Why no AT

Assistive Technology Not Mentioned in 1194.31 (f)

Here is an agenda item ATIA would like to be considered:

1. Functional Performance Criteria: Subpart C, 1194.31 (f)

This section deals with Mobility Impairments, but fails to reference compatibility with Assistive Technology (in contrast to the previous sections (a) - (e), which do reference Assistive Technology). This appears to be an oversight.

-Randy Marsden

David Baquis Response: Failure to Reference AT Was Intentional

With regard to Subpart C, 1194.31 (f):

The failure to reference AT was not an oversight, but was intentional. Doug Wakefield used to explain this in his “508 back to basics workshops”, so I suggest that you ask him about it.

(David Baquis)

Doug Wakefield Response Regarding Failure to Reference AT

Here is a clip from of the relevant part of Doug’s response.

In five of the six parts of Subpart c, we said basically either build access in to the product for a specific disability or provide support for assistive technology. However, in (f) we did not add support for AT:

• (f) At least one mode of operation and information retrieval that does not require fine motor control or simultaneous actions and that is operable with limited reach and strength shall be provided.

The reasoning behind this is as follows: This requirement is addressing the multitude of mechanical controls that may be on a product such as, latches for opening the covers on laptops, on/off switches on all e&it, paper tray releases, release levers or buttons on docking stations, buttons for opening drive doors and so on. The list is endless. This provision is requiring that a product's mechanical controls must meet this provision "out of the box." While there is assistive technology available for people who can't use a mouse or keyboard, it is impossible to design technology that could provide access to all the various ways that mechanical controls can be designed. therefore, the burden to make these controls accessible to people with limited motor function lies with the manufacturer.

Randy Marsden (ATIA) Response

We should be careful not to throw the baby out with the bathwater.

Because AT doesn't exist for certain aspects of physical access, shouldn't preclude us from considering the aspects for which AT does exist (such as keyboard and mouse replacement).

(Randy Marsden - ATIA)