Combined Telecommunications Standards
Section 508 (Subpart B §1194.23, Subpart C §1194.31, Subpart D §1194.41)
Section 255 (Subpart B §1193.23, Subpart C §1193.33–43, Subpart D §1193.51)
The standards are indented (blockquote). Some of the standards have bulleted (unordered list) questions or issues immediately following the standard. The set of initial questions and issues are based on the slides David Baquis used in his presentation to TEITAC and the slides provided by Paul Michaelis to the Telecommunication Subcommittee. Please take a look at this article and see if the groupings make sense and if this structure provides the subcommittee with a framework for tackling a comprehensive review. Comments and suggestions about the proposed structure should be made via the telecommunciations lists.
This document is a combined version of the Section 508 Telecommunications standards (1194.23) and the Section 255 standards (1193.23-1193.51) along with general Section 508 standards that correspond to Section 255 standards (1194.31 and 1194.41). The standards have been grouped into the following areas:
Basic Communications (that include text based) (§1194.23, §1193.51)
508 (a1) Telecommunications products or systems that provide a function allowing voice communication and do not themselves provide TTY functionality, shall provide a standard non-acoustic connection point for TTYs.
- Does this just mean a standard RJ-11 port is available?
- Or 2.5 and 2/3 mm jacks on wireless products?
255 (d) Products which provide a function allowing voice communication and which do not themselves provide a TTY functionality shall provide a standard non-acoustic connection point for TTYs.
508 (a2) Microphones shall be capable of being turned on and off to allow the user to intermix speech with TTY use.
- Is turning a microphone on and off all that is needed to ensure users are allowed to intermix speech and text (sending one and receiving the other)?
- What is the actual requirement -- the turning on and off of a microphone or the ability to send speech/receive text and send text/receive speech?
255 (d) It shall also be possible for the user to easily turn any microphone on and off to allow the user to intermix speech with TTY use.
508 (b) Telecommunications products, which include voice communication functionality, shall support all commonly used cross-manufacturer non-proprietary standard TTY signal protocols.
- If “commonly used” means just standard 45.5 baud Baudot, is that still appropriate?
- Does “non-proprietary standard TTY signal” include ASCII?
- Should IVR systems be required to support ASCII mode?
255 (e) Products, including those providing voice communication functionality, shall support use of all cross-manufacturer non-proprietary standard signals used by TTYs.
508 (c) Voice mail, messaging, auto-attendant, and interactive voice response telecommunications systems shall be usable by TTY users with their TTYs.
- Does this mean IVR systems must be usable in speaking/listening mode, text/text mode (TTY), speaking/text mode (VCO), and text/listening mode (HCO)?
- How can this be delivered if the system includes live communication at some point?
- Should there be a requirement for initial user selection of desired communication mode to eliminate the need for separate numbers?
508 (d) Voice mail, messaging, auto-attendant, and interactive voice response telecommunications systems that require a response from a user within a time interval, shall give an alert when the time interval is about to run out, and shall provide sufficient time for the user to indicate more time is required.
- Are there other access issues related to IVR systems (outside of timing) that should be addressed?
- Should any of the VVSG standards be utilized, e.g. speed of speech adjustment, pause options, etc.
Audio Output (§1194.23, §1193.43, §1193.51)
508 (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.
- Is there a conflict with OSHA standards?
- Is there a need to have a max output specified to prevent the gain from exceeding that level?
- Does the application to “transmitted voice signals” apply to both outgoing and incoming?
- Was 20 db of gain established as a universal design feature to meet the needs of individuals with mild hearing loss and to overcome ambient noise issues?
- Without establishment of a default level or range does the 20 db gain deliver access?
- What about individuals who need greater gain even assuming the default is adequate?
- Does the built-in amplification eliminate options for add on amplification through in-line amplifiers, etc.?
- Is gain the most critical factor in understanding speech?
- Does this or should system side gain be required (versus consumer premises product gain or in software based telecommunications products)?
255 (e) Provide audio or acoustic information, including any auditory feedback tones that are important for the use of the product, through at least one mode in enhanced auditory fashion (i.e., increased amplification, increased signal-to-noise ratio, or combination). For transmitted voice signals, provide a gain adjustable up to a minimum of 20 dB. For incremental volume control, provide at least one intermediate step of 12 dB of gain.
508 (g) If the telecommunications product allows a user to adjust the receive volume, a function shall be provided to automatically reset the volume to the default level after every use.
- Is this necessary if the gain is very small?
- Should the standard align with the FCC rule which requires reset only when the volume exceeds 18 dB gain?
- Should the language of this standard be revised to align with the FCC waiver provisions related to override of the volume reset?
508 (h) Where a telecommunications product delivers output by an audio transducer which is normally held up to the ear, a means for effective magnetic wireless coupling to hearing technologies shall be provided.
255 (i) Where a product delivers output by an audio transducer which is normally held up to the ear, provide a means for effective wireless coupling to hearing aids.
508 (i) Interference to hearing technologies (including hearing aids, cochlear implants, and assistive listening devices) shall be reduced to the lowest possible level that allows a user of hearing technologies to utilize the telecommunications product.
- Should metrics be added or a reference to ANSI/IEEE or other standards?
255 (h) Reduce interference to hearing technologies (including hearing aids, cochlear implants, and assistive listening devices) to the lowest possible level that allows a user to utilize the product.
255 (g) Where a product delivers audio output through an external speaker, provide an industry standard connector for headphones or personal listening devices (e.g., phone-like handset or earcup) which cuts off the speaker(s) when used.
255 (b) Products providing auditory output shall provide the auditory signal at a standard signal level through an industry standard connector.
Input Controls/Keys (§1194.23, §1193.51)
508 (k) Products which have mechanically operated controls or keys, shall comply with the following: (1) Controls and keys shall be tactilely discernible without activating the controls or keys. (2) Controls and keys shall be operable with one hand and shall not require tight grasping, pinching, or twisting of the wrist. The force required to activate controls and keys shall be 5 lbs. (22.2 N) maximum. (3) If key repeat is supported, the delay before repeat shall be adjustable to at least 2 seconds. The key repeat rate shall be adjustable to 2 seconds per character. (4) The status of all locking or toggle controls or keys shall be visually discernible, and discernible either through touch or sound.
255 (c) Touchscreen and touch-operated controls shall be operable without requiring body contact or close body proximity.
Comprehensive Signal Transmission (§1194.23 and §1193.37)
508 (j) Products that transmit or conduct information or communication shall pass through cross-manufacturer, non-proprietary, industry-standard codes, translation protocols, formats or other information necessary to provide the information or communication in a usable format. Technologies which use encoding, signal compression, format transformation, or similar techniques shall not remove information needed for access or shall restore it upon delivery.
- Is this where access of VoIP and issues related to VRS should be addressed? Can we ensure VRS access through existing IT systems versus separate broadband lines? Somewhat similar issue with the current analog requirement for captioned telephone VCO.
- Firewall problems with signal transmission/reception?
255 Telecommunications equipment and customer premises equipment shall pass through cross- manufacturer, non-proprietary, industry-standard codes, translation protocols, formats or other information necessary to provide telecommunications in an accessible format. In particular, signal compression technologies shall not remove information needed for access or shall restore it upon decompression
Functional Interaction (§1194.23, §1194.31, §1193.41. §1193.43, §1193.51)
508 (e) Where provided, caller identification and similar telecommunications functions shall also be available for users of TTYs, and for users who cannot see displays.
508 (a) At least one mode of operation and information retrieval that does not require user vision shall be provided, or support for assistive technology used by people who are blind or visually impaired shall be provided.
508 (b) At least one mode of operation and information retrieval that does not require visual acuity greater than 20/70 shall be provided in audio and enlarged print output working together or independently, or support for assistive technology used by people who are visually impaired shall be provided.
508 (c) At least one mode of operation and information retrieval that does not require user hearing shall be provided, or support for assistive technology used by people who are deaf or hard of hearing shall be provided.
508 (d) Where audio information is important for the use of a product, at least one mode of operation and information retrieval shall be provided in an enhanced auditory fashion, or support for assistive hearing devices shall be provided.
508 (e) At least one mode of operation and information retrieval that does not require user speech shall be provided, or support for assistive technology used by people with disabilities shall be provided.
508 (f) At least one mode of operation and information retrieval that does not require fine motor control or simultaneous actions and that is operable with limited reach and strength shall be provided.
255 - Input, control, and mechanical functions shall be locatable, identifiable, and
operable in accordance with each of the following, assessed independently:
(a) Provide at least one mode that does not require user vision.
(b) Provide at least one mode that permits operation by users with visual
acuity between 20/70 and 20/200, without relying on audio output.
(c) Provide at least one mode that does not require user color perception.
(d) Provide at least one mode that does not require user auditory perception.
(e) Provide at least one mode that does not require user fine motor control
or simultaneous actions.
(f) Provide at least one mode that is operable with user limited reach and strength.
(g) Provide at least one mode that does not require a response time.
Alternatively, a response time may be required if it can be by-passed or adjusted
by the user over a wide range.
(h) Provide at least one mode that does not require user speech.
(i) Provide at least one mode that minimizes the cognitive, memory, language,
and learning skills required of the user.
255 - All information necessary to operate and use the product, including but not limited to,
text, static or dynamic images, icons, labels, sounds, or incidental operating cues, shall
comply with each of the following, assessed independently:
(a) Provide visual information through at least one mode in auditory form.
(b) Povide visual information through at least one mode to users with visual acuity between
20/70 and 20/200 without relying on audio.
(c) Provide moving text in at least one static presentation mode at the option of the user.
(d) Provide auditory information through at least one mode in visual form and, where
appropriate, in tactile form.
255 (f) Visual displays and indicators shall minimize visual flicker that might induce seizures in people with photosensitive epilepsy.
255 (a) Information needed for the operation of products (including output, alerts, icons, on-line help, and documentation) shall be available in a standard electronic text format on a cross-industry standard port and all input to and control of a product shall allow for real time operation by electronic text input into a cross-industry standard external port and in cross-industry standard format. The cross-industry standard port shall not require manipulation of a connector by the user.
Information and Documentation (§1194.41 and §1193.33)
508 (a) Product support documentation provided to end-users shall be made available in alternate formats upon request, at no additional charge.
508 (b) End-users shall have access to a description of the accessibility and compatibility features of products in alternate formats or alternate methods upon request, at no additional charge.
508 (c) Support services for products shall accommodate the communication needs of end-users with disabilities.
255 (a) Manufacturers shall ensure access to information and documentation it provides to its customers.
Such information and documentation includes user guides, installation guides for end- user installable
devices, and product support communications, regarding both the product in general and the
accessibility features of the product. Manufacturers shall take such other steps as necessary including:
(1) Providing a description of the accessibility and compatibility features of the product upon
request, including, as needed, in alternate formats or alternate modes at no additional charge;
(2) Providing end-user product documentation in alternate formats or alternate modes upon
request at no additional charge; and
(3) Ensuring usable customer support and technical support in the call centers and service centers
which support their products at no additional charge.
255 (b) Manufacturers shall include in general product information the contact method for obtaining the information required by paragraph (a) of this section.
255(c) Where manufacturers provide employee training, they shall ensure it is appropriate to an employee's function. In developing, or incorporating existing training programs, consideration shall be given to the following factors: (1) Accessibility requirements of individuals with disabilities; (2) Means of communicating with individuals with disabilities; (3) Commonly used adaptive technology used with the manufacturer's products; (4) Designing for accessibility; and (5) Solutions for accessibility and compatibility.
Product Development/Design (§1193.23, §1193.39)
255 (a) Manufacturers shall evaluate the accessibility, usability, and compatibility of telecommunications equipment and customer premises equipment and shall incorporate such evaluation throughout product design, development, and fabrication, as early and consistently as possible. Manufacturers shall identify barriers to accessibility and usability as part of such a product design and development process.
255 (b) In developing such a process, manufacturers shall consider the following factors, as the manufacturer
deems appropriate:
(1) Where market research is undertaken, including individuals with disabilities in target populations
of such research;
(2) Where product design, testing, pilot demonstrations, and product trials are conducted, including
individuals with disabilities in such activities;
(3) Working cooperatively with appropriate disability-related organizations; and
(4) Making reasonable efforts to validate any unproven access solutions through testing with
individuals with disabilities or with appropriate disability-related organizations that have
established expertise with individuals with disabilities.
255 (a) No change shall be undertaken which decreases or has the effect of decreasing the net accessibility, usability, or compatibility of telecommunications equipment or customer premises equipment.
255 (b) Discontinuation of a product shall not be prohibited.
