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

Collection of Information: Telecommunications Act Accessibility Guidelines; Annual Reporting Burden

These regulations establish guidelines for accessibility, usability, and compatibility of telecommunications equipment and customer premises equipment covered by the Telecommunications Act of 1996. Based on the comments received in response to the NPRM, the Board has revised its estimates of the public reporting and recordkeeping burden for this collection of information. As revised, the burden is estimated to be 107,982 hours in order for manufacturers of telecommunications equipment and customer premises equipment to provide (1) a description of the accessibility and compatibility features of the equipment on request; (2) the contact method for obtaining information concerning the accessibility and compatibility description of the equipment, alternate formats and customer and technical support for the equipment; and (3) end-user product documentation in alternate formats or alternate modes upon request. Assuming there are 479 manufacturers of telecommunications equipment covered by these guidelines, the annual hour burden averages 225 hours per manufacturer.

The revised estimated burden for manufacturers to incorporate the requested information was calculated as follows:

(1) The annual hour burden associated with providing a description of the accessibility and compatibility features of the equipment on request was calculated to be 29,979 hours as follows:

Responding to requests for information:

Respondents . . . . . . . . 479

Average responses . . . . x 191

Hours per response . . . x .08 (5 minutes)

Annual reporting burden7,319 hours

Alternate formats:

Editorial (reformatting, reading for audio cassette, etc.): 22,500 hours (assuming 5,000 new products are manufactured each year and that the description of accessibility and compatibility features will average three pages that will require an average of 1.5 hours per page of editorial work).

Assuming that an average of 50% of the Braille production is performed in-house and 50% is outsourced, the impact would be 160 hours annually.

(2) The annual hour burden associated with providing the contact method to obtain information concerning the accessibility and compatibility features of the equipment, alternate formats and customer and technical support for the equipment was calculated to be 2,500 hours and was based on the following information: There are approximately 5,000 types of new telecommunications products manufactured each year or 10.44 per manufacturer. The burden in providing a contact method is in the identification of the contact method for each type of product. Once the contact method is established, the time involved in including the contact method in the existing product literature is inconsequential. The burden associated with identifying a contact method for each of the 5,000 types of new products manufactured each year is as follows:

Respondents . . . . . . . . 479

Average responses . . . . x 10.44

Hours per response . . . x .5 (30 minutes)

Annual reporting burden 2,500 hours

(3) The annual hour burden associated with providing end-user documentation in accessible formats on request was calculated to be 75,503 hours as follows:

Responding to requests for information: 0 hours. (Callers requesting alternate format will request a description of accessibility features and end-user documentation in a single call; or, the documentation will be combined in a single document. The hour burden for the request for alternate format is addressed in (1) above.

Alternate formats:

Editorial (reformatting, reading for audio cassette, etc.): 75,000 hours (assuming 5,000 new products are manufactured each year and that the end-user documentation will average ten pages)

Assuming that an average of 50% of the Braille production is performed in-house and 50% is outsourced, the impact would be 503 hours annually.

The information collection requirements contained in § 1193.33 of this final rule have been approved by the Office of Management and Budget (OMB) in accordance with the Paperwork Reduction Act of 1995 (42 U.S.C. 3501 - 3530), and assigned OMB control number 3014-0010. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless the collection displays a valid control number.