Thread Subject: Final Report Draft Review: Joint Comment from Panasonic/Canon USA
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Date: Thu, Mar 27 2008 3:30 PM
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Canon USA and Panasonic jointly submit the following for the Final Report
3. User Interface and Electronic Content
It is not clear whether the User Interface and Electronic Content
provisions are applicable to hardware user interfaces.
While the statement below this heading in Subpart C states that these
provisions apply to all "Electronic and Information Technology", the
explanation of this section in the Narrative does not mention
applicability to the huge category of products considered hardware. In
addition, no mention of applicability to hardware is made in the rationale
for the provisions or in the impact metadata.
Most of these provisions originated from Software and Operating System
(Section 508 1194.21), Web-based Intranet and Internet Information and
Application (Section 508 1194.22), or in the Web Content Accessibility
Guidelines (WCAG) 2.0. These requirements were designed for web and
software, not hardware displays and the TEITAC made little consideration
of this large category of products as evidenced by the lack of guidance or
specificity in reference to hardware user interfaces.
Therefore, it is recommended that 3. User Interface and Electronic Content
not apply to hardware displays.
Government Policy and Compliance Analyst
Government Marketing Division
Canon USA, Inc.
TEL: (703) 807-3158
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