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This chapter contains the specific electronic and information technology (EIT) performance requirements related to the following subpart of Section 508:
EIT Technical Standard 1194.23, Telecommunications Products, Provisions (a) thru (j).
The requirements in this chapter cover the following:
• Any product whose primary function is to provide telephone functions (i.e., 2-way voice communication), regardless of type, ranging from traditional business telephones to a wide variety of new and emerging products.
• For products with multiple functions, these requirements apply only to the telephone functions of those products. The convergence of telephony and information technology is blurring the line between different product types as a variety of new and innovative products are created (e.g., softphones, voice over IP, etc.).
• Telecommunications products that provide telephone functions include many components that are subject to the requirements in this chapter:
• Customer premises equipment: Equipment employed on the premises of the Postal Service, including all headquarters and field operations (Post Offices, mail processing centers, etc.) to originate, route, or terminate telecommunications. "Customer premises equipment" includes all end-user devices, routers, switches, trunks/channels, call managers, servers, and software integral to such equipment used on the premises of the Postal Service. Customer premises equipment is distinguished from equipment used by carriers, referred to as "telecommunications equipment" (see below).
• Telecommunications equipment: Equipment, other than customer premises equipment, used by a carrier to provide telecommunications services. "Telecommunications equipment" includes all routers, switches, trunks/channels, call managers, servers, and software integral to such equipment used by the carrier.
• 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. Some examples of a telecommunications services include, but are not limited to, a voice over IP service, a voice mail service, or a wireless phone service.
Note: You may need to synchronize requirements in this chapter with requirements given in other chapters in this handbook. Products that provide telephone functions are subject to the requirements stated in this chapter. However, products often have features that are subject to requirements in other technical chapters (i.e., chapters 5-10). In addition, all products must be assessed using both the applicable specific requirements and the Functional Performance Criteria (see section 4-2.1). For example, using only the requirements in this chapter, it would be possible to design a touchscreen-only product (with no keypad and no voice output) that would be completely inaccessible to people who are blind. However, to ensure that the product would be accessible to people who are blind (i.e., and therefore conforming to Section 508 standards), the Functional Performance Criteria must also be applied.
Some examples of how the requirements in this chapter should be applied are offered here:
• Example 1: Typical desktop telephone with answering machine capability. This product is clearly covered by this chapter's requirements, because its primary function is to provide telephone functions (i.e., 2-way voice communication). The product is also covered by the Functional Performance Criteria, as well as requirements in other chapters depending on the telephone design and features.
• Example 2: A self-contained, single-function fax machine. This stand-alone fax machine cannot be used to make a voice call (i.e., the unit has no handset or microphone). However, the unit has a speaker to enable the user to hear the line status. This product is both a self-contained, closed product and a telecommunications product. In this case, the applicable requirements are as follows:
• From this chapter, only sections 7-6 (Caller ID and Similar Functions) and 7-12 (Controls and Keys) apply, as voice calls are not supported.
• From Chapter 9, Self-Contained, Closed Products, sections 9-2, 9-3, 9-4, 9-6, 9-8, 9-9, and 9-10 all apply. Section 9-5 does not apply, because no biometric form of identification is being used in this example. Section 9-7 does not apply, because the product does not deliver voice output for purposes of a conversation. Section 9-11 does not apply, because this is not a freestanding product. Sections 9-4, 9-9, and 9-10 may not apply, depending on whether the product has a display and on the type of display.
• All Functional Performance Criteria also apply.
• Example 3: An "all-in-one" machine connected to a personal computer that includes a fax, scanner, printer, and copier. This product cannot be used to make voice calls. The product includes software to be loaded on the personal computer. Therefore, this software must meet all applicable requirements in Chapter 5, Software Applications and Operating Systems. The unit itself is similar to the one in the second example and is covered under applicable requirements in this chapter, in addition to Chapter 9, Self-Contained, Closed Products, and the Functional Performance Criteria. To determine exactly which provisions apply to this "All-in-One" product, perform the same kind of analysis performed in the second example (i.e., the stand-alone fax machine).
This chapter applies to anyone who buys or develops telecommunications products or systems that include telephone functions for the Postal Service (i.e., Postal Service employees, suppliers, contractors, and business partners). Telecommunications products include information technology solutions of all sorts, consisting of simple or complex purchases or developed systems, and all associated data, information, training material, documents, and customer support.
Each part of this chapter describes the specific requirements that support one or more provisions in the technical standards for telecommunications 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 7-2.
7-1, Overview
7-2, TTY Connection and Microphones (Provision §1194.23a)
• Rationale
• Techniques
• Testing
• References
7-3, TTY Signal Protocols (Provision §1194.23b)
7-4, Voice Mail, Auto-Attendant and Interactive Voice Response (IVR) Systems (Provision §1194.23c)
7-5, Time Interval Alerts for IVR Systems (Provision §1194.23d)
7-6, Caller ID and Similar Functions (Provision §1194.23e)
7-7, Volume Control (Provision §1194.23f)
7-8, Automatic Volume Reset (Provision §1194.23g)
7-9, Hearing Aid Compatibility (Provision §1194.23h)
7-10, Minimized Interference (Provision §1194.23i)
7-11, Transmission/Conducting Information (Provision §1194.23j)
7-12, Controls and Keys (Provision §1194.23k)
Appendix 7-A, Checklist
While looking at telecommunications barriers, it is helpful to understand the challenges that people with various disabilities face in using telephone functions, voice mail, auto-attendant, interactive voice response (IVR) systems, and other covered technologies. The need for a solution to these challenges resulted in the development of specific telecommunications product accessibility standards in Section 508. Here is a summary of those challenges:
• People with hearing disabilities are typically faced with challenges such as:
• Lack of adequate TTY connections and signal support.
• Interference with hearing technologies (i.e., hearing aids).
• Lack of adequate volume control.
• Insufficient audio quality for both analog/digital/synthesized output and recording/input (not addressed in Section 508).
• Lack of playback control such as repeat and rewind functions (not addressed in Section 508).
• People with visual disabilities are typically faced with challenges such as:
• Inaccessible LCD output for visually presented telephone function information such as caller ID, call logs, and internal directories.
• Inaccessible hardware controls, keys, and switches.
• People with dexterity or mobility disabilities are typically faced with challenges such as:
• Lack of timeout controls and saving of user input upon timeout.
• Inaccessible hardware controls, keys, and switches.
• Lack of error recovery features.
• Reliance on only one mode of input (e.g., voice or manual input).
• Lack of playback control, including transcription (not addressed in Section 508).
• Speech-impaired persons are typically faced with challenges such as:
• Dependency on speech recognition.
• Reliance on only speech-based input.
• Incompatibility with communication aids.
While making telecommunications products accessible presents many challenges, the greatest barrier to compliance with Section 508 is lack of knowledge. Telecommunications products can often be made accessible with minimal difficulty and expense. In addition, buying or building accessible telecommunications products can benefit the population at large, not just people with disabilities.
Accessibility is accomplished by purchasing or developing telecommunications 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 that its telecommunications products continue to be accessible:
• The Postal Service should develop and procure telecommunications products that take advantage of built-in accessibility features when those features are available to both end users and product developers.
• The Postal Service should procure or develop telecommunications products that recognize and maximize the capabilities of the accessibility features installed and activated by a user (e.g., native hardware as well as installed assistive technology). Postal Service telecommunications products procurement personnel and developers should do the following:
• Buy or build products that support industry and regulatory telecommunications standards. Accessibility features are often integrated with these standards to ensure accessibility in telecommunications usage (including input, compression, transmission, storage, and output). Standards related to each specific requirement are shown in the "References" area under that requirement.
• Use standard hardware and software controls instead of custom controls. Standard controls often already support product accessibility features. Using them may eliminate the need for additional configuration or programming to provide explicit accessibility support, unless the behavior of the standard control has been enhanced.
• Buy or build products that support a variety of input methods and output methods.
• Buy or build products that can query or detect the assistive technology in use and configure the telecommunications product automatically. For example, IVR systems might detect the presence of TTY signals and automatically route calls to the appropriate system or subsystem.
• The Postal Service will maintain standards for the following categories of assistive technologies that people with disabilities use to access telecommunications products:
• Teletypewriter (TTY) devices or emulating software/modes: Help people with hearing disabilities by allowing them to transmit text-based conversations by telephone in real time.
• Teleconference systems supported by assistive listening systems: Help people with hearing disabilities participate in meetings and other public settings by transmitting sounds using infrared or FM radio frequencies directly to a personal receiver (i.e., headphones) using a direct feed.
Finally, Postal Service employees are required to register certain software applications and operating systems in the Enterprise Information Repository (EIR) at http://eir. If a telecommunications product contains software applications, they may be subject to EIR requirements. This information will be used to report compliance and includes any related Section 508 noncompliance issues.
When testing telecommunications products for compliance, it is crucial to be aware of the end-user environment. This includes an understanding of a product's stated accessibility features, assistive technologies typically used (such as a TTY), in addition to the product's input, compression, transmission, storage, and output methods.
Manual testing, using the testing methods described in this chapter, is mandatory, because it simulates use by people with disabilities and assistive technology users. If automated testing tools or integrated development environment (IDE) features are available to help automate these methods, they can be used but must be accompanied by manual testing. For example, a developer can use IDE tools to test for valid syntax (e.g., compression schema, input/output format or signal quality, etc.), but a manual inspection must still be done to validate semantics and proper rendering. In other words, the meaningfulness (i.e., quality) of the output must also be considered for end users who may have a disability or who may use assistive technology such as a TTY or a hearing aid.
Telecommunications products or systems that provide telephone functions (i.e., 2-way voice communication) and which do not themselves provide TTY functionality must provide a standard, nonacoustic connection point for TTYs. Microphones must be capable of being turned on and off to allow the user to intermix speech with TTY use (§1194.23, Provision a).
People with significant hearing or speech disabilities commonly use text-based communication to converse over the telephone. Teletypewriters (TTYs) allow transmission of text conversations by telephone in real time. This provision addresses two different issues. One deals with the way a TTY is connected. This is important to ensure signal quality as well as to make the conversation possible in some cases. The other issue pertains to providing support for certain classes of TTY users who communicate by mixing speech and text on a call.
TTYs traditionally have had acoustic modems that use couplers on the top of the device. These are frequently used in offices where hearing people answer the telephone. The acoustic coupling mode allows a hearing call-taker to answer in voice and put the handset into the TTY coupler if needed for a TTY call. Thus, providing a handset that is compatible with a TTY is often helpful for these situations. However, a direct connection is often needed for its unique benefits, such as TTY-answering-machine capability and keyboard dialing. In addition, some TTY models do not have acoustic couplers.
Another important reason for requiring a direct connection is improved signal quality. Acoustic coupling is subject to audio interference from noise in the environment. Also, increasingly, handsets are diverse in design, and many do not fit well into standard acoustic couplers. If an acoustic modem picks up ambient noise while receiving data, it could display unintended characters, making the conversation difficult to understand. Therefore, a direct connection enables TTYs to obtain a clearer signal.
The requirement enabling the intermix of voice and TTY tones is important because it allows some people, depending on their abilities, to use TTYs more efficiently. Originally, TTY users would use TTYs for both typing and reading. Those that could speak, however, quickly determined that (if the other person could hear) they could pick up the receiver when it was their turn to talk and just speak to the other person (who would then type back on their turn). This was much faster and preferred by both sides of the conversation.
TTYs can be used in two distinct ways by people with disabilities, using Voice Carry-Over (VCO) and/or Hearing Carry-Over (HCO).
VCO is for people who have difficulty hearing clearly through the telephone and prefer to speak for themselves in a telephone conversation. Using a VCO telephone/TTY, the VCO user speaks directly to the other person. Everything the other person says is typed by a Telecommunications Relay Service communication assistant and appears on the text display of the VCO user's telephone/TTY. The VCO user reads the text and no typing is necessary (see Figure A).
Figure A. VCO allows a caller to speak and receive typed responses from the other party (via a Telecommunications Relay Service communication assistant or relay officer).
HCO is for people who cannot or prefer not to speak, but who prefer to hear spoken conversation from the party they are calling. Using an HCO telephone or TTY, the HCO user types his or her side of the conversation and sends through a Telecommunications Relay Service communication assistant to the receiving party (who hears the spoken conversation voiced by the relay officer). The receiving party responds with spoken conversation that is heard directly by the HCO telephone/TTY user (see Figure B).
Figure B. HCO allows a caller to type conversation (relayed through a Telecommunications Relay Service communication assistant or relay officer), then hear spoken responses from the person they are calling.
VCO and HCO are most often used with the Telecommunications Relay Service (TRS). TRS is a service, mandated under Title IV of the Americans with Disabilities Act, which employs a live operator known as a communication assistant who facilitates the conversation between people using TTYs and those who are not using them.
Another aspect of this provision is a requirement that the microphone be capable of being turned on or off while using a TTY connection. This requirement was necessary to ensure that a telephone system would not prevent a telephone mouthpiece microphone from working when a TTY was being used with the telephone. For example, if a cellular telephone's headset jack is connected directly to a TTY, the microphone is sometimes disabled. This prevents TTY users from using the VCO option, since no voice input is possible unless the TTY is disconnected from the cellular telephone (at which time the cellular telephone microphone returns to normal operation).
All telephone handsets and systems, regardless of device type, must provide a standard, nonacoustic connection for TTYs.
Individuals who use TTYs to communicate must have a nonacoustic way to connect TTYs, because acoustic-only connectors have a high data-error rate. Handsets on many telephones do not fit well with many TTY acoustic couplers, allowing interference from outside noise. Some digital wireline telephone systems do not offer standard, nonacoustic connectors. Use the following guidance to satisfy this requirement, depending on the type of system being considered:
• Wireline equipment: Wireline equipment must provide a standard non-acoustic connection (i.e., an analog RJ-11 jack) with a ring equivalence of 1 (in addition to the 1-ring equivalent provided for the telephone).The following additional guidance is offered:
• Ports that connect directly into the PSTN must conform to FCC Part 68 standards for analog PSTN telephone lines.
• For digital wireline telephone systems (e.g., multi-line business telephones operating through a PBX), provide either an analog drop line, a SmartAdapter, or data port that supports connection of an analog TTY. Note that both the capabilities of the system and the capabilities of handset units should be assessed when determining where to provide the analog connection. There may be cases in which the connection is best made at the PBX level by installing analog "drop" telephone lines where necessary, similar to what would be provided for a fax machine. In other cases, a "Smart Adapter" or DataPort may be necessary, similar to those used on many hotel telephones. Note that some adapters and converters have circuitry that determines the nature of the line and plug-in equipment and makes the adjustment automatically whereas others are manual.
• For analog wireline telephone systems only, provide "direct-connect" TTYs that offer secondary benefits by supporting "auto answer" features. TTYs connected through an audio jack typically cannot act as answering machines - even if they have answering machine features in them (that work when they are connected through an RJ-11 jack). To answer a telephone (or act as an answering machine), TTYs typically need to have a direct connection to the telephone line. In the future, there may be a standard mechanism for TTYs to answer the telephone when connected through an audio connection point (as opposed to a direct connection) so that TTY auto-answer or answering machines can work. Direct-connect TTYs should be connected only to analog telephones to prevent damage to the TTYs. A TTY should not be plugged directly into a digital telephone network, unless an analog jack or an analog converter is available.
• Cordless analog wireless equipment: The most common nonacoustic connection for cordless analog wireless use is a 2.5 mm headphone jack. Use of the 2.5 mm headphone jack carries limitations. Telephones with audio jacks and no RJ-11 jack will not work with many popular office TTY models that only have RJ-11 jacks, including many of the currently available TTYs with printers and answering machines.
• Digital wireless (i.e., cellular) equipment: The most common nonacoustic connection for cellular equipment is a 2.5 mm headphone jack that conforms to the TIA TSB-121 standard. Cellular telephones must support the VCO/HCO feature using either a standard nonacoustic connection or built-in functionality in the device hardware. Portable TTYs that are compatible with cellular telephones are designed for mobility and do not typically have printers or answering machines and can therefore be supported by the 2.5 mm headphone jack.
All telephones that use 2.5 mm headphone jack connectors to TTY connectivity must pass through the ring signal to the connector so that TTYs with built-in signal connectivity can detect the ringing.
In setting up a TTY, make sure that a suitable visual (or, in the case of a digital wireless or cellular telephone, vibrating) indicator, feature, or third party-device can be activated to alert a TTY user with a hearing loss when the telephone is ringing.
All telephone handsets and systems, regardless of device type, must offer the user the ability to turn the microphone on and off, so as to intermix speech and TTY signals without garbling of TTY text or reduction of speech quality.
When a TTY is connected directly into the network, it must be possible to turn the acoustic pickup (microphone) off (automatically or manually) so that background noise in a noisy environment will not interfere with the TTY signal. This supports use by people who prefer to communicate entirely by TTY. On the other hand, because some TTY users make use of speech for outgoing communications, the microphone enablement feature must be automatic or easy to switch back and forth, or a push-to-talk mode should be provided. Therefore, telephone systems must support the ability for voice and TTY tones to alternate, not to be sent at the same time.
Note: Some TTY users have reported instances in which they connected a TTY to a cellular telephone, which resulted in a deactivation of the telephone's microphone. In those cases, there was no way to talk into the telephone (no way to turn the microphone on). This is frustrating to people with a hearing disability and intelligible speech who prefer to talk instead of type. People who are deaf and use the TTY for both typing and reading would have less of a problem with a connection that disables the microphone. However, even they would be concerned if the telephone was disabled to a point where it was unable to transmit tones for responding to IVR systems. TTY signals are not the same as "touch tone" sounds, and some TTYs may not readily make the necessary tones. On the other extreme, some TTY-phone setups keep a microphone on throughout the entire conversation (never toggling it off). This can cause a problem if the microphone picks up extraneous noise during the data reception mode, resulting in errors.
Desktop or portable computers with telecommunications functions must provide TTY support or offer TTY emulating software, in addition to providing microphone disablement.
When telephone functions are provided on a desktop or portable computer, you must provide TTY support or offer TTY-emulating software, a microphone, and speakers. Some software and modems desktop or portable computers to function as a TTY telephone lines or over the Internet (e.g., VoIP). For such systems to comply with this requirement, they must allow speech and TTY tones to be intermixed (i.e., they must support VCO and HCO for both inbound and outbound calling), and they must allow the microphone to be disabled. For VoIP systems, use software or transmission or configuration techniques that enable full access to telephone functions. VoIP systems offer new possibilities for access to telephone functions by people with disabilities. They can be made accessible using various software components or configurations. For example, some software applications can be loaded onto the telephone server and configured to achieve accessibility, often without requiring any changes to the telephone hardware. Other techniques are currently being developed that would allow every telephone in an organization to be instantly capable of text communication (with and without voice carryover) by simply installing a software program in the call manager. A deaf person could then walk up to any of the 10,000 telephones in an organization and communicate via text (or text and voice), without needing any special equipment. This approach does not require any changes to the telephones themselves. It could be implemented using the VoIP telephones that are already installed.
a. Inspect the product to identify if it provides telephone (i.e., 2-way voice communication) functions.
b. Regardless of product type, if the product does provide telephone functions, conduct a visual inspection, using the following steps:
(1) Determine if product provides TTY functionality.
(2) If not, check for a standard, nonacoustic connection point (e.g., RJ-11, TIA TSB-121, etc.).
(3) Check for microphone off/on or "mute" switch or similar function.
c. After conducting the visual inspection, conduct a performance test to ensure product complies with the requirements of this provision, using the following steps:
(1) Attach a TTY product to the product using the non-acoustic connection point.
(2) Test the product's ability to allow the user to intermix speech with TTY on the same call to insure that VCO is functioning properly. On some telephones, when the microphone is muted, the telephone also prevents the TTY from transmitting through the direct-connect port. This is a problem.
The following references are applicable to the specific requirements stated here:
• Access Board, "Using a TTY"
http://www.access-board.gov/publications/usingATTY/A2.html
• Trace Research Center, University of Wisconsin, Guide
to Section 508
Telecommunications
http://www.trace.wisc.edu/docs/2002-508-collation/index.shtml
?style=default#telecomm
• FCC Order: Federal government must provide toll-free
telecommunication relay service (TRS) Access
http://www.fcc.gov/Bureaus/Common_Carrier/Orders/2000/fcc00056.txt
• FCC Order: Wireless (cellular) providers must be able
to transmit 911
calls made from TTYs
http://www.fcc.gov/Bureaus/Common_Carrier/Orders/2000/fcc00436.txt
• Alliance for Telecommunications Industry Solutions'
TTY Forum
http://www.atis.org/atis/tty/ttyforum.htm
• TIA TSB-121 Standard: Cellular Subscriber Unit
Interface for TDD
(2001)
http://www.tiaonline.org/standards
• Gallaudet University, "TTY Basics"
http://tap.gallaudet.edu/TTY-Basics.htm
• Gallaudet University: "Tools for field testing TTYs with wireless phones"
http://tap.gallaudet.edu/TTYtools/
• Guide to the Section 508 Standards for Electronic and
Information
Technology, Telecommunications Products (1194.23), Updated: June 21,
2001
http://www.access-board.gov/sec508/guide/1194.23.htm
Telecommunications products that provide telephone functions (i.e., 2-way voice communication) must support all commonly used cross-manufacturer nonproprietary standard TTY signal protocols (§1194.23, Provision b).
A two-way, real-time text-based telephone service for people with communication disabilities, based upon TTYs, was developed from teletype machines in the 1960s. The purpose of this provision is to ensure that TTY compatibility (with the signal, not just the connection point) is not overlooked. Specifically, this provision requires that mainstream telecommunications products that provide telephone functions support use of all commonly used cross-manufacturer, nonproprietary, standard signals used by TTYs. Some products compress or alter the audio signal in such a manner that standard signals used by TTYs are not transmitted or decoded properly, preventing successful TTY communication. TTYs that are most commonly used in the U.S. use the U.S. 45.5 baud Baudot protocol (ANSI/TIA/EIA 825). The 300 baud ASCII protocol is almost universally available, especially on dual mode TTYs, but it is less commonly used. These two codes (300 baud ASCII and 45.5 baud Baudot) are considered nonproprietary. Compliance with international standard ITU-T Recommendation V.18 would also meet this provision, but products complying with the ITU standard may not be commercially available.
Regardless of which nonproprietary standard protocol is supported, it is important that products and systems continue to support the protocol used by the TTYs currently in use by most people who are deaf or hard of hearing. However, the intent of this provision is to require support of more than just Baudot or ASCII. At present, only these two are commonly used in the U.S., but others may come into use later. While the Access Board is committed to supporting users of current devices, it does not want to exclude those who buy newer equipment, as long as such devices use protocols that are not proprietary and are supported by more than one manufacturer. Of course, like all the requirements of these standards, this provision is subject to commercial availability, which is why the final rule used the phrase "commonly used."
This provision applies to all telecommunications products that enable and support 2-way telephone functions. Some examples include the following: an analog or digital telephone system, a personal data assistant (PDA) that includes telephone functions, or a fax machine with handset and microphone. Telecommunications products that do not support 2-way telephone functions - for example, a fax machine with a line monitoring speaker only, but that does not include either a handset with microphone or speakerphone - are not covered by this provision.
All telecommunication equipment that provide telephone functions (i.e., 2-way voice communication) must support all commonly used cross-manufacturer, non-proprietary, standard signals used by TTYs. Specifically, the equipment must support the U.S. 45.5 baud Baudot protocol (i.e., the TIA/EIA 825-A standard, "A Frequency Shift Keyed Modem for use on the Public Switch Telephone Network") and the 300 baud ASCII protocol. Alternatively, the newer international standard ITU-T V.18 standard is sufficient to support the requirements of this provision. Note that using TTYs over wireless networks presents different issues than using TTYs over TTY over voice over IP (VoIP).
a. Inspect the product to determine if it provides 2-way telephone functions (i.e., 2-way voice communication).
b. Research the standard TTY signal protocols that support TTY use, and determine which apply to the product in question.
c. Refer to standard methods and tools that exist for TTY signal protocol testing for digital wireless. Apply a consistent approach to TTY protocol testing that uses standard test-case data scripts and automated protocol capture and analysis tools for measuring transmission accuracy (see Gallaudet University in "References").
d. Conduct a performance test on the product. Use overall error performance tests from the TTY Forum's TTY Technical standards implementation tests suite and additional tests as appropriate (http://www.atis.org/atis/tty/ttyforum.htm). End-to-end performance tests using Gallaudet test scripts should be technology-independent.
The following references apply to the specific requirements stated here:
• Access Board, "International Telecommunications Union (ITU) Recommendation v.18"
http://www.access-board.gov/telecomm/marketrep/appendices/v18.htm
• Access Board, "Using a TTY"
http://www.access-board.gov/publications/usingATTY/A2.html
• Trace Research Center, University of Wisconsin, Guide
to Section 508
Telecommunications
http://www.trace.wisc.edu/docs/2002-508-collation/index.shtml
?style=default#telecomm
• Telecommunications Industry Association, Inc. (TIA),
Standards related
to TTYs
http://www.tiaonline.org/standards/search.cfm?keyword=TTY
• ANSI/TIA-825-A-2003 Standard: A Frequency Shift Keyed
Modem for
Use on the Public Switched Telephone Network
http://www.tiaonline.org/standards/search_results2.cfm?
document_no=TIA%2D825%2DA
• Gallaudet University's Technology Access Program:
V.18 New Modem
Standard with TTY Capacity
http://tap.gallaudet.edu/v18.htm
• Alliance for Telecommunications Industry Solutions'
TTY Forum
http://www.atis.org/atis/tty/ttyforum.htm
• FCC Order: Federal government must provide toll-free
telecommunication relay service (TRS) Access
http://www.fcc.gov/Bureaus/Common_Carrier/Orders/2000/fcc00056.txt
• FCC Order: Wireless (cellular) providers must be able
to transmit 911
calls made from TTYs
http://www.fcc.gov/Bureaus/Common_Carrier/Orders/2000/fcc00436.txt
• Guide to the Section 508 Standards for Electronic and
Information
Technology, Telecommunications Products (1194.23), Updated: June 21,
2001
http://www.access-board.gov/sec508/guide/1194.23.htm
• Gallaudet University's Technology Access Program: TTY
Basics
http://tap.gallaudet.edu/tty%2Dbasics.htm
• Gallaudet University's Technology Access Program:
V.18: New
Modem Standard with TTY Capacity
http://tap.gallaudet.edu/v18.htm
Voice mail, auto-attendant, and interactive voice response telecommunications systems must be usable by TTY users with their TTYs. (§1194.23, Provision c).
Interactive Voice Response Systems (IVRs) have become a common means for agencies to manage their calls and save labor costs for common functions, such as routing calls by user selection from a voice menu, health care enrollment, or automated job line announcements. These services provide a number of functions including voice mail, and increasingly, unified messaging, auto-attendant, call routing, information delivery, and interactive voice response. However, for people who use TTYs, these labor-saving services often present barriers.
For example, many hearing-impaired TTY users cannot understand prompts indicating which telephone buttons to push when encountering IVRs. In other cases, users calling through a telecommunications relay service may not be given enough time to respond and get timed-out by the IVRs. Auditory information when typed to a TTY user via relay may not include necessary spacing or punctuation to help a consumer understand sections of what is being conveyed. TTY users have discovered that some voice-mail systems corrupt TTY data left in voice-mail boxes. Moreover, as IVRs replace receptionists, operators, and other customer support methods, TTY users may actually lose services that they previously relied on and may be completely unable to call anyone in an agency (even if the person has a TTY on their desk) because they cannot get through the automated receptionist.
Such IVR systems not only must be fully functional for people who are calling in while using a TTY but must also be fully functional to people who subscribe to the voice-mail service and use a TTY to access it. Voice-mail systems that allow TTY users to retrieve and leave TTY messages are now available. This provision does not require telephone systems to provide voice-to-text conversion capabilities. IVR products that provide TTY users all of the same functions and information as they do for non-TTY users, such as reading streaming text, leaving messages, and managing personal voice mail have been available for more than a decade. This software should not be confused with other software on the market that is designed to allow computers to transmit and receive TTY code for live communication.
This provision applies to all devices that incorporate IVR functionality, such as voice mail systems, auto-attendant, and interactive voice response systems.
Voice mail, auto-attendant, and interactive voice response systems must be usable by TTY callers, both to leave and retrieve messages and to use the system features.
Making voice mail, auto-attendant, and IVRs "usable" involves two tasks: ensuring the IVR has the technical capabilities needed for TTY compatibility and implementing menus and messages so they are TTY-compatible. TTY users (both the caller and the receiver) must be able to navigate and use all end-user functions of IVRs independently without relying on a telecommunications relay service (i.e., IVRs should be able to send and receive TTY signals directly). The TTY character-error rate should ideally be no greater than that experienced by non-TTY users. The benchmark used for wireless TTY compatibility is an average error rate of no higher than 1 percent. TTY users must have sufficient time to read and respond before the system times out. Assume that TTY users will have a DTMF (i.e., touchtone) enabled TTY configuration, such as telephone with TTY attached, wireless telephone with TTY attached, or DTMF-enabled TTY. Time limits for user response based on those requirements in section 7-5 should be considered for the IVR system to be "usable," as this provision requires. The following methods are recommended (see also requirements in Section 7-5, Time Interval Alerts for IVR Systems):
• Establish a separate number for TTY users with the TTY-compatible voice mail, auto-attendant, and interactive voice response system at that number. If a separate number for TTY users is used, it must be equally publicized.
• For systems that support multiple language messaging, use software that recognizes the TTY tones and then treats them as a language variant. In this approach, messages are delivered to TTY users, much as some users might choose a language and receive messages in their preferred language. One challenge with this approach is that many TTY callers do not make TTY tones until they see the call is answered with a "Hello GA" TTY message. Therefore, they may not readily get connected to the TTY channel in a voice mail, auto-attendant, and interactive voice-response system. There are methods (as described below) for eliciting a response from the caller in TTY that could then be used to do the automatic switchover.
• Provide a parallel system for TTY calls, accessed from the initial message in the message tree. In this approach, a TTY call is identified, using the same greeting heard by non-TTY callers. This may be done by using integrated messages that contain both Baudot (TTY text) and voice content in such a way that both voice and TTY users can be served from a single voice file. In this technique, an initial message starts with a "HD" or "HLD" in Baudot to tell TTY users to hold. After this, the voice message plays, followed by a 5-second pause during which the hearing caller should enter a key to enter the message tree. After the pause and voice message to the hearing caller, the voice message is repeated in TTY tones. The hearing caller is thus routed to the audio messaging system and the TTY caller to the TTY messaging system. This setup would need to be designed to minimize delay in the sending of an initial TTY greeting, or TTY users will not recognize that they have called anything other than an exclusively voice-based system.
IVRs that use speech-recognition features must offer at least one mode of operation and information retrieval that does not require user speech or they must offer support for assistive technology used by people with disabilities.
For example, speech-enabled IVRs can ask users to speak an account or employee ID number or enter it using the telephone keys.
Communicate clear requirements to the user for entering DTMF responses (e.g., "touch tones").
Interactive voice response systems often require a user to enter DTMF tones to access a customer service line (e.g., enter their extension number) or to make menu selections. In addition, telephone calling cards may require users to enter a personal identification number via DTMF. Depending on the users' equipment, these tones may be entered directly via a push-button telephone or through the dialing system of a TTY. Note that DTMF tones are not the same as TTY tones, and TTYs make DTMF tones only when set in a "keyboard dialing" mode. Not all TTYs can generate DTMF tones, so the ability to generate DTMF tones with the telephones is important. Users with TTYs in the acoustic mode or with telephones connected in parallel with a direct-connect TTY can enter DTMF tones directly from their telephone. Vendors of TTY products can provide further information on how users may enter DTMF tones.
Offer TTY users the same central voice-mail system answering service as non-TTY users.
Since the voice-mail system of the agency should be completely TTY-compatible, TTYs with answering machine functionality should not be needed (though the voice mail may or may not be easier to use), since TTY users could have their telephone answered by the central voice mail system like everyone else. If TTY-accessible answering machines are used instead of TTY-accessible voic mail, they must provide high enough fidelity to record and play back TTY tones accurately.
a. For IVR systems and products, identify the set of voice mail, auto-attendant, and interactive voice response functions that apply. This must include all of the operational functions (which excludes maintenance and setup features) required to be used by the end-users of the system.
b. Inspect the product using the checklists provided by the Alliance for Telecommunications Industry Solutions' Interactive Voice Response Accessibility Forum (http://inclusive.com/ivr_access/). There are checklists for "Voice IVR" and "TTY IVR." Complete both checklists to verify compliance with this provision.
c. Inspect the product using the Human Factors and Ergonomics Society's Guidelines for "Human Factors Engineering of Software User Interfaces - Interactive Voice Response (IVR) and Telephony" (see "Reference" below). These guidelines are compatible with ISO/IEC IS 13714, "Information technology - Document processing and related communication - User Interface to Telephone-based Services - Voice Messaging Applications," but is less specific than the specifications in ISO/IEC IS 13714 (http://www.atis.org/pub/IVR/HFES-200-5.pdf).
The following references are applicable to the specific requirements stated here:
• Trace Research Center, University of Wisconsin, Guide
to Section 508
Telecommunications
http://www.trace.wisc.edu/docs/2002-508-collation/index.shtml
?style=default#telecomm
• Gallaudet University's Technology Access Program:
Voice Mail and
IVR
http://tap.gallaudet.edu/IVR.htm
• Alliance for Telecommunications Industry Solutions'
IVR Accessibility
Forum
http://www.atis.org/atis/ivr/ivrhom.htm
• Inclusive.com: IVR Accessibility
http://inclusive.com/ivr_access/
• ITU-T (ITU Telecommunication Standardization Sector):
DTMF
Standard
http://www.itu.int/home/
The ITU-T is a committee of the International Telecommunications
Union (ITU). The ITU-T is responsible for making technical
recommendations about telephone and data communication systems.
DTMF (Dual-Tone Multi-Frequency) tones are those used by touch-tone
telephones for tone dialing.
• ISO/IEC IS 13714 (1994). Information technology -
Document
processing and related communication - User Interface to
Telephone-based Services - Voice Messaging Applications
http://www.iso.org/iso/en/CatalogueDetailPage.CatalogueDetail
?CSNUMBER=22721
ISO 13714 is the most detailed of the three standards, but also the
narrowest. It applies to voice mail and voice messaging, specifically
and cannot be applied in its entirety to IVR systems.
• Human Factors & Ergonomics Society: HFES 200.5:
"Human Factors Engineering of Software User Interfaces - Interactive Voice Response (IVR) and Telephony"
http://www.atis.org/pub/IVR/HFES-200-5.pdf
• The Telephone Speech Standards Committee (TSSC) user
interface
guidelines for speech-enabled or speech-recognition business IVR
applications.
http://portal.acm.org/citation.cfm?doid=360405.360435
TSSC is a relatively informal industry group consisting of
representatives from companies developing speech-enabled IVRs for
business transactions. The committee is developing standardizing
terminology and definitions and set of common tasks across
applications for which there will be standardized commands and
prompts.
Voice mail, messaging, auto-attendant, and interactive voice response telecommunications systems that require a response from a user within a time interval must give an alert when the time interval is about to run out and must provide sufficient time for the user to indicate more time is required (§1194.23, Provision d).
When a system requires a user to respond within a specified time, some people with mobility or dexterity disabilities or those using TTYs where they must read the messages may have difficulty completing actions before the timeout. TTY users may require extra time to interact with voice mail, messaging, auto-attendant and interactive voice response systems. For these users, limits on response time can present a real frustration and barrier to using such systems.
Another class of users that often have problems with voice mail, messaging, auto attendant, and interactive voice response systems are TTY users of the Telecommunications Relay Service (TRS). The TRS is a federally mandated system (Title IV of the ADA) that exists in all states, primarily to provide a translation function for TTY callers. This process is slower than audio calls. Voice mail, messaging, auto-attendant, and interactive voice response systems may timeout before the TTY caller can receive the system's message in TTY code from the CA and type in their response. In addition, when multiple choices are offered, TTY callers may need to clarify the options with the communication assistant before understanding their choices. For TRS users, response time limits are a significant barrier.
This provision is also very pertinent to users of a type of relay service known as Speech to Speech (STS). STS callers do not use TTYs. STS callers have speech disabilities and use specially trained STS CAs to repeat what they are saying so that the other party can understand them. Sometimes more than one attempt is necessary for the CA to understand what the person is saying before the CA can begin to pass the message on. Also, due to other physical disabilities, the STS user may also have difficulty entering DTMF tones in a timely fashion. Designers are reminded that this timeout provision applies to all users of voice mail, messaging, auto-attendant, and interactive voice response systems, not just to TTY users.
For these reasons, this provision requires that users be alerted when a time limit is approaching and that they be given the option for extending the time. Ideally, users will have the option of overriding the timed response and will be able to take as much time as required to enter their responses. Alternately, users may continually be alerted to the timeout and extend it as long as they need, until they can effectively respond to the system, as long as user's input is not erased each time a time extension is evoked and granted.
This provision applies to all voice mail, messaging, auto-attendant, and interactive voice response systems that require a user response within a specified time interval.
When timed responses are required, provide a warning 5 seconds before response period timeouts and ensure preservation of user input.
IVR systems used by the Postal Service should minimally use timed responses. However, when a timed response is required, users must be given the option of indicating that additional time is needed to complete their response, especially when using a standard or STS telecommunications relay service. If additional time is requested, the information entered before the warning announcement must be preserved and the user should be allowed to continue inputting information from the point in the message flow where the warning was communicated. For example, if the user is required to enter information, such as a Social Security number, the announcement and ensuing interaction should not erase the information entered by the user to that point. Resetting the system to provide the user with another timed try (with no more time to complete it than the first time) is not sufficient to conform to the requirement of allowing the individual to indicate that more time is required. In addition, the alert should repeat at the end of each response period until the user successfully completes the entire operation (i.e., message flow) or intentionally exits the function so that a destructive timeout does not occur. Preservation of user input and granting extensions of response time have the added benefit of helping ensure that users do not tie up the system for extended periods of time.
Where possible and practical, provide a way for users to repeat, slow down or increase the volume of IVR messages.
Some people with partial hearing loss only recognize some of the words in a message and may need to have messages repeated, repeated more loudly, or repeated more slowly so that they may comprehend what is being said.
Where possible and practical, provide multiple sensory mode alerts.
Multiple sensory methods can be used to alert users that the end of a response period is approaching. For example, in addition to having an audible alert inform a user that a timeout is about to occur, a visual alert (on a display) could accompany the audible alert for the benefit of users with hearing disabilities. If the alert is required for operation, this requirement would satisfy the Functional Performance Criteria (see section 4-2.1).
a. Examine the IVR product to identify all cases in which the product or service requires a response within a time interval.
b. Conduct a performance evaluation of the IVR product or service. For each case of a required response within a time interval, check the following:
• Does the system give an alert when the time interval is about to run out?
• Does the system allow the user to indicate that more time is required?
• Does the system provide sufficient time for the user to indicate that more time is required?
c. Does the system provide additional time as requested?
d. Use the checklists provided by the Alliance for Telecommunications Industry Solutions' Interactive Voice Response Accessibility Forum (http://inclusive.com/ivr_access/). There are checklists for "Voice IVR" and "TTY IVR." Both checklists should be completed to verify compliance with this provision.
The following references are applicable to the specific requirements stated here:
• Trace Research Center, University of Wisconsin, Guide
to Section 508
Telecommunications
http://www.trace.wisc.edu/docs/2002-508-collation/index.shtml
?style=default#telecomm
• Alliance for Telecommunications Industry Solutions'
IVR Accessibility
Forum
http://www.atis.org/atis/ivr/ivrhom.htm
• Gallaudet University's Technology Access Program:
Voice Mail and
IVR
http://tap.gallaudet.edu/IVR.htm
• Inclusive.com: IVR Accessibility
http://inclusive.com/ivr_access/
• ITU-T (ITU Telecommunication Standardization Sector):
DTMF
Standard
http://www.itu.int/home/
The ITU-T is a committee of the International Telecommunications
Union (ITU). The ITU-T is responsible for making technical
recommendations about telephone and data communication systems.
DTMF (Dual-Tone Multi-Frequency) tones are those used by touch-tone
telephones for tone dialing.
• ISO/IEC IS 13714 (1994). Information technology -
Document
processing and related communication - User Interface to
Telephone-based Services - Voice Messaging Applications
http://www.iso.org/iso/en/CatalogueDetailPage.CatalogueDetail?
CSNUMBER=22721
ISO 13714 is the most detailed of the three standards, but also the
narrowest. It applies to voice mail and voice messaging, specifically
and cannot be applied in its entirety to IVR systems.
• Human Factors and Ergonomics Society: HFES 200.5:
"Human Factors Engineering of Software User Interfaces - Interactive Voice Response (IVR) and Telephony"
http://www.atis.org/pub/IVR/HFES-200-5.pdf
• The Telephone Speech Standards Committee (TSSC) user
interface
guidelines for speech-enabled business IVR applications.
http://portal.acm.org/citation.cfm?doid=360405.360435
TSSC is a relatively informal industry group consisting of
representatives from companies developing speech-enabled IVRs for
business transactions. The committee is developing standardizing
terminology and definitions and set of common tasks across
applications for which there will be standardized commands and
prompts.
Where provided, Caller ID and other telephone function information that is available to other users of the same system must be provided to TTY users of that system, who may have visual impairments (§1194.23, Provision e).
This provision addresses two different problems: 1) how to make information that is normally presented on a display accessible to users who cannot see displays, and 2) how to provide information to TTY users that is usually provided on some landline digital telephone systems. The second problem is an issue when TTY users do not use landline digital telephone systems, due to the potential for the system to corrupt TTY signals.
The kind of information pertinent to this provision is information about telephone functions. Many current office and wireless telephones have displays that provide information such as Caller ID or an indication of new voice mail messages to the user. Caller ID functions display both the name and number of a caller. Someone with a visual disability might not be able to see this information and therefore would not experience "comparable access" to the telephone system, unless that information was provided in another format.
TTY users may have special problems obtaining this telephone function information, which is commonly transmitted and displayed via digital channels on landline telephone systems. TTY users have often been limited to the use of analog lines, which provide a connection point, support ring-signaling assistive technology, and avoid garbling of TTY through the digital telecommunications system (see sections 7-3 and 7-11). However, this approach does not provide some additional information provided through a digital telephone system. Therefore, this problem of TTY user telephone function information access needs to be addressed by design engineers for a telephone system to conform to the 508 standards. Supply Management contract officers should know that this is not a problem with all digital telephone systems.
Products and services that deliver, support, or provide special telephone function information, such as Caller ID, are covered by this provision. Automatic location identification (ALI), which displays a caller's address, is also covered, but is less commonly used.
Where possible and practical, provide built-in "talking Caller ID" functions that make telephone function information available directly in at least one nonvisual mode.
Most commonly, the nonvisual format for presenting telecommunications information is audio, so built-in "talking caller ID" approaches that use speech to make textual information available would satisfy this provision.
For systems for which "talking Caller ID" is not possible or practical, provide indirect access to telephone function information via assistive technology in at least one nonvisual mode.
Making this information available to assistive technology allows users to "read" the text through refreshable Braille displays or hear it through screen readers and other.Many landline office telephone systems support the TAPI interface, which is a standard protocol allowing exchange of information between telecommunications equipment and information technology equipment, (i.e., telephones and computers, see References). Through a newer version of the TAPI protocol known as Extended TAPI, telephone function information can be transmitted and presented on a personal computer using a softphone or other software application. Software that will translate the information from the Extended TAPI protocol to a form usable by assistive software is now available. If the software is left running in the background, the user may access (audibly or tactilely using assistive technology) the telephone number of an incoming call in the same length of time as someone looking at the telephone LCD display. A TAPI interface on a telephone not connected to a computer would probably not satisfy this provision unless the telephone had voice output of the visual information on its display.
When telephone function information is time sensitive (as it is with Caller ID), the information must be immediately available to the user without requiring action on the part of the user to access it.
When Caller ID and similar telephone function information is provided, devices must provide equivalent and timely access to the information, using either a direct approach such as "talking Caller ID" or an indirect approach via assistive technology compatibility. For example, if users have a "talking Caller ID" function on their telephones, the function must be user-selectable and be able to speak the Caller ID information immediately, if it is immediately displayed for other users.
a. For telecommunications products that include Caller ID or similar functions, identify the Caller ID or similar functions that are applicable. This must include all of the operational functions (which excludes maintenance and setup features) that end users have to use.
b. For customer premises equipment (CPE), or equipment employed on the premises of a person (other than a carrier) to originate, route, or terminate telecommunications, do the following:
• Determine if the product provides visual Caller ID. If it does, check for voice output (Talking Caller ID).
• If the product does not include visual Caller ID, check for the ability to add an external device specifically providing talking caller ID.
• Check for exposure of the Caller ID info to a computer workstation. For such products, check to see if software or a protocol (e.g., TAPI or extended TAPI protocol) is in use that will make Caller ID and other information available in least one non-visual mode.
c. For telecommunication equipment, other than customer premise equipment, used by a carrier to provide telecommunications services, including software integral to such equipment (including upgrades), determine how the system provides caller ID information to the customer premises eEquipment (CPE).
d. For either kind of product (equipment), if the Caller ID or other function information is time sensitive (as it is with Caller ID), check to see that the information is immediately available to the user without requiring user action to access.
The following references apply to the specific requirements stated here:
• Trace Research Center, University of Wisconsin, Guide
to Section 508
Telecommunications
http://www.trace.wisc.edu/docs/2002-508-collation/index.shtml
?style=default#telecomm
• Microsoft Telephony Application Programming
Interfaces (TAPI, TSPI,
MSPI)
http://msdn.microsoft.com/library/default.asp?url=/library/en-us/
dnanchor/html/tapitspimspi.asp
For transmitted voice signals, telecommunications products that provide telephone functions must 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 must be provided (§1194.23, Provision f).
People with hearing loss generally require additional volume to hear effectively. A user may not be able to understand speech at default volume levels. This provision enables people who are hard of hearing to increase their telephone volume gain to maximize their residual hearing. Many people with hearing loss are more sensitive to noise and less able to recognize words in the presence of noise than individuals with normal hearing. Therefore, increased volume assists these users in achieving a volume level and speech-to-noise ratio sufficient for their needs.
This provision applies to all telecommunications products that provide telephone functions (i.e., that transmit and receive a two-way voice signal), and for which the frequency response of the receiver is conducive to voice communication. Products that only provide one-way communications, such as speakers that give operating instructions to the user, are not covered by this provision.
This provision is consistent with the 1998 ANSI A117.1 document, "Accessible and Usable Buildings and Facilities" (see "references"). ANSI is the voluntary standard-setting body that issues accessibility standards used by the nation's model building codes. This provision is also consistent with the Telecommunications Act Accessibility Guidelines and proposed revisions to the ADA and Architectural Barriers Act Accessibility Revised Guidelines.
Telecommunications products that provide telephone functions (i.e., 2-way voice communication) must provide acoustic output (i.e., volume control) that is user-controllable and which provides amplification adjustable to a gain of at least 20 dB above the default volume.
The term dB refers to "decibel," a unit of relative sound intensity or a logarithmic unit used to describe a ratio. When used with Sound Pressure Level (SPL) (e.g., 65 db SPL), dB expresses an absolute measure of sound pressure level (SPL, or against no sound). Most telecommunications standards now define gain in terms of Receive Output Loudness Rating (ROLR), not SPL.
If a volume control (e.g., a calibrated wheel or slider) is provided that allows a user to set the gain anywhere from 0 to the minimum requirement of 20 dB gain above default, then there is no need to specify an intermediate (i.e., incremental) step of 12 dB. If an incremental volume control is provided (e.g., pressing a volume button repeatedly), one of the intermediate levels must provide 12 dB of gain above default. Some telephones are set with a higher default than others. These telephones are not given "credit" for providing a high default setting and must still provide 20 dB of gain above their default setting in order to conform to this provision. Some telephones may allow the user to reset the default volume. In these cases, the default is that setting that the manufacturer normally uses for the telephones at sales time.
a. Conduct a manual inspection of the product or device's telephone functions for presence of volume control. Determine the default volume level of the device.
b. If the device provides continuous amplification via a calibrated wheel, slider or other control, do the following:
• Measure the base (default) output and the maximum gain.
• Ensure that the maximum gain is at least 20 dB above the default level.
c. If the device provides discrete intermediate volume levels via a push button or other control:
• Measure the gain at each incremental level, ranging from base (default) to maximum.
• Ensure that the maximum gain is at least 20 dB above the default level.
• Ensure that one of the intermediate volume levels is 12 dB above default level.
The following references apply to the requirements stated in this section:
• FCC Hearing Aid Compatibility Act
http://www.fcc.gov/cgb/consumerfacts/hac.html
• ICC/ANSI A117.1-1998 Standard: Accessible and Usable
Buildings
and Facilities
http://webstore.ansi.org/ansidocstore/product.asp?sku=ICC%2FANSI+A117%2E1%2D1998
• Trace Research Center, University of Wisconsin, Guide
to Section 508
Telecommunications
http://www.trace.wisc.edu/docs/2002-508-collation/index.shtml
?style=default#telecomm
• OSHA regulations
http://www.osha-slc.gov/OshDoc/Interp_data/I19910401A.html
• FEC Voting System Standards, April 30, 2002: Provides
some
guidance on explicit volume levels
http://www.fec.gov/pages/vssfinal/vss.html
If a telecommunications product that provides telephone functions allows a user to adjust the receive volume, a function must be provided to reset the volume to the default level automatically after every use (§1194.23, Provision g).
This provision applies to all telecommunications products that provide telephone functions and that allow a user to adjust the volume. It was adopted from the ADA Accessibility Guidelines, where it applies to public telephones used by many people. It also has roots in the FCC's Part 68 rule, which requires an automatic reset when a landline telephone is hung up after a call in which the volume exceeds 18 dB gain. This reset provision is a safety feature for handsets implemented by the FCC, and does not apply when a product is in hands-free (i.e., speakerphone) mode. The ability to override the reset is helpful to people with hearing loss who find it inconvenient to adjust their preferred amplification level for every call, especially on incoming calls. In other words, the telephone will be loud every time that they answer it.
In December 2000, when the Access Board published the Section 508 standards in the Federal Register, it wrote in the preamble that allowing override of the reset function would require a waiver from the FCC. Since that time, the FCC did, in fact, issue such a waiver in March 2001 (http://ftp.fcc.gov/cgb/dro/vc_notic.doc) that states specific conditions (see "Techniques" below). There is also a Memorandum Opinion and Order at (http://ftp.fcc.gov/Bureaus/Common_Carrier/Orders/2001/da010578.doc). On the basis of these events, the Access Board believes that a telecommunications product can conform to this provision if it has either a fixed automatic reset function or an optional override of that switch. This interpretation does not change the 508 standards, which still require an automatic reset function to be provided. It simply acknowledges that a manufacturer (via the FCC waiver) may choose to allow users the ability to override the volume reset function, if the manufacturer wishes to design a telephone that way.
It is important to draw attention to the word "function" in this provision. There is a difference between requiring an automatic reset and requiring a function to reset automatically. Requiring a reset after each call is a fixed action, whereas including reset as an option provides flexibility to turn that function switch on or off. This 508 provision requires a automatic reset function, which is a broader requirement because it allows an override. Provision 1194.23(g) does not preclude an override function. For safety reasons, however, it is recommended that the reset function on telephones normally used by people who are hard of hearing be deactivated only when those telephones will not be shared with other people.
All telecommunications products that provide telephone functions and that allow a user to adjust the volume must provide acceptable, in-range default volume level settings.
The default level could be set anywhere by manufacturer or users within the acceptable ranges described in section 7-7.
All telecommunications products that provide telephone functions and that allow a user to adjust the volume must provide automatic reset of volume level and user override functions.
If a telecommunications product allows a user to adjust the receive volume, a function must be provided to reset the volume to the default level automatically after every use, and the user must be able to override this reset. Products that permit an override of automatic volume reset must comply with the terms in the FCC Report and Order discussed above under "Rationale." The FCC granted its waiver on the basis that telephone manufacturers meet the following conditions (which are required as part of this requirement):
• The volume reset override switch must be labeled as such and located on the telephone in such a way as not to be accessible to accidental engagement.
• A bright indicator light must be prominently displayed on the front of the telephone and must light up when the override is engaged and the telephone is placed in an off-hook condition.
• Next to the light must be a warning that the amplification is at a high level.
• A caution on the use of the volume reset override switch must be included in the users' manual.
• The telephone must 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.
Where possible and practical, telecommunications products that provide telephone functions and that allow a user to adjust the volume must provide a visual indicator of volume setting that can be read before picking up the handset.
This is especially important in telephones that use the push of a button to increase volume via software internal to the telephone. This display design contrasts with telephones, which use dials, slides, or other mechanical volume controls that can be easily viewed.
a. Conduct an inspection of the telecommunication product to determine if it provides receive volume control.
b. Amplify the volume, then verify that the volume level automatically resets after use with amplification.
c. Determine the default volume level and assess if the receive volume returns to default after use.
d. Determine if the product has a feature to allow the user to override the automatic reset of volume level. If it does, ensure that the product has complied with the FCC waiver requirements stated in section 7-8.2.2.
e. Determine if the product offers a visual indicator of volume setting that can be read befpre picking up the handset.
The following references apply to the requirements stated in this section:
• FCC Waiver of Hearing Aid Compatibility Volume
Control Standards,
March 2001, 47 C.F.R. § 68.317(f)
http://ftp.fcc.gov/cgb/dro/vc_notic.doc
• FCC Memorandum Opinion and Order
http://ftp.fcc.gov/Bureaus/Common_Carrier/Orders/2001/da010578.doc
• FCC Hearing Aid Compatibility Act
http://www.fcc.gov/cgb/consumerfacts/hac.html
• ICC/ANSI A117.1-1998 Standard: Accessible and Usable
Buildings
and Facilities
http://webstore.ansi.org/ansidocstore/product.asp?sku=ICC%2FANSI+A117%2E1%2D1998
• Trace Research Center, University of Wisconsin, Guide
to Section 508
Telecommunications
http://www.trace.wisc.edu/docs/2002-508-collation/index.shtml
?style=default#telecomm
• OSHA regulations
http://www.osha-slc.gov/OshDoc/Interp_data/I19910401A.html
• FEC Voting System Standards, April 30, 2002: Provides
guidance on
explicit volume levels
http://www.fec.gov/pages/vssfinal/vss.html
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 must be provided (§1194.23, Provision h).
There are several different ways in which hearing-aid wearers use the telephone. Some use the microphone on their hearing aid to pick up sound from the telephone speaker (i.e., "acoustic coupling"). Some others use a hard-wired electrical connection between the telephone and the hearing aid (i.e., "direct audio input," or "DAI"). A sizeable minority of hearing-aid wearers (typically, but not exclusively, those with higher degrees of hearing loss) use the telecoil feature found in many hearing aids to pick up the speech (i.e., "inductive coupling"). The term "hearing-aid compatibility" (HAC) as used in this section refers to inductive coupling or telecoil compatibility.
There are several problems that hearing-aid users contend with that lead them to choose inductive coupling. One is acoustic feedback, also known as whistling or squealing. This is caused when the telephone speaker is held against the part of the hearing aid with the microphone. Two other problems are that the speech signal is weakened as it passes across the distance between the telephone speaker and the hearing-aid microphone, and ambient noise may enter the hearing aid along with the speech.
The solution to these problems for many people is to bypass the microphone completely and change to the telecoil "T" setting on their hearing aid (colloquially called the "telephone switch" or "T-coil"). A T-coil is a small inductive receiver element located in a hearing aid. It is activated either manually using a small switch located on the hearing aid or by using a remote control supplied with some hearing aids. The input to the hearing aid will be through a magnetic field surrounding the telephone handset. By using a T-coil, a hearing aid can receive the magnetic field, and receive or demodulate the telephone speech from the signal. The advantage of receiving the speech signal as a magnetic signal rather than an acoustic one is that there is no acoustic feedback or background noise to deal with. This feature has made the T-coil option very popular with some hearing aid users. An estimated 20 percent of hearing aids in the U. S. are ordered with a T-coil option. This is what is meant by hearing-aid compatibility (HAC). HAC is common in telephones due to the Hearing Aid Compatibility Act of 1988, which requires HAC in all essential wireline telephones. That requirement is simply carried over to Section 508.
This concept is important, because some people with severe hearing loss are able to use the telephone only if they couple the hearing aid inductively to the telephone. It should not be assumed that a person who is hard of hearing will hear effectively with volume control alone.
The use of T-coils has widened to other applications. Some theaters and auditoriums have installed transmission loops, allowing T-coil users in the audience to receive the performance or presentation through a magnetic signal. Portable assistive listening systems have also been developed that transmit discussions and lectures from a microphone directly to an attendee's T-coil via a receiver with a magnetic coupler.
It is noteworthy that some cochlear implants (the new ear-level style) also have a telecoil incorporated in them. Previously, cochlear implant users could plug their speech processors into an adapter on landline telephones for direct listening. However, the inductive coupling method allows them to use telecommunications products effectively in a wireless fashion.
With developments in technology, new kinds of speaker elements were introduced. Some of these speaker elements produced no magnetic signal or one that is far lower, thus making it impossible to use a T-coil in those products. Because of this, in 1988, the Hearing Aid Compatibility Act was passed requiring all wireline and cordless telephones to provide a magnetic signal sufficient to support the use of a T-coil. The FCC enforces this industry requirement in Part 68 of its rules. In its rules, the FCC adopted EIA RS-504 as the technical requirements for hearing-aid compatibility.
This provision applies to both wireline and wireless telecommunications products that deliver an audio output to a transducer normally held to the ear, such as a traditional telephone handset or headset (Note: telephone "headsets" go over the ear, and should not be confused with earphones that go inside the ear). Currently, there is no FCC requirement or industry standard specifically concerned with defining HAC for wireless telephones, even though wireless telephones must comply with this provision because they do deliver audio output to a transducer normally held to the ear. Therefore, if the product is a fax machine that does not have a handset, this provision does not apply.
Telecommunications products that provide telephone functions and that deliver output by an audio transducer that is held up to the ear must emit a magnetic field sufficient for effective inductive coupling with hearing technologies.
These hearing technologies include hearing aids and cochlear implants equipped with T-coils. The signal provided must be within the useful range prescribed by the applicable industry standards in order to assure good reception with the wide variety of hearing aids. This provision is required because with developments in technology, new kinds of speaker elements have been introduced that produce no magnetic signal or one that is far lower, thus making it impossible to use a T-coil in those products. Because of this, in 1988, the Hearing Aid Compatibility Act was passed, requiring all wireline and wireless telephones to provide a magnetic signal sufficient to support the use of a T-coil. The FCC enforces this industry requirement in Part 68 of its rules (FCC Part 68.316). In its rules, the FCC adopted EIA RS-504 as the technical requirements for hearing aid compatibility (HAC).
Cellular telephones must follow special requirements in order to support hearing aid compatibility.
Currently, there is no FCC requirement or industry standard specifically concerned with defining HAC for wireless telephones. However, on July 10, 2003, the FCC modified the exemption for wireless telephones under the Hearing Aid Compatibility Act of 1988 to require that wireless telephone manufacturers and wireless telephone service providers make digital wireless telephones accessible to individuals who use hearing aids. The FCC ruling requires the following:
• Digital cellular telephone manufacturers must make at least two HAC-compliant handsets with reduced radio frequency emissions for each air interface (e.g., CDMA, TDMA, GSM) they offer available to carriers within 2 years. Each carrier providing digital wireless services, except for nationwide (Tier I) wireless carriers, must make at least two HAC-compliant handset models with reduced radio frequency emissions for each air interface it offers available to consumers within 2 years.
• Nationwide (Tier I) wireless carriers must offer two HAC-compliant handset models with reduced radio frequency emissions for each air interface they employ within 2 years or must ensure that one quarter of its total handset models are HAC-compliant with reduced radio frequency emissions within 2 years, whichever option yields a greater number of handsets.
• Digital cellular telephone manufacturers must make available to carriers at least two HAC-compliant handset models with telecoil coupling for each air interface they produce within 3 years. Each carrier providing digital wireless services must make available to consumers at least two HAC-compliant handset models with telecoil coupling for each air interface it offers within 3 years.
• Half of all digital cellular telephone models offered by a digital cellular manufacturer or carrier must be compliant with the reduced radio frequency emissions requirements by February 18, 2008.
• Manufacturers must label packages containing compliant handsets and must make information available in the package or product manual, and service providers must make the performance ratings of compliant telephones available to consumers.
In addition, the FCC established an exemption for digital cellular manufacturers and carriers that offer a minimal number of handset models. The FCC also encourages digital cellular telephone manufacturers and service providers to offer at least one compliant handset that is a lower-priced model and one that has higher-end features and encourages hearing-aid manufacturers to label their pre-customization products according to the ANSI C63.12-2001 standard.
a. Conduct an inspection of the telecommunication product to determine if it provides audio output from a transducer in a handset or headset.
b. Measure the magnetic field produced by the handset or headset microphone, or examine the manufacturer's product documentation:
• Wireline telephones: Must adopt FCC Part 68 Hearing Aid Compatibility (HAC) testing method.
• Wireless telephones: There are no final FCC criteria; should adhere to requirements stated above under "Techniques."
The following references are applicable to the specific requirements stated here:
• FCC Hearing Aid Compatibility Act
http://www.fcc.gov/cgb/consumerfacts/hac.html
• FCC Accessibility of Digital Wireless Phones to
Individuals with Hearing
Disabilities
http://www.fcc.gov/cgb/consumerfacts/accessiblewireless.html
• ICC/ANSI A117.1-1998 Standard: Accessible and Usable
Buildings
and Facilities
http://webstore.ansi.org/ansidocstore/product.asp?sku=ICC%2FANSI+A117%2E1%2D1998
• ICC/ANSI/IEEE C63.19-2001 Standard: Methods of
Measurement of
Compatibility between Wireless Communication Devices and Hearing
Aids
http://webstore.ansi.org/ansidocstore/product.asp?sku=
C63%2E19%2D2001
• ANSI IEC 60118-13 Ed. 1.0 b:1997 Standard: Hearing
aids - Part 13: Electromagnetic compatibility (EMC)
http://webstore.ansi.org/ansidocstore/product.asp?sku=IEC+
60118%2D13+Ed%2E+1%2E0+b%3A1997
Covers all relevant EMC phenomena for hearing aids. Specifies
measurement methods and acceptance levels for hearing aid immunity
to high frequency electromagnetic fields originating from digital
telephone systems as specified in IEC 61000-4-3.
• TIA-504-A, Telecommunications-Telephone Terminal
Equipment-Magnetic Field and Acoustic Gain Requirements for
Headset Telephones Intended for Use by the Hard of Hearing (R2003)
http://www.tiaonline.org/standards/search_results2.cfm?document_no=TIA%2D504%2DA
• Trace Research Center, University of Wisconsin, Guide
to Section 508
Telecommunications
http://www.trace.wisc.edu/docs/2002-508-collation/index.shtml
?style=default#telecomm
• OSHA regulations
http://www.osha-slc.gov/OshDoc/Interp_data/I19910401A.html
Interference with hearing technologies (including hearing aids, cochlear implants, and assistive listening devices) must be reduced to the lowest possible level that allows a user of hearing technologies to use the telecommunications product (§1194.23, Provision i).
Users of hearing technologies must not be prevented from using telecommunications products due to interference. The term "hearing technologies" includes hearing aids, cochlear implants, assistive listening devices, and other types of hearing technologies. These technologies pick up radio frequency signals that are radiated from digital wireless/cellular telephones' antennas using energy pulses that the hearing instrument circuitry picks up and demodulates as audible interference. In addition, magnetic fields generated by handset components, such as battery leads, may cause noise when hearing technology wearers are using the telecoil to couple inductively to the handset. Many hearing technology users, therefore, hear significant buzzing or pounding sounds that may completely mask the speech of a call and make the wireless digital telephone unusable for voice conversations. Some hearing technologies are more immune to interference than others. Some digital wireless/cellular telecommunications transmission technologies cause more annoying interference than others. For example, code division multiple access (CDMA)-based technologies generally cause less bothersome interference in hearing aids than global system for mobile communications (GSM) technologies.
"Compatibility" ideally means that the hearing instrument and telecommunications product function well as a system. That may require meeting both the magnetic coupling requirement (section 7-9) and this minimized interference requirement. Previously in the 1980s, when the Federal Communications Commission (FCC) referred to hearing-aid compatibility (HAC), it meant only magnetic coupling (Provision h, section 7-9). That provision was written at a time when wireless/cellular telephones were analog and most of those telephones did not cause interference.
However, in keeping with the new challenges posed by digital technologies, the FCC recently redefined HAC for digital wireless/cellular telephones to mean a combination of magnetic coupling and minimized interference. In August 2003, the Federal Communications Commission (FCC) issued a ruling directing wireless/cellular telephone manufacturers and wireless/cellular service providers to take steps to reduce the amount of interference caused by wireless/cellular telephone handsets. The FCC's Report and Order (http://ftp.fcc.gov/cgb/consumerfacts/ accessiblewireless.html) is intended to ensure that redesigned compatible cellular telephone handsets will be widely available and hearing-aid immunity will continue to improve. Specifically, it requires a percentage of wireless/cellular digital telephones with reduced interference within 3 years.
The hearing technology industry and cellular telephone industry recently completed a standard, ANSI C63.19-2001, which provides specific tests and target parameters for hearing aids and wireless/cellular telephones that should be used to determine compliance with this requirement.
This requirement applies to all products that provide a voice telecommunications function.
All products that provide telephone functions (i.e., 2-way voice communication) must minimize interference with hearing technologies to the lowest possible level that allows a user of hearing technologies to use telecommunications products, while at the same time maintaining desired product performance.
The following practices may help manufacturers and developers to do so:
• Consider applying methodologies outlined in ANSI C63.19-2001 to inform the product design process. ANSI C63.19-2001 provides procedures to measure electromagnetic emissions produced by wireless/cellular handsets. The ANSI standard provides two summary test results, one for radio frequency emissions that create a buzzing noise in hearing aids primarily when they are in the microphone (default) setting, and one for compatibility with the hearing aid's telecoil or similar assistive listening device component. For each of these results, there are four levels defined, with category 4 being the best (i.e., lowest emission) category. The FCC has set a minimum of category 3 for telephones that are to be considered and labeled as compatible with hearing aids (rule goes into effect in 2005). Note that CDMA-based technologies generally cause less bothersome interference in hearing aids than do GSM technologies.
• Consider applying information learned from the ICDR "Summit on interference to hearing technologies" (see "References"). In light of the FCC ruling mentioned above, the Federal Interagency Committee on Disability Research (ICDR) held this timely summit in September 2003. Participants included representatives from the digital wireless telephone and hearing aid industries, disability organizations, research centers, and federal agencies. Presentations were made on laws that address hearing-aid compatibility, new technological developments, telephone designs that reduce interference, and results of laboratory and consumer testing.
• Consider using various techniques that help reduce interference emissions from digital wireless (i.e., cellular) telephones, including the following:
• Positioning the antenna away from the ear area.
• Reducing power.
• Modifying the antenna to reduce radio frequency 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 omnidirectional antenna with a directional antenna.
a. Conduct an inspection of the telecommunication product to determine if it provides telephone functions (i.e., 2-way voice communications).
b. Use the ANSI/IEEE C63.19 standard as a guide for compatibility between wireless telephones and hearing technologies. It does not provide an absolute measure of interference across hearing-aid types. It may be useful to provide relative measures of interference among telephones with widely differing levels of interference. Handset, headset, and hearing-aid companies should provide ratings for their products against this standard.
The following references apply to the specific requirements stated in this section:
• FCC Hearing Aid Compatibility Act
http://www.fcc.gov/cgb/consumerfacts/hac.html
• FCC Accessibility of Digital Wireless Phones to
Individuals with Hearing
Disabilities
http://www.fcc.gov/cgb/consumerfacts/accessiblewireless.html
• ICC/ANSI/IEEE C63.19-2001 Standard: Methods of
Measurement of
Compatibility between Wireless Communication Devices and Hearing
Aids
http://webstore.ansi.org/ansidocstore/product.asp?sku=
C63%2E19%2D2001
• TIA-504-A, Telecommunications-Telephone Terminal
Equipment-Magnetic Field and Acoustic Gain Requirements for
Headset Telephones Intended for Use by the Hard of Hearing (R2003)
http://www.tiaonline.org/standards/search_results2.cfm?document_no=TIA%2D504%2DA
• Trace Research Center, University of Wisconsin, Guide
to Section 508
Telecommunications
http://www.trace.wisc.edu/docs/2002-508-collation/index.shtml
?style=default#telecomm
• OSHA regulations
http://www.osha-slc.gov/OshDoc/Interp_data/I19910401A.html
• Federal Interagency Committee on Disability Research
(ICDR) Summit
(September 2003): "Summit on Interference to Hearing Technologies."
http://www.icdr.us/
Participants included representatives from the digital wireless
telephone
and hearing technologies industries, disability organizations, research
centers, and Federal agencies, such as the FCC and the Food and
Drug Administration (FDA). Presentations were made on laws that
address hearing aid compatibility, new technological developments, and
telephone designs that reduce interference, and the results of
laboratory and consumer testing.
Products that transmit or conduct information or communication must 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 that use encoding, signal compression, format transformation, or similar techniques must not remove information needed for access or must restore it upon delivery (§1194.23, Provision j).
Services such as closed captioning and video description provide access to multimedia transmission for people with disabilities (see Chapter 8, Video and Multimedia). The information communicated through these services includes text, audio, and coded information for delivery and/or display of the information. This telecommunications product provision was created largely in response to problems with transmission of closed captioning information being distorted or removed - due to transmission problems - but it also applies to TTY tones (which are covered specifically in other telecommunications product provisions as well).
Historical sources of problems have been stripping and garbling or loss of synchronization of caption data due to compression, duplication, transmission, frame loss or removal, re-encoding, or digital rights management methods. Some systems completely remove captioning accidentally during transmission or compression simply because the designers are not aware that it exists in the synchronization, periods of the signal. On other systems, compression techniques may corrupt the captions, because the compression techniques were designed without knowledge of or consideration for captions. Still other systems, to save bandwidth, do not deliver secondary or auxiliary channels that carry accessibility information. Thus, the captioning or video description information is blocked, and the users who rely on these services for accessibility are denied their benefit.
Another example of TTY problems with digital service is in wireless (e.g., cellular) communications. In some systems, frame errors occur at levels that are tolerated well for voice communications, but are very disruptive to TTY communication. Other problems have arisen from some noise-cancellation algorithms in codecs and from some implementations of digital signaling and audio signal compression schemes. However, the wireless industry, under order from the FCC to make services compatible with TTYs, has now completed its work (in collaboration with handset and TTY manufacturers). Wireless carriers have reported to the FCC that their services carry TTY signals intact.
This provision applies to products and systems that transmit or conduct information or communications - regardless of format - that may contain coding necessary for accessibility (e.g., captioning information or video description in video transmissions). It would also apply to any other devices that transmit information or encode information for transmission (and decode it after). This provision also clearly applies to TTY signals passed through office telecommunications products and services (e.g., routers). TTYs were designed to function as modems over standard telephone lines. Some technological changes in telecommunications systems have caused problems for the TTY signals. This provision is written broadly so as to cover future telecommunications services that may affect accessibility. Captioning, video description, and TTY products that meet the criterion of "cross-manufacturer, non-proprietary, industry-standard" should be supported.
Telecommunications is defined as "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 used extensively in law and regulations affecting telecommunications products. Therefore, there exists substantial legislative, regulatory, and case history defining its terms and scope.
Products that transmit or conduct information or communication must 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.
Products and technologies that use encoding, signal compression, format transformation, or similar techniques must not remove information needed for access or should restore it upon delivery. Some examples of such codes or protocols include the following:
• NTSC Video with closed captions.
• NTSC Video with descriptive audio in the alternate audio channel.
• Digital Video with closed captions.
• Digital Video with secondary audio programs.
• Traditional telephone data stream between two users of TTY equipment.
• Voice over IP data stream between two users of TTY emulating software.
a. Inspect the product or technology for products that transmit or conduct information. Inventory each product or service in the transmission path.
b. Depending on the product type, determine what accessibility information is encoded in the production, signal, or communication and understand the intended delivery approach based on planned system usage.
• For systems that support telephone functions (i.e., 2-way voice communication), the accessibility information will usually be a TTY signal of some kind (which varies based on device).
• For video and multimedia productions, the accessibility will be closed captioning and secondary audio program content (or audio description) (see chapter 8).
c. Examine each product or service in the transmission path to ensure that none of the products or services alter, corrupt, delete, or make unusable any included accessibility information transmitted with the production, signal, or communication along the way to the end user.
• For systems that support telephone functions, insure that cross-manufacturer, non-proprietary, industry-standard codes for TTY are passed through in a usable format.
• For video and multimedia productions, insure that cross-manufacturer, non-proprietary, industry-standard codes for captioning and audio description are passed through in a usable format.
The following references are applicable to the specific requirements stated here:
• Gallaudet University: "Tools for field testing TTYs with wireless phones"
http://tap.gallaudet.edu/TTYtools/
• EIA-708 Specification for Digital Television Closed
Captioning
http://www.tiaonline.org/standards/search_results2.cfm?document_no=EIA%2D708%2DB
• FCC: DTV Regulations
http://www.fcc.gov/dtv/
• FCC Accessibility of Digital Wireless Phones to
Individuals with Hearing
Disabilities
http://www.fcc.gov/cgb/consumerfacts/accessiblewireless.html
• ICC/ANSI/IEEE C63.19-2001 Standard: Methods of
Measurement of
Compatibility between Wireless Communication Devices and Hearing
Aids
http://webstore.ansi.org/ansidocstore/product.asp?sku=
C63%2E19%2D2001
• TIA-504-A, Telecommunications-Telephone Terminal
Equipment-Magnetic Field and Acoustic Gain Requirements for
Headset Telephones Intended for Use by the Hard of Hearing (R2003)
http://www.tiaonline.org/standards/search_results2.cfm?document_no=TIA%2D504%2DA
• Trace Research Center, University of Wisconsin, Guide
to Section 508
Telecommunications
http://www.trace.wisc.edu/docs/2002-508-collation/index.shtml
?style=default#telecomm
• Trace Research and Development Center, "Access to Voice over Internet Protocol (`VoIP')"
http://www.tracecenter.org/docs/2003-NMRC-VoIP-Access/
• Trace Research and Development Center, "Voice over Internet Protocol ("VoIP") Services Forum", December 1, 2003, Expanded Opening
Comments of Gregg C Vanderheiden Ph.D.
http://www.tracecenter.org/docs/2003-12-1-FCC-VoIP-Forum/index.htm
• OSHA regulations
http://www.osha-slc.gov/OshDoc/Interp_data/I19910401A.html
• Federal Interagency Committee on Disability Research
(ICDR) Summit
(September 2003): "Summit on Interference to Hearing Technologies."
http://www.icdr.us/
Participants included representatives from the digital wireless
telephone
and hearing technologies industries, disability organizations, research
centers, and Federal agencies, such as the FCC and the Food and
Drug Administration (FDA). Presentations were made on laws that
address hearing aid compatibility, new technological developments, and
telephone designs that reduce interference, and the results of
laboratory and consumer testing.
Products that have mechanically operated controls or keys must comply with the following four requirements (§1194.23, Provision j): (1) Controls and keys must be tactilely discernible without activating the controls or keys. (2) Controls and keys must be operable with one hand and must not require tight grasping, pinching, or twisting of the wrist. The force required to activate controls and keys must be 5 lbs. (22.2 N) maximum. (3) 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. (4) The status of all locking or toggle controls or keys must be visually discernible and must be discernible either through touch or sound.
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 (e.g., an RJ-11 plug that may be connected into a jack only one time). Some of the reasons behind the four provisions in this requirement are given below:
• Requirement (1) requires that individual keys be locatable and distinguish