EWG:Draft Sept 3

Editorial Working Group > Working Draft created September 3

TEITAC Working Draft - September 3, 2007.

This page is the working draft with the latest versions of the work of the TEITAC. It contains corrections to the Aug 17 draft, marked in bold/italic.

See What's New in the Sept 3 Draft for a list of updated provisions, and provisions with multiple versions.

See * Status Spreadsheet for an overview of the provisions (being updated to match the Sept 3 draft)

Subpart A

The Subpart A subcommittee has a action item from the July 16-18 meetings to summarize all issues and concerns so they may be discussed at the next meeting for resolution.

Editorial notes

• For Subpart A only the current text is included, to facilitate discussion.
• For Subpart A only the metadata is omitted, as this subpart, by definition, applies to all.

Section 1194.1 Purpose

Version 1
The purpose of this part is to implement section 508 of the Rehabilitation Act of 1973, as amended (29 U.S.C. 794d). Section 508 requires that when Federal agencies develop, procure, maintain, or use 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 COMMUNCATION 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.

Version 2
Insert provision to address comparable access in Section 1194.2 Application

Discussion or Rationale In either approach, it is recommended that new explanatory information be provided:

• 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 standards specified in Subpart X. It should be noted that the determination of timely, accurate, complete, and efficient will not be a quantifiable measure.

• Status: Done
• Text from Subcommittee
• Source: {508}1194.1
• Impact:
• External Reference:
• Testability: N/A

Section 1194.2 Application

Recommended new introductory statement:
In general, this section applies only to the consideration of accessibility in the process of developing, procuring, maintaining, or using electronic and information technology.

(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 procuring 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 procurement shall explain why, and to what extent, compliance with each such provision creates an undue burden.

(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 are commercially available that meet some but not all of the standards, the agency must procure the product that best meets the standards.

(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.

Version 2: Options for changing Paragraph (a)(2) and Paragraph (b)

(a)(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, MAINTANENCE, OR USE shall explain why, and to what extent, compliance with each such provision creates an undue burden.

(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 AGENCIES BUSINESS NEEDS AND the APPLICABLE ACCESS standards, given the agency's business needs.

Version 3: Option for Paragraph (b) Remove "If products that meet all of the standards are NOT commercially available the agency must procure the product that best meets THE AGENCIES BUSINESS NEEDS AND the APPLICABLE ACCESS standards, given the agency's business needs."

Discussion or Rationale

• Rationale for Recommended New Introduction: This additional 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. In some cases there is the expectation that accessibility should trump agency business needs and other requirements. This language clarifies that accessibility must be determined within the parameters of Section 508, but does not purport to direct agencies as to how to make overall procurement decisions. Agencies are required to consider accessibility within the framework of other regulated procurement practices such as the FAR. Some subcommittee members indicated that this limitation was sufficiently provided via § 1194.1 Purpose and the new language was not necessary.

• Rationale for Version 2: paragraph (a)(2): Undue burden clause in prior regs only applied to procurement. Assumed oversight- revision to clarify the application of undue burden to development, maintenance and use in addition to procurement.

• Rationale for Version 2: paragraph (b): Clarifies 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. Improves understanding of clause

• Rationale for Version 3: paragraph (b): 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. This presents an opportune time for GSA and the Access Board to consider how to ensure best provide guidance for agencies to implement 508 within the procurement process.

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

• Status: Done
• Text from Subpart A
• Source: {508}1194.2
• Impact:
• External Reference:
• Testability: N/A

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 which 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: Done
Source: {508}1194.3

1194.3 - NEW - Emergency, Field and First Response Use

This part does not apply to any electronic and information technology operated by agencies in a field environment where the function, operation, or use is by a first responder, emergency, security, or law enforcement personnel. This exception does not apply to the agency systems administrative and business applications (including payroll, finance, logistics, and personnel management applications) or any application or system that is intended for use by members of the public.

Rationale Currently the national security exception directly addresses the accessibility exception for electronic and information technologies used as integral parts of weapons or weapons systems, in command-and-control, cryptological activities, and for direct support of intelligence and military missions. The underlying theme of that exception is often what might be considered emergency, or field conditions, and physical requirements as a prerequisite for employment. These same conditions are met in situations such as first responders, fire-fighters, law-enforcement personnel in the field, etc. Because of this similarity some Federal agencies such as Department of Homeland Security, Department of Justice, some portions of the Department of the Treasury, for example, encounter Section 508 acquisitions situations which mirror those in the national Security exception, but which are uncovered now. This requires that the agencies either apply fundamental alteration exception to such purchases, which is not always the most accurate fit, or conduct the market research and take accessibility requirements in to account during the process for items never to be used by people with disabilities. While Section 508 standards are intended to lower barriers to employment, they are not intended to remove all such barriers where disabilities and performing the job are in practice and reality mutually exclusive. Note, first responders in practice can be Federal employees or members of the public; however this exception is not based upon this status, rather the work to be performed and the location that work is performed.

• Impact:

Economic impact: Low This exception will lower the analysis level of Federal requiring officials by addressing this specific situation directly, and lower their potential market analysis workload as well. It will not impact industry negatively as it is not a requirement that they must change business practices or products to meet.

• External Reference:

Definition of "first responder": From Homeland Security Presidential Directive 8, (HSPD8), the term "first responder" refers to those individuals who in the early stages of an incident are responsible for the protection and preservation of life, property, evidence, and the environment, including emergency response providers as defined in section 2 of the Homeland Security Act of 2002 (6 U.S.C.101), as well as emergency management, public health, clinical care, public works, and other skilled support personnel (such as equipment operators) that provide immediate support services during prevention, response, and recovery operations.
Note: adoption of this provision will require reference of the Definition of First Responder in §1194.4 Definitions.

• Status: New: no consensus reached
• Text from Subcommittee
• Source: New

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: Done
Source: {508}1194.3, 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.

Status: Done
Source: {508}1194.3, 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: Done
Source: {508}1194.3, no change

1194.3 - E - Fundamental Alteration

Version 1
This part shall not be construed to require a fundamental alteration in the nature of the E&IT, or its components, GIVEN THE AGENCY'S SPECIFIED PRODUCT REQUIREMENTS OR BUSINESS NEED.

Rationale for Version 1: This proposed language specifically remidns agencies that their implementation of Sectin 508 must support both the agency's mission as well as their responsibilities under Section 508. This version also links the fundamental alteration to the agency's specified requirements - if they are able to specify their requirements - or their business need if they are not able to specify the requirements up front.

Version 2 (Current Provision)
This part shall not be construed to require a fundamental alteration in the nature of a product or its components.

Rationale for Version 2 Additional wording intended to clarify that agency’s specified product requirements (assuming they are constructed in accordance with standard procurement procedures) do not need to be altered. Some TEITAC members indicated this additional language is not needed, as it is implicit.

• Status: Done
• Text from Subcommittee
• Source: {508}1194.3
• Impact:
• External Reference:
• Testability: N/A

1194.3 - F - Service Areas

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

The proposed versions has been reduced to only two.

Version 1

Products designed for spaces frequented only by service personnel for maintenance, repair, or occasional monitoring of equipment and whose controls or interfaces can be executed solely from these spaces are not required to comply with this part. This part does apply to E&IT designed for spaces frequented only by service personnel, but whose controls or interfaces can be executed externally or remotely.

Rationale for Version 1 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.

• Impact:
• External Reference:
• Testability: N/A

Version 2

Remove the current provision.

Rationale for Version 2 Some TEITAC members and subcommittee members recommend the entire exception should be deleted. This recommendation is based on the preference that all products should conform regardless of location and use.

• Impact:
• External Reference:
• Testability: N/A

• Status: In progress: no consensus reached
• Text from Subpart A
• Source: {508}1194.3

1194.3 - NEW - Narrow, Delineated Use

Self-contained, closed products with narrow, delineated personal use (such as calculators, electronic dictionaries, and audio recorders) for which an agency can document readily available specialized products in the commercial marketplace that collectively meet the functional performance criteria (e.g. have features such as speech output available on one unit, large visual display available on another, large keys/buttons available on another, etc.) Are not required to comply with this part as a whole. Agencies must however provide specialized products with appropriate access features as necessary to meet the needs of end-users with disabilities.)

Rationale: Much discussion has transpired regarding the need to address the situations where conformance to the technical and performance standards results in access barriers. For example, requiring all calculators to have speech output, large visual display, enlarged keys, etc. actually creates access barriers depending on the functional limitations of individuals with disabilities. While some committee members are supportive of this concept others hold the position that we should not pursue this idea. While much discussion has taken place and ideas such as identifying products as “personal use” have been proposed there has not been a solution proposed that is understandable at face value (which is important for adoption and implementation) and no benchmarks or criteria have been proposed which can be used for decision-making as to when to apply this exception. This text is a proposal, but was no fully consensus was reached by the subcommittee on it.

• Impact:
• External Reference:
• Testability: N/A
• Status: In progress: no consensus reached
• Text from Subpart A
• Source: New

Section 1194.4 Definitions

The following definitions apply to this part:

Agency

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

Status: Done
Text from: Subpart A

Alternate Formats

• Proposal: Remove as this is not used in any provisions.

Alternate Methods

• Proposal: Remove as this is not used in any provisions.

Application Software

• Text coming from Web and Software Subcommittee.

Discussion information can be found on http://teitac.org/wiki/Web_and_Software:_Definitions.

Assistive Technology

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 information technology.

Status: Done
Text from: Subpart A

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

Authoring Tools

Any software used to create or modify content for publication.

Notes:

• This is not intended to apply to text editors like Notepad. Concern that this will be too broadly applied due to the definition of "content". Subcommittee still working on these concerns.
• Proposal: change "used" to "intended"

Status: In Progress
Text from: Web and Software

Auto-updating

Object whose appearance is modeling one or more data values, such as a status monitor, or stock ticker, and which is updated autonomously by software.

• Concern that there is no consideration for frequency here. Auto-updating at very slow frequencies like once per day is not a problem. Concern that this is too broad and will cause ARIA content to fail even when there is no problem.

Status: In Progress
Text from: Web and Software

Captions

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.

Status: Done
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: Done
Text from: Self-Contained/Closed

Comparable Access

This term will not be defined.

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.

Status: In Progress
Text from: Web and Software

Content Format

An encoding mechanism for storing information. Examples are HTML, JPEG, SMIL, PDF, etc.

Status: Done
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.

Notes

1. Contrast ratios can range from 1 to 21 (commonly written 1:1 to 21:1).
2. For dithered colors, use the average values of the colors that are dithered (average R, average G, and average B).
3. Text can be evaluated with anti-aliasing turned off.
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.
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.

Discussion

• (Peter K): Why in the first note does it say ratio ranges from 1 to 21? Why does it end at 21?
• (Peter K): What about a definition of “luminance”

Status: Done
Text from: Web/Software

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.

Discussion

• (Peter K) Should this perhaps be only visual sensory experience? Or audio too?
• (Gregg V) The definition could apply to either - but we only use it for visual in the standard.

Status: Done
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.

Status: Done
Text from: Subpart A

Discussion or Rationale:

• This definition cannot be changed, as it is derived from Clinger-Cohen. 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
• (Peter K) It seems to me that by this definition, a copier is NOT E&IT, as the IT is embedded. Is this the intention?

Freestanding

• Text coming from Hardware subcommittee

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

General Flash and Red Flash Thresholds

A sequence of flashes or rapidly changing image sequences where all three of the following occur:

1. There are more than three flashes within any one-second period; and
2. The flashing is below 50 Hz [replaces 55 Hz]; and
3. The combined area of flashes occurring concurrently and contiguously occupies more than a total of .006 steradians (25% of any 10 degree visual field on the screen).

• For the general flash threshold, a flash is defined as a pair of opposing changes in relative luminance of 10% or more and the relative luminance of the darker image is below 0.80. An "opposing change" is an increase followed by a decrease, or a decrease followed by an increase.
• For the red flash threshold, a flash is defined as any transition to or from a saturated red.
• Note 1: Flashing that is less than 3 per second or greater than 50 hz automatically passes (see #1 and #2 above)
• Note 2: For general 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.

Status: Done
Text from: Web/Software

Information Technology

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: Done
Text from: Subpart A

Informational Animation

An animation that conveys some information required for understanding content or functionality.

Status: Done
Text from: Web/Software

Interactive Elements

• Text coming from A/V Subcommittee

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

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: Done
Text from: Web/Software

Menu

Set of selectable options.

Discussion

• (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

Status: Done
Text from: Telecommunications
Source: HFES 200

Operable Controls

Any physical control that affects the operation of the product. Operable controls include, but are not limited to, mechanically operated controls, input and output trays, card slots, keyboards, keypads, keys, or buttons, including touch-screens.

Status: Done
Text from: Hardware

Discussion or Rationale: This draft adds individual keys and buttons, as I've inspected many devices that have only those features where the manufacture thought Section 508 didn't apply because it didn't have "a full keyboard".

There was an interesting exchange on the Listserv on this topic regarding full functionality and normal operation.

The question of if this should be "physically operable controls" so it is more specific was raised, but determined to not be needed.

Other Services To Cooperate With Assistive Technologies

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

Status: Done
Text from: Web and Software

Peak Non-crisis Network Traffic

The peak measured network traffic excluding disasters and other crises, or the peak traffic the system is designed to handle.

Status: Done
Text from: Telecommunications

Personal-Private

Products that are used by a single individual. To be considered “personal and private” the product must meet all of the following conditions:

• Individuals may select and order a version that works for them with no policy, technical or economic restrictions.
• Any access features setting functions are accessible in the default mode.
• Individuals may adjust the product to meet their needs.
• Access feature settings are maintained between sessions.

Notes:
If a product is part of a larger system, with specific models or types available to users, the product may only be considered "personal and private" if the list of available models includes at least one that meets the [508] requirements. If agency procurement policy limits choices of specific models, only models included in the policy can be considered in determining whether a product is "personal and private."

This definition is based on the assumption that the choice to use a personal and private product is made by the user. This means that the users know, before encountering the product for either initial or ongoing use, what type of technology it is and what type of technology (if any) they need for personal accessibility.

See the related definition: Public-Shared

Status: In Progress
Text from: Closed

Platform Accessibility Services

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

Status: Done
Text from: Web/Software

Platform Software

Collection of software components that runs on an underlying software or hardware layer, such that the platform creates a virtual environment in which to run applications in a manner which isolates the applications from the underlying layer.

• Note 1: If there is a direct route from the application to the underlying layer then the software components in the middle are not considered to be 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 2: An application offering a compute service, such as a 3d rendering engine where a requesting application can directly access the underlying layer would also not be considered a "platform".
• 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.
• TBD: Notes about bootloader programs and closed systems?

Status: In Progress
Text from: Web/Software

Product

The subcommittee recommends that this term be deleted and that the recommendations uses the term "E&IT" in place of "product" throughout.

Status: Done
Text from: Subpart A

Programatically Determinable

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.

Status: Done
Text from: Web/Software

Public-Shared (was Shared-Public)

Products that are used by multiple individuals. Products are considered “public-shared” if they do not meet the definition of “personal and private.”

Notes:

• Products such as public kiosks are always considered “public-shared,” even if there are accessibility features such as audio.
• Products that are part of a larger system, where there are no models that meet the [508] requirements for accessibility, or where the procuring agency has not included accessible models in the list of models from which users may select, are considered “public and shared.”

See the related definition: Personal-Private

Status: In Progress
Text from: Closed

Real-time Text

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.

Discussion

• (Peter K) Remove "by a terminal"

Status: Done
Text from: Telecommunications

Relative Luminance

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

• Note 1: The relative luminance of an sRGB 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: For dithered colors, use average values of the colors 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 the relative luminance definition is available.

Status: Done
Text from: Web/Software

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: Done
Text from: Telecommunications
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: Done
Text from: Telecommunications

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: Done
Text from: Telecommunications

Undue Burden

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

Status: Done
Text from: Subpart A (no change)

Video Description

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.

Note: This definition should not conflict with the guidelines produced by 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, when complete.

Discussion 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.

Status: Done
Text from: Audio-Video

Web Content

Content which is made available in the World Wide Web.

Alternate proposal: Remove as this is not used in any provisions.

Status: In Progress
Text from: Web and Software

Web Page

• Agreed for removal - from Web and Software Subcommittee.

Discussion information can be found on http://teitac.org/wiki/Web_and_Software:_Definitions.

World Wide Web

A very large set of hypertext-linked content files located on computers connected by the Internet.

Alternate proposal: Remove as this is not used in any provisions.

Status: In Progress
Text from: Web and Software

Section 1194.5 Equivalent Facilitation

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.

Status: Done
Source: {508}1194.5, no change

Technical Provisions

1. Requirements for All Product and Services

1.1 Functional Performance Criteria

Discussion or Rationale: There is a lot of ongoing discussion as to whether the Functional Performance Criteria should be moved to the end of the technical provisions and before the documentation/technical support provisions. There are questions regarding when the functional criteria should be used. There are also two proposals for an introductory paragraph for the section. These are not resolved at this time and are being discussed in the subcommittee and will be raised at the Sept plenary if necessary.

Version 1: If an E&IT product fails to meet one or more of the technical provisions above, meets it via equivalent facilitation, or if the technical provisions do not apply, the agency shall ensure that that the purpose of the technical provisions is met through the following functional performance criteria.

Version 2: After the technical requirements are applied, the following functional performance criteria must be applied to:
1) see if the technical provisions cover all aspects needed to provide access to the product,
2) check any equivalent facilitation, and
3) see if access can be provided in another way if any of the technical provisions are not met.

1.1-A - Without Vision

Products must provide at least one mode that allows [access] without using vision. This access may be provided directly or through assistive technology.

NOTE: The phrase "comparable access" or "access" is still being worked out.

• Status: In Progress
• Text from General
• Source: {508}1194.31(a), {255}1193.31
• Impact:
• External Reference:
• Testability: Expert evaluation
• Metadata
  • Disabilities: Blindness
  • User Activities: All
  • Product Characteristics: All
  • Product Types: All

1.1-B - With Limited Vision

Version 1: At least one mode must be provided that allows [comparable access] to product without requiring visual acuity greater than 20/70. This mode must allow audio and enlarged text output to work together or independently, directly or via AT.

Version 2: Products must provide at least one mode that allows [access] without requiring visual acuity greater than 20/70. This mode must allow audio or enlarged text output to work together or independently, directly or through assistive technology."

Rationale for Version 2: The recommended edit is audio "or" enlarged text output. For small handheld products, it may be difficult to accommodate enlarged text in some cases and audio output may be the most practical alternative. This edit would allow more flexibility appropriate to a wider variety of products.

NOTE: The phrase "comparable access" or "access" is still being worked out.

• Status: In Progress
• Text from General
• Source: {508}1194.31(b), {255}1193.41(b)
• Impact:
• External Reference:
• Testability: Expert evaluation
• Metadata
  • Disabilities: Low vision
  • User Activities: All
  • Product Characteristics: All
  • Product Types: All

1.1-C - With Color Vision Deficits

Products must provide at least one mode that allows access for people with color vision deficits.

Discussion or Rationale:

• This provision can be met by meeting the color and contrast requirements below.
• Propsed: Reword to ensure that this is a visual mode, and does not allow provisions for blindness to meet this provision.
• Proposed for removal, depending on how this section is handled overall.

NOTE: The phrase "comparable access" or "access" is still being worked out.

• Status: In Progress
• Text from General
• Source: new
• Impact:
• External Reference:
• Testability: Expert evaluation
• Metadata
  • Disabilities: Color deficiency/Colorblindness
  • User Activities: All
  • Product Characteristics: All
  • Product Types: All

1.1-D - Without Hearing

Products must provide at least one mode that allows [access] without using hearing. This [access] may be provided directly or through assistive technology.

NOTE: The phrase "comparable access" or "access" is still being worked out.

• Status: In Progress
• Text from General
• Source: {508}1194.31(c), {255}1193.41(d)
• Impact:
• External Reference:
• Testability: Expert evaluation
• Metadata
  • Disabilities: Deafness, Deaf-blindness, Other combined hearing/vision loss
  • User Activities: All
  • Product Characteristics: All
  • Product Types: All

1.1-E - With Limited Hearing

Where audio information is important for the use of a product, it must provide at least one mode that [allows] access with enhanced audio. This [access] may be provided directly or through assistive technology.

NOTE: The phrase "comparable access" or "access" is still being worked out.

• Status: In Progress
• Text from General
• Source: {508}1194.31(d), {255}1193.41(b)
• Impact:
• External Reference:
• Testability: Expert evaluation
• Metadata
  • Disabilities: Hard of hearing,
  • User Activities: All
  • Product Characteristics: All
  • Product Types: All

1.1-F - Without Speech

Products must provide at least one mode that allows [access] without using speech. This [access] may be provided directly or through assistive technology.

NOTE: The phrase "comparable access" or "access" is still being worked out.

• Status: In Progress
• Text from General
• Source: {508}1194.31(e), {255}1193.41(h)
• Impact:
• External Reference:
• Testability: Expert evaluation
• Metadata
  • Disabilities: Speech
  • User Activities: All
  • Product Characteristics: All
  • Product Types: All

1.1-G - With Limited Reach, Strength, or Manipulation

Products must provide at least one mode that allows access for people with limited reach and strength, and that does not require simultaneous actions. This access may be provided directly or through assistive technology.

NOTE: The phrase "comparable access" or "access" is still being worked out.

Discussion or Rationale: Adds AT option.

• Status: In Progress
• Text from General
• Source: {255}1193.41(e)
• Impact:
• External Reference:
• Testability: Expert evaluation
• Metadata
  • Disabilities: Dexterity, Mobility
  • User Activities: All
  • Product Characteristics: All
  • Product Types: All

1.1-H - With No Reach or Touch

Except for closed products, products must provide at least one mode that allows control through assistive technologies to allow [access] for people with no reach or ability to touch.

Discussion or Rationale: This provision is proposed to address a concern that without a provision for individuals who are unable to reach and touch the product, a large group of people will be left out.

On the other side there is a concern that we don't have good techniques for built-in access to products that will address the range reach and touch disabilities. Voice, eye gaze, and head pointing might work, but might not work well enough in the field, or even meet the full range of disabilities being addressed with this provision.

A second concern is around closed products and the fact that if you can't attach AT then you have to rely on a built in solution. Some suggested that we should try to figure out how to create a safe way to have "closed products" be open to AT and thus solve the problem that way.

There is consensus on the issues, but we haven't yet figured out wording that we can reach consensus on or whether it is covered elsewhere.

The Self-Contained/Closed group suggests that we start this item with the words "Except for Closed products,..."

NOTE: The phrase "comparable access" or "access" is still being worked out.

• Status: In Progress
• Text from General
• Source: new
• Impact:
• External Reference:
• Testability: Expert evaluation
• Metadata
  • Disabilities: Dexterity, Mobility
  • User Activities: All
  • Product Characteristics: All
  • Product Types: All

1.1-I - With Cognitive, Language or Learning Limitations

Products provide at least one mode that accommodates cognitive, language or learning impairments, directly or with assistive technology.

Discussion or Rationale: This provision is here as a placeholder. The general group identified several issues and questions in trying to move this forward. The working group is looking for sufficient technical provisions to support the inclusion of a FPC.

From Web and SW Subcommittee: This requirement is extremely broad. Three features recommended by Dr. Clayton Lewis to address the needs of people with cognitive disabilities are:

• Word lookup
• Text Reading
• Spelling assistance

The AT Interoperability provision supports assistive technology with the necessary information to provide these functions.

• Status: In Progress
• Text from General
• Source: {255}1194.41(i)
• Impact:
• External Reference:
• Testability: Expert evaluation
• Metadata
  • Disabilities: Cognitive language/learning
  • User Activities: All
  • Product Characteristics: All
  • Product Types: All

1.2 General Technical Requirements

1.2-J NEW - Accessibility Configuration

In complying with this subpart, each agency must activate accessibility features and configure products so that they are accessible to and usable by people with disabilities.

• Status: Done
• Text from 5-A (first bullet)
• Source:
• Impact:
• External Reference:
• Testability:
• Metadata
  • Disabilities: All
  • User Activities: All
  • Product Characteristics: All
  • Product Types: All

1.2-A - Closed Product Functionality

If any product functionality is closed, then individuals with disabilities must have access to that functionality without the use of any assistive technologies that must be attached or installed. A personal assistive listening device that connects to the standard audio connection required in the audio connection provision is not considered assistive technology.

Discussion or Rationale:

• Status: Done
• Text from Self Contained, Closed
• Source: {508}1194.25(a)
• Impact:
• External Reference:
• Testability: Expert evaluation
• Metadata
  • Disabilities: All
  • User Activities: All
  • Product Characteristics: All
  • Product Types: All

1.2-B - Flashing

Products must not flash more than 3 times in any one second period, unless:

• Flashing created by software is under the general flash and red flash threshold.

• Flashing created by hardware is either:
  • less than YYY candelas; or
  • less than 20 candelas/sq meter and contiguously occupies more than a total of .006 steradians (25% of any 10 degree visual field).

Discussion or Rationale: The hardware portion of this provision is still under development.

• Status: In Progress
• Text from Self Contained, Closed
• Source: {508}1194.21(k) 1194.22(j) 1194.25(i), and {255}1193.43(f)
• Impact:
• External Reference:
• Testability: Inspection
• Metadata
  • Disabilities: All
  • User Activities: All
  • Product Characteristics: All
  • Product Types: All

1.2-C - Biometric ID

As reworked during the plenary
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 form 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.

Explanatory note: 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.

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

• Status: In Progress
• Text from General
• Source: {508}1194.21(k) 1194.22(j) 1194.25(i), and {255}1193.43(f)
• Impact:
• External Reference:
• Testability: Inspection
• Metadata
  • Disabilities: All (that could be caused by loss body part or function)
  • User Activities: All
  • Product Characteristics: All
  • Product Types: All

1.2-D - Pass Through

Products that transmit or conduct information or communication must pass through cross-manufacturer, non-proprietary, industry-standard codes, translation protocols, formats or other information necessary to provide the information or communications in a usable format.

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%.

Discussion or Rationale:

• (Peter K) Virtually every computing device “transmits or conducts information or communication”, so this would apply to things like disk drive firmware and a huge host of other things that have no user input impact. It is nonsensical.
• (Gregg V) It says that these things should not strip disability access information in the process. For most things it would be no issue. In places where it does apply it would be important.

I think the last "usable" is supposed to be Accessible.

• (David B/Gregg) Need note that this applies to captions

• Status: Done
• Text from Telecommunications
• Source: {508}1194.23(j), {255}1193.37
• Impact:
• External Reference:
• Testability: Inspection
• Metadata
  • Disabilities:
  • User Activities:
  • Product Characteristics:
  • Product Types:

1.2-E - Audio information

All information that is needed for operation and use that is provided in audio form must also be available in visual form, either directly or via assistive technology.

• Status: Done
• Text from Self-Contained/Closed
• Source: {255}1194.43(d)
• Impact:
• External Reference:
• Testability: Expert evaluation
• Metadata
  • Disabilities: Deaf, Hard of Hearing
  • User Activities: All
  • Product Characteristics: Sound output – speech, Sound output (other than speech)
  • Product Types: All

1.2-F - Visual Information

All information that is needed for operation and use that is provided in visual form must also be available in audio form and, where appropriate, in tactile form, either directly or via assistive technology.

• Status: Done
• Text from Self-Contained/Closed
• Source: {255}1194.43(a)
• Impact:
• External Reference:
• Testability: Expert evaluation
• Metadata
  • Disabilities: Blind, Low Vision
  • User Activities: All
  • Product Characteristics: Visual display with text, Visual display with graphics
  • Product Types: All

1.2-G - Color

Color coding must not be used as the only means of conveying information, indicating an action, prompting a response, or distinguishing a visual element.

Discussion or Rationale: Harmonize with Color (Web)

• Status: In Progress
• Text from General
• Source: {508}1194.25(g) and 1194.21(i)
• Impact:
• External Reference:
• Testability: Expert evaluation
• Metadata
  • Disabilities: Color deficiency/Colorblindness
  • User Activities: All
  • Product Characteristics: Uses Color (on keys, labels, displays, indicators, anywhere etc.)
  • Product Types: All

1.2-H - Text size

There must be a least one mode where all information provided in text is readable at 3.5 times the [ normal | typical | customary ] viewing distance by people with 20/20 vision. For public-shared products this mode must be the default mode.

Discussion or Rationale:

• This is harmonized with the measurements for 3-U (focus cursor size), but neutral to the size of screen. For text on screen, this measurement might be sufficient, or this note can be incorporated:
  • "A focus cursor that is visually locatable by people with unimpaired vision at 2.5 meters when software is displayed on a 38 cm (15 inch) diagonal screen at 1024 x 768 pixels resolution, without moving the cursor is sufficient."
• Question about scope
  • Is this for only closed products?
  • Input and output for using functionality, but perhaps not serial numbers or other non-functional marking like print in the bottom of the device
  • What about text labels on things like keyboards
  • What about alternative means of communicating (eg) key locations, serial numbers - such as in documentation or a keyboard map.

• Status: In Progress
• Text from Self-Contained/Closed
• Source: {255}1193.43(b)
• Impact:
• External Reference:
• Testability: Inspection
• Metadata
  • Disabilities: Low vision
  • User Activities: All
  • Product Characteristics: Visual display with text
  • Product Types: All

1.2-I - Contrast

Contrast is currently split out between software and hardware. If this approach is successful, then this placeholder provision will be deleted.

• Status: In Progress
• Text from Hardware
• Source:
• Impact:
• External Reference:
• Testability:
• Metadata
  • Disabilities:
  • User Activities:
  • Product Characteristics:
  • Product Types:

2. Hardware Aspects of Products

2.1 All Products with Hardware

2.1-A - Contrast Ratio for Display

For displays on products, at least one mode must exist where the contrast ratio between the luminance at light state compared to luminance at dark state shall be X:1.

• Note: Light (or high) state typically refers to the lighter condition for the display. For example, white content/background on an LCD. Dark (or low) state typically refers to the darker condition for the display. For example, black content/background on an LCD.

Discussion or Rationale: LCD capabilities – define contrast;

• Measurement method – do we need to define? Need to get agreement on language first before spending time on measurement methods.
• For contrast ratios from hardware perspective for active displays (backlit displays such as an LCD) and passive displays.
• Does this apply to cell phones? Yes - need feedback from telecomms industry.

• Status: In Progress - completing values for X:1
• Text from Hardware
• Source: {508} 1194.26(b); {508} 1194.25(c)
• Impact:
• External Reference:
• Testability: Formal test method
• Metadata
  • Disabilities:
  • User Activities:
  • Product Characteristics:
  • Product Types:

2.1-B - Contrast Ratio for Legends and Instructions

If the legend or instructions on the device are the only means of conveying information, then the contrast ratio shall be X:1 and the relative luminance difference must be at least 15% of XXX.

• Note: XXX is a placeholder for the final scale on which the 15% is based.
• Note: If other means of conveying the information in the label or instructions exists (e.g. uniquely tactilely discernible though shape and/or location), then this contrast ratio requirement does not apply.
• Note: This requirement excludes system labels, such as the regulatory labels, where information can be found in other sources associated with the product either in hard- or soft copy format.

Discussion or Rationale: There is some conflict between guidance provided in non-accessiblity ISO standards such as ISO 9241-4

• Status: In Progress - completing values for XXX
• Text from Hardware
• Source: {508} 1194.26(b); {508} 1194.25(c)
• Impact:
• External Reference:
• Testability: Formal test method
• Metadata
  • Disabilities:
  • User Activities:
  • Product Characteristics:
  • Product Types:

2.1-C - Mechanical Controls

All mechanically operated controls and keys:

1. Must be tactilely discernible without activating the controls or keys.
2. Must be operable with one hand and must not require pinching, twisting of the wrist, tight grasping, or simultaneous actions. The force required to activate controls and keys must be 5 lbs. (22.2 N) maximum.
3. If key repeat is supported, the delay before repeat must be adjustable to at least 2 seconds. The key repeat rate must be adjustable to 2 seconds per character.
4. The status of all locking or toggle controls or keys must be visually discernible, and discernible either through touch or sound.

Discussion or Rationale: Changes in this section were limited to the addition of the "Simultaneous controls" to the operability requirements and reordering requirements to align the adjective "tight" with "grasping".

This does not imply that a product must be entirely operable with one hand (eg, product could be placed on a surface).

• Status: Done
• Text from Hardware
• Source: {508} 1194.26(a); 1194.23(k)
• Impact:
• External Reference:
• Testability: Inspection
• Metadata
  • Disabilities: All
  • User Activities: Conversations, data analysis, document sharing and reviewing, media (audio/video) creation and editing.
  • Product Characteristics: Physical controls or connectors, touchscreen or touch sensitive buttons, color
  • Product Types: Hardware, telephone, telephone system, audiovisual equipment, public information terminal, desktop computer system, portable computer system, copier, printer, scanner, other similar peripherals

2.1-D - Touch Operated Controls

If a product utilizes touch screens or touch-operated controls then the product must provide, without requiring user-speech:

1. A functionally equivalent, alternate means of operation that uses Mechanical Controls and does not require vision.
2. A functionally equivalent, alternate means of operation that does not require fine motor control.

Note: This provision should not discourage the provision of control via user speech in addition to the above methods.

Version 2 (proposal from plenary) If a product uses touch screens or touch-operated controls, it must provide a functionally equivalent alternative means of operation that meets the requirements for Mechanical Controls. This alternative must not require either vision or fine motor control.

Note: A product may also provide control via user speech in addition to the above methods.

Discussion or Rationale: This language addresses the issues associated with touch-based controls (including biophysical, accidental activation and vision) by requiring a redundant interaction method without assigning the control type.

Open issues:

• Keyboard controls that provide equivalent functionality are equivalent
• Touch screens can't always provide a 1:1 match of soft and mechanical controls.
• Need to finalize some language that addresses the intent of “redundancy” of controls beyond just requiring another set of mechanical controls.
• Need to add an ability to de-activate the touch screen.
• Is remote control an acceptable alternative

• Status: In Progress
• Text from Hardware
• Source: {508} 1194.26(b); {508} 1194.25(c)
• Impact:
• External Reference:
• Testability: Inspection
• Metadata
  • Disabilities: All
  • User Activities: Conversations, data analysis, document sharing and reviewing, media (audio/video) creation and editing
  • Product Characteristics: Physical controls or connectors, touchscreen or touch sensitive buttons
  • Product Types: Hardware, telephone, telephone system, audiovisual equipment, public information terminal, desktop computer system, portable computer system, copier, printer, scanner, other similar peripheral

2.1-E - Connector or Connection Language

If users can access and the user interface of a product through a non-standard user connection, they must also be able to control that functionality through a standard user connection using standard protocols for that type of input or output. If an adapter is required to convert a non-standard user connection on an E&IT device into a standard user connection, it shall be the responsibility of the E&IT vendor to offer such adapter.

• Note: "Standard Connection" shall be deemed to be a connection that has been readily adopted by industry and is in common and current use. For example, while a serial port with a DB25 connector used for mouse input was a standard connection many years ago, it is no longer in common and current use on modern computers, and would no longer be considered a standard connection.

Discussion or Rationale: The change to the word "connection" allows for wireless

• Status: Done
• Text from Hardware and Telecommunications
• Source: {508} 1194.26(d)
• Impact:
• External Reference:
• Testability: Inspection
• Metadata
  • Disabilities: All
  • User Activities: Conversations, data analysis, document sharing and reviewing, media (audio/video) creation and editing
  • Product Characteristics: Physical controls or connectors, touchscreen or touch sensitive buttons
  • Product Types: Hardware, telephone, telephone system, audiovisual equipment, public information terminal, desktop computer system, portable computer system, copier, printer, scanner, other similar peripheral

2.1-F - Installed or Free-Standing Products

Architecturally installed or free-standing non-portable products intended to be used in one location must have any operable controls positioned within reach.

The Access Board should insert the appropriate reach-range ADAAG requirements at time of adoption.

Discussion or Rationale: This provision should be coordinated with the ADAAG, which is currently in rulemaking

• Status: Done
• Text from Hardware
• Source: {508} 1194.25(j)
• Impact:
• External Reference:
• Testability: Inspection
• Metadata
  • Disabilities: All
  • User Activities: Conversations, data analysis, document sharing and reviewing, media (audio/video) creation and editing
  • Product Characteristics: Physical controls or connectors, touchscreen or touch sensitive buttons
  • Product Types: Hardware, telephone, telephone system, audiovisual equipment, public information terminal, desktop computer system, portable computer system, copier, printer, scanner, other similar peripheral

2.2 If the Product has Speech Output or Throughput

2.2-A - Magnetic Coupling

Products that deliver output with an audio transducer that is normally held up to the ear must provide a means for effective magnetic wireless coupling to hearing technologies that allows a user to effectively utilize the product. This does not apply to headphone, headset, OR other accessories that plug into a jack on the product.

• Status: Done
• Text from Hardware and Telecommunications
• Source: {508}1194.23(h), {255}11943.43(i)
• Impact:
• External Reference:
• Testability: Formal test method
• Metadata
  • Disabilities:
  • User Activities:
  • Product Characteristics:
  • Product Types:

2.2-B - Interference with Hearing Device

Version 1: Interference to hearing technologies (including hearing aids, cochlear implants, and assistive listening devices) must be reduced to the lowest possible level that allows a user of hearing technologies to utilize the telecommunications product.

Recommendation: Advisory Note for U.S. use to include information re existing standards: TIA Standard for Cordless Phones and the ANSI standard for cellular and PCS frequency bands and for hearing aid immunity. Standards do not exist for other frequency bands and for any VoIP at this time.

Discussion or Rationale:

• SC is working on the wording of this and will report back

• Status: In Progress
• Text from Hardware and Telecommunications
• Source: {508}1194.23(i), {255}1193.43(h)
• Impact:
• External Reference:
• Testability: Formal test method
• Metadata
  • Disabilities: Hearing, Hard of Hearing
  • User Activities:
  • Product Characteristics:
  • Product Types:

2.2-C - Audio Connection

When products provide auditory output beyond simple tonal feedback or signaling, the audio signal must be provided at a standard signal level through an industry standard connection that will allow for private listening.

• If the product is a public-shared product then the connection must be via a standard 2.5mm or 3.5mm audio jack.

• If the product is personal-private product then the connection can be wired or wireless as long as a 2.5mm or 3.5mm phone jack adapter is available from the manufacturer.

Alternate wording for clarity

• Public-shared products must provide the connection via a standard 2.5mm or 3.5mm audio jack.

• Personal-private products may provide either a wired or wireless connection. A wired connection must be via a standard 2.5mm or 3.5mm audio jack. A wireless connection may be used as long as a 2.5mm or 3.5mm phone jack adapter is available from the manufacturer.

Discussion or Rationale:

• Need to be more specific about "standard signal level"
• Need to check against the definitions for public-shared and personal-private to be sure they work for this provision (or define the distinction here).

• Status: In Progress
• Text from Hardware
• Source: {508} 1194.23(e); {255} 1193.51(b) & (g)
• Impact:
• External Reference:
• Testability: Inspection
• Metadata
  • Disabilities: All
  • User Activities: Conversations, data analysis, document sharing and reviewing, media (audio/video) creation and editing.
  • Product Characteristics: Physical controls or connectors, touchscreen or touch sensitive buttons
  • Product Types: Hardware, telephone, telephone system, audiovisual equipment, public information terminal, desktop computer system, portable computer system, copier, printer, scanner, other similar peripherals

2.2-D - Volume

All products with auditory output beyond simple tonal feedback or signaling must allow users to adjust the audio level. At peak volume output they must have less than 12 dB symmetrical clipping or a total harmonic distortion (THD) less than XXX dB

• For products located in a public place, the maximum volume level must be at least 80 dB SPL RMS, measured at xx centimeters from the device at maximum volume setting [possible without XXX distortion].
• For products that will not be used in public places or where the volume of the public place is controlled to be under 50 dBA SPL RMS, the maximum volume level must be at least 65 dB SPL RMS.

Discussion or rationale: Final level for THD still to be determined. Question about where are volumes set? Is that where you measure from?

• Status: In Progress - values to be added
• Text from Self-Contained/Closed
• Source: {508}1194.25(f), {255}1193.43(e)
• Impact:
• External Reference:
• Testability: Formal test method
• Metadata
  • Disabilities: Hard of hearing
  • User Activities: All
  • Product Characteristics: Sound output – speech, Sound output (other than speech)
  • Product Types: All

2.2-E - Volume (Gain)

For incoming voice signals:

1. Analog line-powered telecommunications products, wireline, and all cordless telephones (wireline or VoIP) must comply with FCC regulation §68.317 for volume control
2. All cellular phones - TBD
3. All other telecommunications products or systems that provide a function allowing voice communication must provide a gain adjustable from the normal unamplified level to at least 20 dB above the normal unamplified level as measured in accordance with the provisions of the FCC regulation §68.317 for volume control. The volume at the normal unamplified level setting must also meet the requirement in FCC regulation 68.317.

Discussion or Rationale:

• Language for cellular phones pending outcome of ATIS Study Group 11 work
• Further research needed for 20 dB requirement
• Review telecoms/communications to be sure requirement is inclusive
• Need to determine if the word "telecommunications" should be removed

• Status: In Progress
• Text from Telecommunications
• Source: {508}1194.23(f)
• Impact:
• External Reference: FCC §68.317
• Testability: Formal test method
• Metadata
  • Disabilities: Hard of hearing
  • User Activities: Real-time voice conversation, IVR
  • Product Characteristics: Audio output
  • Product Types: Telephones, IVRs

2.2-F - Volume Reset

If the product allows a user to adjust the receive volume to a level greater than 18 dB above normal unamplified level, a function must be provided to automatically reset the volume to a level not greater than 18 dB above normal unamplified level after every use. A manual override control may be provided to prevent the automatic reset, subject to the conditions specified in FCC Memorandum Opinion and Order DA 01-578. This applies to products with transducers held against the ear which are neither headsets nor headphones

• Status: Done
• Text from Telecommunications
• Source: {508}1194.23(g)
• Impact:
• External Reference:
• Testability: Inspection
• Metadata
  • Disabilities:
  • User Activities:
  • Product Characteristics:
  • Product Types:

3. User Interface and Electronic Content Provisions

These provisions apply to all electronic user interfaces and content.

3-A - Color

Color must not be used as the only visual means of conveying information, indicating an action, prompting a response, or distinguishing a visual element.

Discussion or Rationale: Need to add an example

• Status: Done
• Text from Web and Software
• Source: {508}1194.25(g) and 1194.21(i) (was 6.1.A in July 18 draft)
• Impact:
• External Reference:
• Testability: Expert evaluation
• Metadata
  • Disabilities:
  • User Activities:
  • Product Characteristics:
  • Product Types:

3-B - Contrast

Presentation of text (and images of text) in electronic documents must have a default contrast ratio of at least 5:1, except if the text is unavailable items or pure decoration. Large-scale text (or images of large-scale text) can allow a contrast ratio of at least 3:1.

Discussion or Rationale: Harmonization with WCAG 2.0.

• Status: Done
• Text from Web and Software
• Source: new (was 3.2.A and 6.1.B in July 18 draft)
• Impact:
• External Reference:
• Testability: Formal