Closed Subgroup Working Notes
Contents
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Thoughts and directions going forward from July 6 draft
- is there a difference between personal and shared/public products?
- should there be an exception or different rule for "technology solutions provided under services contract" ( where the provider could be required to have accessible versions on tap and provide them on demand - but not have all devices in place be conformant?)
- for personal -/ workstation devices
- If 'tactile' controls not part of Hardware - they need to be part of closed.
Definition: Closed Product
Product where assistive technology cannot be used to achieve some or all of the functionality of the electronic user interface components for any reason including hardware, software, platform, or policy limitation.
NOTE: Products can be closed for one type of disability but not closed for another.
NOTE: Functionality is limited to "electronic UI components" because products are not considered ‘closed’ if mechanical devices like latches or lids cannot be operated by assistive technologies like screen readers. Mechanical devices such as keys that cause electronic input would however trigger “closed” designation if assistive technologies could not achieve the same functionality.
NOTE: A ‘product’ can consist of multiple devices some of which may be AT if the devices are all sold and kept together as a unit.
Discussion: If the definition below for Adaptive Assistive Technology is not accepted, we may need to describe how this applies to products which are installed in or attached to the IT.
Proposed Definition: Adaptive Assistive Technology
[The term Adaptive Assistive Technology is no longer used and a definition is not required.
1194.25 (a) [CLOSED]
If any product functionality is closed, then individuals with disabilities shall have comparable access to that functionality without the use of any assistive technologies. A personal assistive listening device that connects to the standard audio connection required in provision [AUDIO CONNECTION PROVISION] is not considered assistive technology.
Location of provisions
The following provisions relate to Closed Products and we believe they should be located as follows.
The Close Work Group recommends the follow location for the following provisions
General Technical Requirement
1194.25a CLOSED -
1194.25b TIMING
1194.25c TOUCH OPERATED {general technical Requirement or maybe Hardware}
1194.25d BIOMETRIC
1194.25f VOLUME (PUBLIC AREA) {Gen Tech Req or Hardware}
1194.25g COLOR
Hardware
1194.25e AUDIO CONNECTION
1194.25j FREE-STANDING
Software
1194.25h Color Contrast Setttings { should be CONTRAST and in General Technical Requirements then}
Other provisions
There are also other provisions that relate to Closed products and some mechanism is needed to easily identify them for manufacturers who make closed products.
255 provisions that are new Provisions for 508
Visual Information
All information provided in visual form shall also be available in audio form and, where appropriate, in tactile form.
Audio Information
All information provided in audio form shall also be available in visual form.
Text Information
All information provided in text shall be 3/16 inch (4.8 mm) high minimum based on the uppercase letter "I" or, where the display size is not part of the product, 14 pt type.
REF ADAAG - 707.7.2 Characters.
Volume Notes
- dBA is used when talking about background signal because it filters out things that you cannot hear
- when talking about speech out or other out generated sounds you generally talk about dB SPL because you don't need to do an A weighting because you don't generate output that is outside of hearing range.
- 35 dBA SPL - empty classroom (standard)
- 40 dBA SPL - Quiet room
- 65-70 dB SPL - two people talking at about a meter from each other. (average speech level)
- 75-80 dB SPL - would be loud speech.
To accommodate people with mild hard of hearing add 10-15 which
How to measure
Do a long term average value of the output (LEQ or RMS value) (this is used most by Europe)
Distortion
Distortion also important for understanding (in addition to volume)
Report done for Access Board
U.S. Access Board Final Report, December 1999. Please cite this report as follows: Bakke, M. H., Levitt, H., Ross, M., & Erickson, F. (1999). Large area assistive listening systems (ALS): Review and recommendations: Final report to United States Architectural and Transportation Barriers Compliance Board (U.S. Access Board), Lexington School for the Deaf/Center for the Deaf, Rehabilitation Engineering Research Center on Hearing Enhancement, New York. Retrieved January 24, 2006, from http://www.hearingresearch.org/Pubs/Access_Bd_Final_Report.pdf.
BEST SUGGESTED LANGUAGE
All products must allow users to adjust the audio level, and must at peak volume output, have less than 12 dB symmetrical clipping or a total harmonic distortion (THD) less than XXX dB
- For products used in a public place, the maximum volume level must be at least 80 dB SPL RMS
- For products that will not be used in public places or where the volume of the public place is controlled to be under 50 dBA SPL RMS, the maximum volume level must be at least 65 dB SPL RMS.
WhitneyQ: Suggest slight edit for first paragraph:
All products with audio output must allow users to adjust the audio level. At peak volume output they must have less than 12 dB symmetrical clipping or a total harmonic distortion (THD) less than XXX dB
