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9 Self-Contained, Closed Products

9-1 Overview

9-1.1 Contents

This chapter contains the specific electronic and information technology (EIT) performance requirements related to the following subpart of Section 508:

EIT Technical Standard 1194.25, Self-Contained, Closed Products, Provisions (a) thru (j).

9-1.2 Summary

9-1.2.1 Technology

The term "self-contained" is used to define a class of information technology. Unlike personal computers, which can have assistive technology installed, closed products can be accessible only if they have been designed to be accessible by people with limited vision, mobility, or hearing.

The requirements in this chapter cover the following:

• Any products or systems that do not permit end-user-installed assistive technologies. Such products often involve input and output interactions that present accessibility challenges (e.g., touch screens, physical layout/positioning). Unlike personal, customizable devices, many products in this class of technology (kiosks, shared printers) are used by the general public.

• Since they cannot be customized, such closed products must be designed with the needed accessibility features for all users.

• Given the functional disabilities of mobility, hearing, speech, and vision, Subpart C (Functional Performance Criteria) defines the general goal for all closed products as follows: At least one mode of operation and information retrieval must be usable by a user with a disability.

• For self-contained, closed products to be accessible to blind people, the law specifies audio output will be provided to an external headset jack. Provision (a) clarifies that "personal headsets for private listening are not assistive technology."

• The following types of devices are named in the law:

• Information kiosks and information transaction machines: Equipment used by the public to transact business without personal interaction. The classic example of an information transaction machine is an ATM (automated [bank] teller machine). Banks have made considerable progress, resulting from ADA legislation and consequent lawsuits, in making ATM machines reasonably accessible.

• Copiers: Although early designs of copiers were primarily devices without electronic sophistication, newer designs often contain higher degrees of functionality, such as the ability to interface with desktop computers that can be made universally accessible.

• Printers: Like copiers, printers have extensive functions - many of which can be accessed by standard control panels displayed and updated from personal computers. To the extent that the control panels follow the standards described in Chapter 5, Software Applications and Operating Systems, these devices may be fully compliant.

• Calculators: Although most calculator functions are an integral part of PC application software and governed by the standards described in Chapter 5, Software Applications and Operating Systems, accessible calculators usable by people with disabilities can be acquired. Specialized procurement for a specific accommodation of an employee is a 504 solution rather than a 508 compliance decision. Information on possible alternate formats or modes can be noted when a non-accessible EIT purchase is made. For more information, see the FAQ on accessible calculators at Tech Connections (http://www.techconnections.org/resources/guides/ Calculators.cfm).

• Fax machines: Like copiers, fax machines have extensive functions - many of which can be accessed from standard control panels displayed and updated from personal computers. To the extent that the control panels follow the standards described in Chapter 5, Software Applications and Operating Systems, these devices may be fully compliant. It should be noted that many fax machines also support of telecommunications functions - that is, the ability to use an attached handset for a traditional voice call. When this functionality is present, the requirements in chapter 5 also apply.

• Similar types of electronic office equipment: The law states that this standard applies to, but is not limited to, the above listed devices. At the time of the drafting of the 508 standards, Personal Data Assistants (PDA devices) were, functionally, closed products - and were included in many discussions of the provisions in this chapter. According the questions and answers page on the GSA's Section 508 Web site: "This technology is `electronic and information technology' covered by Section 508 and the Access Board's standards. Most hand held devices currently fall in the category of `self contained closed products.' As technology advances, hand held devices may fall into other categories as well."
PDA devices: These devices, if they do not permit additional functions to be added, are closed products. PDA devices that can be modified (software development kit utilities enable the creation of new applications that run under a defined operating system), come under the standard for software applications and operating systems discussed in chapter 5. To the extent that a PDA has telecommunications functions, it comes under the standard discussed in Chapter 7, Telecommunications Products.

This standard in this chapter, 1194.25, covers a single class of technology: technology that is closed to the installation of software that can enable access. The provisions in this standard apply to a single device, devices that represent the convergence of multiple standards (e.g., a fax machine that supports voice communications), or to self-contained devices within a complex systems.

9-1.2.2 Audience

This chapter applies to anyone who buys or develops self-contained, closed products or systems for the Postal Service (i.e., Postal Service employees, suppliers, contractors, and business partners).

9-1.3 Structure and Use

Each part of this chapter describes the specific requirements that support one or more provisions in the technical standards for self-contained, closed products. The technical standards of Section 508 were written primarily from a technology perspective. The Postal Service may consolidate some provisions to help Postal Service employees and business partners understand Postal Service compliance requirements from the perspective of designing for accessibility. Each specific requirement includes a rationale, techniques, testing methods, and references as shown below in section 9-2.

9-1, Overview

9-2, Usability Without Assistive Technology (Provision §1194.25a)

• Rationale

• Techniques

• Testing

• References

9-3, Allowing Sufficient Time (Provision §1194.25b)

9-4, Touch Screens or Contact-Sensitive controls (Provision §1194.25c)

9-5, Biometric Forms of User Identification or Control (Provision §1194.25d)

9-6, Auditory Output (Provision §1194.25e)

9-7, Voice Output in a Public Area (Provision §1194.25f)

9-8, Color Coding (Provision §1194.25g)

9-9, Range of Color Selections (Provision §1194.25h)

9-10, Screen Flickering (Provision §1194.25i)

9-11, Operable controls on Freestanding, Non-Portable devices (Provision §1194.25j)

Appendix 9-A, Checklist

9-1.4 Introduction to Self-Contained, Closed Product Accessibility

Products covered by this standard present challenges from the perspective of device size and dimensions (e.g., can someone in a wheelchair reach the controls of a copier?), user input (what touch screen area or button controls which function?), user feedback (did the function activate? what is the error message?). These challenges vary by type of physical impairment:

• Deaf persons and hearing-impaired (but not deaf) persons are typically faced with challenges such as audible beeps that have no visual counterpart

• Visually impaired and blind persons are typically faced with challenges such as:

• Identification of buttons and controls for input.

• Interaction with an alternative to a touch screen (keypad or alternative).

• Enlarged print or synthetic speech to convey device output.

• Dexterity or mobility-impaired persons are typically faced with challenges such as:

• Control functions located beyond range of user's reach.

• Lack of timeout controls and saving of user input upon timeout.

• Inaccessible hardware keys, controls and switches.

• Lack of error-recovery features.

• Reliance on voice or manual input.

9-1.5 General Requirements

Accessibility is accomplished by purchasing or developing self-contained, closed products that accommodate the widest range of users, including those with disabilities. Listed below are some general requirements that will help the Postal Service ensure continued accessibility of self-contained, closed products:

• The Postal Service will develop and procure self-contained, closed products that take advantage of built-in accessibility features when those features are available to both end users and product developers.

• The Postal Service will procure or develop self-contained, closed products that recognize and maximize the capabilities of the accessibility features installed and activated by a user via an attached personal computer (e.g., operating system features and assistive technologies that enable control of dialogue boxes to activate device controls). Postal Service self-contained, closed products procurement personnel and developers should do the following:

• Buy or build products that support self-contained, closed products standards. Accessibility features are often integrated with these standards in order to ensure accessibility in self-contained, closed products (standard kiosk shapes have been developed to meet appropriate reach specifications - provision j). Standards related to each specific requirement are shown in the "References" area under that requirement.

• Where possible, use standard hardware and software controls instead of custom controls. These standard controls often already support product accessibility features. Using them will often eliminate the need for additional configuration or programming to provide explicit accessibility support, unless the behavior of the standard controls has been enhanced. Full-screen keyboards are well understood. Many self-contained, closed products support the attachment of such input devices. Telephone-style key clusters are another de facto standard.

• Provide flexibility in using a variety of input methods and output methods. Many self-contained, closed products support only one mode of operation. When such devices can be added to a network, people with disabilities may be able to access these products from a personal computer that has assistive technology.

• Consult with accessibility experts and representatives of the disability community when developing unique devices. Assistive technology products for personal computers represent standard solutions to open products. Since there are no comparable, market-tested standard solutions for self-contained, closed products, each new development provides an opportunity to demonstrate the Postal Service's intent to provide the most accessible solution. Accessibility experts and representatives of the disability community are a resource that can vastly enhance the designs of engineers and solution architects.

Finally, Postal Service employees are required to register certain software applications and operating systems in the Enterprise Information Repository (EIR) (http://eir). This information will be used to report compliance and includes any related Section 508 noncompliance issues.

9-1.6 Testing for Compliance

When testing self-contained, closed products for compliance, it is crucial to be aware of the end-user environment. This includes an understanding of the product's stated accessibility features in the context of Postal Service use.

Manual testing, using the testing methods described in this chapter, is mandatory, because it simulates use by disabled users. Automated testing tools or integrated development environment (IDE) features, useful in open environments, are of little value for closed products. Simulation of use by people with disabilities provides the clearest indication of accessibility.

9-2 Usability Without Assistive Technology

Self-contained products must be usable by people with disabilities without requiring an end user to attach assistive technology to the product. Personal headsets for private listening are not assistive technology (§1194.25, Provision a).

9-2.1 Rationale

Self-contained products, unlike personal computers, do not support assistive technology software. Consequently, unlike other provisions that allow a product to meet the standards by being compatible with assistive technology, this provision requires self-contained, closed products to contain built-in accessibility. Most of the technical standards for Subpart B of the law - 1194.21 Software applications and operating systems; 1194.22, Web-based Intranet and Internet information and applications; 1194.24, Video and multimedia products (to the extent that they are embedded in a Web page or application); 1194.26, Desktop and portable computers) - assume that part of the solution to accessibility is the installation of assistive technology (e.g., speech synthesis or voice recognition). For people with disabilities to use self-contained products, the functionality of assistive technology must be an integral part of the design. That is, the functional performance criteria of Subpart C (1194.31) apply: that input and output must be available for people with limited mobility, hearing, speech, and vision.

A personal headset is considered a personal device for audio output, since it is not considered installed assistive technology. Headsets might be also used for privacy in addition to accessibility reasons.

9-2.2 Techniques

9-2.2.1 For Kiosks

• ITM Kiosk without full PC interface: For kiosks that have no full PC functionality (e.g., an ATM), the device should not only allow user input with limited mobility but should also include a headset jack that provides speech output of all screen instructions, data, and key-press locations.

• ITM Kiosk with full PC interface: Some kiosk implementations are created by placing a PC in a kiosk enclosure. Such implementations pose a challenge in that they provide access to operating system functions, application functions, and Internet access. These systems can have assistive technology software (speech synthesis, screen magnification, voice recognition) installed. However, they are not configured for a specific person with a specific disability - as is the case of a personal workstation allocated to a specific Postal Service employee. Their public, multi-user access makes disability-specific configuration difficult. One solution is to add a large print and voice-output menu selection at the start of each session: The menu would be similar to the language-choice menu on ATMs, which enables the user to select an assistive device configuration for the session.

9-2.2.2 For Copiers, Printers, Calculators, Fax Machines:

• COTS without PC interface: For simple (Commercial Off The Shelf) devices that have no interface via a connected PC (either directly attached to the device or indirectly via a network), research of a COTS vendor's VPAT specification will enable the Postal Service to find the most compliant device that needs the business requirements.

• COTS / non-standard with a PC interface: For high-end devices that do have an interface via a connected PC (either directly attached or on the network), research of vendor's VPAT specification will enable the Postal Service to find the most compliant device that meets the business requirements through a software interface that complies with the provisions of Chapter 5, Software Applications and Operating Systems).

9-2.2.3 For PDAs

• For PDAs that are closed systems: Despite the difficulty of finding compliant devices in this category, the essential functions can often be adapted. See the references listed below.

• For PDAs that have operating systems: As of the draft date of this publication, no existing PDA has the rich array of assistive technology found in a PC platform. However, AT software for these devices can be developed. VPAT comparison and business requirements should drive a continual advance toward full compliance.

9-2.3 Testing

a. Inspect the product to identify if the device provides a function allowing access, as specified, by persons with limited vision, hearing, or mobility.

b. If the voice output is designed to be usable by people who are blind, perform the following tests on the device with all visible outputs disabled.

(1) Evaluate a prototype with accessibility experts.

(2) Evaluate functions with an experienced user.

(3) Evaluate functions with a novice user.

c. If a touch screen is used for user input, insure that all functions can be used by alternate key-press system.

d. If an exception was taken when procuring a device that is not fully accessible, define the alternate format or alternate method needed to provide equivalent access to people with disabilities who can not readily use the device.

9-2.4 References

The following references apply to the specific requirements stated here:

• Trace Center Research on Kiosk accommodation (Note sub-page for unique approach: EZ Access keys)
http://www.tracecenter.org/world/kiosks/

• Guide to the Section 508 Standards for Electronic and Information Technology, Self-Contained, Closed Products (1194.25).
http://www.access-board.gov/sec508/guide/1194.25.htm

• PDA references
California State University, Northridge
http://www.csun.edu/cod/conf/2004/proceedings/274.htm
TechDis Accessibility and Generic Features of a PDA
http://www.techdis.ac.uk/PDA/intro3.htm
National Center on Accessible Information Technology in Education
http://www.washington.edu/accessit/articles?62
palmOne Accessibility Program
http://www.palmone.com/us/company/corporate/pap/
University of Toronto
http://learningportal.utoronto.ca/technology/pda.html

9-3 Allowing Sufficient Time

When a timed response is required, the user must be alerted and given sufficient time to indicate more time is required. (§1194.25, Provision b).

9-3.1 Rationale

When a system requires a user to respond within a specified time, some people with mobility or dexterity limitations will be unable to complete input functions. This provision addresses access problems that can arise when self-contained, closed products require a response from a user within a certain time. For example, persons with dexterity-related disabilities might find entering information, such as a Social Security number, within a specified time to be difficult or impossible. This provision requires that users must be notified when a process is about to time out and must be given an opportunity to answer a prompt asking whether additional time is needed.

Since some self-contained, closed products do not require a timed user response, this provision does not apply to them. However, in some devices (e.g., entry of receiving fax number into a fax machine), the provision applies.

The provision has a pervasive application within Section 508. A corresponding provision exists in the Web standard, where assistive technology can be installed (Chapter 6, Web-based Information and Applications Accessibility Guidelines, 1194.22 (p)) and also in the telecommunications standard, specifically IVR interactions (Chapter 7, Telecommunications Products, 1194.23 (c)).

9-3.2 Techniques

9-3.2.1 For Kiosks:

• ITM Kiosk without full PC interface: For kiosks that have no full PC functionality (e.g., an ATM machine), if the functions of the machine include a timeout, users must be notified when a process is about to time out and must be given an opportunity to answer a prompt asking whether additional time is needed.

• ITM Kiosk with full PC interface: Some kiosk implementations are created by placing a PC in a kiosk enclosure. Such implementations pose a challenge in that they provide access to operating system functions, application functions, and Web site access. Refer to provision (a) for details.

9-3.2.2 For Copiers, Printers, Calculators, and Fax Machines:

• COTS without PC interface: Refer to provision (a) for details.

• COTS / non-standard with a PC interface: For high-end devices that have an interface via a connected PC (either directly attached or on the network), and fax interfaces, insure that the dialog box on the PC follows the appropriate standard in chapter 9.

9-3.2.3 For PDAs:

Refer to provision (a) for details.

9-3.3 Testing

a. If the device has a timeout, ensure that both a prompt is given and that more time is available.

b. Performance - For each case of a required response within a time interval does the product meet all of the following criteria:

(1) Does the product give an alert (which is accessible) when the time interval is about to run out?

(2) Does the product allow the user to indicate that more time is required?

(3) Does the product provide sufficient time for the user to indicate that more time is required?

(4) Does the product provide additional time as requested?

c. If an exception was taken when procuring a device that is not fully accessible, define the alternate format or alternate method needed to provide equivalent access to people with disabilities who can not readily use the device.

9-3.4 References

The following references apply to the specific requirements stated in this section:

• Trace Center Research on Kiosk accommodation (Note sub-page for unique approach: EZ Access keys)
http://www.tracecenter.org/world/kiosks/

• Guide to the Section 508 Standards for Electronic and Information Technology, Self-Contained, Closed Products (1194.25)
http://www.access-board.gov/sec508/guide/1194.25.htm

9-4 Touch Screens or Contact-Sensitive Controls

Where a product uses touch screens or contact-sensitive controls, an input method must be provided that complies with §1194.23 (k) (1) through (4). (§1194.25, Provision c).

9-4.1 Rationale

Touch screens and other controls that operate by sensing a person's touch pose access problems for a range of persons with disabilities. This provision does not prohibit the use of touch screens and contact-sensitive controls, but, as modified, the final rule requires a redundant set of controls that can be used by persons who can not access touch screens.

In some instances, a personal computer with a touch screen will be enclosed in a display and used as an "information kiosk." This provision does not prohibit the use of a kiosk touchscreens, but requires a redundant set of controls that can be used by persons whose vision or mobility prevents interaction with touch screens.

The standard for telecommunications products [§1194.23 (k)] requires that touch screens or contact-sensitive controls comply with these four requirements:

• Requirement (1) specifies that individual keys be locatable and distinguishable from the product surface and adjacent keys by touch. This provision applies only to products that have mechanically operated controls or keys, such as ATM/ITM keypads and device keyboards. However, since all devices need to meet the Functional Performance Criteria described in Section 4-2.1, Specific Standards and Functional Performance Criteria, products that incorporate touch screens or contact-sensitive controls are able to meet these criteria only if an alternative way of operating them using tactilely discernable controls is provided. For example, PDAs with telephone functionality and touch screens and desk telephones with touch-screen enhanced features that cannot be operated via tactile controls would come under this provision.

• Requirement (2) specifies that controls and keys must be operable with one hand and that they must not require tight grasping, pinching, or twisting of the wrist. Individuals with tremor, cerebral palsy, or other disabilities may have difficulty operating systems that require fine motor control, a steady hand, or the use of both hands simultaneously for operation. Individuals with high spinal-cord injuries, arthritis, and other conditions may have difficulty operating controls that require significant strength. The requirement's force limit (5 pounds) is based on section 4.27.4 of the ADA Accessibility Guidelines.

• Requirement (3) requires that if key repeat is supported, the delay before repeat must be adjustable to at least 2 seconds. Key repeat rate must be adjustable to 2 seconds per character. This requirement addresses a challenge encountered by some people without fine motor coordination. Sometimes, they accidentally don't release a key fast enough and get several (auto-repeated) characters when they only intended to type one (because the key repeat was faster than they can move). This could potentially result in the same character displaying several times on the screen. It could also result in the same function repeating (e.g., sending the same fax multiple times.). The "key repeat" requirement applies only to controls that have a "key repeat" function.

• Requirement (4) specifies that the status of all locking or toggle controls or keys (e.g., "caps lock", "scroll lock", etc.) must be visually discernible, and discernible either through touch or sound. For example, adding audio patterns, such as ascending and descending pitch tones that indicate when a control is turned on or off, would alleviate the problem of a person who is blind inadvertently pressing the locking or toggle controls. Buttons that remain depressed when activated and switches with distinct positions may also meet this provision.

It should be noted that the rationale for physical access is also repeated in the desktop and portable computer standard discussed in Chapter 10, Desktop and Portable Computers, of this handbook.

9-4.2 Techniques

9-4.2.1 For Kiosks:

• ITM Kiosk without full PC interface: For kiosks that have no full PC functionality (e.g., an ATM), if a touch screen is used, an accessible set of controls also must be provided.

• ITM Kiosk with full PC interface: Some kiosk implementations are created by placing a PC in a kiosk enclosure. Such implementations pose a challenge in that they provide access to operating system functions, application functions, and Web site access. See section 9-2 above for details.

9-4.2.2 For Copiers, Printers, Calculators, and Fax Machines:

• COTS without PC interface: For simple devices that have no interface via a connected PC (either directly attached or on the network), all functions must be controllable by controls and keys that are tactilely discernable. Refer to Section 7-12, Controls and Keys.

• COTS / non-standard with a PC interface: For high-end devices that have an interface via a connected PC (either directly attached or on the network), refer to section 9-2 above for details.

9-4.2.3 For PDAs:

• For PDAs that are closed systems: Despite the difficulty of finding compliant devices in this category, many PDAs have touch screens and are thus governed by this provision. Some PDAs provide for the installation of a full keyboard as an alternate method of input.

• For PDAs that have operating systems: Refer to section 9-2 above for details.

9-4.3 Testing

a. Inspect the product to identify if the device provides a function allowing access as specified in terms of operation with limited vision, hearing, or mobility.

b. Operate all functions of the device without contact with the touch screen, performing the following tests.

(1) Evaluate a prototype with accessibility experts.

(2) Evaluate functions with an experienced user.

(3) Evaluate functions with a novice user.

c. If the text on the screen has an equivalent audio channel that communicates the text in a spoken form, turn off the screen, use a headset, and operate all functions of the device.

d. If an exception was taken when procuring a device that is not fully accessible, define the alternate format or alternate method needed to provide equivalent access to people with disabilities who can not readily use the device.

e. If the touch screen functions can be emulated by an attached PC, investigate control from a personal computer as an alternate mode of operation.

9-4.4 References

The following references are applicable to the specific requirements stated here:

• Trace Center Research on Kiosk accommodation (Note sub-page for unique approach: EZ Access keys)
http://www.tracecenter.org/world/kiosks/

• Guide to the Section 508 Standards for Electronic and Information Technology, Self-Contained, Closed Products (1194.25)
http://www.access-board.gov/sec508/guide/1194.25.htm

• Tiresias - International Information on Visual Disability, guidelines for tactile identifiers on keys
http://www.tiresias.org/guidelines/keys.htm

• Enable Tech: Tools to Consider - Keyboards
http://www.enabletech.ie/Tools2.html

• Section 4.27.4 of the ADA Accessibility Guidelines (ADAAG), codified as the ADA Standards for Accessible Design as part of the Department of Justice's regulation implementing title III of the ADA at 28 C.F.R. pt. 36, Appendix A Telecommunications Act Accessibility Guidelines
http://www.access-board.gov/adaag/html/adaag.htm#4.27

• Trace Research Center, University of Wisconsin, "Ergonomics of a Non-Visual Touchscreen Interface: A Case Study."
http://trace.wisc.edu/docs/touchscreen_ergonomics2000/ ergonomics.htm
This document provides information on touch screen interfaces for people who are blind or visually impaired.

9-5 Biometric Forms of User Identification or Control

When biometric forms of user identification or control are used, an alternative form of identification or activation that does not require the user to possess particular biological characteristics, must also be provided. (§1194.25, Provision d).

9-5.1 Rationale

Biometric controls refer to controls that are activated only if a particular biological feature of the end user exists and matches specific criteria (e.g., voiceprint, fingerprint, or retinal image).

Biometric controls are becoming more common, because they can provide a high level of security or offer increased efficiencies in user interaction with computer systems. Biometric controls are used for two primary purposes: security (i.e., user identification and authentication) and non-security commands or user input. One example is a high-security computer system or information transaction machine that uses retinal scanners or fingerprint identification controls to identify users before providing them access to personal or sensitive data. Another example is a portable computer that offers an optional voice command feature to allow the user access to various applications or data stored on the computer. In the latter example, the voice commands are a benefit because they help the user make selections or provide input more quickly or in a "hands-free" mode.

While biometric controls offer many benefits, they can present significant barriers to people with various disabilities. This requirement addresses this problem by requiring that when biometric controls are used, an alternate access method must be provided that does not compromise security and that does not require specific biological features (e.g., voiceprint, fingerprint, retinal scan) to activate or operate the controls.

Note: This provision is also part of the desktop and portable computer standard discussed in chapter 10 of this handbook.

9-5.2 Techniques

According to the Architectural and Transportation Barriers Compliance board, "The provision does not require a specific alternative. That selection is left up to the agency, which may choose a less expensive form of identification" (36 CFR Part 1194).

Some potential alternatives include the following:

• A shared desktop computer located in a plant management office uses a fingerprint scanner to provide secure access to highly confidential files for a select group of Postal Service employees. As an alternative to the fingerprint scan, the system provides an alternate access method by allowing the user to enter a password and answer some additional verification questions. This alternative access method is also beneficial for all users, either as a redundant check or in situations where the primary method is inadequate (e.g., when the fingerprint scanner ceases to work properly, or when users have a temporary disability such as a broken hand that is in a cast).

• A portable computer uses voice commands to allow users to activate key applications such as a contact database or calendar. As an alternative to the voice commands, the user can enter input using the computer keyboard.

9-5.3 Testing

a. Inspect the product to identify if the biometric control provides a function allowing access as specified in terms of operation with limited vision, hearing, or mobility.

b. If an exception was taken when procuring a device that is not fully accessible, define the alternate format or alternate method needed to provide equivalent access to people with disabilities who can not readily use the device.

9-5.4 References

The following references apply to the specific requirements stated in this section:

• Biometrics Resource Center Website at the National Institute for Standards and Technology
http://www.itl.nist.gov/div895/biometrics

• Guide to the Section 508 Standards for Electronic and Information Technology, Self-Contained, Closed Products (1194.25)
http://www.access-board.gov/sec508/guide/1194.25.htm

• Open Directory Project: Biometrics Links
http://dmoz.org/Computers/Security/Biometrics/

9-6 Auditory Output

When products provide auditory output, the audio signal must be provided at a standard signal level through an industry standard connector that will allow for private listening. The product must provide the ability to interrupt, pause, and restart the audio at anytime. (§1194.25, Provision e).

9-6.1 Rationale

This provision requires that when products use audio as a way to communicate information, the auditory signal must be available through an industry standard connector at a standard signal level. Individuals using personal headsets or similar audio-processing devices need a place to plug these devices into the product in a standard fashion. This gives the user the ability to listen privately to an audio presentation of information that is also presented visually. The product must also provide a method to pause, restart, and interrupt the flow of audio information.

The classic instance of this provision is the use of ATMs by blind people. If an ATM provides an audio rendition of the screen contents, instructions on how to turn on, pause, interrupt, and restart the audio must also be provided. This provision applies only to voice output. It does not require an audio output for devices that emit only "beeps and tones."

People who regularly use information transaction kiosks and require audio rather than visual output generally carry a portable headset (or other listening coupler) with them. Examples of common plugs on headsets include 3.5 mm plugs (the de facto standard in kiosks and used in most portable stereos), and 2.5 mm jacks (used in most cellular phones).

According to the Occupational Safety and Health Administration, and the American Speech, Language, and Hearing Association, 65 dB is the volume level for normal speech (see sections 7-7 and 7-8 of this handbook). Products that provide auditory output must have a feature that automatically resets the volume to the default level after every use. This is consistent with the similar provision addressing telecommunications products.

9-6.2 Techniques

9-6.2.1 For Kiosks:

• ITM Kiosk without full PC interface: Kiosks that have no full PC functionality (e.g., an ATM) require an audio equivalent to screen output.

• ITM Kiosk with full PC interface: See section 9-2.2.1 of this handbook for details.

9-6.2.2 For Copiers, Printers, Calculators, and Fax Machines

• COTS without PC interface: For simple devices that have no interface via a connected PC (either directly attached or on the network), audio output is not yet a standard feature.

• COTS / non-standard with a PC interface: See section 9-2.2.2 of this handbook for details.

9-6.2.3 For PDAs:

See section 9-2.2.3 of this handbook for details.

9-6.3 Testing

a. Inspect the product to identify if the device provides a function allowing access as specified in terms of operation with limited vision, hearing, or mobility.

b. As presently defined, this provision covers self-contained devices for which the output needs to be expressed as speech to an end user with a headset. Testing, therefore, is best done by operating the system with the screen turned off and headsets used as the output mode. Error conditions and introductory text prompts should also be clear.

c. If an exception was taken when procuring a device that is not fully accessible, define the alternate format or method needed to provide equivalent access to people with disabilities who can not readily use the device.

9-6.4 References

The following references apply to the specific requirements stated in this section:

• Trace Center Research on Kiosk accommodation (Note sub-page for unique approach: EZ Access keys)
http://www.tracecenter.org/world/kiosks/

• Guide to the Section 508 Standards for Electronic and Information Technology, Self-Contained, Closed Products (1194.25)
http://www.access-board.gov/sec508/guide/1194.25.htm

9-7 Voice Output in a Public Area

When products deliver voice output in a public area, incremental volume control must be provided with output amplification up to a level of at least 65 dB. Where the ambient noise level of the environment is above 45 dB, a volume gain of at least 20 dB above the ambient level must be user selectable. A function must be provided to automatically reset the volume to the default level after every use (§1194.25, Provision f).

9-7.1 Rationale

People who are hard of hearing, generally speaking, can understand speech only if voice levels are 20 dB above the ambient sound level. This means that as long as the noise level in the surrounding environment is below 45 dB, a 65 dB output level would be sufficient. To comply with this position, a Postal Service engineer (or other appropriate responsible party) must determine the volume of background noise at the location of the machine (specifically whether it is above 45 dB), so that the machine can be selected or calibrated for that specific environment. To comply with this provision, consideration needs to be given to the fact that ambient noise levels may vary in certain environments.

9-7.2 Techniques

This provision is an engineering specification rather than a performance standard. Therefore, the technique is to insure that the specification is met.

9-7.3 Testing

a. Verify that the voice output is appropriate to the ambient noise level.

b. Insure that the audio is adjustable, and that the accessible controls are clearly marked.

c. Verify that the product automatically resets the volume to the default level after every use.

d. If an exception was taken when procuring a device that is not fully accessible, define the alternate format or alternate method needed to provide equivalent access to people with disabilities who can not readily use the device.

9-7.4 References

The following references are applicable to the specific requirements stated here:

• Guide to the Section 508 Standards for Electronic and Information Technology, Self-Contained, Closed Products (1194.25)
http://www.access-board.gov/sec508/guide/1194.25.htm

• Voting Systems Standards, April 30, 2002, Federal Election Commission (FEC)
http://www.fec.gov/pages/vssfinal/vss.html

9-8 Color Coding

Color coding must not be used as the only means of conveying information, indicating an action, prompting a response, or distinguishing a visual element. (§1194.25, Provision g).

9-8.1 Rationale

This provision defines a requirement for self-contained devices with color displays and keys/buttons in which color indicates meaning. Any display that requires a user to distinguish among otherwise identical red and blue objects for different functions (e.g., printing a document or saving a file) would pose problems for anyone who is color blind. Displays must, therefore, not rely on color as the sole indicator of meaning for a visual element. (See Section 5-10, Software Applications and Operating Systems: Color Coding.)

This provision does not prohibit the use of color to enhance identification of important features. It does, however, require that some other method of identification, such as text labels, be combined with the use of color whenever a visual object conveys information.

9-8.2 Techniques

Purchased products should be the most compliant available; developed products must be compliant. If color displays are developed by the Postal Service, they must meet all provisions.

Self-contained, closed products must not use color alone to convey information, indicate an action, prompt a response, or distinguish an important visual event. For example, do not instruct a user to "select the blue icon from the list."

Instead, instruct the user without referring to color alone. If color is used, provide an accessible alternate format or method, such as a textual label or text formatting, to convey the equivalent information (e.g., use color and boldface text to indicate highlighted information).

9-8.3 Testing

a. Inspect the product to determine whether it follows the convention of object identification that uses color as only one of the distinguishing features.

b. If an exception was taken when procuring a device that is not fully accessible, define the alternate format or alternate method needed to provide equivalent access to people with disabilities who can not readily use the device.

9-8.4 References

The following references apply to the specific requirements listed in this section:

• Web/Computer Color Chart for the Color Blind
http://www.toledo-bend.com/colorblind/colortable.html

• Guide to the Section 508 Standards for Electronic and Information Technology, Self-Contained, Closed Products (1194.25)
http://www.access-board.gov/sec508/guide/1194.25.htm

9-9 Range Of Color Selections

When a product permits a user to adjust color and contrast settings, a range of color selections capable of producing a variety of contrast levels must be provided (§1194.25, Provision h).

9-9.1 Rationale

This provision applies to those products that already allow a user to adjust screen colors and contrast.

This provision requires more than just providing color choices. When shades of gray (black and white contrast) are available, this provision also applies. The available choices must also allow for different levels of contrast. Many people experience a high degree of sensitivity to bright displays. People with this condition cannot focus on a bright screen for long because they will soon be unable to distinguish individual letters. An overly bright background causes a visual "white-out." To alleviate this problem, the user must be able to select a softer background and appropriate foreground colors. On the other hand, many visually impaired people can work most efficiently when the screen is set with very sharp contrast settings. Because individual needs vary so much, a program must have a variety of color and contrast settings. (See Section 5-8, Software Applications and Operating Systems: User-Selected Display Attributes, Color, and Contrast.)

9-9.2 Techniques

Purchased products should be the most compliant available; developed products must be compliant. If color displays are developed by the Postal Service, they must meet all provisions.

Self-contained, closed products, when they provide contrast adjustments, must provide a full range of adjustment.

9-9.3 Testing

a. Inspect the product to determine whether it follows the convention of appropriate contrast adjustment.

b. If an exception was taken when procuring a device that is not fully accessible, define the alternate format or alternate method needed to provide equivalent access to people with disabilities who can not readily use the device.

9-9.4 References

The following references are applicable to the specific requirements stated here:

• Web/Computer Color Chart for the Color Blind
http://www.toledo-bend.com/colorblind/colortable.html

• Guide to the Section 508 Standards for Electronic and Information Technology, Self-Contained, Closed Products (1194.25)
http://www.access-board.gov/sec508/guide/1194.25.htm

9-10 Screen Flickering

Products must be designed to avoid causing the screen to flicker with a frequency greater than 2 Hz and lower than 55 Hz. (§1194.25, Provision i).

9-10.1 Rationale

This requirement is specified because some individuals with photosensitive epilepsy can have a seizure triggered by displays that flicker or flash, particularly if the flash has a high intensity and is within certain frequency ranges. The 2 Hz limit was chosen to be consistent with proposed revisions to the ADA Accessibility Guidelines which, in turn, are being harmonized with the International Code Council (ICC)/ANSI A117 standard, "Accessible and Usable Buildings and Facilities", ICC/ANSI A117.1-1998, which refers to a 2 Hz limit. An upper limit was identified at 55 Hz. See Section 5-11, Software Applications and Operating Systems: Video Frequency.

9-10.2 Techniques

Purchased products should be the most compliant available; developed products must be compliant. If displays contain elements that flicker, they must adhere to the specification of this provision.

9-10.3 Testing

a. Search for flashing or blinking text, objects, or other user interface elements. Also, search for elements that employ a quick change from dark to light (similar to strobe lights).

b. Use an electronic tester (i.e., screen calibrator) or a software test feature to determine the time interval between flashes for all blinking or flashing user interface elements.

c. If any flashing or blinking objects cannot be tested, they will need to be omitted from the software application altogether.

d. Adjust or fix any flashing or blinking elements that have an unacceptable Hertz range or that have a high level of contrast between states. Ensure that flashing areas of the screen are kept to as small an area as possible.

e. For all blinking or flashing elements that are included, a method must also be offered that allows users to change the elements' flash rate or disable them altogether.

9-10.4 References

The following references are applicable to the specific requirements stated here:

• Epilepsy Action: Photosensitive Epilepsy
http://www.epilepsy.org.uk/info/photo.html

• International Code Council (ICC)/ANSI A117 standard, "Accessible and Usable Buildings and Facilities," ICC/ANSI A117.1-199
http://www.iccsafe.org/dyn/prod/9033S98.html

• Guide to the Section 508 Standards for Electronic and Information Technology, Self-Contained, Closed Products (1194.25)
http://www.access-board.gov/sec508/guide/1194.25.htm

9-11 Operable Controls on Freestanding, Non-Portable Devices

Products which are freestanding, nonportable, and intended to be used in one location and which have operable controls must comply with the following:

a. The position of any operable control must be determined with respect to a vertical plane, which is 48 inches in length, centered on the operable control, and at the maximum protrusion of the product within the 48-inch length (see Figure A of this part).

b. Where any operable control is 10 inches or less behind the reference plane, the height must be 54 inches maximum and 15 inches minimum above the floor.

c. Where any operable control is more than 10 inches and not more than 24 inches behind the reference plane, the height must be 46 inches maximum and 15 inches minimum above the floor.

d. Operable controls must not be more than 24 inches behind the reference plane (see Figure B of this part).

Figure A

Figure A above illustrates two bird's-eye views of the Vertical Plane Relative to Operative Control. In both views, the vertical plane is centered on the control area. In the first view, the vertical plane is set back from the control area by a protrusion on the device. In the second view, there are no protrusions on the device and the vertical plane is right up against the control area

Figure B

Figure B above illustrates two front views of Height of Operative Control Relative to a Vertical Plane. The first view illustrates a reach of no more than 10 inches deep with the control area between 15 and 54 inches. The second view illustrates a reach greater than 10 inches but not more than 24 inches deep with the control area between 15 and 46 inches.

(§1194.25, Provision j).

9-11.1 Rationale

Provisions 1-4 above apply to the physical characteristics of large office equipment, including reach ranges and the general physical accessibility of controls and features. Examples of these products include, but are not limited to, copiers, information kiosks, and floor-standing printers. These provisions are based on the Americans with Disabilities Act Accessibility Guidelines (ADAAG 4.2 Space Allowance and Reach Ranges).

Some examples may clarify the applicable standards:

• If a document feeder is built within the technical specifications, but access to the platen glass is outside the reach range, a copier would not be in compliance with this provision. Users need to be able to access both the paper feed and the platen glass. Some documents are too small or too large to be run through a paper feed.

• If copier paper trays are not reachable, on the other hand, the copier may still be compliant, because replacing paper is considered to be a maintenance function, not a normal daily operation. Operable controls include, but are not limited to, mechanically operated controls, input and output trays, card slots, keyboards, or key pads. The standards apply to products in their normal operation rather than to maintenance, repair, or occasional monitoring. Other tasks, such as initial setup and configuration, adding and replacing parts, and repair and service tasks are also not covered by the standards.

9-11.2 Techniques

Purchased products should be the most compliant available; developed products must be compliant. If kiosks are developed by the Postal Service, they must meet all provisions.

This provision is essentially an objective specification. Figures are given in appendix 9-A.

9-11.3 Testing

a. Inspect the product to identify its measurements.

b. If an exception was taken when procuring a device that is not fully accessible, define the alternate method needed to provide equivalent access to people with disabilities who can not readily use the device.

9-11.4 References

The following references are applicable to the specific requirements stated here:

• ADAAG 4.2 Space Allowance and Reach Ranges
http://www.adaportal.org/Facility_Access/ADAAG/Appendix/ADAAG_Appendix_4-2.html

• Guide to the Section 508 Standards for Electronic and Information Technology, Self-Contained, Closed Products (1194.25)
http://www.access-board.gov/sec508/guide/1194.25.htm

Appendix 9-A
Self-Contained, Closed Products Accessibility Questions

Products that are freestanding, nonportable, and intended to be used in one location and that have operable controls must comply with the following: