Thread Subject: 1194.23(f) Gain Issues

From: Diane Golden
Date: Mon, Nov 06 2006 4:16 PM

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As a stimulus to discussion, I thought I'd share a couple of issues we have
run into during state procurements with the gain requirement of 508. Would
be very interested in thoughts/suggestions --

(508) 1194.23(f) For transmitted voice signals, telecommunications products
shall provide a gain adjustable up to a minimum of 20 dB. For incremental
volume control, at least one intermediate step of 12 dB of gain shall be
provided.

(255) 1193.43(e) Provide audio or acoustic information, including any
auditory feedback tones that are important for the use of the product,
through at least one mode in enhanced auditory fashion (i.e., increased
amplification, increased signal-to-noise ratio, or combination). For
transmitted voice signals, provide a gain adjustable up to a minimum of 20
dB. For incremental volume control, provide at least one intermediate step
of 12 dB of gain.

This requirement creates a problem for individuals who need more than 20 dB
of gain for access to voice signals (which is a large group of people with
hearing loss.) Unfortunately, adding on an in-line amplifier is not usually
an option with a product that has the built-in gain as there are protections
against piggy-backing gain to prevent over amplification and distortion. As
a result, individuals with moderate to severe hearing loss are forced to
used substitute amplified phones to get the gain needed. In the workplace
that means trying to match features of a separate amplified phone with the
features of everyone else's phones (not an ideal situation.) I'm not sure
if there is a solution -- but it would be nice if this requirement didn't
inadvertantly reduce access for individuals who need a greater gain level.
This may go back to the concept of product line (which is allowed in 255 but
not 508) where there are comparable products in a line with varying degrees
of gain included in a procurement.

There has also been some confusion as to whether or not the reference to
"transmitted voice signals" referrs only to receiving voice (hearing side)
or also to sending speech. I appears most folks have been interpreting the
language to mean receiving side only. This means individuals who need
speech amplification (outgoing) will also need to use a substitute speech
amplified phone. Was this the intent of the standard?

Diane Cordry Golden, Ph.D.
National Association of State Chief Information Officers (NASCIO)

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