Thread Subject: Re: Requirements for telephone amplification
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From: Diane Golden
Date: Mon, Nov 06 2006 4:19 PM
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I couldn't agree more that this issue needs to be clarified once and for
all. As I said on the call, we asked this very question early on in direct
reference not only to the telecom standards but also the closed
self-contained product standards and the answer from the Access Board was
unequivocal -- the 508 standards apply to ALL products purchased by the
federal government. It is our understanding that the 508 standards do not
allow for consideration of "line of products" (a line of phones with varying
degrees of gain and/or other access features provided so one could pick and
choose) or substitution of products or parts of products to meet a standard.
Clearly there are standards that ensure compatibility with add-on AT (as
many of the software and web standards do), but other standards directly
require an access feature be provided regardless of ability to add-on or
substitute something to deliver that feature. We've always understood the
exception language to be an effort to clarify that the AT compatibility
standards do not require AT to be installed with every product.
So that begs the question about the intent of the gain standard. It is not
written like a compatibility standard (e.g. the product shall have a
standard connection point that allows for . . . ). It reads as if the gain
is a required feature of all products purchased. There is a somewhat
similar standard under closed, self-contained products 1194.25 for voice
output in a public area which also requires gain of at least 20 dB over
ambient noise levels. It would seem in the case of products used in a
public area, the gain would have to be built into the product without any
kind of substitute handset/head set used. Hopefully, someone from Access
Board can clarify this for us all!
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ]On Behalf Of Michaelis,
Paul R (Paul)
Sent: Monday, November 06, 2006 2:57 PM
To: = EMAIL ADDRESS REMOVED =
Subject: [teitac-telecom] Requirements for telephone amplification
During the recently concluded telecom conference call, we discussed the
requirement in 1194.23(f) that phones be able to provide 20+ dB of
amplification. For most wired phones, this degree of amplification is
achievable without distortion only when the standard handset is replaced
with a handset that contains a special-purpose amplifier and
special-purpose transducer. A question that we were unable to resolve
is whether ALL phones procured by the government must satisfy the
amplification requirement, or whether it's acceptable to provide
special-purpose handsets only to the individuals who require that degree
I'm not a lawyer, but my impression is that the latter point of view is
supported by the General Exceptions: "(C) Except as required to comply
with the provisions in these standards, section 508 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." It is
also the case that I have NEVER had a contract officer request that all
phones be supplied with amplified handsets.
On the other hand, I'm very uncomfortable with the idea that someone
with hearing loss would be restricted to specially equipped phones. I
think that this would be contrary to what we were hoping to achieve with
Prior to our discussing whether the 20 dB value in 1194.23(f) should be
raised, I'd like clarification about whether ALL phones will be required
-- Paul Michaelis
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