BIOS

Status

Subcommittee decided to send BIOS to the General subcommittee to see if they will own it.

Summary

Key points and next steps here. Details follow.

• We need to focus on BIOS with regards to start up, shut down, system failure (BIOS error messages), multiple OS selection, required hardware log in. See section "Why making BIOS accessible is important."
• Recommend we create new section § 1194.27 Firmware. BIOS is neither pure Hardware or Software.
• Recommend Hardware subcommittee covers this and doesn't pass it over to Software.
• Recommend we call BIOS vendors to get their input.

Some background from Sueann and Gina from IBM

A few points about where Sueann and I are coming from on this topic.

1. As you probably know IBM doesn't develop PCs any more so we don't have access to any technical people at that level.

2. Our servers have their own IBM developed BIOSes so we aren't working with any of the know BIOS vendors.

3. Our servers are developed to follow Section 508 and are evaluated against that standard. I've never heard of anyone here considering either the hardware or software to be "back office" and therefore exempt from these standards.

What you'll find below

To help me get my head around the various issues so we can make a decision about BIOS I summarized the previous listserv discussions and transcripts from our weekly calls.

I'll start with the questions, list the points and then some background info, and a few action items.

I put my opinion between <gc></gc>. When responding, please do the same thing with your initials to keep the speaker clear in the discussion.

Why making BIOS accessible is important

I found an Advisory Committee report that discusses BIOS. I think it might shed some light on why the topic came up in the first place.

Electronic and Information Technology Access Advisory Committee Final Report May 12, 1999 http://www.access-board.gov/sec508/commrept/eitaacrpt.htm

I pasted in the key sections. These are found under

5. Proposed Standards 5.3 Technology Specific Standards 5.3.2 If the E&IT is software in nature and runs on a platform that has an operating system.

5.3.2.9 System startup and restart shall be accessible.

Then, down in the appendix it expands on the proposed standard.

Introduction This appendix expands on the material presented in Section 5 of the report. It provides supporting material and suggestions for accessibility solutions for some of the standards in Section 5. Since the proposed standards in Section 5 stand alone, this material is not intended by the Committee to limit the proposed standards in any way. Instead, we think of this as being part of the building of the technical guidance and material that the Access Board will need to develop. This is only a preliminary list of notes and ideas to support the guidelines. For additional information and pointers to other support sources the reader is referred to the Access Boards Website.

.....

Information Regarding 5.3.2.8 System Startup and shutdown. [I think they mean 5.3.2.9 not .8]

System Startup and shutdown are often areas of significant difficulty for people with disabilities, especially people who depend on assistive technology for access since assistive technology is itself often a software application which cannot function until sufficient operating system services have initialized. For instance, the BIOS and CMOS settings on most PCs are inaccessible. System and network login and shutdown procedures are often inaccessible as well. It is recognized that more than one solution strategy may be required to provide access to all portions of the startup or shutdown process.

Available solutions may include the following:

• Provide an accessible application to read and modify basic system settings such as BIOS or CMOS settings;
• Provide support for industry standard dumb terminal access over an industry standard port to system startup messages and command prompts,

so that assistive technologies may be used to access the more primitive system startup and shutdown routines. Such access can also provide access for software and operating system installations;

• Provide rudimentary built-in assistive technologies to support access to basic system initialization and shutdown procedures, especially to system login and restart.

I thought it would be beneficial to review this section too.

3.3 Undue burden

Undue Burden means significant difficulty or expense. In determining whether an action would impose an undue burden on the operation of the agency in question, factors to be considered include:

3.3.1 The nature and cost of the action needed under this section; 3.3.2 The overall size of the agency's program and resources, including the number of employees, number and type of facilities, and the size of the agency's budget; 3.3.3 The type of the agency's operation, including the composition and structure of the agency's work force; and 3.3.4 The impact of such action upon the resources and operation of the agency.

Questions and a few answers

1. Is BIOS firmware or software?

<gc>BIOS is firmware. Look at definitions below under "What is firmware?" "What is software?" and "What is BIOS?"</gc>

2. Is BIOS a "Self Contained, Closed Product"?

<gc>No. Read definitions below.</gc>

3. As BIOS is firmware - firmware is software that is embedded in a hardware device - does it fall under the Hardware subcommittee or the Software subcommittee?

<gc>The standards makes no mention under § 1194.21 Software applications and operating systems or § 1194.26 Desktop and portable computers (aka Hardware) about firmware. Software does seem to discuss the fact that it is about applications working after the OS is engaged. I propose therefore that it either be under § 1194.26 or there should be a new section § 1194.27 Firmware.</gc>

4. Can you update BIOS?

<gc>Yes. Typically by using device drivers, but that doesn't change the fact that during start up, shut down, configuration changes or during system failures there is no accessibility.</gc>

5. Is BIOS a "maintenance activity"?

<gc>Well, what is "maintenance"? Can we assume it is a task you do not do on a daily basis? And then infrequently at best.</gc>

6a. Would changing Section 508 to require BIOS be accessible cause an "undue burden" for manufacturers?

6b. You mentioned some things had been done in the past to make certain BIOSes more accessible. What were those things? What BIOS?

6c. What are some obvious changes to the BIOS to make it accessible?

<gc>I suggest we call some manufacturers and ask them. There is a list on the Wikipedia page under BIOS.

I believe there are beeps (audio). That is some help to the blind user. Not certain there is any visual feedback with the beeps. When do any beeps occur? Is it one beep or two beeps? Do they indicate different things? There is text on screen during start up and during shut down. Can that be read aloud? What about text-to-speech (TTS) engines? Can it be added to the firmware? These would be good questions for BIOS manufacturers.</gc>

7. Are you requesting the BIOS be made more accessible for everyone, or specifically for Federal workers engaged in IT support and maintenance?

<gc>From what I've read they mean for all users, not just Federal workers.</gc>

Facts

• Settings can be done by some utility software after the computer has booted up from the normal desktop.
• The OS is not yet running and normal AT and IT software are not yet running.
• Some companies require a hardware log in password (IBM does, for example)
• Desktops and laptops boot up (start up), power down and can have failures (blue screen of death as I call it)
• During start up the user can select F1 to change options.
• Some systems have a dual start up to allow the user to select the OS.

Opinions

• If access during boot up is part of daily operation (like a power on password) then that interaction needs to be accessible.
• Manufacturers would probably be reluctant to do this:
• Altering the BIOS could unintentionally change the functioning of some other part of the device.
• AT devices might need access to other parts of the system (example, audio or video).
• It seemed to make more sense to use drivers rather than to attempt to gain access to the BIOS.
• All it really wants is to start and it doesn't matter if the BIOS provides configuration of hardware devices if the software drivers can ignore the BIOS and provide access.

Questions to ask actual PwD

We asked two blind users some questions. Perhaps you can ask some other PwD these same questions?

How do you know when you power on that it is ready for your power-on password to be typed? Is there a beep?

How do you know when you are at the Windows dialog box that asks for Control-Alt-Delete to get to the next log-in dialog? Or is the AT working at that point?

If your systems fails and locks you out, how do you know? Do you just know because the system is unresponsive? Or are there beeps? Then, do you call a sighted person for assistance? Would it be helpful to have the error message read aloud to provide feedback to technical support?

How does shut down work? Some times you can get dialog boxes telling you an application is still shutting down and it is waiting your action. Is the AT still working at that point?

One of the items for discussion is that accessing the BIOS is not a daily function (other than for power-on log in) but would be a "maintenace" function and therefore exempt from accessibility compliance. Would you agree or disagree with that statement?

In your opinion, do you feel access to BIOS for configuration or to view error messages should be required? Or is it "acceptable" to need assistance with this function? This answers the question for an end user. But what about for an IT professional who would like a job managing systems or servers? Shouldn't they require access to BIOS like they would require access to the operating system and applications on the machines.

Do you work on servers or other non-laptop or desktop hardware? Do you know anyone who does? Anyone who works in a data center (or would like to, but can't)? Thank you.

FYI only

WHAT IS BIOS? [1]

• "basic input/output system" which originated with PCs
• Built-in software that determines what a computer can do without accessing programs from a disk
• Typically placed in a ROM chip (or now PROM, EPROM, flash memory)
• Used to boot the machine
• The PC BIOS is fairly standardized

A more complete definition can be found at http://en.wikipedia.org/wiki/BIOS

What is firmware? [2]

Software (programs or data) that has been written onto read-only memory (ROM). Firmware is a combination of software and hardware. ROMs, PROMs and EPROMs that have data or programs recorded on them are firmware.

Looking at the Wikipedia definition of firmware and you'll see BIOS listed as an example. [3]

What is software? [4]

Computer instructions or data. Anything that can be stored electronically is software. The storage devices and display devices are hardware. The terms software and hardware are used as both nouns and adjectives. For example, you can say: "The problem lies in the software," meaning that there is a problem with the program or data, not with the computer itself. You can also say: "It's a software problem."

Software is often divided into two categories:

• systems software : Includes the operating system and all the utilities that enable the computer to function.
• applications software : Includes programs that do real work for users. For example, word processors, spreadsheets, and database management systems fall under the category of applications software.

What is the link for the standards?

http://www.access-board.gov/sec508/standards.htm

What is a back-office exemption?

§ 1194.3 General exceptions.

(f) Products located in spaces frequented only by service personnel for maintenance, repair, or occasional monitoring of equipment are not required to comply with this part.

What is self contained, closed products?

§ 1194.4 Definitions.

Self Contained, Closed Products. Products that generally have embedded software and are commonly designed in such a fashion that a user cannot easily attach or install assistive technology. These products include, but are not limited to, information kiosks and information transaction machines, copiers, printers, calculators, fax machines, and other similar types of products.

What is undue burden

§ 1194.4 Definitions.

Undue burden. Undue burden means significant difficulty or expense. In determining whether an action would result in an undue burden, an agency shall consider all agency resources available to the program or component for which the product is being developed, procured, maintained, or used.