508@HHS

Technical Assistance FAQ's

Technical Standards - Hardware

1194.23 (b) Telecommunications products which include voice communication functionality shall support all commonly used cross-manufacturer non-proprietary standard TTY signal protocols.

Q:	Is support for 300 baud ASCII code or V.18 required?
A:	Support for 300 baud ASCII code is required. Support for V.18 is sufficient but not required.

Q:	Must a product also support 300 baud ASCII in addition 45.5 baud Baudot?
A:	No, 300 baud ASCII code alone is not sufficient to meet the requirements of this provision; 45.5 baud Baudot code is also required.

Q:	Given that 300 Baud ASCII support is required for this carriage requirement 1194.23(b), but is it also required for IVR systems under provision 1194.23(c)?
A:	No — Based on the requirement of 1194.23(b), all TTYs must support the 45.5-baud Baudot protocol. The requirement of 1194.23(c) states that IVR etc. systems must be 'usable by TTY users with their TTYs'. Therefore, if an IVR etc. system works with 45.5 baud Baudot, then it should meet the requirement for provision (c).

1194.23 (c) Voice mail, auto-attendant, and interactive voice response telecommunications systems shall be usable by TTY users with their TTY's.

Is a VM/AA/IVR system that is usable by a 'DTMF-enabled TTY configuration' sufficient for the requirements of this provision?

No, this provision does not presume that a TTY can produce DTMF tones. This provision places requirements on VM/AA/IVR systems, including;

VM/AA/IVR systems should be able to transmit voice data in the 45.5 baud Baudot TTY protocol
VM/AA/IVR systems should be able to hold TTY encoded messages without corruption.

Note: A 'DTMF-enabled TTY configuration' is a TTY that either produce DTMF tones itself, or can work together with a DTMF tone producing system (such as a telephone) to generate DTMF tones.

1194,23 (e) Where provided, caller identification and similar telecommunications functions shall also be available for users of TTYs, and for users who cannot see displays.

Q:	Clarify the basis for determining which functions are similar to caller identification. Is visual display of information the basis for similarity to caller identification?
A:	Although visual means are often used to display output from such functions, the basis for similarity is that these are functions provided by the telecom service provider.

1194.23(f) For transmitted voice signals, telecommunications products shall provide a gain adjustable up to a minimum for 20 dB. For incremental volume control, at least one intermediate step of 12dB of gain shall be provided.

Q:	With regard specifically to telephones, may the first part of this standard be interpreted to require a gain adjustable up to a minimum of 20 dB only when the resulting amplitude would not exceed the maximum acoustic pressure by OHSA for audio transducers that are held against the ear?
A:	This provision places requirements on the gain of the input signal that is provided by a telecommunications product. The requirement is not about acoustic pressure or Sound Pressure Level (SPL). We may assume that products will not allow volumes that exceed the maximum SPL, but this is not the requirement of this provision.

1194.23 (g) If the telecommunications product allows a user to adjust the receive volume, a function shall be provided to automatically reset the volume to the default level after every use.

Q:	In many cases with standard equipment, achieving a >20 dB gain requires two sources of amplification. For example, the maximum gain from many telephones phones is 12 dB, which is also true of many amplified handsets. To achieve 20 dB, both pieces of equipment need to be used. Requiring both to reset adds cost and complexity. Can this be interpreted in a way that allows just one to reset? e.g., define the “default level” as a level not to exceed “neutral” + 12 dB.
A:	No. The ‘default’ level is 0 gain – it is whatever the input signal is. The reset should return to this base input signal level.

Q:	Confirm the proposed assumption, “Assume that this standard refers to products which have a handset, headset, earphone, or other transducer near the ear.”
A:	Yes. The assumption is reasonable. This Section 508 requirement is intended to be consistent with FCC Part 68.317 (f) Hearing aid compatibility volume control: technical standards. This FCC regulation is specific to transducers intended to be held near the ear.

1194.23 (i) Interference to hearing technologies (including hearing aids, cochlear implants, and assistive listening devices) shall be reduced to the lowest possible level that allows a user of hearing technologies to utilize the telecommunications product.

Q:	Does this requirement allow digital wireless products to interfere with hearing aids not specifically designed to work with wireless phones?
A:	No.

Q:	May digital wireless vendors await an FCC ruling before addressing the provision?
A:	This requirement is not changed, altered, or dependent upon FCC ruling. If all manufacturers wait to address the requirement of this provision, there may be exceptions based on a lack of commercial availability until a product meeting this requirement is available for government procurement.

1194.23 (j) Products that transmit or conduct information or communication, shall pass through cross-manufacturer, non-proprietary, industry-standard codes, translation protocols, formats or other information necessary to provide the information or communication in a usable format. Technologies which use encoding, signal compression, format transformation, or similar techniques shall not remove information needed for access or shall restore it upon delivery.

Q:	Does this requirement apply to products that duplicate information or communication, in addition to those that ‘transmit or conduct information or communication’?
A:	No. This does not apply to copy machines.

1194.23 (k)(2) Products which have mechanically operated controls or keys, shall comply with the following: Controls and keys shall be operable with one hand and shall not require tight grasping, pinching, or twisting of the wrist. The force required to activate controls and keys shall be 5 lbs. (22.2 N) maximum.

Q:	Define tight grasp. How tight is tight? Does the 5 lb. force maximum apply?
A:	No definite measure of tight is given.

Q:	Does the 5 lb. force maximum apply to pinching, or is pinching prohibited?
A:	At least one mode of operation that does not require pinching must be provided.

Q:	Does the 5 lb. force apply to twisting of the wrist as a torque maximum, or is twisting of the wrist prohibited?
A:	At least one mode of operation that does not require twisting of the wrist must be provided.

1194.24 (a) All analog television displays 13 inches and larger, and computer equipment that includes analog television receiver or display circuitry, shall be equipped with caption decoder circuitry which appropriately receives, decodes, and displays closed captions from broadcast, cable, videotape, and DVD signals. As soon as practicable, but not later than July 1, 2002, widescreen digital television (DTV) displays measuring at least 7.8 inches vertically, DTV sets with conventional displays measuring at least 13 inches vertically, and stand-alone DTV tuners, whether or not they are marketed with display screens, and computer equipment that includes DTV receiver or display circuitry, shall be equipped with caption decoder circuitry which appropriately receives, decodes, and displays closed captions from broadcast, cable, videotape, and DVD signals.

Q:	This provision refers to ‘conventional displays measuring at least 13 inches vertically’, while the Television Decoder Circuitry Act of 1990 applies to displays measuring 13 inches diagonally. Is this an intentional difference?
A:	No. The intent was to be consistent with the Television Decoder Circuitry Act of 1990. The requirement of this provision is effectively the same as that of the Television Decoder Circuitry Act of 1990. Any product capable of displaying analog digital signals must comply with the provision. Conventional television displays are typically measured diagonally. A screen size measuring 13 inches vertically will in general be larger than one measuring 13 inches diagonally. Since manufacturers of conventional television displays must meet the requirement of both standards, the result is that the smaller of the two measures (i.e. 13 inches diagonally) is effectively the measurement for which this requirement to include caption decoder circuitry applies. This is the intent of this provision.

Q:	To be fully consistent with the Television Decoder Act, this provision would only apply to displays with receiver/tuner circuitry. Does this provision apply to displays (including projectors) that have analog video input and can be used to display closed captioned videotapes but have no receiver/tuner?
A:	No. This provision does not apply to television displays that do not include receiver/tuner circuitry.

1194.24 (b) Television tuners, including tuner cards for use in computers, shall be equipped with secondary audio program playback circuitry.

Q:	Confirm or correct the following: “Assume this provision applies to stereo digital television tuners as well as stereo analog tuners. Mono devices cannot decode SAP. The encoding method requires stereo.”
A:	Yes. This assumption may be true due to technology capability today. However, this is irrelevant from the perspective of the Standard. The requirement is to provide SAP playback circuitry with television tuners.

Q:	If a television tuner is procured without integrated SAP circuitry, and with no stand-alone SAP circuitry directly included in that procurement, but stand-alone SAP circuitry is available in the installation into which it will be placed, is the requirement of these provisions met?
A:	Yes. The requirement for accessibility is on the agency/program that is acquiring E&IT. It is the system that should be assessed. Elements of the system that are needed to make the system accessible must already be in place as a part of the existing technical environment, or they must be acquired as a part of the procurement.

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

Q:	A company would like to make its copier as accessible as possible. They will add voice output for blind users. They would like to also provide an industry standard connection so that deaf/blind individuals could use a Braille notetakers as an interface to the copier. Does this violate 25a or is it equivalent facilitation?
A:	Providing an industry standard connection point to allow assistive technologies to interface with an otherwise self contained product does not result in a violation of 1194.25 (a), neither is it a case for equivalent facilitation.

Q:	Verify the following assumption: “Assume that if a product is being purchased for an application where the user cannot install or attach adaptive technology, it is considered a self-contained, closed product. When a product is being purchased as a part of a package of products, the package of products (the system) is the thing that needs to be assessed.”
A:	Yes. The intended use of the E&IT is an important factor in determining the applicability of the standard. It is the responsibility of the agency program to determine the relevant requirements based on product functional characteristics as they are expressed in the use of the system within the technical environment. It is the system that should be assessed. Elements of the system that are needed to make the system accessible must already be in place as a part of the existing technical environment, or they must be acquired as a part of the procurement.

Q:	Is the following statement true? “If a self-contained closed product is being employed as a computer peripheral or connected to a network, other portions of the Section 508 standards may apply”.
A:	Yes. The intended use of the E&IT is an important factor in determining the applicability of the standard. It is the responsibility of the agency program to determine the relevant requirements based on product functional characteristics as they are expressed in the use of the system within the technical environment.

1194.25 (c) Where a product utilizes touchscreens or contact-sensitive controls, an input method shall be provided that complies with §1194.23 (k) (1) through (4).

Q:	Does this provision apply only to controls operated by human touch, or is a control that is operable by touching an area on the surface of the product with a pencil or other object?
A:	The terms touchscreen and contact-sensitive control do not necessarily imply touch by the human body – contact with objects such a mouthstick, stylus, or pencil are also included.

Q:	The standard explicitly excludes 'maintenance and setup' from the requirements for operable controls. Does this imply that product functions for maintenance and setup are excluded, and that all product functions for normal daily operation are included, independent of the methods to access the function (i.e. various controls)?
A:	No. All product functions typically available to users through touchscreens or contact sensitive controls should be available via an input method that complies with §1194.23 (k) (1) through (4). Setup and maintenance functions typically done for normal operation are NOT exempt from Section 508 requirements. The definition of operable controls states: “A component of a product that requires physical contact for normal operation.” Note that it is the responsibility of the agency program to determine what constitutes ‘normal operation’ for E&IT use within their technical environment.

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

Verify the assumption “Assume that an alternative control is either another biometric choice or else complies with §1194” to make sure the alternative of another biometric choice is ok and that the alternative doesn’t have to be non-biometric.

No. A non-biometric alternative must be provided. Note that the intended use of the E&IT is an important factor in determining the applicability of the standard. It is the responsibility of the agency program to determine the relevant requirements based on product functional characteristics as they are expressed in the use of the system within the technical environment.

Elements of the system that are needed to make the system accessible must already be in place as a part of the existing technical environment, or they must be acquired as a part of the procurement. An individual E&IT product may only provide a biometric form of user identification if the system overall provides a non-biometric alternative.

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

Q:	Incremental volume control only – no continuous amplification/volume control allowed?
A:	The size of the increment may be infinitesimally small, so a ‘continuous’ amplification/volume control is allowed. Rather than continuous, a suggested term is ‘variable’ volume control. The term ‘incremental’ is to distinguish from controls that only go directly to the maximum level. Thus, while the increment may be infinitesimally small, it should not be a single increment the size of the entire range of volume.

Q:	Is there any upper limit that may be specified for volume level, or do we assume that products will not allow volumes that exceed a safe maximum Sound Pressure Level (SPL) although this is not the requirement of this provision?
A:	No upper limit is specified by this requirement. It may be assumed that manufacturers will not develop products that exceed a safe maximum SPL.

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

Q:	Is there guidance on an adequate variety of color selections or range of contrast levels?
A:	Adequate contrast is an accessibility issue that applies beyond E&IT, and so has been examined by the Access Board for other ADA requirements. There are open issues on what constitutes an adequate range of contrast.

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

Does this requirement apply to other blinking elements beyond a display screen, such as LED’s, illuminated buttons, and flashing words?

LED’s and illuminated buttons are not covered by this requirement. Flashing words are typically elements on a display screen, and so typically are included as screen elements that could cause harmful screen flicker. In contrast to a display screen, items that are small in size and typically have a low illumination such as LED’s and illuminated buttons may easily be looked away from and generally do not have a negative affect on users.

1194.25 (j)(2) Products which are freestanding, non-portable, and intended to be used in one location and which have operable controls shall comply with the following: Where any operable control is 10 inches or less behind the reference plane, the height shall be 54 inches maximum and 15 inches minimum above the floor.

Does the requirement automatically drop exactly to the 46-inch max height after the 10-inch (depth) limit has been reached?

Yes, according to 1194.25 the requirement is written as a step function. It is recognized that other international regulations that require a linear progression of the maximum height of controls between 54 inches and 46 inches.

Note that a manufacturer may attempt to make a case for equivalent facilitation if the height of a control is decreased according to a range or linear progression over the control depth, rather than making a quantum step to decrease the depth of the control.

1194.26 (b) If a product utilizes touchscreens or touch-operated controls, an input method shall be provided that complies with §1194.23 (k) (1) through (4).

Does this provision apply only to controls operated by human touch, or is a control that is operable by touching an area on the surface of the product with a pencil or other object?

The terms touchscreen and contact-sensitive control do not necessarily imply touch by the human body – contact with objects such a mouthstick, stylus, or pencil are also included.