Thread Subject: Re: Definition of Product and E&IT

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From: Diane Golden
Date: Thu, May 31 2007 1:15 PM

If I remember the original discussion of the E&IT definition, the desire WAS
to exclude the technical and functional performance standards being applied
to the embedded IT functions of products such as HVAC, medical equipment,
etc. So going with an approach that applies the standards to all E&IT
functions (albeit just those functions) regardless of overall function of
the product will be broadening the application even more than changing "the"
to "a" or "one of the" principle functions. I'm not supportive or opposed
necessarily - just want to make sure the impact is clear.

Diane

-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ]On Behalf Of Jim Tobias
Sent: Thursday, May 31, 2007 1:49 PM
To: 'TEITAC Subpart A Subcommittee'
Subject: Re: [teitac-subparta] Definition of Product and E&IT


I agree with the general point here about "the" and "a" principal
function of the product as E&IT. Perhaps we can do a better job, guided
by the dialogue that occured over Sec. 255 on this same topic. There,
we were concerned with products that had telecom and non-telecom
functions. For example, a desktop phone with a built-in clock. We
agreed to apply 255 to the phone function, but not the clock function.

Here we can apply 508 to any product that has an E&IT function, and only to
the characteristics and features that are required for or directly support
that function.

Can we agree on this concept? If so we can draft the definition's exception
so that non-E&IT
functions are excluded.


***
Jim Tobias
Inclusive Technologies
+1.732.441.0831 v/tty
+1.908.907.2387 mobile
skype jimtobias


> -----Original Message-----
> From: Gregg Vanderheiden [mailto: = EMAIL ADDRESS REMOVED = ]
> Sent: Thursday, May 31, 2007 1:21 PM
> To: = EMAIL ADDRESS REMOVED = ; 'TEITAC Subpart A Subcommittee'
> Subject: Re: [teitac-subparta] Definition of Product and E&IT
>
> Yes - I noticed that the word "THE" was there before.
>
> One thing that has changed since the guidelines were last
> written was that back then products tended to be single
> function. So "THE" made sense then.
>
> Today we are re-organizing the whole guidelines to address
> this change.
> The change of "THE" to "A" is just another change we need to
> make to deal
> with the fact that products now do many function. A PDA-PHONE and a
> SMART-PHONE shouldn't have different rules because one is a
> phone first and
> the other is a PDA first. In this case - if something was
> a refrigerator
> that has a complete web interface on its door that fulfills
> all of the functions of a lab computer it should not be
> exempt because its primary function was a refrigerator -
> while the same lab computer as a stand alone system on the
> bench would have to conform.
>
> Hence it should be "a principal" function.
>
>
> Gregg
> -- ------------------------------
> Gregg C Vanderheiden Ph.D.
>
>
>
> > -----Original Message-----
> > From: = EMAIL ADDRESS REMOVED =
> > [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Diane
> > Golden
> > Sent: Thursday, May 31, 2007 11:44 AM
> > To: TEITAC SubPart A listserv (E-mail)
> > Subject: Re: [teitac-subparta] Definition of Product and E&IT
> >
> > Just to clarify a couple of points.
> >
> > The question on the table about "product" is whether to
> keep that as
> > the term used for shorthand of E&IT or does that word
> convey something
> > too narrow (focus on devices and not services or non-traditional
> > E&IT.) Is there a better term than "product" to use?
> >
> > The current definition of E&IT uses the words "the
> principle function"
> > is not IT in which the word "the" does convey a singular principle
> > function.
> > So changing to "a principle function" or "one of the principle
> > functions"
> > would be a substanative change in scope of application.
> >
> > Diane
> >
> > -----Original Message-----
> > From: Gregg Vanderheiden [mailto: = EMAIL ADDRESS REMOVED = ]
> > Sent: Thursday, May 31, 2007 9:45 AM
> > To: = EMAIL ADDRESS REMOVED = ; 'TEITAC Subpart A Subcommittee'
> > Subject: RE: [teitac-subparta] Definition of Product and E&IT
> >
> >
> > I would suggest that definition of product be left as is.
> >
> >
> > RE the edit to E&IT - t
> > We still have more work to do on this. the phrase "not
> the principle
> > function" is tricky and often mis interpreted. The
> examples helped to
> > clarify but with their removal it can lead to multifunction
> products
> > not being covered even if IT is a major function of the product
> > because it was not THE PRINCIPLE function.
> >
> > Maybe if we change "THE principal" to "A principal"
> > function of the
> > product.
> >
> > That would still eliminate all the simple thermostats and hvac but
> > would not eliminate products that (for example) measured
> but then also
> > acquired, stored, processed, manipulated and displayed data as well.
> >
> >
> >
> >
> > Gregg
> > -- ------------------------------
> > Gregg C Vanderheiden Ph.D.
> >
> > > -----Original Message-----
> > > From: = EMAIL ADDRESS REMOVED =
> > [mailto:teitac-subparta-
> > > = EMAIL ADDRESS REMOVED = ] On Behalf Of Diane Golden
> > > Sent: Wednesday, May 30, 2007 9:59 AM
> > > To: TEITAC SubPart A listserv (E-mail)
> > > Subject: [teitac-subparta] Definition of Product and E&IT
> > >
> > > PRODUCT
> > > Currently the term "Product" is defined as "Electronic and
> > information
> > > technology." The subcommittee had discussed adding the word
> > > "services" to "product" in a number of sections (e.g.
> > Application) but
> > > it appears with the definition of "product" pointed to the E&IT
> > > defintion that would already include the whole of what is covered
> > > given E&IT defines that universe. A suggestion was made
> > that the term
> > > product could be changed if it inherently communicates
> > something too
> > > narrow - perhaps to "system" as that is the substitution the
> > > subcommittee made in the E&IT defintion (see below) or some other
> > > term. Is the preference to change and if so to what -- or
> > stay with
> > > product? (You could delete the term altogether, but then all the
> > > rules would need to use "electronic and information
> > technology", all
> > > three words, in place of "product" throughout all of the
> > rules, which
> > > is just more lengthy but is an option.)
> > >
> > > ELECTRONIC AND INFORMATION TECHNOLOGY The current
> proposed revision
> > > as presented at TEITAC is as follows (new language in CAPS and
> > > deleted language in [brackets]:
> > > "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 SYSTEMS [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 IN WHICH INFORMATION TECHNOLOGY IS NOT THE principal
> > > function of that product. [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.]
> > >
> > > The recommended revisions in sentences two and three are
> primarliy
> > > editorial and are designed to align with suggested change
> in use of
> > > "product"
> > > terminology and to use the term "information technology" to
> > cover the
> > > list in the third sentence without having to repeat all
> those words
> > > from the IT defintion in the E&IT definition. The
> deletion of the
> > > fourth sentence was suggested because the "for example" list of
> > > embedded IT seemed to cause as much confusion as provide helpful
> > > guidance. There were no specific suggestions for this
> > definition at
> > > the plenary meeting but there was some general feeling that
> > the issue
> > > of embedded IT was still confusing especially for
> > procurement folks at
> > > an application level.
> > >
> > > Diane Golden
> > > NASCIO
> > >
> > >

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