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FINAL RULE
ELECTRONIC AND INFORMATION TECHNOLOGY ACCESSIBILITY STANDARDS
QUICK REFERENCE GUIDE



Summary

The Final rule provides technical criteria (or provisions) that outline the specific accessibility requirements of various types of technologies and performance-based requirements, which focus on the functional capabilities of covered technologies. In order for product developers, accessibility compliance testers & procurement agents to determine the compliance of systems (software and/or hardware) to the accessibility requirements as specified in the final rule, there need to be well documented, testable guidelines. This document captures the input (related to evaluation tools, techniques, methodologies and metrics as applicable to each provision specified in the final rule) received thus far to the online survey conducted by the Accessibility Forum team. The Accessibility Forum team encourages the Accessibility Forum participants and interested parties to take the online survey located at http://www.accessibilityforum.org/section508survey/.

It is hoped that this input will provide the project groups with some direction and serve as a useful starting point.

NOTE: Apart from minor corrections and edits, the thoughts reflected in this document are the original comments of the survey respondents.

Links within this document:

  1. 1194.21 Software applications and operating systems
  2. 1194.22 Web-based intranet and Internet information and applications
  3. 1194.23 Telecommunications Products
  4. 1194.24 Video and multimedia products
  5. 1194.25 Self contained, closed products
  6. 1194.31 Functional performance criteria

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Survey Responses

1194.21 Software applications and operating systems.

Provision a. When software is designed to run on a system that has a keyboard, product functions shall be executable from a keyboard where the function itself or the result of performing a function can be discerned textually.

Issue Responses
Metrics
  1. Metric is the excitability of the product. Need to define the time frame for execution of a task. For example, is the time taken 5 seconds, 5 minutes or 5 hours? Need human factors comparison for qualitative measure of differences with non-disabled, but that is not a direct measure. Therefore, need to focus on the execution itself. So, a discussion needs to be held on the time question above. Otherwise it is binomial, either “yes” or “no”.
  2. Do not provide the user with a mouse. Test Tab order - the cursor should move to each entry or selection on the screen. Important items should have keyboard short cuts.
Measurement techniques
  1. Observation: This is a costly process. Survey at the beginning or end of the product use. This is where the end user stats success or not in using. Enter a 1 or 0, a yes or no. This response survey could be a key on the keyboard; a function specifically identified as not or as using the product currently on the active screen.
  2. Use test scripts simulating work - time 5 transactions using the mouse and time 5 transactions using only the keyboard. If 5 is more than 33% greater than 4, the software fails.
Why cannot this metric be measured? No comments received

Provision b. Applications shall not disrupt or disable activated features of other products that are identified as accessibility features, where those features are developed and documented according to industry standards. Applications also shall not disrupt or disable activated features of any operating system that are identified as accessibility features where the application programming interface for those accessibility features has been documented by the manufacturer of the operating system and is available to the product developer.

Issue Responses
Metrics
  1. Some measure of “On” or “Off” or “error” condition happening if some disruption or feature is disabled.
  2. Test the software with the access features turned on while performing a script simulating work.
Measurement techniques
  1. Trap error messages to be parsed by some intelligent agent waiting or running the background.
  2. Turn on Sticky Keys. Perform script. Note any interference. Repeat with MouseKeys; Repeat rate, Key bounce, Magnifier and an assistive application that uses the OS access architecture such as MS Active Accessibility or Java Bridge.
Why cannot this metric be measured?
  1. What have been "identified as accessibility features" and what are the industry standards by which they were developed and documented by?

Provision c. A well defined on-screen indication of the current focus shall be provided that moves among interactive interface elements as the input focus changes. The focus shall be programmatically exposed so that assistive technology can track focus and focus changes.

Issue Responses
Metrics
  1. Be able to track the number of times and places where the focus shifts off the projected trajectory.
  2. Test Tab order - the cursor should move to each entry or selection on the screen. Jaws for Windows (JFW) or WindowEyes would announce the object type as you cursor to it if it were programmatically exposed. Also, perform the Tab order test with JFW on.
Measurement techniques
  1. An intelligent agent that tracks the possible focus paths and is alerted when an off focus event occur.
  2. Load JFW. Test Tab order for each screen. Note if fields are not named correctly. Note fields that are skipped.
Why cannot this metric be measured?
  1. Where is the list of Assistive Technology?

Provision d. Sufficient information about a user interface element including the identity, operation and state of the element shall be available to assistive technology. When an image represents a program element, the information conveyed by the image must also be available in text.

Issue Responses
Metrics
  1. Visual inspection.
  2. Use JFW, cursor to each graphic element and see if it has a Tag.
Measurement techniques
  1. Visual inspection.
Why cannot this metric be measured?
  1. What is "sufficient", what is "available" and which Assistive Technology?

Provision e. When bitmap images are used to identify controls, status indicators, or other programmatic elements, the meaning assigned to those images shall be consistent throughout an application's performance.

Issue Responses
Metrics
  1. Boolean
  2. Visual inspection.
  3. Use a screen reader to go to each image and record the Graphic ID assigned to the image, tool tip text and function performed. Sort the list by Graphic ID and see if the same ID was used for multiple functions.
Measurement techniques
  1. Check each and every one for inconsistency. Note: does this apply to Operating Systems or just applications?
  2. Visual inspection.
  3. Use JFW. Cursor to each control. Record its Graphic ID, tool tip info and function.
Why cannot this metric be measured?
  1. What is "sufficient", what is "available" and which Assistive Technology?

Provision f. Textual information shall be provided through operating system functions for displaying text. The minimum information that shall be made available is text content, text input caret location, and text attributes.

Issue Responses
Metrics
  1. Visual inspection.
  2. Need to consult screen reader manufacturer for appropriate test.
Measurement techniques
  1. Visual inspection.
Why cannot this metric be measured?
  1. "Textual information" is not defined, nor are the "attributes."

Provision g. Applications shall not override user selected contrast and color selections and other individual display attributes.

Issue Responses
Metrics
  1. Boolean
  2. Visual inspection
  3. See if the application changes colors selected by the user.
Measurement techniques
  1. Test for override. Note that not overriding user settings does not guarantee that the result will be usable.
  2. Visual inspection.
Why cannot this metric be measured?
  1. What is "sufficient", what is "available" and which Assistive Technology?

Provision h. When animation is displayed, the information shall be displayable in at least one non-animated presentation mode at the option of the user.

Issue Responses
Metrics
  1. Boolean
  2. Visual inspection
  3. Measurable for simple animation: Using a screen reader, cursor to the animation control and see if it offers a link to a description or a descriptive audio track for the animation.
Measurement techniques
  1. Check to see if there are alternatives. Note that a non-animated presentation mode may still be completely inaccessible.
  2. Visual inspection
Why cannot this metric be measured?
  1. What is "sufficient", what is "available" and which Assistive Technology?

Provision i. Color-coding shall not be used as the only means of conveying information, indicating an action, prompting a response, or distinguishing a visual element.

Issue Responses
Metrics
  1. Boolean
  2. Visual inspection
  3. Test the software with a black and white monitor.
Measurement techniques
  1. Check every use of color
  2. Visual inspection
Why cannot this metric be measured?
  1. What is "sufficient", what is "available" and which Assistive Technology?

Provision j. When a product permits a user to adjust color and contrast settings, a variety of color selections capable of producing a range of contrast levels shall be provided.

Issue Responses
Metrics
  1. Boolean
  2. Visual inspection
  3. Look for the change option and see what it does.
Measurement techniques
  1. Check set-ability of color and contrast. Note that "variety" and "range" are undefined.
  2. Visual inspection
Why cannot this metric be measured?
  1. What is "sufficient", what is "available" and which Assistive Technology?

Provision k. Software shall not use flashing or blinking text, objects, or other elements having a flash or blink frequency greater than 2 Hz and lower than 55 Hz.

Issue Responses
Metrics
  1. Frequency
  2. Visual inspection and frequency counter.
  3. It is possible to test the cases where blinking occurs commonly or under specific conditions. Blinking that occurs under rare error
Measurement techniques
  1. Measure frequency. Note that candlepower variation and normal viewing subtended angle should be included.
  2. Visual inspection and frequency counter.
Why cannot this metric be measured? No comments received

Provision l. When electronic forms are used, the form shall allow people using assistive technology to access the information, field elements, and functionality required for completion and submission of the form, including all directions and cues.

Issue Responses
Metrics
  1. Visual inspection.
  2. Test with a screen reader. Tab to each field and see if it announces each field correctly and if it goes to every field. Tab order will also be important if the form is to be filled out while interviewing someone. Tab order must follow the order of the script for the form to be functional.
Measurement techniques
  1. Visual inspection.
Why cannot this metric be measured?
  1. "Assistive technology" undefined.

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1194.22 Web-based intranet and Internet information and applications.

Provision a. A text equivalent for every non-text element shall be provided (e.g., via "alt", "longdesc", or in element content).

Issue Responses
Metrics
  1. All audio must be captioned or otherwise displayed in text format
  2. Visual inspection to assure compliance.
  3. There are some common elements to many web pages that do not translate well to a text alternative, e.g. image maps, charts, tables. However, it not impossible, nor even difficult, to provide an alternative to such elements. This rule would be easier to comply with, and easier to measure, if it said “text alternative” instead of “text equivalent.”
Measurement techniques
  1. Visual inspection
  2. An alternative to a click able image map could be as simple as a list of areas on the map with text links to the information. A "measurement standard" could include fulfilling this. Does the alternative provide access to either the information in text form, or to a reasonable alternative explanation/description of the visual information?
Why cannot this metric be measured? No comments received

Provision b. Equivalent alternatives for any multimedia presentation shall be synchronized with the presentation.

Issue Responses
Metrics
  1. It is important for text to be as synchronized with the audio as possible
  2. Visual inspection
Measurement techniques
  1. Visual inspection
Why cannot this metric be measured? No comments received

Provision c. Web pages shall be designed so that all information conveyed with color is also available without color, for example from context or markup.

Issue Responses
Metrics
  1. Visual inspection
  2. It would be easier to comply with and to measure this standard if it said "information conveyed with color" rather than "all information conveyed with color.” For example, links to other pages are typically presented on a page with both _underscore_ and text in color. The mere fact that a text link is in a different text color does "convey information," i.e. it visually signals the user that it is a link. A requirement that that information be available without color is silly. If colored image buttons on a menu are in color, this standard seems to say that web managers must also provide a similar page in black and white.
Measurement techniques
  1. Visual inspection
  2. If (for example) colored image maps are on a web page, it's easy enough to convert that to a black and white image using shading and black and white patterns rather than colors.
Why cannot this metric be measured? No comments received

Provision d. Documents shall be organized so they are readable without requiring an associated style sheet.

Issue Responses
Metrics
  1. Visual inspection
Measurement techniques
  1. Visual inspection
Why cannot this metric be measured? No comments received

Provision e. Redundant text links shall be provided for each active region of a server-side image map.

Issue Responses
Metrics
  1. Count of links.
Measurement techniques
  1. Use of active intelligent agents and visual inspection
Why cannot this metric be measured? No comments received

Provision f. Client-side image maps shall be provided instead of server-side image maps except where the regions cannot be defined with an available geometric shape.

Issue Responses
Metrics
  1. Visual inspection.
Measurement techniques
  1. Visual inspection.
Why cannot this metric be measured? No comments received

Provision g. Row and column headers shall be identified for data tables.

Issue Responses
Metrics
  1. Count of fields for row and column.
Measurement techniques
  1. Visual inspection or active intelligent agents used to translate and compare row and column numbers.
Why cannot this metric be measured? No comments received

Provision h. Markup shall be used to associate data cells and header cells for data tables that have two or more logical levels of row or column headers.

Issue Responses
Metrics
  1. Visual inspection.
Measurement techniques
  1. Visual inspection.
Why cannot this metric be measured? No comments received

Provision i. Frames shall be titled with text that facilitates frame identification and navigation.

Issue Responses
Metrics
  1. Visual inspection.
  2. Can the framed information be book marked (or added to "favorites") on a user's browser? If not, then the page should not be considered accessible. Framed sites that box in or "trap" other linked websites should be considered un-accessible.
Measurement techniques
  1. Visual inspection.
Why cannot this metric be measured? No comments received

Provision j. Pages shall be designed to avoid causing the screen to flicker with a frequency greater than 2 Hz and lower than 55 Hz.

Issue Responses
Metrics
  1. Visual inspection.
  2. Animated GIF's are generally a safety hazard. There's no "line to draw" that's reasonably measurable on which images can trigger a seizure and which can't.
Measurement techniques
  1. Visual inspection.
Why cannot this metric be measured? No comments received

Provision k. A text-only page, with equivalent information or functionality, shall be provided to make a web site comply with the provisions of this part, when compliance cannot be accomplished in any other way. The content of the text-only page shall be updated whenever the primary page changes.

Issue Responses
Metrics
  1. Visual inspection.
Measurement techniques
  1. Visual inspection.
Why cannot this metric be measured? No comments received

Provision l. When pages utilize scripting languages to display content, or to create interface elements, the information provided by the script shall be identified with functional text that can be read by assistive technology.

Issue Responses
Metrics
  1. Visual inspection.
Measurement techniques
  1. Visual inspection.
Why cannot this metric be measured? No comments received

Provision m. When a web page requires that an applet, plug-in or other application be present on the client system to interpret page content, the page must provide a link to a plug-in or applet that complies with §1194.21(a) through (l).

Issue Responses
Metrics
  1. Captioning features sometimes require the appropriate plug-in such as QuickTime or RealPlayer
  2. Visual inspection.
  3. It seems that in its present form, the provision "condones" the use of PDF files, which are inconvenient and user-hostile.
Measurement techniques
  1. Visual inspection.
Why cannot this metric be measured? No comments received

Provision n. When electronic forms are designed to be completed on-line, the form shall allow people using assistive technology to access the information, field elements, and functionality required for completion and submission of the form, including all directions and cues.

Issue Responses
Metrics
  1. The ability to navigate anywhere without relying on voice prompts
  2. Visual inspection.
Measurement techniques
  1. Visual inspection.
Why cannot this metric be measured? No comments received

Provision o. A method shall be provided that permits users to skip repetitive navigation links.

Issue Responses
Metrics
  1. Count of links.
Measurement techniques
  1. Use active intelligent agents to interpret navigation links and provide count comparison.
Why cannot this metric be measured?
  1. Not clearly worded

Provision p. When a timed response is required, the user shall be alerted and given sufficient time to indicate more time is required.

Issue Responses
Metrics
  1. The alert should be given in sound AND text
  2. Time signal compared to some standard.
Measurement techniques
  1. Agent can be used to measure time and provide comparison.
Why cannot this metric be measured? No comments received

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1194.23 Telecommunications Products

Provision a. Telecommunications products or systems which provide a function allowing voice communication and which do not themselves provide a TTY functionality shall provide a standard non-acoustic connection point for TTYs. Microphones shall be capable of being turned on and off to allow the user to intermix speech with TTY use.

Issue Responses
Metrics
  1. Speed of visual transmission in words/second - Sound transmission needs to measure normal volume but have the ability to exceed the normal output in decibels (Db).
  2. Clear transmission of Baudot signals to another TTY. For mixed TTY/Voice calls - Capability of TRS service to handle calls from that equipment.
Measurement techniques
  1. Taped samples rated by people with a hearing loss in two ranges. Hard of hearing severe 40-75 db and profound hearing loss in excess of 75 Db with some in 100 db or greater loss range.
  2. Check error rates based on typing and speaking from a script
Why cannot this metric be measured?
  1. This TTY is used for hearing impaired only. Should not be used for hearing person except to communicate with deaf persons.

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

Issue Responses
Metrics
  1. Though the manufacturers have multiple standards, they still need testing at the maximum level. If Telecommunications sets that measurement standard, the manufacturers will modify and become uniform.
  2. Clear transmission of Baudot signals to another TTY
Measurement techniques
  1. Check error rates based on typing and speaking from a script.
Why cannot this metric be measured?
  1. This TTY is used for hearing impaired only. Should not be used for hearing persons except to communicate with deaf persons.

Provision c. Voice mail, auto-attendant, and interactive voice response telecommunications systems shall be usable by TTY users with their TTYs.

Issue Responses
Metrics
  1. Voice messages need to be placed in the system by a voice transcriber via computer... with captioning of the voice translator being automatically coded for TTY messages prior to be accepted by the phone system. Translation of the TTY message should be fed into the computer through a reverse process.
Measurement techniques No comments received
Why cannot this metric be measured? No comments received

Provision d. Voice mail, messaging, auto-attendant, and interactive voice response telecommunications systems that require a response from a user within a time interval, shall give an alert when the time interval is about to run out, and shall provide sufficient time for the user to indicate more time is required.

Issue Responses
Metrics
  1. Warnings should be given in both voice and text
Measurement techniques No comments received
Why cannot this metric be measured?
  1. This function may not be measurable…as it would take a secondary response receiver.
  2. Those who use TTY’s require more time typing on TTY. In other words, most deaf persons don’t seem to like voice mail, menu system (like the ones used by telemarketers). Prefer call direct to proper terminal

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

Issue Responses
Metrics
  1. This would require voicing the number, which could be done by feeding the caller ID into the computer - and accessing a voice reader file.
  2. Pass-through of data to Caller-ID display
  3. Newer, more modern TTD should have built in caller ID, built in strobe light, and instant feedback.
Measurement techniques
  1. Newer, more modern TTD should have built in caller ID, built in strobe light, and instant feedback.
Why cannot this metric be measured? No comments received

Provision f. For transmitted voice signals, telecommunications products shall 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 shall be provided.

Issue Responses
Metrics
  1. 20 db is not significant enough for most folks with a severe or profound loss.
  2. It could be measured, but only to help those with minimal impairment.
Measurement techniques No comments received
Why cannot this metric be measured? No comments received

Provision 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.

Issue Responses
Metrics
  1. For public use, this is important and should be part of the design of the product. However, for people who are the only users of this product, this is definitely an inconvenience. Once the level has been set, there should be a way to maintain that level unless over ridden.
Measurement techniques No comments received
Why cannot this metric be measured? No comments received

Provision h. 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 shall be provided.

Issue Responses
Metrics
  1. Two measures are needed: amplification and clarity (lack of outside interference)
Measurement techniques No comments received
Why cannot this metric be measured? No comments received

Provision 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.

Issue Responses
Metrics
  1. No more than .05% at 40 db across all frequencies. Interference now seems to be the greatest problem in discrimination.
  2. Clarity of phone conversation without side effects like humming, static, etc.
Measurement techniques No comments received
Why cannot this metric be measured? No comments received

Provision 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.

Issue Responses
Metrics
  1. Need a product standardization lab that will sample productions and certify them such as the UL does for electrical equipment.
  2. Clarity of text upon receiving data. If Yes, What measurement techniques could be employed?
Measurement techniques No comments received
Why cannot this metric be measured? No comments received

Provision k. Products, which have mechanically operated controls or keys.

Issue Responses
Metrics No comments received
Measurement techniques
  1. Use standard keyboard adjustments found on computers
Why cannot this metric be measured? No comments received

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1194.24 Video and multimedia products.

Provision 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, wide screen 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.

Issue Responses
Metrics
  1. Intensity of contrast between words and background and Light meter intensity test
  2. (It is the respondent’s belief that) All televisions, even those smaller than 13" can be captioned.
Measurement techniques
  1. Measuring tape
Why cannot this metric be measured?
  1. This TTY is used for hearing impaired only. Should not be used for hearing persons except to communicate with deaf persons.

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

Issue Responses
Metrics No comments received
Measurement techniques No comments received
Why cannot this metric be measured?
  1. This TTY is used for hearing impaired only. Should not be used for hearing persons except to communicate with deaf persons.

Provision c. All training and informational video and multimedia productions, which support the agency's mission, regardless of format, that contain speech or other audio information necessary for the comprehension of the content, shall be open or closed-captioned.

Issue Responses
Metrics
  1. Captioning can be opened in many production pieces and closed in some and run through a laptop so that the captions can be opened by a program that couple provide a reading of coding on media. The equipment is available and standards should match those of the captioned videos that are being produced for entertainment movies.
  2. Captioning must be displayed in sync with audio as much as possible
Measurement techniques
  1. Listening and viewing (reading) - check for error rates
Why cannot this metric be measured?
  1. This TTY is used for hearing impaired only. Should not be used for hearing persons except to communicate with deaf persons.

Provision d. All training and informational video and multimedia productions which support the agency's mission, regardless of format, that contain visual information necessary for the comprehension of the content, shall be audio described.

Issue Responses
Metrics
  1. Audio output of the audio descriptions can be transmitted by FM systems and measured by volume with an ear bud attached to a transducer.
Measurement techniques No comments received
Why cannot this metric be measured?
  1. This TTY is used for hearing impaired only. Should not be used for hearing persons except to communicate with deaf persons.

Provision e. Display or presentation of alternate text presentation or audio descriptions shall be user-selectable unless permanent.

Issue Responses
Metrics
  1. Permanent is preferable.
Measurement techniques No comments received
Why cannot this metric be measured?
  1. This TTY is used for hearing impaired only. Should not be used for hearing persons except to communicate with deaf persons.

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1194.25 Self contained, closed products.

Provision 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.

Issue Responses
Metrics
  1. “As a totally deaf person I'll be SO HAPPY when I can tell if any piece of equipment is ON and when I do NOT have to hear a BEEP to complete a function! Simple measures - light on or off... for many things. Standard sound testing for hookup of audio portion, Measure of DB for those that need amplification build in the system.”
Measurement techniques No comments received
Why cannot this metric be measured? No comments received

Provision b. When a timed response is required, the user shall be alerted and given sufficient time to indicate more time is required.

Issue Responses
Metrics
  1. Set light to flashing with sufficient time to respond...and a snooze button to extend the response time.
  2. A message box prompt with a warning and options for user to respond either in text or voice
Measurement techniques
  1. Visual inspection.
Why cannot this metric be measured?
  1. "Assistive technology" undefined.

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

Provision 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.

Provision e. When products provide auditory output, the audio signal shall be provided at a standard signal level through an industry standard connector that will allow for private listening. The product must provide the ability to interrupt, pause, and restart the audio at anytime.

Provision 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.

Provision g. Color-coding shall not be used as the only means of conveying information, indicating an action, prompting a response, or distinguishing a visual element.

Provision 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.

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

Provision j. Products which are freestanding, non-portable, and intended to be used in one location and which have operable controls.

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1194.31 Functional performance criteria.

Provision a. At least one mode of operation and information retrieval that does not require user vision shall be provided, or support for assistive technology used by people who are blind or visually impaired shall be provided.

Provision b. At least one mode of operation and information retrieval that does not require visual acuity greater than 20/70 shall be provided in audio and enlarged print output working together or independently, or support for assistive technology used by people who are visually impaired shall be provided.

Provision c. At least one mode of operation and information retrieval that does not require user hearing shall be provided, or support for assistive technology used by people who are deaf or hard of hearing shall be provided.

Issue Responses
Metrics
  1. Clarity of sound and readability of text in sync with audio
Measurement techniques No comments received
Why cannot this metric be measured? No comments received

Provision d. Where audio information is important for the use of a product, at least one mode of operation and information retrieval shall be provided in an enhanced auditory fashion, or support for assistive hearing devices shall be provided.

Issue Responses
Metrics
  1. All products have to be accessible to those who cannot use an assistive hearing device to utilize the product.
Measurement techniques No comments received
Why cannot this metric be measured? No comments received

Provision e. At least one mode of operation and information retrieval that does not require user speech shall be provided, or support for assistive technology used by people with disabilities shall be provided.

Issue Responses
Metrics
  1. Use keyboard or one-touch buttons for common responses
Measurement techniques No comments received
Why cannot this metric be measured? No comments received

Provision f. At least one mode of operation and information retrieval that does not require fine motor control or simultaneous actions and that is operable with limited reach and strength shall be provided.

Issue Responses
Metrics
  1. Most of the products and services need to be set to standards that have been tested by a minimum of 100 people with specific levels of each disability. Once approved for that level, the metric is tentatively set. This level needs to be long range tested - by regional areas and feedback solicited as to the accuracy of the standard and applicability of that to all users.
Measurement techniques No comments received
Why cannot this metric be measured? No comments received

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