36 CFR Parts 1190 and 1191 ADA and ABA Accessibility Guidelines - Preamble (Discussion of Comments and Changes)

Section 707.6 covers input controls, including numeric and function keys.

Comment. The proposed rule required all keys used to operate a machine to be tactually discernable [sic] (707.4.2). It included specifications for key surfaces to be raised 1/25 inch minimum and that outer edges have a radius of 1/50 inch maximum (707.4.2). It also required a minimum separation between keys of c inch and specified a distance between function and numeric keys based on the distance between numeric keys (707.4.3). Comments from industry pointed to these provisions as unduly restrictive and raised questions about supporting data for the specified dimensions. These commenters urged a performance-based requirement as more appropriate.

Response. The Board has revised the final rule to require at least one input control for each function (as opposed to "all keys") to be tactually discernible (707.6.1). Key surfaces are required to be raised from surrounding surfaces, but the proposed 1/25 inch minimum has been removed. In addition, the Board has also added a requirement specific to membrane keys. Such keys must also be tactually discernible from surrounding surfaces and other keys where they are the only method of input provided.

Comment. Comments from persons with disabilities called attention to the importance of access to touch screens at fare machines and ATM machines. The proposed rule provided an exception for the touch screens of video display screens (707.4.2, Exception). This exception was meant to apply only to that method of input, since the Board intended that alternative method of input that is tactually discernible would be provided in addition to the touch screen. Commenters misread this exception as completely exempting touch screens from providing tactually discernible controls.

Response. The Board has removed the exception for touch screens in the proposed rule to avoid misinterpretation of its intent. Instead, the Board has revised the requirement for tactually discernible input controls as applying to those key surfaces that are not on active areas of display screens (707.6.1). All machines with touch screens must have tactually discernible input controls as an additional alternative to those activated by touching the screen.

Comment. The proposed rule specified the arrangement of numeric keys according to the standard 12- key telephone keypad layout, which provides numbers in ascending order (707.4.4). The ATM and banking industries indicated that numbers may be arranged in descending order, similar to the arrangement of numeric keys on standard computer keyboards as required by other national standards, such as those issued in Canada. Since ATM manufacturers operate internationally, consistency with other national standards is a key industry concern.

Response. The final rule requires numeric keys to be arranged in an ascending or descending telephone keypad layout (707.6.2). The number five key is required to be tactually distinct from the other keys (a raised dot is commonly used).

Comment. The proposed rule required function keys to be arranged in a specific order and specified particular tactile symbols and colors for standard keys (707.4.5). Comments from industry opposed the mandate for a particular key arrangement which it considered impractical due to various factors that influence the design and layout of function keys. Further, these commenters questioned the need for such a requirement in view of provisions concerning the tactile labels of keys and audible operating instructions and orientation. In addition, comments noted that the tactile symbol assigned to "clear" or "correct" keys (vertical line or bar) was inconsistent with the symbol specified by Canadian standards (raised left arrow). Response. The Board has removed the requirement for function keys to be arranged in a particular horizontal or vertical order, which it considers unnecessary since such keys are to be labeled by standardized tactile symbols. This revision permits manufacturers flexibility in the design of function key layouts. In addition, the Board has changed the required symbol for "clear" or "correct" keys to a raised left arrow for consistency with Canadian standards (707.6.3.2).

Comment. The Board specified colors for standard function keys in the proposed rule and sought comment on the appropriateness of this specification, particularly for people who are color blind (Question 32). Few comments addressed this question. Instead most commenters pointed out that the specified colors did not correlate with standards used in Canada.

Response. Since many ATM manufacturers operate internationally, the Board has elected to withdraw its color specification for function keys to avoid conflict with other existing national standards.

Comment. ATMs often reject input when maximum time intervals are exceeded. Users are at risk of having the ATM card withheld and may encounter additional transaction charges due to repeated attempts to access the machine. The Board sought comment on whether it should include a specific requirement that would allow users to extend the maximum time intervals between transactions beyond the amount of time typically allotted (Question 33). Commenters from the banking industry and ATM manufacturers noted that ATMs include standard features that ask if users want more time to conduct transactions. The requirements for speech output will ensure that such questions are accessible to users with vision impairments.

Response. The Board has not included a requirement for extending transaction time intervals in view of industry practice.