Thread Subject: Re: Requirements for telephone amplification
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From: Karen Peltz Strauss
Date: Mon, Nov 06 2006 5:35 PM
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Ellen and I have been conferring and after going back a bit, we found that
actually the FCC's Section 255 guidelines do not say anything about db gain.
What happened was that the TAAC had proposed using a 12 to 20 db gain, which
was then adopted by the Access Board in its 255 guidelines. But because
rules produced as a result of the FCC's HAC negotiated rulemaking committee
(a committee formed to finalize hearing aid compatibility rules for wireline
phones) required only 18 db gain (in part 68), the FCC decided to reject
this particular Access Board guideline. Although the FCC's 255 rules are
silent on the issue, it was the agency's intent to use the 18 db standard
when it rejected the Access Board's guideline of 12-20 db gain.
----- Original Message -----
From: "Baquis David " < = EMAIL ADDRESS REMOVED = >
To: < = EMAIL ADDRESS REMOVED = >
Sent: Monday, November 06, 2006 7:20 PM
Subject: Re: [teitac-telecom] Requirements for telephone amplification
> Here is the provision in question:
> (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
> The question from the subcommittee: Does this provision apply to all
> telephones procured by federal agencies? The Access Board answer is
> yes. But don't misunderstand. I am not telling you exactly how to
> arrive at conformance with that requirement.
> It is true that 508 Subpart C allows for two methods of accessible
> design: build-in the solution or design for compatibility with assistive
> technology. Either one is allowed for most products (not self-contained
> I think that some of the confusion here centers on the determination of
> whether amplification is an assistive technology or part of the
> mainstream information/communications technology. As you read ahead,
> think about the difference between an amplifier as a component and
> amplification as a function.
> Some people view an amplifier as AT. Therefore, their extended argument
> would be that a telephone WITHOUT amplification can be 508-conformant,
> as long as the phone is designed to be compatible with an amplifier.
> This would leave people with hearing loss having to ask for
> accommodations, which brings us back to the way things were before 508,
> when people had to self identify. I know the disability advocates
> don't like that.
> The other view is that amplification is considered an integral part of
> the IT, and therefore the telephone system would not be complete (and
> 508-conformant) without it built-in. It is an interesting argument to
> use the exception about not all IT products requiring attached AT. It is
> true that I would not expect all telephones to have stand-alone TTYs
> connected to them, for example. But is amplification the same kind of
> thing? Some people would say yes and believe that after the phone has
> been set-up with the attached amplifier, the user will then have
> comparable access, which is the overall intent of 508.
> Of course this presumes the scenario of a person using the phone
> regularly like in an office. But what about lobby phones provided to
> the public - phones that may not have built-in accessibility? Section
> 508 does not get population specific in its requirements. Should each of
> those hard of hearing guest users have to ask for an amplifier?
> You may want to think about a few more things as you sort this out:
> First, if amplification is network-based, then this may be a moot issue.
> In other words, imagine that ALL the users on a network had instructions
> to press star five (I made that up) and they would then be able to
> customize their settings for personal hearing enhancement. This is the
> type of thinking out of the box and the consideration for new
> technologies that we are hoping that the experts will bring into the
> Second, this is not just an amplification issue but extends to a number
> of provisions. Years ago, I can remember demonstrating an inductive
> coupler adaptor. For phones that did not generate a strong magnetic
> field from the earpeice, you could strap a small disk around the
> receiver and then get good hearing aid compatibility.
> Another example would be digital phone systems that do not have direct
> analog jacks for TTY hook-up, but through the provision of a
> digital-to-analog adaptor (which might be kept in the desk of an agency
> administrator), the phone system was considered 508-conformant in
> because it was TTY-connectable via the adaptor. One advisor felt that
> this was acceptable as long as the adaptor was "readily available"
> (meaning you can get it right away and not have to wait on an order), a
> term which we don't have in writing anywhere.
> This is one of those "sufficiency" discussions that we hoped the
> Committee would hash out. What is sufficient for 508-conformance?
> What does compatibilty with AT really mean? How can the 508 standards
> inform the design of products that may double as both AT and IT?
> David Baquis
> Accessibility Specialist
> U.S. Access Board
> 1331 F Street, NW, #1000
> Washington, DC 20004
> 800-USA-ABLE; (202) 272-0013 (voice)
> www.access-board.gov; = EMAIL ADDRESS REMOVED = "Leading the way to
> excellence in accessibility"
> "Thank you for your questions concerning section 508 of the
> Rehabilitation Act Amendments of 1998. Section 508 authorizes the
> Access Board to provide technical assistance to individuals and Federal
> departments and agencies concerning the requirements of this section.
> This technical assistance is intended solely as informal guidance; it is
> not a determination of the legal rights or responsibilities of entities
> subject to section 508."
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