Thread Subject: If 508 applies to a part,then it applies to the whole?

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From: Baquis David
Date: Tue, Mar 06 2007 1:10 PM
Subject: If 508 applies to a part,then it applies to the whole?

That is a specific question that the Access Board needs clarification on
in your report. This refers to the issue of how to apply the standards
when evaluating a product. We recently received an inquiry about a
product where it seemed that software that comes with it would be
covered, but the hardware itself might not fit the definition of E&IT.
This was laboratory equipment. So do you evaluate the software only?
Maybe use of an E&IT functions approach in evaluating equipment will
address this.

If you have not been imagining equipment that you are unfamiliar with,
then I encourage you to step outside your comfort zone. This is a
request that has been made to you by several federal agencies that vary
in focus from medical clinical care to space science. You know that many
federal departments have a research division. Spectometers,
chromatographs, particle sizers and others are just a few examples.

David

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"

From: David Poehlman
Date: Wed, Mar 07 2007 6:00 AM
Subject: Re: If 508 applies to a part,then it applies to the whole?

Hence, it is information technology.

On Mar 6, 2007, at 3:28 PM, William Loughborough wrote:

Baquis David wrote:
> We recently received an inquiry about a
> product where it seemed that software that comes with it would be
> covered, but the hardware itself might not fit the definition of E&IT.
> This was laboratory equipment. So do you evaluate the software only
I would be surprised if almost all laboratory equipment such as
chromatographs/spectrometers/balances and just about any recently
developed stuff didn't qualify as "electronic". The fact that it uses
software and almost inevitably connects to data-handling systems
essentially demands that the intent to assure accessibility extends
thereto.

The question is a human one: can a laboratory worker with disabilities
use it in ways comparable to others? All the stuff about keys, legends,
element positions, etc. surely must apply. Screwdrivers maybe not,
torque wrenches quite possibly! The move towards digital encoding of
measurements is rapid. Tape measures often have spoken outputs to
supplement their readouts.

Love.

From: Sailesh Panchang
Date: Wed, Mar 07 2007 6:35 AM
Subject: Re: If 508 applies to a part,then it applies to the whole?

>I would be surprised if almost all laboratory equipment such as
> chromatographs/spectrometers/balances and just about any recently
> developed stuff didn't qualify as "electronic". The fact that it uses
>software and almost inevitably connects to data-handling systems
>essentially demands that the intent to assure accessibility extends
>thereto.

Here is a contrary view: I disagree. I do not believe that is the intent
merely because these gadgets can be connected to data handling equipment for
further storage / processing of their results.

Section 1194.4 (definitions specifically contains an example of a system
that might contain embedded software but is not EIT: medical equipment where
information technology is integral to its operation.
The definition is fairly elaborate when it states: system / subsystem used
in the creation, conversion, or duplication of data or information . It
excludes systems whose principal function is not the acquisition, storage,
manipulation, management, movement, control, display, switching,
interchange, transmission,
or reception of data or information.
Chromatography is a method of chemical analysis and processing
spectrometer is an optical instrument used to measure properties of light
These gadgets use electronics but are not primarily meant for data handling.


Sailesh Panchang
Senior Accessibility Engineer
Deque Systems Inc. (www.deque.com)
11130 Sunrise Valley Drive, Suite #140,
Reston VA 20191
Phone: 703-225-0380 (ext 105)
E-mail: = EMAIL ADDRESS REMOVED =

From: David Poehlman
Date: Wed, Mar 07 2007 7:20 AM
Subject: Re: If 508 applies to a part,then it applies to the whole?

measuring is not data handling? state analisys is not data
hanndling? Perhaps 508 got it rong and we now need to put it right.
I know people who are loosing their jobs because the non systems they
used to be able to use are now digital.

On Mar 7, 2007, at 8:32 AM, Sailesh Panchang wrote:

> I would be surprised if almost all laboratory equipment such as
> chromatographs/spectrometers/balances and just about any recently
> developed stuff didn't qualify as "electronic". The fact that it uses
> software and almost inevitably connects to data-handling systems
> essentially demands that the intent to assure accessibility extends
> thereto.

Here is a contrary view: I disagree. I do not believe that is the intent
merely because these gadgets can be connected to data handling
equipment for
further storage / processing of their results.

Section 1194.4 (definitions specifically contains an example of a
system
that might contain embedded software but is not EIT: medical
equipment where
information technology is integral to its operation.
The definition is fairly elaborate when it states: system / subsystem
used
in the creation, conversion, or duplication of data or information . It
excludes systems whose principal function is not the acquisition,
storage,
manipulation, management, movement, control, display, switching,
interchange, transmission,
or reception of data or information.
Chromatography is a method of chemical analysis and processing
spectrometer is an optical instrument used to measure properties of
light
These gadgets use electronics but are not primarily meant for data
handling.


Sailesh Panchang
Senior Accessibility Engineer
Deque Systems Inc. (www.deque.com)
11130 Sunrise Valley Drive, Suite #140,
Reston VA 20191
Phone: 703-225-0380 (ext 105)
E-mail: = EMAIL ADDRESS REMOVED =

From: Mark D. Urban
Date: Wed, Mar 07 2007 7:45 AM
Subject: Re: If 508 applies to a part,then it applies to the whole?

Stepping in to this debate -

I have to say that medical and lab equipment is often EIT, although
sometimes PARTS of the device may be excluded from the definition.

There is a technical issue here: using Sailesh's example, Gas
Chromatographs almost always have a computer alongside them to analyze,
store and chart the data the machine collects. I can make an argument the
GC machine itself (the knobs and dials for adjusting and setting sampling
activity, the LED displays for indicating status of the sample, and the
keypad for inputting the number of samples and range to be tested) may not
be EIT, but the part of the device, whether internal or external, that
analyzes, stores, manipulates, or displays electronic information is
definitely EIT.

There is a public policy issue here, as well. By drawing the line of EIT
away from "specialized electronics", we specifically ignore the
congressional mandate for comparable access in the Federal EIT workspace.
Agencies such as NIH, CDC, the Indian Health Services, USDA, EPA, and many
others depend on the ability of most of their workforce to use these
devices. What we are saying, as an outcome of where we draw the line here,
is that persons with disabilities do not have comparable access rights to
the EIT work environments in those agencies, and need not apply.

Regards,

-Mark D. Urban 919-395-8513 (cell)
Chair, North Carolina Governor's Advocacy Council for Persons with
Disabilities
Keep up with the latest in worldwide accessibility at
(http://www.icdri.org/)

-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Sailesh
Panchang
Sent: Wednesday, March 07, 2007 8:33 AM
To: 'TEITAC General Interface Accessibility Subcommittee'
Subject: Re: [teitac-general] If 508 applies to a part,then it applies to
the whole?

>I would be surprised if almost all laboratory equipment such as
> chromatographs/spectrometers/balances and just about any recently
> developed stuff didn't qualify as "electronic". The fact that it uses
>software and almost inevitably connects to data-handling systems
>essentially demands that the intent to assure accessibility extends
>thereto.

Here is a contrary view: I disagree. I do not believe that is the intent
merely because these gadgets can be connected to data handling equipment for
further storage / processing of their results.

Section 1194.4 (definitions specifically contains an example of a system
that might contain embedded software but is not EIT: medical equipment where
information technology is integral to its operation.
The definition is fairly elaborate when it states: system / subsystem used
in the creation, conversion, or duplication of data or information . It
excludes systems whose principal function is not the acquisition, storage,
manipulation, management, movement, control, display, switching,
interchange, transmission,
or reception of data or information.
Chromatography is a method of chemical analysis and processing
spectrometer is an optical instrument used to measure properties of light
These gadgets use electronics but are not primarily meant for data handling.


Sailesh Panchang
Senior Accessibility Engineer
Deque Systems Inc. (www.deque.com)
11130 Sunrise Valley Drive, Suite #140,
Reston VA 20191
Phone: 703-225-0380 (ext 105)
E-mail: = EMAIL ADDRESS REMOVED =