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, develop, fabricate and deliver telecommunications or customer premises equipment, and to make decisions related to the design, development, fabrication and delivery of their products are unique to that manufacturer. The intent of the guidelines in this section is to identify elements the TAAC expects to make up processes for achieving accessibility and usability 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. The basic statement may be 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 readily achievable. Accessibility is easier to achieve if considered at the beginning of and throughout the design process. Manufacturers shall consider access to telecommunications by individuals with disabilities throughout product design, development, fabrication and delivery, as early and consistently as possible.

4.2. EXISTING PRODUCTS

Periodically, manufacturers change, upgrade, or distribute new releases of existing products. Whenever they do so, manufacturers are expected to consider accessibility features, and incorporate those features into existing products when readily achievable. Minor or insubstantial changes such as cosmetic changes, or cost-reduction measures, that do not affect functionality, need not trigger accessibility reviews.

4.3. MARKET RESEARCH

Manufacturers are expected to address the needs of individuals with disabilities in their market research and this research should be comparable to other market research efforts. Examples of primary market research may include targeted recruitment of individuals with disabilities, surveys conducted 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 product specific studies.

INDUSTRY NOTE: The clause "...and this research should be comparable to other market research efforts" is subject to a variety of interpretations. In the interest of preventing future misunderstandings, Committee members representing manufacturers and their trade 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 research related to the use of products for general distribution by individuals 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 whose desire to purchase and use products is being studied and (b) treat the population of individuals with disabilities in a manner substantially similar to its treatment of other groups of potential customers. Accordingly, inclusion of individuals with disabilities in market research related to products for general distribution would satisfy both this section and section 4.7."

4.4. MARKETING COMMUNICATIONS

Information 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 brochures, collateral publicity, 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 manufacturers should consider in addressing this need for accessible information include:

  1. Making product information available in alternate formats, upon request;
  2. Where a telephone contact with the manufacturer is provided in the marketing communications, 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 disability-related organizations who have documented expertise with individuals with disabilities.

4.5. CUSTOMER SERVICE

 Individuals with disabilities need to be able to go through the steps of ordering, billing, and interacting with customer service representatives. Steps that can be taken by manufacturers to meet 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 installable devices) and product support communications, regarding both the product in 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 compatibility features of the product upon request, including, as needed, in alternate formats;
  2. Providing end user product documentation in alternate formats, promptly, 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 products to follow similar accessibility guidelines in product and operational support; and
  2. Encouraging resellers and distributors of the manufacturer's products to refer unresolved customer requests concerning accessibility 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 product 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 and delivery. Manufacturers should consult with individuals with disabilities regarding the accessibility of the product, 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 with 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 accessibility 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 equipment, 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 representatives, etc.) with periodic training regarding the requirements of section 255 directly relevant to that employee's function. Where appropriate 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 products;
  4. Designing for 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.

It is strongly encouraged that training programs include input from the disability community and representative agencies.

4.10. CONSUMER INFORMATIONAL INQUIRIES4.10.1. 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 the accessibility of their products. Manufacturers shall publish this contact information in product literature.

4.10.2. Response Time.

Manufacturers should advise all individuals who make informational inquiries with the point of contact that they can expect a response to their inquiry within fourteen (14) calendar days.

4.10.3. Information Provided.

A manufacturer's response to an inquiry should be made promptly, and should include information on accessibility features, compatibility standards that are supported by the product, and commonly used compatibility options available through adaptive 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 request, 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 coordinate (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 equipment manufacturers collaborate 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.