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

Section 1193.41 Input, control, and mechanical functions [1193.35 in the NPRM] (Section-by-Section Analysis)

This section requires product input, control and mechanical functions to be locatable, identifiable, and operable through at least one mode which meets each of the following paragraphs. This means, each of the product's input, control and mechanical functions must be evaluated against each of paragraphs (a) through (i) to ensure that there is at least one mode that meets each of those requirements. Of course, there may be one mode which meets more than one of the specific provisions. This section does not specify how the requirement is to be met but only specifies the outcome. The appendix to this rule contains a set of strategies which may help in developing solutions. In some cases, a particular strategy may be directly applicable while a different strategy may be a useful starting point for further exploration.

Comment. A few commenters said that it was not clear whether a single mode was to meet all of the paragraphs in this section or whether one mode was to meet paragraph (a), one mode was to meet paragraph (b), and so forth.

Response. In an effort to reduce the redundant language in the TAAC report, confusion may have been created in the NPRM. Therefore, the phrase "at least one mode" has been removed from the overall charging statement and instead repeated in the individual paragraphs. Some additional language has also been provided to clarify that each of the paragraphs (a) through (i) are to be satisfied independently. That is, it may be readily achievable to satisfy (a), (c), and (g), for example, but none of the others. Again, one mode may be able to satisfy more than one paragraph.

Paragraph (a) Operable without vision (Section-by-Section Analysis)

No substantive comments were received on this paragraph and no changes were made, other than the editorial changes mentioned in the opening paragraph of this section.

Paragraph (b) Operable with low vision and limited or no hearing (Section-by-Section Analysis)

Comment. The Trace Center suggested that both the upper and lower limits for low vision be included and that the paragraph title be amended to include the restriction on audio output.

Response. The provision has been modified accordingly.

Paragraph (c) Operable with little or no color perception (Section-by-Section Analysis)

No substantive comments were received on this paragraph and no changes were made, other than the editorial changes mentioned in the opening paragraph of this section.

Paragraph (d) Operable without hearing (Section-by-Section Analysis)

No substantive comments were received on this paragraph and no changes were made, other than the editorial changes mentioned in the opening paragraph of this section.

Paragraph (e) Operable with limited manual dexterity (Section-by-Section Analysis)

No substantive comments were received on this paragraph and no changes were made, other than the editorial changes mentioned in the opening paragraph of this section.

Paragraph (f) Operable with limited reach and strength (Section-by-Section Analysis)

Comment. In the NPRM the Board had asked (Question 6) whether the ADAAG provisions for controls and operating mechanisms and reach ranges should be included here. The few comments on this issue felt those provisions might be too specific for these guidelines.

Response. The ADAAG provisions have not been added to these paragraphs but have been included in the appendix for reference, with the notation that some customer premises equipment might be covered by the ADA and required to comply with ADAAG.

Paragraph (g) Operable without time-dependent controls (Section-by-Section Analysis)

Comment. The NPRM had proposed a three-second time limit. A few comments suggested a single number was not appropriate for different actions and that more research is needed before applying a specific time limit.

Response. The specific time limit has been removed and the more general performance language from the TAAC report substituted. Some of the discussion on this subject provided by the Trace Center has been included in the appendix.

Paragraph (h) Operable without speech (Section-by-Section Analysis)

No substantive comments were received on this paragraph and no changes were made, other than the editorial changes mentioned in the opening paragraph of this section.

Paragraph (i) Operable with limited cognitive skills (Section-by-Section Analysis)

No substantive comments were received on this paragraph and no changes were made, other than the editorial changes mentioned in the opening paragraph of this section.