Section 508 Accessibility Standards for E&IT
Objective Measures Draft Initial Analysis

Section 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.
Terms and Definitions1. product functions - can we assume this means all product functions?2. discerned textually - from Access Board: "can be represented with words".
Assumptions1. Product functions are “executable from the keyboard” in an accessible way, in accordance with other provisions of the Standard.
Outstanding Issues or Assessment Preconditions1. Determine the set of product functions that must be assessed.
Suggestions for Consistent Terminology, Clarification of Issues, or Practical Approaches to Preconditions1. Enumerate all functions where ‘the function itself or the result of performing a function can be discerned textually’. Some ideas for enumerating the relevant set of product functions:a. Exhaustive review of the product interface;b. Exhaustive review of the product documentation, e.g. user manuals;c. Set of functions identified by product vendor as a part of an accessibility statement.d. Identify some set of typical functions from the set of all possible functions for assessment.
Data Collection or Measurement Methods1. Visual inspection of the application. Unplug/disable all input devices except the keyboard, then attempt to execute the identified set of functions using only the keyboard.a. Can the function be executed via the keyboard?b. Is the result of performing the function via the keyboard as expected or advertised?2. Visual inspection of the program documentation. Note that the identified set of functions can be invoked from the keyboard. For applications that have a graphical user interface (GUI), identify any menu commands that do not have a documented short cut.a. Are there documented functions that have no documented keyboard equivalent?b. Are there commands that require pointing or visual analysis of the screen contents?3. Visual inspection of both the application and the program documentation.
Comments and Related Resources 1. Corresponds to W3C WAI WUAG 1.0 Checkpoints 1.1 and 1.22. Enumerating the product functions requires in depth knowledge of the specific application.

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.
Terms and Definitions1. identified as accessibility features – from Access Board: " Many commercially available software applications and operating systems have built-in features that are labeled as access features. These features can typically be turned on or off by the user. This provision prohibits software programs from disrupting these features or disabling these features when selected. Commenters raised concerns that the draft rule did not provide any method of identifying what features are considered “access features.” The rule was accordingly modified to reference “access features that have been developed and documented according to industry standards.”
Assumptions1. Assume the set of “industry standards” according to which accessibility features must be developed and documented are commonly understood and available.
Outstanding Issues or Assessment Preconditions1. Clarify what it means to ‘disrupt’ an activated accessibility feature.2. Is exhaustive testing of all product functions with all operating systems and all other possible products feasible? Determine the set of product functions that must be assessed: a. Enumerate product functions that might affect other accessibility features.b. Enumerate accessibility features of the operating system.c. Enumerate accessibility features of all other products – is this feasible/possible?
Suggestions for Consistent Terminology, Clarification of Issues, or Practical Approaches to Preconditions1. Define an accessibility feature to be ‘disrupted’ whenever its normal appearance or behavior is changed in any perceptible way.a. Should the perception be focused on the modality of the accessibility feature?2. Need a practical bound on the number of product functions. Ideas for enumerating the relevant set of product functions:a. Exhaustive review of the product interface;b. Exhaustive review of the product documentation, e.g. user manuals;c. Set of functions identified by product vendor as a part of an accessibility statement.d. Identify a set of typical functions from the set of all possible functions.3. Need a practical bound on the number of other products for disruption of accessibility features feasible. A practical approach for enumerating the relevant set of other products:a. Enumerate the industry standards that accessibility features must be ‘developed and documented according to’;b. Identify a representative ‘benchmark’ product that exhibits accessibility features based on those industry standards.4. For each operating system, identify the set of accessibility features where the “application programming interface … has been documented by the manufacturer of the operating system and is available to the product developer”.
Data Collection or Measurement Methods 1. Visual inspection of the application. For each operating system the application runs on:a. Enumerate the set of accessibility features.b. For each accessibility feature:i. Turn on the accessibility feature.ii. Exercise all application functions that might affect accessibility features; Note any function that disables or changes the accessibility feature.2. Enumerate the industry standards that product accessibility features must be ‘developed and documented according to’.a. Identify a representative ‘benchmark’ product that exhibits accessibility features based on those industry standards.b. For each accessibility feature:i. Turn on the accessibility feature;ii. Exercise all application functions that might affect accessibility features; Note any function that disables or changes the accessibility feature.
Comments and Related Resources1. Corresponds to W3C WAI WUAG 1.0 Checkpoints 7.1 and 7.2 (7.3, 7.4)2. Data collection would be time consuming for applications with many permutations of modules.

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.
Terms and Definitions1. assistive technology - from Access Board: " Any item, piece of equipment, or system, whether acquired commercially, modified, or customized, that is commonly used to increase, maintain, or improve functional capabilities of individuals with disabilities". A problem remains with the phrase "commonly used", since some AT products are quite scarce, and a very promising AT cannot be "commonly used" if it is new.
Assumptions1. Assume a common understanding about what constitutes a “well-defined” on-screen indication of the current focus.
Outstanding Issues or Assessment Preconditions 1. Clarify what it means to be a “well-defined” on-screen indication.2. Determine the set of interactive interface elements that could have the input focus.3. Clarify the method(s) by which the input focus shall be programmatically exposed.
Suggestions for Consistent Terminology, Clarification of Issues, or Practical Approaches to Preconditions1. Document stakeholder agreement about what constitutes a “well-defined” on-screen indication.2. Enumerate the product interactive interface elements that could have the input focus. Ideas for enumerating the relevant set of product interactive interface elements:a. Exhaustive review of the product interface;b. Exhaustive review of the product documentation, e.g. user manuals;c. Set of interactive interface elements identified by product vendor as a part of an accessibility statement.d. Identify a set of typical interactive interface elements from the set of all possible user interface elements.3. Identify and list the API’s through which information may be programmatically exposed.
Data Collection or Measurement Methods1. Visual inspection of the application. Note that visual inspection for a clear indication of focus would not tell you if the information was programmatically exposed to AT.2. Assessing the program with a screen reader would not be a general measurement of whether focus information was programmatically exposed to all AT. It would test the screen reader’s OSM algorithms and heuristic methods. You would need a software utility that retrieves and displays information about interface elements and the corresponding location of input focus. If such a utility is available, load it and then:a. Exercise all input functions for the application and move focus to all interface elements of screens.b. Note any interface elements not located by the utility or whose location is inaccurate.
Comments and Related Resources1. Corresponds to W3C WAI WUAG 1.0 Checkpoints 6.5 (5.4, 10.6)2. Visual inspection would be time consuming for applications with many permutations of modules and possibilities for input focus.3. Tools are available for certain interfaces to support visual inspection for the programmatic exposure of on-screen focus and focus change information.

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.
Terms and Definitions1. assistive technology – see 1194.21(c)
Assumptions1. Assume a common understanding and agreement about what constitutes “sufficient information” about a user interface element.
Outstanding Issues or Assessment Preconditions1. Determine the set of product user interface elements that must be assessed.2. Are identity, operation and state “sufficient” information about a user interface element?3. Clarify the relationship between this and provision 1194.21(l). A collection of individual user interface elements together can make up a higher-level ‘user interface element’, such as an electronic form. Is information about such a higher-level user interface elements (e.g. a form) required to be made available to assistive technology?
Suggestions for Consistent Terminology, Clarification of Issues, or Practical Approaches to Preconditions1. Enumerate the product user interface elements that should be/are available to assistive technology. Some ideas for enumerating the relevant set of product user interface elements:a. Exhaustive review of the product interface;b. Exhaustive review of the product documentation, e.g. user manuals;c. Set of user interface elements identified by product vendor as a part of an accessibility statement.d. Identify a set of typical user interface elements from the set of all possible user interface elements.2. Document stakeholder agreement about what constitutes “sufficient information” about a user interface element that should be exposed to assistive technology.
Data Collection or Measurement Methods1. Assessing the program with a screen reader would not be a general measurement of whether user interface element information was programmatically exposed to all AT. It would test the screen reader’s OSM algorithms and heuristic methods. You would need a software utility that retrieves and displays information about interface elements. If such a utility is available, load it and then:a. Exercise all user interface elements for the application.b. Note any interface elements not identified by the utility or whose information is inaccurate.
Comments and Related Resources 1. Corresponds to W3C WAI WUAG 1.0 Checkpoints 1.2 and 6.42. Data collection would be time consuming for applications with many permutations of modules.3. Tools are available for certain interfaces to support visual inspection for the programmatic exposure of certain attributes of various User Interface objects.

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.
Terms and Definitions
Assumptions
Outstanding Issues or Assessment Preconditions1. Determine the number of bitmap images that must be assessed.
Suggestions for Consistent Terminology, Clarification of Issues, or Practical Approaches to Preconditions1. Enumerate the set of bitmap images that must be assessed. Ideas for enumerating the relevant set of bitmap images:a. Exhaustive review of the product interface;b. Exhaustive review of the product documentation, e.g. user manuals;c. Set of bitmap images identified by product vendor as a part of an accessibility statement.d. Identify a set of typical bitmap images from the set of all possible user interface elements.
Data Collection or Measurement Methods 1. Visual inspection of the application. This would require a check that the functions assigned are consistent. For each application module, list all bitmapped images and their function. For all duplicate bitmapped images, note any differences in function (maybe use a program to compare the bitmaps). a. If the same image is scaled up or down, how do you compare?
Comments and Related Resources 1. Data collection would be time consuming for applications with many bitmap images used for controls.

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.
Terms and Definitions
Assumptions1. Assume that the “minimum information” listed about text is sufficient.2. Assume that operating systems provide support (system functions) for displaying the required information about text.
Outstanding Issues or Assessment Preconditions1. Determine the number of operating systems that the product must be assessed with.
Suggestions for Consistent Terminology, Clarification of Issues, or Practical Approaches to Preconditions1. Enumerate the required text information that must be made available by the software application and must be supported by the operating system(s).2. Enumerate the operating systems that the application is designed to work with. For each operating system:a. Identify the operating system functions for displaying textb. Clarify that the operating system functions support the required text information.
Data Collection or Measurement Methods1. Visual inspection of the application. We would need a utility that retrieves the text information around the caret and displays it for the data collector. Load a utility that displays the caret location, the text at that location and the text attributes:a. Run a test suite for the application that uses all input functions and moves focus to all edit fields.b. Note any texts that differ from the description shown by the utility.
Comments and Related Resources 1. Data collection would be time consuming for applications with many permutations of modules.

Provision (g) Applications shall not override user selected contrast and color selections and other individual display attributes.
Terms and Definitions
Assumptions1. Assume common understanding and agreement on what beyond contrast and color selection is included as “individual display attributes”.
Outstanding Issues or Assessment Preconditions1. Clarify the relationship between this and provision 1194.21(b). Does this imply that contrast and color settings are not considered accessibility features?
Suggestions for Consistent Terminology, Clarification of Issues, or Practical Approaches to Preconditions1. Enumerate the “other individual display attributes” that are subject to this provision.
Data Collection or Measurement Methods1. Visual inspection of the application. Access the application preferences and note whether there is an option to control OS contrast and color. Turn the option on.a. Change the foreground, background, and window element contrast and color using the application preferences.b. Run a(n automated) test suite for the application that uses all application screens and modules.c. Note any application function that disables or changes the OS contrast or color.
Comments and Related Resources 1. Data collection would be time consuming for applications with many permutations of modules.

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.
Terms and Definitions
Assumptions1. Assume the non-animated mode presents the equivalent information as displayed by the animation.
Outstanding Issues or Assessment Preconditions1. Determine the number of uses of animation displayed by the product.2. Clarify what is meant by “at the option of the user’”. What if both animated and non-animated are presented simultaneously without a user option?
Suggestions for Consistent Terminology, Clarification of Issues, or Practical Approaches to Preconditions1. Enumerate the controls and displays in each module of the application that display animation. Ideas for enumerating the relevant uses of animation:a. Exhaustive review of the product interface;b. Exhaustive review of the product documentation, e.g. user manuals;c. Set of controls and displays identified by product vendor as a part of an accessibility statement.d. Identify a set of typical controls and displays that often use animation from the set of all possible user interface elements.
Data Collection or Measurement Methods1. Check for a method of turning off animation of controls. 2. Check for option turning on redundant information for animated presentations.3. Visual inspection of the application. Load the application preferences area and note whether it has options controlling animation. Inactivate animation.a. For each animated element, see if animation is turned off on controls and alternate information provided for presentations.
Comments and Related Resources 1. Corresponds to W3C WAI WUAG 1.0 Checkpoints 2.1, 2.5, 2.6, 4.4, 4.5 and 4.6

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.
Terms and Definitions
Assumptions1. Assume that other means (besides color coding) convey the same information content that is conveyed by the color-coding.
Outstanding Issues or Assessment Preconditions1. Determine the number of uses of color coding by the product to convey information, indicate an action, prompt a response, or distinguish a visual element.
Suggestions for Consistent Terminology, Clarification of Issues, or Practical Approaches to Preconditions1. Enumerate the uses of color-coding to convey information in each module of the application. Ideas for enumerating the relevant uses of color coding:a. Exhaustive review of the product interface;b. Exhaustive review of the product documentation, e.g. user manuals;c. List of uses of color-coding identified by product vendor as a part of an accessibility statement.
Data Collection or Measurement Methods1. Visual inspection of the application. Check for functions or items encoded using color only. Note this requires running an extensive test suite to look for error messages that use color-coding. 2. An alternative would be to inspect the source code for color displays.
Comments and Related Resources 1. Corresponds to W3C WAI WUAG 1.0 Checkpoints 10.72. Data collection would be time consuming for applications with many modules.

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.
Terms and Definitions1. "variety of color selections capable of producing a range of contrast levels" – The Access Board balanced comments requested more or less specificity than the "originally-proposed requirement for 8 foreground and 8 background colors", but there is no guidance here about the size of the range.
Assumptions1. Assume agreement on what constitutes a reasonable “variety” of color selections and contrast levels.
Outstanding Issues or Assessment Preconditions1. Clarify what is meant by a “variety” of color settings. How many is a variety? 2. Clarify what is meant by a ”range” of contrast levels.
Suggestions for Consistent Terminology, Clarification of Issues, or Practical Approaches to Preconditions1. Document stakeholder agreement about what constitutes a reasonable “variety” of color selections for both foreground and background.
Data Collection or Measurement Methods1. Visual inspection of the application. Check the program’s preference controls. If it allows adjustment to foreground, background color or color of other elements, note how many color options are available.a. For each application module, check preferences for color controls, see if enough colors are available.
Comments and Related Resources 1. Corresponds to W3C WAI WUAG 1.0 Checkpoints 4.3

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.
Terms and Definitions
Assumptions1. Assume agreement on what is meant by “other elements” beyond text objects.2. Assume that only the frequency is an issue, and that the duty cycle (i.e. 50/50 on/off vs. 90/10 on/off) is not an issue.
Outstanding Issues or Assessment Preconditions 1. Clarify what is meant by “other elements” beyond text objects.
Suggestions for Consistent Terminology, Clarification of Issues, or Practical Approaches to Preconditions
Data Collection or Measurement Methods1. Visual inspection of the application. Run a test suite that extensively exercises the program including all error conditions. Note any use of flashing elements. Time the flashing for each. Check all program modules and enumerate all flashing elements.2. An alternative would be to search the source code for commands that provide flashing or blinking displays.
Comments and Related Resources 1. Corresponds to W3C WAI WUAG 1.0 Checkpoints 3.3 and 3.42. Assessment could be time consuming for applications with many modules.

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.
Terms and Definitions1. assistive technology – see 1194.21(c)
Assumptions
Outstanding Issues or Assessment Preconditions1. Clarify the relationship between this and provision 1194.21(d). A collection of individual user interface elements together can make up a higher-level ‘user interface element’, such as an electronic form. Is information about such a higher-level user interface elements (e.g. a form) required to be made available to assistive technology?
Suggestions for Consistent Terminology, Clarification of Issues, or Practical Approaches to Preconditions1. Define a programming API for AT to get information about the current field: name, prompt, description, units, caret location.
Data Collection or Measurement Methods1. Visual inspection of the application. We would need a utility that retrieves the text information around the edit field containing the caret and displays it for the data collector.a. Run a test suite for the application that uses all input functions and moves focus to all edit fields.b. Note any text that differs from the description shown by the utility.
Comments and Related Resources 1. Corresponds to W3C WAI WUAG 1.0 Checkpoints 2.1 and 2.3 (5.5)

Section 508 Accessibility Standards for E&IT
Objective Measures Draft Initial Analysis

Section 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).
Terms and Definitions1. text equivalent – from Access Board: “A text equivalent means adding words to represent the purpose of a non-text element.”2. non-text element – from Access Board: “A non-text element is an image, graphic, audio clip, or other feature that conveys meaning through a picture or sound.”
Assumptions
Outstanding Issues or Assessment Preconditions1. Determine which non-text elements convey meaning and thus require text alternatives.a. from Access Board: “The types of non-text elements requiring actual text descriptions are limited to those elements that provide information required for comprehension of content or those used to facilitate navigation.”2. Determine if the semantics of alternative text are equivalent to a non-text element.a. from Access Board: “The text information associated with a non-text element should, when possible, communicate the same information as its associated element. For example, when an image indicates an action, the action must be described in the text.”b. some say things like a logo need not be described in depth, just captioned such as "Logo of Whatever Administration", while others have argued that the logo needs to be described in more detail.3. This potentially requires that two sets of alternatives have to be developed for the same information: captions/transcripts for deaf users and video description for blind users.
Suggestions for Consistent Terminology, Clarification of Issues, or Practical Approaches to Preconditions1. Enumerate any non-text elements for which all agree that a text equivalent need not be provided.a. Blank and transparent pixel gifs, used as place holders and formatting, should not be described. Empty "" quotes are sometimes used instead, which will cause screen readers to skip over the graphic without recognizing it or describing it, which is exactly what the sighted person does. Note this technique is generally considered a kludge and may not be forwards compatible.
Data Collection or Measurement Methods1. Visual inspection of HTML. a. Search the HTML source for “IMG” tags. For each IMG, note if there is an “alt” or “longdesc” text equivalent provided. The “alt” attribute should be always required. The “longdesc” attribute should be optional.b. Search the HTML source for client-side image maps (image with a “usemap” attribute, and a <map> element with and “id” attribute that is the same value as the image’s “usemap”). For each map, note if there is an “alt” text equivalent provided.c. Search the HTML source for <APPLET> or <OBJECT> or <EMBED> tags. For each <applet> element, note if there is an “alt” attribute. For each <object> element, note if there is nested content which provides the text equivalent. For each <embed> element, note if there is an “alt” attribute.2. Check each multimedia presentation for the existence of closed or open captioning and for audio description of critical visual elements.3. Apply AT to make sure screen readers are not caused to "stutter"a. For example when JAWS encounters a graphic that is also a link, it says "link" "graphic" and then reads the alt text - which should NOT say link or graphic.4. Required human judgment: a. Is the alternative text provided “equivalent” to the meaning of the non-text element?b. Are captions accurate?c. Is video description needed?d. Are the key visual elements described?
Comments and Related Resources 1. Corresponds to W3C WAI WCAG 1.0 Checkpoint 1.12. Automated tools exist to verify parts of this provision that do not require human judgment. 

Provision (b) Equivalent alternatives for any multimedia presentation shall be synchronized with the presentation.
Terms and Definitions1. multimedia presentation – This term may refer to both interactive and non-interactive media of many types. 
Assumptions1. A multimedia presentation is any production presenting both audio and video information.2. The intent is to require synchronized "equivalent alternatives" for audio information (via captioning) and video information (via audio description). Note that 1194.22 (a) require an alternative text equivalent for audio information.3. Multimedia rendering software, such as Real Player, and Microsoft Media Player, is required to display the synchronized equivalent alternatives.a. Section 1194.21 requires software applications to be accessible, but there is nothing specific requiring the synchronized display of equivalent alternatives.b. Section 1194.31 requires the display of equivalent alternatives.c. This provision 1194.22 (b) requires that display to be synchronized with the presentation.4. This potentially requires that two sets of alternatives have to be developed for the same information: captions/transcripts for deaf users and video description for blind users.
Outstanding Issues or Assessment Preconditions1. Determine if the semantics of the equivalent alternatives are actually equivalent.a. Quality/adequacy assessment method for captioningb. Quality/adequacy assessment method for audio description2. Determine if the alternatives are synchronized – what is an acceptable time window within which the alternative is said to be synchronized with a presentation element, and outside of which the alternative is said to be not synchronized.
Suggestions for Consistent Terminology, Clarification of Issues, or Practical Approaches to Preconditions
Data Collection or Measurement Methods 1. Check each multimedia presentation for the synchronization of captioning and audio description. a. Inspect to find synchronized text tracks in SMIL or Quicktime files.b. Open captioning might be embedded into video stream, requiring human verification.2. Required human judgmentsa. Are the alternatives actually equivalent?b. Are the equivalent alternatives synchronized with the presentation?
Comments and Related Resources1. Corresponds to W3C WAI WCAG 1.0 Checkpoint 1.42. Automated tools exist to verify the applicability of this provision. Need to verify manually if the captions are equivalent and the alternate presentation is synchronized with the multimedia presentation.

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.
Terms and Definitions
Assumptions
Outstanding Issues or Assessment Preconditions 1. Determine if there is any information that is conveyed with color.2. Determine if that information is equivalently available without color.
Suggestions for Consistent Terminology, Clarification of Issues, or Practical Approaches to Preconditions1. Agree upon consistent reporting to identify:a. The use of color coding to convey information, indicate an action, prompt a response, or distinguish a visual element.b. How the information, action, response, or visual element is otherwise conveyed, indicated, prompted, or distinguished.
Data Collection or Measurement Methods1. From Access Board: “There are two simple ways of testing a web page to determine if this requirement is being met: by either viewing the page on a black and white monitor, or by printing it out on a black and white printer. Both methods will quickly show if the removal of color affects the usability of the page.”2. Required human judgmentsa. Is color conveying information?b. Is that information redundantly conveyed without color?
Comments and Related Resources1. Corresponds to W3C WAI WCAG 1.0 Checkpoint 2.1.2. Automated tools exist to verify parts of this provision, but visual inspection is required for complete analysis.

Provision (d) Documents shall be organized so they are readable without requiring an associated style sheet.
Terms and Definitions1. documents –can we assume this means all web elements with text content?2. readable – readable implies that content makes sense in the absence of presentational features from a style sheet.
Assumptions1. A document means any web element with text content.2. Readable in this context implies that text content makes sense in the absence of presentational features from a style sheet. 3. This requirement really intends that web pages must not interfere with user-defined style sheets.
Outstanding Issues or Assessment Preconditions1. Determine if the readable text content makes sense – to whom? How to qualify the user?
Suggestions for Consistent Terminology, Clarification of Issues, or Practical Approaches to Preconditions1. Agree on consistent reporting to identify the use of style sheets to convey information.
Data Collection or Measurement Methods1. View the page with Lynx or with a browser with style sheets turned off and determine if is “readable”.2. Employing a user-defined style sheet, view the page and determine if any of the preferences selected by the user-defined style sheet are disrupted.
Comments and Related Resources 1. Corresponds to W3C WAI WCAG 1.0 Checkpoint 6.12. Automated tools exist to verify the applicability of this provision. Need to manually verify if the page is readable without the associated style sheets.3. From Access Board: “In general, the "safest" and most useful form of style sheets are "external" style sheets, in which the style rules are set up in a separate file.”

Provision (e) Redundant text links shall be provided for each active region of a server-side image map
Terms and Definitions
Assumptions
Outstanding Issues or Assessment Preconditions1. Determine if semantics of the redundant text links are “equivalent” to that of image region.
Suggestions for Consistent Terminology, Clarification of Issues, or Practical Approaches to Preconditions1. Agree on consistent reporting to identify active regions of all server-side image maps and their associated redundant text links.
Data Collection or Measurement Methods 1. Visual inspection of the HTML.a. Inspect the page for server-side image maps. Most people don't know what a server side image map is, or if they have one on their site - just look for the <ISMAP> coding.b. Does each active region have a redundant text link? 2. Required human judgmentsa. Is the text link semantically equivalent to the image region? 
Comments and Related Resources 1. Corresponds to W3C WAI WCAG 1.0 Checkpoint 1.22. Automated tools exist to verify parts of this provision that do not require human judgment.3. It helps if the redundant text links are provided before the image map so that a blind user can know what is going on before they get to the non-readable image map. This is not part of the 508 requirements.

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.
Terms and Definitions
Assumptions
Outstanding Issues or Assessment Preconditions1. Determine if an image region “cannot be defined with an available geometric shape”.
Suggestions for Consistent Terminology, Clarification of Issues, or Practical Approaches to Preconditions1. Agree upon consistent reporting to identify active regions of server-side image maps that cannot be defined with an available geometric shape.
Data Collection or Measurement Methods1. Visual inspection of the HTML and related server-side image map files.a. Inspect the page for server-side image maps - just look for the <ISMAP> coding.b. Examine the map, requiring access to the map file on the server: this is not in the client HTML. Could the region be defined with an available geometric shape?2. Required human judgments:a. Can the image region “be defined with an available geometric shape”?b. Is the text link equivalent? If we are asking whether it’s equivalent by URL (links to the same place), then this does not require human judgment - either you find a link that is equivalent or determine that one has not been provided. If we are asking if the content of the text link is the same as that of the “alt” attribute, then this also may not require human judgment – either the text link is the same as the “alt” text or it is not. The issue of whether the content of the “alt” attribute is actually equivalent to the semantic of the non-text element is dealt with by provision 1194.22 (a).
Comments and Related Resources 1. Corresponds to W3C WAI WCAG 1.0 Checkpoint 9.12. Automated tools exist to verify parts of this provision that do not require human judgment. Note that access to server-side map file is not typically available over HTTP with most Web servers.

Provision (g) Row and column headers shall be identified for data tables.
Terms and Definitions1. data tables – does this refer to all tabular organizations of information, including the use of tables strictly for layout purposes?
Assumptions
Outstanding Issues or Assessment Preconditions1. Determine if a table is a data table. Most tables are layout tables - does this provision still apply?
Suggestions for Consistent Terminology, Clarification of Issues, or Practical Approaches to Preconditions1. Agree upon consistent reporting to identify use of data tables.2. It would be helpful for each product (web-site) to state what the row and column headers are, which ones work for which browser, for which screen reader, and what version of each screen reader.
Data Collection or Measurement Methods1. Visual inspection of the HTML.If the page has data tables, are row and column headers identified? a. Column headers: the first row of the table is composed of <th> elements instead of <td> elements. b. Row headers: the first cell of each row is a <th> element instead of a <td> element.2. Required human judgments:a. Is the table a data table?
Comments and Related Resources 1. Corresponds to W3C WAI WCAG 1.0 Checkpoint 5.12. Automated tools exist to verify parts of this provision that do not require human judgment. 

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.
Terms and Definitions
Assumptions
Outstanding Issues or Assessment Preconditions
Suggestions for Consistent Terminology, Clarification of Issues, or Practical Approaches to Preconditions1. Agree upon consistent reporting to identify use of data tables having two or more levels of row or column headers.2. It would be helpful here to state what markup can be used for this, the proper nomenclature, which ones work for which browser and for which screen reader and what version of each screen reader.
Data Collection or Measurement Methods1. Visual inspection of the HTML.If the page has data tables more than two levels, are row and column headers associated with each data cell? Look for HTML 4 markup for this purpose. We’d want to find various combinations of the <thead>, <col>, <colgroup>, and <th> elements, and “axis”, “id”, “scope”, and “headers” attributes. More detail on the specifics of how HTML tables can use this markup to meet this requirement is available from the Access Board:a. Using the "Scope" Attribute in Tablesb. Using the "ID" and "Headers" Attributes in Tables2. Required human judgment: a. Does markup reflect table semantics?
Comments and Related Resources 1. Corresponds to W3C WAI WCAG 1.0 Checkpoint 5.22. Automated tools exist to verify parts of this provision that do not require human judgment. This is pretty complex for automated tools to handle reliably. They can detect if these elements have been provided, but typically not if they’re used correctly.

Provision (i) Frames shall be titled with text that facilitates frame identification and navigation.
Terms and Definitions
Assumptions
Outstanding Issues or Assessment Preconditions1. Determine if the semantics of a text title “facilitates” frame identification and navigation.
Suggestions for Consistent Terminology, Clarification of Issues, or Practical Approaches to Preconditions1. Agree upon consistent reporting to identify use of frames in the web page.2. It has been stated and taught at Section 508 Accessibility classes that frames should not be titled "top", "left" or "right" or "bottom". This needs to be said.
Data Collection or Measurement Methods1. If the page contains frames, is each frame clearly identified through a TITLE attribute?2. Is each frame clearly identified by including text within the body of each frame that clearly identifies the frame? a. From Access Board: “For instance, in the case of the navigation bar, a web developer could consider putting words such as "Navigational Links" at the beginning of the contents of the frame to let all users know that the frame depicts navigational links. Providing titles like this at the top of the contents of each frame will satisfy these requirements.”3. Required human judgment: a. Is frame text title appropriate?
Comments and Related Resources 1. Corresponds to W3C WAI WCAG 1.0 Checkpoint 12.12. Automated tools exist to verify parts of this provision that do not require human judgment.3. Note that the NAME attribute may identify the frame for scripting, but not for purposes of this provision.

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.
Terms and Definitions
Assumptions1. Assume all interface elements including background are subject to this requirement.a. Does this mean the whole page? A portion of the page? Is any image moving on the page at this frequency verboten?
Outstanding Issues or Assessment Preconditions
Suggestions for Consistent Terminology, Clarification of Issues, or Practical Approaches to Preconditions1. Agree upon consistent reporting to identify use of flickering elements in a web page.
Data Collection or Measurement Methods2. Visual inspection. a. Does the page contain flashing elements? b. If the page contains scripts, do they generate a condition that uses flashing elements?
Comments and Related Resources 1. Corresponds to W3C WAI WCAG 1.0 Checkpoint 7.12. Automated tools exist to verify parts of this provision that do not require human judgment.3. From Access Board: “The 2 Hz limit was chosen to be consistent with proposed revisions to the ADA Accessibility Guidelines which, in turn, are being harmonized with the International Code Council (ICC)/ANSI A117 standard, "Accessible and Usable Buildings and Facilities", ICC/ANSI A117.1-1998 which references a 2 Hz limit.”

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.
Terms and Definitions
Assumptions
Outstanding Issues or Assessment Preconditions 1. Determine if “compliance cannot be accomplished in any other way” than a text-only page. This is really a judgment call - hard to measure.2. Determine if the information and functionality of the text-only page is “equivalent” to that of the primary page of the web site.
Suggestions for Consistent Terminology, Clarification of Issues, or Practical Approaches to Preconditions1. Agree upon consistent reporting to identify the use of equivalent text-only pages.
Data Collection or Measurement Methods1. Compare each text-only page to the corresponding primary page to see if the information is the same.2. Required human judgment: a. is the text-only page equivalent to the primary page?
Comments and Related Resources 1. Corresponds to W3C WAI WCAG 1.0 Checkpoint 11.42. Automated tools exist to verify parts of this provision that do not require human judgment.

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.
Terms and Definitions1. assistive technology – see 1194.21(c)
Assumptions
Outstanding Issues or Assessment Preconditions1. Determine if the semantics of the text information are adequate for “functional text” - that is text that when read conveys an accurate message as to what is being displayed by the script.
Suggestions for Consistent Terminology, Clarification of Issues, or Practical Approaches to Preconditions
Data Collection or Measurement Methods1. Use a screen reader on the page - carefully listen to note if all of the content is rendered for the blind as it is for the sighted. Also it must be noted if the page is navigable without a mouse.2. Required human judgment to determine what part of the script is necessary information vs. decoration?a. Image rollovers – usually okb. interface adjustments – can be ok, but needs verificationc. form validation – ok if server-side alternative providedd. form submission – problem (accessible alternatives exist)e. dynamic html – often problem, really needs human judgmentf. redirect/refresh page – problem (accessible alternatives exist)g. create popup window – usually a problemh. change current window – usually a problemi. generate content – problem
Comments and Related Resources 1. Access Board provides recommendations for using many of the more popular HTML event handlers that are often used to trigger or perform scripts and functions, including:a. onClickb. onDblClickc. onMouseDown and onMouseUpd. onMouseOver and onMouseOute. onLoad and onUnloadf. onChangeg. onBlur and onFocus2. Automated tools exist to verify parts of this provision that do not require human judgment.

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).
Terms and Definitions1. applet, plug-in or other application – does this include Microsoft Word, Excel and Powerpoint files in addition to pdf, shockwave, and flash files?
Assumptions1. Assume the plug in or applet or application is widely available across a multitude of platforms.a. e.g. is there a pdf reader for the Linux o/s?2. Assume that compliance with 1194.21 (a) through (l) is clearly and commonly understood and assessed.
Outstanding Issues or Assessment Preconditions
Suggestions for Consistent Terminology, Clarification of Issues, or Practical Approaches to Preconditions1. Agree upon consistent reporting to identify use of applets, plug-ins, or other helper applications required by a web page.
Data Collection or Measurement Methods1. Visual examination of the HTMLa. Look for the <object> tagb. Look for the <applet> tagc. Look for any special tags that are proprietary to some plug-in manufacturers.d. If the page uses an applet or plug-in, does the page have a link to an accessible version of the required application?2. Required human judgments:a. Does the application that is linked from the web page comply with 1194.21 (a)–(l)?
Comments and Related Resources 1. Automated tools exist to verify parts of this provision that do not require human judgment.

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.
Terms and Definitions1. assistive technology – see 1194.21(c)a. Clarify which types of assistive technology must be allowed to access the form. Only screen readers? Which screen readers?2. field elements – are these input fields? Labels?3. functionality – does this mean that forms should be designed so that the user can tab through the field and can submit it without using a mouse?
Assumptions1. Experience has shown that there is a lot of room for interpretation in this guideline. We need guidance on exactly what HTML features the Access Board considers relevant to this provision.
Outstanding Issues or Assessment Preconditions1. Determine whether the information, field elements, and functionality is “required” for completion and submission of the form.
Suggestions for Consistent Terminology, Clarification of Issues, or Practical Approaches to Preconditions1. Agree upon and enumerate the types of assistive technology that must be supported.2. Specify the design features of an electronic form that generally allow access to assistive technology (e.g. the relationship between control labels and controls, or the sequence/ordering of form fields and directions or cues). Access Board provides some recommendations for design:a. “The first rule of thumb is to place labels adjacent to input fields, not in separate cells of a table.”b. Explicit use of the <LABEL> tag and associated FOR attributec. Avoid implicit use of the <LABEL> tag
Data Collection or Measurement Methods1. Do screenreaders get information in correct order?a. Note some screen readers read web page In sequence to an attribute named “tabindex” – if used, the sequence of this attribute must be the same as the TAB sequence for moving through the form.
Comments and Related Resources 1. Corresponds to W3C WAI WUAG 1.0 Checkpoints 2.1 and 2.3 (5.5)2. Automated tools exist to verify parts of this provision that do not require human judgment.3. Labels should be placed before the input fields: placing the blank, editable field first and then following the label identifying the data required for input is a less accessible design. This forces a blind person into an uncomfortable navigation - having to skip the input field, go to the identifying data label, and then returning to the input field to enter the data. A classic example of this is a search engine: the empty input field is first, and then the button that says "search". 


Provision (o) A method shall be provided that permits users to skip repetitive navigation links.
Terms and Definitions1. repetitive navigation links – from Access Board: “a host of routine navigational links at a standard location – often across the top, bottom, or side of a page.”
Assumptions
Outstanding Issues or Assessment Preconditions1. Identify those links that are “repetitive navigation links”.2. Skip to where?
Suggestions for Consistent Terminology, Clarification of Issues, or Practical Approaches to Preconditions1. Agree upon consistent reporting to identify use of “repetitive navigation links”.
Data Collection or Measurement Methods1. If a page has “repetitive navigation links”, does the first link on the page jump past these repetitive navigation links to the main content area?
Comments and Related Resources 1. Automated tools exist to verify parts of this provision that do not require human judgment.


Provision (p) When a timed response is required, the user shall be alerted and given sufficient time to indicate more time is required.
Terms and Definitions1. sufficient time – There is no duration specified. The EITAAC Report suggested a timeout maximum equivalent to 5 times the default.
Assumptions1. Assume that along with providing the user the opportunity to request additional time, the product or service is also required to actually provide the additional time.2. Assume that when the alert is provided is at the discretion of the web product.
Outstanding Issues or Assessment Preconditions
Suggestions for Consistent Terminology, Clarification of Issues, or Practical Approaches to Preconditions1. Agree to consistent reporting of the value for how much time is provided for the user to acknowledge a timed response alert.
Data Collection or Measurement Methods1. If the page contains a field with timed response, does the page give an alert and allow it to be turned off or the time increased?2. Required human judgments: a. is the alert is meaningful?b. is user clearly told how to indicate more time?3. Assessment method for timed response alert:a. Determine if the page requires a user response within a time interval. If yes:b. Does the page have features that give the user the ability to indicate that more time is required? c. Does the page provide “sufficient time” for the user to indicate that more time is required? 4. Assessment method for additional time:a. Determine if the page provides adequate timed response alert (method 3 above). b. If yes, does the page provide additional time as requested?
Comments and Related Resources 1. Automated tools exist to verify parts of this provision that do not require human judgment.

Section 508 Accessibility Standards for E&IT
Objective Measures Draft Initial Analysis

Section 1194.23 Telecommunication 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.
Terms and Definitions1. standard non-acoustic connection point - Most TTYs do not have audio jacks, but most do have RJ-11 jacks. Are those sufficient? If not, which standard jack(s) is/are to be used?
Assumptions1. Assume TTY devices support the input and output signal levels associated with each connector.
Outstanding Issues or Assessment Preconditions1. Determine what is meant by “standard non-acoustic connection point”.
Suggestions for Consistent Terminology, Clarification of Issues, or Practical Approaches to Preconditions1. Agree upon and enumerate the “standard non-acoustic connection points”, (e.g. RJ-11, 2.5 mm jack, 3.5 mm jack).2. Document standard input and output signal levels associated with each “standard non-acoustic connection point” identified.3. Agree upon consistent reporting terminology to clearly and consistently identify products that provide a “function allowing voice communication”.4. Agree upon consistent reporting terminology to clearly and consistently identify products that provide TTY functionality.
Data Collection or Measurement Methods 1. TTY functionality or connection:a. Determine if product provides a “function allowing voice communication”. If yes:b. Determine if product provides TTY functionality. If not:c. Check for a “standard non-acoustic connection point”.2. Microphones:a. Determine if product provides a “function allowing voice communication”. If yes:b. Identify microphone and check for off/on mute” switch or similar function.
Comments and Related Resources1. Coordinate results with ATIS sponsored TTY Forum activities.

Provision (b) Telecommunications products that include voice communication functionality shall support all commonly used cross-manufacturer non-proprietary standard TTY signal protocols.
Terms and Definitions1. commonly used cross-manufacturer non-proprietary standard TTY signal protocols - is this set of protocols well-defined?
Assumptions1. Assume ATIS sponsored TTY Forum approach applies to Section 508 requirements.
Outstanding Issues or Assessment Preconditions1. Determine what is meant by the “commonly used cross-manufacturer non-proprietary standard TTY signal protocols”. From the Access Board –a. “A standard was published for TTYs on June 23, 2000, which is available from the Telecommunications Industry Association. Under 508, this is the protocol which must be retained as TTY signals pass through phone systems.”b. “Some TTYs also include the optional ability to connect at a rate of 300 baud ASCII, which enables them to communicate with some computers or other TTYs with the same protocol. These two codes (300 baud ASCII and 45.5 baud Baudot) are considered non-proprietary.”
Suggestions for Consistent Terminology, Clarification of Issues, or Practical Approaches to Preconditions 1. Agree upon and enumerate the “commonly used cross-manufacturer non-proprietary standard TTY signal protocols” (e.g. ANSI/TIA/EIA 825, 300 baud ASCII).2. Gain common understanding of the assessment and reporting approach of Gallaudet and the TTY Forum.
Data Collection or Measurement Methods1. Employ TTY testing methods and tools developed by Gallaudet and the TTY Forum for the “commonly used cross-manufacturer non-proprietary standard TTY signal protocols”.a. Gallaudet and the TTY Forum employ protocol capture and analysis software tools for measuring transmission accuracy.
Comments and Related Resources1. From Access Board – “This provision is consistent with language in the Telecommunications Act Accessibility Guidelines”. The reference for these guidelines is 36 CFR Part 1193, Effective date: March 5, 1998.2. ITU-T Recommendation V.18 gives a range of tones (390 Hz to 2300 Hz) that is related to the idea of ‘standard’ test data scripts such as those employed by Gallaudet and the TTY Forum.a. From the Access Board – “Equipment that contains a v.18 chip will enable transmission in many protocols including these two” – referring to the two codes (300 baud ASCII and 45.5 baud Baudot) that are considered non-proprietary.b. Note the US Telecommunication Industry does not generally support ITU-T Recommendation V.18 - it goes beyond the FCC255 and E911 requirements.
Provision (c) Voice mail, auto-attendant, and interactive voice response telecommunications systems shall be usable by TTY users with their TTYs.
Terms and Definitions 1. usable - does this mean that all the functions must be accessible to the user?
Assumptions1. Assume ATIS sponsored IVR Forum approach will apply to Section 508 requirements.
Outstanding Issues or Assessment Preconditions1. Determine the scope and meaning of the term “usable” - Does this imply that all voice mail, auto-attendant, and interactive voice response (IVR) functions must be accessible to the user? 2. Does the existence and/or use of TRS relate to the requirements of this provision?a. From the Access Board – “Often when calling through relay services, TTY users are not given enough time to respond and get timed-out by the IVRS.”b. From the Access Board – “Auditory information when typed to a TTY user via relay may not include necessary spacing or punctuation to help a consumer understand sections of what is being conveyed.”3. Is the availability of a separate telephone number for TTY access acceptable?4. Is the ability of a TTY to be able to output CCITT DTMF acceptable?
Suggestions for Consistent Terminology, Clarification of Issues, or Practical Approaches to Preconditions1. Clarify how voice mail can be “usable” by TTY users with their TTYs – is it that voice mail messages can contain TTY machine code?a. From the Access Board – “TTY users have discovered that some voice mail systems corrupt TTY data left in voice mail boxes.”2. Clarify how auto-attendant and IVR systems can be “usable” by TTY users with their TTYs a. Is it that the IVR system must recognize a TTY machine code signal as a menu selection, and then branch take an appropriate action?i. From the Access Board – “Due to a hearing disability, many TTY users cannot understand prompts indicating which phone buttons to push when encountering IVRSs.”3. Gain a common understanding of the work of the IVR Forum.
Data Collection or Measurement Methods
Comments and Related Resources1. Coordinate progress with the ATIS sponsored IVR Forum.2. A related standard is ISO/IEC IS 13714, Information technology - Document processing and related communication - User Interface to Telephone-based Services - Voice Messaging Applications.3. A related standard has been proposed by the Human Factors and Engineering Society - HFES 200.5: Human Factors Engineering of Software User Interfaces – Interactive Voice Response (IVR) and Telephony. HFES 200.5 states “The guidelines in this section are intended to be compatible with ISO/IEC IS 13714, Information technology - Document processing and related communication - User Interface to Telephone-based Services - Voice Messaging Applications. The guidance in this section is intended to apply to IVR applications generally and is, therefore, less specific than that found in ISO/IEC IS 13714.” 

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.
Terms and Definitions 1. sufficient time - There is no duration specified. The EITAAC Report suggested a timeout maximum equivalent to 5 times the default. [Note also that this Standard requires the user to be able to request additional time, but does not require the product or service to provide the additional time.]
Assumptions1. Assume that along with providing the user the opportunity to request additional time, the product or service is also required to actually provide the additional time.
Outstanding Issues or Assessment Preconditions1. Determine the meaning of “sufficient time” to indicate that additional time is required.a. The EITAAC Report suggested that “sufficient time” for a timeout maximum would be an amount equivalent to 5 times the default, but what is the default value?
Suggestions for Consistent Terminology, Clarification of Issues, or Practical Approaches to Preconditions1. Agree upon the meaning of “sufficient time”, or agree to consistent reporting of the value for how much time is provided by a product to acknowledge a timed response alert.
Data Collection or Measurement Methods1. Timed response alert:a. Determine if the IVR system requires a user response within a time interval. If yes:b. Does the IVR system have features that give the user the ability to indicate that more time is required? c. Does the IVR system provide “sufficient time” for the user to indicate that more time is required? 2. Additional time:a. Determine if the IVR system provides adequate timed response alert (method 1 above). If yes:b. Does the IVR system provide additional time as requested?
Comments and Related Resources1. Coordinate progress with ATIS sponsored IVR Forum.2. This provision is identical to section 1194.22(p).

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.
Terms and Definitions 1. similar telecommunications functions – Is visual display of information the basis for similarity?2. available for users of TTYs - Does this mean that the Caller ID information should be displayed on the TTY, that TTYs not interfere with the display of the Caller ID information on a Caller ID display, that Caller ID information of TTY users should be distinguished in some manner, or some combination of these features?a. The Access Board comment says, "Caller identification information need not be transmitted to the end-user where a telecommunications relay service is used."
Assumptions
Outstanding Issues or Assessment Preconditions1. Determine the set of telecommunications functions that are “similar” to caller IDa. Is it functions that rely on a visual display of information?2. Determine how “similar” functions can be “available to users of TTYs”a. Is it that these functions must recognize and interpret TTY machine code? (i.e. Caller ID information of TTY users is distinguished in some manner).b. Is it that the Caller ID (or “similar”) information should be displayed on the TTY?c. Is it that TTYs not interfere with the information that is transmitted associated with these “similar” functions? (i.e. TTYs not interfere with the display of the Caller ID information on a Caller ID display).d. Determine how “similar” functions can be “available … for users who cannot see displays” - does this imply text-to-other modality conversion (e.g. talking caller ID)?i. From the Access Board – “Talking Caller ID would be one means of making that information available in an alternate format.”
Suggestions for Consistent Terminology, Clarification of Issues, or Practical Approaches to Preconditions1. Agreements on the basis for determining which functions are “similar” to caller ID.2. Agreement on the meaning of “available to users of TTYs, and for users who cannot see displays”.
Data Collection or Measurement Methods1. Customer Premises Equipment (CPE):a. Determine if the product provides visual Caller ID. If yes:b. Check for voice output (Talking Caller ID). If not:c. Check for the ability to add an external device specifically providing talking caller ID. If no:d. Check for exposure of the Caller ID info to a computer workstation. 2. Telecommunication Equipment :a. Determine how the system provides caller id information to the Customer Premises Equipment (CPE)? Does the system have a means of customizing the settings for a phone line to indicate that it is a TTY customer and provide an alternative method of caller id compatible with TTY?
Comments and Related Resources1. Coordinate results with ATIS sponsored TTY Forum.

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.
Terms and Definitions
Assumptions1. Assume the lowest and highest volume settings are clear and audible by users with no hearing disability.2. Assume the frequency response of the receiver covers the range required for voice communication.3. Assume the gain applies to the earpiece, for adjusting gain of received voice signals.a. It is wrong to assume the gain applies to voice output – this is amplification volume control, which is different from receiving volume control.b. This does not imply that CPE must support output volume gain control. (e.g. this does not imply that telephone handsets need to provide adjustable or incremental amplification of the output signal).
Outstanding Issues or Assessment Preconditions1. Does this assume the minimum baseline level is 0? (i.e. is 20 db a threshold value for volume, or are 12 db and 20 db increments above a minimum baseline level not specified by the standard)?
Suggestions for Consistent Terminology, Clarification of Issues, or Practical Approaches to Preconditions1. Agree upon consistent reporting terminology to clearly identify the value of the lowest and highest volume settings, and/or to describe the maximum volume gain and steps available.2. Agree upon an adequate range of receiver frequency response to cover voice communication.2. Clarify the relationship between this 20dB or higher Standard and the FCC Part 68 requirement for 18dB of gain. c. Some engineers are concerned that exceeding 18dB will be problematic for FCC acceptance.3. Note that Section 255 of Telecom Act requires 12dB gain4. Clarify the meaning of ‘for transmitted voice signals’ – does not mean voice output but received voice signals.
Data Collection or Measurement Methods1. Adopt FCC Part 68 measurement methods, but extend from 18dB to 20dB? 2. If the device provides amplification, measure the base output, measure the maximum gain. If the device only provides discrete intermediate volume levels, measure the gain at each level.
Comments and Related Resources1. From the Access Board – “This provision is consistent with the 1998 American National Standards Institute (ANSI) A117.1 document, ‘Accessible and Usable Buildings and Facilities.’”2. From the Access Board – “This standard is consistent with the Telecommunications Act Accessibility Guidelines and proposed revisions to the ADA and Architectural Barriers Act Accessibility Revised Guidelines.”3. There may be technical problems associated with meeting other FCC requirements at levels above 18dB (i.e. 20db). This needs further research.

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.
Terms and Definitions
Assumptions1. Assume that the volume “default level” is safe, clear, and audible by users with no hearing disability.
Outstanding Issues or Assessment Preconditions1. Should personal communication devices be exempt?
Suggestions for Consistent Terminology, Clarification of Issues, or Practical Approaches to Preconditions1. Agree upon an appropriate “default level”, or agree to consistent reporting of the value of the “defaults level”.
Data Collection or Measurement Methods1. Determine if the product provides receive volume control. If yes:2. Determine the default volume level, and assess if the receive volume returns to default after return to on-hook condition.a. Does the product have a feature to automatically revert to the default output level? b. Does the product always revert to the default, or is that behavior a user controlled option?
Comments and Related Resources1. From the Access Board – “The provision is adopted from the ADA Accessibility Guidelines (ADAAG), where it applies to public phones used by many people. The FCC's Part 68 rules requires an automatic reset when the phone is hung up if the volume exceeds 18 dB gain”.

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.
Terms and Definitions1. hearing technologies – what technologies does this include? 2. effective magnetic coupling – does this mean the generation of sufficient magnetic field strength? If so, then we need to clarify the meaning of ‘sufficient’.
Assumptions1. Can we assume that hearing technologies means "hearing aids, cochlear implants, and assistive listening devices" as described 1194.23(i)?2. From the Access Board – “Note that this provision does not require a product to fit comfortably, nor does it address the problem of interference to hearing aids. (People with over-the-ear hearing aids often find that headsets do not direct sound into their hearing aid very well, even if the headset is HAC.)”
Outstanding Issues or Assessment Preconditions1. Can we assume the FCC HAC rulemaking process will define the meaning of “effective magnetic wireless coupling”?
Suggestions for Consistent Terminology, Clarification of Issues, or Practical Approaches to Preconditions1. Agree upon the “hearing technologies” subject to the requirements of this provision.
Data Collection or Measurement Methods1. Assessment method for wireline phonesa. Adopt FCC Part 68 Hearing Aid Compatibility (HAC) testing method.2. Assessment method for wireless phonesa. No FCC standard exists for wireless phones - NPRM is in process.b. ANSI Standard C63.19 exists for methods of measurement and definitions of limits for establishing hearing aid compatibility and the accessibility of wireless communications devices to wearers of hearing aids.3. Assessment method for either/both wireline or wireless phonesa. Measure magnetic field produced by the handset microphone when playing a standard set of voice output. Compare to known values from a phone that provides good magnetic coupling.
Comments and Related Resources1. From the Access Board – “This standard is consistent with language in the Telecommunications Act Accessibility Guidelines.”

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.
Terms and Definitions1. lowest possible level – how is this defined/determined?
Assumptions1. Assume that “hearing technologies” are sufficiently immune to transmissions occurring in accordance with FCC rules (e.g. the pulsed RF of digital wireless technologies like wireless LAN, cell phone, etc).2. Assume the “the lowest possible level” of allowed interference to hearing technologies is clearly understood and documented.
Outstanding Issues or Assessment Preconditions1. Clarify “the lowest possible level” of allowed interference to hearing technologies.2. Clarify if testing methods specified by ANSI/IEEE C63.19 are appropriate.
Suggestions for Consistent Terminology, Clarification of Issues, or Practical Approaches to Preconditions1. Identify and agree on the specific FCC rules referred to by assumption 1 above.a. Wireline phones and other devices follow FCC Part 15 rules.
Data Collection or Measurement Methods1. From the Access Board - " The ANSI/IEEE C63.19 Standard, available from the American National Standards Institute, can be used to assess electromagnetic characteristics of hearing aids and wireless phones for the purpose of determining compatibility."a. Note that IEC, HIA, and others have not to date accepted ANSI 63.19.
Comments and Related Resources1. The ANSI/IEEE C63.19 Standard is available from the American National Standards Institute

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.
Terms and Definitions1. cross-manufacturer, non-proprietary, industry-standard codes, translation protocols, formats or other information – what does this include?
Assumptions
Outstanding Issues or Assessment Preconditions1. Is the meaning of “cross-manufacturer, non-proprietary, industry-standard codes, translation protocols, formats or other information” a moving target?
Suggestions for Consistent Terminology, Clarification of Issues, or Practical Approaches to Preconditions1. Agree upon and enumerate the “cross-manufacturer, non-proprietary, industry-standard codes, translation protocols, formats or other information”.a. There seems to be currently no broadly accepted standards here.b. From the Access Board – “The provision was written broadly enough to ensure that it will apply to evolving technologies.”2. Clarify which FCC requirements exist for including caption decoders and SAP capabilities on certain receivers.
Data Collection or Measurement Methods1. Some assessment methods for certain specific examples of “cross-manufacturer, non-proprietary, industry-standard codes, translation protocols, formats or other information”:a. Review the specification of system to see if supports secondary audio channels. If there is no information, play a video through the system to test secondary audio.b. Review the specification of system to see if it strips out inter-frame data from video signals, if there is no information, play a video with closed captioning through the system to test.c. If the compression – decompression algorithms used are not loss-less, repeat 1194.23(b) test over the network.
Comments and Related Resources1. FCC has some requirements for including Caption decoders and SAP capabilities on certain receivers.

Provision (k-1) Products which have mechanically operated controls or keys, shall comply with the following:Controls and keys shall be tactilely discernible without activating the controls or keys.
Terms and Definitions1. tactilely discernible – From Access Board – “Individual keys must be identifiable and distinguishable from adjacent keys by touch”.
Assumptions
Outstanding Issues or Assessment Preconditions2. Clarify to what degree controls and keys must they be “tactilely discernible”.a. ETSI standard ES 201 381 for nibs on keys may be relevant. Should it be generalized? What about standards for other controls, such as latches and toggles?
Suggestions for Consistent Terminology, Clarification of Issues, or Practical Approaches to Preconditions1. Agree on an amount of force required to be “tactilely discernible”, or agree to consistent reporting of the value for how much force is required to activate a controls or keys.
Data Collection or Measurement Methods1. Touch each mechanically operated control or key with a force required to be “tactilely discernible” and note whether the function is activated.a. Measurement of ‘success’ is completely subjective since the required force is unspecified.
Comments and Related Resources1. ETSI standard ES 201 381 for nibs on keys may be relevant. 

Provision (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.
Terms and Definitions1. tight grasping – how tight?
Assumptions1. Assume the overall control design is clearly and consistently understood.2. Assume that no control or key may require more than one hand to operate.3. "...shall not require tight grasping, pinching, or twisting of the wrist" may be interpreted as either "shall not require tight grasping, (tight) pinching, or (tight) twisting of the wrist", or "shall not require tight grasping, (any) pinching, or (any) twisting of the wrist." a. Regarding twisting, it can't possibly be "5 pounds" because twisting force is torque, measured in ft-lbs or oz-in. So there is a clear (if peripheral) case of a mismatch in objective measures written into the Standard.b. Assume that "5 lb" was intended to mean either lb. or ft/lb. If this number was not intended to apply to pinching and twisting as well as grasping, we must conclude that either NO pinching or twisting is allowed, or that we have to quantify what "tight" means when applied not only to grasping, but also to "pinch and twist".c. Available guidance from GSA alludes to avoiding excessive effort, rather than avoiding these motions entirely. 
Outstanding Issues or Assessment Preconditions1. Does the 5 lb. force maximum include "grasping, pinching, or twisting of the wrist"?a. It is problematic to measure the force required by non push-button controls such as pull-type, rotary, slide, thumb wheels, and toggles.
Suggestions for Consistent Terminology, Clarification of Issues, or Practical Approaches to Preconditions1. Agree on and enumerate the various types of controls, and agree on consistent reporting of the number and type of controls for each product.a. Agree on consistent reporting that identifies controls that require two hands or “tight grasping, pinching or twisting of the wrist”.2. Agree on a common meaning for “tight grasping”, or agree on consistent reporting of the force required for effective grasping of controls.
Data Collection or Measurement Methods1. For each control and key:a. Note if two hands are required to operate the control.b. Note if a tight grasp is needed (how tight is tight?).c. Note if pinching or twisting of the wrist is need to operate the control.d. Measure the force needed to activate the controli. Measuring a quantitative value (5 lbs.) for simple push-button control operation is relatively straightforward. ii. Objectively measuring the activating force is more complicated. Equally important are the effects of knob diameter, toggle configuration, surface textures, surrounding surfaces, etc.
Comments and Related Resources1. The standard limits the force required is based on section 4.27.4 of the ADA Accessibility Guidelines, codified as the ADA Standards for Accessible Design as part of the Department of Justice’s regulation implementing title III of the ADA at 28 C.F.R. pt. 36, Appendix A. 2. It is also consistent with the Telecommunications Act Accessibility Guidelines.3. There is also data from the Institute for Occupational Ergonomics in the UK.

Provision (k-3) Products which have mechanically operated controls or keys, shall comply with the following: If key repeat is supported, the delay before repeat shall be adjustable to at least 2 seconds. Key repeat rate shall be adjustable to 2 seconds per character.
Terms and Definitions
Assumptions
Outstanding Issues or Assessment Preconditions1. Clarify distinction between “delay before repeat” and “repeat rate”.2. Clarify the meaning of “at least 2 seconds” and “to 2 seconds”.
Suggestions for Consistent Terminology, Clarification of Issues, or Practical Approaches to Preconditions1. Agree on the distinction between “delay before repeat’” and “repeat rate”.2. Agree that “at least 2 seconds” means greater than or equal to two seconds, and “to 2 seconds” means less than two seconds.3. Agree on consistent reporting of key repeat support functionality (yes/no), and for values of:a. key repeat delay timeb. key repeat rate
Data Collection or Measurement Methods1. Key repeat rate:a. Hold a key down for 2 seconds or more and observe if key repeat occurs.b. Hold a key down for less than 2 seconds and observe if key repeat does not occur.c. Inspect the user manual and reference manual to determine if key repeat delay is adjustable. If so note the allowed range of times for repeat delay.2. Key repeat rate adjustment:a. Inspect the user manual and reference manual to determine if key repeat rate is adjustable. If so note the allowed range of repeat rates.
Comments and Related Resources1. From the Access Board – “Some systems do not support key repeat. However, where key repeat is provided, this provision requires the repeat to be adjustable. Specifically, the delay must be adjustable for a length of time that is no greater than 2 seconds between repeats.”

Provision (k-4) Products which have mechanically operated controls or keys, shall comply with the following: The status of all locking or toggle controls or keys shall be visually discernible, and discernible either through touch or sound.
Terms and Definitions1. visually discernible - to what type and severity of low vision must it be discernible?a. 20/200 vision (legal blindness) might be a good objective test for visual discernibility; legally blind users may be used, or simulation lenses worn by user with 20-20 vision.
Assumptions
Outstanding Issues or Assessment Preconditions1. Determine the level of touch or sound that is adequate to discern the status of locking or toggle controls.a. Audible discernibility seems more difficult to assess than visual, given the potential influence of ambient sound.
Suggestions for Consistent Terminology, Clarification of Issues, or Practical Approaches to Preconditions1. Clarify the meaning of “visually discernible”.2. Agree on and enumerate the various types of controls, and agree on consistent reporting to identify the number and type of locking or toggle controls or keys for each product.
Data Collection or Measurement Methods1. For each locking or toggle control or key:a. Check that the status of the control or key is “visually discernible”.b. Check for either an audible or tactile indicator for the status of the control or key.2. Touch each mechanically operated control or key with a force required to be “tactilely discernible” and note whether the status is discernible.
Comments and Related Resources1. From the Access Board – “This provision requires the status of toggle controls, such as the "caps lock" or "scroll lock" keys to be identifiable by either touch or sound, in addition to visual means.”