Thread Subject: Re: Requirements for telephone amplification

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From: Diane Golden
Date: Tue, Nov 07 2006 4:45 AM

If this logic is applied to all the 508 standards (e.g. all can be met either by the product conforming to the standard "as is" or through some add-on product) then the captioning decoder standard would not require a chip -- adding on a decoder (provided you can find one now) would meet the standard. Similarly, adding on captions or description as needed would be OK. One could argue you could add alt tags as needed rather than them being there "as is". If this is the case -- it is a massive shift in application of the standards.

Diane Golden


----- Original Message ----
From: Baquis David < = EMAIL ADDRESS REMOVED = >
To: = EMAIL ADDRESS REMOVED =
Sent: Monday, November 6, 2006 6:20:33 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
provided.
http://www.access-board.gov/sec508/guide/1194.23.htm#(f)

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
products).

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
discussion.

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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