Thread Subject: Re: Volume gain standard

Note

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From: Tom Brett
Date: Mon, Sep 10 2007 5:05 AM

Paul indicates that he has not seen more than a handful of 508 compliant
configurations purchased.




I think the government purchasers are correct in buying only configurations
that are needed. I do not think 508 or any other law can force the
government to buy items or configurations that are not needed.



<http://teitac.org/wiki/EWG:Draft_Sept_14#1194.3_-_C_-_Employees_Not_Individ
uals_With_Disabilities>
http://teitac.org/wiki/EWG:Draft_Sept_14#1194.3_-_C_-_Employees_Not_Individu
als_With_Disabilities says:


1194.3 - C - Employees Not Individuals With Disabilities


Except as required to comply with the provisions in this part, this part
does not require the installation of specific accessibility-related software
or the attachment of an assistive technology device at a workstation of a
Federal employee who is not an individual with a disability.

* Status: Done
* Text from Subpart A Subcommittee
* Source: {508}1194.3(c), no change

For clarification I think that this exception should be changed to read:

Except as required to comply with the provisions in this part, this part
does not require the installation of specific accessibility-related
software, hardware, configurations, or the attachment of an assistive
technology device at a workstation of a Federal employee who is not an
individual with a disability.











Tom Brett



_____

From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Michaelis, Paul
R. (Paul)
Sent: Sunday, September 09, 2007 2:06 PM
To: TEITAC Committee
Cc: = EMAIL ADDRESS REMOVED =
Subject: Re: [teitac-telecom] [teitac-committee] Volume gain standard



A few quick personal comments about the volume gain requirement (not
necessarily reflecting my company's official position):



On every bid and proposal I have supported, my company provides pricing for
our standard desktop telephones and for the same telephones equipped with
specialized handsets that provide the user-adjustable amplification required
by Section 508. If I recall correctly, the price difference is
approximately fifty dollars per phone. I have never seen any customer,
including our government customers, purchase more than a handful of the
508-compliant configurations. The feedback I have received is that these
configurations are purchased only for employees who are known to be
hard-of-hearing.



A comparatively small percentage of my company's revenue is from sales to
government agencies. This means that, even if there is a change in the
government's procurement policies, such that all phones must conform to the
amplification requirement, the vast majority of our sales will continue to
be to customers who don't want to spend extra money for extra amplification.




It has been suggested that the new Section 508 rules should require 20 dB of
available amplification to be a built-in feature of the phones, as opposed
to being achievable by swapping the standard handset for a handset that
includes an auxiliary amplifier. If this requirement were adopted, the
telecom industry could wind up having to build two different versions of
every phone: (1) a standard version that satisfies what the vast majority of
our customers tell us they want, and (2) a specialized version that
satisfies the requirements of a customer that, quite frankly, has a poor
record of buying and using what they require the telecom industry to build.




Please be aware that I am fully in favor of providing the additional
amplification that is required by people who are hard-of-hearing, and that I
would love to see all endpoints have this capability. Configurations that
satisfy this need are available. The fundamental problem is that they are
not being purchased. This problem is not going to be solved by requiring
the telecom industry to implement a different configuration that is equally
unlikely to be purchased.



-- Paul Michaelis






_____

From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Diane Golden
Sent: Saturday, September 08, 2007 6:54 PM
To: TEITAC Committee
Subject: Re: [teitac-committee] Volume gain standard

Two issues remain for me --



1) This still leave unclear if the 20 dB gain must be built-in to every
item or if it can be added on via a swapped out handset that has the gain.
It sort of sounds like the swapped out handset or even an add-on in-line
amplifier would work given the statement about swapping out headsets.



2) The exclusion of headsets is still confusing to me. An awful lot of
people with mild-moderate hearing loss who could get by with 20 dB of gain
are not going to be wearing hearing aids. Even if they are wearing hearing
aids, many will use an open fitting which means the headset or handset works
just fine over the hearing aid. If the phone has a "tone" adjustment, I
would say there are at least as many hard of hearing folks who would use the
amplification of the phone over their hearing aids if the 20 dB gain is
enough.



Diane

----- Original Message ----
From: Gregg Vanderheiden < = EMAIL ADDRESS REMOVED = >
To: TEITAC Committee < = EMAIL ADDRESS REMOVED = >
Sent: Friday, September 7, 2007 11:33:24 PM
Subject: Re: [teitac-committee] Volume gain standard

Close.

It would read something like

Products designed to be held up to the ear during use and that provide a
function allowing voice communication must provide a gain adjustable from
the normal unamplified level to at least 20 dB above the normal unamplified
level as measured in accordance with the provisions of the FCC regulation
68.317 for volume control. The volume at the normal unamplified level
setting must also meet the requirement in FCC regulation 68.317. (This does
not apply to headphones or headsets where a standard audio connection is
available per AUDIO CONNECTOR PROVISION)



Rationale:
Earbuds etc don't work with hearing aids and in fact go into the ear where
the hearing aid already is. As long as there is an Audio Connection point,
people who use neckloops, or other connections to their hearing aids can
connect or plug in a headset that will meet their needs. Requiring all
headphones and headsets to conform is not necessary since people who need
special ones can obtain them. For volume, there is another problem. Unless
you control the headset AND the device, you cannot determine what the output
of the headset will be due to the fact that they have different
efficiencies. The exception is not for the phone itself but for headsets
and headphones that would be plugged into the phone.




Does this handle the issues?




Gregg
-- ------------------------------
Gregg C Vanderheiden Ph.D.



> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf
> Of Diane Golden
> Sent: Friday, September 07, 2007 11:50 AM
> To: 'TEITAC Committee'
> Subject: [teitac-committee] Volume gain standard
>
> If I understand the discussion correctly, the revised version
> of the volume gain standard would read something like --
>
> "E&IT that provide a function allowing voice communication
> designed to be held up to the ear during use (detachable
> headsets and headphones not
> included) must provide a [built-in? or add-on/substitutable
> component delivered?] gain adjustable from the normal
> unamplified level to at least 20 dB above the normal
> unamplified level as measured in accordance with the
> provisions of the FCC regulation 68.317 for volume control.
> The volume at the normal unamplified level setting must also
> meet the requirement in FCC regulation 68.317."
>
> While I undersand and support the intent of excluding voice
> communication products that do not have control over the end
> receiver unit -- there are many traditional telephone
> products that use headsets and alternatives to handsets as a
> core feature and might be seen as excluded with this language.
> Separately, there still needs to be a decision made regarding
> whether or not the volume gain must be built-in to every
> phone purchased -- rather than being delivered via a
> substituted "special" handset and/or some other form of
> add-on amplifier that is available but not included in every
> phone purchased (see ? language in brackets).
>
> Diane Golden
> NASCIO
>
>

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