Thread Subject: Re: Touch-based controls language

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From: Debbie Cook
Date: Wed, Aug 22 2007 2:10 PM
Subject: Re: Touch-based controls language

I would like to speak in favor of Proposal 1. The primary issue is that
there is no equivalent means that anyone has identified for implementing
number2. If anindividual uses a touch screen control, themost equivalent
alternative is a mechanical control (anotherform oftouch control.) Use of
speech reduces privacy which is essential to the operation ofmany devicesw.
Use of add-on technologies such asAT or add-on IT is notequivalent because
they require the individual to have them. There is nothing that would
prohibit implementation of any of these alternatives under equivalent
facilitation if it can be shown that for thespecific product they are indeed
equivalent.
----- Original Message -----
From: < = EMAIL ADDRESS REMOVED = >
To: < = EMAIL ADDRESS REMOVED = >; < = EMAIL ADDRESS REMOVED = >
Sent: Tuesday, August 21, 2007 7:41 AM
Subject: Re: [teitac-closed] [teitac-hardware] Touch-based controls language


The following language was suggested a couple of weeks ago. Just
getting it back into the discussion loop. Please comment.




The two versions of the requirement that appear in the July 6 draft are:

Version 1 - If a product utilizes touch screens or touch-operated
controls, an input method must be provided that complies with Mechanical
Controls Section.
Version 2 - If a product utilizes touch screens or touch-operated
controls, an equivalent means of input/interaction/control shall be
provided.

Here is an attempt to reword the requirement to address the concerns
that I heard at the TEITAC plenary this morning.


If a product utilizes touch screens or touch-operated controls
(a) A functionally equivalent, alternate means of operation that
does not require vision must be provided.
(b) A functionally equivalent, alternate means of operation that
does not require fine motor control must be provided.
(c) If the product is freestanding, non-portable, and intended to
be used in one location, the alternate means in (a) and (b) must not
require speech.

Related Sufficient Techniques:
If a product utilizes touch screens or touch-operated controls, and is
freestanding, non-portable, and intended to be used in one location, a
sufficient technique to satisfy the requirement would be to provide
functionally equivalent Mechanical Controls (see). To protect the
privacy of the user, speech cannot be required . However, if Mechanical
Controls are provided, redundant voice controls may be provided as well.

To satisfy the requirement for other products that utilize touch screens
or touch-operated controls, sufficient techniques include providing
functionally equivalent (1) Mechanical Controls, or (2) voice controls
with audio response.


Here are some additional thoughts:

1. In order to leave room for innovation, the provision begins to look
something like the Functional Performance Criteria. In order to
compensate for this, I tried to consider the human abilities that may be
required for operation of a touch screen or touch control (vision and
fine motor control), and to address those specific interface
requirements.

2. This language does not address the needs of those who have multiple
disabilities.


Peter Manyin
Accessibility Specialist
Federal Reserve Board




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

From: Peter J. Manyin
Date: Thu, Aug 23 2007 4:00 PM
Subject: Re: Touch-based controls language

Hi, Debbie. Thanks for responding to my proposed language regarding
alternatives to touch-based controls. I would like to respond to a couple
of your points.

* "If an individual uses a touch screen control, the most equivalent
alternative is a mechanical control (another form of touch control.)"

I agree, unless the user has a motion disability with limited dexterity.
In that case, voice control or some other interface might offer the most
comparable functionality. I think that requiring functionally equivalent
mechanical controls is too limiting to innovation.

* "Use of speech reduces privacy which is essential to the operation of
many devices."

I agree that use of speech may reduce privacy, depending on the
environment in which the device is used. In the case of an information
kiosk, the user cannot choose the environment, which is why user speech
must not be required. For mobile products, it seems that there can be
limited expectation of privacy if the user is in a public environment.

I'm not sure I agree that privacy is essential to the operation of many
devices, but I agree that privacy is highly desirable for the operation of
many devices. I am not a procurement official, but I think that if
privacy is essential to the operation of a device, the procurement
official would include private operation as a functional requirement of
the product.

Any other thoughts, or suggestions for wording of the provision? Thanks!

Peter Manyin
Accessibility Specialist
Federal Reserve Board

From: Debbie Cook
Date: Fri, Aug 24 2007 8:40 AM
Subject: Re: Touch-based controls language

Well I'm concerned that this will sound costic, so I need to say up front
that it is absolutely a serious recommendation with no attempt at sarcasm.
If speech output is truly an equivalent to silent operation of devices, then
it should be the primary means of input and the touch screen controls should
not be permitted at all. I think my point is, that while it's the only means
of operating devices for some people, and while it's completely adequate in
some settings for any person, there are often times that an individual would
be distracting to others in the environment if they had to speak in a normal
and clear voice to a device. And there are many devices where the devices
don't respond well. My cell phone, for example, has great speech in
capability but I rarely use it because in noisy environments or in places
where there are other people, it poses a problem. So, I'm waiting to hear
what, other than speech, is going to be used in place of the touchscreen
controls.
----- Original Message -----
From: < = EMAIL ADDRESS REMOVED = >
To: < = EMAIL ADDRESS REMOVED = >
Sent: Thursday, August 23, 2007 2:57 PM
Subject: Re: [teitac-hardware] [teitac-closed] Touch-based controls language


Hi, Debbie. Thanks for responding to my proposed language regarding
alternatives to touch-based controls. I would like to respond to a couple
of your points.

* "If an individual uses a touch screen control, the most equivalent
alternative is a mechanical control (another form of touch control.)"

I agree, unless the user has a motion disability with limited dexterity.
In that case, voice control or some other interface might offer the most
comparable functionality. I think that requiring functionally equivalent
mechanical controls is too limiting to innovation.

* "Use of speech reduces privacy which is essential to the operation of
many devices."

I agree that use of speech may reduce privacy, depending on the
environment in which the device is used. In the case of an information
kiosk, the user cannot choose the environment, which is why user speech
must not be required. For mobile products, it seems that there can be
limited expectation of privacy if the user is in a public environment.

I'm not sure I agree that privacy is essential to the operation of many
devices, but I agree that privacy is highly desirable for the operation of
many devices. I am not a procurement official, but I think that if
privacy is essential to the operation of a device, the procurement
official would include private operation as a functional requirement of
the product.

Any other thoughts, or suggestions for wording of the provision? Thanks!

Peter Manyin
Accessibility Specialist
Federal Reserve Board



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

From: Randy Marsden
Date: Fri, Aug 24 2007 9:15 AM
Subject: Re: Touch-based controls language

I agree with Peter.

Version 1 takes care of access for people who are blind, but does not
help people with other types of physical disabilities. Version 2
does a better job of encompassing all types of disabilities.
Remember - besides speech recognition, keyboard and mouse
alternatives are commonly used (both software and hardware-based).
For example, as long a whatever is being controlled on the screen of
a touch-based device can also be actuated by a mouse, then head-
pointing devices can be used by people without the use of hands.

-Randy

On Aug 23, 2007, at 3:57 PM, = EMAIL ADDRESS REMOVED = wrote:

>
> Hi, Debbie. Thanks for responding to my proposed language
> regarding alternatives to touch-based controls. I would like to
> respond to a couple of your points.
>
> * "If an individual uses a touch screen control, the most
> equivalent alternative is a mechanical control (another form of
> touch control.)"
>
> I agree, unless the user has a motion disability with limited
> dexterity. In that case, voice control or some other interface
> might offer the most comparable functionality. I think that
> requiring functionally equivalent mechanical controls is too
> limiting to innovation.
>
> * "Use of speech reduces privacy which is essential to the
> operation of many devices."
>
> I agree that use of speech may reduce privacy, depending on the
> environment in which the device is used. In the case of an
> information kiosk, the user cannot choose the environment, which is
> why user speech must not be required. For mobile products, it
> seems that there can be limited expectation of privacy if the user
> is in a public environment.
>
> I'm not sure I agree that privacy is essential to the operation of
> many devices, but I agree that privacy is highly desirable for the
> operation of many devices. I am not a procurement official, but I
> think that if privacy is essential to the operation of a device,
> the procurement official would include private operation as a
> functional requirement of the product.
>
> Any other thoughts, or suggestions for wording of the provision?
> Thanks!
>
> Peter Manyin
> Accessibility Specialist
> Federal Reserve Board
>

From: James Elekes
Date: Fri, Aug 24 2007 9:30 AM
Subject: Re: Touch-based controls language

Deb and Peter,

While I can see the justification in each presentation, I have to
agree with Deb. I had the problem of "Voice" brought home this past
week when travelling via Amtrak from NYC to D.C. The only seats
available were in the "Quiet Car". I was expecting a call and, of
course it came in somewhere between the two points. Rather than
fumbling with the touch controls, I used Voice Input and, was
immediately chastised by the Conductor and several around me. I was
encouraged to step into the foyer between cars (Acccella travelling
at 135 mph). Touch Controls were impracticle due to their
design/position (and the instability of the foyer) but, Voice was
equally inappropriate. What's the option?

My apologies if this situation doesn't add to the discussion but, I
believe it's a practical example of the frustration being experienced
in real life by those of us who have visual impairments.

-Jim

James J. Elekes, Chairman
Telecommunications, Electronic/Information Technologies Committee
United States Access Board

(O) 888.564.8430


At 10:37 AM 8/24/2007, you wrote:
>Well I'm concerned that this will sound costic, so I need to say up front
>that it is absolutely a serious recommendation with no attempt at sarcasm.
>If speech output is truly an equivalent to silent operation of devices, then
>it should be the primary means of input and the touch screen controls should
>not be permitted at all. I think my point is, that while it's the only means
>of operating devices for some people, and while it's completely adequate in
>some settings for any person, there are often times that an individual would
>be distracting to others in the environment if they had to speak in a normal
>and clear voice to a device. And there are many devices where the devices
>don't respond well. My cell phone, for example, has great speech in
>capability but I rarely use it because in noisy environments or in places
>where there are other people, it poses a problem. So, I'm waiting to hear
>what, other than speech, is going to be used in place of the touchscreen
>controls.
>----- Original Message -----
>From: < = EMAIL ADDRESS REMOVED = >
>To: < = EMAIL ADDRESS REMOVED = >
>Sent: Thursday, August 23, 2007 2:57 PM
>Subject: Re: [teitac-hardware] [teitac-closed] Touch-based controls language
>
>
>Hi, Debbie. Thanks for responding to my proposed language regarding
>alternatives to touch-based controls. I would like to respond to a couple
>of your points.
>
>* "If an individual uses a touch screen control, the most equivalent
>alternative is a mechanical control (another form of touch control.)"
>
>I agree, unless the user has a motion disability with limited dexterity.
>In that case, voice control or some other interface might offer the most
>comparable functionality. I think that requiring functionally equivalent
>mechanical controls is too limiting to innovation.
>
>* "Use of speech reduces privacy which is essential to the operation of
>many devices."
>
>I agree that use of speech may reduce privacy, depending on the
>environment in which the device is used. In the case of an information
>kiosk, the user cannot choose the environment, which is why user speech
>must not be required. For mobile products, it seems that there can be
>limited expectation of privacy if the user is in a public environment.
>
>I'm not sure I agree that privacy is essential to the operation of many
>devices, but I agree that privacy is highly desirable for the operation of
>many devices. I am not a procurement official, but I think that if
>privacy is essential to the operation of a device, the procurement
>official would include private operation as a functional requirement of
>the product.
>
>Any other thoughts, or suggestions for wording of the provision? Thanks!
>
>Peter Manyin
>Accessibility Specialist
>Federal Reserve Board
>
>
>
>--------------------------------------------------------------------------------
>
>
>

From: Debbie Cook
Date: Fri, Aug 24 2007 9:55 AM
Subject: Re: Touch-based controls language

I am not op[posed to adding additional requirements to number 1 in
recognition of the fact that it doesn't accommodate everyone. But #2 does
not either, becaue it does not describe what will be equivalent. It is not
measurable.
----- Original Message -----
From: "James Elekes" < = EMAIL ADDRESS REMOVED = >
To: "TEITAC desktop/portable (hardware) subcommittee"
< = EMAIL ADDRESS REMOVED = >
Sent: Friday, August 24, 2007 8:29 AM
Subject: Re: [teitac-hardware] [teitac-closed] Touch-based controls language


Deb and Peter,

While I can see the justification in each presentation, I have to
agree with Deb. I had the problem of "Voice" brought home this past
week when travelling via Amtrak from NYC to D.C. The only seats
available were in the "Quiet Car". I was expecting a call and, of
course it came in somewhere between the two points. Rather than
fumbling with the touch controls, I used Voice Input and, was
immediately chastised by the Conductor and several around me. I was
encouraged to step into the foyer between cars (Acccella travelling
at 135 mph). Touch Controls were impracticle due to their
design/position (and the instability of the foyer) but, Voice was
equally inappropriate. What's the option?

My apologies if this situation doesn't add to the discussion but, I
believe it's a practical example of the frustration being experienced
in real life by those of us who have visual impairments.

-Jim

James J. Elekes, Chairman
Telecommunications, Electronic/Information Technologies Committee
United States Access Board

(O) 888.564.8430


At 10:37 AM 8/24/2007, you wrote:
>Well I'm concerned that this will sound costic, so I need to say up front
>that it is absolutely a serious recommendation with no attempt at sarcasm.
>If speech output is truly an equivalent to silent operation of devices,
>then
>it should be the primary means of input and the touch screen controls
>should
>not be permitted at all. I think my point is, that while it's the only
>means
>of operating devices for some people, and while it's completely adequate in
>some settings for any person, there are often times that an individual
>would
>be distracting to others in the environment if they had to speak in a
>normal
>and clear voice to a device. And there are many devices where the devices
>don't respond well. My cell phone, for example, has great speech in
>capability but I rarely use it because in noisy environments or in places
>where there are other people, it poses a problem. So, I'm waiting to hear
>what, other than speech, is going to be used in place of the touchscreen
>controls.
>----- Original Message -----
>From: < = EMAIL ADDRESS REMOVED = >
>To: < = EMAIL ADDRESS REMOVED = >
>Sent: Thursday, August 23, 2007 2:57 PM
>Subject: Re: [teitac-hardware] [teitac-closed] Touch-based controls
>language
>
>
>Hi, Debbie. Thanks for responding to my proposed language regarding
>alternatives to touch-based controls. I would like to respond to a couple
>of your points.
>
>* "If an individual uses a touch screen control, the most equivalent
>alternative is a mechanical control (another form of touch control.)"
>
>I agree, unless the user has a motion disability with limited dexterity.
>In that case, voice control or some other interface might offer the most
>comparable functionality. I think that requiring functionally equivalent
>mechanical controls is too limiting to innovation.
>
>* "Use of speech reduces privacy which is essential to the operation of
>many devices."
>
>I agree that use of speech may reduce privacy, depending on the
>environment in which the device is used. In the case of an information
>kiosk, the user cannot choose the environment, which is why user speech
>must not be required. For mobile products, it seems that there can be
>limited expectation of privacy if the user is in a public environment.
>
>I'm not sure I agree that privacy is essential to the operation of many
>devices, but I agree that privacy is highly desirable for the operation of
>many devices. I am not a procurement official, but I think that if
>privacy is essential to the operation of a device, the procurement
>official would include private operation as a functional requirement of
>the product.
>
>Any other thoughts, or suggestions for wording of the provision? Thanks!
>
>Peter Manyin
>Accessibility Specialist
>Federal Reserve Board
>
>
>
>--------------------------------------------------------------------------------
>
>
>

From: James Elekes
Date: Fri, Aug 24 2007 10:05 AM
Subject: Re: Touch-based controls language

Agreed.

-Jim


At 11:54 AM 8/24/2007, you wrote:
>I am not op[posed to adding additional requirements to number 1 in
>recognition of the fact that it doesn't accommodate everyone. But #2 does
>not either, becaue it does not describe what will be equivalent. It is not
>measurable.
>----- Original Message -----
>From: "James Elekes" < = EMAIL ADDRESS REMOVED = >
>To: "TEITAC desktop/portable (hardware) subcommittee"
>< = EMAIL ADDRESS REMOVED = >
>Sent: Friday, August 24, 2007 8:29 AM
>Subject: Re: [teitac-hardware] [teitac-closed] Touch-based controls language
>
>
>Deb and Peter,
>
>While I can see the justification in each presentation, I have to
>agree with Deb. I had the problem of "Voice" brought home this past
>week when travelling via Amtrak from NYC to D.C. The only seats
>available were in the "Quiet Car". I was expecting a call and, of
>course it came in somewhere between the two points. Rather than
>fumbling with the touch controls, I used Voice Input and, was
>immediately chastised by the Conductor and several around me. I was
>encouraged to step into the foyer between cars (Acccella travelling
>at 135 mph). Touch Controls were impracticle due to their
>design/position (and the instability of the foyer) but, Voice was
>equally inappropriate. What's the option?
>
>My apologies if this situation doesn't add to the discussion but, I
>believe it's a practical example of the frustration being experienced
>in real life by those of us who have visual impairments.
>
>-Jim
>
>James J. Elekes, Chairman
>Telecommunications, Electronic/Information Technologies Committee
>United States Access Board
>
>(O) 888.564.8430
>
>
>At 10:37 AM 8/24/2007, you wrote:
> >Well I'm concerned that this will sound costic, so I need to say up front
> >that it is absolutely a serious recommendation with no attempt at sarcasm.
> >If speech output is truly an equivalent to silent operation of devices,
> >then
> >it should be the primary means of input and the touch screen controls
> >should
> >not be permitted at all. I think my point is, that while it's the only
> >means
> >of operating devices for some people, and while it's completely adequate in
> >some settings for any person, there are often times that an individual
> >would
> >be distracting to others in the environment if they had to speak in a
> >normal
> >and clear voice to a device. And there are many devices where the devices
> >don't respond well. My cell phone, for example, has great speech in
> >capability but I rarely use it because in noisy environments or in places
> >where there are other people, it poses a problem. So, I'm waiting to hear
> >what, other than speech, is going to be used in place of the touchscreen
> >controls.
> >----- Original Message -----
> >From: < = EMAIL ADDRESS REMOVED = >
> >To: < = EMAIL ADDRESS REMOVED = >
> >Sent: Thursday, August 23, 2007 2:57 PM
> >Subject: Re: [teitac-hardware] [teitac-closed] Touch-based controls
> >language
> >
> >
> >Hi, Debbie. Thanks for responding to my proposed language regarding
> >alternatives to touch-based controls. I would like to respond to a couple
> >of your points.
> >
> >* "If an individual uses a touch screen control, the most equivalent
> >alternative is a mechanical control (another form of touch control.)"
> >
> >I agree, unless the user has a motion disability with limited dexterity.
> >In that case, voice control or some other interface might offer the most
> >comparable functionality. I think that requiring functionally equivalent
> >mechanical controls is too limiting to innovation.
> >
> >* "Use of speech reduces privacy which is essential to the operation of
> >many devices."
> >
> >I agree that use of speech may reduce privacy, depending on the
> >environment in which the device is used. In the case of an information
> >kiosk, the user cannot choose the environment, which is why user speech
> >must not be required. For mobile products, it seems that there can be
> >limited expectation of privacy if the user is in a public environment.
> >
> >I'm not sure I agree that privacy is essential to the operation of many
> >devices, but I agree that privacy is highly desirable for the operation of
> >many devices. I am not a procurement official, but I think that if
> >privacy is essential to the operation of a device, the procurement
> >official would include private operation as a functional requirement of
> >the product.
> >
> >Any other thoughts, or suggestions for wording of the provision? Thanks!
> >
> >Peter Manyin
> >Accessibility Specialist
> >Federal Reserve Board
> >
> >
> >
> >-------------------------------------------------------------------
> -------------
> >
> >
> >

From: Peter J. Manyin
Date: Fri, Aug 24 2007 11:25 AM
Subject: Re: Touch-based controls language

Regarding touch-based controls, thanks for the lively discussion on the
listserve and the conference call. Here is the provision's wording from
the conference call today, August 24:

If a product utilizes touch screens or touch-operated controls then the
product must provide directly or through AT that does not require
user-speech:
(a) A functionally equivalent, alternate means of operation that uses
Mechanical Controls and does not require vision.
(b) A functionally equivalent, alternate means of operation that does
not require fine motor control.

After the conference call, I took another look at the wording, and I think
that we can compact the provision a bit. Assuming that Mechanical
Controls do not require user vision or user speech:

If a product utilizes touch screens or touch-operated controls then the
product must provide directly or through AT:
(a) A functionally equivalent, alternate means of operation that
consists of Mechanical Controls.
(b) A functionally equivalent, alternate means of operation that does
not require fine motor control or user speech.

Peter Manyin
Accessibility Specialist
Publications

From: Randy Marsden
Date: Fri, Nov 09 2007 5:45 PM
Subject: Touch-based controls language

Hi Everyone:

I know we missed the deadline for getting info into the sandbox, but
I wanted to try to get everyone on the same page regarding Touch
Controls prior to next week's meetings.

The following is proposed text that we brought to the last plenary,
after a fair amount of vetting on the list serve (and recognition
goes to Peter Manyin for drafting this):

Version 1
If a product utilizes touch screens or touch-operated controls then
the product must provide, without requiring user-speech:

A functionally equivalent, alternate means of operation that uses
Mechanical Controls and does not require vision.
A functionally equivalent, alternate means of operation that does not
require fine motor control.
Note: This provision should not discourage the provision of control
via user speech in addition to the above methods.


Then, during the plenary when it was being discussed, a Version 2 was
entered on the Wiki as follows:

Version 2 (proposal from plenary)
If a product uses touch screens or touch-operated controls, it must
provide a functionally equivalent alternative means of operation that
meets the requirements for Mechanical Controls. This alternative must
not require either vision or fine motor control.

Note: A product may also provide control via user speech in addition
to the above methods.

Rationale: This language addresses the issues associated with touch-
based controls (including biophysical, accidental activation and
vision) by requiring a redundant interaction method without assigning
the control type.



As Rob and I reviewed this earlier this week, we realized that we
don't think that Version 2 was exactly what we intended and may have
been incomplete when entered into the Wiki during the last plenary.
Specifically, the first sentence of Version 2 requires Mechanical
Controls, while the second stipulates use not requiring fine motor
control. Those two requirements will likely conflict with one
another (ie. you can't require mechanical controls AND require that
they don't require fine motor control).

I have checked my notes from the last plenary, but unfortunately
didn't document what the objections were to the Version 1 wording.
So, we'd like to take a step back to the original language in Version
1 (which we feel addresses both disability segments - blindness and
motor impairments - who will have trouble with touch controls) and re-
discuss it. If there are valid concerns, we can amend it again and
go from there. Sorry for the confusion - this one fell through the
cracks.

-Randy Marsden (HW co-chair)
ATIA