Thread Subject: Additional issues with closed,self-contained products

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: Mon, Oct 30 2006 4:15 PM

Some additional thoughts/issues from the application side on closed,
self-contained products.

The current closed, self-contained product standards (b) through (j) provide
a pretty minimal level of built-in access features through those technical
requirements. But then (a) trumps everything by requiring the product "be
usable by people with disabilities without requiring an end-user to attach
AT to the product." Literally applied, that means each and every closed,
self-contained product should have a wide range of built-in access features
to meet the functional limitations of a variety of disabilities. As a
result, procurement folks should be rating higher (and agencies should be
buying) products with the most built-in access features.

Unfortunately, building in a whole bunch of access features in low-end
products can actually result in an individual with a disablity getting a
product they cannot use. The classic example is a calculator which is
identified as a self-contained closed product. Accessibility features on a
calculator might include enlarged keys, large print key markings, a big
screen display and speech output. However, a product with ALL those
features might NOT meet the needs of blind person for whom the enlarged keys
make touch key entry nearly impossible. The 508 rules as currently written
do not allow for access features to be considered as part of a "product
line" as does 255. So the fact that one can purchase different basic
calculators with different access features is not figured into the 508
standards application nor is the fact that lots of built-in access features
can actually "trip over" one another if they are not software features that
can be toggled on and off. With closed, self-contained products (and
actually some telecom products) this creates access problems rather than
solves them.

Also in application there seems to be a major distinction between closed,
self-contained products that are used within a work setting (printer, fax,
copier, DVD player, etc.) versus products that are exclusively designed to
be used by the mass public (kiosk, ATM, voting machine.) With the first,
not only do you have the option of purchasing items from a line of products
to meet different access need, but for many of these functions you also have
other alternatives e.g. a combined printer/copier that can be operated via
individual computer station. With public use products, you have few options
other than the product (as it stands) delivering all the accessibility
needed (you might be able to attach headsets or a switch, but use of
personal AT overall is very limited.)

Are these fundementally two different types of closed products? What does
that mean for standards needed? Should the concept of product line be
utilized? Does this second group of products require more rigerous
standards than the current self-contained, closed standards to deliver
access? Should those standards be roughly comparable to the Voluntary
Voting System Guidelines adopted by the Election Assistance Commission?

Diane

Diane Cordry Golden, Ph.D., Director
Missouri Assistive Technology
816/350-5280 (direct voice)
= EMAIL ADDRESS REMOVED =
www.at.mo.gov

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