# *1194.23 Telecommunications Products*

***Overview***

This technical category deals with telecommunications devices such as
digital, analog, wire, wireless, and Internet based products. It also
includes such devices as PBX (in-house electronic exchanger) and
telephone answering machines.

[]{.mark}

The category addresses communication devices used by people who are
deaf, hard of hearing, visually impaired, or speech impaired to
communicate over networks designed to carry voice. Whenever a device
transmits and receives voice over a telecommunications network, it must
then be able to support the hookup and successful interoperation of TTY
AT.

Due to the technical nature of the standards in this category, many of
the evaluation statements and tests for compliance require specialized
tools and expertise in telecommunication products. This could be
daunting, but there is an easy solution and that is to contact the
manufacturer of the product for information. This should not be a
problem since the manufacturer stated that their product was Section 508
compliant.

##### **Remember That...**

-   Coupling refers to the connection between telecommunications
    products such as telephones and hearing technologies like hearing
    aids

-   Acoustic coupling is often ineffective as it is susceptible to
    noise, poor coupling of the phone earpiece, and acoustic feedback

-   Hearing Aid Compatible (HAC) act allows inductive coupling with
    hearing aids rather than rely on an acoustic coupling method.
    However, with the advent of digital wireless telecommunications, new
    challenges have arisen for the hearing aid user. This problem has
    not yet been completely resolved.

-   Many of these laws are equivalents to the FCC's Hearing Aid
    Compatibility laws, so therefore many products will already be at
    least partially compliant.

-   Approach the requirements in this section from the end user's
    perspective.

-   Manual testing is the preferred method since it best replicates the
    impact and effectiveness of AT on the end users.

-   Whenever a technical issue is difficult to understand or evaluate,
    contact the product manufacturer.

***References for 1194.23***

-   Guide to the Section 508 Standards for Electronic and Information
    Technology, Telecommunications Products (1194.23), Updated: June 21,
    2001, <http://www.access-board.gov/sec508/guide/1194.23.htm>

-   "Tools for field testing TTYs with wireless phones" copyright
    Gallaudet University, http://tap.gallaudet.edu/trerc.htm

-   Text Telephone (TTY) Forum - Alliance for Telecommunications
    Industry Solutions (ATIS), http://www.atis.org/atis/ttyforum.htm

-   Trace Research Center, University of Wisconsin, Guide to Section 508
    Telecommunications. www.trace.wis.edu

-   TIA/EIA-TSB121 -- Cellular Subscriber Unit Interfaces for TDD.
    www.tiaonline.org/standards/search_results2.cfm?document

-   ANSI/TIA/EIA 825, June 23, 2000

-   ANSI/EIA-504-1989, \"Magnetic Field Intensity Criteria for Telephone
    Compatibility with Hearing Aids"

-   ANSI/TIA/EIA-504-1-1994, \"An Addendum to EIA-504\"

-   ANSI C63.19 - 2001, \"American National Standard for Methods of
    Measurement of Compatibility between Wireless Communications Devices
    and Hearing Aids\"

-   ANSI Standard C63.19, American National Standard for Methods of
    Measurement of Compatibility between Wireless Communications Devices
    and Hearing Aids

-   ISO/IEC IS 13714 (1994). Information technology - Document
    processing and related communication - User Interface to
    Telephone-based Services - Voice Messaging Applications.

-   HFES 200.5: Human Factors Engineering of Software User Interfaces --
    Interactive Voice Response (IVR) and Telephony. Human Factors and
    Engineering Society (HFES) (in ballot)

-   OSHA régulation 1910.95 - Occupational noise exposure., -
    <http://www.osha-slc.gov/OshDoc/Interp_data/I19910401A.html>

-   FCC Part 68.317 (a), (c), (f)

-   <http://www.fcc.gov/cgb/consumerfacts/hac.html>, (47 CFR 68.317),
    <http://www.fcc.gov/wcb/iatd/part_68.html>

-   FCC Hearing Aid Compatibility Act of 1988
    <http://www.fcc.gov/cgb/consumerfacts/hac.html>, (47 CFR 68.317),
    <http://www.fcc.gov/wcb/iatd/part_68.html>

-   ETSI ES 201 381 (December 1998) Telecommunication keypads and
    keyboards: Tactile identifiers, http://www.etsi.org/

-   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, <http://www.usdoj.gov/crt/ada/reg3a.html>

-   Access Board "Using TTY."
    [http://www.access-board.gov/publications/usingATTY/A2.html]{.underline}

## 1194.23 (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.

###### *In other words...* 

Telecommunication products (e.g., telephones) or systems that provide
voice communication must also have the capability to provide standard
non-acoustic connection points for TTY. Microphones must be capable of
being turned on and off to allow user to intermix speech with TTY use.

###### *Term*

*Teletypewriter* (TTY) -- Communications device used by people who are
deaf, hard of hearing, or speech impaired to communicate over networks
designed to carry voice.

###### *Determining compliance* 

Based on a visual inspection of a product that provides voice
communications:

-   If the product does not provide TTY functionality built-in, the
    product should have a standard non-accoustic connection point (e.g.,
    RJ-11 or TSB-121)

-   If the product includes a microphone, it must have an off/on and
    mute switch function.

###  Notes

-   Although 300 baud ASCII includes a carrier tone signal that causes
    problems in supporting Voice Carry Over (VCO); TTYs must also
    support 45.5 baud Baudot which works fine with VCO. VCO and Hearing
    Carry Over (HCO) are strategies for using TTYs that are not strictly
    'two-way text conversation'. VCO allows people who are hard of
    hearing or oral deaf (deaf with intelligible speech) to use a TTY
    without typing. They only use the TTY for reading during the inbound
    direction of the call, and talk to their party by speaking into a
    microphone. Similarly, HCO allows a person with a speech disability
    to hear a response from their party directly, and use the TTY for
    sending text in the outbound direction.

-   For traditional phones (e.g., desk or public phones), an analog,
    Public Switched Telephone Network (PSTN) compatible RJ-11 port or a
    2.5 mm jack will allow connection of a TTY.

-   For Integrated Services Digital Network (ISDN) systems, an ISDN
    Terminal Adapter (RJ-11, analog, PSTN compatible) will provide the
    TTY connection

-   For wireless analog or digital systems, a 2.5 mm headset jack on the
    handset will allow the connection of a TTY

-   For voice over Internet Protocol (IP), there is no specific
    connector at this time. However, any one of the above connectors may
    be appropriate, depending on the implementation of this technology.
    Research is under way to determine effectiveness of various voice
    over IP systems in carrying TTY and to determine solutions to
    problems identified.

## 1194.23 (b) Telecommunications products that include voice communication functionality shall support all commonly used cross-manufacturer non-proprietary standard TTY signal protocols.

###### *In other words...* 

Voice telecommunication products must support commonly used protocols
such as 45.5 baud Baudot and 300 baud ASCII.

###### *Term*

*Teletypewriter* (TTY) -- Communications device used by people who are
deaf, hard of hearing, or speech impaired to communicate over networks
designed to carry voice.

###### *Determining compliance* 

-   The quick, non-technical method to determine compliance is to read
    the user manual or check with the manufacturer.

-   A more comprehensive method for determining compliance is to
    identify the standard TTY signal protocols (e.g., 45.5 baud Baudot
    and 300 baud ASCII) and use of the standard methods and tools that
    exist for TTY signal protocol testing for digital wireless.

### Notes

-   The Alliance for Telecommunications Industry Solutions (ATIS)
    sponsors the Interactive Voice Response (IVR) Accessibility Forum
    "to investigate and document potential accessibility and usability
    solutions for voice-mail and other interactive voice response
    systems and services"

-   Use of the IVR TTY Forum test methodology alone is not sufficient
    for Voice over IP (VoIP) systems

-   Wireless carriers must inform the FCC when their networks are TTY
    compatible - the largest carriers have said that they are now in
    compliance. They must also support TTY compatible handsets. Federal
    agencies need to assure that handsets they purchase are TTY
    compatible, but should not have to do independent testing of
    carriers networks.

-   Satisfying this requirement will support interoperability with TTY
    (teletypewriter) assistive technology.

-   In general, the objective is that landline, wireless, and voice over
    IP phone systems will be able to pass TTY signals/protocol without
    unacceptable character loss or error. At this time, support for the
    TTY protocol as documented in American National Standards Institute
    (ANSI) Telecommunications Industry Association (TIA) EIA 825 is
    required to provide TTY interoperability in the U.S. (Proprietary
    protocols are also widely used in TTYs but these are not
    standardized and support is not required although desirable from a
    user standpoint.)

-   Under Federal Communications Commission (FCC) mandate, the wireless
    industry has developed and implemented a number of standards to
    support the protocol found in ANSI/TIA/EIA 825.

## 1194.23 (c) Voice mail, auto-attendant, and interactive voice response telecommunications systems shall be usable by TTY users with their TTYs.

###### *In other words* 

Automated telecommunication services (e.g. voice mailboxes) must support
TTY interaction.

###### *Term*

*Teletypewriter* (TTY) -- Communications device used by people who are
deaf, hard of hearing, or speech impaired to communicate over networks
designed to carry voice.

###### *Determining compliance* 

.For all interactive voice responsive systems (e.g., voice mail)

-   A TTY user must be able to leave a message, navigate an automated
    menu, or otherwise interact with the telecommunication product.

### Notes 

-   Having voice mail record and playback TTY messages with acceptable
    loss of data. Generally this means providing control by Dual Tone
    Multi Frequency (DTMF) or Baudot and communication of information in
    (Baudot) TTY.

-   There is currently no way for a "command" from a TTY to be
    distinguished from "communication" from a TTY. IVR design is very
    hard if the user is trying to use Baudot numbers for both data entry
    and flow control. It is hard to know if Baudot-encoded number is
    intended as "speech" or as a command, unless all commands are
    provided as DTMF number tones.

-   The IVR Forum is still debating this and many issues and
    manufacturers must follow the FCC direction at the end of that
    Forum.

-   Maintaining separate IVR or voicemail systems for voice and TTY
    users satisfies this requirement, analogous to supporting separate
    web-sites (primary and text-only) as described in 1194.22 (k).

## 1194.23 (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.

###### *In other words* 

A user should be alerted when any time dependent function is about to
run out. The user of the system should be able to indicate that more
time is required if necessary.

**Note:** Assume that informed humans can reasonably and consistently
judge the amount of time that is sufficient for a user to indicate that
more time is required.

###### *Determining compliance* 

For each product or function that requires a response:

-   If there is not a response time required, this standard is not
    applicable

-   If a response is required within a specific interval:

    -   The user must be warned before the response time has elapsed

    -   Sufficient time is provided by the product for the user to
        indicate that more time is required

    -   The user can extend the response time to allow sufficient time
        for the user to complete the function

-   Although not required by law, a useful feature is as follows: When
    time has run out, the product or function automatically resets
    without losing any user input or key presses already entered. This
    is called 'non-destructive time outs.' It is defined as where the
    entrance or additional cues are repeated but the user is not thrown
    out, their input is not erased, and they are returned to the point
    in the program where they were when the time ran out.

## 1194.23 (e) Where provided, caller identification and similar telecommunications functions shall also be available for users of TTYs, and for users who cannot see displays.

###### *In other words* 

Caller identification and similar functions of a telecommunication
device must be accessible to TTY users and those who cannot see the
device's display.

###### *Term*

*Teletypewriter* (TTY) -- Communications device used by people who are
deaf, hard of hearing, or speech impaired to communicate over networks
designed to carry voice.

###### *Determining compliance* 

All of the operational functions (which excludes maintenance and setup
features) are included in the complete set of functions covered by this
requirement. Some telecommunication functions that can cause problems
for TTY include Caller-ID (Name and Number Delivery), Message Waiting
indication, and Call Selector (\*61).

For equipment employed on the premises of a person (other than a
carrier) to originate, route, or terminate telecommunications:

-   If the product provides visual Caller ID, it should either

    -   Provide for voice output, or

    -   Have a connection method for adding an external Caller ID
        product with voice output

-   Check for exposure of the Caller ID info to a computer workstation.
    There should be software or protocols that will make Caller ID and
    other information available in at least one non-visual mode

**Notes:**

-   Some telecommunications functions expect the user to rely on either
    audible or visual information. For example, a feature may provide
    information to the user via a special dial tone or ring pattern. To
    many TTY users, this audible information is not available, so they
    cannot properly use the feature. Alternatively, a feature may
    provide information to the user via a flashing light or an icon in a
    display. This visual information is not available to users who
    cannot see the display, so they cannot properly use the feature. The
    key to making such features accessible is redundancy in the method
    of information delivery. This means supplementing the audible
    information with visual or tactile information, and supplementing
    visual information with audible or tactile information. Providing
    such redundancy should let most users access more product features.

-   Satisfying this requirement will support interoperability with TTY
    (teletypewriter) assistive technology. Some ways in which the
    necessary interoperability with Caller ID could be achieved include:

```{=html}
<!-- -->
```
-   The TTY user could use an external display that provides Caller ID.

-   The TTY user could use a telephone that has Caller ID functions
    built in.

-   An ISDN phone with RJ-11 interface could pass through the Caller ID
    functions for a TTY connected to it.

```{=html}
<!-- -->
```
-   With regard to access by "users who cannot see displays," the
    following Caller ID implementations may provide limited solutions
    for blind users:

```{=html}
<!-- -->
```
-   Integrated or external Caller ID devices that articulate the number.

-   Where the phone is only used in a work area that includes a speech
    output or Braille-based technology, telephony Application
    Programming Interface (API) that is compatible with that access
    technology could provide access to the function.

```{=html}
<!-- -->
```
-   Sometimes these features are unavailable to TTY users because
    digital Private Branch Exchange (PBX) information may not be
    provided through the analog connections and adapters that are needed
    for direct-connecting TTY to the PBX or other internal telephone
    system.

## 1194.23 (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.

###### *In other words* 

Telecommunication products that transmit voice communications must have
the ability to amplify the volume and have an intermediary setting.

###### *Terms*

*Decibel* (dB) -- Unit of relative sound intensity

*Gain* -- The ratio of output to input in electrical signals (e.g.,
amplification)

###### *Determining compliance* 

If the product has a volume control:

-   The volume must be able to be amplified above the default level.

-   Check the user manual to determine the maximum volume in decibels
    and whether it is equal to or greater than 20

Notes:

-   Some engineers are concerned that exceeding 18dB will be problematic
    for FCC acceptance. The FCC maximum gain is 18 dB, but this may be
    exceeded if an automatic volume reset is provided. Since 1194.23 (g)
    requires automatic volume reset, the 20 db gain required by this
    provision does not conflict with the FCC requirements.

-   Some engineers believe there may be technical problems with meeting
    other requirements at levels above 18dB. This needs further
    research. In the United States, none of the commonly accepted
    standards for digital voice communication between telephones and
    associated back-office equipment (such as PBX\'s) has 20 dB of
    amplitude headroom available, and providing such gain would result
    in unusable output. Under typical conditions, the maximum additional
    gain in the output of back-office systems, without introducing
    unacceptable levels of distortion, is about 12 dB.

-   Some systems and products cannot provide 20 dB of true gain without
    exceeding the 125 dB safety criteria.

-   Additional technical issues may exist with other requirements for
    VoIP.

-   Satisfying this requirement does not involve interoperability with
    assistive technology.

## 1194.23 (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.

###### *In other words* 

On telecommunication products that have adjustable volume, there must be
an automatic volume reset function that sets the volume back to the
default level.

**Note:** Assume that this standard refers to products that have a
handset, headset, earphone, or other transducer near the ear. Assume
that the volume default level is safe, clear, and audible for fully able
users.

###### *Determining compliance* 

For telecommunication products with volume adjustments,

-   The product must have a feature to automatically revert back to the
    default output level after every use. This does not mean it must
    reset every time, but that it is possible to enable the product to
    reset after each use.

Notes

-   Note that personal communications devices such as cell phones do not
    typically default at the current time. Users of personal
    communication devices might desire a customized setting that does
    not always default. Note that most phones and phone systems do not
    currently default to a "0 gain" state.

-   Satisfying this requirement does not involve interoperability with
    assistive technology.

## 1194.23 (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.

###### *In other words*

When using a telecommunication product such as a telephone, there must
be a means to effectively use magnetic wireless coupling devices such as
a hearing aid.

**Note**: Assume that effective magnetic wireless coupling to hearing
aids with a telecoil and cochlear implants is applicable to this
requirement.

###### *Determining compliance*

It is difficult to determine compliance for this standard without the
use of special testing equipment and expertise in this field. However,
The HAC Act requires all new landline telephones produced or imported
after 1989 to be compatible with hearing aids, so current landline
phones (including cordless) meet this provision.

**Notes**

-   The technical standards for HAC telephones are specified in
    ANSI/EIA-504-1989, \"Magnetic Field Intensity Criteria for Telephone
    Compatibility with Hearing Aids,\" ANSI/TIA/EIA-504-1-1994, \"An
    Addendum to EIA-504,\" which adds the HAC requirements, and the FCC
    regulations at 47 CFR 68.317 (a)

-   On July 10, 2003, FCC modified the exemption for wireless phones
    under the HAC Act and required digital wireless phones capable of
    being effectively used with hearing aids. To make digital wireless
    phones accessible to individuals who use hearing aids, the FCC found
    that digital wireless phone manufacturers and service providers
    should be required to take steps to reduce the amount of
    interference emitted from digital wireless phones and to provide the
    internal capability for telecoil coupling.

-   Satisfying this requirement supports interoperability with hearing
    devices, such as hearing aids, cochlear implants, and assistive
    listening devices.

## 1194.23 (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.

###### *In other words* 

Interference to hearing technologies (e.g., hearing aids, cochlear
implants, assistive listening systems) should be reduced to the lowest
possible level.

###### *Determining compliance* 

It is difficult to determine compliance for this standard without the
use of special testing equipment and expertise in this field. Consult
the manufacturer to ensure they comply with the telecommunications
standards in the notes below.

### Notes

-   To achieve the lowest possible level of interference, consider the
    following:

    -   ANSI C63.19-2001 provides procedures to test the interference
        level produced by handsets;

    -   Code Division Multiple Access (CDMA)--based technologies
        generally causes less bothersome interference in hearing aids
        than do Groupe Spéciale Mobile (GSM) technologies, and analog
        cellular transmission is not bothersome to hearing aids;

    -   Handsets that support telecoil-compatible accessories and
        assistive technology are on the market

-   ANSI/IEEE C63.19 is a standard developed to aid compatibility
    between wireless phones and hearing technologies. It does not
    provide an absolute measure of interference across hearing aid
    types. It may be useful to provide relative measures of interference
    among telephones with widely differing levels of interference.
    However, currently neither the handset nor the hearing aid companies
    are providing ratings for their products using this standard.

-   Satisfying this requirement will support interoperability with
    hearing devices, such as hearing aids, cochlear implants, and
    assistive listening devices.

-   There is presently a problem with the multiplexer in the handsets of
    digital wireless services generating radio frequency (RF) noise into
    unshielded assistive hearing devices. Magnetic fields in the handset
    also generate noise in the telecoil circuitry of hearing aids.

## 1194.23 (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.

###### *In other words* 

Any telecommunication product must have the ability to process
information in a usable format. Products shall not remove information
required for access.

**Note:** This requirement applies to the transmission of TTY signals
over voice-based telecommunications systems, including Voice over IP.
The requirement was written broadly to ensure that it would apply to
evolving technologies.

###### *Determining compliance* 

It is difficult to determine compliance for this standard without the
use of special testing equipment and expertise in this field. Contact
the manufacturer or consult the user manual to determine whether a
product under review removes or does not provide access to usable
formats of the information it transmits, conducts, or passes through.

### Notes 

-   Satisfying this requirement will support interoperability with
    assistive technologies, such as TTY, audio descriptions and closed
    captioning

-   Analog television caption technology is standardized under EIA-608,
    and digital television captions are standardized under EIA-708. Note
    that EIA-608 captions are frequently used in DVDs, because subtitles
    generated for international markets do not include accessibility
    information, such as description of background sounds.

-   Audio descriptions are currently carried using the Secondary Audio
    Programming (SAP) channel

## 1194.23 (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.

###### *In other words* 

The controls and keys on a telecommunication product must be designed
and manufactured so that they are tactilely discernible without
activating the function of the control or key.

###### *Term*

*Tactilely discernible* -- The ability of an object to be located and
distinguished from adjacent objects by touch

###### *Determining Compliance* 

-   Keyboards must have navigational bumps on the keys (e.g., the F and
    J keys on a standard keyboard, or the 5 key on a numeric pad)

-   You must be able to locate controls or keys with your eyes shut and
    without activating the function of the keys

-   Although not required by the law similar keys such as arrow keys,
    numeric keypad, and function keys should be grouped together

### Note: Satisfying this requirement does not involve interoperability with assistive technology 

## 1194.23 (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.

###### *In other words* 

Mechanically operated controls must be operated with one hand and not
require tight grasping, pinching or twisting of the wrist. The strength
to activate any control or key has to be less than 5 pounds of effort.

###### *Determining compliance* 

Consult the manufacturer or user manual for the amount of force required
to operate controls. Also, perform the following:

-   Attempt to operate the product with one hand. Pay particular
    attention to controls such as latches, which must also be compliant

-   Examine the user manual for function keys (e.g., programmable phone
    buttons) and attempt to perform all documented features with one
    hand

-   No function should require tight grasping, pinching, twisting of the
    wrist (e.g., contrast controls), or more than five pounds of
    pressure to operate a control or key

If any of the conditions are questionable, then a more definitive
evaluation is required and the use of special tools are required.

**Notes:**

-   It is difficult to measure the force required by non push-button
    controls such as pull-type, rotary, slide, thumb wheels, and
    toggles. Check the user manual or contact the manufacturer for
    specific information.

-   1194.31 (f) prohibits simultaneous actions and applies to all
    products. Therefore, even if simultaneous actions could be done with
    one hand (and therefore, permitted under strict interpretation of
    the wording of this provision), they are prevented under 1194.31.
    When reviewing items for this requirement, it is useful to make sure
    no simultaneous actions are required.

## 1194.23 (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.

###### *In other words* 

Telecommunications products with key repeat features must allow a two
second delay before repeating a key being held down. Products with key
repeat features must also allow up to two seconds between each
repetition of a key being held down.

**Note:** Some systems do not support key repeat. However, on products
where key repeat is provided, this provision requires the repeat to be
adjustable.

###### *Determining compliance*

It is best to avoid products that require the pressing of the same key
in rapid succession. However, if it is required of users

Attempt to locate key repeat features by reading the user manual or
consulting the manufacturer. If the product has key repeat functions:

-   The telecommunication product must have the ability to control the
    rate of the key repeat

If a key repeat feature cannot be found, hold down a key for 10 seconds.

-   Look for key repeating behavior. If key repeat behavior is observed,

```{=html}
<!-- -->
```
-   The delay before a key being pressed is repeated, must be adjustable
    to at least 2 seconds

-   The rate at which the key is repeated must be able to be set to 2
    seconds

####### Notes 

-   Some systems have a key repeat acceleration feature. For such
    systems, the measurement should be taken when the key repeat rate
    stabilizes. If the acceleration feature can be turned off,
    measurements should be done with this acceleration feature disabled.

-   Satisfying this requirement does not involve interoperability with
    assistive technology

## 1194.23 (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.

###### *In other words*

All locking or toggle controls or keys must be visually discernible
through touch or sound.

**Notes:** Assume that more than one person would reliably determine:

-   The type and severity of low vision to which a control or key must
    be discernible (e.g., a good heuristic is to procure for people with
    20/70 vision; meaning what most people see at 70 feet, they would
    see at 20 feet away)

-   The level of sound that is adequate to discern the status of locking
    or toggle controls (see requirements (f) through (h)), and

-   The amount of force required for the status of a control or key to
    be tactilely discernible without activating (e.g., lightly running
    your fingers over the F and J keys of a QWERTY keyboard to locate
    the navigational bumps without actually typing the F or J key)

###### *Determining compliance* 

For each locking or toggle control or key:

-   They must be visually discernible.

-   They must have either an audible or tactile indicator for status.

### Notes 

-   Discernible by sound may be difficult to assess due to ambient noise

-   Satisfying this requirement does not involve interoperability with
    assistive technology