Electronic and Information Technology Access
                         Advisory Committee
                                  
                                  
                                  
                                  
                                  
                                  
                                  
                                  
            Recommendations for Accessibility Standards:
                                  
                                  
               Electronic and Information Technology











developed for:
U.S. Architectural and Transportation Barriers Compliance Board
May 1999
                                                 ELECTRONIC AND INFORMATION TECHNOLOGY 
                 ACCESS ADVISORY COMMITTEE MEMBERS

Brenda Battat. . . . . . . . . . Self Help for Hard of Hearing people
Patricia M. Beattie. . . . . . . . .National Industries for the Blind
Stephen Berger . . . . .Association of Access Engineering Specialists
David A. Bolnick . . . . . . . . . . . . . . . .Microsoft Corporation
Judy Brewer. .World Wide Web Consortium, Web Accessibility Initiative
Curtis Chong . . . . . . . . . . . . National Federation of the Blind
Debbie Cook. . . . . . . . . . . . . . .American Council of the Blind
Randy W. Dipner. . . . . . . . . . . . . .Meeting the Challenge, Inc.
Caesar Eghtesadi . . . . . . . . . . . . . . . . . . . . Pitney Bowes
James R. Fruchterman . . . . . . . . . . . . . . . . . . . Arkenstone
John M. Godfrey. . . . . . . .Information Technology Industry Council
Larry Goldberg . . . . . . .WGBH National Center for Accessible Media
Diane C. Golden. . . . . . . . . . . Association of Tech Act Projects
Steve Jacobs . . . . . . . . . . . . . . . . . . . . .NCR Corporation
Earl Johnson . . . . . . . . . . . . . . . . . . . . Sun Microsystems
Steven Mendelsohn. . . . . . . . . United Cerebral Palsy Associations
Arthur R. Murphy . . . . . . . . . . .Georgia Institute of Technology
Michael G. Paciello. . . . . . . . . . . . . . . . WebABLE! Solutions
Jim Serafin. . . . . . . . . . . . . . Electronic Industries Alliance
William H. Sahlberg. . . . . . . . . . . . . . . . . . . .FutureForms
Larry Scadden, chair . . . . . . . . . . .National Science Foundation
Paul W. Schroeder. . . . . . . . . .American Foundation for the Blind
Ronald L. Smith. . . . . . . . . . . . . . . . . . . .Compaq Computer
Claude Stout . . . . . . . . . . . . National Association of the Deaf
James W. Thatcher, vice chair. . . . . . . . . . . .IBM Special Needs
Gregg C. Vanderheiden. . . . . .Trace Research and Development Center
Roger Wellman. . . . . . . . . . . . . . . . . . . . . . Easter Seals

Access Board Members And Staff

Pam Holmes, Member
William F. Paul, member
Dennis M. Cannon, staff
Doug Wakefield, Designated Federal Official
The Access Board wishes to thank the following individuals for their active
        participation during the advisory committee process

Charles Abernethy. . . . . . . . . . . . . . . . . . .Compaq Computer
Seville Allen. . . . . . . . . . . . . . . U.S. Department of Defense
Don Barrett. . . . . . . . . . . . . . . U.S. Department of Education
David Baquis . . . . . . . . . . Self Help for Hard of Hearing people
Marney Beard . . . . . . . . . . . . . . . . . . . . Sun Microsystems
Jim Berish . . . . . . . . . . . . . . . . . . . . . .Hewlett Packard
Roberta Brosnahan. . . . . . . . . . . . . . . . . . . . . Arkenstone
Deborah Buck . . . . . . . . . . . . Association of Tech Act Projects
Brian Charlson . . . . . . . . . . . . .American Council of the Blind
Carol CohenNational Institute on Disability and Rehabilitation Research
William A. Curtis. . . . . . . . . . . . . . . . . . . . Georgia Tech
Jennifer Dexter. . . . . . . . . . . . . . . . . . . . . Easter Seals
Gus Estrella . . . . . . . . . . . United Cerebral Palsy Associations
Geoff Freed. . . . . . . . .WGBH National Center for Accessible Media
Robert H. Gattis, Jr.. . . . . . . . . . .Meeting the Challenge, Inc.
Pam Gregory. . . . . . . . . . . . .Federal Communications Commission
Karl Hebenstreit . . . . . . . . . . .General Services Administration
Don Heffernan. . . . . . . . . . . . .General Services Administration
Seth Jackson . . . . . . . . . . . . . . .Thompson Publishing Company
Phil Jenkins . . . . . . . . . . . . . . . . . . . .IBM Special Needs
Bill LaPlant . . . . . . . . . . . . . . . . . . . U.S. Census Bureau
Pia R. Lederman. . . . . . . . . . . . . U.S. Department of Education
Sharon Laskowski . . . National Institute on standards and technology
Amanda Lee . . . . . . . . . . . . . . . . . . . . . . .Bell Atlantic
Chuck LetourneauWorld Wide Web Consortium, Web Accessibility Initiative
Jennifer C. Mechem . . . . . . . . . . . U.S. Department of Education
Mary Lou Mobley. . . . . . . . . . . . . . U.S. Department of Justice
Wayne McCoy. . . . . . National Institute on Standards and Technology
Ken S. Nakata. . . . . . . . . . . . . . . U.S. Department of Justice
Michael D. O'Hare. . . . . . . . . . . . . . . . . . . . Pitney Bowes
Peter Olson. . . . . . . . . . . . . . . . . . . . . .CD Publications
Dejan Pavlovic . . . . . . . . . . . . . . . . . . . . . .Oracle Corp
Joseph S. Roeder . . . . . . . . . .National Industries for the Blind
Janina Sajka . . . . . . . . . . . .American Foundation for the Blind
Ken Salaets. . . . . . . . . .Information Technology Industry Council
Derek Shields. . . . . . . . . . . . . . . U.S. Department of Defense
Laura Stanton. . . . . . . . . . . . .General Services Administration
Susan H. Stillwell . . .Association of Access Engineering Specialists
Karen Peltz Strauss. . . . . . . . . National Association of the Deaf
Joe Tozzi. . . . . . . . . . . . . . . . U.S. Department of Education                         TABLE OF CONTENTS

EXECUTIVE SUMMARY. . . . . . . . . . . . . . . . . . . . . . . . . .1
     
     Summary of Recommended Standards. . . . . . . . . . . . . . . .3
     Generic Standards . . . . . . . . . . . . . . . . . . . . . . .4
     Technology Specific Standards . . . . . . . . . . . . . . . . .5
     Other Components of the EITAAC Report . . . . . . . . . . . . .5

1. HISTORY OF SECTION 508. . . . . . . . . . . . . . . . . . . . . .6
     
2. RELATED FEDERAL LEGISLATION PROTECTING THE RIGHTS OF INDIVIDUALS WITH
DISABILITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . .8

3. DEFINITIONS . . . . . . . . . . . . . . . . . . . . . . . . . . 12

3.1 Electronic and Information Technology. . . . . . . . . . . . . 12
     3.1.1 Preamble to the E&IT Definition . . . . . . . . . . . . 12
     3.1.2 Body of the E&IT Definition . . . . . . . . . . . . . . 12
3.2 Disability.. . . . . . . . . . . . . . . . . . . . . . . . . . 13
3.3 Undue burden.. . . . . . . . . . . . . . . . . . . . . . . . . 13

4. SECTION 508 IMPLEMENTATION. . . . . . . . . . . . . . . . . . . 13

4.1 Procurement Process. . . . . . . . . . . . . . . . . . . . . . 14
     4.1.1 Compliance with standards . . . . . . . . . . . . . . . 14
     4.1.2 Alternative technical approaches and technological change14
4.2 Standards Refreshment. . . . . . . . . . . . . . . . . . . . . 15
4.3 Principles for Implementation. . . . . . . . . . . . . . . . . 16
     4.3.1 Principle of User Access and Efficiency . . . . . . . . 16
     4.3.2 Principle of Technical Feasibility. . . . . . . . . . . 17
     4.3.3 Principle of Proportionality. . . . . . . . . . . . . . 17
     4.3.4 Principle of Flexibility. . . . . . . . . . . . . . . . 17
     4.3.5 Principle of Compatibility and Adaptability.. . . . . . 17
4.4 Technical Guidance . . . . . . . . . . . . . . . . . . . . . . 18

5. PROPOSED STANDARDS. . . . . . . . . . . . . . . . . . . . . . . 18

5.1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . 18
5.2 Generic Standards for Accessibility. . . . . . . . . . . . . . 19
     5.2.1 Accessibility of operation and Information. . . . . . . 19
         5.2.1.1 Usable without vision.. . . . . . . . . . . . . . 20
         5.2.1.2 Usable with low vision without relying on audio.. 20         5.2.1.3 Usable with little or no color perception.. . . . 20
         5.2.1.4 Usable without hearing. . . . . . . . . . . . . . 20
         5.2.1.5 Usable with limited hearing . . . . . . . . . . . 20
         5.2.1.6 Usable with limited manual dexterity, reach and/or strength.21
         5.2.1.7 Usable without time-dependent controls or displays.21
         5.2.1.8 Usable without speech.. . . . . . . . . . . . . . 21
         5.2.1.9 Usable with limited cognitive or memory abilities.21
         5.2.1.10 Usable with language or learning disabilities. . 21
         5.2.1.11 Availability of audio cutoff.. . . . . . . . . . 22
         5.2.1.12 Prevention of visually-induced seizures. . . . . 22
         5.2.1.13 Biometric identification/activation bypassing. . 22
         5.2.1.14 Usable with upper extremity prosthetics. . . . . 22
         5.2.1.15 Hearing aid compatibility. . . . . . . . . . . . 22
         5.2.1.16 Usable from a wheelchair or similar mobility device22
     5.2.2 Compatibility With Devices used for Access. . . . . . . 23
         5.2.2.1 Information Pass Through. . . . . . . . . . . . . 23
         5.2.2.2 External electronic access to all information and control mechanisms.23
         5.2.2.3 Connection point for external audio processing devices.23
     5.2.3 Information, Documentation, Labeling & Support. . . . . 23
5.3 Technology Specific Standards. . . . . . . . . . . . . . . . . 24
     5.3.1 If the E&IT has a physical keyboard . . . . . . . . . . 24
     5.3.2 If the E&IT is software in nature and runs on a platform that has an operating
         system.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25
     5.3.3 If the E&IT utilizes Web based information or applications26
     5.3.4 If the E&IT provides Telecommunications functions . . . 26
     5.3.5 If the E&IT utilizes Video or Multimedia. . . . . . . . 27
     5.3.6 If the E&IT is an Information Transaction Machine (ITM) 28
     5.3.7 If the E&IT is a PDA. . . . . . . . . . . . . . . . . . 28
     5.3.8 If the E&IT provides an interface over a network. . . . 29
     5.3.9 If the E&IT has cabling and /or other connections . . . 29
     5.3.10 If the E&IT is used to produce information . . . . . . 29

6. APPENDICES. . . . . . . . . . . . . . . . . . . . . . . . . . . 30

6.1 References . . . . . . . . . . . . . . . . . . . . . . . . . . 30
6.2 Glossary . . . . . . . . . . . . . . . . . . . . . . . . . . . 30
6.3 Acronyms . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
6.4 Examples and Background Information. . . . . . . . . . . . . . 31
6.5 Prototype Disability Access Compliance Form. . . . . . . . . . 41               Electronic and Information Technology
                  Access Advisory Committee Report


Executive Summary

The Workforce Investment Act of 1998, signed into law on August 7, 1998, contains amendments to the
Rehabilitation Act of 1973.  The changes to Section 508 of the 1998 amendments to the Rehabilitation Act
were designed to strengthen current law to ensure that people with disabilities will have equity in the use of
electronic and information technology (E&IT).  When Federal departments or agencies develop, procure,
maintain, or use electronic and information technology, they shall ensure that the electronic and information
technology allows Federal employees with disabilities to have access to and use of information and data that
is comparable to the access to and use of information and data by Federal employees who are not individuals
with disabilities, unless an undue burden would be imposed on the department or agency.  Section 508 also
requires that "individuals with disabilities, who are members of the public seeking information or services from
a Federal department or agency, have access to and use of information and data that is comparable to that
provided to the public who are not individuals with disabilities."  The legislation exempts only national security
systems from coverage of Section 508.

The 1998 Amendments to Section 508 directed the Architectural and Transportation Barriers Compliance
Board (Access Board) to develop and publish standards by February 7, 2000 setting forth a definition of
electronic and information technology and the technical and functional performance criteria necessary for
achieving accessibility to such technology and information by individuals with disabilities.  The definition of
electronic and information technology is required to be consistent with the definition of information technology
contained in the Clinger-Cohen Act of 1996.  The new legislation also instructed the Access Board and GSA
to provide technical assistance to Federal agencies and consumers once the standards are implemented on
August 7, 2000.

In developing its standards, the Access Board was directed to consult with various Federal agencies, the
electronic and information technology industry, and appropriate public or nonprofit agencies or organizations,
including organizations representing individuals with disabilities. In response to these requirements, the Access
Board established the Electronic and Information Technology Access Advisory Committee (EITAAC)
comprised of 26 organizations representing the various sectors identified in the legislation.  This report reflects
the deliberations and recommendations of EITAAC.

The purpose of this report is to provide a set of recommended standards for Federal procurement officers
and commercial suppliers of electronic and information technology and services that will result in access to
and use of the technology and information by individuals with disabilities.  This report represents minimally
acceptable standards. All entities involved in the design, production, and procurement process of relevant
electronic and information technology are stronglyencouraged to go beyond these standards to maximize the accessibility and usability of products by all
individuals.

Section 508 is designed to be implemented through the Federal procurement process. In addition to the
obligation to create standards which describe and define accessibility with sufficient clarity for effective
enforcement, the EITAAC recommendations have also attempted to address the implementation of these
standards through Federal procurement.

Manufacturers and providers of Electronic and Information Technology  (E&IT) products need to be able to
make design choices and R&D investments with a clear understanding of the criteria Federal procurement
officials will use. Federal procurement officials in turn need to acquire E&IT based on verifiable accessibility. 
Federal enforcement officials need to be able to measure improvements in accessibility, in order to report
progress to Congress, as required by law, and to take enforcement action where appropriate.  People with
disabilities, whether Federal employees or the general public, need to be able to rely on the Federal
procurement system to promptly and effectively deliver accessible E&IT incorporating current technologies,
including advances in accessibility.

Agencies shall procure E&IT in a manner as to meet the requirements of Section 508.  Agencies are
responsible for evaluating the compliance of the E&IT they procure with the relevant accessibility standards. 
Agencies need to make this evaluation without respect to the method of procurement, so that the same
standards apply to procurement of complete systems from single vendors, procuring systems integrated by a
Seat Management contractor or other integrator, or procuring products from different vendors and
assembling these products into systems.

The EITAAC recommends a written questionnaire approach which permits suppliers to indicate the technical
approaches and features in their products and services that are applicable to the adopted standards.

The EITAAC recognizes the need of Federal agencies and people with disabilities to benefit from advances in
technology and understanding of human factors. The pace of technology advancements in E&IT is rapid and
the level of innovation is high. In this environment, a static standard consisting of design specification and fixed
checklists would tend to stifle innovation and to delay the availability of technology advancements to people
with disabilities.  At the same time, clear and specific standards are necessary in order to ensure compliance. 
To balance these needs, the EITAAC recommended standards that explicitly address alternative technical
approaches. These technical standards describe the required level of accessibility and the relevant
accessibility features which are either available or under development at the time of publication.
Manufacturers and providers should be encouraged to exceed these minimum requirements, and the
procurement process should reward them for doing so.  This will foster innovation and improvement in
accessibility.To ensure the goals of Section 508 are achieved fully, effectively, and efficiently, agencies must exercise
judgment in applying the recommended accessibility standards to each application of E&IT.  The EITAAC
recommends a set of guiding principles for agencies to take into account in making these judgments.  These
principles, defined in Section 4, include: user access and efficiency;  technical feasibility; proportionality
between requirements and the benefits they achieve; flexibility for individuals to operate in the way they
prefer;  and compatibility and adaptability of E&IT.

Summary of Recommended Standards

Electronic and Information technology (E&IT) procured by the Federal government shall be accessible to and
usable by individuals with disabilities.  Being accessible and usable by people with disabilities includes being
able to perform all the regular operating functions of the E&IT including input and control functions, operation
of any mechanical mechanisms, and access to information displayed in visual and auditory form.  It also
includes the ability to work with the assistive technologies used to access E&IT and should not interfere with
the assistive technologies used on a daily basis by people with disabilities.  Documentation and services
associated with E&IT shall also be accessible and usable.

These standards apply to a full range of E&IT including those used for communication, duplication,
computing, storage, presentation, control, transport and production.  These must be accessible and usable by
as wide a range of people with disabilities as possible including people with:

     visual disabilities (e.g., blindness, low vision and lack of color perception)
     hearing disabilities (e.g., hard of hearing, deafness)
     people with physical disabilities (e.g., limited strength, reach or manipulation, tremor, lack of
     sensation)
     people with speech disabilities
     people with language, learning or cognitive disabilities (e.g., reading disabilities, thinking,
     remembering, sequencing disabilities)
     other disabilities (e.g., epilepsy, short stature), and
     individuals with any combination of these disabling conditions (e.g., deaf-blindness).

The recommended access standards are arranged in two sections, generic standards and technology specific
standards.

The generic requirements are the highest level of requirements and apply to all E&ITs.  These requirements
are performance standards in nature  and are written based upon the varieties of human needs for access
found in the population.  Being based upon human needs, these requirements do not mandate specific
technical implementations, which may be used to address these needs.

The technology specific standards apply only to E&IT which includes the specified feature or function cited. 
These requirements are more limited in scope.  These requirements provide standards for the specific access
attributes required in the specified class of E&IT.
These standards are not written to reflect the status or limitations of current technologies.  Thus, not all
standards may be technically/commercially feasible for all technologies today.  The rapid development of
technology however is creating new opportunities for adding flexibility and capabilities to products over time. 
But changes in technology do not always benefit accessibility.  In the past, new technologies have resulted in
significant temporary setbacks to access.  The best example of this is the transition from character based
computing to pixel based computing (the graphical user interface).  Therefore, in considering innovative new
E&IT, Federal agencies must be especially diligent in applying the standards in  Section 5 of these standards.

Generic Standards

The generic standards are organized into three major areas.  The first area sets forth standards for
accessibility of operation and information.  The second area requires compatibility with the peripheral
devices often used by people with disabilities.  The third area covers documentation and services
associated with E&IT.  Together, they establish performance-based standards for accessibility. These
conditions should be applied  individually and in combination.

The recommended standards for the accessibility of operations and information state that E&IT shall be
accessible when it can meet specified physical, sensory and cognitive needs of various disabilities to ensure
that E&IT is usable by people with disabilities and the information presented via E&IT is accessible to them. 
Accessibility of the product includes being able to locate, identify, and operate all of the input, control and
mechanical functions, as well as being able to access the information provided by or through it.  Accessibility
of information includes the ability to access text, static or dynamic images, icons, labels, sounds or incidental
operating cues.

The recommended standards for compatibility with peripheral devices are intended to ensure that E&IT
will be able to work with the adaptive technology utilized by persons with disabilities. E&IT needs to maintain
accessibility information that is present in media, and allow for the physical or wireless connection of adaptive
technology.

The standards for access to information, documentation, labeling, and support ensure that people with
disabilities can take advantage of the information and services that are connected to E&IT. Such information
and documentation includes user guides, installation guides for end-user installable devices, and E&IT support
communications, regarding both the E&IT and its accessibility features.  This shall include provision of
documentation in alternate formats or alternate modes and ensuring accessible and usable customer support
and technical support.  Customer training shall be made available in an accessible form to users with
disabilities.Technology Specific Standards

The technology specific standards which build on the generic standards provide detailed guidance on how to
achieve accessibility for many common cases.  The technology specific standards are to be considered in
addition to the generic standards and cover the following classes of E&IT:

     Keyboards
     Software
     Web-based information and applications
     Telecommunications
     Multimedia
     Information Transaction Machines
     PDAs
     Cabling

The EITAAC identified these areas as being critical to accessibility, but not encompassing all of the issues
involved in the generic standards.  The EITAAC expects that standards in other specific areas will need to be
developed.  Ongoing review of these standards in light of technology advancements is critically important to
ensuring that the standards are current and achieve the desired objectives.

Other Components of the EITAAC Report

In addition to developing proposed standards, the EITAAC made a set of recommendations for the
implementation of the Section 508 provisions.  As charged by Congress, the EITAAC developed a definition
of Electronic & Information Technology, to interpret the language of the statute. Recommendations were
made in the areas of procurement process, standards refreshment, principles for determining accessibility, and
technical guidance.  Together, the EITAAC feels these recommendations and standards are key to the
successful implementation of Section 508.1.   A History of Section 508

Section 508 dates back to 1986, when Congress added this section to the Rehabilitation Act of 1973.  The
Rehabilitation Act contains comprehensive prohibitions against employment discrimination by the Federal
government, 29 U.S.C. 791, by contractors for the Federal government, 29 U.S.C. 793, and by programs
and activities receiving Federal financial assistance.  29 U.S.C. 794.  In the 1980's Federal agencies
significantly increased their dependency on electronic office technologies.  Section 508 was added to ensure
that such E&IT would be accessible to individuals with disabilities.  Pub. L. 99-506, Title VI, 603(a); Title I
103(d)(2)(A), (C), as amended, Pub. L 100-630, Title II, 206(f); Pub. L. 102-569, Title V 509(a),
codified at 29 U.S.C. 794d.

Although Congress adopted the mandates of Section 508 in 1986, efforts to ensure access to electronic
technologies procured by Federal agencies actually began a few years earlier.  Specifically, in 1984, the
National Institute on Disability and Rehabilitation Research (NIDRR), in conjunction with the Department of
Education's Office of Special Education and Rehabilitative Services and the White House, established a
Government-Industry Task Force which brought together representatives from the computer industry and
consumers with disabilities on computer access issues.  That same year, the General Services Administration
(GSA) established the Interagency Committee for Computer Support of Handicapped Employees and the
Clearinghouse on Computer Accommodation.  Both groups were designed to promote the use of information
technology in a manner that would enhance the productivity of Federal employees with disabilities.

Section 508 directed the Secretary of Education to work with NIDRR and the GSA on the development of
agency procurement guidelines for the purchase and lease of accessible electronic office equipment.  The
legislation required the release of these guidelines by October of 1987, and set a target date of September,
1988, for their adoption by GSA.  In October, 1987, after consultation with an advisory committee and with
guidance from the electronics industry and persons with disabilities, the Department of Education and GSA
issued Section 508 guidelines which addressed management responsibilities and functional performance
specifications for input, output, and documentation access to electronic equipment.  On January 1, 1991, after
receiving further comment from agencies, vendors, and individuals with disabilities, GSA published Bulletin C-
8 containing these guidelines as amended, in the Federal Information Resources Management System
(FIRMR).  In a related matter, in April of 1987, the GSA had published Bulletin 48 in the FIRMR.  Bulletin
48 sets forth requirements for agencies to provide accommodations designed to meet the needs of employees
with disabilities when replacing the agencies' computer systems.

Section 508 directed Federal agencies to comply with the electronic equipment accessibility guidelines issued
by the GSA.  Although a few Federal agencies did initiate efforts to comply with the mandates of Section
508, the decade following the passage of this legislation showed little consistency amongst these agencies,
with the vast majority all but ignoring its directives.  A significant problem seemed to be the lack of an
enforcement mechanism in Section 508.  Without any teeth, the very existence of Section 508 went virtually
unnoticed by many segments of the Federal government.  In 1997, the uneven application of Section 508
prompted the introduction of new legislation designed to strengthen and enforce its objectives.

The Federal Electronic and Information Technology Accessibility Compliance Act was introduced in 1997. 
With some revision, the language contained in this proposed legislation was ultimately inserted into the
Workforce Investment Act of 1998 and added as a new Section 508 into the Rehabilitation Act Amendments
of 1998.  Pub. L. 105-220, Title IV, 408(b), codified at 29 U.S.C. 794d.  Exempting only national
security systems in its revised form, Section 508 contains a strict mandate for Federal agencies to ensure that
the electronic and information technology which they develop, procure, maintain, or use is accessible to both
Federal employees with disabilities and individuals with disabilities outside the government who need
government information, unless doing so would impose an undue burden.  The new law, which applies to
electronic and information technology that is procured after August 7, 2000, specifically directs Federal
agencies to provide access to information and data that is comparable to the access available to individuals
without disabilities.  Where providing access would result in an undue burden, agencies are directed to (1)
provide documentation on why compliance will create an undue burden and (2) provide the information and
data through an alternative means of access.

The amended version of Section 508 directs the Access Board to publish standards by February 7, 2000,
setting forth (1) a definition of electronic and information technology, and (2) technical and functional
performance criteria necessary to achieve electronic and information access.  The definition of electronic and
information technology established by the Access Board must be consistent with the definition of information
technology contained in the Clinger-Cohen Act.  40 U.S.C. 1401(3).  Congress enacted the Clinger-Cohen
Act in 1996 for the purpose of creating consistency across Federal agencies in the acquisition, use, and
disposal of information technology.  Pub. L. 104-106, as amended Pub. L. 104-208, codified at 40 U.S.C.
1401 et. seq.  That Act defines information technology as "any equipment or interconnected system or
subsystem of equipment, that is used in the automatic acquisition, storage, manipulation, management,
movement, control, display, switching, interchange, transmission, or reception of data or information by the
executive agency."  Among other things, Clinger-Cohen states that the term "information technology" includes
computers, ancillary equipment, software, firmware, support services, and related resources.

Section 508 also directs the Access Board to consult with representatives of Federal agencies, the electronic
and information technology industry, and organizations representing individuals with disabilities in the course of
developing the new Section 508 standards.  The Access Board has fulfilled this obligation through EITAAC. 
The new legislation also instructs the Access Board and GSA to provide technical assistance to Federal
agencies and consumers once these standards have been finalized.The revised provisions of Section 508 contain a number of safeguards to finally ensure Federal compliance
with Section 508.  Already, by February 1, 1999, each Federal agency had an obligation to evaluate, and
submit a report to the Attorney General on the extent to which electronic and information technology within its
agency was accessible and usable by individuals with disabilities.  By February 1, 2000, the Attorney
General, with information provided from each of the Federal agencies, is directed to prepare a report to the
President on the extent to which technology available in these agencies is accessible and usable by individuals
with disabilities.  This report is to be followed by similar, biennial reports from the Attorney General to the
President.

In addition to the above reporting requirements, within six months after the Access Board publishes its
Section 508 standards, the Federal Acquisition Regulatory Council must revise the Federal Acquisition
Regulation; each Federal agency must then revise its own Federal procurement policies and directives to
incorporate the new Section 508 standards.  Finally, unlike its predecessor, beginning August 7, 2000, the
amended Section 508 allows individuals to file complaints against Federal agencies alleging noncompliance
with Section 508.  Agencies receiving such complaints are directed to utilize their existing complaint
procedures for Section 504 of the Rehabilitation Act.

A separate law, the Technology-Related Assistance for Individuals with Disabilities Act of 1988, later
replaced by the Assistive Technology Act of 1998, and now known as the AT Act, has required states to
provide assurances of their compliance with Section 508 as a condition to receiving Federal funds for their
technology assistance programs.  Although all of the states have submitted such assurances, the lack of
Federal efforts to enforce Section 508's provisions has put the value of these assurances into question.  The
new Section 508 standards will provide much needed guidance to ensure compliance with these assurances.

2.   Related Federal Legislation Protecting the Rights of Individuals with Disabilities

Section 508 does not stand alone in its objective to ensure access by individuals with disabilities.  A number
of Federal laws preceded this legislation, setting the stage for a barrier-free information age.  Indeed, the new
language of Section 508 plainly states that this section shall not be construed to limit the rights, remedies or
procedures available under other Federal laws that may provide greater or equal protections for individuals
with disabilities.  Thus, even where there is overlap with Section 508, other Federal legislation establishing
disability protections remain in full force.

Rehabilitation Act of 1973 - The Rehabilitation Act of 1973, discussed briefly above, was the first piece of
legislation designed to ensure that Federal agencies, its contractors, and its financially assisted programs and
activities would provide access to their employees and beneficiaries. Section 501, for example, requires
Federal employers to carry out the functions of their jobs, unless providing those accommodations would
impose an undue hardship.  Section 501 focuses on the responsibility of these agencies to accommodate the
individual access needs of their employees.  Section 508's requirements for accessible electronic and
information technology will facilitate compliance with the mandates of Section 501 by providing employers
with some of the tools needed to provide these accommodations.  Section 508 goes further, however,
requiring Federal departments or agencies that develop, procure, maintain, or use electronic and information
technology to make sure that all such technology is accessible, whether or not needed or requested by a
specific employee.  Similarly, the availability of accessible information and data required under section 508
will assist Federal agencies charged with providing information to the public under Section 504 of the
Rehabilitation Act.

Telecommunications for the Disabled Act -  Perhaps the first Federal law to directly address the need for
access to new technologies by individuals with disabilities was the Telecommunications for the Disabled Act
of 1982 (TDA).  Pub. L. No. 97-410, codified as amended at 47 U.S.C. 610 (1988).  TDA was designed
to expand the number of hearing aid compatible telephones both inside and outside the Federal government, 
and to ensure the availability of specialized customer premises equipment to all individuals with disabilities at
reasonable prices.  In TDA, Congress, already envisioning the dawn of major technological changes,
established a new national policy to ensure disability access as these changes occurred.  This policy was
announced in the House Report accompanying the bill:  "[M]aking the benefits of the technological revolution
in telecommunications available to all Americans, including those with disabilities, should be a priority of our
national telecommunications policy."  H. Rep. No. 888, 97th Cong., 2d Sess. 5 (1982).  Setting the stage for
Section 508 as well as other pieces of Federal legislation, the legislative history of TDA revealed a new
understanding by Congress that the costs to society of denying such access, by "depriv[ing] many individuals
of the opportunity to have gainful employment" and "impair[ing] . . . the quality of life for disabled Americans"
far exceeded the costs of ensuring such access.  Id. at 4.

Hearing Aid Compatibility Act - The Telecommunications Act of 1982 was followed by two pieces of
legislation in 1988 that again addressed the telecommunications access needs of individuals who are deaf and
hard of hearing.  The first of these, the Hearing Aid Compatibility Act, Pub. L. No.  100-394, codified at 47
U.S.C. 610 (1988), created a mandate for nearly all telephones made or imported into the United States
after August 16, 1989, to be hearing aid compatible.  Various FCC proceedings that followed produced rules
which will assure nearly ubiquitous access to wireline telephones by hearing aid wearers early in the twenty-
first century.

Telecommunications Accessibility Enhancement Act - The second law enacted in 1988 was the
Telecommunications Accessibility Enhancement Act (TAEA), Pub.  L. No. 100-542, codified at 40 U.S.C.
762 (1988).  TAEA created a Federal relay system for calls to, from, and within the Federal government.  It
also directed Congressional members to acquire TTYs for their offices, created a Federal directory of TTY
numbers, and directed the Federal Communications Commission (FCC) to complete an inquiry into the
establishment of a nationwide interstate telecommunications relay system.  TAEA's provisions bear a
relationship to the present Section 508 in that it was designed to specifically reduce technological barriers for
Federal employees.  Toward this end, the Senate's Report on TAEA explained "[i]t has long been recognized
that all employers should take whatever steps possible to fully integrate persons with physical impairments into
the work force."  S. Rep.  No. 464, 100th Cong., 2d Sess. 2 (1988).  Again, Congress concluded that the
costs of installing accessible equipment and providing accessible telecommunications services were
outweighed by the overriding benefits that such access created.

Americans with Disabilities Act - In 1990, our nation witnessed the passage of the Americans with
Disabilities Act (ADA), Pub. L. No. 101-336, codified at 42 U.S.C. 12101, et. seq., landmark legislation
that created new and comprehensive civil right protections for individuals with disabilities in the private sector. 
The ADA is far reaching   its provisions prohibit discrimination by most private employers (Title I), all state
and local government agencies (Title II), and places of public accommodation, such as museums, banks,
restaurants, and theaters (Title III).  Its provisions under Title IV mandate the provision of round-the-clock
nationwide telecommunications relay services, designed to make our nation's telecommunications networks
more accessible to people who are deaf, hard of hearing, or speech impaired.   Finally, the ADA contains
provisions for structural access to new and altered commercial facilities and places of public accommodation. 
These have been implemented through a series of detailed rules, known as the ADA Accessibility Guidelines,
or ADAAG. 28 C.F.R. Part 1191 et. seq.  ADAAG's specifications require the elimination of nearly all
physical barriers in these new and renovated buildings.  Among other things, these guidelines contain
requirements for certain forms of telecommunications access,  including requirements for hearing aid
compatibility, volume control, and TTYs.  They also provide standards on reach ranges, for access to fixed
equipment control consoles and operable parts.  While providing useful guidance for the development of the
EITAAC standards, the ADA focuses on private entities; neither the ADAAG nor the ADA specifically
covers access to electronic equipment procured or used by Federal agencies.

The ADA's provisions have made a considerable impact on our society, opening many doors to employment,
educational, and recreational opportunities that had previously been closed.  But a few years after passage of
the ADA, it became clear that the provisions of the ADA had not contemplated the huge technological
revolution that was enveloping our country.  Although individuals with disabilities were finally gaining some
physical and communications access to government and business employment and services, access to
burgeoning telecommunications and information technologies remained elusive.  When, in the early 1990's,
Congress began considering sweeping changes to our nation's telecommunications policies, disability
advocates saw a ripe opportunity to have this need addressed.  As a consequence, passage of the
Telecommunications Act of 1996 brought with it the arrival of a new civil rights law for individuals with
disabilities:  Section 255.

Telecommunications Act of 1996 -  Section 255 of the Telecommunications Act of 1996, Pub. L. 104-
104, codified at 47 U.S.C. 255, requires telecommunications services and equipment to be accessible,
where readily achievable.  Where not readily achievable, such services and equipment must nevertheless be
compatible with existing peripheral devices or specialized customer premises equipment used to achieve
access, again where this is readily achievable.  Readily achievable is defined as "easily accomplishable and
able to be carried out without much difficulty or expense."  The legislation contemplates that manufacturers
and service providers will consider access needs during the design, development and fabrication of their
offerings, so that expensive and burdensome retrofitting for access will not be necessary.

Section 255 directed the Access Board to develop guidelines to achieve access to telecommunications
equipment and customer premises equipment (CPE) within eighteen months after the legislation's enactment. 
In order to accomplish this task, the Access Board created a body similar to EITAAC   called the
Telecommunications Access Advisory Committee, or TAAC.  After meeting over a period of seven months,
TAAC presented its proposed guidelines to the Access Board in January of 1997.  The contents of these
proposals formed the basis for the Access Board's Section 255 guidelines, released to the public on
February 3, 1998, 63 Fed. Reg. 5608 (Feb. 3, 1998), codified at 36 C.F.R. Part 1193, and effective as of
March 5, 1998.  The FCC will soon release rules to implement Section 255's mandates for
telecommunications service providers.  Those rules will also create procedures to enforce Section 255's
provisions with respect to telecommunications services, telecommunications equipment, and CPE.

The Access Board's guidelines on Section 255 create detailed requirements for the accessibility, usability,
and compatibility of telecommunications equipment and CPE.  36 C.F.R. 1193 et. seq.  Among other
things, the guidelines contain requirements for input, output, display, control, and mechanical functions to be
accessible by individuals with varying disabilities and functional limitations.  The compatibility requirements
focus on the need for standard connectors, compatibility of controls with prosthetics, and TTY compatibility. 
In order to identify access needs and solutions, the guidelines direct manufacturers to consider consulting with
individuals with disabilities, and suggest including individuals with disabilities in market research and the
validation of access solutions.  The new rules define "usability" as access to information about the product,
and direct that "instructions, product information . . . , documentation, and technical support" be functionally
equivalent to that which is provided to individuals without disabilities. In order to monitor the industry's
progress in making telecommunications equipment accessible, the Access Board will compile periodic
"market monitoring reports," that will identify the state of the art of CPE and telecommunications equipment,
as well as problem areas and solutions that have been used to achieve access to these products.  The first of
these reports is well under way.

Section 508 of the Rehabilitation Act is the next logical step in the progression of these various Federal civil
rights laws.  Much of the earlier legislation focused on access to what has traditionally fallen into the field of
"telecommunications."  But our nation is now witnessing a rapid convergence of these traditionally
telecommunications technologies with new and advanced electronic and information technologies.  As our
Federal government becomes increasingly reliant on these convergent technologies, Section 508 will ensure
that individuals with disabilities will be able to reap their many benefits.3.   Definitions

3.1  Electronic and Information Technology
3.1.1    Preamble to the E&IT Definition

It is understood that Electronic and Information Technology addresses a broader spectrum than Information
Technology alone, and includes the full breadth of the information environment of the future. It is understood
that the intent of Section 508 is to ensure that government employees and the public have access to the
government's information environment as it evolves.

It is understood that the information environment that is evolving is something that we only imperfectly
understand today but that it will include (but not be restricted to) the acquisition, creation, translation,
duplication, manipulation, storage, management, movement, control, display, switching, interchange,
transmission, or reception of information in a broad range of forms including voice, graphics, text, and data
structures of all types both on a real time basis (e.g., conversation, communication, interaction) and delayed
presentation basis (e.g. information serving, publishing etc.). It is understood that the definition of "Electronic
and Information Technology" in Section 508 was meant to address the future and be broader than but
consistent with (completely include) the definition of "Information Technology" put forth by the Clinger Cohen
Act of 1996 including the exclusion for national security equipment.

3.1.2    Body of the E&IT Definition

The term "Electronic and Information Technology" (E&IT) shall mean electronic technology that is used in
carrying out information activities, involving any form of information, where:

"Electronic Technology" includes but is not limited to equipment, hardware, computers, software, firmware
and similar procedures, systems, ancillary technologies, technologies which cause content to be active in any
way, documentation, services (including support services) and related resources. It includes subsystems,
interconnections, and interconnected systems.

"Information Activities" include, but are not limited to, the creation, translation, duplication, serving,
acquisition, manipulation, storage, management, movement, control, display, switching, interchange,
transmission, or reception of data or information. Information activities include delayed presentation activities
such as information servers and messaging systems as well as synchronous, real-time communication
activities.

"Any Form of Information" includes, but is not limited to, voice, graphics, text, dynamic content, and data
structures of all types whether they are in electronic, visual, auditory, optical or any other form.3.2  Disability

As used in this document, disability has the same definition as it does under the Rehabilitation Act of 1973 as
amended.

3.3  Undue burden

Undue Burden means significant difficulty or expense.  In determining whether an action would impose an
undue burden on the operation of the agency in question, factors to be considered include:

3.3.1    The nature and cost of the action needed under this section;
3.3.2    The overall size of the agency's program and resources, including the number of employees, number
         and type of facilities, and the size of the agency's budget;
3.3.3    The type of the agency's operation, including the composition and structure of the agency's work
         force; and 
3.3.4    The impact of such action upon the resources and operation of the agency.

4.   Section 508 Implementation

Section 508 is designed to be implemented through the Federal procurement process. In addition to the
obligation to create standards which describe and define accessibility with sufficient clarity for effective
enforcement, the Electronic Information Technology Access Advisory Committee (EITAAC)
recommendations must also address the implementation of these standards through Federal procurement. 
The EITAAC's recommendations are intended to address the needs of all parties involved in the procurement
process.

Manufacturers and providers of E&IT products need to be able to make design choices and R&D
investments with a clear understanding of the criteria Federal procurement officials will use.  Federal
procurement officials in turn need to acquire E&IT based on verifiable accessibility.   Federal enforcement
officials need to be able to measure improvements in accessibility, in order to report progress to Congress, as
required by law, and to take enforcement action where appropriate.  People with disabilities, whether Federal
employees or the general public, need to be able to rely on the Federal procurement system to promptly and
effectively deliver accessible E&IT incorporating current technologies, including advances in accessibility.

Addressing these needs will foster the successful, effective implementation of Section 508.  All of these
requirements need to be met within the statutory definitions and the Undue Burden standard imposed by
Section 508.  The EITAAC has been very mindful of the additional complexities and responsibilities
associated with the need for effective procurement under the FAR and has incorporated these factors in its
deliberations. The major implementation factors affecting accessibility are described below.

4.1  Procurement Process

In its deliberations, the EITAAC was mindful that the ultimate application of accessibility will be in the
purchase of goods and services in Federal procurements. Within the procurement regulations structure,
compliance with Section 508 may be addressed by a combination of two approaches:

     A Representations requirement which compels vendors to declare as a condition of the contract, that
     the products and services comply with all statutory procurement requirements, including Section 508. 
     Such declarations would be subject to applicable administrative and statutory penalties.

     An Evaluation approach, which incorporates accessibility as one of the attributes examined and
     evaluated by the Government as a part of the source selection decision.

The EITAAC report is structured to address both approaches by both defining the minimal acceptable
accessibility requirements and also encouraging alternate technical approaches which incorporate technology
advancements and innovations in accessibility.

4.1.1    Compliance with standards

Agencies will procure E&IT in such a way as to meet the requirements of Section 508. The standards of
evaluation are in Section 5.2 of this report.  In addition, E&IT that fits the conditions in Section 5.3 shall meet
or exceed the standards in Section 5.3.  The procurement agency is responsible for evaluating the E&IT
against these standards. Agencies shall carry out this evaluation whether:

     Procuring complete systems from single vendors
     Buying systems integrated by a Seat Management contractor or other integrator, or 
     Buying products from different vendors and assembling these products into accessible systems.

In every case, the agency is responsible for compliance with Section 508. To meet this obligation, agencies
should address accessibility in determinations of need and include accessibility within the scope of market
research as defined in the Federal Acquisition Regulations (FAR). The EITAAC recommends a written
questionnaire format which permits suppliers to indicate the technical approaches and features in their
products and services that are applicable to the adopted standards.

4.1.2    Alternative technical approaches and technological change

The EITAAC recognizes the need of Federal agencies and people with disabilities to benefit from
technological advances. The pace of technology advancements in E&IT is rapid and the level of innovation is
high. In this environment, a static standard consisting of design specification and fixed checklists would tend to
stifle innovation and to delay the availability of technology advancements to people with disabilities.  At the
same time, clear and specific standards are necessary in order to ensure compliance.  To balance these
needs, the EITAAC standards explicitly address alternative technical approaches. The technical standards
describe the minimum acceptable level of accessibility and the relevant accessibility features which are either
available or under development at the time of publication.

Therefore, the accessibility requirements in this report are intended as a baseline, the minimum to which
additional improvements and enhancements will be added. Manufacturers and providers should be
encouraged to exceed these requirements, and the procurement process should reward them for doing so. 
This will foster innovation and improvement in accessibility.

4.2  Standards Refreshment

Over time, improvements in technical approaches to accessibility of Federal E&IT will come from three
primary sources.  One source will be the continuing development of technical standards for accessibility.  A
second source is advances in scientific understanding of human factors.  These developments will be
incorporated by the periodic Standards Refreshment by the Access Board.  Thus, the accessibility standards
and the detailed technical assistance the Access Board provides to agencies will be evaluated and updated
over time.  The third source will be producers of E&IT products and of assistive technologies, who will
progressively introduce new inventions, new innovations, and new products into the marketplace (see Section
4.1.2 above).  As with the evaluation of accessibility compliance, the responsibility for evaluating these
alternative technical approaches rests with the Federal agencies.  The intent of section 508 is to encourage the
introduction of new E&IT products and approaches which progressively enhance and improve the
accessibility of E&IT to Federal employees and to the General Public.  In turn, the EITAAC standards are
designed to encourage agencies to consider these improved alternatives as they are introduced.

Concurrent with the development of the EITAAC standards, multiple national and international standards
have been developed and are continuing to emerge.  The EITAAC has referred to some of these standards in
section 5.3.  Others are expected to be cited by the Access Board in technical assistance to Federal
agencies.  These standards and standard setting committees include, among others:

     World Wide Web Consortium Web Accessibility Initiative Guidelines  (Web Content, User Agent, &
     Authoring Tool)
     ISO TC 159: Software Accessibility
     ISO TC 173: Technical systems and aids for people with disabilities
     ANSI C63.19: Wireless Hearing Aid Compatibility
     IEC TC 100: Ease-of-use of appliance controllers, to meet the needs of people with disabilities
     (Japan)
     SOGITS N 1032 - EN for DG XIII: (European Standards)
     Nordic Standards for Accessibility

These examples demonstrate the degree to which accessibility is receiving increasing attention and priority
throughout the world.  This heightened interest suggests further investments and advancements in accessibility
technologies in many countries and across multiple scientific disciplines.  As these advancements progress, the
Access Board (or other appropriate body) should review and update the Federal accessibility standards to
reflect the advancing State of the Art.  Because E&IT is a global market, the use of international standards
where appropriate will also benefit agencies and people with disabilities by reducing costs that would be
associated with designing and developing different products to meet conflicting requirements in different
markets.

4.3  Principles for Implementation

In implementing the Section 508 requirements, Federal agencies are responsible for ensuring that Federal
E&IT provides Federal employees and members of the public who have disabilities access to data and
information that is comparable to that of employees and members of the public who do not have disabilities,
except where this requirement would create an undue burden on the agency.  Section 5 presents the
EITAAC's recommended standards for identifying whether E&IT provides this comparable access. Agencies
should take the principles set forth in this section into account in implementing these requirements.  These are
necessary in order to ensure that the requirements of Section 508 are met fully, effectively, and efficiently--
both now and in the future as the technological capability of E&IT evolves.  The Access Board will provide
ongoing technical assistance to agencies in applying these principles.

4.3.1    Principle of User Access and Efficiency

Accessibility is measured for each individual in their interaction with specific E&IT.  Relevant issues are
whether the individual with a disability can use the E&IT to perform the same tasks, access the same
information, with the same approximate ease and in the same approximate time and at the same cost as a
person without a disability using the E&IT.  For this evaluation, cost is to the individual Federal employee or
member of the public, not to the procuring agency.  For example, if the information is available to the general
public for free, the accessible version of that information shall also be free.

This principle focuses on the user's ability to independently perform tasks to the best of their abilities. 
Accessibility provisions should not only permit basic access, they should also allow people with disabilities to
maximize the use of the abilities they have.  People with disabilities need efficient access to be comparably
productive with their colleagues.4.3.2    Principle of Technical Feasibility

The standards in Section 5 were written to allow for evolution in the technical feasibility of these requirements. 
The rapid development of technology makes any determination of current technical feasibility extremely short
lived.  Hence, at the highest level of this standard the document attempts to set forth the generic requirements
based on human need.  Section 5.3 identifies with greater specificity the current, technologically feasible
approaches for making certain classes and features of E&IT accessible.  Full compliance with a particular
standard  in Section 5.2 may not currently be technically feasible with current technology for some particular
applications. Technical feasibility must therefore be evaluated within the procurement process.  However, as
technology advances, the agencies must exercise judgment, with technical assistance from the Access Board,
industry, and consumers, to determine when a requirement has become technically feasible for a particular
application or environment.  This judgment must then be incorporated into the agencies' procurement
processes to ensure continuing compliance with Section 508.

4.3.3    Principle of Proportionality

In implementing the standards, agencies must ensure that no standard is applied so as to go beyond what is
necessary to achieve its objective.  This principle is intended to assure that requirements do not create
unforeseen inefficiencies and create cost without significant benefit.

4.3.4    Principle of Flexibility

Agencies should apply this principle to reflect the fact that different users have preferences or necessities to
operate E&IT in different ways.  Just as it is common to be able to achieve a given operation in any of several
ways (for example by a mouse or keyboard commands), where available, more than one accessibility option
should be provided.  For example, telling a person with low vision that the only accessibility accommodation
was speech output rather than providing screen magnification is not a reasonable position.

4.3.5    Principle of Compatibility and Adaptability

The E&IT products, services, and systems that Federal agencies procure for use by their employees and the
public as well as the technologies (including Assistive Technologies) whose purpose is to provide accessibility
that are purchased by Federal agencies must be compatible.

In procuring E&IT and Assistive Technologies, to comply with Section 508, agencies have a responsibility to
do more than merely verify that the E&IT works in one application with one particular Assistive Technology
product.  At the same time, it is unreasonable to expect that agencies and vendors of E&IT can ensure that
the E&IT will be directly compatible with (or adaptable to work with) every current or prospective
accessibility technology.  Nevertheless, agencies have a responsibility to ensure that E&IT and accessibility
technologies are as broadly compatible as possible without creating an undue burden.  In making this
determination, agencies should consider the use of government, or industry standards for hardware and
software interfaces as positive, but not definitive, indicators that E&IT and accessibility technologies that are
being considered for procurement will be compatible.

4.4  Technical Guidance

The Access Board must be able to provide coherent technical guidance to Federal agencies seeking to
comply with Section 508.  Because Section 508 addresses E&IT, the standards for accessibility will change
rapidly with time.  Issues will become better understood, and best practices will evolve.  The Access Board
needs to be funded to deliver this technical guidance, or the ability of Federal agencies to implement Section
508 will be impaired.

5.   Proposed Standards

5.1  Introduction

Electronic and Information technology (E&IT) procured by the Federal government shall be accessible to and
usable by individuals with disabilities.  Being accessible and usable by people with disabilities includes being
able to perform all the regular operating functions of the E&IT including input and control functions, operation
of any mechanical mechanisms, and access to information displayed in visual and auditory form.   It also
includes the ability to work with the assistive technologies used to access E&IT and should not interfere with
the assistive technologies used on a daily basis by people with disabilities.  Documentation and services
associated with E&IT shall also be accessible and usable.

These standards apply to a full range of E&IT as defined in 3.1.2  including those used for communication,
duplication, computing, storage, presentation, control, transport and production.

These must be accessible and usable by as wide a range of people with disabilities as possible including
people with:

     visual disabilities (e.g., blindness, low vision and lack of color perception),
     hearing disabilities (e.g., hard of hearing, deafness),
     people with physical disabilities (e.g., limited strength, reach or manipulation, tremor, lack of
     sensation),
     people with speech disabilities,
     people with language, learning or cognitive disabilities (e.g., reading disabilities, thinking,
     remembering, sequencing disabilities),
     other disabilities (e.g., epilepsy, short stature), and
     individuals with any combination of these disabling conditions (e.g., deaf-blindness).These access standards are arranged in two sections

     Generic Standards - Apply to all E&IT (5.2)
     Technology Specific Standards - that only apply to E&ITs which have a particular characteristic or
     function. (5.3)

The generic requirements are the highest level of requirements and apply to all E&ITs.  These requirements
are performance standards in nature and are written based upon the varieties of human needs for access
found in the population.  Being based upon human needs, these requirements do not mandate specific
technical implementations, which may be used to address these needs.  Further, they are not written to reflect
the status or limitations of current technologies.  Hence, at the highest level of this standard the document
attempts to set forth the need, allowing technical feasibility to be determined within the procurement process.

The technology specific standards apply only to E&IT which includes the specified feature or function cited. 
These requirements are more limited in scope.  These requirements provide standards for the specific access
attributes required in the specified class of E&IT.

These standards are not written to reflect the status or limitations of current technologies.  Thus, not all
standards may be technically/commercially feasible for all technologies today.  The rapid development of
technology however is creating new opportunities for adding flexibility and capabilities to products over time. 
But changes in technology do not always benefit accessibility.  In the past, new technologies have resulted in
significant temporary setbacks to access.  The best example of this is the transition from character based
computing to pixel based computing (the graphical user interface).  Therefore, in considering innovative new
E&IT, Federal agencies must be especially diligent in applying the standards in Section 5 of these standards.

E&IT shall be able to satisfy each of the following conditions to ensure that E&IT is usable by people with
disabilities and the information presented via E&IT is accessible to them.  These conditions shall be applied 
individually and in combination.  All those that are possible (without undue burden) for any E&IT should be
applied.

5.2  Generic Standards for Accessibility
5.2.1    Accessibility of operation and Information

Accessibility of the product includes being able to locate, identify, and operate all of the input, control and
mechanical functions, as well as being able to access the information provided by or through it.  Accessibility
of information includes the ability to access text, static or dynamic images, icons, labels, sounds or incidental
operating cues.

Accessibility also includes being able to accommodate the physical characteristics of individuals with
disabilities as well as personal assistive technologies which are used to extend or enhance their personal
abilities such as hearing aids, cochlear implants, prosthetics and wheelchairs, etc.

5.2.1.1 Usable without vision.

     5.2.1.1.1 Provide at least one mode that does not require user vision.  [TAAG]
     5.2.1.1.2 Provide visual information through at least one mode in auditory form.  [TAAG]

5.2.1.2 Usable with low vision without relying on audio.

     5.2.1.2.1 Provide at least one mode that permits operation of controls and mechanical functions by
     users with visual acuity between 20/70 and 20/200, without relying on audio output. [TAAG]
     5.2.1.2.2 Provide visual information through at least one mode to users with visual acuity between
     20/70 and 20/200 without relying on audio. [TAAG]
     5.2.1.2.3 If audio and non-audio access approaches are provided they shall be able to work both
     separately or simultaneously.
     5.2.1.2.4 The contrast between the text and the background behind the text at its worst location shall
     be greater than 70% or it shall be able to adjust the text or background to meet this specification.

5.2.1.3 Usable with little or no color perception.

     5.2.1.3.1 Provide at least one mode that does not require user color perception. [TAAG]
     5.2.1.3.2 Information presented shall not require color perception.

5.2.1.4 Usable without hearing.

     5.2.1.4.1 Provide at least one mode that does not require user auditory perception. [TAAG]
     5.2.1.4.2 Provide auditory information through at least one mode in visual form and, where
     appropriate, in tactile form. [TAAG]  For multimedia material or where user interaction is required,
     display of the visual/tactile form shall be in synchrony with the audio presentation.

5.2.1.5 Usable with limited hearing.

     5.2.1.5.1 Provide audio information, including any auditory feedback tones that are important for the
     use of the product, through at least one mode in enhanced auditory fashion (i.e., increased
     amplification).
     5.2.1.5.2 For voice output from devices, provide incremental volume control with output amplification
     up to a level of at least 97 dB SPL with at least one intermediate step of 89 dB SPL.
     5.2.1.5.3 For transmitted voice signals, provide a gain adjustable up to a minimum of 20 dB.  For
     incremental volume control, provide at least one intermediate step of 12 dB of gain.
     5.2.1.5.4 For the safety of other users, if the E&IT has the possibility of exceeding 120 dB SPL then
     a mechanism shall be included to automatically reset the volume to a safe level after every use (e.g.
     when handset is replaced) but not before.
         5.2.1.5.4.1 If there is an automatic volume reset then there shall be an override for non-public,
         non-shared E&ITs or a means to easily reset to the user's volume setting.
         5.2.1.5.4.2 Where there is an override there shall be a way to visually determine the current
         volume setting.

5.2.1.6 Usable with limited manual dexterity, reach and /or strength.

     5.2.1.6.1 Provide at least one mode that does not require fine motor control or simultaneous actions.
     [TAAG]
     5.2.1.6.2 Provide at least one mode that is operable with limited reach and strength. [TAAG]
     5.2.1.6.3 The E&IT shall comply with the following section of the ADAAG 1998: Section 4.27.4
     Controls and Operating Mechanisms

5.2.1.7 Usable without time-dependent controls or displays.

     5.2.1.7.1 Provide at least one mode that does not require a response time. Alternatively, a response
     time may be required if the response time may be by-passed or adjusted by the user over a range
     equal to at least 5 times the average user setting with a value of at least 5 seconds.
     5.2.1.7.2 Provide moving text in at least one static presentation mode at the option of the user.
     [TAAG]

5.2.1.8 Usable without speech.

     5.2.1.8.1 Provide at least one mode that does not require user speech. [TAAG]

5.2.1.9 Usable with limited cognitive or memory abilities.

     5.2.1.9.1 Provide at least one mode that minimizes the cognitive, and memory ability required of the
     user.

5.2.1.10 Usable with language or learning disabilities.

     5.2.1.10.1 Provide at least one mode that accommodates people with learning disabilities.5.2.1.11 Availability of audio cutoff.

     5.2.1.11.1 Where E&IT access features deliver speech output, provide a mechanism for private
     listening.
     5.2.1.11.2 Where E&IT access features deliver speech output, provide a mechanism for
     interuptability.

5.2.1.12 Prevention of visually-induced seizures.

     5.2.1.12.1 Visual displays and indicators shall minimize visual flicker that might induce seizures in
     people with photosensitive epilepsy. [TAAG]  Rates of 3 Hz or lower, or 60 Hz or higher are
     recommended.

5.2.1.13 Biometric identification /activation bypassing.

     5.2.1.13.1 Where biometric forms of user identification or activation are used (retinal scanning, iris
     scanning, voiceprint identification, fingerprint scanning etc.), an alternative form of identification or
     activation which does not require the user to possess particular biological characteristics, shall be
     provided.

5.2.1.14 Usable with upper extremity prosthetics.

     5.2.1.14.1 Touchscreens or touch-operated controls shall be usable without requiring body contact
     or close human body proximity. [TAAG]

5.2.1.15  Hearing aid compatibility.

     5.2.1.15.1 Where an E&IT delivers output by an audio transducer which is normally held up to the
     ear, provide a means for effective magnetic wireless coupling to hearing aids. If the E&IT
     communicates by RF, electromagnetic compatibility with hearing aids shall be addressed. EIA RS-
     504 defines the signal level requirements for this section. ANSI C63.19 (draft)provides the tests and
     parameters for compatibility between hearing aids and wireless communications devices including
     magnetic (t-coil) and electromagnetic compatibility.  [NOTE: ANSI C63.19 (draft) applies and
     extends the requirements of EIA RS-504 for use with wireless communications devices.  It provides
     more specific guidance for cases where an RF transmission field is also involved.]

5.2.1.16 Usable from a wheelchair or similar mobility device.

     5.2.1.16.1 E&IT shall be usable from a wheelchair or similar mobility device.  For this reason the
     E&IT shall comply with the following provisions of the ADAAG 1998: Section 4.2 Space Allowance
     and Reach Ranges; Section 4.3 Accessible Route; Section 4.5 Ground and Floor Surfaces.

5.2.2    Compatibility With Devices used for Access

5.2.2.1 Information Pass Through.

     5.2.2.1.1 All E&IT that acts as a transport or conduit for information/communication shall pass
     through cross-manufacturer, non-proprietary, industry-standard codes, translation protocols, formats
     or other information necessary to provide the information/communication in an accessible format.  In
     particular, technologies which use encoding, signal compression, format transformation, or similar
     techniques shall not remove information needed for access or shall restore it upon delivery.

5.2.2.2 External electronic access to all information and control mechanisms.

     5.2.2.2.1 Information and control needed for the real time operation of an E&IT (including equivalent
     access to control, output, alerts, icons, on-line help, and on-line documentation) shall be available to
     an external device in a cross-industry standard form that is easily and completely translatable into text. 
     This form shall be available via a cross-industry standard port that does not require manipulation of a
     connector by the user.

5.2.2.3 Connection point for external audio processing devices.

     5.2.2.3.1 E&ITs providing auditory output shall provide the auditory signal at a standard signal level
     through an industry standard connector. [TAAG]  An exception is E&ITs that only provide simple
     auditory information that is also provided visually by the E&IT.

5.2.3    Information, Documentation, Labeling & Support

Information, documentation, labeling, and support provided to customers shall be accessible. Such
information and documentation includes user guides, installation guides for end-user installable devices, and
E&IT support communications, regarding both the E&IT in general and the accessibility features of the E&IT. 
This includes (but is not limited to):

     5.2.3.1 Providing a description of the accessibility and compatibility features of the E&IT upon
     request, including, as needed, in alternate formats or alternate modes at no additional charge.
     5.2.3.2 Providing end-user E&IT documentation in alternate formats or alternate modes upon request
     at no additional charge.
     5.2.3.3 Ensuring accessible and usable customer support and technical support in the call centers and
     service centers (including TTY and training in the use of telecommunications relay services) which
     support their E&ITs at no additional charge beyond that which is charged to non-disabled users
     (including allowances for extra communication time).
     5.2.3.4 Making electronic versions of the documents available on the Internet in accessible form on
     an accessible site.  It shall also be available on request via mail.
     5.2.3.5 Including the contact method for obtaining the information required by this section, in general
     E&IT information.
     5.2.3.6 Ensuring that any training provided (by manufacturers, providers or other parties)
     accommodates the functional capabilities of all participants.  In developing, or incorporating existing
     training programs, consideration shall be given to the following factors: Accessibility needs of
     individuals with disabilities (as participants or trainers); Means of communicating with individuals with
     disabilities before and after training; Commonly used adaptive technology used with the manufacturers
     and provider's E&ITs; Solutions for accessibility and compatibility.

5.3  Technology Specific Standards.

In addition to the requirements above, the following standards apply to E&IT with the following functions:

5.3.1    If the E&IT has a physical keyboard...

In addition to the requirements in Section 5.2 and applicable portions of Section 5.3, it shall meet the
following requirements:

     5.3.1.1 Keys shall be tactilely discernable without actuating the keys.
     5.3.1.2 The keyboard delay before repeat, if keyboard repeat is supported, shall be adjustable to at
     least 2 seconds. Key repeat rate shall be adjustable to 2 seconds per character.
     5.3.1.3 All actions available or required by the E&IT shall be available from the keyboard (i.e.,
     keyboard equivalents for all non-keyboard actions or commands).
     5.3.1.4 E&IT (including software applications and electronic forms) shall provide logical navigation
     among interface elements (e.g. fields, buttons and controls) such as by tabbing or use of cursor keys.
     5.3.1.5 Assigned keyboard access (e.g., Ctrl+P for Print, Escape for cancel) shall be provided for
     commonly used functions or commands.
     5.3.1.6 All keyboard access functionality shall be documented with the E&IT and/or follow
     documented operating system conventions.
     5.3.1.7 The software intended to be installed on an E&IT shall not interfere with existing accessibility
     features built into the E&IT or its operating system (e.g., Sticky Keys, Slow Keys, Repeat Keys).
     5.3.1.8 The status of all locking or latching keys shall  be discernable either through touch or sound, in
     addition to being visually discernable.
     5.3.1.9 The keyboard map shall not change except under user control, so that a user memorizing key
     locations shall be able to rely on those locations.5.3.2    If the E&IT is software in nature and runs on a platform that has an operating system.

In addition to the requirements in Section 5.2 and applicable portions of Section 5.3, it shall meet the
following requirements:

     5.3.2.1 It shall support Keyboard Access as described in Section 5.3.1, if the E&IT has a keyboard.
     5.3.2.2 Provide a well-defined visual focus indicator that moves among interactive interface elements
     as the input focus changes. The  focus shall be programmatically exposed (read and set) so that 
     assistive technology can track focus and focus changes.
     5.3.2.3 Sufficient information about a user interface element shall be available to assistive technology
     to enable the AT to understand the identity, operation and state of the element (e.g., element is a text
     box with label "enter password," or a check box which is checked).
     5.3.2.4 Where an image represents an interface element or the state of an interface element, there
     must be a way for assistive technology to associate meaningful text with the image.  Examples include
     providing text labels for desktop icons, or making text available as a pop-up, tool-tip, or bubble help
     to concisely indicate state, or the result of acting on the element. Such text shall be programmatically
     accessible to assistive technology.
     5.3.2.5 The use of images shall be consistent throughout the application (e.g., use the same folder
     icon or the same icon to indicate 'selected' if such is used in several places in the application).
     5.3.2.6 Provide text through an Application Programming Interface (API)supporting interaction with
     assistive technology or use system text writing tools. The minimum information that shall be available
     to an assistive technology is text content, text input caret location, and text attributes.
     5.3.2.7 Provide a wide variety of color and font settings to allow for high contrast color schemes,
     large fonts and different font styles, including serif and sans-serif. Inherit and respect system-wide
     color settings.
     5.3.2.8 Do not use color coding as the only means of conveying information or indicating an action.
     The software must provide an alternative or parallel method of displaying information that can be used
     by individuals who do not possess the ability to identify colors.
     5.3.2.9 System startup and restart shall be accessible.
     5.3.2.10 Electronic forms shall be accessible in a manner, which allows full access to the information,
     field elements, and functionality required for completion of the form including all directions and cues.
     5.3.2.11 Software packages which install applications and operating system components shall
     conform to provisions in Sec. 5.3.1 and 5.3.2, or be fully accessible through an industry standard port
     as provided in Sec. 5.2.2.2.5.3.3    If the E&IT utilizes Web based information or applications...

In addition to the requirements in Section 5.2 and applicable portions of Section 5.3, if the E&IT utilizes
Web-based information or formats, including intranet information, HyperText Markup Language (HTML),
Extensible Markup Language (XML)and similar formats, it shall meet the following requirements:

     5.3.3.1 Web content shall conform with level 'Double-A', satisfying all Priority 1 and 2 checkpoints,
     of the World Wide Web Consortium (W3C) 'Web Content Accessibility Guidelines 1.0" available at
     http://www.w3.org/TR/WAI-WEBCONTENT
     5.3.3.2 Tools for authoring Web page and sites (What-You-See-Is-What-I-Get
     (WYSIWIG)editors, conversion tools, image editors, site management tools) shall comply with
     Priorities 1 and 2 of the [ latest version at time Access Board does its regulations] of the W3C
     'Authoring Tool Accessibility Guidelines' available at http://www.w3.org/TR.
     5.3.3.3. User agents shall comply with Priorities 1 and 2 of the [ latest version at time Access Board
     does its regulations] of the W3C 'User Agent Accessibility Guidelines' available at
     http://www.w3.org/TR.
     5.3.3.4 If there are navigation links or tool bars at the top and left side of your page, provide a link at
     the top of the page (a text link or as alt-text on an image) that says "skip over navigation links," and
     takes the user to the main content, starting point, or headline of the page.
     5.3.3.5 If extensive ASCII art is used, then a link shall be provided to allow a user to jump to the end
     of the ASCII art.

5.3.4    If the E&IT provides Telecommunications functions...

In addition to the requirements in Section 5.2 and applicable portions of Section 5.3, it shall meet the
following requirements:

     5.3.4.1 Telecommunications E&IT and customer premises E&IT shall be compatible with peripheral
     devices and specialized customer premises E&IT commonly used by individuals with disabilities to
     achieve accessibility, and shall comply with the following provisions, as applicable:
     5.3.4.1.1 TTY connectability:
         E&ITs 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.
         It shall also be possible for the user to easily turn any microphone on and off to allow the user
         to intermix speech with TTY use.
     5.3.4.1.2 TTY signal compatibility:
         E&ITs which include voice communication functionality, shall support use of all cross-
         manufacturer non-proprietary standard signals used by TTYs.
     5.3.4.2 TTY users shall be able to utilize voice mail, auto-attendant, and interactive voice response
     systems directly with their TTY.
     5.3.4.3 Voice mail, auto-attendant, and interactive voice response systems shall provide at least one
     mode which does not require users to respond within a timed interval or allows users to adjust the
     timing and repetition of those intervals so that the systems can be used both by people with slower
     response times and by Telecommunication Relay Services or other situations where a person is
     interpreting for or assisting a user.
     5.3.4.4 If messaging is supported for voice calls, it shall be supported for TTY.
     5.3.4.5 Special services such as ANI (Automatic Number Identification) and ALI (Automatic
     Location Identification), if provided for voice telephony users, shall also be provided for users of a
     TTY and for users who cannot see displays.

5.3.5    If the E&IT utilizes Video or Multimedia...

In addition to the requirements in Section 5.2 and applicable portions of Section 5.3, it shall meet the
following requirements:

     5.3.5.1 Regardless of format, all video that contains speech or other audio necessary for
     comprehension of the content shall be either open- or closed-captioned.  Closed captioned video
     must not require separate hardware, circuitry, or software to open the captions, except as noted in
     Section 5.3.5.5.
         5.3.5.1.1 Analog video media shall use the "EIA-608 specification" for line-21 closed caption
         data.
         5.3.5.1.2 Digital video formats that are defined by the Advanced Television Systems
         Committee (ATSC) shall use the specification EIA-708-A for closed captioning.  (NOTE:  By
         July 1, 1999 the FCC will initiate an NPRM on characteristics of Advanced Television Closed
         Captioning.  The resulting rule may or may not be identical to EIA-708-A, and when issued
         should be incorporated into the E&IT guidelines.)
         5.3.5.1.3 Digital video disk (DVD) stored video shall use the EIA-608 specification.
     5.3.5.2 When a piece of media, including analog and digital video, contains visual information
     essential to understanding its content, the media shall also be available with narrative descriptions of
     visual displays. Digital video formats, including digital broadcast formats defined by the Advanced
     Television Systems Committee (ATSC) shall use the ancillary audio channels as defined in ATSC
     ancillary audio technical specifications, unless the narrative description is in the primary audio channel.
     5.3.5.3 Display or presentation of alternate text presentation or narrative descriptions shall be user-
     selectable unless permanent.
     5.3.5.4 All television displays 13 inches and larger, and computer equipment that includes tv receiver
     circuitry (TV E&IT) shall be equipped with caption decoder circuitry which receives and properly
     decodes and displays closed captions from broadcast, cable, videotape, and DVD signals.  Analog
     displays and receivers in computer components shall comply with the Federal Communications
     Commission part 15 rules which govern the specifications for television receivers.  Digital television
     displays shall contain decoder circuitry as defined in EIA-708 and shall receive and properly decode
     closed captions from digital television and from compatible auxiliary video sources.  TV E&IT not
     governed by these rules (e.g., monitors less than 13 inches, or monitors not equipped with built-in
     tuners and therefore not considered television displays), shall be equipped with separate closed
     caption decoders that comply with EIA-608.
     5.3.5.5 Digital television displays shall be equipped with caption decoder circuitry which receives and
     properly decodes and displays closed captions according to the "EIA-708-A" specification.
     5.3.5.6 Analog television displays shall be equipped with Secondary Audio Program playback
     circuitry as defined by the Multi-channel Television Sound specification.
     5.3.5.7 Digital television displays shall be equipped with ancillary audio playback capabilities as
     defined by the Advanced Television Systems Committee.
     5.3.5.8 Embedded or encoded alternate text presentations (closed captions) and narrative
     descriptions shall be preserved intact when a piece of media is copied, transmitted, reformatted
     (edited), or transformed for display on subsequent platforms (particularly when digitized from an
     original analog format). "Preserved intact" includes maintaining all styles and exact timing and
     synchronization commands and zero introduction of errors or garbling of data.

5.3.6    If the E&IT is an Information Transaction Machine (ITM)...

In addition to the requirements in Section 5.2 and applicable portions of Section 5.3, Information Transaction
Machines, including, but not limited to, Automated Teller Machines (ATMs),  Electronic kiosks and Point-of-
Sale (POS) terminals, shall meet the following:

     5.3.6.1 The establishing of a person's identity and user interface (UI) display and interaction
     preferences shall be possible and of equivalent ease for people with and without disabilities. Examples
     of identification methods include cards, smart cards and biometrics. Examples of UI display
     preferences include magnified content, voice output, and remote access.
     5.3.6.2 The ITM shall be useable without the need of attaching a device to it or copying an assistive
     technology from a user device onto it. For purposes of this provision, a 2.5 mm. headphone jack that
     supports the use of headphones shall not be considered an external device.
     5.3.6.3 The ITM shall support full access to the functionality of the ITM in a secure manner via an
     external personal device connected to the ITM through wireless means, based on cross industry,
     community developed standards, per 5.2.2.2.1.

5.3.7    If the E&IT is a PDA...

In addition to the requirements in Section 5.2 and applicable portions of Section 5.3, it shall meet the
following requirements:

     5.3.7.1 If it is not currently technically feasible to make a PDA accessible for a segment of disabled
     users, the host functions that support that PDA shall be made available to personal devices, such as
     laptop computers or dedicated notetakers, to achieve equivalent functionality

5.3.8    If the E&IT provides an interface over a network...

In addition to the requirements in Section 5.2 and applicable portions of Section 5.3, it shall meet the
following requirements:

     5.3.8.1 The user interface it provides over the network must meet the applicable requirements of
     section  5.3.2.

5.3.9    If the E&IT has cabling and /or other connections...

In addition to the requirements in Section 5.2 and applicable portions of Section 5.3, it shall meet the
following requirements:

     5.3.9.1 Connection of appropriate cables, mounting and attaching external elements of the E&IT (e.g.
     connecting an external monitor or accessory), the force required to make connections shall be no
     greater than 5 lbf (22.2 N).
     5.3.9.2 Cables shall be tactilely differentiable or keyed for corresponding connections (which are also
     tactilely differentiable).

5.3.10   If the E&IT is used to produce information...

In addition to the requirements in Section 5.2 and applicable portions of Section 5.3, it shall meet the
following requirements:

     5.3.10.1 Technologies used for production of information  (i.e., documents, multimedia, etc.) shall
     allow for and facilitate the creation of alternative modality formats (visual, audible, tactile and text) if
     the basic format is not modality independent (e.g., text). Document formats that are primarily
     designed to recreate images of documents that contain text (except hand-written text) shall not be
     used unless the text is fully accessible.6.   Appendices

6.1  References

IEEE Std 100-1997, The New IEEE Standard Dictionary of Electrical and Electronics Terms 5th ed.

6.2. Glossary

American Sign Language
     A language using a communication system of gestures, handshapes, body movements, and facial
     expressions to represent words and concepts.  ASL has a syntax, grammatical structure, and idioms
     that are distinct from spoken English.

Alternate formats
     Alternate formats may include, but are not limited to, Braille, W3C-WCAG 1.0 compliant HTML,
     ASCII text, large print, and audio cassette recording.

Alternate modes
     Different means of providing information to users of products including product documentation and
     information about the status or operation of controls. Examples of alternate modes may include, but
     are not limited to, voice, fax, relay service, TTY, Internet posting, captioning, text-to-speech
     synthesis, and video description.

Assistive Technologies
     Any piece of equipment, product system, or other technology, whether acquired commercially,
     modified, or customized, that is used to increase, maintain, or improve functional capabilities of
     individuals with disabilities.

Compatible
     Compatible generally means the E&IT can be used with, does not interfere with, and where
     applicable, can be connected to assistive technology products (hardware and/or software) used by
     individuals with disabilities to achieve access.

TTY
     Originally an abbreviation for teletypewriter, TTYs are text telephone devices which provide real-
     time, two-way text-based communications over telephone networks.  All TTYs support
     communication using Baudot encoding at 45.45 baud although they may also support other speeds or
     standards as well.6.3  Acronyms

ADA      Americans with Disabilities Act
ADAAG    Americans with Disabilities Act Architectural Guidelines
API      Application Programming Interface
ASL      American Sign Language
AT       Assistive Technology
ATM      Automated Teller Machines
ATSC     Advanced Television Systems Committee
E&IT     Electronic and Information Technology
EITAAC   Electronic Information Technology Access Advisory Committee
FAR      Federal Acquisition Regulations
HTML HyperText Markup Language
ITM      Information Transaction Machines
LD       Learning Disability
PDA      Personal Digital Assistant
POS      Point-of-Sale
RF       Radio Frequency
SPL      Sound Pressure Level
TAAG     Telecommunications Act Accessibility Guidelines
TTY      See Definitions
UI       User Interface
WYSIWYG  What-You-See-Is-What-You-Get
W3C      WorldWide Web Consortium
XML      Extensible Markup Language

6.4  Examples and Background Information

Introduction

This appendix expands on the material presented in Section 5 of the report.  It provides supporting material
and suggestions for accessibility solutions for some of the standards in Section 5.  Since the proposed
standards in Section 5 stand alone, this material is not intended by the Committee to limit the proposed
standards in any way.  Instead, we think of this as being part of the building of the technical guidance and
material that the Access Board will need to develop.  This is only a preliminary list of notes and ideas to
support the guidelines.  For additional information and pointers to other support sources the reader is referred
to the Access Boards Website at www.access-board.gov.

Information Regarding 5.2.1.1  Usable without vision.

Solutions: Simple controls can be made accessible by tactile means when coupled with good (accessible)
instructions.  Braille is a good mechanism for providing accessible text to those who know Braille (though not
all people who are blind know Braille - especially people who lose their sight when they are older).  Voice
output is rapidly becoming a viable approach due to continually dropping electronic costs and provides the
most widely accessible method for providing access to both displays and controls.  (Voice is also helpful to
people with learning and cognitive disabilities - See 5.2.1.9 and 5.2.1.10.)

Information Regarding 5.2.1.2  Usable with low vision without relying on audio.

Background: Low vision is sometimes accompanied by hearing loss.  This is especially common in older
people.  Audio alone as an accessibility strategy will fail to meet the needs of this group.

Information Regarding 5.2.1.3  Usable with little or no color perception.

Background: This guideline should in no way suggest that color should be avoided.  Color is good and very
helpful for many disabilities.  Information that is conveyed by color however should also be conveyed in other
ways as well.

Information Regarding 5.2.1.5  Usable with limited hearing.

Background: People with limited hearing often cannot see well either, especially people who are older. 
Allowing them to use their residual hearing  is therefore important rather than having to rely on sight (e.g.
relying on access techniques that would be used by people who are deaf).  The 97dB SPL requirement for
the minimum level for the maximum volume setting (into a sealed ear coupler) comes from the original AMPS
standard TIA/EIA IS-19B and has propagated through the newer cellular phone standards as well.

Information Regarding 5.2.1.7  Usable without time-dependent controls or displays.

Background: This is an important issue for many disabilities.  For people who are blind - additional time is
often necessary to find and have text read before they can respond. For people with low vision, it often takes
them longer to both locate and examine text to read it.  For people who are using a Telecommunication Relay
service, there are often translation delays that greatly slow people down.  People with physical disabilities
often are slower and need additional time.  Many also find their physical control degrades rapidly when put
under timed pressure.  People whose native language is different often need longer to read and respond -
including some people who are deaf and whose native language is ASL.  People with learning disabilities as
well as people with cognitive disabilities also often need a longer period to either read or respond.

Information Regarding 5.2.1.8  Usable without Speech.

Background: This applies to some people who are deaf, who have physical disabilities and who have
cognitive-language disabilities.

Information Regarding 5.2.1.10  Usable with Learning Disabilities.

Background: People with learning disabilities have an average or better intelligence with neurological
disorders that affect reading, writing, listening, speaking, performing mathematics, reasoning or handling
distractions. Many of the same solutions that assist people with other disabilities are also helpful to people
with learning disabilities ("LD").  For example, multiple modes of information presentation are often quite
helpful to people with LD, i.e., seeing and hearing information at the same time and enlarging the text. 
Persons with Attention Deficit Disorder can benefit from less complex user interfaces, fewer distractions and
clear instructions.  Ready access to human technical support is an important accommodation issue for people
with LD.

Information Regarding 5.2.1.11.1  Availability of audio cutoff. - Private Listening.

Background: This applies only to audio output which is provided as an access feature although it should also
be provided where the audio can be turned up and would be a significant annoyance if it were used at higher
volume levels.  A headphone jack is considered private listening.

Information Regarding 5.2.1.11.2  Availability of audio cutoff. - Interruptability.

Background: If speech output is used as an alternative to a visual display, it is often desirable to be able to
have speech interrupted whenever the user invokes a control to execute the next function.  This feature, often
referred to as "interruptability," enables the user to move quickly from one task to the next without wasting
time listening to unnecessary or unwanted verbal information.

Solutions: Provide a mode which silences any ongoing speech whenever the user invokes a function or makes
a selection.  For example, suppose an ATM is asking the user to select a transaction.  Upon pressing a
transaction selection, the verbal menu being spoken is halted immediately and the verbal prompts for the
transaction selected are spoken.
Another possible solution is to provide a button which, when pressed, stops the outgoing speech.

Information Regarding 5.2.1.12  Prevention of visually-induced seizures.

Background: 20hz is the peak for photosensitive epilepsy.  Sensitivity is also enhanced by bright flashes and
flashes that occupy large areas of the visual field.

Information Regarding 5.2.1.15  Hearing aid compatibility.

Background: A hearing aid compatible telephone emits magnetic impulses that can be picked up by telecoils
in certain hearing aids.  The hearing aid user activates the telecoil with a switch on the hearing aid.  This
enables the user to maximize the hearing aid's volume without feedback and background noise.

Information Regarding 5.2.1.14  Usable with upper extremity prosthetics.

Background: Having a device that requires body touch to be activated  (e.g. temperature or capacitance
sensitive) creates problems for people using prosthetics.

Solutions: Avoid such designs, by making controls pressure rather than capacitance or heat activated.

Information Regarding 5.2.2.1  Information Pass Through.

Background: Some compression schemes assume there is no data in certain portions of a certain type of
signal.  However, these historically unused signal areas are often used to pass along additional accessibility
information.  For example, some video compression technologies effectively stripped captions from video. 
Some wireless telecommunication devices would not pass TTY signals without unacceptable distortion.

Information Regarding 5.2.2.2  External electronic access to all information and control mechanisms.

Background: Some individuals cannot access traditional input controls and/or output mechanisms.  External
access would permit the accessibility of these devices to these individuals.

Solutions: To provide external access to the full functionality of the device's interface (including controls and
displays) the data interface to the target device and should be in a format that allows the external device to
determine at least the following:

     The name of each component that the user must interact with (e.g. volume control, directions)
     The purpose or role of each component that the user must interact with (e.g. button, rotary dial, text
     region)
     The contents of any text which is part of the interface or displays
     The state of any other display elements or indicators
     The state of each control that the user must interact with (e.g. checked, unchecked, on, off)
     The programmatic command for activating each control action (one control may have more than one
     action)
     The current setting of any adjustable controls that the user must interact with
     The setting range of the adjustable controls that the user must interact with.

The phrase "does not require manipulation of a connector by the user " refers to techniques such as infrared
or RF which allow use by people who cannot operate connectors due to physical or other limitations. 
Accessible control over a wired network also meets the "no connector manipulation required" clause  if
presence at the E&IT is not required simultaneously.

Information Regarding 5.2.2.3  Connection point for external audio processing devices.

Solutions: A standard headphone or headset  jack with standard signal levels would be a solution to this.

Information Regarding 5.2.3  Information, Documentation, Labeling & Support.

Background: Information, Documentation, Labeling & Support should be available to and usable by persons
with disabilities in the same timeframes as it is to users without disabilities.  Documentation should be available
in alternate format to printed text; phone support services available through text telephone support; technician
support will have a working knowledge of the integration of assistive technology into the automated office
electronic systems.
When non-visual labeling is not possible on internal or external components with which the user must interact,
the accessible documentation should contain a detailed verbal description of the layout to identify connectors,
switches, switch settings, etc. by their physical shape, texture or proximity and orientation to recognizable
tactile landmarks.

Information Regarding 5.3.1  If the E&IT has a physical keyboard...

Background: Touchscreens and other keypads that are featureless tactilely, and rely on visual indications of
where to press are impossible for blind people to use without some alternative technique that makes it
possible for blind people to know where to press.  This Section is intended to present the accessibility
requirements for keypads, keyboards and other similar controls.

Solutions: If the device does not have tactile cues then a tactile overlay which provides tactile cues to key
locations can be used.  Voice output can be used to identify keys and other controls.  For touchscreens,
access can be provided via a list of all the items on the screen which can be navigated with voice output by
touching the screen and by using arrow keys.  (See also Information Regarding 5.2.1.1. Usable without
vision.)

Information Regarding 5.3.2  If the E&IT is software in nature and runs on a platform that has a
operating system...

These standards apply to accessibility for operating systems and application software.  This includes software
used as a client for cross-platform  access to an E&IT which is also software in nature and executing on an
operating system different or separate from the client. Typical software includes but is not limited to:
browsers, calendars, banking and financial transaction systems, database management systems, electronic
data interchange, e-mail, external file transfer protocols, group ware, order entry, project management,
scheduling, spread sheet programs, terminal emulation, and word processing.Information Regarding 5.3.2.2 and 5.3.2.3  Visual focus and objects.

Programmers who write software may not have been aware of the effects their design decisions have on the
use of their products by people with disabilities.  As a result, design decisions are often made that make it
difficult or impossible for some people to use that software. One typical problem is caused when the
developer chooses non-standard objects so as to enhance appearance, to provide differentiation, or to
simplify cross-platform development. The problems that these non-standard controls present are primarily in
the inability of screen reading and screen magnifying software to track the active point, the visual focus, on the
display.  As the visual focus changes with keyboard input, the assistive technology won't know that anything
has happened, or it may not be able to tell that anything has happened.

Even such a simple software application as terminal emulation, presenting interaction with the text screen of a
main-frame computer, can be made inaccessible to a blind or visually impaired user when the developer tries
to use a special text cursor which may not be followed (or tracked) by screen reading or screen magnifying
software.

Software development does not have to be reduced to all software using the same set of standard objects.
Instead, different platforms provide their own solutions of accessibility application programming interfaces
(API's) so that programmers can use non-standard controls while providing the accessibility information to the
assistive technology.  The terminal emulation example above is solved when the programmer uses a standard
text cursor,  has the standard text cursor as an option, lets the standard cursor also track the editing point, or
uses an accessibility API to inform the assistive technology of changes in the caret location

The inaccessibility of non-standard controls effects other disabled users than those with visual impairments.
Voice navigation is much more difficult (or impossible) when programs use non-standard controls and do not
employ the accessibility API's.  Similarly for on-screen keyboards.

Information Regarding 5.3.2.1  Keyboard access.

Keyboard access is central for access to software by people with disabilities.  If developers would require
that their applications and systems be fully functional and tested by users without a mouse, a large number
access issues would be resolved for a number of disabilities groups.

Information Regarding 5.3.2.4 and 5.3.2.5  Images and icons.

The first requirement for access to E&IT which is Web-based information says that accessible text shall be
associated with images that provide information.  For a Web page, that text equivalent can be provided with
what is called "alt-text." The same requirement holds for software. If images (i.e. icons) are used to identify
objects or the states of objects, then assistive technologies need to be able to get hold of a text description of
the image. This can be accomplished using an accessibility API or some platform specific standard method
such as text pop-ups.

The text associated with the image must be meaningful.  For example, consider a text equivalent for a
photographic image of the Earth as seen from outer space. If the purpose of the image is mostly that of
decoration, then the text "Photograph of the Earth as seen from outer space" might fulfill the necessary
function. If the purpose of the photograph is to illustrate specific information about world geography, then the
text equivalent should convey that information. If the photograph has been designed to tell the user to select
the image (e.g., by clicking on it) for information about the earth, equivalent text would be "Information about
the Earth". Thus, if the text conveys the same function or purpose for the user with a disability as the image
does for other users, then it can be considered a text equivalent.

Since a screen reader may programmatically identify an image with some text in an operation taken by the
user, if the same icon is used for the same purpose throughout an application, that identification process is
simplified and the application more accessible by a person using a screen reader.

Information Regarding 5.3.2.6  Accessible text.

A screen reader has to be able to speak, using synthesized speech, or display in refreshable Braille, the text
that appears on the display.  The problem is, how does the screen reader know what text is there. For
character based platforms, like DOS, all the text on the screen is available from video memory.  For graphical
systems, it is more difficult.  The screen reader can figure out what text has been written to the display by
"hooking" standard operating system calls and recording that text in a so-called off-screen model.  For
standard controls, the screen reader can query the operating system to know what text is displayed.  Finally
the screen reader may use an application programming interface provided by the software.  Besides knowing
the text, the assistive technology needs to know the text attributes, like color, font and style.

Information Regarding 5.3.2.7 and 5.3.2.8  Colors and fonts.

Software should provide for a wide variety of color and font settings. By being able to choose different
foreground and background colors a large group of people with visual impairments will be able to use
software that would otherwise (with default colors) be inaccessible. Being able to switch to yellow characters
on a green background can make a screen readable for some.  Some platforms provide a high-contrast
setting. Software should support that high contrast setting.  In addition, large character fonts are very useful to
an even larger population. Add a display (view) option that uses large fonts and fonts without serifs.  Do not
require that the larger fonts be those saved with the document or sent to co-worker.

Information Regarding 5.3.2.8  System Startup and shutdown.

System Startup and shutdown are often areas of significant difficulty for people with disabilities, especially
people who depend on assistive technology for access since assistive technology is itself often a software
application which cannot function until sufficient operating system services have initialized.  For instance, the
BIOS and CMOS settings on most PCs are inaccessible.  System and network login and shutdown
procedures are often inaccessible as well.  It is recognized that more than one solution strategy may be
required to provide access to all portions of the startup or shutdown process.

Available solutions may include the following:

     Provide an accessible application to read and modify basic system settings such as BIOS or CMOS
     settings;
     Provide support for industry standard dumb terminal access over an industry standard port to system
     startup messages and command prompts, so that assistive technologies may be used to access the
     more primitive system startup and shutdown routines. Such access can also provide access for
     software and operating system installations;
     Provide rudimentary built-in assistive technologies to support access to basic system initialization and
     shutdown procedures, especially to system login and restart.

Information Regarding 5.3.2.10  Electronic Forms.

Electronic forms should allow the accessibility of each field or element on the form to be at the same
accessible level available to the non-disabled user.  (e.g. capable of reading subtotals, totals, state of check
boxes and radio gangs, etc.)  An Electronic form should maintain its structural integrity as it is accessed by
various adaptive technologies. (Because forms are the most basic medium for transferring information, the
form should be able to maintain its universal appearance for all users to access)  Electronic forms, regardless
of the type of assistive technology being used, should possess the ability to generate comments relative to the
field or form being used. (Forms contain information beyond the entry of "name" or "address" this factual
information should be available)  Navigation through an electronic form should comply with keyboard
standards specified elsewhere in this document. Comparable keystrokes should be available for each mouse
action.  Electronic forms software should be compatible with assistive technology commonly used by persons
with disabilities.

Information Regarding 5.3.3  If the E&IT utilizes Web based information or applications...

Background: Unless access is carefully considered in creating web applications, many people with disabilities
will not have the mandated access to information, documents and forms. For example, if an agency takes a
printed form and places that on the Web as a TIFF image this form will almost certainly be inaccessible as are
most PDF documents that are not created in a very particular way.  If relevant information is only
communicated in a graphic, or only in audio, then entire groups of people with disabilities will be unable to
access that information.

Solutions: Use the W3C Accessibility  Guidelines.  Avoid image-based formats for information including text.

Information Regarding 5.3.4  If the E&IT is Telecommunications products...

Information on TTY Functionality

To provide TTY functionality, a device or system should meet the following description:

     1. It should be interoperable with legacy TTY equipment including support for 45.45 baud Baudot. 
     The solution need not support little-used or obsolete TTY models, but in general should support the
     installed base of TTYs sold over the previous ten years. Compliance with ITU V.18 is one way of
     demonstrating interoperability with legacy TTY equipment.  ITU Recommendation V.18 specifies
     interworking with the following TTY protocols:
         Baudot @ 45.45 baud (U.S. TTYs)
         Baudot @ 50 baud (used in New Zealand, Australia, South Africa and some other countries;
         also known as "international" Baudot)
         V.21/text telephone version (used in Sweden, Norway, and Finland).
         DTMF (used in Denmark, Holland, and some other countries)
         EDT ("European Deaf Telephone," used in Germany, Austria, Switzerland, and several other
         countries)
     2. The transmission rate should be no slower than the defacto Baudot rate of 45.45 baud.
     3. The character error rate should be under 1%.
     4. The caller should be able to visually monitor all aspects of call progress (ring, busy, answered-in-
     voice, etc.) that is provided in auditory form.
     5. There should also be a provision for non-auditory alerting.  [Built in or via connection]  A portable
     vibrating device or built-in vibrator may be used to provide ring signaling on a wireless or cordless
     phone. If an RJ-11 connection is used to provide non-auditory alerting connection,  then a minimum
     ring equivalent of 2 should be provided.
     6. The caller should be able to transmit TTY signals independent of the condition of the receiving
     modem.  (This allows the TTY user to signal to the answering party or TTY detector circuitry that the
     call is in TTY mode.)
     7. VCO (Voice Carry Over) and HCO (Hearing Carry Over) should be supported.
     8. It should provide an alphanumeric keyboard with one key for each letter of the alphabet.

Products which are themselves TTYs or provide full TTY Functionality do not need to make provision for
TTY connector.

Information Regarding 5.3.5  If the E&IT utilizes Multimedia...

In addressing presentation issues for multimedia, we use a broad definition: video, audio, animation, graphics
and text combined in numerous ways and delivered via a variety of platforms: video and audiotape, CD- and
DVD-ROM, Internet-based, broadcast, narrowcast, and satellite-delivered.

The multimedia standards is also focused as narrowly as possible on CONTENT issues and not command
and control of the delivery device, which are covered in other areas.  When a piece of media contains audio
information essential to understanding its content, the media should also be capable of creating a user-
selectable visual display in text format of that audio.  The types of audio that should have an alternate text
presentation include narration, dialog, speech and vocal music and essential non-speech sounds such as sound
effects needed for comprehension of content and identification of speakers and sound sources.  Examples of
audio NOT requiring alternate text presentation include incidental background music and ambient sounds
unimportant to understanding of the content.

In the case of audio tracks provided as part of software-based multimedia, interactive or otherwise, alternate
text presentation may be achieved through the use of various multimedia authoring tools (such as Adobe
premiere or Macromedia Director) or may employ such formats as the W3C's Synchronized Media
Interchange Language (SMIL) or Microsoft's Synchronized Accessible Multimedia Interchange format
(SAMI).  Regardless of authoring technology, the following guidelines will enhance comprehension via
alternate text presentation:

     text should be user-selectable
     text should be displayed on the screen or other display device in a manner so as not to obscure other
     essential on-screen information
     text should be clearly legible and distinguishable from background visuals o  text should be fully
     synchronized with the audio it is reflecting
     if the media is being presented in a computer operating system that offers a "ShowSounds" preference
     (such as Microsoft Windows), the alternate text presentation should automatically be displayed if the
     user selects this preference.
     triggering display of alternate text presentation should not automatically mute the audio portion of the
     program
     the user should be able to disable or adjust sound volume

Information Regarding 5.3.6  If the E&IT is an Information Transaction Machine (ITM)...

The ITM should provide a way to receive and transmit information to an external device.  The protocol, or
combined protocols, used to convey a UIs content and support interaction with an ITM by an external device
should be based on industry accepted and community developed standards. For example, a handset may be
used to transmit UI information and short range RF or directional IR could be used to transmit UI information
to and support interaction by an external device.  See Information Regarding 5.2.2.2 above.  NOTE: For
other approaches and examples see http://www.access-board.gov/xxx/yyy/exampleslist.html.6.5  Prototype Disability Access Compliance Form.

The following is an example of one way that procurement officers could request information on the
accessibility features of E&IT products being submitted under bid.

Disability Access Compliance Form (Instructions)

This form is provided as a means of summarizing a product's accessibility. It should be completed and
submitted with the bid package.  The form is to be completed based on an analysis of operational chains for
each product. This is done by performing the following analysis:

     A list of all operations required to operate the product is made.  Care should be taken to include the
     activities required to learn how to operate the product and provide regular maintenance.

     For each operation construct operational chains of the steps required to perform each operation.

     Analyze each operational chain for each of the areas of limitation.

     If in a given category all of the operational steps can be accomplished then the product may be listed
     as accessible for that category. If it is not then the box should not be checked.

Illustration

For a desktop business telephone a list of operations is made. A list of steps is then made for each of these
operations.  As one example, if the user documentation can be accessed by someone without vision then that
operation is accessible.  As another example, to make a call the phone must be taken off hook, the dialtone
sensed, the number dialed, the call conducted, the call terminated and the phone placed back on-hook. For
the no vision category, if all of these steps can be accomplished without vision then that operation is
accessible.  If not all operations are accessible without vision then the Partially Accessible box should be
checked and details provided. The process then repeats itself for the other categories listed.

A claim of new or superior accessibility should only be made if the product offers something unique or
demonstrably superior for a given class of accessibility, as compared to what is generally available in
comparable product offerings on the market. Details and supporting evidence may be provided to amplify
such claims.  If industry standards that apply to the product type and can be used to objectively substantiate
the claim of accessibility exist,  these should be cited and used as the basis for the claim. Where they exist, the
use of industry standards, which provide an objective basis for making a claim of accessibility, is preferred.

Prototype/Example Disability Access Compliance Form

This form is designed to summarize the 508 compliance of a product or contract offering.  The contractor
should complete the form and present it with the bid package. Additional information on access features that
are believed to be new or exemplary may be attached. Supporting documentation for the items summarized
on this form should not be submitted with the form, but made available, if requested by the contracting officer.

     1.  Name and Model of product:

     2.  Features and functions of the product:

     3.  Describe any new or special accessibility features of this product:

     4.  For each area below, state whether all of this product's FUNCTIONS (as described above)
     are accessible or if it is partially accessible.  Provide any notes applicable to each area in the space
     provided to the right of the area checkboxes.

     No Vision
         [checkbox]    Entire functionality is accessible.
         [checkbox]    Partial functionality is accessible. (specify)
     
     Low Vision (no audio)
         [checkbox]    Entire functionality is accessible.
         [checkbox]    Partial functionality is accessible. (specify)
     
     No Color Vision
         [checkbox]    Entire functionality is accessible.
         [checkbox]    Partial functionality is accessible. (specify)

     No Hearing
         [checkbox]    Entire functionality is accessible.
         [checkbox]    Partial functionality is accessible. (specify)
     
     Hard of Hearing
         [checkbox]    Entire functionality is accessible.
         [checkbox]    Partial functionality is accessible. (specify)

     Limited Manual Dexterity, Reach or Strength
         [checkbox]    Entire functionality is accessible.
         [checkbox]    Partial functionality is accessible. (specify)     No Time Dependence
         [checkbox]    Entire functionality is accessible.
         [checkbox]    Partial functionality is accessible. (specify)

     No Speech
         [checkbox]    Entire functionality is accessible.
         [checkbox]    Partial functionality is accessible. (specify)

     Cognitive and Learning
         [checkbox]    Entire functionality is accessible.
         [checkbox]    Partial functionality is accessible. (specify)

     No Specific Biometrics Required
         [checkbox]    Entire functionality is accessible.
         [checkbox]    Partial functionality is accessible. (specify)

     Minimizes Seizure Induction
         [checkbox]    Entire functionality is accessible.
         [checkbox]    Partial functionality is accessible. (specify)

     Compatibility
         [checkbox]    Product is compatible with hearing aids.
         [checkbox]    Product is not held up to the ear for listening or it provides hearing aid coupling.
         [checkbox]    Product is compatible with upper limb prosthetics.
         [checkbox]    Product is compatible with wheelchair use.
         [checkbox]    Accessibility Information Pass Through is provided.
         [checkbox]    Standard external electronic access is provided for all info and control.
         [checkbox]    Standard audio connection point standard is met.

     Other
         [checkbox]    If access features provide speech output - private listening is available.
         [checkbox]    Product meets Documentation, Labeling and Support Standards.
     
     Technology specific standards
         [checkbox]    Product meets technology specific standards for Physical Keyboards.
         [checkbox]    Product meets technology specific standards for Cabling and connections.
         [checkbox]    Product meets technology specific standards for Software.
         [checkbox]    Product meets technology specific standards for Web Based Applications.
         [checkbox]    Product meets technology specific standards for Telecommunications.
         [checkbox]    Product meets technology specific standards for Multimedia.
         [checkbox]    Product meets technology specific standards for ITMs.
         [checkbox]    Product meets technology specific standards for PDAs / Thin Clients.

5.   Describe the processes and procedures used to verify the information above: