Section 8 - May 30 Draft

May 30 Draft > Comments on the Structure

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Comments on the structure of Section: 8 - Process

EWG: Three provisions from Section 255 map to this section:

• {255}1193.23(a)- Manufacturers shall evaluate the accessibility, usability, and compatibility of telecommunications equipment and customer premises equipment and shall incorporate such evaluation throughout product design, development, and fabrication, as early and consistently as possible. Manufacturers shall identify barriers to accessibility and usability as part of such a product design and development process.

• {255}1193.23(b)- In developing such a process, manufacturers shall 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.

• {255}1193.23(c) - Where manufacturers provide employee training, they shall ensure it is appropriate to an employee's function. In developing, or incorporating existing training programs, consideration shall be given to the following factors:

1. Accessibility requirements of individuals with disabilities;
2. Means of communicating with individuals with disabilities;
3. Commonly used adaptive technology used with the manufacturer's products;
4. Designing for accessibility; and
5. Solutions for accessibility and compatibility.