Telecommunications Access Advisory Committee (TAAC)
Final Report
January 1997
1.1. CHARGE AND RESPONSIBILITIES OF THE
TELECOMMUNICATIONS ACCESS ADVISORY COMMITTEE
1.2. PURPOSE
1.3. GUIDING PRINCIPLES
2.0 HISTORY OF TELECOMMUNICATIONS ACCESS FOR INDIVIDUALS WITH DISABILITIES
4.10.1. Point of Contact
4.10.2. Response Time
4.10.3. Information Provided
5.2.1. Accessible To and Usable By Individuals with Disabilities,
Where Readily Achievable.
5.2.2. Compatible with Existing Peripheral Devices or SCPE Used by Individuals
with Disabilities, Where Readily Achievable.
5.3.1. Input, Control and Mechanicals
5.3.2. Output, Displays and Feedback.
5.3.3. Documentation
5.3.4. Compatibility Guidelines
6.0 COMPLIANCE AND COORDINATION
6.1. COMPLIANCE AND COORDINATION OVERVIEW
6.2. ACCESS BOARD GUIDELINES
6.2.1. Reauthorization of Guidelines
6.3.1. Development of Standards
6.3.2. Refreshment of Standards
6.3.3. Coordination of Standards
6.3.4. International Harmonization
6.4.1. Establishment of Coordination Point.
6.4.2. Participation of Individuals with Disabilities
6.4.3. Access Engineering Specialist Training
6.4.4. Disability Representatives Training
6.4.5. Access Specialist Certification
6.4.6. Presentation of Access Needs and Strategies
6.4.7. Input into Guidelines
6.4.8. Input into Standards
6.4.9. Industry/Disability Advisory Panel to the FCC
6.4.10. Research
6.4.11. Recognition for Access Innovation
6.5.1. Verification of Accessibility, Usability, and Compatibility
6.5.2. Use of Qualified Access Specialists
6.5.3. Documentation
6.5.4. Certification of Access Testing Laboratories
6.6. DECLARATION OF CONFORMITY
6.6.1. Issuing Declaration of Conformity
6.6.2. Location of Declaration of Conformity
6.6.3. Contents of Declaration of Conformity
6.6.4. Text of Declaration of Conformity
6.7.1. Manufacturer’s Point of Contact
6.7.2. Consumer Information
6.7.3. FCC Point of Contact
6.7.4. FCC Review of Complaints
6.7.5. FCC Discretionary Use of Industry/Disability Advisory Panel
6.7.6. FCC Selection of Measures in Instances of Non-Compliance
6.7.7. Collection of Data
6.8.1. Access Board Production of Annual Report
6.8.2. Contents of the Report
6.8.3. Availability of Report
6.8.4. Actions Triggered by Report
This report contains recommendations of the Telecommunications Access Advisory Committee (TAAC or Committee) to the Architectural and Transportation Barriers Compliance Board (Access Board). The TAAC was convened by the Access Board in June 1996 to assist the Board in fulfilling its mandate under the Communications Act of 1934 as amended by the Telecommunications Act of 1996, Section 255 (hereinafter referred to simply as section 255). Section 255 requires that the Access Board, in conjunction with the Federal Communications Commission (FCC or Commission), develop guidelines, by August 8, 1997, for access to telecommunications equipment and customer premises equipment (CPE) by individuals with disabilities. Portions of section 255 which are relevant to the charge of the TAAC read as follows:
(b) MANUFACTURING -- A manufacturer of telecommunications equipment or customer premises equipment shall ensure that the equipment is designed, developed, and fabricated to be accessible to and usable by individuals with disabilities, if readily achievable.
...
(d) COMPATIBILITY -- Whenever the requirements of subsections (b) ... are not readily achievable, such a manufacturer ... shall ensure that the equipment ... is compatible with existing peripheral devices or specialized customer premises equipment commonly used by individuals with disabilities to achieve access, if readily achievable.
(e) GUIDELINES -- Within 18 months after the date of enactment of the Telecommunications Act of 1996, the Architectural and Transportation Barriers Compliance Board shall develop guidelines for accessibility of telecommunications equipment and customer premises equipment in conjunction with the Commission. The Board shall review and update the guidelines periodically.
In selecting members of the TAAC, the Access Board sought to ensure representation of the various interests affected by the promulgation of accessibility guidelines. Committee members represented organizations advocating for the access needs of individuals with disabilities, manufacturers of telecommunications equipment and customer premises equipment, manufacturers of specialized customer premises equipment, manufacturers of software, and telecommunications service providers. Between June 1996 and January 1997, the Committee held six meetings, each of three working days in length, during which members worked to develop recommendations for implementing section 255's requirements. This report contains those recommendations, and is intended to guide the Access Board in the final preparation of the section 255 guidelines. The Committee hopes that the diligent efforts to achieve consensus among the various interests represented on the TAAC have laid the groundwork for future cooperative efforts in the implementation of section 255.
In preparing the recommendations contained in this report, the Committee recognized that evolving telecommunications technologies often make it difficult to distinguish whether a product’s functions and interfaces are the result of the design of the product itself, or are the result of a service provider’s software or even an information service format. It was the intent of this Committee to recommend steps to ensure that telecommunications equipment and CPE are accessible to and usable by individuals. The recommended guidelines do not differentiate between hardware and software implementations of a product’s functions or features, nor is any distinction made between functions or features built into the product and those that may be provided from a remote server over the network.
This report is divided into six sections:
Section 1: "Overview," describes the mandates and charges of the Access Board, the FCC, and the TAAC, as well as eight guiding principles created by the Committee to assist in the development of accessibility guidelines.
Section 2: "History of Telecommunications Access for Individuals with Disabilities," provides historical information on legislation and manufacturing practices impacting telecommunications access for individuals with disabilities.
Section 3: "Definitions," sets forth definitions and terminology which are utilized throughout the TAAC Report.
Section 4: "Process Guidelines," sets forth proposed processes for manufacturers to follow in designing and developing accessible equipment.
Section 5: "Performance Guidelines," provides examples of how to make telecommunications equipment accessible. This section, along with Appendix C, will be updated on a regular basis, and is intended to provide engineers and product developers with a sense of what persons with disabilities need in order to effectively access and use telecommunications equipment and CPE.
Section 6: "Compliance and Coordination Guidelines," outlines a process for ensuring compliance with the accessibility guidelines and establishes mechanisms for coordination between industry and people with disabilities.
The provisions of section 255 reflect Congress’ recognition that individuals with disabilities need improved access to telecommunications technology. Congress placed an obligation on manufacturers to consider accessibility when designing, developing, and fabricating telecommunications equipment and CPE. Among other things, these recommendations set forth factors to be considered throughout these processes to achieve accessibility. Because the pace of technological change is so rapid, it is expected that many aspects of accessibility which are not readily achievable today may become readily achievable in the future. Manufacturers need to remain current in their assessment of whether it is readily achievable to make their products accessible by seeking out information on how to incorporate access into those products.
An important approach in designing accessible products is called universal design. This is the practice of designing products so that they are usable by the broadest possible audience. Products designed in this way are usable by more people without reducing the usability or attractiveness for mass or core audiences of the product. With universal design, the goal is to ensure maximum flexibility, benefits, and ease of use for as many individuals as possible. In the past, some products or designs developed with universal design principles have attracted a wider audience than may have otherwise been attracted by the product. For example, curbcuts, originally designed to ensure wheelchair access, are routinely used by parents with strollers, bicyclists, and delivery personnel. Similarly, closed captioning on television programming, created for the benefit of individuals who are deaf or hard or hearing, is frequently used in airports, restaurants, and other noisy locations where it is difficult to hear the audio portion of the programming. Finally, an audio adjunct to caller ID not only enables individuals who are blind to learn the identity of a caller, but enables family members eating dinner to identify callers without leaving the dinner table. The TAAC encourages the use of universal design in the manufacture of telecommunications equipment and CPE.
In developing the final accessibility guidelines required by section 255, the TAAC recommends that the Access Board adhere to the following eight principles:
This section contains a brief overview of historical developments affecting telecommunications for individuals with disabilities. It is intended that this section will provide a framework for the development of the TAAC recommendations contained in this report.
In order to understand the recommendations of this report, it is important to first consider some barriers individuals with disabilities have encountered in accessing telecommunications as well as some actions the telecommunications industry has taken to make telecommunications equipment accessible prior to the enactment of the Telecommunications Act of 1996.
Access to telecommunications has been of great concern to people with disabilities since the invention of the telephone. Initial advocacy efforts came from people who are deaf and hard of hearing. In the mid-1960s, a fundamental barrier -- the lack of a visual alternative to voice communication by people who are deaf -- began to fall with the invention of an acoustic coupler that allowed teletypewriter signals to be sent and received through the telephone network. AT&T and others donated teletypewriters and a volunteer organization of telecommunications workers, the Telephone Pioneers, worked with the deaf community to assist in bringing this technology to those who needed it. This demonstrated how industry and persons with disabilities can work together, given the opportunity.
Since the early 1970s, several telecommunications companies have initiated and supported the development of a number of access technologies. The application of Baudot technology (both TTY hardware and the protocol) to text terminals for deaf, hard of hearing, and speech disabled users, and its dissemination, was a principal focus of their efforts in this area. In addition to general initiatives, some of these companies provided case-by-case custom support for telecommunications functions for people with disabilities, including special assemblies, such as on-hook/off-hook switches that could be controlled by light touch, puff and sip, and electronic environmental controls. These products enabled many persons with disabilities to live more independently. The Telephone Pioneers published and distributed the first compendium of telecommunications accessibility tools known as the "Green Book."
In the late 1970s, consumers began to take their concerns to state utility commissions and legislatures. The state of California took the lead by assessing a line charge to finance the lending of TTYs. This program was later extended to other specialized customer premises equipment used by people who are hard of hearing as well as those with speech disabilities, and those experiencing other problems with telephone access.
In the 1980s, a number of telecommunications companies began efforts to maximize access for persons with disabilities. First, they participated in state equipment distribution programs for people with disabilities. Second, many companies participated in the initial efforts to establish telecommunications relay services (TRS). Finally, several companies initiated research in speech recognition technology that would offer new input and output opportunities for people who had speech, vision, and physical limitations.
The hearing aid compatibility standard grew out of a characteristic of older telephone receivers. These receivers leaked magnetic signals that could be picked up by a small coil in the hearing aid. This eliminated acoustic background noise and thus improved audibility of speech. When manufacturers switched to newer, more efficient receiver designs, the inductive coupling was no longer possible. This spurred a decade-long advocacy effort to achieve hearing aid compatibility in all telephones, and which resulted in the development of the EIA Standard RS-504, first issued in 1982, which established formal criteria defining the magnetic field intensity from a telephone receiver, and the Hearing Aid Compatibility Act of 1988. (The details of the HAC Act are discussed in the legislative history section of this report.)
In general, solutions to telecommunications barriers had focused primarily on adaptations to inaccessible equipment and the provision of specialized customer premises equipment. Lately, some service providers and manufacturers have become aware that solutions to barriers for individuals with disabilities are sometimes of benefit to a wider range of customers as well. For example, the vibrating pager is accessible to deaf persons but it also means the pager won’t interrupt an important business meeting. The voice-activated telephone dialer can be used by someone with limited use of her hands as well as a driver who wants to place a call on her cellular phone without taking her eyes off the road. The voice-output Caller ID device is usable by a blind person and, at the same time, allows identification of the caller without having to leave the dinner table to see the device. These and similar designs are examples of the application of universal design principles: that is, incorporating features in the product itself to make it more usable by a wider audience.
By the 1980s, telecommunications and customer premises equipment had become much more diverse. Some of the new technologies improved accessibility and offered new functionality. With the diversity, however, came a new array of access problems. For example, the proliferation of facsimile created a new barrier to people with low vision or blindness. At the same time, ongoing problems with access to the voice network led deaf individuals to advocate for telephone relay service in their states and ultimately nationwide, through Title IV of the ADA.
As the convergence of telephone, computers, and television technologies began to escalate in the late 1980s and early 1990s, individuals with disabilities began to realize both the tremendous potential of technology and the potential for setbacks in accessibility. Of particular concern was the impact of these technologies on employment and participation in the mainstream of technology. For example, the marriage of computers and networks brought the graphical user interface, an inaccessible interface for people who are blind, into the world of telecommunications, extending its importance as a tool in the workplace.
As a result, consumers with different types of disabilities focused on telecommunications advocacy, with the goal of ensuring that telecommunications and customer premises equipment would be as accessible as possible.
Developing accessibility guidelines for the new generation of telecommunications and customer premises equipment poses a series of issues for both the industry and individuals with disabilities. For example, with the rapid pace of technological innovation within the telecommunications industry, individuals with disabilities are concerned that new technologies be accessible so that they can compete in the workplace. Moreover, as technology becomes commonplace in the American lifestyle, individuals with disabilities need to know if they will be able to use such equipment, or if it will be useable with specialized customer premises equipment. Also, how will individuals with disabilities know if a particular piece of equipment meets their needs? These issues are discussed in this report.
The telecommunications industry also has concerns with the implementation of section 255. A key issue for industry is how the criteria of readily achievable can be applied to telecommunications of equipment accessibility. Industry is also concerned with how to develop accessible products without discouraging innovation and thus putting them at a competitive disadvantage within the marketplace. Finally, there is a concern about what will happen if industry can make a given product accessible to some, but not all disabilities. These and other issues became the focus of discussions of the Telecommunications Access Advisory Committee.
Prior to the 1980s, little had been done by state or federal legislatures to address the needs of individuals with disabilities to utilize telecommunications equipment. Starting in the early 1980s, some states developed programs for the provision of telecommunications relay services and the distribution of specialized customer premises equipment, such as text telephones (TTYs), telebraille machines, and artificial larynxes. Relay services enable persons who are speech or hearing disabled and who use TTYs to communicate by telephone with persons who use conventional voice telephones via a third party called a communications assistant. For the most part, these state relay and distribution programs could not meet all of the demands for telecommunications services or equipment by individuals with disabilities.
The first important step in the development of a national telecommunications policy for persons with disabilities was the Telecommunications for the Disabled Act of 1982. This law expressly allowed states to require carriers to continue providing subsidies for specialized equipment needed by persons with impaired hearing, speech, vision, or mobility. The 1982 Act also set forth requirements for certain telephones to be compatible with hearing aids. This new law made clear that compatibility between telephones and hearing aids was necessary to accommodate the needs of some persons with hearing loss. In this law, for the first time Congress recognized the FCC’s obligation to ensure that individuals with disabilities "have access to the universal telephone network." H. Rep. No. 888 (97th Congress, 2d Session. 1982) 4. The House Report explained:
"Persons with normal hearing may be unable fully to appreciate the pervasiveness of the telephone both in commercial transactions and personal contacts. The inability to use this instrument, except through an interpreter, is not only a practical disability but a constant source of dependency and personal frustration. Conversely, the ability independently to use the telephone may enable persons with other severe handicaps ... to lead self-sufficient lives in regular contact with society. The Committee believes that making the benefits of the technological revolution in telecommunications available to all Americans, including those with disabilities, should be a priority of our national telecommunications policy." (Id. at 4-5).
In 1986, Congress continued to recognize the importance of providing access to information technology when, in Section 508 of the 1986 Amendments to the Rehabilitation Act, Congress directed federal government agencies to limit their purchases to information technology that is accessible or could support accessibility. In 1988, Congress took an additional step in recognition of the crucial role that access to technology plays in the lives of individuals with disabilities, with the Technology Related Assistance for Individuals with Disabilities Act. Title I of that Act provides federal funding for grants to states to increase access to assistive technology and accessible information technology.
In 1988, Congress also passed the Hearing Aid Compatibility Act (HAC Act). The HAC Act required that all landline telephones (with the exception of secure telephones) made in or imported into the United States after a certain date (August 1989, with the exception of cordless telephones, which were given an extension until August 1991) must be hearing aid compatible. In 1988, Congress also passed the Telecommunications Access Enhancement Act. This legislation established an expanded federal relay services for calls to, from, and within the federal government, and was designed to improve telecommunications access for persons who use TTYs.
In July of 1990, the Americans with Disabilities Act (ADA) was signed into law. The ADA was the first comprehensive civil rights law to prohibit discrimination against persons with disabilities in employment, state and local government programs, places of public accommodation, transportation, and telecommunications. Title IV of the ADA mandated the establishment of a nationwide telecommunications relay service (TRS) by July 26, 1993. The ADA’s requirement for TRS has begun to open the world of telecommunications to individuals with hearing and speech disabilities. Titles I, II, and III have also impacted somewhat on telecommunications access by individuals with disabilities. Although these sections do not impose any requirements for the development of accessible telecommunications products and services, they do require employers, state and local governments, and places of public accommodation, respectively, to provide auxiliary aids and services, which may include accessible telecommunications products and services, to achieve effective communication by individuals with disabilities. Finally, the ADA Accessibility Guidelines (ADAAG), promulgated by the Access Board, require certain telephones covered by the ADA to be physically accessible, hearing aid compatible, and have volume control. These guidelines also require TTYs to be provided at certain public pay phone locations. Notwithstanding these various mandates for telecommunications access under the ADA, nothing in the ADA requires the manufacture of telecommunications products that are accessible. Among other things, section 255 of the Communications Act (as amended) is intended to fill this gap.
In October of 1990, Congress went on to enact the Television Decoder Circuitry Act. This law now requires television sets with screens 13 inches or larger, manufactured or imported into the United States, to be equipped with a computer chip which decodes closed captioning on television programs. Decoder equipped televisions enable persons who are deaf or hard of hearing to receive caption output with regular television programming where captioning is otherwise incorporated into the programming. A new Section 713 of the Communications Act, added by the 1996 Act, further expands such television access by applying new requirements for captioning on new and previously published video programming.
The Telecommunications Act of 1996 follows this long history of legislative efforts to improve telecommunications access for individuals with disabilities. In addition to mandating access to telecommunications equipment and customer premises equipment, section 255 of this Act mandates access to telecommunications services. The FCC is charged with enforcing section 255, and is expected to initiate further proceedings.
In order to meet its responsibilities under section 255(e) of the Telecommunications Act, the Access Board chartered the Telecommunications Access Advisory Committee, under the Federal Advisory Committee Act. The purpose of this Advisory Committee was to bring together members of the telecommunications industry, manufacturers of telecommunications equipment and customer premises equipment, and persons with disabilities to provide the Access Board with recommendations on what the accessibility guidelines should address.
On March 28, 1996, the Access Board published a notice of intent to establish an advisory committee to make recommendations to the Access Board on accessibility guidelines for telecommunications equipment and customer premises equipment. (See Appendix D) The notice requested nominations for membership on the Committee from manufacturers of telecommunications equipment and customer premises equipment; manufacturers and developers of peripheral devices or specialized customer premises equipment commonly used by individuals with disabilities to achieve access; organizations representing the access needs of individuals with disabilities affecting hearing, vision, movement, manipulation, speech, and interpretation of information; telecommunications providers and carriers; developers of telecommunications software; and other persons affected by the accessibility guidelines.
Over 60 nominations were submitted. From this group, the Board selected 33 organizations. (See Appendix D) Of this original group, three organizations did not send a representative and one organization withdrew midway through the process. Once established, the Committee accepted the applications of four additional members to achieve better representation of the interests in this proceeding.
Strategies -- state precisely how a design feature should be implemented. Illustrative examples might include:
Performance Guidelines -- are guidelines which state what should be achieved but do not specify how it would be achieved. Illustrative examples might include:
Process Guidelines -- are guidelines that specify the process that a company should use in designing and bringing a product to market as well as post introduction processes. Illustrative examples might include:
Compliance Guidelines -- are guidelines that specify the steps a manufacturer should take to demonstrate that it has met the guidelines. Illustrative examples might include:
The meaning of terms not specifically defined in this document shall be as defined by collegiate dictionaries in the sense that the context implies.
Accessible -- Means that a person with a disability can use the equipment to perform the same tasks, access the same information, with the same ease, in the same time and at the same cost as a person using the equipment without a disability, and that the person can use the product in its standard manufactured and shipped form without having to modify the product or to purchase special technologies.
Alternate Formats, Alternate Methods -- Alternate formats and alternate methods may include, but are not limited to: voice, FAX, TRS (relay service), Internet posting, closed captioning, audiotext, audio-cassette recording, audio-description, Braille, ASCII text, and large print.
Communications Act -- The Communications Act of 1934 [47 U.S.C.] was amended by the Telecommunications Act of 1996, which added a number of sections, including section 255 (see Appendix B).
Compatible -- Means that the telecommunications or customer premises equipment is designed so that it can be used with, does not interfere with, and, where applicable, can be connected to existing peripheral devices or specialized customer premises equipment commonly used by individuals with disabilities to achieve access.
Customer Premises Equipment (CPE) -- The term ‘customer premises equipment’ means equipment employed on the premises of a person (other than a carrier) to originate, route, or terminate telecommunications. (47 U.S.C. 153)
Comment -- The TAAC members agree that the statutory definitions for "telecommunications equipment" and "customer premises equipment" are meant to be interpreted broadly to include a wide array of electronic products which provide telecommunications, including personal computers. Because electronic products are largely software driven, the TAAC concludes that the definition of telecommunications equipment and customer premises equipment includes the software which provides telecommunications functions.
Customer Premises User Interface (CPUI) -- the interface which the user must interact with when using CPE for telecommunications.
Disability -- The term ‘disability’ has the meaning given to it by section 3(2)(A) of the Americans with Disabilities Act of 1990 (42 U.S.C. 12102(2)(A)). [47 U.S.C. 255(a)(1)]
As Defined in the ADA -- "The term ‘disability’ means, with respect to an individual - (a) a physical or mental impairment that substantially limits one or more of the major life activities of such individual; (b) a record of such an impairment; or (c) being regarded as having such an impairment." [42 U.S.C. 12102(2)(A)]
The TAAC report reflects the intent of Congress as noted in the following language from the Senate Committee Report on the Telecommunications Act of 1996: "The [Senate] Committee intends the definition of disability to principally cover individuals with functional limitations of hearing, vision, movement, manipulation, speech, or interpretation of information ...."
Manufacturer -- Denotes a manufacturer of telecommunications equipment and/or customer premises equipment (CPE). Specifically included are manufacturers of the customer premises user interface for telecommunications and/or customer premises equipment, including software which provides the interface.
Readily Achievable -- The term ‘readily achievable’ has the meaning given to it by section 301(9) of the Americans with Disabilities Act (42 U.S.C. 12181(9)). [47 U.S.C. 255(a)(2)]
As Defined in the ADA, Section 301(9) -- "The term ‘readily achievable’ means easily accomplishable and able to be carried out without much difficulty or expense. In determining whether an action is readily achievable, factors to be considered include:
(A) the nature and cost of the action needed under this Act;
(B) the overall financial resources of the facility or facilities involved in the action; the number of persons employed at such facility; the effect on expenses and resources, or the impact otherwise of such action upon the operation of the facility;
(C) the overall financial resources of the covered entity; the overall size of the business of a covered entity with respect to the number of its employees; the number, type, and location of its facilities; and
(D) the type of operation or operations of the covered entity, including the composition, structure, and functions of the workforce of such entity; the geographic separateness, administrative or fiscal relationship of the facility or facilities in question to the covered entity." [42 U.S.C. 12181(9)]
Comment --The TAAC interprets the application of the readily achievable criteria in the 1996 Act to be somewhat different from the use of "readily achievable" in the Americans with Disabilities Act. The ADA’s use of "readily achievable" applies to retrofitting of buildings, and is used to determine the proportion of effort to be expended in providing architectural accessibility. The 1996 Telecommunication Act’s use of the term applies to the design, development and fabrication of telecommunications equipment and customer premises equipment. The TAAC’s recommended guidelines provide more information on how readily achievable should be implemented in practice.
Several factors are important in the determination of whether certain accessibility features are readily achievable. They include the size of the manufacturer and the amount of effort required to implement accessibility and marketability of the resulting product. For instance, implementing certain accessibility features is not readily achievable if doing so would drive the manufacturer out of business, require efforts far exceeding those involved in designing the product without the access features or render the product unmarketable. Implementing certain accessibility features is readily achievable if the cost to do so is small relative to the cost of the entire production design effort, adds little or nothing to the manufacturing and distribution costs, and has minimal or positive impact on the product’s marketability. The Design Process portion of this report will assist in moving these two extremes closer to each other.
Telecommunications -- The term ‘telecommunications’ means the transmission, between or among points specified by the user, of information of the user’s choosing, without change in the form or content of the information as sent and received. [47 U.S.C. 153]
Comment -- A change in information format (e.g., text to Braille or text to speech) to provide access is not a "change in the form or content" excluded under the definition of telecommunications.
Telecommunications Act -- The Telecommunications Act of 1996 amended the Communications Act of 1934 and added several sections including section 255.
Telecommunications Equipment -- The term ‘telecommunications equipment’ means equipment, other than customer premise equipment, used by a carrier to provide telecommunications services and includes software integral to such equipment (including upgrades). [47 U.S.C. 153]
Telecommunications Service -- The term ‘telecommunications service’ means the offering of telecommunications for a fee directly to the public, or to such classes of users as to be effectively available directly to the public, regardless of the facilities used. [47 U.S.C. 153]
Text Telephone (TTY) -- Machinery or equipment that employs interactive graphic (i.e., typed) communications through the transmission of coded signals across the standard telecommunications network. Text telephones can include, for example, devices known as TDDs (telecommunication display devices or telecommunication devices for deaf persons) or computers.
Usable -- The term ‘usable’ means the telecommunications equipment or CPE can be effectively used by individuals with disabilities, including, but not limited to, the availability of instructions, accessible feature information, documentation, technical support and delivery in alternate formats or through alternate methods.
The guidelines that follow address the process of designing for accessibility rather than the performance of accessible devices. The processes used by a manufacturer to design, develop, fabricate and deliver telecommunications or customer premises equipment, and to make decisions related to the design, development, fabrication and delivery of their products are unique to that manufacturer. The intent of the guidelines in this section is to identify elements the TAAC expects to make up processes for achieving accessibility and usability for individuals with disabilities. Manufacturers would decide how each element may be integrated into their individual process.
Each guideline consists of a basic statement about the element. The basic statement may be accompanied by additional statements about particular aspects of that element, a rationale, and/or a list of examples or situations in which the guideline would apply.
Section 255 requires that manufacturers provide access to telecommunications equipment and customer premises equipment where readily achievable. Accessibility is easier to achieve if considered at the beginning of and throughout the design process. Manufacturers shall consider access to telecommunications by individuals with disabilities throughout product design, development, fabrication and delivery, as early and consistently as possible.
Periodically, manufacturers change, upgrade, or distribute new releases of existing products. Whenever they do so, manufacturers are expected to consider accessibility features, and incorporate those features into existing products when readily achievable. Minor or insubstantial changes such as cosmetic changes, or cost-reduction measures, that do not affect functionality, need not trigger accessibility reviews.
Manufacturers are expected to address the needs of individuals with disabilities in their market research and this research should be comparable to other market research efforts. Examples of primary market research may include targeted recruitment of individuals with disabilities, surveys conducted in an accessible manner and separate or integrated focus groups. Examples of secondary market research may include cooperative studies or research, as well as general access related research and product specific studies.
INDUSTRY NOTE: The clause "... and this research should be comparable to other market research efforts" is subject to a variety of interpretations. In the interest of preventing future misunderstandings, Committee members representing manufacturers and their trade associations submit the following as their opinion about the interpretation of this clause: "This clause should not mean that, when conducting market research related to products for general distribution, manufacturers are expected to duplicate their market research expenditures in order to conduct additional market research related to the use of products for general distribution by individuals with disabilities. Rather, with respect to market research studies, it should mean that manufacturers are expected to: (a) recognize that individuals with disabilities are among the potential customers whose desire to purchase and use products is being studied and (b) treat the population of individuals with disabilities in a manner substantially similar to its treatment of other groups of potential customers. Accordingly, inclusion of individuals with disabilities in market research related to products for general distribution would satisfy both this section and section 4.7."
Information about products and their accessibility or compatibility features should be available to and usable by individuals with disabilities. Examples of such communications include broadcast and print media advertising, product brochures, collateral publicity, internet sites or other media. Such information needs to be available to consumers contemplating the purchase of a device, or to end users of CPE.
Steps which manufacturers should consider in addressing this need for accessible information include:
Individuals with disabilities need to be able to go through the steps of ordering, billing, and interacting with customer service representatives. Steps that can be taken by manufacturers to meet this need include making customer service processes available through alternate formats and alternate methods, upon request.
Individuals with disabilities require access to documentation (e.g., user guides, installation guides for end-user installable devices) and product support communications, regarding both the product in general and specifically the accessibility features of the product. Steps that shall be taken by manufacturers that will assist individuals with disabilities to meet these needs include:
Other steps that can be taken include but are not limited to:
Consultation with end users and end-user testing are important in achieving a product that meets the design goals. To achieve a product that is accessible to and usable by individuals with disabilities, the needs of individuals with disabilities should be considered as early as possible during the development of the product concept, and at appropriate stages during product design, development, fabrication and delivery. Manufacturers should consult with individuals with disabilities regarding the accessibility of the product, as needed, to achieve accessibility and usability. Some methods that may be used to achieve this are:
Manufacturers shall consider accessibility and usability of their products for individuals with disabilities. To this end, manufacturers are expected to identify potential or actual barriers to accessibility and usability as part of the product development process. When accessibility is not readily achievable, manufacturers shall design products compatible with existing peripheral devices and/or specialized customer premises equipment, if readily achievable.
Manufacturers should actively seek to stay current in their accessibility designs. Manufacturers should also provide employees (engineers, product managers, service representatives, etc.) with periodic training regarding the requirements of section 255 directly relevant to that employee’s function. Where appropriate to an employee’s function, such training should include:
It is strongly encouraged that training programs include input from the disability community and representative agencies.
A manufacturer shall establish and maintain a point of contact to assist customers regarding access features. Wherever possible, the point of contact should include a voice telephone number, TTY number, e-mail address, fax number, and postal address for consumer inquiries regarding the accessibility of their products. Manufacturers shall publish this contact information in product literature.
Manufacturers should advise all individuals who make informational inquiries with the point of contact that they can expect a response to their inquiry within fourteen (14) calendar days.
A manufacturer’s response to an inquiry should be made promptly, and should include information on accessibility features, compatibility standards that are supported by the product, and commonly used compatibility options available through adaptive devices, as needed to guide the individual to the best access provisions available. Should the individual require further assistance, the manufacturer should give the individual information on how to contact the Access Board for further help.
Manufacturers shall promptly provide to consumers, upon request, a disability access statement explaining the accessibility and compatibility features of a product. This statement shall be provided in alternate formats as needed. Such a statement should include:
Manufacturers of SCPE and manufacturers of telecommunications equipment and CPE should coordinate (for instance, through voluntary standards setting) to ensure compatibility between SCPE and telecommunications equipment and CPE.
Rationale: Compatibility should be readily achievable more frequently if SCPE, CPE, and telecommunications equipment manufacturers collaborate to minimize overall effort and expense. SCPE, CPE and telecommunications equipment manufacturers could develop voluntary interface standards that would help to reduce the number of different interfaces and the conflicting interface technologies which otherwise would proliferate.
These guidelines provide objectives for product performance which will assist manufacturers in designing, developing and fabricating telecommunications and customer premises equipment to be more accessible to and usable by individuals with disabilities. In addition, these performance guidelines should encourage the use and further development of design practices intended to make products more usable by people with a wide range of disabilities.
Appendix C provides examples of strategies for addressing these guidelines.
Level 1 guidelines are intended to help define the overall goals that a company should try to achieve in the design of its products. They give no guidance as to how to achieve the goals but help to define what is meant by "access to the widest range of people."
General Guideline A: Where readily achievable, products shall be designed, developed and fabricated to 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). Older individuals in particular commonly have multiple functional limitations.
(Note: The list above is illustrative of the range of disabling conditions of approximately 10-20% of the U.S. population, but is not an exhaustive list of every type and combination of disability. Also, there are many people who do not have disabilities who also fit the above descriptions and would benefit -- for example, someone who cannot read, someone who has broken his/her arm, people who must work with gloves on, etc.)
Since there is no single interface design that accommodates all disabilities, accessibility is likely to be accomplished through product designs which emphasize interface flexibility to maximize user configurability and multiple, alternative and redundant modalities of input and output.
General Guideline B: Whenever it is not readily achievable
to make a product accessible to and usable by individuals with disabilities,
the product shall be compatible with existing peripheral devices or specialized
customer premises equipment commonly used by individuals with disabilities
to achieve access, if readily achievable.
Section 255 requires that manufacturers ensure the usability as well
as the accessibility and/or compatibility of products, if readily achievable.
It is understood that there will be cases where manufacturers may not be
able to achieve the creation of a single product that addresses accessibility
for all or some combinations of disabilities without sacrificing product
usability. Therefore, there will be cases where a company will have to
use discretion in choosing among accessibility features. In this situation,
manufacturers should consider incorporating in another comparable product,
the access feature or features not addressed. A manufacturer may not ignore
consideration of the needs of any covered group of individuals with disabilities
when determining what accessibility features the product should address.
Guideline: Where readily achievable, product input, control and mechanical functions shall be fully operable via at least one mode whose components are locatable, identifiable, and accurately operable without requiring the user to see.
Rationale: Individuals with severe visual disabilities or blindness cannot locate or identify controls, latches, input slits etc. by sight or operate controls that require sight.
Guideline: Where readily achievable, the product input, control and mechanical functions shall be fully operable via at least one mode by individuals who have low vision but are not legally blind, which does not rely on audio output.
Note: 20/70 after correction is the beginning of low vision; 20/200 after correction is the beginning of legal blindness; a field of vision of less than 20 degrees after correction also constitutes legal blindness.
Rationale: Individuals with severe visual disabilities often also have severe hearing disabilities (especially older users) and cannot rely on audio access modes commonly used by those who are blind.
Guideline: Where readily achievable, product input, control, mechanical and display functions shall be fully operable via at least one mode that does not require color perception.
Rationale: Many people have an inability to see or distinguish between certain color combinations. Others are unable to see color at all.
Guideline: Where readily achievable, product input, control and mechanical functions shall be fully operable via at least one mode whose components are locatable, identifiable, and accurately operable without requiring the user to hear.
Rationale: Individuals who are hard of hearing or deaf cannot locate or identify those controls that require hearing.
Guideline: Where readily achievable, product input, control and mechanical functions shall be fully operable via at least one mode that does not require fine motor control or simultaneous actions.
Rationale: Individuals with tremor, cerebral palsy, paralyses, arthritis, artificial hands, and other conditions may have difficulty operating systems which require fine motor control, assume a steady hand, or require two hands or fingers for operation.
Guideline: Where readily achievable, product input, control and mechanical functions shall be fully operable via at least one mode that is operable with limited reach or strength.
Rationale: Individuals with spinal cord injuries, ALS, arthritis, MS, MD and other conditions may have difficulty operating systems which require reach or strength.
Guideline: Where readily achievable, product input, control and mechanical functions shall be fully operable via at least one mode that does not require a response within a period of time, or where the response time is adjustable over a wide range.
Rationale: Individuals with physical, sensory and cognitive disabilities may not be able to find, read and operate a control quickly.
Guideline: Where readily achievable, product input and control functions shall be fully operable via at least one mode that does not require speech.
Rationale: Many individuals cannot speak or speak clearly either due to physical disability or deafness. Products which require speech in order to fully operate them, and which do not provide an alternate way to achieve the same function are not usable by these people.
Guideline: Where readily achievable, product input, control and mechanical functions shall be fully operable via at least one mode that minimizes the cognitive, memory and learning skills required of the user to operate the product.
Rationale: Many individuals have reduced cognitive abilities either
from birth, accident/illness, or aging. These include reduced memory, sequencing,
reading, and interpretive skills.
Guideline: Where readily achievable, all information (text, static or dynamic images and labels) which is provided visually shall also be available in auditory form.
Rationale: Some individuals have difficulty seeing or reading, or cannot see or read.
Guideline: Where readily achievable, all information which is provided through a visual display including text and dynamic images, labels or incidental operating cues, shall be perceivable via at least one mode by individuals who have low vision but are not blind, without requiring audio presentation.
Rationale: Individuals with severe visual disabilities often also have severe hearing disabilities (especially older users) and cannot rely on audio access modes used by those who are blind.
Guideline: Where readily achievable, text which is presented in a moving fashion shall also be available via at least one static presentation mode at the option of the user.
Rationale: Moving text can be an access problem because individuals with low vision, physical or sensorimotor disabilities find it difficult or impossible to track moving text with their eyes.
Guideline: Where readily achievable, all information which is provided auditorially, including those incidental operating sounds and speech, which are important for use of the product, shall be available via at least one mode in appropriate visual form and/or where appropriate in tactile form.
Rationale: Individuals who have difficulty hearing or who are unable to hear the product are unable to hear auditory output or to hear mechanical and other sounds that are emitted by a device which may be needed for its safe or effective operation.
Guideline: Where readily achievable, all information which is provided auditorially, including incidental operating sounds, which is important for use of the product, shall be available via at least one mode in enhanced auditory fashion (for example, increased amplification, or reduction of background noise).
Rationale: Individuals who have difficulty hearing but are not deaf find it much easier to use their hearing than to have to rely on access strategies used by people who are deaf.
CLOSELY RELATED GUIDELINES: See C-2 and C-3 dealing with hearing aid compatibility.
Guideline: Where readily achievable, visual displays shall be designed so as to avoid high probability of triggering a seizure in an individual with photo-sensitive epilepsy.
Rationale: Individuals with photo-sensitive epilepsy can have a seizure triggered by displays which flicker or flash, particularly if the flash has a high intensity and is within certain frequency ranges.
Guideline: Where readily achievable, sound displays shall be designed so as to avoid audio behaviors that create a high probability of a seizure in an individual with sound-induced epilepsy.
Rationale: Individuals with sound-induced epilepsy can have a seizure triggered by acoustic output.
Guideline: Where readily achievable, products which use audio output access modes, shall have a headphone jack or personal listening device (e.g., phone-like handset or earcup) which cuts off the speaker when used.
Rationale: Individuals using the audio access mode, as well as those
using a device with the volume turned up, need a way to limit the range
of audio broadcast.
Guideline: Documentation (printed, on-line or tutorial, including promotional materials) shall be accessible to and usable by individuals with all disabilities or alternate formats shall be available.
Rationale: People who have disabilities often are unable to use standard
printed documentation if they cannot see, documentation that is presented
on screen in small fonts if they have poor vision, documentation that presents
important information auditorially if they are deaf, etc.
Guideline: Where readily achievable,
Rationale: Some individuals with severe or multiple disabilities are unable to use the built-in displays and control mechanisms on a product.
Guideline: Where readily achievable, products providing auditory output shall provide the auditory signal via an industry standard connector and signal level.
Rationale: Individuals using amplifiers, audio couplers, and other audio processing devices need a place to tap into the audio generated by the product in a standard way.
Guideline: Where readily achievable, products providing auditory output via an audio transducer which is normally held up to the ear shall provide a means for effective wireless coupling to hearing aids.
Rationale: Individuals who are hard of hearing use hearing aids with a T-coil feature to allow them to listen to audio output of products without picking up background noise and to avoid problems with feedback, signal attenuation or degradation.
5.3.4.4 (C-4). Non-Interference with Hearing Technologies.
Guideline: Where readily achievable, products shall not cause interference with hearing technologies (including hearing aids, cochlear implants, and assistive listening devices) which are used by a product user or bystanders.
Rationale: Individuals who are hard of hearing use hearing aids and other assistive listening devices, but they cannot be used if other products introduce noise into the hearing technologies because of stray electromagnetic interference.
Guideline: Where readily achievable, touchscreen and touch-operated controls shall be able to be activated without requiring body contact or close body proximity.
Rationale: Individuals who have artificial hands or use headsticks or mouthsticks to operate products have difficulty with capacitive or heat-operated controls which require contact with a person’s body rather than a tool.
Guideline: Where readily achievable, products 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 acoustic pickup on the product on and off to allow the user who can talk to intermix speech (live microphone) with text telephone use.
Rationale: Individuals who use text telephones (TTYs) to communicate using text-over-telephones must have some non-acoustic way to connect TTYs to telephones to get clear TTY connections. Acoustic coupling is subject to interference from ambient noise, as many handsets do not provide an adequate seal with TTYs. Therefore, alternate (non-acoustic) connections are needed. Control of the microphone is needed for situations such as pay-phone usage, where ambient noise picked up by the mouthpiece often garbles the signal (user needs to be able to mute the handset microphone). Some users of TTYs cannot hear and use the TTY to receive communication but can talk and use speech for outgoing communication. The microphone on/off switch on the telephone should therefore be easy to flip back and forth or have a push-to-talk mode available.
Guideline: Where readily achievable, products providing voice communication functionality shall be able to support use of all cross-manufacturer non-proprietary standard signals used by telecommunication devices designed for use by or with people who are deaf, hard of hearing or have speech impairments.
Rationale: Some telecommunication systems, which have been developed and released, compress the audio signal in such a manner that standard signals used by TTYs are distorted or attenuated, preventing successful TTY communication over the systems.
The committee was unable to reach consensus on this introductory section due to time constraints. Some committee members believed this section should be characterized as the following:
This section describes the compliance and coordination partnership which is recommended by the committee for guiding the access requirements of section 255. Some components of the structure are not in existence at this time. Others are only now being initiated. For this reason this section is as much a roadmap to the future as it is a system for judging compliance.
The compliance system presented in this document, and more specifically in this section requires and relies upon a coordinated partnership between industry and individuals with disabilities. Specifically it requires a system which facilitates effective partnering throughout all stages of the process, including development of guidelines, standards, product design and development, verification of accessibility, complaint investigation, and market monitoring. In order to succeed, this system requires the good faith support of these parties. In keeping with this understanding, this section is written with an assumption of reasonableness and balance from all parties. Any interpretations that may be made which are clearly unbalanced and consistently prejudicial to any interest are not intended.
The section describes three mechanisms for controlling and assessing compliance. At the first and highest level are the guidelines developed by the Access Board. These provide the overall direction for this effort. Supporting the guidelines are access related consensus standards developed by standards setting bodies. Where they are appropriate and available, these documents provide specific technical guidance for important parts of the compliance assessment. Standards often serve to document standard test methodologies, compatibility requirements and at times to provide technical guidance to established practice. The third level, found in section 6.4, is expert opinion, fostered by an ongoing dialogue between consumer and industry representative.
Rationale: This section proposes that the optimum structure for the development of telecommunications access is a mix of public and private sector initiatives. A variety of such models exist today throughout the government. One example is the FCC’s handling of the issue of TV interference. In the early 1980s, the FCC was given regulatory authority in this area. However, it implemented that authority by working with a private sector standard setting body to write the required technical standards. In parallel with this effort, dialogue with the affected manufacturers resulted in voluntary inclusion of the required suppression circuitry in most TV sets. The FCC continues to actively monitor the issue to assure that the public interest is being served. In that not all of the components described in this section are currently sufficiently developed, it is implied, and at times stated, that the Access Board and FCC will work with the appropriate parties to develop these components. The agencies should monitor the development of these components, and to the extent that some components do not develop as envisioned, the Access Board should expeditiously review the compliance and coordination model, and may change it sooner than the recommended five-year review.
However, the committee believes that the structure envisioned is quite realistic. Indeed it is heartening to note that since the inception of the TAAC, the National Association of Radio and Telecommunications Engineers (NARTE) has initiated an Association of Access Engineers and Specialists. It is hoped that this new organization, working in close cooperation with other interested organizations, such as RESNA (Rehabilitation Engineering and Assistive Technology Society of North America), TIA (Telecommunications Industry Association), IEEE (Institute of Electrical and Electronics Engineers), EIF (Electronic Industries Foundation), RERC (Rehabilitation Engineering Research Centers), and others will provide many of the services called for in section 6.4.
Other committee members believed this section should be characterized as the following:
This section describes the committee’s recommendation for a framework for coordination among manufacturers and consumers to identify access needs and solutions to those needs, ensuring compliance with the requirements of section 255, and encouraging the prompt, informal resolution of complaints about the accessibility of telecommunications and customer premises equipment. The principal elements comprising this framework are:
Rationale: The framework described in this section relies heavily on private sector initiatives and cooperation among manufacturers and individuals with disabilities and organizations advocating for their interests to foster the development of those elements of the framework that are in the early stages of development. For example, the National Association of Radio and Telecommunications Engineers (NARTE) has initiated an Association of Access Engineers and Specialists. This new organization, and others that may be established, in cooperation with other existing organizations like the Rehabilitation Engineering and Assistive Technology Society of North America (RESNA), the Institute of Electrical and Electronics Engineers (IEEE), the Telecommunications Industry Association (TIA), the Electronic Industries Foundation (EIF), and the Rehabilitation Engineering Research Centers (RERC), could provide many of the contact point functions described in section 6.4. It is expected that the FCC and Access Board will encourage the development of the cooperative elements of this framework and monitor and evaluate the progress of their development and take further action if appropriate.
The Access Board shall review and reauthorize these guidelines at a maximum interval of five years, incorporating input from representatives of industry, individuals with a wide range of disabilities and organizations which represent the needs of individuals with disabilities, academic and research specialists in the area of access engineering, the FCC, and input from the annual market monitoring report.
Where standards are appropriate, the Access Board and FCC should work in conjunction with standards setting bodies, including consortia, to encourage the development of and where appropriate, officially recognize consensus standards developed for telecommunications accessibility. This process shall incorporate input from individuals with a wide range of disabilities and organizations which represent the needs of individuals with disabilities. Examples of areas in which standards would be useful are: to provide objective evaluation and test methods, provide for standardized user interfaces, provide for compatibility between CPE and SCPE and others. The utmost care should be exercised to assure that these standards do not hinder innovation and technological development, but rather work in concert with innovation.
In order to receive official recognition of a consensus standard, developed for telecommunications accessibility, the standard setting body sponsoring the standard should review and refresh it every five years or more frequently, if needed.
Industry should coordinate the development of accessibility standards with officially recognized standard setting bodies such as the American National Standards Institute (ANSI) wherever appropriate.
Industry should promote harmonization of accessibility standards with international bodies such as the International Standards Organization (ISO) or the International Electrotechnical Commission (IEC) wherever appropriate.
The model described in section 6 relies heavily on the presence of an organization or organizations to provide effective and efficient communications and feedback for the implementation of telecommunications access. Such a "coordination point" might be a sub-society of an existing engineering society, governed by its own board comprised of industry representatives, individuals with disabilities, representatives of organizations which represent the needs of individuals with disabilities, and academic and research specialists in the area of access. If a coordination point or points is established, the FCC and Access Board are encouraged to support and assist, as appropriate, the development of such organizations to serve the purposes listed in this section. If such organizations do not develop as required in this model, the Access Board and FCC shall as expeditiously as possible review the model and change it if appropriate.
Rationale: The industry members of the TAAC have argued that many aspects of the effort to provide telecommunications access will be most effectively and efficiently provided through private sector initiative. This section assumes that the monetary savings and the administrative simplicity of a Declaration of Conformity system will provide sufficient motivation for the creation and support of the initiative described in this section. The committee observes with great interest the development of an accessible design society sponsored by NARTE. The committee encourages the Access Board and FCC to monitor the development of this, or other similar efforts, and to the degree they appropriately fulfill the functions described in this section, utilize these initiatives. Should initiatives such as these fail, other kinds of solutions will be required.
The coordination point should facilitate participation of individuals and organizations representing the needs of individuals with disabilities by ensuring accessibility of events and accommodations such as communication access and alternative formats for materials, and by supporting attendance and participation in training by individuals with disabilities through sponsorships.
The coordination point could facilitate the development of appropriate curricula through entities such as universities and trade associations, and should ensure provision of training on access needs and strategies to access specialists, in conjunction with training provided to individuals with disabilities.
The coordination point should facilitate the development of appropriate curricula and should provide on-going training on fundamentals of telecommunications and access to individuals with disabilities and representatives of organizations representing the needs of individuals with disabilities, in conjunction with training provided to access specialists.
The coordination point should support the development of a certification process for access specialists. Such a certification process should contain provisions for annual updating of access specialist training to ensure that practitioners are current with the state-of-the-art.
The coordination point could host an annual symposium with technical sessions to provide a forum for presentation of papers and research results on access engineering. This annual symposium could also receive and review the annual marketing monitoring report from the Access Board to identify key areas of need in access for the coming year.
The coordination point may, if requested, provide industry and disability input into periodic refreshment of the Access Board guidelines.
The coordination point could, if requested, provide industry and disability input into the development, refreshment, coordination and international harmonization of standards.
The coordination point could, if requested, convene and maintain an advisory panel comprised of industry representatives, individuals with disabilities and representatives of organizations representing the needs of individuals with disabilities, to provide opinion, at the FCC’s request, on inquiries and complaints which have been submitted to the FCC.
The coordination point could identify areas of access needs where research and development are in demand and sponsor research in those areas.
The coordination point could establish an awards program for access innovations to stimulate industry efforts in this area.
Manufacturers shall verify readily achievable accessibility and usability of products, and compatibility of products with existing peripherals and specialized CPE where access and usability is not readily achievable, through:
The terms standard and standardized in items 2 and 3, above, refer to tests, methods and techniques which are documented in consensus standards, developed by recognized standards settings bodies and recognized as being appropriate by the Access Board and FCC, as provided for in section 6.3.1.
When utilizing the verification methods of expert opinion or standard tests, manufacturers should use qualified access specialists to supervise the verification and, as appropriate, in implementing process and performance plans throughout product design and development.
Note: Consensus was not reached on the use of shall or should on this item. [Should/shall] is therefore used in the following paragraph.
Manufacturers [should/shall] document accessibility design decisions, whether or not access solutions are found to be readily achievable. Documentation sufficient to show compliance with the accessibility requirements of section 255 [should/shall] be retained.
The Access Board, in cooperation with recognized laboratory accrediting agencies, should promote the development of a certification process for access testing laboratories.
For all telecommunications equipment and customer premises equipment, the manufacturer shall supply with the product, at the time of marketing or importation, a declaration of conformity (DOC) with section 255.
Rationale: The declaration represents a manufacturer’s self-evaluation of adherence to Access Board and/or FCC evolving guidelines in determining whether accessibility and usability of a product by individuals with disabilities is readily achievable, or to the extent that accessibility and usability is not readily achievable, compatibility of the product with existing peripheral devices or specialized customer premises equipment commonly used by individuals with disabilities is readily achievable for the given product.
The DOC is relatively brief (see 6.6.3, 6.6.4), and because it provides no information about the accessibility or compatibility features of the particular product, it cannot replace the provision of useful consumer information, as covered in sections 4.4, 4.6, 4.10, and other places in this report.
If standards concerning appropriate methods of evaluation and verification of accessibility are developed by standards setting bodies as described in section 6.3, whether or not formally adopted by the Access Board or the FCC, it is expected that these methods will be used by manufacturers in evaluating and verifying accessibility and compatibility.
The DOC shall be included as a separate sheet or other medium in the product box, or located within a user’s manual in such a way that the user may quickly find the declaration itself, or an accessible visual, auditory, or tactile prompt to its location.
Rationale: The DOC, which includes contact information, must be easily locatable by individuals who customarily use alternate formats, in order that they may contact the manufacturer’s point of contact to request alternate formats of the product literature including the user manual. Some manufacturers may choose to provide with the product a declaration alternatively formatted for the individuals with particular disabilities for whom the product is designed, developed, and fabricated.
The declaration of conformity shall include the following:
Section 255 requires manufacturers to design, develop, and fabricate telecommunications products to be accessible to and usable by individuals with disabilities if readily achievable. When accessibility and usability is not readily achievable, such products must be compatible with peripheral devices commonly used by individuals with disabilities, if that is readily achievable. The TAAC urges the FCC to adopt a consistent content and format for a declaration of conformity to reduce confusion by both consumers and manufacturers as to the specific requirement.
Some committee members believed that the declaration of conformity should contain the following language:
This product complies with section 255 of the Communications Act. This means that the manufacturer [or enter name of manufacturer] considered access and use by individuals with disabilities during product design, development, and fabrication. The manufacturer [or insert name of manufacturer] incorporated accessibility or compatibility to the extent that it was readily achievable to do so. The resulting product may not be completely accessible to each and every type and degree of disability, or compatible with any particular specialized customer premises equipment or peripheral devices commonly used by individuals with disabilities.
For further information about the accessibility or compatibility features of this product, product documentation in alternate formats, or other questions about accessibility matters, please contact our Accessibility Coordinator. [Provide contact address information, see section 4.10.1]
Rationale: This text conveys the disability access requirements and readily achievable limitation contained in section 255 and clarifies that compliance with section 255 does not necessarily mean that access or compatibility is readily achievable for all or any specific disability or specialized equipment used by individuals with disabilities. This formulation avoids troubling language in the proposal below which would likely lead consumers to believe that disability access is not necessarily required by section 255.
Other committee members believed the statement should contain the following:
This product complies with section 255 of the Communications Act. This means that the manufacturer [or enter name of manufacturer] considered access and use by individuals with disabilities during product design, development, and fabrication and incorporated accessibility or compatibility features to the extent that it was readily achievable to do so. It does not mean that the product necessarily is, or is required to be, accessible to or usable by an individual with any particular type or degree of disability or compatible with any specific peripheral device.
For further information about the accessibility or compatibility features of this product, product documentation in alternate formats, or other questions about accessibility matters, please contact our Accessibility Coordinator. [Provide contact address information, see section 4.10.1]
Rationale: Without the qualifications reflected in the third sentence, purchasers of its products could be misled by the statement about the extent to which the product incorporates accessibility features or about the extent of the manufacturer’s obligation to do so. This language has the virtue of bluntness. The more blunt the statement, the less likely consumers will be misled by the statement and the less likely manufacturers and consumer advocates will be blamed for misunderstandings.
As required in section 4.10, manufacturers shall establish and maintain a point of contact to assist customers regarding access features. The equipment manufacturer should be the initial and, it is hoped, primary resolver of consumer inquiries and complaints. When a manufacturer cannot adequately meet a consumer’s needs they are required in section 4.10.3 to deliver the material described in 6.7.2 to the consumer.
The Access Board shall develop material which gives consumer information regarding telecommunications access. This material is intended to provide a bridge for a consumer to the best telecommunications access information available. This material should provide points of contact for help with the needs of specific disabilities. It should also assist the consumer by providing information sources on available adaptive devices. Equipment manufacturers who are unable to fully meet a consumer’s needs are required to give them the information in section 4.10.3.
The FCC should maintain a point of contact for individuals with disabilities, and manufacturers for receipt of inquiries and complaints regarding accessibility of telecommunications equipment and CPE, and publish this FCC point of contact in the Federal Register.
FCC policies with respect to complaints about the accessibility of telecommunications or customer premises equipment should:
(a) encourage consumers to express informally their concerns or grievances about a product to the manufacturer or supplier who brought the product to market before complaining to the FCC; and
(b) encourage manufacturers to respond within 30 days to consumer concerns or grievances about the accessibility of their products with information or actions sufficient to resolve the concerns.
If the manufacturer has issued a declaration of conformity, individuals with disabilities are encouraged to make inquiries to the manufacturer regarding product features relating to accessibility and compatibility, before bringing a complaint to the FCC. When a complaint is made to the FCC, the FCC should determine whether the complainant has discussed concerns and grievances with the manufacturer but was unable to satisfactorily resolve the complaint. If the complainant has not conducted any such discussions, the FCC should encourage the complainant to contact the manufacturer for this purpose or the FCC should take such action as it deems appropriate to assist the complainant to resolve the complaint informally.
The Access Board and/or the FCC should allow adequate time for manufacturers to reflect these guidelines in their processes for designing, developing, fabricating and delivering telecommunications equipment and customer premises equipment.
While the committee reached consensus on the use of a declaration of conformity, it could not agree on the weight such a declaration should be given by the FCC in dealing with complaints.
Some committee members believed that the DOC should be given the following consideration:
A manufacturer responding to a complaint should be presumed to have complied with section 255 if the manufacturer:
(a) Demonstrates adherence to section 255 guidelines, including any recognized good practices associated with design, development, and fabrication that may be associated with such guidelines; and
(b) Supplies a declaration of conformity as provided in section 6.6; or
(c) Demonstrates that one or more of the manufacturer’s other products or product options provides a satisfactory substitute for the challenged product, through reasonably comparable features, prices and availability.
Where the FCC finds that a manufacturer has not complied with section 255, punitive measures should be avoided if the manufacturer has documented good-faith efforts to follow section 255 guidelines and any related good practices; instead, the FCC may require the manufacturer to address the lack of accessibility, usability, or compatibility.
Rationale: The only significant difference in the two versions, is in section 6.7.4.4(c), which allows the availability of an accessible or compatible equipment alternative to create a presumption of compliance. Since the effect is only presumptive, the complainant may still prevail by offering evidence sufficient to overcome the presumption.
Other committee members felt the DOC should be given the following consideration:
In determining whether a manufacturer has complied with section 255 with respect to a particular product, the FCC shall give considerable weight to the extent to which the manufacturer undertook good faith efforts to comply with the guidelines implementing section 255.
Where the FCC finds that a manufacturer’s product does not comply with section 255, punitive measures should be avoided if the manufacturer has documented good faith efforts to fully and adequately follow section 255 guidelines, or, if one or more of the manufacturer’s other products or product options, having comparable features, functions, price, and availability, provides a satisfactory substitute for the accessibility and usability, or compatibility which may be lacking in the product which is the subject of a complaint. The FCC may require the manufacturer to address the lack of accessibility, usability, or compatibility in the product which is the subject of a complaint if it finds that it would have been readily achievable to have designed, developed or fabricated the product to be accessible and usable or compatible.
Rationale: In attempting to determine the compliance of a telecommunications product with section 255, it is proper for the FCC to carefully consider a manufacturer’s good faith efforts to comply with the guidelines implementing section 255. However, a "blanket" presumption of compliance cannot be accorded inasmuch as the FCC may determine that the disability access efforts were not sufficient, even though the efforts were carried out in good faith. Furthermore, section 255 does not provide the FCC with the authority to make a finding of compliance based on substitute or comparable products. The law is clear in its application to all covered products. However, it is reasonable for the FCC to mitigate penalties against a manufacturer who can demonstrate compliance with the guidelines implementing section 255 or who can show that an equivalent product is available as a substitute for a product which is inaccessible. The FCC is expected to determine the extent to which accessibility and usability or compatibility was readily achievable for the product and to require the manufacturer to take steps to resolve the inaccessibility.
In considering whether a manufacturer has demonstrated adherence to the section 255 guidelines with respect to a particular product, the FCC shall consider:
For the purpose of making the above consideration, the FCC may request from the manufacturer documentation on:
The FCC may at its discretion refer inquiries and complaints to a joint industry/disability advisory panel for opinion.
In selection of measures, the FCC may consider whether a manufacturer showed due diligence in complying with mandatory specifications and requirements of these guidelines, and followed advisory specifications and recommendations from these guidelines, or utilized alternative implementation.
The FCC should maintain a database of inquiries and complaints received and the resulting findings or complaint resolutions for annual compilation and review. The FCC shall make this and other access related information it has available to the Access Board.
The Access Board shall survey the marketplace annually to assess the state of the telecommunications market relative to product accessibility and to suggest means to improve telecommunications access for people with disabilities.
The annual market monitoring report shall include information on the availability of accessible telecommunications products in the marketplace by type and by applicable disability. The annual market monitoring report shall include information from the FCC on number and types of inquiries and complaints, with their final resolution or findings, across all covered market sectors. The Access Board, working with the FCC, shall identify trends which impact telecommunications access for people with disabilities. In addition, the Access Board should identify research or product development work needed to rectify an existing market deficiency or pattern of inaccessibility to prevent future deficiencies.
Rationale: The annual market monitoring report is intended to present a balanced, high level viewpoint of the state of telecommunications accessibility. It should cite positive trends and progress. It should also identify deficiencies, trends or patterns of lack of access and areas needing further work. Its primary purpose is to guide the application of resources to access issues. Hence, it should applaud areas where resources are being effectively applied and identify areas needing additional action, with suggestions as to the kinds of action needed.
The Access Board shall announce the availability of the annual market monitoring report to the public in the Federal Register, and shall deliver the report to the FCC, and to the members of the coordination point (see 6.4). The Access Board shall make the report available, in print or alternate formats, to any interested party upon request.
If the annual market monitoring report indicates important product areas showing lack of progress or if substantial patterns of non-compliance with section 255 are identified, the FCC and/or the Access Board may call for associated industry cooperative efforts or may initiate proceedings to develop more stringent compliance measures for section 255. The Access Board may also recognize and recommend processes or innovative technical solutions (best practices) which may improve product design or accessibility.
NOTE: The Access Board will be maintaining updated reference material on telecommunication access on its web site at http://www.access-board.gov/. The Trace Research and Development Center, under sponsorship of the U.S. Department of Education’s National Institute on Disability and Rehabilitation Research (NIDRR) will also be maintaining a web site at http://trace.wisc.edu/telecomm/ that will contain continually updated bibliographic information on telecommunications access as well as an on-line design tool and an on-line collection of examples of accessible designs and techniques.
ADA -- Americans with Disabilities Act
ADAAG -- Americans with Disabilities Act Accessibility Guidelines
ANSI -- American National Standards Institute
CPE -- Customer Premises Equipment
DOC -- Declaration of Conformity
EIA -- Electronic Industries Association
FCC -- Federal Communication Commission
HAC -- Hearing Aid Compatibility Act
HTTP -- Hyper Text Transport Protocol (part of an internet web address)
IEEE -- Institute of Electrical and Electronic Engineers
ISO -- International Organization for Standardization
IrDA -- Infra Red Data Association
ITU -- International Telecommunications Union
NARTE -- National Association of Radio and Telecommunications Engineers
QWERTY -- The standard alpha-numeric keyboard. Name is taken from the letters
on the top row of the keys.
RERC -- Rehabilitation Engineering Research Centers
RESNA -- Rehabilitation Engineering and Assistive Technology Society of
North America
RF -- radio frequency
TAAC -- Telecommunications Access Advisory Committee
TIA -- Telecommunications Industry Association
TRS -- Telephone Relay Service
TTY -- Text Telephone
U.S.C.-- United States Code
I. Section 255: Access by Persons with Disabilities
II. Section 251: Interconnection
III. Section 305: Video Programming Accessibility
NOTE: Although video programming accessibility is not within the scope
of this document and is not covered or treated elsewhere, it is included
in this Appendix for reference and because it is a disability related provision
in the Telecommunications Act of 1996.
(a) DEFINITIONS-- As used in this section --
(1) DISABILITY -- The term ‘disability’ has the meaning given to it by section 3(2)(A) of the Americans with Disabilities Act of 1990 (42 U.S.C. 12102(2)(A)).
(2) READILY ACHIEVABLE -- The term ‘readily achievable’ has the meaning given to it by section 301(9) of that Act (42 U.S.C. 12181(9)).
(b) MANUFACTURING -- A manufacturer of telecommunications equipment or customer premises equipment shall ensure that the equipment is designed, developed, and fabricated to be accessible to and usable by individuals with disabilities, if readily achievable.
(c) TELECOMMUNICATIONS SERVICES -- A provider of telecommunications services shall ensure that the service is accessible to and usable by individuals with disabilities, if readily achievable.
(d) COMPATIBILITY -- Whenever the requirements of subsections (b) and (c) are not readily achievable, such a manufacturer or provider shall ensure that the equipment or service is compatible with existing peripheral devices or specialized customer premises equipment commonly used by individuals with disabilities to achieve access, if readily achievable.
(e) GUIDELINES -- Within 18 months after the date of enactment of the Telecommunications Act of 1996, the Architectural and Transportation Barriers Compliance Board shall develop guidelines for accessibility of telecommunications equipment and customer premises equipment in conjunction with the Commission. The Board shall review and update the guidelines periodically.
(f) NO ADDITIONAL PRIVACY RIGHTS AUTHORIZED -- Nothing in this section
shall be construed to authorize any privacy right of action to enforce
any requirement of this section or any regulation thereunder. The Commission
shall have exclusive jurisdiction with respect to any complaint under this
section.
(a) GENERAL DUTY OF TELECOMMUNI-CATIONS CARRIERS -- Each telecommunications carrier has the duty --
1. to interconnect directly or indirectly with the facilities and equipment of other telecommunications carriers; and
2. not to install network features, functions, or capabilities that
do not comply with the guidelines and standards established pursuant to
section 255 or 256.
III. Section 305: Video Programming Accessibility.
Title VII is amended by inserting after section 712 (47 U.S.C. 612) the following new section:
"SEC. 713. VIDEO PROGRAMMING ACCESSIBILITY.
(a) Commission Inquiry.--Within 180 days after the date of enactment of the Telecommunications Act of 1996, the Federal Communications Commission shall complete an inquiry to ascertain the level at which video programming is closed captioned. Such inquiry shall examine the extent to which existing or previously published programming is closed captioned, the size of the video programming provider or programming owner providing closed captioning, the size of the market served, the relative audience shares achieved, or any other related factors. The Commission shall submit to the Congress a report on the results of such inquiry.
(b) Accountability Criteria.--Within 18 months after such date of enactment, the Commission shall prescribe such regulations as are necessary to implement this section. Such regulations shall ensure that--
(1) video programming first published or exhibited after the effective date of such regulations is fully accessible through the provision of closed captions, except as provided in subsection (d); and
(2) video programming providers or owners maximize the accessibility of video programming first published or exhibited prior to the effective date of such regulations through the provision of closed captions, except as provided in subsection (d).
(c) Deadlines for Captioning.--Such regulations shall include an appropriate schedule of deadlines for the provision of closed captioning of video programming.
(d) Exemptions.--Notwithstanding subsection (b)-
(1) the Commission may exempt by regulation programs, classes of programs, or services for which the Commission has determined that the provision of closed captioning would be economically burdensome to the provider or owner of such programming;
(2) a provider of video programming or the owner of any program carried by the provider shall not be obligated to supply closed captions if such action would be inconsistent with contracts in effect on the date of enactment of the Telecommunications Act of 1996, except that nothing in this section shall be construed to relieve a video programming provider of its obligations to provide services required by Federal law; and
(3) a provider of video programming or program owner may petition the Commission for an exemption from the requirements of this section, and the Commission may grant such petition upon a showing that the requirements contained in this section would result in an undue burden.
(e) Undue Burden.--The term ‘undue burden’ means significant difficulty or expense. In determining whether the closed captions necessary to comply with the requirements of this paragraph would result in an undue economic burden, the factors to be considered include--
(1) the nature and cost of the closed captions for the programming;
(2) the impact on the operation of the provider or program owner;
(3) the financial resources of the provider or program owner; and
(4) the type of operations of the provider or program owner.
(f) Video Descriptions Inquiry.--Within 6 months after the date of enactment of the Telecommunications Act of 1996, the Commission shall commence an inquiry to examine the use of video descriptions on video programming in order to ensure the accessibility of video programming to persons with visual impairments, and report to Congress on its findings. The Commission’s report shall assess appropriate methods and schedules for phasing video descriptions into the marketplace, technical and quality standards for video descriptions, a definition of programming for which video descriptions would apply, and other technical and legal issues that the Commission deems appropriate.
(g) Video Description.--For purposes of this section, `video description’ means the insertion of audio narrated descriptions of a television program’s key visual elements into natural pauses between the program’s dialogue.
(h) Private Rights of Actions Prohibited.--Nothing in this section shall be construed to authorize any private right of action to enforce any requirement of this section or any regulation thereunder. The Commission shall have exclusive jurisdiction with respect to any complaint under this section.
This appendix provides example strategies and notes to assist in understanding
the guidelines and as a source of ideas for alternate strategies for achieving
them. The strategies, and notes here are not mandatory in nature. The manufacturer
is not required to incorporate all of these strategies or any specific
strategy. They are free to use these or other strategies in addressing
the guidelines. The listing below is not comprehensive. Nor does following
these example strategies guarantee an accessible product. For a comprehensive
listing of all of the published strategies to date, as well as for further
information and links to on-going discussions the reader is referred to
the Access Board’s web page at: http://www.access-board.go/ and the
National Institute on Disability and Rehabilitation Research’s
Rehabilitation Engineering Center on Access to Telecommunications System’s
strategies web page which can be found at:
http://trace.wisc.edu/telecomm/.
Guideline: Where readily achievable, product input, control and mechanical functions shall be fully operable via at least one mode whose components are locatable, identifiable, and accurately operable without requiring the user to see.
Rationale: Individuals with severe visual disabilities or blindness cannot locate or identify controls, latches, input slits etc. by sight or operate controls that require sight.
Goal: All individuals, regardless of onset of blindness, will be able to accurately and efficiently operate products without assistance.
Problems: Individuals who cannot see must use either touch or sound to locate and identify controls. If a product uses a flat, smooth touch screen or touch membrane, the user without vision will not be able to even locate the controls without auditory or tactile cues. Once the controls have been located, the user must then be able to tell what the functions of the controls are. Finally, they must be able to operate the controls. Individuals who have low vision or are blind cannot accurately operate some types of controls which require vision for use. These include mice, trackballs, dials without markings or stops, and push-button controls with only one physical state, where the only indication of the setting is visual.
If you use buttons on your product, making them discrete buttons which can be felt allows a person to locate them tactilely. If you are using a flat membrane keyboard, putting a raised edge around the control areas or buttons makes it possible to tactilely locate the keys. Once an individual locates the different controls, they need to identify what they are. If you have a standard number pad arrangement, putting a nib on the "5" key may be all that is necessary for identifying the numbers. On a QWERTY keyboard, putting a tactile nib on the "F" and "J" keys allows a touch typist who is blind to easily locate their hands on the keys. Providing distinct shapes for keys can either indicate their function or make it easy to tell them apart. Providing braille labels for keys and controls allows individuals who know braille to figure out what the controls are for. Providing large raised letters can work for short labels on large objects. Where it is not possible to use raised large letters, you may be able to incorporate a voice mode which announces keys when pressed, but does not activate them. This would allow people to turn on the voice mode long enough to explore and locate the item they are interested in, then release the voice mode and press the control. If it is an adjustable control, voice confirmation of the status may also be important.
For connectors, either provide a tactile indication as to the way the plug should be oriented or use orientation-independent or self-orienting plugs. Wireless connection strategies, which eliminate the need to orient or insert connectors, also solves the problem.
Avoiding buttons that are activated when touched will allow an individual to explore the controls in order to find the desired button. If you cannot avoid touch-activated controls (for example, on a touch screen), you can provide an alternate mode where a confirm button is used to confirm selections (for example, items are read when touched, and activated when the confirm button is pressed). It is also a good idea to make all actions reversible, or require confirmation before executing non-reversible actions.
Once controls have been located and users know what the functions of the controls are, they must be able to operate the controls. Individuals who have low vision or blindness cannot accurately operate some types of controls which require vision for use. These include mice, track balls, dials without markings or stops, and push-button controls with only one state where the only indication of the position or setting of the control (mouse, pointer, etc.) is visual.
Providing a rotational or linear stop and tactile or audio detents is one strategy that can be used. Another is to provide keyboard or discrete push-button access to the functions. If the product has an audio system and microprocessor, audio feedback of the setting may be used. For simpler devices, tactile markings may be sufficient. Controls can also be shaped in a fashion that they can easily be tactilely read (e.g., a twist knob shaped like a pie wedge). If using keys, particularly keys which do not have any physical travel, some type of audio and tactile feedback should be provided so that the individual knows when the key has been activated. If the key is a two-state key (on/off), use a key that is physically different (a toggle switch or a push-in/pop-out switch), so the person can tell what state it is in by feeling it.
If you have an optional voice mode for operating the product a simple "query" mode could be provided, which would allow the individual to find out both the function and state of a switch without actually activating it.
In many cases, there may be other design considerations which make the optimal mode of operation for someone who is sighted something which would not be easily operated by someone without vision (e.g., use of a touchscreen or mouse). In this case, the primary strategy may be to provide a closely linked parallel method for efficiently achieving the same results (e.g., keyboard access) if you have keyboard "SpeedList" access for touchscreens, etc.
Guideline: Where readily achievable, the product input, control and mechanical functions shall be fully operable via at least one mode which is operable by individuals who have low vision but are not legally blind, which does not rely on audio output.
Note: 20/70 after correction is the beginning of low vision; 20/200 after correction is the beginning of legal blindness; a field of vision of less than 20 degrees after correction also constitutes legal blindness.
Rationale: Individuals with severe visual disabilities often also have severe hearing disabilities (especially older users) and cannot rely on audio access modes commonly used by those who are blind.
Problem/Objective: For individuals who have low vision and who also have hearing impairments or who are deaf, many of the auditory strategies used by individuals who are blind cannot be used. Tactile strategies are still quite useful, except for braille which few people with low vision know, especially individuals who are older. The objective here, therefore, is to maximize the number of people who can use their residual vision combined with tactile senses to operate the product. It should be noted, however, that individuals with diabetes who are losing their vision also lose fine tactile sensation in their fingertips, although more pronounced tactile information (e.g., the shape of a large knob or strong tactile detents) can be felt.
Goal: Anyone who has low vision can use products, even if they have no useful hearing.
Strategies for addressing this guideline basically revolve around making the information on the product easier to see. This includes using high-contrast print symbols and visual indicators, minimizing glare on the display and control surfaces, providing adequate lighting, positioning controls near the items they control to make them easy to find, and using Arabic instead of Roman numerals. The type-face and type-spacing you use can greatly effect legibility and symbols can sometimes be used which are much more legible and understandable than fine print. Where the display is dynamic, an ability to enlarge the visual display can also be used.
In addition to making it easier to see, there are strategies which can be used to reduce the need to see things clearly in order to operate them. A judicious use of color-coding (always redundant with other cues) and following standard conventions and stereotypes can be used to reduce the need to read labels (or read labels more than the first time). In addition, all of the tactile strategies discussed under the previous guideline (I-1) can also be used here.
Guideline: Where readily achievable, product input, control, mechanical and display functions shall be fully operable via at least one mode that does not require color perce