National Council on Disability

October 28, 2004

Design for Inclusion:

Creating a New

Marketplace
National Council on Disability 

1331 F Street, NW, Suite 850 

Washington, DC 20004 

Design for Inclusion: Creating a New Marketplace 

This report is also available in alternative formats and on NCD’s award-winning Web site 

(www.ncd.gov). 

Publication date: October 28, 2004 

202-272-2004 Voice 

202-272-2074 TTY 

202-272-2022 Fax 

Note: The views contained in this report do not necessarily represent those of the 

Administration, as this and all NCD documents are not subject to the A-19 Executive 

Branch review process. 

Reference herein to any specific commercial product, process, or service by trade name, 

trademark, manufacturer, or otherwise does not constitute or imply its endorsement by the 

National Council on Disability. 
1331 F Street, NW ■ Suite 850 ■ Washington, DC 20004

202-272-2004 Voice ■ 202-272-2074 TTY ■ 202-272-2022 Fax ■ www.ncd.gov

NATIONAL COUNCIL ON DISABILITY

An independent federal agency working with the President and Congress to increase the

inclusion, independence, and empowerment of all Americans with disabilities.

October 28, 2004

The President

The White House

Washington, D.C. 20500

Dear Mr. President:

On behalf of the National Council on Disability (NCD), I am submitting a report entitled, Design for

Inclusion: Creating a New Marketplace. This report aims to educate designers and manufacturers about

the way electronic and information technology (E&IT) intersects with the needs of individuals with

disabilities, and how designing with access in mind can significantly increase the size of targeted markets

for E&IT.

Designing with access in mind can be accomplished through Universal design. Universal design is a

process to ensure that electronic and information technology is inclusive, accessible, and usable by

everyone, including people with disabilities. Incorporating universal design processes when developing

E&IT is one solution to accommodating people with disabilities that also improves the usability of the

products for the rest of the population. NCD’s research attempts to understand the market for universally

designed mainstream consumer products and services, document successful universal design development

processes, understand consumer needs, understand universal design facilitators and barriers, and identify

and address current issues in universal design.

This research falls at a time when understanding and incorporating universal design into the development

process are most crucial. We are in the window of opportunity for implementing Section 508 of the

Rehabilitation Act of 1973 (as amended). Section 508 requires the Federal Government to purchase

accessibly designed E&IT. If progress is not made quickly in improving the skills of government and

industry employees on accessibility issues, the window will soon shut with little having been

accomplished.

Progress must be made now, and the purpose of this report is to present the information and

recommendations that will guide this progress.

Sincerely,

Lex Frieden

Chairperson

(The same letter of transmittal was sent to the President Pro Tempore of the U.S. Senate and the

Speaker of the U.S. House of Representatives.)

1
2 
3 

National Council on Disability Members and Staff 

Members 

Lex Frieden, Chairperson, Texas 

Patricia Pound, First Vice Chairperson, Texas 

Glenn Anderson, Ph.D., Second Vice Chairperson, Arkansas 

Milton Aponte, J.D., Florida 

Robert R. Davila, Ph.D., New York 

Barbara Gillcrist, New Mexico 

Graham Hill, Virginia 

Joel I. Kahn, Ph.D., Ohio 

Young Woo Kang, Ph.D., Indiana 

Kathleen Martinez, California 

Carol Novak, Florida 

Anne M. Rader, New York 

Marco Rodriguez, California 

David Wenzel, Pennsylvania 

Linda Wetters, Ohio 

Staff 

Ethel D. Briggs, Executive Director 

Jeffrey T. Rosen, General Counsel and Director of Policy 

Mark S. Quigley, Director of Communications 

Allan W. Holland, Chief Financial Officer 

Julie Carroll, Attorney Advisor 

Joan M. Durocher, Attorney Advisor 

Martin Gould, Ed.D., Senior Research Specialist 

Geraldine Drake Hawkins, Ph.D., Program Analyst 

Pamela O’Leary, Interpreter 

Brenda Bratton, Executive Assistant 

Stacey S. Brown, Staff Assistant 

Carla Nelson, Office Automation Clerk 
4 
5 

Dedication 

This National Council on Disability report is dedicated to Ronald Mace, “a nationally and 

internationally recognized architect, product designer, and educator whose design philosophy 

challenged convention and provided a design foundation for a more usable world. He coined 

the term ‘universal design’ to describe the concept of designing all products and the built 

environment to be aesthetic and usable to the greatest extent possible by everyone, regardless 

of their age, ability, or status in life” (Center for Universal Design). 
6 
7 

Acknowledgments 

The National Council on Disability (NCD) wishes to express its appreciation to W. Bradley Fain 

of Georgia Tech Research Institute (GTRI), who was the principal investigator for this project. 

Researchers in GTRI’s Electronic Systems Laboratory performed the work documented in this 

report. NCD acknowledges the contributions of Steve Jacobs of the Ideal Group, who performed 

the market definition and research for this report. NCD also acknowledges the participation of 

the industry partners that supported the industry study portion of this research. The industry 

partners provided invaluable insight into the impact of section 508 on business and the barriers 

and facilitators relating to the adoption of universal design principles. NCD also acknowledges 

the donation of equipment and services utilized during the user study portion of the research. The 

following companies provided products and services, at no cost to the project, for user testing: 

HP, Nokia, and SENCORE Electronic Test Equipment. 

NCD would also like to acknowledge the efforts of Gerry Field, WGBH Boston, for providing 

the closed-captioned test stream used in user testing. 
8 
9 

Contents 

Executive Summary ...................................................................................................................... 13 

Important Findings and Recommendations ............................................................... 14 

I. Introduction................................................................................................................................ 21 

Definition of Universal Design.................................................................................. 23 

Role of Assistive Technology in Universal Design................................................... 28 

Research Process........................................................................................................ 35 

II. Market Definition and Research ............................................................................................... 37 

Definition of the Market Environment ...................................................................... 38 

Market Forces......................................................................................... 39 

Local Environment ................................................................................. 44 

Human Condition ................................................................................... 45 

Legal Framework.................................................................................... 49 

Standards and Guidelines ....................................................................... 60 

Customer Analysis..................................................................................................... 63 

People with Disabilities.......................................................................... 63 

Other Customer Markets ........................................................................ 65 

Analysis of Market Trends......................................................................................... 66 

Cell Phones............................................................................................. 66 

ATM Machines....................................................................................... 70 

Personal Digital Assistants..................................................................... 72 

Televisions.............................................................................................. 75 

Voice Recognition.................................................................................. 78 

Distance Learning................................................................................... 81 

III. Product Analysis...................................................................................................................... 87 

Product Line Assessment Methodology .................................................................... 89 
10 

Product Line Assessments ......................................................................................... 90 

ATM Machines....................................................................................... 90 

Cell Phones........................................................................................... 102 

Distance Learning Software ................................................................. 121 

Personal Digital Assistants................................................................... 136 

Televisions............................................................................................ 150 

Voice Recognition Software................................................................. 165 

IV. Industry Study ....................................................................................................................... 173 

Analysis of Facilitators and Barriers to Accessible Design..................................... 174 

Design Facilitators................................................................................ 174 

Organizational Facilitators ................................................................... 176 

Informational Facilitators ..................................................................... 177 

Financial Facilitators ............................................................................ 178 

Legal Facilitators .................................................................................. 178 

Design Barriers..................................................................................... 180 

Organizational Barriers ........................................................................ 181 

Informational Barriers .......................................................................... 182 

Financial Barriers ................................................................................. 182 

Legal Barriers ....................................................................................... 183 

Industry Study Data Collection Methodology ......................................................... 183 

Analysis of Industry Data: Factors Influencing Adoption of UD Practices............. 185 

Business Case....................................................................................... 185 

Strategy/Policy...................................................................................... 188 

Resource Allocation/Funding............................................................... 188 

Organization/Staff ................................................................................ 189 

Training/Awareness.............................................................................. 191 

Research ............................................................................................... 192 
11 

Design................................................................................................... 193 

Testing.................................................................................................. 196 

Demand/Legislation ............................................................................. 197 

Marketing/Sales.................................................................................... 198 

Customers/People with Disabilities ..................................................... 199 

Analysis of the Industry Study Findings.................................................................. 200 

V. Discussion .............................................................................................................................. 219 

A Sizable Market Exists for Universally Designed Products and Services............. 220 

Universal Design Principles Can Be Easily Incorporated into Current Design 

Practices................................................................................................................... 222

Products Designed To Be Accessible Sometimes Do Not Meet the Needs 

of Users.................................................................................................................... 224

Legislation Is Currently Both a Facilitator and a Barrier to Universal Design........ 226 

Government, Industry, and Consumers Have Important Roles To Play in 

Promoting Universal Design.................................................................................... 228 

Industry and Consumers Would Benefit from Better Industry Coordination 

with AT Vendors ..................................................................................................... 231 

VI. Conclusions........................................................................................................................... 235 

Analysis of Purchase Decisions for Accessible Products ........................................ 236 

Comparison of Strategies To Promote Universal Design and Strategies 

To Promote Safety ................................................................................................... 241 

Analysis of the Market for Universally Designed Products and Services ............... 244 

Analysis of the Impact of Section 508..................................................................... 245 

Analysis of Industry Practices.................................................................................. 248 

Analysis of Consumers of Universally Designed Products and Services ................ 251 

List of Acronyms and Abbreviations .......................................................................................... 255

Bibliography................................................................................................................................ 259 

Appendix ..................................................................................................................................... 275 
12 

List of Tables 

Table 1. Accessibility Grades for Each Target Population for the Six Product Lines .............. 171 

Table 2. Comparison Between Promotion of Consumer Product Safety and Accessibility...... 243 
13 

Executive Summary 

Designing with access in mind can significantly increase the size of targeted markets for 

electronic and information technology (E&IT). Good business practice dictates that designers and 

engineers avoid unintentionally excluding large populations of consumers from accessing and 

using the E&IT they develop and manufacture. People with disabilities are at the highest risk of 

exclusion. Other consumer groups are also at risk. They are— 

• Individuals 65+ years old 

• Consumers living in low-bandwidth information infrastructures 

• People who never learned to read 

• Users of English as a Second Language (ESL) 

• Tourists and people living in multilingual societies 

• Consumers living in high-density populations 

Designing with access in mind can be accomplished through universal design (UD). Universal 

design is a process to ensure that E&IT is inclusive, accessible, and usable by everyone, 

including people with disabilities. Accessible design is a step forward when developing E&IT 

products, but it tends to lead to technologies that will be used separately, or in addition to, the 

main E&IT product, which diminishes the effectiveness of designing for all. Incorporating UD 

processes when developing E&IT is one solution to accommodating people with disabilities that 

also improves the usability of the products for the rest of the population. 

The National Council on Disability (NCD) undertook this research to understand the market for 

universally designed mainstream consumer products and services, document successful UD 

development processes, understand consumer needs, understand UD facilitators and barriers, and 

identify and address current issues in universal design. This research comes at a time when 

understanding and incorporating UD into the development process are most crucial. We are in the 

window of opportunity for implementing section 508. If progress is not made quickly in improving 
14 

the skills of government and industry employees on accessibility issues, the window will soon shut 

with little having been accomplished. If industry does not see that federal agencies are serious about 

implementing section 508 in a consistent manner, companies will shift the monetary and human 

resources needed for improving accessibility to product development opportunities that offer a 

higher return on investment. Progress must be made now, and the purpose of this report is to 

present the information and recommendations that will guide this progress. 

Through this research, NCD aims to educate designers and manufacturers about how electronic 

and information technology intersects with the needs of individuals with disabilities. In addition 

to providing knowledge about disabilities, we see the importance here and now of educating 

individuals on universal design. Currently, many business people have never heard of UD, and 

many of those who have do not understand that it is more than just a design for disability. This 

research aims to provide businesses with the knowledge of UD methods they need to clearly see 

how their complex products can be made accessible in a cost-effective way. 

As part of this research, six product lines were analyzed from the telecommunications, software, 

consumer electronics, and digital services industries for both accessibility and usability. We 

estimated how useful these products are to people with disabilities and whether the products 

conformed to section 508 standards and section 255 guidelines. We were able to present 

recommendations for improving such products. At a time when the incorporation of universal 

design is crucial, NCD hopes that the information provided in this report will motivate and drive 

the development of more universally, accessibly designed E&IT. 

Important Findings and Recommendations 

User Study. The purpose of the user study was to document and understand user experiences with 

the six product lines under study. The experiences and thoughts of the consumer with a disability 

provided important insight into the future design of accessible products and can potentially 

influence the universal design process. The key findings of the user study are as follows: 
15 

• Users with disabilities are often asked to pay high prices for phones with feature sets that 

are not useful to them. 

• Rapid changes in technology often cause decreases in accessibility. 

• Users are reluctant to adopt technologies that have proven frustrating in the past. 

• Users have difficulty finding devices that match their functional capabilities because of the 

lack of familiarity sales associates have with accessibility features. 

• Users are reluctant to invest in technologies that have an unproven accessibility record. 

• Accessibility solutions must consider the needs of the individual with disabilities. 

Substantial increases in accessibility will be required before increased sales to members of the 

disability community are realized. 

Product Analysis. A detailed product line analysis was conducted for each of the product lines 

selected for study. The purpose of this research was to document accessibility issues that prevent 

people with disabilities from fully accessing the selected products and to document accessibility 

features that either are currently offered or could be offered by manufacturers. The end result of 

this product analysis was the assignment of an accessibility grade to each product line for each 

disability group. These grades may be useful to designers and manufacturers to identify the target 

populations that should be consulted during the design process so that more accessible design 

features are incorporated into new products. 

Industry Study. The purpose of the industry study was to document UD practices within 

industries represented by the six product lines selected for study. Five categories of facilitators 

and barriers to accessible design were examined: design, organizational, informational, financial, 

and legal. A discussion of these barriers and facilitators as experienced by the six companies is 

included in this section.

In addition, 11 business concerns were identified as having an influence on UD practices within 

an organization. Each business concern had a different level of influence, depending on the 
16 

strength of the other factors. The factors influencing the adoption of UD practices included the 

business case, strategy and policy, demand and legislation, marketing and sales, research, design, 

testing, resource allocation and funding, organization and staff, training, and the customer and 

consideration of people with disabilities. 

All the companies that participated in the industry study have made strategic decisions to address 

the accessibility of their products and services. A few of the companies had long-standing 

accessibility programs that were reinvigorated by the technical requirements of section 508. 

Other companies initiated their accessibility activities while planning for their response to section 

508. In both cases, section 508 clearly has had an impact on the way accessibility and UD are 

being addressed by industry. The industry study found that the most common approaches to 

addressing accessibility issues are— 

• Increasing awareness of employees 

• Integrating accessibility requirements into the design process 

• Performing accessibility verification testing 

• Establishing an accessibility program office 

Discussion. Through this research, we have come to better understand the market for universally 

designed mainstream consumer products and services, documented successful universal design 

development processes, achieved a better understanding of consumer needs, analyzed UD 

facilitators and barriers, and identified and addressed current issues in universal design. This 

research program has found that— 

• A market for universally designed products and services exists. 

• UD principles can be easily incorporated into current design practices. 

• Products designed to be accessible sometimes do not meet the needs of users. 

• Legislation is currently both a facilitator and a barrier to UD. 
17 

• Many barriers to UD remain and must be addressed before significant progress can be made. 

Several important recommendations can be made from this research for designers, developers, federal 

agencies, and companies striving to incorporate universal design into their development process: 

Strategies for Government and Industry to Promote Universal Design 

Recommendation #1. Use standards (government or industry) to prohibit 

nonessential features that pose accessibility problems unless an alternative 

interface that solves the problem is provided. 

Recommendation #2. Use standards (government or industry) to eliminate 

interoperability problems that create accessibility problems. 

Recommendation #3. Use market forces to regulate features that pose 

intermediate levels of accessibility problems. Require labeling and other 

information to be provided, and allow recourse through tort (warranty) as well as 

through general demand, as reflected in consumer purchases. 

Recommendation #4. Develop training materials and educational articles 

documenting the market potential for UD products and services. 

Strengthening the Impact of Section 508 

Section 508 was developed to govern the purchase of accessible electronic and information 

technology purchased by the Federal government. Despite having been in place for nearly three 

years, section 508 has yet to reach its potential. One of the greatest shortfalls of Section 508 is 

the lack of understanding of and attention to the functional performance requirements. 

Recommendation #5. Institute procedures designed to ensure that due diligence is 

given to section 508 procurement requirements. Perform an internal analysis of the 

impact of section 508 on the procurement of actual products. Publish the results of 
18 

the analysis as a way of convincing industry that the Federal Government is 

committed to section 508. 

Recommendation #6. Consider requesting supporting evidence for claims made 

on voluntary product accessibility templates (VPATs) from all vendors responding 

to bid proposals. 

Recommendation #7. Develop a quick accessibility checklist for specific product 

lines likely to be procured by the Federal Government. The quick accessibility 

checklist would assist procurement officials in market research by providing them 

with a list of items that they can inspect themselves when procuring products. The 

checklist would be tailored to specific product lines and would not require detailed 

expertise to evaluate. 

Recommendation #8. Develop guidance for reporting conformance with 

functional performance criteria guidelines. 

Recommendation #9. Support the coordination of state and local government 

adoption of section 508 technical requirements. Provide state and local 

governments with documents and training programs designed to ensure unification 

of technical requirements. 

Recommendation #10. Study and document the nontechnical aspects of 

accessibility, including social, psychological, and organizational accessibility. 

Promote UD solutions that consider all aspects of accessibility. 

Promoting the Inclusion of Universal Design in Industry Practices 

Companies are not aware of the design process modifications needed to incorporate universal 

design principles. The Federal Government should support the refinement of specific design 

process interventions that can easily be incorporated. 
19 

Recommendation #11. Develop, test, and disseminate methodologies for 

integrating UD into existing design practices. 

Recommendation #12. Support the development of university-level training 

materials that could be incorporated into the curriculums of existing designoriented degree programs. The training materials should include awarenessexpanding videos and other teaching resources that illustrate the potential impact 

of key design process interventions on the lives of people with disabilities and 

other beneficiaries of UD. 

Recommendation #13. Develop, test, and disseminate design reference users to 

illustrate the range of functional capabilities and limitations typical among people 

with disabilities. Design reference users (popular in specifying the target 

population in Department of Defense acquisitions) is a set of descriptions of 

prototypical users who, taken together, express the range of functional capabilities 

and limitations of the population that must be accommodated by the design project. 

The use of design reference users would greatly simplify the need for designers to 

research and integrate information pertaining to the functional limitations and 

capabilities of people with disabilities. 

Recommendation #14. Develop a standard methodology for testing accessibility 

and comparing the accessibility of similar products. 

Recommendation #15. Coordinate with industry to promote the integration of 

accessibility concepts, principles, and guidelines into the development tools used 

by designers to develop products. 
20 

Creating a New Marketplace 

Consumers with disabilities find many E&IT products to be inaccessible. A sizeable un-tapped 

market for universal design products and services exists. However, few companies appreciate 

the size of the market or know how to tap its potential. 

Recommendation #16. Develop an information clearinghouse where users can 

obtain information about accessibility issues and the features designed to address 

the issues for specific product lines. Educate consumers on how to shop for UD 

products and services. List vendor resources where consumers can obtain more 

information about UD products. 

Recommendation #17. Develop marketing strategies and approaches that will 

facilitate a connection with people with disabilities. 

Recommendation #18. Train people with disabilities to become subject-matter experts 

for the purpose of participating in design focus groups and accessibility evaluations. 

Recommendation #19. Create job-related outcomes for bulk purchasers for the 

successful procurement of products and services with UD features. 

Conclusions 

People with disabilities want to use the same products that everyone else uses. They do not want 

to be limited to specialized products that are more costly. Implementation of UD is the best way 

to satisfy this desire of people with disabilities, while also providing more cost-effective products 

for all users. While it is impossible to satisfy the needs of all users, products and services that 

come closer to accommodating a variety of physical and cognitive differences will benefit both 

users and companies. 
21 

I. Introduction 

The explosive development of information technology is rapidly changing the way we work, 

shop, communicate, and play. In the 19th and early 20th centuries, our grandparents saw America 

change from an agrarian society to an industrial one. We are now in the middle of a second 

transformation, from an industrial society to an information society, sparked by the development 

of information science, microprocessors, and wireless technology. Information technology and 

telecommunications are now relied upon for routine daily activities that contribute to overall 

quality of life, such as making doctor’s appointments, obtaining directions, and purchasing goods 

and services. Companies are increasingly expanding their presence into emerging markets. As the 

National Council on Disability (NCD) points out, “Companies are serving populations they have 

never before served” (NCD, 2002). 

Every consumer is different. No two people have the exact same set of learning styles, abilities, 

experiences, and educational background. What used to be one market of billions of consumers is 

evolving into billions of markets of one consumer, as computer technology makes it economical 

for products to be customized to meet the user’s needs. This marketing shift is a dramatic change 

from a few short years ago. To remain competitive, companies must learn to develop products 

that accommodate the wants, needs, and preferences of as many individual consumers as is 

technically possible and economically feasible. 

Designing with access in mind can significantly increase the size of targeted markets for 

electronic and information technology (E&IT). Good business practice dictates that designers and 

engineers avoid unintentionally excluding large populations of consumers from accessing and 

using the E&IT they develop and manufacture. People with disabilities are at a high risk of 

exclusion. Other consumer groups are also at risk. They are— 

• Individuals 65+ years old 

• Consumers living in low-bandwidth information infrastructures 

• People who never learned to read 
22 

• Users of English as a Second Language (ESL) 

• Tourists and people living in multilingual societies 

• Consumers living in high-density populations 

Universal design (UD) has been proposed as a means to meet needs of consumers, including 

those with special needs, while maximizing a company’s potential to develop a marketable, easyto-use product. The purpose of this research program is to understand the market for universally 

designed mainstream consumer products and services, document successful UD development 

processes, understand consumer needs, understand UD facilitators and barriers, and identify and 

address current issues in universal design. 

The future of design for inclusion is in jeopardy. We are in the window of opportunity for 

implementing section 508. If progress is not made quickly in improving the skills of government 

and industry employees on accessibility issues, the window will soon shut with little having been 

accomplished. If industry does not see that federal agencies are serious about implementing 

section 508 in a consistent manner, companies will shift the monetary and human resources 

needed for improving accessibility to product development opportunities that offer a higher 

return on investment. Progress must be made now, and the purpose of this report is to present the 

information and recommendations that will guide this progress. 

Through this research, NCD aims to educate designers and manufacturers about how electronic 

and information technology intersects with the needs of individuals with disabilities. In addition 

to providing knowledge about disabilities, we see the importance here and now of educating 

individuals on universal design. Currently, many people business people have never heard of UD, 

and many of those who have do not understand that it is more than just a design for disability. 

This research aims to provide businesses with the knowledge of UD methods they need to clearly 

see how their complex products can be made accessible in a cost-effective way. 
23 

This study examined the philosophical, economic, and technological rationales that currently 

drive the development of UD and identified specific barriers to increased implementation, while 

also addressing commonly held assumptions about universal design. Six product lines were 

analyzed from the telecommunications, software, consumer electronics, and digital services 

industries for both accessibility and usability. We estimated how useful these products are to 

individuals with disabilities and whether the products conform to section 508 requirements and 

section 255 guidelines. In doing so, we were able to present recommendations for improving 

such products. This report aims to aid industry in adopting UD practices by using the information 

obtained on current industry practices, barriers, and facilitation factors to investigate methods for 

motivating companies to incorporate UD methods in product development. 

At a time when the incorporation of universal design is crucial, NCD hopes that the information 

provided in this report will motivate and drive the design for more universally designed E&IT. 

Definition of Universal Design 

Universal design, or design for inclusion, is a process to ensure that E&IT is inclusive, 

accessible, and usable by everyone, including people with disabilities. Accessible design is a step 

forward when developing E&IT products, but it tends to lead to technologies that will be used 

separately, or in addition to, the main E&IT product, which diminishes the effectiveness of 

designing for all. Incorporating UD processes when developing E&IT is one solution to 

accommodating people with disabilities that also improves the usability of the products for the 

rest of the population. 

The above definition encapsulates what it means to design with universal access in mind. UD has 

been referred to as many things and has been defined in many ways and with many perspectives. 

Despite the differences in interpretation and definition, one thread that ties the perspectives 

together is that all people, young and old, with and without disabilities, can have access to the 

same opportunities. Some alternative terms that have been used to refer to UD are inclusive 

design, design for inclusion, lifespan design, transgenerational design, barrier-free design, 
24 

design-for-all, and accessibility. The first four terms have their roots in accomplishing social 

inclusion, the next two have their roots in design of the built environment, and the last is linked 

to legislated requirements for accommodation (Ostroff, 2001). 

The term universal design was originally coined in the 1970s by Ronald Mace. 

Ron Mace was a nationally and internationally recognized architect, product 

designer, and educator whose design philosophy challenged convention and 

provided a design foundation for a more usable world. He coined the term 

“universal design” to describe the concept of designing all products and the built 

environment to be aesthetic and usable to the greatest extent possible by everyone, 

regardless of their age, ability, or status in life (Center for Universal Design, n.d.). 

Other characteristics of UD are summarized, in part, from interviews with visionaries regarding 

accessibility and UD (Fain et al., 2001). The visionaries talked about including a wide range of 

individuals in all stages of the design process; integrating accessible features so they don’t stand 

out (resulting in social integration); and creating things so that they can be made available “out of 

the box,” enabling as many people as possible to use them. It is considered a design methodology 

and an extension of the user-centered design process. Additional variations include the 

following: 

...[T]he practice of designing products or environments that can be effectively and 

efficiently used by people with a wide range of abilities operating in a wide range 

of situations (Vanderheiden, 1997, p. 2014). 

...[B]uilding products that are robust and accommodating. Universal designs take 

account of differences in sight, hearing, mobility, speech, and cognition. Universal 

design helps not only people with disabilities, but also any of us when we’re tired, 

busy, or juggling many tasks (Francik, 1996). 

...[T]he design of products and environments to be usable by all people, to the 

greatest extent possible, without the need for adaptation or specialized design. The 

intent of universal design is to simplify life for everyone by making products, 

communications, and the built environment more usable by as many people as 

possible at little or no extra cost. Universal design benefits people of all ages and 

abilities (Center for Universal Design, n.d.). 
25 

A much greater awareness of disabilities has evolved in the last century, in part as a result of a 

significant increase in the human lifespan. The general population has had greater exposure to 

human limitation as the people around them have aged and developed limitations, while at the 

same time living outside institutions and becoming more independent. This exposure has 

increased awareness of limitations that can impede the average individual and has led to design 

changes in products to help overcome these limitations. Initially, these design changes were 

implemented as special features that added to the cost and stood out as features for people with 

special needs. Over time, designers began to recognize that many design changes could be made 

on a larger scale, reducing the cost and benefiting a larger portion of the population (Center for 

Universal Design, n.d.). Research led to the formulation of design principles that describe the 

objectives of UD. 

In 1997, North Carolina State University’s Center for Universal Design documented and 

published seven Principles of Universal Design (1997): 

• Equitable Use: The design is useful and marketable to people with diverse abilities. 

• Flexibility in Use: The design accommodates a wide range of individual preferences and 

abilities. 

• Simple and Intuitive Use: Use of the design is easy to understand, regardless of the user’s 

experience, knowledge, language skills, or current concentration level. 

• Perceptible Information: The design communicates necessary information effectively to 

the user, regardless of ambient conditions or the user’s sensory abilities. 

• Tolerance for Error: The design minimizes hazards and the adverse consequences of 

accidental or unintended actions. 

• Low Physical Effort: The design can be used efficiently and comfortably and with a 

minimum of fatigue. 
26 

• Size and Space for Approach and Use: Appropriate size and space are provided for 

approach, reach, manipulation, and use, regardless of the user’s body size, posture, or 

mobility. 

These principles serve as guidelines for the designers of accessible products. If these principles 

are incorporated into and considered during the design process, the result will be products that 

are accessible to a wide range of users. In addition to principles such as the ones mentioned 

above, standards have been and will continue to be developed that serve as guidelines for 

designers and manufacturers. These standards mandate that products, services, or places are 

accessible to particular groups of people and provide requirements that must be met. Universal 

designers must incorporate these principles and standards and use them for guidance when 

developing products and services to be accessible to the wide population. 

The definition of UD must address the population it is intended to benefit. Consideration must be 

given to various disability groups—blind, low vision, deaf, limited hearing, limited manual 

dexterity, limited cognition, and lack of reading ability—keeping in mind that these limitations 

may result from situational constraints rather than a formally defined disability, as defined below: 

OPERABLE WITHOUT VISION = is required by people who are blind – and – 

people whose eyes are busy (e.g., driving your car or phone browsing) or who are 

in darkness. 

OPERABLE WITH LOW VISION = is required by people with visual impairment

– and – people using a small display or in a smoky environment. 

OPERABLE WITH NO HEARING = is required by people who are deaf – and – 

by people in very loud environments or whose ears are busy or are in forced 

silence (library or meeting). 
27 

OPERABLE WITH LIMITED HEARING = is required by people who are hard of 

hearing – and – people in noisy environments. 

OPERABLE WITH LIMITED MANUAL DEXTERITY = is required by people 

with a physical disability – and – people in a space suit or chemical suit or who 

are in a bouncing vehicle.

OPERABLE WITH LIMITED COGNITION = is required by people with a 

cognitive disability – and – people who are distracted or panicked or under the 

influence of alcohol. 

OPERABLE WITHOUT READING = is required by people with a cognitive

disability – and – people who just haven’t learned to read this language, people 

who are visitors, people who left reading glasses behind (Vanderheiden, n.d.). 

While there is no strong basis for characterizing UD and discriminating UD products from nonUD products, a few sets of evaluation criteria have been identified. The Center for Universal 

Design has developed two versions of Universal Design Performance Measures. The consumer 

version helps guide personal purchasing decisions. The designer’s version “...provides a good 

relative assessment of universal usability, but the measures are not an absolute tool for achieving 

universal design” (Story, 2001). These measures consider questions for phase of use of 

commercial products: packaging, instructions, product installation, use, storage, maintenance, 

repair, and disposal. In addition, Vanderheiden (2001) has identified three levels for evaluating 

products. Level 1 is assigned for features that, if not implemented, will cause a product to be 

unusable for certain groups or situations. Level 2 is assigned for features that, if not 

implemented, will make the product very difficult to use for some groups and situations. Level 3 

is assigned for features that, if implemented, will make the product easier to use but do not make 

it usable or unusable. 
28 

Now that UD definitions, principles, and evaluation techniques have been discussed, the question 

becomes, “What is the reality of UD?” In other words, “Is UD achievable?” The answer to this 

question depends, in part, on how UD is defined. On the one hand, there is Ronald Mace’s 

definition, which indicates that people from all walks of life should have the same opportunities. 

At some level, this is achievable. Consider the curb cut. Curb cuts came about because of the 

Americans with Disabilities Act (ADA), but it turns out that they are beneficial to all of society: 

people pushing baby strollers or using roller blades, for example. The curb cut is most definitely 

considered to have achieved UD. On the other hand, one viewpoint of UD suggests the ideal that 

designs should be usable by individuals under every circumstance. While it’s true that many 

things are usable by a range of individuals, not all of those things are designed in an ideal manner 

for those same individuals. It is not possible to account for every variation in human ability, 

need, and preference. As stated by Story, Mueller, and Mace (1998), 

It is possible to design a product or an environment to suit a broad range of users, 

including children, older adults, people with disabilities, people of atypical size or 

shape, people who are ill or injured, and people inconvenienced by circumstance. 

[Yet,] it is unlikely that any product or environment could ever be used by 

everyone under all conditions. Because of this, it may be more appropriate to 

consider universal design a process, rather than an achievement. 

Role of Assistive Technology in Universal Design 

According to the U.S. Assistive Technology Act of 1998, 

The term assistive technology means technology designed to be utilized in an 

assistive technology device or assistive technology service. The term assistive 

technology device means any item, piece of equipment, or system, whether 

acquired commercially, modified, or customized, that is used to increase, maintain, 

or improve functional capabilities of individuals with disabilities (Assistive 

Technology Act, 1998). 

People with disabilities are commonly aided by the use of assistive technology (AT). Users with 

visual impairments may benefit from the use of the following ATs: 
29 

• Speech input and synthesized speech output 

• Screen readers 

• Screen magnifiers 

• Screen projectors 

• Signage and text printed in Braille and large letters with high contrast, standardized 

keyboards and keyboard layout with landmarks 

• Visual, acoustic, and tactile feedback and alert signals 

• Smart cards that provide a preferred user interface and output 

• Audio recorded information 

Users with hearing impairments may benefit from the use of the following ATs: 

• Text telephones 

• Nonverbal information 

• Visual, acoustic, and tactile feedback and alert signals 

• Adjustable signal level and tone on audio devices 

• Adjustable temporal and spatial resolution in visual communications 

• Volume control 

• Additional earpieces 

• Provisions for inductive coupling to hearing aids 

Users with mobility impairments may benefit from the use of the following ATs: 

• Tilting keyboards and keypads 

• Hands-free data entry and response selection 

• Speech input 
30 

• Intelligent word prediction software 

• Alternative pointing devices, such as mouth sticks 

• Keyboard controllers 

• Body position switches 

• Book holders and page turners 

• Arm supports 

• Touchscreens 

• Remote switches 

Users with cognitive disabilities may benefit from the use of the following ATs: 

• Standardized icons 

• Tactile cues 

• Landmarks, both visual and tactile 

• Speech-synthesized output 

• Speech input 

• Visual examples using drawings and icons for help systems 

Some of these assistive technologies can be designed into the product lines themselves; others 

must be used externally to the device. There is an ongoing debate regarding the role of AT in 

universal design. At the core of the issue is whether the capabilities of AT should be built into 

mainstream products (those designed for the general public) or whether they should be separate 

products that can be used with mainstream products by those who need them. There are three 

schools of thought regarding the use of AT: 

1. AT should be the primary solution to providing people with disabilities access to E&IT. 
31 

2. E&IT manufacturers should enhance the accessibility of their products to extents that are 

technically possible and economically feasible. Beyond this, AT should be used. 

3. E&IT manufacturers should make all their products accessible by everyone, under all 

circumstances, in any situation. 

While it is clear that a single design cannot accommodate all individuals in all contexts 

(Stephanidis, 2001; Vanderheiden, 1990), an inclusive design can accommodate a larger number 

of people than one designed for the “average” user. In addition, ATs themselves cannot readily 

accommodate the needs of all users, and it is burdensome and costly for AT to keep up with 

changing mainstream technologies. On the other hand, AT developers have detailed knowledge 

about the needs of users with various functional limitations, and they can develop better products 

if they can focus on the needs of their target users. 

Some believe that the solution is for AT developers to develop better products rather than 

mainstream developers trying to design products that are useful to everyone. However, with this 

approach, people who need assistive technology are required to purchase AT products in addition 

to the mainstream products. They must also carry their AT device around so that they always 

have the capability to use a product. The best solution is, perhaps, a middle ground, keeping in 

mind that part of UD is ensuring compatibility with some types of AT (e.g., touchsticks), but UD 

doesn’t have to require the use of AT. 

...[U]niversal design in [information technology and telecommunications] IT&T 

products should not be conceived as an effort to advance a single solution for 

everybody, but as a user-centered approach to providing products that can 

automatically address the possible range of human abilities, skills, requirements, 

and preferences (Stephanidis, 2001). 

Assistive technology development, whether or not it is integrated in mainstream products, is 

critical. The Assistive Technology Act of 1998 (P.L. 105-394) provides federal support for 

research and promotion of AT; Title II specifically relates to coordinating research for assistive 

technology and universal design (U.S. Department of Commerce, 2003). 
32 

There are a number of arguments against the design of AT as separate products: 

• AT requires added cost on top of the mainstream products and is affected, in part, by 

insurance reimbursement policies (U.S. Department of Commerce, 2003). 

• AT is sometimes prohibitively expensive, even without the cost of the mainstream 

products. 

• It is not always possible for a person to carry around all necessary AT products. 

• AT is focused on a limited audience. 

• Different AT is needed to accommodate different functional limitations. 

• The economics of ATs are such that the limited market and limited purchasing power of 

the market will likely limit the abilities of AT companies to keep up with the pace of 

mainstream technologies. 

• Often when an innovation in mainstream technology takes place, an update in the AT is 

required; this results in extra cost for the person requiring AT or, at the very least, 

introduces risk. For example, installation of a new software product may interfere with the 

operation of existing AT. Technology is changing so rapidly that once an access problem 

is solved, it is common for a new access problem to surface (Stephanidis, 2001; Emiliani, 

2001). 

• While ATs can be portable, security concerns may prohibit their use; for example, a library 

may prohibit the installation of a screen magnifier on a public computer. 

• AT companies do not have the resources needed to work closely with companies to ensure 

compatibilities with their products or to do product testing (U.S. Department of 

Commerce, 2003). 

• AT companies often do not share the features they have planned for their products with 

other companies until the AT is released. While industry would like to have the data 

sooner, AT companies are reluctant to promise technologies that they might not be able to 

deliver. 
33 

Arguments favoring the design of ATs as separate products include the following: 

• AT allows companies to focus on the development of their specialized products, thus 

resulting in a better job of handling the accessibility issues to meet the needs of people 

with disabilities. 

• It is possible for AT to become so mainstream that it is no longer considered AT. 

Eyeglasses, for example, are no longer thought of as assistive technology, and closedcaptioning and voice recognition software are becoming more commonplace. 

• AT is better equipped to handle specialized or rare needs of people with disabilities, and 

there will likely always be a need for some forms of assistive technology. In addition, AT 

can be tailored to address unique needs (U.S. Department of Commerce, 2003). 

Arguments for integrated AT and UD include the following (Vanderheiden, 1990; Winograd, 

1997): 

• Many product adaptations necessary to accommodate some functional limitations can be 

implemented in mainstream products at little or no extra cost. 

• Many product adaptations necessary to accommodate some functional limitations can also 

facilitate use by the general population (e.g., the curb cut). Some benefits of implementing 

accessibility features that have a more global benefit include lower fatigue, increased 

speed, and lower error rates. 

• AT cannot accommodate the needs of the many individual subgroups that have special 

needs (e.g., mild versus severe hearing loss). 

• Special features can be integrated into mainstream products so they are transparent to users 

who don’t need them (e.g., “sticky keys”). 

Regardless of how people with disabilities use the technology, it will have a large impact on their 

independence and ability to fully participate in society, resulting in an added cost benefit to 

society as a whole (Vanderheiden, 1990). The population of people who may require some sort of 
34 

accommodation is ever-growing with the increase of the elderly population, so much so that the 

term “general population” possibly should be redefined in the minds of designers. Although the 

market potential for products is great, the limited population for any given AT creates financial 

constraints for small companies that focus on AT development. Large companies typically have 

the finances but not the expertise to address a wide range of needs (AAATE, 2003). 

Complications stem not only from the wide variety of functional limitations but also from the 

ever-increasing need for rapid configuration of technologies to accommodate environmental and 

other contextual needs. The increasingly mobile society, for example, may mean that individuals 

need specialized accommodation over a period of a day or even hours, while a more fixed 

environment may require little variation in configuration. “...[I]n the context of the emerging 

distributed and communication-intensive information society, users are not only the computerliterate, skilled, and able-bodied workers driven by performance-oriented motives, nor do users 

constitute a homogeneous mass of information-seeking actors with standard abilities, similar 

interests, and common preferences with regard to information access and use” (Stephanidis, 

2001, p. 6). The AT industry alone cannot address the variable contexts that create a need for 

more customized situational technologies. 

If products are not going to be designed with AT built in, they need to be designed from the 

ground up to be fully compatible with AT, and AT needs to be designed so well that people with 

disabilities no longer have accessibility issues with products. If products are designed with UD 

principles in mind, they will likely be accessible to a large number of people with disabilities 

without the use of AT. Regardless of the resolution to this debate, if any, AT and mainstream 

developers must work together to achieve the greatest accommodation possible and to develop 

adaptors, when necessary. “The use of an adaptor is appropriate when two systems cannot 

otherwise accommodate each other; this is the case when accessibility problems are alleviated by 

the choice of alternative input/output devices or by communication via an alternative modality” 

(Benyon, Crerar, and Wilkinson, 2001). Thus, there is a place in society for both integrated AT 

and UD, as well as for separate AT products. 
35 

Research Process 

An extensive research program was conducted to complete each of the research activities 

documented in this report. This research program was conducted by examining the roles and 

perspectives of industry, Federal Government, and consumers with respect to the six product 

lines that are important to people with disabilities. The six product lines studied were automated 

teller machines (ATMs), cellular phones, distance learning software, personal digital assistants 

(PDAs), televisions, and voice recognition technologies. For more information about the research 

process undertaken in preparing this report and additional information, please consult the online 

version of the report at http://www.ncd.gov. 
36 
37 

II. Market Definition and Research 

Electronic and information technology is driving the creation of new communities that are 

forever changing the way people live, learn, work, and play. Companies are increasingly 

expanding their presence in emerging markets. Businesses are serving populations they have 

never served before. Every consumer is different. No two people have the same set of 

characteristics, learning styles, abilities, experiences, or educational backgrounds. Developing 

products that accommodate the wants, needs, and preferences of as many individual consumers 

as is technically possible and economically feasible can greatly enhance a company’s competitive 

advantage. 

Designing with access in mind can significantly increase the size of E&IT markets on a global 

basis. Good business practices dictate that designers and engineers avoid excluding large groups 

of consumers from accessing and using E&IT. Groups at the highest risk of unintentional 

exclusion are— 

• People with disabilities 

• Individuals 65+ years old 

• Consumers living within low-bandwidth information infrastructures 

• Users of English as a Second Language (ESL) 

• Tourists traveling to nonnative language destinations 

• Consumers living in high-density populations 

This market analysis examined many aspects of manufacturing “more accessibly designed” 

E&IT. This analysis was intended to help answer questions such as the following: 

• Is there a market for more accessibly designed products? 

• Does the capacity exist to develop more accessibly designed products in each of the 

presented product lines? 
38 

• What factors influence the market for more accessibly designed products for each of the 

product lines presented? 

All the product lines reviewed in this report are manufactured by members of the E&IT industry. 

Naturally, in order for these products to be manufactured, the E&IT industry must exist. In order 

to exist, it must be profitable. A question often asked by the disability community is, “How can 

we ensure that the E&IT products and services being manufactured are accessible to people with 

disabilities?” E&IT manufacturers pose a similar question. They ask, “How can we ensure that 

the E&IT products and services we manufacture are accessible and usable by as many people as 

is technically possible and economically feasible without the need for customization?” The 

questions are different. The motivations are different. The market drivers are different. The 

solutions can be remarkably similar. 

Definition of the Market Environment 

Historically, the primary forces driving the manufacture of more accessible E&IT products and 

services have been legal, moral, social, and ethical. The assumption was that if legal, moral, 

social, and ethical issues no longer existed, the motivation to manufacture more accessible E&IT 

would all but disappear. The next two sections discuss the reasons why nothing could be further 

from the truth. 

In contrast to the historical notion of what the primary forces driving the manufacture of 

accessible E&IT are, in actuality a majority of the forces driving demand for more accessibly 

designed E&IT fall into the following five categories: 

• Market forces 

• Local environment 

• Human condition 

• Legal framework 

• Standards and guidelines 
39 

Market Forces 

Market forces consistently drive the demand for more accessibly designed E&IT. Market forces 

include the need to respond to consumer behavior, the work of federal agencies, legislation 

mandating developments in the accessibility of E&IT, changing marketing philosophies (from 

mass marketing to a one-on-one marketing philosophy), competition within the market, emerging 

technology trends, and economic expansion. These market forces are discussed below in terms of 

how they drive the markets for more accessibly designed E&IT products. 

Consumer Behavior 

E&IT is prevalent in schools, libraries, individuals’ homes, work environments, places of 

recreation, banks, and even supermarkets. It is because of this widespread presence that 

consumers are more technically literate than they were five years ago. Devices such as cell 

phones, PDAs, voice recognition systems, and the wireless Web enable us to carry our offices 

with us when we travel. We are more mobile now than ever before. Consumers have become 

accustomed to getting the information they need when they need it and where they want it. This 

has created an expectation of immediacy. When consumers don’t get what they want quickly, 

they become impatient. E&IT designers need to respond to consumer behavior by providing 

products and services that not only meet but exceed the high expectations of a technically literate, 

mobile consumer base. Increasing the accessibility of information services and mobile 

technologies increases access to the information demanded by consumers with high expectations. 

Federal Government

The Federal Government serves as a catalyst for more accessibly designed E&IT products 

through its buying power, the development of legislation, and the support of AT accommodation 

labs. Section 508 of the Rehabilitation Act amendments of 1998 mandates the purchase of 

accessibly designed E&IT. As a result, all federal agencies appointed section 508 coordinators 

(Section 508, 2003). Those coordinators are responsible for organizing and supporting the 

implementation of section 508 in their respective departments and agencies, and they serve as the 

central point of contact for information concerning accessibility issues and solutions. In addition 
40 

to section 508, other legislation provides guidelines for designing more accessible E&IT. The 

Architectural and Transportation Barriers Compliance Board (Access Board) developed the ADA 

Accessibility Guidelines for Buildings and Facilities (ADAAG), and the Telecommunications 

Act Accessibility Guidelines (section 255) mandates the design of more accessible E&IT 

products and services. There are also presidential initiatives driving the design of more accessible 

E&IT. These initiatives include the President’s New Freedom Initiative (White House, 2001), the 

No Child Left Behind Initiative (U.S. House of Representatives, 2002), and the disabilityinfo.gov 

Web site (DisabilityInfo.gov, 2003). 

In addition to these acts and initiatives, many federal agencies have created AT accommodation 

labs. These labs serve as focal points for information regarding accommodations, disabilities, and 

assistive technology. These resources include the following: 

• Department of Agriculture’s TARGET Center 

http://www.usda.gov/oo/target 

• Department of Education’s Assistive Technology Program 

http://www.ed.gov/offices/OCIO/programs_services/assistive_technology/index.html 

• Department of the Interior’s Accessible Technology Program 

http://www.doi.gov/atc 

• Department of Transportation’s Disability Resource Center 

http://www.drc.dot.gov 

• Department of Labor’s Job Accommodation Network 

http://www.jan.wvu.edu 

• The National Institute on Disability and Rehabilitation Research, U.S. Department of 

Education’s ABLEDATA database of assistive technologies 

http://www.abledata.com 

• Department of Veterans’ Affairs Adaptive Training Program 

http://www.va.gov/oirm/itss/itc/brochsb.htm 
41 

• General Services Administration’s Center for Information Technology Accommodations 

(CITA) 

http://www.gsa.gov/Portal/gsa/ep/contentView.do?contentId=9815&contentType=GSA_O

VERVIEW 

Clearly, the Federal Government is an important market force for driving accessibility 

requirements. 

Marketing Philosophies 

Marketing philosophies have changed radically over the past 35 years. The marketing philosophy 

of the 1960s was mass marketing (Mass Marketing Definition, 2003), in which the seller views 

the market as a homogeneous whole and, therefore, has only one marketing program (the same 

product, the same price, the same promotion, and the same distribution system) for everyone in 

the population. This type of marketing is also referred to as unsegmented or undifferentiated 

marketing. 

Marketing philosophies of the 1970s included product line extension (Product Line Stretching 

Definition, 2003) and market segmentation (Market Segmentation Definition, 2003). Product line 

extension adds depth to an existing product line by introducing new products in the same product 

category. Market segmentation is the division of a totally heterogeneous market into groups or 

sectors with relatively homogeneous needs and wants. 

In the 1980s, the marketing philosophy shifted to one of niche marketing (Niche Marketing 

Definition, 2003). Niche marketing or concentrated marketing is a marketing segmentation 

strategy in which the firm focuses all its efforts and resources on serving one segment of the 

market. 

In the 1990s, value-added marketing became popular. Value-added marketing is a strategy in 

which a company buys products, customizes them for a particular application, and then resells 

them. There was also a shift toward marketing to individual customers rather than to the larger 
42 

mass. Don Peppers and Martha Rogers invented the phrase “one-to-one” marketing (Peppers and 

Rogers, 1997) to illustrate the revolutionary concept of treating different customers differently. 

One-to-one marketing supports the establishment of permanent relationships with your 

customers. One-to-one subscribes to providing products and services to customers according to 

their individual wants, needs, and preferences. “Share of customer” replaces market share. The 

marketing focus shifts from institutions to individual consumers. 

Once a company acquires the knowledge and experience required to manufacture more 

accessibly designed E&IT, it can take an asset marketing approach (Asset-Based Marketing 

Definition, 2003) to providing its E&IT products globally. Asset marketing uses the knowledge 

and skills a company has already developed as the basis for growth. For example, a company that 

is skilled in developing kiosks that are accessible to people who are blind can market kiosks 

designed in a similar manner to countries that have high populations of people who have never 

learned to read. This global marketing (Global Marketing Definition, 2003) philosophy enables 

companies to sell the same, or very similar, products to world markets with essentially the same 

promotion. This marketing approach is also commonly referred to as international marketing. 

Competition 

Competition in the E&IT industry is fierce. The industry is constantly looking for ways to 

increase efficiency, competitive advantage, sales, market shares, and profitability. It is also 

looking to cut costs. Businesses are constantly developing new and innovative products and 

services with the hope of achieving these objectives, and adding functionality that enhances the 

accessibility and usability of a product can be very beneficial. In extremely competitive markets, 

several companies have correctly identified UD as a potential market discriminator. When highly 

similar product lines are all competing for the same customer, a product designed with access in 

mind may have the needed advantage required to outbid the competitors. 
43 

Technology Trends 

A variety of rising mainstream technology trends fuels the need for more accessibly designed 

E&IT. The functionalities of multiple individual devices are now being integrated into a single 

device, including pagers, cell phones, PDAs, palmtop computers, smart phones, MP3 players, 

and so on. This trend is creating a dependence on one device to accomplish multiple functions. 

Thus, if not more accessibly designed, this multiple functionality precludes the use of such 

devices by certain segments of the population, for example, people 65+ years of age. Developing 

and manufacturing an accessible interface for a device that provides multiple functions is less 

expensive than developing and manufacturing an accessible interface for multiple single-function 

devices. 

Decreasing costs are making E&IT devices more affordable to emerging markets, which have the 

greatest concentration of individuals with low income and a greater concentration of individuals 

who are unable to read and write. E&IT manufacturers need to move into emerging markets in 

order to increase sales and gain competitive price advantage through economies of scale. 

Increasing processing power, disk storage, memory capacity, and battery life are enabling 

developers to integrate advanced access technologies (speech recognition, text-to-speech 

synthesis, projected displays, etc.) into devices where it had not previously been technically 

possible to do so. In addition, the Internet and the World Wide Web are now being used as a 

primary infrastructure for education, government services, news, and business. Customers’ 

technical knowledge and expectations are constantly increasing, along with the use of wireless 

Internet appliances and wireless infrastructures. Legal mandates to manufacture more accessibly 

designed E&IT in support of people with disabilities are a driving force behind these 

technological trends. 

Economic Expansion 

The strength of our global economy is, to a great extent, the result of the investment in and 

application of new technologies by governments, businesses, and individuals. Technology is the 
44 

foundation upon which developing countries can build thriving, financially independent, selfsufficient economies. The technologies that build this foundation include computers, networks, 

ATMs, wired and wireless information infrastructures, wireless handheld Internet appliances, and 

cellular telephones, to name a few. Applications include online banking, distance learning, egovernment, and e-commerce (World Information Technology, 2003). 

Local Environment 

Another force that drives the market for accessibly designed E&IT is local environments. The 

following is a discussion of two environmental factors: variances in bandwidth and tourism. 

Bandwidth 

As of May 2004, more than half (51.39 percent) of home Internet users in the United States relied 

on dial-up modems of 56Kbps or less. Of all U.S. home Internet users, 42.53 percent used 

56Kbps modems, 6.52 percent used 28/33.3Kbps modems, and 2.34 percent used 14.4Kbps 

modems (Nielsen/NetRatings, 2004). 

Computers using dial-up connections cannot handle graphics as quickly and efficiently as 

computers connected via broadband. It is for this reason that dial-up users surf the Internet with 

graphics turned off. They do this to speed up downloads. Low-bandwidth connections do not 

lend themselves to a lot of graphic images, video-based information, or streaming audio. 

Multimedia content can be problematic for users with slower connections. Wireless devices 

communicating with the Internet at slow connect speeds can also be a source of accessibility and 

usability problems. 

There are solutions to these problems. Some companies have the ability to control the settings on 

the browsers used on their employees’ PCs. When available corporate Intranet bandwidth is at a 

premium, these companies can simply issue a central command to turn off graphics on all client 

PC browsers. This can immediately free up as much as 80 percent of available bandwidth. 

Designing Web sites for low-bandwidth access tends to increase accessibility for users with 
45 

disabilities. For example, a graphics- or animation-intensive site often requires high bandwidth 

and is inaccessible to those who are blind. In contrast, a text-based site loads quickly and is 

accessible to screen readers. Dial-up environments will continue to drive the development of 

more accessible E&IT in the foreseeable future. 

Tourism 

During the first quarter of 2004, the United States welcomed 8 million international visitors. This 

was an increase of 12 percent compared to the first quarter of 2003. 

Visiting tourists often make use of ATMs, self-service kiosks, ticketing kiosks, and other 

tourism-related information technologies. Many tourists use English only as a second language. 

Content written in simplified English is more understandable to users of ESL. Simplified English 

content has other significant benefits. For example— 

• It reduces the cost of language translation. 

• It reduces ambiguity. 

• It speeds reading. 

• It reduces liability associated with misunderstandings. 

The use of simplified content was originally included in various accessibility design guidelines in 

support of people with cognitive reading disabilities. Using simplified language has now evolved 

into a market force driving the design of more accessible E&IT. 

Human Condition 

Aside from forces stemming from the market and the environment, many of the forces driving 

the accessible design of E&IT fall under aspects of the human condition. E&IT products must be 

designed with people of different disabilities, various age groups, various levels of literacy, 

various languages, different learning styles, and different experience levels with activities such as 

using the Internet in mind. These aspects of the human condition bring with them the demand for 
46 

accessible E&IT products that cater not just to one category but to many different types of users. 

Below is a summary of the forces that drive the demand for E&IT that is accessible to a wide 

range of users. 

Disability 

Census 2000 counted 54 million people in the United States with some type of long-lasting 

condition or disability (NCD, 2004). These individuals represented 19.3 percent—nearly one in 

five people—of the 257.2 million people age five and older in the civilian, noninstitutionalized 

population. Their conditions included a wide range of disabilities, not all of which precluded the 

use of E&IT. Within this population, Census 2000 found— 

• 9.3 million (3.6 percent) with a sensory disability involving sight or hearing 

• 21.2 million (8.2 percent) with a condition limiting basic physical activities, such as 

walking, climbing stairs, reaching, lifting, or carrying 

• 12.4 million (4.8 percent) with a physical, mental, or emotional condition causing 

difficulty in learning, remembering, or concentrating 

• 6.8 million (2.6 percent) with a physical, mental, or emotional condition causing difficulty 

in dressing, bathing, or getting around inside the home 

• 18.2 million of those age 16 and older with a condition that made it difficult to go outside 

the home to shop or visit a doctor (8.6 percent of the 212.0 million people this age) 

• 21.3 million of those ages 16 to 64 with a condition that affected their ability to work at a 

job or business (11.9 percent of the 178.7 million people in this age group) 

E&IT products and services that are accessible to people with disabilities appeal to the wider 

population as well. Accessible design can significantly enhance the sales of a product. For 

example, all of the following products were first developed in support of people with disabilities 

and are now used by the wider population: 

• Auto-dialers 
47 

• Flatbed scanners 

• Microphones 

• Speech recognition 

• Speech synthesis 

• Talking ATMs 

• Talking caller ID 

• Vibrating pagers 

Age 

There are 36 million consumers 65 years of age and older living in the United States (Population, 

2003). People 65+ years of age are often not able to see, hear, think, or move about as easily as 

they did when they were younger. In order to enable people 65+ years of age to access and use 

E&IT, these differences must be accommodated. In addition, 52 percent of people 65+ years of 

age have some type of disability. Thirty-three percent of persons 65+ years of age have a severe 

disability. 

By 2030, there will be about 70 million older persons, more than twice the number in 2000.

People 65+ represented 12.4 percent of the population in the year 2000, but are expected to grow 

to 20 percent of the population by 2030 (Administration on Aging, 2002). Furthermore, 

individuals who are accustomed to operating E&IT will demand accessible E&IT as their 

functional capabilities diminish. 

Language 

Language is certainly a driving force in today’s market for more accessible E&IT. According to 

Global Reach, there are 262 million English-speaking people online. Non-English-speaking 

populations online are 474 million. By the end of 2005, the ratio of English-speaking to nonEnglish-speaking users will decrease significantly (Global Reach, 2003). 
48 

Sixty-four percent of people who visit the Internet seek sites in languages other than English 

(Global Reach, 2003). In a world where International Data Corporation (IDC) predicted that 

Internet spending outside the United States will have exceeded $914 billion in 2003, effective 

Web site globalization is the next imperative of Internet enterprises (IDC, 2000). Despite the vast 

international opportunities projected, few U.S. companies appear poised to take advantage of 

them. More than half (55 percent) of U.S. companies do nothing to customize their Web sites for 

foreign visitors; less than one-quarter even allow a choice of language, according to recent IDC 

Internet Executive ePanel research. With such minor globalization efforts, it is not surprising that 

72 percent of U.S. companies that are online currently draw only 10 percent or less of their ecommerce revenue from outside the United States. To increase their e-commerce revenue, 

companies must strive to design Web sites that are accessible to the non-English-speaking 

population. 

Learning Style 

There are three major types of learning styles (Live Text, 2000). They are visual, auditory, and 

kinesthetic. Visual learners need to see a person’s body language and facial expression to fully 

understand the content of what is being said. They tend to prefer sitting at the front of a 

classroom, play, or lecture hall to avoid visual obstructions (e.g., people’s heads). They may 

think in pictures and learn best from visual displays, including diagrams, illustrated textbooks, 

overhead transparencies, videos, flipcharts, and handouts. During a lecture or classroom 

discussion, visual learners often prefer to take detailed notes to absorb the information. Auditory 

learners learn best through verbal lectures, discussions, talking things through, and listening to 

what others have to say. Auditory learners interpret the underlying meanings of speech through 

listening to tone of voice, pitch, speed, and other nuances. Written information may have little 

meaning until it is heard. These learners often benefit from reading text aloud and using a tape 

recorder. Tactile/kinesthetic learners learn best through a hands-on approach, actively exploring 

the physical world around them. They may find it hard to sit still for long periods and may 

become distracted by their need for activity and exploration. Enabling people to acquire 
49 

information in the manner most appropriate to their learning style(s) enhances the effectiveness 

of E&IT and accommodates users with sensory disabilities. 

Experience Level 

Many people who are learning to use an application on the Web for the first time want all the 

help they can get. There will come a time, however, when the extra help is no longer needed or 

desired. One of the benefits of accessible design practices is having the ability to customize user 

interfaces based on the wants, needs, and preferences of individual users. 

Legal Framework 

The following is a summary of key laws, statutes, and standards that have improved accessibility 

for individuals with disabilities in this country. Each law is summarized, followed by a 

discussion of who is primarily affected by the law and the law’s approach toward addressing 

accessibility issues. These laws and standards are a driving force in the market for accessibly 

designed products, as they set the standards and guidelines for what must be done by the 

government and industry to accommodate the needs of individuals with disabilities. 

Section 508 of the Rehabilitation Act 

Section 508 of the Rehabilitation Act of 1973 requires that when federal agencies develop, 

procure, maintain, or use E&IT, they must ensure that individuals with disabilities have access to 

and use of information that is comparable to the access and use by federal employees who do not 

have disabilities, unless an undue burden (significant expenses or difficulties) is imposed on the 

agency. The law also requires that individuals with disabilities in the general public seeking 

information or services from a federal agency have access to information and services 

comparable to that provided to individuals without disabilities, unless undue burden is imposed 

on the agency. When compliance does impose an undue burden, agencies must still provide 

disabled individuals with the information and data by allowing them to use it by an alternative 

means of access (e.g., captioning, audio description). 
50 

Section 508 covers E&IT such as computer hardware, software, networks, ancillary equipment, 

firmware, technology services, telecommunications products, information kiosks and transaction 

machines, World Wide Web sites, multimedia, and office equipment such as copiers and fax 

machines. Section 508 does not cover equipment that contains embedded information technology 

that is used as an integral part of the product but the principal function of which is not the 

acquisition, storage, manipulation, management, movement, control, display, switching, 

interchange, transmission, or reception of data or information (e.g., HVAC equipment and 

medical equipment). As a guideline, E&IT systems can be considered to be accessible to 

individuals with disabilities if they can be used in a variety of ways that do not depend on a 

single sense or ability. 

Section 508 has the potential to greatly improve accessibility to E&IT for individuals with 

disabilities. The Federal Government will likely become a better employer to the many people 

with disabilities who work for it, as well as a model employer for industry. In addition, members 

of the public with disabilities will have greater accessibility to government information and 

services related to technology. 

Those affected directly by section 508 include federal departments and agencies and vendors that 

serve the Federal Government. The initial impact is at the procurement stage. Section 508 must 

be integrated into the procurement process by determining which technical provisions from 

section 508 apply in a given situation, performing market research to determine the availability of 

products and services that meet the applicable technical provisions, deciding which technical 

provisions, if any, do not apply due to an exception, and submitting technical specifications and 

minimum requirements to a contracting officer. 

Private companies and software developers are also affected by section 508. Although section 

508 does not require private companies to alter their products, full implementation of the law 

may provide an incentive for companies that want to do business with the government to build 

better accessibility features into their products. Currently, however, there is a perception by some 
51 

in industry that section 508 conformance is being “rubber stamped” by procurement officials and 

that the content of documents describing section 508 conformance, such as voluntary product 

accessibility templates (VPATs), is not important as long as it is merely offered. If section 508 is 

fully addressed by procurement officials, accessibility will become a key discriminator for federal 

sales. Increased competition will raise the bar for hardware and software vendors that want to 

create new and innovative solutions to addressing accessibility issues. Software developers are 

affected by section 508 in that they are now trying to integrate the applicable section 508 

provisions into their entire software development life cycle. Developers are faced with the 

challenge of either making their software compatible with assistive technology or making 

software products accessible without the aid of other AT. 

In contrast to other federal laws that take a “push” approach toward improving the accessibility 

of E&IT by mandating that new, better technologies are manufactured and adopted, section 508 

does not explicitly require manufacturers to make their products more accessible. Rather, section 

508 uses a “pull” approach, in which the federal agencies are responsible for seeking better 

products to address accessibility problems by procuring products that comply with the provisions 

when such products are available in the commercial marketplace or when such products are 

developed in response to government solicitation. 

Section 255 of the Telecommunications Act 

Section 255 of the Telecommunications Act of 1996 requires that telecommunications products 

and services be accessible to people with disabilities, to the extent that such access is readily 

achievable. If manufacturers cannot make their products more accessible, they must design 

products to be compatible with adaptive equipment used by people with disabilities when it is 

readily achievable to do so. 

Telecommunications products covered under this Act include wired and wireless 

telecommunication devices such as telephones, pagers, and fax machines; products that have a 

telecommunication service capability such as computers with modems; and equipment that 
52 

carriers use to provide telecommunications services, which includes the software integral to that 

equipment. Also covered are basic and special telecommunication services, including regular 

telephone calls, call waiting, speed dialing, call forwarding, computer-provided directory 

assistance, call monitoring, caller identification, call tracing, repeat dialing, interactive voice 

response systems, and voice mail. 

The implementation of section 255 of the Telecommunications Act stands to improve access and 

the number and range of accessible products in the telecommunications industry. Companies that 

manufacture telecommunications products or provide telecommunications services are expected 

to shift toward a more universal, inclusive design process in the development of new products 

and services. Those affected by section 255 include manufacturers of telecommunications 

equipment and customer premises equipment as well as the providers of telecommunications 

services. Companies must research ways to make their products more accessible and provide 

training for their staffs on accessibility. Manufacturers must modify their design processes to 

ensure that accessibility and usability are considered in the earliest design phases of a product. 

The law has been beneficial to manufacturers and service providers because they have found that 

by making products easier to use for people with disabilities, the products often are easier for 

everyone to use. 

Section 255 takes more of a push approach toward improving accessibility by establishing a set 

of guidelines that manufacturers in this industry must follow in designing new products and 

services. Companies are advised to use these guidelines and implement training procedures as 

specified by the law. Section 255 is related to section 508 of the Rehabilitation Act in that the 

U.S. Access Board has incorporated the language of the guidelines specified in section 255 into 

the 508 standard. This consistent language has enabled companies to develop products that meet 

both the design requirements of the manufacturers and the procurement requirements of the 

federal agencies. 
53 

Hearing Aid Compatibility Act 

The Hearing Aid Compatibility (HAC) Act of 1988 requires that the Federal Communications 

Commission ensure that all telephones manufactured or imported for use in the United States 

after August 1989, as well as all “essential” telephones, are hearing aid compatible. “Essential” 

telephones have been defined as coin-operated telephones, telephones provided for emergency 

use, and other telephones frequently needed for use by persons with hearing aids. This includes 

telephones in the workplace, in confined settings such as hospitals or nursing homes, and in hotel 

and motel rooms. 

Telephone manufacturers are directly affected; they must design phones with volume control and 

other features for users with hearing aids. Owners of hospitals, hotels, and other places with 

“essential” telephones must ensure that the telephones they purchase for their buildings are 

hearing aid compatible. Employers must ensure that all telephones in both common and 

noncommon areas in their workplaces are hearing aid compatible and that any new telephones 

they purchase are hearing aid compatible. 

Unlike section 255 of the Telecommunications Act, in which companies must ensure that their 

products are accessible to hearing aid users only if it is readily achievable for them to do so, 

under the HAC Act this requirement is absolute. Like section 255 of the Telecommunications 

Act, section 255 takes a push approach, mandating that corporations and business owners 

purchase telephones that are hearing aid compatible and that the Federal Communications 

Commission (FCC) ensure that all essential telephones and telephones manufactured or imported 

for use in the United States are hearing aid compatible. 

Americans with Disabilities Act 

The Americans with Disabilities Act (ADA) of 1990 recognizes and protects the civil rights of 

people with disabilities. It provides protection from discrimination against individuals on the 

basis of disability. Covered under the ADA are a wide range of disabilities, and a person with a 

disability is defined as anyone with a physical or mental impairment that substantially limits one 
54 

or more major life activities. These include physical conditions that affect mobility, stamina, 

sight, hearing, and speech, as well as emotional illnesses and learning disorders. The ADA 

addresses access of individuals with disabilities to the workplace (Title I), state and local 

government services (Title II), and places of public accommodation and commercial facilities 

(Title III). In addition, phone companies are required, under the ADA, to provide 

telecommunications services for people who have hearing or speech impairments (Title IV). 

Title I, which deals with employment of individuals with disabilities, requires that employers do 

not discriminate against qualified individuals with disabilities and that they reasonably 

accommodate the disabilities of qualified applicants and employees by modifying work stations 

and equipment, unless undue burden should result. Title II, which deals with public services, 

requires that state and local governments do not discriminate based on disability and that they 

ensure that their buildings are accessible, that new and altered streets and pedestrian walkways 

contain curb cuts at intersections, and that each service or program is operated so that it is readily 

accessible to and usable by individuals with disabilities. In addition, this title requires that transit 

facilities, buses and rail vehicles, key stations in rail systems, Amtrak stations, and vehicles for 

demand response systems be made accessible, unless certain exceptions apply. Title III, which 

deals with public accommodations, requires that restaurants, hotels, theaters, shopping malls, 

retail stores, museums, libraries, parks, private schools, and day care centers, among other places 

of public accommodation, do not discriminate based on disability. Any alterations to existing 

places of public accommodation are required to be done in an accessible manner. Moreover, new 

busses for specified public transportation must be accessible, and elevators must meet certain 

conditions. Title IV, which covers telecommunications, states that telephone companies must 

provide telecommunications relay services for hearing-impaired and speech-impaired individuals 

24 hours per day. 

The ADA has had a significant impact on American society, allowing individuals with 

disabilities to pursue opportunities that were not available to them in the past. One of the largest 

groups affected by the ADA is employers, who must both reasonably accommodate the needs of 
55 

employees with disabilities and refrain from discriminating against them. If an employer fails to 

comply with the ADA, the employee can sue, forcing the company to comply or pay damages. In 

addition, state and local government bodies, educational institutions, and virtually any place of 

public accommodation or employment are directly affected by the ADA and must comply with 

the regulations. 

The Annenberg Washington Program, a nonprofit institute in communication studies, met in 

1994 and expanded upon a previously published white paper in which it stated its initial findings 

that the average cost of most ADA accommodations was approximately $36, a much lower 

amount than many anticipated. The program found that the impact of the ADA on American 

businesses did not create onerous legal burdens, as many believed would be the case, but rather 

has provided a framework for employers and employees for dispute avoidance and resolution. 

Overall, the ADA has had a positive impact on society. 

The ADA has also taken a push approach toward addressing issues of accessibility. The push is 

for the businesses and organizations themselves to devise solutions based on the requirements set 

forth in the ADA. 

Electronic Industries Alliance (EIA) Standards: EIA- 608 and EIA-708

The EIA-608 standard specifies the use of closed-captions in analog TV signals. EIA-608 

addressed the lack of standards for Line 21 closed-captioning, to ensure that new decoders would 

all work the same way and that captioners could create captions that would appear in a consistent 

and predictable manner on every TV set. The Television Data Systems Committee of the EIA 

enhanced the Line 21 system by adding new characters and assigning codes that would allow the 

center of the screen to be used for captioning. They also allowed roll-up captions, for the first 

time enabling real-time captions to be placed somewhere other than the bottom of the screen. 

This work became known as the EIA-608 standard, and all captioning software and all TV 

receivers built after July 1993 were required to comply with it. 
56 

When digital television (DTV) was developed, a new need arose for the ability to change the size 

of the caption display—making the captions larger and more readable or smaller and less 

obtrusive. The conversion of closed-captions for service with digital was necessary. This need 

could not be accommodated in the EIA-608 standard, and thus the EIA-708 standard was 

introduced. The current version, EIA-708B, covers two areas. It defines how captioned data are 

to be encoded and transmitted (known as the transmission protocol or transmission layer). It also 

defines where in a DTV signal the caption data are to be placed, the bandwidth allocated, and the 

format of the data. The second area is the display protocol, which determines how captions are 

displayed on the screen of a DTV. The 708 captioning format was designed to allow for the use 

of the entire unicode set, which includes every character in the alphabet in any language plus the 

complete range of symbols. Almost any program can thus be captioned. 

Many groups are affected by the introduction of the EIA-708 standard. Manufacturers are 

affected because the Decoder Circuitry Act of 1990 states that “[d]igital television receivers and 

tuners must be capable of decoding closed-captioning information that is delivered pursuant to 

the industry standard EIA-708-B.” This Act requires the FCC to update its rules for decoders as 

new technologies such as DTV are developed. Television broadcasters are also largely affected 

by the new 708 captioning format, because the pressure is building to produce new programming 

with digital closed-captions based on this standard. Broadcasters and producers must begin 

devising plans to make this move and invest in the equipment they will need to do so. Also 

significantly affected are the viewers with auditory impairments who will benefit from much 

greater flexibility and a higher quality of captioning with the EIA-708 standard. 

A push approach toward the development of a new standard has been taken in the movement 

from EIA-608 to EIA-708 captioning. After developing the new standard, the EIA put the 

responsibility on the broadcasters and producers to comply with these standards in their 

captioning. This push to move from EIA-608 (analog) to EIA-708 (digital) has brought many 

improvements to closed-captioning. Television viewers can now control the size of the caption 

text. In addition, EIA-708 offers more letters and symbols, supports multiple fonts and text and 
57 

background colors, and allows the viewer to replace the traditional black-box background with a 

colored box or do away with it entirely. Also, EIA-708 increases the data rate by 16 times over 

that provided by EIA-608, allowing DTV captions to contain much more information. However, 

most DTV content currently still relies on the EIA-608 standard captions that have been 

converted to the EIA-708 format, because the consumer base of DTV receivers is not yet high 

enough to justify the added expense of native EIA-708 encoding. 

Individuals with Disabilities Education Act 

The Individuals with Disabilities Education Act (IDEA) was first enacted in 1975. The Act was 

passed to ensure that students with disabilities receive free, appropriate public education and the 

related services and support they need to achieve in the least restricted environment appropriate 

to their individual needs. IDEA was created to help states and school districts meet requirements 

for educating children with disabilities and to pay part of the expenses of doing so. IDEA 

consists of three parts: Part B provides grants to states for services for preschool and school-age 

children, Part C funds early intervention services for infants and toddlers, and Part D supports 

national activities to improve the education of children with disabilities, including research and 

professional development programs.

IDEA covers children with disabilities until they graduate from high school or until they are 22 

years of age if graduation is delayed. Students who may have a covered disability must be 

evaluated. If it is determined that the student does have a disability covered by IDEA, the school 

is required to annually develop an individualized education program (IEP) for the student and 

place him or her in a regular classroom setting when possible. Amendments to the Act adopted in 

1997 have shifted the focus of IDEA from merely providing children with disabilities access to 

an education to improving results for all children in the education system.

The primary group affected by and benefiting from IDEA are children with disabilities. As a 

result of IDEA, students with disabilities now learn among their peers. U.S. Senator Jim Jeffords 

reports that since the initiation of IDEA, dropout rates for students with disabilities have 
58 

significantly declined and graduation rates have gone up. The percentage of college freshman 

with disabilities has tripled as a result of the improved education children with disabilities have 

available to prepare them for college. Teachers and parents of children with disabilities are also 

significantly affected by IDEA. These two groups play a large role in the development of a 

child’s IEP. Teachers have had to adjust to having children with disabilities in the same 

classroom as children without disabilities, learning together. Others involved in the public 

education system are certainly affected as well. 

The enactment of IDEA has followed a push approach in requiring that public schools make free 

education that adheres to the provisions set forth in the Act available to students with disabilities. 

The legislation places the responsibility upon the schools and provides them with the 

requirements they must meet, while providing some financial assistance. 

Instructional Material Accessibility Act 

The purpose of the Instructional Material Accessibility Act of 2003 (IMAA) is to improve access 

to printed instructional materials used by students in elementary and secondary schools who are 

blind or have other visual disabilities. The Act creates an efficient system for the acquisition and 

distribution of instructional materials in the form of electronic files suitable for conversion into a 

variety of specialized formats. IMAA requires one national file format and a single national 

repository for files, which simplifies the process of obtaining materials for students with 

disabilities. Having a national file format will make the conversion process for producing 

specialized formats more efficient by reducing the amount of human intervention necessary. 

Having one national file format will make it easier for states, publishers, Braille software 

developers, and Braille transcribers to work with files. Braille transcribers will have more time to 

use their expertise in formatting and proofing files, leading to high-quality Braille. Students will 

directly benefit because the national file format will eliminate needless steps in scanning and 

reformatting files. Teachers will benefit, as well, by having materials available in specialized 

formats for their students who have disabilities at the same time they are available to their other 

students. 
59 

State and local education agencies that receive federal funding under IDEA are responsible for 

developing a statewide plan within two years of the enactment of IMAA to ensure that printed 

materials required for classroom instruction in elementary and secondary schools are available in 

specialized formats to individuals with disabilities at the same time they are made available to 

students without disabilities. 

This Act is a push approach toward improving access to printed instructional materials for 

visually impaired students. IMAA requires all the states to adopt the national file format. 

Video Description Restoration Act 

The Video Description Restoration Act (VDRA), which is pending in Congress, would restore 

the FCC’s video description rules that were overturned in federal court on November 8, 2002. 

The Act would guarantee TV access for individuals who are blind or visually impaired through 

video description. The FCC would be expressly granted authority to restore its minimum 

requirements, with increased access over time. Those minimum requirements mandated that the 

major networks and cable channels in the top 25 television markets present at least four hours of 

described programming per week and that video-described programs be made available in 

smaller markets where TV stations have the equipment to do so. VDRA has been rigorously 

supported by the American Council for the Blind and other blind and deaf organizations, because 

they feel that video description will achieve for people who are blind what closed-captioning 

does for individuals who are deaf. 

The community of people who are blind or visually impaired would benefit from VDRA by once 

again having video description available to them, affording them the same access to information 

on television as sighted viewers. Also affected would be the television program providers and 

owners who would be required to offer video description for a portion of their programming. 

VDRA permits an exemption if the provision of video description would be unduly burdensome 

to the provider or owner, or if video description is not necessary to achieve video programming 

accessibility by persons who are blind or otherwise visually impaired. 
60 

VDRA would restore the FCC’s rule for the minimum requirements major networks and cable 

channels must meet in terms of the amount of video description they provide. This push approach 

taken by the FCC would ensure that at least a portion of programs would be made available for 

the visually impaired through video description. The number of hours of video description 

mandated by the FCC may grow larger, leading to increased access to television programming 

for the visually impaired over time. 

Standards and Guidelines 

In addition to the laws mentioned in the previous section, standards and guidelines exist that 

drive more accessibly designed E&IT. These are discussed below. 

ADA Accessibility Guidelines 

The Access Board’s guidelines, issued under the Americans with Disabilities Act, are to be 

completely updated and revised. The ADA Accessibility Guidelines (ADAAG) cover the 

construction and alteration of facilities in the private sector (places of public accommodation and 

commercial facilities) and the public sector (state and local government facilities). The 

accessibility guidelines issued under the Architectural Barriers Act (ABA) primarily address 

facilities in the federal sector and other facilities designed, built, altered, or leased with federal 

funds. The guidelines under both laws are being updated together in one rule that contains three 

parts: a scoping document for ADA facilities, a scoping document for ABA facilities, and a 

common set of technical criteria that the scoping documents will reference. As a result, the 

requirements for both ADA and ABA facilities will be more consistent. The guidelines also 

include new scoping and technical provisions for accessible housing that derive from 

requirements for “Type A” dwelling units contained in the 1998 edition of the ICC/ANSI A117.1 

standard, “Accessible and Usable Buildings and Facilities.” Of specific interest is 4.34.5 

Equipment for Persons with Vision Impairments. Instructions and all information for use must be 

made accessible to and independently usable by persons with vision impairments. 
61 

Telecommunications Act Accessibility Guidelines

On February 3, 1998, the Access Board issued its final guidelines for the accessibility, usability, 

and compatibility of telecommunications equipment and customer premises equipment covered 

by section 255 of the Telecommunications Act of 1996 (Telecommunications Act Accessibility 

Guidelines, 1998). The Act requires manufacturers of telecommunications equipment and 

customer premises equipment to ensure that the equipment is designed, developed, and fabricated 

to be accessible to and usable by individuals with disabilities, if readily achievable. When it is 

not readily achievable to make the equipment accessible, the Act requires manufacturers to 

ensure that the equipment is compatible with existing peripheral devices or specialized customer 

premises equipment commonly used by individuals with disabilities to achieve access, if readily 

achievable. 

Web Content Accessibility Guidelines 1.0 

These guidelines explain how to make Web content accessible to people with disabilities (Web 

Content Accessibility Guidelines 1.0, 1999). The guidelines are intended for all Web content 

developers (page authors and site designers) and for developers of authoring tools. The primary 

goal of these guidelines is to promote accessibility. However, the adoption of these guidelines 

will also make Web content more available to all users, no matter what user agent they are using 

(e.g., desktop browser, voice browser, mobile phone, automobile-based personal computer) or 

constraints they may be operating under (e.g., noisy surroundings, under- or over-illuminated 

rooms, in a hands-free environment). The adoption of these guidelines will also help people find 

information on the Web more quickly. These guidelines do not discourage content developers 

from using images, video, and so on, but rather explain how to make multimedia content more 

accessible to a wide audience. 

Authoring Tool Accessibility Guidelines 1.0 

This specification provides guidelines for Web authoring tool developers (Authoring Tool 

Accessibility Guidelines 1.0, 2000). Its purpose is twofold: to assist developers in designing 

authoring tools that produce accessible Web content and to assist developers in creating an 
62 

accessible authoring interface. Authoring tools can enable, encourage, and assist users 

(“authors”) in the creation of accessible Web content through prompts, alerts, checking and 

repair functions, help files, and automated tools. It is just as important that all people be able to 

create content as it is for all people to have access to it. The tools used to create this information 

must therefore be accessible. Adoption of these guidelines will contribute to the proliferation of 

Web content that can be read by a broader range of readers and authoring tools that can be used 

by a broader range of authors. 

User Agent Accessibility Guidelines 1.0 

This document provides guidelines for designing user agents that lower barriers to Web 

accessibility for people with visual, hearing, physical, cognitive, and neurological disabilities 

(User Agent Accessibility Guidelines 1.0, 2002). User agents include HTML browsers and other 

types of software that retrieve and render Web content. A user agent that conforms to these 

guidelines will promote accessibility through its own user interface and through other internal 

facilities, including its ability to communicate with other technologies (especially assistive 

technologies). Furthermore, all users, not just users with disabilities, should find conforming user 

agents to be more usable. In addition to helping developers of HTML browsers and media 

players, this document will also benefit developers of assistive technologies because it explains 

what types of information and control an AT may expect from a conforming user agent. 

Technologies not addressed directly by this document (e.g., technologies for Braille rendering) 

will be essential to ensuring Web access for some users with disabilities. 

XML Accessibility Guidelines 

This document by the World Wide Web Consortium (W3C) provides guidelines for designing 

Extensible Markup Language (XML) applications that lower barriers to Web accessibility for 

people with visual, hearing, physical, cognitive, and neurological disabilities (XML Accessibility 

Guidelines, 2002). XML, used to design applications such as XHTML, SMIL, and SVG, 

provides no intrinsic guarantee of the accessibility of those applications. This document explains 

how to include features in XML applications that promote accessibility. 
63 

Customer Analysis 

The purpose of this section is to highlight the consumer markets targeted by the industries being 

studied. A more detailed customer analysis can be found in the appendix to the online version of 

this report. 

People with Disabilities 

Estimates vary greatly on the number of persons with disabilities living within the United States 

and worldwide. The latest Census Bureau disability statistics report, Characteristics of the 

Civilian Noninstitutionalized Population by Age, Disability Status, and Type of Disability: 2000,

estimates that there are 49.7 million people with disabilities living in the United States (Age 

Structure, 2003). Applying the disability percentages presented in this report to the age structures 

categorized by the World Factbook (including populations less than five years of age), results in a 

figure of 54 million, which is often cited as the actual number of people with disabilities living in 

the United States. This is the figure reported by the NCD (2004). Comparing the U.S. disability 

statistics with those of other countries indicates that China, India, Russia, Mexico, and Turkey 

have greater instances of disabilities for any age category because they have poorer health care 

than the United States. The market for universally designed products and services seems clear 

when global disability statistics (498 million people) are analyzed for these countries, which 

currently have the top five emerging markets. A detailed look at these emerging markets can be 

found in the appendix to this report online. 

The specific customer populations of interest for the purpose of this study are people with the 

following disabilities or conditions: 

• Low vision 

• Blind 

• Hard of hearing 

• Deaf 
64 

• Upper-mobility impaired 

• Lower-mobility impaired 

• Cognitive 

Each of the above conditions is defined in terms of a loss of functional capability that may be 

temporary or permanent or may develop as a natural part of the aging process. The functional 

limitations may be caused by genetics, disease, traumatic injury, aging, environmental or 

situational factors, or some combination of multiple factors. In other words, the analysis is not 

restricted to functional limitations resulting from what is traditionally termed a disability. This 

approach, espoused by the functional model of disabilities (Kaplan, n.d.), allows us to consider a 

wide segment of the population who could truly benefit from universal design. 

It is important to understand the functional capabilities and limitations, as well as alternative 

strategies of access, of the target population in order to properly assess the impact of various 

accessibility features on mainstream products. Each of the target populations has different 

functional capabilities and limitations and thus experiences different issues with the product lines 

under study. 

Visual Impairments 

In general, people with impaired vision may have difficulty perceiving visual detail, focusing on 

objects either close up or at a distance, separating objects that do not have sufficient contrast, 

perceiving objects in both central and peripheral vision, perceiving color and contrast brightness, 

adapting to different light levels, tracking moving objects, and judging distances (Story, Mueller, 

and Mace, 1998). 

Hearing Impairments 

In general, people who are deaf and hard of hearing may have difficulty localizing the source or 

direction of sound, filtering out background sound, perceiving both high- and low-pitched 

sounds, and carrying on a conversation (Story, Mueller, and Mace, 1998). 
65 

Mobility Impairments 

In general, people with impaired mobility may have difficulty with tasks requiring range of 

motion, coordination, strength, and balance. More specifically, difficulties may be apparent in the 

following areas: reaching, pushing, pulling, lifting, lowering, carrying, grasping, squeezing, 

rotating, twisting, and pinching (Story, Mueller, and Mace, 1998). 

Cognitive Disabilities 

In general, people with cognitive disabilities may have difficulty “...receiving, comprehending, 

interpreting, remembering, or acting on information” (Story, Mueller, and Mace 1998). More 

specifically, difficulties may be apparent in the following areas: beginning a task without a 

prompt or reminder, responding within an appropriate time frame, concentrating, comprehending 

visual or auditory information, understanding or expressing language, following procedures or 

doing things in order, organizing information, remembering things, making decisions and solving 

problems, and learning new things and doing things a new or different way (Story, Mueller, and 

Macel, 1998). 

Other Customer Markets 

In addition to people with disabilities, other customer markets targeted in this study include the 

following. A discussion of each of these customer populations can be found in the appendix to 

the online version of this report. 

• Individuals 65+ years of age 

• Consumers living in low-bandwidth information infrastructures 

• People who have never learned to read 

• Users of ESL 

• Tourists 

• Consumers living in high-density populations 
66 

• Consumers in situations that reduce sensory or visual capabilities 

Analysis of Market Trends 

The market for E&IT products is constantly changing and evolving as new product trends arise. 

New trends in cellular phones, ATMs, PDAs, televisions, speech recognition technology, and 

distance learning are changing the way we learn, do business, store data, bank, communicate with 

others, and entertain ourselves. There are many market forces that reflect the desires of the E&IT 

industry (such as gaining a competitive advantage and complying with U.S. laws) and of the 

consumer (such as wanting easy-to-use products that are efficient and increase the user’s safety). 

These forces create the demand for more accessibly designed products. New products are 

consistently emerging with the aim of serving a wider population of users, including users with 

various disabilities, and increasing the overall ease of use for everyone. Current trends in the 

industries for the six product lines presented in this report are discussed below, along with the 

market forces that create the demand for those products. Information in this section of the report 

comes from many different sources, all of which are cited in the text. 

Cell Phones 

Scarborough Research, the nation’s leader in local, regional, and national consumer information, 

estimates that “almost two-thirds (62 percent) of American adults own a cell phone” (McFarland, 

2002). Most cell phones are used to make telephone calls, surf the Web, and receive messages. 

Cell phones are invaluable in an emergency. They have helped save people’s lives, whether 

assisting in locating people involved in an airplane crash or enabling people to call for help when 

faced with a medical emergency. Many people use them for long-distance calling instead of 

signing up for a long-distance plan through their home telephone service provider. Cell phones 

give people the ability to surf the Web without a computer, take a photo and immediately send it 

to someone else, and receive messages, stock quotes, news, and other information anywhere, 

anytime. 
67 

Market Forces Creating Demand for More Accessibly Designed Cell Phones 

1. The desire on the part of the E&IT industry to achieve competitive advantage and increase 

profits. Desire on the part of consumers to purchase the most convenient and easy-to-use 

cell phone. Examples of these market forces include the following innovations: 

— Easier data entry: The desire to enter text into a cell phone easily was a major 

market driver in making cell phones more accessible. Until recently, entering a 

single character (i.e., A–Z) into a cell phone required up to six key presses. For 

example, you would have to press the #2 key six times and then the #key to select 

and enter a capital C. Here is, in order, what each key press would do: First press = 

a, second press = A, third press = b, fourth press = B, fifth press = c, sixth press = 

C, and # enters the character. Consumer demand led to the development of new cell 

phone keypads. For example, the FastapTM keypad is an extremely simple, intuitive, 

and powerful computer interface that fits in a small mobile phone. Modern phones 

offer a lot more than just voice communication. Mobile phones are data devices 

with the ability to write messages, collect and store information, and buy things. 

They are essentially networked computer terminals. Alphanumeric keypads make a 

cell phone easier to use for people with low vision (Fastap, n.d.). 

— Voice dialing: Voice dialing is a common feature on most digital cell phones. The 

technology has gone even further. iVoice, Inc., recently released a new hands-free 

feature to its Speech Enabled Auto Attendant that allows outbound callers to speak 

the number they wish to dial (iVoice, Inc., 2003). 

— Talking caller ID: Most people would like to know who is calling them before 

answering their cell phone, especially if they are occupied in an eyes-busy, handsbusy, environment. Lucent Technologies offers talking caller ID in support of 

helping wireless network operators rapidly deploy new features and generate new 

revenues (Cambridge Telecom Report, 2000). 
68 

— Automatic ring mode adjustment: A cell phone that is aware of where it is and 

adjusts its ring mode accordingly is being patented by IBM’s research lab in 

Winchester, MA. The new system uses global positioning system (GPS) technology 

to switch the phone’s ringing modes. In “region definition” mode, the phone stores 

its current GPS coordinates while the owner tells it whether to ring loudly, quietly, 

vibrate, or divert to an answering service. This can be done separately in several 

locations—home, work, church, and your favorite bar, for example—so the phone 

knows exactly how to behave at that location. (Note: The cell phone industry is 

already building GPS receivers into handsets so that emergency services can locate 

callers.) 

— Large fonts: Samsung’s SCH-T300 can display numbers in a large font. (Samsung, 

n.d.). 

— Bluetooth communications: Bluetooth comes built into products consumers use 

every day—like cell phones, headsets, PDAs, laptops, and, yes, even cars—and it 

allows devices that have Bluetooth built in to “talk” to each other without a wire 

connection. If a cell phone and headset both have Bluetooth built in, the user could 

put the headset on and leave the phone in his or her pocket. Bluetooth can also 

connect a car to the driver’s Bluetooth-enabled cell phone. The phone in this 

scenario connects to the car’s audio system, and dash-installed controls take over 

the function of the phone. Calls are made and retrieved using voice recognition, and 

the user never has to touch the actual phone (Auto Channel, 2003). 

2. The desire on the part of the E&IT industry to comply with federal laws. The desire on the 

part of consumers to be safe, get help in case of an emergency, and maintain contact with 

young children, aging parents with Alzheimer’s, or others at risk. Examples of these 

market forces include the following advancements: 
69 

— Global positioning system feature: Facing a federal requirement to provide 

location data to 911 dispatch centers by 2005, cell phone carriers have developed a 

GPS system to track wireless calls. A special chip in the phone times the signals 

from three satellites to calculate its position, which is relayed to the nearest 911 

center (LaGeese, 2003). GPS-equipped cell phones can also be used to maintain 

contact with young children, aging parents with Alzheimer’s, or others at risk, or to 

find out if your children are where they say they are when you call them. 

— Cellular phone with built-in optical projector for display of data: A patent for a 

cellular phone that is compact in size and weight includes a mechanism for 

displaying received wireless data in its original page format, as sent from the 

original source. This allows for viewing each original page as a whole page, rather 

than as a series of partial pages. The phone also allows the display of received 

wireless visual data with characters in their true original size, thus allowing for ease 

of reading and use. 

Market Forces Reducing the Accessibility of Cell Phones 

1. The desire on the part of the E&IT industry to achieve competitive advantage through 

innovation. Desire on the part of consumers to purchase distinctive cell phones suited to a 

personal sense of style. Examples include the following: 

— Miniaturization. Many cellular phones are being designed to be more portable and 

less obtrusive. As a result, keypads have shrunk, making it difficult for users who 

are blind to tactilely identify keys. In addition, users without fine motor control 

skills have difficulty activating the smaller keys. 

— Nonstandard keypads. Some stylized phones have keypads arranged in a circular 

pattern or other nonstandard layout. Users who are blind find it difficult to identify 

the keypad keys because they are not arranged in the familiar layout.
70 

2. The desire on the part of the E&IT industry to achieve competitive advantage and increase 

profits. Desire on the part of consumers to purchase the most advanced, feature-rich cell 

phone. The following is an example: 

— Smart phones. There is a trend to integrate PDA functionality with cellular phones. 

The complexity of the user interface and the dexterity required to operate the smart 

phone may place the phone beyond the capabilities of some users.

ATM Machines 

The classic definition of an automated teller machine (ATM) is an unattended machine, external 

to a bank, that dispenses money when a personal coded card is used. There are more than 200 

million users of ATMs in the United States. Billions of transactions are processed in the United 

States yearly. According to Grant Thornton LLP, there are 350,000 ATMs in the United States; 

250,000 are in nonbank locations, and 150,000 of these ATMs are owned by nonfinancial 

companies (Grant Thornton, 2003). 

ATMs have revolutionized the way most people do their banking. Customers can take care of 

financial transactions at any time of the day or night without having to go to a bank building per 

se, since ATMs are readily available at supermarkets, convenience stores, shopping malls, hotels, 

and many other public places. ATMs are used for cash withdrawals, transferring money between 

accounts, looking up account balances, depositing cash and checks, purchasing money orders, 

obtaining credit-card advances, and purchasing stamps. Talking ATMs have enabled people who 

are blind to experience the convenience of anytime banking. In the future, ATMs will be able to 

send person-to-person “cash” payments, cash checks, deposit cash immediately into your 

account, and be accessed by a cell phone or PDA. 

Market Forces Creating Demand for More Accessibly Designed ATMs 

1. The desire on the part of the E&IT industry to comply with U.S. and international laws. 

Examples of legal requirements that have prompted accessibility include the following: 
71 

— United States: ADA Accessibility Guidelines for Buildings and Facilities 

(ADAAG) as amended through September 2002: Section 4.34 Automated Teller 

Machines [4.34.5] Equipment for Persons with Vision Impairments states, 

“Instructions and all information for use shall be made accessible to and 

independently usable by persons with vision impairments (Access Board, n.d.). 

— United States: Section 707 of ICC/ANSI A117.1 Standard on Accessible and 

Usable Buildings and Facilities is entitled “Automatic Teller Machines (ATMs) and 

Fare Machines.” Although the 2003 version of this document has not yet been 

finalized or published, the following is an example of preliminary wording (in part): 

“Speech Output Machines shall be speech enabled. Operating instructions and 

orientation, visible transaction prompts, user input verification, error messages, and 

all displayed information for full use shall be accessible to and independently usable 

by individuals with vision impairments. Speech shall be delivered through a 

mechanism that is readily available to all users including, but not limited to, an 

industry standard connector or a telephone handset. Speech shall be recorded or 

digitized human, or synthesized” (International Code Council, n.d.). 

— Australia: The Australian Bankers’ Association (ABA), the Human Rights and 

Equal Opportunity Commission (HREOC), and the Accessible E-Commerce Forum 

worked with representatives from member banks, other financial institutions, 

community groups, suppliers and retailers, and the National Office for the 

Information Economy’s (NOIE) Access Branch to develop a set of voluntary 

industry standards to improve the accessibility of electronic banking (Australian 

Bankers’ Association, n.d.). 

— United Kingdom: Access to ATMs: UK Design Guidelines provides researchbased information to ensure that ATMs meet the needs of all users. The guidelines 

are based on ergonomic research and testing, offering design principles and 

guidance for those who design, manufacture, install, and maintain ATMs. The 2002 
72 

edition reflects and builds on the experience gained from advances in the design of 

ATMs and the practical application of the 1999 edition (Feeney, 2003). 

2. The desire on the part of the United Nations and the World Bank to reduce poverty in 

developing countries by helping those countries grow and prosper. The desire on the part 

of the E&IT industry to achieve competitive advantage and generate revenue from 

emerging markets. The desire on the part of consumers in developing countries to have the 

basic necessities of life. Examples of these market forces at work include the following: 

— The unbanked: ATMs can be a channel for the flow of money that is being kept 

“under the pillows” of billions of people living in emerging market areas who do 

not have a bank account. There also are about 11 million consumers in the United 

States who do not have bank accounts (Cipherwar.com, 2000). Delton Yuen, NCR’s 

vice president, Financial Solutions Division, Asia-Pacific, stated, “If every 

household saves money in pillowcases or a cookie jar, the economic system is going 

to have less money to go around to fund capital investments. For countries to ensure 

that the economy grows, they need capital. And when the money within a country is 

not channeled into the financial system or banking system, that capital is circulating 

less and less” (McGill, 2002). 

— Talking ATMs: Although these devices are being developed for people who are 

blind, they can also accommodate people who cannot read. There are 440 million 

people who cannot read living in the top five emerging markets. 

Personal Digital Assistants 

PDAs store, analyze, and retrieve needed information on demand, anytime and anywhere. A PDA 

can be used as a calculator, address book, calendar, memo pad, expense tracker, and an electronic 

information storage device. They serve as portable personal computers and augmentative 

communications devices. Some of the many industries using PDAs are health care, 
73 

building/construction, engineering, restaurant, and sales. PDAs are useful for dispatching crews 

and managing mobile personnel. While they are particularly useful in the business world, they are 

excellent memory aids for individuals. Information can be transferred between the PDA and a 

personal computer, providing portable access to information. PDAs are also being used for 

leisure-time activities. They can provide golfers with distance measurements and scorecards. It is 

also possible to watch a movie on your PDA. Gartner Group predicted worldwide PDA revenue 

would be $3.53 billion in 2003, or approximately 10 million new units shipped worldwide 

(Directions Magazine, 2003a). 

Market Forces Creating Demand for More Accessibly Designed PDAs 

The primary force is the desire to minimize the cost of doing business. PDAs are now replacing 

what were once expensive, proprietary, industry-specific telecommunication devices. Another 

force is the desire of consumers to maximize the ease of use of PDAs in eyes-busy, hands-busy 

environments. Professionals using PDAs in eyes-busy, hands-busy environments are likely to 

find PDAs more user-friendly and easier to use if they are equipped with voice recognition and 

text-to-speech technologies. Examples of improvements resulting from these market forces 

include the following: 

• Health care: Wireless-equipped PDAs have been embraced by the medical community to 

access medical records, write electronic prescriptions, and use as a portable nursing-unit 

terminal. PDAs are also replacing high-cost medical devices. CardioNet developed a 

proprietary PDA-type electrocardiogram monitoring device connected to electrodes on a 

patient’s chest. The PDA receives signals from the electrodes and transmits data to the 

PDA device (CardioNet, n.d.). 

• Public safety: Field officers use Internet-ready PDAs to access remote records from 

management databases. This helps to improve the efficiency of creating incident reports. It 

also optimizes the transfer of queries and responses (Directions Magazine, 2003b). 

• Workforce management: Cobb EMC is an electric cooperative serving more than 

170,000 customers in five metropolitan Atlanta counties. Cobb EMC uses PDAs to 
74 

dispatch crews. The cooperative claims that this has helped to streamline work processes 

and increase service reliability (Directions Magazine, 2003c). 

• Military: Applications and devices developed for use by the military include the V3 

Rugged PDA; industry-leading handheld capabilities; integrated Bluetooth for wireless 

link to phones, printers, and PCs; TFT screen with 64K colors; Windows CE-based Pocket 

PC with IBM ViaVoice, MS Pocket Office, and other applications (General Dynamics, 

n.d.). 

• Multimedia industry: Pocket PC Films, in Sherman Oaks, California, uses PDA 

technology to distribute video content for Pocket PC and Palm OS devices. Film fans can 

buy CD-ROM titles, load them on their computers, and sync them into their handheld 

devices. Pocket PC Films now distributes 25,000 titles. The huge potential market to use 

PDAs to view high-quality multimedia has led manufactures to equip them with highquality audio capabilities. For more information, access the following Web site: 

http://store.yahoo.com/pocketpcfilms/xsxtremwinsp.html. 

• Assistive technology industry: In order to reduce the cost of their products, several AT 

vendors are replacing their proprietary augmentative communications device hardware 

with PDAs. The touchscreen, text-to-speech, and voice recognition capabilities of PDAs 

make this possible. Two vendors in particular are pioneering this trend. They are Enkidu 

Research with its Palmtop Portable and Saltillo with its ChatPC. 

• Simplified writing interfaces: Written Chinese has 6,000 characters. A computer 

keyboard has 47 character keys. Chinese data entry is so difficult that there is an entire 

industry of people who make their living as typists. Someone who is really good with the 

Chinese version of Microsoft Word (which takes the simplified “pinyin” transliteration 

and guesses at the character the writer means) can type maybe 20 words a minute. Until, 

that is, PDA manufacturers started to equip PDAs with better chips and faster algorithms. 

Voice interfaces are becoming so powerful that the Mandarin PDA-based language 

recognizer can distinguish about 40,000 words and still not tax the memory or processing 

power of the PDA (Kumagai, n.d.).
75 

Televisions 

A television is technically described as a telecommunication system that receives, decodes, and 

displays images and plays audio of objects, stationary or moving, broadcast from a separate 

transmitter. Television is the medium that entertains, informs, and educates; it can also serve as a 

companion to people who, because of circumstances beyond their control, are confined to their 

homes. Traditionally, people have used TVs to get news reports and watch movies, sports events, 

and sitcoms. Cable TV is a telecommunication system that receives, decodes, and displays 

images and plays audio of objects, stationary or moving, broadcast over cable directly to the 

receiver. With cable TV, people have many more options of channels to watch, some devoted to 

a particular subject of interest, such as HGTV for the home and garden enthusiast or news 

broadcasts 24 hours a day. In addition, movies can be purchased on a pay-per-view basis. 

Technologically advanced TV systems allow viewers to play interactive games, take a distance 

learning course, send instant messages, surf the Web, send an email, and shop for and purchase 

products, including movie tickets and CDs from talk shows and concerts. 

HDTV (high-definition television) is a system that has more than the usual number of lines per 

frame, resulting in pictures that show more detail. Interactive television (iTV) provides richer 

entertainment, interaction, and more information pertaining to the shows, props, and people 

involved in its creation. In a sense, it combines traditional TV viewing with the interactivity 

enjoyed by those communicating through a network, such as the Internet. According to Disney, 

its iTV program, “Disney Active Portal on Sky Digital,” is a major step forward. It offers Disney 

more flexibility and control of its interactivity in terms of design and dynamic update. The new 

application empowers kids, giving them the opportunity to participate in shows while still being 

able to watch the action on screen. 

Market Forces Creating Demand for More Accessibly Designed Televisions 

1. The desire on the part of the E&IT industry to comply with U.S. laws. Examples of how 

these market forces resulted in enhanced products and services include the following:
76 

— Emergency programming: FCC rules require broadcasters and cable operators to 

make local emergency information accessible to persons who are deaf or hard of 

hearing and to persons who are blind or have visual disabilities. This means that 

emergency information must be provided both orally and in a visual format. Video 

programming distributors include broadcasters, cable operators, satellite television 

services (such as DirecTV and the Dish Network), and other multichannel video 

programming distributors (FCC, 1999). 

— Captioning: Congress first instituted the requirement that television receivers 

contain circuitry designed to decode and display closed-captioning. As of July 1993, 

the FCC required that all analog television sets with screens 13 inches or larger sold 

in the United States contain built-in decoder circuitry that allows viewers to display 

closed-captions. Beginning July 1, 2002, the FCC also required that digital 

television (DTV) receivers include closed-caption display capability. As part of the 

Telecommunications Act of 1996, Congress instructed the FCC to require video 

program distributors (cable operators, broadcasters, satellite distributors, and other 

multichannel video programming distributors) to phase in closed-captioning of their 

television programs. In 1997, the FCC implemented rules to provide a transition 

schedule for video program distributors to follow in providing more captioned 

programming. The rules require that distributors provide an increasing amount of 

captioned programming according to a set schedule. All English language 

programming prepared or formatted for display on analog television and first shown 

on or after January 1, 1998, as well as programming prepared or formatted for 

display on digital television that was first published or exhibited after July 1, 2002, 

is considered “new programming” and must be captioned according to benchmarks 

set by the FCC. The following benchmarks establish how much new programming 

must be captioned each calendar quarter: 

> January 1, 2000, to December 31, 2001: 450 hours of programming per 

channel per quarter 
77 

> January 1, 2002, to December 31, 2003: 900 hours of programming per 

channel per quarter 

> January 1, 2004, to December 31, 2005: 1350 hours of programming per 

channel per quarter 

> January 1, 2006, and thereafter: 100 percent of all programming, with some 

exemptions 

— Digital television TV mandate: The FCC has issued a ruling that requires DTV 

licensees to simulcast 50 percent of the video programming of their analog channel 

on their DTV channel by April 1, 2003. This requirement increases to 75 percent on 

April 1, 2004, and 100 percent on April 1, 2005. The simulcasting requirement was 

intended to ensure that consumers enjoy continuity of free, over-the-air video 

programming service when the analog spectrum is reclaimed at the end of the 

transition. With digital transmission, a TV broadcaster will be able to 

> Send multiple programming at the same time over the same channel 

> Improve the quality of the transmission with options not available with 

analog transmission 

> Offer digital data services, which will allow the TV broadcaster to send out 

virtual newspapers and other types of services directly to your TV 

2. The desire on the part of the E&IT industry to achieve competitive advantage and generate 

revenue. 

— Word-search videos using closed-captions: The need to produce just-in-time 

news stories used to cause problems for broadcasters. When a major event occurred, 

news programs would have to scramble around looking for some footage that 

supported the subject of the news story. For example, when an entertainer passes 

away, news programs might show a clip or two of the last interview with that 

individual. It could be very time-consuming to search through logs and libraries to 

find the appropriate footage. That is, until broadcasters gained the ability to both 
78 

store digital copies of their broadcasts on computers and conduct word searches on 

them using the captions. Captioning their programming has enabled many news 

broadcasters to achieve a competitive advantage in the marketplace by being the 

first to announce a breaking event with the appropriate video content. 

Voice Recognition 

Voice recognition technology (VRT) by itself is neither accessible nor inaccessible. It is the 

integration of VRT into other products and services that can help to make those products and 

services more accessible and usable. VRT, also referred to as speech recognition technology 

(SRT), provides telecommunications and computing devices with the ability to recognize and 

carry out voice commands or take dictation. VRT is generally identified as either being speaker 

dependent or speaker independent. Speaker-dependent systems recognize only a particular 

individual’s voice and are often used in dictation products. Speaker-independent systems can 

recognize multiple voices. Speaker-dependent systems are better able to process an individual’s 

quirky speech patterns, but they can take a significant amount of time to train. There are also 

continuous versus discrete speech recognition systems, in which, respectively, the user can talk at 

a normal rate or is required to talk with pauses between words. 

Voice recognition enhances quality of life and independence for many people. Users do not have 

to use their hands when operating a telecommunications device that incorporates VRT. This 

technology is also useful in a hands-busy environment, such as when a radiologist analyzes xrays by holding them up to the light and verbally dictates the results to a computer. It is also 

helpful when operating small devices such as cell phones and PDAs. 

Many industries are adding VRT to their communication systems as a way to lower operational 

expenses by cutting the costs of call handling. In 1996, Charles Schwab became the first major 

consumer company to offer voice recognition for its customers to get stock quotes and other 

information at the customer’s convenience. In addition to brokerage houses, the banking, health 
79 

care, law enforcement, travel, transportation, and entertainment industries, to name just a few, are 

also incorporating VRT. 

The Market Forces Creating Demand for More Accessible and Usable VRT 

1. The desire on the part of the E&IT industry to achieve competitive advantage. The desire 

of consumers to purchase easy-to-use and convenient products. The following is an 

example of an innovation resulting from these market forces: 

— Voice dialing: People trying to operate a cell phone in an eyes-busy, hands-busy, 

environment might experience difficulty. This market factor led to the incorporation 

of VRT into cell phones and the development of hands-free accessories for cell 

phones. People with upper mobility disabilities, people with low vision, and many 

senior citizens can also benefit from voice dialing. Voice dialing is a common 

feature on most digital cell phones. PCS-Direct, an Internet-based phone store, 

carries nine different cell phones equipped with voice dialing (PCS-Direct, n.d.). 

2. The desire on the part of the E&IT industry to reduce cost and employee turnover. The 

desire on the part of call-center agents to make their jobs as pleasant and nonrepetitive as 

possible. Examples of innovations resulting from these market forces include the 

following: 

— Interactive voice response (IVR) systems: To date, companies have attempted to 

handle interactions with their customers using touch-tone IVR systems, but 

customers are not entirely satisfied with this form of interaction. Touch-tone 

interfaces are both frustrating and ineffective. In order to support customer 

interactions more quickly and efficiently, companies are beginning to move to 

speech recognition systems. Many call centers use systems that combine digitized 

speech and speech recognition. Using IVR systems costs much less than using callcenter agents. Thanks to IVR, customer requests can be handled with little human 

intervention. Call-center agents can then become more productive doing other 
80 

things. Another benefit of IVR is that agents no longer need to repeat the same 

information to each caller, over and over again. This tends to increase employee 

satisfaction and reduce turnover. “Following this, the market is believed to be on its 

way to being worth $43 billion by 2007” (Telecomworldwire, 2002). 

— Web-based voice portals: VRTs can be used to enable people to access a Web site 

using a telephone. Extending access to a commercial Web site by telephone can 

attract new customers who may not be in a position to use a computer connected to 

the Internet. There are many instances of this use. For example— 

> People operating from within low-bandwidth infrastructures 

> People who never learned to read 

> Mobile professionals who need quick access to information while on the go 

> Senior citizens who recognize the value of the Internet but are simply more 

comfortable using a telephone 

> People who are blind or visually impaired 

> People who are traveling and don’t have access to their PCs 

— VoiceXML standards: The VoiceXML Forum is an industry organization 

established to promote VoiceXML as the universal standard for speech-enabled 

Web applications. The VXML Forum “aims to drive the market for voice- and 

phone-enabled Internet access by promoting a standard specification for VXML, a 

computer language used to create Web content and services that can be accessed by 

phone.” Following standards breeds success and enhances the compatibility and 

interoperability of your system with others. Systems that have been developed 

according to standards are easier and less expensive to maintain. 

— Dictation, voice recognition, and transcription: Many professions require the 

transcription of voice-recorded data. These professions include law enforcement, 

medicine, and the legal profession. The financial pressures to drive transcription 
81 

costs down and productivity rates up helped to fuel the $8 billion speech 

recognition industry. 

Distance Learning 

“Distance learning is used in all areas of education, including pre-K through grade 12, higher 

education, home school education, continuing education, corporate training, military and 

government training, and telemedicine” (USDLA, n.d.). Students participating in distance 

learning can use the learning style of their choice. Audio-based classes can consist of recordings, 

synthesized speech, and audio-conferencing. Video-based learning includes video and 

videoconferencing and Webcasting. Print-centered techniques include online texts, books, and 

handouts. Employers also benefit when their employees participate in distance learning courses. 

“Travel expenses are reduced or eliminated, there is increased productivity as employees don’t 

need to leave the office for extended periods of time, teams are brought together without 

restrictions on schedule or location, and it provides the ability to reach geographically dispersed 

populations with a uniform and consistent approach” (Thunderbird, n.d.). Also, higher education 

facilities are finding that distance learning is less expensive to support than traditional classroom 

learning. 

The types of technologies for implementing distance learning include “two-way video with twoway audio (two-way interactive video), one-way video with two-way audio, one-way live video, 

one-way prerecorded video (including prerecorded videotapes provided to students and TV 

broadcast and cable transmission using prerecorded video), two-way audio transmission (e.g., 

audio/phone conferencing), one-way audio transmission (including radio broadcast and 

prerecorded audiotapes provided to students), Internet courses using synchronous (i.e., 

simultaneous or real-time) computer-based instruction (e.g., interactive computer conferencing or 

Interactive Relay Chat), Internet courses using asynchronous (i.e., not simultaneous) computerbased instruction (e.g., e-mail, listservs, and most World Wide Web-based courses), CD-ROM, 

multimode packages (i.e., a mix of technologies that cannot be assigned to a primary mode), and 

other technologies” (Tabs, 2003, p. 11). Online education is now offered at more than 56 percent 
82 

of the nation’s two- and four-year colleges and universities, with distance learning beginning to 

extend to high schools and lower. 

Market Forces Creating Demand for More Accessibly Designed Distance-Learning Technology 

1. The World Bank and its members want to reduce poverty and strengthen emerging 

economies: American businesses have invested more than $250 billion in the top 15 

emerging markets with the sincere belief that they will yield significant returns on their 

investment. Distance education is a critical success factor in human development in 

emerging markets. Some call it the foundation of business success in emerging markets. 

Education provides the high-level skills necessary to establish a growing, self-sustaining 

E&IT labor market. It can also provide the training required by engineers, doctors, 

teachers, nurses, business entrepreneurs, social scientists, and many other professionals 

critical to the success of maturing a developing economy. 

The information infrastructures supporting a majority of distance learning activities 

in emerging markets are low-bandwidth environments. Many of their resources 

will need to operate over wireless devices. This means that the content will need to 

be developed in an accessible manner. 

Billions of workers live in emerging markets. They are the individuals who 

ultimately benefit from an effective distance-learning infrastructure. However, in 

the top five emerging markets, there are 440 million people who can’t read. In 

order to benefit from distance learning, the materials need to be provided in 

alternate formats. 

2. Corporations want to educate their employees more effectively and less expensively: 

Distance learning produces a 60 percent faster learning curve than traditional instruction. 

More than 6,000 U.S. companies offered distance learning courses to their employees in 

2003, up from 391 in 1998. The U.S. corporate skills business training market is projected 
83 

to reach $18.3 billion by 2006 (compounded annual growth rate [CAGR] of 13.3 percent). 

Worldwide, the distance-learning IT education and training market is projected to reach 

$28.6 billion by 2006 (CAGR of 7.1 percent). 

3. Universities want to reduce costs, increase enrollment, and still offer a quality 

education. Conservatively, there are 45 million users of online higher education. By 2025, 

the global demand for online education is forecast to reach 160 million students. For every 

foreign student studying in the United States, there are three to five students who would 

access U.S. education online if they could (Moe, 2002). 

4. The law: Many countries have policies relating to Web accessibility. They are Australia, 

Canada, Denmark, Finland, France, Germany, Hong Kong, India, Ireland, Italy, Japan, 

New Zealand, Portugal, Spain, the United Kingdom, and the United States of America. 

The European Union also has Web-access policies. Distance learning usually takes place 

via the Web (Web Accessibility Initiative, n.d.). Several countries have detailed policies 

that specifically apply to education, as described here: 

— Australia has a Disability Discrimination Act (1992) that applies to education. 

— Canada’s Charter of Rights and Freedoms guarantees the basic rights and freedoms 

important to Canada as a free and democratic society. The Canadian Government 

has also established a Common Look and Feel for Canadian Government Web sites, 

which includes accessibility provisions. 

— The UK’s Special Educational Needs and Disability Act took effect on September 

1, 2002. The Act removes the previous exemption of education from the Disability 

Discrimination Act (1995), ensuring that discrimination against students with 

disabilities will be unlawful. Institutions incurred additional responsibilities in 

2003, with the final sections of legislation coming into effect in 2005. 
84 

The following U.S. policies make accessibility a requirement for distance learning: 

— ADA and section 504: Two federal laws govern accessibility of education: Title II 

of the ADA and section 504 of the Rehabilitation Act of 1973 (as amended in 

1998). All elementary, secondary, and postsecondary educational institutions are 

regulated under these laws. A useful legal analysis of the requirements is provided 

in the California Community Colleges’ Distance Education Access Guidelines 

(California Community College, 1999). 

— Section 508: To ensure that its technology is accessible to its own employees and to 

the public, the Federal Government has created regulations based on section 508 of 

the Rehabilitation Act that require that E&IT developed, procured, maintained, or 

used by the Federal Government be accessible to people with disabilities. These 

regulations apply to all federal purchases of technology. Requirements in section 

508 may also affect state colleges and universities, pending policy decisions from 

the Department of Education’s Office of Civil Rights. 

— California higher education requirements: The California Community College 

system has released Distance Education Access Guidelines and Alternate Media 

Access Guidelines. The Alternate Media Access guidelines serve as a guide for the 

implementation of California Law AB422, requiring publishers to provide 

textbooks in electronic format to the three systems of higher education in California 

(the University of California, the California State University, and the California 

Community Colleges). The Distance Education Access Guidelines include a 

summary of legal requirements as well as access guidelines for specific modes of 

distance education instructional delivery. These documents and other resources are 

available from the High Tech Center Training Unit of the California Community 

Colleges. 
85 

— Texas K-12 textbook adoptions: Texas has for several years been studying the issue 

of access to electronic books and educational software for students with disabilities. 

Two reports, one issued in 1997 and one in 1999, provide information on how 

educational materials can be made accessible. Texas requires publishers to provide 

electronic files for adopted print materials and is in the process of incorporating the 

federal section 508 requirements as an optional part of its adoption process for 

interactive educational software and electronic textbooks. Further information about 

Texas textbook accessibility is available from the Texas School for the Blind and 

Visually Impaired. 
86 
87 

III. Product Analysis 

This section documents the primary findings of a detailed product line analysis for each of the 

product lines selected for study. The purpose of this research is to document accessibility issues 

that prevent people with disabilities from fully accessing the selected products and to document 

accessibility features that are either currently offered or potentially could be offered by 

manufacturers. For a more detailed discussion of the product line analysis, including a discussion 

of the product lines broken down according to different disability types, consult the appendix to 

the online version of this report at http://www.ncd.gov. 

The accessibility of a given product is based primarily on a determination of access to core 

features of the product, with some consideration for additional features that enhance the product 

but are not necessary for use of the product for its primary purpose. For this research, both 

accessible and UD features are considered. Accessible design is defined as the design of products 

that makes them accessible to people with disabilities without requiring the purchase of 

additional equipment or specialized training. Universal design, or design for inclusion, is the 

design of products and environments to make them usable by all people, to the greatest extent 

possible, without the need for adaptation or specialized design. A disability is considered any 

restriction or lack of ability, resulting from an impairment, to perform an activity in the manner 

or within the range of activity considered standard for a human being. 

Under section 508, each federal department or agency, including the U.S. Postal Service, when 

developing, procuring, maintaining, or using E&IT, must ensure that the E&IT allows— 

• Federal employees with disabilities to have access to and use of information and data 

comparable to the access to and use of information and data by federal employees who do 

not have disabilities. 

• Individuals with disabilities who are members of the public seeking information or 

services from a federal department or agency to have access to and use of information and 
88 

data comparable to the access to and use of information and data by members of the public 

who are not disabled. 

Section 508 applies without regard to the medium of the technology. However, section 508 

permits exceptions if an undue burden would be imposed upon the agency or department. 

In general, section 508 requires that products be— 

• Usable by people who are blind 

• Usable by people with low vision without relying on audio 

• Usable with little or no color perception 

• Usable by people who are deaf 

• Usable by people with limited hearing 

• Usable by people with limited manual dexterity, reach, and/or strength 

• Usable with time-dependent controls or displays 

• Usable by people without speech 

• Usable by people with limited cognitive or memory abilities 

• Usable by people with language or learning disabilities 

• Available with audio cutoff (private listening) 

• Designed to prevent visually induced seizures 

• Available with biometric identification/activation bypassing 

• Usable by people with upper extremity prosthetics 

• Hearing aid compatible 

• Usable from a wheelchair or similar personal vehicle 
89 

Also, section 508 requires compatibility with peripheral devices and that accessibility of 

information, documentation, labeling, and support be provided to customers. Section 508 

provides guidelines for software applications and operating systems, Web-based Internet 

information and applications, telecommunications products, video and multimedia products, selfcontained closed products, desktop and portable computers, and functional performance criteria. 

Product designers should consider features that facilitate the following capabilities: Users with 

visual impairments need to be able to identify, differentiate, and operate all controls and displays, 

without accidentally activating undesired controls; they should be able to detect control 

activation and outcome; they should not be required to depend on color to differentiate control 

and display states to successfully use the device. Users with hearing impairments need to be able 

to acquire information via a nonauditory format, detect control activation and outcome, and use 

assistive listening devices. Users with mobility impairments need to be able to view, reach, and 

activate all controls and displays; manipulate levers, drawers, panels, and all controls; activate 

controls without accidentally activating adjacent controls; activate controls with the use of an 

assistive device; and have sufficient time to enter commands. Finally, users with cognitive 

disabilities need to be able to understand the controls and displays and have sufficient time to 

enter commands. 

Product Line Assessment Methodology 

The product line assessment provides an identification of accessibility issues within each product 

line and an assessment of accessibility features designed to address specific issues. The 

assessment of accessibility issues involves the calculation of an “impact score” for each issue and 

target population. The impact score is an estimation of the affect of a particular accessibility issue 

on a particular target population. The score is calculated at the task level based on two separate 

dimensions. The first dimension, task priority, is defined as a measure of task importance. Highpriority tasks are those that are essential to the device, while low-priority tasks are defined as 

those that are not essential or would not be expected to be performed by the end-user. The second 

dimension, accessibility, is defined as an estimation of the ability of a user with a given set of 
90 

functional capabilities and limitations to satisfactorily complete a given task. Accessibility is 

classified at three levels: little or no difficulty, some difficulty, or great difficulty. After impact 

scores are calculated from the priority and accessibility level for each task, they are used to assign 

an accessibility grade to each product line for each target population. 

Product Line Assessments 

The sections below describe the results of the product line assessments. Each product line section 

is organized as follows: background, accessibility features, compliance with government 

regulations, and conclusions. 

Part of the product line assessment included conducting a task-based accessibility analysis for 

each product line. A detailed discussion of this task-based accessibility analysis is available in 

the appendix to the online version of this report. The task-based accessibility analysis consists of 

identifying the core functionality (tasks) for the product line, identifying the priority level for 

each task, and assigning a task-accessibility estimation for each task. The task-accessibility score 

is derived from expert evaluations, a Georgia Tech survey on universal design, and user testing. 

The combination of the task-priority levels and the task-accessibility estimation is used to 

calculate an impact score, which is then used to create an accessibility grade for the product line. 

These accessibility grades appear at the conclusion of this section of the report. 

Please note that reference herein to any specific commercial product, process, or service by trade 

name, trademark, manufacturer, or otherwise does not constitute or imply endorsement by the 

National Council on Disability. 

ATM Machines 

Despite their popularity and capabilities, ATMs are not accessible by everyone. People who have 

visual disabilities may have difficulty reading the display and providing accurate inputs. People 

who have a mobility disability may have difficulty approaching the device, reaching the controls, 

and reading the display. People who have cognitive disabilities may have difficulty reading the 
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display and understanding the options. Each of these challenges can be overcome, to some 

extent, through proper design. 

Task-Based Accessibility Analysis 

The core functionality considered necessary to effectively use an ATM consists of the following: 

• Locating an ATM 

• Locating an accessible ATM 

• Inserting the bank card 

• Remembering a personal identification number (PIN) 

• Entering a PIN number 

• Making a cash withdrawal 

• Making a deposit 

• Checking account balances 

• Transferring money 

• Printing a statement 

• Retrieving a receipt 

• Retrieving the bank card 

• Reading a receipt 

People may have difficulty accomplishing these basic tasks, depending on functional limitations 

resulting in an impairment, environmental or situational factors that create barriers, or the design 

of the ATM. Accessibility issues for the disability population were identified, along with an 

impact rating for each issue. The disability populations include people who have an impairment 

resulting from environmental or situational factors. The issues identified and impact ratings 
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assigned for each disability group can be found in the appendix to the online version of this 

report. 

Accessibility Features 

A review of various ATM manufacturers’ marketing data produced a number of features 

identified as accessible design components. Each of these components is listed, along with a 

description of the component and an assessment of the usefulness of the feature for disability 

groups. Some of these features may have been designed with a particular disability population in 

mind; others may have been designed simply as desirable features. In many cases, the 

accessibility features benefit or are used by a variety of people, and they may be considered to 

provide universal access. 

Large sunlight-readable color display: ATM displays can be very difficult for 

the average person to use simply because of lighting issues, natural or otherwise. 

Sunlight often creates glare on electronic displays, sometimes making it impossible 

to even discern that any text appears on the display. In some cases this can be 

overcome by shifting the viewing orientation, but this is not an option for all 

people. Sunlight-readable displays can increase accessibility by preventing glare. 

With the exception of people who are blind, this will have a medium impact for all 

users and will help solve the problem of not being able to receive visual 

information. 

Touchscreen display: Touchscreens provide the manufacturer with a method of 

creating a dynamic display, providing more information in less space. 

Touchscreens can be designed with large, high-contrast buttons or icons that can 

provide an alternative solution for those with partial visual impairment or motor 

disabilities. Selection via large touch areas on the screen may be preferable to some 

users as an alternative to keyboard or function key input. Additionally, for users 

with complete vision loss, touchscreen functions can be mapped—or directed—
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down to the tactile keyboard. But unless the functions are mapped in this way, or 

an alternative audio interface is provided, touchscreens are not accessible to people 

who are blind and will have a negative impact. If keyboard mapping is 

implemented or an alternative audio interface is provided, touchscreens will have 

no impact on people who are blind. They will have a medium impact for those with 

low vision and mobility impairments if implemented with large touch areas and 

text or graphics. If good graphical metaphors are used, touchscreens will have a 

medium positive impact for the cognitively disabled. They will help solve the 

problem of making inputs and possibly of receiving and interpreting visual 

information. 

Talking ATM: A talking ATM is one with voice displays. Talking ATMs are 

useful in circumstances in which it is difficult to read the text display because of a 

visual impairment, low reading ability, significant glare on the screen, or possibly 

having to view the screen from a seated position. Inclusion in design will have a 

high impact for those who are blind, a medium impact for those with low vision or 

cognitive disability, and a low impact for all other users. It will help solve the 

problem of receiving and interpreting visual information. 

Private headphone jacks for talking ATM: Voice instructions can be provided 

publicly, or privately through the use of headphones. Voice instructions can help 

guide the user through the transaction and provide information such as feedback on 

keypress entries and account balance (things that would typically be presented 

visually). This would allow a person who is blind to perform an ATM transaction 

independently, although it is likely that audio feedback would not be available for 

PIN entry for security reasons. This would probably be an inconvenience for the 

user but would not prevent use of the ATM. Implementation in design will have a 

high impact for people who are blind, a medium positive impact for users with low 
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vision, and a neutral impact for other users. Choice of private audio will help solve 

the problem of not being able to receive auditory or visual information.

Mapping function keys to the keypad: This is a software feature that allows the 

function keys at the side of the ATM display to be mapped, or directed, down to 

the keyboard. This means that the user can perform the entire transaction from the 

keyboard, which minimizes the distance a user has to stretch to reach the keys. It 

also helps people who are blind by providing a more familiar key layout to use for 

input. Function key mapping will have a medium impact for people who are blind 

and people who have upper or lower mobility impairments, and a neutral impact 

for all others. It will help solve the problems of not being able to locate or identify 

controls and not being able to make inputs.

Raised tactile symbols: Raised tactile symbols help those with visual 

impairments, particularly if they are blind, distinguish keys that most people 

differentiate through a text label or graphic. In some cases, these symbols may 

include a Braille keypad, although Braille proficiency is not widespread. Other 

alternatives include protruding keytips, which enable the visually impaired to feel 

the edge of individual keys and so determine the end of one key and the start of 

another, and increased character size, to assist those with visual impairments. 

Implementation in design has a neutral impact for most users, but a medium impact 

for those who are vision impaired. It will help solve the problem of not being able 

to locate and identify controls. 

Raised area (nib) on the “5” key: A nib is a raised area that helps users identify 

the location of the center of the keypad so they can then determine the position of 

the remaining keys. Given a standard telephone keypad layout with the addition of 

nonnumeric keys, the nib helps the user (particularly the user with a visual 

impairment) find the “5” key, from which the remaining numeric keys can be 
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easily identified. Inclusion in design will have a high impact for users who are 

blind, a medium impact for those with low vision, and a neutral impact for other 

users. It will help solve the problem of not being able to locate and identify 

controls. 

Keys on the keypad that are discernible by touch: Tactile separators typically 

provide either raised or indented spaces between controls to assist in tactile 

differentiation of numeric keys from other keys. Inclusion in design will have a 

high impact for those who are blind, a medium impact for those with upper 

mobility impairments, and a low impact for all others. It will help solve the 

problems of not being able to locate and identify controls and not being able to 

make accurate inputs. 

Tactile feedback keypad: Tactile feedback results from the keys springing back to 

position once pressed, indicating that a key has been pressed and input accepted. 

Touchscreens, for example, do not have tactile feedback. Inclusion in design will 

have a high impact for people who are blind, a medium positive impact for those 

with low vision, and a low impact for other users. 

User-controllable playback speed: User-controllable speed allows the user to 

make adjustments to auditory output to meet information processing needs. Visual 

output tends to be available until the next selection is made, but auditory output is 

temporal, and user control allows review of information as needed. This is 

particularly beneficial to people who are blind and perhaps to some users with low 

vision or cognitive disabilities. Implementation in design will have a medium 

positive impact for people who are blind and a low impact for other users. It will 

help solve the problem of difficulty receiving auditory information. 
96 

User-controllable volume: Volume control allows the user to make adjustments 

to auditory output to meet sound level needs, particularly in noisy environments. 

This is particularly beneficial to the hard of hearing. Implementation in design will 

have a high positive impact for the hard of hearing and a low impact for other 

users. It will help solve the problem of difficulty receiving auditory information. 

Visual alert: Visual alerts may be in the form of a change in text display or a light. 

They serve as an alternative or supplement to vibrating and auditory alerts. Visual 

indicators are particularly beneficial for people who are deaf or hard of hearing. 

Inclusion in design will have a high impact for users who are deaf, a medium 

impact for those who are hard of hearing, and a low impact for all others. They will 

help solve the problem of not being able to receive auditory information. 

Pause control for talking ATM: Pause control allows the user to pause the verbal 

output from the device. This is helpful to give one time to write something down or 

to think about what option might be desired. Inclusion in design will have a 

medium impact for users who are blind and a low impact for all other users. Pause 

control will help solve the problem of not being able to read text on the screen. 

Replay control for talking ATM: Replay control allows the user to listen to a 

message more than once. This is helpful if the voice output was not understood or 

could not be heard over environmental sounds. Inclusion in design will have a 

medium impact for users who are blind or hard of hearing and a low impact for all 

other users. Replay control will help solve the problem of not being able to read 

text on the screen. 

Voice recognition for talking ATM: Voice recognition allows a user to speak in 

his or her voice to make inputs to the device. This is particularly useful for those 

who cannot physically activate the controls or who cannot tactilely differentiate the 
97 

controls to know, for example, which button to press. Inclusion in design will have 

a high impact for users who are blind, a medium impact for users with low vision 

and upper mobility impairments, and a low impact for all others. Voice recognition 

will help solve the problems of not being able to locate, identify, and activate the 

controls. 

ATM that can be controlled by a cell phone or PDA: External control of the 

ATM allows individuals to use their own personal accessible device to interact 

with an ATM that may not otherwise be accessible for a particular disability type. 

Inclusion in design will have a medium impact for users who are blind, have low 

vision, or have an upper mobility impairment and a low impact for all other users. 

PDA or cell phone control will help solve the problems of not being able to read 

text on the screen or to locate, identify, and activate the controls. 

Large keys for the keypad: Large keys on the keypad increase the ability to 

accurately press the desired key without inadvertently pressing any adjacent keys. 

Inclusion in design will have a medium impact for those who are blind, have low 

vision, or have poor fine motor control and a low impact for all other users. It will 

help solve the problem of having difficulty making accurate inputs. 

Large fonts on the display: Large fonts on the display increase the text size for 

circumstances in which small text is difficult to read. Inclusion in design will have 

a high impact for those with low vision, a low impact for users who are blind, and 

a medium impact for all other users. It will help solve the problem of not being 

able to read text on the screen. 

Large display screen: Large display screens reduce screen clutter and increase the 

space available for larger text and graphics. Inclusion in design will have a medium 
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impact for low-vision users and a low impact for all others. It will help solve the 

problem of not being able to read text on the screen. 

High-contrast display: High contrast provides the option for users to adjust the 

color or brightness of the foreground and background colors so that the text stands 

out from the background, increasing readability. Inclusion in design will have a 

high impact for those with low vision and most users under very bright- or lowlight conditions. It will have a low impact for other disability populations. High 

contrast will help solve the problem of not being able to receive visual information. 

Ability to request additional time: Ability to request additional time allows the 

user to complete a transaction despite the need to use more than the normal amount 

of allotted time to complete individual transaction components. Inclusion in design 

will have a high impact for most users, depending on the output mode (visual or 

auditory) from the device. Additional time will help solve the problems of not 

being able to receive visual or auditory information, not being able to reach 

controls, and not being able to grasp objects. 

Graphical instructions: When good metaphors are used and display resolution is 

sufficient, graphical instructions may be easier to see than text instructions, 

particularly if the font size for text is small. Inclusion in design will have a medium 

impact for those who have low vision and a low impact for all other users. 

Graphical instructions will help solve the problem of not being able to read text on 

the screen. 

Text equivalents for auditory information: Text equivalents are a means of 

providing redundant information so that someone who has difficulty with one 

sense (in this case, hearing) has an alternative method of obtaining the information 

being provided (in this case, through eyesight). Inclusion in design will have a high 
99 

impact for those who are deaf or hard of hearing and a low impact for all other 

users. Text equivalents will help solve the problem of not being able to receive 

auditory information. 

Detachable controls: Detachable controls provide the option for individuals to 

place the control panel in their laps, for example, limiting the amount of reach 

required to activate the control, increasing the ability to support the hand and arm, 

and possibly making the difference between being able to use the device or not. 

Inclusion in design will have a high impact for those with those with a lower 

mobility impairment or any user operating the ATM while seated in a wheelchair, 

and a low impact for all other users. Detachable controls will help solve the 

problem of not being able to reach the controls from a seated position. 

More space between keys on the keypad: More space between the keys increases 

the ability to differentiate the keys by touch and to accurately press the desired key 

without inadvertently pressing any adjacent keys. Inclusion in design will have a 

medium impact for those who are blind, have low vision, or have an upper 

mobility impairment, and a low impact for all other users. It will help solve the 

problem of having difficulty locating controls and making accurate inputs. 

Concave keys on the keypads: Concave or curved-inward keys help prevent 

fingers from slipping off the keys, which often results in inadvertent activation of 

adjacent keys. This type of key also increases the ability to differentiate the keys 

from each other and from the surrounding area on the device. Inclusion in design 

will have a medium to high impact for users who are blind, have low vision, or 

have an upper mobility impairment, and a low impact for all other users. Concave 

keys will help solve the problem of locating controls and making accurate inputs. 
100 

Keys that can be operated without human contact: Some individuals use 

pointing devices or other mechanisms to help them reach or activate controls. 

Some devices require moisture content or heat (characteristics of touch) to activate 

the controls; these devices cannot be used by someone who needs to use an 

alternative input device. Controls that are operable without physical human contact 

will have a high impact for someone with an upper mobility impairment and a low 

impact for all other users. 

Rubberized keys: Rubberized keys help prevent fingers from slipping off the 

keys, which often results in inadvertent activation of adjacent keys. Textured keys 

also help the user differentiate the key itself from the surface of the device, 

particularly if the keys are not raised sufficiently. Inclusion in design will have a 

medium to high impact for users who are blind, have low vision, or have an upper 

mobility impairment, and a low impact for all other users. Rubberized keys will 

help solve the problem of locating controls and making accurate inputs. 

Additional features that may enhance accessibility include the following: 

Type of card reader—swipe, dip, or motorized: These are typically 

accompanied by tactile indicators and flashing lights to assist in card insertion. 

People with different capabilities may benefit more from one type of reader than 

another. For example, a vertical card swipe may be difficult for someone with 

limited reach. It may be difficult for users without fine motor control to retrieve a 

fully inserted card (dip card reader) from the device. Users who are blind may have 

difficulty finding the card reader or determining the proper orientation of the card. 

Implementation of a certain style will have a high impact for users who are blind or 

have upper mobility impairments. Use of a motorized reader or a horizontal swipe 

with tactile cues will help solve the problem of having difficulty inserting the ATM 

card into the machine. 
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Customer telephone: This can be used to acquire human assistance if the 

customer has difficulties using the ATM. A customer telephone will have a low 

impact for all users. It can help solve the problems of not being able to receive 

visual information or not being able to locate and identify controls. 

Digital video camera: This can be used in conjunction with the customer 

telephone to allow the customer service representative to see the customer’s 

difficulty. A digital video camera will have a low impact for all users. This can 

help solve the problems of not being able to receive visual information or not being 

able to locate and identify controls.

Multilingual capability: Multilingual capabilities will help those who have 

difficulty operating the ATM because of unfamiliarity with the language. This will 

have a medium impact for users with cognitive disabilities. It may help solve the 

problem of not being able to interpret visual information. 

LED indicator: LEDs provide a visual indication of status information, or they 

may provide guidance on what to select next or where to insert an object. They 

serve as an alternative or supplement to vibrating and auditory alerts. Visual 

indicators are particularly beneficial for people who are deaf or hard of hearing. 

They will have a low impact for all other users, and will help solve the problem of 

not being able to receive auditory output. 

User manuals in alternative formats: Alternative formats include large print, 

Braille, and audio. Inclusion in design will have a high impact for users who are 

blind or have low vision and a neutral impact for other disability populations. It 

will help solve the problems of not being able to read or handle printed materials. 
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Compliance with Government Regulations 

The primary parts of section 508 that are applicable to ATMs address self-contained, closed 

products (1194.25); functional performance requirements (1194.31); and documentation 

(1194.41). Many of these regulations have an impact on all users; others have a larger impact on 

one disability group than another. 

The following section 508 regulations are seen as issues for ATMs: 

• Verify that all controls and keys are tactilely discernible without activating the controls or 

keys. Some ATMs only use touchscreens, which are counter to this regulation. 

• Verify that at least one mode of operation and information retrieval is provided that does 

not require user vision or, alternatively, that support is provided for assistive technology 

used by people who are blind or visually impaired. The majority of ATM information is 

provided through a text display, which cannot be seen by a user who is blind. 

• At least one mode of operation and information retrieval that does not require visual acuity 

greater than 20/70 must be provided through audio and enlarged print output working 

together or independently; otherwise, support for AT used by people who are visually 

impaired must be provided. ATMs do not always provide voice output and often use font 

sizes smaller than 14 points, which is inadequate for someone with low vision. 

• At least one mode of operation and information retrieval that does not require fine motor 

control or simultaneous actions and that is operable with limited reach and strength must 

be provided. ATMs are often mounted at a height that is difficult or impossible for people 

in a seated position to access. The level of the display and control panel varies from one 

ATM to the next, and some are better suited to individuals in wheelchairs than others. 

Cell Phones 

Despite their popularity and their capabilities, cell phones are not accessible to everyone. There 

are limitations that make cell phones either inaccessible or difficult to use (and, therefore, 

possibly undesirable). People who have visual impairments may have the most difficulty reading 
103 

the display and accessing visual information. People who are deaf or hard of hearing may have 

difficulty carrying on a verbal conversation and detecting auditory alerts. People with a mobility 

disability may have difficulty making accurate inputs and simultaneously handling the phone and 

manipulating the controls. People who have cognitive disabilities may have difficulty 

understanding metaphors that are used and remembering how to access information. Each of 

these problems can be overcome, to some extent, through proper design. 

Background 

Digital cellular telephone service is growing rapidly in the United States because of the 

advantages it offers over older analog service. Digital service allows for more users, less 

expensive service, higher sound quality, more features, and better security. There are different 

types of digital cellular technology, including code-division multiple access (CDMA) and several 

varieties of time-division multiple access (TDMA), global system for multiple communications 

(GSM), and integrated digital enhanced network (iDen). The particular type of digital technology 

in use varies by service provider. 

The introduction of digital cellular telephone service in the mid-1990s also introduced a new 

access barrier for people who wear hearing aids. Analog systems work fairly well with teletype 

devices (TTYs). Some phones have built in modular jacks into which a TTY can be plugged; 

other phones can be used with an adapter. Initially, digital systems did not work well with TTYs. 

Digital wireless transmissions inherently contain errors, but error correction techniques can 

reduce the problem for speech. Digital networks are less forgiving in the case of the tones 

generated by TTY devices, however, and the transmission errors can cause characters to be lost 

or changed, resulting in unintelligible messages. 

When digital cellular telephones are in close proximity to hearing aids, interference may be heard 

through the hearing aid. The interference may be perceived as a buzzing, humming, or squealing 

inside the hearing aid. This interference does not occur with all combinations of telephone, 

hearing aid, and cellular service; but when it does occur, it can make use of the telephone 
104 

annoying, difficult, or impossible. In general, older, larger hearing aids are more susceptible to 

interference than newer models. Studies have shown that a distance of one to two feet between 

the phone and the hearing aid will reduce or eliminate the interference in most cases. 

The electromagnetic field surrounding the antenna of the telephone is the primary source of 

interference. Moving the antenna farther from the hearing aid may reduce or eliminate 

interference. The loudness of the interference also depends on the power of the transmission, 

which in turn varies with the distance from the telephone to the cellular base station. “Flip 

phone” designs may reduce interference by placing the antenna farther from the hearing aid and 

by shielding the hearing aid from the antenna. But the antenna is not the only source of 

interference; internal telephone electronics, such as the back light on the screen, can also cause 

interference. 

Possible solutions from the cellular industry may include reducing the required transmission 

power by adding more base stations, improving antenna technology and shielding the telephone, 

and providing accessories such as neckloops that induce sound into the T-coil of hearing aids 

without requiring proximity of the telephone to the hearing aid. 

Possible solutions from the hearing aid industry include increased shielding of hearing aids and 

modification of the circuitry and design of hearing aids to minimize interference. 

Digital Cell Phone Compatibility with TTY 

In 1996, the FCC issued a requirement that wireless carriers be capable of connecting 911 calls 

over a digital wireless network for callers using a TTY. The deadline for compliance was 

extended repeatedly as various wireless carriers worked to provide a solution. 

Since September 1997, the TTY Forum (sponsored by the Alliance for Telecommunications 

Industry Solutions, or ATIS) has worked to develop technically feasible solutions that will enable 

TTY users to make TTY calls over digital wireless systems. The TTY Forum is composed of 
105 

various stakeholders, including wireless carriers, wireless handset manufacturers, wireless 

infrastructure manufacturers, manufacturers of TTYs, 911 and telecommunications relay service 

providers, and consumer organizations representing people with hearing and speech disabilities. 

In January 2000, Lucent Technologies announced a solution for TTY access using digital cellular 

telephones. The solution was developed by the Bell Labs Speech and Audio Processing 

Technologies group; it involves upgrading software in both the network and the handset. The 

software detects the TTY characters being sent and repeatedly transmits those characters to the 

receiving end, allowing the receiving end to correctly regenerate the tones corresponding to the 

characters. 

At its meeting on June 4, 2002, the TTY Forum announced that many wireless service providers 

were prepared to meet the FCC’s June 30, 2002, deadline for TTY compatibility, and that testing 

had shown that digital wireless TTY consistently performed better than TTY over analog circuits. 

To enable the TTY calls over digital voice channels, digital wireless handsets and networks had 

to be redesigned to accommodate the speed and tone of TTY Baudot signals. Numerous 

problems had to be overcome, including setting standards for the interface between TTY devices 

and digital wireless mobile phones operating with several different digital standards. 

However, while wireless TTY compatibility services work well for nonemergency 

communication, at the time of the announcement there were some remaining issues for 

emergency situations. Wireless 911 TTY calls may suffer high character error rates when 

received by some public service answering points (PSAPs). Test results from the ATISsponsored TTY Technical Standards Implementation Incubator show that the problem 

encountered may be related to older and nonstandardized TTY equipment or software used by 

some PSAPs. The wireless telecommunications industry performed due diligence to ensure that 

the digital network would be capable of transmitting TTY calls by the June 30, 2002, deadline 

and was committed to continue to work to provide access to 911 for its customers using TTYs. 

There is some indication that wireless networks now support digital TTY with compatible 
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phones, but this cannot be verified since it is illegal to test 911 services. A number of carriers 

petitioned the FCC for an extension to the 911 requirements.

Hearing Aid Compatibility with Cellular Telephones

The Hearing Aid Compatibility Act of 1988 (HAC Act) required the FCC to ensure that all 

telephones manufactured or imported for use in the United States after August 1989, and all 

“essential” telephones, were hearing aid compatible. Secure telephones and mobile telephones 

were exempt from the HAC Act, however. 

In November 2001, the FCC released a Notice of Proposed Rulemaking to reexamine the 

exemption of mobile phones from the requirements of the HAC Act. On August 14, 2003, the 

FCC released a Report and Order modifying the exemption for wireless phones under the HAC 

Act to require that digital wireless phones be capable of being used effectively with hearing aids. 

The FCC ruling requires digital wireless phone manufacturers to make available within two years 

at least two HAC-compliant handsets with reduced radio frequency (RF) emissions for each air 

interface (e.g., CDMA, TDMA, GSM) they offer. It also requires each carrier providing digital 

wireless services, except for nationwide (Tier I) wireless carriers, to make available to consumers 

within two years at least two HAC-compliant handset models with reduced RF emissions for 

each air interface it offers. 

Nationwide (Tier I) wireless carriers must offer within two years two HAC-compliant handset 

models with reduced RF emissions for each air interface they employ or ensure that one quarter 

of their total handset models are HAC-compliant with reduced RF emissions within two years, 

whichever option yields a greater number of handsets. 

Digital wireless phone manufacturers must make available to carriers within three years at least 

two HAC-compliant models with telecoil coupling for each air interface they produce, and each 
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carrier providing digital wireless access must make available to consumers within three years at 

least two HAC-compliant handset models with telecoil coupling for each air interface it offers. 

Further, one-half of all digital wireless phone models offered by a digital wireless manufacturer 

or carrier must be compliant with the reduced RF emissions requirements by February 18, 2008. 

Manufacturers must label packages containing compliant handsets and must make information 

available in the package or product manual. Service providers must make available to consumers 

the performance ratings of compliant phones. 

In addition, the FCC established an exemption for digital wireless manufacturers and carriers that 

offer a minimal number of handset models. The FCC encourages digital wireless phone 

manufacturers and service providers to offer at least one compliant handset that is a lower-priced 

model and one that has higher-end features, and encourages hearing aid manufacturers to label 

their precustomization products according to the American National Standards Institute (ANSI) 

standard. 

On September 5, 2003, ATIS established the ATIS Hearing Aid Compatibility Incubator. The 

ATIS HAC incubator consists of a diverse mix of wireless service providers, wireless 

manufacturers, hearing aid manufacturers, and other parties. The mission of the HAC incubator 

is to investigate performance between hearing aids and wireless devices to determine methods of 

enhancing interoperability and usability for consumers with hearing aids. 

On October 1, 2003, DAMAX, a manufacturer of cellular telephone antennas, announced a line 

of directional antennas that show promise for improving the hearing aid compatibility of existing 

handsets. 

Task-Based Accessibility Analysis 

The core functionality considered necessary to effectively use a cell phone consists of the 

following: 
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• Locating the cell phone 

• Identifying the current state of the phone: on or off 

• Turning the phone on and off 

• Locking the phone 

• Unlocking the phone 

• Dialing numbers on the keypad 

• Storing a phone number 

• Recalling a stored phone number 

• Receiving a phone call 

• Receiving caller-ID information 

• Accessing voice mail 

• Attaching a headset 

• Using a headset 

• Determining battery status 

• Determining signal strength 

• Detecting when the phone is in roam mode 

• Receiving a text message 

• Sending a text message 

• Charging the phone 

Additional functionality that is typically inherent in cell phone design includes the following: 

• Using a calculator 

• Playing games 
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People may have difficulty accomplishing these basic tasks, depending on functional limitations 

resulting in an impairment, environmental or situational factors that create barriers, and the 

design of the phone. Accessibility issues for each disability population were identified, along 

with an impact rating for each issue. The disability populations include people who have an 

impairment resulting from environmental or situational factors. The issues identified and impact 

ratings assigned for each disability group can be found in the appendix to the online version of 

this report. 

Accessibility Features 

A review of various cell phone manufacturers’ marketing data produced a number of features 

identified as accessible design components. Each of these components is listed, along with a 

description of the component and an assessment of the usefulness of the feature for disability 

groups. Some of these features may have been designed with a particular disability population in 

mind; others may have been designed simply as desirable features. In many cases, the 

accessibility features benefit or are used by a variety of people, and they may be considered 

indicative of universal access. 

Loopset for hearing aids: A loopset is an accessory that increases clarity and 

reduces background noise when translating from sound over the telephone line to a 

hearing aid device. Inclusion in design will have a high impact for users who are 

hard of hearing and who use T-coil equipped hearing aids and will help resolve the 

issue of not being able to receive verbal information. Availability of loopsets will 

have no impact for other disability populations. 

Voice dialing: Voice dialing provides users with the option to speak the name of 

the person they want to call rather than using numeric dialing or accessing a name 

from the directory. Inclusion in design will have a high impact for people who are 

blind and a medium positive impact for users with low vision and upper mobility 

impairments. It will have a low impact for other disability groups. All users (except 
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perhaps the speech impaired) may find the feature useful. Although voice dialing is 

not likely to increase accessibility under general circumstances, it will in some 

situational contexts in which the user’s hands are unavailable. This is an example 

of a feature that is nearly universally usable, but it should not replace traditional 

dialing methods; voice dialing may be problematic for people without speech, 

people with laryngitis, or in noisy environments. Voice dialing will help resolve 

the issues of not being able to locate or identify controls and not being able to 

make accurate inputs. 

Adjustable contrast: Adjustable contrast provides the option for users to adjust 

the color or brightness of the foreground and background colors on the display 

screen to increase clarity and readability. Inclusion in design will have a high 

impact for those with low vision and most users under very bright- or low-light 

conditions. It will have a low impact for other disability populations. Adjustable 

contrast will help resolve the issue of not being able to receive visual information.

Roller key: The roller key provides an alternative to successive button presses, 

allowing the user to slide the thumb or finger over a roller in order to scroll 

through contents on a screen. This is an example of a feature that is nearly 

universally usable, but it should not replace traditional navigation methods. 

Inclusion in design will have a low impact for all disability groups. 

User manual in alternative formats: Alternative formats include large print, 

Braille, and audio. Inclusion in design will have a high impact for those who are 

blind or have low vision and a neutral impact for other disability populations. It 

will help resolve the issues of not being able to read or handle printed materials. 

One-touch dialing: One-touch dialing provides the option to map phonebook 

entries to numeric keys. Once programmed, the key can be pressed for an extended 
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period of time to dial the phone number rather than dialing in full or navigating 

through the phonebook. This is a desirable feature for all people, regardless of 

disability. Inclusion in design will have a high impact for people with upper 

mobility impairments (if they can sustain the key press) and visual impairments 

and a low impact for all other users. It will help resolve the issues of locating or 

identifying controls and making accurate inputs. 

Customized ring tones/alerts: Ring-tone options provide the user with a choice 

regarding the ring sound that is heard when there is an incoming call. In some 

cases, the phone can be set to ring differently for different callers. Customized 

alerts provide the user with a choice of the sound or tone that is heard when 

different alerts (e.g., reminders) are triggered. This user profiling is particularly 

useful for individuals who are blind who may not otherwise be able to determine 

the source of an incoming call, and inclusion in design will have a medium-high 

positive impact. Certain ring tones may be more perceptible than others for the 

hard of hearing, and inclusion of ring-tone options in design will have a medium 

impact for this group and will help resolve the issue of not being able to receive 

acoustic alerts and signals. While inclusion for other disability groups does not 

affect accessibility, ring-tone options are a highly desirable feature. Different ring 

tones also help users distinguish their own cell phone ring from someone else’s. 

Text-based functionality: Similar to sending email, text messaging via cell phone 

provides a mobile communication mechanism and has become highly popular. It 

allows individuals to communicate in noisy environments and when verbal 

conversations are inappropriate. It is particularly beneficial for people who are deaf 

or hard of hearing, who may not be able to hold a verbal conversation. Cell phones 

with text messaging and dedicated text messaging devices are very popular among 

users who are hearing impaired. However, text messaging is a somewhat slower 

communication method, and it is difficult to share and perceive emotion accurately 
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from text messaging. Inclusion in design will have a high impact for people who 

are deaf or hard of hearing and low impact for other population groups. Text 

messaging will help resolve the issue of not being able to receive auditory 

information by providing a viable alternative. 

Vibrating alerts and visual indicators: Vibrating alerts are an alternative to 

auditory alerts. Vibrating alerts are valuable for all users in various situational 

contexts, such as a business meeting; but they really enhance accessibility for 

people who are hard of hearing and deaf, who may not otherwise be able to detect 

an incoming call. Inclusion in design will have a high impact for users who are 

deaf, a medium impact for users who are hard of hearing, and a low impact for all 

other users. Vibrating alerts will help resolve the issue of not being able to receive 

auditory information. Visual indicators may be in the form of a change in text 

display or a light. They serve as an alternative or supplement to vibrating and 

auditory alerts. Visual indicators are particularly beneficial for people who are deaf 

or hard of hearing . Inclusion in design will have a high impact for users who are 

deaf, a medium impact for those who are hard of hearing, and a low impact for all 

others. Visual indicators will also help resolve the issue of not being able to receive 

auditory information. 

Cradle that attaches to mobility aid: A mobile holder is a mounting mechanism 

that can be attached to a wheelchair or other mobility aid or installed in a car to 

provide a consistent, secure place to store the cell phone. It also facilitates onehanded dialing by eliminating the need to simultaneously hold the phone and 

manipulate the controls. Mobile holders are particularly useful for people with 

upper mobility impairments. Inclusion in design will have a high impact for this 

group and a low impact for other groups, and it will help resolve the issue of not 

being able to lift and hold the device. 
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Raised area (nib) on the “5” key: A nib is a raised area that helps users identify 

the location of the center of the keypad so they can then determine the position of 

the remaining keys. Given a standard telephone keypad layout with the addition of 

nonnumeric keys, the nib helps the user (particularly the user with a visual 

impairment) find the “5” key, from which the remaining numeric keys can be 

easily identified. Inclusion in design will have a high impact for users who are 

blind, a medium impact for those with low vision, and a neutral impact for other 

users. It will help resolve the issue of not being able to locate and identify controls. 

Keypress feedback: Tactile feedback results from the keys springing back to 

position once pressed, and it is typically accompanied by a clicking sound. Both 

feedbacks are indicators that the key has been pressed and input accepted. 

Touchscreens lack both tactile and tonal feedback. Inclusion of keypress feedback 

in design will have a high impact for those who are blind, a medium impact for 

those with low vision, and a low impact for other users. 

TTY compatibility: A TTY is a small device with a keyboard that allows the user 

to type input rather than speak. This is then transmitted to the person on the other 

end of the line, who must also have a TTY device or use a relay service to translate 

from text to voice. Inclusion of TTY compatibility in design will have a high 

impact for people who are deaf or hard of hearing and a neutral impact for other 

users. It will help solve the issue of not being able to receive auditory information. 

Text messaging is a good alternative to TTY if all parties have access to it. 

Voice tag for menu navigation: Voice tags are spoken commands that can be 

used to bypass keypress inputs to control the phone. Voice tag use is quite 

common, though it is most beneficial for those with vision and mobility 

impairments who might otherwise not be able to make accurate inputs. Inclusion in 

design will have a high impact for these groups and a low impact for all others. It 
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will resolve the issues of not being able to locate and identify controls, not being 

able to receive visual information, difficulty with inputting information, and 

difficulty finding desired features. 

Zoom display: A zoom display provides the option to increase the text size, 

reducing the number of lines of text available at any given time. Inclusion in design 

will have a medium impact for users with low vision and a low impact for others. It 

will help resolve the issue of not being able to receive visual information. 

Brightly backlit display: Backlighting provides the option to adjust the screen 

lighting to accommodate low-light conditions. This is useful for all individuals in 

some contexts and is useful for users with low vision in a wider variety of 

conditions. Inclusion in design will have a medium impact for users with low 

vision and a low impact for all other users. It will help resolve the issue of not 

being able to receive visual information. 

Adjustable volume: Volume control is important for both auditory alerts and 

conversation. It is particularly important for hard-of-hearing people, but it is useful 

for all. Inclusion in design will have a medium impact for hard-of-hearing people 

and a low impact for all other users. It will help resolve the issue of not being able 

to receive auditory information. 

Icon/graphic menu: Pictorial representations as text alternatives generally allow 

for more information to be presented on a single screen. They are particularly 

useful for people who might have a reading impairment. They also provide the 

opportunity to declutter the screen, which is useful for users who have low vision 

or cognitive disabilities (if good metaphors are used). Inclusion in design will have 

a medium impact for users with low vision and users with cognitive disabilities 

(unless implemented with poor metaphors, in which case it may have a negative 
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impact for users with cognitive disabilities). This will help resolve the accessibility 

issue of difficulty interpreting textual information. 

Audio cue capability: Audio alerts are typically used to identify conditions such 

as a low battery. They are most useful for those with vision impairments and others 

in low-light conditions. Other people enjoy auditory displays and will use them, 

though they do not enhance their accessibility. Inclusion in design will have a high 

impact for people who are blind, a medium impact for those with low vision or 

upper mobility and cognitive disabilities, and a low impact for all others. It will 

help resolve the issue of not being able to receive visual information. 

External audio output (via headset): External audio output allows the user to 

carry on a conversation without needing to hold the phone. Amplified headsets 

enhance the sound output to increase the clarity of the information. Amplification 

is not strictly volume level, but more an intensity of different signals. Headsets 

help to concentrate the sound at the ear while blocking out some environmental 

noises. External audio is particularly useful for people who have upper mobility 

disabilities; if implemented in design, it will have a high impact. If the headset is 

amplified, it will have a high impact for hard-of-hearing users and will help resolve 

the issue of not being able to understand speech information. It will have a low 

impact for other users. 

Keys on the keypad that are discernible by touch: Tactile separators typically 

provide either raised or indented spaces between controls to assist in tactile 

differentiation of numeric keys from other keys. Inclusion in design will have a 

high impact for those who are blind, a medium impact for those with upper 

mobility impairments, and a low impact for all others. It will help resolve the 

issues of not being able to locate and identify controls and not being able to make 

accurate inputs. 
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Voiced menu options: Voiced menu options provide verbal output of the different 

menu screens, allowing the user to make appropriate inputs without having to see 

the display. This greatly increases the number of features that benefit a visually 

impaired user, in particular. Inclusion in design will have a high impact for those 

who are blind or have low vision, a medium impact for those with upper mobility 

impairments, and a low impact for all others. It will help resolve the issues of not 

being able to read text on the screen or to locate and identify controls. 

Screen magnifiers: Screen magnifiers increase the size of the text on the display. 

Inclusion in the design will have a high impact for those who have low vision and 

a low impact for all other users. It will help resolve the issue of not being able to 

read text on the screen. 

Larger keys on the keypad: Larger keys on the keypad increase the ability to 

accurately press the desired key without inadvertently pressing any adjacent keys. 

Inclusion in design will have a medium impact for those who are blind, have low 

vision, or have poor fine motor control and a low impact for all other users. It will 

help resolve the issue of having difficulty making accurate inputs. 

More space between keys on the keypad: More space between the keys increases 

the ability to differentiate the keys by touch and to accurately press the desired key 

without inadvertently pressing any adjacent keys. Inclusion in design will have a 

medium impact for those who are blind, have low vision, or have an upper 

mobility impairment and a low impact for all other users. It will help resolve the 

issue of having difficulty locating controls and making accurate inputs. 

Talking battery-level indicators: Talking battery-level indicators provide users 

who cannot see the screen with necessary information about the need to charge the 

phone. Inclusion in design will have a high impact for those who are blind and 
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have low vision and a low impact for all other users. It will help resolve the issue 

of not being able to read the display. 

Talking signal-strength indicators: Talking signal-strength indicators provide 

users who cannot see the screen with necessary information about the availability 

of coverage to successfully make and receive calls. Inclusion in design will have a 

high impact for those who are blind and have low vision and a low impact for all 

other users. It will help resolve the issue of not being able to read the display. 

Talking caller-ID: Talking caller-ID provides users, particularly those with visual 

impairments, with information about an incoming call. Caller-ID allows users to 

identify the caller before answering the phone, permitting the user to decide not to 

answer without worrying about missing an important call. Inclusion in design will 

have a high impact for those who are blind or have low vision and a low impact for 

all other users. It will help resolve the issue of not being able to read text on the 

screen. 

Large fonts on the display: Large fonts increase the text size on the display. 

Inclusion in design will have a high impact for those with low vision, a low impact 

for users who are blind, and a medium impact for all other users. It will help 

resolve the issue of not being able to read text on the screen. 

Large display screens: Large display screens reduce screen clutter and increase 

the space available for larger text and graphics. Inclusion in design will have a 

medium impact for low vision users and a low impact for all others. It will help 

resolve the issue of not being able to read text on the screen. 

Simplified connector for power: Simplified connectors for power allow the user 

to use a single hand with minimal pinching or grasping to connect the power cord 

to the device. Simplified connectors are not limited to insertion in a single 
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orientation. Inclusion in design with have a medium impact for users who are 

blind, have low vision, or have an upper mobility impairment, and a low impact for 

all other users. 

Simplified connector for headsets: Simplified connectors for headsets allow the 

user to use a single hand with minimal pinching or grasping to connect the headset 

cord to the device. Simplified connectors are not limited to insertion in a single 

orientation. Inclusion in design with have a medium impact for users who are 

blind, have low vision, or have an upper mobility impairment, and a low impact for 

all other users. 

Hearing aid compatibility: Hearing aid compatibility includes both the ability for 

someone using a hearing aid to use the cell phone without interference and the 

ability to be in proximity of someone else using a cell phone without experiencing 

interference. Inclusion in design will have a high impact for users who are hard of 

hearing and a low impact for all others. Hearing aid compatibility will help resolve 

the issue of not being able to receive auditory information. 

Concave keys on the keypads: Concave or inwardly curved keys help prevent 

fingers from slipping off the keys, which often results in inadvertent activation of 

adjacent keys. This type of key also increases the ability to differentiate the keys 

from each other and from the surrounding area on the device. Inclusion in design 

will have a medium to high impact for users who are blind, have low vision, or 

have an upper mobility impairment, and a low impact for all other users. Concave 

keys will help resolve the issue of locating controls and making accurate inputs. 

Keys that can be operated without human contact: Some individuals use 

pointing devices or other mechanisms to help them reach or activate controls. 

Some devices require moisture content or heat (characteristics of touch) to activate 
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the controls; these devices cannot be used by someone who needs to use an 

alternative input device. Controls that are operable without physical human contact 

will have a high impact for someone with an upper mobility impairment and a low 

impact for all other users. 

Rubberized keys: Rubberized keys help prevent fingers from slipping off the 

keys, which often results in inadvertent activation of adjacent keys. Textured keys 

also help the user differentiate the key itself from the surface of the device, 

particularly if the keys are not raised sufficiently. Inclusion in design will have a 

medium to high impact for users who are blind, have low vision, or have an upper 

mobility impairment, and a low impact for all other users. Rubberized keys will 

help resolve the issues of locating controls and making accurate inputs. 

Speakerphone: A speakerphone allows the user to carry on a conversation without 

needing to hold the phone. This is particularly useful for people who have upper 

mobility disabilities; if implemented in design, it will have a high impact. It will 

have a low impact for other users. A speakerphone will help resolve the issue of 

not being able to receive auditory information. 

Additional features that may enhance accessibility are described in this discussion of an 

accessible phone: http://www.trace.wisc.edu/docs/phones/tcrd1/summary/index.htm. These 

features include: 

Key shape: Keys can be shaped to be associated with their function. This can help 

someone relying on the tactile sense to better differentiate keys and may help those 

with cognitive disabilities to learn the appropriate use of various controls. 

Inclusion in design will have a high impact for people who are blind, a medium 

impact for people who have cognitive disabilities, and a low impact for all others. 
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Help request key: A help request key allows the user to press a designated key 

and then press another key to get information (verbal output), such as the status of 

a function or the function name for the selected key. Implementation in design will 

have a medium impact for those who are blind and a neutral impact for all other 

users. It will help resolve the issues of not being able to locate and identify controls 

or not being able to receive visual information. 

Key confirmation: Key confirmation provides feedback about the selected option 

before activation of the control. It then requires the user to confirm the selection to 

implement activation. Key confirmation helps to prevent accidental activation, 

which is especially common for those who are blind or have upper mobility 

impairments. Implementation in design will have a medium impact for both of 

these groups and a neutral impact for others. (If key confirmation is not optional, it 

might have a negative impact for other users by slowing their transactions.) It will 

help resolve the issue of having difficulty locating controls and making accurate 

inputs. 

Compliance with Government Regulations 

The primary parts of section 508 that are applicable to cell phones address telecommunications 

(1194.23), self-contained closed products (1194.25), functional performance requirements 

(1194.31), and documentation (1194.41). Many of these regulations have an impact on all users; 

others have a larger impact on one disability group than another. 

The following section 508 regulations are seen as issues for cell phones: 

• TTY compatibility. 

• Verify that all controls and keys are tactilely discernible without activating the controls or 

keys. Many of the keys on cell phones do not have adequate tactile separators or a 

sufficient nib on the “5” key to facilitate tactile differentiation. 
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• The status of all locking or toggle controls or keys must be visually discernible and 

discernible either through touch or sound. The status of the phone when it is locked is 

available only visually. 

• When products provide auditory output, the audio signal must be provided at a standard 

signal level through an industry standard connector that will allow for private listening. 

Some cell phones use proprietary connectors. 

• Verify that at least one mode of operation and information retrieval is provided that does 

not require user vision or, alternatively, that support is provided for assistive technology 

used by people who are blind or visually impaired. The majority of information is 

provided through a text display on the cell phone, which cannot be seen by a user who is 

blind. 

• At least one mode of operation and information retrieval that does not require visual acuity 

greater than 20/70 must be provided in audio and enlarged print output, working together 

or independently, or support for AT used by people who are visually impaired must be 

provided. Cell phones do not provide voice output, and they typically do not use more than 

a 10-point font, which is inadequate for someone with low vision. 

• Where audio information is important for the use of a product, at least one mode of 

operation and information retrieval shall be provided in an enhanced auditory fashion, or 

support for assistive hearing devices must be provided. While many cell phones are 

designated as hearing aid compatible and loopsets are available for some phones, they do 

not work for all people with hearing aids. Some cell phones also provide insufficient 

volume control to assist those with hearing impairments. 

Distance Learning Software 

Distance learning is an excellent option for people with limited mobility or restricted schedules 

and those not near an educational provider. There are some human limitations, however, that 

make distance learning either inaccessible or difficult to use. People who have visual 

impairments may have difficulty accessing visual information and making accurate inputs. 
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People who are deaf or hard of hearing may have difficulty accessing auditory information. 

People who have a mobility disability may have difficulty making accurate inputs and responding 

quickly enough to prompts. People who have cognitive disabilities may have difficulty 

understanding the language and responding quickly enough to prompts. Each of these challenges 

can be overcome, to some extent, through proper design (Tabs, 2003). 

Streaming media are audio and video distributed in real time over the Internet. “Streaming” 

means the file can be viewed and heard before it is fully downloaded. An initial portion of the 

file is downloaded, or buffered, and begins playing, while the remainder of the file arrives in a 

continuous stream. Streaming media often refers not only to media distributed in real time, but to 

any media downloaded from the Internet. 

In general, two sets of users will benefit most from streaming video that is accessible: people 

who are deaf or hard of hearing, and those who are blind or have low vision. People who are deaf 

or hard of hearing rely on captions to understand the audio content. People who are blind or have 

low vision rely on an audio description of the video content. However, as with all universal 

design, everyone benefits when streaming media is made accessible, even the provider of the 

streaming media. For example, captions can be made searchable, allowing for a much more 

elaborate video clip search and retrieval system. Captions also make streaming media more 

accessible for individuals who do not speak English, those for whom English is their second 

language, and those for whom printed English is more accessible than spoken English. Captions 

have also been shown to consistently improve reading retention of presented material. 

Background 

There are two main pieces of legislation that dictate accessibility of streaming media. The most 

obvious is the Americans with Disabilities Act of 1990, which requires that all public programs 

and services be accessible to people with disabilities. The second and most relevant piece of 

legislation is section 508, which was signed into law in August 1998 and became effective in 

June 2001. Section 508 requires that E&IT used by the Federal Government be accessible by 
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people with disabilities and that accessibility must be comparable to that provided to the public 

without disabilities. 

The provision of captioning for Internet video streams is still in its infancy when compared to the 

captioning of television programming. In some ways, captioning video streams is a more 

challenging problem because of the number of different video formats that must be considered. 

There is not at present any single, predominant standard for the captioning of Internet video 

streams. Several similar but distinct techniques are used; the techniques that are available depend 

on the format of the video stream. Three major formats are Apple’s Quicktime, Microsoft’s 

Windows Media, and Real’s RealPlayer. Each format has software bugs and some level of 

unreliability with respect to captioning. 

Windows Media

Windows Media Player adds captions using Microsoft’s Synchronized Accessible Media 

Interchange (SAMI). SAMI is an extensible markup language (XML) based text language. SAMI 

files contain the actual captions, as well as information about when and how the captions should 

display. SAMI is structured very similarly to hypertext markup language (HTML), and many 

HTML formatting tags are allowed in SAMI. Broadly speaking, SAMI files consist of caption 

text with tags specifying the appearance of the text and time tags that control when each caption 

should be displayed (in terms of elapsed milliseconds from the start of the media file). SAMI 

files can be created in any text editor, though using a captioning program such as MAGpie to 

enter caption times simplifies the process. 

There are two ways of adding captions to a media file. If the media file is embedded in a Web 

page (a practice that is not recommended for accessibility), code can be added to the Web page to 

display the captions along with the video. The recommended method involves creating a third 

file, called an active streaming XML (ASX) file. The ASX file is a pointer file that contains 

details about the media presentation and tells Windows Media Player which files (media and 

captions) to retrieve and play. 
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RealPlayer

RealPlayer uses the Synchronized Multimedia Integration Language (SMIL), developed by the 

World Wide Web Consortium (W3C), to choreograph the presentation of video and captions. 

SMIL is written as an XML application. 

To caption a RealPlayer file, a RealText file containing caption text, timing, and formatting 

information is created. The RealText file can be created in any text editor, but using a captioning 

program such as MAGpie to enter caption times simplifies the process. Next, an SMIL file must 

be created that links the video (RealPlayer) file and the caption (RealText) file, and creates the 

screen regions in which the video and caption files will be played. Links to the SMIL files must 

be provided in the form of real audio movie (RAM) files. The link points to the RAM file, which 

in turn points to the SMIL file, which in turn points to the RealPlayer and RealText files. The 

video file can also be embedded in a Web page, but this practice is not recommended because of 

the accessibility problems it creates. 

Quicktime

There are two methods for captioning Quicktime movies. The first involves creating a Quicktime 

text track and making it a part of the Quicktime movie. The result is a single file that contains 

audio, video, and captions. Quicktime Pro is required for this method. The second method 

involves creating a text track movie as a separate file, which is then synchronized with the movie 

with SMIL (as described above for RealPlayer). 

In either case, a caption file must be created. This file can be created using any text editor or by 

using MAGpie. In the first method, Quicktime Pro is used to convert the caption file to a text 

track and merge it with the video file. In the second method, a separate SMIL file is created. 

There are a number of ways to access captioned Quicktime movies. If the captions are embedded 

in the movie, a direct link to the movie can be provided. Quicktime movies (or SMIL files) can 

be embedded into Web pages; this is an accessible option for Quicktime, because there is an 
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option to make the control bar visible on the screen. Code can also be included in a Web page 

that will open a Quicktime movie or SMIL presentation in the Quicktime player. 

Task-Based Accessibility Analysis 

The core functionality considered to be necessary to effectively use distance learning programs 

consists of the following: 

• Logging in to the system 

• Navigating the system 

• Obtaining content—text, auditory, visual (graphics, videos) 

• Filling out forms 

• Reading email messages 

• Using Instant Messaging software 

• Reading documents in Microsoft Word format 

• Reading documents in Adobe PDF format 

• Viewing presentations in Microsoft PowerPoint format 

• Using chat software 

Additional functionality that is typically inherent in distance learning design includes the 

following: 

• Participating in audio or video conferencing 

People may have difficulty accomplishing these basic tasks, depending on functional limitations 

resulting in an impairment, environmental or situational factors that create barriers, and the 

design of the system being used. Accessibility issues for each disability population were 

identified, along with an impact rating for each issue. The issues identified and the impact ratings 
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assigned for each disability group can be found in the appendix to the online version of this 

report. 

Accessibility Features 

A review of various distance learning providers’ marketing data produced features identified as 

accessible design components. Each of these components is listed, along with a description of the 

component and an assessment of the usefulness of the feature for disability groups. Some of 

these features may have been designed with a particular disability population in mind; others may 

have been designed simply as desirable features. In many cases, the accessibility features benefit 

or are used by a variety of people, and they may be considered to provide universal access. Each 

of the accessibility features listed below is a function of the distance learning software as well as 

the content developed by an administrative user of the software. Each of the features has the 

capability to be implemented in distance learning if the content developers include it in the 

course materials. Distance learning vendors provide guidance for course developers that 

addresses many of these issues. 

Use of alt tags: Alt tags provided with images allow screen reader users to obtain 

information about the images that are present on the page. Without alt tags, a blind 

person using a screen reader may know only that an image is present but will have 

no idea what it represents. In addition, alt tags can be used as a means to ignore 

images that exist for aesthetic reasons and do not provide important information by 

providing blank or null alt text for the image, which simplifies the process of 

obtaining information through a screen reader. Implementation in design will have 

a high impact for those who are blind, a medium impact for those who have low 

vision, and a low impact for all others. It will help resolve the issue of being unable 

to receive important visual information, and in some cases, of having difficulty 

interpreting visual information. 
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Synchronized multimedia: Multimedia can consist of text, video, audio, and 

other content. Sometimes multiple sensory outputs are provided but not directly in 

parallel, which can be confusing for the individual performing multiple sensory 

processing. Multimedia should be synchronized with the material, or there should 

be linked multimedia files containing synchronized equivalent alternatives to assist 

those who may benefit from redundant information sources. Synchronized 

multimedia will have a medium impact on most users. 

All information conveyed with color is also available without color: Color is a 

very good tool for grouping controls or identifying important information, as long 

as the viewer can see and differentiate color. Color provides a means to create 

contrast, code objects, and provide meaning without words. However, some people 

with visual impairments cannot benefit from the use of color, and the meaning may 

be lost to some people with cognitive disabilities. Therefore, while color is useful 

and should be used, it should not be the only means to differentiate objects, 

provide structure, or present useful information. Anything represented with color 

should also be available without color. Following this guideline in design will have 

a high impact for users who are blind or have low vision, a medium impact for 

users with cognitive difficulties, and a low impact for other users. Ensuring that no 

information is conveyed with color alone will help resolve the issues of not being 

able to receive important visual information and not being able to interpret some 

visual information. 

Documents are organized so they are readable without requiring an 

associated style sheet: When documents require style sheets, individuals may not 

be able to control the appearance (font size, etc.) of the information on the page or 

to use their own customized style sheet. This may create problems for those who 

use screen readers. Implementing pages that are readable without style sheets will 
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have a high impact for those with visual impairments. It will help resolve the issue 

of not being able to receive visual information. 

Only client-side image maps are used (or, redundant text links are provided 

for each active region of a server-side image map): Client-side image maps 

make information available to people browsing with nongraphical user agents and 

offer immediate feedback as to whether or not the pointer is over an active region. 

Implementation of only client-side image maps in design will have a high impact 

for users who are blind and a medium impact for those with low vision. There will 

be a low impact for all other users. It will help resolve the issue of not being able to 

receive visual information. 

Row and column headers are provided for data tables in order to take 

advantage of newer screen reader capabilities to process this additional 

information: Tables that are not constructed in an organized fashion with headers 

to describe the row and column contents are very difficult to interpret for someone 

relying on a screen reader. Headers can help the individual determine the 

organization of the information being presented. This facilitates navigation through 

the table and comprehension of the information contained in the table. 

Implementation in design will have a high impact for those who are blind, a 

medium impact for those who have low vision, and a neutral impact for all others. 

It will help resolve the issue of not being able to receive visual information. 

Framesets are titled to facilitate identification and navigation: Frame titles let 

users know, for example, whether they are in the navigation frame or the content 

frame. Providing titles helps a person using a screen reader distinguish the 

organization of the information and facilitates navigation. Implementation in 

design will have a high impact for people who are blind and a low impact for all 
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other users. It will help resolve the issue of not being able to receive visual 

information. 

Pages are designed to avoid causing the screen to flicker with a frequency 

greater than 2 Hz and lower than 55 Hz: Some flicker frequencies can induce 

visual seizures. Flicker is most often an issue for animations, and pages should be 

designed so that only appropriate animations are used. Moving content can cause 

difficulty for people with low vision and cognitive disabilities, particularly if they 

must react at the same speed to click an object, for example. In addition, screen 

readers cannot read moving text. Implementation in design will have a high impact 

for those who are susceptible to visual seizures; a medium impact for those who 

have low vision, cognitive disabilities, or upper mobility impairments; and a low 

impact for other users. It will help resolve the issues of not being able to receive 

visual information, having difficulty interpreting visual information, and having 

difficulty making inputs, particularly when there is a time constraint. 

Dynamic scripting is not used for content presentation: Dynamic scripting can 

be problematic for screen readers, sometimes providing an inaccurate description 

of the page content and preventing the user from receiving the same information 

that can be obtained visually. Implementation in design will have a high impact for 

users with no vision, a medium impact for users with low vision, and a neutral 

impact for other users. It will help resolve the issue of not being able to receive 

visual information. 

Plug-ins are supported as embedded content or as automatically launched 

files: Some plug-ins that require interaction will only work with mouse input, 

which excludes a large number of users. Appropriately applied plug-ins 

implemented in design will have a high impact for those who are blind or have 

upper mobility impairments, a medium impact for those with low vision, and a 
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neutral impact for the remainder of users. They will help resolve the issue of not 

being able to receive visual information and make appropriate inputs. 

Form labels are placed next to the form input elements that are referenced, 

including input boxes and radio buttons: This allows screen reader users to 

appropriately associate labels with the form elements. A user should be able to fill 

out the form with either keyboard or mouse input. Implementation in design will 

have a high impact for those who have visual or cognitive disabilities and a low 

impact for all other users. It will help resolve the issues of not being able to receive 

visual information and of having difficulty interpreting visual information. 

For navigation links located in the body of the main content page, code exists 

to allow screen readers to detect and skip the navigation links: When 

navigation links are in the main content page, they are read each time the page is 

accessed. This can be very time-consuming and unnecessary for someone using a 

screen reader to find or review a part of the page. Providing a means for the user to 

skip over the navigation links allows the user to read through the page and get to 

the needed information more easily and quickly. Implementation in design will 

have a high impact for those who are blind and a medium impact for those with 

low vision. It will help resolve the issue of not being able to receive visual 

information. 

Session timeout settings can be modified by the system administrator to allow 

for more time, if necessary: Some systems require an input within a certain 

amount of time before they end the session; this provides security and helps free up 

access to others. However, some people cannot respond in appropriate time limits 

because they are using a screen reader, which takes longer than expected to process 

the page; they themselves are slow to process the page content; or they have 

difficulty with fine motor control and making appropriate inputs. If time-dependent 
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settings can be controlled as needed for individuals, it will have a high impact for 

those who are blind or have cognitive disabilities or upper mobility impairments. It 

will help resolve the issues of not being able to receive visual information and 

having difficulty making inputs. 

Online help documentation is provided describing layout, context, 

functionality of each feature, and instructions for using the features: Some 

systems may use functionality that is atypical or not intuitive, particularly for those 

who cannot visually explore the contents. Implementation of online help 

documentation will have a medium impact for those with visual or cognitive 

disabilities and a low impact for all other users. 

Additional features we feel would make a distance learning program accessible include the 

following: 

Screen reader compatibility: Screen readers allow users to obtain information 

without visually perceiving it. Visual information is translated into auditory output 

that is read to the user. The most common users of screen reading technology are 

those who are blind or have low vision. Implementation in design will have a high 

impact for those who are blind, a medium impact for those with low vision, and a 

neutral impact for all others. Screen reading compatibility will help resolve the 

issue of not being able to receive visual information. 

Printed materials available in alternative formats: Alternative formats include 

large print, Braille, and audio. They mostly benefit users with visual impairments, 

providing a high impact for that user group. Distribution of documents in an 

accessible electronic format that is convertible is often preferred. It will help 

resolve the issue of not being able to receive visual information. 
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Uncluttered pages, pages that are well organized, and pages that don’t have 

backgrounds that interfere with processing foreground information: Pages 

with a lot of information, colors, patterns, and movement can be very difficult for 

some people to process. Avoiding these things in design will have a medium 

impact on those with low vision and cognitive disabilities. It will help resolve the 

issues of having difficulty receiving and interpreting visual information and having 

difficulty finding desired features. 

Consistent layouts from page to page: Information that is organized in a similar 

fashion from one page to the next helps the user to quickly find items of interest. 

Implementation in design will have a medium impact for those who have a 

cognitive disability and a low impact for all other users. It will help resolve the 

issues of having difficulty receiving and interpreting visual information and having 

difficulty finding desired features. 

Closed-captioned video: Videos, audio clips, and live presentations naturally have 

audio output, but they do not readily have comparable visual output available. 

Graphics and text to describe the audio information, particularly direct 

transcriptions, can greatly enhance the accessibility of this information for those 

with hearing impairments, having a high impact for this population of users. It will 

help resolve the issue of not being able to receive auditory information. 

A text-only page, with equivalent information or functionality, should be 

provided when accessibility cannot be achieved in any other way: The content 

of the text-only page should be updated whenever the primary page changes. This 

will have a high impact for those who are blind, a medium impact for those with 

low vision, and a low impact for other users. It will help solve the issue of not 

being able to receive visual information. 
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User manuals in alternative formats: Alternative formats include large print, 

Braille, and audio. Inclusion in design will have a high positive impact for users 

who are blind or have low vision, possibly the same for those with hearing 

impairments (depending on the original format), and no impact for other disability 

populations. It will help resolve the issue of not being able to receive visual (and 

possibly auditory) information. 

Screen magnifier compatibility: A screen magnifier increases the size of the 

display and button labels to enhance the readability for those with low vision. It is 

an alternative, particularly if adjustable screen resolution and font size are 

unavailable. Implementation in design will have a medium impact for those with 

low vision and a neutral impact for other users. It will help resolve the issues of not 

being able to receive visual information and not being able to locate and identify 

controls. 

Adjustable font sizes: Small fonts are very difficult to read for users with low 

vision, who typically need to squint or use a magnifying glass to read them. They 

are also more difficult to read under low-light conditions and when users are 

fatigued. Implementation in design of adjustable font sizes will have a high impact 

on users with low vision and, with the exception of people who are blind, a low 

impact on all other users. It will help resolve the issue of not being able to receive 

visual information. 

Adjustable contrast: Adjustable contrast provides the option for users to adjust 

the color or brightness of the foreground and background colors to increase clarity. 

Inclusion in design will have a high impact for those with low vision and most 

users under very bright- or low-light conditions. It will have a low impact for other 

disability populations. Adjustable contrast will help resolve the issue of not being 

able to receive visual information. 
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Graphics that are described in detail: Graphics may be impossible to see for a 

person who is blind, difficult to see and interpret for those who have low vision, 

and difficult to understand for those who do not learn well from pictures. Inclusion 

of detailed descriptions will have a high impact for those who are blind or have 

low vision, and a low to medium impact for all other users. Described graphics will 

help resolve the issue of not being able to receive visual information. 

Video that is described in detail: Video may be impossible to see for a person 

who is blind and difficult to see for those who have low vision or are limited to 

small video screens with insufficient resolution. Inclusion of detailed descriptions 

will have a high impact for those who are blind or have low vision, and a low 

impact for all other users. Described video will help resolve the issue of not being 

able to receive visual information. 

Adjustable volume: Volume control is important for auditory information and 

alerts. This is particularly important for hard-of-hearing people, but it is useful for 

all. Inclusion in design will have a medium impact for hard-of-hearing people and 

a low impact for all other users. It will help resolve the issue of not being able to 

receive auditory information. 

Ability to request additional time: Ability to request additional time allows the 

user to be able to complete a transaction despite the need to use more than the 

normal amount of allotted time to complete individual transaction components. 

Inclusion in design will have a high impact for most users, depending on the output 

mode (visual or auditory) from the device. Additional time will help resolve the 

issues of not being able to receive visual or auditory information and having 

difficulty with control inputs. 
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Voice recognition: Voice recognition allows the user to provide inputs verbally 

rather than through mechanical keypresses. Voice recognition is particularly useful 

for those who cannot see to make the correct inputs or cannot reach or have 

difficulty activating mechanical controls. Implementation in design will have a 

high impact for those who are blind, a medium impact for those who have low 

vision or an upper mobility impairment, and a low impact for other users. It will 

help resolve the issues of having difficulty entering/inputting information, 

difficulty making accurate inputs, difficulty lifting and holding the device, and 

possibly difficulty finding desired features and interpreting visual information. 

Compliance with Government Regulations 

The primary parts of section 508 that are applicable to distance learning address software 

applications and operating systems (1194.21), Web-based Intranet and Internet information and 

applications (1194.22), video and multimedia products (1194.24), functional performance 

requirements (1191.31), and documentation (1191.41). Many of these regulations have an impact 

on all users; others have a larger impact on one disability group than another. 

The following section 508 regulations are seen as issues for distance learning: 

• Sufficient information about a user interface element, including the identity, operation, and 

state of the element, must be available to assistive technology. When an image represents a 

program element, the information conveyed by the image must also be available in text. 

The creators of distance learning content do not always provide text equivalents for 

graphical information. Some features of the software interface are not recognized by 

screen readers. 

• A text equivalent for every nontext element must be provided (e.g., via “alt,” “longdesc,” 

or in-element content). The creators of distance learning content do not always provide 

text equivalents for graphical information. 
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• Equivalent alternatives for any multimedia presentation must be synchronized with the 

presentation. Equivalent alternatives are often not provided and are typically not synched 

when they are available. 

• At least one mode of operation and information retrieval must be provided that does not 

require user vision or, alternatively, that support for assistive technology used by people 

who are blind or visually impaired is provided. Much content is provided in a graphical 

fashion that cannot be seen by those with visual limitations and that cannot be read by a 

screen reader. 

• At least one mode of operation and information retrieval that does not require user hearing 

must be provided, or support for AT used by people who are deaf or hard of hearing must 

be provided. Distance learning content is often provided in an auditory fashion without 

closed-captioning or text to accompany the output. 

Personal Digital Assistants 

Despite their popularity and their capabilities, PDAs are not accessible to everyone. There are 

some human limitations that make PDAs either inaccessible or difficult to use (and therefore 

perhaps undesirable). People who have visual impairments may have difficulty accessing visual 

information and providing accurate inputs. People who are deaf or hard of hearing may have 

difficulty detecting auditory alerts. People who have a mobility disability may have difficulty 

simultaneously handling the PDA and manipulating the controls. People who have cognitive 

disabilities may have difficulty understanding metaphors and jargon and remembering how to 

access information. Each of these challenges can be overcome, to some extent, through proper 

design. 

Background 

Personal digital assistants are popular for both personal and business use. There are thousands of 

applications available for PDAs, many of them free, that support a wide range of activities. PDAs 

have the potential to provide benefits to individuals with disabilities, but they are not currently 
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accessible to all users. Users generally interact with PDAs by use of a small stylus for input and a 

small screen for output, producing barriers for users with visual or mobility impairments in 

particular. 

Text Input and Output

To assist people who are unable to use the stylus, nearly all PDAs support the attachment of 

various types of keyboards, including those that support one-handed typing such as the 

halfkeyboard.

The AlphaPad is a software application for PalmOS and Window CE that uses a 12-key keyboard 

along with word prediction software. The keyboard is displayed on a touchscreen, so fine motor 

control is necessary, but it could be useful for low-mobility users. Thumbscript is another textentry system that uses gestures on a nine-button grid to produce characters. It is compatible with 

any device having eight actuation points arranged radially around a center and may be useful for 

users with mobility impairments. There are a number of other variations on stylus-based text 

entry, as well. 

Several products provide some degree of voice interaction with PDAs. IBM has released a 

version of its ViaVoice application for Pocket PCs. This application serves as a text-to-speech 

screen reader and also allows user input utilizing a limited command vocabulary. ScanSoft’s 

Dragon PDsay provides similar functionality for Pocket PCs. Both of these products are 

command-based and don’t support dictation or application-specific functionality beyond a basic 

core set of popular applications. 

Display Features

TealMagnify is a screen magnifier for PalmOS that may be of use to people with visual 

impairments, although it requires users to touch a button on the PDA to activate it and apparently 

produces rather pixilated results. 
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For users with low vision, many PDAs are now available with bright color displays. Palm claims 

that some (but not all) of its color models provide a variety of color and contrast adjustments for 

users with visual impairments, and there are a number of third-party applications that allow 

customization of display colors. Pocket PCs apparently can also be modified to provide a higher 

contrast color scheme. 

PDAs Designed Specifically for Users with Disabilities

Enkidu makes a line of portable communication devices known as the IMPACT family that is 

designed specifically for users with various disabilities. These devices provide speech output and 

support input via touchscreen, integrated buttons, keyboard, or external switches. 

Task-Based Accessibility Analysis 

The core functionality considered to be necessary to effectively use a PDA consists of the 

following: 

• Locating the PDA 

• Turning the PDA on and off 

• Storing an appointment 

• Recalling an appointment 

• Viewing the calendar 

• Using the calculator 

• Making and retrieving a memo or notes 

• Storing contact information 

• Recalling contact information 

• Reading/composing/sending email 

• Making and retrieving a TO DO list entry 
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• Syncing with a computer 

• Adjusting screen contrast 

• Adjusting font sizes 

• Receiving an alert 

• Detecting battery status 

• Charging or replacing batteries 

• Installing software 

Additional functionality that is typically inherent in PDA design includes the following: 

• Tracking expenses 

People may have difficulty accomplishing these basic tasks, depending on functional limitations 

resulting in an impairment, environmental or situational factors that create barriers, and the 

design of the PDA. Accessibility issues for each disability population were identified (taken in 

part from www.techdis.ac.uk/PDA/front.htm), along with an impact rating for each issue. The 

disability populations include people who have an impairment resulting from environmental or 

situational factors. The issues identified and the impact ratings assigned for each disability group 

can be found in the appendix to the online version of this report. 

Accessibility Features 

A review of various PDA manufacturers’ marketing data produced few features identified as 

accessible design components. Each accessibility feature is listed, along with its description, a 

determination of availability in the product line, and an assessment of whether the feature 

actually improves accessibility. 

Screen reader compatibility: Screen readers allow users to obtain information 

without the need to perceive it visually. Visual information is translated into 

auditory output that is read to the user. The most common users of screen reading 
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technology are people who are blind or have low vision. Implementation in design 

will have a high impact for these groups and a neutral impact for other groups. It 

will help resolve the issue of not being able to receive visual information. Jaws and 

other screen readers are not available for mainstream PDAs. ViaVoice is available, 

but it is designed more for voice input than output, and output is very limited. 

ViaVoice provides some options for a person who is blind trying to use a PDA, but 

it is not a substitute for a screen reader. 

Additional features that would make a PDA accessible include the following (taken in part from 

www.techdis.ac.uk/PDA/front.htm): 

Adjustable display resolution: Display resolution affects the quality of the visual 

images provided as well as the amount of information that can be seen at a single 

time. Someone with low vision, for example, may need a lower display resolution, 

which increases the size of the images, in order to clearly interpret the information 

provided. Thus, allowing the display resolution to be adjusted enhances the 

accessibility for various individuals. If implemented in design, it will have a high 

impact on those with low vision and, with the exception of people who are blind, a 

medium impact on other users. It will help resolve the issue of not being able to 

receive visual information. 

Adjustable font size: Small fonts are very difficult to read for users with low 

vision, who typically need to squint or use a magnifying glass to read them. They 

are also more difficult to read under low-light conditions and when users are 

fatigued. Implementation in design of adjustable font sizes will have a high impact 

on users with low vision and, with the exception of people who are blind, a low 

impact on all other users. It will help resolve the issue of not being able to receive 

visual information. 
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Adjustable contrast control: Adjustable contrast provides the option for users to 

adjust the color or brightness of the foreground and background shades to increase 

clarity. Ease of contrast adjustment, for example, through a hardware control, 

greatly improves the accessibility for many individuals, but it could mean the 

difference between being able to use the PDA and not for a low-vision user. 

Inclusion in design will have a high impact for those with low vision and most 

users under very bright- or low-light conditions. It will have a low impact for other 

disability populations. Adjustable contrast will help resolve the issue of not being 

able to receive visual information. 

Ability to adjust screen colors: Adjustable color provides the option for users to 

adjust the color or brightness of the foreground and background colors to increase 

clarity. Inclusion in design will have a high impact for those with low vision and 

for most users under very bright- or low-light conditions. It will have a low impact 

for other disability populations. Adjustable color will help resolve the issue of not 

being able to receive visual information. 

Good screen lighting: Adjustable screen lighting accommodates low-light 

conditions. This is useful for all individuals in some contexts and can also be 

useful for users with low vision in a wider variety of conditions. Inclusion in 

design will have a medium impact for users with low vision and a low impact for 

all other users. It will help resolve the issue of not being able to receive visual 

information. 

Buttons with good tactile quality: Buttons that have texture and are not slick are 

easier to distinguish by feel and to use without slipping and accidentally activating 

an adjacent control. Implementation in design will have a medium impact on those 

who are blind and those with upper mobility impairments. It will help resolve the 
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issues of having difficulty locating and identifying controls and difficulty making 

accurate inputs. 

Adequately sized button labels and symbols: Users with low vision may have 

difficulty reading small labels or interpreting small symbols, particularly under 

low-light conditions. Implementation in design of adequately sized text and 

graphics on buttons will have a high impact on users with low vision and, with the 

exception of people who are blind, a low impact on all other users. It will help 

resolve the issues of not being able to receive visual information and not being able 

to locate and identify controls. 

Voice recognition: Voice recognition provides the option to provide inputs 

verbally rather than through mechanical keypresses. This is particularly useful for 

those who cannot see to make the correct inputs or cannot reach or have difficulty 

activating mechanical controls. Implementation in design will have a high impact 

for those who are blind, a medium impact for those who have low vision or an 

upper mobility impairment, and a low impact for other users. It will help resolve 

the issues of having difficulty entering/inputting information, difficulty making 

accurate inputs, difficulty lifting and holding the device, and possibly the 

difficulties of finding desired features and interpreting visual information. 

Screen magnifier compatibility: An external screen magnifier increases the size 

of the display and button labels to enhance the readability for those with low 

vision. It is an alternative, particularly if adjustable display resolution and font size 

are unavailable. Implementation in design will have a medium impact for those 

with low vision and a neutral impact for other users. It will help resolve the issues 

of not being able to receive visual information and not being able to locate and 

identify controls. 
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Good use of visual metaphors; simple graphical navigational aids: Graphics 

are very useful for people who have difficulty reading text. Graphics can help 

declutter a display by reducing the need for text. Implementation in design will 

have a high impact on the cognitively disabled, a medium impact for those with 

low vision, a neutral impact for people who are blind, and a low impact for all 

other users. It will help resolve the issues of not being able to receive or understand 

visual information and not being able to find desired features. 

Clear menu structures: Simple menus and information organization help all users 

find the information they are looking for in a timely fashion. They require fewer 

inputs, which can be very beneficial for those who have trouble finding or 

manipulating controls. Implementation in design will have a high impact for all 

users. It will help resolve the issues of not being able to receive or understand 

visual information and not being able to find desired features. 

Auditory, visual, and vibrating alerts: Alerts provided in a redundant fashion 

assist users with specific physical impairments as well as those who encounter a 

situation in which the normal alerting mode is insufficient. Implementation in 

design will have a high impact for users who are visually or hearing impaired and a 

medium impact for all other users. It will help resolve the issue of not being able to 

receive visual or auditory information. 

Use of simple language (not PDA-specific technical jargon): Some individuals 

may have difficulty using a device simply because they do not understand the terms 

that are used to refer to various features. Implementation of simple language will 

have a high impact on users who have a cognitive disability and a medium impact 

on all other users. It will help resolve the issues of not being able to respond in the 

allotted period of time or not being able to interpret visual information. 
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Minimal force requirement for activating controls: The effort required to 

activate a control may be more than an individual can provide, preventing that 

individual from using the device. Implementation of minimal force will have a 

high impact for users with upper mobility impairments and a low impact for all 

other users. It will help resolve the issue of not being able to make inputs. 

Input alternatives other than stylus and touchscreen controls (e.g., keyboard): 

Users who cannot see or who have difficulty controlling certain input devices 

benefit from having an alternative input mechanism. Implementation in design will 

have a high impact for users who are blind, have low vision, or have an upper 

mobility impairment. It will have a low impact for all other users. It will help 

resolve the issue of not being able to provide inputs. 

Choice of stylus size and style: A stylus is typically a very thin, smooth-surfaced 

pointing device, which can be difficult for some individuals to hold onto. 

Implementation of choice of styli will have a high impact on those with upper 

mobility impairments and a neutral impact on all other users. It will help resolve 

the issue of not being able to make accurate inputs. 

PDA cases designed with materials that increase friction and grip: A PDA case 

typically houses the PDA device, even while in use. The case adds to the size and 

potentially awkward shape of the device, which can be cumbersome for some 

users. Implementation of friction in design will provide a medium impact for users 

with upper mobility impairments and a neutral impact for all other users. It will 

help resolve the issue of not being able to lift and hold the device. 

An overall shape and size (weight) that allows the device to be comfortably 

held in the average adult hand: The shape and size of a PDA can affect the 

ability to hold the device and, specifically, to hold and manipulate the device 
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simultaneously. A lightweight contoured shape will have a high medium impact on 

users with upper mobility impairments and a low impact on all other users. It will 

help resolve the issue of not being able to lift and hold the device. 

The availability or feasibility of mounting brackets for use with a desk or 

wheelchair or in a fixed location: A mobile holder is a mounting mechanism that 

can be attached to a wheelchair or other mobility aid or installed in a car to provide 

a consistent, secure place to store the PDA. When using a PDA, people often hold 

the device with one hand and make inputs with the other. This is problematic for 

people who may be unable to hold and manipulate the device simultaneously. 

However, if the device were constructed so it could be secured to another surface 

to handle the “holding component” of using the PDA, it would increase the 

accessibility for those with an upper mobility impairment. If implemented in 

design, this feature will have a high impact for those with upper mobility 

impairments and a low impact for other groups. It will help resolve the issue of not 

being able to lift and hold the device. 

Adjustable zoom: A zoom display provides the option to increase the text size 

predefined amounts, reducing the number of lines of text available at any given 

time. Inclusion in design will have a medium impact for users with low vision and 

a low impact for others. It will help resolve the issue of not being able to receive 

visual information. 

Availability of user-defined alerts: Auditory alerts sometimes accompany visual 

alerts, which can help differentiate one from another. For those who cannot see, 

however, or for people who are hard of hearing, a way to make the alerts more 

distinct and meaningful for will increase the user’s ability to process and make use 

of the auditory alerts by themselves. Implementation in design will have a high 

impact for those who are hard of hearing or have visual impairments and a low 
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impact for all other users. It will help resolve the issues of not being able to receive 

visual information and difficulty receiving auditory information. 

User manuals in alternative formats: Alternative formats include large print, 

Braille, and audio. Inclusion in design will have a high impact for users who are 

blind or have low vision, a medium impact for users with upper mobility 

impairments, and no impact for other disability populations. It will help resolve the 

issues of not being able to read or handle printed materials. 

Large fonts on the display: Large fonts on the display increase the text size for 

circumstances in which small text is difficult to read. Inclusion in design will have 

a high impact for those with low vision, a low impact for users who are blind, and 

a medium impact for all other users. It will help resolve the issue of not being able 

to read text on the screen. 

Large display screens: Large display screens reduce screen clutter and increase 

the space available for larger text and graphics. Inclusion in design will have a 

medium impact for low vision and cognitively disabled users and a low impact for 

all others. It will help resolve the issue of not being able to read text on the screen. 

High-contrast displays: High contrast provides the option for users to adjust the 

color or brightness of the foreground and background colors so that the text stands 

out from the background, increasing readability. Inclusion in design will have a 

high impact for those with low vision and most users under very bright- or lowlight conditions. It will have a low impact for other disability populations. High 

contrast will help resolve the issue of not being able to receive visual information. 

Large keys: Large keys on the keypad increase the ability to accurately press the 

desired key without inadvertently pressing any adjacent keys. Inclusion in design 

will have a medium impact for those who are blind, have low vision, or have poor 
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fine motor control, and a low impact for all other users. It will help resolve the 

issue of having difficulty making accurate inputs. 

More space between keys: More space between the keys increases the ability to 

differentiate the keys by touch and to accurately press the desired key without 

inadvertently pressing any adjacent keys. Inclusion in design will have a medium 

impact for those who are blind, have low vision, or have an upper mobility 

impairment, and a low impact for all other users. It will help resolve the issue of 

having difficulty locating controls and making accurate inputs. 

Keys that are discernible by touch: Tactile separators typically provide either 

raised or indented spaces between controls to assist in tactile differentiation of 

numeric keys from other keys. Inclusion in design will have a high impact for those 

who are blind, a medium impact for those with upper mobility impairments, and a 

low impact for all others. It will help resolve the issues of not being able to locate 

and identify controls and not being able to make accurate inputs. 

Simplified connector for power: A simplified power connector allows the user to 

use a single hand with minimal pinching or grasping to connect the power cord to 

the device. Simplified connectors are not limited to insertion in a single 

orientation. Inclusion in design will have a medium impact for users who are blind, 

have low vision, or have an upper mobility impairment, and a low impact for all 

other users. 

Simplified connector for headsets: A simplified headset connector allows the 

user to connect the headset cord to the device with a single hand with minimal 

pinching or grasping. Simplified connectors are not limited to insertion in a single 

orientation. Inclusion in design will have a medium impact for users who are blind, 
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have low vision, or have an upper mobility impairment, and a low impact for all 

other users. 

Adjustable timeouts: Adjustable timeouts allow the individual to set the amount 

of time for features that have timeout settings. This accommodates those who may 

be slower in making inputs or who prefer to minimize the number of inputs, which 

may increase when a setting times out. Inclusion in design will have a medium 

impact for those who are blind, have low vision, or have upper mobility 

impairments. Adjustable timeouts will help resolve the issues of not being able to 

receive visual information or to respond within an allotted period of time. 

Ability to request additional time: Ability to request additional time allows the 

user to complete a transaction despite the need to use more than the normal amount 

of allotted time to complete individual transaction components. Inclusion in design 

will have a high impact for most users, depending on the output mode (visual or 

auditory) from the device. Additional time will help resolve the issues of not being 

able to receive visual or auditory information, not being able to reach controls, and 

not being able to grasp objects.

Adjustable volume: Volume control is important for auditory alerts. It is 

particularly important for hard-of-hearing people, but it is useful for all. Inclusion 

in design will have a medium impact for hard-of-hearing people and a low impact 

for all other users. It will help resolve the issue of not being able to receive 

auditory information. 

Concave keys on the keypads: Concave or inwardly curved keys help prevent 

fingers from slipping off the keys, which often results in inadvertent activation of 

adjacent keys. This type of key also increases the ability to differentiate the keys 

from each other and from the surrounding area on the device. Inclusion in design 
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will have a medium to high impact for users who are blind, have low vision, or 

have an upper mobility impairment, and a low impact for all other users. Concave 

keys will help resolve the issue of locating controls and making accurate inputs. 

Keys that can be operated without human contact: Some individuals use 

pointing devices or other mechanisms to help them reach or activate controls. 

Some devices require moisture content or heat to activate the controls; these 

devices cannot be used by someone who needs to use an alternative input device. 

Controls that are operable without physical human contact will have a high impact 

for someone with an upper mobility impairment and a low impact for all other 

users. 

Rubberized keys: Rubberized keys help prevent fingers from slipping off the 

keys, which often results in inadvertent activation of adjacent keys. Textured keys 

also help the user differentiate the key itself from the surface of the device, 

particularly if the keys are not raised sufficiently. Inclusion in design will have a 

medium to high impact for users who are blind, have low vision, or have an upper 

mobility impairment, and a low impact for all other users. Rubberized keys will 

help resolve the issue of locating controls and making accurate inputs. 

Compliance with Government Regulations 

The primary parts of section 508 that are applicable to PDAs address self-contained closed 

products (1194.25), functional performance requirements (1191.31), and documentation 

(1191.41). Many of these regulations have an impact on all users; others have a larger impact on 

one disability group than another. 
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The following section 508 regulations are seen as issues for PDAs: 

• Verify that all controls and keys are tactilely discernible without activating the controls or 

keys. Since the PDA system is primarily touchscreen-based, it is not possible to have 

tactilely discernible controls unless they are redundant with hardware controls. 

• Verify that this self-contained product is usable by people with disabilities, without 

requiring the end-user to attach assistive technology to the product. There is very little a 

user who is blind can accomplish with a PDA without the assistance of voice output. 

Unfortunately, screen reader software is not yet available for a PDA. 

• Verify that at least one mode of operation and information retrieval is provided that does 

not require user vision or, alternatively, that support for AT used by people who are blind 

or visually impaired is provided. As indicated above, there is very little a user who is blind 

can accomplish with a PDA without the assistance of voice output. Unfortunately, screen 

reader software is not yet available for a PDA. 

• Provide at least one mode of operation and information retrieval that does not require 

visual acuity greater than 20/70 in audio and enlarged print output, working together or 

independently, or provide support for AT used by people who are visually impaired. PDAs 

do not provide voice output, and they typically do not use more than a 10- or 12-point font, 

which is inadequate for someone with low vision. Increased font size is available only for 

a limited application set. 

Televisions 

There are some human limitations that make TVs either inaccessible or difficult to use. People 

who have visual impairments may have difficulty perceiving visual information and providing 

accurate inputs. People who are deaf or hard of hearing may have difficulty perceiving auditory 

information. People who have a mobility disability may have difficulty activating controls. 

People who have cognitive disabilities may have difficulty understanding control options. 
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Background 

Television is the medium that entertains, informs, and educates; it can also serve as a companion 

to people who, because of circumstances beyond their control, are confined to their homes. 

Traditionally, people have used TV to get news reports and watch movies, sports events, and 

sitcoms. However, televisions are not currently accessible to all users. Certain services have 

become available to make television more accessible to users with disabilities. Closed-captioning 

and real-time captioning for live broadcasts have made televisions more accessible to users with 

hearing impairments by allowing them to understand the auditory portion of television programs. 

Descriptive video services have increased accessibility for users with visual impairments by 

allowing them to better understand the visual portion of television programs. New challenges to 

accessibility have been posed with the rise of digital television and interactive services, but 

accessible design solutions have been proposed to overcome the barriers associated with this new 

technology. 

Closed-Captioning

In 1970, the National Bureau of Standards began investigating the possibility of using a portion 

of the network television signal to broadcast time information in a part of the signal not used for 

picture information. The American Broadcasting Company (ABC) network took part in this 

project; and although the project didn’t work, ABC suggested that it might be possible to send 

captions in the unused bandwidth. 

In 1971, two captioning technologies were demonstrated at the First National Conference on 

Television for the Hearing Impaired. A second demonstration was held at Gallaudet College on 

February 15, 1972. In the second demonstration, ABC presented closed-captions embedded in 

the normal broadcast of The Mod Squad. The Federal Government agreed to fund the 

development and testing of captioning. 

In 1973, engineers at the Public Broadcasting System (PBS) started working on the project under 

contract to the Bureau of Education for the Handicapped of the Department of Health, Education, 
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and Welfare. The closed-captioning system was successfully tested that year in Washington, 

D.C., with the captions being broadcast using Line 21 of the vertical blanking interval. In 1976, 

the FCC set aside Line 21 for the transmission of closed-captions in the United States. 

The first closed-captioned television series was broadcast on March 16, 1980. In 1982, the 

National Captioning Institute (NCI) developed real-time captioning for use in newscasts, sports 

events, and other live broadcasts. 

NCI partnered with the ITT Corporation in the late 1980s to develop the first caption-decoding 

microchip that could be built directly into new television sets in 1989. In 1990, the Television 

Decoder Circuitry Act was passed. This Act mandated that, by mid-1993, all new television sets 

13 inches or larger manufactured for sale in the United States must contain caption-decoding 

technology. 

Also in 1990, the Americans with Disabilities Act was passed. Title III of the ADA requires that 

public facilities, such as hospitals, bars, shopping centers, and museums (but not movie theaters), 

provide access to verbal information on televisions, films, or slide shows. (Captioning is 

considered one way of making this information available.) Federally funded public service 

announcements must also be captioned. 

To implement the closed-captioning requirements of the Telecommunications Act of 1996, the 

FCC established rules and implementation schedules for the captioning of television 

programming. These rules went into effect on January 1, 1998, and established an eight-year 

transition period for new programming. (At the end of the transition period, 100 percent of 

nonexempt new programs must be captioned.) A similar schedule was established for the 

captioning of Spanish-language programming. 

Section 508 of the Rehabilitation Act, as strengthened by the Workforce Investment Act of 1998, 

requires that federal agencies make their E&IT accessible to people with disabilities, including 

employees and the general public. The requirements of section 508 apply to an agency’s 
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procurement of E&IT, as well as to the agency’s development, maintenance, or use of E&IT. All 

training and informational video and multimedia productions that support the agency’s mission, 

regardless of format, must be open- or closed-captioned if they contain speech or other audio 

information necessary for the comprehension of the content. All training and informational video 

and multimedia productions that support the agency’s mission, regardless of format, must include 

an audible description of the video content if they contain visual information necessary for the 

comprehension of the content. 

By 1998, new standards for captioning in high definition television (HDTV) were being created. 

These new standards greatly expanded the capabilities of captioning for HDTV, including— 

• Variable-size captions 

• Multiple fonts and colors 

• Different font and background styles 

• More information bandwidth 

• A larger symbol set 

In addition to the obvious benefits to deaf and hard-of-hearing persons, captioned television is a 

valuable tool for young children who are learning to read, illiterate adults who are learning to 

read, children and adults with learning disabilities, people in public places, and people learning 

English as a second language. 

Descriptive Video Service 

Descriptive video information or descriptive video service (DVS) enables visually impaired 

people to better understand the visual portions of television programs. A TV program with DVS 

has an additional audio track with a narrator describing the setting, what actions are taking place, 

who is talking, and any other important information that a visually impaired person would not be 

able to see. The narration is timed so that the narration does not interfere with dialog. 
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The roots of DVS date back to the 1960s, when some attempts were made to fill in the gaps for 

Star Trek episodes through audio cassettes. In the 1970s, a former radio broadcaster began 

describing movies on a radio station in Philadelphia. In 1981, Margaret Pfanstiehl began 

describing live theatrical performances in Washington, D.C., and later developed descriptive 

techniques and described some programs that were broadcast over the radio reading service. 

In 1985, stereo television broadcasting began. WGBH, a Boston public television station, began 

exploring possible ways to use the secondary audio program (SAP) audio channel to carry 

narrated descriptions of a program’s key visual elements. The goal was to eliminate the need for 

a specially developed assistive device in order to receive the descriptions. 

In 1988, the Corporation for Public Broadcasting awarded WGBH a grant to develop a complete 

business and operational plan for the permanent establishment of DVS. At the same time, 

WGBH funded all aspects of a national test of the service that was conducted in conjunction with 

PBS and other groups. 

In 2000, spurred by the major networks’ failure to voluntarily offer DVS, the FCC mandated the 

provision of DVS by broadcasters; but various groups (including the National Association of 

Broadcasters, the Motion Picture Association of America, and the National Cable and 

Telecommunications Association) challenged the mandate in court. They claimed that the FCC 

exceeded its authority and, by compelling speech, violated the First Amendment. The core of the 

issue appeared to be one of cost. 

Under the FCC measure, network affiliates would have to offer four hours a week of prime time 

or children’s shows by June 2002; cable and satellite operators would have a similar requirement 

for top networks. Certain programming, including live news, sports, and talk shows, would be 

exempt. 

There were a number of legal decisions between 2000 and 2002, with courts variously upholding 

and overturning the FCC mandate. In mid-June 2003, Senator John McCain introduced a bill (S. 
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1264, FCC Reauthorization Act of 2003) that would reinstate the FCC mandate. The bill was 

approved by the Senate Committee on Commerce, Science, and Transportation and is now 

awaiting approval by the full Senate. There is no House bill as of this printing.

The application of DVS is still somewhat limited compared to closed-captioning, consisting 

mainly of programming on PBS and a few other networks. Certain movies for which descriptions 

have been developed are available by direct mail, in libraries, and in video rental stores. 

Real-Time Captioning

In 1982, NCI developed real-time captioning, a process for captioning newscasts, sports events, 

specials, and other live broadcasts as the events are being televised. In real-time captioning, court 

reporters who have been trained as real-time captioners type at speeds in excess of 225 words per 

minute to give viewers instantaneous access to live information. The viewer sees the captions 

within two to three seconds of the words being spoken, with the delay resulting from the time it 

takes the captioner to hear the words spoken and then key the words, and for the captions to be 

encoded. 

Real-time captioners write what they hear phonetically, using a stenotype machine (also known 

as a shorthand machine), which has only 24 keys and a number bar. The basic concept behind 

machine shorthand is phonetic, where combinations of keys represent sounds, but the theory is 

much more complex than straight phonics. Multiple keys can be depressed simultaneously on 

steno machines to create different word combinations. No two captioners write exactly the same 

way, so each has a custom dictionary (typically containing 50,000 to 100,000 entries) composed 

of the phonetics and their corresponding English that the captioner uses to build words and create 

punctuation. The steno then goes into a computer system, where it is translated into text and 

commands. The captioning software on the computer formats the stream of text into captions and 

sends them to a caption encoder. 
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Accessibility of Digital Television and Interactive Services

Interacting with a modern television set, even for an action as basic as selecting a program, has 

become far more complex with the advent of digital television. The digital set-top boxes (STBs) 

used to access digital programming offer access to a large amount of information, entertainment, 

and services via electronic program guides (EPGs), which require users to scroll through lots of 

on-screen text and graphics to select programs or access advanced features such as parental 

controls and advance scheduling. The highly visual nature of this style of interface has created 

serious barriers for consumers who are blind or have low vision. 

These barriers are similar in nature to those that were created by graphical user interfaces for 

computer operating systems and by the rise of the World Wide Web. Over time, screen readers 

and other technologies emerged to provide access to these environments, but so far those 

solutions have not been applied to STBs for digital television. The automatic conversion of EPGs 

to synthesized speech has proven problematic. 

In February 2001, the National Center for Accessible Media (NCAM) at Boston public 

broadcasting station WGBH partnered with America Online to explore ways to make interactive 

TV accessible to audiences who are blind or visually impaired, focusing initially on making the 

EPG more accessible. The assumption was that the majority of the solutions required to make the 

EPG accessible will also apply to making other content accessible with the STB. Funding for the 

research was provided by the National Institute on Disability and Rehabilitation Research. 

In August 2003, NCAM published A Developer’s Guide to Creating Talking Menus for Set-top 

Boxes and DVDs (NCAM, 2003). This document discusses the accessibility problems posed by 

the EPG and presents possible technological solutions to the problems and guidelines for content 

development. 

According to the Guide, there are challenges in finding the best strategy for translating on-screen 

visual information into a spoken equivalent, and there are also technological challenges in 

actually delivering the spoken information. The primary technological challenges result from the 
157 

operating constraints of current STB hardware. The computers inside American STBs are too 

primitive to support the additional capability needed to provide voice output. 

The Guide states that speech synthesis is a far more feasible solution than the use of prerecorded 

speech, because the number of audio samples that would be required in the latter case would be 

unworkable. A system could be designed where the synthesized speech is provided from a central 

server along with the current program guide information, but the bandwidth and storage 

requirements of this approach make it unfeasible. The STB itself could perform the speech 

synthesis, which is a trivial task for most modern computers, but until the computing power of 

STBs catches up with that of desktop systems, this approach is not possible. 

Some other alternatives include using a more powerful third-party STB—such as a TiVO or other 

personal digital recorder—to do the speech synthesis, or to dispense with the STB altogether and 

route the cable signal through a desktop computer. 

For users with low vision and/or other disabilities, the ability to adjust various aspects of the 

display (such as font sizes and text/background contrast settings) would be beneficial. In the 

article “Interactive Digital Television Services for People with Low Vision,” Sylvie Perera (n.d.) 

advocates the use of a smart card identification system to allow low-vision users to set personal 

preferences for such features as text size, content layout, speech output, audio description, color 

combinations, timeouts, reminders, and alerts. This scheme could also be extended to assist users 

with other disabilities by allowing the smart card preferences to include subtitles, signing, and 

other features. 

Task-Based Accessibility Analysis 

The core functionality considered to be necessary to effectively use a TV consists of the 

following: 

• Turning the TV on and off 
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• Changing the input source 

• Changing the channel 

• Adjusting the volume 

• Activating closed-captioning (CC) 

• Accessing the EPG 

• Activating DVS 

• Adjusting picture quality settings 

• Using picture-in-picture (PIP) features 

Additional functionality that is typically inherent in TV design includes the following: 

• Setting the time 

• Automatically or manually adding/deleting channels 

• Setting the TV to turn on and off automatically 

In many cases, these functions require or are facilitated by use of the remote control. 

People may have difficulty accomplishing these basic tasks, depending on functional limitations 

resulting in an impairment, environmental or situational factors that create barriers, and the 

design of the TV. Accessibility issues for each disability population were identified, along with 

an impact rating for each issue. The disability populations include people who have an 

impairment resulting from environmental or situational factors. The issues identified and the 

impact ratings assigned for each disability group can be found in the appendix to the online 

version of this report. 

Accessibility Features 

A review of various TV manufacturers’ marketing data produced a single feature identified as an 

accessible design component. This component is listed, along with a description of the 
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component and an assessment of the usefulness of the feature for disability groups. While this 

feature was designed with a particular disability population in mind, it turns out that it benefits 

and has been used by a much wider variety of people than anticipated and may be considered a 

universal design feature. 

Closed-captioning: Information can be obtained from TV both visually and 

auditorily, but the visual information is very limited for something like a news 

show, for example, which inhibits hearing-impaired people from benefiting from 

the TV as an information source. The Television Decoder Circuitry Act of 1990 

requires decoder chips in U.S. TVs; as of 1993, all 13-inch or larger TVs were 

required to have decoder circuitry built in to provide CC. A phase-in is under way 

to make CC available for all TV programming. In addition to helping people who 

are deaf or hard of hearing, CC benefits those whose native language differs from 

the programming language and children or others who are learning to read 

(http://www.fcc.gov/cgb/consumerfacts/closedcaption.html). CC has greatly 

enhanced the accessibility of TV for people who are deaf or hard of hearing, 

having a high impact if implemented in design, and serves as a useful feature with 

low impact for the population as a whole. It helps resolve the issue of not being 

able to receive auditory information. 

Additional features that would make a TV more accessible include the following: 

Selection of SAP via a dedicated button on the remote control: SAP is an oftenused feature, most commonly used for translation of English programming into 

Spanish or, less commonly, to provide sign language interpretation. Access to this 

programming option is often nonintuitive and cannot be done quickly. Access 

through a dedicated remote control button would greatly enhance accessibility for 

those challenged by sound or cognition, having a medium impact for these groups 
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if implemented in design and a neutral impact for other users. It will help resolve 

the issue of not being able to interpret auditory or visual information. 

Selection of DVS via a dedicated button on the remote control: Access to DVS 

is typically through a menu structure that is often nonintuitive and cannot be done 

quickly. Access through a dedicated remote control button would greatly enhance 

accessibility for those who are blind or have low vision, having a high impact for 

these groups if implemented in design and a neutral impact for other users. It will 

help resolve the issue of not being able to interpret visual information. 

Selection of CC via a dedicated button on the remote control: Access to CC is 

typically through a menu structure that is often nonintuitive and cannot be done 

quickly. Access through a dedicated remote control button would greatly enhance 

accessibility for those challenged by sound, having a medium impact for this group 

if implemented in design and a neutral impact for other users. It will help resolve 

the issue of not being able to interpret auditory information. 

Vivid picture for clarity of CC: CC is typically provided in all capital letters, 

which is harder to read than mixed capital and lowercase letters. In addition, the 

readability varies with the quality of the television on which it is viewed. For 

example, HDTV sets offer a higher resolution image and typically greater clarity of 

CC material. Good picture quality can greatly enhance accessibility of information 

provided textually. Implementation in design will have a high impact for those 

with visual and hearing impairments and a low impact for all others. It will help 

resolve the issues of not being able to receive auditory and visual information. 

High-quality audio system: For those people who depend on the auditory output 

of the TV to obtain information, quality of audio output can have a large impact on 

ability to accurately perceive information, especially for those who have a visual 
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disability and cannot benefit from the redundancy provided by the images. 

Implementation in design will have a high impact for those who are hard of hearing 

and a medium impact for all other users, with the exception of those who are deaf. 

It will help resolve the issue of having difficulty receiving auditory information. 

User manuals in alternative formats: Alternative formats include large print, 

Braille, and audio. Accessible electronic formats are also often acceptable. 

Inclusion in design will have a high impact for users who are blind or have low 

vision and a neutral impact for other disability populations. It will help resolve the 

issues of being unable to read or handle printed materials. 

Voice-activated remote controls: A voice-activated remote control will allow the 

user to provide all inputs via voice rather than through mechanical key presses. If 

implemented in design, this will have a high impact for people who are blind and 

those with upper mobility impairments, a medium impact for those with low 

vision, and a neutral impact for other users. It will help resolve the issues of not 

being able to locate or identify controls, not being able to lift and hold the remote 

control, and not being able to make accurate inputs, and it may help with not being 

able to find desired features or respond within the allotted time. 

Talking remote controls: A talking remote control is one with voice displays. 

Talking remote controls are useful in circumstances in which it is difficult to make 

control inputs or read the text display because of a visual impairment, significant 

glare on the screen, or possibly having to view the screen from a seated position. 

Inclusion in design will have a high impact for those who are blind, a medium 

impact for those with low vision, and a low impact for all other users. It will help 

resolve the issue of receiving and interpreting visual information. 
162 

Large buttons on the remote: Large keys on the keypad increase the ability to 

accurately press the desired key without inadvertently pressing any adjacent keys. 

Inclusion in design will have a medium impact for those who are blind, have low 

vision, or have poor fine motor control, and a low impact for all other users. It will 

help resolve the issue of having difficulty making accurate inputs. 

More space between keys on the remote: More space between the keys increases 

the ability to differentiate the keys by touch and accurately press the desired key 

without inadvertently pressing any adjacent keys. Inclusion in design will have a 

medium impact for those who are blind, have low vision, or have an upper 

mobility impairment, and a low impact for all other users. It will help resolve the 

issue of having difficulty locating controls and making accurate inputs. 

DVS: DVS provides auditory output of key visual elements in visual 

programming. Inclusion in design will have a high impact for those who are blind 

or have low vision and a low impact for all other users. It will help resolve the 

issue of not being able to receive visual information. 

Voiced on-screen menus: Voiced on-screen menus provide verbal output of the 

visual displays from the TV, allowing a user to become familiar with the menus 

without having to see them. On-screen menus are used for functions such as 

controlling TV features (such as CC or DVS) and setting up a VCR to tape a 

program. Inclusion in design of voiced menus will have a high impact for those 

who are blind or have low vision and a low impact for all other users. Voiced 

menus help resolve the issue of not being able to receive visual information. 

Voiced program guides: Voiced program guides provide verbal output of the 

programming available on the TV. Inclusion in design of voiced program guides 

will have a high impact for those who are blind or have low vision and a low 
163 

impact for all other users. Voiced program guides help resolve the issue of not 

being able to receive visual information. 

Ability to adjust program guide font size: Adjustable font size allows the user to 

set the size of the program guide lettering so that it is comfortable to read. Font 

size can be an issue for those with visual disabilities and for anyone who is seated 

at a fair distance from the TV. Inclusion in design will have a high impact for those 

who have low vision and a low impact for all other users. Adjustable font size will 

help resolve the issue of not being able to receive visual information. 

Ability to adjust program guide font color: Adjustable font color can be used to 

increase contrast for text information. Inclusion in design will have a high impact 

for those who have low vision and a low impact for all others. Adjustable color 

will help resolve the issue of not being able to receive visual information. 

Ability to adjust program guide background color: Adjustable background 

color can also be used to increase contrast for text information. Inclusion in design 

will have a high impact for those who have low vision and a low impact for all 

others. Adjustable color will help resolve the issue of not being able to receive 

visual information. 

Ability to adjust CC font size: Adjustable font size allows the user to set the size 

of the CC lettering so that is comfortable to read. Font size can be an issue for 

those with visual disabilities and for anyone who is dependent on using CC. 

Inclusion in design will have a high impact for those who are deaf and hard of 

hearing, a medium impact for those who have low vision, and a low impact for all 

other users. Adjustable font size will help resolve the issue of not being able to 

receive visual or auditory information. 
164 

Ability to adjust CC font color: Adjustable font color can be used to increase 

contrast for text information. Inclusion in design will have a high impact for those 

who are deaf and hard of hearing, a medium impact for those who have low vision, 

and a low impact for all other users. Adjustable font size will help resolve the issue 

of not being able to receive visual or auditory information. 

Ability to adjust CC background color: Adjustable background color can also be 

used to increase contrast for text information. Inclusion in design will have a high 

impact for those who are deaf and hard of hearing, a medium impact for those who 

have low vision, and a low impact for all other users. Adjustable CC background 

color will help resolve the issue of not being able to receive visual or auditory 

information. 

Ability to adjust CC display rate: Adjustable display rate allows the user to set 

the speed at which CC is displayed. All people read at different rates, and those 

who have a visual impairment in addition to a hearing impairment may need some 

additional time to process the CC information. Inclusion in design will have a high 

impact for those who are deaf or hard of hearing, a medium impact for those who 

have low vision, and a low impact for all other users. Adjustable CC display rate 

will help resolve the issue of not being able to receive visual or auditory 

information. 

Concave keys on remote control: Concave or inwardly curved keys help prevent 

fingers from slipping off the keys, which often results in inadvertent activation of 

adjacent keys. This type of key also increases the ability to differentiate the keys 

from each other and from the surrounding area on the device. Inclusion in design 

will have a medium to high impact for users who are blind, have low vision, or 

have an upper mobility impairment, and a low impact for all other users. Concave 

keys will help resolve the issue of locating controls and making accurate inputs. 
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Compliance with Government Regulations 

The primary parts of section 508 that are applicable to TVs address video and multimedia 

products (1194.24), self-contained closed products (1194.25), functional performance 

requirements (1191.31), and documentation (1191.41). Many of these regulations have an impact 

on all users; others have a larger impact on one disability group than another. The following 

section 508 regulation is seen as an issue for TVs: 

• At least one mode of operation and information retrieval that does not require user hearing 

must be provided, or support for assistive technology used by people who are deaf or hard 

of hearing must be provided. Not all programs are captioned, and there are many 

inaccuracies and lapses in captioning when it is available. 

Voice Recognition Software 

There are some human limitations that make voice or speech recognition software either 

inaccessible or difficult to use (and therefore, perhaps, undesirable). While there are very few 

limitations for any one disability population, all groups may be challenged by getting the 

software trained, making accurate inputs, overcoming problematic voice characteristics, and 

dealing with noisy environments. Some of these issues can be overcome through proper design. 

Task-Based Accessibility Analysis 

The core functionality considered to be necessary to effectively use speech recognition programs 

consists of the following: 

• Using automatic voice recognition phone attendants 

• Understanding computerized voices 

• Using your voice to control your computer 

• Using voice recognition software in public settings 

• Using voice recognition software over a headset 
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• Activating voice input 

• Providing appropriate voice input (consider training, vocabulary, speech characteristics) 

• Correcting errors 

People may have difficulty accomplishing these basic tasks, depending on functional limitations 

resulting in an impairment, environmental or situational factors that create barriers, and the 

design of the voice recognition software. Accessibility issues for each disability population were 

identified, along with an impact rating for each issue. The disability populations include people 

who have an impairment resulting from environmental or situational factors. The issues 

identified and the impact ratings assigned for each disability group can be found in the appendix 

to the online version of this report. 

Accessibility Features 

A review of various speech recognition software manufacturers’ marketing data failed to identify 

any features as accessible design components. Features that would make speech recognition 

accessible include: 

Automatic suggestion of alternatives for voice recognition errors: A dictionary 

is available from which words can be suggested that resemble those that are not 

understood by the software. If the software is capable of providing good 

alternatives, this prevents the user from having to continue to attempt the speech 

input. Implementation in design will have a high impact for people who have 

cognitive disabilities and a medium impact for all other users. It will help resolve 

the issue of having difficulty entering information. 

Ability to filter out background noise: Noise filters help prevent accidental and 

perhaps inappropriate input that may go undetected or may cause the user to enter a 

different mode than desired. Implementation in design will have a high impact for 
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all users and will help resolve the issues of not being able to receive visual or 

auditory information. 

Availability of macros: Macros can be used to enter groupings of information that 

are often used as input, such as name and address. One voice command is used to 

cue the system to enter the data set, greatly reducing the amount of verbal input 

required and reducing error. Implementation in design will have a high impact for 

all users. 

Readback options: Readback allows the user to get feedback on how the voice 

input has been interpreted. It may be provided as each input is given or after 

multiple inputs to allow for more continuous data entry. Implementation in design 

will have a high impact for those with visual impairments and a neutral impact for 

other users. It will help resolve the issue of not being able to receive visual 

information. 

User manuals in alternative formats: Alternative formats include large print, 

Braille, and audio. Inclusion in design will have a high impact for users who are 

blind or have low vision, a medium impact for those who have an upper mobility 

impairment, and a neutral impact for other disability populations. It will help 

resolve the issue of not being able to read or handle printed materials. 

Ability to pause voice messages: Pause control allows the user to pause the verbal 

output from the device. This is helpful to give some time to write something down 

or to think about what option might be desired. Inclusion in design will have a 

medium impact for users who are blind and a low impact for all other users. Pause 

control will help resolve the issue of not being able to read text on the screen. 

Ability to replay voice messages: Replay control allows the user to listen to a 

message more than once. This is helpful if the voice output was not understood or 
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could not be heard over environmental sounds. Inclusion in design will have a 

medium impact for users who are blind and hard-of-hearing users and a low impact 

for all other users. Replay control will help resolve the issue of not being able to 

read text on the screen. 

Adjustable volume: Volume control is important for auditory alerts. It is 

particularly important for hard-of-hearing people, but it is useful for all. Inclusion 

in design will have a medium impact for hard-of-hearing people and a low impact 

for all other users. It will help resolve the issue of not being able to receive 

auditory information. 

Ability to change voice types: Voice types may consist of male or female, for 

example. Some voices are more comfortable for a user to listen to; some are better 

understood by one user than by another. Inclusion in design will have a medium 

impact for all users. It will help resolve the issue of not being able to receive 

auditory information. 

Ability to adjust the speed of voice messages: A speed that is too slow can 

negatively affect productivity, but a faster speed may not be well understood by all 

users. Adjustable speed of voice messages allows the user to set the level that is 

comfortable for him or her. Inclusion in design will have a medium impact for all 

users. It will help resolve the issue of not being able to receive auditory 

information. 

Ability to request additional time: Ability to request additional time allows the 

user to complete a transaction despite the need to use more than the normal amount 

of allotted time to complete individual transaction components. Inclusion in design 

will have a high impact for most users, depending on the output mode (visual or 

auditory) from the device. Additional time will help resolve the issues of not being 
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able to receive visual or auditory information, not being able to reach controls, and 

not being able to grasp objects. 

Headset compatibility: Headsets provide privacy for the user and reduce 

distraction to neighboring individuals. Headsets also help to control environmental 

noises that may be misinterpreted by the voice recognition software. Inclusion in 

design will have a high impact for all users. 

Adjustable microphone: Adjustable microphones allow users to reposition the 

microphone so that the device is at a comfortable level for the user. Users with 

lower mobility impairments will benefit from the design. 

Wireless microphone: Wireless microphones allow users to move about without 

being directly attached to the device that is being controlled. Users with lower 

mobility impairments will benefit from the added freedom of movement. 

Compliance with Government Regulations 

The primary parts of section 508 that are applicable to voice recognition software address 

software applications and operating systems (1194.21), functional performance requirements 

(1191.31), and documentation (1191.41). Many of these regulations have an impact on all users; 

others have a larger impact on one disability group than another. 

The following section 508 regulation is seen as an issue for voice recognition software: 

• Verify that at least one mode of operation and information retrieval is provided that does 

not require user vision or, alternatively, that support for assistive technology used by 

people who are blind or visually impaired is provided. 
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Conclusions 

The final result of the analysis of each product line is the accessibility grade. The overall 

accessibility grade for a product line is an index of the cumulative impact of all accessibility 

issues. The accessibility grade is a letter grade on the familiar scale of A, B, C, D, and F. The 

following definitions are offered for each grade: 

A = Excellent accessibility. Users with an impairment are generally able to make 

full use of the product, with few limitations. 

B = Good accessibility. Users with an impairment are able to make good use of 

the product, but some areas of product functionality are not accessible. 

C = Fair accessibility. Users with an impairment can access some of the 

functionality of the device, but many aspects of product functionality are not 

accessible. 

D = Poor accessibility. Users with an impairment can make use of a small 

proportion of the functionality of a device, but most aspects of product 

functionality are not accessible. 

F = Accessibility failure. Users with an impairment are generally not able to use 

the product. 

The accessibility letter grades are assigned according to the impact scores calculated for each 

target population. Details on how these grades were calculated and the task priorities, 

accessibility levels, and impact scores for each target population for each product line can be 

found in the appendix to the online version of this report. Accessibility grades may be useful to 

industry in prioritizing UD efforts and identifying what target populations should be consulted 

during the design process so that more accessible design features are incorporated into new 

products. 
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Table 1. Accessibility Grades for Each Target Population for the Six Product Lines 

Product Line 

Target 

Population ATMs 

Cell 

Phones 

Distance 

Learning 

Software PDAs TVs 

Voice 

Recognition 

Software 

Low Vision C C C C B C 

Blind D F F F D D 

Hard of Hearing A C B B B D 

Deaf A D D B B F 

Upper Mobility C C C D A A 

Lower Mobility C A A A A A 

Cognitive C C C C A C 

As these results indicate, certain product lines are very accessible to some target populations but 

largely inaccessible to others. It would be helpful in informing the UD process and developing 

products that are more accessible to people with disabilities if designers consulted the target 

populations for which a product line received accessibility grades of D or F during future product 

development. For ATMs, users who are blind will likely be unable to use an ATM or portions of 

the core functionality because of a lack of accessibility features; blind users should be considered 

in the design of new features for ATMs. Cellular phones are largely inaccessible to users who are 

blind and users who are deaf. Incorporating more features that make this product line more 

accessible to these users will expand the market for cellular phones. Distance learning software is 

largely inaccessible to users who are blind and users who are deaf. Adhering to accessibility 

regulations and guidelines for designing software will improve the accessibility of distance 

learning software for these user groups. PDAs are largely inaccessible to users who are blind and 

users with upper mobility impairments. Televisions were found to be most inaccessible to users 

who are blind because of an inability to locate, access, and read information, features, and 

controls. Voice recognition software is largely inaccessible to users who are blind, hard of 

hearing, or deaf. 
172 
173 

IV. Industry Study 

The purpose of the industry study was to document universal design practices within industries 

represented by the six product lines selected for study. Six different companies, representing each 

of the six product lines, were selected as industry partners. Selection of industry partners was 

primarily based on their leadership in the marketplace and their ability to deliver candid 

representations of their experiences with UD. During data collection, every effort was extended 

to foster an environment in which companies would be able to deliver documentation of actual 

processes and experiences. 

Each company was individually approached by Georgia Tech and asked to participate in the 

research program. Nondisclosure agreements (NDAs) were signed to assure the companies that 

Georgia Tech would protect any proprietary data disclosed during the course of the study, as well 

as to foster a general environment of open and frank discussions. Full disclosure was critical to 

the success of the industry study, because it was important that actual experiences be 

documented, as opposed to ideal situations or marketing hype. The NDA restricts Georgia Tech 

from releasing any proprietary information belonging to the industry partners. Therefore, it is not 

the intent of this study to provide detailed descriptions of experiences recorded as part of the 

research. This section documents the general experiences of companies that are representative of 

the six product lines selected for analysis and provides a basis for identifying candidate 

interventions or approaches for the promotion of UD. 

As part of the industry study, we investigated the presence of barriers and facilitators to 

accessible design. When an industry partner indicated experiences with a particular barrier, key 

personnel were interviewed to determine the policies and procedures that were used to overcome 

the barrier. Before interviewing the industry partners, we identified a candidate list of facilitator 

and barriers. 
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Analysis of Facilitators and Barriers to Accessible Design 

Source materials, generated as part of the Information Technology Technical Assistance and 

Training Center (ITTATC), were reviewed to identify potential facilitators to accessible design. 

Facilitators are defined as concepts, procedures, or actions that can be employed by industry that 

might result in the development of accessible technologies. We read the needs assessment 

literature review, a survey of ITTATC National Advisory Committee participants, and a survey 

of accessibility visionaries in order to create the initial list of facilitators. The list was 

supplemented by our experience consulting with industry and our preliminary findings from the 

ITTATC case studies project. 

The list of facilitators is divided into five categories: design, organizational, informational, 

financial, and legal facilitators. Design facilitators are methods or tools that can be implemented 

in the design process to possibly achieve a more accessible design. Organizational facilitators 

include augmentations to communications and infrastructure that may enhance the effectiveness 

of an accessibility program in a company. Informational facilitators address the lack of 

knowledge in accessible design and the continuation of common misperceptions. Financial 

facilitators include factors that make accessibility appear to be fiscally attractive. Finally, legal 

facilitators include legal positions that make accessibility easier to achieve. 

Design Facilitators 

• Integrate accessibility into engineering processes. Often accessibility of a product can be 

improved by integrating the consideration of the product’s accessibility as a formal step in 

the engineering design process. The most desirable outcome is usually observed when 

accessibility is addressed very early in the design process. 

• Develop standardized mechanisms for connecting assistive technologies. A common 

complaint from industry is that it is difficult to ensure that their products successfully 

interface with AT, because not enough is known about the detailed interface requirements 

of the variety of AT products on the market. 
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• Make technological advancements for handling adaptive devices and flexible design. For 

example, develop smaller components for connecting assistive devices so that products 

can be smaller and lighter. 

• Develop innovative strategies to promote awareness and understanding of universal design 

issues. For example, a company could sponsor a design challenge contest to address a 

specific accessibility concern or award bonuses to those who significantly contribute to the 

design of a more accessible product. 

• Share ideas, concepts, and research with other organizations, including encouragement of 

peer-reviewed research. Two possible means to accomplish this are by hosting a 

conference or publishing a journal of accessible design. 

• Develop awareness of efforts in accessible design from competing companies. 

• Develop accessible design standards and guidelines. 

• Develop a tool to help individuals understand their role in universal design. 

• Provide training for understanding accessible design, including demonstrations of why a 

particular approach may not work for an individual with a particular limitation. This will 

help the designers adjust their approach to thinking about accessible design and 

developing accessibility design practices in the early phases. 

• Fund the acquisition of ergonomic and human performance data for people with 

disabilities. 

• Develop methods for measuring accessibility and comparing the accessibility of two 

similar products. One approach to addressing these issues would be to start or participate 

in a working group to develop standardized measurement methods. 

• Develop a working group to formulate a clear definition of design goals related to 

accessibility. 

• Promote the benefits of UD. Accessible design is likely to benefit a much larger 

population than the target group. 
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• Perform accessibility evaluations on new and existing products and services. 

• Include elderly individuals and individuals with disabilities in the design process. Get 

input from them early and recruit them to participate in evaluations. This can be done 

through prototype and product testing, focus groups, direct contact with the designers, 

discussion forums, and other mechanisms. 

• Test for product compatibility with assistive technologies. 

• Hire product designers with disabilities or with experience in creating universally designed 

products. 

• Hire support personnel with disabilities to work directly with designers. 

• Designate an accessibility coordinator to monitor accessibility issues and become familiar 

with related standards and guidelines. 

• Provide concrete design examples of universally designed products. 

Organizational Facilitators 

• Share accessibility information companywide, and make it part of the culture. Ensure that 

all departments have the same understanding of accessibility requirements. 

• Educate the company on the tangential benefits of accessible design. While most 

companies recognize that increased accessibility will result in an increase in the user base, 

some do not realize the benefit of UD for the existing user base. 

• Increase diversity in the workforce. 

• Develop brown bag and discussion groups regarding accessibility efforts so that upper 

management has the opportunity to learn about these efforts and factor this information 

into corporate decisions. 

• Ensure that the personnel responsible for making marketing, product development, and 

design decisions are educated about accessibility and accessible design. 
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• Educate middle management on how accessible design can be made part of the design 

process without burdening schedule and budget requirements. 

• Recognize accessibility as a necessity for the general population rather than as an 

exception. 

• Incorporate accessibility standards into quality assurance programs. 

Informational Facilitators 

• Educate employees that people with disabilities have the same wants and needs as people 

without disabilities (e.g., communication, bill paying, travel). Remind them that the 

general population suffers from a number of temporary disabilities as well as disabilities 

related to aging. 

• Recognize that relatively small changes can have a large impact on accessibility. 

Something as simple as reducing the force required to press a button can greatly increase 

the usability of a product for all potential users without taking away from design creativity. 

• Provide accessibility training for managers, designers, sales representatives, customer 

service personnel, and any other groups that may benefit from the knowledge. 

• Advertise accessibility features of products, and emphasize the benefits for everyone. 

• Gather as much information about accessibility and disabilities as possible. Survey 

employees, canvas disability groups for information, hold community meetings to get 

direct input from people familiar with disabilities, and provide a Web link and/or phone 

number dedicated to obtaining feedback on product accessibility. 

• Form partnerships/relationships with organizations devoted to promoting accessibility. 

• Provide information to consumers about their rights under section 508 and section 255 and 

the company’s efforts to comply with those regulations. Complete voluntary product 

accessibility templates (VPATs) for products so that consumers can make informed 

decisions. 
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• Purchase assistive technologies for designers to work with, and train them to use the 

devices properly. 

• Increase exposure of engineers and designers to accessible design. Train them when 

they’re hired, develop a short course that can be made available through local universities, 

and encourage someone in the company to teach at local universities to increase exposure 

at the university level. 

• Recruit employees who have a background in universal design. 

• Ask employees (particularly those with temporary or permanent disabilities) to comment 

on the usability of products they use and to provide design suggestions. Establish a 

mechanism for employees to provide feedback, and possibly develop a discussion forum 

from which additional informal feedback can be acquired. Use the people already in the 

company, as many of them may have experiences with others who have limitations. 

Financial Facilitators 

• Recognize accessibility as a product enhancement, not as a prohibitive-cost retrofit. 

• Market products with accessible features to a large population, not just to the target market 

for which they are believed to be appropriate. 

• Use employees to reduce costs associated with funding research in accessible design. 

• Include accessible design as a regular part of the design process rather than as a feature 

that needs to be addressed separately at added cost. 

• Factor accessibility upgrades into the cost of other important upgrades. 

• Study the cost of not designing accessible products. For example, revenue may be lost 

because of the inability to effectively market to a federal customer. 

Legal Facilitators 

• Demonstrate efforts to comply with section 508. Create VPATs. 
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• Review consumer complaints received by legislators and industry. 

• Designate an accessibility expert to monitor government regulations. 

• Pressure the government for more detailed requirements that industry must meet or 

guidelines for satisfying the regulations. 

The process used to identify candidate barriers was similar to the process used to identify 

candidate facilitators. Source materials, generated as part of ITTATC, were reviewed to identify 

potential barriers to accessible design. Barriers are defined as potential roadblocks to a successful 

accessibility program. We read the needs assessment literature review, a survey of ITTATC 

National Advisory Committee participants, and a survey of accessibility visionaries in order to 

create the initial list of barriers. The list was supplemented by our experience consulting with 

industry and our preliminary findings from the ITTATC case studies project. 

Similar to the list of facilitators, the list of barriers is divided into five categories: design, 

organizational, informational, financial, and legal barriers. Design barriers are obstacles in the 

design process that may result in difficulty in achieving an accessible design. Organizational 

barriers include impediments to communications and infrastructure that may limit the 

effectiveness of an accessibility program in a company. Informational barriers have to do with 

the lack of knowledge about accessible design and the continuation of common misperceptions. 

Financial barriers include factors that make accessibility appear to be fiscally unattractive. 

Finally, legal barriers include factors that make accessibility difficult to implement because of 

litigation concerns. 

Some of the barriers are merely perceived barriers, resulting from a lack of knowledge of or 

insufficient experience in accessibility. Other barriers represent more significant challenges to the 

accessibility community in general. 
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Design Barriers 

• Marketing and technology trends sometimes run counter to accessibility requirements. For 

example, the cell phone industry has followed a trend in miniaturization that has resulted 

in the creation of a smaller keypad that is difficult to use for individuals with some types 

of upper mobility impairments. The font size used for the labels on these keypads has been 

reduced as well. 

• There is a general lack of peer-reviewed research in accessible design. Many human 

factors professions complain of the lack of human performance research to support design 

in general. Even fewer studies focus on human performance issues for people with 

disabilities. In addition, little information exists about standard practices and methods of 

accessible design in the open literature. Designers simply do not have access to 

information they need to create accessible products. 

• There is a lack of realistic standard guidelines and principles of accessible design. 

• Designers lack an understanding of accessible design and what can be achieved if products 

are designed from the beginning with accessibility in mind. Very few commercially 

available products exist that represent successful exercises in accessible design. 

• Designers do not have access to information about people with disabilities in a format 

usable to them. Designers often require human performance and ergonomic data in an 

easy-to-use format to support design decisions. Unfortunately, human performance and 

ergonomic data for special populations, including people with disabilities, are not a part of 

the standard data sets. Designers must consult outside sources and attempt to compile the 

necessary data from a wide variety of technical reports and published articles. The 

compilation of these data is extremely time-consuming and often unfeasible. 

• A standard accessible design process has not been documented, tested, or verified. 

• Implementation of multiple methods of display and control may make it difficult to create 

a streamlined user interface. Many feel that the addition of accessibility features creates an 

unwieldy user interface. 
181 

• There is no standardized method of measuring accessibility or comparing the accessibility 

of two similar products. Designers do not have a way of determining whether their designs 

have met their accessibility goals. 

• Many feel that there is no clear definition of how accessible a product has to be in order to 

be considered an accessible design. 

• Many designers equate accessible design with designing products for the lowest common 

denominator. 

• Individuals with disabilities are not integrated into the design or evaluation process. 

• There is a lack of tools and resources useful for efficiently creating accessible products. 

Organizational Barriers 

• Often there is a lack of communication across departments about accessibility 

requirements. A few pockets of accessibility awareness seem to exist in many companies, 

but there is a lack of structure integrating a comprehensive accessibility program. 

• Many companies lack accessibility champions who are in a position to influence company 

decisions. In many cases, personnel responsible for a company’s accessibility efforts come 

from human factors, usability, or disability support groups. In general, these groups do not 

have a large amount of input in corporate decisions. 

• Often personnel responsible for making accessibility decisions have little knowledge about 

accessibility or accessible design. 

• Middle management often perceives accessible design to be in direct conflict with 

schedule and budget requirements. 

• Accessibility is often a minor concern compared with other corporate issues, especially in 

today’s economy. 

• There is a lack of infrastructure to support accessible design. 
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Informational Barriers 

• Some view people with disabilities as not having the same wants and needs as people 

without disabilities. 

• Sometimes designers fail to consider the possibility that someone with a disability would 

attempt to use the products they design. 

• Sometimes accessibility features are poorly communicated to the consumers who require 

the features. 

• Specific information about accessibility and disabilities, in general, is not easy to obtain. 

• Companies often do not know how to market to people with disabilities. 

• Consumers are not familiar with their rights under section 508 and section 255. 

• Some designers do not have sufficient access to assistive technology interface 

requirements. 

• Engineers and designers are not sufficiently exposed to accessible design at the university 

level. 

• Accessibility is often interpreted narrowly to include only physical access to the 

technology. 

Financial Barriers 

• The cost of developing new technologies associated with accessibility is often seen as 

prohibitive. 

• The target market for accessible design is not well understood or defined. 

• There is a general lack of sources of funding for research in accessible design. 

• Some people feel that the business case for accessibility is weak. 

• It is difficult for companies to market to consumers with disabilities. 

• The cost associated with retrofitting existing products is significant. 
183 

• The cost associated with purchasing accessible products is often not affordable by people 

with disabilities. 

• The technology required to produce accessible products is not available at a reasonable 

cost. 

Legal Barriers 

• Some companies feel that they are under pressure to self-certify compliance with section 

508 in order to compete. 

• Some feel that federal regulation does not go far enough in detailing the requirements that 

industry must meet. Others feel that the regulations unnecessarily restrict creative design 

and innovation. 

• Exploration of the federal requirements through litigation is both time-consuming and 

costly. 

• Some companies believe their competition is incorrectly representing its product’s 

accessibility. 

• Procurement officials do not understand accessibility requirements to a sufficient degree. 

Officials may not be able to recognize when an accessibility claim is false. 

• Section 508 is either not being adhered to or is being adhered to inconsistently. 

Industry Study Data Collection Methodology 

Six companies or industry partners were selected for participation in the study. Once the 

companies were identified and the points of contact (POCs) established, each was given a list of 

topics related to accessibility in the company. Georgia Tech requested initial reactions during 

preliminary phone interviews and then conducted onsite visits and in-person interviews with 

various individuals involved in the accessibility program. Some industry partners chose to 

provide detailed documentation and formal responses to our initial inquiries before the 
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interviews. The purpose of the in-person interview was to obtain additional information and 

documentation to enhance the initial responses provided on the topics of interest. 

The data collected were based on a series of topics related to accessibility in each company. The 

type and format of data requested in response to each of the 10 topic areas is listed below: 

 1. Documentation of current design practices, with emphasis on user interface design and 

other aspects of products related to accessibility and UD. 

 2. Documentation of current product evaluation practices, with emphasis on accessibility and 

UD. 

 3. Key personnel who make decisions about product design, product selection, and/or 

marketing related to accessibility and UD. 

 4. Current products (fielded or in development) with specific accessibility features or other 

direct relationship to accessibility. 

 5. Lessons learned in developing accessible products. Focus on organizational barriers 

encountered, technical challenges, financial barriers, informational barriers, and legal 

challenges. 

 6. Company forecasts of demand and requirements for products with accessibility features. 

 7. Company training materials related to accessibility and UD. 

 8. Company-funded research into accessibility and UD. 

 9. Company contact with members of the disability community relevant to product 

accessibility and usability by individuals with disabilities. 
185 

 10. Company position on product accessibility and UD. 

Georgia Tech scheduled an initial meeting with the company POC, during which the industry 

study objectives and data requirements were reviewed in detail. Any readily available 

information was collected, and the company POC was charged with identifying sources for 

archival data and arranging personal interviews with individuals qualified to supply the required 

information. The information analyzed in this summary is based on materials provided directly 

from the company, notes from the in-person meeting, and publicly available materials. 

Analysis of Industry Data: Factors Influencing Adoption of UD Practices 

As defined by Tobias and Vanderheiden (1998), the primary factors that influence the adoption 

of UD principles are government regulation (or the threat of regulation) and profitability. The 

purpose of the industry study was to build upon previous work and understand how the 

perception of profitability affects UD. Eleven business concerns have been identified as having 

an influence on UD practices in an organization. Each business concern has a different level of 

influence, depending on the strength of the other factors. The factors influencing the adoption of 

UD practices include the business case, strategy and policy, demand and legislation, marketing 

and sales, research, design, testing, resource allocation and funding, organization and staff, 

training, and the customer and consideration of people with disabilities. Detailed descriptions of 

the impact of each business concern on UD are described below. 

Business Case 

The business case is the financial justification and plan for including accessibility in product 

design. Central to consideration of the adoption of UD principles for all six industry partners was 

the identification of a compelling business case to justify committing the required resources to 

the effort. Someone at a company wishing to add accessibility features to an existing product or 

to add schedule and budget to accommodate building accessibility into the design of a new 

product is often required to justify the added expense by producing either a formal or informal 

business case for accessibility. 
186 

There are several methods that might be used to construct a business case. Each method relies on 

the interpretation of market forecasts and sales data and is, therefore, somewhat subjective. For 

example, a senior manager might look at federal sales data and determine that the number of 

sales at risk because of the production of inaccessible products is negligible and therefore 

produce a very weak business case for accessibility. A second senior manager might look at the 

same data and see great potential for increasing the market share of federal sales by enhancing 

accessibility, therefore determining that the business case for accessibility is strong. 

The industry study identified the following primary justifications for the business case for UD: 

• Increase market share to include people with disabilities 

• Increase federal sales market share 

• Reduce risk of losing market share 

• Increase overall usability of the product or service 

• Reduce risk of costly legal action 

• Increase status as a corporate citizen 

While increasing market share in general is traditionally regarded as a strong justification for a 

business case, the potential to increase market share by extending the market focus to cover 

people with disabilities is often seen as a relatively weak business case, primarily for two 

reasons. First, the market for people with disabilities is highly segmented. The cost associated 

with developing a product for users with various disabilities and levels of functional capabilities 

is not justified by the potential of direct sales to people with disabilities. Second, the amount of 

disposable income available to people with disabilities is not perceived to be great. The 

additional cost associated with producing accessible products cannot be passed along directly to 

consumers with disabilities. 

Companies do not appear to fully appreciate the potential value of extending their market share 

to nontraditional markets through UD. Universal design is generally associated with design for 
187 

inclusion of people with disabilities. The market analysis documented elsewhere in this report 

illustrates that this view of the market for UD products is unnecessarily restrictive. Companies 

representing the six product lines selected for analysis have failed to embrace the extended 

market perspective for UD products. 

The introduction of section 508 of the Rehabilitation Act, requiring federal agencies to consider 

accessibility in the procurement of most products and services, should have had a direct impact 

on the calculation of the market size of UD products. Sales to the Federal Government represent 

a significant portion of sales for many companies producing E&IT products and related services. 

Based on the face value of section 508, businesses wishing to increase federal sales might do so 

by developing a more accessible product than the competition and using accessibility as a key 

discriminator on competitive bids. However, many of the industry partners failed to recognize the 

potential increase in federal sales as a strong business case, perhaps because of the perception 

that procurement officials are not consistent in enforcing section 508. 

Perhaps more compelling than the potential increase in federal sales is the threat of loss of 

Federal Government market share to a competitor. A company that enjoys a large share of the 

federal market could lose market share if a competitor creates an accessible product that federal 

procurement officials choose over the traditional supplier in an effort to conform to the 

requirements of section 508. In reality, none of the companies participating in the industry study 

were aware of any lost sales that could be attributed directly to an attempt of a procurement 

official to conform to the requirements of section 508. 

Business cases are sometimes generated in response to less tangible benefits and threats that are 

not directly related to a company’s market position. For example, one of the companies in the 

industry study referred to corporate citizenship as a justification for research into accessibility 

and UD. Another company perceived accessibility as clearly being related to usability, which had 

been identified as a key market discriminator. Finally, one company mentioned a concern about 

avoiding future legal actions as a motivator for accessibility. 
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Strategy/Policy 

Strategy is the high-level plan for UD or the implementation of accessible design features. A 

policy is a written a statement that is a reflection of corporate strategy. Most industry partners 

had an informal or formal policy statement approved by senior management; however, they 

differed widely in their content and implementation. External policy statements tended to be used 

primarily for marketing and had little overall impact on processes and procedures. When an 

internal policy statement was drafted and issued to employees, it usually had the effect of 

temporarily increasing awareness of accessibility; but a sustained, corporatewide commitment is 

rare without the dedication of resources. Internal policy statements that lack an associated 

commitment of resources are rarely enforced. 

An effective policy must reach the level of a corporate instruction or directive and address 

inclusion of people with disabilities in design and evaluation of products, increased training, 

incorporation of documented standards and guidelines, increased research and development, 

increased marketing of accessibility features and efforts, and lowered costs for products with 

accessibility features. The policy must also be associated with an implementation plan and a 

commitment of needed resources. 

Corporate culture had a strong influence on accessibility. In two of the six companies in the 

industry study, employees reported that the corporate culture was such that accessibility was 

expected to be considered when making design decisions. A strong corporate culture was 

generally associated with a strong customer voice requiring that accessibility be considered. 

Accessibility will be considered, independent of policy, if the customer demand is great. Policy 

tended to be more entrenched in corporate culture if someone from senior management 

experienced a disability or a close relationship with someone with a disability. 

Resource Allocation/Funding 

Resource allocation and funding was the single most frequently identified reason for the failure 

of accessibility policy. Four of the six companies had money earmarked for staffing accessibility 
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program offices; however, the program offices were often underfunded and did not have 

sufficient resources to effect change in the corporation. In some cases, the accessibility program 

office consisted of only one or two individuals who served as the focal point for accessibility 

concerns throughout the company. Only one company earmarked money specifically for 

accessibility research. Outreach to employees was also severely limited. The accessibility 

program offices often developed plans for implementing universal or accessible design but 

lacked funding to appropriately implement the plans. 

At least one company that decided to commit to accessibility and establish an accessibility 

program office was reevaluating the commitment of resources because of an inability to 

demonstrate return on investment (ROI). The company cited a lack of impact of accessibility 

features on federal procurement decisions as the primary motivator for reconsidering its 

commitment to accessibility. Companies spending less money on accessibility were not 

perceived to suffer decreased sales as a result of section 508 procurement regulations. 

Organization/Staff 

Several methods of staffing for accessibility issues were observed. The most common staffing 

organization, used by four of the six companies, involved the development of an accessibility 

program office responsible for UD and accessibility issues throughout the corporation. The size 

of the accessibility program offices varied from a single member to a staff of five or six with a 

background in accessibility issues. In other cases, responsibility for accessibility was integrated 

into existing groups, such as marketing or human factors. 

Two staffing trends were noted. First, the presence of a single accessibility champion or a small 

number of accessibility champions was very common among the industry partners. The success 

of the accessibility program in a company that must rely on the work of a very small number of 

accessibility champions was directly related to the workload or attrition of the champions. Loss 

of an accessibility champion could result in a major setback of accessibility objectives. Second, 

the accessibility program office may become a place to assign nonproductive personnel. While 
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the majority of accessibility program offices are staffed by competent individuals capable of 

advancing UD principles if given adequate resources, some companies have assigned 

accessibility to individuals who are either transitioning between departments or are experiencing 

difficulty marketing themselves within the company. 

The mission of the accessibility program offices also varied widely. In some cases, the program 

offices were mostly reactive, responding to requests for information or to particular accessibility 

concerns. In other cases, the accessibility program offices were very proactive and focused on 

developing and testing new technologies that might be integrated into future products. In reality, 

a balanced approach is required. The group charged with accessibility should be able to respond 

to the immediate needs of the corporation as well as contribute to future planning and 

development of universally designed products. 

Unfortunately, the accessibility program office in the four companies that had program offices 

demonstrated very little control over design decisions that directly affected the accessibility of 

the final product. The accessibility program office should be constructed to include groups (or 

individuals) who have decision-making responsibilities to influence product accessibility. This 

may include a human factors group or an accessibility group, or even an oversight group that can 

serve as a resource for other groups in the company. It also helps for accessibility awareness to be 

widespread throughout the company. One method of accomplishing this is to have staff in each 

group or available to each group who have more extensive training and who can advocate for 

inclusion of accessibility features. 

Another staffing mechanism for enhancing accessibility practices in the company is to hire 

people with various disabilities and ensure that they are involved with the design and evaluation 

of products. However, this mechanism can be used inappropriately. For example, it would be 

inappropriate to send a new product to a single employee with a disability and ask the employee 

to quickly review the product rather than conducting more extensive product testing. This 

approach is especially problematic if the employee has other responsibilities, has little experience 
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with product evaluations, and is not prepared to comment on the accessibility of the product 

beyond his or her personal experiences. 

Training/Awareness 

Some corporate accessibility training was offered to employees; however, training relating to UD 

and accessibility is not widespread. The most common type of training was aimed at increasing 

employee awareness of section 508, accessibility policy, people with disabilities, and the specific 

accessibility issues associated with the products that the company produces. An important 

function of several accessibility program offices was to provide targeted training to key decision 

makers, as needed. The targeted training was largely informal and usually conducted on a rather 

limited basis. The training offered was generally focused on program managers and design teams. 

Very little training was offered to sales or marketing teams. 

Typically, accessibility awareness is made available on an as-needed basis and is specific to a 

project. In some cases a brief introduction is provided to all employees regarding the importance 

of UD, but sometimes it is simply awareness through diversity training. Training materials may 

include an overview of the range of disabilities (including situational disabilities), assistive 

technologies, principles of UD, minimal design requirements, business and consumer arguments 

for addressing accessibility, consequences of not addressing accessibility, a review of 

accessibility features, legal requirements, and barriers and lessons learned. 

Training of staff is one of the best mechanisms for getting accessibility included in product 

design. Often accessibility is overlooked because of a lack of awareness of the issues. People do 

not realize how inaccessible products can be to individuals with disabilities and they do not 

understand how much an individual’s life can be improved with the availability of more 

accessible products. Training can greatly affect accessibility practices through increasing 

awareness of disability issues, increasing awareness of standards and guidelines, and providing 

tools (processes and checklists, for example) to facilitate accessibility implementation. 
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Companies should be aware of hidden messages in corporate training. For example, if a company 

emphasizes section 508 conformance over accessibility in general, employees may come to view 

UD and accessibility as a federal sales issue. Designers may choose to ignore accessibility 

requirements if they know that their product is not likely to be marketed to the Federal 

Government. 

To be effective, training should be tailored for the decision makers who routinely affect 

accessibility in the corporation. Technical staff might like to consider the needs of people with 

disabilities, but they are junior staff members who do not have the power to implement major 

design decisions. Technical staff training is effective if concrete design examples and 

information about integrating UD guidelines into the design process are offered. However, 

changes to the design process are often resisted by middle managers, who argue that extra 

development time would be required, that money must be expended, or that these changes are not 

relevant to the target market. The key decision makers are the key product team members and the 

personnel who are responsible for defining the products’ functional requirements. 

One successful method of providing UD and accessibility awareness training is to incorporate 

basic constructs into employee induction training. Other successful training methods include 

alternative delivery methods, such as a video, on the importance of UD and the impact of 

inaccessibility on the lives of people with disabilities. Computer-based training materials have 

also been used to increase general awareness of accessibility issues. 

Research 

With one notable exception, the accessibility program offices of the four companies participating 

in the industry study were not directly linked with corporate research. One company was able to 

successfully integrate personnel with research experience into the accessibility program office. 

This integration allowed the program office to offer design solutions to the accessibility problems 

that it identified through testing. However, most accessibility program offices were not in a 
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position to influence research priorities or review research before it was integrated into a product 

development cycle. 

Several companies successfully employed external consultants to assist with UD or accessibility 

research. However, externally funded research tended to be more exploratory in nature and less 

focused on design-oriented solutions. 

Research into accessibility issues is dependent on available funding. Much design work is 

dependent on research of the best way to implement accessibility features, compatibility with 

assistive technologies, and development of emerging technologies. Advanced and ongoing 

research can influence accessibility implementation through identification of features that are 

useful for the disability community, cost-effective, and appealing to a wide population. 

Design 

In many cases, accessibility processes are in place for both design and quality assurance, 

including user-centered design, but are either not documented or not followed consistently. 

Accessibility requirements are not well integrated into existing design processes. For those 

companies that do include accessibility requirements in the design process, the requirements are 

typically tailored to the specific product line or range of product lines produced by the company. 

Design decisions are made by a range of personnel. Industrial designers or design management 

teams typically handle display and control layout. Product managers or core team members detail 

the design and ensure manufacturability. Some design decisions are made at the engineering 

level. Typically, decisions about trade-offs are made at an upper-management level. Decisions 

about product requirements are typically handled at the marketing level. Accessibility champions 

can have some influence over the design, independent of the above-mentioned roles. 

All six companies participating in the industry study adopted some variant of a product 

development or life cycle design process. However, the companies varied in the extent to which 
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they followed engineering process manuals. Smaller projects and internal research and 

development projects tended to operate outside the formally defined development process. None 

of the companies reported immediate changes to the development process in response to section 

508. Rather, UD and accessibility requirements have slowly been integrated into the development 

process, mainly in response to efforts from members of the companies’ internal accessibility 

program offices. Three of the six companies reported that accessibility was addressed in its 

formal engineering product manuals. However, two of those three companies reported that their 

formal engineering process simply required that accessibility be considered at some point in the 

design process. In general, detailed requirements or checklists relating to accessibility were not 

found in formal design documents. 

The product life cycle design process is intended to manage the product from its inception 

through its retirement and eventual cessation of support. Although different companies have 

different names for their design processes, the processes all generally follow these steps: 

• Product planning 

• Requirements definition 

• Product specification 

• Development 

• Verification and testing 

• Manufacturing 

• End-of-life management 

In order for UD principles to be incorporated into the final product, the principles must be 

considered at the very beginning of design. Accessibility must be considered during product 

planning. Companies that relied solely on accessibility testing after product development were 

unable to have a substantial impact on the overall accessibility of the product. Product planners 

must decide very early whether accessibility will be considered in the design of the product and 
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to what extent the product will meet or exceed accessibility technical guidelines. Companies that 

failed to consider accessibility early in product development often failed to have a significant 

impact on the accessibility of the final design. 

In the requirements-definition phase, it is important to define objectively testable requirements 

for accessibility. It is not sufficient to require that the product be accessible, because doing so 

provides little information to designers and prevents accessibility verification testing. Vague 

accessibility requirements are more likely to be ignored in both the development and the 

verification and testing phases of design. Proper accessibility requirements should be defined in 

the form of the incorporation of relevant section 508 technical requirements or specific functional 

performance requirements. For example, the requirements document could incorporate specific 

paragraphs from section 508 technical requirements that apply to the specific product under 

development, or it could require that specific user tasks must be able to be performed by a given 

population of users with specified functional capabilities and limitations. 

During the product-specification phase, the functionality and appearance of the product is 

defined in accordance with the definition of product requirements. Personnel with expertise in 

UD must be available to assist in defining the specifications, reviewing the product specifications 

that affect accessibility, and determining whether the accessibility-related product requirements 

are met by the product specification. Major changes to the product design are unlikely after the 

product specification has been produced, so it is critical that accessibility be considered before 

moving on to the design phase. 

During development, the design is conceptualized, produced, and prototyped. Typically, a project 

leader will arrange a multidisciplinary team that might involve members of engineering, 

computer science, industrial design, human factors, quality assurance, and marketing. At least 

one member of the development team should have an understanding of the accessibility issues 

related to the product under development. Iterative testing and development are important during 

this phase. 
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Testing 

Companies participating in the industry study routinely performed usability testing, but they 

rarely included users with disabilities in usability testing and rarely conducted user testing for 

accessibility. Accessibility evaluations are different from standard usability evaluations in at least 

three ways. First, accessibility evaluations measure the degree to which a specific impairment 

restricts the operation of a device. In addition to measuring how effective a device is, usability 

evaluations also tend to measure customer satisfaction and efficiency. While satisfaction and 

efficiency data may be collected during an accessibility evaluation, this type of data is not the 

primary focus. A device that has usability issues may still remain accessible, as long as the 

usability problems do not disproportionably affect the ability of a user with an impairment to 

accomplish a given task. Second, accessibility evaluations are, in general, performance-based 

rather than subjective. The focus of an accessibility evaluation is generally on measuring 

functional performance. Finally, the primary motivation for performing an accessibility 

evaluation is compliance with government regulations. While technical standards and guidelines 

for usability certainly exist, there are few legal requirements that must be met in order for a 

device to be considered usable. 

Federal procurement officers, in an attempt to comply with section 508, routinely request 

information about the accessibility of a product before a purchase. All the companies that 

participated in the industry study reported some level of UD or accessibility testing. However, 

the depth and breadth of the testing varied widely. Most testing was performed in order to fill out 

a voluntary product accessibility template. One company’s engineering process required that a 

VPAT be constructed before launching the product. Although it is unlikely that an unfavorable 

evaluation would delay product launch, requiring the VPAT prior to launch does force the design 

team to consider accessibility. VPATs are often requested by federal procurement officers as part 

of their required market research. Two of the six companies performed quality assurance or 

requirements-verification testing as part of the normal design process. 
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Testing was generally restricted to an inspection for conformance with the technical requirements 

of section 508. Notably, the functional performance requirements of section 508 were often 

overlooked. The functional performance requirements are perceived as being difficult to test. The 

most effective method of testing these requirements involves user-in-the-loop testing with 

representative members of the disability community. Use of a task-based approach is critical to 

accurately measure accessibility and directly compare the accessibility of more than one similar 

product. None of the industry partners routinely performed user testing for the purpose of 

measuring conformance with the functional performance requirements of section 508. 

The industry partners were split regarding a preference for internal or independent third-party 

testing. Three companies preferred to keep testing in-house, and three companies preferred to 

contract an independent lab to perform testing. 

As with any kind of testing, accessibility evaluations are more effective if they are conducted in 

conjunction with an iterative design process. Testing can have the greatest impact on accessibility 

if people with disabilities are included in the evaluation process and have the opportunity to do 

early testing to facilitate design changes. 

Demand/Legislation 

Demand is affected by consumer needs and interest as well as legislation requiring accessibility. 

Demand can influence the presence of UD features in three ways. First, consumers may voice 

their interest in products with accessibility features. If customer demand is great enough, 

companies are likely to address accessibility issues. Second, some companies primarily market to 

other companies. For example, cell phone manufacturers market their products to cellular 

network providers. The purchaser—the cellular network provider in this example—is in a strong 

position to pass along requirements for UD to the manufacturer. Finally, if enforceable 

legislation requires the government to purchase accessible products or requires a minimal level of 

accessibility, industry will not be able to ignore the need to incorporate accessibility features into 

its products. 
198 

However, legislation has not been extremely effective in increasing demand for accessible 

products. Many problems stem from conflicting requirements. Local and global requirements 

may differ. The business customer’s requirements may differ from other requirements that 

support accessibility for the end-user. In addition, the regulations do not change as quickly as 

technology does, limiting the development of enhanced capabilities. Not all consumers have the 

latest version or model, rendering some applications inaccessible for those using older 

technologies. To complicate the issues further, the federal requirements are too general to be 

extremely useful and lend themselves to various interpretations. Some companies even 

misrepresent accessibility of their products; they claim to be 100 percent accessible but fail to 

deliver an accessible product or deliver only a partially accessible product. 

Marketing/Sales 

One method of increasing demand involves adequate marketing of products with accessibility 

features. Often, companies develop products that have accessibility features, but they are not 

marketed as features that support the needs of a particular disability population. Unless the 

consumer does extensive research, it may not be evident that the features exist. Consumers do 

not always know what to ask for or how to ask, so unless the products are marketed appropriately 

or the sales staff are trained to identify features that may benefit a particular user, awareness of 

those features will remain low. Sales staff should be trained to discuss accessibility features with 

consumers, to spot consumers who may benefit from particular features, and to relay customer 

requests back to designers or another appropriate department in the company that will get those 

requests factored into design considerations. 

Some companies do not have any forecasts for accessibility marketing. There is considerable 

recognition that the aging population is increasing and will need to be accommodated, though 

this is not addressed in the current marketing strategy. There is also increased recognition for 

accommodation of temporary disabilities resulting from a physical or mental impairment or from 

an environmental or situational limitation. 
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Customers/People with Disabilities 

The final influences on accessibility are the customer—whether a business customer (for 

example, the carrier, in the case of cell phones) or the end-user. When a business customer is the 

major driver of product requirements, UD solutions are not likely to be integrated into a product 

if they are not requested. 

End-users, including people with disabilities, can influence the design process by supporting 

companies in their efforts to generate products that include accessibility features. Customers can 

also influence the design process by making their problems and successes known to the 

companies so the designers can build on that knowledge and improve the process for future 

product development. However, there were few examples of customer feedback resulting in a 

change to the design of a product. 

Many companies shy away from direct interaction with people with disabilities or disability 

advocacy groups. Companies often perceive that inclusion of people with disabilities is 

complicated, perhaps even aversive in nature. As an alternative, they sometimes have phone 

contact with accessibility organizations that assist them in understanding the needs of users with 

various functional limitations. The quantity and quality of the guidance received from the 

advocacy group is perceived to be largely dependent on who happens to answer the phone on a 

given day. 

Companies are often hesitant about interaction with disability advocacy groups unless the 

technology they are developing is perceived to be accessible. Companies often seek an advocacy 

group’s “stamp of approval” but rarely interact directly with the group to improve the 

accessibility of an inaccessible product. Some companies interact specifically with employees 

with disabilities but do not involve outside individuals. Other interaction is through conferences, 

workshops, and trade shows. Some companies perform user testing internally or through outside 

consultants, and this occasionally involves people with disabilities. 
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Analysis of the Industry Study Findings 

All the companies that participated in the industry study have made strategic decisions to address 

the accessibility of their products and services. A few of the companies had long-standing 

accessibility programs that were reinvigorated by the technical requirements of section 508. 

Other companies initiated their accessibility activities while planning for their response to section 

508. Regardless, section 508 has clearly had an impact on the way accessibility and UD are being 

addressed in industry. The most common approaches to addressing accessibility issues were— 

• Increasing the awareness of employees 

• Integrating accessibility requirements into the design process 

• Performing accessibility verification testing 

• Establishing an accessibility program office 

All six companies in the industry study provided training, formally or informally, to a subset of 

their employees. Three of the companies have integrated accessibility guidance, particularly the 

technical requirements of section 508, into their design process. Four of the six companies 

performed accessibility verification testing for the purpose of generating a VPAT for federal 

procurement officials. Finally, three of the industry study partners established accessibility 

program offices to coordinate accessibility activities in the company. 

The industry study has identified a number of situations in which UD principles have been 

successfully integrated into corporate culture; however, there are still numerous opportunities for 

improvement. First, government legislation has had an impact on the accessibility of E&IT but 

has fallen far short of its potential to inspire universally designed products. Second, the industry 

study identified a number of barriers to accessibility experienced by the study participants. Some 

issues were associated with specific industries; however, the vast majority of barriers are 

common to all industries represented by the six product lines selected for study. The potential to 

develop interventions that are likely to have a profound effect on a large number of companies 

producing E&IT products and services is significant. 
201 

A research project studying the barriers to UD was conducted from 1996 to 1998 by Dr. Pieter 

Ballon, Dr. Gerd Paul, Dr. Leslie Haddon, and Dr. Monique van Dusseldorp under the European 

Union’s Telematics Applications for the Integration of Disabled People and the Elderly (TIDE) 

program. The team interviewed 68 managers from telecommunications, computer hardware, 

software, electronic commerce, public information services, Internet, broadcast, and interactive 

services firms. The interviewees were middle- and high-ranking managers from marketing, 

product management, design, and usability departments, primarily in the Netherlands, Germany, 

and the United Kingdom. Ballon’s team found that there was a low awareness of UD among 

these upper- and mid-level managers. Few of them believed that UD would improve industry’s 

development practices. 

The researchers did find a number of positive factors. Many of the managers understood and 

appreciated the concept of UD, because it fit with their existing criteria for good design. At the 

same time, UD is compatible with trends in the IT industry to offer solutions that adapt to users’ 

preferences, experience levels, and task requirements. Finally, the researchers found interest in 

the possibility of expanding markets to include older people and people with disabilities. 

The researchers felt that the quality of marketing information concerning the needs of real and 

potential users was comparatively low in the E&IT industry compared with other, more mature 

consumer goods industries. In most E&IT industry sectors, information and guidelines on 

inclusive design are lacking. They found that larger companies have more means and procedures 

with which to consider the user and his or her needs in the design process than small enterprises, 

especially start-up firms in software and Web design. 

The research identified nine types of barriers to the implementation of UD principles. At the 

most general level are barriers relating to a failure to sufficiently consider or involve any endusers in the design process. More important, companies fail to consider or involve older people 

and end-users with disabilities in the design process. Some general developments in the E&IT 
202 

industry also have a negative impact on implementation: the speed of product development, 

market trends, and industry organization. 

For this industry study, a list of potential barriers to UD was reviewed with each of the industry 

partners. The industry partners were asked to comment on their experiences and to report 

methods, if any, that were used to overcome the barriers. The purpose of the study was to build 

upon the findings of the TIDE program by reviewing an extensive list of accessibility barriers 

with E&IT companies competing in the U.S. market. The following barriers were common to 

most of the companies participating in the industry study: 

• Section 508 is either not being adhered to or is being adhered to inconsistently. 

• Some people feel that the business case for UD and accessibility is weak. 

• A standard accessible design process has not been documented, tested, or verified. 

• There is a lack of realistic standards, guidelines, and principles for accessible design. 

• There is no standardized method of measuring accessibility or comparing the accessibility 

of two similar products. 

• Many feel that there is no clear definition of how accessible a product has to be to be 

considered an accessible design. 

• Often there is a lack of communication across departments regarding accessibility 

requirements. 

• Many companies lack accessibility champions who are in a position to influence company 

decisions. 

• Middle management often perceives accessible design to be in direct conflict with 

schedule and budget requirements. 

• Individuals with disabilities are not integrated into the design or evaluation processes. 
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Common barriers identified during the industry study are discussed in detail in the following 

paragraphs: 

Section 508 is either not being adhered to or is being adhered to 

inconsistently. Inconsistent application of section 508 by federal procurement 

officials was the most commonly heard complaint among the industry partners. As 

might be expected, the industry partners that did not market to the Federal 

Government were less concerned about section 508 issues. 

Two of the industry partners did not market to the Federal Government, and four of 

the partners produced products that were directly marketed to the Federal 

Government. The industry partner representing a distance learning software 

company markets its products mainly to universities. The company perceived that 

it must conform with the technical requirements of section 508 because its 

customers were demanding conformance; however, the company was technically 

not obligated to develop products in conformance with section 508. The company 

made a decision to design to section 508 because its customers incorrectly assumed 

that section 508 applied to them because they received federal funding as public 

universities. The company representing cell phone manufacturing had little 

experience with section 508, mainly because it marketed its products almost 

exclusively to the cellular network carriers and did not feel much pressure to 

conform to section 508 requirements. 

The four remaining companies that did market to the Federal Government 

expressed discontent with the way federal procurement officials have procured 

products and services under section 508. In general, companies responded to 

section 508 in one of two ways. Some adopted a “wait and see” attitude while 

minimally responding to the requirements of section 508. Such companies might 

produce VPATs, but they were unlikely to invest resources in developing products 
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to conform to section 508 until the cost could be justified. Companies in this 

category have yet to experience either lost or increased sales to Federal 

Government customers because of section 508. There is a perception by some in 

industry that section 508 conformance is being “rubber stamped” by procurement 

officials and that the content of the VPAT is not important as long as a VPAT is 

offered. 

Other companies have been very proactive in their response to section 508. Two of 

the companies in the industry study have incorporated section 508 requirements 

into their design process. However, at least one company is currently reconsidering 

its accessibility program investment in response to section 508 because it has not 

realized increased federal sales from its increase in overall accessibility. 

Furthermore, the company did not observe a reduction in federal sales for 

competitors that were perceived as producing less accessible products. In short, 

accessibility seems to have failed to become a key discriminator, as promised 

under section 508. 

Some people feel that the business case for UD and accessibility is weak. All 

six companies reported that they struggled with the business case for universally 

designed products and services. Most companies could not report specific instances 

in which accessibility was a key discriminator in a federal procurement. In the 

absence of data suggesting that federal sales could be increased with UD or data 

suggesting that federal sales were at risk because of nonconforming products, 

companies were reluctant to use federal sales figures in developing a business case 

for UD. 

A standard accessible design process has not been documented, tested, or 

verified. Several companies have attempted to integrate UD into their standard 

product development process. Process interventions typically include prompts to 
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consider accessibility during design, the addition of accessibility requirements to 

requirements-definition documents, and limited testing with users with disabilities. 

However, no one has been able to determine if the interventions are sufficient or if 

additional interventions are required to produce accessible products and services. 

The impact of the integration of candidate accessibility interventions into the 

design process has not been studied extensively. 

There is a lack of realistic standards, guidelines, and principles of accessible 

design. Accessibility design guidelines that are currently available are not 

sufficiently detailed to have a profound effect on the overall accessibility of all 

E&IT products. Some guidance does exist, such as the technical requirements 

associated with sections 508 and 255; however, the guidance is sometimes 

ambiguous or subject to alternative interpretations. 

There is no standardized method of measuring accessibility or comparing the 

accessibility of two similar products. The industry partners struggled with the 

issue of measuring accessibility of products or comparing the accessibility of two 

similar products. An industry agreed-upon accessibility metric does not exist. In 

addition, industry has not identified a standard method of measuring accessibility. 

Currently, accessibility is measured only in terms of section 508 conformance. The 

VPAT is currently the agreed-upon vehicle for reporting accessibility. It does not, 

however, necessarily reflect the actual accessibility of the product it was created 

for, nor does the VPAT allow procurement officials to directly compare the 

accessibility of two similar products. 

Many feel that there is no clear definition of how accessible a product has to 

be to be considered an accessible design. Many people see UD as a goal. The 

goal is to create a product that is usable by as many people in as many situations as 

possible. Given that complete accessibility is either impossible or cost-prohibitive, 
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companies are struggling to determine just how accessible their products need to be 

to be considered accessible. The problem is compounded by the fact that 

companies do not have useful methodologies for measuring accessibility. 

Often there is a lack of communication across departments regarding 

accessibility requirements. Communication between the accessibility program 

offices and other departments was limited by the resources of the program office. 

While some proactive outreach activities were observed, the accessibility program 

offices were generally reactionary in nature. Most of the decisions that affect 

accessibility take place within product design teams working on specific projects 

and outside the influence of the program office. Also, sales departments in two of 

the industry partners were not well connected with the personnel making decisions 

about new product development. In two companies, the demand for accessible 

products was great, but that demand was not communicated to the group defining 

the requirements for the next-generation products. 

Many companies lack accessibility champions who are in a position to 

influence company decisions. Accessibility champions working within the 

companies participating in this study had diverse backgrounds and job 

responsibilities. The accessibility champion, to be truly effective, must be able to 

influence corporate decisions for the purpose of setting priorities and securing 

resources to further UD efforts. 

Middle management often perceives accessible design to be in direct conflict 

with schedule and budget requirements. Project managers are responsible for 

making sure that a development project comes in on time and on budget. Because 

accessibility generally does not have a specific budget, the project manager 

perceives the research required to identify accessibility requirements and integrate 

them into the design as a threat to his or her objectives. If accessibility features can 
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be developed without adversely affecting budget or schedule, they have a chance of 

being integrated into the product; however, accessibility activities are often the first 

to be cut if budget or schedule is threatened. 

Individuals with disabilities are not integrated into the design or evaluation 

processes. Many of the industry partners did not include people with disabilities in 

either the design phase or the testing and evaluation phase of product development. 

Tight schedules or limited resources were the most common reasons cited for lack 

of integration of people with disabilities into the design process. Other problems 

exist because of the accessibility barriers themselves. For example, it would be 

difficult to find a user who is blind who has extensive experience with computerbased training software if computer-based training software is generally 

inaccessible to users who are blind. Also, very few users with disabilities are 

experienced in participating in design focus groups or accessibility evaluations. 

Industry partners that perform user testing with people with disabilities typically 

perform only very limited or sporadic testing. 

ATM Industry UD Barriers. The most important barriers to UD expressed by the industry 

partner representing the ATM industry were— 

• A standard accessible design process has not been documented, tested, or verified. 

• Sometimes accessibility features are poorly communicated to the consumers who require 

the features. 

• The cost of developing and fielding new technologies associated with accessibility is often 

seen as prohibitive. 

• Personnel responsible for making accessibility decisions often have little knowledge about 

accessibility or accessible design. 

• Accessibility is often interpreted narrowly to include only physical access to the 

technology. 
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Barriers specific to the ATM industry identified during the industry study are discussed in detail 

in the following paragraphs. 

A standard accessible design process has not been documented, tested, or 

verified. Factors beyond the immediate control of manufacturers of ATMs often 

affect the accessibility of ATMs. For example, while the manufacturer supplies 

guidelines for placement of the ATM, the purchaser of the ATM may choose to 

install the ATM in an inaccessible location. Furthermore, the purchaser often 

insists on loading custom software onto the ATM that may or may not take 

advantage of the built-in accessibility features of the device. 

Sometimes accessibility features are poorly communicated to the consumers 

who require the features. Some users may not be fully aware of the accessibility 

features available on ATMs. UD features may not be used if users are unable to 

identify ATMs that possess the features or understand how to use them. While 

manufacturers often create end-user instruction materials and product brochures, 

the applicability of the materials is limited by the extent of software customization 

performed by the purchaser. 

The cost of developing and fielding new technologies associated with 

accessibility is often seen as prohibitive. ATMs represent a substantial 

investment for the purchaser. Replacement of ATMs is often cost-prohibitive or 

extremely difficult. Furthermore, the life expectancy of ATMs is such that they 

rarely need a full replacement. Product components are simply replaced as needed 

or as substantially upgraded functionality is made available. Accessibility 

enhancements are unlikely to justify replacement of an existing ATM or even 

provide justification for replacing key ATM components. However, if the 

accessibility enhancements are bundled with security or performance 

enhancements, purchasers may find the upgrade more attractive. 
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Personnel responsible for making accessibility decisions often have little 

knowledge about accessibility or accessible design. Banks may place the ATM 

in an inaccessible location, may design inaccessible screens, or may design the 

pathway to the ATM in such a way as to make it inaccessible. 

Accessibility is often interpreted narrowly to include only physical access to 

the technology. During a normal design process, the total user experience is often 

considered; however, it may be overlooked when the design is focused on 

accessibility. For example, when addressing access issues for individuals in a 

seated position, the inability of the user to privately enter the user PIN is 

overlooked. A seated person cannot conceal the keypresses in the same manner as 

someone standing. Accessibility evaluations should address the total user 

experience and not just the physical access issues. 

Cell Phone Industry UD Barriers. The most important barriers to UD expressed by the industry 

partner representing the cell phone industry were— 

• Marketing and technology trends sometimes run counter to accessibility requirements. 

• Sometimes accessibility features are poorly communicated to the consumers who require 

the features. 

• Companies often do not know how to market to people with disabilities. 

• The cost associated with purchasing accessible products is not affordable by people with 

disabilities. 

Barriers specific to the cell phone industry identified during the industry study are discussed in 

detail in the following paragraphs. 

Marketing and technology trends sometimes run counter to accessibility 

requirements. Several marketing trends run counter to UD in cell phones. 
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Miniaturization is currently driving the development of most cell phones. As the 

form factor of cell phones is reduced, the space available for both the display and 

the keypad is reduced. Users who have difficulty reading information on small 

displays or users who have difficulty selecting small keys have difficulty using 

small cell phones. In addition, there is a current trend to expand the capabilities of 

phones to include PDA functionality. The “smart phones” are controlled by 

complex menu structures that may be difficult for some users to navigate. 

Sometimes accessibility features are poorly communicated to the consumers 

who require the features. Cell phone manufacturers build phones to the 

requirements specified by the carriers and often have little interaction with endusers. In general, the cellular network providers are the exclusive customers of the 

cell phone manufacturers. The cell phone manufacturers have little control over 

how their products are marketed to end-users. Therefore, accessibility features built 

into cell phones are often not communicated to the end-user. 

Companies often do not know how to market to people with disabilities. In the 

cell phone industry, this issue applies to the cellular network providers rather than 

the manufacturers. The sales staff members of the cellular network providers are 

often not familiar with the accessibility features of the phones operating on their 

networks and are incapable of advising people with disabilities about their 

purchase decision. 

The cost associated with purchasing accessible products is not affordable by 

people with disabilities. Accessibility features tend to be added to the high-end 

products, which are typically not subsidized by the carrier. Higher processing 

speeds and greater memory are often required to operate accessibility features such 

as voiced menu options. Phones containing adequate processing and storage 

resources tend to be relatively expensive. Customized third-party software 
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designed to increase the accessibility of programmable phones is also expensive 

and therefore out of reach of most users with disabilities. 

Distance Learning Software Industry UD Barriers. The most important barriers to UD 

expressed by the industry partner representing the distance learning software industry were— 

• Designers lack an understanding of accessible design and what can be achieved if products 

are designed with accessibility in mind from the beginning. 

• There is a lack of tools and resources useful for efficiently creating accessible products. 

• The amount of time required to produce accessible products is prohibitive. 

Barriers specific to the distance learning software industry identified during the industry study 

are discussed in detail in the following paragraphs. 

Designers lack an understanding of accessible design and what can be 

achieved if products are designed with accessibility in mind from the 

beginning. Although developers of the core distance learning software seem to 

understand and design for accessibility, the developers of course content may not 

have the same appreciation for UD. Professors, teachers, instructors, and teaching 

assistants are responsible for the development of the vast majority of distance 

learning course content. The content may consist of videotaped lectures, 

audiotapes, transcripts of lectures, PowerPoint presentations, PDF documents, 

multimedia presentations, streamed video, and electronic texts. Each content type 

is associated with very specific accessibility issues. For example, streamed video 

should be closed-captioned and, in some cases, audio described in order to be 

considered accessible. Unfortunately, few content providers are able to commit the 

necessary resources required to develop fully accessible content. 

There is a lack of tools and resources useful for efficiently creating accessible 

products. The tools available to content providers offer little assistance in creating 
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accessible content. Often content must be recoded manually in order to be 

accessible. For example, the effort required to design and develop an accessible 

slide presentation is often many times greater than the effort required to create the 

presentation without the accessibility features. Presentation software such as 

Microsoft’s PowerPoint does not natively generate accessible content. Therefore, 

the content provider must work outside the presentation software to develop an 

accessible HTML representation of the original presentation. 

The amount of time required to produce accessible products is prohibitive. It 

can take an experienced professional as much as 14 hours to caption 1 hour of 

video. Content providers simply do not have the time, resources, or tools to create 

fully accessible distance learning content. 

PDA Industry UD Barriers. The most important barriers to UD expressed by the industry 

partner representing the PDA industry were— 

• Marketing and technology trends sometimes run counter to accessibility requirements. 

• Companies often do not know how to market to people with disabilities. 

• The cost associated with purchasing accessible products is not affordable by people with 

disabilities. 

• Designers lack an understanding of accessible design and what can be achieved if products 

are designed with accessibility in mind from the beginning. 

Barriers specific to the PDA industry identified during the industry study are discussed in detail 

in the following paragraphs. 

Marketing and technology trends sometimes run counter to accessibility 

requirements. The primary interface for most PDA devices, such as Palm OS or 

Pocket PC–based products, is a touch-sensitive stylus interface. The touch-
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sensitive interface, like the touchscreen interface, is not accessible to people who 

are blind. Low-vision users may find it difficult to use assistive technologies, such 

as a magnifying lens, while holding the device and using the stylus. Users with fine 

motor control limitations will find it extremely difficult to select items from the 

on-screen menus because of the precise motor control movements required to use a 

touch-sensitive stylus interface. Although the potential for use of a PDA by people 

with disabilities is great, the technology is currently inaccessible to many users. 

Many of the elements needed for the development of an accessible PDA are 

already embedded in existing products. Technologies for voice recognition 

interfaces—such as microphones, speakers, storage, and a sufficiently fast 

processor to process the voice recognition algorithms—are generally built into 

many PDAs. However, the software required to fully implement the technology in 

an accessible manner has not yet been developed. As an alternative to using the 

stylus interface, some programs support navigation using the hardware keys found 

on many PDAs. Keypress navigation is available for some applications, but 

adoption of the alternative navigation scheme is not widespread among software 

developers. 

Companies often do not know how to market to people with disabilities. 

Perhaps because of the inaccessibility inherent to the touch-sensitive stylus 

interface, the accessibility of mainstream PDAs seems to have been overlooked. 

Therefore, PDAs are generally not marketed to people with disabilities, nor is the 

potential for PDAs to improve the lives of people with disabilities recognized. 

The cost associated with purchasing accessible products is not affordable by 

people with disabilities. While the cost of PDAs has been reduced, they still 

represent a substantial investment for consumers. People with disabilities are 

reluctant, and rightly so, to invest in technologies with unproven track records on 
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accessibility. Accessible devices with PDA functionality, such as Freedom 

Scientific’s PACMate, can cost up to 10 times the price of a standard PDA. 

Therefore, few people with disabilities are able to afford the devices without 

assistance. 

Designers lack an understanding of accessible design and what can be 

achieved if products are designed with accessibility in mind from the 

beginning. Because of the touch-sensitive stylus interface, many see the PDA as 

inherently inaccessible, just as a digital camera is inherently inaccessible to a 

person who is blind. PDAs, particularly as storage capacities and processing power 

increase, are gradually becoming true handheld personal computers. It is 

reasonable to assume that a capable PDA could employ some of the same 

mechanisms for accessibility as personal computers. For example, voice displays 

used in conjunction with keypad navigation could be used in a similar manner to 

the way screen readers are used with personal computers. Voice recognition 

technologies could provide access to users who are unable to interact with the 

screen or keys. Screen magnifiers could be employed to assist users with low 

vision. Cooperation among hardware manufacturers, operating system developers, 

software application developers, and AT software developers will be needed to 

produce a fully accessible PDA. Currently, hardware manufacturers are reluctant to 

change their products unless the necessary accessibility features are built into the 

operating system and there is demand from software application developers. 

Television Manufacturing Industry UD Barriers. The most important barriers to UD 

expressed by the industry partner representing the television manufacturing industry were— 

• Personnel responsible for making accessibility decisions often have little knowledge about 

accessibility or accessible design. 

• There is a lack of realistic standards, guidelines, and principles of accessible design. 
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Barriers specific to the television industry identified during the industry study are discussed in 

detail in the following paragraphs. 

Personnel responsible for making accessibility decisions often have little 

knowledge about accessibility or accessible design. Accessibility of television 

sets depends on the cooperation of television manufacturers, content distributors, 

and content developers. Television manufacturers are responsible for developing 

hardware designs to take advantage of accessibility features, such as closedcaptioning and descriptive audio, added by content developers. Content distributors 

must be aware of the accessibility features and deliver the content so it does not 

interfere with these features. Design decisions made by television manufacturers, 

content distributors, and content developers often are made for technological, 

financial, or creative reasons without consideration for accessibility. 

There is a lack of realistic standards, guidelines, and principles of accessible 

design. While standards and guidelines exist for some aspects of television 

accessibility, such as closed-captioning, very little guidance is available for the 

accessibility of most television components. For example, little if any guidance is 

available for the accessibility of remote controls or on-screen menus. 

Voice Recognition Software UD Barriers. The most important barriers to UD expressed by the 

industry partner representing the voice recognition software industry were— 

• The technology required to produce accessible products is not available at a reasonable 

cost. 

• The cost of developing and fielding new technologies associated with accessibility is often 

seen as prohibitive. 

Barriers specific to the voice recognition software industry identified during the industry study 

are discussed in detail in the following paragraphs. 
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The technology required to produce accessible products is not available at a 

reasonable cost. Great advances in technology have improved both response time 

and accuracy of voice recognition software. However, frequent errors and 

recognition delays greatly affect the overall usability of voice recognition software. 

There are two basic types of voice recognition software. Natural language 

recognition software, such as Dragon Naturally Speaking or IBM ViaVoice, 

attempts to process and recognize a vast vocabulary of words. Such software can 

be used to navigate computer programs as well as produce text. In general, the user 

is required to tune the voice recognition software to the nuances of his or her voice 

in order to obtain acceptable levels of voice recognition accuracy. In contrast, 

limited vocabulary voice recognition software, such as an automated phone 

attendant, improves accuracy by constraining the number of words that the system 

can recognize. Limited vocabulary systems are speaker-independent and do not 

require tuning to the user’s voice. 

Natural language voice recognition software is still perceived as being too 

inaccurate and slow for use as an alternative to keyboard and mouse input. Users 

with disabilities who have used the technology in the past are reluctant to purchase 

additional software because of past disappointments. However, user perception of 

limited vocabulary voice recognition software is changing. Specialized voice 

recognition software can be embedded in common products such as digital copiers 

and public kiosks to provide access to a device that would otherwise be 

inaccessible. 

The cost of developing and fielding new technologies associated with 

accessibility is often seen as prohibitive. Although the pathway to embedding 

voice recognition technology in common E&IT products is understood, 

implementation of the integration can be challenging. The embedded voice 

recognition system typically consists of a voice recognition algorithm, audio input 
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and output circuitry, a processor to execute the voice recognition algorithms, and a 

software vocabulary. The audio circuitry and processor represent a nontrivial 

production cost. The cost to develop the voice recognition algorithms (or to license 

existing ones) and capture needed samples of the vocabulary can also be high. 
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V. Discussion 

The purpose of this research program is to understand the market for universally designed 

mainstream consumer products and services, document successful UD development processes, 

understand consumer needs, understand UD facilitators and barriers, and identify and address 

current issues in universal design. On the basis of the data collected during the market analysis, 

product assessment, industry study, and user study, certain conclusions can be drawn about the 

state of UD and the likely trends that will facilitate or inhibit the development of UD products 

and services. 

First, a sizeable market for UD products and services exists. However, few companies appreciate 

the size of the market or know how to tap its potential. 

Second, UD objectives can be achieved by making relatively minor modifications to the product 

design process currently used by manufacturers. The fact that companies can achieve UD 

objectives without changing their core design process is significant, because UD principles can 

be incorporated with minimal disruption. Furthermore, design process interventions, such as the 

adoption of accessibility requirements or the performance of user testing with people with 

disabilities, can be incorporated gradually as part of an organized, deliberate rollout of a UD 

program. 

Third, our review of the state of UD indicates that products that are designed to be accessible 

sometimes do not meet the actual needs of the target population. Developers may not fully 

understand the needs of users with disabilities, because people with disabilities are not usually 

integrated into the design process, and information about the functional capabilities and 

limitations of people with disabilities is not available in a conveniently accessible format. Also, 

technical solutions to accessibility issues may be formulated in the absence of the total design or 

with little understanding of how the feature will be used. 
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Finally, the discussion section ends with an analysis of the barriers to the implementation of UD 

faced by industry and a discussion of possible facilitators for the adoption of UD principles. The 

following paragraphs discuss the major findings of the UD research project in further detail. 

A Sizable Market Exists for Universally Designed Products and Services 

The market analysis and focus group study results demonstrate that a market does indeed exist 

for UD products and services. E&IT is driving the creation of new communities that are forever 

changing the way people live, learn, work, and play. Companies are increasingly expanding their 

presence in emerging markets. Businesses are serving populations they have never served before. 

No two people have the same set of characteristics, learning styles, preferences, abilities, 

experiences, and educational backgrounds. The classes of people making up the market for UD 

products and services include— 

• Users with disabilities 

• Users with temporary disabilities 

• Users with functional limitations due to situational factors 

• Users with low literacy skills 

• Users in low bandwidth areas 

• Users desiring increased functionality and usability 

• Users who do not speak English as their primary language 

• Users in high-population-density areas 

• Users who are elderly 

Approximately 21.19 percent of the total U.S. population has a formally classified permanent 

disability (i.e., low vision, blind, hard of hearing, deaf, upper-mobility impaired, lower-mobility 

impaired, or cognitively disabled). When considered at a more global level, almost 500 million 

people in just the United States and the top five emerging markets have permanent disabilities. 
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Add to that number those people with permanent disabilities in all other parts of the world, as 

well as individuals who experience temporary or situational disabilities or an impairment 

resulting from one of the classifications listed above, and it is clear that accessible designs are 

critical to everyday functions. 

In addition to the sheer numbers of people who can benefit from UD products and services, there 

are legal mandates to address the needs of people with disabilities. Legislation provides further 

justification for developing products and services that can be used by larger segments of the 

population. Technological advances are ever-increasing, which enhances our ability to provide 

products that are usable by more people. These products can also be provided more cheaply. Cost 

is a barrier that has been difficult to overcome in the past. 

As previously specified, users with disabilities include those who have low vision; are blind, hard 

of hearing, or deaf; or have an upper- or lower-mobility or cognitive disability. Temporary and 

situational disabilities result in functional limitations that mimic those of permanent disabilities. 

People in darkness or an eyes-busy situation (e.g., driving a car) can benefit from the same tactile 

cues that people who are blind use. Low vision is created when someone has dilated pupils, is 

without his or her reading glasses, is in a smoky or low-light environment, or is presented with a 

small display using small fonts. Noisy environments create similar issues as for people who are 

hard of hearing. Very loud environments (e.g., a construction site) or forced-silence 

environments (e.g., a library or meeting) create a need for alternative means of communication, 

as for people who are deaf. Limited manual dexterity results if someone has a broken arm, 

arthritis, or hand tremors; is in a bouncing vehicle; or is wearing gloves. Finally, temporary 

limited cognition can result when individuals are distracted or panicked, under the influence of 

alcohol, or in an environment where their native language is not spoken. 

Users with low literacy skills or who are in an environment where the native language is not their 

primary language (including tourists) can benefit from some of the same products and product 

features that help cognitively disabled individuals, including use of simple language, good 
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graphical metaphors, and redundant text and pictures. Users in low-bandwidth areas can benefit 

from some of the same products and product features that help people with low vision and users 

who are blind, including text alternatives for graphics and low-density displays. 

The elderly population is ever-increasing, and many difficulties faced by people with various 

types of disabilities will become issues for the aging population as well. Products that can be 

developed for use by a variety of individuals will benefit people as they age. The elderly 

experience limitations to their sight, hearing, manual dexterity, and cognition. Many of these 

individuals are accustomed to having access to various technologies and have come to rely on 

them; they will expect to be able to continue to use these technologies, despite any age-associated 

limitations they may develop. They will not want to purchase new products to accommodate their 

developing limitations. This includes products that are easy to understand and use, that have 

adequately spaced and sized buttons, and that have sufficiently sized labels and display elements, 

to name a few features. 

The final group is users who desire increased functionality and usability. For example, the cell 

phone used to be simply a voice communications device. Now many cell phones have text 

messaging as well. Text messaging is one feature that is particularly beneficial to people who are 

deaf or hard of hearing, but a large percentage of the population has adopted the technology for 

situations in which voice communication is inappropriate. Many product features, if designed 

with different user groups in mind, can benefit a large part of the population, satisfying the needs 

of many rather than just a few. 

Universal Design Principles Can Be Easily Incorporated into Current 

Design Practices 

The industry study included a review of the design practices of the industry partners. While 

different companies have different names for the individual design processes, the processes 

generally follow these steps: 

• Product planning 
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• Requirements definition 

• Product specification 

• Development 

• Verification and testing 

• Manufacturing 

• End-of-life management 

The application of UD principles does not require a major modification to the way companies 

currently develop products. Minor changes in the way products are developed will lead to 

significant increases in accessibility. The most important modification to the design process 

occurs in the very first stage of design: product planning or product conceptualization. During 

this stage, the objectives of the design product are outlined and the high-level conceptualization 

of the product is developed. Accessibility must be considered during this stage. Companies that 

failed to consider accessibility in product planning often failed to have a significant impact on the 

accessibility of the final design. 

The incorporation of UD principles at the product-planning stage involves expanding the user 

requirements to include people with disabilities and adapting to principles of UD in the 

conceptualization of the specific product being designed. For example, if a new copier is under 

development, product planners might consider early on that users who are blind should be able to 

complete all the primary tasks supported by the device. This consideration might lead product 

planners to conceptualize a copier with a user interface that is supplemented with a secondary, 

but integrated, user interface that is accessible to those who are blind. Users with disabilities 

should be consulted during the product-planning phase. 

Slight modifications to the requirements-definition phase can also lead to significant 

improvements in accessibility. In the requirements-definition phase, it is important to define 

objectively testable requirements for accessibility. It is not sufficient to require that the product 
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be accessible, because doing so provides little information to designers and prevents accessibility 

verification testing. Vague accessibility requirements are more likely to be ignored in both the 

development and the verification and testing phases of design. Testable requirements that are 

tailored to the product being developed should be incorporated into the requirements definition 

of the product. Again, the addition of accessibility requirements does not change the way the 

product is designed. Rather, these requirements are simply added to the existing requirementsdefinition methodology. The same methods used for monitoring, tracking, and measuring 

standard product requirements can and should be applied to accessibility requirements. 

During the product-specification phase, the functionality and appearance of the product is 

defined in accordance with the definition of product requirements. Personnel with expertise in 

UD must be available to assist in defining the specifications, reviewing the product specifications 

that affect accessibility, and determining if the accessibility-related product requirements are met 

by the product specifications. Given that most companies use some sort of integrated team 

development process during the product-specification and product-development phases, the 

addition of a team member with UD expertise is not likely to be disruptive. In fact, an existing 

team member can assume the role of the UD expert on the development team by becoming 

familiar with UD principles and understanding the functional limitations and capabilities of 

people with disabilities. 

The product-development phase typically involves iterative design and testing of prototypes. The 

product-development test plan should be broadened to include users with disabilities and testing 

with common assistive technologies. Testing should be task-based. The outcome of testing 

should be determined by human performance rather than the subjective impressions of the users. 

Products Designed To Be Accessible Sometimes Do Not Meet the Needs 

of Users 

Manufacturers, sometimes with good intentions, often develop products that, while innovative, 

fail to meet the needs of the intended population. Occasionally, products are developed with 
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accessibility features that only partially meet the needs of users. For example, some cellular 

phones have been developed with auditory indicators for battery and signal strength; however, 

the user is required to operate a user interface that requires vision to properly activate and 

configure the additional features. In this case, the designers of the system were successful in 

developing a needed indicator for users who are blind, but they fell short of the solution the 

implementation of the feature set was developed to address. Occasionally, developers working on 

accessibility issues are segmented from the general design and must develop accessibility 

solutions independent of the main design path. This practice can lead to a failure to integrate 

accessibility into all aspects of the design process. 

Occasionally, designers fail to fully appreciate the needs of users with disabilities. For example, 

an ATM developer may incorrectly assume that Braille labels on numeric keypads increase 

accessibility for people who are blind. In reality, most users who are blind are comfortable using 

a standard keypad. What users request most often is a standard keypad with raised buttons and a 

nib on the “5” key. The nib serves to quickly orient the user to the arrangement of the keypad and 

is much more useful than Braille labels on the keys. In fact, the Braille labels may interfere with 

the user’s ability to quickly identify the “5” and therefore increase transaction times for users 

who are blind. 

Failure to address the needs of users with disabilities typically results from a separation of the 

user from the design process or the separation of the designer of accessibility features from the 

mainstream design activities. Companies interested in developing universally designed products 

and services should consider consulting with people with disabilities or accessibility subjectmatter experts when contemplating an addition of a design feature that is intended to increase the 

accessibility of the product. Furthermore, companies should consider mainstreaming 

accessibility-feature development as soon as practical so that the feature will be well integrated 

into the product and all aspects of the feature, such as configuration and activation, will be 

considered. 
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Legislation Is Currently Both a Facilitator and a Barrier to Universal 

Design 

The Federal Government has a critical role to play in the promotion of UD. Accessibility-related 

legislation can affect businesses in several ways, some positive and some negative. 

Straightforward ways in which businesses can experience a direct positive impact from 

legislation include the following: 

• Legislation can remove barriers that inhibit provision of accessible products and services. 

The primary method by which legislation can remove these barriers is to set standards for 

interoperability in a complex network of systems. The impact of such legislation can be to 

remove barriers that prohibit content providers from marketing accessible products 

because of infrastructure constraints. Such legislation can also allow infrastructure 

developers to invest in feasible technologies with the assurance that content providers will 

produce compatible products. 

• Legislation can create new markets for accessible products and services. Legislation that 

creates new markets for accessible products or services also creates new ancillary 

opportunities for testing and marketing those products or services. These new markets can 

be pursued by all types of businesses. 

• Legislation can alter the market dynamics for a given class of products, creating a new 

product attribute that can be used to gain market share. Legislation that alters the market 

dynamics in this way inherently creates a way for an incumbent business to lose market 

share to a competitor—thereby creating an incentive for the incumbent to improve the 

accessibility of products to guard against the loss of market share. 

Straightforward ways in which businesses can experience a negative impact from legislation 

include the following: 

• Legislation can add to the base cost of producing a product or providing a service, without 

creating a commensurate offset in (increased) price. This type of impact is particularly 

negative when different suppliers experience different impacts in costs—for example, 
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when some competitors are exempted from full compliance and thus do not experience the 

same cost increases as other competitors. 

• Legislation can eliminate markets for certain existing or planned products. Products can be 

eliminated because they are noncompliant with requirements of the legislation and thus 

cannot be sold or because they are not compatible with a prescribed architecture for 

interoperability and thus cannot function properly in a network of systems. 

The effects described above are direct impacts on the markets for products and services offered 

by businesses. Legislation can also have indirect effects on businesses that are positive or 

negative. These effects are called “indirect” because they are manifested in long-term trends in 

product development rather than in immediate effects on markets. Indirect effects on businesses 

that are positive include the following: 

• Legislation can encourage businesses to invest in solving accessibility-related problems. 

• Legislation can create an incentive for innovation in developing accessible products and 

services. 

• By creating larger markets for accessible products, legislation can facilitate corporate 

strategies with respect to societal issues and corporate stewardship. For some businesses, 

the opportunities to contribute to the overall betterment of society (and to receive 

appropriate recognition for doing so) through improved accessibility of their products may 

fit well with their plans in such diverse areas as energy efficiency, environmental impact, 

and community investment. 

Legislation can also have indirect impacts that are negative for businesses. Examples include the 

following: 

• Legislation can set a minimum standard for acceptability that becomes the de facto 

maximum standard. Businesses may be unable or unwilling to justify developing 

improvements in accessibility because compliance is a simple binary judgment; 

improvements are not seen as economically justifiable. 
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• Legislation can create a regulatory environment in which the focus is on compliance with 

the regulations rather than on achieving the outcome sought by the regulations. Businesses 

may produce products that comply with the regulations but are not truly accessible. 

Businesses may choose to advocate interpretations of regulations that circumvent the 

intended outcome. 

• Legislation can be used to advance or oppose political agendas with little regard for the 

actual outcomes that are influenced by the legislation. Businesses can be negatively 

affected by these political agendas. For example, a business might decide to oppose 

“government regulation” related to accessibility on ideological grounds, even though it 

may be in the best interest of that business (not to mention society at large) for the 

legislation to pass. 

Government, Industry, and Consumers Have Important Roles To Play in 

Promoting Universal Design 

Government, industry, and consumers can all have a hand in promoting the development of UD 

products. Users who participated in the study focus groups were asked to comment on what the 

Federal Government, manufacturers of products, and consumers could do to promote universal 

design. 

Government Involvement. Focus group participants indicated the following: 

• Government can fund research, similar to this project, in which consumers with 

disabilities are involved early in the process. 

• Government can provide funding or tax breaks to encourage companies to develop some 

accessible products so that companies can see the value they can provide. 

• Government can get consumer input and make the general public more aware of 

accessibility and disability issues, and can provide funding to make accessible products 

more affordable. Getting consumer input should include putting the question out to the 

disability community on how to improve the technologies, rather than making decisions 

for the disabled about their needs and desires. 
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• Government needs to continue to develop and enforce legislation and standards, without 

which industry is unlikely to act on the needs of special populations. 

• Focus groups should be used in standards development and should include participation 

from a variety of consumers as well as individuals with technical knowledge; standards 

should be developed in conjunction with solutions to make them more realizable. 

• Government should put a mechanism in place to force its entities to consider their 

technology purchases and the impact on different disability populations (e.g., the U.S. 

Postal Service purchase of touchscreen displays). 

• Government is in a position to influence by example. If it is addressing UD-related issues 

and can demonstrate positive outcomes to industry and consumers, awareness will increase 

and others are likely to follow suit. 

Industry Involvement. Industry can do similar things, as indicated by focus group participants: 

• Industry can get consumers with disabilities involved early in the design process and 

conduct more focus groups. 

• Industry should always consult the people they’re designing for, whether through direct 

involvement or market research. 

• Industry should hire people with disabilities, at least as consultants, to provide input 

throughout the design and development process. This would also assist in increasing 

awareness of the needs of people with disabilities. 

• Industry spends millions in advertising dollars. It should put a portion of those funds 

toward designing for people with disabilities and funding research to assist those with 

disabilities. 

• Industry need to make products more affordable and do extensive marketing so that people 

are aware that these products are available. 
230 

• Industry needs to consider the wider market that can benefit from products with 

accessibility features, as well as understand that there are people with disabilities that 

would like to use their products. 

• Industry needs to recognize the advantage that can be had by building in UD from the 

beginning. 

• Industry should provide a mechanism (e.g., an accessibility program office) for consumers 

to voice their concerns, and it should act more on the concerns that it hears about. 

Consumer Involvement. Focus group participants indicated the following: 

• Consumers can influence the development of UD products by participating in research 

studies, surveys, and product evaluations. 

• Consumers can spend time talking to and educating product sales people about features 

that can benefit someone with a certain disability and about the lack of usefulness of some 

features for people with particular disabilities. This education can extend to other members 

of the community as well, to make people aware of the issues that affect people with 

various disabilities. 

• They can speak up and contact companies directly to advocate for their disability 

community and provide suggestions for design improvements. Consumers need to be very 

specific when contacting manufacturers to complain about products that are not accessible. 

They should provide both positive and negative feedback. If companies know what they 

are doing right, their awareness will increase, and they will be likely to continue to 

implement designs they know are useful. 

• In addition to contacting manufacturers, people with disabilities should contact 

government to voice their concerns and increase awareness of how many people with 

disabilities there are in the population. 

• Consumers can donate their old accessibility aids to others who may benefit from them 

because they cannot afford the technologies themselves. 
231 

• Consumers should contact state agencies, which can communicate to the larger disability 

populations to inform them of accessible opportunities and products they may not know 

about. State agencies can serve as an information outlet to the disability community and as 

a means to help government and industry gather data they need to take steps to improve 

accessibility in all matters of life. 

• Consumers can purchase the products they find most accessible. They should not purchase 

products from companies that fail to demonstrate an effort to address UD, and they should 

encourage others to do the same. 

Industry and Consumers Would Benefit from Better Industry Coordination 

with AT Vendors 

Assistive technology manufacturers possess the technical knowledge, experience, and talents that 

can help E&IT manufacturers succeed in selling E&IT into emerging markets. It is difficult for 

AT manufacturers to support the needs of E&IT manufacturers for many reasons. Most of the 

difficulty may be attributed to the differences in size and available resources between AT and 

E&IT manufacturers. 

Randy Marsden, director of ATIA and president and CEO of Madentec (USA) Inc., uses the 

following analogy to paint a picture of what compatibility of AT and E&IT is all about: 

Owners of public buildings are obliged to make them accessible to everyone, 

including people with physical disabilities. They do this by focusing on providing 

wheelchair ramps, automatic door openers, etc., which are of limited value in and 

of themselves, unless there is also a wheelchair in the picture. But few building 

owners provide wheelchairs as part of the “accessibility package” of their building. 

Wheelchairs are usually a very personal item (size, weight, style, etc.). Instead, 

building owners make sure their ramps and doors are compatible with the 

wheelchairs on the market that are provided by specialized vendors. 

Continuing with the analogy, the building owner can do smaller things to help 

make their building more accessible themselves. For example, they could put 

larger door knobs and door pulls on their doors that make them more accessible to 

everyone. You wouldn’t expect someone to bring their own door knob. But when it 
232 

comes to major items, building owners focus on simply being compatible with the 

more specialized equipment that is provided by people who better understand the 

disability marketplace. 

E&IT vendors are like the building owners. They have the ability to make their products 

compatible with AT products used by people with disabilities to the extent that is technically 

possible and economically feasible. While AT is not the primary approach to universal design, 

AT manufacturers do have a role to play in ensuring that E&IT is accessible. 

At the lowest level, universal design of E&IT should mean that products and services should be 

developed so that they do not actively interfere with the operation of assistive technologies if the 

user chooses to use AT. For example, some software applications, when installed on a user’s 

personal computer, may disable screen readers. While the software may not rely on AT for 

accessibility, it should at least ensure that use of the software does not interfere with AT that may 

be installed on the user’s system. This implies that E&IT vendors should, at a minimum, have 

some understanding of AT and how it is used. 

AT may also be used to enhance the user experience. While independent accessibility is an 

important UD goal, in some instances AT interoperability may be built into products for the 

mutual benefit of the developer of the technology and the user. For example, a software 

developer should not be required to reinvent screen reader technologies for every application. 

The developer should instead concentrate on ensuring that the software is interoperable with 

existing AT. Consumers benefit from the arrangement because they may rely on the user 

interface of a screen reader that is familiar and customized to meet their needs. Industry benefits 

because developers can focus on the development of the application user interface rather than the 

reinvention of solutions that have already been fielded. 

Opportunities for enhancing the interoperability between AT and E&IT products include 

identifying reasonable, achievable, functional performance criteria and developing AT/E&IT 

interoperability specifications and interoperability testing procedures. Both AT and E&IT 

vendors would benefit from a clear understanding of requirements. Also, there is a need for AT 
233 

manufacturers to be active participants in the creation of interoperability specifications. Notice 

that the word “specifications” is used in a plural form, because there is not a single solution to 

interoperability. Instead, there is a need for ongoing cooperation between E&IT and AT 

manufacturers to continually define interoperability specifications on a product-by-product basis, 

acknowledging the fact that some products can be grouped into similar categories and a common 

interoperability solution can be applied. 

E&IT manufacturers can actively support the AT industry by— 

• Actively participating in creating interoperability specifications 

• Adhering to interoperability specifications 

• Assigning “point people” within each E&IT manufacturer to support AT manufacturers’ 

efforts to achieve the highest levels of compatibility and interoperability and to answer 

highly technical questions about specific E&IT products 

• Providing, at no cost, E&IT loaner products and possibly human resources for testing 

AT/E&IT interoperability 

The Federal Government can support the AT industry by weaving the tracking of AT products 

into the fabric of the Department of Commerce’s mainstream E&IT product research and 

continuing efforts in support of facilitating dialog between AT and E&IT vendors. 
234 
235 

VI. Conclusions 

Given the ultimate goal of promoting universal design in consumer products, policymakers are 

confronted with choices of strategies that will help further progress toward that goal. Two broad 

categories of strategies emerge: market-based strategies and rule-based strategies. Market-based 

strategies attempt to use market forces, which translate into supply and demand forces, to 

promote UD. A simple example of a market-based strategy is use of advertising to encourage 

consumers to purchase accessible products. If the advertisements are effective, demand for 

accessible products will increase, and the supply will increase to match the demand. Rule-based 

strategies attempt to use standards or regulations to encourage suppliers to develop and offer 

accessible products; latent demand for such products is expected to subsequently become 

manifest. Rule-based strategies can be based in industry-adopted standards, in government 

regulations and policies, or both. A simple example of a rule-based strategy is a regulation that 

all telephones sold in Australia must have a nib on the “5” key. 

A hybrid strategy combines rule-based features and market-based features. A leading example is 

section 508 of the Rehabilitation Act, which seeks to create a bigger market for accessible 

products by regulating the purchases made by the Federal Government. For products purchased 

in significant quantities by the Federal Government, companies have an incentive to increase the 

accessibility of the products and thereby increase their sales. The rules regarding product features 

and capabilities only apply to federal purchases. 

Rule-based strategies “push” UD forward; market-based strategies “pull” it forward. Some 

aspects of UD are better served by a push strategy, and other aspects are better served by a pull 

strategy. Delineating the mixture of push versus pull and the overall philosophy of when to use 

which strategy requires consideration of how purchase decisions are made and how production 

decisions are made. 
236 

Analysis of Purchase Decisions for Accessible Products 

The decision to purchase an accessible product is first and foremost a decision to make a 

purchase. Whether the item is, in fact, accessible might not be known when the decision is made. 

Factors that influence the decision to purchase an accessible product are simply factors that 

influence a purchase decision—the accessibility of the product cannot influence this behavior. 

The three factors that primarily interact in a purchase decision are— 

• The availability of resources to apply to the purchase. 

• The perceived inherent value of the item. 

• The properties of alternative purchases; in particular, the perceived values of these 

alternatives. Note that the alternatives could be products in the same class as the putative 

accessible product or could simply be something altogether different. 

A full exposition of the complex topic of consumer choice is well beyond the scope of this 

exercise. Central to this exercise, however, is consideration of the primary contributors to a 

purchase decision. 

The accessibility of a given product can only affect the purchase decision if it affects the inherent 

perceived value of that item. There are two broad categories of factors that can affect the 

perceived inherent value of an item: 

• Actual experience with the item or highly similar items 

• Presence of discriminators that predict eventual experience with that item 

The purchaser’s “actual experience” with an item is quite different when the item is for personal 

use than when it will not be used personally. The actual experience with an item for personal use 

primarily consists of the utility of the item. When items are purchased for others to use, actual 

experience may consist of direct knowledge of the outcomes experienced by those users (as 

would be the case with a purchase made for a family member or employee); but the purchaser 
237 

may have no knowledge of outcomes if the purchase is made on behalf of an agency or large 

company. 

To illustrate, consider safety as a factor in making a purchase decision. Safety affects the decision 

only if a product’s being “safe” or “safer” affects its inherent perceived value. It is a relevant 

factor for virtually all products. Even users of illegal drugs expect the drugs they buy to be “safe” 

with respect to the intended use (e.g., not cut with a poison that would cause immediate death). 

But the perception of whether an item is safe does not affect the perceived inherent value of an 

item if the purchasing agent does not, and will not, experience the outcome of the purchase with 

respect to safety. For example, an individual buying some product (e.g., an electrical extension 

cord) for personal use would not purchase the product if he or she perceived that it was unsafe—

that using it might result in harm to self or damage to property. But if the purchase is to stock the 

shelves of a national discount retailer, the issue of safety is not a personal one. Safety is a 

relevant consideration only to the extent that job performance assessment or personal liability are 

affected by the eventual experiences of consumers who make retail purchase decisions. 

If bulk purchasers are in a situation in which the accessibility of the products they select does 

affect their personal outcome—in the form of job performance ratings or other means of personal 

accountability—these purchasers will need access to information that will help them predict the 

accessibility outcomes that will be experienced by the eventual end-users of the products they 

purchase. Thus, two requirements must be met: personal outcome experienced by the bulk 

purchaser that is contingent on whether the product is accessible, and availability of reliable 

information on which to make the purchase decision. 

The presence of discriminators that predict actual experience also affects decisions in the same 

way. If the item is for personal use, a discriminator that reliably signals the eventual experience 

will have virtually the same effect as the experience itself. Three types of discriminators are 

commonly found in the marketplace: brands (self-identifying words or symbols that are 

associated with a common source of products); unregulated claims (assertions and suggestions 
238 

made in advertising, packaging, and other methods about outcomes that will be experienced); and 

regulated labels (words and other data whose meanings are regulated so as to provide a more 

trustworthy basis for predicting the eventual experience with an item.) 

Note that a purchaser’s direct experience with the outcome of purchasing a product cannot affect 

the purchase of that product, because the actual experience of outcome occurs after the purchase 

is made. The experience of the outcome can only affect future purchase decisions, not past 

decisions. Further, the effect on future purchase decisions affects demand in the market only if 

the purchases are made often enough to have an impact on production decisions. To illustrate, if 

purchasers purchased a given product only once in their lifetimes, their actual experience with 

the outcome of that purchase would never affect the market, because they would never have the 

opportunity to use their experience to shape their next purchase. Similarly, if purchases of a 

given product are made quite infrequently—every few years, for example—their actual 

experience of the outcome with respect to accessibility would have relatively little impact on 

demand forces in the market. 

If products are purchased infrequently, then, the actual accessibility of a product can affect the 

purchase decision only to the extent that information (such as labels, brands, or claims) is 

available to consumers that will allow them to predict (consciously or unconsciously) their 

experience of outcome. Otherwise, the lag times for effects of consumer demand in the market 

will be far too long to have a significant impact on production decisions. 

On the other hand, if purchases are made frequently, the consumer’s actual experience of 

outcome can more readily and directly affect demand forces in the market. To illustrate, if one 

brand of pay telephone is accessible (e.g., compatible with hearing aids) and another brand is not, 

consumers who have hearing aids and who regularly use pay phones will quickly learn which 

brand to select. If users in this category constitute a significant segment of the market, usage rates 

for the accessible product will increase and pull the market toward the accessible product. This is 

especially true when there are no other discriminators among competing products. Conversely, if 
239 

users in this category do not constitute a significant segment of the market, the pull factor will be 

slight and could well have no impact. 

Thus, if the purchase decision is made frequently relative to the production decisions in the 

market, the consumer’s actual experience can shape market demand if the segment of affected 

users is sufficiently large. The presence of good predictor information (labels, brands, claims) 

may further amplify this effect. 

Reliable predictors in the form of labels, brands, or claims can also affect the market in an 

aggregate sense when they generally apply to multiple classes of products. For example, if brand 

A of one type of product is reliably accessible to users with a specific impairment, that same 

brand name on a different product could be used as a predictor of the experience of outcome and, 

therefore, affect demand for that product, even if the product is purchased infrequently. 

If a consumer makes a decision to purchase, that decision usually involves selection of a specific 

choice from a field of available, competing products that meet some qualification criteria. The 

qualification criteria may simply be provision of the basic functionality of the device, but they 

may also include some other factors of personal significance to the purchaser. (Examples of other 

factors of personal significance are country of origin or trusted retailer.) A useful class of models 

of consumer choice from economic theory segments consumer choices among available products 

into the following three categories: 

• Best price—the consumer selects the product with the lowest price from among all 

available, qualifying products. 

• Best product—the consumer selects the best product from among all available, qualifying 

products, irrespective of price. 

• Best value—the consumer selects a product on the basis of both price and performance, 

through some conscious or unconscious weighting of features and price. Of particular 
240 

interest in the present context is the notion that best value decisions may actually focus on 

one dimension of performance rather than impartially weighting all performance factors. 

The accessibility of the product can affect “best price” or “best product” choices only if it forms 

part of the qualification criteria. This path could be used to influence the market for accessible 

products by advocating that consumers, businesses, and governments consider only products that 

meet some accessibility criteria (similar to purchasing paper with at least a certain amount of 

recycled content). Products then compete on price or on overall capabilities, but only if they meet 

minimum accessibility criteria. 

The accessibility of the product can affect best value choices either through inclusion in the 

qualification criteria or by being one (and perhaps the only) dimension of performance that is 

considered in determining value. This can be promoted by providing information about product 

accessibility to consumers so they can consider it. Providing such information can lead to some 

best value decisions being based primarily on the level of accessibility in the product—that is, 

some consumers will select the most accessible product when they make a best value choice. 

Demand forces in the market can therefore promote UD and accessibility of products through the 

following mechanisms: 

• For products that are purchased often by individuals for their own use, consumer demand 

will help drive the market to supply accessible products. 

• For products that are purchased relatively infrequently, consumers must be given 

information that helps them predict their experience of outcome in order for consumer 

demand to affect supply. 

• For products that are purchased for use by others (e.g., bulk purchases made by large 

companies or government agencies), the outcome experienced by the purchaser is not the 

accessibility of the product itself. The outcome experienced by the purchaser, in terms of 

job performance ratings or personal accountability, must be made contingent on the 

accessibility outcomes experienced by the eventual users of the product in order for this 
241 

type of purchase to contribute to market demand. For this to happen, these purchasers need 

access to information that will help them predict the outcome that will be experienced by 

the eventual users. 

Pull legislation can create and affect demand forces in three primary ways: imposing 

requirements to provide information (such as standard labeling) that can educate individuals and 

bulk purchasers; creating job-related outcomes for bulk purchasers (particularly in government); 

and creating opportunities for private tort lawsuits to pursue warranty issues related to 

accessibility. 

Comparison of Strategies To Promote Universal Design and Strategies To 

Promote Safety 

As policymakers consider the ultimate goal of promoting UD in consumer products, it becomes 

clear that no single strategy will be appropriate for all types of products. It is useful to consider 

the mixture of strategies that are necessary to promote safety in consumer products. The 

following points summarize (at the risk of oversimplification) the strategies that are used to 

promote safety of consumer products: 

• For nonessential product features that are inherently dangerous, but the danger is not open 

and obvious, regulations either prohibit the feature altogether or prescribe safeguards that 

must be provided. Examples include levels of radiated energy generated by the product 

and presence of toxic chemicals in the product. Producers may not include these 

nonessential features in their product, irrespective of cost or inconvenience incurred. 

• For design features that are inherently dangerous when used inappropriately, but that must 

be present to achieve the functionality of the product, a combination of government and 

industry rules dictates design safeguard features that must be added to prevent 

inappropriate use of the product and/or warnings and instructions that must accompany the 

product. 
242 

• For design features that pose an intermediate level of risk but that also contribute to 

functionality and/or reduce cost, a combination of industry practices, customer demand, 

and private tort lawsuits jointly shape the provision of design safeguard features, warnings 

and instructions, and other efforts related to promoting product safety. In this context, an 

intermediate level of risk means that the probability of an adverse event is not sufficiently 

high to warrant government or industry rules, but it is not trivially low either. 

• For safety factors that are associated with interoperability of products (e.g., voltage 

compatibility, physical couplings and connectors with infrastructure), government and/or 

industry standards are used to define allowed configurations. 

If these strategies were translated directly to the goal of promoting UD and accessibility, the 

following strategies would be suggested: 

• Nonessential design features that inherently produce inaccessible products for a given 

recognized impairment should be prohibited altogether or should be allowed only if 

specified alternatives are also provided. For example, touchscreen interfaces for devices 

that do not inherently require a touchscreen could be prohibited unless accompanied by an 

equivalent voice display. 

• Design features that reduce cost or contribute to functionality but that also cause 

accessibility problems should either be accompanied by alternative features that remediate 

the accessibility problem for the affected group of users or should have clear labeling that 

allows affected users to know about the accessibility problem. 

• Design features that pose a risk of inaccessibility (i.e., the accessibility problem is not 

prohibitive, but there is a nontrivial probability that affected users will have trouble 

performing some tasks with the device or otherwise have restricted use of the device) 

should be accompanied by labeling (and other supporting information, as appropriate) that 

allows the affected users to know about the problem. Absence of such labeling could form 

the basis of private lawsuits through implied warranty. Alternately, labeling and warranty 

could be provided to assert the accessibility of the device and to specify the limitations 
243 

thereof, and failure to perform as specified could form the basis of an express warranty 

claim. 

• When accessibility is dependent on interoperability of products or within an infrastructure 

(such as the telecommunications infrastructure), government and industry standards should 

be adopted to define allowable configurations, and all allowed configurations should result 

in accessibility. 

The following table summarizes the comparison between promotion of consumer product safety 

and consumer product accessibility. 

Table 2. Comparison Between Promotion of Consumer Product Safety and Accessibility 

Issue 

Strategy used for product 

safety 

Equivalent strategy to 

promote accessibility 

Nonessential feature poses 

significant problem 

Government or industry 

standard prohibits the feature 

or requires safeguard. 

Government or industry 

standard prohibits the feature 

or requires alternative 

interface. 

Essential feature poses 

problem if used 

inappropriately 

Safeguards must be provided 

to discourage inappropriate 

use; warnings and instructions 

must be provided. 

Alternative interface must be 

provided, if possible; clear 

labeling is required to inform 

consumers of remaining 

accessibility issues. 

Design feature creates risk 

with nontrivial probability, but 

not high enough to be 

prohibitive 

Industry practices and 

consumer demand influence 

whether the feature is offered; 

warnings about the risk must 

be provided; private lawsuit is 

available to those who 

experience the problem. 

Industry practices and 

consumer demand will 

determine whether the feature 

is offered; labeling must be 

provided to indicate level of 

accessibility (or to alert 

consumer to accessibility 

limitations); warranty claims 

are available to those affected 

by the problem. 

Interoperability issues within 

some infrastructure can create 

problem 

Government or industry 

standards adopted to define 

allowable configurations. 

Government or industry 

standards adopted to ensure 

product accessibility when 

used in the infrastructure. 

The recommendations derived from the above are as follows: 
244 

Recommendation #1. Use standards (government or industry) to prohibit 

nonessential features that pose accessibility problems unless an alternative 

interface that solves the problem is provided. 

Recommendation #2. Use standards (government or industry) to eliminate 

interoperability problems that create accessibility problems. 

Recommendation #3. Use market forces to regulate features that pose 

intermediate levels of accessibility problems. Require labeling and other 

information to be provided, and allow recourse through tort (warranty) lawsuits as 

well as through general demand as reflected in consumer purchases. 

Analysis of the Market for Universally Designed Products and Services 

Businesses, in general, are not aware of the market potential for universally designed products 

and services. Data gathered from the industry study indicated that the industry study partners 

generally took a rather narrow view of the market potential for UD products. By far the most 

important consumer of UD products and services is perceived by industry to be the Federal 

Government. Many of the industry partners recognized the need for developing accessible 

technologies for people with disabilities but failed to recognize the population as a significant 

market. Participating companies continue to struggle with the development of a supportable 

business case for UD products. 

Recommendation #4. Develop training materials and educational articles 

documenting the market potential for UD products and services. 

To address the needs of industry, the Federal Government should support the development of 

training materials and the publication of articles in major business journals that document the 

market potential for universally designed products. The publications should outline potential 

sources of untapped revenue and present a meaningful financial argument for developing 
245 

accessible technologies. The research should be conducted by reputable financial analysts with 

experience in the development of business cases and the evaluation of market trends. The project 

should include in-depth case studies of specific products that not only have had an impact on the 

lives of people with disabilities but are also mainstream commercial successes. 

Analysis of the Impact of Section 508 

Section 508 was developed to govern the purchase of electronic and information technology 

purchased by the Federal Government. Federal agencies must ensure that individuals with 

disabilities have access to and use of information that is comparable to the access and use by 

federal employees who do not have disabilities, unless an undue burden (significant expenses or 

difficulties) is imposed on the agency. The law also requires that individuals with disabilities in 

the general public seeking information or services from a federal agency have access to 

information and services comparable to those provided to individuals without disabilities, unless 

undue burden is imposed on the agency. When compliance does impose an undue burden, 

agencies must still provide disabled individuals with the information and data by allowing them 

to use it by an alternative means of access (e.g., captioning, audio description). While agencies 

must procure products that best meet the standards, section 508 does not require that 

manufacturers make their products more accessible. 

Recommendation #5. Institute procedures designed to ensure that due diligence is 

given to section 508 procurement requirements. Perform an internal analysis of the 

impact of section 508 on the procurement of actual products. Publish the results of 

the analysis as a way of convincing industry that the Federal Government is 

committed to section 508. 

Despite having been in place for nearly three years, section 508 has failed to reach its potential. 

Section 508 has failed to have a real impact on the purchase of products. The industry study 

results demonstrate that the perception in industry is that companies are not losing sales by not 

having accessible products. If federal agencies need to make a purchase, they will purchase what 
246 

is available; they cannot wait for accessible products to become available. Some companies have 

put efforts into awareness and some development of the accessibility of their products, but their 

efforts are focused on the specific products that are most likely to be purchased by the Federal 

Government. Other products in the same company continue to be developed without 

consideration for accessibility. The products that are most likely to be purchased by the Federal 

Government are least likely to be purchased by small businesses or the individual consumer, 

greatly limiting the number of people that will benefit from even moderate accessible design. 

Recommendation #6. Consider requesting supporting evidence for claims made 

on VPATs from all vendors responding to bid proposals. 

Recommendation #7. Develop a quick accessibility checklist for specific product 

lines likely to be procured by the Federal Government. The quick accessibility 

checklist would assist procurement officials with market research by providing 

them with a list of items that they can inspect themselves when procuring products. 

The checklists would be tailored to specific product lines and would not require 

detailed expertise to evaluate. 

When considering products for purchase, procurement officials consult VPATs for the 

purchasing decisions. However, there is wide interpretation of the section 508 requirements by 

those filling out VPATs; even within a company, two very different VPATs could be generated 

by different individuals for the same product. In some cases, those filling out the VPATs are not 

as familiar with the product as the designers and are likely not aware of the issues that people 

with disabilities may face when trying to use the products. In addition, there are rarely data from 

user testing (of people with disabilities) to support the statements made on the VPAT. 

Companies are also uncertain about which products are relevant under section 508 and which 

aspects of the covered products are governed by the regulations. 

Recommendation #8. Develop guidance for reporting conformance with 

functional performance criteria guidelines. 
247 

One of the greatest shortfalls of section 508 is the lack of understanding of and attention to the 

functional performance requirements. These requirements, in particular, are too ambiguous to 

support the needs of industry. Since the implementation of section 508, an increasing amount of 

information has been made available on how to interpret some of the language of the 

requirements (e.g., as seen at http://www.access-board.gov/sec508/guide/index.htm), but nothing 

has yet been made available on the functional performance requirements, which are the most 

difficult to interpret. Other UD standards and guidance are also ambiguous and insufficient to 

support the needs of industry in developing more accessible products. Lack of understanding of 

the issues is a disincentive to the company; in many cases, industry could benefit from productline-specific guidance. Industries can also benefit from a methodology for measuring 

accessibility of their products. 

Recommendation #9. Support the coordination of state and local government 

adoption of section 508 technical requirements. Provide state and local 

governments with documents and training programs designed to ensure unification 

of technical requirements. 

Despite these shortfalls of section 508, state and local governments will likely adopt accessibility 

legislation similar to section 508. There is concern at the state and local level for providing equal 

access for all citizens, and the adoption of similar legislation at these levels may spur more 

industries to be more attentive to the issues and increase their development of accessible 

products. In addition, state and local legislation may provide additional understanding of how to 

interpret the standards. It is hoped that this legislation will not contradict or conflict with federal 

legislation or laws enacted in other states or municipalities. Industry will suffer if the technical 

requirements for accessibility diverge. 

Recommendation #10. Study and document the nontechnical aspects of 

accessibility, including social, psychological, and organizational accessibility. 

Promote UD solutions that consider all aspects of accessibility. 
248 

Another way in which section 508 falls short is that it is limited to technological access. 

Accessibility solutions, when they exist, often address only technological access. They fail to 

address the social, psychological, and situational needs of users relating to accessibility. For 

example, as revealed in the user study, if an ATM machine were completely accessible, some 

individuals who are blind or have low vision would still not use it or would continue to use it 

only in the company of a friend or family member because of a concern for their safety. As 

another example, while technological access may be available for a product, it may still be 

inaccessible to a subset of individuals because they cannot afford to purchase the product. This 

situation is often interpreted by industry as low demand, when in fact the demand can simply not 

be demonstrated because of the low incomes of many people with disabilities. These situations 

that reduce overall accessibility should not diminish the efforts of industry to increase 

accessibility of their products for various individuals, however, as it does provide the option for 

individuals to use these products if the necessity arises or if their situations change. 

Analysis of Industry Practices 

Despite consumer demand and government oversight (and limited guidance) regarding accessible 

products, companies lack tools and information resources needed to create UD products. To 

begin with, corporate policy can affect the adoption of UD in a company. Without the support of 

upper management, UD often cannot become a reality unless there is a strong advocate within the 

company. If corporate policy emphasizes accessible design solutions and perhaps user testing 

with people with disabilities, those issues become more difficult for designers and managers to 

ignore, and they are likely to find ways to at least begin to address them despite a lack of tools or 

knowledge. 

Recommendation #11. Develop, test, and disseminate methodologies for 

integrating UD into existing design practices. 

Companies are not aware of the design process modifications needed to incorporate UD 

principles. The Federal Government should support the refinement of specific design process 
249 

interventions that can easily be incorporated. Guidelines for incorporating UD principles into the 

design process should be developed and illustrated with real-world examples, if possible. 

Training materials should be distributed to companies interested in incorporating UD principles 

into their design process as a series of UD best practices. 

Recommendation #12. Support the development of university-level training 

materials that could be incorporated into the curricula of existing design-oriented 

degree programs. The training materials should include awareness-expanding 

videos and other teaching resources that illustrate the potential impact of key 

design process interventions on the lives of people with disabilities and other 

beneficiaries of UD. 

Recommendation #13. Develop, test, and disseminate design reference users to 

illustrate the range of functional capabilities and limitations typical among people 

with disabilities. Design reference users, popular in specifying target populations in 

Department of Defense acquisitions, is a set of descriptions of prototypical users 

that expresses the range of functional capabilities and limitations of the population 

that must be accommodated by the design project. The use of design reference 

users would greatly simplify the need for designers to research and integrate 

information pertaining to the functional limitations and capabilities of people with 

disabilities. 

Designers and engineers lack information about the functional capabilities and limitations of 

people with disabilities. Few companies hire people with disabilities to provide design input for 

their products, and most university-level design courses do not adequately address UD. General 

information about functional capabilities is hard to come by and is not generally available in an 

easy-to-use format. Also, there is significant variability of functional capabilities, even within a 

disability group (particularly for individuals with upper-mobility impairments). All of these 

issues create a barrier for developing UD products. Despite the variability, some general 
250 

guidance can be developed (similar to section 508) to address the majority of issues that will 

arise. 

Recommendation #14. Develop a standard methodology for testing accessibility 

and comparing the accessibility of two similar products. 

Even given an understanding of functional limitations, companies lack a methodology to truly 

measure accessibility, which would also provide a means to compare accessibility among similar 

products. They do not understand the importance of including people with a variety of disabilities 

in product evaluations. And, even if they do develop products that satisfy the standards of section 

508 and other UD guidelines, that does not guarantee accessibility. 

Despite the lack of tools, some products exist that are considered “accidentally accessible.” Many 

of these designs were not created with a disability in mind (e.g., the Sidekick), but they happened 

to provide a great benefit for a particular disability population. In many cases, manufacturers may 

not even be aware that their designs have benefited special populations. The problem with these 

accidental solutions is that they may not carry through into future designs because their potential 

is not understood by the designers. If these features can be identified, however, and understood 

by the designers as benefiting more than the general public, designers may be able to overcome 

the fact that they lack formal tools or training to facilitate accessible design. 

Recommendation #15. Coordinate with industry to promote the integration of 

accessibility concepts, principles, and guidelines into the development tools used 

by designers to develop products. 

If the concepts of UD are integrated into the tools that designers use to develop products, more 

accessible products will be designed with little extra effort or cost on the part of industry. 

Industry needs to recognize that a small amount of effort to modify existing practices will have 

great benefits in the long run. 
251 

Analysis of Consumers of Universally Designed Products and Services 

Consumers with disabilities find many E&IT products to be inaccessible. They are quick to adopt 

accessible technologies when they become available and are loyal to companies that produce 

accessible technologies. Cost can be a significant barrier to adoption of these technologies, 

however. Many consumers with disabilities must pay for features they cannot use. For example, 

users who are blind typically cannot use many of the advanced features of cell phones, but 

companies today rarely provide a basic voice communication device. Also, many accessibility 

features tend to be bundled with higher-end products, increasing the cost for those who can 

benefit most but who are typically in a low-income situation. The focus group data indicated that 

people with disabilities are hesitant to pay for new technologies that are not proven to be 

effective for their needs. Perhaps one way to increase market share for these products is to 

distribute a small number of free devices for review by various disability groups, which can then 

spread the word of the value to be had for the cost. People with disabilities often do not have 

extra money to spend, but they are willing to spend a little bit extra for something they feel will 

benefit them in their daily lives. Increased demand and profitability will result as convenient, 

easy-to-use products become more prevalent at a lower cost. 

Recommendation #16. Develop an information clearinghouse where users can 

obtain information about accessibility issues and the features designed to address 

the issues for specific product lines. Educate consumers on how to shop for UD 

products and services. List vendor resources where consumers might obtain more 

information about universally designed products. 

Consumers tend to be misinformed or underinformed regarding product features they can benefit 

from. Companies fail to adequately market to people with disabilities, and it is not uncommon 

for marketing materials to be inaccessible to some individuals. In addition, general-population 

marketing of accessibility features can increase sales as awareness of product features increases 

for those who have a temporary disability, are not involved with a disability-specific advocacy 

group, or live in remote areas with less access to health care and specialized services. If products 
252 

can benefit multiple populations, there should be an increase in sales. Someone might purchase a 

talking clock, for example, for an occasional specific need, but they first need to be aware that 

this product exists; therefore, companies should not limit marketing to the population they expect 

to benefit from the product. 

Recommendation #17. Develop marketing strategies and approaches that will 

facilitate a connection with people with disabilities. 

An awareness from those in marketing departments of different populations believed to benefit 

from specific products and product features can help shape the marketing strategy, resulting in 

increased sales and more satisfied consumers. An example is the Sidekick. The Sidekick is a 

device about twice the size of the average cell phone that has extensive text messaging 

capabilities; it is also a cell phone. The Sidekick was not designed for the community of people 

who are deaf, nor has it been extensively marketed to users who are deaf, but its features greatly 

increase the communications capabilities of users who are deaf. Through word of mouth it has 

become a very popular device. General marketing of its text messaging capabilities has likely 

attracted the attention of users who are deaf, although they were not intended as the targeted 

population. 

People with disabilities want to use the same products that everyone else uses. They do not want 

to be limited to specialized products that are more costly. Implementation of UD is the best way 

to satisfy this desire of people with disabilities, while also providing more cost-effective products 

for all users. While it is impossible to satisfy the needs of all users, products and services that 

come closer to accommodating a variety of physical and cognitive differences will benefit both 

users and companies. 

Recommendation #18. Train people with disabilities to become subject-matter 

experts for the purpose of participating in design focus groups and accessibility 

evaluations. 
253 

The Federal Government should consider the development of training programs to help 

consumers with disabilities communicate their needs to companies interested in UD. The training 

programs should educate users about the industrial design process and suggest strategies for 

effectively formulating and communicating user needs. The program should prepare users for 

participation in focus group research as well as research designed to measure the accessibility of 

a product. 

Recommendation #19. Create job-related outcomes for bulk purchasers related to 

the successful procurement of products and services with UD features. 

Currently there are no incentives for successfully procuring accessible technologies and services. 

Indeed, the current system may actively dissuade some purchasers from considering accessibility, 

if the market research process is perceived as delaying the procurement of needed products. In 

addition, the outcome of purchasing inaccessible technologies is usually not known immediately 

and may never directly affect the purchaser. The Federal Government should institute programs 

designed to actively encourage section 508 compliance at the level of the individual purchaser 

through incentives or job-related performance criteria and provide direct feedback with regard to 

the accessibility of the products purchased. 

For additional information, see the online version of this report at www.ncd.gov.
254 
255 

List of Acronyms and Abbreviations 

AAATE Association for the Advancement of Assistive Technology in Europe 

ABA Architectural Barriers Act 

ADA Americans with Disabilities Act 

ADAAG Americans with Disabilities Act Accessibility Guidelines 

ANSI American National Standards Institute 

ASX active streaming XML 

AT assistive technology 

ATIS Alliance for Telecommunications Industry Solutions 

ATM automated teller machine 

B blind 

CAGR compound annual growth rate

CC closed captioning 

CITA Center for Information Technology Accommodations 

CDMA Code Division Multiple Access 

D deaf 

DTV digital television 

DVD digital video disc 

DVS descriptive video service 

E&IT electronic and information technology 

EIA Electronic Industries Alliance 

ENCT Electronic Newsroom Captioning Technique 
256 

EPG electronic program guide 

ESL English as a Second Language 

EU European Union 

FCC Federal Communications Commission 

GAO Government Accountability Office 

GPS global positioning system 

GSM global system for mobile communications 

GTRI Georgia Tech Research Institute 

HAC Hearing Aid Compatibility Act 

HDTV high definition television 

HH hard of hearing 

HREOC Human Rights and Equal Opportunity Commission 

HTML hypertext markup language 

Hz Hertz 

IDEA Individuals with Disabilities Education Act 

IDEN Integrated Digital Enhanced Network 

IEEE Institute of Electrical and Electronics Engineers

IEP individualized education program 

IFA International Federation of Ageing

IMAA Instructional Material Accessibility Act 

ISO International Organization for Standardization 

IT information technology 

IT&T information technology and telecommunications 
257 

ITTATC Information Technology Technical Assistance and Training Center 

iTV interactive television 

IVR interactive voice response 

L low 

LED light emitting diode 

LM lower mobility 

LONGDESC long description 

LV low vision 

M medium 

mm millimeter 

NCAM National Center for Accessible Media 

NCD National Council on Disability 

NCI National Captioning Institute 

NCRA National Court Reporters Association

NOIE National Office for the Information Economy

PBS Public Broadcasting System 

PDA personal digital assistant 

PIN personal identification number 

PIP picture-in-picture 

POC point of contact 

PSAP public service answering point 

RAM real audio movie 

RF radio frequency 
258 

RNIB Royal National Institute of the Blind

ROI return on investment 

SAMI Synchronized Accessible Media Interchange 

SAP secondary audio program 

SMIL synchronized multimedia integration language 

SRT speech recognition technology 

STB set-top box 

TIDE Telematics Applications for the Integration of Disabled People and the Elderly 

TTY teletype 

UD universal design 

UM upper mobility 

USDLA U.S. Distance Learning Association 

VDRA Video Description Restoration Act 

VPAT voluntary product accessibility template 

VRT voice recognition technology 

W3C World Wide Web Consortium 

XML extensible markup language 
259 

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Appendix 

Mission of the National Council on Disability 

Overview and Purpose 

The National Council on Disability (NCD) is an independent federal agency with 15 members 

appointed by the President of the United States and confirmed by the U.S. Senate. The overall 

purpose of NCD is to promote policies, programs, practices, and procedures that guarantee equal 

opportunity for all individuals with disabilities, regardless of the nature or significance of the 

disability, and to empower individuals with disabilities to achieve economic self-sufficiency, 

independent living, and inclusion and integration into all aspects of society. 

Specific Duties 

The current statutory mandate of NCD includes the following: 

• Reviewing and evaluating, on a continuing basis, policies, programs, practices, and 

procedures concerning individuals with disabilities conducted or assisted by federal 

departments and agencies, including programs established or assisted under the 

Rehabilitation Act of 1973, as amended, or under the Developmental Disabilities 

Assistance and Bill of Rights Act, as well as all statutes and regulations pertaining to 

federal programs that assist such individuals with disabilities, to assess the effectiveness of 

such policies, programs, practices, procedures, statutes, and regulations in meeting the 

needs of individuals with disabilities. 

• Reviewing and evaluating, on a continuing basis, new and emerging disability policy 

issues affecting individuals with disabilities at the federal, state, and local levels and in the 

private sector, including the need for and coordination of adult services, access to personal 

assistance services, school reform efforts and the impact of such efforts on individuals 

with disabilities, access to health care, and policies that act as disincentives for individuals 

to seek and retain employment. 

• Making recommendations to the President, Congress, the Secretary of Education, the 

director of the National Institute on Disability and Rehabilitation Research, and other 

officials of federal agencies about ways to better promote equal opportunity, economic 

self-sufficiency, independent living, and inclusion and integration into all aspects of 

society for Americans with disabilities. 

• Providing Congress, on a continuing basis, with advice, recommendations, legislative 

proposals, and any additional information that NCD or Congress deems appropriate. 

• Gathering information about the implementation, effectiveness, and impact of the 

Americans with Disabilities Act of 1990 (ADA) (42 U.S.C. § 12101 et seq.). 
276 

• Advising the President, Congress, the commissioner of the Rehabilitation Services 

Administration, the assistant secretary for Special Education and Rehabilitative Services 

within the Department of Education, and the director of the National Institute on Disability 

and Rehabilitation Research on the development of the programs to be carried out under 

the Rehabilitation Act of 1973, as amended. 

• Providing advice to the commissioner of the Rehabilitation Services Administration with 

respect to the policies and conduct of the administration. 

• Making recommendations to the director of the National Institute on Disability and 

Rehabilitation Research on ways to improve research, service, administration, and the 

collection, dissemination, and implementation of research findings affecting persons with 

disabilities. 

• Providing advice regarding priorities for the activities of the Interagency Disability 

Coordinating Council and reviewing the recommendations of this council for legislative 

and administrative changes to ensure that such recommendations are consistent with 

NCD’s purpose of promoting the full integration, independence, and productivity of 

individuals with disabilities. 

• Preparing and submitting to the President and Congress an annual report titled National 

Disability Policy: A Progress Report. 

International 

In 1995, NCD was designated by the Department of State to be the U.S. Government’s official 

contact point for disability issues. Specifically, NCD interacts with the special rapporteur of the 

United Nations Commission for Social Development on disability matters. 

Consumers Served and Current Activities 

Although many government agencies deal with issues and programs affecting people with 

disabilities, NCD is the only federal agency charged with addressing, analyzing, and making 

recommendations on issues of public policy that affect people with disabilities, regardless of age, 

disability type, perceived employment potential, economic need, specific functional ability, 

veteran status, or other individual circumstance. NCD recognizes its unique opportunity to 

facilitate independent living, community integration, and employment opportunities for people 

with disabilities by ensuring an informed and coordinated approach to addressing the concerns of 

people with disabilities and eliminating barriers to their active participation in community and 

family life. 

NCD plays a major role in developing disability policy in America. In fact, NCD originally 

proposed what eventually became the ADA. NCD’s present list of key issues includes improving 

personal assistance services, promoting health care reform, including students with disabilities in 

high-quality programs in typical neighborhood schools, promoting equal employment and 
277 

community housing opportunities, monitoring the implementation of the ADA, improving 

assistive technology, and ensuring that those persons with disabilities who are members of 

diverse cultures fully participate in society. 

Statutory History 

NCD was established in 1978 as an advisory board within the Department of Education (P.L. 95-

602). The Rehabilitation Act Amendments of 1984 (P.L. 98-221) transformed NCD into an 

independent agency. 
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280 

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1331 F Street, NW, Suite 850 US Postage Paid 

Washington, DC 20004 Permit No. G-279 

Official Business 

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Design for Inclusion • National Council on Disability • October 28, 2004