Thread Subject: Need comments on provision for Interfernce with Hearing Devices

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From: Brenda Battat
Date: Tue, Jul 31 2007 12:10 PM
Subject: Need comments on provision for Interfernce with Hearing Devices

At the TC SC yesterday the following provision was discussed. Consumers
want to keep the original 508 text at 2.3-B. Alternative language has
been proposed - see below - as some people have expressed concern about
the "lowest possible level" wording. We do not want to weaken the
provision, which we believe the new alternative text does. Please review
the two versions below and give me your feedback ASAP

Thank y ou

Brenda Battat Co chair TC SC

1194.23(i) Interference with Hearing Device

This text is unchanged from original 508 text. It is at 2.3-B of the
EWG July 6 Draft.

Interference to hearing technologies (including hearing aids, cochlear
implants, and assistive listening devices) must be reduced to the lowest
possible level that allows a user of hearing technologies to utilize the
telecommunications product.



Note: Text may need to be reviewed again; "lowest possible level" is
problematic. Possible alternative text:

Potential sources of interference to hearing technologies (including
hearing aids, cochlear implants, and assistive listening devices) must
be reduced as much as possible to provide a more compatible environment
for a user of hearing technologies to utilize the telecommunications
product.

From: Diane Golden
Date: Tue, Jul 31 2007 12:40 PM
Subject: Re: Need comments on provision for Interfernce withHearing Devices

The original standard is problematic because the "lowest possible level" is
extremely subjective which leaves procurement officials with no way to judge
conformance based on vendor provided information. Without reference to a
metric or some measurable way to evaluate the level of interference, the
standard doesn't accomplish much. Unfortunately, the suggested re-wording
doesn't address the problem -- "reduced as much as possible" is no more
measurable than "lowest possible level". Is there not some metric used to
measure interference or is it just a subjective rating?

Diane Golden
NASCIO


-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ]On Behalf Of Brenda Battat
Sent: Tuesday, July 31, 2007 1:13 PM
To: TEITAC Telecommunications Subcommittee
Subject: [teitac-telecom] Need comments on provision for Interfernce
withHearing Devices


At the TC SC yesterday the following provision was discussed. Consumers
want to keep the original 508 text at 2.3-B. Alternative language has been
proposed - see below - as some people have expressed concern about the
"lowest possible level" wording. We do not want to weaken the provision,
which we believe the new alternative text does. Please review the two
versions below and give me your feedback ASAP

Thank y ou

Brenda Battat Co chair TC SC

1194.23(i) Interference with Hearing Device

This text is unchanged from original 508 text. It is at 2.3-B of the EWG
July 6 Draft.

Interference to hearing technologies (including hearing aids, cochlear
implants, and assistive listening devices) must be reduced to the lowest
possible level that allows a user of hearing technologies to utilize the
telecommunications product.



Note: Text may need to be reviewed again; "lowest possible level" is
problematic. Possible alternative text:

Potential sources of interference to hearing technologies (including hearing
aids, cochlear implants, and assistive listening devices) must be reduced as
much as possible to provide a more compatible environment for a user of
hearing technologies to utilize the telecommunications product.

From: Karen Peltz Strauss
Date: Tue, Jul 31 2007 1:05 PM
Subject: Re: Need comments on provision for InterferncewithHearing Devices

Diane

While there is a measurable standard for achieving hearing aid compatibility
on wireless phones, there is no current standard for other products, and is
not likely to be one in the near future. That is why I believe it is best
to leave the language as is, which is basically a goal-oriented guideline.

Karen

----- Original Message -----
From: "Diane Golden" < = EMAIL ADDRESS REMOVED = >
To: "'TEITAC Telecommunications Subcommittee'"
< = EMAIL ADDRESS REMOVED = >
Sent: Tuesday, July 31, 2007 2:47 PM
Subject: Re: [teitac-telecom] Need comments on provision for
InterferncewithHearing Devices


> The original standard is problematic because the "lowest possible level"
> is
> extremely subjective which leaves procurement officials with no way to
> judge
> conformance based on vendor provided information. Without reference to a
> metric or some measurable way to evaluate the level of interference, the
> standard doesn't accomplish much. Unfortunately, the suggested re-wording
> doesn't address the problem -- "reduced as much as possible" is no more
> measurable than "lowest possible level". Is there not some metric used to
> measure interference or is it just a subjective rating?
>
> Diane Golden
> NASCIO
>
>
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ]On Behalf Of Brenda Battat
> Sent: Tuesday, July 31, 2007 1:13 PM
> To: TEITAC Telecommunications Subcommittee
> Subject: [teitac-telecom] Need comments on provision for Interfernce
> withHearing Devices
>
>
> At the TC SC yesterday the following provision was discussed. Consumers
> want to keep the original 508 text at 2.3-B. Alternative language has been
> proposed - see below - as some people have expressed concern about the
> "lowest possible level" wording. We do not want to weaken the provision,
> which we believe the new alternative text does. Please review the two
> versions below and give me your feedback ASAP
>
> Thank y ou
>
> Brenda Battat Co chair TC SC
>
> 1194.23(i) Interference with Hearing Device
>
> This text is unchanged from original 508 text. It is at 2.3-B of the EWG
> July 6 Draft.
>
> Interference to hearing technologies (including hearing aids, cochlear
> implants, and assistive listening devices) must be reduced to the lowest
> possible level that allows a user of hearing technologies to utilize the
> telecommunications product.
>
>
>
> Note: Text may need to be reviewed again; "lowest possible level" is
> problematic. Possible alternative text:
>
> Potential sources of interference to hearing technologies (including
> hearing
> aids, cochlear implants, and assistive listening devices) must be reduced
> as
> much as possible to provide a more compatible environment for a user of
> hearing technologies to utilize the telecommunications product.
>
>
>
>
>
>


--------------------------------------------------------------------------------


>

From: Michaelis, Paul R. (Paul)
Date: Tue, Jul 31 2007 1:10 PM
Subject: Re: Need comments on provision for Interfernce withHearing Devices

Brenda,

I don't like either, chiefly because compliance is not testable.
Without physically measurable attributes and minimal acceptable values,
I'm afraid that all we'll have is a statement of philosophy, rather than
a requirement that would ensure usability.

-- Paul Michaelis

From: Diane Golden
Date: Tue, Jul 31 2007 1:15 PM
Subject: Re: Need comments on provision for InterferncewithHearing Devices

Was there some discussion about moving "aspirational" or goal-oriented
guidelines to one place rather than mixing them in with more measurable,
technical standards? (Or did I dream that up?) That would really help from
the application perspective.

Diane

-----Original Message-----
From: Karen Peltz Strauss [mailto: = EMAIL ADDRESS REMOVED = ]
Sent: Tuesday, July 31, 2007 2:04 PM
To: = EMAIL ADDRESS REMOVED = ; TEITAC Telecommunications Subcommittee
Subject: Re: [teitac-telecom] Need comments on provision for
InterferncewithHearing Devices

Diane

While there is a measurable standard for achieving hearing aid compatibility
on wireless phones, there is no current standard for other products, and is
not likely to be one in the near future. That is why I believe it is best
to leave the language as is, which is basically a goal-oriented guideline.

Karen

----- Original Message -----
From: "Diane Golden" < = EMAIL ADDRESS REMOVED = >
To: "'TEITAC Telecommunications Subcommittee'"
< = EMAIL ADDRESS REMOVED = >
Sent: Tuesday, July 31, 2007 2:47 PM
Subject: Re: [teitac-telecom] Need comments on provision for
InterferncewithHearing Devices


> The original standard is problematic because the "lowest possible level"
> is
> extremely subjective which leaves procurement officials with no way to
> judge
> conformance based on vendor provided information. Without reference to a
> metric or some measurable way to evaluate the level of interference, the
> standard doesn't accomplish much. Unfortunately, the suggested re-wording
> doesn't address the problem -- "reduced as much as possible" is no more
> measurable than "lowest possible level". Is there not some metric used to
> measure interference or is it just a subjective rating?
>
> Diane Golden
> NASCIO
>
>
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ]On Behalf Of Brenda Battat
> Sent: Tuesday, July 31, 2007 1:13 PM
> To: TEITAC Telecommunications Subcommittee
> Subject: [teitac-telecom] Need comments on provision for Interfernce
> withHearing Devices
>
>
> At the TC SC yesterday the following provision was discussed. Consumers
> want to keep the original 508 text at 2.3-B. Alternative language has been
> proposed - see below - as some people have expressed concern about the
> "lowest possible level" wording. We do not want to weaken the provision,
> which we believe the new alternative text does. Please review the two
> versions below and give me your feedback ASAP
>
> Thank y ou
>
> Brenda Battat Co chair TC SC
>
> 1194.23(i) Interference with Hearing Device
>
> This text is unchanged from original 508 text. It is at 2.3-B of the EWG
> July 6 Draft.
>
> Interference to hearing technologies (including hearing aids, cochlear
> implants, and assistive listening devices) must be reduced to the lowest
> possible level that allows a user of hearing technologies to utilize the
> telecommunications product.
>
>
>
> Note: Text may need to be reviewed again; "lowest possible level" is
> problematic. Possible alternative text:
>
> Potential sources of interference to hearing technologies (including
> hearing
> aids, cochlear implants, and assistive listening devices) must be reduced
> as
> much as possible to provide a more compatible environment for a user of
> hearing technologies to utilize the telecommunications product.
>
>
>
>
>
>


----------------------------------------------------------------------------
----


>

From: terry.weaver@gsa.gov
Date: Tue, Jul 31 2007 1:45 PM
Subject: Re: Need comments on provision for InterferncewithHearing Devices

During yesterday's conference call, either Brenda or Karen mentioned that
the only way to test this is to hold a hearing aide near the device and
check for feedback. Can we include a statement to that effect?

(Alternative suggestion from Brenda's email of 7/29)
Potential sources of interference to hearing technologies (including
hearing aids, cochlear implants, and assistive listening devices) must be
reduced as much as possible to provide a more compatible environment for a
user of
hearing technologies to utilize the telecommunications product.

(Terry's modification of the alternative)
Potential sources of interference to hearing technologies (including
hearing aids, cochlear implants, and assistive listening devices) must be
reduced so that a hearing aide does not produce any audible feedback when
held within ?? inches/centimeters of the device.

From: Diane Golden
Date: Tue, Jul 31 2007 2:00 PM
Subject: Re: Need comments on provision for InterferncewithHearing Devices

OK, now I have to say I'm completely confused. Acoustic feedback is whole
different issue from electromagnetic interference. Perhaps I'm wrong, but
my assumption was always that this standard was trying to address the EMI
problem, not acoustic feedback issues. Most feedback is a by-product of the
hearing aid fitting, earmold choice, and positioning of the hearing aid mic
in relation to anything in the environment (usually not E&IT).

Diane Golden
NASCIO

-----Original Message-----
From: = EMAIL ADDRESS REMOVED = [mailto: = EMAIL ADDRESS REMOVED = ]
Sent: Tuesday, July 31, 2007 2:44 PM
To: = EMAIL ADDRESS REMOVED = ; TEITAC Telecommunications Subcommittee
Cc: 'TEITAC Telecommunications Subcommittee';
= EMAIL ADDRESS REMOVED =
Subject: Re: [teitac-telecom] Need comments on provision for
InterferncewithHearing Devices



During yesterday's conference call, either Brenda or Karen mentioned that
the only way to test this is to hold a hearing aide near the device and
check for feedback. Can we include a statement to that effect?

(Alternative suggestion from Brenda's email of 7/29)
Potential sources of interference to hearing technologies (including hearing
aids, cochlear implants, and assistive listening devices) must be reduced as
much as possible to provide a more compatible environment for a user of
hearing technologies to utilize the telecommunications product.

(Terry's modification of the alternative)
Potential sources of interference to hearing technologies (including hearing
aids, cochlear implants, and assistive listening devices) must be reduced so
that a hearing aide does not produce any audible feedback when held within
?? inches/centimeters of the device.

From: Thomas Albin
Date: Tue, Jul 31 2007 2:10 PM
Subject: Re: Need comments on provision for InterferncewithHearing Devices

Wouldn't we want to know that the hearing aid was functioning
properly and was representative of hearing aids in general? Is there
a standard for hearing aids with regard to emf interference?

On Jul 31, 2007, at 2:44 PM, = EMAIL ADDRESS REMOVED = wrote:

>
> During yesterday's conference call, either Brenda or Karen
> mentioned that the only way to test this is to hold a hearing aide
> near the device and check for feedback. Can we include a statement
> to that effect?
>
> (Alternative suggestion from Brenda's email of 7/29)
> Potential sources of interference to hearing technologies
> (including hearing aids, cochlear implants, and assistive listening
> devices) must be reduced as much as possible to provide a more
> compatible environment for a user of
> hearing technologies to utilize the telecommunications product.
>
> (Terry's modification of the alternative)
> Potential sources of interference to hearing technologies
> (including hearing aids, cochlear implants, and assistive listening
> devices) must be reduced so that a hearing aide does not produce
> any audible feedback when held within ?? inches/centimeters of the
> device.
>

From: Brenda Battat
Date: Tue, Jul 31 2007 2:40 PM
Subject: Re: Need comments on provision forInterferncewithHearing Devices

There is a standard for measuring hearing aid immunity to inteference.
And there is a standard for measuring the interference output of mobile
wireless devices - ANSI C63.19. The other question is whether or not
this provision applies only to wireless handheld devices for which there
are standards and can be measured objectively or whether it applies to
any device that might cause interference such as computers for which
there currently is no measurement

From: Brenda Battat
Date: Tue, Jul 31 2007 3:00 PM
Subject: Re: Need comments on provision forInterferncewithHearing Devices

No what I was referring to on the casll was in response to a comment
that how would manufacturers of devices other then wireless handsets
know when they have met this provision as there are no objective ways to
measure outcome. I stated that today a quick way would be hold a hearing
aid close to the device, not necessarily up to the ear, and you can
easily hear the interference - not acoustic feedback - but EMI
interference

From: Diane Golden
Date: Tue, Jul 31 2007 3:30 PM
Subject: Re: Need comments on provision forInterferncewithHearing Devices

I'm not sure what I could do in a procurement review with information
reported by vendor about a person subjectively listening for EMI by holding
a hearing aid up to their product. To make that comparable between vendors,
minimally the hearing aid RF immunity would have to be specified, or better
yet one particular make/model of hearing aid would need to be used by all
vendors so the results were comparable across products. The "listening
judgement" would have to be quantified somehow into a rating scale and it
would need to be done for both acoustic and telecoil coupling. Is this what
folks were considering as a method for verification??

Diane


-----Original Message-----
From: Brenda Battat [mailto: = EMAIL ADDRESS REMOVED = ]
Sent: Tuesday, July 31, 2007 4:01 PM
To: = EMAIL ADDRESS REMOVED = ; TEITAC Telecommunications Subcommittee
Subject: RE: [teitac-telecom] Need comments on provision
forInterferncewithHearing Devices



No what I was referring to on the casll was in response to a comment that
how would manufacturers of devices other then wireless handsets know when
they have met this provision as there are no objective ways to measure
outcome. I stated that today a quick way would be hold a hearing aid close
to the device, not necessarily up to the ear, and you can easily hear the
interference - not acoustic feedback - but EMI interference

_____

From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Diane Golden
Sent: Tuesday, July 31, 2007 4:08 PM
To: 'TEITAC Telecommunications Subcommittee'
Subject: Re: [teitac-telecom] Need comments on provision
forInterferncewithHearing Devices


OK, now I have to say I'm completely confused. Acoustic feedback is whole
different issue from electromagnetic interference. Perhaps I'm wrong, but
my assumption was always that this standard was trying to address the EMI
problem, not acoustic feedback issues. Most feedback is a by-product of the
hearing aid fitting, earmold choice, and positioning of the hearing aid mic
in relation to anything in the environment (usually not E&IT).

Diane Golden
NASCIO

-----Original Message-----
From: = EMAIL ADDRESS REMOVED = [mailto: = EMAIL ADDRESS REMOVED = ]
Sent: Tuesday, July 31, 2007 2:44 PM
To: = EMAIL ADDRESS REMOVED = ; TEITAC Telecommunications Subcommittee
Cc: 'TEITAC Telecommunications Subcommittee';
= EMAIL ADDRESS REMOVED =
Subject: Re: [teitac-telecom] Need comments on provision for
InterferncewithHearing Devices



During yesterday's conference call, either Brenda or Karen mentioned that
the only way to test this is to hold a hearing aide near the device and
check for feedback. Can we include a statement to that effect?

(Alternative suggestion from Brenda's email of 7/29)
Potential sources of interference to hearing technologies (including hearing
aids, cochlear implants, and assistive listening devices) must be reduced as
much as possible to provide a more compatible environment for a user of
hearing technologies to utilize the telecommunications product.

(Terry's modification of the alternative)
Potential sources of interference to hearing technologies (including hearing
aids, cochlear implants, and assistive listening devices) must be reduced so
that a hearing aide does not produce any audible feedback when held within
?? inches/centimeters of the device.

From: Gregg Vanderheiden
Date: Sun, Aug 26 2007 10:30 PM
Subject: Re: Need comments on provision for InterferncewithHearing Devices

Yes.



Also

"As much as possible" - raises the question - 'possible with what?"
possible with current hardware? current software? with how much effort?



Remember - readily achievable and undue burden are still in effect. So the
"lowest possible level" language may be ok because it automatically becomes



"lowest possible level that is readily achievable" for 255



"lowest possible level that isn't an undue burden for the government to
purchase" for 508



Actually, if we just leave it as lowest possible - then the limits
automatically engage.

This is testable by companies but not by anyone else.

Makes it possible to comply but hard to externally verify without company
providing rationale and/or info.






Gregg
-- ------------------------------
Gregg C Vanderheiden Ph.D.






_____


From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Diane Golden
Sent: Tuesday, July 31, 2007 1:48 PM
To: 'TEITAC Telecommunications Subcommittee'
Subject: Re: [teitac-telecom] Need comments on provision for
InterferncewithHearing Devices

The original standard is problematic because the "lowest possible level" is
extremely subjective which leaves procurement officials with no way to judge
conformance based on vendor provided information. Without reference to a
metric or some measurable way to evaluate the level of interference, the
standard doesn't accomplish much. Unfortunately, the suggested re-wording
doesn't address the problem -- "reduced as much as possible" is no more
measurable than "lowest possible level". Is there not some metric used to
measure interference or is it just a subjective rating?



Diane Golden

NASCIO





-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ]On Behalf Of Brenda Battat
Sent: Tuesday, July 31, 2007 1:13 PM
To: TEITAC Telecommunications Subcommittee
Subject: [teitac-telecom] Need comments on provision for Interfernce
withHearing Devices

At the TC SC yesterday the following provision was discussed. Consumers
want to keep the original 508 text at 2.3-B. Alternative language has been
proposed - see below - as some people have expressed concern about the
"lowest possible level" wording. We do not want to weaken the provision,
which we believe the new alternative text does. Please review the two
versions below and give me your feedback ASAP



Thank y ou



Brenda Battat Co chair TC SC

1194.23(i) Interference with Hearing Device

This text is unchanged from original 508 text. It is at 2.3-B of the EWG
July 6 Draft.

Interference to hearing technologies (including hearing aids, cochlear
implants, and assistive listening devices) must be reduced to the lowest
possible level that allows a user of hearing technologies to utilize the
telecommunications product.



Note: Text may need to be reviewed again; "lowest possible level" is
problematic. Possible alternative text:

Potential sources of interference to hearing technologies (including hearing
aids, cochlear implants, and assistive listening devices) must be reduced as
much as possible to provide a more compatible environment for a user of
hearing technologies to utilize the telecommunications product.