Thread Subject: Re: 1194.3 Exceptions
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From: David Poehlman
Date: Sat, Jun 16 2007 6:30 AM
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I've some comments below marked with dp.
(f) Products THAT ARE located in AND WHOSE OPERATIONS CAN ONLY BE EXECUTED
FROM spaces frequented only by service personnel for maintenance, repair, or
occasional monitoring of equipment are not required to comply with this
Rationale: Additional wording attempts to restrict this exception to
products that are not only located in service areas, but execution of the
product's function must also be available only from the "back office" area.
Some TEITAC members suggested the entire exception should be deleted.
dp: I agree with the deletion. We don't know that this might not have an
impact on hiring or on someone who is already employeed. This provision
says, "the disabled need not apply".
(g) (proposed new section)
SELF-CONTAINED, CLOSED PRODUCTS WITH NARROW, DELINEATED PERSONAL USE (SUCH
AS CALCULATORS, ELECTRONIC DICTIONARIES, AND AUDIO RECORDERS) FOR WHICH AN
AGENCY CAN DOCUMENT READILY AVAILABLE SPECIALIZED PRODUCTS IN THE COMMERCIAL
MARKETPLACE THAT COLLECTIVELY MEET THE FUNCTIONAL PERFORMANCE CRITERIA (E.G.
HAVE FEATURES SUCH AS SPEECH OUTPUT AVAILABLE ON ONE UNIT, LARGE VISUAL
DISPLAY AVAILABLE ON ANOTHER, LARGE KEYS/BUTTONS AVAILABLE ON ANOTHER, ETC.)
ARE NOT REQUIRED TO COMPLY WITH THIS PART AS A WHOLE. AGENCIES MUST HOWEVER
PROVIDE SPECIALIZED PRODUCTS WITH APPROPRIATE ACCESS FEATURES AS NECESSARY
TO MEET THE NEEDS OF END-USERS WITH DISABILITIES.
dp: This appears to be market restrictive. If I am blind and have motor
issues, under the current wording, I cannot necessarily get a personal item
to meet my needs. I could be rong and will gladly yeild my position if I
Rationale: To eliminate the application of all functional performance and
technical standards to these types of products which results in purchase of
one product with multiple unwanted and sometimes conflicting access
Some TEITAC members suggested this might be described as a "product line"
approach and could be expanded to clearly include this concept.
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