access to telecommunications equipment 

and customer premises equipment 

by individuals with disabilities

telecommunications access advisory committee

final report

january 1997
February 26, 1997

Ms. Judith E. Heumann

Chairperson

United States Architectural and

Transportation Barriers Compliance Board

1331 F Street, NW

Washington, D.C. 20004-1111

Dear Ms. Heumann:

It gives me great pleasure to officially transmit to the Access Board, the Telecommunications

Access Advisory Committee’s Final Report. Although a challenging assignment, I'm sure the

committee members would agree that our seven month effort was a most worthy endeavor and

professionally enhancing experience. We believe we have developed a comprehensive set of

recommendations that will help the Access Board in developing its accessibility guidelines for

telecommunications equipment and customer premises equipment under section 255 of the

Telecommunications Act of 1996.

As Chairman of the Committee I want to express my appreciation to you, the other members of

the Board, and the staff for appointing such a knowledgeable, experienced and dedicated

committee. Further, the staff support provided by the Access Board to assist the committee

was, throughout the entire process, outstanding and invaluable. Without such a talented

committee and such a capable staff, the Committee's report would surely be far less complete.

On behalf of the Committee, it was a distinct pleasure serving the Access Board in this very

significant project. The Committee stands ready to assist in implementing its

recommendations.

Sincerely,

Roberta E. Breden

Chairman, Telecommunications Access Advisory Committee
Member Organizations of the Telecommunications Access Advisory Committee and Their Appointed

Representatives:

Alexand er Graha m Bell/Con sumer A ction Netwo rk ........................... Alfred Sonnenstrahl

A T&T . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . Michael DelCasino

American Council of the Blind ................................................... Julie H. Carroll

American Foundation for the Blind ..................... Paul Schroeder, Committee Vice Chairman

American Speech-Language Hearing Association .................................. Holly Kaplan

Arkenstone ............................................................ James R. Fruchterman

Cellular Telecommunications Industry Association ................................ Jo-Anne Basile

Consumer Electronics Manufacturers Association ............................... George Hanover

The Council of Organizational Representatives ............................... Karen Peltz Strauss

The Ericsson Corporation ................................................. Lars-Goran Larsson

Gallaudet University ......................................................... Judith E. Harkins

Inclusive Technologies ............................................................. Jim Tobias

Lucent Technologies ........................................................ Steven M. Crosby

Massachusetts Assistive Technology Partnership ................................... Judy Brewer

Microsoft Corporation .......................................................... David Bolnick

Motorola, Inc. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A lfred R. Lucas

NCR ........................................................................ Steve I. Jacobs

National Association for State Relay Administration ................................. Willis J. Mann

National Federation of the Blind .................................................. T.V. Cranmer

Northern Telecom . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Leigh A . Thorpe

Netscape Comm unications ................................................ Glenn A. Ma nishin

NYNEX Corporation .............................................................. Brian Lane

Pacific B ell ................................................................ Marcia Straehley

Pennsy lvania C itizens Co nsumer Council ......................................... Jack O ’Keeffe

Personal Communications Industry Association ................................... Mark J. Golden

RESNA .................................................................... Alexand ra Enders

Self Help for Hard of Hearing People, Inc. ......................................... Brenda Battat

Siemens Business Communications, Inc. ........................................ Stephen Berger

Telecommunications Industry Association ...................... Roberta Breden, Com mittee C hair

Trace Research and Development Center ............................... Gregg C. Vanderheiden

United Cerebral Palsy Associations, Inc. ........................................ Jenifer Simpson

United States Telephone Association .......................................... Mary McD ermott

World Institute on D isability ....................................................... Betsy Bayha

Access Board Member ................................................... June Isaacson Kailes

Access Board Designated Federal Official .................................... Dennis M. Cannon

Other Significant Contributions Were M ade By: 

Gilbert Becker . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . NA S RA -- A lte rnate

Mary Brooner ........................................................... Motoro la -- Alterna te

Roberta Brosnahan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Arkens tone -- Alternate

Carl C argill ............................................................. Netsca pe -- Altern ate

Russell Carstensen ....................................................... Sentel Corporation

Nolan Crabb . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A CB -- Alternate

Todd Colqu itt ............................................................. USTA -- Alterna te
Charles C. Diggs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A SHA -- Alternate

Alan Dinsmore . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A FB -- Alternate 

Linda Dubroof .......................................... Federal Communications Commission

Luis G. Estrella ............................................................. UCPA -- Alterna te

Andy Firth .............................................. Federal Communications Commission

Ellen P. Francik .................................................................. Pacific B ell

Tina Ghabel ................................................................ PCIA -- A lternate

Erik R. Hansson ............................................................ Nortel -- Alternate

Katherine Harris . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . CTIA

Peter F. Harter .................................................... Netscape Communications

Elaine R. Hatcher . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A T&T -- Alternate

Marylyn Howe . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . MA T P -- Alterna te

David Jatlow ............................................................ Ericsson -- Alternate

Deborah Kaplan ............................................................ WID -- Alternate

Barry K asinitz . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . SHH H -- Alternate

Sam Lucente ........................................................... Netsca pe -- Altern ate

Elizabe th Lyle ........................................... Federal Communications Commission

Michael May . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Arkens tone -- Alternate

Mary McManus .............................................. Lucent Techno logies -- Alternate

David Mease ...................................................... Netscape Communications

H. Boyd Morrison . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . CEM A -- Alternate

David J. Nelson . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Amtrak

Gerard Nelson ................................................ Lucent Techno logies -- Alternate

Susan Palmer ........................................................ Pacific B ell -- Alterna te

Jeremy H. Pem ble ....................................................... Sieme ns -- Alternate

Jeffrey Pledger ................................................................. Bell Atlan tic

Pamela Ransom ............................................................. Issue Dynamics

Lisa Roberts ............................................................... CTIA -- Alternate

Mark Rubin ............................................. Federal Communications Commission

Laura Ruby . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A T&T -- Alternate

Martha Schleck ..................................................................... NYNEX

Grant E. Se iffert . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . TIA -- Alternate

David Siehl ............................................. Federal Communications Commission

Jim Seippel ............................................................. Sieme ns -- Alternate

Anthony Serafini ........................................ Federal Communications Commission

Scott Stanley . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . NYN EX -- A lte rnate

Christine Thompson ..................................... Trace Research & Development Center

Pamela Wallace ............................................................ NFB -- Alternate

Jackie Wheeler .................................................................. Telesensory

Ann Whelehan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . NYN EX -- A lte rnate

Bonnie White ....................................................................... NYNEX

Stan Wiggins ........................................... Federal Communications Commission

Norman S. Williams . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Gallaudet University -- Alternate

Kathleen M. Woods ......................................................... USTA -- Alterna te
v

TABLE OF CONTENTS

1.0

OVERVIEW

1.1. CHARGE AND RESPONSIBILITIES OF THE T ELECOMM UNICATIONS ACCESS

ADVISORY COMMITTEE ..................................................... 1

1.2. PURPOSE ................................................................... 2

1.3. GUIDING PRINCIPLES ....................................................... 3

2.0

HISTORY OF TELECOMMUNICATIONS ACCESS FOR

INDIVIDUALS WITH DISABILITIES

2.1. BARRIERS TO TELECOMMUNICATIONS AND DESIGN SOLUTIONS .............. 5

2.2. LEGISLATIVE HISTORY ...................................................... 7

2.3. ESTABLISHMENT OF TH E TELECOMM UNICATIONS ACCESS 

ADVISORY COMMITTEE ..................................................... 9

3.0

TERMS AND DEFINITIONS

3.1. GENERAL TERMINOLOGY: DEFINITION OF GUIDELINE TERMS . . . . . . . . . . . . . . . . 11

3.2 DEFINITIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

4.0 

PROCESS GUIDELINES

4.1. GENERAL . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

4.2. EXISTING PRODUCTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

4.3. MARKET RESEARCH . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

4.4. MARKETING COMMUNICATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

4.5. CUSTOMER SERVICE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

4.6. PRODUCT AND OPERATIONAL SUPPORT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

4.7. DETERMINATION OF ACCESSIBILITY NEEDS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

4.8. PRODUCT DESIGN AND DEVELOPMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

4.9. TRAINING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

4.10. CONSUMER INFORMATIONAL INQUIRIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

4.10.1. Point of Contact . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

4.10.2. Response Time . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

4.10.3. Information Provided . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
vi

4.11. DISABILITY ACCESS STATEMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

4.12. SPECIALIZED CPE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

5.0

PERFORMANCE GUIDELINES

5.1. INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

5.2. LEVEL 1 -- GENERAL PERFORMANCE GUIDELINES . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

5.2.1. Accessible To and Usable By Individuals with Disabilities, Where Readily Achievable. 19

5.2.2. Compatible with Existing Peripheral Devices or SCPE U sed by Individuals with

Disabilities, Where Readily Achievable. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

5.3. LEVEL 2 GUIDELINES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

5.3.1. Input, Control and Mechanicals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

5.3.2. Output, Displays and Feedback. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

5.3.3. Documentation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

5.3.4. Compatibility Guidelines . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

6.0

COMPLIANCE AND COORDINATION

6.1. COMPLIANCE AND COORDINATION OVERVIEW . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

6.2. ACCESS BOARD GUIDELINES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

6.2.1. Reauthorization of Guidelines . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

6.3. CONSENSUS STANDARDS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

6.3.1. Development of Standards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

 6.3.2. Refreshment of Standards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

6.3.3. Coordination of Standards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

6.3.4. International Harmonization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

6.4. COORDINATION POINT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

6.4.1. Establishment of Coordination Point. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

6.4.2. Participation of Individua ls with Disabilities. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

6.4.3. Access Engineering Specialist Training . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

6.4.4. Disability Representatives Training. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

6.4.5. Access Specialist Certification. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

6.4.6. Presentation of Access Needs and Strategies. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

6.4.7. Input into Guidelines. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

6.4.8. Input into Standards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

6.4.9. Industry/Disability Advisory Panel to the FCC. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

6.4.10. Research. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

6.4.11. Recognition for Access Innovation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

6.5. ACCESS VERIFICATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

6.5.1. Verification of Accessibility, Usab ility, and Compatibility . . . . . . . . . . . . . . . . . . . . . . . 29

6.5.2. Use of Qualified Access Specialists. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

 6.5.3. Documentation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

6.5.4. Certification of Access T esting Laboratories. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

6.6. DECLARATION OF CONFORMITY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30

6.6.1. Issuing Declaratio n of Conformity. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30

6.6.2. Location of Declaration of Conformity. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30

6.6.3. Contents of Declaration of C onformity. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30

6.6.4. Text of Declaration of Conformity. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30

6.7. INQUIRIES AND COMPLAINTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

6.7.1. M anufacturer’s P oint of Contact. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
vii

6.7.2. Consumer Information. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

6.7.3. FCC Point of Contact. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32

6.7.4. FCC Review of Complaints. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32

6.7.5. FCC Discretionary Use of Industry/Disability Advisory Panel. . . . . . . . . . . . . . . . . . . . . 33

6.7.6. FCC Selection of Measures in Instances of Non-Compliance. . . . . . . . . . . . . . . . . . . . . . 33

6.7.7. Collection of Data. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34

6.8. MARKET MONITORING REPORT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34

6.8.1. Acc ess Board Production of Annual Repo rt. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34

6.8.2. Contents of the Report. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34

6.8.3. Availability of Repo rt. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34

6.8.4. Actio ns Triggered by Report. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34

7.0

REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35

8.0

APPENDICES

APPENDIX A . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39

APPENDIX B . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41

APPENDIX C . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45

APPENDIX D . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59
viii
1

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed rules will

be made through the Federal rulemaking process.

1.0

 OVERVIEW

1.1. CHARGE AND

RESPONSIBILITIES OF THE

TELECOMMUNICATIONS ACCESS

ADVISORY COMMITTEE

This report contains recommendations of the

Telecommunications Access Advisory Committee

(TAAC or Com mittee) to the Architectural and

Transportation Barriers Compliance Board (Access

Board). The TAAC was convened by the Access

Board in June 1996 to assist the Board in fulfilling

its mandate under the Communications Act of 1934

as amended by the Telecommunications Act of 1996,

Section 255 (her einafter referre d to simply as section

255). Section 255 req uires that the Access Board, in

conjunction with the Federal Commun ications

Commission (FCC or Commission), develop

guidelines, by August 8, 1997, for acce ss to

telecommunications equipment and customer

premises equipment (CPE) by individuals with

disabilities. Portions of section 255 which are

relevant to the charge of the TAA C read as follows:

(b) MANUFACTURING -- A manufacturer of

telecommunications equipment or customer prem ises

equipment shall ensure that the equipment is

designed, developed, and fabricated to be acc essible

to and usa ble by individuals with disabilities, if

readily achievable.

...

(d) COMPATIBILITY -- Whenever the

requirem ents of subsections (b) ... are not readily

achievable, such a manu facturer ... sha ll 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.

(e) GUIDELINES -- Within 18 months after the

date of enactment of the Telecommunications Act of

1996, the Architectural and Transportation Barriers

Compliance Board shall develop guidelines for

accessibility of telecom munica tions equipment a nd

customer premises equipment in conjunction w ith

the Comm ission. The B oard sh all review and up date

the guidelines periodically.
2

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed

rules will be made through the Federal rulemaking process.

In selecting members of the TAAC, the Access

Board sought to ensure representation of the various

interests affected by the promulga tion of acces sibility

guidelines. Committee members represented

organizations advocating for the access needs of

individuals with disabilities, manufacturers of

telecommunications e q uipment and customer

premises equipment, manufacturers of specialized

customer premises equipment, manufacturers of

software, and telecommunications service providers.

Between June 1996 and January 1997 , the

Committee held six meetings, each of three working

days in length, during which members worked to

develop recommendations for implementing section

255 's requireme nts. This rep ort contains those

recommendations, and is intended to guide the

Access Board in the final preparation of the section

255 guidelines. The C ommittee hopes that the

diligent efforts to achieve conse nsus among the

various interests represented on the TAAC have laid

the groundwork for future cooperative efforts in the

implementation of section 255.

In preparing the recommendations contained in

this report, the Committee recognized that evolving

telecommunications technologies often make it

difficult to distinguish wheth er a prod uct’s functions

and interfaces are the result o f the design of the

product itself, or are the result of a serv ice provid er’s

software or even an information service format. It

was the intent of this Committee to recommend steps

to ensure that telecommunications equipment and

CPE are accessible to and usable by individuals.

The recommended guidelines do not differentiate

between hardware and software implementations of

a product’s functions or fea tures, nor is any

distinction made between fun ctions or featu res built

into the product and those that may be provided from

a remote server over the network.

This report is divided into six sections:

Section 1: “ Overview,” describes the

mandates and charges of the Access Board, the FCC,

and the TAAC, as well as eight guiding principles

created by the Committee to assist in the

development of accessibility guidelines.

Section 2: “History of Telecomm unications

Access for Individuals with Disabilities,” provides

historical information o n le gislation and

manufacturing practices impacting

telecommunications access for individuals with

disabilities.

Section 3: “Definitions,” sets forth definitions

and terminology which are utili zed throughout the

TAAC Repo rt.

Section 4: “Process Guidelines,” sets forth

proposed processes for manufacturers to follow in

designing and developing accessible equipment.

Section 5: “Performance Guidelines,”

provides examples of how to make

telecommunications equipme nt accessible. This

section, along with Appendix C, will be updated on

a regular basis, a nd is intended to provide engineers

and product developers with a sense of what persons

with disabilities need in order to effectively access

and use telecommunications equipment and CPE.

Section 6: “Compliance and Coordination

Guideline s,” outlines a process for ensuring

compliance with the accessibility guidelines and

establishes mechanisms for coordination between

industry and people with disab ilities.

1.2. PURPOSE

The provisions of section 255 reflect Congress’

recognition that individuals with disabilities need

improved access to telecommunications technology.

Congress placed an obligation on manufacturers to

consider accessibility when designing, developing,

and fabricating telecommunications equipment and

CPE. Among other things, these recommendations

set forth factors to be considered throughout these

processes to achieve accessibility. Because the pace

of technological change is so rapid, it is expected

that many aspects of accessibility which are not

readily achievable tod ay may become read ily

achievab le in the future. Manufacturers need to

remain current in their assessme nt of whether it is

readily achievable to make their produ cts accessible

by seeking out information on how to incorporate

access into those products.

An important approach in designing accessible

products is called universal design. This is the
3

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed rules will

be made through the Federal rulemaking process.

practice of designing products so that they are usab le

by the broadest possible audience. Products

designed in this way are usable by more people

without reducing the usability or attractiveness for

mass or core audiences of the product. Wit h

universal design, the goal is to ensure maximum

flexibility, benefits, and ease of use for as many

individuals as possible. In the past, some products or

designs developed with universal design principles

have attracted a wider audience than may have

otherwise been attracted by the product. For

example, curbcuts, originally designed to ensure

wheelchair access, are ro utinely used by parents with

strollers, bicyclists, and delivery personnel.

Similarly, closed captioning on telev ision

programming, created for the benefit of individuals

who are deaf or hard or he aring, is frequently used in

airports, restaurants, and other noisy locations where

it is difficult to hear the audio portion of the

programming. Finally, an audio adjunct to caller ID

not only enables individuals who are blind to learn

the identity of a caller, but enables family members

eating dinner to identify callers without leaving the

dinner table. The TAAC encourages the use of

universal desi gn in the manufac ture of

telecommunications equipment and CPE.

1.3. GUIDING PRINCIPLES

In developing the final accessibility guidelines

required by section 255, the TAAC recommends that

the Access B oard ad here to the following eight

principles:

1. The guidelines must be specific enough that

one can determine when they have been followed.

2. The guidelines mu st be sufficiently flexible

to give manufacturers the freedom to innovate.

3. Produc ts should be made accessible to and

usable by peop le with as wide a range of abilities or

disabilities as is readily achievable.

4. Whenever it is not readily achievable to

m ake a product accessible to and useable by

individuals with disabilities, the manufacturer or

provider of that product shall ensure that the product

is compatible with existing peripheral devices or

specialized customer p remises equ ipment commonly

used by individuals with disabilities to achieve

access, if readily achievable.

5. The Committee understands that it may not

be readily achievable to make every type of product

accessible for every type of disability using present

technology. Future technologies may result in

accessibility where it is not currently readily

achievable.

6. Because telecommunications technology is

changing so rapidly it is expected that the guidelines

will need to be updated on a regular basis.

7. The guidelines must reflect the fact that

computer, telephone, information, and teletransaction systems may converge such that single

devices may simultaneously provide a ll of these

functions.

8. The guidelines should address process,

performance, and compliance and coord ination

issues. 
4

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed

rules will be made through the Federal rulemaking process.
5

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed rules will

be made through the Federal rulemaking process.

2.0 

HISTORY OF

TELECOMMUNICATIONS

ACCESS FOR

INDIVIDUALS WITH

DISABILITIES

This section contains a brief overview of

historical developments affecting

telecommunications for individuals with disabilities.

It is intended that this section will provide a

framework for the development of the TAAC

recommendations contained in this report.

2.1. BARRIERS TO

TELECOMMUNICATIONS AND 

DESIGN SOLUTIONS

In order to understand the recommendations of

this report, it is important to first consider some

b a r r i e r s i n d i v i d u a l s w i t h d i s a b i l i ti e s h a ve

encountered in accessing telecom munication s as well

as some actions the telecommunications industry has

taken to make telec ommunic ations equipment

accessible prior to the enactment of the

Telecommunications Act of 1996. 

Access to telecommunications has been of great

concern to people w ith disabili ties since the

invention of the telephone. Initial advocacy efforts

came from people who are deaf and hard of hearing.

In the mid-19 60s, a fundamental barrier -- the lack of

a visual alternative to voice communication by

people who are deaf -- began to fall with the

invention of an acoustic c oupler that allowed

teletypewriter signals to be sent and received through

the telephone network. AT&T and others donated

teletypewriters and a volunteer organization of

teleco m m u n i c a t io ns work e r s , t h e T e l e p h o ne

Pioneers, worked with the deaf community to assist

in bringing this technology to those who needed it.

This demonstrated how industry and persons with

disabilities can work together, given the opportunity.

Since the early 1970s, several

telecommunications companies have initiated and

supported the development of a number of access

technologies. The application of Baudot technology

(both TTY hardware and the protocol) to text

terminals for deaf, hard of hearing, and speech

disabled users, and its dissemination, was a principal

focus of their efforts in this area. In addition to
6

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed

rules will be made through the Federal rulemaking process.

general initiatives, some of these companies

provided case-by-case custom s upport for

telecommunications functions for people with

disabilities, including special assemblies, such as

on-hook/off-hook switches that could be controlled

by light touch, puff and sip, and electronic

environmental controls. These products enabled

many p ersons with disabilities to live more

independently. The Telephone Pioneers published

a n d d i s t r ib u t e d t h e f i r st c o m p e nd i u m of

telecommunications accessibility tools known as the

“Green B ook.”

In the late 1970s, consumers began to take their

concerns to state utilit y commissions and

legislatures. The state o f California took the lead by

assessing a line charge to finance the lending of

TTYs. This program was later extended to other

specialized customer premises equipment used by

people who are ha rd of hearing as well as those w ith

speech disabilities, and those experiencing other

problems with telephone access.

In the 1980s, a number of telecommunications

companies began eff orts to maxim ize access for

persons with disabilities. First, they participated in

state equipment distribution programs for people

with disabili ties. Second, many compan ies

participated in the initial efforts to establish

telecommunications relay services (T RS). Finally,

several companies initiated research in speech

recognition technology that would offer new input

and output opportunities for people who had speech,

vision, and physical limitations. 

The hearing aid compatibility standard grew out

of a character istic of older telep hone rece ivers.

These receivers leaked magnetic signals that could

be picked up by a sma ll coil in the hearin g aid. This

eliminated acoustic background noise and thus

improved audibility of speech. When manufacturers

switched to newer, more efficient receiver designs,

the inductive coupling was no longer possible. This

spurred a decade-long advocacy effort to achieve

hearing aid comp atibility in all telephones, and

which resulted in the development of the EIA

Standard RS-504 , first issued in 198 2, which

established formal criteria d efining the magnetic

field intensity from a telephone receiver, and the

Hearing Aid Compatibility Act of 1988. (The details

of the HAC Act are discussed in the legislative

history section of this report.) 

In general, solutions to telecommunications

barriers had focused prim arily on adaptations to

inaccessible equipment and the provision of

specialized customer premises equipment. Lately,

some service providers and manufacturers have

become aware that s olutions to barriers for

individuals with disabilities are sometimes of benefit

to a wider range of customers as well. For example,

the vibrating pager is accessible to deaf persons but

it also means the pager won’t interrupt an important

business meeting. The voice-activated telephone

dialer can be used by someone with limited use of

her hands as well as a driver who wants to place a

call on her cellula r phone w ithout taking her eyes off

the road. The voice-output Caller ID device is

usable by a blind perso n and, at the same time,

allows identification of the caller without having to

leave the dinner table to see the device. These and

similar designs are examples of the application of

universal design principles: that is, incorporating

features in the product itself to make it more usable

by a wider audience.

By the 1980s, telecomm unications and customer

premises equipment had become much more diverse.

Some of the new technologies improved ac cessibility

and offered new functionality. With the diversity,

however, came a new array of access problems. For

example, the proliferation of facsimile created a new

barrier to people with low vision or blindness. At

the same time, ongoing problems with access to the

voice network led deaf individuals to advocate for

telephone relay service in their states and u ltimately

nationwide, through Title IV of the ADA.

As the convergence of telephone, computers,

and television technologies began to escalate in the

late 1980s and early 1990s, individuals with

disabilities began to realize both the tremendous

potential of technology and the potential for setbacks

in accessibility. Of particular concern was the

impact of these technologies on employment and

participation in the mainstream of technology. For

example, the marriage of computers and networks

brought the graphical user interface, an inaccessible

interface for people w ho are blind , into the world of

telecommunications, extending its importance as a

tool in the workplace.
7

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed rules will

be made through the Federal rulemaking process.

As a result, consumers with different types of

disabili ties focused on telecommunications

advocacy, with the goal of ensuring that

telecommunications and customer prem ises

equipment would be as accessible as possible. 

Developing accessibility guidelines for the new

generation of telecommunications and customer

premises equipment poses a series of issues for both

the industry and individuals with disabilities. For

example, with the rapid pace of technologic al

innovation within the telecommunications industry,

individuals with disabilities are concerned that new

technologies be accessib le so that they can compete

in the workpla ce. Moreover, as technology becomes

commonplace in the American lifestyle, individuals

with disabilities need to know if they will b e able to

use such equipment, or if it will be useable with

specialized customer p remises equipment. Also,

how will individuals with disabilities know if a

particular piece of equipment meets their needs?

These issues are discussed in this repo rt.

The telecommunications industry also has

concerns with the implementation of section 255. A

key issue for industry is how the criteria of readily

achievable can be applied to telecommunications of

equipme nt accessibility. Industry is also concerned

with how to develop accessible products without

discouraging innovation and thus putting them at a

competitive disadvantage within the marketplace.

Finally, there is a concern about what will happen if

industry can make a given product accessible to

some, but not all disabilities. These and other issues

became the f ocus of dis cussions of the

Telecommunications Access Advisory Committee.

2.2. LEGISLATIVE HISTORY

Prior to the 198 0s, little had bee n done b y state

or federal legislatures to address the needs of

individuals with disabilities to utiliz e

telecommunications equipment. Starting in the early

1980s, some states developed programs for the

provision of telecommunications relay services and

the distribution of specialized customer premises

equipment, such as text telephones (TT Ys),

telebraille machines, and artificial larynxes. Relay

services enable persons who are speech or hearing

disabled and who use TTYs to communicate by

telephone with persons who use conventional voice

telephones via a third party called a communications

assistant. For the most part, these state relay and

distribution program s could no t meet all of th e

demands for telecommunications services or

equipment by individuals with disabilities.

The first important step in the development of a

national telecomm unications p olicy for perso ns with

disabilities was the Telecommunica tions for the

Disabled Act of 1982. This law expressly allowed

states to require carriers to continue pro viding

subsidies for specialized equipment needed by

persons with impaired hearing, speech, vision, or

mobility. The 1982 Act also set forth requirements

for certain telephones to be compatible with hearing

aids. This new law made clear that compatibility

between telephones and hearing aids was necessary

to accommodate the needs of som e persons w ith

hearing loss. In this law, for the first time Congress

recognized the FCC’s obligation to ensure that

individuals with disabilities “have acce ss to the

universal telephone network.” H. Rep. No. 888

(97th Congress, 2d Session. 1982) 4. The Ho use

Report explained:

“Persons with normal hearing may b e unable

fully to appreciate the pervasiveness o f the

telephone both in commercial transactions and

personal contacts. The inability to use this

instrument, except through an interpreter, is not only

a practical disability but a constant source of

dependency and personal frustration. Conversely,

the ability independently to use the telephone may

enable persons with other severe handicaps ... to lead

self-sufficient lives in regular contact with society.

The Committee believes that making the benefits of

the technological revolution in telecommunications

available to all Americans, including those with

disabilities, should be a priority of our national

telecommunications policy.” (Id. at 4-5).

In 1986, Congress continued to recognize the

importance of providing access to information

technology when, in Section 508 of the 1986

Amendments to the Rehabilitation Act, Congress

directed federal government agencies to limit their

purchases to information technology that is

accessible or could support accessibility. In 1988,
8

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed

rules will be made through the Federal rulemaking process.

Congress took an additional step in recognition of

the crucial role that access to technology plays in the

lives of individuals with disa bilities, with the

Technology Related Assistance for Individuals w ith

Disabilities Act. Title I of that Act provides federal

funding for grants to states to increase access to

assistive technology and accessible information

technology.

In 1988, Congress also passed the Hearing Aid

Comp atibility Act (HAC Act). The HAC Act

required that all landline telephones (with the

exception of secure telephones) made in or imported

into the United S tates after a certa in date (August

1989, with the exception of cordless telephones,

which were given an extension until August 1991)

must be hea ring aid com patible. In 1988, Congress

also passed the Telecommunications Access

Enhancement Act. This legislation established an

expanded federal relay services for calls to, from,

and within the federal government, and was designed

to improve telecomm unications access for persons

who use TT Ys.

In July of 1990, the Americans with Disabilities

Act (ADA) was signed into law. The ADA was the

first comprehensive civil rights law to prohibit

discrimination against persons with disabilities in

employment, state and local government programs,

places of public accommodation, transportation, and

telecommunications. Title IV of the ADA mandated

the establishment of a nationwide

telecommunications relay service (T RS) by Ju ly 26,

1993. The ADA’s requirement for TRS has begun to

open the world of telecomm unications to in dividuals

with hearing and speech d isabilities. Titles I, II, and

III have also impacted somew hat on

telecomm unications access by i ndividuals with

disabilities. Although these sections

 do not impose any requirements for the development

of accessible telecommunications products and

services, they do require employers, state and local

governments, and places of public accommodation,

respectively, to provide auxiliary aids and services,

which may include accessible telecommunications

products and services, to achieve effective

communication by individuals with disabilities.

Finally, the ADA Accessibility Guidelines

(ADAAG), promulgated by the Access Board,

require certain telephones covered by the AD A to be

physically accessible, hearing aid compatible, and

have volume co ntrol. These guidelines also require

TTYs to be provided at certain public pay phone

locations. Notwithstanding these various mandates

for telecommunications access under the ADA,

nothing in the ADA requires the manufacture of

telecommunications products that are accessible.

Among other things, section 255 of the

Communications Act (as amended) is intended to fill

this gap.

In October of 1990, Congress went on to enact

the Television Decoder Circuitry Act. This law now

requires television sets with screens 13 inches or

larger, manufactured or imported into the United

States, to be equipped with a computer chip which

decodes closed cap tioning on te levision programs.

Decoder equipped televisions enable persons who

are deaf or hard of hearing to receive caption output

with regular television programming where

captioning is otherwise incorporated into the

programming. A n e w S e c t io n 7 1 3 of the

Communications Act, added by the 1996 Act, further

expands such television access by applying new

requireme nts for captioning on new and previo usly

published video programming.

The Telecommunications Act of 1996 follows

this long history of legislative efforts to improve

telecommunications access for individuals with

disabilities. In addition to mandating access to

telecommunications equipment and customer

premises equipment, section 255 of t h is Act

mandates access to telecommunications services.

The FCC is charged with enforcing section 255, and

is expected to initiate further proceedings.
9

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed rules will

be made through the Federal rulemaking process.

2.3. ESTABLISHMENT OF THE

TELECOMMUNICATIONS ACCESS

ADVISORY COMMITTEE

In order to meet its responsibilities under section

255(e) of the Telecommunications Act, the Access

Board chartered the Telecommunications Access

Advisory Committee, under the Federal Advisory

Committee Act. T he purpose of this Advisory

Comm ittee was to bring together members of the

telecommunications industry, manufacturers of

telecommunications equipment and customer

premises equipme nt, and perso ns with disabilities to

provide the Access Board with recommendations on

what the accessibility guidelines should address.

On March 28, 1996, the Access Bo ard published

a notice of intent to establish an advisory committee

to make recommendations to the Access Board on

accessibility guidelines for tele communications

equipment and customer premises equipment. (See

Appen dix D) The notice requested nominations for

membership on the Committee from manufacturers

of telecommunications equipment and customer

premises equipment; manufacturers and developers

of perip heral devices or specialized customer

premises equipment commo nly used by individuals

with disabilities to achieve access; organizations

representing the access needs of individuals with

disabilities affecting hearing, vision, movement,

manipulation, speech, and interpretation of

information; telecommunications providers and

carriers; developers of telecommunications software;

and other persons affected by the accessib ility

guidelines.

Over 60 nominations were submitted. From this

group, the Board selected 33 organizations. (See

Appendix D) Of this o riginal group, three

organizations did not send a representative and one

organization withdrew midway through the process.

Once established, the Co mmittee accepted the

applications of four additional members to achieve

better represe ntation of the interests in this

proceeding.
10

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed

rules will be made through the Federal rulemaking process.
11

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed rules will

be made through the Federal rulemaking process.

3.0

TERMS AND

DEFINITIONS

3.1. GENERAL TERMINOLOGY: 

DEFINITION OF GUIDELINE

TERMS

Strategies -- state precisely how a design

feature should be implemented. Illustrative

examples might include:

 If a numeric keypad is used then there should be

a tactile indicator on the 5 key;

 If an Infrared port is used then it should support

XYZ standard; and

 Modems should all support QRS

communication pro tocol.

Performance Guidelines -- are guidelines

which state what should be achieved but do not

specify how it would be achieved. Illustrative

examples might include:

 Product should have sufficient volume to be

heard above ambient noise;

 Produc t should be usable without looking at it;

 Produc t should be usable if it is not possible to

hear it.

Process Guidelines -- are guidelines that

specify the process that a company should use in

designing and bringing a product to market as well as

post introduction processes. Illustrative examples

might include:

 The initial product documentation on system

requirements and description should include

accessibility considerations;

 Information on products should b e available in

alternate accessible forms;

 Product support lines will be knowledgeable of

assistive technologies that are com monly used

with their prod uct.

Compliance Guidelines -- are guidelines that

specify the steps a manufacturer should take to

demonstrate t h a t i t h a s m e t t h e g u i d e li n e s.

Illustrative examples might include:

 The manufacturer has filed a Declaration of

Conform ity;

 The manufacturer has fully documented its good

faith efforts;
12

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed

rules will be made through the Federal rulemaking process.

 The product has been reviewed by a qualified

access specialist. 

3.2. DEFINITIONS

The meaning of terms not sp ecifically defined in

this document shall be as defined by collegiate

dictionaries in the sense that the context implies.

Accessible -- Means that a person with a

disability can use the equipm ent to perform the same

tasks, access the same information, with the same

ease, in the same time and at the same c ost as a

person using the equipme nt without a disa bility, and

that the person can use the product in its standard

manufactured and shipped form without having to

modify the product or to purchase special

technologies.

Alternate Forma ts, Alternate Methods --

Alternate formats and alternate methods may

include, but are not limited to: voice, FAX, TRS

(relay service), Internet posting, closed captioning,

audiotext, audio-casse tte r ecording,

audio-description, Braille, ASCII text, and large

print.

Communications Act -- The Communications

Act of 1934 [47 U.S.C.] was amended by the

Telecommunications Act of 1996, which added a

number of sections, in cluding section 255 (see

Appendix B).

Compatible -- Means that the

telecommunications or customer premises equipment

is designed so that it can be used with, does not

interfere with, and, where applicable, can be

connected to existing peripheral devices o r

specialized customer premises equipm ent comm only

used by individuals with disabilities to achieve

access.

Customer Premises Equipment (CPE) -- The

term ‘customer premises equipment’ means

equipment employed on the premises of a person

(other than a carrier) to originate, rou te, or terminate

telecommunications. (47 U.S.C. 153)

Comment -- The TAAC members agree that the

statutory definitions for “telecommunications

equipment” and “customer premises equipment” are

meant to be interpreted broa dly to include a wide

array of electronic p roducts which provide

telecommunications, including personal computers.

Because electronic products are largely software

driven, the TAAC concludes that the definition of

telecommunications equipment and customer

premises equipment includes the software whic h

provides telecomm unications functions.

Customer Premises User Interfac e (CPU I) --

the interface which the user must interact with when

using CPE for telecommunications.

Disability -- The term ‘disability’ has the

meaning given to it by section 3(2)(A) of the

Americans with Disabilities Act of 1990 (42 U.S.C.

12102(2)(A)). [47 U.S.C. 255(a)(1)]

As Defined in the ADA -- “The term ‘d isability’

means, with respect to an individual - (a) a physical

or mental impa irment that sub stantially limits one or

more of the major life activities of such ind ividual;

(b) a record of such an impairment; or (c) being

regarded as having such an imp airment.” [42 U.S.C.

12102(2)(A)]

The TAAC report reflects the intent of Congress

as noted in the following language from the Senate

Committee Report on the Telecommunications Act

of 1996: “The [Senate] Committee intends the

definition of disability to principally cover

individuals with functional limitations of hearing,

vision, moveme nt, ma n i p u l a ti o n , s p eech, or

interpretation of information ....”

Manufacturer -- Denotes a manufacturer of

telecommunications equipment and/or customer

premises equipment (CPE). Specifically included

are manufacturers of the customer premises user

interface for telecommunications and/or customer

premises equipment, including software which

provides the interface.

Readily Achievable -- The term ‘readily

achievable’ has the meanin g given to it by section

301(9) of the Americans with Disabilities Act (42

U.S.C. 12181(9)). [47 U.S.C. 255 (a)(2)]
13

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed rules will

be made through the Federal rulemaking process.

As Defined in the ADA, Section 301(9) -- “The

term ‘r eadily achievable’ mea ns easily

accomplishable and able to be carried out without

much difficulty or expense. In determining whether

an action is readily achievable, facto rs to be

considered include: 

(A) the nature and cost of the action needed

under this Ac t;

(B) the overall financial resources of the facility

or facilities involved in the action; the number of

persons employed at such facility; the effect on

expenses and resources, or the impact otherwise of

such action upon the operation of the facility;

(C) the overall financial reso urces of the

covered entity; the overall size of the business of a

covered entity with respect to the number of its

employees; the number, type, and location of its

facilities; and

(D) the type of operation or operations of the

covered entity, including the composition, structure,

and functions of the workforce of such entity; the

geographic separateness, administrative or fiscal

relationship of the facility or facilities in question to

the covered entity.” [42 U.S.C. 12181(9)]

Comment --The T AAC inte rprets the application

of the readily achievable criteria in the 1996 Act to

be somewha t different from the use of “readily

achievable” in the Americans with Disa bilities Act.

The ADA’s use of “readily achievable” applies to

retrofitting of buildings, and is used to determine the

proportion of effort to be expended in providing

architectural accessibility. The 1996

Telecommunication Act’s use of the term applies to

the design, development and fabrication of

telecommuni cations equipment and customer

premises equipment. The TAAC’s recommended

guidelines provide more information on how readily

achievable should be implemented in practice. 

Several f a c t o r s a r e i m p o rtant in the

determina tion of whether certain accessibilit y

features are readily achievable. They include the

size of the manufacturer and the amount of effort

required to impleme nt accessibility a nd marketab ility

of the resulting prod uct. For instance, implementing

certain accessibility feature s is not readily ac hievable

if doing so would drive the manufacturer out of

business, require efforts far exceeding those involved

in designing the product without the access features

or render the product unmarketable. Implementing

certain accessibility features is readily achiev able if

the cost to do so is small relative to the cost of the

entire production design effort, adds little or nothing

to the manufacturing and distribution costs, and has

minimal or positive impact on the produ ct’s

marketability. The Design Process portion of this

report will assist in moving these two extremes

closer to each other. 

Telecommuni cations -- The term

‘telecommunications’ means the transmission,

between or among points specified by the user, of

information of the user’s cho osing, without c hange in

the form or content of the information as sent and

received. [47 U.S.C. 153]

Comment -- A change in information format

(e.g., text to Braille or text to speech) to provide

access is not a “change in the form or content”

excluded under the definition of

telecommunications.

Telecommunications Act -- The

Telecommunications Act of 1996 amended the

Communications Act of 1934 and added several

sections including section 255.

Telecommunications Equipment -- The term

‘telecommunications eq uipment’ means equipment,

other than customer premise equipment, used by a

carrier to provide telecommunications services and

includes software in tegral to such equipment

(including upgrades). [47 U.S.C. 153]

Telecommunications Service -- The term

‘telecommunications service’ means the offering of

telecommunications for a fee directly to the public,

or to such classes of users as to be effe ctively

available directly to the public, regardless of the

facilities used. [47 U.S.C. 153] 

Text Telephone (TTY) -- Machinery or

equipment that employs interactive graphic (i.e.,

typed) communications through the transmission of

coded signals across the standard

telecommunications network. Text telephones can

include, for example, devices known as TDDs

( t e le c o m m u n i c a t io n display devices or
14

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed

rules will be made through the Federal rulemaking process.

telecommunication devices for deaf persons) or

computers. 

Usable -- The term ‘usable’ means the

telecommunications equipment or CPE can be

effectively used by individuals with disabilities,

including, but not limited to, the availability of

instructions, accessible fea ture info rmation,

docum entation, technical supp ort and de livery in

alternate formats or through alternate methods.
15

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed rules will

be made through the Federal rulemaking process.

4.0

PROCESS

GUIDELINES

The guidelines that follow address the process of

designing for accessibility rather than the

performance of accessible devices. The processes

used by a manufacturer to design, de velop, fabr icate

and deliver telecommunications or customer

premises equipment, and to make decisions related to

the design, development, fabrication and delivery of

their produc ts are unique to that manufacturer. The

intent of the guideline s in this section is to id entify

elements the TAA C expects to make up processes

for achieving accessibility and usa bility for

individuals with disabilities. Manufacturers would

decide how each element may be integrated into their

individual process.

Each guideline consists of a basic statement

about the element. T he basic statement may b e

accompanied by additional statements about

particular aspects of that element, a rationale, and/or

a list of examples or situations in which the guideline

would apply.

4.1. GENERAL

Section 255 requires that manufacturers provide

access to telecommunications equipment and

customer premises equipment where read ily

achievable. Accessibility is easier to achieve if

considered at the beginning of and throughout the

design process. Manu facturers shall consider access

to telecommunications by individuals with

disabilities throughou t product design, develo pment,

fabrication and delivery, as early and consistently as

possible.

4.2. EXISTING PRODUCTS

Periodically, manufacturers change, upgrade, or

distribute new release s of existing produc ts.

Whenever they do so, manufacturers are expected to

consider accessibility features, and incorporate tho se

features into existing products when read ily

achievable. Minor or insubstantial changes such as

cosmetic changes, or cost-reduction measures, that

d o not affect functionality, need not trigger

accessibility reviews.
16

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed

rules will be made through the Federal rulemaking process.

4.3. MARKET RESEARCH

Manufacturers are expected to address the needs

of individuals with d isabilities in their market

research and this research should be comp arable to

other market research efforts. Examples of primary

market research may include targeted recruitment of

individuals with disabilities, surveys cond ucted in an

accessible manner and separate or integrated focus

groups. Examples of secondary market research may

include cooperative studies or research, as well as

general access related research and produc t specific

studies.

INDUSTRY NOTE : The clau se “... and th is

research should be comparable to other market

research efforts” is subject to a variety of

interpretations. In the interest of preventing future

misunderstandings, Comm ittee members

representing manufacturers a n d t h e i r tr a de

associations submit the following as their opinion

about the interpretation of this clause: “ This clause

should not mean that, when conducting market

research related to products for general distribution,

manufacturers are expected to duplicate their

market research expenditures in order to conduct

additional market re search rela ted to the use of

produc ts for genera l distribution b y individu als with

disabilities. Rather, with respect to market research

studies, it should mean that manufacturers are

expected to: (a) recognize that individuals with

disabilities are among the potential customers wh ose

desire to purchase an d use products is being studied

and (b) treat the po pulation of individuals w ith

disabilities in a manner sub stantially similar to its

treatment of other groups of potential customers.

Accordingly, inclu sion of individuals with

disabilities in market research related to prod ucts

for genera l distribution would satisfy both this

section an d section 4 .7.”

4.4. MARKETING

COMMUNICATIONS

I n f o rm atio n about products and their

accessibility or compatibility features should be

available to and usable by individuals with

disabilities. Examples of such communications

include broadcast and print media advertising,

product brochure s, collateral pu blicity, internet sites

or other media. Such information needs to be

available to consumers contemplating the purchase

of a device, or to end users of CPE.

Steps which manu facturers shou ld consider in

addressing this need for accessible information

include:

1. Making product information available in

alternate formats, upon req uest;

2. Where a telephone con tact with the

manufacturer is provided in the marketing

communi cations, providing operator access in

alternate formats and in alternate methods upon

request and at an equivalent cost to the consumer

(e.g., toll free or local rates);

3. Providing closed captioning in TV

advertising for telecommunications products;

4. Working cooperatively with organizations

representing individuals with disabilities, for

example by providing information for newsletters,

mailings, or meetings, as appropriate; and

5. Making reasonable efforts to validate any

unproved access solutions through testing with

individuals with disabilities or with appropriate

d i s a b i l i ty - r e l a te d organizations who have

documented expertise with ind ividuals with

disabilities.

4.5. CUSTOMER SERVICE

Individuals with disabilities need to be able to

go through the steps of ord ering, billing, and

interacting with customer service representatives.

Steps that can be tak en by manu facturers to m eet this

need include making customer service processes

available through alternate formats and alternate

methods, upon request.

4.6. PRODUCT AND OPERATIONAL

SUPPORT

Individuals with disabilities require access to

documentation (e.g., user guides, installation guides

for end-user installa ble devices) and product support

communications, regarding both the product in
17

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed rules will

be made through the Federal rulemaking process.

general and specifically the accessibility features of

the product. Steps that shall be taken by

manufacturers that will assist individuals with

disabilities to meet these needs include:

1. Providing a description of the accessibility

and compatib ility features of the product upon

request, including, as needed, in alternate form ats;

2. Providing end user product documentation

in alternate form ats, promp tly, at no additional cost;

3. Ensuring accessible customer support and

technical support, upon request, in the call centers

and service centers which support their products;

Other steps that can be taken include but are not

limited to:

1. Encouraging third party distributors of the

manufacturer’s p r o d u c t s to f o llow similar

accessibility guidelines in product and operational

support; and

2. Encouraging resellers and distributors of the

manufacturer’s products to refer unreso lved

customer requests concer ning accessib ility and

compatibility of the product to the manufacturer, as

appropriate.

4.7. DETERMINATION OF

ACCESSIBILITY NEEDS

Consultation with end users and end-user testing

are important in achieving a product that meets the

design goals. To achieve a p roduct that is accessible

to and usable by individuals with disabilities, the

needs of individuals with disabilities should be

considered as early as possible during the

development of the product concept, and at

appropriate stages during product design,

development, fabrication an d delivery.

Manufacturers should consult with individuals with

disabilities regarding the accessibility of the produc t,

as needed, to achieve accessibility and usability.

Some methods that may be used to achieve this are:

1. Inclusion of individuals with disabilities in

the target populations of market research;

2. Inclusion of individuals w ith disabilities in

product trials;

3. Direct consultation with disability advocacy

organizations; and

4. Direct consultation with individuals with

disabilities. 

4.8. PRODUCT DESIGN AND

DEVELOPMENT

Manufacturers shall consider accessibility and

usability of their products for individuals with

disabilities. To this end, manufacturers are expected

to identify potential or actual barriers to ac cessibility

and usability as part of the product development

process. When accessibility is not readily

achievable, manufacturers shall design products

compatible with existing peripheral devices and/or

specialized customer premises eq uipment, if readily

achievable.

4.9. TRAINING

Manufacturers should actively seek to stay

current in their accessibility designs. Manufacturers

should also provide employees (engineers, product

managers, service repr esentatives, etc.) w ith periodic

training regarding the requirements of section 255

directly relevant to that employee’s function. Where

approp riate to an employee’s function, such training

should include:

1. Accessibility requirements of individuals

with disabilities;

2. Means of communicating with individuals

with disabilities;

3. Commonly-used adaptive technology

appropriate to their pro ducts;

4. Designing fo r accessibility;

5. Solutions for accessibility and/or

compatibility; and

6. Identification of contact person(s) within

the company who will address customer requests

concerning accessibility and compatibility.
18

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed

rules will be made through the Federal rulemaking process.

It is strongly encouraged that training programs

include input from the disability community and

representative agencies.

4.10. CONSUMER

INFORMATIONAL INQUIRIES

4.10.1. Point of Contact. 

A manufacturer shall establish and maintain a

point of contact to assist customers regarding access

features. Wherever possible, the point of contact

should include a voice telephone number, TTY

number, e-mail address, fax number, and postal

address for consumer inquiries regarding th e

accessibility of their products. Manufacturers sha ll

publish this contact information in product literature.

4.10.2. Response Time. 

Manufacturers should advise all individuals who

make informational inquiries with the p oint of

contact that they can exp ect a response to their

inquiry within fourteen (14) calendar d ays.

4.10.3. Information Provided. 

A manufacture r’s response to an inquiry sho uld

be made promptly, and should include information

on accessibility features, compatibility standards that

are supported by the product, and commonly used

compa tibility options available through ad aptive

devices, as needed to guide the individual to the best

access provisions available. Should the individual

require further assistance, the manufacturer should

give the individual information on how to contact the

Access Board for further help.

4.11. DISABILITY ACCESS

STATEMENT

Manufacturers shall promptly provide to

consumers, upon reque st, a disability access

statement explaining the accessibility and

compatibility features of a product. This statement

shall be provided in alternate formats as needed.

Such a statement should include:

1. A list of the product’s accessibility or

compatibility features;

2. Compatibility standards supported by the

product;

3. Information about other accessible or

compatible products from that manufacturer; and

4. Identification of contact person(s) who will

address customer inquiries concerning accessibility

and compatibility (as in 4.10.1.).

4.12. SPECIALIZED CPE (SCPE)

Manufacturers of SCPE and manufacturers of

telecommunications equipment and CPE should

coordin ate (for instance, through voluntary standards

setting) to ensure compatibility between SCPE and

telecommunications equipment and CPE.

Rationale: Compatibility should be readily

achievable more frequently if SCPE, CPE, and

telecommunications equipme nt manufacturers

collabora te to minimize overall effort and expense.

SCPE, CPE and telecommunications equipment

manufacturers could develop voluntary interface

standards that would help to reduce the number of

different interfaces and the conflicting interface

technologies which otherwise would proliferate.
19

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed rules will

be made through the Federal rulemaking process.

5.0 

PERFORMANCE

GUIDELINES

5.1. INTRODUCTION

These guidelines provide objectives for product

performance which will assist manufacturers in

designing, develop ing and fabr icating

t e l e co m m unic ations and customer prem ises

equipment to be more accessible to and usable by

individuals with disabilities. In addition, these

performance guidelines should encourage the use

and further development of design practices intended

to make pro ducts more usable by people with a wide

range of disabilities.

Appen dix C provides examples of strategies for

addressing these guidelines.

5.2. LEVEL 1 -- GENERAL

PERFORMANCE GUIDELINES

Level 1 guidelines are intended to help define

the overall goals that a company should try to

achieve in the design of its products. They give no

guidance as to how to achieve the goals but help to

define what is meant by “access to the widest range

of people.” 

5.2.1. Accessible To and Usable By Ind ividuals

with Disabilities, Where Readily Achievable.

General Guideline A: Where readily achievable,

produc ts shall be designed, developed and fabricated

to be accessible to and usable by individuals with

disabilities. This includes people with visual

disabilities (e.g., low vision and blindness), hearing

disabilities (e.g., hard of he aring, deafness), people

with physical disabilities (e.g., limited strength, reach

or manipulation, tremor, speech impa irments, lack of

sensation), people w ith language o r cognitive

disabilities (e.g., reading disabilities, thinking,

remembering, sequencing disabilities), and other

disabilities (e.g., epilepsy, sho rt stature), and

individuals with any combination of these disabling

conditions (e.g., deaf-blindness). Older individuals

in particular common ly have multiple functional

limitations.
20

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed

rules will be made through the Federal rulemaking process.

(Note: The list above is illustrative of the range

of disabling conditions of approximately 10-20% of

the U.S. population, but is not an exhaustive list of

every type and combination of disability. Also, there

are many people who do not have disabilities who

also fit the above descriptions and would b enefit --

for example, someone who cannot read, someone

who has broken his/her arm, people who must work

with gloves on, etc.)

Since there is no single interface design that

accommo dates all disabilities, accessibility is likely

to be accomplished through product designs which

emphasize interface flexibility to maximize user

configurab ility and multip le, alternative and

redundant modalities o f input and output.

5.2.2. Compatible with Existing Peripheral

Devices or SCPE Used by Individuals with

Disabilities, Where Readily Achievable.

General Guideline B: Wh enever it is not re adily

achievab le to make a product accessible to and

usable by individuals with disabilities, the product

shall be compatib le with existing peripheral devices

or specialized customer premises equipment

commo nly used by individuals with disab ilities to

achieve access, if readily achievable.

5.3. LEVEL 2 GUIDELINES

Section 255 requires that manufacturers ensure

the usability as well as the accessibility and/or

compa tibility of products, if readily achievable. It is

understood that there will be cases where

manufacturers may not be able to achieve the

creation of a single produ c t that addresses

accessibility for all or some combinations of

disabilities without sacrificing product usability.

Therefore, there will be cases where a compa ny will

have to use discretion in choosing among

accessibility features. In this situation,

manufacturers should consider incorporating in

another comparable product, the access feature or

features not addressed. A manufacturer may not

ignore consideration of the needs of any covered

group of individ uals with disabilities when

determining what accessibility features the product

should address.

5.3.1. Input, Control and M echanicals.

5.3.1.1 (I-1). Locate, Identify, and

Operate Controls without Vision.

Guideline: Where readily achievable, product

input, control and mechanic al functions shall b e fully

operable via at least one mode whose components

are locatable, identifiable, and ac curately ope rable

without requiring the user to see.

Rationale: Individuals with severe visual

disabilities or blindness cannot locate or ide ntify

controls, latches, input slits etc. by sight or ope rate

controls that require sight.

5.3.1.2 (I-2). Operate with Low Vision

without Requiring Audio.

Guideline: Where readily achievable, the

product input, control and mechanic al functions shall

be fully operable via at least one mode by

individuals who have low visio n but are not legally

blind, which d oes not rely on audio output.

Note: 20/70 after correction is the beginning of

low vision; 20/200 after correction is the beginning

of legal blindness; a field of vision of less than 20

degrees after correction also constitute s legal

blindness.

Rationale: Individuals with severe visual

disabilities often also have severe hearing disabilities

(especially older users) and cannot rely on audio

access modes commonly used by those who are

blind.

5.3.1.3 (I-3). Operate without Color

Perception or with Color Perception

Limitations.

Guideline: Where readily achievable, product

input, control, mechanical and display functions shall

be fully operable via at least one mode that does not

require color perception.

Rationale: Many pe ople have an inab ility to see

or distinguish between certain color combinations.

Others are unable to see color at all.
21

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed rules will

be made through the Federal rulemaking process.

5.3.1.4 (I-4). Locate, Identify, and

Operate Controls without Hearing.

Guideline: Where readily achievable, product

input, control and mechanic al functions shall b e fully

operable via at least one mode w hose com ponents

are locatable, identifiable, and accurately operable

without requiring the user to hear.

Rationale: Individuals who are hard of hearing

or deaf cannot locate or identify those controls that

require hearing.

5.3.1.5 (I-5). Low Manipulation

Requirement.

Guideline: Where readily achievable, product

input, control and mechanic al functions shall b e fully

operable via at least one mode that does not require

fine motor control or simultaneo us actions.

Rationale: Individuals with tremor, cerebral

palsy, paralyses, arthritis, artificial hands, and other

conditions may have difficulty operating systems

which require fine motor control, assume a steady

hand, or require two hands or fingers for operation.

5.3.1.6 (I-6). Operate with Limited

Reach and Strength.

Guideline: Where readily achievable, product

input, control and mechanic al functions shall b e fully

operable via at least one mode that is operable with

limited reach or strength.

Rationale: Individuals with spinal cord injuries,

ALS, arthritis, MS, MD and other conditions may

have difficulty operating systems which require

reach or strength.

5.3.1.7 (I-7). Non-Time-Dependent

Controls.

Guideline: Where readily achievable, product

input, control and mechanic al functions shall b e fully

operab le via at least one mode that does not require

a response within a period of time, or whe re the

response time is adjustable over a wide range.

Rationale: Individuals with physical, sensory

and cognitive disa bilities may not b e able to find,

read and operate a control quickly.

5.3.1.8 (I-8). Identify and Operate

Controls without Speech.

Guideline: Where readily achievable, product

input and control functions shall be fully operable

via at least one mode that does not require speech.

Rationale: Many individuals cannot speak or

speak clearly either due to physical disability or

deafness. Produc ts which requ ire speech in order to

fully operate them, and which do not provide an

alternate way to achieve the same function are not

usable by these people.

5.3.1.9 (I-9). Language and Cognitive

Requirements.

Guideline: Where readily achievable, product

input, control and mechanic al functions shall b e fully

operable via at least one mode that minimizes the

cognitive, memory and learning skills required of the

user to ope rate the product.

Rationale: Many individuals have reduced

cognitive abilities either from birth, accident/illness,

or aging. These incl ude reduced memory,

sequencing, reading, and interpretive skills.

5.3.2. Output, Displays and Fee dback.

5.3.2.1 (O-1). Visual Information

Available in Auditory Form.

Guid eline: Where readily achievable, all

information (text, static or dynamic images and

labels) which is provided visually shall also be

available in auditory form.

Rationale: Some individuals have difficulty

seeing or reading, or cannot see or read.

5.3.2.2 (O-2). Make Visual Information

Accessible to People with Low Vision without

Requiring Audio.
22

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed

rules will be made through the Federal rulemaking process.

Guideline: Where readily achievable, all

information which is provided through a visual

display including text and dynamic images, labels or

incidental operating cues, shall be perceivable via at

least one mode by individuals who have low vision

but a r e not blind, w i t ho u t r e q u ir i n g a u d io

presentation.

Rationale: Individuals with severe visual

disabilities often also have severe hearing disabilities

(especially older users) and cannot rely on audio

access modes used by those who are blind.

5.3.2.3 (O-3). Access to Mov ing Text.

Guideline: Where readily achievable, text

which is presented in a moving fa shion shall also be

available via at least one static presentation mode at

the option of the user.

Rationale: Moving text can be an access

problem because individuals with low vision,

physical or sensorimotor disabilities find it difficult

or impossible to track mo ving text with their eyes.

5.3.2.4 (O-4). Visual an d/or Tactile

Availability of Auditory Information.

Guideline: Where readily achievable, all

information which is prov ided aud itorially, including

those incidental operating sounds and speech, which

are important for use of the product, shall be

available via at least one mode in appropriate visual

form and/or where appropriate in tactile form.

Rationale: Individuals who have difficulty

hearing or who are unable to hear the product are

unable to hear auditory output or to hear mechanical

and other sounds that are emitted by a device which

may be needed for its safe or effective operation.

5.3.2.5 (O-5). Make Auditory

Information Accessible to People who are Hard

of Hearing without Requiring Vision.

Guideline: Where readily achievable, all

information which is provided auditorially, including

incidental operating sounds, which is important for

use of the prod uct, shall be available via at least one

mode in enhanced auditory fashion (for example,

increased amplification, or reduction of background

noise).

Rationale: Individuals who have difficulty

hearing but are not deaf find it much easier to use

their hearing than to have to rely on access strategies

used by people who are deaf.

CLOSELY RELATED GUIDELINES: See C-2

and C-3 d ealing with hearing aid compatibility. 

5.3.2.6 (O-6). Prevention of VisuallyInduced Seizu res.

Guideline: Where readily achievable, visual

displays shall be designed so as to avoid high

probability of triggering a seizure in an individual

with photo-sensitive epilepsy.

Rationale: Individuals with photo-sensitive

epilepsy can have a se izure triggered by displays

which flicker or flash, particularly if the flash has a

high intensity and is within certain frequency ranges.

5.3.2.7 (O-7). Prevention of SoundInduced Seizu res.

Guideline: Where readily achievable, sound

displays shall be designed so as to avoid audio

behaviors that create a high probability of a seizure

in an individua l with sound-induced epilepsy.

Rationale: Individuals with sound-induced

epilepsy can have a seizure triggered by acoustic

output.

5.3.2.8 (O-8). Audio Cutoff.

Guideline: Where readily achiev able, prod ucts

which use audio output access modes, shall have a

headphone jack or personal listening device (e.g.,

phone-like handset or earcup) which cuts off the

speaker when used.

Rationale: Individuals using the audio access

mode, as well as those using a device with the

volume turned up, need a way to limit the range of

audio bro adcast.

5.3.3. Documentation.
23

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed rules will

be made through the Federal rulemaking process.

5.3.3.1 (D-1). Ability to Access Product

Documentation and Related On-Line

Information.

Guideline: Documentation (printed, on-line or

tutorial, including promotional materials) shall be

accessible to and usable by individuals with all

disabilities or alternate formats shall be available.

Rationale: People who have d isabilities often

are unable to use standard printed documentation if

they cannot see, documentation that is presented on

screen in small fonts if they have poor vision,

documentation that presents important information

auditorially if they are deaf, etc.

5.3.4. Compatibility Guidelines.

5.3.4.1 (C-1). External Electronic Access

to All Information and Control M echanisms.

Guideline: Where readily achievable,

1. All information needed for the operation of

a product (including output, alerts, labels, on-line

help, and documentation) shall be available in a

standard electronic text format on a cross-industry

standard p ort;

2. All input to and control of a product shall

allow for real time operation via electronic text input

into a cross-industry standard external port and in

cross-industry standard format; and 

3. The port used for 1 and 2 shall not require

manipulation of a connector by the user.

Rationale: Some individuals with severe or

multiple disabilities are unable to use the built-in

displays and control mechanisms on a product.

5.3.4.2 (C-2). Connection Point for

External Audio Processing Devices.

Guideline: Where readily achiev able, prod ucts

providing auditory output shall provide the auditory

signal via an industry standard connector and signal

level.

Rationale: Individuals using amplifiers, audio

couplers, and other audio processing devices need a

place to tap into the audio generated by the product

in a standard way.

5.3.4.3 (C-3). Hearing Aid Coupling.

Guideline: Where readily achiev able, prod ucts

providing auditory output via an audio transducer

which is normally held up to the ear shall provide a

means for effective wireless coupling to hearing aids.

Rationale: Individuals who are hard of hearing

use hearing aids with a T-coil feature to allow them

to listen to audio output of pr oducts without picking

up background noise and to avoid problem s with

feedback, signal attenuation or degradation.

5.3.4.4 (C-4). Non-Interference with

Hearing Technolog ies.

Guideline: Where readily achiev able, prod ucts

shall not cause interference with hearing

technologies (including hearing aids, cochlear

implants, and assistive listening devices) which are

used by a product user or bystanders.

Rationale: Individuals who are hard of hearing

use hearing aids and other assistive listening devices,

but they cannot be used if other products introduce

noise into the hearing technologies because of stray

electromagnetic interference.

5.3.4.5 (C-5). Prosthetic Compatibility of

Controls.

Guid eline: Where readily achievable,

touchscreen and touch-operated controls shall be

able to be activated without requiring body contact

or close body proximity.

Rationale: Individuals who have artificial hands

or use headstick s or mouths ticks to oper ate produ cts

have difficulty with capacitive or heat-op erated

controls which require contact with a person’s body

rather than a tool.

5.3.4.6 (C-6). Text Telephone

Connectability.
24

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed

rules will be made through the Federal rulemaking process.

Guideline: Where readily achiev able, prod ucts

which prov ide a function allowing voice

communication and which do not themselves provide

a TTY functionality shall provide a standard nonacoustic connection point for TTY s. It shall also be

possible for the user to easily turn any acous tic

pickup on the product on and off to allow the user

who can talk to intermix speech (live microphone)

with text telephone use.

Rationale: Individuals who use text telephones

(TTY s) to communicate using text-over-telephones

must have some non-acoustic way to connect TTYs

to t e le p h on e s t o ge t cl e ar T TY connections.

Acoustic coupling is subject to interference from

ambient noise, as many handsets do not provide an

adequa te seal with TTY s. Therefore, alternate (nonacoustic) connections are needed. Control of the

microphone is needed for situations such as payphone usage, where ambient noise picked up by the

mouthpiece often garbles the signal (user ne eds to be

able to mute the handset microphone). Some users

of TTYs cannot hear and use the TTY to receive

communication but can talk and use speech for

outgoing communication. The microphone on/off

switch on the telephone should therefore be easy to

flip back and forth or have a push-to-talk mode

available.

5.3.4.7 (C-7). Text Telephone Signal

Compatibility.

Guideline: Where readily achiev able, prod ucts

providing voice com munication functionality shall

be able to supp ort use of all cross-manufacturer nonproprietary standard signals used by

telecommunication devices designed for use by or

with people who are deaf, hard of hearing or have

speech impairments.

Rationale: Some telecomm unication systems,

which have been developed and released, co mpress

the audio signal in such a manner that standard

signals used by TTYs are distorted or attenuated,

preventing successful TTY communication over the

systems.
25

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed rules will

be made through the Federal rulemaking process.

6.0 

COMPLIANCE

AND

COORDINATION

6.1. COMPLIANCE AND

COORDINATION OVERVIEW

 The committee was unable to reach consensus on

this introductory section due to time constra ints.

Some committee membe rs believed this section

should be characterized as the following:

This section describes the compliance and

coordination partnership which is recommended by

the committee for guiding the access requirements of

section 255. Some components of the structure are

not in existence at this time. Others are only now

being initiated. For this reason this sec tion is as

much a roadmap to the future as it is a system for

judging compliance.

The compliance system presented in this

document, and more specifically in this section

requires and relies upon a coordinated partne rship

between industry and individuals with disabilities.

Specifically it requires a system which facilitates

effective partnering throughout all stages of the

process, including development of guidelines,

standards, product design and development,

verification of accessibility, complaint investigation,

and market monitoring. In order to succeed, this

system requires the good faith support of these

parties. In keeping with this understanding, this

section is written with an assumption of

reasonableness and balance from all parties. Any

interpretations that may be made which are clearly

unbalanced and consiste ntly prejudicia l to any

interest are not intended.

The section describes three mechanisms for

controlling and assessing compliance. At the first

and highest level are the guidelines developed by the

Access Board. These provide the overall direction

for this effort. Supporting the guidelines are access

related consensus standards developed by standards

setting bodies. Where they are appropriate and

available, these documents provide specific technical

guidance for important parts of the compliance

assessment. Standards often serve to document

standard t e s t m e th o d o logies, compatibility

requireme nts and at times to provide technical

guidance to established practice. The third level,
26

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed

rules will be made through the Federal rulemaking process.

found in section 6.4, is expert opinion, fostered by an

ongoing dialogue between consumer and industry

representative.

Rationale: This section proposes that the

optimum structure for the d evelopment of

telecommunications access is a mix of public and

private sector initiatives. A variety of such models

exist t o d ay t hr o u gh o u t t h e g o v er n m en t . O ne

example is the FCC’s handling of the issue of TV

interference. In the early 1980s, the FCC was given

regulatory authority in this area. Ho wever, it

implemented that authority by working with a private

sector standard setting body to write the required

technical standards. In parallel with this effort,

dialogue with the affected manufacture rs resulted in

voluntary inclusion of the required suppression

circuitry in most TV se ts. The FCC continues to

actively monitor the issue to assure tha t the public

interest is being served. In that not all of the

compo nents described in this section are curre ntly

sufficiently develop ed, it is implied, and at times

stated, that the Access Board and FCC will work

with the appropriate parties to develop these

componen ts. The agencies should monitor the

development of these components, and to the extent

that some components do not develop as envisioned,

the Access B oard should exped itiously review the

compliance and coordination model, and may change

it sooner than the recommended five-year review.

However, the committee believes that the

structure envisioned is quite realistic. Indeed it is

heartening to note that since the inception of the

TAAC, the National Association of Radio and

Teleco mmunications Engineers (NARTE) has

initiated an Association of Access Engineers and

Specialists. It is hoped that this new organization,

working in close cooperation with other interested

organizations, such as RE SNA (R ehabilitation

Engineering and Assistive Technology Society of

North America), TIA (Telecommunications Industry

Association), IEEE ( Institute of Elec trical and

Electronics Engineers), EIF (Electronic Industries

Foundation), RERC (Rehabilitation Engineering

Research Centers), and others will provide many of

the services called for in section 6.4.

Other committee members believed this section

should be characterized as the following:

This section describes the committee’s

recommendation for a framework for coordination

among manufacturers and consumers to identify

access needs and solutions to those needs, ensuring

compliance with the requirements of section 255,

and encouraging the pro mpt, informal resolution

of complaints about the accessibility of

telecommunications and customer prem ises

equipment. The principal elements comprising this

framework are:

1. these guidelines;

2. the anticipated development, when and

where appropriate, of consensus standards for

telecommunications accessibility by standards setting

bodies;

3. a coordina tion point to fa cilitate the

exchange of information about access needs and

solution among manufacturers and consumers;

4. manufacturers’ verification of the readily

achievable accessibility and usability of their

equipment and supplying a declaration of conformity

o f adhe rence to the Access Board and F C C

guidelines for determining whether accessibility,

usability, or compatib ility is readily achievable; and

5. alternate approaches to inquiries and

complaints that encourage manufacturers to provide

consumers information about the accessib ility

features of their products and consumers to express

informally their concerns about a product’s

accessibility prior to complaining to the FCC.

Rationale: The framework described in this

section relies heavily on private sector initiatives and

cooperation among manufacturers and individuals

with disabilities and organizations advocating fo r

their interests to foster the development of those

elements of the framework that are in the early stages

of development. For example, the National

Association of Radio and Telecommunications

Engineers (NARTE) has initiated an Association of

Access Engineers and Specialists. This new

organization, and others that may be established, in

cooperation with other existing organizations like the

Rehabilitation Engineering and Assistive Technology

Society of North America (RESNA), the Institute of

Electrical and Electronics Engineers (IEE E), the

Teleco mmunica tions Industry Association (TIA), the

Electronic Industries Fo undation (EIF), and the

Rehabilitation Engineering Research Centers

(RERC), could pro vide many o f the contact point
27

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed rules will

be made through the Federal rulemaking process.

functions described in section 6.4. It is expected that

the FCC an d Access Board will encourage the

development of the cooperative elements of this

framework and monitor and evaluate the progress of

their development and take further action if

approp riate. 

6.2. ACCESS BOARD GUIDELINES

6.2.1. Reauthorization of Guidelines.

The Access Board shall review and reauthorize

these guidelines at a maximum interval of five years,

incorporating input from repre sentatives of ind ustry,

individuals with a wide range of disabilities and

organizations which represent the needs of

individuals with disabilities, academic and research

specialists in the area of access engineering, the

FCC, and input from the annual market monitoring

report. 

6.3. CONSENSUS STANDARDS

6.3.1. Development of Standards.

Where standards are appro priate, the Access

Board and FCC should work in conjunction with

standards setting bodies, including consor tia, to

encourage t h e d e ve l o p m ent of and where

approp riate, officially recognize consensus standards

developed for telecommunications a ccessibility.

This process sh all incorpo rate input from individuals

with a wide range of disabilities and organizations

which represent the needs of ind ividuals wit h

disabilities. Examples of areas in which standards

would be useful are: to provide objective evaluation

and test methods, provide for standardized use r

interfaces, provide fo r compa tibility between CPE

and SCPE and others. The utmost care should be

exercised to assure that these standards do not hinder

innovation and technological development, but rather

work in concert with innovation.

6.3.2. Refreshmen t of Standards.

In order to receive official recognition of a

consensus standard, developed for

telecommunications accessibility, the standard

setting body sponsoring the standard should review

and refresh it every five years or mo re frequently, if

needed.

6.3.3. Coordina tion of Standards.

Industry should coordinate the development of

accessibility standards with officially recognized

standard setting bodies such as the American

National Standards Institute (ANSI) wherever

appropriate.

6.3.4. International Harmonization.

Industry should promote harmonization of

accessibility standards with international bodies such

as the International Standards Organization (ISO) or

the International Electrotechnical Commission (IEC)

wherever appropriate. 

6.4. COORDINATION POINT

6.4.1. Establishment of Coordination Po int.

The model d escribed in section 6 relie s heavily

on the presence of an organization or organizations

to provide effective and efficient communic ations

and feed b a c k f or t h e im p l ementation of

telecommunications access. Such a “coordination

point” might be a sub-society of an existing

engineering society, governed by its own board

comprised of industry representatives, individuals

with disabilities, representatives of organizations

which represent the needs of individuals with

disabilities, and academic and research sp ecialists in

the area of access. If a coordination point or points

is established, the FCC and Access Board are

encouraged to support and assist, as appropriate, the

development of such organizations to serve the

purposes listed in this section. If such organizations

do not develop as required in this model, the Acce ss

Board and FCC shall as expeditiously as possible

review the model and change it if appropriate.

Rationale: The industry members of the TAAC

have argued that many aspects of the effort to

provide telecommunications access will be most
28

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed

rules will be made through the Federal rulemaking process.

effectively and efficiently pro vided through private

sector initiative. This section assumes that the

monetary savings and the administrative simplicity of

a Declaratio n of Confo rmity system will provid e

sufficient motivation for the creation and support of

the initiative describ ed in this section. The

committee observes w ith great interest the

development of an accessible design society

sponsored by NARTE. The committee encourages

the Access Board and FCC to monitor the

development of this, or other similar efforts, and to

the degree they approp riately fulfill the functions

described in this section, utilize these initiatives.

Should initiatives such as these fail, other kinds of

solutions will be required.

6.4.2. Participation of Individuals with

Disabilities.

The coordination point should facilitate

participation of individua ls and orga nizations

representing the needs of individuals with disabilities

b y e n s u r i n g a c c e ss i b i l i ty o f e v e n t s a nd

accommodations such as communication access and

alternative formats for materials, and by supporting

attendance a n d participation in training by

individuals with disabilities through sponsorships.

6.4.3. Access Engineering Specialist Training.

The coordination point could facilitate the

development of appropriate curricula through entities

such as universities and trade associations, and

should ensure provision of training on access needs

and strategies to access specialists, in conjunction

with training provided to individuals with

disabilities.

6.4.4. Disability Representatives Training.

The coordination point sho uld facilitate the

development of appropriate curricula and should

provide on-going training o n fundamentals of

telecommunications and access to individuals with

disabilities and representatives of organizations

representing the needs of individuals with

disabilities, in conjunctio n with training pro vided to

access specialists. 

6.4.5. Access Specialist Certification.

The coordination point should support the

development of a certification process for access

specialists. Such a certification process should

contain provisions fo r annual updating of access

specialist training to ensure that practitioners are

current with the state-of-the-art.

6.4.6. Presentation of Access Needs and

Strategies.

The coordination point could host an annual

symposium with technical sessions to provide a

forum for presentation of papers and research results

on access engineering. This annual symposium

could also receive and review the annual marketing

monitoring report from the Access B oard to identify

key areas of need in access for the coming year.

6.4.7. Input into Guidelines.

The coordination point may, if requested,

provide industry and d isability input into period ic

refreshment of the Access B oard guidelines.

6.4.8. Input into Stan dards.

The coordination point could, if requested,

provide industry and disa bility input into the

development, refresh m e n t , c o o rd in a t i o n and

international harmonization of standards.

6.4.9. Industry/Disability Advisory Panel to

the FCC.
29

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed rules will

be made through the Federal rulemaking process.

The coordination point could, if requested,

convene and maintain an advisory panel comprised

of industry representatives, individuals with

disabilities and representatives of organizations

representing the needs of individuals with

disabilities, to provide opinion, at the FCC’s re quest,

on inquiries and complaints which have been

submitted to the FCC.

6.4.10. Research.

The coordination point could identify areas of

access needs where research and develop ment are in

demand and sponsor research in those areas.

6.4.11. Recognition for Access Innovation.

The coordination point could establish an

awards program for access innovations to stimulate

industry efforts in this area. 

6.5. ACCESS VERIFICATION

6.5.1. Verification of Accessibility, Usability,

and Compatibility.

Manufacturers shall verify readily ac hievable

accessibility and usability of products, and

compatibility of products with existing peripherals

and specialized CPE where access and usab ility is

not readily achievable, through:

1. Utilization of the expert opinion of

qualified access specialists, when other methods are

not available for a given application; or

2. Whenever possible, using standard tests

where available and recomm ended testing

approaches where standard tests are unavailable. It

is strongly recommended that such testing be

supervised by a qualified access specialist; or 

3. Use of standardized methods and

techniques, where such methods have been validated

for the intended application; or 

4. Utilization of certified access testing

laboratories where available.

The terms standard and stand ardized in items 2

and 3, above, refer to tests, methods and techniques

which are documented in consensus standards,

developed by recognized standards settings bodies

and recognized as being appropriate by the Access

Board and FCC, as provided for in section 6.3.1.

6.5.2. Use of Qua lified Access Specialists.

When utilizing the verification methods of

expert opinion or standard tests, manufacturers

should use qualified access specialists to supervise

the verification and, as approp riate, in implementing

process and performance plans throughout product

design and development.

6.5.3. Documentation.

Note: Consensus was not reached on the use of

shall or should on this item. [Should/shall] is

therefore used in the following paragraph.

Manufacturers [should/shall] document

accessibility design decisions, whether or no t access

solutions are found to be rea dily achievab le.

Documentation sufficient to show compliance with

the accessibility requirements of section 255

[should/shall] be retained.

6.5.4. Certification of Access Testing

Laboratories.

The Access Board, in cooperation with

recognized laboratory accrediting agencies, should

promote the development of a certification process

for access testing laboratories. 

6.6. DECLARATION OF

CONFORMITY

6.6.1. Issuing Declaration of Conformity.

For all telecommunications equipment and

customer premises equipment, the manufacturer shall

supply with the product, at the time of marketing or
30

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed

rules will be made through the Federal rulemaking process.

importation, a declaratio n of conform ity (DOC ) with

section 255.

Rationale: The declaration rep resents a

manufacturer’s self-evaluation of adherence to

Access Board and/or FCC evolving guidelines in

determining whether accessibility and usability of a

product by individuals with d isabilities is readily

achievable, or to the exten t that accessibility and

usability is not readily achievable, compatibility of

the product with existing peripheral devices or

specialized customer prem ises equipm ent comm only

used by individuals with disab ilities is readily

achievable for the given p roduct.

The DOC is relatively brief (see 6.6.3, 6.6.4),

and because it provides no information about the

accessibility or compatibility features of the

particular product, it cannot replace the provision of

useful consumer information, as covered in sections

4.4, 4.6, 4.10, and other places in this report.

If standards concerning appropriate methods of

evaluation and verification of accessibility are

developed by standards setting bodies as described

in section 6.3, whether or not formally adopted by

the Access Board or the FCC, it is expected that

these methods will be used by manufacturers in

e v a l u a t i n g a n d v e r i f y in g a c c e s s i b i li t y a nd

compatibility.

6.6.2. Location of Declaration of Conformity.

The DOC shall be included as a separate sheet

or other medium in the produ ct box, or located

within a user’s manual in such a way that the user

may quickly find the declaration itself, or an

accessible visual, auditory, or tactile p rompt to its

location.

Rationale: The DOC, which includes contact

information, must be easily locatable b y individuals

who customarily use alternate formats, in order that

they may contact the manufacturer’s point of contact

to request alte rnate formats of the product literature

including the user manual. Some manufacturers may

choose to provide with the product a declaration

alternatively formatted for the individuals with

particular disabilities for whom the product is

designed, developed, and fab ricated. 

6.6.3. Contents of Declaration of Conformity.

The declaration of conform ity shall include the

following: 

1. A brief statement of the purpose of section

255 (see 6.6.4);

2. Identification of the product, e.g., name and

model number;

3. A statement of product conformity (see

6.6.5);

4. Information on how to contact the

manufacturer’s responsible party (see 4.10.1).

6.6.4. Text of Declaration of Conformity.

Section 255 requires manufacturers to design,

develop, and fabricate telecommunications products

to be accessible to and usab le by individua ls with

disabilities if readily achiev able. When accessibility

and usability is not readily achievable, such prod ucts

must be comp atible with perip heral devices

commonly used by individuals with disabilities, if

that is readily achievable. The TAAC urges the FCC

to adopt a consistent content and format for a

declaration of conform ity to reduce confusion by

both consumers and manufacturers as to the spec ific

requireme nt.

Some committee members believed that the

declaration of conform ity should contain the

following language: 

This product complies with section 255 of the

Communications Act. This means that the

manufacturer [or enter name of manufactu rer]

considered access and use by individuals with

disabilities during product design, development, and

fabrication. The manufacturer [or insert name of

manufacturer] incorporated accessibility or

compa tibility to the extent that it was readily

achievable to do so. The resulting product may not

be complete ly accessible to each and every type and

degree of disability, or compatible with any

particular specialized customer premises equipment

or peripheral devices commonly used by individuals

with disabilities.

For further information about the accessibility or

compatibility features of this product, product
31

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed rules will

be made through the Federal rulemaking process.

documentation in alternate formats, or other

questions about accessibility matters, please contact

our Accessibility Coordinator. [Provide contact

address information, see section 4.10.1]

Rationale: This text conveys the disab ility

access requireme nts and read ily achievab le limitation

contained in section 255 and clarifies that

compliance with section 255 does no t necessarily

mean that access or compatibility is readily

achievable for all or any specific disability or

specialized equipment used by individuals with

disabilities. This formulation avoids troubling

language in the propo sal below wh ich would like ly

lead consumers to believe tha t disability access is not

necessarily required by section 255.

Other committee members believed the

statement should contain the following:

This product complies with section 255 of the

Communications Act. This means that the

manufacturer [or enter name of manufacturer]

considered access and use by individ uals with

disabilities during product design, development, and

fabrication and incorporated accessibility or

compa tibility features to the ex tent that it was read ily

achievable to do so. It does not mean that the

product necessarily is, or is required to be, acce ssible

to or usable by an individual with any particular type

or degree of disability or co mpatible w ith any

specific peripheral device.

For further information about the accessibility or

compatibility features of this product, product

documentation in alternate formats, or other

questions about accessibility matters, please contact

our Accessibility Coordinator. [Provide contact

address information, see section 4.10.1]

Rationale: Without the qualifications reflected

in the third sentence, purchaser s of its produc ts could

be misled by the statement about the extent to which

the product incorporates accessibility features or

about the extent of the manufacturer’s obligation to

do so. This language has the virtue of bluntness.

The more blunt the statement, the less likely

consumers will be misled by the statement and the

less likely manufacturers and consumer advocates

will be blamed for misunderstandings.

6.7. INQUIRIES AND COMPLAINTS

6.7.1. Manufac turer’s Point of Contact.

As required in se ction 4.10 , manufacture rs shall

establish and maintain a point of contact to assist

customers regarding access features. The equipment

manufacturer should be the initial and, it is hoped,

primary resolver of consumer inquiries and

complaints. When a manufactu rer canno t adequate ly

meet a consumer’s needs they are required in section

4.10.3 to deliver the material described in 6.7.2 to

the consumer.

6.7.2. Consumer Information.

The Access Board shall develop material which

gives consumer in formation re garding

telecommunic ations access. This material is

intended to provide a bridge for a consumer to the

best telecommunications access information

available. This material should provide points of

contact for help with the needs of specific

disabilities. It should also assist the consumer by

providing information sources on available adaptive

devices. Equipment manufacturers who are unable

to fully meet a con sumer’s needs are required to give

them the information in section 4.10.3.

6.7.3. FCC Point of C ontact.

The FCC should maintain a point of contact for

individuals with disabilities, and manufacturers for

receipt of inquiries and com plaints regard ing

accessibility of telecommunications equipment and

CPE, and publish this FCC point of contact in the

Federal Register.

6.7.4. FCC R eview of C omplaints.

6.7.4.1 Informal Resolution.

FCC policies with respect to complaints about

the accessibility of telecommunications or customer

premises equipment should:

(a) encourage consumers to express informally

their concerns or grievances about a product to the
32

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed

rules will be made through the Federal rulemaking process.

manufacturer or supplier who bro ught the pro duct to

market before complaining to the FCC; and

(b) encourag e manufacturers to resp ond within

30 days to consumer concerns or grievances about

the accessibility of their products with information or

actions sufficient to resolve the concerns.

6.7.4.2 Referral of Inqu iries. 

If the manufacturer has issued a declaration of

conformity, individuals with disabilities are

encouraged to make inquiries to the manufacturer

regarding product features relating to accessibility

and compatibility, before bringing a co mplaint to the

FCC. When a complaint is made to the FCC, the

FCC should determine whether the complainant has

discussed concerns and grievances with the

manufacturer but was unable to satisfactorily resolve

the complaint. If the complainant has not conducted

any such discussions, the FCC sh ould encourage the

complainant to contact the manufacturer for this

purpose or the FCC sho uld take such action as it

deems appropriate to assist the comp lainant to

resolve the complaint informally.

6.7.4.3 Implemen tation. 

The Access Board and/or the FCC should allow

adequate time for manufacturers to reflect these

guidelines in their processes for designing,

developing, fabricating and delivering

telecommunications equipmen t a n d cu s t o m er

premises eq uipment.

6.7.4.4 Significance of Declaration of

Conformity.

While the committee reached consensus on the

use of a declaration of conform ity, it could not agree

on the weight such a declaration should be given by

the FCC in dealing with co mplaints. 

Some committee members believed that the

DOC should be given the following consideration:

A manufacturer responding to a complaint

should be presum ed to have complied with section

255 if the manufacturer:

(a) Demonstrates adherence to section 255

guidelines, including any recognized good practices

associated with design, development, and fabrication

that may be associated with such guidelines; and

(b) Supplies a declaration of conformity as

provided in section 6.6; or 

(c) Demonstrates that one or more of the

manufacturer’s other products or product options

provides a satisfactory substitute for the challenged

product, through reasonably comparable features,

prices and availability.

Where the FCC finds that a manufacturer has

not complied with section 255, punitive measures

should be avoided if the manufacturer has

documented good-faith effo rts to follow section 255

guidelines and any related good practices; instead,

the FCC may require the manufacturer to address the

lack of accessibility, usability, or compatibility.

Rationale: The only significant difference in the

two versions, is in section 6.7.4.4(c), which allows

the availability of an accessible or compatible

equipment alternative to create a presumption of

compliance. Since the effec t is only presumptive, the
33

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed rules will

be made through the Federal rulemaking process.

complainant may still prevail by offering evidence

sufficient to overcome the presumption.

Other committee membe rs felt the DO C should

be given the following consideration:

In determining whether a manufacturer has

complied with section 255 with res pect to a

particular product, the FCC shall give considerable

weight to the extent to which the manufacturer

undertook good fa ith efforts to comply with the

guidelines implementing section 255.

Where the FCC finds that a manufacturer’s

product does not co mply with section 255, punitive

measures should be avoided if the manufacturer has

documented good faith efforts to fully and

adequately follow section 255 guidelines, or, if one

or more of the manufacturer’s other products or

product options, having comparable features,

functions, price, and availability, provides a

satisfactory substitute for the accessibility and

usability, or comp atibility which may b e lacking in

the produc t which is the subject o f a compla int. The

FCC may require the manufa cturer to address the

lack of accessibility, usability, or compatibility in the

product which is the subject of a complaint if it finds

that it would have been readily achievable to have

designed, developed or fabricated the product to be

accessible and usable or compatible.

Rationale: In attempting to determine the

compliance of a telecomm unications product with

section 255, it is proper for the FCC to carefully

consider a manufacturer’s good faith efforts to

comply with the guidelines implem enting section

255. H owever, a “blanket” presumption o f

compliance cannot be accorded inasmuch as the FCC

may determine that the disability access efforts were

not sufficient, even though the efforts were carried

out in good faith. Furthermore, section 255 does not

provide the FCC with the authority to make a finding

of complianc e based o n substitute or comparable

products. The law is clear in its applicatio n to all

covered produc ts. Howeve r, it is reasonab le for the

FCC to mitigate penalties against a manufacturer

who can demonstrate compliance with the guidelines

implementing section 255 or who can show that an

equivalent product is available as a substitute for a

product which is inaccessible . The FC C is expected

to determine the extent to which accessibility and

usability or compatibility was readily achiev able for

the product and to require the manufacturer to take

steps to resolve the inaccessibility.

6.7.4.5 Review of M anufacturer’s

Documentatio n by FC C. 

In considering whether a manufacturer has

demonstrated adherence to the section 255

guidelines with respect to a particular product, the

FCC shall consider:

1. The extent to which the manufacturer

undertook good faith efforts to achiev e accessibility

and usability during the pro duct design,

developm ent, fabrication, an d delivery o f that

product, and

2. In the case where accessibility and usability

was not readily achievable, the extent to which the

manufacturer undertoo k good faith efforts to achieve

compatibility during the de sign develo pment,

fabrication and delivery o f that product.

For the purpose of making the above

consideration, the FCC may request from the

manufacturer documentation on:

1. The good faith efforts undertaken by the

company to achieve access or compatibility and

2. Alternatives considered during the design

process to achieve accessibility and co mpatibility.

6.7.5. FCC Discretionary Use of

Industry /Disability A dvisory Panel.

The FCC may at its discretion refer inquiries

and complaints to a joint industry/disa bility advisory

panel for opinion.

6.7.6. FCC Selection of Measures in Instances

of Non-Compliance.

In selection of measures, the FCC may consider

whether a manufacturer showed due diligence in

complying with mandatory specifications and

requirements of these guidelines, and followed

advisory specifications and recommendations from

these guidelines, or utilized alternative

implementation.
34

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed

rules will be made through the Federal rulemaking process.

6.7.7. Collection of Data.

The FCC should maintain a database of inquiries

and complaints received and the resulting findings or

complaint resolutions for annual compilation and

review. The FC C shall make this and other access

related information it has available to the Access

Board.

6.8. MARKET MONITORING

REPORT

6.8.1. Access Board Production of Annual

Report.

The Access Board shall survey the marketplace

annually to assess the state of the

telecommunications market relative to product

accessibility and to suggest means to improve

telecommunications access for people with

disabilities.

6.8.2. Contents of the Report.

The annual market monitoring report shall

include information o n the availability o f accessible

telecommunications products in the marketplace by

type and by ap plicable disa bility. The annual market

monitoring report shall include information from the

F C C o n n u m b er a n d t y p e s o f in q u i r i e s a nd

complaints, with their final resolution or findings,

across all covered market sectors. The Access

Board, working with the FCC, shall identify trends

which impact

telecommunications access for people with

disabilities. In addition, the Access Board should

identify research or product development work

needed to rectify an existing market deficiency or

patte rn of inaccessibility to preven t future

deficiencies.

Rationale: The annual market monitoring report

is intended to present a balanced, high level

viewpoint of the state of telec ommunic ations

accessibility. It should cite positive trends and

progress. It should also identify deficiencies, trends

or patterns of lack of access and areas need ing

further work. Its primary purpose is to guide the

application of resources to access issues. Hence, it

should applaud areas where resources are being

effectively applied and identify a reas needing

additional action, with suggestions as to the kinds of

action needed.

6.8.3. Availability of Report.

The Access Board shall announce the

availability of the annual market monitoring report to

the public in the Federal Register, and shall deliver

the report to the FCC, and to the members of the

coordination point (see 6.4). The Access Board shall

make the report available, in print or alternate

formats, to any interested party upon req uest.

6.8.4. Actions Triggered by R eport.

If the annual market monitoring report indicates

important product areas showing lack of progress or

if substantial pa tterns of non-compliance with section

255 are identified, the FCC and/or the Access Board

may call for associated industry coo perative efforts

or may initiate proceedings to develop more

stringent compliance measures for section 255. The

Access Board may also recognize and recommend

processes or innovative technic al solutions (best

practices) which may improve product design or

accessibility.
35

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed rules will

be made through the Federal rulemaking process.

7.0 

REFERENCES

NOT E: The Acce ss Board will be maintaining

updated reference material on telecommunication

access on its web site at http://www.accessboard.gov. The Trace Research and Development

Center, under sponsorship of the U.S. Department of

Educatio n’s National Institute on D isability and

Rehabilitation Research (NIDRR) will also be

maintaining a web site at

http://trace.wisc.e du/telecom that will contain

continually updated bibliographic information on

telecommunications access as well as an on-line

design tool and an on-line collection of examples of

accessible designs and techniques.
36

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed

rules will be made through the Federal rulemaking process.
37

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed rules will

be made through the Federal rulemaking process.

8.0 

APPENDICES
38

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed

rules will be made through the Federal rulemaking process.
39

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed rules will

be made through the Federal rulemaking process.

APPENDIX A

Acronyms

ADA -- Americans with Disabilities Act

ADAAG -- Americans with Disabilities Act

Accessibility Guidelines

ANSI -- American N ational Stand ards Institute

CPE -- Customer Premises Equipment

DOC -- Declaration of Conformity

EIA -- Electronic Industries Association

FCC -- Federal Communication Commission

HAC -- Hearing Aid Compatibility Act

HTT P -- Hyper Text Transport Protocol (part of an

internet web address)

IEEE -- Institute of Electrical and Electronic

Engineers

ISO -- International Organization for Standardization

IrDA -- Infra Red Data Association

ITU -- International Telecommunications Union

NARTE -- National Association of Radio and

Telecommunications Engineers

QWERTY -- The standard alpha-numeric keyboard.

Name is taken from the letters on the top row of

the keys.

RERC -- Rehabilitation Engineering Research

Centers

RESNA -- Rehabilitation Engineering and Assistive

Technology Society of North America

RF -- radio frequency

TAAC -- Telecommunications Access Advisory

Committee

TIA -- Telecommunications Industry Association

TRS -- Telephone Relay Service

TTY -- Text Te lephone

U.S.C.-- United States Code
40

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed

rules will be made through the Federal rulemaking process.
41

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed rules will

be made through the Federal rulemaking process.

APPENDIX B

Disability Related Provisions of the

Telecommunications Act of 1996.

Contents

I. Section 255: Acc ess by Perso ns with Disabilities

II. Section 251: Interconnection 

III. Section 305: Vid eo Prog ramming Accessibility

NOTE: Alth ough video programming

accessibility is not within the scope of this document

and is not covered or treated e lsewhere, it is included

in this Appendix for reference and because it is a

disability related pro vision in the

Telecommunications Act of 1996.

I. Section 255: Access by Persons with

Disabilities.

(a) DEF INITIONS-- As used in this section --

(1) DISABILITY -- The term ‘disability’ has

the meaning given to it by section 3(2)(A) of the

Americans with Disabilities Act of 1990 (42 U.S.C.

12102(2)(A)).

(2) READ ILY AC HIEV ABLE -- The term

‘readily achievable’ has the meaning given to it by

section 301(9) of that Act (42 U.S.C. 12181(9)).

(b) MANUFACTURING -- A manufacturer of

telecommunications equipment or custom er premises

equipment shall ensure that the equipment is

designed, develop ed, and fab ricated to b e accessible

to and usable by individuals with disabilities, if

readily achievable.

(c) TELECOMMUNICATIONS SER VICE S --

A provider of te lecommunications services shall

ensure that the service is accessible to and usable by

individuals with disabilities, if readily achievable.

(d) COM PAT IBILIT Y -- Whenever the

requireme nts of subsections (b) and (c) are not

readily achievable, such a manufacturer or provider

shall ensure that the equipment or service is

compatible with existing peripheral devices o r

specialized customer premises equipment commo nly

used by individuals with disabilities to achieve

access, if readily achievable.

(e) GUID ELINE S -- Within 18 months after the

date of enactment of the Telecommunications Act of

1996, the Architectural and Transportation Barriers

Compliance Board shall develop guidelines for

accessibility of telecommunications equipment and

customer premises equipment in conjunction with the

Commission. The Board shall review and update the

guidelines periodically.

(f) NO ADDITIONAL PRIVACY RIGHTS

AUTHORIZED -- Nothing in this section shall be

construed to authorize any privacy right of action to

enforce any requirement of this section or any

regulation thereunder. The Co mmission shall have

exclusive jurisdiction with respect to any complaint

under this section.

II. Section 251: Interconnection.

(a) GENERAL DUTY OF TELE COMM UNICATIONS CARRIERS -- Each telecommunications

carrier has the duty --

1. to interconnect directly or indirectly with the

facilities and equip ment of o ther telecommunications

carriers; and

2. not to install network features, functions, or

capabilities that do not comply with the guidelines

and standards established pursuant to section 255 or

256. 

III. Section 305: Video Programming

Accessibility.

Title VII is amended by inserting after section

712 (47 U.S.C. 612) the following new section:
42

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed

rules will be made through the Federal rulemaking process.

“SEC. 713. VIDEO PROGRAM MING

ACCESSIBILITY.

(a) Commission Inquiry.--Within 180 days after

the date of enactment of the Telecommunications

A c t o f 1 9 96, t h e F e d e r al C o m m u n i c a ti o ns

Commission shall complete an inquiry to ascertain

the level at which video programming is closed

captioned. Such inquiry shall examine the extent to

which existing or pre viously pub lished prog ramming

is closed captioned, the size of the video

programming provider or programming owner

providing closed captioning, the size of the market

served, the relative audience shares achieved, or any

other related factors. The Co mmission sha ll submit

to the Congress a report on the results of such

inquiry.

(b) Accoun tability Criteria.--Within 18 months

after such date of enactment, the Commission shall

prescribe such regulations as are necessary to

implement this section. Such regulations shall

ensure that--

(1) video programming first published or

exhibited after the effective date of such regulations

is fully accessible through the provision of closed

captions, except as provided in subsection (d); and

(2) video programming providers or owners

maximize the accessibility of video programming

first published or exhibited prior to the effective date

of such regulations through the provision of closed

captions, except as provided in subsection (d).

(c) Deadlines for Captioning.--Such regulations

shall include an approp riate schedule of deadlines for

the provision of closed captioning of v ideo

programming.

(d) Exemptions.--Notwithstanding subsection

(b)-

(1) the Commission may exempt by regulation

programs, classes of programs, or services for which

the Commission has determined that the provision of

closed capti oning would be economically

burdensome to the provider or owner of such

programming;

(2) a provider of video programming or the

owner of any program carried by the pro vider shall

not be obligate d to supply closed captions if such

action would be inconsiste nt with contracts in effect

on the date of enactment of the Telecommunications

Act of 1996, except that nothing in this section shall

be construed to relieve a vid eo programming

provider of its obligations to provide services

required by Federal law; and

(3) a provider of video programming or program

owner may petition the Commission for an

exemption from the req uirements of this section, and

the Commission may grant such petitio n upon a

showing that the requir ements contained in this

section would result in an undue burden.

(e) Undue Burden.--The term ‘undue burden’

means signif icant difficulty or expense. I n

determining whether the closed captions necessary to

comply with the requirements of this paragraph

would result in an undue economic burden, the

factors to be considered include--

(1) the nature and cost of the closed captions for

the programming;

(2) the impact on the operation of the provider

or program owner;

(3) the financial resources of the provider or

program owner; and

(4) the type of operations of the provider or

program owner.

(f) Video Descriptions Inqu iry.--Within 6

months after the date of enactm ent of th e

Telecommunications Act of 1996, the Commission

shall commence an inquiry to examine the use of

video descriptions on video program ming in ord er to

ensure the accessib ility of video programming to

persons with visual impairments, and repo rt to

Congress on its findings. The Commission’s report

shall assess appropriate methods and schedules for

phasing video descriptions into the marketplace,

technical and quality standards for video

descriptions, a definition of programming for which

video descriptions would apply, and other technical

and legal issues that the Commission deems

appropriate.

(g) Video Description.--For purposes of this

section, `video description’ means the insertion of

audio narrated descriptions of a television pro gram’s

key visual elements into natural pauses between the

program’s dialogue.
43

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed rules will

be made through the Federal rulemaking process.

(h) Private Rights of Actions Prohibited.--

Nothing in this section shall be construed to

authorize any private right of action to enforce any

requirement of this section or any regulation

thereunder. The Commission shall have exclusive

jurisdiction with respect to any comp laint under this

section.
44

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed

rules will be made through the Federal rulemaking process.
45

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed rules will

be made through the Federal rulemaking process.

APPENDIX C

Example Strategies for Addressing

Guidelines

This appendix provides example strategies and

notes to assist in understanding the guidelines and as

a source of ideas for alternate strategies for achieving

them. The strategies, and notes here are not

mandatory in nature. The manufacturer is not

required to incorpo rate all of these strategies or any

specific strategy. They are free to use these or other

strategies in addressing the guidelines. The listing

below is not comprehensive. Nor does following

these example strategies guarantee an accessible

product. For a comprehensive listing of all of the

published strategies to date, as well as for further

information and links to on-going discussions the

reader is referred to the Access B oard’s web page at:

http://www.access-board.gov and the National

Institute on Disab ility and Reh abilitation Re search’s

Rehabilitation Engineering Center on Access to

Telecommunications System’s strategies web page

which can be found at: http://trace.wisc.edu/telecom.

5.3.1. Input, Control and Mechanicals

I-1: Locate , Identify, and Operate Controls

without Vision

Guideline: Where readily achievable, product

input, control and mechanic al functions shall b e fully

operable via at least one m ode whose components

are locatable, identifiable, and accurately op erable

without requiring the user to see.

Rationale: Individuals with severe visual

disabilities or blindness cannot locate or identify

controls, latches, input slits etc. by sight or operate

controls that require sight.

Goal: All individuals, regardless of onset of

blindness, will be able to accurately and efficiently

operate products without assistance.

Problems: Individuals who cannot see must use

either touch or sound to locate and identify controls.

If a product uses a flat, smooth touch screen or touch

membrane, the user without vision will not be able to

even locate the controls without aud itory or tactile

cues. Once the controls have been located, the user

must then be able to tell what the functions of the

controls are. Finally, they must be able to operate

the controls. Individuals who have low vision or are

blind cannot accurately operate some types of

controls which require vision for use. These include

mice, trackballs, dia ls without markings or stops, and

push-button controls with only one physical state,

where the only indication of the setting is visual.

Examp le Strategies for Making Controls

Locatable and Identifiable and for Orienting the

User:

If you use buttons on your product, making them

discrete buttons which can be felt allows a person to

locate them tactilely. If you are using a flat

membrane keyboard, putting a raised edge around

the control areas or buttons m akes it possible to

tactilely locate the keys. Once an individual locates

the different controls, they ne ed to identify what they

are. If you have a sta ndard nu mber pa d arrange ment,

putting a nib on the “5" key may be all that is

necessary for identifying the numbers. On a

QWERTY keyboard, putting a tactile nib on the “F”

and “J” keys allows a touch typist who is blind to

easily locate their hands on the keys. Providing

distinct shapes for keys can either indicate their

function or make it easy to tell them apart. Providing

braille labels for keys and co ntrols allows ind ividuals

who know bra ille to figure out what the controls are

for. Providing large raised letters can work for short

labels on large objects. Whe re it is not possible to

use raised large letters, you ma y be able to

incorporate a voice mode which announces keys

when pressed, but does not activate them. This
46

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed

rules will be made through the Federal rulemaking process.

would allow people to turn on the voice mode long

enough to explore and lo cate the item they are

interested in, then release the voice mode and press

the control. If it is an adjustable control, voic e

confirmation of the status may also be imp ortant.

For connectors, either provid e a tactile

indication as to the way the plug should be oriented

or use orientation-independent or self-orienting

plugs. Wireless connection strategies, which

eliminate the need to orient or insert connectors, also

solves the problem.

Avoiding buttons that are activated when

touched will allow an individual to explore the

controls in order to find the desired button. If you

cannot avoid touch-activated controls (for example,

on a touch screen), you can provide an alternate

mode where a co nfirm button is used to co nfirm

selections (for example, items are read when

touched, and activate d when the c onfirm butto n is

pressed). It is also a good idea to make all actions

reversible, or require confirmation before executing

non-reversible actions.

Examp le Strategies for Creating Controls which

can be Used without Vision

Once controls have been located and users know

what the functions of the controls are, they must be

able to operate the controls. Individuals who have

low vision or blindness cannot accurately operate

some types of controls which require vision for use.

These include mice, track balls, dials without

markings or stops, and push-button controls with

only one state where the only indication of the

position or setting of the control (mouse, pointer,

etc.) is visual.

Providing a rotational o r linear stop an d tactile

or audio detents is one strategy that can be used.

Another is to provide keyboard or discre te pushbutton access to the functions. If the product has an

audio system and microprocessor, audio feedback of

the setting may be u sed. For simpler devices, tactile

markings may be sufficient. Controls can also be

shaped in a fashion that they can easily be tactilely

read (e.g., a twist knob shaped like a pie wedge). If

using keys, particularly keys which do not have any

physical travel, some type of audio and tac tile

feedback should be provided so that the individual

knows when the key has been activated. If the key is

a two-state key (on/off), use a key that is physically

different (a toggle switch or a push-in/pop-out

switch), so the person can tell what state it is in by

feeling it.

If you have an optional voice m ode fo r

operating the product a simple “query” mode could

be provided, which would allow the individ ual to

find out both the functio n and state of a switch

without actually activating it.

In many cases, there may be other design

considerations which make the optimal mode of

operation for someone who is sighted something

which would not be easily operated by someone

without vision (e.g., use of a touchscreen or mouse).

In this case, the primary strategy may be to provide

a closely linked parallel method for efficiently

achieving the same results (e.g., keyboa rd access) if

you have keyboard “SpeedList” access for

touchscreens, etc.

Compatibility with assistive devices: See also

guidelines dealing with compatibility with software

and hardware assistive technologies.

I-2: Operate with Low Vision without

Requiring Audio

Guideline: Where re adily achievable, the

product input, contro l and mech anical functions shall

be fully operable via at least one mode which is

operab le by individuals who have low vision but are

not legally blind, which does not rely on audio

output.

Note: 20/70 after correction is the beginning of

low vision; 20/200 after correction is the beginning

of legal blindness; a field of vision of less than 20

degrees after correction also constitutes legal

blindness.

Rationale: Individuals with severe visual

disabilities often also have severe hearing disabilities

(especially older users) and cannot rely on audio

access modes c ommon ly used by those who are

blind. 

Problem/Objective: For individuals who have

low vision and who also have hearing impairments or
47

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed rules will

be made through the Federal rulemaking process.

who are deaf, many of the auditory strategies used by

individuals who are blind cannot b e used. Tactile

strategies are still quite useful, except for braille

which few people with low vision know, especially

individuals who are older. The objective here,

therefore, is to maximize the numbe r of peop le who

can use their residual vision co mbined with tactile

senses to operate the product. It should be noted,

however, that individua ls with diabetes who are

losing their vision also lose fine tactile sensatio n in

their fingertips, although more p ronounced tactile

information (e.g., the shape of a large knob or strong

tactile detents) can be felt.

Goal: Anyone who has low vision can use

products, even if they have no useful hearing. 

Examp le non-auditory strategies for maximizing

usability for people with low vision:

Strategies for addre ssing this guideline basically

revolve around making the information on the

product easier to see. This includes using highcontrast print symbols and visual indicators,

minimizing glare on the display and control surfaces,

providing adequate lighting, positioning controls

near the items they control to make them easy to

find, and using Arabic instead of Roman numerals.

The type-face and type-spacing you use can greatly

effect legibility and symb ols can sometimes be used

which are much more legible and understandable

than fine print. Where the display is dynamic, an

ability to enlarge the visual display can also be used.

In addition to making it easier to see, there are

strategies which can be used to reduce the need to

see things clearly in order to operate them. A

judicious use of color-coding (always redundant with

other cues) and following standard conventions and

stereotypes can be used to reduce the need to read

labels (or read labels more than the first time). In

addition, all of the tactile strategies discussed under

the previous guideline (I-1) can also be used here.

I-3: Operate with Color Perception Problems

Guideline: Where readily achievable, product

input, control, mechanical and display functions shall

be fully operable via at least one mode that does not

require color perception.

Rationale: Many pe ople have an inab ility to see

or distinguish between certain color co mbinations.

Others are unable to see color at all.

Goal: Anyone who has trouble perceiving color

accurately can use products.

Example strategies for maximizing usability by

people with color perception anomalies o r color

blindness:

Strategies for addre ssing this guideline basically

revolve around eliminating the requirement that a

person see color to operate the device. This does not

eliminate the use of colo r in any way as long as the

information conveyed by the color is also conveyed

in some other fashion. In addition, there are a

number of things that can be done to allow even

individuals with color anomalies to be able to take

advantage of the color-coded information. First,

there are a number of common pairs of colors that

are indistinguishab le by peop le with color p erceptio n

anomalies. Avoiding these color p airs avoids or

reduces the problems for these individuals. In

addition, as long as the colors have different hues

and intensity, differently colored objects can be

distinguished even on a black and white screen by

their different appearance. Depending upon the

produc t, the manufac turer may also be able to allow

the user to adjust colors to match their preferences

and visual abilities. It is generally a good idea to

also avoid colors with a low luminance.

I-4: Locate, Identify, and Operate Controls

without Hearing

Guideline: Where readily achievable, product

input, control and mechanic al functions shall b e fully

operable via at least one mode whose components

are locatable, identifiable, and accurately ope rable

without requiring the user to hear.

Rationale: Individuals who are hard of hearing

or deaf cannot locate or identify those controls that

require hearing.

Problem: Products that provide o nly audio

prompts cannot be controlled by individuals who are

deaf or hard of hearing. For example, a voice-based

interactive system that can be controlled only by
48

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed

rules will be made through the Federal rulemaking process.

listening to menu items and then pressing bu ttons is

not accessible. If the user has to wait for a tone in

order to move to the next step in a process, an

individual who is deaf or hard of hearing will have

difficulty using the product.

Example strategies for dealing with this

guideline:

By addressing the output issues under O-4,

many accessibility problems that affect input under

this guideline can be so lved. For example, text

versions of audio prompts could be provided

(synchronized with the audio so that the timing is the

same). If prompts are provided visually (O-4) and

no speech or vocalization is required (I-8), most

problems under I-4 will be solved.

I-5: Low Manipulation Requirement

Guideline: Where readily achievable, product

input, control and mechanic al functions shall b e fully

operable via at least one mode that does not require

fine motor control or simultaneo us actions.

Rationale: Individuals with tremor, cerebral

palsy, paralyses, arthritis, artificial hands, and other

conditions may have difficulty operating systems

which require fine motor control, assume a steady

hand, or require two hands or fingers for operation.

Problem: Individuals may have difficulty

manipulating controls on products for any one of a

number o f reasons. They may have Cerebral Palsy,

Parkinson’s Disease, or some other neuromuscular

condition which reduces the amount of physical

control they may have. They may have a spinal cord

injury, ALS, or M S which limits their strength or

their ability to manipulate objects with their fingers.

They may have arthritis which either prevents them

from being able to move their joints or which results

in great pain. T hey may have missing limbs or

artificial hands which only provide a grasping

f u n c t io n b ut not a twisting or other fine,

manipulative motions, or their movements may just

be slower, mea ning that it will take them longer than

average to carry out activities.

Goal: Individuals who have tremor, irregular

movement, who cannot twist controls, or who can

use only a mouthstick or headstick to control things

will be able to operate pro ducts.

Some example strategies for creating products

that are more usable by individuals with reduced

manipulation abilities are provided below, grouped

by topic.

Example strategies for dealing with timing and

time-outs: See Guideline I-7 Non-time dependent

controls.

Example strategies to avoid accidental activation

of controls:

Using larger buttons or controls, or buttons

which are more w idely spaced, is one strategy.

Providing guard bars between the buttons or near the

buttons so that accidental movements would hit the

guard bars can help avoid accidental bumping of

switches. An optional mod e where buttons must be

depressed for a longer period of time (SlowKeys)

before they would accept input can also be used to

separate between inadvertent motions or bumps and

desired activation.

Avoid buttons which are activated when touched

or, where that is difficult to do (e.g., with

touchscreens) provide a mode wh ere there is a

confirm button which an individual can use to

confirm that the item they touched is the one they are

interested in. It is also a good idea to make all

actions reversible and/or to request confirm ation

before entering into non-reversible actions.

Example strategies to deal with reduced

manipulation or grip:

Latches, controls, key combinations, etc. which

require simultaneous activation of two or more

buttons, latches, etc. (to open, operate, etc.) can be

difficult or impossible for individuals to operate who

have arthritis or who operate them with a head stick

or mouse stick, etc. The same goes for very small

controls or controls which require rotation of the

wrist or pinch and twist. One strategy would be to

avoid these types of co ntrols, another would be to

provide alternate means for achieving the same

functions.
49

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed rules will

be made through the Federal rulemaking process.

Controls which have non-slip surfaces and those

that can be operated with the side of the hand, elbow

or pencil can be used to minimize physical activity

required. In some cases, rotary controls can be used

if they can be operated without grasping and twisting

(e.g., a thin pie slice shape control or an edge

control). Providing a concave top on buttons makes

them easier to use with head sticks, mouse sticks and

artificial or trembling hands.

Strategies for making it easier to insert cards or

connectors include providing a bevel around the slot

or connector, using cards or connectors which can be

inserted in any orientation or which self-center or

self-align. Locating the slot or connector on the

front and near a ledge or open space that th e

individual can use to brace their hand or arm can

also increase their ability to either rest or steady their

arm/hand and facilitate use of the slot or connector.

Again, on some d esigns it will be controls which

are difficult to manipulate which may be the most

efficient, logical or effective mechanism for a

majority of users. In this case, alternate strategies

for achieving the same functions which do not

require that fine manipulation be used could be

provided.

Alternate access method s:

Where the optimal technique for users without

disabilities involves techniques which would cause

problems for people w ith physical disab ilities,

provide alternate means for achieving the same

functions. One could also support speech

input/voice recognition as an alternative input,

although it should not be the only input technique

(see I-8).

I-6: Operate with Limited R each and Strength

Guideline: Where readily achievable, product

input, control and mechanic al functions shall b e fully

operab le via at least one mod e that is opera ble with

limited reach or strength.

Rationale: Individuals with spinal cord injuries,

ALS, arthritis, MS, MD and other conditions may

have difficulty operating systems which require

reach or strength.

Examp le strategies for minimizing reach

requirements for prod ucts:

The most straight-forw ard strategy is to place

the controls whe re they can be easily reached with

minimal changes to body position. M any products

which have contro ls located on different parts of the

product also allow the functions to be con trolled

from the keyboa rd, which is loc ated direc tly in front

of the user. Allowing voice recognition to be used as

an option also provides input flexibility, but it should

never be the only means for achieving a function.

Finally, providing a remote control option for a

product not only moves all of the controls for the

product together on a unit that can be positioned

optimally for the individual, but also allows the

individual to operate the device without having to

move to it. In this case, using a standard

communication format would be important to allow

the use of alternate remote controls for those who

cannot use the standard remote co ntrol.

Example strategies for minimizing strength

requirements for prod ucts:

Basic strategies involve reducing the force

needed to operate controls, latches, etc., as well as

avoiding the need for sustained pressure or activity

(e.g., use guards rather than increased strength

requireme nts to avoid accidental activation of crucial

switches). Other strategies involve providing arm or

wrist rests or supports, providing shortcuts to reduce

the number o f actions need ed, or completely

eliminating the need to o perate controls wherever

possible by having automatic adjustments. Reducing

the need to reach (see above) is also very helpful

here.

I-7: Non-T ime Dependent C ontrols

Guideline: Where readily achievable, product

input, control and mechanic al functions shall b e fully

operab le via at least one mode that does not require

a response within a period o f time, or where the

response time is adjustab le over a wide range. 

Rationale: Individuals with physical, sensory

and cognitive disabilities may not be able to find,

read and operate a control quickly.
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rules will be made through the Federal rulemaking process.

Goal: Products can be operated by individuals

regardless of how long it takes them to respond.

Examp le strategies for minimizing response time

requirements:

Running out of time is a common problem for

people both with and wit hout disabilities.

Addressing the problem of individuals with

disabilities usually involves just applying and

extending the strategies trad itionally employed . The

easiest solution is to avoid any time-out situations or

places where the user must respond to a question or

moving display in a set amount of time or at a

specific time (e.g., a rotating display). Where timed

responses are required or appropriate, allowing the

user to adjust them or set them to very high values

can be useful. Warning a user that time is running

out and allowing them to secure extended time can

also be used in many cases. Finally, if the standard

mode of operatio n would b e awkward or inefficient,

then an alternate mode of opera tion could be

provided which p rovided these abilities.

I-8: No Speech Required

Guideline: Where readily achievable, product

input and contro l functions shall be fully operable

via at least one mode that does not require speech.

Rationale: Many individuals cannot speak or

speak clearly either due to physical disability or

deafness. Produc ts which requ ire speech in order to

operate them, and which do not provide a n alternate

way to achieve the same function will not be usable

by these people.

Example strategies for avoiding speech:

Basically, the way to address this guideline is

simply to provide an alternate mechanism for

achieving all of the functions which are controlled by

speech. If a product includes speech identification or

verification, an alternate mechanism for this should

be provided as well.

Example strategies to maximize use of speech

systems: 

It is helpful to try to maximize the number of

individuals who can use their speech to control the

product even if they have a disability. Almost all of

the standard strategies for improving speech

recognition reliability will be helpful here. In

addition, it is important to include individuals who

are deaf or who have dysarthria (speech movement

disability) in the subject populations that are used to

develop the voice recognition algorithms, so that the

algorithms will better accommodate with the speech

characteristics exhibited by these groups.

I-9: Language and Cognitive Requirements

Guideline: Where readily achievable, product

input, control and mechanic al functions shall b e fully

operable via at least one mode that minimizes the

cognitive, memory and learning skills required of the

user to ope rate the product.

Rationale: Many individuals have reduced

cognitive abilities either from birth, accident/illness,

or aging. These include reduced memory,

sequencing, reading, and interpretive skills.

Goal: No one is prevented from using a

telecommunication product or feature because they

cannot figure out how to o perate it.

Example strategies for minimizing language,

memory, learning and cognitive skills required:

Most of these strategies in this category are just

extensions of techniques for making products easier

for everyone to learn and use. Many of these can be

found in any human factors design manual, including

following conventions, using standard colors and

shapes, grouping things together which work

together, etc. On devices which have some controls

that are used by everybody and other controls which

would only be used by advanced users, it is generally

good practice to separate the two, putting the more

advanced features behind a door or under a separate

menu item, etc.

Some of the techniques and strategies listed for

providing access for individuals who are blind are

also very helpful here. For example, devices which

read the contents of the display aloud, controls which

will announce their settings or their functions, etc.,
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NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed rules will

be made through the Federal rulemaking process.

not only make it possible for people who are blind to

figure out the contro ls and displa ys, but also ma ke it

easier for these products to be used by individuals

who have difficulty reading.

Wherever possible, designing products that are

self-adjusting helps to eliminate additional controls

which must be learned, and reduces the visual

clutter. On systems which have sign-in procedures,

it is helpful to allow users’ settings to be associated

with them when they sign in, insert their

identification card, etc. The sy stem can then

autoconfigure to them. Some new “smart cards” are

being designed with user preferences encoded on the

card.

Where a complex series of steps is required,

some type of cueing might be provided to help lead

the person through the process. It is also helpful to

provide an “undo” or back up function, so that any

mistakes can be easily corrected. Where systems are

not reversible, some type of confirmation might be

requested.

On labels and instructions, it is helpful to use

short and simple phrases or sentences.

Abbreviations should be avoided wherever possible.

Eliminating the need to respond within a certain time

or to read text within a certain time window is also

helpful here.

5.3.2 Output, Displays and Feedback

O-1: Visual Information Available in Auditory

Form

Guideline: Where readily achievable, all

information (text, static or dynamic images and

labels) which is provided visu ally shall also be

available in auditory form.

Rationale: Some individuals have difficulty

seeing or reading, or cannot see or read.

Problem: Individuals with cognitive or language

disabilities, as well as individuals with low vision or

blindness, are not able to access text which is

presented visually, but not available in auditory

form.

In addition, people w ith low vision or blindness

are also unable to access information presented

graphically or in other visual forms unless it is also

presented auditorally. Visual presentations which

are purely decorative in nature are not as essential as

that information which is needed for understanding

and use of the products.

Goal: All information is perceivab le by all

individuals who cannot read or see.

Examp le strategies for achieving this objective:

The most universal way to address this problem

is to provide speech output of all text which is

presented on the display as well as labels of the

produc t. For information which is presented in nontext form (e.g., a picture or graphic), a verbal

description should also be provided, unless it is just

decorative in nature. Although most people who are

legally blind do not know braille, it is an extremely

effective mechanism for those who do: providing

braille labels for controls, for example. Large raised

print can also be used but is generally restricted to

rather large objects due to the size o f the letters.

When speech output is provided, there could be

a mechanism to allow for the spoken message to be

repeated if the message is very long. A message for

stepping thro ugh them is helpful.

O-2: Make Visual Information Accessible by

People with Low Vision without Requiring

Audio

Guideline: Where readily achievable, all

information which is prov ided through a visual

display including text and dynamic image s, labels or

incidental operating c ues shall be p erceivable via at

least one mode by individuals who have low vision

but are not blind, without requiring audio

presentation.

Rationale: Individuals with severe visual

disabilities often also have severe hearing disabilities

(especially older users) and cannot rely on audio

access modes used by those who are blind.
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NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed

rules will be made through the Federal rulemaking process.

Goal: All people who have low vision but are

not legally blind can use their vision to access

visually presented information on a pro duct.

Example strategies for achieving this goal:

Strategies for achieving this guideline ge nerally

revolve around p roviding larg er, higher contrast print

and graphics. Ind ividuals with 20/200 vision can see

lettering if they get close to it, unless it is very small

or very poor contrast. Although 14 or 18 point type

is recomm ended, it is usually not po ssible to put this

size print on small devices. Making the lettering as

large and high contrast as possible, however, will

maximize the numbe r of peop le who are ab le to use

the product. On displays where the font size could

be varied, allowing the user to increase the font size

is helpful, even if it means that the user must pan or

step around the display in order to see the full

display.

O-3: Perceive Mov ing Text

Guideline: Where readily achievable, text

which is presented in a moving fashion will also be

available via at least one mode in a static

presentation mode at the option of the user.

Rationale: Moving text can be an access

problem because individuals with low vision,

physical or sensorimotor disabilities find it difficult

or impossible to track mo ving text with their eyes.

Example strategies for achieving this guideline:

Strategies here usually involve some mechan ism

for freezing the text. A “Times Square” display

which provides a line at a time would be one

example. Allowing the user to freeze the text to read

it would be another strategy. A third approach might

be simply to provide the same information in another

type of display which does not move.

O-4: Visual and/or Tactile Availability of

Auditory Information

Guideline: Where readily achievable, all

information which is provided auditorially, including

those incidental operating sounds and speech, which

are important for use of the produ ct, shall be

available via at least one m ode in ap propriate visual

form and/or where appropriate in tactile form.

Rationale: Individuals who have difficulty

hearing or who are unable to hear the product are

unable to hear audito ry output or to hear mechanical

and other sound s that are emitted by a device which

may be needed for its safe or effective operation

Goal: Information which is prese nted

auditorally is available to all users, even if they

cannot hear.

Example strategies for achieving this guideline

are provided below by topic.

Alerting and status functions:

To alert the user to a call, page, or other

message, or to warn the user, a visual or tactile signal

that will attract the person’s attention can be used.

In portable devices, a tactile signal such as vibration

is often more effective than a visual signal for this

purpose because a visual signal may e asily be

missed. A remote vibrating signaler is a promising

solution if it is not readily achiev able or effective to

build vibration into a portable device. For stationary

devices, a prominen t visual indication in the field of

vision (e.g., a screen flash for a computer user, a

flashing light for a phone user) is effective.

Text presentation:

To inform the user of the status of a process

(e.g., line status on a phone call, power on, saving to

disk, disconnec ted), text messa ges may be used. It is

also desirable to have an image or light that is

activated whenever acoustic energy is present on a

telephone line.

 Speech messages can be mad e accessible if

portrayed simultaneously in text form (as standard or

optional mode) and displayed where easily seen by

the user. Such captions should usually be verbatim

and displayed long enough to be easily read. If the

equipment provides speech messages and the user

must respond to those messages (e.g., interactive

voice response and voice mail), a text-telephoneaccessible method of accessing the system could be

provided. If the system pro vides in teractive

communication using speech and video, it would be
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NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed rules will

be made through the Federal rulemaking process.

helpful to provide a method and channel for allowing

non-speech communication (e.g., text conversation)

in parallel with the video.

Certain operations of equipment make sounds

that give status information, although these sounds

are not programmed signals. Examples include the

whir of an operating disk drive and the click of a key

being pushed. Where sounds of this type provide

information important for operating the device, they

should be made visua lly accessible by use of a light

or other visual confirmation of activation.

Voice interaction:

If equipment uses voice or speech messages to

which the user must respond (e.g., voice mail,

interactive voice response, etc.) , a TTY -accessible

method for using the system could also be provided.

If the system provides interactive com munication

using speech and video, a mechanism for allowing

non-speech communication in parallel with the video

could be provided.

O-5: Make Audito ry Information A ccessible

by People Who are Hard of Hearing without

Requiring Vision

Guideline: Where readily achievable, all

information which is provided auditorially, including

incidental operating sounds, which is important for

use of the product, shall be available via at least one

mode in enhanced auditory fashion (for exa mple,

increased amplification, or reduction of background

noise).

Rationale: Individuals who have difficulty

hearing but are not deaf find it much easier to use

their hearing than to have to rely on access strategies

used by people who are deaf.

Goal: All people who are hard of hearing but

not deaf can use their hearing to access aud itorally

presented information o n a product.

CLOSELY RELATED GUIDE LINES : See also

C-2 and C-3 which deal with hearing aid

compatibility. 

Examp le strategies for addressing this guideline:

Strategies for addressing this guideline include

improving the signal to noise ratio by making the

volume adjustable, increasing the m a x i m um

undistorted volume, and minimizing background

noise by such methods as better coupling between

the signal source and the user.

Alerting tones are most likely to be heard if they

involve multiple tones separated in frequency which

contrast with the environm ent. Occasio nally,

varying tones may be prefe rred for attracting

attention.

If speech is used, it is best to test its

intelligibility with individuals who are hard of

hearing to maximize its clarity and ease o f

understanding to this population group. Again, the

ability for the user to have any messages repeated or

to repeat the m essage if no response is received from

the user is helpfu l . F o r e ss e n t i al a u d i to ry

information, the information might be repeated and

an acknowledgment from the user requested.

The intelligibility of the output can also be

maximized by the location of the speakers and by

keeping them away from noise sources. However,

visual displays are often more desirable than loud

prompts or alerts, because the latter reduce privacy

and can annoy o thers unless the amplified signal is

isolated by means of a headphone, induction

coupling, direct plug-in to a hearing aid, or other

methods. (See strategies under O -4.) The use of a

telephone handset or earcup which can be held up to

the ear can improve intelligibility without disturbing

others in the area. If a handset or ear cup is used,

making it compatible with a hearing aid (T -coil)

allows the user to directly couple the auditory signal

to their hearing aid s. If the microphone in the

handset is not being use d, turning it off will also

reduce the amount of background noise which the

person hears in the earpiece. Providing a headphone

jack also allows individuals to plug in headphones,

induction loops, or amplifiers which they may use to

hear better.

O-6: Prevention of Visually-Induced Seizures

Guideline: Where readily achievable, visual

displays shall be desig ned so as to avoid high
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NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed

rules will be made through the Federal rulemaking process.

probability of triggering a seizure in an individual

with photo-sensitive epilepsy.

Rationale: Individuals with photo-sensitive

epilepsy can have a se izure triggered by displays

which flicker or flash, particularly if the flash has a

high intensity and is within certain frequency ranges.

Examples of strategies for achieving this

guideline:

Strategies here will revolve around reducing or

eliminating screen flicker or image flashing. In

particular, the 10-30 hertz range is the mo st sensitive

frequency range, and should be avoided. The chance

of triggering seizures can also be reduced by

avoiding very bright flashes which occupy a large

part of the visual field (p articularly in the center of

the visual field) in order to minimize the impact on

the visual cortex.

O-7: Prevention of Sound-Induced Seizures

Guideline: Where readily achievable, sound

displays shall be designed so as to avoid aud io

behaviors that create a high probability of a seizure

in an individua l with sound-induced epilepsy.

Rationale: Individuals with sound-induced

epilepsy can have a seizure triggered by audio

output.

Examples of strategies for achieving this

guideline:

Strategies here revolve around avoiding sudden

or rapidly repeating and loud sounds.

O-8: Audio Cutoff

Guideline: Where readily achiev able, prod ucts

which use audio o utput access modes, sha ll have a

headphone jack or personal listening device (e.g.,

phone-like handset or earcup ) which cuts off the

speaker when used.

Rationale: Individuals using the audio access

mode, as well as those using a d evice with the

volume turned up, need a way to limit the range of

audio broadc asts.

Example strategies for achieving this guideline:

If an audio headphone jack is provided, a cut-off

switch can be included in the jack so that insertion of

the jack would cut off the speaker. If a telephonelike handset is used, the external speakers can be

turned off when the handset is removed from the

cradle.

5.3.3. Documentation

D-1: Ability to Access Product Documentation

and Related On-Line Information

Guideline: Documentation (printed, on-line or

tutorial, including pro motional materials) shall be

accessible to and usable by individuals with all

disabilities or alternate formats shall be available.

Rationale: People who have disabilities often

are unable to use standard p rinted documentation if

they cannot see, documentation that is presented on

screen in small fonts if they have poor vision,

documentation that presents important information

auditorially if they are deaf, etc.

Example strategies for achieving this guideline:

Strategies for addressing this guideline fall into

two categories. Making the standard documentation

as accessible a s possible an d provid ing alternate

formats.

There are a numb er of strategies for making

print easier to read . These include using larger type

size, high contrast between lettering and background,

and not printing text over patterned backgrounds.

Materials that can be copied in black and white are

easier for users to enlarge using copier machines.

Controll ing the language level and keeping the

document as easy to read as possible is also

important.

Manuals which are spiral bound or bound so that

they can lie flat are easier for people with physical

disabilities to use. Tabs are also helpful.

Electronic manuals and on-line help have the

advantage that they can be easily presented in either
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be made through the Federal rulemaking process.

visual or auditory form (via speech synthesizer), and

can also be mo re easily electronically enlarged . In

order for this to work however, all information must

be available in electronic text form. Any information

that is presented in graphic form would also need to

be presented in the text or the graphics would have

to be described. Any text which is presented as a

graphic and cannot be saved as ASCII or is not

written to the screen using the standard system text

drawing tools would not be accessible to the screen

reader/voice synthesizer.

Alternate forms for print documentation include

braille, audio tape, and enlarged printed

documentation (14 to 18 point). Videotapes can be

captioned (either open or closed captioned) to make

them accessible by those who are hard of hearing or

deaf. Adding video description can make many of

them accessible to people who have low vision or

blindness. The most universal form of alternate

documentation is the ASCII text file. However, it is

only usable by those who have a computer which

may or may not fit the consumer profile for a

product. 

5.3.4. Compatibility Guidelines

C-1: Externa l Electron ic Access to All

Information and Control Mechanisms

Guideline: Where readily achievable:

1. All information needed for the operation of

a product (including output, alerts, labels, on-line

help, and documentation) shall be available in a

standard electronic text format on a cross-industry

standard p ort;

2. All input to and control of a product shall

allow for real time operation via electronic text input

into a cross-industry standard e xternal port and in

cross-industry standard format; and

3. The port used for 1 and 2 shall not require

manipulation of a connector by the user.

Rationale: Some ind ividuals with severe or

multiple disabilities are unable to use the built-in

displays and control mechanisms on a product.

Example strategies for achieving this guideline:

The two most common forms of manipulationfree connections are an infrared connection or an RF

connection point. At the present time, the IrDA

infrared connectio n point is the most unive rsally

used approach.

At the present time, a cross-industry standard for

alternative control and display d oes not exist. A

standard protocol is under development. A crossindustry standards effort is required in order to

provide a common reference point that both CPE and

SCPE manufacturers can work toward.

C-2: Connection Point for E xternal A udio

Processing Devices

Guideline: Where readily achiev able, prod ucts

providing auditory ou tput shall provide the auditory

signal via an industry standard connector and signal

level.

Rationale: Individuals using amplifiers, audio

couplers, and other audio processing devices need a

place to tap into the audio generated by the product

in a standard way.

Problem: Individuals w ho canno t hear well can

often use the prod ucts if they can isolate and enhance

the audio output. For example, they could plug in a

headphone which makes the audio louder and helps

shut out background noise; they might feed the signal

through an amplifier to make it louder, or through

filters or frequency sh ifters to make it b etter fit their

audio profile. If they are wearing a hearing aid, they

may directly connect their hearing aid to the audio

signal or plug in a small audio loop which allows

them to couple the audio signal through their hearing

aid’s built-in T-coil. Devices which can process the

information and provide visual and/or tactile output

are also possible.

Example strategies for achieving this guideline:

The most common strategy for achieving this

objective is the use of a stand ard miniature plug-in

jack. For small products, a subminiature phone jack

could be used.

This is an area where on-going coordination

between manufacturers of CPE and manufacturers of
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NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed

rules will be made through the Federal rulemaking process.

assistive technology would be important, to ensure

that changes in technology are addressed by

standards.

C-3: Hearing Aid Coupling

Guideline: Where readily achiev able, prod ucts

providing auditory output via an audio transducer

which is normally held up to the ear shall provide a

means for effective wireless coupling to hearing aids.

Rationale: Individuals who are hard of hearing

use hearing aids with a T-coil feature to allow them

to listen to audio output of pr oducts without picking

up background noise and to avoid problems with

feedback, signal attenuation or degradation.

Example strategies for achieving this guideline:

The Hearing Aid Compatibility (HAC) Act

defines a telephone as hearing aid comp atible if it

provides internal means for effective use with

hearing aids that are d esigned to be comp atible with

telephones which meet e stablished technical

standards fo r hearing aid compatib ility.

The technical standards for the HAC telephones

are specified in two documents, ANSI/EIA-504-

1989, “Magnetic Field Intensity Criteria for

Telephone Compatibility with Hearing Aids,” and

ANSI/TIA/EIA-504-1-1994, “An Addendum to EIA504,” which add s the HAC requirements.

A good strategy for addressing this guideline for

any product held up to the ear would be to meet

these same technical requirements.

If not readily achievab le to provid e built-in

telecoil compatibility, an accessory or other means of

providing the electro-m agnetic signal is the next

strategy to be considered. Alternate methods of

internal coupli ng, not yet identified, are also

encouraged, and these should be developed in

concert with the hearing aid industry an d individua ls

who are hard of hearing.

C-4: Non-Interference with Hearing

Technologies

Guideline: Where readily achiev able, prod ucts

shall not cause interference with hearing

technologies (including hearing aids, cochlear

implants, and assistive listening devices) which are

used by a product user or bystanders.

Rationale: Individuals who are hard of hearing

use hearing aids and other assistive listening devices,

but they cannot be used if prod ucts introduce noise

into the listening aids because of stray

electromagnetic interference.

Example strategies for achieving this guideline:

Strategies for reducing interference (as well as

improving hearing aid immunity) are being

researched. The most desirable strategy is to avoid

the root ca uses of interference when

telecommunications equipme nt is initially designed.

The industry should work toward transmission and

channel-sharing technologies that do not generate

interference, and should test new technologies for

possible interference with assistive technologies.

If the root sources of interference c annot read ily

be removed, then shielding, placemen t of

components to avoid hearing aid interference, and

field-canceling techniques are among those that may

be effective.

The ongoing work of ANSI C-63, which is

working toward imp rovemen ts in usability of certain

phones by wearers of hearing aids, should be

monitored and incorp orated if a standard is adopted.

C-5: Prosthetic Compatibility of Controls

Guideline: Where readily a chievable,

touchscreen and touch-operated controls shall be

able to be activated without requiring body contact

or close body proximity.

Rationale: Individuals who have artificial hands

or use headstick s or mouths ticks to oper ate produ cts

have difficulty with capacitive or heat-operated

controls which require contact with a person’s body

rather than a tool.

Problem: Individuals who wear prosthetics are

unable to operate some types of products because
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be made through the Federal rulemaking process.

they either require motions that c annot easily b e

made with a prosthetic ha nd, or bec ause prod ucts are

designed which require touch of the human skin to

operate them (e.g., capacitive touchscreen kiosks),

making it impossible for individuals with artificial

arms or hands to operate the kiosks, except perhaps

with their nose or chin. Some individuals who do

not have the use of their arms use either a headstick

or a mouthstick to opera te products.

Example strategies for achieving this guideline:

Avoid controls and mechanisms which require

a grasping and twisting motion. Use controls and

sensors which can be activated with a mechanical

device.

C-6: Text Telephone Con nectability

Guideline: Where readily achiev able, prod ucts

which provide a function allowing voice

communication and which do not themselves provide

a text telephone functionality shall provide a

standard non-acoustic connection point for text

telephones. It shall also be possible for the user to

easily turn any acoustic pickup on the product on and

off to allow the use r who can ta lk to intermix speech

(live microphone) with text telephone use.

Rationale: Individuals who use TT Ys to

communicate using text over telephones must have

some non-acoustic way to connect TT Ys to

telephones to get clear TT Y conne ctions. Acoustic

coupling is subject to inte rference from ambient

noise, as many hand sets do not p rovide an a dequate

seal with TTY s. Therefo re, alternate (non-acoustic)

connections are needed. Control of the microphone

is needed for situations such as pay-phone usage,

where ambient noise picked up by the mouthpiece

often garbles the signal (user needs to be able to

mute the handset microphone). Some users of TTYs

cannot hear and u se the TT Y to rece ive

communication but can talk and use speech for

outgoing communication. The m icrophone on/off

switch on the telephone should therefore be easy to

flip back and forth or have a p ush-to-talk mode

available.

Goal: A text telephone can be connected to and

used with any te lecommunicati ons product

supporting speech communication without requiring

purchase of a special adapter, and the user is able to

intermix speech and clear text tele phone

communication.

Example strategies for implementing this

guideline:

The most common approach today is to provide

an RJ-11 jack. On very small products, where there

may not be room for this large jack, a miniature or

subminiature phone-jack wired as a “headset” jack

(with both speaker and microphone conn ections)

could be used as an alternate approach. In either

case, a mechanism for turning the phone mouthpiece

(microphone) on and off would reduce garbling in

noisy environme nts, while allowing the user to speak

into the microphone when desired (to conduct

conversations with mixed voice and text telephone).

Note: For equip ment that com bines voice

communications, screens, keyboards and data

communication functions, it is desirable to build in

text telephone capability for direct access to voice

communications channels.

C-7: Text Telephone Signal Com patibility

Guideline: Where readily achiev able, prod ucts

providing voice com munication functionality shall

be able to support use of all cross-manufacturer nonproprietary standard signals used by

telecommunication devices designed for use by or

with people who are deaf, hard of hearing or have

speech impairments.

Rationale: Some telecommunication systems,

which have been developed and released, compress
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NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed

rules will be made through the Federal rulemaking process.

the audio signal in such a manner that standard

signals used by text telephones are distorted or

attenuated, preventing successful text telephone

communication over the systems.

Goal: A text telephone can be used with any

product providing voice communication function.

Example solution strategies for achieving this

guideline:

The de facto standard of domestic text

telephones is Baudot, which has been defined in ITU

Recommendation V.18. This guideline can be

addressed by ensuring that the tones used can travel

through the phones compression circuits undistorted.

It is even more desirable to provide undistorted

connectivity to the telephone line in the frequency

range of 390 Hz to 2300 Hz (ITU-T

Recommendation V.18), as this range covers all of

the text telephone protocols known throughout the

world.

An alternate strategy might be to recognize the

tones, transmit them as codes, and resynthesize them

at the far end.

In addition, as n oted abo ve, it should b e possible

for individuals using TTYs to conduct conversations

with mixed voice and TTY, and to control all aspects

of the product/system and receive any messages

generated by the product/system.
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NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed rules will

be made through the Federal rulemaking process.

APPENDIX D

ARCHITECTURAL AND TRANSPORTATION

BARRIERS COMPLIANCE BOARD

Telecommunications Act Accessibility Guidelines

f o r C u s t o m e r P r e m i se s E q u ipment and

Telecommunications Equipment

AGENCY: A r c h i t e c tu r a l a n d Transportation

Barriers Compliance Board.

ACTION: Notice of intent to establish advisory

committee.

SUMMARY: The Archite ctural and

Transportation Barriers Compliance Board (Access

Board) announces its intent to establish a

Telecommunications Access Advisory Committee

(Committee) to develop accessibility guidelines

under the Telecommunications Act of 1996 and

requests applications from interested organizations

for representatives to serve on the Comm ittee. The

Committee will make recommendations to the

Access Board on accessibility guidelines for

telecommunications equipment a n d c us t o m er

premises eq uipment.

DATES: Applications should be received by April

27, 1996.

ADDRESSES: Applications should be sent to the

Office of Technical and Information Services,

Architectural and Transportation B arriers

Compliance Board , 1331 F Street, NW., suite 1000,

Washington, D.C. 20004-1111. Fax number (202)

272-5447. Applications may also be sent via

electronic mail to the Access Board at the following

address: cannon@ access-board.gov. 

FOR FURT HER INFOR MATION CONTACT:

Dennis Cannon, Office of Technical and Information

Services, Architectural and Transportation Barriers

Compliance Board, 1331 F Street, NW ., suite 1000,

Washington, D.C. 20004 -1111. Telephone number

(202) 272-5434 extensio n 35 (Voice); (202) 272-

5449 (TTY). Electroni c mail address:

cannon@access-board.gov. This document is

available in alternate formats (cassette tape, braille,

large print, or computer disc) upon request.

SUPPLEMENTARY INFORMATION: On

February 8, 1996, the President signed the

Telecommunications Act of 1996. The Architectural

and Transportation Barriers Compliance Board

(Access Board) is responsible for developin g

accessibility guidelines in conjunction with the

Federal Communications Commission under section

255 (e) of the Act for telecommunications equipment

and custom er premises equipment.1

The term “telecommunications equipment” is

defined as equipment, other than customer premises

equipment, used by a carrier to provide

telecommunications services, and includes software

integral to such equipment (including upg rades).

P.L. 104-104, sec. 3 (a)(2)(50). The term “customer

premises equipment” is de fined as equipment

employed on the premises of a person (other than a

carrier) to originate, route, or terminate

telecommunications. P.L. 104-104, sec. 3 (a)(2)(38).

The Telecommunications Act requires the

accessibility guidelines to be issued within 18

months after the date of enactment. The Board is

also required to review and update the guidelines

periodica lly. The Board’s guidelines for

telecommunications equipment and customer

 1 The Access Board is an independent Federal

agency established by section 502 of the Rehabilitation

Act of 1973, as amended, whose primary mission is to

promote accessibility for individuals with disabilities. 

The Access Board consists of 25 members. Thirteen are

appointed by the President from among the public, a

majority of who are required to be individuals with

disabilities. The other twelve are heads of the following

Federal agencies or their designees whose positions are

Executive Level IV or above: The Departments of

Health and Human Services, Education, Transportation,

Housing and Urban Development, Labor, Interior,

Defense, Justice, Veterans Affairs, and Commerce;

General Services Administration; and United States

Postal Services.
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NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed

rules will be made through the Federal rulemaking process.

premises equipment are required to principally

address the access needs of individuals with

disabilities affecting hearing, vision, movement,

manipulation, speech, and interpretation of

information.

The Senate report to the Telecommunications

Act directs the Board to develop its guidelines by

involving parties affected by the l a w. “T he

Committee expects that manufacturers of equipment

and providers of service will be fully included in this

process.” S. Rept. 10 4-23, at 53 . Throughout the

process of developing its guidelines, the Access

Board, in conjunc tion with the Federal

Communications Commission, intends to coordina te

and consult with representatives of individ uals with

disabilities and interested telecommunications

equipment and service providers to ensure that the ir

concerns and interests are given full consid eration in

the rulemaking process.

The Access Board will begin the process of

developing the accessibility guidelines by

establishing a Telecommunications Access Advisory

Committee. The establishment of the Comm ittee is

in the public interest and will supp ort the agency in

performing its duties and responsibilities under the

Teleco mmunications Act of 1996. The Access

Board believes that the Comm ittee will facilitate the

involvement of individuals with disabilities and

telecommunications equipment and service providers

in the development of the guidelines.

The Committee will make recommendations to

the Access Board on issues such as:

 types of equipment to be covered by the

guidelines;

 barriers to the use of such equipment by persons

with disabilities affecting hearing, vision,

movement, m a n i p u l a t i o n , s p e e c h , a nd

interpretation of information;

 solutions to such barriers, if known, categorized

by disability (different solutions may be needed

for different disabilities) and research on such

barriers; and

 contents of the guidelines.

The Committee will be expected to present a

report with its recommendations to the Access Board

within six months of the Committee’s first meeting.

The Access Board requests applications from

organizations representing the following interests for

membership on the Committee:

 manufacturers of telecommunications equipment

and custom er premises equipment; 

 manufacturers and developers of peripheral

devices or specialized customer premises

equipment commonly used by individuals with

disabilities to achieve access;

 organizations representing the access needs of

individuals with disabilities affecting hearing,

vision, moveme nt, manipula tion, speech, and

interpretation of information; 

 telecommunications providers and carriers; 

 developers of telecommunications software;

and 

 other persons affected by these accessibility

guidelines.

The number o f Committee members will be

limited to effectively acco mplish the Committee’s

work and will be balanced in terms of interests

represented. Organiza tions with similar inter ests are

encouraged to nominate a single organization to

represent their interest. Althou gh the Com mittee will

be limited in size, there will be opportunities for the

public to present written information to the

Committee, participate through the Internet and to

comment at Committee meetings.

Applications should be sent to the Access Board

at the address listed at the beginning of this notice.

The application should include a statement of the

organization’s interests and the name, title, address

and telephone number of the person who would

represent the organization on the Committee. The

application should also describe the person’s

qualifications, including any experience the person

has had with making telecommunications equipment

and customer premises equipment accessible to

individuals with disabilities.

Committee members will not be compensated

for their service. The Access Board may pay travel

expenses for a limited num ber of per sons who w ould

otherwise be unable to participate on the Committee.

Committee members will serve as representatives of

their organizations, not as individuals. They will not

be considered special government employees and
61

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed rules will

be made through the Federal rulemaking process.

will not be required to file confidential financial

disclosure reports. 

After the applications have been reviewed, the

Access Board will publish a notice in the Federal

Register announcing the appointment of Committee

members and the first meeting of the Committee.

The first meeting of the Comm ittee is tentatively

scheduled

for June 10-1 2, 1996 in Washington, D.C. The

Committee will operate in accordance with the

Federal Advisory C ommittee Act, 5 U.S.C. app 2.

Committee meetings will be held in Washington,

D.C. Each meeting will be open to the public. A

notice of each meeting will be published in the

Federal Register at least fifteen days in advance of

the meeting. Records will be kept of each meeting

and made available for public inspection.

_________________________________

Judith E. Heumann,

Chairman, U.S. Architectural and Transportation

Barriers Compliance Board.
62

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed

rules will be made through the Federal rulemaking process.
63

NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed rules will

be made through the Federal rulemaking process.

ARC HITECTURAL AND TRANSPORTATION

BARRIERS COMPLIANCE BOARD

Telecommunications Act Ac cessibility Guidelines

for Telecommunications Equipment and

Customer Premises Equipment

AGENCY: Architectural and Trans portatio n

Barriers Compliance Board.

ACTION: Notice of appointment of advisory

committee members and notice of first meeting.

SUMMARY: T he Architectural and

Transportation Barriers Compliance B oard (Access

Board) is announcing the appo intment of me mbers to

its Teleco mmunica tions Access Advisory Committee

(Committee). The Committee will make

recomm endati ons t o th e Acc e s s B o ard on

accessibility guidelines for telecommunications

equipment and customer p remises equ ipment. These

recommendations will be used by the Access Board

to develop accessibility guidelines under section 255

(e) of the Telecommunications Act of 1996. The

Committee is composed of representatives of

manufacturers of telecommunications equipment

and customer premises equipment; organizations

representing the access needs of individuals with

disabilities; telecommunications providers and

carriers; and other persons affected by the guidelines.

This notice also announces the time and place of the

first Comm ittee meeting, which will be open to the

public.

DATES: The first meeting of the Committee is

scheduled for Wednesday, June 12, 1996 through

Friday, June 14, 1996, beginning at 9:30 a.m. each

day. Decisions with respect to future meetings will

be made at the first meeting and from time to time

thereafter. Notices of future meetings will be

published in the Federal Register.

ADDRESSES: The first meeting of the Committee

will be held at the American Speech-Language and

Hearing Association offices, 10801 Rockville Pike,

Rockville, MD 2085 2. Persons attending the

meetings are strongly encouraged to use public

transportation since parking is extremely limited.

The American Speech-Language and Hearing

Association offices are located north o f the

Grosvenor Metro subway station. Persons who m ust

drive should call D ennis Cannon at the Access

Board. The facility is accessible to individuals with

disabilities. Sign languag e interpreters , assistive

listening systems and real time transcriptio n will be

available. Subsequent meetings will be held at

locations to be announced.

FOR FURTHER INFORMATION CONTACT:

Dennis Cannon, Office of Technical and Information

Services, Architectural and Transportation Barriers

Compliance Board, 1331 F Street, NW., suite 1000,

Washington, D.C. 20004-1111. Te lephone number

(202) 272-5434 extension 35 (Voice); (202) 272-

5449 (TTY). Electronic mail address:

cannon@access-board.gov. This documen t is

available in alternate formats (cassette tape, braille,

large print, or computer disc) upon request.

SUPPLEMENTARY INFORMATION: On

March 28, 1996, the Access Board published a

notice of intent to establish an advisor y committee to

make recommendations to the Access Board on

accessibility guidelines for telecommunications

equipment and custom er premise s equipme nt. 61 FR

13813 (March 28, 1996). Under section 255 (e) of

the Telecommunications Act of 1996, the Access

Board is responsible for developing these guidelines,

in conjunctio n with the Fed eral Com munications

Commission. The notice requested nominations for

membership on the Committee from manufacturers

of telecommunications equipment and customer

premises equipment; manufacturers and developers

of peripheral devices or specialized customer

premises equipment commonly used by individuals

with disabilities to achieve access; organizations

representing the access needs of individuals with

disabilities affecting hearing, vision, movement,

manipulatio n, speech, and interpretation of

information; telecommunications providers and

carriers; developers of telecom munications software;

and other persons affected by these accessibility

guidelines.

Over 60 nominations were submitted. For the

reasons stated in the notice of intent, the Access

Board has determined that establishing the

Committee is necessary and in the public interest.

The Access Board has appointed membe rs to the

Committee from the following organizations:
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NOTE: This report is a set of recommendations from the Advisory Committee to the Access Board. Any proposed

rules will be made through the Federal rulemaking process.

AT&T

American Council of the Blind

American Foundation for the Blind

Arkenstone

Broad Alliance for Multimedia Technology and

Applications

Cellular Telecommunications Industry Association

Consumer Action Network

Consumer Electronics Manufacturers Association

The Council of Organizational Representatives

Deaf and Disabled Telecommunications Program

Digital Equipment Corporation

The Ericsson Corporation

Gallaudet University

Inclusive Technologies

Lucent Technologies

Massachusetts Assistive Technology Partnership 

NCR

National Association for State Relay Administration

National Federation of the Blind

Northern Telecom

NYNEX Corporation

Pacific Bell

Pennsylvania Citizens Co nsumer Council

Personal Communications Industry Association

RESNA

Self Help for Hard of Hearing People, Inc.

Siemens Rolm Communications, Inc.

Telecommunications Industry Association

Trace Research and Development Center

United Cerebral Palsy Associations, Inc.

U.S. Society for Augmentative and Alternative

Communication

United States Telephone Association

World Institute on Disa bility

The Access Board regrets being unable to

accomm odate all requests for membership on the

Committee. There were several factors which were

important in the Access Board’s decision not to add

more members. In order to keep the Committee to a

size that can be effective, it is necessary to limit

membership. It is also desirable to have balance

among members of the Committee representing

different clusters of interest, such as disability

organizations and the telecommunications industry.

In addition, it is not essential that every concerned

organization is represented, so long as every interest

is represented by an appropriate organization. The

Committee membership identified above provides

representation for each interest affected by issue s to

be discussed.

Committee meetings will be open to the public

and interested persons can attend the meetings and

communicate their views. Members of the public

will have an opportunity to address the Committee

on issues of interest to them and the Committee.

Members of groups or individuals who are not

members of the Committee may also have the

oppor tunity to participate with subcommittees of the

Committee. The Access Board believes that

participation of this kind can be very valuable for the

advisory committee process. Additionally, all

interested persons will have the op portunity to

comment when the proposed accessibility guidelines

for telecomm unications equipment and customer

premises equipment are issued in the Federal

Register by the Access Board.

_________________________________

Judith E. Heumann,

Chairman, U.S. Architectural and Transportation

Barriers Compliance Board.