Thread Subject: Contribution to the GeneralInterfaceAccessibilitySubcommittee

Note

This archival content is maintained by WebAIM and NCDAE on behalf of TEITAC and the U.S. Access Board . Additional details on the updates to section 508 and section 255 can be found at the Access Board web site.

From: Gregg Vanderheiden
Date: Sun, Oct 22 2006 9:55 PM

Jim posed two questions at the end of his last email.



1. Was the Section 255 approach considered for 508, and if it was, why was

it rejected?



It was considered. And if you look at the EITAAC report it is much more in
keeping with 255 than the final rule was. It wasn?t followed exactly
because it had to cover a broader range of technologies. But the committee
did recommend something close to 255. The Access Board changed the
recommendation quite a bit. For one ? they made it technology based rather
than function based. The AB did note this and asked for suggested
reorganizations. At least one that recommended returning to ?function?
approach was filed by Trace and it looks like another was filed by Randy
Dipner if I understood his comments correctly.



Pasted below (and also attached) are the table of contents from the EITAAC
report and a summary of the 255 regs. As can be seen they were closely
related.



It can also be seen that the last committee recommended a functional
approach.











2. The limited functional component approach in the 508 NPRM did not survive
the rulemaking. Why not?



Don't know. Have to ask Access-board or someone else on the inside. The
deliberations were closed.









Gregg

-- ------------------------------

Gregg C Vanderheiden Ph.D.







FROM EITAAC RECOMMENDATIONS



5.2 Generic Standards for Accessibility. 17

5.2.1 Accessibility of operation and Information. 17

5.2.1.1. Usable without vision. 17

5.2.1.2. Usable with low vision without relying on audio. 17

5.2.1.3. Usable with little or no color perception. 17

5.2.1.4. Usable without hearing. 18

5.2.1.5. Usable with limited hearing. 18

5.2.1.6. Usable with limited manual dexterity, reach and / or strength. 18

5.2.1.7. Usable without time-dependent controls or displays. 18

5.2.1.8. Usable without speech. 18

5.2.1.9. Usable with limited cognitive or memory abilities. 18

5.2.1.10. Usable with language or learning disabilities. 18

5.2.1.11. Availability of audio cutoff. 18

5.2.1.12. Prevention of visually-induced seizures. 19

5.2.1.13. Biometric identification / activation bypassing. 19

5.2.1.14. Usable with upper extremity prosthetics. 19

5.2.1.15. Hearing aid compatibility. 19

5.2.1.16 Usable from a wheelchair or similar mobility device. 19

5.2.2 Compatibility With Devices used for Access 19

5.2.2.1. Information Pass Through. 19

5.2.2.2. External electronic access to all information and control
mechanisms. 19

5.2.2.3. Connection point for external audio processing devices. 20

5.2.3. Information, Documentation, Labeling & Support 20

5.3. Technology specific Standards. 20

5.3.1. If the E&IT has a physical keyboard... 20

5.3.2. If the E&IT is software in nature and runs on a platform that has an
operating system. 21

5.3.3. If the E&IT utilizes Web based information or applications... 21

5.3.4. If the E&IT provides Telecommunications functions... 22

5.3.5. If the E&IT utilizes Video or Multimedia... 22

5.3.6. If the E&IT is an Information Transaction Machine (ITM)... 23

5.3.7. If the E&IT is a PDA. 23

5.3.8. If the E&IT provides an interface over a network. 23

5.3.9. If the E&IT has cabling and /or other connections... 23

5.3.10. If the E&IT is used to produce information... 24








>From Telecom access Guidelines




1193.41 Input, control, and mechanical functions.

Input, control, and mechanical functions shall be locatable, identifiable,
and operable in accordance with each of the following, assessed
independently:

(a) Operable without vision.

(b) Operable with low vision and limited or no hearing.

(c) Operable with little or no color perception.

(d) Operable without hearing.

(e) Operable with limited manual dexterity.

(f) Operable with limited reach and strength.

(g) Operable without time-dependent controls.

(h) Operable without speech.

(i) Operable with limited cognitive skills..



§ 1193.43 Output, display, and control functions.

All information necessary to operate and use the product, including but not
limited to, text, static or dynamic images, icons, labels, sounds, or
incidental operating cues, shall comply with each of the following, assessed
independently:

(a) Availability of visual information.

(b) Availability of visual information for low vision users..

(c) Access to moving text.

(d) Availability of auditory information..

(e) Availability of auditory information for people who are hard of hearing.

(f) Prevention of visually-induced seizures..

(g) Availability of audio cutoff..

(h) Non-interference with hearing technologies.

(i) Hearing aid coupling.




§ 1193.51 Compatibility.


(a) External electronic access to all information and control mechanisms.

(b) Connection point for external audio processing devices.

(c) Compatibility of controls with prosthetics.

(d) TTY connectability.

(e) TTY signal compatibility.




§ 1193.37 Information pass through.


Telecommunications equipment and customer premises equipment shall pass
through cross-manufacturer, non-proprietary, industry-standard codes,
translation protocols, formats or other information necessary to provide
telecommunications in an accessible format.




§ 1193.39 Prohibited reduction of accessibility, usability, and
compatibility.


(a) No change shall be undertaken which decreases or has the effect of
decreasing the net accessibility, usability, or compatibility of
telecommunications equipment or customer premises equipment.

(b) Exception: Discontinuation of a product shall not be prohibited.




§ 1193.33 Information, documentation, and training.


(a) Manufacturers shall ensure access to information and documentation it
provides to its customers. ?? including:

(1) Providing a description of the accessibility and compatibility features
of the product upon request, including, as needed, in alternate formats or
alternate modes at no additional charge;

(2) Providing end-user product documentation in alternate formats or
alternate modes upon request at no additional charge; and

(3) Ensuring usable customer support and technical support in the call
centers and service centers which support their products at no additional
charge.

(b) Manufacturers shall include in general product information the contact
method for obtaining the information required by paragraph (a) of this
section.

(c) Where manufacturers provide employee training, they shall ensure it is
appropriate to an employee's function. In developing, or incorporating
existing training programs, consideration shall be given to the following
factors:

(1) Accessibility requirements of individuals with disabilities;

(2) Means of communicating with individuals with disabilities;

(3) Commonly used adaptive technology used with the manufacturer's products;

(4) Designing for accessibility; and

(5) Solutions for accessibility and compatibility.

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