Proposed Report - REV 3 - 3/25/1999

This is a draft of Section 5 of the proposed report. This is an initial draft or working document. This version is posted for comments and input. Please look over carefully for errors and omissions.

5. Proposed Standards

5.1. Introduction

Electronic and Information technology (E&IT) procured by the federal government shall be accessible to and usable by individuals with disabilities. This includes people with visual disabilities (e.g., low vision and blindness), hearing disabilities (e.g., hard of hearing, deafness), people with physical disabilities (e.g., limited strength, reach or manipulation, tremor, speech impairments, lack of sensation), people with language or cognitive disabilities (e.g., reading disabilities, thinking, remembering, sequencing disabilities), and other disabilities (e.g., epilepsy, short stature), and individuals with any combination of these disabling conditions (e.g., deaf-blindness).

These access standards are arranged in two sections

5.2. Generic Standards for Accessibility

5.2.1. Input, control, mechanical and display functions

Equipment shall be able to satisfy the following conditions assessed independently regarding E&IT operation by the user (including location, identification and operation of input, control and mechanical functions) and information display (including text, static or dynamic images, icons, labels, sounds or incidental operating cues):

5.2.1.1. Usable without vision. {Question 1a:}

5.2.1.1.1. Provide at least one mode that does not require user vision. [TAAG]

5.2.1.1.2. Information which is presented visually shall also be available, in at least one mode, in auditory form. [TAAG-LIKE]

5.2.1.1.3. The E&IT should comply with the following provision: ADAAG section 4.4 Protruding Objects {Question 1b}

5.2.1.2. Usable with low vision and limited or no hearing. [Footnote 1]

5.2.1.2.1. Provide at last one mode that permits operation by users with visual acuity between 20/70 and 20/200, without relying on audio output. [TAAG]

5.2.1.2.2. Information which is presented visually shall also be available in a form that does not require user visual acuity better than 20/70, and that does not rely on audio. [TAAG-LIKE]

5.2.1.2.3. On dynamic displays, avoid patterned backgrounds behind text or graphics or allow users to turn that feature off. {Question 2:}

5.2.1.3. Usable with little or no color perception.

5.2.1.3.1. Provide at last one mode that does not require user color perception. [TAAG]

5.2.1.3.2. Information presented will not require color perception.

5.2.1.4. Usable with limited hearing

5.2.1.4.1. Information which is provided in auditory form shall be available in enhanced auditory fashion (i.e., increased amplification, or increased signal-to-noise ratio). {Question 3a, 3b, 3c}

5.2.1.4.2. For transmitted voice signals, provide a gain adjustable up to a minimum of 20 dB. For incremental volume control, provide at least one intermediate step of 12 dB of gain. [TAAG]

5.2.1.4.3. If there is an automatic volume reset then this shall be override-able for non-public, non-shared E&ITs. Where there is an override there needs to be a way to visually determine the volume setting.

5.2.1.5. Usable without hearing.

5.2.1.5.1. Provide at last one mode that does not require user auditory perception. [TAAG]

5.2.1.5.2. Information which is provided in auditory form shall be available in visual form and, where appropriate, in tactile form. [TAAG-LIKE] Display of the visual form should be in synchrony with the audio presentation.

5.2.1.6. Usable with limited manual dexterity, reach and / or strength.

5.2.1.6.1. Provide at last one mode that does not require fine motor control or simultaneous actions. [TAAG]

5.2.1.6.2. Provide at last one mode that is operable with limited reach and strength. [TAAG]

5.2.1.6.3. The E&IT should comply with the following section of the ADAAG: Section 4.27 Controls and Operating Mechanisms

5.2.1.7. Usable without time-dependent controls or displays.

5.2.1.7.1. Provide at last one mode that does not require a response time. Alternatively, a response time may be required if the response time may be by-passed or adjusted by the user over a wide range… [TAAG] …equal to 5 times the average user setting.

5.2.1.7.2. Text which is presented in a moving fashion shall also be available in a static presentation mode at the option of the user. [TAAG-LIKE]

5.2.1.8. Usable without speech.

5.2.1.8.1. Provide at last one mode that does not require user speech. [TAAG]

5.2.1.9. Usable with limited cognitive, language or learning abilities.

5.2.1.9.1. Provide at last one mode that minimizes the cognitive, memory, language, and learning skills required of the user. [TAAG]

5.2.1.10. Availability of audio cutoff.

5.2.1.10.1. Where an E&IT delivers audio output through an external speaker, provide a personal listening device (e.g., phone-like handset or earcup) or provide an industry standard connector for headphones either of which cuts off the speaker(s) when used. [TAAG-LIKE] [Footnote 2]

5.2.2. Personal Compatibility

E&ITs must be compatible with the physical characteristics of individuals with disabilities as well as with those personal assistive technologies which are used to extend or enhance their personal abilities such as hearing aids, cochlear implants, prosthetics and wheelchairs.

5.2.2.1. Prevention of visually-induced seizures.

5.2.2.1.1. Visual displays and indicators shall minimize visual flicker that might induce seizures in people with photosensitive epilepsy. [TAAG] Rates of 3 Hz or lower, or 60 Hz or higher are recommended.

5.2.2.2. Usable with upper extremity prosthetics

5.2.2.2.1. Touchscreens or touch-operated controls should be usable without requiring body contact or close body proximity. [TAAG]

5.2.2.3. Biometric identification / activation bypassing

5.2.2.3.1. Where biometric forms of user identification or activation are used (retinal scanning, iris scanning, voiceprint identification, fingerprint scanning etc.), an alternative form of identification or activation which does not require the user to possess particular biological characteristics, should be provided.

5.2.2.4. Hearing aid coupling

5.2.2.4.1. Where an E&IT delivers output by an audio transducer which is normally held up to the ear, provide a means for effective wireless coupling to hearing aids. [TAAG]

5.2.2.5. Non-interference with hearing technologies

5.2.2.5.1. Reduce interference to hearing technologies (including hearing aids, cochlear implants, and assistive listening devices) to the lowest possible level that allows a user to utilize the E&IT. [TAAG] {Question 4}

5.2.2.6. Usable from a wheelchair or similar personal vehicle

5.2.2.6.1. The E&IT should comply with the following provisions of the ADAAG: Section 4.2 Space Allowance and Reach Ranges; Section 4.3 Accessible Route; Section 4.5 Ground and Floor Surfaces

5.2.3. Compatibility With Peripheral Devices

5.2.3.1. Information Pass Through.

5.2.3.1.1. All E&IT that acts as a transport or conduit for information/communication shall pass through cross-manufacturer, non-proprietary, industry-standard codes, translation protocols, formats or other information necessary to provide the information/communication in an accessible format. In particular, signal compression technologies shall not remove information needed for access or shall restore it upon decompression. [TAAG]

5.2.3.2. External electronic access to all information and control mechanisms.

5.2.3.2.1. Information needed for the operation of E&ITs (including output, alerts, icons, on-line help, and documentation) shall be available in a standard electronic text format on a cross-industry standard port and all input to and control of an E&IT shall allow for real time operation by electronic text input into a cross-industry standard external port and in cross-industry standard format. The cross-industry standard port shall not require manipulation of a connector by the user. [TAAG]

5.2.3.3. Connection point for external audio processing devices.

5.2.3.3.1. E&ITs providing auditory output shall provide the auditory signal at a standard signal level through an industry standard connector. [TAAG] An exception is E&ITs that only provide simple beeps or tones which can all be uniquely identified by visual feedback provided by the E&IT.

5.2.4. Information, Documentation, Labeling & Support

Manufacturers should ensure access to information, documentation, labeling, and support it provides to its customers. Such information and documentation includes user guides, installation guides for end-user installable devices, and E&IT support communications, regarding both the E&IT in general and the accessibility features of the E&IT. Manufacturers should take such steps as necessary, including:

5.2.4.1.1. Providing a description of the accessibility and compatibility features of the E&IT upon request, including, as needed, in alternate accessible formats or alternate accessible modes at no additional charge.

5.2.4.1.2. Providing end-user E&IT documentation in alternate accessible formats or alternate accessible modes upon request at no additional charge.

5.2.4.1.3. Ensuring accessible and usable customer support and technical support in the call centers and service centers (including TTY and voice relay services) which support their E&ITs at no additional charge beyond non-disabled users (including allowances for extra communications time).

5.2.4.1.4. Manufacturers should include in general E&IT information the contact method for obtaining the information required by this section.

5.2.4.1.5. Serial numbers will be available in alternate formats for both hardware E&ITs and software. Registration of E&ITs should be achievable without requirement for visual identification of serial numbers.

5.2.4.1.6. Where training is provided, ensure it accommodates the functional capabilities of all participants. In developing, or incorporating existing training programs, consideration should be given to the following factors: Accessibility needs of individuals with disabilities (as participants or trainers); Means of communicating with individuals with disabilities before and after training; Commonly used adaptive technology used with the manufacturer's E&ITs; Solutions for accessibility and compatibility.

5.3. Conditional Standards.

In addition to the requirements above, the following standards apply to the following E&ITs with the following functions:

5.3.1. If the E&IT has a physical keyboard...

5.3.1.1.1. Keys must be tactilely discernable

5.3.1.1.2. The keyboard delay before repeat must be adjustable to at least 2 seconds. Key repeat rate must be adjustable to 2 seconds per character. [Footnote 3]

5.3.1.1.3. All actions available or required by the program must be available from the keyboard (i.e., keyboard equivalents for all non-keyboard actions or commands).

5.3.1.1.4. The E&IT should provide a logical tab order among interface elements (fields, buttons etc.)

5.3.1.1.5. Assigned keyboard access (e.g., Ctrl+P for Print, Escape for cancel) must be provided for commonly used functions or commands.

5.3.1.1.6. All keyboard access functionality shall be documented with the E&IT and/or follow documented operating system conventions.

5.3.1.1.7. The software intended to be installed on an E&IT shall not interfere with existing accessibility features built into the E&IT or its operating system (e.g., Sticky Keys, Slow Keys, Repeat Keys).

5.3.1.1.8. The status of all locking or latching keys should be tactually or auditorally discernable

5.3.2. If the E&IT is software in nature and runs on a platform that has separate operating system...

5.3.2.1.1. Keyboard Access: (see KEYBOARD, above)

5.3.2.1.2. Provide a well-defined visual focus indicator that moves among interactive interface elements as the input focus changes. This focus indication must be programmatically exposed (read and set) to assistive technology.

5.3.2.1.3. Assistive technology must be able to determine enough information about user interface elements to be able to understand their use (e.g., element is a text box with label "enter password," or a check box which is checked).

5.3.2.1.4. Where an Icon is an image representing an object or the state of an object there must be a way for assistive technology to associate text with icons by, for example, having text next to icons (see the desktop icons in Windows 95) or making text available as text pop-ups, tool-tips, or bubble help. {TEXT MUST BE PROGRAMMATICALLY EXPOSED TO AT?}

5.3.2.1.5. The use of icons shall be consistent throughout the application (e.g., use the same folder icon or the same icon to indicate 'selected' if such is used in several places in the application) {Question 5}.

5.3.2.1.6. Provide text through an API (application programming interface) supporting interaction with assistive technology or use system text drawing tools. The minimum information that must be available to an assistive technology is text content, text input caret location, and text attributes. {Question 6}.

5.3.2.1.7. Provide a wide variety of color and font settings. Inherit and respect system-wide color settings.

5.3.2.1.8. System startup and restart must be accessible without the need for assistive technology.

5.3.3. If the E&IT utilizes Web based information...

5.3.3.1.1. Web content will comply with Priorities 1 and 2 of the latest formally approved version of the Web Content Accessibility Guidelines published by the World-Wide-Web Consortium (W3C).

5.3.3.1.2. Web tools will comply with Priorities 1 and 2 of the latest formally approved version of the Authoring Tools Guidelines of the W3C

5.3.3.1.3. Web user agents will comply with Priorities 1 and 2 of the latest formally approved version of the User Agents Guidelines of the W3C

5.3.3.1.4. Information Production: technologies used for production of information packages or packets should allow for and facilitate the creation of alternative modality formats (visual, audible, tactile and text) if the basic format is not modality independent (e.g., text).

5.3.4. If the E&IT is Telecommunications equipment...

5.3.4.1.1. Compatibility: Telecommunications equipment and customer premises equipment shall be compatible with peripheral devices and specialized customer premises equipment commonly used by individuals with disabilities to achieve accessibility, and shall comply with the following provisions, as applicable:

5.3.4.1.2. TTY connectability: E&ITs which provide a function allowing voice communication and which do not themselves provide a TTY functionality shall provide a standard non-acoustic connection point for TTYs. It shall also be possible for the user to easily turn any microphone on and off to allow the user to intermix speech with TTY use.

5.3.4.1.3. TTY signal compatibility: E&ITs, including those providing voice communication functionality, shall support use of all cross-manufacturer non-proprietary standard signals used by TTYs.

5.3.5. If the E&IT utilizes Multimedia...

5.3.5.1.1. Particular media formats may have one or more solutions for achieving alternate text presentation.

5.3.5.1.2. Analog video must use the "EIA-608 specification" for line-21 closed caption data.

5.3.5.1.3. Digital video formats, as defined by the Advanced Television Systems Committee or ATSC, must use the "EIA-708-A" specification for closed captioning.

5.3.5.1.4. Alternate presentation of visual information: When a piece of media contains visual information essential to understanding its content, the media must also be available with narrative descriptions of visual displays. In the case of analog (NTSC) and digital (ATSC) video, use of accepted technical specifications will assure comprehensive and common access through narrative descriptions. When provided via broadcast cable or satellite, analog video must use the Secondary Audio Program for delivery of narrative descriptions. Digital video formats, including digital broadcast formats defined by the Advanced Television Systems Committee must use the ancillary audio channels as defined in ATSC ancillary audio technical specifications.{Question 7}

5.3.5.1.5. Controls. Display or presentation of alternate text presentation or narrative descriptions should be user-selectable unless permanent.

5.3.5.1.6. If media content is delivered via other hardware devices such as television receivers or kiosks or similar devices, access to controls should be in top-level (opening screen) menus or initial on-screen displays.

5.3.5.1.7. Hardware/Equipment: Analog television displays must be equipped with caption decoder circuitry which receives and properly decodes and displays closed captions according to Federal Communications Commission Part 15 Rules which govern the specifications for television receivers. TV equipment not governed by these rules (e.g. monitors less than 13 inches, or monitors not equipped with built-in tuners and therefore not considered receivers and projection televisions with separate tuners) must be equipped with external closed caption decoders built to the above-named FCC Rules.

5.3.5.1.8. Digital television displays must be equipped with caption decoder circuitry which receives and properly decodes and displays closed captions according to Federal Communications Commission Rules to be established in 1999.

5.3.5.1.9. Analog television displays must be equipped with Secondary Audio Program playback circuitry as defined by the Multi-channel Television Sound specification.

5.3.5.1.10. Digital television displays must be equipped with ancillary audio playback capabilities as defined by the Advanced television Systems Committee.

5.3.5.1.11. Other media delivery hardware and devices (such as integrated or standalone CD-ROMs and DVDs) must be capable of presenting the audio of narrative descriptions via integrated or attached speakers or headphones {Question 8}

5.3.5.1.12. Conversion between formats: Embedded or encoded alternate text presentations (closed captions) and narrative descriptions must be preserved intact when a piece of media is copied, transmitted, reformatted (edited), or transformed for display on subsequent platforms (particularly when digitized from an original analog format). "Preserved intact" includes maintaining all styles and exact timing and synchronization commands and zero introduction of errors or garbling of data.

5.3.6. If the E&IT is an Information Transaction Machine (ITM), Automated Teller Machine (ATM), KIOSK, Point-Of-Sale (POS) Terminal, etc...

5.3.6.1.1. The ITM must be useable without the need of physically attaching a device to it or copying an assistive technology from a user's disk onto it.

5.3.6.1.2. The software must support secure interaction with an external personal device connected to the ITM through wireless means.

5.3.6.1.3. The protocol enabling secure interactions must be based on cross industry, community developed standards.

5.3.6.1.4. The establishing a person's identity and UI display and interaction preferences must be possible and of equivalent ease for people with and without disabilities. Examples of identification methods include cards, smart cards and biometrics. Examples of UI display preferences include magnified content, voice output, and remote access.

5.3.6.1.5. External connection (SEE Compatibility section in Generic Guidelines)

5.3.7. If the E&IT is a PDAs/Thin Client...

{missing a proposal}

5.3.8. If the E&IT has cabling and /or other connections...

5.3.8.1.1. Connection of appropriate cables, mounting and attaching elements of the E&IT both internally inside the E&IT, and externally to other E&ITs such as mounting a hard drive in an available drive bay and connecting it to the mother board, or seating a video card in an available bus slot and connecting an external monitor, the force required to make connections shall be no greater than 5 lbf (22.2 N).

5.3.8.1.2. Cables should be tactilely labeled or keyed for corresponding connections (which are also tactilely labeled).

5.3.8.1.3. Equipment port/cable connection labeling: Port, cable connection will be labeled with icons containing a clear area and size as described in §1193.51 Appendix 4.30.4 .{Question 9}


Footnotes

Footnote 1:

the phrase " with limited or no hearing" was added to the end of the Telecom Guideline here to make it correspond with the actual guideline.

Footnote 2:

Audio Cutoff was rewritten since original appeared to imply that the jack was for the handset or earcup. . Original Telecom guideline read " Where an E&IT delivers audio output through an external speaker, provide an industry standard connector for headphones or personal listening devices (e.g., phone-like handset or earcup) which cuts off the speaker(s) when used."

Footnote 3:

2 seconds should be allowed for situations involving the removal of a hand or pointing device. 5 Seconds should be allowed for the activation of a control.


Questions

Question 1a:

How does this whole item (Usable without vision) apply to web pages? Software? Do the more specific guidelines below override this one? (not usually the way it works with generic and specific - or is it?)

Question 1b:

Keep this in?

Question 2:

Is this too restrictive? There are two parts to this.

  1. This is a problem on dynamic displays where there is a screen reader (where displaying the background text can make the text disappear to the screen reader even if it is visual. This is also a problem if the background pattern interferes with low vision viewing of foreground text.
  2. However, this is very common, and is not a problem with printed material (or displayed materials) if there is no screen reader and the background is very light compared to dark clear foreground text.

This item only talks about dynamic displays. But should there be something said about print materials? How do we separate situations where there is a problem from those where there are not. Leave this unspecified and leave it up to individual assesment?

Question 3a:

Does providing better signal to noise ratio mean that you can ignore volume? The "or" seems to imply that.

Question 3b:

Is volume control only needed if there is voice? Do "beeps" need a volume adjustment?

Question 3c:

Should we be specifying a gain? Or Absolute output level? Or both?

Question 4:

Should this reflect the current work and / or the need for hearing aid manufacturers to participate in solution?

Question 5:

Is this too restrictive. While it is often good to have consistency, (for cognitive and screen reader reasons) there are also times when it can be better to not use exactly the same icon everywhere - even for a similar function. Requiring this would cut off this option.

Question 6:

How about activation information??

Question 7:

Doesn't this exclude any use of second languages on TV?

Question 8:

Should VCRs, Tuners, Tape Players etc be also covered in this section??.

Question 9:

Is this even possible on small E&ITs?


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