Three cuts at generic guidelines

["Jim Fruchterman"<jim@arkenstone.org>]

     The generic guidelines were discussed in our last plenary meeting.  I 
     wanted to chop down the generic guidelines into a very short and 
     succinct statement.  This would then form the basis of any more 
     detailed standard, because to a great extent a more specific standard 
     would be talking about how to accomplish the generic standard.  I 
     wanted to look at the different source documents and excerpt just the 
     key elements.
     
     I have presented three different cuts below, which represent lightly 
     edited versions of existing documents:
     Final Rule on Section 255, by the Access Board
     The functional guidelines document Gregg presented
     My chopped down elements of the TAAC report
     
     I have tried to make these more comparable.  I have cut the rationales 
     from the TAAC material, and cut repetitive phrases such as undue 
     burden or readily achievable.  I have focused on input and output and 
     controls, and left some of the other issues for later.
     
     They are each separated by asterisks.  I'd like some feedback on these 
     options.  They all cover similar territory in slightly different ways. 
      
     
     Jim Fruchterman
     
     
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     First: the Section 255 final rule from the Access Board:
     § 1193.41 Input, control, and mechanical functions.
     Input, control, and mechanical functions shall be locatable, 
     identifiable, and operable in accordance with each of the following, 
     assessed independently:
     (a) Operable without vision. Provide at least one mode that does not 
     require user vision.
     (b) Operable with low vision and limited or no hearing. Provide at 
     least one mode that permits operation by users with visual acuity 
     between 20/70 and 20/200, without relying on audio output.
     (c) Operable with little or no color perception. Provide at least one 
     mode that does not require user color perception.
     (d) Operable without hearing. Provide at least one mode that does not 
     require user auditory perception.
     (e) Operable with limited manual dexterity. Provide at least one mode 
     that does not require user fine motor control or simultaneous actions.
     (f) Operable with limited reach and strength. Provide at least one 
     mode that is operable with user limited reach and strength.
     (g) Operable without time-dependent controls. Provide at least one 
     mode that does not require a response time. Alternatively, a response 
     time may be required if it can be by-passed or adjusted by the user 
     over a wide range.
     (h) Operable without speech. Provide at least one mode that does not 
     require user speech.
     (i) Operable with limited cognitive skills. Provide at least one mode 
     that minimizes the cognitive, memory, language, and learning skills 
     required of the user.
     § 1193.43 Output, display, and control functions.
     All information necessary to operate and use the product, including 
     but not limited to, text, static or dynamic images, icons, labels, 
     sounds, or incidental operating cues, shall comply with each of the 
     following, assessed independently:
     (a) Availability of visual information. Provide visual information 
     through at least one mode in auditory form.
     (b) Availability of visual information for low vision users. Provide 
     visual information through at least one mode to users with visual 
     acuity between 20/70 and 20/200 without relying on audio.
     (c) Access to moving text. Provide moving text in at least one static 
     presentation mode at the option of the user.
     (d) Availability of auditory information. Provide auditory information 
     through at least one mode in visual form and, where appropriate, in 
     tactile form.
     (e) Availability of auditory information for people who are hard of 
     hearing. Provide audio or acoustic information, including any auditory 
     feedback tones that are important for the use of the product, through 
     at least one mode in enhanced auditory fashion (i.e., increased 
     amplification, increased signal-to-noise ratio, or combination). For 
     transmitted voice signals, provide a gain adjustable up to a minimum 
     of 20 dB. For incremental volume control, provide at least one 
     intermediate step of 12 dB of gain.
     (f) Prevention of visually-induced seizures. Visual displays and 
     indicators shall minimize visual flicker that might induce seizures in 
     people with photosensitive epilepsy.
     (g) Availability of audio cutoff. Where a product delivers audio 
     output through an external speaker, provide an industry standard 
     connector for headphones or personal listening devices (e.g., 
     phone-like handset or earcup) which cuts off the speaker(s) when used.
     (h) Non-interference with hearing technologies. Reduce interference to 
     hearing technologies (including hearing aids, cochlear implants, and 
     assistive listening devices) to the lowest possible level that allows 
     a user to utilize the product.
     (i) Hearing aid coupling. Where a product delivers output by an audio 
     transducer which is normally held up to the ear, provide a means for 
     effective wireless coupling to hearing aids.
     ***********************************************************
     Second, the applicable part of the functional guidelines document 
     Gregg presented:
     
     Information Production
     
     IP -1      (All) technologies used for production of information 
     packages or packets should allow for and facilitate the creation of 
     alternative modality formats (visual, audible, tactile and text) if 
     the basic format is not modality independent (e.g., text).   
     
     
     Storage and Serving Functions
     
     SS-1       (All) technologies and formats providing a storage function 
     should support the linked storage of alternate modality formats for 
     any information stored (unless it is modality independent)  
     
     SS-2       (All) technologies providing a serving function should 
     support the serving of information either a) in flex-modal form (where 
     user can choose the modality for presentation after it arrives) or b) 
     in a select-modal form where the user can specify which modality 
     (visual, audible, text) that they want the information served/sent in. 
       
     
     
     Transport, Translation and Delivery
     
     TTD-1      (All) technologies and formats providing a transport 
     function should be capable of transporting flex-modal information 
     packages without distorting or removing any components of the package. 
      
     
     TTD-2      (All) technologies and formats providing a transport 
     function should be capable of supporting user directed routing of 
     specific information types to translators so that they automatically 
     show up in alternate formats or in a combination package (containing 
     both original format and translated format of the information)  
     
     Note:  A format is considered to be in accessible form if it can be 
     readily translated into accessible form by a free , readily available 
     (to the user) utility.
     
     
     Presentation of Information
     P-1b       Technologies that present information to the user for any 
     purpose (directly or indirectly) will do so in a fashion that can be 
     perceived by a person: 
     · without vision
     · with low vision and no hearing
     · without hearing
     · who is hard of hearing without vision
     · who cannot see or hear
     · cannot read
     · have limited skills in the language(s) used
     
     P-2        Technologies which present information in a time sequenced 
     manner should allow user to control the pace of delivery over a very 
     wide range (5 x normal), be able to freeze presentation at any time 
     and allow the information to be re-presented in whole or in part.  [as 
     is possible without undue burden] 
     
     P-3        Technologies which provide a presentation function should 
     avoid triggering seizures in users who are sensitive to presentational 
     stimulation (for example, people with photosensitive epilepsy who can 
     experience a seizure when confronted with flashing light in certain 
     frequency ranges)  
     
     P-4        Technologies that provide presentation functions that 
     cannot meet P1 through P3 for all users should provide a mechanism for 
     wirelessly connecting an alternate display (remote console).
        
     
     P-5        Technologies that are meant to be interacted with via voice 
     should also support TTY interaction.
     
     ---------------
     Notes:  a) "Any purpose" includes control feedback and incidental 
     information such as might come from sounds that a product makes that 
     is useful to operator.
     b) "Visual enhancements" include, but are not limited to, enlargement, 
     increased contrast, highlighting, and edge enhancement.
     c) "Auditory enhancements"  include, but are not limited to, 
     amplification, frequency shifting, signal noise ratio enhancement, 
     clarification
     
     
     
     Control 
     
     C-1        (All) Technologies that provide a control function should 
     allow operation of controls by users: 
     · without vision
     · low vision, no hearing
     · no hearing
     · hard of hearing, no vision
     · limited dexterity
     · limited reach
     · who can only interact with the product using words or text
     · who cannot respond within normal reaction time
     · cannot handle complex tasks
     · have limited skills in the language(s) used
     
     C-2        Where C-1 cannot be met for all users, products providing 
     controls should allow alternate control and display (remote console) 
     devices to be used wirelessly to control the product
     
     C-3        Technologies which have biometric identification mechanisms 
     should support alternative, non-biometric identification mechanisms. 
     
     
     
     Interaction 
     
     Technologies that allow or support interaction between people (real or 
     artificial) in either synchronous or asynchronous form should:
     
     I-1        support real time translation of the information streams 
     between different sensory modalities.
     I-2        Where I-1 cannot be met for all sensory modalities, provide 
     a means for connecting alternate technologies capable of translating 
     information into different modalities.
     I-3        Technologies that are meant to be interacted with via voice 
     should also support TTY interaction.
     
     **************************************
     The TAAC report:
     5.2.1. Accessible To and Usable By Individuals with Disabilities
     General Guideline A: Unless it would create an undue burden, products 
     shall be accessible to and usable by individuals with disabilities. 
     This includes people with visual disabilities (e.g., low vision and 
     blindness), hearing disabilities (e.g., hard of hearing, deafness), 
     people with physical disabilities (e.g., limited strength, reach or 
     manipulation, tremor, speech impairments, lack of sensation), people 
     with language or cognitive disabilities (e.g., reading disabilities, 
     thinking, remembering, sequencing disabilities), and other 
     disabilities (e.g., epilepsy, short stature), and individuals with any 
     combination of these disabling conditions (e.g., deaf-blindness). 
     Older individuals in particular commonly have multiple functional 
     limitations.
     Since there is no single interface design that accommodates all 
     disabilities, accessibility is likely to be accomplished through 
     technology  which emphasize interface flexibility to maximize user 
     configurability and multiple, alternative and redundant modalities of 
     input and output.
     
     5.3. LEVEL 2 GUIDELINES
     5.3.1. Input, Control and Mechanicals.
     5.3.1.1 (I-1). Locate, Identify, and Operate Controls without Vision.
     Guideline: 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.
     5.3.1.2 (I-2). Operate with Low Vision without Requiring Audio.
     Guideline: 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.
     5.3.1.3 (I-3). Operate without Color Perception or with Color 
     Perception Limitations.
     Guideline: Product input, control, mechanical and display functions 
     shall be fully operable via at least one mode that does not require 
     color perception.
     5.3.1.4 (I-4). Locate, Identify, and Operate Controls without Hearing.
     Guideline: 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.
     5.3.1.5 (I-5). Low Manipulation Requirement.
     Guideline: 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.
     5.3.1.6 (I-6). Operate with Limited Reach and Strength.
     Guideline: Product input, control and mechanical functions shall be 
     fully operable via at least one mode that is operable with limited 
     reach or strength.
     5.3.1.7 (I-7). Non-Time-Dependent Controls.
     Guideline: 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.
     5.3.1.8 (I-8). Identify and Operate Controls without Speech.
     Guideline: Product input and control functions shall be fully operable 
     via at least one mode that does not require speech.
     5.3.1.9 (I-9). Language and Cognitive Requirements.
     Guideline: 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.
     5.3.2. Output, Displays and Feedback.
     5.3.2.1 (O-1). Visual Information Available in Auditory Form.
     Guideline: All information (text, static or dynamic images and labels) 
     which is provided visually shall also be available in auditory form.
     5.3.2.2 (O-2). Make Visual Information Accessible to People with Low 
     Vision without Requiring Audio.
     Guideline: 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.
     5.3.2.3 (O-3). Access to Moving Text.
     Guideline: 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.
     5.3.2.4 (O-4). Visual and/or Tactile Availability of Auditory 
     Information.
     Guideline: 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.
     5.3.2.5 (O-5). Make Auditory Information Accessible to People who are 
     Hard of Hearing without Requiring Vision.
     Guideline: 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).
     CLOSELY RELATED GUIDELINES: See C-2 and C-3 dealing with hearing aid 
     compatibility. 
     5.3.2.6 (O-6). Prevention of Visually-Induced Seizures.
     Guideline: Visual displays shall be designed so as to avoid high 
     probability of triggering a seizure in an individual with 
     photo-sensitive epilepsy.
     5.3.2.7 (O-7). Prevention of Sound-Induced Seizures.
     Guideline: 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.
     5.3.2.8 (O-8). Audio Cutoff.
     Guideline: 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.
     5.3.4. Compatibility Guidelines.
     5.3.4.1 (C-1). External Electronic Access to All Information and 
     Control Mechanisms.
     Guideline: Where readily achievable,
     1. All information needed for the operation of a product (including 
     output, alerts, labels, on-line help, and documentation) shall be 
     available in a standard electronic text format on a cross-industry 
     standard port;
     2. All input to and control of a product shall allow for real time 
     operation via electronic text input into a cross-industry standard 
     external port and in cross-industry standard format; and 
     3. The port used for 1 and 2 shall not require manipulation of a 
     connector by the user. 
     5.3.4.2 (C-2). Connection Point for External Audio Processing Devices.
     Guideline: Products providing auditory output shall provide the 
     auditory signal via an industry standard connector and signal level.
     5.3.4.3 (C-3). Hearing Aid Coupling.
     Guideline: 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.
     5.3.4.4 (C-4). Non-Interference with Hearing Technologies.
     Guideline: 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.
     5.3.4.5 (C-5). Prosthetic Compatibility of Controls.
     Guideline: Touchscreen and touch-operated controls shall be able to be 
     activated without requiring body contact or close body proximity.
     5.3.4.6 (C-6). Text Telephone Connectability.
     Guideline: 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.
     5.3.4.7 (C-7). Text Telephone Signal Compatibility.
     Guideline: 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.
     
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