Thread Subject: Re: Requirements for telephone amplification

Note

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From: Baquis David
Date: Wed, Nov 08 2006 4:20 PM

As a follow-on to my last email, I wanted to clarify the sequential
application of 508 Subparts B and C.

Subpart B should be used first (by designers, evaluators, requesters,
etc). In those provisions, you will often see language, such as: "the
product shall". That means that the solution should be built-in.
Therefore, in http://www.access-board.gov/sec508/guide/1194.23.htm#(f),
it is clear that the amplification should be built into the telephone.

I am glad that Brenda brought the HAC Act requirement for volume control
to our attention. However, even without that, 508 would still require
built-in amplification as a purchasing requirement.

I apologize for confusion resulting from my earlier comments below.
Actually, we do not know of any federal agency that has misinterpreted
that requirement and looked for an "out" to getting amplified phones.
(Although we do know of at least one instance in which 508 was
completely overlooked in all respects in the procurement of an expensive
telephone system ... and no one complained. I was the only person who
picked up on it and we are not a watchdog advocacy group, but I did call
the agency and speak with them about it.)

Subpart C is to be used when it is not possible for a company to meet
Subpart B. This is addressed in an FAQ, which I have cut/pasted below.
See: B.2.ii at:
http://www.section508.gov/index.cfm?FuseAction=Content&ID=75

"ii. How should an agency proceed in identifying "applicable" technical
provisions in Subparts B, C, and D of the Access Board's standards to
ensure acquired products provide comparable access?
Agencies should first look to the provisions in Subpart B to determine
if there are specific technical provisions that apply to the EIT need
they are seeking to satisfy.
If there are applicable provisions in Subpart B that fully address the
product or service being procured, then the agency need not look to
Subpart C. Acquired products that meet the specific technical provisions
set forth in Subpart B will also meet the broader functional performance
criteria in Subpart C.
If an agency's procurement needs are not fully addressed by Subpart B,
then the agency must look to Subpart C for applicable functional
performance requirements.
Agencies must also remember the additional considerations of Subpart D.
Subpart D requires that: (a) product support documentation provided to
end users shall be made available in alternate formats upon request at
no additional charge; (b) end users shall have access to a description
of the accessibility and compatibility features of products in alternate
formats or methods upon request, also at no additional charge; and (c)
support services (e.g., help desk) for products shall accommodate the
communication needs of end users with disabilities.
For example, if an agency were to enter into a seat management contract
for desktop computing resources, the hardware and software to be
provided by the contractor would be required to meet the provisions in
section 1194.26 (Desktop and Portable Computers), and 1194.21 (Software
Applications and Operating Systems) of Subpart B of the Access Board's
standards. If these provisions fully addressed the agency's procurement
software and hardware needs, the agency would also be in compliance with
Subpart C. If some or all of the features were not covered by Subpart B,
the agency would also have to look to Subpart C. With respect to the
support services provided under the seat management contract, the agency
would also need to take into account any appropriate information,
documentation, or support requirements in Subpart D.
In all cases, agencies, when evaluating offers, must consider products
that provide equivalent facilitation (see section B.3, below)."

David Baquis

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