Thread Subject: Re: 1194.3 Exceptions
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From: Michele Budris
Date: Wed, Jun 20 2007 8:50 AM
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Responding to David Poehlman, I have to disagree. There are clear
cases where this is needed.
Example, we have extremely large media backup units. The smallest
system breaks into 3 pieces sized to fit a freight elevator. They
are designed to have robots inside moving media around inside. There
is just no way to make the unit accessible. BUT a person running the
system can do so remotely. Are you telling me I must make the entire
machine accessible? That defeats the entire purpose of the system. I
want to make it usable by people with disabilities, and that is done
by making the user interface accessible from a remote location. A
person with disabilities can add media via the shuttle door that is
accessible. But there is physically no way I can make the entire unit
accessible. The goal of the product is to be as much media storage as
possible in the system. Think entire Library of Congress within one
of these systems.
The exemption allows me to meet business needs of my customers, but
also requires I make use of the system accessible. I think that is a
good requirement. I don't see this exception as a way to make the
entire product not accessible.
Michele Budris
Sun Microsystems, Inc.
On Jun 16, 2007, at 6:26 AM, David Poehlman wrote:
> 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
> part.
>
> 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".
>
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