- Provision Requirements are design elements necessary for product conformance to the Section 508 provision.
- Recommended Practices are design approaches that augment or exceed the 508 provision requirement and enhance usability and accessibility.
“Electronic and information technology covered by section 508 must comply with each of the relevant sections of this part . For example, a computer and its software programs would be required to comply with §1194.26, Desktop and portable computers, §1194.21, Software applications and operating systems, and the functional performance criteria in §1194.31.”The products affected by the provisions governing Telecommunications Products extend from the traditional telephone to a wide variety of new and emerging products. The convergence of telecommunications and information technology is blurring the line between different product types as a variety of new and innovative products are created. Section 508 was designed to be flexible, assuring that all electronic and information technology procured by the government is accessible and allowing clear and common sense application of its various provisions. Common sense and flexibility should be utilized in interpreting the suggested guidance delineated within this technical assistance document. Therefore, provisions from both Subpart B as well as Subpart C of the 508 standards may apply to certain products or services. For example, using only 1194.23 (the Telecommunications Products provisions), it is possible to design a touch screen-only product (with no keypad and no voice output) that would be completely inaccessible to people who are blind. However, applying the provisions from 1194.31 (Functional Performance Criteria) would make the product conforming to the Section 508 standards. The term “Telecommunications Function” is derived from the definition of telecommunications and related terms. Both Section 508 (of the Rehabilitation Act) and Section 255 (of the Telecommunications Act) use this definition, which reads:
Telecommunications: 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.This definition is utilized extensively in law and regulations affecting telecommunications products. Therefore, there exists substantial legislative, regulatory, and case history defining its terms and scope. Other related definitions, derived from the Telecommunications Accessibility Guidelines for Section 255 of the 1996 Telecommunications Act are:
Customer premises equipment: Equipment employed on the premises of a person (other than a carrier) to originate, route, or terminate telecommunications. Telecommunications equipment: Equipment, other than customer premises equipment, used by a carrier to provide telecommunications services, and includes software integral to such equipment (including upgrades). Telecommunications service: 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.Again, products generally have primary functions that will be covered by one of the six technical areas in Subpart B. However, products often have features that may be covered in other sections of Subpart B as well as Subpart C. Some examples of how the Telecommunications Products provisions should be applied will now be given to assist in further clarifying the correct application of these provisions. Three types of products will be used to illustrate how the provisions should apply. The first example is a typical desktop telephone with answering machine capability. The second is a self-contained, single-function FAX machine. The third is a complex “All-in-One” machine that includes FAX, scanner, copier, and printer. The unit connects to a personal computer and contains software to be loaded on the personal computer. 1. A typical desktop telephone with answering machine is clearly covered by section 1194.23 because its primary function is to provide telecommunications functionality. All parts of 1194.23 apply to this product, as do all parts of 1194.31. Provisions from other technical sections of 508 may also apply based on the telephone design and features.
§1194.25(b) Timed Responses
§1194.25(c) Touchscreens and Controls
§1194.25(d) Biometric Forms/User ID
§1194.25(e) Auditory Output
§1194.25(f) Volume Control
§1194.25(g) Color Coding
§1194.25(h) Color and Contrast Settings
§1194.25(i) Screen Flicker
§1194.25(j) Operable Controls
Telecommunications products or systems 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. Microphones shall be capable of being turned on and off to allow the user to intermix speech with TTY use.
|§1194.23(b) Telecommunications products which include voice communication functionality shall support all commonly used cross-manufacturer non-proprietary standard TTY signal protocols.|
|§1194.23(c) Voice mail, auto-attendant, and interactive voice response telecommunications systems shall be usable by TTY users with their TTYs.|
|§1194.23(d) Voice mail, messaging, auto-attendant, and interactive voice response telecommunications systems that require a response from a user within a time interval, shall give an alert when the time interval is about to run out, and shall provide sufficient time for the user to indicate more time is required.|
|§1194.23(e) Where provided, caller identification and similar telecommunications functions shall also be available for users of TTYs, and for users who cannot see displays.|
|§1194.23(f) For transmitted voice signals, telecommunications products shall provide a gain adjustable up to a minimum of 20 dB. For incremental volume control, at least one intermediate step of 12 dB of gain shall be provided.|
|§1194.23(g) If the telecommunications product allows a user to adjust the receive volume, a function shall be provided to automatically reset the volume to the default level after every use.|
|§1194.23(h) Where a telecommunications product delivers output by an audio transducer which is normally held up to the ear, a means for effective magnetic wireless coupling to hearing technologies shall be provided.|
|§1194.23(i) Interference to hearing technologies (including hearing aids, cochlear implants, and assistive listening devices) shall be reduced to the lowes Arial">t possible level that allows a user of hearing technologies to utilize the telecommunications product.|
|§1194.23(j) Products that transmit or conduct information or communication, shall pass through cross-manufacturer, non-proprietary, industry-standard codes, translation protocols, formats or other information necessary to provide the information or communication in a usable format. Technologies which use encoding, signal compression, format transformation, or similar techniques shall not remove information needed for access or shall restore it upon delivery.|
|§1194.23(k) Products which have mechanically operated controls or keys, shall comply with the following: (1) Controls and keys shall be tactilely discernible without activating the controls or keys. (2) Controls and keys shall be operable with one hand and shall not require tight grasping, pinching, or twisting of the wrist. The force required to activate controls and keys shall be 5 lbs. (22.2 N) maximum. (3) If key repeat is supported, the delay before repeat shall be adjustable to at least 2 seconds. Key repeat rate shall be adjustable to 2 seconds per character. (4) The status of all locking or toggle controls or keys shall be visually discernible, and discernible either through touch or sound.|
(1) The volume reset override switch shall be labeled as such and located on the telephone in such a way as to not be accessible to accidental engagement; (2) A bright indicator light shall be prominently displayed on the front of the telephone and shall light up when the override is engaged and the telephone is placed in an off-hook condition; (3) Next to the light shall be a warning that the amplification is at a high level; (4) A caution on the use of the volume reset override switch shall be included in the users’ manual; and (5) The telephone shall include a warning printed in Braille that can be securely attached to the back of the handset, or, if the telephone has only a headset, above the dial buttons, to indicate that a high volume setting may be engaged.Design Guidance
- Positioning the antenna away from the ear area.
- Reducing power.
- Modifying the antenna to reduce RF currents in the area near the user’s ear.
- Using a clamshell design that moves the antenna away and partially shields it.
- Providing the user with ability to turn off backlighting.
- Inserting shielding in the wireless/cellular digital telephone.
- Replacing an omni-directional antenna with a directional antenna.
- Study the effects of cordless (landline) telephone products on hearing technologies and ameliorate interference. Digital cordless phones have been reported to interfere with some hearing aids. Specifically, vendors could test products and report on the extent to which they result in interference to hearing technologies when the cochlear implant or hearing aid is in microphone mode, and when it is in telecoil mode.
(1) Controls and keys shall be tactilely discernible without activating the controls or keys. (2) Controls and keys shall be operable with one hand and shall not require tight grasping, pinching, or twisting of the wrist. The force required to activate controls and keys shall be 5 lbs. (22.2 N) maximum. (3) If key repeat is supported, the delay before repeat shall be adjustable to at least 2 seconds. Key repeat rate shall be adjustable to 2 seconds per character. (4) The status of all locking or toggle controls or keys shall be visually discernible, and discernible either through touch or sound.Introduction & Background These provisions apply to user operable controls, which are components of a product that are operated by physical contact. Typically, the control panel or user interface, and their major components, buttons, keys, and knobs, are the primary items of concern. However, mechanically operated controls such as latches are also covered – as long as they require contact for “normal operation”. Examples of normal operation would include selecting features and pressing keys. Operable controls required for maintenance, service, repair, installation, and configuration or occasional monitoring are not covered by this provision. An example would be an RJ-11 plug that may be connected into a jack only one time. Since section “k” contains 4 provisions, each of those provisions will be addressed separately within this area. Each provision will have its own Requirements and Recommendations sections. Provision 1194.23(k)(1) Controls and keys shall be tactilely discernible without activating the controls or keys. Design Guidance What is meant by 'tactilely discernible'? Individual keys should be locatable and distinguishable from the product surface and adjacent keys by touch. Conformance with this provision can be accomplished by using various shapes, spacing, or tactile markings. The normal desktop computer keyboard, for example, would meet this provision because the tactile marks on the "j" and "f" keys permit a user to locate all other keys tactilely from these landmarks and the edges of the keyboard. In addition, the physical spacing of the function, "num pad" and cursor keys make them easy to locate by touch. Many telephones also have a raised dot on the number 5 button, enabling them to orient their fingers around the 12 keys. Because touch is necessary to discern tactile features, this provision requires keyboards to allow exploration by touch that will not automatically activate a function based on mere contact. Fortunately, most keyboards require some pressure on individual keys in order to enable a keystroke. However, "capacitance" keyboards would not meet this provision because they react as soon as they are touched and have no raised marks or actual keys. They may not react at all when touched by a person with a prosthesis. A "membrane" keypad with keys that must be pressed can be made tactilely discernible by separating keys with raised ridges so that individual keys can be distinguished by touch. How are touch screens and other contact sensitive controls dealt with? This provision only applies to products that have mechanically operated controls or keys, such as standard telephone keypads and computer keyboards. It is not intended to apply to touch screens. Touch screens and other contact sensitive controls are not specifically prohibited by any of the provisions of 1194.23. However, since all devices need to meet 1194.31, the performance criteria, products that incorporate touchscreens or contact sensitive controls are only able to meet the 1194.31 criteria if an alternative way of operating them using tactilely discernable controls was provided. At this time, some telecommunications products with touch screens and other contact sensitive controls do not conform with this provision. For example, there are PDAs with telephone functionality and touch screens, as well as desk telephones with touch screen enhanced features that cannot be operated via tactile controls. Provision Requirements Controls and keys should be tactilely discernible without activating the controls or keys. Recommended Practices
 36 CFR 1194,
Electronic and Information Technology Accessibility Standards, Architectural
and Transportation Barriers Compliance Board, Published in the Federal
Register on December 21, 2000.
 Americans with Disabilities Act, 42 U.S.C. §§ 12101 et seq., (ADA).