.)
> -----Original Message-----
> From: Capozzi David [mailto: = EMAIL ADDRESS REMOVED = ]
> Sent: Sunday, April 01, 2007 12:18 AM
> To: Deborah Buck; Baquis David ; Creagan Tim; Mike Paciello;
> Jim Tobias
> Cc: Laura Ruby
> Subject: RE: [teitac-subparta] Re;
> Productswithnarrowdelineated use -- Thermometers
> The definition of E&IT is certainly within "our" authority to address.
> The law states that the Board "shall issue and publish
> standards setting forth ... a definition of electronic and
> information technology that is consistent with the definition
> of information technology specified in section 5002(3) of the
> Clinger-Cohen Act of 1996 (40 U.S.C. 1401(3))."
> So, to the extent that you want to recommend changes to the
> definition, we need to remain "consistent" with
> Clinger-Cohen. Consistent does not mean identical it just
> means not inconsistent.
> One of the slides I showed on the first day of the first
> meeting of the advisory committee said "Issues within our authority:
> Definition of electronic and information technology Technical
> and functional performance criteria Accessibility of
> telecommunications equipment and customer premises equipment"
> So changing the definition is not out-of-bounds. Whether you
> all want to do that is entirely your decision.
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