Thread Subject: Re: E&IT determination

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From: Hoffman, Allen
Date: Tue, Sep 18 2007 7:55 AM
Subject: Re: E&IT determination

All:


At the plenary a discussion took place about how to identify what is and
isn't E&IT. It was agreed that we can't change the definition for E&IT
as it is based upon Klinger-cohen, and the current language may not be
as sufficient to provide the framework for people to use when making
this determination.

I think if we can define some framework around this it would be an
excellent item to add as supplementary information for use in the next
phases of this process.

Some questions raised have been:

Is medical equipment E&IT? (David Baquis).

Are baggage scanners E&IT? (me). Why or why not.

Is mail handling equipment E&IT? Why or why not.

Is a portable "stud finder" E&It?

Is a security monitor E&It? (think video surveillance).

I tend to look at this on the more relaxed side of things. E&IT may be
included in some much more complicated, and often mechanically-based
mechanisms, but is not the principle function of it. My example would
be mail handling equipment. I'm sure that, for example, a mail handling
system should be keyboard operable if it is operated from a workstation
of some type, but I just don't think this kind of system should be
included.

Terry had some process to this determination that asked if an item was
E&IT and then asked about technical provisions applicability. Is this
the right sequence? For items that have no technical provisions
applicable, does that lead to high degree of "not being E&IT)?

Anyway, some starting points.

Allen Hoffman -- DHS Office on Accessible Systems & Technology

From: Gregg Vanderheiden
Date: Tue, Sep 18 2007 1:05 PM
Subject: Re: E&IT determination

Here is another one.



If a lab computer is E&IT - would it still be E&IT if I attached it to the
front of a refrigerator? Currently our language says no. I think we
need to think about this.



On the other hand we don't want the computer chip in the refrigerator that
controls the temperature to get classified as E&IT.



Maybe something like



If it is the primary function or if it would be functioning E&IT if detached
or if it stood alone..



Don't know. Tough one to create criterion that does not provide a large
loophole or an overbroad net.




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






_____


From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Hoffman, Allen
Sent: Tuesday, September 18, 2007 8:48 AM
To: TEITAC General Interface Accessibility Subcommittee
Subject: Re: [teitac-general] E&IT determination

All:





At the plenary a discussion took place about how to identify what is and
isn't E&IT. It was agreed that we can't change the definition for E&IT as it
is based upon Klinger-cohen, and the current language may not be as
sufficient to provide the framework for people to use when making this
determination.



I think if we can define some framework around this it would be an excellent
item to add as supplementary information for use in the next phases of this
process.



Some questions raised have been:



Is medical equipment E&IT? (David Baquis).



Are baggage scanners E&IT? (me). Why or why not.



Is mail handling equipment E&IT? Why or why not.



Is a portable "stud finder" E&It?



Is a security monitor E&It? (think video surveillance).



I tend to look at this on the more relaxed side of things. E&IT may be
included in some much more complicated, and often mechanically-based
mechanisms, but is not the principle function of it. My example would be
mail handling equipment. I'm sure that, for example, a mail handling system
should be keyboard operable if it is operated from a workstation of some
type, but I just don't think this kind of system should be included.



Terry had some process to this determination that asked if an item was E&IT
and then asked about technical provisions applicability. Is this the right
sequence? For items that have no technical provisions applicable, does that
lead to high degree of "not being E&IT)?



Anyway, some starting points.



Allen Hoffman -- DHS Office on Accessible Systems & Technology

From: Robinson, Norman B - Washington, DC
Date: Wed, Sep 19 2007 7:40 AM
Subject: Re: E&IT determination

For the discussion, I've pulled the actual definitions of E&IT and IT in
below my response.

The question of "Is it E&IT" is always specific to the implementation.
The six example questions:

1.
Is medical equipment E&IT? (David Baquis).
2.
Are baggage scanners E&IT? (me). Why or why not.
3.
Is mail handling equipment E&IT? Why or why not.
4.
Is a portable "stud finder" E&It?
5.
Is a security monitor E&It? (think video surveillance).
6.
If a lab computer is E&IT - would it still be E&IT if I
attached it to the front of a refrigerator? Currently our language
says no.

The question is always a) what data or information is being used and b)
how is it being used? My own opinion is that the definition currently
offered provides a bad illustrative example as HVAC equipment has been
automated and placed on the network for remote management and
monitoring, clearly making it E&IT due to the "interchange,
transmission, or receptions of data".

So, I consider first, is the information self-contained and not
available outside the unit itself? Is the information presented able to
be transmitted? If not, it is possible it doesn't fall within the
definition of E&IT. Otherwise, all bets are off.

Specifically:

1. Medical equipment: I use a heart monitor that plugs into an Ethernet
connection so a doctor can monitor my heart remotely from any computer.
E&IT!
2. Baggage scanners: If the baggage scanner provides notification to the
management of the system that a suspicious package is found, via
automated message over a network. E&IT!
3. Mail handling equipment: (thank you, something I might know something
about!) If it is transmitting data and information, clearly E&IT. We
have and do apply Section 508 compliance to them.
4. A portable "stud finder": I don't think it is E&IT, at least none
that I've seen. But the day one has a blue-tooth interface that
transmits the data to a computer, yes, yes it could be!
5. Security video surveillance camera: Maybe. If is uses the network to
transmit information, that information is usually computer controlled.
If it is the "automated snapshot web cam" of which there are many
products currently available, I would say yes too. This is no different
than traffic cameras - the information about the image itself should be
tagged automatically and provided to the user in an accessible way;
date, time, location identifier for the camera, image name. Not being
able to see the image is no reason the information can't be accessible.
6. E&IT on the front of a refrigerator is E&IT. What language would lead
you to believe Section 508 would NOT apply?

My question is, if Section 508 does not apply, what rights does a person
with a disability have for access to that equipment? And if Section 508
does not apply which technical guidance would you suggest we follow as
best practice?

I hope my email adds and does not detract from the discussion.

Electronic and information technology. Includes information technology
and any equipment or interconnected system or subsystem of equipment,
that is used in the creation, conversion, or duplication of data or
information. The term electronic and information technology includes,
but is not limited to, telecommunications products (such as telephones),
information kiosks and transaction machines, World Wide Web sites,
multimedia, and office equipment such as copiers and fax machines. The
term does not include any equipment that contains embedded information
technology that is used as an integral part of the product, but the
principal function of which is not the acquisition, storage,
manipulation, management, movement, control, display, switching,
interchange, transmission, or reception of data or information. For
example, HVAC (heating, ventilation, and air conditioning) equipment
such as thermostats or temperature control devices, and medical
equipment where information technology is integral to its operation, are
not information technology.

Information technology. Any equipment or interconnected system or
subsystem of equipment, that is used in the automatic acquisition,
storage, manipulation, management, movement, control, display,
switching, interchange, transmission, or reception of data or
information. The term information technology includes computers,
ancillary equipment, software, firmware and similar procedures, services
(including support services), and related resources.

Regards,



Norman B. Robinson
Section 508 Coordinator
IT Governance, US Postal Service
phone: 202.268.8246

-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Hoffman,
Allen
Sent: Tuesday, September 18, 2007 9:48 AM
To: TEITAC General Interface Accessibility Subcommittee
Subject: Re: [teitac-general] E&IT determination


All:


At the plenary a discussion took place about how to identify
what is and isn't E&IT. It was agreed that we can't change the
definition for E&IT as it is based upon Klinger-cohen, and the current
language may not be as sufficient to provide the framework for people to
use when making this determination.

I think if we can define some framework around this it would be
an excellent item to add as supplementary information for use in the
next phases of this process.

Some questions raised have been:

Is medical equipment E&IT? (David Baquis).

Are baggage scanners E&IT? (me). Why or why not.

Is mail handling equipment E&IT? Why or why not.

Is a portable "stud finder" E&It?

Is a security monitor E&It? (think video surveillance).

I tend to look at this on the more relaxed side of things. E&IT
may be included in some much more complicated, and often
mechanically-based mechanisms, but is not the principle function of it.
My example would be mail handling equipment. I'm sure that, for
example, a mail handling system should be keyboard operable if it is
operated from a workstation of some type, but I just don't think this
kind of system should be included.

Terry had some process to this determination that asked if an
item was E&IT and then asked about technical provisions applicability.
Is this the right sequence? For items that have no technical provisions
applicable, does that lead to high degree of "not being E&IT)?

Anyway, some starting points.

Allen Hoffman -- DHS Office on Accessible Systems & Technology

From: Gregg Vanderheiden
Date: Thu, Sep 20 2007 12:00 AM
Subject: Re: E&IT determination

Hi Norman,



The definition of E&IT is not in scope for the General committee.



I think you might post this on the TEITAC committee list.




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






_____


From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Robinson,
Norman B - Washington, DC
Sent: Wednesday, September 19, 2007 8:35 AM
To: TEITAC General Interface Accessibility Subcommittee
Subject: Re: [teitac-general] E&IT determination

For the discussion, I've pulled the actual definitions of E&IT and IT in
below my response.

The question of "Is it E&IT" is always specific to the implementation. The
six example questions:

1. Is medical equipment E&IT? (David Baquis).
2. Are baggage scanners E&IT? (me). Why or why not.
3. Is mail handling equipment E&IT? Why or why not.
4. Is a portable "stud finder" E&It?
5. Is a security monitor E&It? (think video surveillance).
6. If a lab computer is E&IT - would it still be E&IT if I attached it
to the front of a refrigerator? Currently our language says no.

The question is always a) what data or information is being used and b) how
is it being used? My own opinion is that the definition currently offered
provides a bad illustrative example as HVAC equipment has been automated and
placed on the network for remote management and monitoring, clearly making
it E&IT due to the "interchange, transmission, or receptions of data".

So, I consider first, is the information self-contained and not available
outside the unit itself? Is the information presented able to be
transmitted? If not, it is possible it doesn't fall within the definition of
E&IT. Otherwise, all bets are off.

Specifically:

1. Medical equipment: I use a heart monitor that plugs into an Ethernet
connection so a doctor can monitor my heart remotely from any computer.
E&IT!
2. Baggage scanners: If the baggage scanner provides notification to the
management of the system that a suspicious package is found, via automated
message over a network. E&IT!
3. Mail handling equipment: (thank you, something I might know something
about!) If it is transmitting data and information, clearly E&IT. We have
and do apply Section 508 compliance to them.
4. A portable "stud finder": I don't think it is E&IT, at least none that
I've seen. But the day one has a blue-tooth interface that transmits the
data to a computer, yes, yes it could be!
5. Security video surveillance camera: Maybe. If is uses the network to
transmit information, that information is usually computer controlled. If it
is the "automated snapshot web cam" of which there are many products
currently available, I would say yes too. This is no different than traffic
cameras - the information about the image itself should be tagged
automatically and provided to the user in an accessible way; date, time,
location identifier for the camera, image name. Not being able to see the
image is no reason the information can't be accessible.
6. E&IT on the front of a refrigerator is E&IT. What language would lead you
to believe Section 508 would NOT apply?

My question is, if Section 508 does not apply, what rights does a person
with a disability have for access to that equipment? And if Section 508 does
not apply which technical guidance would you suggest we follow as best
practice?

I hope my email adds and does not detract from the discussion.

Electronic and information technology. Includes information technology and
any equipment or interconnected system or subsystem of equipment, that is
used in the creation, conversion, or duplication of data or information. The
term electronic and information technology includes, but is not limited to,
telecommunications products (such as telephones), information kiosks and
transaction machines, World Wide Web sites, multimedia, and office equipment
such as copiers and fax machines. The term does not include any equipment
that contains embedded information technology that is used as an integral
part of the product, but the principal function of which is not the
acquisition, storage, manipulation, management, movement, control, display,
switching, interchange, transmission, or reception of data or information.
For example, HVAC (heating, ventilation, and air conditioning) equipment
such as thermostats or temperature control devices, and medical equipment
where information technology is integral to its operation, are not
information technology.

Information technology. Any equipment or interconnected system or subsystem
of equipment, that is used in the automatic acquisition, storage,
manipulation, management, movement, control, display, switching,
interchange, transmission, or reception of data or information. The term
information technology includes computers, ancillary equipment, software,
firmware and similar procedures, services (including support services), and
related resources.

Regards,



Norman B. Robinson
Section 508 Coordinator
IT Governance, US Postal Service
phone: 202.268.8246

-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Hoffman, Allen
Sent: Tuesday, September 18, 2007 9:48 AM
To: TEITAC General Interface Accessibility Subcommittee
Subject: Re: [teitac-general] E&IT determination

All:





At the plenary a discussion took place about how to identify what is and
isn't E&IT. It was agreed that we can't change the definition for E&IT as it
is based upon Klinger-cohen, and the current language may not be as
sufficient to provide the framework for people to use when making this
determination.



I think if we can define some framework around this it would be an excellent
item to add as supplementary information for use in the next phases of this
process.



Some questions raised have been:



Is medical equipment E&IT? (David Baquis).



Are baggage scanners E&IT? (me). Why or why not.



Is mail handling equipment E&IT? Why or why not.



Is a portable "stud finder" E&It?



Is a security monitor E&It? (think video surveillance).



I tend to look at this on the more relaxed side of things. E&IT may be
included in some much more complicated, and often mechanically-based
mechanisms, but is not the principle function of it. My example would be
mail handling equipment. I'm sure that, for example, a mail handling system
should be keyboard operable if it is operated from a workstation of some
type, but I just don't think this kind of system should be included.



Terry had some process to this determination that asked if an item was E&IT
and then asked about technical provisions applicability. Is this the right
sequence? For items that have no technical provisions applicable, does that
lead to high degree of "not being E&IT)?



Anyway, some starting points.



Allen Hoffman -- DHS Office on Accessible Systems & Technology