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

Note

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From: Gregg Vanderheiden
Date: Fri, Jun 01 2007 12:35 AM

Hmmm

Interesting approach. This sounds like the right way to do this. That way
E&IT is covered even if compound in a device - but the non-E&IT
functionality doesn't inherit the regs when they otherwise would not have.


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



> -----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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