Thread Subject: Re: 1194.3 Exceptions

Note

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From: Peter Korn
Date: Mon, Jun 25 2007 9:45 PM

Hi Tom,

I don't understand how we would apply the "standard ports" provisions to
devices like these. Servers such as the one Michele cites are intended
to operate 95%+ (99.999%?) of the time with nobody touching them
directly - only interacting with them remotely via software running on
their local computer. It doesn't make sense to connect a Braille display
or a switch or a head tracker to one of these servers. Rather, it makes
sense to connect those AT devices to the workstation that is running the
remote software that is controlling the server.

We aren't suggesting that the remote software not be accessible (it
should meet all of the 508 software criteria), nor are we suggesting
that this software not run on an accessible workstation (the workstation
should meet all of the 508 OS and hardware criteria).


Let me provide another example: Sun's Project Blackbox
(http://www.sun.com/emrkt/blackbox/index.jsp) which is a complete,
self-contained datacenter built into a standard sized shipping
container. The business requirements of this device include:
1. that it is an actual, standard shipping container - so it can be
shipped on ships, trucks, rail, etc.
2. that it can be placed outside of buildings - on roofs, in parking
lots, etc.
3. that it can be packed VERY densely with equipment. In fact, the key
value proposition is the sheer amount of servers that get packed (and
powered, and cooled) inside the container
4. that it be completely remotely operable - what is termed "LOM" or
"Lights Out Management"; only in the most rare circumstances should it
ever be necessary to have someone go into one of these server containers
for service/maintenance

There are only three "ports" on one of these storage container/data
centers: power, water (for cooling), and network. Connecting a Braille
display directly to the container exterior makes no sense (nor any other
AT device). Likewise, we can't fit a wheelchair inside and still meet
the density needs of customers who would consider purchasing one of
these (see a photo of how narrow the service space is at:
http://www.sun.com/emrkt/blackbox/gallery.xml?t=2&p=&s=)


Regards,

Peter Korn
Accessibility Architect,
Sun Microsystems, Inc.

> Ok…the only concern I would have it that agencies not purchase servers
> without the required ports/connections by using the Maintenance only
> Interface Exception (back office).
>
> Tom Brett
>
> ------------------------------------------------------------------------
>
> *From:* = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] *On Behalf Of
> * = EMAIL ADDRESS REMOVED =
> *Sent:* Wednesday, June 20, 2007 11:25 AM
> *To:* TEITAC Subpart A Subcommittee
> *Cc:* 'TEITAC Subpart A Subcommittee';
> = EMAIL ADDRESS REMOVED =
> *Subject:* Re: [teitac-subparta] 1194.3 Exceptions
>
>
> If I understand Michele's example properly, then the AT needed to
> support a user is connected to the workstation and operates remotely.
> The inner workings of the storage device are a good example of
> hardware operating in a location that is frequented by service
> personnel on an occasional basis - normal use is either remotely
> operated through a workstation or loading media through a physical
> door. We could refer to that as a back office exemption or use
> commercial unavailability - which could net the same result.
>
>
>
> *"Tom Brett" < = EMAIL ADDRESS REMOVED = >*
> Sent by: = EMAIL ADDRESS REMOVED =
>
> 06/20/2007 10:52 AM
>
> Please respond to
> "TEITAC Subpart A Subcommittee" < = EMAIL ADDRESS REMOVED = >
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> To
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> "'TEITAC Subpart A Subcommittee'" < = EMAIL ADDRESS REMOVED = >
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> Subject
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> Re: [teitac-subparta] 1194.3 Exceptions
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> Very good point.
>
> But what happens if there are no ports that would allow me to connect
> my AT?
> Clearly back office mean that the hardware is required to be in an
> area that
> is frequented by service personnel on an occasional basis.
> Tom Brett
>
>
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Michele
> Budris
> Sent: Wednesday, June 20, 2007 10:46 AM
> To: TEITAC Subpart A Subcommittee
> Subject: Re: [teitac-subparta] 1194.3 Exceptions
>
> 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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