Thread Subject: language for the functional performance criteria 1.1-H - Without Physical Contact

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From: Gregg Vanderheiden
Date: Mon, Oct 22 2007 2:30 PM
Subject: language for the functional performance criteria 1.1-H - Without Physical Contact

The following language for the functional performance criteria 1.1-H -
Without Physical Contact was worked out today on the General call.



It is being posted to GENERAL and TEITAC for information and comment.



If desired it can be put into the draft for broad review. We leave that up
to the chairs or TEITAC to determine.




Gregg & Michael
-- ------------------------------
Gregg C Vanderheiden Ph.D.








http://teitac.org/wiki/Monday_10-22-2007_General_telecon#Notes_from_Meeting


1.1-H - Without Physical Contact

Products must provide at least one mode that allows access to all
functionality of the product without requiring any physical contact with the
product beyond initial connection and setup of a special interface device.
This access may be provided directly or through assistive technology.

Note: While it is preferable that no contact at all be required, the use of
a standard physical connection such as a USB would meet this provision.


Rationale and Notes


* A large population of people with physical disabilities cannot reach
out to touch a product or cannot reach out long enough to actually operate a
product physically. The Forrester Study by Microsoft cited people with
physical disabilities as being second only to blindness and low vision as
providing difficulties in using computers.
* Use of cameras to monitor user movement to control input would meet
this provision.
* Allowing users to control the product using their own communication
or control via a universal wireless connection would also meet this
provision.

* ANSI/INCITS URC standard would be one
* Wireless USB would be another solution

* A connection is allowed since it may be necessary. Individuals could
have a companion or bystander connect them and still allow them privacy in
completing the transaction. Methods not requiring any contact or assistance
of course are preferred.

From: Whitney Quesenbery
Date: Mon, Oct 22 2007 2:40 PM
Subject: Re: language for the functional performance criteria 1.1-H - Without Physical Contact

At 03:28 PM 10/22/2007, Gregg Vanderheiden wrote:
>If desired it can be put into the draft for broad review. We leave that
>up to the chairs or TEITAC to determine.

It has been posted in the draft (for 26 Oct), so we can work towards and
from a single document. It is listed as In Progress, for now.

W



Whitney Quesenbery
Whitney Interactive Design
= EMAIL ADDRESS REMOVED =
phone: 908-638-5467
mobile: 908-328-5959
www.WQusability.com
www.usabilityprofessionals.org

"Warning: Objects in the calendar are closer than they appear."

From: Whitney Quesenbery
Date: Mon, Oct 22 2007 2:45 PM
Subject: Re: language for the functional performance criteria 1.1-H - Without Physical Contact

At 03:28 PM 10/22/2007, Gregg Vanderheiden wrote:
>If desired it can be put into the draft for broad review. We leave that
>up to the chairs or TEITAC to determine.

It has been posted in the draft (for 26 Oct), so we can work towards and
from a single document. It is listed as In Progress, for now.

W



Whitney Quesenbery
Whitney Interactive Design
= EMAIL ADDRESS REMOVED =
phone: 908-638-5467
mobile: 908-328-5959
www.WQusability.com
www.usabilityprofessionals.org

"Warning: Objects in the calendar are closer than they appear."

From: Whitney Quesenbery
Date: Mon, Oct 22 2007 2:50 PM
Subject: Re: language for the functional performance criteria 1.1-H - Without Physical Contact

At 03:28 PM 10/22/2007, Gregg Vanderheiden wrote:
>If desired it can be put into the draft for broad review. We leave that
>up to the chairs or TEITAC to determine.

It has been posted in the draft (for 26 Oct), so we can work towards and
from a single document. It is listed as In Progress, for now.

W



Whitney Quesenbery
Whitney Interactive Design
= EMAIL ADDRESS REMOVED =
phone: 908-638-5467
mobile: 908-328-5959
www.WQusability.com
www.usabilityprofessionals.org

"Warning: Objects in the calendar are closer than they appear."

From: Schomburg, Paul
Date: Mon, Oct 22 2007 8:15 PM
Subject: 1.1-H - Without Physical Contact

Greg: I'm struggling to understand how this can be supported by Telecom
or CE products at the present time. It seems to me that many products
would need to be redesigned to support a new interface without knowing
how to interoperate with an unknown interface device. This may be
appropriate for a federal office but it is probably not 'readily
achievable' for consumer telecom products and thus should not be applied
under 255 to all telecom products. I am uncertain what is required to
allow an ANSI/INCITS URC to interoperate.



For CE products, I think the availability of an IR port for remote
controls could enable many CE products to comply, since this interface
is fairly standard for products with a visual user interface (e.g. TVs,
VCR/DVD players/recorders, etc.). Could this be added to your third
bullet under rationale & notes? Some CE products do not have an IR
interface (e.g. audio amplifiers, etc.) but these may not require direct
control by the user beyond initial setup and should be exempted.



Some CE and office products can be controlled via software from a PC
either over a network interface (Ethernet) or via a more direct
connection such as IEEE 1394 or USB interface. I hope these methods
would also comply. Can you confirm that control by PC software that
works with AT is sufficient?



Thanks, Paul

From: Gregg Vanderheiden
Date: Mon, Oct 22 2007 9:30 PM
Subject: Re: 1.1-H - Without Physical Contact

HI Paul,



You might want to direct some of these calls to Randy Marsden. But I can
answer a couple



You asked:

Some CE and office products can be controlled via software from a PC either
over a network interface (Ethernet) or via a more direct connection such as
IEEE 1394 or USB interface. I hope these methods would also comply. Can
you confirm that control by PC software that works with AT is sufficient?

Yes - if the product is usually hooked up to a PC then controlling it via
the PC is not only possible, it is the usual way.





A camera however would not usually be connected to a PC. So that one would
not be able to meet this guideline today. If you had a remote control for
the camera though (say IR) then one could do much that way - though maybe
not all. If you had a URC (universal remote console) connection - it
would meet the provision.



Many CE products have UPnP or other network control methods. Those could
also be used - if AT could control them. We are working on a Universal
Control Hub that would facilitate this as well as AT that would support it.
We were doing it for other reasons but it could help here too.










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






_____


From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Schomburg, Paul
Sent: Monday, October 22, 2007 9:14 PM
To: TEITAC General Interface Accessibility Subcommittee
Cc: Jasionowski, Tony; Schomburg, Paul
Subject: [teitac-general] 1.1-H - Without Physical Contact

Greg: I'm struggling to understand how this can be supported by Telecom or
CE products at the present time. It seems to me that many products would
need to be redesigned to support a new interface without knowing how to
interoperate with an unknown interface device. This may be appropriate for
a federal office but it is probably not 'readily achievable' for consumer
telecom products and thus should not be applied under 255 to all telecom
products. I am uncertain what is required to allow an ANSI/INCITS URC to
interoperate.



For CE products, I think the availability of an IR port for remote controls
could enable many CE products to comply, since this interface is fairly
standard for products with a visual user interface (e.g. TVs, VCR/DVD
players/recorders, etc.). Could this be added to your third bullet under
rationale & notes? Some CE products do not have an IR interface (e.g. audio
amplifiers, etc.) but these may not require direct control by the user
beyond initial setup and should be exempted.



Some CE and office products can be controlled via software from a PC either
over a network interface (Ethernet) or via a more direct connection such as
IEEE 1394 or USB interface. I hope these methods would also comply. Can
you confirm that control by PC software that works with AT is sufficient?



Thanks, Paul




_____


From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Gregg
Vanderheiden
Sent: Monday, October 22, 2007 3:35 PM
To: 'TEITAC Committee'; 'TEITAC General Interface Accessibility
Subcommittee'
Subject: [teitac-committee] FW: Sorry I missed the meeting...posting...



The following language for the functional performance criteria 1.1-H -
Without Physical Contact was worked out today on the General call.



It is being posted to GENERAL and TEITAC for information and comment.



If desired it can be put into the draft for broad review. We leave that up
to the chairs or TEITAC to determine.




Gregg & Michael
-- ------------------------------
Gregg C Vanderheiden Ph.D.








http://teitac.org/wiki/Monday_10-22-2007_General_telecon#Notes_from_Meeting


1.1-H - Without Physical Contact

Products must provide at least one mode that allows access to all
functionality of the product without requiring any physical contact with the
product beyond initial connection and setup of a special interface device.
This access may be provided directly or through assistive technology.

Note: While it is preferable that no contact at all be required, the use of
a standard physical connection such as a USB would meet this provision.


Rationale and Notes


* A large population of people with physical disabilities cannot reach
out to touch a product or cannot reach out long enough to actually operate a
product physically. The Forrester Study by Microsoft cited people with
physical disabilities as being second only to blindness and low vision as
providing difficulties in using computers.
* Use of cameras to monitor user movement to control input would meet
this provision.
* Allowing users to control the product using their own communication
or control via a universal wireless connection would also meet this
provision.

* ANSI/INCITS URC standard would be one
* Wireless USB would be another solution

* A connection is allowed since it may be necessary. Individuals could
have a companion or bystander connect them and still allow them privacy in
completing the transaction. Methods not requiring any contact or assistance
of course are preferred.

From: Schomburg, Paul
Date: Mon, Oct 29 2007 5:05 PM
Subject: Re: 1.1-H - Without Physical Contact

Folks: I think this provision as drafted is confusing, incomplete and
requires more in-depth discussion. My primary concern is that the
existence of a network interface by itself does not provide access to
"all the features of the product" and thus by itself cannot assure
accessibility. With regard to the specific solutions sited by Greg
Vanderheiden, I don't know of any commercial off-the-shelf product that
is compatible with the ANSI/INCITS URC standard and thus doubt it is a
practical solution at this time. I also don't believe that the "use of
cameras to monitor user movement to control input would meet this
provision" since such a method of control is not a product feature a
manufacturer could incorporate into the product itself.



Rather than apply this to all E&IT products, these requirements should
only be applied to products with a visual interface that could be
accessed from across a network. I would need further explanations or
examples for how E&IT products without a visual interface could comply
to be comfortable with applying this to all E&IT products. To be
proactive here are some suggestions for a new version, but there may be
other parties that also need to weigh in with their views:



1.1-H - Without Physical Contact

Products with a visual interface must provide at least one mode that
allows the product to be accessible for people with disabilities with
only minimal physical contact with the product such as power-on,
initialization of a call, change of a mode of operation, or initial
connection and setup of a special interface device. This access may be
provided directly or through assistive technology.



Rationale and Notes

* It is well known that a large population of people with physical
disabilities cannot reach out to touch a product or cannot reach out
long enough to actually operate a product physically.
* While it is preferable that no contact at all be required, some
physical contact may be needed to turn power on, initialize a telephone
call or change mode of operation. In some cases it may be required for
the user to be assisted by a companion or bystander with these
operations.
* Assistive Technology examples:

* The use of a standard network interface (e.g. USB,
Ethernet, IEEE 1394, Wi-Fi, Bluetooth, etc.) that allows users to
control the product using software via a wired or wireless network
connection would meet this provision.
* The use of the infra-red ("IR") port used for remote
controls in consumer electronics products would meet this provision.

* Direct Access examples:

* Voice dialing is an example of direct access. Access to
voice dialing may require physical contact with the product to initiate
the call or change mode of operation to enable voice dialing.



Best regards, Paul

From: Randy Marsden
Date: Mon, Oct 29 2007 6:10 PM
Subject: Re: 1.1-H - Without Physical Contact

Paul:

The intent here is to make sure people with physical disabilities
(think Christopher Reeve) can access a product ( the same as someone
who is blind, deaf, etc). Restricting it to only products with a
visual interface doesn't seem like the fair solution, since we don't
make that restriction for other types of disabilities.

Remember: most IT devices that have standard connections (such as
BlueTooth, USB ports, etc) would comply with this FPC, since there is
an abundance of AT that could plug into them (well, and at least an
abundance of USB-based AT - BlueTooth AT is slowing emerging).

So, the main hurdle, I think, is what to do about Closed systems
(either by choice or design) that don't have any standard connections
to which AT can plug into. For such systems, there is no doubt that
some sort of add-on technology would need to be incorporated, just as
it is now for people who are blind, etc.

A final note: we acknowledged during our discussions to date that
meeting this provision may be technically more difficult today than
the other types of disabilities, for closed systems. But that is
primarily because it hasn't been considered in the past, and so no-
one has built solutions for it. By including it now, we show the
intent to move toward accommodating these folks. If we leave it off
(like last time), I doubt any work will be pursued to accommodate
them and in five years, we'll be saying the same thing. There is
always the undue burden clause if it truly is not technically or
feasibly possible. But I believe that keeping it in the FPC provides
a nudge in the right direction.

-Randy Marsden
Assistive Technology Industry Association


On Oct 29, 2007, at 5:00 PM, Schomburg, Paul wrote:

> Folks: I think this provision as drafted is confusing, incomplete
> and requires more in-depth discussion. My primary concern is that
> the existence of a network interface by itself does not provide
> access to “all the features of the product” and thus by itself
> cannot assure accessibility. With regard to the specific solutions
> sited by Greg Vanderheiden, I don’t know of any commercial off-the-
> shelf product that is compatible with the ANSI/INCITS URC standard
> and thus doubt it is a practical solution at this time. I also
> don’t believe that the “use of cameras to monitor user movement to
> control input would meet this provision” since such a method of
> control is not a product feature a manufacturer could incorporate
> into the product itself.
>
>
>
> Rather than apply this to all E&IT products, these requirements
> should only be applied to products with a visual interface that
> could be accessed from across a network. I would need further
> explanations or examples for how E&IT products without a visual
> interface could comply to be comfortable with applying this to all
> E&IT products. To be proactive here are some suggestions for a new
> version, but there may be other parties that also need to weigh in
> with their views:
>
>
>
> 1.1-H - Without Physical Contact
>
> Products with a visual interface must provide at least one mode
> that allows the product to be accessible for people with
> disabilities with only minimal physical contact with the product
> such as power-on, initialization of a call, change of a mode of
> operation, or initial connection and setup of a special interface
> device. This access may be provided directly or through assistive
> technology.
>
>
>
> Rationale and Notes
>
> It is well known that a large population of people with physical
> disabilities cannot reach out to touch a product or cannot reach
> out long enough to actually operate a product physically.
> While it is preferable that no contact at all be required, some
> physical contact may be needed to turn power on, initialize a
> telephone call or change mode of operation. In some cases it may
> be required for the user to be assisted by a companion or bystander
> with these operations.
> Assistive Technology examples:
> The use of a standard network interface (e.g. USB, Ethernet, IEEE
> 1394, Wi-Fi, Bluetooth, etc.) that allows users to control the
> product using software via a wired or wireless network connection
> would meet this provision.
> The use of the infra-red (“IR”) port used for remote controls in
> consumer electronics products would meet this provision.
> Direct Access examples:
> Voice dialing is an example of direct access. Access to voice
> dialing may require physical contact with the product to initiate
> the call or change mode of operation to enable voice dialing.
>
>
> Best regards, Paul
>
>
>
> From: Schomburg, Paul
> Sent: Monday, October 22, 2007 10:14 PM
> To: 'TEITAC General Interface Accessibility Subcommittee'
> Cc: Jasionowski, Tony; Schomburg, Paul
> Subject: 1.1-H - Without Physical Contact
>
>
>
> Greg: I’m struggling to understand how this can be supported by
> Telecom or CE products at the present time. It seems to me that
> many products would need to be redesigned to support a new
> interface without knowing how to interoperate with an unknown
> interface device. This may be appropriate for a federal office but
> it is probably not ‘readily achievable’ for consumer telecom
> products and thus should not be applied under 255 to all telecom
> products. I am uncertain what is required to allow an ANSI/INCITS
> URC to interoperate.
>
>
>
> For CE products, I think the availability of an IR port for remote
> controls could enable many CE products to comply, since this
> interface is fairly standard for products with a visual user
> interface (e.g. TVs, VCR/DVD players/recorders, etc.). Could this
> be added to your third bullet under rationale & notes? Some CE
> products do not have an IR interface (e.g. audio amplifiers, etc.)
> but these may not require direct control by the user beyond initial
> setup and should be exempted.
>
>
>
> Some CE and office products can be controlled via software from a
> PC either over a network interface (Ethernet) or via a more direct
> connection such as IEEE 1394 or USB interface. I hope these
> methods would also comply. Can you confirm that control by PC
> software that works with AT is sufficient?
>
>
>
> Thanks, Paul
>
>
>
> From: = EMAIL ADDRESS REMOVED = [mailto:teitac-
> = EMAIL ADDRESS REMOVED = ] On Behalf Of Gregg Vanderheiden
> Sent: Monday, October 22, 2007 3:35 PM
> To: 'TEITAC Committee'; 'TEITAC General Interface Accessibility
> Subcommittee'
> Subject: [teitac-committee] FW: Sorry I missed the
> meeting...posting...
>
>
>
> The following language for the functional performance criteria 1.1-
> H - Without Physical Contact was worked out today on the General
> call.
>
>
>
> It is being posted to GENERAL and TEITAC for information and comment.
>
>
>
> If desired it can be put into the draft for broad review. We
> leave that up to the chairs or TEITAC to determine.
>
>
>
>
> Gregg & Michael
> -- ------------------------------
> Gregg C Vanderheiden Ph.D.
>
>
>
>
>
>
>
>
> http://teitac.org/wiki/
> Monday_10-22-2007_General_telecon#Notes_from_Meeting
>
>
> 1.1-H - Without Physical Contact
>
> Products must provide at least one mode that allows access to all
> functionality of the product without requiring any physical contact
> with the product beyond initial connection and setup of a special
> interface device. This access may be provided directly or through
> assistive technology.
>
> Note: While it is preferable that no contact at all be required,
> the use of a standard physical connection such as a USB would meet
> this provision.
>
> Rationale and Notes
>
> A large population of people with physical disabilities cannot
> reach out to touch a product or cannot reach out long enough to
> actually operate a product physically. The Forrester Study by
> Microsoft cited people with physical disabilities as being second
> only to blindness and low vision as providing difficulties in using
> computers.
> Use of cameras to monitor user movement to control input would meet
> this provision.
> Allowing users to control the product using their own communication
> or control via a universal wireless connection would also meet this
> provision.
> ANSI/INCITS URC standard would be one
> Wireless USB would be another solution
> A connection is allowed since it may be necessary. Individuals
> could have a companion or bystander connect them and still allow
> them privacy in completing the transaction. Methods not requiring
> any contact or assistance of course are preferred.
>
>
>

From: Randy Marsden
Date: Mon, Oct 29 2007 6:15 PM
Subject: Re: 1.1-H - Without Physical Contact

Paul:

The intent here is to make sure people with physical disabilities
(think Christopher Reeve) can access a product ( the same as someone
who is blind, deaf, etc). Restricting it to only products with a
visual interface doesn't seem like the fair solution, since we don't
make that restriction for other types of disabilities.

Remember: most IT devices that have standard connections (such as
BlueTooth, USB ports, etc) would comply with this FPC, since there is
an abundance of AT that could plug into them (well, and at least an
abundance of USB-based AT - BlueTooth AT is slowing emerging).

So, the main hurdle, I think, is what to do about Closed systems
(either by choice or design) that don't have any standard connections
to which AT can plug into. For such systems, there is no doubt that
some sort of add-on technology would need to be incorporated, just as
it is now for people who are blind, etc.

A final note: we acknowledged during our discussions to date that
meeting this provision may be technically more difficult today than
the other types of disabilities, for closed systems. But that is
primarily because it hasn't been considered in the past, and so no-
one has built solutions for it. By including it now, we show the
intent to move toward accommodating these folks. If we leave it off
(like last time), I doubt any work will be pursued to accommodate
them and in five years, we'll be saying the same thing. There is
always the undue burden clause if it truly is not technically or
feasibly possible. But I believe that keeping it in the FPC provides
a nudge in the right direction.

-Randy Marsden
Assistive Technology Industry Association


On Oct 29, 2007, at 5:00 PM, Schomburg, Paul wrote:

> Folks: I think this provision as drafted is confusing, incomplete
> and requires more in-depth discussion. My primary concern is that
> the existence of a network interface by itself does not provide
> access to “all the features of the product” and thus by itself
> cannot assure accessibility. With regard to the specific solutions
> sited by Greg Vanderheiden, I don’t know of any commercial off-the-
> shelf product that is compatible with the ANSI/INCITS URC standard
> and thus doubt it is a practical solution at this time. I also
> don’t believe that the “use of cameras to monitor user movement to
> control input would meet this provision” since such a method of
> control is not a product feature a manufacturer could incorporate
> into the product itself.
>
>
>
> Rather than apply this to all E&IT products, these requirements
> should only be applied to products with a visual interface that
> could be accessed from across a network. I would need further
> explanations or examples for how E&IT products without a visual
> interface could comply to be comfortable with applying this to all
> E&IT products. To be proactive here are some suggestions for a new
> version, but there may be other parties that also need to weigh in
> with their views:
>
>
>
> 1.1-H - Without Physical Contact
>
> Products with a visual interface must provide at least one mode
> that allows the product to be accessible for people with
> disabilities with only minimal physical contact with the product
> such as power-on, initialization of a call, change of a mode of
> operation, or initial connection and setup of a special interface
> device. This access may be provided directly or through assistive
> technology.
>
>
>
> Rationale and Notes
>
> It is well known that a large population of people with physical
> disabilities cannot reach out to touch a product or cannot reach
> out long enough to actually operate a product physically.
> While it is preferable that no contact at all be required, some
> physical contact may be needed to turn power on, initialize a
> telephone call or change mode of operation. In some cases it may
> be required for the user to be assisted by a companion or bystander
> with these operations.
> Assistive Technology examples:
> The use of a standard network interface (e.g. USB, Ethernet, IEEE
> 1394, Wi-Fi, Bluetooth, etc.) that allows users to control the
> product using software via a wired or wireless network connection
> would meet this provision.
> The use of the infra-red (“IR”) port used for remote controls in
> consumer electronics products would meet this provision.
> Direct Access examples:
> Voice dialing is an example of direct access. Access to voice
> dialing may require physical contact with the product to initiate
> the call or change mode of operation to enable voice dialing.
>
>
> Best regards, Paul
>
>
>
> From: Schomburg, Paul
> Sent: Monday, October 22, 2007 10:14 PM
> To: 'TEITAC General Interface Accessibility Subcommittee'
> Cc: Jasionowski, Tony; Schomburg, Paul
> Subject: 1.1-H - Without Physical Contact
>
>
>
> Greg: I’m struggling to understand how this can be supported by
> Telecom or CE products at the present time. It seems to me that
> many products would need to be redesigned to support a new
> interface without knowing how to interoperate with an unknown
> interface device. This may be appropriate for a federal office but
> it is probably not ‘readily achievable’ for consumer telecom
> products and thus should not be applied under 255 to all telecom
> products. I am uncertain what is required to allow an ANSI/INCITS
> URC to interoperate.
>
>
>
> For CE products, I think the availability of an IR port for remote
> controls could enable many CE products to comply, since this
> interface is fairly standard for products with a visual user
> interface (e.g. TVs, VCR/DVD players/recorders, etc.). Could this
> be added to your third bullet under rationale & notes? Some CE
> products do not have an IR interface (e.g. audio amplifiers, etc.)
> but these may not require direct control by the user beyond initial
> setup and should be exempted.
>
>
>
> Some CE and office products can be controlled via software from a
> PC either over a network interface (Ethernet) or via a more direct
> connection such as IEEE 1394 or USB interface. I hope these
> methods would also comply. Can you confirm that control by PC
> software that works with AT is sufficient?
>
>
>
> Thanks, Paul
>
>
>
> From: = EMAIL ADDRESS REMOVED = [mailto:teitac-
> = EMAIL ADDRESS REMOVED = ] On Behalf Of Gregg Vanderheiden
> Sent: Monday, October 22, 2007 3:35 PM
> To: 'TEITAC Committee'; 'TEITAC General Interface Accessibility
> Subcommittee'
> Subject: [teitac-committee] FW: Sorry I missed the
> meeting...posting...
>
>
>
> The following language for the functional performance criteria 1.1-
> H - Without Physical Contact was worked out today on the General
> call.
>
>
>
> It is being posted to GENERAL and TEITAC for information and comment.
>
>
>
> If desired it can be put into the draft for broad review. We
> leave that up to the chairs or TEITAC to determine.
>
>
>
>
> Gregg & Michael
> -- ------------------------------
> Gregg C Vanderheiden Ph.D.
>
>
>
>
>
>
>
>
> http://teitac.org/wiki/
> Monday_10-22-2007_General_telecon#Notes_from_Meeting
>
>
> 1.1-H - Without Physical Contact
>
> Products must provide at least one mode that allows access to all
> functionality of the product without requiring any physical contact
> with the product beyond initial connection and setup of a special
> interface device. This access may be provided directly or through
> assistive technology.
>
> Note: While it is preferable that no contact at all be required,
> the use of a standard physical connection such as a USB would meet
> this provision.
>
> Rationale and Notes
>
> A large population of people with physical disabilities cannot
> reach out to touch a product or cannot reach out long enough to
> actually operate a product physically. The Forrester Study by
> Microsoft cited people with physical disabilities as being second
> only to blindness and low vision as providing difficulties in using
> computers.
> Use of cameras to monitor user movement to control input would meet
> this provision.
> Allowing users to control the product using their own communication
> or control via a universal wireless connection would also meet this
> provision.
> ANSI/INCITS URC standard would be one
> Wireless USB would be another solution
> A connection is allowed since it may be necessary. Individuals
> could have a companion or bystander connect them and still allow
> them privacy in completing the transaction. Methods not requiring
> any contact or assistance of course are preferred.
>
>
>

From: Schomburg, Paul
Date: Tue, Oct 30 2007 9:00 AM
Subject: Re: 1.1-H - Without Physical Contact

Randy: Thanks for this explanation. Compatibility with AT is a worthy goal but one that requires more discussion.

I understand your concern about restricting this section to products with a visual interface. It was not my intent to restrict access for a kind of disability but to limit the requirement to a set of products with more advanced capabilities. I would be open to any suggested edits that would exempt basic telecom, CE devices or closed products from a requirement to add a USB port or other network connection.

In the IT world USB may be common, but this is certainly not the case for CE or Telecom products. I am also skeptical that a 'common' interface by itself is enough to allow AT to control the product. Some products may use the USB port to access only a limited set of functions to support a particular operation of the product, such as file tranfer. For example, Telecom products often use Bluetooth only for connecting to a earbud or to transfer address book data. Because of this limited functionality, Bluetooth by itself does not ensure access to all the features of the phone.

To make this proposal work, Manufacturers would have to define protocols to expose the functions of the product through a standard interface to the AT. Requiring this would likely entail a complete redesign of many products. This burden would have to work with an unknown AT, which may or may not ever become available, and thus could not be tested.

I think it would also be impractical for AT vendors to try to develop a device or software that could interface with many different protocols in many variations of different manufacturers' phones. Therefore, it also seems unnecessary to burden all phones with this requirement under Sec. 255.

Thanks, Paul


-----Original Message-----
From: Randy Marsden [mailto: = EMAIL ADDRESS REMOVED = ]
Sent: Mon 10/29/2007 8:08 PM
To: TEITAC General Interface Accessibility Subcommittee
Cc: TEITAC Committee; Schomburg, Paul
Subject: Re: [teitac-general] 1.1-H - Without Physical Contact

Paul:

The intent here is to make sure people with physical disabilities (think Christopher Reeve) can access a product ( the same as someone who is blind, deaf, etc). Restricting it to only products with a visual interface doesn't seem like the fair solution, since we don't make that restriction for other types of disabilities.

Remember: most IT devices that have standard connections (such as BlueTooth, USB ports, etc) would comply with this FPC, since there is an abundance of AT that could plug into them (well, and at least an abundance of USB-based AT - BlueTooth AT is slowing emerging).

So, the main hurdle, I think, is what to do about Closed systems (either by choice or design) that don't have any standard connections to which AT can plug into. For such systems, there is no doubt that some sort of add-on technology would need to be incorporated, just as it is now for people who are blind, etc.

A final note: we acknowledged during our discussions to date that meeting this provision may be technically more difficult today than the other types of disabilities, for closed systems. But that is primarily because it hasn't been considered in the past, and so no-one has built solutions for it. By including it now, we show the intent to move toward accommodating these folks. If we leave it off (like last time), I doubt any work will be pursued to accommodate them and in five years, we'll be saying the same thing. There is always the undue burden clause if it truly is not technically or feasibly possible. But I believe that keeping it in the FPC provides a nudge in the right direction.

-Randy Marsden
Assistive Technology Industry Association


On Oct 29, 2007, at 5:00 PM, Schomburg, Paul wrote:


Folks: I think this provision as drafted is confusing, incomplete and requires more in-depth discussion. My primary concern is that the existence of a network interface by itself does not provide access to "all the features of the product" and thus by itself cannot assure accessibility. With regard to the specific solutions sited by Greg Vanderheiden, I don't know of any commercial off-the-shelf product that is compatible with the ANSI/INCITS URC standard and thus doubt it is a practical solution at this time. I also don't believe that the "use of cameras to monitor user movement to control input would meet this provision" since such a method of control is not a product feature a manufacturer could incorporate into the product itself.



Rather than apply this to all E&IT products, these requirements should only be applied to products with a visual interface that could be accessed from across a network. I would need further explanations or examples for how E&IT products without a visual interface could comply to be comfortable with applying this to all E&IT products. To be proactive here are some suggestions for a new version, but there may be other parties that also need to weigh in with their views:



1.1-H - Without Physical Contact

Products with a visual interface must provide at least one mode that allows the product to be accessible for people with disabilities with only minimal physical contact with the product such as power-on, initialization of a call, change of a mode of operation, or initial connection and setup of a special interface device. This access may be provided directly or through assistive technology.



Rationale and Notes

* It is well known that a large population of people with physical disabilities cannot reach out to touch a product or cannot reach out long enough to actually operate a product physically.
* While it is preferable that no contact at all be required, some physical contact may be needed to turn power on, initialize a telephone call or change mode of operation. In some cases it may be required for the user to be assisted by a companion or bystander with these operations.
* Assistive Technology examples:

* The use of a standard network interface (e.g. USB, Ethernet, IEEE 1394, Wi-Fi, Bluetooth, etc.) that allows users to control the product using software via a wired or wireless network connection would meet this provision.
* The use of the infra-red ("IR") port used for remote controls in consumer electronics products would meet this provision.

* Direct Access examples:

* Voice dialing is an example of direct access. Access to voice dialing may require physical contact with the product to initiate the call or change mode of operation to enable voice dialing.



Best regards, Paul




_____


From: Schomburg, Paul
Sent: Monday, October 22, 2007 10:14 PM
To: 'TEITAC General Interface Accessibility Subcommittee'
Cc: Jasionowski, Tony; Schomburg, Paul
Subject: 1.1-H - Without Physical Contact



Greg: I'm struggling to understand how this can be supported by Telecom or CE products at the present time. It seems to me that many products would need to be redesigned to support a new interface without knowing how to interoperate with an unknown interface device. This may be appropriate for a federal office but it is probably not 'readily achievable' for consumer telecom products and thus should not be applied under 255 to all telecom products. I am uncertain what is required to allow an ANSI/INCITS URC to interoperate.



For CE products, I think the availability of an IR port for remote controls could enable many CE products to comply, since this interface is fairly standard for products with a visual user interface (e.g. TVs, VCR/DVD players/recorders, etc.). Could this be added to your third bullet under rationale & notes? Some CE products do not have an IR interface (e.g. audio amplifiers, etc.) but these may not require direct control by the user beyond initial setup and should be exempted.



Some CE and office products can be controlled via software from a PC either over a network interface (Ethernet) or via a more direct connection such as IEEE 1394 or USB interface. I hope these methods would also comply. Can you confirm that control by PC software that works with AT is sufficient?



Thanks, Paul




_____


From: = EMAIL ADDRESS REMOVED = [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Gregg Vanderheiden
Sent: Monday, October 22, 2007 3:35 PM
To: 'TEITAC Committee'; 'TEITAC General Interface Accessibility Subcommittee'
Subject: [teitac-committee] FW: Sorry I missed the meeting...posting...



The following language for the functional performance criteria 1.1-H - Without Physical Contact was worked out today on the General call.



It is being posted to GENERAL and TEITAC for information and comment.



If desired it can be put into the draft for broad review. We leave that up to the chairs or TEITAC to determine.




Gregg & Michael
-- ------------------------------
Gregg C Vanderheiden Ph.D.








http://teitac.org/wiki/Monday_10-22-2007_General_telecon#Notes_from_Meeting


1.1-H - Without Physical Contact

Products must provide at least one mode that allows access to all functionality of the product without requiring any physical contact with the product beyond initial connection and setup of a special interface device. This access may be provided directly or through assistive technology.

Note: While it is preferable that no contact at all be required, the use of a standard physical connection such as a USB would meet this provision.


Rationale and Notes


* A large population of people with physical disabilities cannot reach out to touch a product or cannot reach out long enough to actually operate a product physically. The Forrester Study by Microsoft cited people with physical disabilities as being second only to blindness and low vision as providing difficulties in using computers.
* Use of cameras to monitor user movement to control input would meet this provision.
* Allowing users to control the product using their own communication or control via a universal wireless connection would also meet this provision.

* ANSI/INCITS URC standard would be one
* Wireless USB would be another solution

* A connection is allowed since it may be necessary. Individuals could have a companion or bystander connect them and still allow them privacy in completing the transaction. Methods not requiring any contact or assistance of course are preferred.

From: Schomburg, Paul
Date: Tue, Oct 30 2007 9:05 AM
Subject: Re: 1.1-H - Without Physical Contact

Randy: Thanks for this explanation. Compatibility with AT is a worthy goal but one that requires more discussion.

I understand your concern about restricting this section to products with a visual interface. It was not my intent to restrict access for a kind of disability but to limit the requirement to a set of products with more advanced capabilities. I would be open to any suggested edits that would exempt basic telecom, CE devices or closed products from a requirement to add a USB port or other network connection.

In the IT world USB may be common, but this is certainly not the case for CE or Telecom products. I am also skeptical that a 'common' interface by itself is enough to allow AT to control the product. Some products may use the USB port to access only a limited set of functions to support a particular operation of the product, such as file tranfer. For example, Telecom products often use Bluetooth only for connecting to a earbud or to transfer address book data. Because of this limited functionality, Bluetooth by itself does not ensure access to all the features of the phone.

To make this proposal work, Manufacturers would have to define protocols to expose the functions of the product through a standard interface to the AT. Requiring this would likely entail a complete redesign of many products. This burden would have to work with an unknown AT, which may or may not ever become available, and thus could not be tested.

I think it would also be impractical for AT vendors to try to develop a device or software that could interface with many different protocols in many variations of different manufacturers' phones. Therefore, it also seems unnecessary to burden all phones with this requirement under Sec. 255.

Thanks, Paul


-----Original Message-----
From: Randy Marsden [mailto: = EMAIL ADDRESS REMOVED = ]
Sent: Mon 10/29/2007 8:08 PM
To: TEITAC General Interface Accessibility Subcommittee
Cc: TEITAC Committee; Schomburg, Paul
Subject: Re: [teitac-general] 1.1-H - Without Physical Contact

Paul:

The intent here is to make sure people with physical disabilities (think Christopher Reeve) can access a product ( the same as someone who is blind, deaf, etc). Restricting it to only products with a visual interface doesn't seem like the fair solution, since we don't make that restriction for other types of disabilities.

Remember: most IT devices that have standard connections (such as BlueTooth, USB ports, etc) would comply with this FPC, since there is an abundance of AT that could plug into them (well, and at least an abundance of USB-based AT - BlueTooth AT is slowing emerging).

So, the main hurdle, I think, is what to do about Closed systems (either by choice or design) that don't have any standard connections to which AT can plug into. For such systems, there is no doubt that some sort of add-on technology would need to be incorporated, just as it is now for people who are blind, etc.

A final note: we acknowledged during our discussions to date that meeting this provision may be technically more difficult today than the other types of disabilities, for closed systems. But that is primarily because it hasn't been considered in the past, and so no-one has built solutions for it. By including it now, we show the intent to move toward accommodating these folks. If we leave it off (like last time), I doubt any work will be pursued to accommodate them and in five years, we'll be saying the same thing. There is always the undue burden clause if it truly is not technically or feasibly possible. But I believe that keeping it in the FPC provides a nudge in the right direction.

-Randy Marsden
Assistive Technology Industry Association


On Oct 29, 2007, at 5:00 PM, Schomburg, Paul wrote:


Folks: I think this provision as drafted is confusing, incomplete and requires more in-depth discussion. My primary concern is that the existence of a network interface by itself does not provide access to "all the features of the product" and thus by itself cannot assure accessibility. With regard to the specific solutions sited by Greg Vanderheiden, I don't know of any commercial off-the-shelf product that is compatible with the ANSI/INCITS URC standard and thus doubt it is a practical solution at this time. I also don't believe that the "use of cameras to monitor user movement to control input would meet this provision" since such a method of control is not a product feature a manufacturer could incorporate into the product itself.



Rather than apply this to all E&IT products, these requirements should only be applied to products with a visual interface that could be accessed from across a network. I would need further explanations or examples for how E&IT products without a visual interface could comply to be comfortable with applying this to all E&IT products. To be proactive here are some suggestions for a new version, but there may be other parties that also need to weigh in with their views:



1.1-H - Without Physical Contact

Products with a visual interface must provide at least one mode that allows the product to be accessible for people with disabilities with only minimal physical contact with the product such as power-on, initialization of a call, change of a mode of operation, or initial connection and setup of a special interface device. This access may be provided directly or through assistive technology.



Rationale and Notes

* It is well known that a large population of people with physical disabilities cannot reach out to touch a product or cannot reach out long enough to actually operate a product physically.
* While it is preferable that no contact at all be required, some physical contact may be needed to turn power on, initialize a telephone call or change mode of operation. In some cases it may be required for the user to be assisted by a companion or bystander with these operations.
* Assistive Technology examples:

* The use of a standard network interface (e.g. USB, Ethernet, IEEE 1394, Wi-Fi, Bluetooth, etc.) that allows users to control the product using software via a wired or wireless network connection would meet this provision.
* The use of the infra-red ("IR") port used for remote controls in consumer electronics products would meet this provision.

* Direct Access examples:

* Voice dialing is an example of direct access. Access to voice dialing may require physical contact with the product to initiate the call or change mode of operation to enable voice dialing.



Best regards, Paul




_____


From: Schomburg, Paul
Sent: Monday, October 22, 2007 10:14 PM
To: 'TEITAC General Interface Accessibility Subcommittee'
Cc: Jasionowski, Tony; Schomburg, Paul
Subject: 1.1-H - Without Physical Contact



Greg: I'm struggling to understand how this can be supported by Telecom or CE products at the present time. It seems to me that many products would need to be redesigned to support a new interface without knowing how to interoperate with an unknown interface device. This may be appropriate for a federal office but it is probably not 'readily achievable' for consumer telecom products and thus should not be applied under 255 to all telecom products. I am uncertain what is required to allow an ANSI/INCITS URC to interoperate.



For CE products, I think the availability of an IR port for remote controls could enable many CE products to comply, since this interface is fairly standard for products with a visual user interface (e.g. TVs, VCR/DVD players/recorders, etc.). Could this be added to your third bullet under rationale & notes? Some CE products do not have an IR interface (e.g. audio amplifiers, etc.) but these may not require direct control by the user beyond initial setup and should be exempted.



Some CE and office products can be controlled via software from a PC either over a network interface (Ethernet) or via a more direct connection such as IEEE 1394 or USB interface. I hope these methods would also comply. Can you confirm that control by PC software that works with AT is sufficient?



Thanks, Paul




_____


From: = EMAIL ADDRESS REMOVED = [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Gregg Vanderheiden
Sent: Monday, October 22, 2007 3:35 PM
To: 'TEITAC Committee'; 'TEITAC General Interface Accessibility Subcommittee'
Subject: [teitac-committee] FW: Sorry I missed the meeting...posting...



The following language for the functional performance criteria 1.1-H - Without Physical Contact was worked out today on the General call.



It is being posted to GENERAL and TEITAC for information and comment.



If desired it can be put into the draft for broad review. We leave that up to the chairs or TEITAC to determine.




Gregg & Michael
-- ------------------------------
Gregg C Vanderheiden Ph.D.








http://teitac.org/wiki/Monday_10-22-2007_General_telecon#Notes_from_Meeting


1.1-H - Without Physical Contact

Products must provide at least one mode that allows access to all functionality of the product without requiring any physical contact with the product beyond initial connection and setup of a special interface device. This access may be provided directly or through assistive technology.

Note: While it is preferable that no contact at all be required, the use of a standard physical connection such as a USB would meet this provision.


Rationale and Notes


* A large population of people with physical disabilities cannot reach out to touch a product or cannot reach out long enough to actually operate a product physically. The Forrester Study by Microsoft cited people with physical disabilities as being second only to blindness and low vision as providing difficulties in using computers.
* Use of cameras to monitor user movement to control input would meet this provision.
* Allowing users to control the product using their own communication or control via a universal wireless connection would also meet this provision.

* ANSI/INCITS URC standard would be one
* Wireless USB would be another solution

* A connection is allowed since it may be necessary. Individuals could have a companion or bystander connect them and still allow them privacy in completing the transaction. Methods not requiring any contact or assistance of course are preferred.

WebAIM is an initiative of:
Center for Persons with Disabilities (CPD) Utah State University