Thread Subject: View Point Opinion: <Functional Performance Criteria>

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From: Jasionowski, Tony
Date: Thu, Mar 27 2008 8:55 AM
Subject: View Point Opinion: <Functional Performance Criteria>

Comments on the Functional Performance Criteria




Panasonic supports the goal of the functional performance criteria to
providing access to E&IT and telecommunications products where there are
no specific technical criteria defined. It is our view that access to
"all functionality", as all the FPC criteria are currently drafted, is
too broad and too undefined to be useful or readily achievable. The
functional criteria should only require accessibility necessary to
operate the product, and should exclude functions like turning on
electrical power, changing consumables, initial configuration or
configuration changes, set-up and maintenance.



For telecommunications products, Section 255 requires a product to be
accessible to and useable by persons with disabilities unless readily
achievable. Only in the case it is not readily achievable to provide
direct accessibility is the manufacturer required to "ensure that the
equipment or software is compatible with existing peripheral devices or
specialized customer premises equipment commonly used by individuals
with disabilities to achieve access, if readily achievable." Under
Section 255, the scope of this provision is limited by U.S. statute to
only information that is needed for operation and use the
telecommunications functions of the product.



Tony Jasionowski

Senior Group Manager Accessibility

Panasonic Corporation of North America (PNA)

Technology Liaison & Alliances Group (TLAG)

1E-6

One Panasonic Way

Secaucus, New Jersey 07094

Tel.: 201-348-7777

Fax: 201-348-7807

" = EMAIL ADDRESS REMOVED = " (new)

"www.panasonic.com"