Thread Subject: Re: Requirements for telephone amplification
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From: Brenda Battat
Date: Mon, Nov 06 2006 5:40 PM
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I hear you all had a good discussion about volume control today. Sorry I
missed it. Here is some background as I know it and my take on volume
The hearing Aid Compatibility Act has a requirement for the manufacture
of every wireline phone to include volume control in addition to HAC.
This was incorporated as an outcome of the FCC HAC Negotiated Rulemaking
Committee - pre-508. It was not to be retroactive. So if an old phone
turns up in the workplace, for example, identified by an employee as not
having VC and HAC, then a certain number of days are allowed to replace
that phone with a new one that does.
The VC gain in 508 was taken from existing levels in ADA and FCC
regulations. HLAA was not happy with the gain levels as they just do not
meet the needs of many people with hearing loss. We receive lots of
complaints for both landline and wireless not being loud enough. The
current gain is good in noisy situations for people who do not have
hearing loss or who have early hearing loss. People who have more
hearing loss combine the VC with telecoil coupling and then may be able
to use the phone depending on other factors such as background noise,
signal quality, articulation of the speaker on the other end,
interference levels in digital handsets, immunity of hearing aids,
strength of the telecoil and whether or not the telecoil has been
At the urging of SHHH (now HLAA) the original Access Board 508 NPRM was
suggesting to allow up to 25dB of gain (that was the best we could get.)
But this level did not make it into the Final Rule as a result of
opposition from industry.The argument against more gain was distortion
for all users. HLAA commissioned two labs to test distortion and both
labs found no evidence of it.
Going to 24dB would get access to a lot more people with a range of
hearing losses. However, there would still be some people who would need
higher boosts - handsets sold as special equipment reach 35-40dB gain
and people using those are usually much happier.
The other big question is, how many phones actually reach the current
required levels? There is definitely variability from phone to phone and
no way for a consumer to know how much boost is actually being provided.
The gain should be documented.
Federal employees must be able to use any phone to be effective workers
and also in case of emergency they need equivalent access for their own
and others' safety. Therefore the VC gain should be built in. Its
ridiculous to expect employees to carry handsets from one office or
floor to another.We have to take this opportunity to fix a problem that
has irked people for a long time and jeopardized their ability to use a
phone effectively. We need to settle on a gain level that is effective
for as many people as possible and then figure out a way to manufacture
Associate Executive Director
Hearing Loss Association of America (formerly SHHH)
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Diane
Sent: Monday, November 06, 2006 4:58 PM
To: 'TEITAC Telecommunications Subcommittee'
Subject: Re: [teitac-telecom] Requirements for telephone amplification
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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