# *1194.25 Self Contained, Closed Products*

***Overview***

By definition, a self-contained, closed product is a device unto itself.
The Section 508 technical standards for this category apply to products
that generally have embedded software and are commonly designed in such
a fashion that a user cannot easily attach or install assistive
technology. Another definition for self-contained, closed product is a
product that is purchased for an application where the user cannot
install or attach adaptive technology. Examples of this type of products
include copiers, printers, fax machines, calculators, and information
kiosks.

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If a product falls into this category, no interoperability capabilities
are mandated for it. However, there are some specific requirements that
have implications for assistive technology. If a printer is to be
integrated with an external computer and driver software, the software
interface to the printer and its drivers would be considered subject to
the provisions of 1194.21, Software Applications and Operating Systems.

The standards require that alternative access features be built into the
product so users do not have to attach an assistive device to it. Other
specifications address mechanisms for private listening (handset or a
standard headphone jack), touch screens, auditory output and adjustable
volume controls, and location of controls in accessible reach ranges.

### Remember That...

-   If a coordinator does not have the required technical skills, tools
    and/or knowledge to determine compliance (e.g., 1194.25(f)), the
    easiest and most effective way to evaluate a product is to read the
    user manual or call the manufacturer. Since the manufacturer has
    already stated that the product is compliant, they should have no
    trouble explaining exactly how it complies with the standard. It is
    highly recommended that the coordinator takes notes of the
    manufacturer's explanations and makes them part of the official
    procurement documentation.

-   Compliance for some standards is required only if a certain
    condition exist. For example, 1194.25(h) is only applicable if the
    product has adjustable color and contrast settings. If the product
    does not offer the adjustments, then the standard does not apply.

-   Products in this category provide all required accessibility as a
    standalone unit without the support of external assistive
    technology.

-   Satisfying these requirements does not involve interoperability with
    assistive technology.

-   Interoperability that goes on internally, between the components of
    a self-contained closed product, is outside the scope of Section
    508.

### References for 1194.25

-   Guide to the Section 508 Standards for Electronic and Information
    Technology, Self contained, closed products (1194.25), Updated:
    August 1, 2001, <http://www.access-board.gov/sec508/guide/1194.25.>

-   National Institute for Standards and Technology Biometrics Resource
    Center: <http://www.itl.nist.gov/div895/biometrics>

-   TIA/EIA-TSB121 -- Cellular Subscriber Unit Interfaces for TDD.

-   Voting Systems Standards, April 30, 2002, Federal Election
    Commission (FEC). <http://www.fec.gov/pages/vssfinal/vss.html>

-   Americans with Disabilities Act Accessibility Guidelines - ADAAG 4.2
    Space Allowance and Reach Ranges,
    <http://www.access-board.gov/adaag/html/adaag.htm#4.2>

## 1194.25 (a) Self- contained products shall be usable by people with disabilities without requiring an end-user to attach assistive technology to the product. Personal headsets for private listening are not assistive technology.

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

Self-contained products must be usable by people with disabilities.
Products cannot require the attachment of assistive technology for their
use.

**Note:** Personal headsets for private listening do not fall under this
standard

###### *Term*

*Self Contained, Closed Products* -- Products that generally have
embedded software and are commonly designed or used in such a fashion
that a user cannot attach or install assistive technology (e.g.,
copiers, printers, fax machines, calculators, and information kiosks)

###### *Determining compliance*

-   Important functional keys must be logically designed (e.g., the
    on/off key is large and easy to tactilely identify)

-   Important functional keys should be easy to use (e.g., requesting a
    number of copies to be printed)

-   All important auditory information should have a visual equivalent,
    and visa versa

Identify all product functions.

-   Where does the product warn the user of problems (i.e., at the
    product and/or at the individual's PC)? Many vendors provide an
    on-screen message that warns the user of functional problems (e.g.,
    paper jam or out of paper). This works well if the user is at their
    PC before going to the product. However, how does the vendor alert
    the user of a problem once the user is at the product?

**Notes:**

-   Providing an industry standard connection point to allow assistive
    technologies to interface with an otherwise self contained product
    does not result in a violation of 1194.25 (a), neither is it a case
    for equivalent facilitation.

-   A personal digital assistant (PDA) is not necessarily a self
    contained, closed product. Non-closed products are increasingly
    being used as PDAs.

## 1194.25 (b) When a timed response is required, the user shall be alerted and given sufficient time to indicate more time is required.

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

Alert the user whenever a time-critical action is required on their
part. The user must be given sufficient time to indicate if they need
more time to respond.

**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.

###### *Determine compliance*

This standard applies to any product that automatically resets to "0" or
a default setting after a specific length of time where there is no
input (e.g., copiers, kiosks). For each product or function that
requires a response:

-   If a response is required within a specific amount of time,

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

    -   The product must provide sufficient time for the user to
        indicate that more time is required

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

-   A user should be able to extend the response time to allow
    sufficient time for the user to complete the function by indicating
    such

**Note:** Although not required, it is good programming practice to
include a method that when time has run out, the product or/function
that must automatically reset does not lose any user input or key
presses that they have 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.

## 1194.25 (c) Where a product utilizes touchscreens or contact-sensitive controls, an input method shall be provided that complies with §1194.23 (k) (1) through (4).

###### *In other words*

An input method other than touch-responsive controls is required for
devices using touchscreens or touch-operated controls (e.g.
non-mechanic).

**Note:** This provision does not prohibit the use of touchscreens and
contact sensitive controls, but requires a redundant set of controls
that can be used by persons who have access problems with touchscreens

###### *Determining compliance*

For all controls related to normal system operation,

-   The product must provide an alternative set of controls aside from
    touch operated controls for touch screen devices

To ensure that controls and keys are tactilely discernable,

-   Navigational bumps can be provided on the keys (e.g., 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

For determining whether controls or keys can be operated with one hand,
and to check that all locking or toggle controls and keys are visually
discernable:

-   Attempt to operate the product with one hand.

-   Examine the user manual for function keys and attempt to perform all
    documented features

-   No function should require tight grasping, pinching, twisting of the
    wrist, or more than five pounds of pressure to operate a control or
    key

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-   While determining for operation with one hand, visually inspect or
    review the product documentation for visual indication of function
    activation

If a computer supports key repeat features

-   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

**Note:** Please see 1194.23 (k), standards (1) through (4). The terms
touchscreen and contact-sensitive control do not necessarily imply touch
by the human body -- contact with objects such a mouthstick, stylus, or
pencil are also included.

## 1194.25 (d) When biometric forms of user identification or control are used, an alternative form of identification or activation, which does not require the user to possess particular biological characteristics, shall also be provided.

###### *In other words* 

If a system uses biometrics for identification (e.g. retinal scanning or
fingerprint identification) or for system operation, the system must
also provide a means of equivalent, alternative access independent of
any particular biological feature (e.g., entering a password).

###### *Term*

*Biometric controls* -- Controls that are activated by a particular
biological feature or physical characteristic.

###### *Determining compliance*

Determine all user identification or controls that require particular
user biometrics

-   Provide an alternative means for user identification or operation of
    a control. This can often be done through the implementation of
    passwords

**Notes:**

-   When providing a biometric-independent control or form of user
    identification, ensure that it complies with the applicable Section
    508 standards. Some standards to consider are Desktop and Portable
    computers, Software Applications and Operating Systems, and
    Web-based Intanet and Internet Information and Applications

-   See 1194.26 (d) for related information

## 1194.25 (e) When products provide auditory output, the audio signal shall be provided at a standard signal level through an industry standard connector that will allow for private listening. The product must provide the ability to interrupt, pause, and restart the audio at anytime.

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

If a product provides an audio output signal, it must meet specific
requirements that allow for private listening.

**Notes:**

-   If a product does not have an audio output signal, then this
    standard does not apply.

-   Assume that an informed person is able to determine what a standard
    signal level (e.g., volume) would be for a product.

###### *Term* 

*Auditory output* -- In the context of this requirement, auditory output
is any voice output, including synthesized voice.

###### *Determine compliance*

If the product provides auditory output:

-   There must be a standard audio connection point

-   There should be a volume control that complies with 1194.23(k)
    (1)-(3)

-   If in a public area, the output provided is enough sound so the
    auditory output can be heard

    -   There must be controls for audio interrupt, pause, and restart.

    -   All the controls must be easily identifiable and usable.

**Notes:**

-   Industry standard audio connection points are 2.5 mm or 3.5 mm
    jacks. The larger 3.5 mm jack is the connection point typically used
    by persons with visual disabilities.

-   Industry standard signal levels for digital wireless phones are
    specified in Electronics Industries Association (EIA) TSB-121.

-   Satisfying this requirement supports interoperability with assistive
    technology by allowing the use of hearing aids, cochlear implants,
    and assistive listening devices.

## 1194.25 (f) When products deliver voice output in a public area, incremental volume control shall be provided with output amplification up to a level of at least 65 dB. Where the ambient noise level of the environment is above 45 dB, a volume gain of at least 20 dB above the ambient level shall be user selectable. A function shall be provided to automatically reset the volume to the default level after every use.

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

When a product has voice output and it will be used in a public area, it
must have incremental volume control for the user to increase voice out
put above the ambient level. The product must automatically reset volume
to default level after every use.

###### *Terms*

*Ambient noise* -- The background sound of an environment in relation to
which all foreground sounds are heard. Ambient noise level is a measure
of the ambient noise of an environment over a given period of time in
Decibels.

*Incremental volume control* -- Volume control that allows more than one
step between minimum and maximum levels. The size of the increment may
be small enough to effectively provide a continuous, or variable, volume
control.

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

###### *Determining compliance*

It is hard to ensure complete compliance without reading the user
manual, consulting the manufacturer, or using specialized audio testing
equipment. However there are several practical methods for initial
testing. If the product has voice output and is in a public area:

-   The product must provide incremental volume control to amplify the
    volume so that the voice output can be heard over the ambient
    background noise.

-   The product must automatically reset the volume to the default level
    after every use.

**Note:** Location of the product is an important consideration for this
requirement. If two units are located next to each other in an otherwise
quiet room, their 65 dB output will raise the ambient noise level to
over 45 dB.

***1194.25 (g) Color-coding shall not be used as the only means of
conveying information, indicating an action, prompting a response, or
distinguishing a visual element.***

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

Products cannot use color as the only means of conveying information,
indicating an action, prompting a response, or distinguishing a visual
element.

###### *Determining compliance* 

Color should never be the only means to identify a function. Any time
color is used to identify a function, there must be an alternative or
different reference and that reference has to be unique.

For example, a form that requires the user to complete only the areas in
red would be noncompliant. One solution would be to have the user
complete all the red areas with an asterisk or a red star (however, only
if there are no other stars on the form).

-   For all functions that require color-coding to convey information,
    there must also be an alternate for prompting a response or
    distinguishable visual element

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-   For all functions that require color-coding, the information or
    action must also be conveyed without color. Two ways to evaluate
    this standard are:

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-   If a black and white setting is available, turn it on and verify
    that all information is still conveyed

-   Print the information without color on a black and white printer or
    adjust the display to monochrome, and verify that all information is
    still conveyed

**Notes:**

-   Methods for determining all the places color-coding is used to
    convey information include review of the product interface and the
    product documentation (e.g., user manuals plus online help)

-   The alternative to color-coding must be accessible with and without
    assistive technology

-   All uses of color-coding for operation (which excludes maintenance
    and setup) are included in the complete set of functions covered by
    this requirement.

## 1194.25 (h) When a product permits a user to adjust color and contrast settings, a range of color selections capable of producing a variety of contrast levels shall be provided.

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

A range of color selections when provided should be capable of producing
a variety of contrast levels.

**Note:** If the product does not permit adjustable color and contrast
settings (e.g., only black and white are offered), the standard does not
apply.

###### *Determining compliance* 

When the product allows the user to adjust color or contrast settings,
it must:

-   Allow color adjustment to foreground, background, or other elements.

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-   Provide a range of colors. For example, Microsoft allows at least 30
    variations. As a minimum, the product should include the selection
    of the eight primary colors for both the foreground and background.

Another way to check if the standard is compliant:

-   If a black and white setting is available, turn it on*.* All of the
    information should still be readable.

**Notes:**

-   See 1194.21 (j) for related information

-   There should be a combination that will provide a soft background,
    low contrast color scheme as well as combinations that provide a
    high contrast color scheme.

-   Investigate empirical data on contrast ranges and requirements.

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-   Avoid reds and greens together. White on black, black on white, and
    yellow on black are examples of high contrast settings.

-   Lighthouse International provides guidelines for effective color
    contrast on their web site, www.lighthouse.org/color_contrast.htm

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-   Primary colors are different for pigment than for light. Color
    combinations should be based on video display not printed material.

## 1194.25 (i) Products shall be designed to avoid causing the screen to flicker with a frequency greater than 2 Hz and lower than 55 Hz.

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

Design products to avoid screen flicker with a frequency greater than 2
Hz and lower than 55 Hz.

###### *Terms*

*Hertz* (Hz) -- A unit of frequency equal to one cycle per second

*Flicker* -- An unintentional and undesirable cyclic variation in
display of a screen image. Also called flashing or blinking elements.

###### *Determining compliance* 

It is best not to use products with screen flickers. If you do, two
methods to quickly evaluate the screen flicker rate are:

-   Check the user manual for flicker rate. If it is not listed, call
    the manufacturer for information.

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-   The screen should not flash or blink faster than at a one second
    interval. If you do not have a timing device a quick way to
    determine a one second interval is to count "one thousand one",
    which is fairly close to one second.

**Notes**

-   See 1194.21(k) for related information

-   If there are multiple items that are flashing simultaneously in the
    same visual space, the cumulative effect should be considered.

-   Check the product interface and documentation (e.g., user manual) to
    find all of the display screen images

-   Remember that flicker rate can be affected by processor speed and
    graphic cards so it is best to measure flicker rate on all the
    pertinent products.

-   Because 2 Hz is relatively slow, it is possible to use visual
    observation to determine if the flicker is greater than 2 Hz.

-   LED's and illuminated buttons are not covered by this requirement.

## 1194.25 (j)(1) Products which are freestanding, non-portable, and intended to be used in one location and which have operable controls shall comply with the following: The position of any operable control shall be determined with respect to a vertical plane, which is 48 inches in length, centered on the operable ![](media/image1.wmf){width="6.375in" height="2.75in"}control, and at the maximum protrusion of the product within the 48 inch length (see Figure 1).

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

When a product is free-standing, non-portable, and intended to be used
in one location (e.g., an information kiosk), it must have operable
controls that comply with the reach ranges in 1194.25(j) (1) through
(4).

###### *Term*

*Operable control* -- *a* component of a product that requires physical
contact for normal operation (e.g., mechanically operated controls,
keyboards, or keypads).

###### *Determining compliance* 

## There are several ways to determine compliance.

-   Sit in front of the product in a chair with a seat height of 23 ¾"
    (the seat height of a wheel chair). Check the length of your reach
    (most people's reach falls between 20-30"). You should be able to
    easily reach the controls

-   To verify or specifically determine compliance, check the user
    manual or use a measuring device.

## 1194.25 (j)(2) Products which are freestanding, non-portable, and intended to be used in one location and which have operable controls shall comply with the following: Where any operable control is 10 inches or less behind the reference plane, the height shall be 54 inches maximum and 15 inches minimum above the floor.

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

When a product is free-standing, non-portable, and intended to be used
in one location (e.g., an information kiosk), it must have operable
controls that comply with the reach ranges in 1194.25(j) (1) through
(4).

###### *Determining compliance*

Establish the reference plane for each operable control. See 1194.25
(j)(1).

## There are several ways to determine compliance.

-   In front of the product, sit in a chair with a seat height of 23 ¾"
    (the seat height of a wheel chair). Check the length of your reach
    (most people's reach falls between 20-30"). *Can you easily reach
    the operating controls?*

-   To verify or specifically determine compliance, check the user
    manual or use

> a measuring devise to determine that the operating controls are 10
> inches or less behind their reference plane and the relevant operable
> control is at least 15 inches and not more than 54 inches above the
> floor.

**Notes:**

-   A product may have controls in more than one vertical location
    resulting in more than one reference plane

-   All operable controls (which excludes maintenance and setup) are
    included in the complete set of elements covered by this
    requirement.

-   Manufacturer may attempt to make a case for equivalent facilitation
    if the height of a control is decreased according to a range or
    linear progression over the control depth, rather than making a
    quantum step to decrease the depth of the control.

## 1194.25 (j)(3) Products which are freestanding, non-portable, and intended to be used in one location and which have operable controls shall comply with the following: Where any operable control is more than 10 inches and not more than 24 inches behind the reference plane, the height shall be 46 inches maximum and 15 inches minimum above the floor.

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

When a product is free-standing, non-portable, and intended to be used
in one location (e.g., an information kiosk), it must have operable
controls that comply with the reach ranges in 1194.25(j) (1) through
(4).

###### *Determining compliance* 

Establish the reference plane for each operable control. See 1194.25
(j)(1).

## There are several ways to determine compliance.

-   In front of the product, sit in a chair with a seat height of 23 ¾"
    (the seat height of a wheel chair). Check the length of your reach
    (most people's reach falls between 20-30"). *Can you easily reach
    the operating controls?*

-   To verify or specifically determine compliance, check the user
    manual or use

> a measuring devise to determine that the operating controls are 10
> inches and not more than 24" behind their reference plane and the
> relevant operable control is at least 15 inches and not more than 46
> inches above the floor.

**Notes:**

-   All operable controls (which exclude maintenance and setup controls)
    are included in the complete set of elements covered by this
    requirement.

-   Documentation in user manuals can be a good indication of user vs.
    maintenance personnel activities.

-   Access to controls required for typical user monitoring functions is
    considered a part of normal daily operation.

## 1194.25 (j)(4) Products which are freestanding, non-portable, and intended to be used in one location and which have operable controls shall comply with the following: Operable controls shall not be more than 24 inches behind the reference plane (see Figure 2).

###### ![](media/image2.wmf){width="5.9944444444444445in" height="3.129861111111111in"} *In other words...*

When a product is free-standing, non-portable, and intended to be used
in one location (e.g., an information kiosk), it must have operable
controls that comply with the reach ranges in 1194.25(j) (1) through
(4).

###### *Determining compliance*

Establish the reference plane for each operable control. See 1194.25
(j)(1).

-   In front of the product, sit in a chair with a seat height of 23 ¾"
    (the seat height of a wheel chair). Check the length of your reach
    (most people's reach falls between 20-30"). *Can you easily reach
    the operating controls?*

-   To verify or specifically determine compliance, check user manual or
    use

> a measuring devise to determine compliance that the operating controls
> are not more than 24" behind their reference plane.