5.0 PERFORMANCE GUIDELINES

5.1. INTRODUCTION

These guidelines provide objectives for product performance which will assist manufacturers in designing, developing and fabricating telecommunications and customer premises 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 products more usable by people with a wide range of disabilities.

Appendix 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 Individuals with Disabilities, Where Readily Achievable.

General Guideline A: Where readily achievable, products 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 hearing, deafness), people with physical disabilities (e.g., limited strength, reach or manipulation, tremor, speech impairments, lack of sensation), people with language or cognitive disabilities (e.g., reading disabilities, thinking, remembering, sequencing disabilities), and other disabilities (e.g., epilepsy, short stature), and individuals with any combination of these disabling conditions (e.g., deaf-blindness). Older individuals in particular commonly have multiple functional limitations.

(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 benefit -- 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 accommodates all disabilities, accessibility is likely to be accomplished through product designs which emphasize interface flexibility to maximize user configurability and multiple, alternative and redundant modalities of input and output.

5.2.2. Compatible with Existing Peripheral Devices or SCPE Used by Individuals with Disabilities, Where Readily Achievable.

General Guideline B: Whenever it is not readily achievable to make a product accessible to and usable by individuals with disabilities, the product shall be compatible with existing peripheral devices or specialized customer premises equipment commonly used by individuals with disabilities 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 compatibility 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 product that addresses accessibility for all or some combinations of disabilities without sacrificing product usability. Therefore, there will be cases where a company 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 individuals with disabilities when determining what accessibility features the product should address.

5.3.1. Input, Control and Mechanicals.5.3.1.1 (I-1). Locate, Identify, and Operate Controls without Vision.

Guideline: Where readily achievable, product input, control and mechanical functions shall be fully operable via at least one mode whose components are locatable, identifiable, and accurately operable 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.

5.3.1.2 (I-2). Operate with Low Vision without Requiring Audio.

Guideline: Where readily achievable, the product input, control and mechanical functions shall be fully operable via at least one mode 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 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 people have an inability to see or distinguish between certain color combinations. Others are unable to see color at all.

5.3.1.4 (I-4). Locate, Identify, and Operate Controls without Hearing.

Guideline: Where readily achievable, product input, control and mechanical functions shall be fully operable via at least one mode whose components 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 mechanical functions shall be fully operable via at least one mode that does not require fine motor control or simultaneous 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 mechanical functions shall be 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 mechanical functions shall be fully operable via at least one mode that does not require a response within a period of time, or where the response time is adjustable over a wide range.

Rationale: Individuals with physical, sensory and cognitive disabilities may not be 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. Products which require 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 mechanical functions shall be fully operable via at least one mode that minimizes the cognitive, memory and learning skills required of the user to operate 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.

5.3.2. Output, Displays and Feedback.5.3.2.1 (O-1). Visual Information Available in Auditory Form.

Guideline: 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.

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 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.

5.3.2.3 (O-3). Access to Moving Text.

Guideline: Where readily achievable, text which is presented in a moving fashion 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 moving text with their eyes.

5.3.2.4 (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 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 product, 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 dealing with hearing aid compatibility.

5.3.2.6 (O-6). Prevention of Visually-Induced Seizures.

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 seizure 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 Sound-Induced Seizures.

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 individual 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 achievable, products 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 broadcast.

5.3.3. Documentation.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 disabilities 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 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 port;
  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 achievable, products 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 achievable, products 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 products without picking up background noise and to avoid problems with feedback, signal attenuation or degradation.

5.3.4.4 (C-4). Non-Interference with Hearing Technologies.

Guideline: Where readily achievable, products 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.

Guideline: 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 headsticks or mouthsticks to operate products have difficulty with capacitive or heat-operated controls which require contact with a person's body rather than a tool.

5.3.4.6 (C-6). Text Telephone Connectability.

Guideline: Where readily achievable, products which provide a function allowing voice communication and which do not themselves provide a TTY functionality shall provide a standard non-acoustic connection point for TTYs. It shall also be possible for the user to easily turn any acoustic 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 (TTYs) to communicate using text-over-telephones must have some non-acoustic way to connect TTYs to telephones to get clear TTY connections. Acoustic coupling is subject to interference from ambient noise, as many handsets do not provide an adequate seal with TTYs. Therefore, 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 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 achievable, products providing voice communication functionality shall be able to support use of all cross-manufacturer non-proprietary 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 the audio signal in such a manner that standard signals used by TTYs are distorted or attenuated, preventing successful TTY communication over the systems.