Thread Subject: Requirements for telephone amplification

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From: Michaelis, Paul R (Paul)
Date: Mon, Nov 06 2006 4:19 PM
Subject: Requirements for telephone amplification

During the recently concluded telecom conference call, we discussed the
requirement in 1194.23(f) that phones be able to provide 20+ dB of
amplification. For most wired phones, this degree of amplification is
achievable without distortion only when the standard handset is replaced
with a handset that contains a special-purpose amplifier and
special-purpose transducer. A question that we were unable to resolve
is whether ALL phones procured by the government must satisfy the
amplification requirement, or whether it's acceptable to provide
special-purpose handsets only to the individuals who require that degree
of amplification.

I'm not a lawyer, but my impression is that the latter point of view is
supported by the General Exceptions: "(C) Except as required to comply
with the provisions in these standards, section 508 does not require the
installation of specific accessibility-related software or the
attachment of an assistive technology device at a workstation of a
Federal employee who is not an individual with a disability." It is
also the case that I have NEVER had a contract officer request that all
phones be supplied with amplified handsets.

On the other hand, I'm very uncomfortable with the idea that someone
with hearing loss would be restricted to specially equipped phones. I
think that this would be contrary to what we were hoping to achieve with
508.

Prior to our discussing whether the 20 dB value in 1194.23(f) should be
raised, I'd like clarification about whether ALL phones will be required
to comply.

Thank you.

-- Paul Michaelis

From: Brett, Thomas F
Date: Mon, Nov 06 2006 4:19 PM
Subject: Re: Requirements for telephone amplification

>Prior to our discussing whether the 20 dB value in 1194.23(f) should be
>raised, I'd like clarification about whether ALL phones will be required
>to comply.

I concur that Section 508 does not require that everybody be provided with assistive technology. If a particular product requires the use of screen reader technology because there is a blind individual, that technology need only be supplied to the individual who needs it. The interpretation that I used not only with telecommunications but other EIT is that the product must be capable of supporting the use of assistive technology.


Tom Brett



-----Original Message-----
From: = EMAIL ADDRESS REMOVED = on behalf of Michaelis, Paul R (Paul)
Sent: Mon 11/6/2006 3:56 PM
To: = EMAIL ADDRESS REMOVED =
Subject: [teitac-telecom] Requirements for telephone amplification

During the recently concluded telecom conference call, we discussed the
requirement in 1194.23(f) that phones be able to provide 20+ dB of
amplification. For most wired phones, this degree of amplification is
achievable without distortion only when the standard handset is replaced
with a handset that contains a special-purpose amplifier and
special-purpose transducer. A question that we were unable to resolve
is whether ALL phones procured by the government must satisfy the
amplification requirement, or whether it's acceptable to provide
special-purpose handsets only to the individuals who require that degree
of amplification.

I'm not a lawyer, but my impression is that the latter point of view is
supported by the General Exceptions: "(C) Except as required to comply
with the provisions in these standards, section 508 does not require the
installation of specific accessibility-related software or the
attachment of an assistive technology device at a workstation of a
Federal employee who is not an individual with a disability." It is
also the case that I have NEVER had a contract officer request that all
phones be supplied with amplified handsets.

On the other hand, I'm very uncomfortable with the idea that someone
with hearing loss would be restricted to specially equipped phones. I
think that this would be contrary to what we were hoping to achieve with
508.

Prior to our discussing whether the 20 dB value in 1194.23(f) should be
raised, I'd like clarification about whether ALL phones will be required
to comply.

Thank you.

-- Paul Michaelis





I

From: Diane Golden
Date: Mon, Nov 06 2006 4:19 PM
Subject: Re: Requirements for telephone amplification

I couldn't agree more that this issue needs to be clarified once and for
all. As I said on the call, we asked this very question early on in direct
reference not only to the telecom standards but also the closed
self-contained product standards and the answer from the Access Board was
unequivocal -- the 508 standards apply to ALL products purchased by the
federal government. It is our understanding that the 508 standards do not
allow for consideration of "line of products" (a line of phones with varying
degrees of gain and/or other access features provided so one could pick and
choose) or substitution of products or parts of products to meet a standard.
Clearly there are standards that ensure compatibility with add-on AT (as
many of the software and web standards do), but other standards directly
require an access feature be provided regardless of ability to add-on or
substitute something to deliver that feature. We've always understood the
exception language to be an effort to clarify that the AT compatibility
standards do not require AT to be installed with every product.

So that begs the question about the intent of the gain standard. It is not
written like a compatibility standard (e.g. the product shall have a
standard connection point that allows for . . . ). It reads as if the gain
is a required feature of all products purchased. There is a somewhat
similar standard under closed, self-contained products 1194.25 for voice
output in a public area which also requires gain of at least 20 dB over
ambient noise levels. It would seem in the case of products used in a
public area, the gain would have to be built into the product without any
kind of substitute handset/head set used. Hopefully, someone from Access
Board can clarify this for us all!

Diane Golden


-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ]On Behalf Of Michaelis,
Paul R (Paul)
Sent: Monday, November 06, 2006 2:57 PM
To: = EMAIL ADDRESS REMOVED =
Subject: [teitac-telecom] Requirements for telephone amplification


During the recently concluded telecom conference call, we discussed the
requirement in 1194.23(f) that phones be able to provide 20+ dB of
amplification. For most wired phones, this degree of amplification is
achievable without distortion only when the standard handset is replaced
with a handset that contains a special-purpose amplifier and
special-purpose transducer. A question that we were unable to resolve
is whether ALL phones procured by the government must satisfy the
amplification requirement, or whether it's acceptable to provide
special-purpose handsets only to the individuals who require that degree
of amplification.

I'm not a lawyer, but my impression is that the latter point of view is
supported by the General Exceptions: "(C) Except as required to comply
with the provisions in these standards, section 508 does not require the
installation of specific accessibility-related software or the
attachment of an assistive technology device at a workstation of a
Federal employee who is not an individual with a disability." It is
also the case that I have NEVER had a contract officer request that all
phones be supplied with amplified handsets.

On the other hand, I'm very uncomfortable with the idea that someone
with hearing loss would be restricted to specially equipped phones. I
think that this would be contrary to what we were hoping to achieve with
508.

Prior to our discussing whether the 20 dB value in 1194.23(f) should be
raised, I'd like clarification about whether ALL phones will be required
to comply.

Thank you.

-- Paul Michaelis

From: Baquis David
Date: Mon, Nov 06 2006 5:30 PM
Subject: Re: Requirements for telephone amplification

Here is the provision in question:
(f) For transmitted voice signals, telecommunications products shall
provide a gain adjustable up to a minimum of 20 dB. For incremental
volume control, at least one intermediate step of 12 dB of gain shall be
provided.
http://www.access-board.gov/sec508/guide/1194.23.htm#(f)

The question from the subcommittee: Does this provision apply to all
telephones procured by federal agencies? The Access Board answer is
yes. But don't misunderstand. I am not telling you exactly how to
arrive at conformance with that requirement.

It is true that 508 Subpart C allows for two methods of accessible
design: build-in the solution or design for compatibility with assistive
technology. Either one is allowed for most products (not self-contained
products).

I think that some of the confusion here centers on the determination of
whether amplification is an assistive technology or part of the
mainstream information/communications technology. As you read ahead,
think about the difference between an amplifier as a component and
amplification as a function.

Some people view an amplifier as AT. Therefore, their extended argument
would be that a telephone WITHOUT amplification can be 508-conformant,
as long as the phone is designed to be compatible with an amplifier.
This would leave people with hearing loss having to ask for
accommodations, which brings us back to the way things were before 508,
when people had to self identify. I know the disability advocates
don't like that.

The other view is that amplification is considered an integral part of
the IT, and therefore the telephone system would not be complete (and
508-conformant) without it built-in. It is an interesting argument to
use the exception about not all IT products requiring attached AT. It is
true that I would not expect all telephones to have stand-alone TTYs
connected to them, for example. But is amplification the same kind of
thing? Some people would say yes and believe that after the phone has
been set-up with the attached amplifier, the user will then have
comparable access, which is the overall intent of 508.

Of course this presumes the scenario of a person using the phone
regularly like in an office. But what about lobby phones provided to
the public - phones that may not have built-in accessibility? Section
508 does not get population specific in its requirements. Should each of
those hard of hearing guest users have to ask for an amplifier?

You may want to think about a few more things as you sort this out:

First, if amplification is network-based, then this may be a moot issue.
In other words, imagine that ALL the users on a network had instructions
to press star five (I made that up) and they would then be able to
customize their settings for personal hearing enhancement. This is the
type of thinking out of the box and the consideration for new
technologies that we are hoping that the experts will bring into the
discussion.

Second, this is not just an amplification issue but extends to a number
of provisions. Years ago, I can remember demonstrating an inductive
coupler adaptor. For phones that did not generate a strong magnetic
field from the earpeice, you could strap a small disk around the
receiver and then get good hearing aid compatibility.

Another example would be digital phone systems that do not have direct
analog jacks for TTY hook-up, but through the provision of a
digital-to-analog adaptor (which might be kept in the desk of an agency
administrator), the phone system was considered 508-conformant in
because it was TTY-connectable via the adaptor. One advisor felt that
this was acceptable as long as the adaptor was "readily available"
(meaning you can get it right away and not have to wait on an order), a
term which we don't have in writing anywhere.

This is one of those "sufficiency" discussions that we hoped the
Committee would hash out. What is sufficient for 508-conformance?
What does compatibilty with AT really mean? How can the 508 standards
inform the design of products that may double as both AT and IT?

David Baquis
Accessibility Specialist
U.S. Access Board
1331 F Street, NW, #1000
Washington, DC 20004
800-USA-ABLE; (202) 272-0013 (voice)
www.access-board.gov; = EMAIL ADDRESS REMOVED = "Leading the way to
excellence in accessibility"

"Thank you for your questions concerning section 508 of the
Rehabilitation Act Amendments of 1998. Section 508 authorizes the
Access Board to provide technical assistance to individuals and Federal
departments and agencies concerning the requirements of this section.
This technical assistance is intended solely as informal guidance; it is
not a determination of the legal rights or responsibilities of entities
subject to section 508."

From: Karen Peltz Strauss
Date: Mon, Nov 06 2006 5:35 PM
Subject: Re: Requirements for telephone amplification

Ellen and I have been conferring and after going back a bit, we found that
actually the FCC's Section 255 guidelines do not say anything about db gain.
What happened was that the TAAC had proposed using a 12 to 20 db gain, which
was then adopted by the Access Board in its 255 guidelines. But because
rules produced as a result of the FCC's HAC negotiated rulemaking committee
(a committee formed to finalize hearing aid compatibility rules for wireline
phones) required only 18 db gain (in part 68), the FCC decided to reject
this particular Access Board guideline. Although the FCC's 255 rules are
silent on the issue, it was the agency's intent to use the 18 db standard
when it rejected the Access Board's guideline of 12-20 db gain.

----- Original Message -----
From: "Baquis David " < = EMAIL ADDRESS REMOVED = >
To: < = EMAIL ADDRESS REMOVED = >
Sent: Monday, November 06, 2006 7:20 PM
Subject: Re: [teitac-telecom] Requirements for telephone amplification


> Here is the provision in question:
> (f) For transmitted voice signals, telecommunications products shall
> provide a gain adjustable up to a minimum of 20 dB. For incremental
> volume control, at least one intermediate step of 12 dB of gain shall be
> provided.
> http://www.access-board.gov/sec508/guide/1194.23.htm#(f)
>
> The question from the subcommittee: Does this provision apply to all
> telephones procured by federal agencies? The Access Board answer is
> yes. But don't misunderstand. I am not telling you exactly how to
> arrive at conformance with that requirement.
>
> It is true that 508 Subpart C allows for two methods of accessible
> design: build-in the solution or design for compatibility with assistive
> technology. Either one is allowed for most products (not self-contained
> products).
>
> I think that some of the confusion here centers on the determination of
> whether amplification is an assistive technology or part of the
> mainstream information/communications technology. As you read ahead,
> think about the difference between an amplifier as a component and
> amplification as a function.
>
> Some people view an amplifier as AT. Therefore, their extended argument
> would be that a telephone WITHOUT amplification can be 508-conformant,
> as long as the phone is designed to be compatible with an amplifier.
> This would leave people with hearing loss having to ask for
> accommodations, which brings us back to the way things were before 508,
> when people had to self identify. I know the disability advocates
> don't like that.
>
> The other view is that amplification is considered an integral part of
> the IT, and therefore the telephone system would not be complete (and
> 508-conformant) without it built-in. It is an interesting argument to
> use the exception about not all IT products requiring attached AT. It is
> true that I would not expect all telephones to have stand-alone TTYs
> connected to them, for example. But is amplification the same kind of
> thing? Some people would say yes and believe that after the phone has
> been set-up with the attached amplifier, the user will then have
> comparable access, which is the overall intent of 508.
>
> Of course this presumes the scenario of a person using the phone
> regularly like in an office. But what about lobby phones provided to
> the public - phones that may not have built-in accessibility? Section
> 508 does not get population specific in its requirements. Should each of
> those hard of hearing guest users have to ask for an amplifier?
>
> You may want to think about a few more things as you sort this out:
>
> First, if amplification is network-based, then this may be a moot issue.
> In other words, imagine that ALL the users on a network had instructions
> to press star five (I made that up) and they would then be able to
> customize their settings for personal hearing enhancement. This is the
> type of thinking out of the box and the consideration for new
> technologies that we are hoping that the experts will bring into the
> discussion.
>
> Second, this is not just an amplification issue but extends to a number
> of provisions. Years ago, I can remember demonstrating an inductive
> coupler adaptor. For phones that did not generate a strong magnetic
> field from the earpeice, you could strap a small disk around the
> receiver and then get good hearing aid compatibility.
>
> Another example would be digital phone systems that do not have direct
> analog jacks for TTY hook-up, but through the provision of a
> digital-to-analog adaptor (which might be kept in the desk of an agency
> administrator), the phone system was considered 508-conformant in
> because it was TTY-connectable via the adaptor. One advisor felt that
> this was acceptable as long as the adaptor was "readily available"
> (meaning you can get it right away and not have to wait on an order), a
> term which we don't have in writing anywhere.
>
> This is one of those "sufficiency" discussions that we hoped the
> Committee would hash out. What is sufficient for 508-conformance?
> What does compatibilty with AT really mean? How can the 508 standards
> inform the design of products that may double as both AT and IT?
>
> David Baquis
> Accessibility Specialist
> U.S. Access Board
> 1331 F Street, NW, #1000
> Washington, DC 20004
> 800-USA-ABLE; (202) 272-0013 (voice)
> www.access-board.gov; = EMAIL ADDRESS REMOVED = "Leading the way to
> excellence in accessibility"
>
> "Thank you for your questions concerning section 508 of the
> Rehabilitation Act Amendments of 1998. Section 508 authorizes the
> Access Board to provide technical assistance to individuals and Federal
> departments and agencies concerning the requirements of this section.
> This technical assistance is intended solely as informal guidance; it is
> not a determination of the legal rights or responsibilities of entities
> subject to section 508."
>
>

From: Brenda Battat
Date: Mon, Nov 06 2006 5:40 PM
Subject: Re: Requirements for telephone amplification

Hello Everyone
I hear you all had a good discussion about volume control today. Sorry I
missed it. Here is some background as I know it and my take on volume
control.

The hearing Aid Compatibility Act has a requirement for the manufacture
of every wireline phone to include volume control in addition to HAC.
This was incorporated as an outcome of the FCC HAC Negotiated Rulemaking
Committee - pre-508. It was not to be retroactive. So if an old phone
turns up in the workplace, for example, identified by an employee as not
having VC and HAC, then a certain number of days are allowed to replace
that phone with a new one that does.

The VC gain in 508 was taken from existing levels in ADA and FCC
regulations. HLAA was not happy with the gain levels as they just do not
meet the needs of many people with hearing loss. We receive lots of
complaints for both landline and wireless not being loud enough. The
current gain is good in noisy situations for people who do not have
hearing loss or who have early hearing loss. People who have more
hearing loss combine the VC with telecoil coupling and then may be able
to use the phone depending on other factors such as background noise,
signal quality, articulation of the speaker on the other end,
interference levels in digital handsets, immunity of hearing aids,
strength of the telecoil and whether or not the telecoil has been
programmed.

At the urging of SHHH (now HLAA) the original Access Board 508 NPRM was
suggesting to allow up to 25dB of gain (that was the best we could get.)
But this level did not make it into the Final Rule as a result of
opposition from industry.The argument against more gain was distortion
for all users. HLAA commissioned two labs to test distortion and both
labs found no evidence of it.

Going to 24dB would get access to a lot more people with a range of
hearing losses. However, there would still be some people who would need
higher boosts - handsets sold as special equipment reach 35-40dB gain
and people using those are usually much happier.

The other big question is, how many phones actually reach the current
required levels? There is definitely variability from phone to phone and
no way for a consumer to know how much boost is actually being provided.
The gain should be documented.

Federal employees must be able to use any phone to be effective workers
and also in case of emergency they need equivalent access for their own
and others' safety. Therefore the VC gain should be built in. Its
ridiculous to expect employees to carry handsets from one office or
floor to another.We have to take this opportunity to fix a problem that
has irked people for a long time and jeopardized their ability to use a
phone effectively. We need to settle on a gain level that is effective
for as many people as possible and then figure out a way to manufacture
it.



Brenda Battat
Associate Executive Director
Hearing Loss Association of America (formerly SHHH)
301-657-2248 phone
301-913-9413 fax


-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Diane
Golden
Sent: Monday, November 06, 2006 4:58 PM
To: 'TEITAC Telecommunications Subcommittee'
Subject: Re: [teitac-telecom] Requirements for telephone amplification

I couldn't agree more that this issue needs to be clarified once and for
all. As I said on the call, we asked this very question early on in
direct reference not only to the telecom standards but also the closed
self-contained product standards and the answer from the Access Board
was unequivocal -- the 508 standards apply to ALL products purchased by
the federal government. It is our understanding that the 508 standards
do not allow for consideration of "line of products" (a line of phones
with varying degrees of gain and/or other access features provided so
one could pick and choose) or substitution of products or parts of
products to meet a standard. Clearly there are standards that ensure
compatibility with add-on AT (as many of the software and web standards
do), but other standards directly require an access feature be provided
regardless of ability to add-on or substitute something to deliver that
feature. We've always understood the exception language to be an effort
to clarify that the AT compatibility standards do not require AT to be
installed with every product.

So that begs the question about the intent of the gain standard. It is
not written like a compatibility standard (e.g. the product shall have a
standard connection point that allows for . . . ). It reads as if the
gain is a required feature of all products purchased. There is a
somewhat similar standard under closed, self-contained products 1194.25
for voice output in a public area which also requires gain of at least
20 dB over ambient noise levels. It would seem in the case of products
used in a public area, the gain would have to be built into the product
without any kind of substitute handset/head set used. Hopefully,
someone from Access Board can clarify this for us all!

Diane Golden


-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ]On Behalf Of Michaelis,
Paul R (Paul)
Sent: Monday, November 06, 2006 2:57 PM
To: = EMAIL ADDRESS REMOVED =
Subject: [teitac-telecom] Requirements for telephone amplification


During the recently concluded telecom conference call, we discussed the
requirement in 1194.23(f) that phones be able to provide 20+ dB of
amplification. For most wired phones, this degree of amplification is
achievable without distortion only when the standard handset is replaced
with a handset that contains a special-purpose amplifier and
special-purpose transducer. A question that we were unable to resolve
is whether ALL phones procured by the government must satisfy the
amplification requirement, or whether it's acceptable to provide
special-purpose handsets only to the individuals who require that degree
of amplification.

I'm not a lawyer, but my impression is that the latter point of view is
supported by the General Exceptions: "(C) Except as required to comply
with the provisions in these standards, section 508 does not require the
installation of specific accessibility-related software or the
attachment of an assistive technology device at a workstation of a
Federal employee who is not an individual with a disability." It is
also the case that I have NEVER had a contract officer request that all
phones be supplied with amplified handsets.

On the other hand, I'm very uncomfortable with the idea that someone
with hearing loss would be restricted to specially equipped phones. I
think that this would be contrary to what we were hoping to achieve with
508.

Prior to our discussing whether the 20 dB value in 1194.23(f) should be
raised, I'd like clarification about whether ALL phones will be required
to comply.

Thank you.

-- Paul Michaelis

From: Diane Golden
Date: Tue, Nov 07 2006 4:45 AM
Subject: Re: Requirements for telephone amplification

If this logic is applied to all the 508 standards (e.g. all can be met either by the product conforming to the standard "as is" or through some add-on product) then the captioning decoder standard would not require a chip -- adding on a decoder (provided you can find one now) would meet the standard. Similarly, adding on captions or description as needed would be OK. One could argue you could add alt tags as needed rather than them being there "as is". If this is the case -- it is a massive shift in application of the standards.

Diane Golden


----- Original Message ----
From: Baquis David < = EMAIL ADDRESS REMOVED = >
To: = EMAIL ADDRESS REMOVED =
Sent: Monday, November 6, 2006 6:20:33 PM
Subject: Re: [teitac-telecom] Requirements for telephone amplification


Here is the provision in question:
(f) For transmitted voice signals, telecommunications products shall
provide a gain adjustable up to a minimum of 20 dB. For incremental
volume control, at least one intermediate step of 12 dB of gain shall be
provided.
http://www.access-board.gov/sec508/guide/1194.23.htm#(f)

The question from the subcommittee: Does this provision apply to all
telephones procured by federal agencies? The Access Board answer is
yes. But don't misunderstand. I am not telling you exactly how to
arrive at conformance with that requirement.

It is true that 508 Subpart C allows for two methods of accessible
design: build-in the solution or design for compatibility with assistive
technology. Either one is allowed for most products (not self-contained
products).

I think that some of the confusion here centers on the determination of
whether amplification is an assistive technology or part of the
mainstream information/communications technology. As you read ahead,
think about the difference between an amplifier as a component and
amplification as a function.

Some people view an amplifier as AT. Therefore, their extended argument
would be that a telephone WITHOUT amplification can be 508-conformant,
as long as the phone is designed to be compatible with an amplifier.
This would leave people with hearing loss having to ask for
accommodations, which brings us back to the way things were before 508,
when people had to self identify. I know the disability advocates
don't like that.

The other view is that amplification is considered an integral part of
the IT, and therefore the telephone system would not be complete (and
508-conformant) without it built-in. It is an interesting argument to
use the exception about not all IT products requiring attached AT. It is
true that I would not expect all telephones to have stand-alone TTYs
connected to them, for example. But is amplification the same kind of
thing? Some people would say yes and believe that after the phone has
been set-up with the attached amplifier, the user will then have
comparable access, which is the overall intent of 508.

Of course this presumes the scenario of a person using the phone
regularly like in an office. But what about lobby phones provided to
the public - phones that may not have built-in accessibility? Section
508 does not get population specific in its requirements. Should each of
those hard of hearing guest users have to ask for an amplifier?

You may want to think about a few more things as you sort this out:

First, if amplification is network-based, then this may be a moot issue.
In other words, imagine that ALL the users on a network had instructions
to press star five (I made that up) and they would then be able to
customize their settings for personal hearing enhancement. This is the
type of thinking out of the box and the consideration for new
technologies that we are hoping that the experts will bring into the
discussion.

Second, this is not just an amplification issue but extends to a number
of provisions. Years ago, I can remember demonstrating an inductive
coupler adaptor. For phones that did not generate a strong magnetic
field from the earpeice, you could strap a small disk around the
receiver and then get good hearing aid compatibility.

Another example would be digital phone systems that do not have direct
analog jacks for TTY hook-up, but through the provision of a
digital-to-analog adaptor (which might be kept in the desk of an agency
administrator), the phone system was considered 508-conformant in
because it was TTY-connectable via the adaptor. One advisor felt that
this was acceptable as long as the adaptor was "readily available"
(meaning you can get it right away and not have to wait on an order), a
term which we don't have in writing anywhere.

This is one of those "sufficiency" discussions that we hoped the
Committee would hash out. What is sufficient for 508-conformance?
What does compatibilty with AT really mean? How can the 508 standards
inform the design of products that may double as both AT and IT?

David Baquis
Accessibility Specialist
U.S. Access Board
1331 F Street, NW, #1000
Washington, DC 20004
800-USA-ABLE; (202) 272-0013 (voice)
www.access-board.gov; = EMAIL ADDRESS REMOVED = "Leading the way to
excellence in accessibility"

"Thank you for your questions concerning section 508 of the
Rehabilitation Act Amendments of 1998. Section 508 authorizes the
Access Board to provide technical assistance to individuals and Federal
departments and agencies concerning the requirements of this section.
This technical assistance is intended solely as informal guidance; it is
not a determination of the legal rights or responsibilities of entities
subject to section 508."

From: Jagbell
Date: Tue, Nov 07 2006 1:35 PM
Subject: Re: Requirements for telephone amplification

Tom-

How are you arriving at this conclusion? Can you please point me to
the place in the statue that says this?

Thanks,

Janice Schacter
On Nov 6, 2006, at 4:45 PM, Brett, Thomas F wrote:

> >Prior to our discussing whether the 20 dB value in 1194.23(f)
> should be
> >raised, I'd like clarification about whether ALL phones will be
> required
> >to comply.
>
> I concur that Section 508 does not require that everybody be
> provided with assistive technology. If a particular product
> requires the use of screen reader technology because there is a
> blind individual, that technology need only be supplied to the
> individual who needs it. The interpretation that I used not only
> with telecommunications but other EIT is that the product must be
> capable of supporting the use of assistive technology.
>
>
> Tom Brett
>
>
>
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED = on behalf of
> Michaelis, Paul R (Paul)
> Sent: Mon 11/6/2006 3:56 PM
> To: = EMAIL ADDRESS REMOVED =
> Subject: [teitac-telecom] Requirements for telephone amplification
>
> During the recently concluded telecom conference call, we discussed
> the
> requirement in 1194.23(f) that phones be able to provide 20+ dB of
> amplification. For most wired phones, this degree of amplification is
> achievable without distortion only when the standard handset is
> replaced
> with a handset that contains a special-purpose amplifier and
> special-purpose transducer. A question that we were unable to resolve
> is whether ALL phones procured by the government must satisfy the
> amplification requirement, or whether it's acceptable to provide
> special-purpose handsets only to the individuals who require that
> degree
> of amplification.
>
> I'm not a lawyer, but my impression is that the latter point of
> view is
> supported by the General Exceptions: "(C) Except as required to comply
> with the provisions in these standards, section 508 does not
> require the
> installation of specific accessibility-related software or the
> attachment of an assistive technology device at a workstation of a
> Federal employee who is not an individual with a disability." It is
> also the case that I have NEVER had a contract officer request that
> all
> phones be supplied with amplified handsets.
>
> On the other hand, I'm very uncomfortable with the idea that someone
> with hearing loss would be restricted to specially equipped phones. I
> think that this would be contrary to what we were hoping to achieve
> with
> 508.
>
> Prior to our discussing whether the 20 dB value in 1194.23(f)
> should be
> raised, I'd like clarification about whether ALL phones will be
> required
> to comply.
>
> Thank you.
>
> -- Paul Michaelis
>
>
>
>
>
> I
>
>

From: Brett, Thomas F
Date: Tue, Nov 07 2006 2:30 PM
Subject: Re: Requirements for telephone amplification

Here is how I have arrived at that conclusion:

1194.3 General exceptions.

(c) Except as required to comply with the provisions in this part, this part does not require the installation of specific accessibility-related software or the attachment of an assistive technology device at a workstation of a Federal employee who is not an individual with a disability.

http://www.section508.gov/index.cfm?FuseAction=Content&ID=12#General
Tom Brett

From: SKP1066@aol.com
Date: Wed, Nov 08 2006 1:40 AM
Subject: Re: Requirements for telephone amplification

I am not a lawyer, either, so pardon my ignorance. DGiven the intent of 508,
does "specific accessibility-related software or the attachment of an
assistive technology device" pertain only if direct access is not embedded in the
product? So, would a purchaser first try to identify a phone that is HAC or a
copier with text to speech, for example, but lacking that as an option then only
need to provide the accessibility software or hardware on an as needed basis
by the individual user?

Susan

From: Brett, Thomas F
Date: Wed, Nov 08 2006 4:05 AM
Subject: Re: Requirements for telephone amplification

>I am not a lawyer, either, so pardon my ignorance. DGiven the intent of >508, does "specific accessibility-related software or the attachment of an >assistive technology device" pertain only if direct access is not embedded in >the product? So, would a purchaser first try to identify a phone that is HAC >or a copier with text to speech, for example, but lacking that as an option >then only need to provide the accessibility software or hardware on an as >needed basis by the individual user?

This is my understanding of the law. The policy that I have followed for the past 5 years is that as long as the equipment/software/product is capable of being used with assistive technology, that equipment/software/product meets the applicable Section 508 Standards.

Using screen reader technology as an example, it would cost approximately $1,000 to outfit every workstation with this technology. To insure that this technology will work would require that the RAM be increased and that every user be granted admin rights to their PC. The vast majority of the workstation users would never access that technology.

Tom Brett

From: Jagbell
Date: Wed, Nov 08 2006 6:15 AM
Subject: Re: Requirements for telephone amplification

Good Morning Everyone-

Shouldn't the addition of assistive technology be the last resort and
not the first resort? If OPM doesn't insist that the technology is
embedded than who will? The government should be setting the
standard and not following the path of least resistance.

Since I am an attorney, my understanding of Section 255 is that the
Guidelines require the manufacturers to include the access if it is
readily achievable. Just because a manufacturer says it cannot
include it is not the end of the story, they must provide
documentation. We should not allow manufacturers to get off the hook
so easily.

Also as far as the screen reader technology, I think that technology
could benefit many people especially as the population starts aging.
Why are we requiring people to self-identify? Wasn't the point of
Section 255 and Section 508 to stop people to having to self-
identify? Am I missing something??

Best,

Janice Schacter






On Nov 8, 2006, at 6:04 AM, Brett, Thomas F wrote:

> >I am not a lawyer, either, so pardon my ignorance. DGiven the
> intent of >508, does "specific accessibility-related software or
> the attachment of an >assistive technology device" pertain only if
> direct access is not embedded in >the product? So, would a
> purchaser first try to identify a phone that is HAC >or a copier
> with text to speech, for example, but lacking that as an option
> >then only need to provide the accessibility software or hardware
> on an as >needed basis by the individual user?
>
> This is my understanding of the law. The policy that I have
> followed for the past 5 years is that as long as the equipment/
> software/product is capable of being used with assistive
> technology, that equipment/software/product meets the applicable
> Section 508 Standards.
>
> Using screen reader technology as an example, it would cost
> approximately $1,000 to outfit every workstation with this
> technology. To insure that this technology will work would require
> that the RAM be increased and that every user be granted admin
> rights to their PC. The vast majority of the workstation users
> would never access that technology.
>
> Tom Brett
>
> From: = EMAIL ADDRESS REMOVED = on behalf of
> = EMAIL ADDRESS REMOVED =
> Sent: Wed 11/8/2006 3:39 AM
> To: = EMAIL ADDRESS REMOVED =
> Subject: Re: [teitac-telecom] Requirements for telephone amplification
>
> I am not a lawyer, either, so pardon my ignorance. DGiven the
> intent of 508, does "specific accessibility-related software or the
> attachment of an assistive technology device" pertain only if
> direct access is not embedded in the product? So, would a
> purchaser first try to identify a phone that is HAC or a copier
> with text to speech, for example, but lacking that as an option
> then only need to provide the accessibility software or hardware on
> an as needed basis by the individual user?
>
> Susan
>

From: Brett, Thomas F
Date: Wed, Nov 08 2006 8:25 AM
Subject: Re: Requirements for telephone amplification

I don't think it is right to say "If OPM doesn't insist that the technology is
embedded than who will?"

OPM is required to follow the law like every other agency. There is nothing in the regulations that authorizes an agency to require more from the Rehabilitation Act that what is authorized.

Tom Brett



-----Original Message-----
From: = EMAIL ADDRESS REMOVED = on behalf of Jagbell
Sent: Wed 11/8/2006 8:14 AM
To: TEITAC Telecommunications Subcommittee
Subject: Re: [teitac-telecom] Requirements for telephone amplification

Good Morning Everyone-

Shouldn't the addition of assistive technology be the last resort and
not the first resort? If OPM doesn't insist that the technology is
embedded than who will? The government should be setting the
standard and not following the path of least resistance.

Since I am an attorney, my understanding of Section 255 is that the
Guidelines require the manufacturers to include the access if it is
readily achievable. Just because a manufacturer says it cannot
include it is not the end of the story, they must provide
documentation. We should not allow manufacturers to get off the hook
so easily.

Also as far as the screen reader technology, I think that technology
could benefit many people especially as the population starts aging.
Why are we requiring people to self-identify? Wasn't the point of
Section 255 and Section 508 to stop people to having to self-
identify? Am I missing something??

Best,

Janice Schacter






On Nov 8, 2006, at 6:04 AM, Brett, Thomas F wrote:

> >I am not a lawyer, either, so pardon my ignorance. DGiven the
> intent of >508, does "specific accessibility-related software or
> the attachment of an >assistive technology device" pertain only if
> direct access is not embedded in >the product? So, would a
> purchaser first try to identify a phone that is HAC >or a copier
> with text to speech, for example, but lacking that as an option
> >then only need to provide the accessibility software or hardware
> on an as >needed basis by the individual user?
>
> This is my understanding of the law. The policy that I have
> followed for the past 5 years is that as long as the equipment/
> software/product is capable of being used with assistive
> technology, that equipment/software/product meets the applicable
> Section 508 Standards.
>
> Using screen reader technology as an example, it would cost
> approximately $1,000 to outfit every workstation with this
> technology. To insure that this technology will work would require
> that the RAM be increased and that every user be granted admin
> rights to their PC. The vast majority of the workstation users
> would never access that technology.
>
> Tom Brett
>
> From: = EMAIL ADDRESS REMOVED = on behalf of
> = EMAIL ADDRESS REMOVED =
> Sent: Wed 11/8/2006 3:39 AM
> To: = EMAIL ADDRESS REMOVED =
> Subject: Re: [teitac-telecom] Requirements for telephone amplification
>
> I am not a lawyer, either, so pardon my ignorance. DGiven the
> intent of 508, does "specific accessibility-related software or the
> attachment of an assistive technology device" pertain only if
> direct access is not embedded in the product? So, would a
> purchaser first try to identify a phone that is HAC or a copier
> with text to speech, for example, but lacking that as an option
> then only need to provide the accessibility software or hardware on
> an as needed basis by the individual user?
>
> Susan
>

From: Jagbell
Date: Wed, Nov 08 2006 8:50 AM
Subject: Re: Requirements for telephone amplification

It is all how the Rehabilitation act is interpreted. The purpose of
this group is to close the gaps. Our goal should be universal
access. Add-ons are not universal access.

Janice Schacter



On Nov 8, 2006, at 10:18 AM, Brett, Thomas F wrote:

> I don't think it is right to say "If OPM doesn't insist that the
> technology is
> embedded than who will?"
>
> OPM is required to follow the law like every other agency. There
> is nothing in the regulations that authorizes an agency to require
> more from the Rehabilitation Act that what is authorized.
>
> Tom Brett
>
>
>
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED = on behalf of Jagbell
> Sent: Wed 11/8/2006 8:14 AM
> To: TEITAC Telecommunications Subcommittee
> Subject: Re: [teitac-telecom] Requirements for telephone amplification
>
> Good Morning Everyone-
>
> Shouldn't the addition of assistive technology be the last resort and
> not the first resort? If OPM doesn't insist that the technology is
> embedded than who will? The government should be setting the
> standard and not following the path of least resistance.
>
> Since I am an attorney, my understanding of Section 255 is that the
> Guidelines require the manufacturers to include the access if it is
> readily achievable. Just because a manufacturer says it cannot
> include it is not the end of the story, they must provide
> documentation. We should not allow manufacturers to get off the hook
> so easily.
>
> Also as far as the screen reader technology, I think that technology
> could benefit many people especially as the population starts aging.
> Why are we requiring people to self-identify? Wasn't the point of
> Section 255 and Section 508 to stop people to having to self-
> identify? Am I missing something??
>
> Best,
>
> Janice Schacter
>
>
>
>
>
>
> On Nov 8, 2006, at 6:04 AM, Brett, Thomas F wrote:
>
> > >I am not a lawyer, either, so pardon my ignorance. DGiven the
> > intent of >508, does "specific accessibility-related software or
> > the attachment of an >assistive technology device" pertain only if
> > direct access is not embedded in >the product? So, would a
> > purchaser first try to identify a phone that is HAC >or a copier
> > with text to speech, for example, but lacking that as an option
> > >then only need to provide the accessibility software or hardware
> > on an as >needed basis by the individual user?
> >
> > This is my understanding of the law. The policy that I have
> > followed for the past 5 years is that as long as the equipment/
> > software/product is capable of being used with assistive
> > technology, that equipment/software/product meets the applicable
> > Section 508 Standards.
> >
> > Using screen reader technology as an example, it would cost
> > approximately $1,000 to outfit every workstation with this
> > technology. To insure that this technology will work would require
> > that the RAM be increased and that every user be granted admin
> > rights to their PC. The vast majority of the workstation users
> > would never access that technology.
> >
> > Tom Brett
> >
> > From: = EMAIL ADDRESS REMOVED = on behalf of
> > = EMAIL ADDRESS REMOVED =
> > Sent: Wed 11/8/2006 3:39 AM
> > To: = EMAIL ADDRESS REMOVED =
> > Subject: Re: [teitac-telecom] Requirements for telephone
> amplification
> >
> > I am not a lawyer, either, so pardon my ignorance. DGiven the
> > intent of 508, does "specific accessibility-related software or the
> > attachment of an assistive technology device" pertain only if
> > direct access is not embedded in the product? So, would a
> > purchaser first try to identify a phone that is HAC or a copier
> > with text to speech, for example, but lacking that as an option
> > then only need to provide the accessibility software or hardware on
> > an as needed basis by the individual user?
> >
> > Susan
> >

From: Brett, Thomas F
Date: Wed, Nov 08 2006 9:00 AM
Subject: Re: Requirements for telephone amplification

I concur fully. That could be one of the recommendations that needs to come out of these subcommittees...remove this general exception.

But when the Access Board does its Economic Impact it will say that for this new 'product' it will cost $$$ more to deploy it that if we only allowed people with disabilities to have it. For example, supplying screen reader technology to a small agency of 3,000 people would cost in excess of $3,000,000. When the product being deployed cost only $500,000, it does not seem reasonable. The same argument can be made for telephones. I am aware of a telephone that that costs $495 per desk set that meets everything we have talked about in this subcommittee thus far. The normal desk set costs from $150 - $200. How would there be a good justification to the tax payers for buing a phone for everyone that costs $495.



Tom Brett

From: Jagbell
Date: Wed, Nov 08 2006 9:45 AM
Subject: Re: Requirements for telephone amplification

I have a couple of things to say on this issue:

1- Access is not determined solely by price. If it were, there would
never be access. Access should not be dependent on "the goodness" of
governmental appropriators. A New Civil Right pg. 95

2- Just as cities support rural access because that is what is
appropriate so must non-disabled access support disability access.

3- There is the assumption that accessibility only benefits the
person with the disability. That is not the case. Access for people
with disabilities benefits everyone. For example, if you are having
a heart attack, would you want to know everyone who needs to call for
an ambulance can? Also, it is important for people without a
disability to be able to reach people who do have a disability.
These are the same issues that were raised with TTYs and were over
come. Have you read Karen Peltz Strauss' book "A New Civil Right"?
It details all of the legislative history and clarifies these issues.

4- If a government agency cannot buy a phone system because it does
not have the appropriate features, the phone seller will be forced to
figure out how to overcome some hurdles to bring the cost down.
Otherwise, they lose business. The Sections give an incentive for
businesses to solve the issue. Plus, the costs are driven down e.g.
the decoder chip in tvs.

5- Everyone has to live within their budgets. It may mean that the
item cannot be purchased or money is shifted from somewhere else to
fund the dollars. But, the purchase cannot be at the expense of
people with disabilities if universal design is readily achievable.
The budget is looked at in the context of the overall budget and not
just the dollars that are allocated to say the phone system.

6- Without appropriate access, society as a whole incurs greater
costs through lost unemployment and productivity.

7- On a personal note, I have no problem paying taxes for services
that I do not use. I do that everyday for medicare, the fire dept
etc. That is part of being a citizen of the United States.

Best,

Janice






On Nov 8, 2006, at 10:57 AM, Brett, Thomas F wrote:

> I concur fully. That could be one of the recommendations that needs
> to come out of these subcommittees...remove this general exception.
>
> But when the Access Board does its Economic Impact it will say that
> for this new 'product' it will cost $$$ more to deploy it that if
> we only allowed people with disabilities to have it. For example,
> supplying screen reader technology to a small agency of 3,000
> people would cost in excess of $3,000,000. When the product being
> deployed cost only $500,000, it does not seem reasonable. The same
> argument can be made for telephones. I am aware of a telephone
> that that costs $495 per desk set that meets everything we have
> talked about in this subcommittee thus far. The normal desk set
> costs from $150 - $200. How would there be a good justification to
> the tax payers for buing a phone for everyone that costs $495.
>
>
>
> Tom Brett
>
> From: = EMAIL ADDRESS REMOVED = on behalf of Jagbell
> Sent: Wed 11/8/2006 10:48 AM
> To: TEITAC Telecommunications Subcommittee
> Subject: Re: [teitac-telecom] Requirements for telephone amplification
>
> It is all how the Rehabilitation act is interpreted. The purpose
> of this group is to close the gaps. Our goal should be universal
> access. Add-ons are not universal access.
>
> Janice Schacter
>
>
>
> On Nov 8, 2006, at 10:18 AM, Brett, Thomas F wrote:
>
>> I don't think it is right to say "If OPM doesn't insist that the
>> technology is
>> embedded than who will?"
>>
>> OPM is required to follow the law like every other agency. There
>> is nothing in the regulations that authorizes an agency to require
>> more from the Rehabilitation Act that what is authorized.
>>
>> Tom Brett
>>
>>
>>
>> -----Original Message-----
>> From: = EMAIL ADDRESS REMOVED = on behalf of Jagbell
>> Sent: Wed 11/8/2006 8:14 AM
>> To: TEITAC Telecommunications Subcommittee
>> Subject: Re: [teitac-telecom] Requirements for telephone
>> amplification
>>
>> Good Morning Everyone-
>>
>> Shouldn't the addition of assistive technology be the last resort and
>> not the first resort? If OPM doesn't insist that the technology is
>> embedded than who will? The government should be setting the
>> standard and not following the path of least resistance.
>>
>> Since I am an attorney, my understanding of Section 255 is that the
>> Guidelines require the manufacturers to include the access if it is
>> readily achievable. Just because a manufacturer says it cannot
>> include it is not the end of the story, they must provide
>> documentation. We should not allow manufacturers to get off the hook
>> so easily.
>>
>> Also as far as the screen reader technology, I think that technology
>> could benefit many people especially as the population starts aging.
>> Why are we requiring people to self-identify? Wasn't the point of
>> Section 255 and Section 508 to stop people to having to self-
>> identify? Am I missing something??
>>
>> Best,
>>
>> Janice Schacter
>>
>>
>>
>>
>>
>>
>> On Nov 8, 2006, at 6:04 AM, Brett, Thomas F wrote:
>>
>> > >I am not a lawyer, either, so pardon my ignorance. DGiven the
>> > intent of >508, does "specific accessibility-related software or
>> > the attachment of an >assistive technology device" pertain only if
>> > direct access is not embedded in >the product? So, would a
>> > purchaser first try to identify a phone that is HAC >or a copier
>> > with text to speech, for example, but lacking that as an option
>> > >then only need to provide the accessibility software or hardware
>> > on an as >needed basis by the individual user?
>> >
>> > This is my understanding of the law. The policy that I have
>> > followed for the past 5 years is that as long as the equipment/
>> > software/product is capable of being used with assistive
>> > technology, that equipment/software/product meets the applicable
>> > Section 508 Standards.
>> >
>> > Using screen reader technology as an example, it would cost
>> > approximately $1,000 to outfit every workstation with this
>> > technology. To insure that this technology will work would require
>> > that the RAM be increased and that every user be granted admin
>> > rights to their PC. The vast majority of the workstation users
>> > would never access that technology.
>> >
>> > Tom Brett
>> >
>> > From: = EMAIL ADDRESS REMOVED = on behalf of
>> > = EMAIL ADDRESS REMOVED =
>> > Sent: Wed 11/8/2006 3:39 AM
>> > To: = EMAIL ADDRESS REMOVED =
>> > Subject: Re: [teitac-telecom] Requirements for telephone
>> amplification
>> >
>> > I am not a lawyer, either, so pardon my ignorance. DGiven the
>> > intent of 508, does "specific accessibility-related software or the
>> > attachment of an assistive technology device" pertain only if
>> > direct access is not embedded in the product? So, would a
>> > purchaser first try to identify a phone that is HAC or a copier
>> > with text to speech, for example, but lacking that as an option
>> > then only need to provide the accessibility software or hardware on
>> > an as needed basis by the individual user?
>> >
>> > Susan
>> >

From: Gregg Vanderheiden
Date: Wed, Nov 08 2006 10:45 AM
Subject: Re: Requirements for telephone amplification

The definition I have heard was that if there was a charge per user to add
access it was an adaptation and not built-in access.




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






_____


From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Brett, Thomas F
Sent: Wednesday, November 08, 2006 9:58 AM
To: TEITAC Telecommunications Subcommittee; TEITAC Telecommunications
Subcommittee
Subject: Re: [teitac-telecom] Requirements for telephone amplification

I concur fully. That could be one of the recommendations that needs to come
out of these subcommittees...remove this general exception.



But when the Access Board does its Economic Impact it will say that for this
new 'product' it will cost $$$ more to deploy it that if we only allowed
people with disabilities to have it. For example, supplying screen reader
technology to a small agency of 3,000 people would cost in excess of
$3,000,000. When the product being deployed cost only $500,000, it does not
seem reasonable. The same argument can be made for telephones. I am aware
of a telephone that that costs $495 per desk set that meets everything we
have talked about in this subcommittee thus far. The normal desk set costs
from $150 - $200. How would there be a good justification to the tax payers
for buing a phone for everyone that costs $495.







Tom Brett




_____


From: = EMAIL ADDRESS REMOVED = on behalf of Jagbell
Sent: Wed 11/8/2006 10:48 AM
To: TEITAC Telecommunications Subcommittee
Subject: Re: [teitac-telecom] Requirements for telephone amplification

It is all how the Rehabilitation act is interpreted. The purpose of this
group is to close the gaps. Our goal should be universal access. Add-ons
are not universal access.



Janice Schacter







On Nov 8, 2006, at 10:18 AM, Brett, Thomas F wrote:





I don't think it is right to say "If OPM doesn't insist that the technology
is
embedded than who will?"

OPM is required to follow the law like every other agency. There is nothing
in the regulations that authorizes an agency to require more from the
Rehabilitation Act that what is authorized.

Tom Brett



-----Original Message-----
From: = EMAIL ADDRESS REMOVED = on behalf of Jagbell
Sent: Wed 11/8/2006 8:14 AM
To: TEITAC Telecommunications Subcommittee
Subject: Re: [teitac-telecom] Requirements for telephone amplification

Good Morning Everyone-

Shouldn't the addition of assistive technology be the last resort and
not the first resort? If OPM doesn't insist that the technology is
embedded than who will? The government should be setting the
standard and not following the path of least resistance.

Since I am an attorney, my understanding of Section 255 is that the
Guidelines require the manufacturers to include the access if it is
readily achievable. Just because a manufacturer says it cannot
include it is not the end of the story, they must provide
documentation. We should not allow manufacturers to get off the hook
so easily.

Also as far as the screen reader technology, I think that technology
could benefit many people especially as the population starts aging.
Why are we requiring people to self-identify? Wasn't the point of
Section 255 and Section 508 to stop people to having to self-
identify? Am I missing something??

Best,

Janice Schacter






On Nov 8, 2006, at 6:04 AM, Brett, Thomas F wrote:

> >I am not a lawyer, either, so pardon my ignorance. DGiven the
> intent of >508, does "specific accessibility-related software or
> the attachment of an >assistive technology device" pertain only if
> direct access is not embedded in >the product? So, would a
> purchaser first try to identify a phone that is HAC >or a copier
> with text to speech, for example, but lacking that as an option
> >then only need to provide the accessibility software or hardware
> on an as >needed basis by the individual user?
>
> This is my understanding of the law. The policy that I have
> followed for the past 5 years is that as long as the equipment/
> software/product is capable of being used with assistive
> technology, that equipment/software/product meets the applicable
> Section 508 Standards.
>
> Using screen reader technology as an example, it would cost
> approximately $1,000 to outfit every workstation with this
> technology. To insure that this technology will work would require
> that the RAM be increased and that every user be granted admin
> rights to their PC. The vast majority of the workstation users
> would never access that technology.
>
> Tom Brett
>
> From: = EMAIL ADDRESS REMOVED = on behalf of
> = EMAIL ADDRESS REMOVED =
> Sent: Wed 11/8/2006 3:39 AM
> To: = EMAIL ADDRESS REMOVED =
> Subject: Re: [teitac-telecom] Requirements for telephone amplification
>
> I am not a lawyer, either, so pardon my ignorance. DGiven the
> intent of 508, does "specific accessibility-related software or the
> attachment of an assistive technology device" pertain only if
> direct access is not embedded in the product? So, would a
> purchaser first try to identify a phone that is HAC or a copier
> with text to speech, for example, but lacking that as an option
> then only need to provide the accessibility software or hardware on
> an as needed basis by the individual user?
>
> Susan
>

From: Jagbell
Date: Wed, Nov 08 2006 10:50 AM
Subject: Re: Requirements for telephone amplification

Can you please clarify this? Where is this definition from?

Thanks,

Janice



On Nov 8, 2006, at 12:39 PM, Gregg Vanderheiden wrote:

> The definition I have heard was that if there was a charge per user
> to add access it was an adaptation and not built-in access.
>
>
>
>
> Gregg
> -- ------------------------------
> Gregg C Vanderheiden Ph.D.
>
>
>
>
>
> From: = EMAIL ADDRESS REMOVED = [mailto:teitac-telecom-
> = EMAIL ADDRESS REMOVED = ] On Behalf Of Brett, Thomas F
> Sent: Wednesday, November 08, 2006 9:58 AM
> To: TEITAC Telecommunications Subcommittee; TEITAC
> Telecommunications Subcommittee
> Subject: Re: [teitac-telecom] Requirements for telephone amplification
>
> I concur fully. That could be one of the recommendations that needs
> to come out of these subcommittees...remove this general exception.
>
>
>
> But when the Access Board does its Economic Impact it will say that
> for this new 'product' it will cost $$$ more to deploy it that if
> we only allowed people with disabilities to have it. For example,
> supplying screen reader technology to a small agency of 3,000
> people would cost in excess of $3,000,000. When the product being
> deployed cost only $500,000, it does not seem reasonable. The same
> argument can be made for telephones. I am aware of a telephone
> that that costs $495 per desk set that meets everything we have
> talked about in this subcommittee thus far. The normal desk set
> costs from $150 - $200. How would there be a good justification to
> the tax payers for buing a phone for everyone that costs $495.
>
>
>
>
>
>
>
> Tom Brett
>
>
>
> From: = EMAIL ADDRESS REMOVED = on behalf of Jagbell
> Sent: Wed 11/8/2006 10:48 AM
> To: TEITAC Telecommunications Subcommittee
> Subject: Re: [teitac-telecom] Requirements for telephone amplification
>
> It is all how the Rehabilitation act is interpreted. The purpose
> of this group is to close the gaps. Our goal should be universal
> access. Add-ons are not universal access.
>
>
>
> Janice Schacter
>
>
>
>
>
>
>
> On Nov 8, 2006, at 10:18 AM, Brett, Thomas F wrote:
>
>
>
>
> I don't think it is right to say "If OPM doesn't insist that the
> technology is
> embedded than who will?"
>
> OPM is required to follow the law like every other agency. There
> is nothing in the regulations that authorizes an agency to require
> more from the Rehabilitation Act that what is authorized.
>
> Tom Brett
>
>
>
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED = on behalf of Jagbell
> Sent: Wed 11/8/2006 8:14 AM
> To: TEITAC Telecommunications Subcommittee
> Subject: Re: [teitac-telecom] Requirements for telephone amplification
>
> Good Morning Everyone-
>
> Shouldn't the addition of assistive technology be the last resort and
> not the first resort? If OPM doesn't insist that the technology is
> embedded than who will? The government should be setting the
> standard and not following the path of least resistance.
>
> Since I am an attorney, my understanding of Section 255 is that the
> Guidelines require the manufacturers to include the access if it is
> readily achievable. Just because a manufacturer says it cannot
> include it is not the end of the story, they must provide
> documentation. We should not allow manufacturers to get off the hook
> so easily.
>
> Also as far as the screen reader technology, I think that technology
> could benefit many people especially as the population starts aging.
> Why are we requiring people to self-identify? Wasn't the point of
> Section 255 and Section 508 to stop people to having to self-
> identify? Am I missing something??
>
> Best,
>
> Janice Schacter
>
>
>
>
>
>
> On Nov 8, 2006, at 6:04 AM, Brett, Thomas F wrote:
>
> > >I am not a lawyer, either, so pardon my ignorance. DGiven the
> > intent of >508, does "specific accessibility-related software or
> > the attachment of an >assistive technology device" pertain only if
> > direct access is not embedded in >the product? So, would a
> > purchaser first try to identify a phone that is HAC >or a copier
> > with text to speech, for example, but lacking that as an option
> > >then only need to provide the accessibility software or hardware
> > on an as >needed basis by the individual user?
> >
> > This is my understanding of the law. The policy that I have
> > followed for the past 5 years is that as long as the equipment/
> > software/product is capable of being used with assistive
> > technology, that equipment/software/product meets the applicable
> > Section 508 Standards.
> >
> > Using screen reader technology as an example, it would cost
> > approximately $1,000 to outfit every workstation with this
> > technology. To insure that this technology will work would require
> > that the RAM be increased and that every user be granted admin
> > rights to their PC. The vast majority of the workstation users
> > would never access that technology.
> >
> > Tom Brett
> >
> > From: = EMAIL ADDRESS REMOVED = on behalf of
> > = EMAIL ADDRESS REMOVED =
> > Sent: Wed 11/8/2006 3:39 AM
> > To: = EMAIL ADDRESS REMOVED =
> > Subject: Re: [teitac-telecom] Requirements for telephone
> amplification
> >
> > I am not a lawyer, either, so pardon my ignorance. DGiven the
> > intent of 508, does "specific accessibility-related software or the
> > attachment of an assistive technology device" pertain only if
> > direct access is not embedded in the product? So, would a
> > purchaser first try to identify a phone that is HAC or a copier
> > with text to speech, for example, but lacking that as an option
> > then only need to provide the accessibility software or hardware on
> > an as needed basis by the individual user?
> >
> > Susan
> >

From: Baquis David
Date: Wed, Nov 08 2006 4:20 PM
Subject: Re: Requirements for telephone amplification

As a follow-on to my last email, I wanted to clarify the sequential
application of 508 Subparts B and C.

Subpart B should be used first (by designers, evaluators, requesters,
etc). In those provisions, you will often see language, such as: "the
product shall". That means that the solution should be built-in.
Therefore, in http://www.access-board.gov/sec508/guide/1194.23.htm#(f),
it is clear that the amplification should be built into the telephone.

I am glad that Brenda brought the HAC Act requirement for volume control
to our attention. However, even without that, 508 would still require
built-in amplification as a purchasing requirement.

I apologize for confusion resulting from my earlier comments below.
Actually, we do not know of any federal agency that has misinterpreted
that requirement and looked for an "out" to getting amplified phones.
(Although we do know of at least one instance in which 508 was
completely overlooked in all respects in the procurement of an expensive
telephone system ... and no one complained. I was the only person who
picked up on it and we are not a watchdog advocacy group, but I did call
the agency and speak with them about it.)

Subpart C is to be used when it is not possible for a company to meet
Subpart B. This is addressed in an FAQ, which I have cut/pasted below.
See: B.2.ii at:
http://www.section508.gov/index.cfm?FuseAction=Content&ID=75

"ii. How should an agency proceed in identifying "applicable" technical
provisions in Subparts B, C, and D of the Access Board's standards to
ensure acquired products provide comparable access?
Agencies should first look to the provisions in Subpart B to determine
if there are specific technical provisions that apply to the EIT need
they are seeking to satisfy.
If there are applicable provisions in Subpart B that fully address the
product or service being procured, then the agency need not look to
Subpart C. Acquired products that meet the specific technical provisions
set forth in Subpart B will also meet the broader functional performance
criteria in Subpart C.
If an agency's procurement needs are not fully addressed by Subpart B,
then the agency must look to Subpart C for applicable functional
performance requirements.
Agencies must also remember the additional considerations of Subpart D.
Subpart D requires that: (a) product support documentation provided to
end users shall be made available in alternate formats upon request at
no additional charge; (b) end users shall have access to a description
of the accessibility and compatibility features of products in alternate
formats or methods upon request, also at no additional charge; and (c)
support services (e.g., help desk) for products shall accommodate the
communication needs of end users with disabilities.
For example, if an agency were to enter into a seat management contract
for desktop computing resources, the hardware and software to be
provided by the contractor would be required to meet the provisions in
section 1194.26 (Desktop and Portable Computers), and 1194.21 (Software
Applications and Operating Systems) of Subpart B of the Access Board's
standards. If these provisions fully addressed the agency's procurement
software and hardware needs, the agency would also be in compliance with
Subpart C. If some or all of the features were not covered by Subpart B,
the agency would also have to look to Subpart C. With respect to the
support services provided under the seat management contract, the agency
would also need to take into account any appropriate information,
documentation, or support requirements in Subpart D.
In all cases, agencies, when evaluating offers, must consider products
that provide equivalent facilitation (see section B.3, below)."

David Baquis

From: Debbie Cook
Date: Wed, Nov 08 2006 4:25 PM
Subject: Re: Requirements for telephone amplification

The challenge here is raising the bar on what is to be a minimum standard.
That may not yield universal access. Whether we lik eit or not, the charge
does includ studying the economic impact. That doesn't just mean figuring
out how much it costs. It also may be that in raising the bar, we do so over
an extended period of time to reduce the cost of that implementation. This
may be a trade off over not being able to do it at all.
----- Original Message -----
From: "Brett, Thomas F" < = EMAIL ADDRESS REMOVED = >
To: "TEITAC Telecommunications Subcommittee"
< = EMAIL ADDRESS REMOVED = >; "TEITAC Telecommunications Subcommittee"
< = EMAIL ADDRESS REMOVED = >
Sent: Wednesday, November 08, 2006 7:57 AM
Subject: Re: [teitac-telecom] Requirements for telephone amplification


I concur fully. That could be one of the recommendations that needs to come
out of these subcommittees...remove this general exception.

But when the Access Board does its Economic Impact it will say that for this
new 'product' it will cost $$$ more to deploy it that if we only allowed
people with disabilities to have it. For example, supplying screen reader
technology to a small agency of 3,000 people would cost in excess of
$3,000,000. When the product being deployed cost only $500,000, it does not
seem reasonable. The same argument can be made for telephones. I am aware
of a telephone that that costs $495 per desk set that meets everything we
have talked about in this subcommittee thus far. The normal desk set costs
from $150 - $200. How would there be a good justification to the tax payers
for buing a phone for everyone that costs $495.



Tom Brett

From: jagbell@nyc.rr.com
Date: Wed, Nov 08 2006 4:40 PM
Subject: Re: Requirements for telephone amplification

Hi Debbie-

How are we charged with studying the economic impact?
Thanks,
Janice
Sent from my BlackBerry wireless handheld.

-----Original Message-----
From: Debbie Cook < = EMAIL ADDRESS REMOVED = >
Date: Wed, 08 Nov 2006 15:14:43
To:TEITAC Telecommunications Subcommittee < = EMAIL ADDRESS REMOVED = >
Subject: Re: [teitac-telecom] Requirements for telephone amplification

The challenge here is raising the bar on what is to be a minimum standard.
That may not yield universal access. Whether we lik eit or not, the charge
does includ studying the economic impact. That doesn't just mean figuring
out how much it costs. It also may be that in raising the bar, we do so over
an extended period of time to reduce the cost of that implementation. This
may be a trade off over not being able to do it at all.
----- Original Message -----
From: "Brett, Thomas F" < = EMAIL ADDRESS REMOVED = >
To: "TEITAC Telecommunications Subcommittee"
< = EMAIL ADDRESS REMOVED = >; "TEITAC Telecommunications Subcommittee"
< = EMAIL ADDRESS REMOVED = >
Sent: Wednesday, November 08, 2006 7:57 AM
Subject: Re: [teitac-telecom] Requirements for telephone amplification


I concur fully. That could be one of the recommendations that needs to come
out of these subcommittees...remove this general exception.

But when the Access Board does its Economic Impact it will say that for this
new 'product' it will cost $$$ more to deploy it that if we only allowed
people with disabilities to have it. For example, supplying screen reader
technology to a small agency of 3,000 people would cost in excess of
$3,000,000. When the product being deployed cost only $500,000, it does not
seem reasonable. The same argument can be made for telephones. I am aware
of a telephone that that costs $495 per desk set that meets everything we
have talked about in this subcommittee thus far. The normal desk set costs
from $150 - $200. How would there be a good justification to the tax payers
for buing a phone for everyone that costs $495.



Tom Brett

From: Jim Tobias
Date: Fri, Nov 10 2006 9:50 AM
Subject: Re: Requirements for telephone amplification

Can you please cite the source for this? It sounds really wrong. I can
imagine "adaptations" (did you mean "accommodations"?) that are free, and
some things that are charged for that are not adaptations/accommodations.


***********
Jim Tobias
Inclusive Technologies
= EMAIL ADDRESS REMOVED =
+1.732.441.0831 v/tty
skype jimtobias
www.inclusive.com





_____

From: Gregg Vanderheiden [mailto: = EMAIL ADDRESS REMOVED = ]
Sent: Wednesday, November 08, 2006 12:39 PM
To: 'TEITAC Telecommunications Subcommittee'
Subject: Re: [teitac-telecom] Requirements for telephone amplification



The definition I have heard was that if there was a charge per user to add
access it was an adaptation and not built-in access.




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






_____


From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Brett, Thomas F
Sent: Wednesday, November 08, 2006 9:58 AM
To: TEITAC Telecommunications Subcommittee; TEITAC Telecommunications
Subcommittee
Subject: Re: [teitac-telecom] Requirements for telephone amplification

I concur fully. That could be one of the recommendations that needs to come
out of these subcommittees...remove this general exception.



But when the Access Board does its Economic Impact it will say that for this
new 'product' it will cost $$$ more to deploy it that if we only allowed
people with disabilities to have it. For example, supplying screen reader
technology to a small agency of 3,000 people would cost in excess of
$3,000,000. When the product being deployed cost only $500,000, it does not
seem reasonable. The same argument can be made for telephones. I am aware
of a telephone that that costs $495 per desk set that meets everything we
have talked about in this subcommittee thus far. The normal desk set costs
from $150 - $200. How would there be a good justification to the tax payers
for buing a phone for everyone that costs $495.







Tom Brett




_____


From: = EMAIL ADDRESS REMOVED = on behalf of Jagbell
Sent: Wed 11/8/2006 10:48 AM
To: TEITAC Telecommunications Subcommittee
Subject: Re: [teitac-telecom] Requirements for telephone amplification

It is all how the Rehabilitation act is interpreted. The purpose of this
group is to close the gaps. Our goal should be universal access. Add-ons
are not universal access.



Janice Schacter







On Nov 8, 2006, at 10:18 AM, Brett, Thomas F wrote:





I don't think it is right to say "If OPM doesn't insist that the technology
is
embedded than who will?"

OPM is required to follow the law like every other agency. There is nothing
in the regulations that authorizes an agency to require more from the
Rehabilitation Act that what is authorized.

Tom Brett



-----Original Message-----
From: = EMAIL ADDRESS REMOVED = on behalf of Jagbell
Sent: Wed 11/8/2006 8:14 AM
To: TEITAC Telecommunications Subcommittee
Subject: Re: [teitac-telecom] Requirements for telephone amplification

Good Morning Everyone-

Shouldn't the addition of assistive technology be the last resort and
not the first resort? If OPM doesn't insist that the technology is
embedded than who will? The government should be setting the
standard and not following the path of least resistance.

Since I am an attorney, my understanding of Section 255 is that the
Guidelines require the manufacturers to include the access if it is
readily achievable. Just because a manufacturer says it cannot
include it is not the end of the story, they must provide
documentation. We should not allow manufacturers to get off the hook
so easily.

Also as far as the screen reader technology, I think that technology
could benefit many people especially as the population starts aging.
Why are we requiring people to self-identify? Wasn't the point of
Section 255 and Section 508 to stop people to having to self-
identify? Am I missing something??

Best,

Janice Schacter






On Nov 8, 2006, at 6:04 AM, Brett, Thomas F wrote:

> >I am not a lawyer, either, so pardon my ignorance. DGiven the
> intent of >508, does "specific accessibility-related software or
> the attachment of an >assistive technology device" pertain only if
> direct access is not embedded in >the product? So, would a
> purchaser first try to identify a phone that is HAC >or a copier
> with text to speech, for example, but lacking that as an option
> >then only need to provide the accessibility software or hardware
> on an as >needed basis by the individual user?
>
> This is my understanding of the law. The policy that I have
> followed for the past 5 years is that as long as the equipment/
> software/product is capable of being used with assistive
> technology, that equipment/software/product meets the applicable
> Section 508 Standards.
>
> Using screen reader technology as an example, it would cost
> approximately $1,000 to outfit every workstation with this
> technology. To insure that this technology will work would require
> that the RAM be increased and that every user be granted admin
> rights to their PC. The vast majority of the workstation users
> would never access that technology.
>
> Tom Brett
>
> From: = EMAIL ADDRESS REMOVED = on behalf of
> = EMAIL ADDRESS REMOVED =
> Sent: Wed 11/8/2006 3:39 AM
> To: = EMAIL ADDRESS REMOVED =
> Subject: Re: [teitac-telecom] Requirements for telephone amplification
>
> I am not a lawyer, either, so pardon my ignorance. DGiven the
> intent of 508, does "specific accessibility-related software or the
> attachment of an assistive technology device" pertain only if
> direct access is not embedded in the product? So, would a
> purchaser first try to identify a phone that is HAC or a copier
> with text to speech, for example, but lacking that as an option
> then only need to provide the accessibility software or hardware on
> an as needed basis by the individual user?
>
> Susan
>