Note

This archival content is maintained by WebAIM and NCDAE on behalf of TEITAC and the U.S. Access Board . Additional and up-to-date details on the updates to section 508 and section 255 can be found at the Access Board web site.

Draft Report 2007-04-16

Composite of Subcommittee draft reports due April 16, 2007.

Contents

Subpart A — General

Current provision Keep current language? Change in jurisdiction? Modification Rationale:  Why is this change suggested? Economic Assessment
row1 yes/no yes/no mod1 why1 cost1
row2 yes/no yes/no mod2 why2 cost2
row3 yes/no yes/no mod3 why3 cost3
row4 yes/no yes/no mod4 why4 cost4
row5 yes/no yes/no mod5 why5 cost5
row6 yes/no yes/no mod6 why6 cost6
row7 yes/no yes/no mod7 why7 cost7
row8 yes/no yes/no mod8 why8 cost8
row9 yes/no yes/no mod9 why9 cost9


New provision Rationale:  What issue does this provision address? Economic Assessment
new1 why1 cost1
new2 why2 cost2
new3 why3 cost3



 


 

 

Subpart B — Technical Standards

1194.21 Software applications and operating systems.

1194.22 Web-based intranet and internet information and applications.

Interim Reports > Draft 2 Submission


Recommendations on existing 1194.21 provisions

Current provision Keep current language? Change in jurisdiction? Modification Rationale:  Why is this change suggested? Economic Assessment
1194.21 (a) no no TBD
  • Some think current wording is fine
  • Some think we need to improve the wording of "textually discernible" but not raise the bar in 508 to include free-form drawing.
  • Some think we should harmonize with ISO and require that free-form drawing be keyboard operable. Within this group, there are some who still do not like the specific ISO wording.
TBD
1194.21 (b) no no TBD "other products" is a testability issue. TBD
1194.21 (c) no no Software shall provide a visual indication of which user interface object currently has the keyboard focus. If the object is a text entry field, a visual indication of the text insertion point shall be provided, and is sufficient. Clarification that both an object cursor and text caret are not needed for text entry fields. Harmonization with ISO 9241-171. 0
1194.21 (d) no no Software that provides user interface objects shall either use the accessibility services provided by platform software or other services to cooperate with assistive technologies when such services allow the software to meet the accessibility provisions of this standard. Using such services, software shall:
  • provide assistive technology with object information including but not limited to:
    • role, state(s), boundary, name, and description
    • any table row & column, and row & column headers (if the object is in a table)
    • current value and any minimum or maximum (if the object represents one of a range of values)
    • relationship this object has as a label for another, or being labelled by another
    • parent or containing element, and any children objects
    • text contents, text attributes, and the boundary of text rendered to the screen
  • provide assistive technology with a list of actions that can be executed on an object and allow assistive technology to programmatically execute any of those actions;
  • allow assistive technology to track and modify focus, text insertion point, and selection attributes of user interface objects;
  • provide assistive technology with notification of events relevant to user interactions, including but not limited to changes in the object's state(s), value, name, description, or boundary
21 (d) does not sufficiently enumerate the information that is required for interoperability with AT. This recommendation has been worded to harmonize with ISO 9241-171. +
1194.21 (e) yes no Critical for assistive technologies, such as screen readers, that render content in a different modality. 0
1194.21 (f) no yes Delete this provision. This requiement is covered in the proposed modification to 21(d). 0
1194.21 (g) no no Applications shall utilize user selected contrast and color selections and other individual display attributes when the availability of those selections are developed and documented according to industry standards. Subjective interpretation of "shall not override". 0
1194.21 (h) no no When an informational animation is displayed that will last for more than three seconds, software shall give the user a means to pause and restart the animation. When a decorative animation is displayed that will last for more than three seconds, software shall give the user a means to stop the animation.
  • alternatives should not be required if the animation conforms to all of the requirements in this section; that is, it is accessible. If animations don't conform, a static alternative can be provided under equivalent facilitation.
  • for decorative animations, stopping is sufficient. There is no need to provide a mechanism to restart it.
+
1194.21 (i) yes no 0
1194.21 (j) no no When a product permits a user to adjust color and contrast settings, at least one color selection capable of producing a minimum luminosity contrast ratio of n:1 shall be provided. Default combinations of foreground and background colours (hue and luminance) should produce a minimum luminosity contrast ratio of n:1 Current provision is weak and unfailable. If an app doesn't permit the user to adjust color and contrast settings, it passes. If it does permit the user to adjust them, the requirement to provide "a variety of color selections capable of producing a range of contrast levels" is so subjective that they all pass. +
1194.21 (k) no no TBD. Upper bound should be 50Hz. Too restrictive. Small things, such as a blinking text cursor, that fail this provision do not cause problems. Harmonize with WCAG 2.0. 0
1194.21 (l) yes no 0


Recommendations on New Provisions for 1194.22

New provision Rationale:  What issue does this provision address? Economic Assessment
Keyboard operability provision TBD. Replaces current provision on server side image maps. Also needed for JavaScript and other Web technology implementations. TBD
The purpose of each link shall be capable of being determined from the link text and its programmatically determinable link context. Combined with new keyboard operability provision, ensures that server side image maps are accessible. TBD
Information and relationships conveyed through presentation shall be programmatically determinable, and notification of changes to these is available to user agents, including assistive technologies. For example:
  • row and column headers are identifed for data tables
  • markup is used to associate data cells and header cells for data tables that have two or more logical levels of row or column headers.
  • markup is used to identify section headings
Technology-neutral provision that replaces technology-specific provisions on table headers TBD
A focus cursor shall be provided that visually indicates which user interface element currently has the keyboard input focus, as well as the focus location within that element when one exists. The focus cursor shall be programmatically determinable so that assistive technology can track focus and focus changes. Focus cursors are provided by user agents for some technologies (HTML, PDF, etc.) but are needed for other technologies (JavaScript, Flash, etc.) TBD
For all user interface components, the name and role shall be programmatically determinable, states, properties, and values that can be set by the user shall be programmatically determinable and can be programmatically set, and notification of changes to these items is available to user agents, including assistive technologies. For example:
  • Frames shall be titled with text that facilitates frame identification and navigation.
Needed for non-HTML technologies and when re-purposing HTML elements such as
which has no semantic meaning by default.
TBD
Components that have the same functionality within a set of Web units shall be identified consistently. WCAG 2.0 requirement needed to ensure that the 1194.22 is complete if 1194.22(m) is removed. TBD
For each time limit that is set by the content, at least one of the following is true:
  • Deactivate: the user shall be allowed to deactivate the time limit; or
  • Adjust: the user shall be allowed to adjust the time limit over a wide range that is at least ten times the length of the default setting; or
  • Extend: the user shall be warned before time expires and given at least 20 seconds to extend the time limit with a simple action (for example, "hit any key"), and the user is allowed to extend the time limit at least ten times; or
  • Real-time Exception: the time limit is an important part of a real-time event (for example, an auction), and no alternative to the time limit is possible; or
  • Essential Exception: the time limit is part of an activity where timing is essential (for example, competitive gaming or time-based testing) and time limits can not be extended further without invalidating the activity.
WCAG 2.0 requirement needed to ensure that the 1194.22 is complete if 1194.22(m) is removed. TBD
Content shall be capable of being paused by the user unless the timing or movement is part of an activity where timing or movement is essential. WCAG 2.0 requirement needed to ensure that the 1194.22 is complete if 1194.22(m) is removed. TBD
Text, images of text, or diagrams, and their respective backgrounds, shall have a luminosity contrast ratio of at least n:1. WCAG 2.0 requirement needed to ensure that the 1194.22 is complete if 1194.22(m) is removed. TBD

Recommendations on a new section to cover content formats

The Web and Software subcommittee was charged with looking at the issue of accessible content - e-mail, attachments in e-mail, etc. One issue is that the content format itself has to have certain features to enable the creation of accessible content. We therefore recommend adding a section that defines the necessary accessibility features. Agencies should store information only in compliant content formats and should therefore purchase products that support compliant content formats. Note that content creators still have to utilize the features in order for the content to actually be accessible.

New provision Rationale:  What issue does this provision address? Economic Assessment
When a content format supports non-text objects, an encoding mechanism shall be provided to associate non-text objects with textual descriptions displayable by a user-agent. See rationale in introductory paragraph above. TBD
When a content format supports multimedia, an encoding mechanism shall be provided to include synchronized text of verbal content, and audio descriptions of critical nonverbal activity displayable by a user-agent. See rationale in introductory paragraph above. TBD
When a content format supports 2 dimensional display of information, an encoding mechanism shall be provided to identify the logical linear reading order of the content displayable by a user-agent. See rationale in introductory paragraph above. TBD
When a content format supports row and column headers in data tables, an encoding mechanism shall be provided to identify row and column headers for data tables displayable by a user-agent. See rationale in introductory paragraph above. TBD
When a content format supports data tables that have two or more logical levels of row or column headers, an encoding mechanism shall be provided to associate row and column headers with data cells, displayable by a user-agent. See rationale in introductory paragraph above. TBD
When a content format supports interactive elements, an encoding mechanism shall be provided to identify name, operation, and state, of any interactive elements displayable by a user-agent. See rationale in introductory paragraph above. TBD
When a content format supports links, an encoding mechanism shall be provided to identify link text displayable by a user-agent. See rationale in introductory paragraph above. TBD
When a content format supports embedded comments, an encoding mechanism shall be provided to identify embedded comments and associate those comment locations within the document. See rationale in introductory paragraph above. TBD
When a content format supports scanned images of text, an encoding mechanism shall be provided to identify text of scanned images of text, displayable by a user-agent. Note, this means allowing for inclusion of the text of a scanned image of text. See rationale in introductory paragraph above. TBD
When a content format supports dynamic presentations, graphs, or other extracted information, an encoding mechanism shall be provided to include data used for any dynamic presentations, graphs, or other extracted information displayable by a user-agent. See rationale in introductory paragraph above. TBD



 


 

D.  Other Recommendations

  • The Access Board should provide a document, for historical purposes, explaining the changes from the current standard to the new standard and the rationale for each.

</noinclude>

 


 

1194.23 Telecommunications products.  Includes Section 255

Current provision Keep current language? Change in jurisdiction? Modification Rationale:  Why is this change suggested? Economic Assessment
1194.23(a) no no (a) Telecommunications products and other products capable of providing real-time voice communications and do not themselves provide TTY or other real-time text conversation functionality:
  1. shall provide a standard non-acoustic connection point for TTYs all analog and TDM-digital wired telephones must be equipped with an RJ11 jack or have built in capability to support an RJ11 module that can provide a connection point for TTYs;
  2. A terminal that does not have send and receive capability for real-time text shall support the connection of real-time text capable devices in conjunction with the voice call capability in the same location and the same permissions for use as the terminal.  NOTE: Terminals can be hardware or software based.
  3. shall be capable of allowing simultaneous speech and text without interference or its microphone shall be capable of being turned on and off to allow the user to intermix speech with text [TTY] use.
Is there a legal def of real-time comm?  Proposed Definition:  Two-way communcations that employ transmission of conversational, remote interactions wherein the characters are transmitted w/in 1 sec. of time created.  
1194.23(b) no no (b) Products that provide real-time voice conversation text functionality shall do so in the standard format that is supported for that transport medium.
  1. products that connect directly to the PSTN shall support TIA 825 Baudot where they interface to the PSTN;
  2. Products that connect directly to the Internet via SIP shall support RFC 4103 where they interface to the Internet via SIP
  3. All other Products (including PBX, cellular, and peer to peer Internet phones) that do not connect to PSTN or use SIP over the Internet shall support the standard real-time text format for that system.  These systems only need to support TIA 825 Baudot at the juncture to the PSTN (if any) and only need to support RFC 4103 at the point where they connect to public SIP systems (if any).
   
1194.23(c) no no (c) Voice mail, messaging, auto-attendant, and interactive voice response telecommunications systems shall:
  1. be usable by TTY users with their TTYs and by individuals using relay services including voice carry over, hearing carry over, video relay, and speech-to-speech relay services,
  2. have audio capability sufficient for high intelligibility,
  3. have highly intelligible recorded messages and prompts without any background sounds that would reduce intelligibility,
  4. provide full player controls that allow users to pause, rewind, slow down and repeat all messages and prompts, and adjust volume,
  5. include menus that contain no more than 6 items,
  6. provide easy to understand and act upon menu items and other navigational messages,
  7. provide controls that are consistent throughout the application,
  8. allow the user to correct any errors or confirm any input that would lead to permanent changes in their account or profile
  9. Have an “easy out” to reach a live customer service representative.
   
1194.23(d) yes no (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. n/a 0
1194.23(e) no no (e) Where provided, visual interfaces for telecommunications status information such as caller identification and similar telecommunications functions as part of interactive voice response systems or equivalents shall also be available for users of TTYs or other text conversation systems, and for users who cannot see displays and shall meet all accessibility provisions for software and content. Issue:  Does mute have to be its own button, not a function softkey?  
1194.23(f) no no (f) For receive transmitted voice signals,
  1. line powered telecommunications products shall comply with FCC regulation §68.317 for volume control,

OR

  1. * telecommunications products shall provide a built in 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.
  2. all other telecommunications products or systems that provide a function allowing voice communication shall provide a gain adjustable up to a minimum of 20? dB with [.For] incremental volume control of at least one intermediate step of 12 dB of gain [shall be] provided as measured and documented in accordance with the provisions of the FCC regulation &sect68.317 for volume control.
   
1194.23(g) no no (g) If the telecommunications product allows a user to adjust the receive volume, a function shall be provided to automatically reset the volume to a safe level after every use if the volume is capable of greater than 18 dB of gain along with an option for user override of that automatic default.    
1194.23(h) no no (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 that allows the user of such technologies to effectively utilize the telecommunication product.  This guideline shall apply to wireless, wireline, cordless and Bluetooth ?? applications.    
1194.23(i) yes no (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.   0
1194.23(j) yes no (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.  Firewalls, routers, gateways and other products that pass real-time voice communication shall also pass real-time text communication signals (including mixed voice & real-time text) that are standard for that technology platform without distortion or error beyond 1%.
  1. for PSTN this would be TIA/EIA 825 Baudot.

NOTE:  Only phones that are passing text signals onto another device, e.g. TTY, would be subject to this provision.

   
1194.24(k)   YES (k) Products which have mechanically operated controls or keys, shall comply with the following... Moved to HARDWARE  

 

'


New provision Rationale:  What issue does this provision address? Economic Assessment
(x)  The user interface of IP terminals that provide real-time voice communication shall meet the following provisions:
  1. IP terminal user interfaces that have a multiline display shall display any real-time text that is received in the standard format for that platform;
  2. IP terminal user interfaces that have the ability to generate text shall allow sending real-time text in the standard real-time text format for that platform;
  3. Such real time text send and receive capabilities shall be synchronized with voice as part of the same communication session.
IP version of 1194.23(a) Cheaper, easier to do than hardware to t/c products.
(x) Systems that support real-time voice communication shall support at least one standard (for the system) means for real time text communication that is supported by all terminal, router, gateway and other products on that system, and that meets the following requirements:
  1. Provides transmission of character with less than 1 second delay from entry;
  2. Provides transmission with less than 1% character error under normal but heavy network traffic;
  3. Support intermixing of speech and text in both directions (simultaneously if and only if IP based).
  4. IP systems cannot rely upon audio channels for transmission of real-time text.
IP version of 1194.23(b)  



 


 

 

1194.24 Video and multimedia products.

Current provision Keep current language Change in Jurisdiction? Modification Rationale:  Why is this change suggested?
1194.24(a) All analog television displays 13 inches and larger, and computerequipment that includes analog television receiver or display circuitry,shall be equipped with caption decoder circuitry which appropriatelyreceives, decodes, and displays closed captions from broadcast, cable,videotape, and DVD signals. As soon as practicable, but not later than July 1, 2002, widescreen digital television (DTV) displays measuring at least 7.8 inches vertically, DTV sets with conventional displays measuring at least 13 inches vertically, and stand-alone DTV tuners, whether or not they aremarketed with display screens, and computer equipment that includes DTV receiver or display circuitry, shall be equipped with caption decoder circuitry which appropriately receives, decodes, and displays closedcaptions from broadcast, cable, videotape, and DVD signals. no   All analog television displays measured 13 inches diagonally and larger, and computer equipment that includes analog television receiver or display circuitry, shall be equipped with caption decoder circuitry which appropriately receives, decodes, and displays CEA 608-standard closedcaptions from broadcast, cable, satellite, videotape, and DVD signals. Wide-screen (16:9) digital television (DTV) displays measuring at least 7.8 inches vertically, DTV sets with conventional (4:3) displays measuring at least 13 inches diagonally, and stand-alone DTV tuners, whether or not theyare marketed with display screens, and computer equipment that includes DTV receiver or display circuitry, shall be equipped with CEA 708-standard caption decoder circuitry which appropriately receives, decodes, and displays closed captions from broadcast, cable, satellite, videotape, and DVD signals. HD-DVD, BluRay and other digital video source devices must either pass CEA 708 data, when available, to the caption decoding circuitry of DTV displays or must decode CEA 708 data, when available, and pass an open-captioned signal to the DTV display. Updated to include new technology and standards, such as EIA-708, HD-DTV, BlueRay, etc.
1194.24(b) Television tuners, including tuner cards for use in computers, shall be equipped with secondary audio program playback circuitry. no   Analog-signal television tuners, including tuner cards for use in computers, shall be equipped with secondary audio program playback circuitry for support of video description. Digital-signal television tuners, including tuner cards for use in computers, shall be equipped with ancillary audio program playback circuitry for support of video description. Ensure that descriptions are supported in both analog and digital environments.
1194.24(c) All training and informational video and multimedia productions which support the agency's mission, regardless of format, that contain speech or other audio information necessary for the comprehension of the content, shall be open or closed captioned. no   All materials containing video and/or audio, regardless of format, that contain speech or other audio information necessary for the comprehension of the content, must comply with the following:
  1. Materials containing prerecorded audio and no additional time-based content must provide either a transcript or synchronized captions.
  2. Materials containing prerecorded video with concurrent audio must provide synchronized captions and may offer a transcript in addition to, but not in place of, the captions.
  3. materials containing real-time audio, with or without video, must provide synchronized real-time captions.
  1. Clarify the use of transcripts.
  2. Clarify language regarding real-time captions.
1194.24(d) All training and informational video and multimedia productions which support the agency’s mission, regardless of format, that contain visual information necessary for the comprehension of the content, shall be audio described. no   All materials containing video and/or audio, regardless of format, that contain visual information necessary for the comprehension of the content, must comply with the following:
  1. Materials containing prerecorded video and no audio or other additional time-based content must provide either a separate text description of the video or provide an additional audio track to convey the informational content of the video.
  2. Materials containing prerecorded video with concurrent audio must provide synchronized audio descriptions, or a separate text description of the video, to convey the informational content of the video.
  3. Materials containing live video must provide synchronized audio descriptions in real time to convey the informational content of the video.
  1. Clarify the use of transcripts.
  2. Clarify language regarding real-time descriptions.
1194.24(e) Display or presentation of alternate text presentation or audio descriptions shall be user-selectable unless permanent. no   At the time of playback, captions and/or audio descriptions must be either (a) capable of being turned on and off (“closed”), or (b) visible or audible to all users (“open”). Clarify language regarding open vs closed captions/descriptions.


New provision Rationale:  What issue does this provision address?
1194.24(f) All materials containing interactive elements that are part of the content must comply with 1194.21 [a-z] as well as 1194.24 a-e. Ensure that interactive materials that are part of a video/audio presentation are accessible.


Quality and placement of captioning/text descriptions need to be addressed and provided specs for multimedia design, type of fonts, and delivery.

Clarification is needed to ensure that transcripts are not an option in place of captioning, but rather to supplement the captioned live programs/prerecorded videos or materials.


 

1194.25 Self contained, closed products.

Current provision Keep current language? Change in jurisdiction? Modification Rationale:  Why is this change suggested? Economic Assessment
1194.25 (a) Self contained products shall be usable by people with disabilities without requiring an end-user to attach assistive technology to the product. Personal headsets for private listening are not assistive technology. no no If any functionality of a hardware or software product is closed for any reason, including hardware, setting or policy, such that assistive technology for a particular user group cannot be used with the product, then the product functionality must be fully usable by that group without AT. (Headsets for private listening are not considered AT). Self-contained is a functional characteristic of either hardware or software features of a product rather than of a class of products. This provision will apply to products that are partially or completely locked to AT and clarifies that other modes need to be provided in such cases. 0
1194.25 (b) When a timed response is required, the user shall be alerted and given sufficient time to indicate more time is required. yes Software N/A Software provision applicable whether a feature is closed or open to AT. 0
1194.25 (c) Where a product utilizes touchscreens or contact-sensitive controls, an input method shall be provided that complies with §1194.23 (k) (1) through (4). Yes Hardware N/A Controls, whether touch screen or mechanical, are a hardware function applicable to product features that are closed or open to AT. 0
1194.25 (d) When biometric forms of user identification or control are used, an alternative form of identification or activation, which does not require the user to possess particular biological characteristics, shall also be provided. No General Under Discussion May need clarification that this provision applies to biometrics related to product usage rather than biometrics for other purposes. 0
1194.25 (e) When products provide auditory output, the audio signal shall be provided at a standard signal level through an industry standard connector that will

allow for private listening.  The product must provide the ability to interrupt, pause, and restart the audio at anytime.

yes First sentence moved to hardware; second sentence moved to software. Further discussion This is two provisions and should be designated in hardware and software respectively. 0
1194.25 (f) When products deliver voice output in a public area, incremental volume control shall be provided with output amplification up to a level of at least 65 dB. Where the ambient noise level of the environment is above 45 dB, a volume gain of at least 20 dB above the ambient level shall be user selectable. A function shall be provided to automatically reset the volume to the default level after every use. not determined not determined N/D N/D N/D
1194.25 (g) Color coding shall not be used as the only means of conveying information, indicating an action, prompting a response, or distinguishing a visual element. yes General N/A Applicable to all products hardware/software, closed/open to AT 0
1194.25 (h) When a product permits a user to adjust color and contrast settings, a range of color selections capable of producing a variety of contrast levels shall be provided. yes software N/A This is a function of software. 0
1194.25 (i) Products shall be designed to avoid causing the screen to flicker with a frequency greater than 2 Hz and lower than 55 Hz. no software 55 HZ modified to 50 HZ Not correctly implemented from the EITAAC 0
1194.25 (j) Products which are freestanding, non-portable, and intended to be used in one location and which have operable controls shall comply with the following: (1) The position of any operable control shall be determined with respect to a vertical plane, which is 48 inches in length, centered on the operable control, and at the maximum protrusion of the product within the 48 inch length (see Figure 1 of this part). (2) Where any operable control is 10 inches or less behind the reference plane, the height shall be 54 inches maximum and 15 inches minimum above the floor. (3) Where any operable control is more than 10 inches and not more than 24 inches behind the reference plane, the height shall be 46 inches maximum and 15 inches minimum above the floor. (4) Operable controls shall not be more than 24 inches behind the reference plane (see Figure 2 of this part). yes hardware N/A Applies to any stand alone hardware 0

 

1194.26 Desktop and portable computers.

I.  Material which can be described as “Changes to Existing Provisions”

  1. Modification – Material which modifies existing provisions.
  2. Rationale – Why is this change suggested?
  3. Estimated Economic Impact. This field should contain the Subcommittee’s rough estimate of total impact on the economy. These changes should be measured from the current 508 standard only. For example, if the provision is not different, there is no net economic impact.
  • Cost impact is coded as:
    • “0” for negligible impact
    • “-“ for minor negative impact
    • “+” for minor positive impact
    • “- -“ for major negative impact
    • “++” for major positive impact


Current provision Keep current language Change Group? Modification Rationale:  Why is this change suggested? Comment Cost Impact
  1194.26 (a) All mechanically operated controls and keys shall comply with § 1194.23 (k) (1) through (4).   Yes   No   See individual .23 k(1-4)       0
  1194.23 (k) (1) Controls and keys shall be tactilely discernible without activating the controls or keys.   Yes   No         0
  1194.23 (k) (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.   Yes   No   Controls and keys shall be operable with one hand and shall not require pinching, twisting of the wrist, or tight grasping. The force required to activate controls and keys shall be 5 lbs. (22.2 N) maximum.   Change language to provide clarity relative to application of tight.   Should consider clearly defining what is meant by each characteristic and static or dynamic nature of movement. Also, should reference ISO Keyboard standards as guidance for keyboard forces.   -
  1194.23 (k) (3) If key repeat is supported, the delay before repeat shall be adjustable to at least 2 seconds. Key repeat rate shall be adjustable to 2 seconds per character.   Yes   No         0
  1194.23 (k) (4) The status of all locking or toggle controls or keys shall be visually discernible, and discernible either through touch or sound.   Yes   No         0
  1194.25 (c) and also 1194.26 (b) If a product utilizes touch screens or touch-operated controls, an input method shall be provided that complies with § 1194.23 (k) (1) through (4).            
  1194.26 (c) When biometric forms of user identification or control are used, an alternative form of identification or activation, which does not require the user to possess particular biological characteristics, shall also be provided.     Yes - General         0
  1194.26 (d) Where provided, at least one of each type of expansion slots, ports and connectors shall comply with publicly available industry standards.   No   No   Where provided, at least one of each type of expansion slots, ports, connectors, and wireless connection shall comply with publicly available industry standards.   Wireless options should be considered as potential ports.     0
  1194.25 (j) (1) Products which are freestanding, non-portable, and intended to be used in one location and which have operable controls shall comply with the following. The position of any operable control shall be determined with respect to a vertical plane, which is 48 inches in length, centered on the operable control, and at the maximum protrusion of the product within the 48 inch length on products which are freestanding, non-portable, and intended to be used in one location and which have operable controls.   Yes   From self-contained         0
  1194.25 (j) (2) Products which are freestanding, non-portable, and intended to be used in one location and which have operable controls shall comply with the following. Where any operable control is 10 inches or less behind the reference plane, the height shall be 54 inches maximum and 15 inches minimum above the floor.   No   From self-contained   Change 54 inches to 48 inches   Align with recent ADAAG changes     -
  1194.25 (j) (3) Products which are freestanding, non-portable, and intended to be used in one location and which have operable controls shall comply with the following, Where any operable control is more than 10 inches and not more than 24 inches behind the reference plane, the height shall be 46 inches maximum and 15 inches minimum above the floor.   Yes   From self-contained         -
  1194.25 (j) (4) Products which are freestanding, non-portable, and intended to be used in one location and which have operable controls shall comply with the following. Operable controls shall not be more than 24 inches behind the reference plane.   Yes   From self-contained         -



Team is in the process of reviewing JIS 83451 for applicable content.


 

Subpart C — Functional Performance Criteria

1194.31 Functional performance criteria.

Current provision Keep current language Change Group? Modification Rationale:  Why is this change suggested? Cost Impact
  1194.26 (c) When biometric forms of user identification or control are used, an alternative form of identification or activation, which does not require the user to possess particular biological characteristics, shall also be provided.   Yes   Came here from Hardware   No   No impact.
  {508} S 1194.31 (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.

{255}S 1193.41 (*)(a) Operable without vision. Provide at least one mode that does not require user vision.

 No  No   At least one mode shall be provided that allows full use of product without using vision, directly or with users' AT.   Fixes 3 problems. 1- full use required for direct or AT, 2 - functions might be mixed (direct & AT) 3 - in order to be accessible via AT it must be AT users' have. (We have not specified which users). No impact. Text clarified which would cause minor decrease in implementation costs.
  {508} S 1194.31 (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.


{255}S 1193.41 (*)(b) Operable with low vision and limited or no hearing. Provide at least one mode that permits operation by users with visual acuity between 20/70 and 20/200, without relying on audio output. S 1193.43 (*)(b) Availability of visual information for low vision users. Provide visual information through at least one mode to users with visual acuity between 20/70 and 20/200 without relying on audio.

 No  No  At least one mode shall be provided that allows full use of product without requiring visual acuity greater than 20/70, and that allows audio and enlarged text output to work together or independently, directly or with users' AT.   Fixes same 3 problems No impact. Text clarified which would cause minor decrease in implementation costs.
  {508}S 1194.31 (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.

{255} S 1193.41 (*)(d) Operable without hearing. Provide at least one mode that does not require user auditory perception. S 1193.43 (*)(d) Availability of auditory information. Provide auditory information through at least one mode in visual form and, where appropriate, in tactile form.

 No  No   At least one mode shall be provided that allows full use of product without using hearing, directly or with users' AT.   Fixes same 3 problems No impact. Text clarified which would cause minor decrease in implementation costs.
  {508} S 1194.31 (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.


{255}S 1193.41 (*)(b) Operable with low vision and limited or no hearing. Provide at least one mode that permits operation by users with visual acuity between 20/70 and 20/200, without relying on audio output.

 No  No  Where audio information is important for the use of a product,At least one mode shall be provided that allows full use of product with enhanced audio, directly or with users' AT.   Fixes same 3 problems No impact. Text clarified which would cause minor decrease in implementation costs.
  {508} S 1194.31 (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.


{255}S 1193.41 (*)(h) Operable without speech. Provide at least one mode that does not require user speech.

 No  No  At least one mode shall be provided that allows full use of product without using speech, directly or with users' AT.   Fixes same 3 problems No impact. Text clarified which would cause minor decrease in implementation costs.
  {255}S 1193.31 (*)(e) Operable with limited manual dexterity. Provide at least one mode that does not require user fine motor control or simultaneous actions. S 1193.41 (*)(f) Operable with limited reach and strength. Provide at least one mode that is operable with user limited reach and strength.  No  No  At least one mode shall be provided that allows full use of product with limited reach and strength and without simultaneous actions, directly or with users' AT.   Fixes same 3 problems PLUS adds AT in a way that works (since good for some parts but not for others) Adds AT option. Should potentially reduce cost to companies by giving additional options - and increase productivity and employment by people with disabilities. So this would decrease costs and increase benefits.
  {508} NONE
{255}S 1193.41 (*)(i) Operable with limited cognitive skills. Provide at least one mode that minimizes the cognitive, memory, language, and learning skills required of the user.
 No  No  At least one mode shall be provided that accommodates cognitive, language or learning impairments, directly or with users' AT.   To cover cognitive, language and learning aspects. This is one of the largest or the largest group of people with disabilities in the government. The cost in increased productivity can be great. Even simplification act has talked about using plain language. And GSA reports that there is some guidance there to use plain language. The cost to learn to write plainly though is not known or other aspects of this. The benefits are believed to outweigh costs in the end however so a net decrease in cost is believed.
  {508}"S 1194.21 (k) Software shall not use flashing or blinking text, objects, or other elements having a flash or blink frequency greater than 2 Hz and lower than 55 Hz.


S 1194.22 (j) Pages shall be designed to avoid causing the screen to flicker with a frequency greater than 2 Hz and lower than 55 Hz.
S 1194.25 (i) Products shall be designed to avoid causing the screen to flicker with a frequency greater than 2 Hz and lower than 55 Hz."
{255}S 1193.43 (*)(f) Prevention of visually-induced seizures. Visual displays and indicators shall minimize visual flicker that might induce seizures in people with photosensitive epilepsy.

 No     At LEAST needs to be 50 HZ

should be changed to limit to flashing no more than 3 per 1 second period that are larger that is greater 25% of the central 10 degrees of vision. (that can be made simpler by assuming viewing distance) That will eliminate worrying about small indicators or areas of the screen. Haven't worked on this yet. NOTE: Keeping flashing to less than 3 per 1 second period would meet the above spec.

  General since it can be hardware, software, Media, Content. @@ should add text to indicate that is is to avoid seizures not distraction. Should lower costs by allowing removing Flash restrictions from things that are not problems.


Can't use 508 organization - that is mixed product domains, characteristics and applications. And we can't use committee structure because some committees are product function (telecom) while some are characteristics (closed, involve hardware) and some are mixed (have software with an OS + content).

Recommend a linear sortable presentation of the provisions that does not try to organize them by technology or disability. This listing can then be sorted or filtered to show which would apply to different domains, product types, applications or disabilities. This would also facilitate incorporation into an updated "buy accessible" tool.

The best organization we have now is the one that grew out of the blended approach.

LINEAR SORTABLE FORMAT

Linear Sortable Format

NOTE: All bulletted items are just short names for provisions that are being worked on by the different working groups. They are placeholders used for showing structure - not final wording of anything.

1 Overall Functional Performance Criteria

  • Full use without Vision - in at least one mode (direct or via AT)
  • Full use with Low Vision without Audio - in at least one mode (direct or via AT)
  • Full use without Hearing - in at least one mode (direct or via AT)
  • Full use with Enhance Audio - in at least one mode (direct or via AT)
  • Full use without Speech - in at least one mode (direct or via AT)
  • Full use with limited reach, strength or dexterity - in at least one mode (direct or via AT)
  • Full use with cognitive, language or learning disabilities - in at least one mode (direct or via AT)

2. Don't block use (both if direct access or access via AT)

  • If speaker held to the ear minimize hearing aid interference
  • Have no more than 3 flashes in one second above thresholds (Seizure)
  • Provide Alternative to biometric ID
  • Pass through non-proprietary Access signals

3. Build Accessibility Into Product

General - All products

  • If not operable by users AT (for any group), make product fully usable by that group without AT
  • No interference with Built in Access Features
  • Consistent use of images for controls, status, etc
  • All visual information (printed or displayed) in Auditory form in 1 mode
  • Impose No Time limitations or make time limit adjustable
    • If IVR (e.g.Voicemail, Auto-attend, Voice menus,,etc.) no time limit pr time limit adjustable. (subset of above?)
    • Make Any Key Repeat Delay & Rate Adjustable & Turn off (2 sec)

Input Devices

All Products with input devices

  • Provide Visual and either audio or tactile key status indicators
  • If touchscreen or touch control then provide non-touch alternate [and softkeys ?]
  • Make controls compatible with prosthetics

If the Product has Physical Controls

  • Controls meet ADAAG approach and Reach Specs
  • Controls meet ADAAG control specs.
    • Tactilely Discernable without activation
    • No require pinching, twisting of the wrist, or tight grasping.
    • If Keyrepeat then adjustable
    • Status of locking and toggle keys visual and auditory or tactile

If the Product has Standard Keyboard or keyboard interface

  • Make Product Operable Using Only Input to Standard Keyboard interface (or Keyboard equivalent)

Output Devices

If the Product has Visual Output or Display

  • Variety of Color & Font settings for Contrast
  • Information not provided in color alone.
  • At least 1 non-animated version available
  • Moving text available static in 1 mode
  • No override of display settings {if this includes audio then can't go here}

If the product has Audio Output

  • If speaker held to the ear provide hearing aid compatible coupling
  • Provide amplification for products in public places
  • Provide Voice amplification for Telecom
  • Loud volume auto reset (+indicator + override)
  • Standard Connector available for Audio Output

If product provides real-time voice conversation functionality

  • - ( Proposed text conversation Provisions would go here when finalized. )

If product (hardware or software) plays or displays AudioVideo material

  • Caption decode and Display supported
  • Players/Displays support Audio Descriptions

4. Make product work with adaptive assistive technology

Provide Software support for adaptive AT

  • All info and control avail to INTERNAL AT
    • Provide Text through API / OS Text tools
    • Focus Indicator Avail to AT (+clearly visible covered above)

Allow connection of external alternate presenters, controllers, and displays

  • Standard ports
  • Support connection of alternate interfaces
  • If product provides for real-time conversation then it must meet provisions
    • If not providing function itself then provide direct connect of standard real-teim Text Terminal& mic toggle
    • Support for standard text conversation signals
    • Voicemail, Auto-attend, & IVR work with Standard realtime text formats
    • Caller ID etc accessible to Blind & realtime text users

5. Content

General - all content

  • Alternate Text for all non-text elements
  • Documents readable without style sheets
  • Image map redundant links
  • Use Client-side image maps (w/ alt text)
  • Content provides Skip over navigation links
  • Accessible Electronic Forms
  • Headers provided on data tables
  • Table markup associates cells and headers
  • Link to conformant Plug-in provided
  • Frames have titles
  • Text alternative for scripts
  • Text-only page [ alternate accessible page ] -- (only if only way)

Audio and/or Video content

  • Provide synchronized alternatives to synchronized audio and video
  • AV Material is Captioned (Open or closed) {using format for that media}
  • Provide Audio description of video {using format for that media}
  • Captions & Audio Description User selectable unless Embedded in Video

6. Documentation, help, and support services

Documentation and help

  • Information and documentation is accessible ( +Web?)
  • Description of accessibility features avail

Support services

  • Accessible product support phone services
  • Contact information avail for access info
  • Accessible Product Training

7. Product Development & Installation Process & Tools

Process guidance

  • Include PWD throughout process (4 parts)
  • Changes shall not decrease access
  • Include access in design, devel, & fabrication

Authoring tools

(placeholder for any authoring tool guidelines that might be developed that aren't just software access which would be covered above)


B1 .  Issues this subcommittee has not yet addressed, but which should be addressed.

  • how to phrase the provisions so their coverage is clear
  • how to deal with provisions where there is a general overall one but some specific sub items
  • how to incorporate 'sufficient techniques' idea
  • bios questions
  • issues for cognitive language and learning
  • whether there is something to be done in allergy area
  • A method shall be provided to stop any blinking or movement that lasts more than 3 seconds. This is a first pass and needs work. Also check to be sure it isnt too broad. 1194.21(h) covers this for animation in software. Is this the only technology (thus should this go to software/web??)
  • Relationship of functional performance to closed?


  • review of other standards to determine provisions that need to be added
    • to make up for gaps in this standard
    • to cover new aspects not there or clear last time around
    • to increase quality of the standard
  • Cooperation between AT. (Should we even be talking about what AT should do? It is an adaptation to E&IT not an E&IT)

(some of this is being done in some other groups )


 

Subpart D — Information, Documentation, and Support

1194.41 Information, documentation, and support.

Documentation:April 16 Draft 1

WebAIM is an initiative of:
Center for Persons with Disabilities (CPD) Utah State University