Most of the product information we received from companies or located independently is found in the product data sheets in Section IV. We contacted 96 companies, analyzed more than 900 products for accessibility, and prepared data sheets on 487 products, covering all 15 Product Types. These products represent the offerings of 42 companies.
The Market Monitoring Report process itself offered companies the opportunity to review their products and consider which features address the Access Board Guidelines. It was hoped that this internal review would provide an opportunity for company employees to learn more about the Access Board Guidelines, disability access in general and begin to encourage creative thinking about access solutions. The actual MMR will also provide an excellent resource for manufacturers of telecommunications equipment, customer premises equipment and telecommunications service providers. Manufacturers will be able to learn from other companies’ products and access features and service providers will receive a general overview of those telecommunications products with access features that are on the market.
It is important to distinguish between product functions and product features. Functions are the “product’s answer to the set of user tasks”; features are the “user tools” inherent in the product used to perform the functions (Wood, 1995). That is, placing a telephone call is a function; the dial tone and the touch-tone keypad are features used to accomplish the function. Every Product Type has a different set of functions. Every Model within a Type shares the basic functions of that Type, but may also perform additional functions. Models permit users to perform functions through their features, and Models vary widely as to which features they contain.
This variation in features, and in the design of the user interface in general, poses a difficult problem for the analysis of accessibility. In fact, each function of a product may require a user to perform several operations in order. A given person with a disability may be able to accomplish some, but not all of them. For example, placing a call on a basic telephone requires the user to lift the handset, listen for the dial tone, and press one or more keys. Some people with impaired manipulation or hearing loss will be able to accomplish part of this “chain of operations” but not all of them. Their ability to perform some of them does not count. A user must be able to perform all of them in order to place the call.
The research for this Report could only review features. There was no way to investigate the actual user interfaces of all the products we analyzed to determine what was required of the user to perform a complete function. There is great value in a feature-by-feature analysis. Where key access obstacles are known, improvements in a single feature may be all that a large number of people with disabilities need in order to be able to use a product. Designers and engineers need to focus on the feature level at several stages in product design and implementation, and the fine details of each feature can be manipulated to improve accessibility. However, a feature-by-feature analysis can never reveal the extent to which the product is “accessible” since it cannot explore the chain of operations and reveal its weak or missing links.
In the Consumer Survey we received several comments from consumers with different disabilities about their difficulty in getting product information about access features in retail stores.
“It took me a long time to find one I could use
because the store clerks didn’t seem to know anything about the products,
or maybe what I was asking was too unimportant to them.”
“It’s hard for me to shop for phones because I have to ask for
the boxes and even then I can’t always find what I’m looking for.”
We performed a short experiment to determine how widespread this problem might be.
We randomly selected 20 Models (10 cordless telephones and 10 wireless telephones). The feature we selected for the test was an audible low-battery indication, a feature that is present on many portable products but is not often highly salient.
We examined product packaging, store shelf feature lists, collateral material (display text or brochures for the specific Model), and manuals at a total of 12 retail locations (8 large electronics stores and 4 brand name wireless telephone stores) over a two-week period.
We later returned to the same stores and asked 12 clerks (one for each location) the same question about the access feature, asking only about Models for which we already knew the answer.
The total number of cases was 40; 28 cordless phones and 12 wireless phones, 31 at electronics stores and 9 at wireless stores.
Product packaging was available in 26 of the 40 cases, either by examining
the item on the shelf or asking for one from behind the counter.
(Packaging was available for all but 2 of the wireless cases.)
There was no mention of a low-battery indication on 11 of them.
Of the remaining 15, 6 were ambiguous (e.g. “low battery warning”)
and 4 referred only to a visual signal.
Five explicitly mentioned an audible alert.
Product feature lists on almost all of the packaging was printed in small
type.
There was either a shelf list of features or collateral material in all 40
cases. There were 5 mentions of
a low battery indicator in brochures, and none on shelf lists.
Two brochures mentioned a distinct low battery tone; the other 3 mentioned
or showed a visual display.
Manuals were made available in 17 of the cases (including all of the wireless stores). With 2 exceptions, electronics store clerks would not open a sealed box to provide a look at the manual. Few offered to try to find a manual.
When examined, 15 of the manuals indicated that there was a low-battery indicator
and whether it was visual (5), audible (7), or both (3).
Four of the 8 electronics store clerks stated that they were sure there was a low-battery indicator. Six of them sought either packaging, a manual, or a colleague to answer the question; the other 2 did not follow up on the question in any way. Of the 6 who answered it, 5 did so correctly.
All 4 wireless clerks attempted to answer the question, after stating that
they knew there was an indicator. They also used packaging, manuals, or a colleague.
All 4 were correct.
In our analysis of the industry-supplied information and the consumer comments,
it became clear that certain Product Types always or almost always address certain
Guidelines. For example, a basic
wireline residential telephone, with twelve mechanical keys in a conventional
3 X 4 matrix layout, and no display, is essentially operable without vision
(Guideline 1193.41a), both for receiving and placing calls.
Similarly, no identified one-way pager interferes with hearing technologies
(Guideline 1193.43h), since these pagers are receivers only, not transmitters.
Note that this does not mean that it is impossible to design one of these devices
so that would fail to address the respective Guideline.
They will be, however, the exceptions that prove the rule. We selected
features that “generically address a Guideline” when fewer than 5%
of the Models of the given Equipment Type lacked the feature in any form.
Clearly, both manufacturers and consumers will need to pay attention
to the Guideline when designing or purchasing products of a given Type.
There are three benefits to including this generic information.
The first is to notify consumers that they will be able, more likely
than not, to find an acceptable model of this Type.
This confidence could be an important incentive to technologically unsophisticated
consumers worried about their ability to find a product that will meet their
needs when the product type is a new one, or new to them.
Second, this information serves to notify companies that a new design
will more easily address the Guideline if it stays within the generic solution
as described. This should not be
interpreted as a mandate to discourage innovation, but to emphasize that a radical
departure from the “typical” design requires that the designers re-analyze
in detail the specific access issue in question.
Third, including generic information enables regulators to focus their
resources on the difficult problems rather than redundantly review all models
of all Types that address any given Guideline.
In some of the discussions about Section 255 an approach has been mentioned
that accessibility and/or compatibility should be reviewed across a company’s
entire product line rather than on a product-by-product basis.
This “product line” view would argue that a company’s
products should be seen as complying with a Guideline as long as at least one
of its models of each relevant Product Type addressed that Guideline.
Note that including this “Generic” section in the Report does
not explicitly or implicitly support or oppose a product line view. The
product line view issue is a compliance issue, and this Report is an attempt
to understand current market offerings and consumer behaviors.