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

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: Diane Golden
Date: Fri, Jun 01 2007 3:05 PM

I think you are referring to the deletion of the "For example" sentence
because HVAC and medical equipment industry has not been engaged in the
discussion. If I remember correctly the original concern about the current
"for example" list is that it is very short and not terribly helpful in
identifying the range of products that have embedded IT but for which IT is
not the primary function. So the alternative to deleting the for example
list would be to expand it to be more representative.

However, given the recommendation to eliminate the exception for embedded
E&IT, expanding such a list would be applicable. See Jim Tobias's
suggestion for applying 508 to all E&IT, but limiting the application to
just the E&IT function when embedded in products with other functions.

The group appears to be at very divergent points on this one . . . maybe
another one for which we have separate recommendations.

Diane

-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ]On Behalf Of
= EMAIL ADDRESS REMOVED =
Sent: Friday, June 01, 2007 2:31 PM
To: 'TEITAC Subpart A Subcommittee'
Subject: Re: [teitac-subparta] Definition of Product and E&IT




The following should remain a part of the E&IT definition until adequate
feedback is solicited from the affected stakeholder groups:

[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.]

HVAC & medical device stakeholders are currently not represented on the
TEITAC. The committee lacks expertise in how accessibility standards should
be determined especially for the complex and broad category of medical
products. (See medical device definition by FDA at
http://www.fda.gov/cdrh/devadvice/312.html)

Without input from the federal and state governments, Department of Defense
hospitals, and industry with expertise in these areas who will be most
affected by this change- I'm concerned that the technical standards will not
be appropriately address these products, and will cause more frustration
than will be helpful in encouraging accessible design for HVAC and medical.

The currently proposed Subpart B revisions were not designed considering the
unique aspects of these products, in contrast to the many TEITAC experts
providing input on software, hardware, audio/video, etc.

We should seriously consider encouraging feedback on this part so we
understand the consequences of this change before moving forward.

Aubrey

Aubrey Woolley
Government Policy and Compliance Analyst
Government Marketing Division
Canon USA, Inc.
TEL: (703) 807-3158
= EMAIL ADDRESS REMOVED =



"Diane Golden" < = EMAIL ADDRESS REMOVED = >
Sent by: = EMAIL ADDRESS REMOVED =
05/30/2007 11:28 AM Please respond to
= EMAIL ADDRESS REMOVED = ; Please respond to
TEITAC Subpart A Subcommittee < = EMAIL ADDRESS REMOVED = >


To "'jagbell'" < = EMAIL ADDRESS REMOVED = >, "'TEITAC Subpart A Subcommittee'"
< = EMAIL ADDRESS REMOVED = >
cc
Subject Re: [teitac-subparta] Definition of Product and E&IT







The lists are already in the current definition. The subcommittee
recommended deleting the second list as noted in the proposed revision and
identified problems with keeping the other in, but did not reach consensus
about deleting or revising it.

-----Original Message-----
From: jagbell [mailto: = EMAIL ADDRESS REMOVED = ]
Sent: Wednesday, May 30, 2007 10:09 AM
To: = EMAIL ADDRESS REMOVED = ; TEITAC Subpart A Subcommittee
Subject: Re: [teitac-subparta] Definition of Product and E&IT


Product- I support adding services.
E&IT- I would recommend listing the list in alphabetical order so
that no item is given unnecessary weight b being listed first. Also,
why is it okay to list items here? :)

Janice

On May 30, 2007, at 10:58 AM, Diane Golden wrote:

> 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
>
>

WebAIM is an initiative of:
Center for Persons with Disabilities (CPD) Utah State University