Thread Subject: Preamble reference where meeting technical provisions meets FPC
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From: Phill Jenkins
Date: Thu, Aug 16 2007 1:20 PM
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There was a request to post to the list the reference where in the
preamble (and FAQ, but not addressed here) there is discussion about where
software that complines with the technical provisions also satisfies the
FPC. See Paragraph A below.
Subpart C -- Functional Performance Criteria
Section 1194.31 Functional Performance Criteria
This section provides functional performance criteria for overall product
evaluation and for technologies or components for which there is no
specific requirement under other sections. These criteria are also
intended to ensure that the individual accessible components work together
to create an accessible product. This section requires that all product
functions, including operation and information retrieval, be operable
through at least one mode addressed in each of the following paragraphs.
Comment. The ITIC requested clarification as to how a manufacturer would
determine the type and number of assistive technology devices for which
support must be provided by a product.
Response. Manufacturers do not need to be aware of the universe of
assistive technology products on the market. Each provision specifies the
type of assistive technology that must be supported. For example,
Â§1194.31(a) addresses those assistive technology devices which provide
output to persons who cannot see the screen. Such devices may include
screen readers, Braille displays and speech synthesizers. There are
numerous resources available to manufacturers to assist them in
identifying specific types of assistive technology which would be used to
access their product.
Paragraph (a) provides that at least one mode of operation and information
retrieval that does not require user vision shall be provided, or support
for assistive technology used by people who are blind or visually impaired
shall be provided. It is not expected that every software program will be
self-voicing or have its own built-in screen reader. Software that
complies with Â§1194.21 would also satisfy this provision. (See Â§1194.27(a)
in the NPRM.) No substantive comments were received regarding this
provision and no changes were made in the final rule.
Paragraph (b) . . .
IBM Research - Human Ability & Accessibility Center
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