Access to Information Technologies by people with disabilities

Arnold F. Winkler                                                                                                                   May 8, 2000


Update May 8, 2000:  The below mentioned NPRM has been issued in the Federal Register.  Comments are invited by May 30, 2000.


US activities


In November of 1999, the Architectural and Transportation Barrier Board (called the Access Board) issued a Notice of Proposed Rulemaking (NPRM) on revisions to the Americans with Disabilities Act Access Guidelines (ADAAGs).  These are mandatory requirements for publicly accessible facilities.  For the most part, they address physical and architectural issues, but there are also sections that are directly relevant for IT equipment. 


These specific areas of the proposed regulation are:


·         Section 508 of the Rehabilitation Act, which covers accessibility of electronic and information technology procured by the federal government

·         Section 255 of the Telecommunications Act, which covers accessibility of telecommunications

·         Section 707 contains revisions to the Americans With Disabilities Act (ADA) accessibility guidelines (ADAAGs) for IT in public places, such as information kiosks


All three proceedings share the common involvement of the U.S. Architectural Barriers and Transportation Compliance Board (Access Board) in setting technical requirements for accessibility.  The Access Board's requirements in these three areas are put into effect through policies set by, respectively, the Federal Acquisitions Regulations (FAR) Council; the Federal Communications Commission (FCC); and the Dept. of Justice.


ITI, the Information Technology Industry Council, has formed a working group to monitor the activity, assess the possible impact on the industry, and develops industry comments to the NPRM. 


The working group discussed the concern that firms may be required by customers (e.g., government agencies under Section 508, institutions that provide public accommodation under the ADA) to declare compliance with vague requirements that cannot be measured objectively.  Courts have already ruled that government agencies can mandate compliance with requirements that are impossible to meet using today's technology, as long as there is a reasonable prospect that technical development will advance sufficiently to make the goal achievable.  Therefore, it is possible that the generic performance requirements from the Access Board would become mandatory even in the absence of detailed technical standards supporting design and conformance with the generic performance requirements. 



Section 707 – ATMs, Fare Machines, and Information Kiosks


The new regulations, valid for any such installation except for drive-up only ATMs, specify:

·         Easy access with wheel chairs

·         The same degree of privacy for all users (headsets or connector jacks?)

·         Specific key arrangement on input pads, physical separation, tactile marking, color coding and location of function keys

·         Adjustable time delay to automatic disconnect

·         Visual and audible operating instructions initiated by the user

·         Video display screens to be visible from 40 inches above the floor

·         Font and size of characters on the screen, background and foreground with sufficient contrast

·         Dispensing of bills with lowest denomination on top

·         Options for receipts in print or voice or both


Section 255 – Telecommunications Act


Telecommunication functions

·         Telecommunication products for voice communication must either provide TTY functionality or a standard non-acoustic point connection point for a TTY

·         TTY signals must be cross industry and non proprietary

·         Voice mail and interactive voice systems must be useable by TTYs, the timing of required responses must be variable

·         Caller-ID and similar functionality must be available for users with TTYs or users that can not see displays

·         Volume control for audio must be provided, with automatic default setting after each use

·         Magnetic, wireless coupling of audio output to hearing technologies shall be provided

·         Interference to hearing technology (assistive devices) shall be reduced to the lowest level possible.


Section 508 – Access of people with disabilities to electronic and information technologies


This section specifies requirements for accessibility for the built environment, transit vehicles, telecommunication equipment and sets design standards for federally funded facilities.  More specifically, it covers the full range of electronic and information technologies in the Federal sector, including those used for communication, duplication, computing, storage, presentation, control, transport and production.  The term "information technology" includes computers, ancillary equipment, software, firmware and similar procedures, services (including support services), and related resources. 


 Exempt are systems used for military command, weaponry, intelligence, and cryptographic activities, and if the accessibility standard would impose an "undue burden" for the agency.  The term "undue burden" is defined as "significant difficulty or expense".  However, the agency must still provide people with disabilities access to the information or data that are affected. 


General requirements:

·         Color coding must not be the only means to convey information

·         Physical location of operable controls are narrowly specified

·         The flash rate of blinking elements must not exceed 2 Hertz

·         For timed responses, the time must be adjustable to at least 5 times the default time

·         If biometric identification or activation is used, an alternative form must be provided

·         For touch-operated controls, an alternative method without body contact must be available


Component specific requirements

·         The status of switches must be discernible through touch or sound

·         Pointer actions must be possible via keyboards also

·         Navigation must be possible by keystrokes

·         Assistive technologies must be supported

·         Images, text and text attributes, as well as electronic forms must be available through assistive technology

·         User preferences should be stored on the system

·         All telecommunication requirements as specified for section 255

·         For all video or multimedia displays, 13 inches or larger, closed captions capability must be provided

·         Television tuners must have secondary audio output

·         Video and multimedia productions must have captions for the hearing impaired and audio descriptions for people with visual impairments – alternate presentation must be selectable.

·         Information Kiosks must not require end users to attach assistive technology, must provide privacy, and must allow audio-level adjustment.


Compatibility with assistive technology

·         Information must be transmitted in cross industry, non proprietary formats and protocols.

·         Technologies that compress or transform the signals must restore them to original form on delivery

·         Connectors for assistive technologies must comply with industry standards

·         Operating system software must not interfere with assistive technology


Functional performance criteria

·         At least one mode of operation must support visually or hearing impaired persons with assistive technologies

·         At least one mode of operation must be provided that does not require speech

·         At least one mode of operation must be provided that does not require fine motor control and that is operable with limited reach and strength.


Information, documentation and support

·         Agencies must ensure that product documentation to end users is available in alternate form at no additional charge

·         Agencies must ensure that end users have access to a description of accessibility features of products, provided by the agency in alternate modes.

·         Support services for products must be provided to accommodate the communication needs of end users with disabilities.




It is proposed that the standard must be implemented 6 months after being published in the Federal Register. 

Beginning August 7, any individual with disabilities may file a complaint alleging that a Federal agency fails to comply with section 508 – this discrepancy is due to delays in specifying the requirements and in the public review process. 

Products, procured before August 7, 2000 don't need to be retrofit, but the fate of existing, constantly maintained web sites is not clearly defined – it is expected that they will be accessible.


ITI comments to the NPRM


ITI has reviewed the proposed regulations. Its major comment is that the regulations are too much implementation oriented – preferably they should describe the functionality requirements rather than prescribing the method of implementing the features.  This leaves the way open for technological innovation and development of advanced assistive technology. 



Non-US activities


ISO/IEC : Addressing the needs of older persons and people with disabilities in standardization work


ISO and IEC recognize the need to include the requirements of older persons and people with disabilities in all relevant standards production and revision work.  This can be achieved by following the basic principles of:

·         Universal and accessible design

·         Direct consumer representation of older persons and people with disabilities

·         Relevant information interchange


ISO/IEC published these principles in March 2000 encouraging the National Member Bodies to ensure that national standards as well as international ones are developed, reviewed, and approved with this additional design goal in mind. 


EN Mandate to the European Standards Bodies


The European commission issued a mandate in June of 1999 for a guidance document in the field of safety and usability of products for people with special needs (e.g. elderly and disabled). 


The mandate covers standards that promote barrier-free design, enabling the use of products by disabled and elderly people by applying the principles of design for all, adaptable design, and assistive technology. 


Four Technical Committees in CEN are addressing the specific needs:

·         CEN/TC 293 – Technical aids for disabled persons, e.g. wheel chairs

·         CEN/TC 224 – Machine readable cards, consumer requirements

·         CEN/TC 251 – Medical informatics

·         CEN/TC10/WG 7 – lifts and escalators



W3C activities


WAI, the Web Access Initiative of the W3C -World Wide Web Consortium has taken the lead in defining technical solutions to the requirements in section 508 of the Access NPRM.  The WAI group, strongly supported by the AFB (American Federation of the Blind) has produced documents that are intended to advise designers of web sites so that the access requirements can be met. 

Voice interfaces for input and output, color coding, adjustable font sizes, memorized end-user profiles, interfaces for assistive technologies, and more  … are described in sufficient detail to allow developing web pages and web browsers with the required functionality.



Information flow


Links to documents mentioned above are on the Standards Access web site - http://standards.tr.unisys.com/access/access.htm


If you have any comments, requests, or contributions, or if you are interested in participating in ITI's activities, please contact us. 

Steve.Oksala@Unisys.com or Arnold.Winkler@Unisys.com