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EWG:Draft Oct 26 With Cognitive Language Learning Limitations

1.1-I - With Cognitive, Language or Learning Limitations

This page is the text proposed in the Nov Plenary Meeting.

Go to the current version in the Oct 26 Draft

Go to the Sandbox of this Provision


Proposed text in Oct 26 draft:
no text was provided


Proposed text from Karen PS
Products must provide at least one mode that accommodates cognitive, language, memory or learning impairments, directly or with assistive technology.

Rationale: 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"


Comment from ITI
While ITI appreciates the sincere interest and desire of many to address cognitive disabilities within Section 508, we believe that doing so would present a number of serious challenges for manufacturers and government agencies, including:

  • A lack of technical provisions relevant to cognitive disorders
  • A lack of differentiation of various types of cognitive disorders, and
  • A lack of clear distinction of when the needs for those with cognitive disorders are met.

If we are still struggling with even understanding what this should be at this time, then we likely don't have enough time to finish it. Accordingly, we recommend removal of this provision.

Comment from Sun
We included our comments in the ITI report for this provision, but feel strongly that this item needs resolution. If we are still struggling with even understanding what this should be at this time, then we likely don't have enough time to finish it. The current provision text is written as a general goal, and Sun supports including "should" language for this provision at this point, if it is stated in the context of a goal for the technical provisions.

Comments from ITAA
EWG Note: While the ITAA comments applied to the Sept 14 draft, they were retained here since they could apply to the text proposed by Karen PS. ITAA needs to confirm this assumption made by the EWG.)

  • This requirement is overly broad. Anyone can claim conformance.
  • This theoretical mode of operation is not testable as described, even by "Expert Evaluation". There are no thresholds described, e.g., grade level reading.
  • What are the criteria for satisfying this mode.
  • Until there are thresholds defined, we prefer this provision not be included.

Other Comments

  • 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 AT with the necessary information to provide these functions.

Comments from CSD/Trace Center
Use language proposed by Karen PS from 255

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