EWG:Draft Oct 26 Without Physical Contact

1.1-H - Without Physical Contact

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:
Products must provide at least one mode that allows access to all functionality of the product without requiring any physical contact with the product beyond initial connection and setup of a special interface device. This access may be provided directly or through assistive technology.

Note: While it is preferable that no contact at all be required, the use of a standard physical connection such as a USB would meet this provision.

Explanatory Notes

• Use of cameras to monitor user movement to control input would meet this provision.
• Allowing users to control the product using their own communication or control via a universal wireless connection would also meet this provision.
  • ANSI/INCITS URC standard would be one
  • Wireless USB would be another solution
• A connection is allowed since it may be necessary. Individuals could have a companion or bystander connect them and still allow them privacy in completing the transaction. Methods not requiring any contact or assistance of course are preferred.

Version 2 from Paul S: Products with a visual interface must provide at least one mode that allows the product to be accessible for people with disabilities with only minimal physical contact with the product such as power-on, initialization of a call, change of a mode of operation, or initial connection and setup of a special interface device. This access may be provided directly or through assistive technology.

Rationale and Notes

• 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.
• 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 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.
• 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.
• Direct Access examples:
  • Voice dialing is an example of direct access. Access to voice dialing may require physical contact with the product to initiate the call or change mode of operation to enable voice dialing.

Comment from Paul S regarding his proposed text:
I think this provision as drafted is confusing, incomplete and requires more in-depth discussion. My primary concern is that the existence of a network interface by itself does not provide access to “all the features of the product” and thus by itself cannot assure accessibility. With regard to the specific solutions sited by Greg Vanderheiden, I don’t know of any commercial off-the-shelf product that is compatible with the ANSI/INCITS URC standard and thus doubt it is a practical solution at this time. I also don’t believe that the “use of cameras to monitor user movement to control input would meet this provision” since such a method of control is not a product feature a manufacturer could incorporate into the product itself.

Rather than apply this to all E&IT products, these requirements should only be applied to products with a visual interface that could be accessed from across a network. I would need further explanations or examples for how E&IT products without a visual interface could comply to be comfortable with applying this to all E&IT products.

Comments from ITI
Products not meeting the no-touch through AT portion of the provision can claim the exception for "closed products". There is an inescapable logical loop rendering this proposed provision completely ineffective. The proposed provision should be removed because, in addition to the logical loop problem, no-touch access through AT is already served by the limited mobility functional standard (1.1-G) as well as many of the technical standards.

Comments from CSD/Trace Center
If there is concern here – then perhaps an 'at risk' note could be used to say that it would be removed if certain things were not true by the time the rules were promulgated.