Touch Controls

Touch Driven Language from 508

Biometric Language

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.

1194.26 (c) 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.

Touch Language

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).

(k) Products which have mechanically operated controls or keys, shall comply with the following:

(1) Controls and keys shall be tactilely discernible without activating the controls or keys.

(2) Controls and keys shall be operable with one hand and shall not require tight grasping, pinching, or twisting of the wrist. The force required to activate controls and keys shall be 5 lbs. (22.2 N) maximum.

(3) If key repeat is supported, the delay before repeat shall be adjustable to at least 2 seconds. Key repeat rate shall be adjustable to 2 seconds per character.

(4) The status of all locking or toggle controls or keys shall be visually discernible, and discernible either through touch or sound.

1194.26 (b) If a product utilizes touch screens or touch-operated controls, an input method shall be provided that complies with § 1194.23 (k) (1) through (4).

Touch Screen Discussion

This is an attempt to summarize key points from a transcript. Unfortunately, there are sections that were not very clear.

Mechanical and touch sensitive controls need to be separated. In fact there may be 3 types of controls to consider:

1. Mechanical
2. Touch sensitive
3. Touch dependent (biometric)

Mechanical controls may not be the best alternative to a touch sensitive control – language should be drafted to allow alternatives

Touch screen versus touch sensitive:

• touch screen more of a biometric technology
• touch sensitive is still a “mechanically” driven solution but there is greater control of the sensitivity and timing characteristics. The example give was adaptive controls on a microwave.

Potential touch sensitive characteristics:

• Control must be tactiley discernible
• Control must have a mechanism to minimize accidental activation due to touch
• Control characteristics, such as time to registration of signal, pressure, etc., should be adjustable

Potential touch screen content:

• An alternative method to achieve touch screen control functions must be provided via an alternative format or interact (for example voice control).

Section from Transcript regarding this topic.

When he comes on hold maybe combat and visit car on [ indiscernible ]. Let's continue on the other points. We seem to have a bit of controversy. I would like to go back to 1194.26 E where it is talking about touch screen. In the notes, there has been quite a few added here. Debbie, I'm going to read them for your benefit. Just 12th my voice is giving out. I had put notes to the effect that touch screen devices are good for people with mobility impairment but not so good for people who are blind because of the inability to have a tactile feel of the key. I made those comments there. Someone else has inserted a question. I had said its a good thing for people with mobility and parents because it means all controls are software based and therefore they can access it. [ indiscernible ].

I guess that would be moving a mouse on the button on a screen or something. Then another comment inserted. I had suggested functions that are performed by Takako control shall be also be performed all [ indiscernible ] and there is another comment inserted.

This is Debbie. I don't see that one as the alternative mechanical controls thing operated in a different way. I don't see that as a compatibility issues at all. It could be, that is one of the alternate disappeared the other alternative would be there is more than one mode of operation appeared more than one mode of operation could include a voice activated, could include a pad that creates an alternate touch screen that is not specifically 80 grid could include a variety of things. I think what we want to say is that -- this would be true for the touch screen or touch controls, and that the mechanical controls that there needs to be more than one which operate them. I think we talked before about the fact that these are really related, that they need to be neat to be separated into the two pieces so that you have one discussion that addresses if there are mechanical controls than those controls need to be tactically discernible and the controls -- their knees to be more than one which to activate them and any time in needs to be adjustable. Another cause is that if there is a touch screen or touch the sensitive control, I wouldn't call it a touch screen I would call it a touch sensitive control because mechanical controls are incredibly touch sensitive whether it is a touch screen, some of the same things apply. I think they should be separated into two things, especially if we do end up adopting something like the tool that Greg developed people are going to go with their product they're going to say does my product have mechanical controls? Does my party have a touch screen or do this or have that? My current thinking still is that these need to be separated into two.

This is Randy. I think that makes sense. It gives more to the touch sensitive versus touch screen. I completely agree. I saw a pant application that Apple -- patents application talking about an idea of making [ indiscernible ] around the display of touch-sensitive input device not even on the screen but the actual closure touch the areas that could be -- I think you're right about that. We are going to see more and more touch sensitive. It sounds like if we split them in two, and what we are seeing for the benefit of mobility mechanical control there should be some other way of [ indiscernible ] the same version without pushing the mechanical control. The second part is the touch system control and finish the sentence for me on that one?

Pardon me?

On the clause that we deal with touch sensitive control, do we keep the wording that they must be tactfully discernible or --

No. With touch sensitive controls, because they might not be. What you have to have is an alternative input mode in addition, to the touch sensitive control. Touch sensitive control if they are touch sensitive it doesn't matter if they are tactfully discernible as you --

This is Jim from the access board. What if we applied the standard to that and I will leave it to your expertise but I have several appliances in my home that our commercial appliances, but I have had them adapted because of my near Rock Cafe, on -- neuropathy but I have to have it certain count put forth before it will activate. If I am running my hand down, I come to the third attack on a button which is a Braille Trier's some simple, I have to put some mild pressure. Is the same thing in reading Braille come to the button and light pressure to activate.

Those -- this is Debbie. Those aren't necessarily considered touch sensitive because just the fact of touching them doesn't activate them. They do require pressure.

This is Jim. They told me they could make it as soon as there was any indication of sensitivity, it would activate. I said I need something that is an affirmative action for me and modify it that way.

This is Debbie. There are any number of ways we could do it. I would say that the industry preference generally is to be given a choice. We would want to get some industry consultation about whether it is okay to require that a certain level of force be put on them. Most of them and do these days because if you have in your pocket you are going to biologically start running the device. Most of them do have the ability to not necessarily adjust it. I don't know if it is a reasonable requirement and we want to get industry consultation or it's result requirement to say and B adjustable. How adjustable is one of the mechanisms that people could use. The other mechanism is there does need to be an alternative and the example for that one, the good example and where we can get some of the language would be from the voting guidelines --

One of the people that wrote the accessibility usability --

This is Debbie. Right. That is the place we should be looking for some of these because you did a great job of looking. With the voting guidelines, the two things that are required about your microwave, my microwave is the same, the two things that are required about the appliance is that A, the control is adjustable in terms of how much sensitivity, how much touch is required and B, a somebody had to discern it. So the issue I think is to describe -- and I can think of language. The issue is to describe that those two things have to be achievable. The person has to be able to cultivate the control in some way whether on the control of with the voting machine or a separate input. There has to be an input mechanism isn't activated instantly by touch. Then, there has to be a methodology for identifying the input area is.

I'm going to jump in treat this is Randy. It looks like we have quite a few more people on the call. We just started out with four of us. They're is a few in the Q with their hand up. Indulging that Debbie does not have a laptop.

I was getting so engrossed in the decision I forgot my hand was up. This is David. When the session began we were limiting the potential impact of a touch screen I think where the Debbie was going with that was covering my concern. The touch screen could be the opposite. In terms of people with mobility issues could be worse. Really depending on what the mobility issue is. I think you started addressing it with some of the alternatives. I would put a plug in if there is a secondary level recommendation for the adjustability because that is where it really comes in handy for people with Nero-motor and neurological, what Jim Jim was suggesting works for him.

The only other concern I have what I think of touch-sensitive control and I look at my smart phone, to come up with an alternative for that and make it accessible for an AT alternative, I am not sure how well that will solve the problem. If you end up having to lug around additional keyboard in order to grab your phone and work on your e-mail it defeats the purpose of that particular product. Those are my thoughts at this point. I thought you were coming up with some great stuff, Debbie.

This is Randy. I guess my hand is up. Just anecdotally, go to the idea of touch interface. Our company is building a keyboard for [ indiscernible ] that is a class keyboard. The top surface is pure glass and below it's our sensors that detect touch capacity and allows us to type. The purpose is so hot that it is easy to clean. There is absolutely no tactfully discernible anything related to the key there to look at the glass keyboard and touch with the letter is and they're touching glass and this is a touch it come is activated. Of that product, we can make it so that you can touch the key and press it. I think there is stuff out there that really are purer touch sensitive and there's no way to make another one. We need to have some wording around that. For example, keyboard I'm talking about it that was being used by the federal government somewhere and someone who is blind came into the job, and alternate it might be a rubber keyboard where they could feel the keys but my still be [ indiscernible ].

This is Debbie.

Just put me whenever any to be.

It looks like David put his hand back up as well.

This is David why saki. Your description it made me realize that the ability to disable the touch control I think would be very important. A component of how we handle accessibility for touched control. People that use their laptops that are blind need to be able to use the IBM based the research at control and be able to turn off their touch pad. And likewise hit anything else, if not knowing where you are going to touch is Greg to set stuff off lease to be disabled.

This is Randy. Debbie?

This is Debbie Perry based on the discussion you just have about the product talking about with the glass. This breaks out a third component to this. We have already established we have mechanical controls and we have touch controls and actually the ones that relate to Jim's point would be pressured sensitive control. For example, on your glass, which is a different set of touch. There are some things like Jim's appliance that you can either adjust or they, by default that they require a certain level of pressure as you touch them and they are therefore kind of clause I-mechanical because you are pressing ssing something under the glass where is your device is assuming biometrics and assuming pressure comes to the thing and activates and my concern about that for lots of people is a person using a mouse stick or something may not apply even pressure, things drag or slide. Probably what we want to do is break this into three component parts that relate to touch controls themselves come pressure sensitive controls as a subset of that and then the mechanical.

Thanks, Debbie. Just to clarify, there is pressure to activate a touch sensitive control and also, by metric, that may be another sub category because with our class keyboard there's no pressure required if the sensitivity is set fairly high, you can put your finger barely above the glass without your finger touching it-should this is Debbie. If you put a mouse stick up there in that case -- we've already got a provision that says you can't have a biometric?

It would not work with a mouse.

This would violate 508 on account of the biometric requirement that is already there it violates it based on existing requirements. It violates 508 based on biometrics alone we have got biometrics covered.

This is Randy it may not need an extra thing.

This is Debbie. No, not here.

This is David. There is one other component that may be a sub category and that is the temporal element, Norris how long does it have to be touched for? That's another potential adjustable piece. Of course, we have the is that a lot for folks with tremors and some types of specificity critic there's ways to be able to maintain that as a control device, by adjusting the time you can adjust the added burden keystrokes. I want to throw that out as a possibility.

That is very interesting point. Debbie, would it be possible for you to put this into your words?

Let me take a look at this in relation to some of the things that are out there and see if I can at least draft something for discussion and put them on the list.

This is ready. I think David, you just touched on a possible solution if there are touch sensitive controls that are not technically discernible and they get activated as soon as you touch them, then the possible solution to another mode maybe to voice the controls as you touch them and have a time variable if you remain on that keyboard X number of seconds activates the key.

This is David. Exactly where I was thinking in the beginning of that. That is one way of handling its.

This is Debbie. There are a lot of products that don't have the capacity for voice output. That would be where an industry might decide to facilitate but reject include that in the requirements. We need to make tactfully discernible only a requirement of actual mechanical controls because that is where you are talking about buttons, levers, wheels, things that are potentially tactfully discernible. It doesn't make sense to require necessarily that the touch screen it tactfully discernible because it requires you to explore all over it to find things. You can't put dots on you don't necessarily want verbal output for everything you encountered on the screen. The alternative that we are always looking at about that is an alternative way to and put it if you have re touch-sensitive screen. And then some requirements that we might want to look at around the touch sensitivity issue that would look at issues around adjustability of the timing of the event, the timing of the activation possibly been adjustable and pressure required and we have a piece about biometrics.

This is Randy. Is the one more comment on the subject?

I like everything he just said. That was well-cooked. The beginning of the voice output maybe it would be addressed some place else, but I would think that the people with visual and parents will have a fit if we weren't addressing the need for voice output, especially when you have screens where the tactile disability is not going to work because it is a dynamic screen. The options are changing in terms of what you are controlling or accessing. People with visual impairment have to know what those options are.

This is Debbie that's a fraction of the software of the product not the hardware. When we talk about hardware and talk about the I identify the key so you are identify the output that is actually a software functionality and what we need to be doing there is looking at the software standards to ensure that there are software standards aren't limited to PC-type devices because you need access to the output to come to the results of pressing a key not just with the keys and do you don't necessarily need to verbally hear what wiki does. That's really distracting. You want to know is what the output of it was. I want to know did the okay prompt take>>tom brett: debbie...then we are saying that there is a class of AT that may not meet all of the standards? >>tom brett: by that i mean a touch screen will need to comply with some but not all of the provisions? >>tom brett: there will be a certain population that will not be able to use that input device. it schism.

This is Debbie. Absolutely. That is why we have to have alternative ways of in putting. Because we are talking about hardware we need to be talking about input more than output. That is why we talk about in the hardware requirements we talked about keys being tactically discernible, but we don't talk in hardware about being able to read the results of a key press does that is controlled by software.

This is and David. Debbie, I hear what you are saying but for me to consider that as software, since I am [ indiscernible ] I know when my control has been affected. I am using the screen and that ties in with our original intent of the corporal which meant physical and sensory. The sensory output is part of the hardware interface process. I am not saying that we don't Corneille this closely with the software folks, but when we kind of shifted over from the face to face meeting we were taken on the visual output which would then have to have some type of auditory output as an alternative as part of the hardware and software process.

This is Randy treated David you had your hand up, was sacked for that point?

This is David. Sure.

This is David with the access board and I apologize if I have come in late. In looking at the standard in general you may have noticed this is addressed in three different places, the telecom the self-contained and the computers and is worded in three different ways. As a clean this up you may want to look at consistency issues. We have three different terms, touched operated, contact, touch screen and you may want to change them remove them or whatever. The other concept to consider it would be different areas is the introductory clause where a product uses a touch screen or products that have mechanically operated controls and keys comma. That is a problem. It doesn't say it applies to mechanically operated controls and she's only two whatever word they use like context sensitive keys and then in the reverse of under Telecom, if you're mechanically operated controls and cheese but not if there is a touch screen. That's a pretty simple point but just to look at consistency. My third point besides the introductory clause by 1/3 point is you may want to consider in your discussion advisory notes, not just what might the design requirements be but would it be helpful to have an advisory inodorous something that has a definition that clarifies what you mean by these terms.

This is Debbie. We are going to put them all next to each other because this is exactly the problem I have seen over the years. We're going to break these apart so if you have mechanical control if you have the touch sensitive, make them right next to each other so we can try to cover all the scenarios so that as you are looking at them you can say mind doesn't have this one, but it does have this.