36 CFR Part 1193 Telecommunications Act (Section 255) Accessibility Guidelines - Preamble

Section 1193.35 Redundancy and Selectability [1193.33 in the NPRM] (Section-by-Section Analysis)

This section proposed that products incorporate multiple modes for input and output functions and that the user be able to select the desired mode.

Comment. Manufacturers objected to this provision on the basis that it added unnecessary and potentially unwanted functions to a product which could affect its marketability and even result in a "fundamental alteration" of the product. It would also, in their view, cause the product to be too complicated.

Response. Although this provision was supported by persons with disabilities, it may run contrary to section 1193.41 (i), which intends to make products accessible to persons with limited cognitive skills. As a result, the provision is being reserved at this time, with a recommendation for redundancy and selectability placed in the appendix. The Board intends to consider this provision further and highlight it for evaluation in its market monitoring report. If the Board's market monitoring report shows that redundancy and selectability can be provided without unnecessary complexity, it will re-evaluate the "reserved" status of this provision.