SCCP Report 2007-03-12
TEITAC subcommittee report § 1194.25 Self Contained, Closed Products — 3/12/07
I. Material which can be described as “Changes to Existing Provisions”
- Modification – Material which modifies existing provisions.
- Rationale – Why is this change suggested?
| Current provision | Keep current language | Change in Jurisdiction? | Modification | Rationale: Why is this change suggested? |
|---|---|---|---|---|
| 1194.25(a) Self contained products shall be usable by people with disabilities without requiring an end-user to attach assistive technology to the product. Personal headsets for private listening are not assistive technology. | No | No | Under discussion | Proposed that self-contained is a functional characteristic of either hardware or software rather than a class of products. Identify that a closed product function could be by design, policy or perhaps other reasoning. Not requiring AT will be changed to reflect that AT is not readily available or that a choice has been made not to be compatible with available AT. |
| 1194.25(b) When a timed response is required, the user shall be alerted and given sufficient time to indicate more time is required. | Yes | Software | NA | This is a function of software. |
| 1194.25(c) Where a product utilizes touchscreens or contact-sensitive controls, an input method shall be provided that complies with §1194.23 (k) (1) through (4). | No | Hardware | Under discussion | The text of this provision refers to touch sensitive controls but the compliance points taken from telecomm refer to mechanical controls. |
| 1194.25(d) When biometric forms of user identification or control are used, an alternative form of identification or activation, which does not require the user to possess particular biological characteristics, shall also be provided. | No | Hardware | Under discussion | May need clarification that this provision applies to biometrics related to product usage rather than biometrics for other purposes. |
| 1194.25(e) When products provide auditory output, the audio signal shall be provided at a standard signal level through an industry standard connector that will allow for private listening. The product must provide the ability to interrupt, pause, and restart the audio at anytime. | Yes | First sentence moved to hardware; second sentence moved to software. | Further discussion | This is two provisions and should be designated in hardware and software respectively. |
| 1194.25(f) When products deliver voice output in a public area, incremental volume control shall be provided with output amplification up to a level of at least 65 dB. Where the ambient noise level of the environment is above 45 dB, a volume gain of at least 20 dB above the ambient level shall be user selectable. A function shall be provided to automatically reset the volume to the default level after every use. | Not Determined | Not Determined | ||
| 1194.25(g) Color coding shall not be used as the only means of conveying information, indicating an action, prompting a response, or distinguishing a visual element. | Yes | Hardware and software as applicable | ||
| 1194.25(h) When a product permits a user to adjust color and contrast settings, a range of color selections capable of producing a variety of contrast levels shall be provided. | Yes | Software | This is a function of software. | |
| 1194.25(i) Products shall be designed to avoid causing the screen to flicker with a frequency greater than 2 Hz and lower than 55 Hz. | No | Software | 55 Hz changed to 50 Hz. | Not correctly implemented from the EITAC. |
1194.25(j) Products which are freestanding, non-portable, and intended to be used in one location and which have operable controls shall comply with the following:
| Yes | Hardware | Applies to hardware. |
II. Entirely New Provisions
No new provisions have been proposed. Implementation and clarification of the Functional Performance Criteria is essential to increasing accessibility of closed product functions. Therefore, this subcommittee has agreed to focus some energy on review of the Functional Criteria to determine if further standards based on their implementation might be necessary to accommodate functions where AT is not available or is otherwise excluded.
III. Other Material
A. Recommendations on organization of the provisions
Provisions should be organized by characteristic rather than by product to the extent possible. This is especially critical to Closed characteristics of products where the product comprises hardware and software, and where accessibility must be designed into the product itself due to product design constraints, use requirements or lack of available AT.
B. Issues this subcommittee is not addressing, but which should be addressed.
C. Recommendations relating to Themes or other content.
This subcommittee will need to comment on the following:
- Cost benefit related to self-contained implementation of accessibility of low cost technologies such as calculators — product line approach; exemptions.