EWG:Draft Jan 7

Editorial Working Group > Current Draft

The final report of the Committee, and all minority reports can be found on The Access Board web site. Just scroll down to the end of the chronological listing for both HTML and .DOC versions.

This page reflects the work of the Committee from the January in-person 
meeting the end of the committee work on April 3. This page was updated 
through the March 25 meeting, but final editorial adjustments to the 
provisions made as the final report was prepared may not be reflected 
in the version on this page. Please see the TEITAC final report. 

* Status Spreadsheet - an overview of the status of the work 

General Introduction

This language was accepted from the 508/255 Task Force to be used as a blanket rationale for the provisions regarding Section 255. It is placed in a general introduction because it affects provisions in Parts B, C and D. Note that language here, and elsewhere in the provisions are taken from the approved Task Force report "TF report 1. 9. 08.doc"

In establishing the rules implementing Section 255, the FCC has defined the types of products and services which must comply with the rules. The FCC has determined that the 255 rules also apply to information and documentation associated with the covered products, as well as information and documentation necessary to use the covered products. This information and documentation includes user guides, bills, installation guides for end-user installable devices, and product support and communications. Technical standards that would improve the accessibility of any of the items covered by Section 255, whether a phone, a printed user guide, or a web-based billing function, would be candidates for inclusion in the Access Board’s Section 255 guidelines. Unless otherwise noted, the technical standards apply to section 255, because they are necessary to make the covered products accessible to and usable by people with disabilities, consistent with Section 255.

Subpart A

Section 1194.1 Purpose

The purpose of this part is to implement section 508 of the Rehabilitation Act of 1973, as amended (29 U.S.C. 794d) and Section 255 of the Telecommunications Act, 47 U.S.C. 255.

Purpose for Section 255

Pursuant to Section 255 of the Telecommunications Act, this part provides requirements for accessibility, usability, and compatibility of new telecommunications and interconnected voice over Internet protocol (VoIP) products and customer premises equipment (CPE) used to provide telecommunications services or interconnected VoIP service, as well as existing products and CPE that undergo substantial change or upgrade, or for which new releases are distributed. This part does not apply to minor or insubstantial changes to existing products and CPE that do not affect functionality

Text from: Telecommunications §1193.2; FCC Report and Order No. 07-110, released June 15, 2007) – amended to include interconnected VoIP equipment and CPE (new material in italics)

Purpose for Section 508

Section 508 of the Rehabilitation Act requires that when Federal agencies develop, procure, maintain, or use telecommunications, electronic and information technology, Federal employees with disabilities have access to and use of information and data including communication that are as timely, accurate, complete, and efficient as compared to the access and use by Federal employees who are not individuals with disabilities, unless an undue burden would be imposed on the agency. Section 508 also requires that individuals with disabilities, who are members of the public seeking information or services from a Federal agency, have access to and use of information and data including communication that are as timely, accurate, complete, and efficient as compared to that provided to the public who are not individuals with disabilities, unless an undue burden would be imposed on the agency.

Explanatory Notes (for both 255 and 508 versions

• Timely access means that individuals with disabilities have

information and data available to them at the same time as individuals without disabilities, but that does not preclude captions that are slightly delayed or other reasonable differences in timing given individual situations.

• Accurate means that the information and data reflects the intended

meaning especially when converted into another form or media.

• Complete means that all critical information and data is present when

accessed by assistive technology or converted into another form or media.

• Efficient means that an individual with a disability exerts a

reasonably similar or comparable amount of effort (given the capacity of current assistive technology) in using electronic and information technology as compared to an individual without a disability.

Access may be delivered via built-in access features or compatibility with assistive technology as described in the technical requirements specified in Subpart C.

The determination of timely, accurate, complete, and efficient will not be a quantifiable measure.

Rationale: Federal procurement officials and other subcommittee members requested the addition of information to help guide them in determining when access to data and information for individuals with disabilities was "comparable" to that available for individuals without disabilities. The subcommittee relied on information from Office of Civil Rights decisions regarding comparable access to identify the critical concepts of "timely, accurate, complete and efficient". The explanatory note was developed to assist in assuring understanding and consistency in application. The subcommittee added the word "communication" to "information and data" to clarify that communication is part of information and data. While this information has been infused into the Purpose section, it could alternatively be added as a new section under Application.

• Status from on November plenary: Could not reach consensus
• Text from Subpart A Subcommittee
• Source: {508}1194.1
• Impact:
• External Reference:

Section 1194.2 Application

Multiple versions will be sent to the Access Board.

Application for Section 255

Where readily achievable, telecommunications and interconnected VoIP equipment and customer premises equipment must comply with the requirements of Part [C-Technical Requirements] of this [rule].

Where it is not readily achievable to comply with Part [C-Technical Requirements] , telecommunications and interconnected VoIP equipment and customer premises equipment must comply with the requirements of Part [B-Functional Performance Critera], if readily achievable.

Product design, development and evaluation (for equipment and CPE covered under Section 255)

(a) Manufacturers must evaluate the accessibility, usability, and compatibility of equipment and customer premises equipment used to provide telecommunications and interconnected VoIP services and must incorporate such evaluation throughout product design, development, and fabrication, as early and consistently as possible. Manufacturers must identify barriers to accessibility and usability as part of such a product design and development process.

(b) In development such a process, manufacturers must 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.

Prohibited reduction of accessibility, usability and compatibility

(a) For purposes of Section 255, no change must be undertaken which decreases or has the effect of decreasing the net accessibility, usability, or compatibility of telecommunications equipment, interconnected VoIP equipment, or customer premises equipment used with telecommunications or interconnected VoIP services.

(b) Exception: Discontinuation of a product must not be prohibited.

Text from: Telecommunications §1193.21 (first paragraph) and Telecommunications §1193.23 (second section).

Application for Section 508

In general, this section applies only to the consideration of accessibility in the process of developing, procuring, maintaining, or using electronic and information technology. (see note #1).

(a) Products covered by this part shall comply with all applicable provisions of this part. When developing, procuring, maintaining, or using electronic and information technology, each agency shall ensure that the products comply with the applicable provisions of this part, unless an undue burden would be imposed on the agency.

(1) When compliance with the provisions of this part imposes an undue burden, agencies shall provide individuals with disabilities with the information and data involved by an alternative means of access that allows the individual to use the information and data.

(2) When developing, procuring, maintaining, or using a product, if an agency determines that compliance with any provision of this part imposes an undue burden, the documentation by the agency supporting the development, procurement, maintenance, or use must explain why, and to what extent, compliance with each such provision creates an undue burden. (see note #2)

(3) When determining whether application of the standards would result in an undue burden, an agency must consider all agency resources available to the program or component for which the product is being developed, procured, maintained, or used.

(4) Technical infeasibility, if substantiated by empirical evidence or documentation, is one factor in determining whether application of the standards [provisions] would consitute an undue burden. (see note #3)

(b) When procuring a product, each agency shall procure products which comply with the provisions in this part when such products are available in the commercial marketplace or when such products are developed in response to a Government solicitation. Agencies cannot claim a product as a whole is not commercially available because no product in the marketplace meets all the standards.

If products that meet all of the standards are not commercially available the agency must procure the product that best meets the applicable access standards, given the agency's business needs. (see note #4)

(c) Except as provided by §1194.3(b), this part applies to electronic and information technology developed, procured, maintained, or used by agencies directly or used by a contractor under a contract with an agency which requires the use of such product, or requires the use, to a significant extent, of such product in the performance of a service or the furnishing of a product.

Rationale and Notes

Note 1: This additional introductory language is intended to clarify that all of the regulations in this section that impact agency procurement procedures, apply only to the consideration of accessibility. The additional language is not intended to provide regulatory direction regarding how agencies consider other factors, such as business and technical needs and requirements, when making an acquisition. The FAR defines procurement parameters for a number of agencies and agencies need to determine how to address accessibility within the parameters of other required procurement considerations and processes. The workgroup has discussed the fact that there have been varying interpretations of how Section 508 should be applied when making an acquisition. Agencies are required to consider accessibility within the framework of other regulated procurement practices such as the FAR. Consensus was not reached on this item and the alternative position is to not add this introductory language.

Note 2: The undue burden clause in prior regulations only applied to procurement. It is assumed the application of undue burden should apply to all areas covered by Section 508 including development, maintenance and use of E&IT in addition to procurement.

Note 3: Subsection (3) was added to infuse information from the definition of undue burden into the application section and subsection (4) was added to clarify how technical infeasibility is considered as part of undue burden.

Note 4: The last sentence of this subsection (in italics) has been reworded to clarify the use of “best meets” when products are not commercially available that comprehensively meet each and every standard, but might partially meet one or more individual standards or meet some but not all of the standards. The rewording is intended to improve understanding of the sentence. A reference to business need has also been added in an attempt to clarify the interaction between degree to which a product conforms to the access standards and overall agency needs. The wording “given business needs” was an attempt to parallel the direction from the Access Board that best meets means “best meets the agency’s needs in light of the accessibility requirements of Section 508.”

Consensus was not reached on this item and an alternative position is to delete the last sentence completely, leaving the subsection with the first two sentences. Deleting the last sentence would defer all procurement decision-making procedures to the Federal Acquisition Regulations (FAR) and/or other governing procurement policies. The Access Board and FAR will be simultaneously considering the 508 regulations. As a result, GSA and the Access Board could consider how to ensure best provide guidance for agencies to implement 508 within the procurement process through the FAR rather than the Section 508 regulations.

A third alternative would be to keep the current regulatory language without change.

TEITAC Recommendation to the Access Board:
Develop supplemental materials to assist in determining what is and is not E&IT.

Notes from Plenary Call, March 4, 2008:

Peter: Regarding #4, Technical infeasability issue. Wants a reference to fundamental alteration or expand this to encompass fundamental alteration. Peter given AI to write a proposal.

• Status: Consensus on March 4
• Text from Subpart A Subcommittee
• Source: {508}1194.2, {255}1193.21 (first paragraph,) {255} 1193.23 (second section)
• Impact:
• External Reference:

Section 1194.3 General Exceptions

1194.3 - A - Intelligence Or Security Systems

This part does not apply to any electronic and information technology operated by agencies, the function, operation, or use of which involves intelligence activities, cryptologic activities related to national security, command and control of military forces, equipment that is an integral part of a weapon or weapons system, or systems that are critical to the direct fulfillment of military or intelligence missions. Systems which are critical to the direct fulfillment of military or intelligence missions do not include a system that is to be used for routine administrative and business applications (including payroll, finance, logistics, and personnel management applications).

• Status: Consensus on Dec 4
• Text from Subpart A Subcommittee
• Source: {508}1194.3(a), no change

1194.3 - B- Incidental To A Contract

This part does not apply to electronic and information technology that is acquired by a contractor incidental to a contract.

• Status: Consensus on Dec 4
• Text from Subpart A Subcommittee
• Source: {508}1194.3(b), no change

1194.3 - C - Employees Not Individuals With Disabilities

Except as required to comply with the provisions in this part, this part does not require the installation of specific accessibility-related software or the attachment of an assistive technology device at a workstation of a Federal employee who is not an individual with a disability.

Rationale: The subcommittee has determined this provision is clear as written and does not need any changes

• Status: Consensus on Dec 4
• Text from Subpart A Subcommittee
• Source: {508}1194.3(c), no change

1194.3 - D - Access By Public

When agencies provide access to the public to information or data through electronic and information technology, agencies are not required to make products owned by the agency available for access and use by individuals with disabilities at a location other than that where the electronic and information technology is provided to the public, or to purchase products for access and use by individuals with disabilities at a location other than that where the electronic and information technology is provided to the public.

• Status: Consensus on Dec 4
• Text from Subpart A Subcommittee
• Source: {508}1194.3(d), no change

1194.3 - E - Fundamental Alteration

This part shall not be construed to require a fundamental alteration in the nature of the product or its components.

1. A fundamental alteration occurs when the accessibility feature or functionality would substantially reduce the overall functionality of the product, materially render some features inoperable by those not using the access feature, or substantially impede or deter use of the product by those not using the access feature.

2. With respect to assistive technology that is E&IT, a fundamental alteration occurs when compliance with one or more of the technical standards or functional performance criteria would substantially reduce the overall functionality of the assistive technology for its primary targeted disability population, materially render some features inoperable by the target population, or substantially impede or deter use of the product by the target population.

3. For E&IT subject to Section 255, in order to claim fundamental alteration, a manufacturer must document that compliance with one or more of the technical standards or functional performance criteria would substantially or materially interfere with the purpose and function for which the product is being developed.

1194.3 - F - Maintenance and Monitoring Aspects of Products

Those portions of products whose design limits physical access, and which are only accessed for maintenance, repair, or occasional monitoring are not required to comply with this part. This part does apply to the controls or interfaces of such products where the controls or interfaces could be executed externally or remotely.

Rationale: Additional wording attempts to restrict this exception to products that are specifically designed to be located in areas frequented only by service personnel rather than covering all products by virtue of their location. It also makes clear that being able to support the system remotely is acceptable.

• Status: Consensus on Jan 9
• Text from Subpart A Subcommittee
• Source: {508}1194.3(f)

Section 1194.4 Definitions

Accessible Content Format (no consensus)

Version 1:
A format that supports the creation of content to meet Section 508 requirements.

Version 2, proposed in email by Judy B, March 18:
A data format that enables the encoding of information in such a manner that it is consistent with the relevant provisions of Section 508.

Status: Discussion via email

Agency

Any Federal department or agency, including the United States Postal Service.

Status: Consensus on Dec 18
Text from: Subpart A

Application Software

Software which runs on and makes use of services provided by platform software. This includes "desktop" software bundled with an operating system, personal productivity applications, development tools, Web browsers, and other non-OS software.

NOTE: This term is currently not used in the provisions. If it continues to not be used, it will be removed.

Status: Consensus on Dec 18 (recommend removal, if no longer used)
Text from: Web and Software Subcommittee.

Assistive Technology

Version 1 - Consensus on Dec 18
Assistive technology is any item, piece of equipment, or system, whether acquired commercially, modified, or customized, that is commonly used to increase, maintain, or improve functional capabilities of individuals with disabilities. As used in this part, the term includes traditional assistive technology hardware and software along with (mainstream technology used as assistive technology,) virtual assistive technology delivered as a web service and integration of products into a system that provides assistive technology functions which allow individuals with disabilities to access electronic and information technology.

Note: Abbreviated as "AT"

Rationale: Added language clarifying that assistive technology includes web based and integration services.

Version 2 - added language for 255, per request on March 11
Assistive technology is any item, piece of equipment, or system, whether acquired commercially, modified, or customized, that is commonly used to increase, maintain, or improve functional capabilities of individuals with disabilities. As used in this part, the term includes traditional assistive technology hardware or software, mainstream technology used as assistive technology, virtual assistive technology delivered as a web service, the integration of products into a system that provides assistive technology functions which allow individuals with disabilities to access electronic and information technology, and existing peripheral devices or specialized customer premises equipment commonly used by individuals with disabilities to achieve access.

Rationale for change: Need to add language for section 255. The following is how the statutory language be somehow defined as AT when used in the context of Section 255.
(d) Compatibility
Whenever the requirements of subsections (b) and (c) of this section are not readily achievable, such a manufacturer or provider shall ensure that the equipment or service is compatible with existing peripheral devices or specialized customer premises equipment commonly used by individuals with disabilities to achieve access, if readily achievable.

Status: Consensus on Dec 18, request to add information for Section 255 on March 11, no quorum on call
Text from: Subpart A

Authoring Tools (no consensus)

Any software intended to create or modify electronic content for publication in one or more formats that support compliance with the user interface and content provisions.

Note: Simple text editors that can only create or modify content in conforming formats by directly editing the code are not considered authoring tools under this definition.

Status: Jan 2 - agreement on sense of definition, but no quorum, no final decision; March 10 added "electronic"
Text from: Web and Software

Blinking (no consensus)

Switch back and forth between two visual states in a way that is meant to draw attention.

Note: See also flash (It is possible for something to be large enough and blink brightly enough at the right frequency to be also classified as a flash).

Status: New proposal, March 17
Text from: General, WCAG

CAPTCHA

Initialism for "Completely Automated Public Turing test to tell Computers and Humans Apart"

Note 1: CAPTCHA tests often involve asking the user to type in text that is presented in an obscured image or audio file.

Note 2: A Turing test is any system of tests designed to differentiate a human from a computer. It is named after famed computer scientist Alan Turing. The term was coined by researchers at Carnegie Mellon University.

Status: Consensus on Dec 18
Text from: Web and Software

Captions (no consensus)

Version 1:
Captions are synchronized text equivalents for audio information. Captions are similar to subtitles in that they convey the content of spoken dialog, but also include text for non-spoken information such as important sound effects, music, laughter, and speaker identification and location. Captions should not obscure or obstruct relevant or key information. In some countries captions are called subtitles.

Version 2 - WCAG 2.0
Synchronized media or text equivalents for audio information including both dialog and non-dialog audio information

Note 1: Captions are similar to dialog-only subtitles except captions convey not only the content of spoken dialog, but also equivalents for non-dialog audio information needed to understand the program content, including sound effects, music, laughter, speaker identification and location.

Note 2: Closed Captions are captions that can be turned on and off in some players.

Note 3: Open Captions are captions that cannot be turned off. For example, if the captions are visual equivalent images of text embedded in video.

Note 4: Captions should not obscure or obstruct relevant information in the video.

Note 5: In some countries, captions are called subtitles.

Note 6: Video descriptions can be, but do not need to be, captioned since they are descriptions of information that is already presented visually.

Version 3 (email March 16, with agreement from Gregg, Karen, Geoff):
Synchronized “text” and symbol equivalents for audio information.

Note 1: The term “text” in this definition refers both to electronic text and to images of text that might be embedded in the video.

Note 2: Captions are similar to dialogue-only subtitles except captions convey not only the spoken words, but also other audio information needed to understand the program content, including sound effects, music, laughter, tone of voice, speaker identification, and location.

Note 3: Captions can be “closed” or “open”. Captions that are “closed” can generally be turned on and off by viewers. Captions that are “open” are any captions that cannot be turned off. For example, captions that are visual equivalent images of text embedded in video are “open”.

Note 4: Captions should not obscure or obstruct relevant information in the video.

Note 5: In some countries captions are called subtitles.

Note 6: Video descriptions can be, but do not need to be, captioned because they are descriptions of information that is already presented visually.

Rationale for version 3:
Some of the issues that came up on the side discussions that are all addressed above are as follows.

1. Captions are not just text but also include other symbols (music notes etc) that should be allowed

2. The word ‘text’ is ambiguous since we allow images of text here but images of text cannot be used as text in other parts of these same guidelines. Need a note to clarify

3. If we just say visual equivalents – then sign language would satisfy this and it shouldn’t – that shouldn’t be called captioning

4. Open captions are not just images of text embedded in video stream – but can be any captions that cannot be turned off and on.

5. Closed captions cannot be turned on and off in all players/viewers

6. Can we use dialogue instead of dialog to avoid confusion with dialog boxes (in which captions can in fact be presented)

7. Non-verbal (which means non-word) can separate out visual signing from visual symbols like music notes but many people misread non-verbal to mean non-vocal or non-speech and that creates all sorts of new problems. the “non-spoken” is close here but the cue that the person is SHOUTING is non-verbal but not non-spoken so ‘non-spoken’ misses some of the important information.

8. Keep it simple - (at one time the definition had grown to “synchronized visual equivalents for both dialogue and non-dialogue audio information needed to understand the media content where the equivalents are either text or images of text combined with non-verbal visual elements (such as music notes).”) until we regrouped and went back to the simple one we had and just applied the essential fixes needed to it.

9. ‘symbols’ doesn’t cover font styling and color – but that could be covered by word ‘text’ in definition since they are characteristics of text and adding “and font styling and color” to the definition would make it more complete as the expense of making it more complex.

Open Issues

• Version 3 was agreed to by the task force, but the committee did not have enough time to bring this definition back up for a consensus decision.

Status: Consensus on Dec 18- reopened in email Feb 15, updated via email March 9
Text from: Audio/Visual

Caption Text (no consensus)

Definition from WCAG:
Text presented and synchronized with synchronized media to provide not only the speech, but also non-speech information conveyed through sound, including meaningful sound effects and identification of speakers

Note 1: In some countries, the term "subtitle" is used to refer to dialogue only and "captions" is used as the term for dialogue plus sounds and speaker identification. In other countries, subtitle (or its translation) is used to refer to both.

Note 2: Video descriptions can be, but do not need to be, captioned since they are descriptions of information that is already presented visually.

Comments to Resolve:
There is a proposal to remove this definition and use only "captions."

Status: Discussion via email
Text from: Audio/Visual

Closed Product Functionality

Functionality of a product where assistive technology can not be used to achieve some or all of the functionality of the electronic user interface components for any reason including hardware, software, platform, license, or policy limitation.

• Products can be closed for one type of disability but not closed for another.
• 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.
• 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.
• Policy includes manufacturer, or vendor policies,etc. Agencies are responsibility for agency policies. If important to procurement agencies should reflect requirement as specifications in the RFP. (e.g. "Connection of user devices will not be allowed." or "All peripheral ports must be sealable.")

Status: Consensus on Dec 18
Text from: Self-Contained/Closed

Content

Information and sensory experience to be communicated to the user by means of software, including but not limited to: text, images, sounds, videos, controls and animations, as well as the encoding that defines the structure, presentation, and interactions associated with those elements. For example: word processing files, presentation files, spreadsheet files, text files, portable document files, web based content, etc.

Status: Consensus reached Jan 7
Text from: Web and Software

Content Format

An encoding mechanism for storing information.

Note: Examples are HTML, JPEG, SMIL, PDF, etc.

Status: Consensus reached Jan 7
Text from: Web/Software

Contrast Ratio

The relative luminance of the lighter of the foreground or background colors compared to the relative luminance of the darker of the foreground or background colors.

• (L1 + 0.05) / (L2 + 0.05), where
  • L1 is the relative luminance of the lighter of the foreground or background colors, and
  • L2 is the relative luminance of the darker of the foreground or background colors.

Note 1: Contrast ratios can range from 1 to 21 (commonly written 1:1 to 21:1).

Note 2: For dithered colors, use the average values of the colors that are dithered (average R, average G, and average B).

Note 3: Text can be evaluated with anti-aliasing turned off.

Note 4: Background color is the specified color of content over which the text is to be rendered in normal usage. If no background color is specified, then white is assumed.

Note 5: For text displayed over gradients and background images, authors should ensure that sufficient contrast exists for each part of each character in the content.

Status: Consensus reached Jan 7
Text from: Web/Software

Customer Premises Equipment (Consensed)

Equipment employed on the premises of a person (other than a carrier) to originate, route, or terminate telecommunications or interconnected VoIP service.

Status: Consensus on Dec 18
Text from: Telecommunications §1193.3
Source: Telecommunications Act of 1996; FCC Order No. 07-110

Decoration

Sensory experience to be communicated to the user that does not convey relevant information, does not have a function, and is included only for aesthetic purposes.

Status: Consensus reached Jan 7)
Text from: Web and Software

Electronic and Information Technology

Includes information technology and any equipment or interconnected system or subsystem of equipment that is used in the creation, conversion, or duplication of data or information. The term electronic and information technology includes, but is not limited to, telecommunications products (such as telephones), information kiosks and transaction machines, World Wide Web sites, multimedia, and office equipment such as copiers and fax machines. The term does not include any equipment that contains embedded information technology that is used as an integral part of the product, but in which information technology is not the principal function of that product.

Explanatory Note
This definition is derived from Clinger-Cohen and cannot be changed. However, this is still an issue for agencies, and TEITAC might want to recommend that Access Board and GSA work together to create advisory notes to help them determine what is (and is not) E&IT.

Note suggested by CSD/Trace Center (no consensus)
E&IT that is combined with non-E&IT is covered but the coverage does not extend to the non-E&IT. There are many compound products that are clearly IT with something added. For example, a computer mounted on the door of a refrigerator should count as a computer – but the refrigerator should not be included.

(Note on when AT is E&IT moved for discussion to Collection on AT-IT )

Status: Definition part of Clinger-Cohen. Notes still to be discussed
Text from: Subpart A
Source: Clinger-Cohen

Enhanced Audio (no consensus)

Audio which has been enhanced through amplification and/or through a variety of audio signal processing to make it easier for people with hearing loss to understand.

• NOTE: The definition was added to support 1.1-E - With Limited Hearing. If rewrite provision, the definition is not needed.

Status: Jan 2: Since the provision that uses this is not resolved, not able to consider this definition consensed. Updated March 10
Text from: General

Flash (no consensus)

A pair of opposing changes in luminance (relative luminance for software and content) that can cause seizures in some people if it is large enough and in the right frequency range

Note 1: See general flash threshold and red flash threshold definitions for information about types of flash that are not allowed.

Note 2: See also blinking.

Status: New proposal, March 17
Text from: WCAG, General

Free-Standing (no consensus)

Proposed definition from Trace
Standing on the floor and not intended to be placed on a table or built into a structure

Example: The kiosk was a free standing device that stood on the carpet in front of the registration desk.

Note: The subcommittee is requesting input on whether this should be defined since it is used in other parts of the ADA regulations and could have impacts there.

Status from on November plenary: Not discussed
Text coming from Hardware

General Flash and Red Flash Thresholds for Hardware (Consensus on Concept)

The Committee agreed that this draft language for 2.1-B-Flashing (Hardware) and the related definition General Flash and Red Flash Thresholds for Hardware be sent to the Access Board as a basis for further work on exact numbers in the definition and further work.

A hardware flash is below the threshold (i.e. software or content passes) if any of the following is true:

1. There are no more than three General Flashes and / or no more than three Red Flashes within any one-second period; OR

2. The flash frequency is 50 or 60 Hz and is due to a refresh that is intrinsically tied to the local line frequency OR

3. The flash frequency is 75 hz or greater OR

4. General flashes (that have less than a 590 nm wavelength) are no more than 20 cd/m2 AND red flashes (that have a 590 nm wavelength or longer) are no more than 2.5 cd/m2 OR

5. General flashes are no more than (1200/N^0.3)(0.006/AREA – 1) cd/m2 AND red flashes (that have a 590 nm wavelength or longer) are no more than (150/^0.3)(0.006/AREA – 1) cd/m2 OR

6. There is an adaptive brightness feature that always keeps the changes in luminance of flashes from all sources (that might flash > 3 hz) below the maximum of (1, ambient(in lux)/700 lux) times the threshold values in 4 or 5 above.

• where N is the number of sources that are flashing together more than 3 times per second within a 0.024 steradian circle
• where AREA is the summed area of the N sources, measured in steradians (at the minimum typical/expected viewing distance)
• and where sources that are separated by less than .4 degrees ( ~2mm at 12 inch viewing distance) are treated as a single source with AREA being the area from edge to edge of the group.

Note 1: Most products can safely use a minimum typical / expected viewing distance of 12 inches where 0.006 steradians would be a circle of 1.05 inch diameter.

Note 2: Red sources with wavelengths of 590 or more nm are especially provocative since, due to the way the eye and brain process light with longer wavelengths.

Note 3: Each of the following examples would meet option 5 (when viewed from at least 12 inches) even when all of the sources are flashing together at more than 3 Hz:

• 1 round LED with a diameter of 5 mm or less, and no more than 32,000 cd/m2.
• 1 rectangular indicator with a size of 10 by 20 mm or less, and no more than 2,100 cd/m2.
• 3 square indicators (within a 2.1 inch circle) each 6 mm square or less, and no more than 3,500 cd/m2
• 4 round indicators (within a 2.1 inch circle) each 8 mm in diameter or less, and no more than 1,400 cd/m2.
• 5 rectangular indicators (within a 2.1 inch circle) each 6 by 2 mm, and no more than 6,100 cd/m2.

(For light sources that are Red flashes (that have a 590 nm wavelength or longer) the values for luminance in this note should be divided by 8.)

(For comparison, the maximum brightness of a white screen on an LCD computer monitor is about 200 to 400 cd/m2)

Rationale: The hardware flash values are based on the CIE Small Angle Disability Glare Equation in Johannes J Vos "On the cause of disability glare and its dependence on glare angle and ocular pigmentation" in Clinical and Experimental Optometry 86.6, November 2003 and "Commission Internationale de l'Eclairage CIE. CIE equations for disability Glare. CIE report #146. Vienna: CIE 2002. This equation also includes an age factor. 62.5 was used as the age in generating the constants in equation in #5 above.

Note to Access Board: The working group came up with the definitions for “general flash and red flash thresholds for hardware” after much effort but there was not sufficient time to explore them as much as necessary to come to consensus on them. The “general flash and red flash thresholds for hardware” therefore does not have consensus. What the group did consense on were the following:

1. Very bright point sources or very bright small sources can be a problem (per Graham Harding)

2. Very bright point sources or very bright small sources should be allowed if they flash less than 3 per second

3. Flashing above 3 per second should be allowed if is as equivalently safe as with the Software flash thresholds.

4. Some metrics for identifying ‘equivalently safe’ were created but more time is needed by everyone to study them and their derivation before they are used by anyone including the Access Board.

5. The numbers were included in this report in order to facilitate review by different parties.

• Text from: Hardware/New

General Flash and Red Flash Thresholds for Content and User Interfaces (no consensus)

A flash or rapidly changing image sequence is below the threshold (i.e. software or content passes) if any of the following is true:

1. There are no more than three General Flashes and / or no more than three Red Flashes within any one-second period; or

2. The combined area of flashes occurring concurrently occupies no more than a total of .006 steradians within any 10 degree visual field on the screen (25% of any 10 degree visual field on the screen) at typical viewing distance where:

• A general flash is defined as a pair of opposing changes in relative luminance of 10% or more of the maximum relative luminance where the relative luminance of the darker image is below 0.80; and where "a pair of opposing changes" is an increase followed by a decrease, or a decrease followed by an increase, and

• A red flash is defined as any pair of opposing transitions involving a saturated red.

Exception: Flashing that is a fine, balanced, pattern such as white noise or an alternating checkerboard pattern with "squares" smaller than 0.1 degree (of visual field at typical viewing distance) on a side does not violate the thresholds.

Note 1: For general software or Web content, using a 341 x 256 pixel rectangle anywhere on the displayed screen area when the content is viewed at 1024 x 768 pixels will provide a good estimate of a 10 degree visual field for standard screen sizes and viewing distances (e.g. 15-17 inch screen at 22-26 inches). (Higher resolutions displays showing the same rendering of the content yield smaller and safer images so it is lower resolutions that are used to define the thresholds.)

Note 2: A transition is the change in relative luminance (or relative luminance/color for red flashing) between adjacent peaks and valleys in a plot of relative luminance (or relative luminance/color for red flashing) measurement against time. A flash consists of two opposing transitions.

Note 3: The current working definition in the field for "pair of opposing transitions involving a saturated red" is where, for either or both states involved in each transition, R/(R+ G + B) >= 0.8, and the change in the value of (R-G-B)x320 is > 20 (negative values of (R-G-B)x320 are set to zero) for both transitions. R, G, B values range from 0-1 as specified in “relative luminance” definition. (Harding and Binnie 2002)

Note 4: Tools are available that will carry out analysis from video screen capture. However, no tool is necessary if flashing is less than or equal to 3 flashes in any one second period (content automatically passes (see #1 and #2 above)).

• Status: March 17 New text proposed, replaces earlier versoin

Text from: Web/Software

Information Technology (no consensus)

Any equipment or interconnected system or subsystem of equipment, that is used in the automatic acquisition, storage, manipulation, management, movement, control, display, switching, interchange, transmission, or reception of data or information. The term information technology includes computers, ancillary equipment, software, firmware and similar procedures, services (including support services), and related resources.

Status from on November plenary: Not discussed
Text from: Subpart A

Interactive Elements (no consensus)

Proposed definition from GV
Elements of the user interface that are acted on by the user.

• Since this term is used in multiple places, it must be defined.

Status from on November plenary: Not discussed
Text coming from A/V Subcommittee

Interconnected Voice over Internet Protocol (VoIP) Product

A product that is used to provide interconnected VoIP service

Status: Consensus on Dec 18
Text from: FCC regulations 47 C.F.R. §9.3

Interconnected Voice over Internet Protocol (VoIP) Service

A service that:

1. Enables real-time, two-way voice communications;
2. Requires a broadband connection from the user's location;
3. Requires Internet protocol-compatible customer premises equipment; and
4. Permits users generally to receive calls that originate on the public switched telephone network and to terminate calls to the public switched telephone network.

Status: Consensus on Dec 18
Text from: FCC regulations 47 C.F.R. §9.3

Keyboard

A set of systematically arranged keys by which a machine or device is operated and alphanumeric input is provided such as a computer keyboard, a cell-phone keypad, or a television remote control that can generate alphanumeric input. Tactilely discernable keys that are used in conjunction with the main cluster of keys are included in the definition of keyboard as long as their function also maps to keys on any keyboard interfaces.

Status: Consensus on Dec 18
Text from: Web and Software

Keyboard Interface

A means for accepting input from a keyboard. For software, this would be the ability to accept keyboard input from the operating system including on-screen keyboards. For hardware this would be the ability to connect a keyboard via wired or wireless connection.

Status: Consensus on Dec 18
Text from: Web and Software

Label

Text or other component with a text alternative that is presented to a user to identify a component within content.

Note 1: A label is presented to all users whereas the name may be hidden and only exposed by assistive technology. In many (but not all) cases the name and the label are the same.

Status: Consensus on Feb 26
Text from: WCAG

Large Scale Text

At least 18 point or 14 point bold

Note 1: Fonts with extraordinarily thin strokes or unusual features and characteristics that reduce the familiarity of their letter forms are harder to read, especially at lower contrast levels.

Note 2: Font size is the size when the content is delivered. It does not include resizing that may be done by a user.

Status: Consensus on Dec 18
Text from: Web/Software

Manufacturer (no consensus)

A manufacturer of telecommunications or VoIP equipment or customer premises equipment that sells to the public or to vendors that sell to the public; a final assembler.

• Requested this definition be added to support Section 255.
• (GV) Change so that it is not limited to VOIP since it is used more generally in the provisions and this would limit all those provisions.

Status from on November plenary: Not discussed
Text from: Telecommunications §1193.3
Source: Telecommunications Act of 1996; FCC Order No. 07-110

Menu (no consensus)

Set of selectable options.

Comments to be resolved:

• (Peter K) this needs to be scoped, perhaps just to telecom or “audio menus”. As it reads now, things like a collection of radio buttons would be considered a menu. Also, where is this term used in 508? three things to consider: instead of “Set of selectable options”, what about “Presentation of a set of selectable options”, or “Presentation of a set of user-selectable options”. But in either case, we should note that this is an audio/aural presentations
• (Gregg V) Menu is used in a number of places. We need to be careful of each one.
• (CSD/Trace Center) Agree with Peter K and Gregg V comments. Menu is used in 2 places: 3-CC advisory note example referring to software menus and in 4-C to refer to menu's on television display like device. No suggested text.

• This was discussed at the November plenary and the term removed from provision 6C - Interactive Elements, but the term is still used and the definition can not be removed as proposed.

Status from on November plenary: Discussed but not completed
Text from: Telecommunications
Source: HFES 200

Non-text Object

Any object that is not a sequence of characters that is programmatically determinable or where the sequence is not expressing something in human language

Note: This includes, but is not limited to, ASCII Art (which is a pattern of characters), emoticons, leetspeak (which is character substitution), and images representing text.

Status: Consensus on Dec 18
Text from: Web/Software

Other Services To Cooperate With Assistive Technologies

A method, other than the platform accessibility services, used to interoperate with assistive technologies.

Status: Consensus on Dec 18
Text from: Web and Software

Peripheral Devices (no consensus)

Devices employed in connection with telecommunications or VoIP equipment or customer premises equipment to translate, enhance, or otherwise transform telecommunications or VoIP services into a form accessible to individuals with disabilities

• Requested this definition be added to support Section 255.

Status from on November plenary: Not discussed
Text from: Telecommunications §1193.3
Source: Telecommunications Act of 1996; FCC Order No. 07-110

Platform Accessibility Services

Services provided by a platform enabling interoperability with assistive technology, commonly in the form of accessibility APIs (application programming interfaces)

NOTE: This term is currently not used in the provisions. If it continues to not be used, it will be removed.

Status: Consensus on Dec 18 (recommend removal, if no longer used)
Text from: Web/Software

Platform Software

Collection of software components that runs on an underlying software or hardware layer, and that provides a set of software services to applications that allows them to be isolated from the underlying software or hardware layer.

Note 1: For our purposes, it is those software components/services provided to applications for the creation or manipulation of user interfaces and user input - that impact accessibility - which are of concern for whether something is a platform or not. An application offering a compute service, such as a 3d rendering engine where a requesting application isn't using the software components/services to create a user interface and interact with the user, should not be considered a "platform".

Note 2: If applications typically connect directly to the underlying layer, rather than relying solely on the platform software components and services, then it is likely that the software components in the middle are not acting as a "platform". For example, a program which hosts plug-in's is not a platform if the plug-in can directly access the underlying layer.

Note 3: A particular software component may play the role of a platform in some situations and not in others. Platforms can include such things as Internet browsers, operating systems, plug-ins to internet browsers or other software applications, and under some situations, byte-code interpreted virtual environments, and other "programming within another programming" environments.

Status: Consensus on Dec 18
Text from: Web/Software

Programmatically Determinable (no consensus)

Version 1
Can be determined by software from data provided in a user-agent-supported manner such that various user agents including assistive technologies can extract and present this information to users in different modalities.

Version 2 (Trace)
Determinable by user agents, including assistive technologies, from the data provided.

Note 1: Purpose is to allow user agents including assistive technologies to extract and present this information to users in different modalities.

Note 2: Programmatically determinable requires that the information be determinable by existing assistive technologies.

Version 3 (WCAG)
Determined by software from author-supplied data provided in a way that different user agents, including assistive technologies, can extract and present this information to users in different modalities

Example 1: Determined in a markup language from elements and attributes that are accessed directly by commonly available assistive technology.

Example 2: Determined from technology-specific data structures in a non-markup language and exposed to assistive technology via an accessibility API that is supported by commonly available assistive technology.

Comments to Resolve:

• Peter K: Disagree with second note - and that goes to the heart of the 3-New Assistive Technologies provision. I believe something should be "programmatically determinable" [full stop] whether or not AT is in the picture. If and where we want to mean "programmatically determinable by existing AT", then we should spell that out in those places. I think this is particularly important in light of common engineering understanding of this term (and will cause significant confusion if we define it to mean more).
• Randy M, Gregg V: Prefer to keep AT in the definition.
• Allen H: In note 2, "existing" assistive technology indicates "at a point in time". Wen the product is designed, developed, or delivered, used, upgraded, replaced? I can work with the items up to the second note.

Status from on November plenary: Not discussed
Text from: Web/Software

Readily Achievable

Easily accomplishable and able to be carried out without much difficulty or expense.

Status: Consensus on Dec 18
Text from: Telecommunications §1193.3 (no change)
Source: Telecommunications Act of 1996

Real-time Text (no consensus)

Communications that employ the transmission of text wherein the characters are transmitted by a terminal within a maximum of 1 second of character input. This would typically be for conversational purposes but also may be used in voicemail, IVR and other similar applications.

Comments to be resolved:

• (Peter K) Do we need "by a terminal"
• (Gregg V) I believe that phrase was included to prevent the 1 second from being applied to things that retransmit the text enroute.
• (CSD/Trace Center) After the word "terminal" add "(hardware or software)" to clarify since that is how it is used in the provisions.

Status from on November plenary: Not discussed
Text from: Telecommunications

Relative Luminance (no consensus)

The relative brightness of any point in a colorspace, normalized to 0 for black and 1 for maximum white

Note 1: For the sRGB colorspace, the relative luminance of a color is defined as L = 0.2126 * R + 0.7152 * G + 0.0722 * B where R, G and B are defined as:

• if RsRGB <= 0.03928 then R = RsRGB/12.92 else R = ((RsRGB+0.055)/1.055) ^ 2.4
• if GsRGB <= 0.03928 then G = GsRGB/12.92 else G = ((GsRGB+0.055)/1.055) ^ 2.4
• if BsRGB <= 0.03928 then B = BsRGB/12.92 else B = ((BsRGB+0.055)/1.055) ^ 2.4

and RsRGB, GsRGB, and BsRGB are defined as:

• RsRGB = R8bit/255
• GsRGB = G8bit/255
• BsRGB = B8bit/255

The "^" character is the exponentiation operator. (Formula taken from sRGB and IEC-4WD.)

Note 2: Almost all systems used today to view Web content assume sRGB encoding. Unless it is known that another color space will be used to process and display the content, authors should evaluate using sRGB colorspace. If using other color spaces, see Understanding Success Criterion 1.4.3.

Note 3: If dithering occurs after delivery, then the source color value is used. For colors that are dithered at the source, the average values of the colors that are dithered should be used (average R, average G, and average B).

Note 4: Tools are available that automatically do the calculations when testing contrast and flash.

Note 5: A MathML version of relative luminance definition is available WGAC.

Status from on November plenary: Not discussed, updated by Gregg March 18 to add "in a colorspace"
Text from: Web/Software

Simple Tactile Form (no consensus)

Tactile form that does not require the memorization of any spatial or temporal tactile patterns.

Note 1: Simple vibration or switch up/down positions are examples of simple tactile forms.

Note 2: Braille, tactile Morse code, and vibration patterns are samples of more complex tactile forms that require memorization of non-trivial spatial and tactile patterns respectively, and therefore are not Simple Tactile Forms.

Note 3: Different numbers of tactile buzzes, or different frequency buzzes would be non-trivial patterns, and would not be simple tactile forms.

Status: Updated from emails, March 11, March 12
Text from: Provision 1-E

Specialized Customer Premises Equipment

Equipment, employed on the premises of a person (other than a carrier) to originate, route, or terminate telecommunications or VoIP services, which is commonly used by individuals with disabilities to achieve access..

Status: Consensus on Dec 18
Text from: Telecommunications §1193.3; FCC Order No. 07-110

Synchronized Media

Audio or video displayed at the same time as other time-based content that is required for understanding of the complete presentation. The other content that the audio or video is synchronized with to meet this definition does not include equivalents such as captions, subtitles, or video description.

Status: Consensus on Dec 18
Text from: A/V

Telecommunications

The transmission, between or among points specified by the user, of information of the user's choosing, without change in the form or content of the information as sent and received. (Telecommunications Act of 1996)

Status: Consensus on Dec 18
Text from: Telecommunications
Source: Telecommunications Act of 1996

Telecommunications Equipment

Equipment, other than customer premises equipment, used by a carrier to provide telecommunications services, and includes software integral to such equipment (including upgrades).

Status: Consensus on Dec 18
Text from: Telecommunications §1193.3 (no change)
Source: Telecommunications Act of 1996

Telecommunications Service

The offering of telecommunications for a fee directly to the public, or to such classes of users as to be effectively available directly to the public, regardless of the facilities used.

Status: Consensus on Dec 18
Text from: Telecommunications §1193.3 (no change)
Source: Telecommunications Act of 1996

Terminal

Device and/or software with which the end user directly interacts and that provide the user interface.

NOTE: For some systems, the software that provides the user interface may reside on more than one device such as a phone and a server.

Status: Consensus reached Jan 7
Text from: Telecommunications

Text (no consensus)

Sequence of characters that is programmatically determinable, where the sequence is expressing something in human language.

Status: New - 26 Feb. Proposed to ensure harmonization
Text from: WCAG

TTY

An abbreviation for teletypewriter. Machinery or equipment that enables interactive text based communications through the transmission of frequency-shift-keying audio tones across the PSTN according to TIA-825-A (A Frequency Shift Keyed Modem For Use On The Public Switched Telephone Network). As used in this part, the term TTY includes devices for text-to-text communications along with voice and text intermixed communications such as voice carry over and hearing carry over. TTYs may include computers with special modems. TTYs are a subset of devices called text telephones.

Status: Consensus on Dec 18
Text from: Telecommunications

Typically Held to the Ear

A product that is positioned immediately adjacent to ear, either by hand or by a strap or holder of some kind, in typical use.

• Headphone and headsets that connect to a product via a standard connector are not considered as products that are "held up to the ear" but rather alternate speakers to a device.
• Handsets are considered products or part of a product

NOTE: Headphones and headsets with standard connectors are not included in this definition becasue users can substitute other headphones or headsets or neck loops that meet their individual needs and can use them with the product.

Status: Consensus on Jan 9
Text from: Hardware/Telecommunications

Unavailable Items

Interface elements that cannot be selected, or interacted with accept as read-only items on screen due to application state or other reasons.

Status: Consensus on Dec 18
Text from: Web and Software, listed in provision 3-D User Preferences

Undue Burden

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

Status: Consensus on Dec 18
Text from: Subpart A (no change)

Usable

Means that individuals with disabilities have access to the full functionality and documentation for the product, including instructions, product information (including accessible feature information), documentation, and technical support functionally equivalent to that provided to individuals without disabilities.

Status: Consensus on Dec 18
Source: Telecommunications §1193.3 (no change)

Video Description (no consensus)

The insertion of verbal or auditory description(s) of on-screen visuals intended to describe important visual details that are not contained in, or that cannot be understood from, the main audio output alone. Video descriptions supplement the regular audio track of the program and are usually inserted between dialogue narration to provide information about actions, characters, and on-screen text that appear without verbalization. Video descriptions are a way to let people who are blind or have low vision know what is happening on screen.

Rationale The American Foundation for the Blind along with the National Center for Accessible Media at WGBH (NCAM), under contract from the Described and Captioned Media Program (U.S. Department of Education) administered by the National Association of the Deaf, is developing guidelines and best practices for authoring video description. As of August 2007, a first draft has been developed by an expert committee of academics, educators, producers, consumers and others. These guidelines should be completed by the end of 2008. This definition should not conflict with these guidelines

Status: Discussed Jan 7, Larry to resolve email issues
Text from: Audio-Video
External Reference: Guidelines (draft) from the Described and Captioned Media Program (U.S. Department of Education)

Section 1194.5 Equivalent Facilitation (Consensed)

Nothing in this part is intended to prevent the use of designs or technologies as alternatives to those prescribed in this part provided they result in substantially equivalent or greater access to and use of a product for people with disabilities.

Rationale: The subcommittee has determined this provision is clear as written and does not need any changes

Status: Consensus reached on Jan 9
Source: {508}1194.5, no change

Subpart B: Functional Performance Criteria

The purpose of the Functional Performance Criteria is to help Federal departments or agencies determine whether products being used, developed, procured or maintained meet the functional needs of individuals with disabilities. The functional performance criteria have three roles:

1. If any of the technical provisions are not met, the Functional Performance Criteria must/can be used to see if access is provided in another way (i.e. through equivalent facilitation).

2. If the technical provisions are met, the Functional Performance Criteria must/can be used to see if the technical provisions cover all aspects needed to provide access to the product. (i.e overall evaluation)

3. The Functional Performance Criteria can also be used to help departments and agencies identify and report product functions that may not meet the Functional Performance Criteria and evaluate the importance of the lack of access to those functions relative to the intended use of the product.

A - Without Vision
Products must provide at least one mode that allows access to all functionality of the product without using vision. (See note on functional performance criteria and assistive technology.)

B - With Limited Vision
Products must provide at least one mode that allows access to all functionality of the product visually without requiring visual acuity greater than 20/70 and without relying on audio output. (See note on functional performance criteria and assistive technology.)

C - With Color Vision Deficits
Products must provide at least one mode that allows access to all functionality without relying on users’ perception of color. (See note on functional performance criteria and assistive technology.)

D - Without Hearing
Products must provide at least one mode that allows access to all functionality of the product without using hearing. (See note on functional performance criteria and assistive technology.)

E - With Limited Hearing (No Consensus)
TEXT AS OF MARCH 25
Version 1:
Where audio information is important for the use of a product, it must provide at least one mode that allows user control of volume and/or reduction of background noise. (See note on functional performance criteria and assistive technology.)

Version 2:
Products must provide at least one mode that allows access to all functionality of the product with limited hearing. (See note on functional performance criteria and assistive technology.)

Version 3, proposed in email from Gregg, March 17:
Where audio information is required for the use of a product, the product must provide at least one mode that allows user control of volume and/or reduction of background noise. (See note on functional performance criteria and assistive technology.)

• IBM/Sun: seems to be more of a general technical provision. Recommend change the FPC entry using the wording similar to that used in "without hearing"

G - Without Speech
Products must provide at least one mode that allows access to all functionality of the product without requiring user speech. (See note on functional performance criteria and assistive technology.)

H - With Limited Reach, Strength, or Manipulation
Products must provide at least one mode that does not require gestures, pinching, twisting of the wrist, tight grasping, or simultaneous actions. In this mode, all controls must be within reach (as defined by the reach limits in the current ADAAG). (See note on functional performance criteria and assistive technology.)

I - Without Physical Contact (No Consensus)
TEXT AS OF MARCH 25
Products must provide at least one mode that allows access necessary to operate all functionality of the product without requiring any physical contact with the product beyond initial connection and setup of a special interface device. This does not apply to powering product up, changing consumables, configuration, set-up or maintenance. (See note on functional performance criteria and assistive technology.)

Note: For initial setup, it is acceptable to use a physical connector (eg. a USB connector) to connect the user's special interface device.

Rationale and Notes 1. It is well known that a large population of people with physical disabilities cannot reach out to touch a product or cannot reach out long enough to actually operate a product physically.

2. While it is preferable that no contact at all be required, some physical contact may be needed to turn power on, initialize a telephone call, load or remove paper or consumables, or change mode of operation. In some cases it may be required for the user to be assisted by a companion or bystander with these operations.

3. Assistive Technology examples:

• The use of a standard network interface (e.g. USB, Ethernet, IEEE 1394, Wi-Fi,

Bluetooth, etc.) that allows users to control the product using software via a wired or wireless network connection would meet this provision.

• The use of the infra-red (“IR”) port used for remote controls in consumer electronics

products would meet this provision.

4. Direct Access examples:

• Voice dialing or voice control is an example of direct access. Access to voice

dialing or voice control may require physical contact with the product to initiate the call or change mode of operation to enable voice recognition.

Open issues for I

• TIA cannot agree to this in its current wording. The concern is the phrase

"all functionality" even when you consider use with Bluetooth, etc. because those technologies still require a "push to talk" action for general operation.

• Avaya: This would add expense to low-end products, so more comfortable with

this just for 508.

J - With Cognitive, Language or Learning Limitations (No Consensus)
TEXT AS OF MARCH 25
Version 1: proposed by Karen PS, Trace, CSD in FPC version 1 above:
Products must provide at least one mode that accommodates cognitive, language, memory or learning impairments. (See note on functional performance criteria and assistive technology.)

Rationale for J: The telecommunications guidelines include a requirement for provision of a mode that “minimizes the need for memory.” §1193.41(i). This version adds the word "memory".

Version 2
{This provision subject to wording that would be testable}.

Open issues for J:

• Sun: include in the narrative a list of technical provisions that support CLL disabilities. Should include info in the narrative explaining the info we have and how we were unable to specifically address the criteria.
• Allen: Regarding "J" make the list of which provisions apply, and write guidelines noting evaluation guidelines for how evaluate.
• Note to plenary regarding provision "J", this is part of Section 255. § 1193.41 Input, control, and mechanical functions.
  

Input, control, and mechanical functions shall be locatable, identifiable, and operable in accordance with each of the following, assessed independently:
(i) Operable with limited cognitive skills. Provide at least one mode that minimizes the cognitive, memory, language, and learning skills required of the user.

Note on functional performance criteria and assistive technology: The Functional Performance Criteria state what should be possible with the product, but do not specify how this may be accomplished. In some cases the access to the functionality of the product may be direct, without any assistive technologies. In other cases the access may be possible if a piece of assistive technology is used in conjunction with the product (e.g., screen reader, special keyboard, etc.). Either means for achieving access satisfies Section 508. For Section 255, where readily achievable, products must provide access directly through compliance with the technical requirements. Where that is not readily achievable, products must comply with §1193 Subpart D-Requirements for Compatibility With Peripheral Devices and Specialized Customer Premises Equipment.

Advisory Note to the Access Board: The Committee was unable to come to an agreement on whether items #1 and #2 above are required ("must") or an option ("can"). The Access Board is requested to make this determination.

Note for EWG or Access Board: We need a note explaining what "provide at least one mode" means, and that one mode does not exclude another.

• Randy: Agreed to not address multiple disabilities at the beginning of this TEITAC review, so each of these FPC are mutually exclusive.
• Karen to look for notes regarding FPCs and multiple disabilities.

Subpart C: Technical Provisions

For the purposes of Section 255, each manufacturer of a product that is used to provide telecommunications or interconnected VoIP service must ensure that such products are designed, developed and fabricated to incorporate the access features described in the functional performance and technical criteria contained in this part, if readily achievable. Whenever it is not readily achievable to incorporate such access features directly into the products, the manufacturer must ensure that the products are compatible with existing peripheral devices or specialized customer premises equipment commonly used by individuals with disabilities to achieve access, if readily achievable. (Source: FCC Regulations 47 C.F.R. §§6.5; 7.5)

For the purposes of Section 508, compliance with the functional performance and technical criteria contained in this part may be achieved directly or through assistive technology by each federal agency, unless the agency can show that such compliance would cause an undue burden.

1 General Technical Requirements

1-A - Closed Functionality

If any functionality of a product is closed for any reason including policy constraints or technical limitations then that closed functionality must be made available to and operable by people with disabilities within the product itself. As a result, the following provisions would not apply to the closed functionality:

• 2.1-E - Standard User Interface Connection
• 3-F - All Non-Text Objects
• 3-G - Human Language
• 3-H - Language of Parts
• 3-N - Link Purpose
• 3-O - Information and Relationships
• 3-Q - Disruption of Access Features
• 3-P - User Interface Components
• 3-U - AT Interoperability
• 3-V - Accessibility Services
• 3-VV - Assistive Technology

• Status: Consensus reached at November Plenary
• Text from Self Contained, Closed
• Source: {508}1194.25(a)
• Impact:
• External Reference:
• Testability: Expert evaluation
• Disabilities: All

1-B - Biometric ID

If a product uses a biometric form of user identification which relies on a person possessing one unique biological characteristic that some people may not have, an alternative method of identification must also be provided.

Agencies must provide an alternate, biometric or non-biometric, means of access for anyone who can not use the provided biometrics-based form of identification.

Note: Fingerprints and iris patterns are two examples of "unique biological characteristics that some people may not have."

Rationale: This would allow biometric systems in the future that are based on circulatory system or other characteristics common to all people.

TEITAC Discussion to be sent to the Access Board:
People who do not have fingers, eyes, etc are not able to make use of biometrics-based E&IT simply because currently these solutions rely upon only one unique biometric measurement, such as a fingerprint. Allowing such solutions to accept alternative biometrics will greatly decrease the number of people who are unable to use such biometrics solutions, since people with multiple disabilities of this type are a smaller portion of the population. This, however, is only an interim step until biometric or nonbiometric alternatives are identified and integrated into security best practices that "all people" regardless of disability are able to use. For example, one potential solution may rely only upon circulation; if this is a characteristic of all people, it would be an accessible biometric.

Until non-biometric forms of identification, control or activation have been integrated into security best practices, such biometric-based systems must be developed to allow multiple biometrics to be used. Alternatively, until a biometric solution is identified that all people can use, biometrics systems that use multiple biometrics or non-biometrics must be employed. Fingerprints and retina patterns are just two examples. It is less likely for people to be missing fingerprints and retinas than either one alone. However, even when multiple biometrics are provided, alternate means of access must also be provided (in policy and implementation) for anyone who cannot use any of them. For example, if someone has neither retinas nor fingers, another procedure, which could involve physical assistance, is needed to provide comparable access.

We strongly recommended that the Access-Board direct research to identify nonbiometrics forms of identification, control or activation, or biometric alternatives that all people can make use of, to be integrated into security best practices and standards in the near future.

It is the opinion of computer security professionals in the ITAA membership that the Access Board should not specify solutions to security issues in Section 508, but rather leave it to National Institute of Standards and Technology (NIST) and their partners to remedy this in the standards for security identification. We encourage the access board to provide them with the an understanding of the issue.

• Status: Consensus reached at November Plenary
• Text from: General
• Source: {508}1194.25(d), {508}1194.26(c) (was 1.2-D in Oct 26 draft)
• Impact:
• External Reference:
• Testability: Inspection
• Disabilities: All that could be caused by loss of a relevant body part or function

1-C - Pass Through

Products that transmit or conduct information or communication must preserve accessibility information that is transmitted in non-proprietary, industry-standard codes, translation protocols, or formats.

Technologies which use encoding, signal compression, format transformation, or similar techniques must not remove information needed for access, or must restore it upon delivery.

Firewalls, routers,gateways and other products that pass real-time voice communication must also pass real-time text communication signals (including mixed voice and real-time text) that are standard in the United States for that technology platform without distortion or error beyond 1%.

• Status: Consensus reached on Jan 7
• Text from Telecommunications
• Source: {508}1194.23(j), {255}1193.37
• Impact:
• External Reference:
• Testability: Inspection
• Disabilities: Hearing, vision, cognition

1-D - Audio Information