The Access Board should consider
harmonizing its architectural access guidelines with Section 255 Guidelines, as
it relates to public telephones. As
noted above, one of the continuing complaints about public telephones is the
difficulty people with visual impairments have in locating them.
This may deserve an additional Guideline directed towards both the
manufacturers and installers of public telephones.
There seems to be a contradiction in
this Guideline. Its text is,
“Operable with low vision and limited or no hearing” and its explanation is,
“Provide at least one mode that permits operation by users with visual acuity
between 20/70 and 20/200, without relying on audio output.”
“Without relying on audio output” seems to mean that designing the
audio output so that it can be used by people who are hard of hearing would not
meet the Guideline. However
the initial text includes both people who are deaf and people who are hard of
One way to resolve this is to remove
“limited or” from the initial text, so that is reads, “Operable with low
vision and no hearing,” and its explanation is, “Provide at least one mode
that permits operation by users with visual acuity between 20/70 and 20/200,
without relying on audio output.” Except
for the addition of the visual acuity limitation, this would be identical to
Another resolution is to divide the
Guideline into two. One of them
would read, “Operable with low vision and limited hearing” and its
explanation is, “Provide at least one mode that permits operation by users
with visual acuity between 20/70 and 20/200, without relying on audio output
that cannot be heard by individuals with limited hearing.”
The other would read, “Operable with low vision and no hearing,” and
its explanation is, “Provide at least one mode that permits operation by users
with visual acuity between 20/70 and 20/200, without relying on audio output.”
A second difficulty with this Guideline
is that the degree of visual impairment is specified (“visual acuity between
20/70 and 20/200”) in a way that may be counterproductive.
For example, what if a user’s visual acuity is 20/65?
This text should be changed to read, “visual acuity better than or
equal to 20/200.”
A third difficulty with this Guideline is that the degree of visual impairment is specified but the degree of hearing impairment is not. Industry may have difficulty addressing this Guideline without better guidance as to the degree of hearing loss intended to be supported.
Strategy 2.a. now reads: “Avoid any timed-out situations or provide instances where the user must respond to a question or moving display in a set amount of time or at a specific time (e.g., a rotating display).” The word “provide” should be removed.
The explanation for this Guideline reads: “Provide visual information through at least one mode in auditory form.” Strategies 2.b and 2.c. refer to braille and large raised print. The explanation should be changed to read “Provide visual information through at least one mode in non-visual form.”
Strategy 2.b. is redundant.
In Strategy 1, the word “auditorial” should be changed to “auditorially.”
The explanation now reads, “Reduce interference to hearing technologies (including hearing aids, cochlear implants, and assistive listening devices) to the lowest possible level that allows a user to utilize the product.” The phrase “that allows a user to utilize the product” should be removed, or replaced by “so that a person who uses those hearing technologies can also use the product.”
In Strategy 3, “9 mm jack” should be changed to “2.5 mm jack.”
In addition to their life as regulatory objects, these Guidelines should be able to serve consumers and industry. Consumers may want to see only Guidelines that specifically address their own disabilities; an industry audio engineer may want to see only Guidelines that address audio input and output. We may rightly say that such a narrow view of accessibility will lead individuals and companies to incorrect conclusions about both their responsibilities and the best and most creative means of solving access problems. Nevertheless, in the face of a task that to them seems strange and overwhelmingly complex, engineers and product designers may begin by searching for the familiar and constrained. It behooves the Board to offer as friendly and usable a set of documents as possible.
The Guidelines that deal specifically
with product features are now roughly divided into three categories: control and
operation (input), availability of information (output), and compatibility with
assistive technology. Here are
other groupings that different audiences may find useful:
Other schemes are possible, either collapsing or expanding the categories.
User interface (conceptual/menus/software)
In the course of researching this
Report, it became clear to us that certain features are closely tied to certain
Guidelines. For example, 1193.41(a)
“Operable without vision” and nibs on the ‘5’ key; 1193.41(e)
“Operable with limited manual dexterity” and large buttons; and 1193.43(a)
“Availability of visual information” and speech synthesis are all
effectively linked. Some of
these features are mentioned in the Strategies section of the respective
Guideline, and some are not. A
format that explicitly shows these linkages – and can be added to as new
solutions emerge – would be a useful aid to corporate designers and engineers.
The Electronic and Information Technology Access Advisory Committee (EITAAC) developed additional technical material that could be useful in elaborating the Section 255 Guidelines in just this manner. EITAAC’s work is based on Section 508 of the Workforce Investment Act of 1998. This section uses a different compliance standard than Section 255 of the Telecommunications Act of 1996: “undue burden” instead of “readily achievable.” In using any of the EITAAC results, this distinction must be carefully observed.
The Guidelines that refer to cognitive
or language impairments should specify and address the range of individuals in
this category, which includes people with severe mental retardation and highly
intelligent people with difficulties reading text or interpreting speech.
The needs of these two groups are so different as to be worthy of
distinct categorization. It should be remembered that more dimensions than measured
intelligence exist, such as memory capacity, speed of response, and ability to
Correspondingly, market indications are large if all subsegments are considered. This is especially true if people with certain mental illnesses are included; according to the National Health Interview Survey, one of the largest categories of people who have difficulty using the telephone are people experiencing stress or having difficulty concentrating (NCHS, 1994 -1995).
The current Guidelines are of three types: control and operation of products, compatibility with assistive devices, and availability of information through products, that is, the ability to receive content from another person or source. There are no Guidelines concerning producing content except for three compatibility Guidelines (1193.51(a), 1193.51(d), and 1193.51(e)), and these may not be sufficient for a person with speech impairment. For example, a person may use a telephone headset with a microphone and earphone. The earphone is covered by Guidelines 1193.51(b), but not the microphone. Similarly, 1193.43(e) covers amplification of the incoming signal, but not the outgoing one. The Board should develop one or more Guidelines covering the expressive production of content.