Thread Subject: Re: AT and IT interoperability - the regime we are operating under today

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From: Randy Marsden
Date: Fri, Oct 26 2007 2:55 PM

The problem is the statement issued by the Access Board is
ambiguous. The single sentence quoted by Peter appears to suggest
that an IT manufacturer doesn't need to be aware of the "AT
universe". However, if you read the entire paragraph, the last
sentence seems to suggest the opposite: that "there are numerous
resources available to manufacturers to assist them in identifying
specific types of assistive technology which would be used with their
product". Clearly, that sentence indicates some level of
responsibility for the manufacturer to get educated about what AT
exists for their product(s). So, I don't agree with Peter that it is
clear what is meant - especially when considering the entire directive.

Bruce - I feel the directive issued by the Access Board contains
statements that can be viewed as conflicting, and is part of what has
led to the lack of consensus on this point.

Randy Marsden
ATIA



On Oct 26, 2007, at 1:56 PM, Peter Korn wrote:

> Hi Bruce,
>
> Thank you very much for this clarification. From this, it seems clear
> that the regime we are operating under today (as set by the Access
> Board
> in the quote Bruce provided to us) is that E&IT manufacturers are not
> expected to "be aware of the universe of AT", and that by
> supporting the
> specific provisions in 1194.21 relating to any given AT, E&IT vendors
> are understood to be satisfying the functional performance criteria.
>
> Therefore, any and all work we do - in specifying the rich set of
> information E&IT must provide to AT as we have done in 3-U, and in
> setting forth platform requirements as we have done in 3-V and
> elsewhere
> - is an improvement over the current regime and in no way a step
> backward from what the Access Board expected would be the case.
>
>
> Certainly this still leaves open the question of whether our drafts
> "go
> far enough"; but I believe it closes the question of whether our
> drafts
> "go backward" in any way. They do not.
>
>
> Regards,
>
> Peter Korn
> Accessibility Architect,
> Sun Microsystems, Inc.
>
>> Responding to Peter's question posted to list:
>> http://teitac.org/mailarchives/mail_message.php?id=7381&listid=1
>>
>> The Access Board is eager for TEITAC to advise on this concern.
>> If there is not a single consensus position, multiple
>> recommendations are welcomed. The Access Board has already
>> addressed this issue as best we can in the preamble to the 508
>> rulemaking:
>>
>> <begin quote>
>>
>> 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, §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
>> §1194.21 would also satisfy this provision. (See §1194.27(a) in
>> the NPRM.) No substantive comments were received regarding this
>> provision and no changes were made in the final rule.
>>
>> <end quote>
>>
>> http://www.access-board.gov/sec508/preamble.htm
>>

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