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 protocol.

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;
  • Product should be usable without looking at it;
  • Product 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 be available in alternate accessible forms;
  • Product support lines will be knowledgeable of assistive technologies that are commonly used with their product.

Compliance Guidelines -- are guidelines that specify the steps a manufacturer should take to demonstrate that it has met the guidelines. Illustrative examples might include:

  • The manufacturer has filed a Declaration of Conformity;
  • The manufacturer has fully documented its good faith efforts;
  • The product has been reviewed by a qualified access specialist.

The meaning of terms not specifically 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 equipment to perform the same tasks, access the same information, with the same ease, in the same time and at the same cost as a person using the equipment without a disability, 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 Formats, 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-cassette recording, 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, including 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 or specialized customer premises equipment commonly 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, route, 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 broadly to include a wide array of electronic products 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 which provides telecommunications functions.

Customer Premises User Interface (CPUI) -- 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 'disability' means, with respect to an individual - (a) a physical or mental impairment that substantially limits one or more of the major life activities of such individual; (b) a record of such an impairment; or (c) being regarded as having such an impairment." [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, movement, manipulation, speech, 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 meaning 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)]

As Defined in the ADA, Section 301(9) -- "The term 'readily achievable' means easily accomplishable and able to be carried out without much difficulty or expense. In determining whether an action is readily achievable, factors to be considered include:

(A) the nature and cost of the action needed under this Act;

(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 resources 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 TAAC interprets the application of the readily achievable criteria in the 1996 Act to be somewhat different from the use of "readily achievable" in the Americans with Disabilities 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 telecommunications equipment and customer premises equipment. The TAAC's recommended guidelines provide more information on how readily achievable should be implemented in practice.

Several factors are important in the determination of whether certain accessibility features are readily achievable. They include the size of the manufacturer and the amount of effort required to implement accessibility and marketability of the resulting product. For instance, implementing certain accessibility features is not readily achievable 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 achievable 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 product's marketability. The Design Process portion of this report will assist in moving these two extremes closer to each other.

Telecommunications -- The term 'telecommunications' means the transmission, between or among points specified by the user, of information of the user's choosing, without change 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 equipment' means equipment, other than customer premise equipment, used by a carrier to provide telecommunications services and includes software integral 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 effectively 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 (telecommunication display devices or 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 feature information, documentation, technical support and delivery in alternate formats or through alternate methods.