Self contained, closed products (1194.25)
(a) Self contained products shall 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.
What are self contained, closed products?
Self
contained closed products generally have embedded software and are commonly
designed in such a fashion that a user cannot easily attach or install
assistive technology. For example, one could attach a screen reader to a
computer which meets the section 508 standards but one would not be
expected to attach a screen reader to a copier machine. A copier machine is
an example of a self-contained, closed product. Other examples include, calculators,
fax machines, information transaction machines, and information kiosks.
Unlike other provisions which 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. Although not
built-in, a headset is considered an allowable add-on, since it is not
considered assistive technology in this case. Headsets might be used for
privacy, not accessibility reasons.
(b) When a timed response is required, the user shall be alerted and given sufficient time to indicate more time is required.
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 would find entering information such as a social security number within a specified time difficult or impossible. This provision requires that a user be notified if a process is about to time-out and be given an opportunity to answer a prompt asking whether additional time is needed.
(c) Where a product utilizes touchscreens or contact-sensitive controls, an input method shall be provided that complies with §1194.23 (k) (1) through (4).
(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.
What products are generally covered under this provision?>
This
provision covers products that use touch screens or other controls which
operate through a person’s touch. In some instances, a personal computer
with a touch-screen will be enclosed in a display and used as an
"information kiosk". Touchscreens 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 touchscreens
and contact sensitive controls, but requires a redundant set of controls
that can be used by persons who have access problems with touchscreens.
Is the latching mechanism to release a toner
cartridge in a copier considered a control covered by section 508?
No. Changing a toner cartridge is considered
maintenance, not normal daily operations. These provisions apply to
operable controls which are defined as components of a product that require
physical contact for normal operation. Operable controls include, but are
not limited to, mechanically operated controls, input and output trays,
card slots, keyboards, or keypads. These provisions are intended to apply
to products in their normal operation rather than when a product may be
used for maintenance, repair, or occasional monitoring. Operable controls
for tasks such as initial set-up and configuration, adding and replacing
parts, and repair and service tasks, are not covered by the standards.
Would printer control panels used for configuration,
status, diagnostic, or maintenance functions be required to be accessible?
If a panel of lights were used strictly for
troubleshooting, they would not be addressed by the standards. However,
these controls are usually available for all to use and may be temporarily
set for the tasks of co-workers. Adjustments may be needed for features in
a copier such as contrast, reduction, double sided, stapling, and sorting.
Sometimes, people accidentally hit an exposed button and the user needs to
put the system back on-line. Therefore, these controls are necessary for
normal daily operation and are required to be accessible.
What is meant by "tactilely discernible"?
Individual keys must be identifiable and
distinguishable from adjacent keys by touch. A product can meet this
provision 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. In addition, the physical spacing of
the function, "numpad" and cursor keys make them easy to locate
by touch. Because touch is necessary to discern tactile features, this
provision requires keyboards to enable touch that does 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 persons with prostheses. 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.
What is meant by "status of controls" and
why do people need that information?
This provision requires that the status of
toggle controls, such as the "caps lock" or "scroll
lock" keys be identifiable by either touch or sound, in addition to
visual means. 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. Also, buttons which remain depressed when
activated and switched with distinct positions may meet this provision.
What does "key repeat" mean?
This provision addresses a challenge
encountered by some people with fine motor coordination difficulty.
Sometimes, they accidentally press a key several times when intending to
hit it only once. This could potentially result in the same character
displaying several times on the screen. Some systems do not support key
repeat. However, where key repeat is provided, this provision requires the
repeat to be adjustable. Specifically, the delay must be adjustable for a
length of time that is no greater than 2 seconds between repeats.
How will individuals with disabilities benefit from
the requirement enabling operability without tight grasping, pinching,
twisting, or pressure?
Individuals with tremor, cerebral palsy, or
other disabilities may have difficulty operating systems which require fine
motor control, a steady hand, or two hands to be used simultaneously for
operation. Individuals with high spinal cord injuries, arthritis, and other
conditions may have difficulty operating controls which require significant
strength. This provision limits the force required to five pounds and is
based on section 4.27.4 of the ADA
Accessibility Guidelines, 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. This
provision is also consistent with the Telecommunications
Act Accessibility Guidelines.
(d) When biometric forms of user identification or control are used, an alternative form of identification or activation, which does not require the user to possess particular biological characteristics, shall also be provided.
What are biometric forms of user identification or
control?
Biometric controls refer to controls that are
activated only if a particular biological
feature (e.g., voiceprint) of the user exists and matches specific
criteria. Other examples include retinal scans and fingerprint
identification that may become a common practice for allowing an individual
to gain access to personal data from an information transaction type of
machine.
Biometric controls provide a high level of security. However, when a system needs to be accessed by a person with a disability and that disability prohibits the use of a specific biometric feature, a non-biometric alternative should be provided that does not compromise security.
(e) When products provide auditory output, the audio signal shall 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.
Does this provision apply to "beeps and
tones" or to voice signals only?
This provision applies only to voice output.
For example, it could apply to a device that is providing voice output for
a person who is unable to see a visual display.
What is meant by a standard connector?
People who regularly use information
transaction kiosks may plan to carry a portable headset (or other listening
coupler) with them. Examples of common plugs on headsets include those that
fit 2.5 mm jacks (such as those in most cellular phones) and 3.5 mm plugs
(such as those in most portable stereos). There have been problems in the
past when manufacturers made proprietary plugs that were flat with multiple
pins and were compatible only their own products.
(f) When products deliver voice output in a public area, incremental volume control shall 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 shall be user selectable. A function shall be provided to automatically reset the volume to the default level after every use.
How was the level of 65 dB determined?
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. This provision
requires that audio output from a kiosk type product have a minimum level
of 65 dB. A feature has been required to automatically reset the volume to
the default level after every use. This is consistent with a similar
provision addressing telecommunications products.
What
are the needs of people with partial hearing?
People who are hard of hearing, generally
speaking, require voice levels to be 20 dB above the ambient sound level to
understand speech. This means that as long as the noise level in the
surrounding environment is below 45 dB, the 65 dB output level would be
sufficient. If the product is in an environment with a high noise level,
the user must be able to raise the volume to a setting of 20 dB higher than
the ambient noise level. This would require the owner or other appropriate
responsible party to determine the volume of the background noise at the
location of the machine (specifically whether it is above 45 dB), so the
machine can be selected or calibrated for that specific environment. To
effectively meet this provision, consideration needs to be given to the
fact that ambient noise levels may vary in certain environments.
(g) Color coding shall not be used as the only means of conveying information, indicating an action, prompting a response, or distinguishing a visual element.
How can color coding create accessibility
difficulties?
A software program that requires a user to
distinguish between otherwise identical red and blue squares for different
functions (e.g., printing a document versus saving a file) would pose
problems for anyone who was color blind and would generally be very
difficult to run with assistive technology. Screen reading software can
announce color changes. However, this is an "on/off" feature.
This means that if a user had to identify a specific color, they would have
to have all colors announce which would greatly reduce the usability of the
software for that person.
Does the provision prohibit the use of colors?
No. 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.
(h) 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 shall be provided.
Do all products have to provide color selections?
No. This provision is applied to those
products that already allow a user to
adjust screen colors.
What is the desired outcome of this requirement?
This provision requires more than just
providing color choices. 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 people with low vision can work most efficiently when the screen
is set with very sharp contrast settings. Because there is such a
variance in individual needs it is necessary for a program to have a
variety of color and contrast settings.
(i) Products shall be designed to avoid causing the screen to flicker with a frequency greater than 2 Hz and lower than 55 Hz.
Why are flashing or blinking displays limited by this provision?
This requirement is necessary 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 references a 2 Hz limit. An
upper limit was identified at 55 Hz.
(j) Products which are freestanding, non-portable, and intended to be used in one location and which have operable controls shall comply with the following:
(1) The position of any operable control shall 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 1 of this part).
(2) Where any operable control is 10 inches or less behind the reference plane, the height shall be 54 inches maximum and 15 inches minimum above the floor.
(3) Where any operable control is more than 10 inches and not more than 24 inches behind the referenc plane, the height shall be 46 inches maximum and 15 inches minimum above the floor.
(4) Operable controls shall not be more than 24 inches behind the reference plane (see Figure 2 of this part).
What do these provisions require?
These provisions 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
free standing printers. These provisions are based on the Americans
with Disabilities Act Accessibility Guidelines (ADAAG 4.2 Space Allowance and Reach Ranges).
If a document feeder was within the technical
specifications, but access to the platen glass was outside the reach range,
would a copier machine meet the provisions?
No. Users need to be able to access both ways of placing a piece of paper on a copier for copying. There are some things
(too small or too large) that cannot be run through a paper feed.
If the trays for storing reams of paper are not
reachable, does the copier machine meet the provisions?
Copier paper tray access is not covered under
the standards because replacing paper is considered 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 keypads. The standards apply to products in their
normal operation rather than when a product may be used for maintenance,
repair, or occasional monitoring. Other tasks such as initial set-up and
configuration, adding and replacing parts, and repair and service tasks are
also not covered by the standards.