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

Comment. Section 707 specifically covers ATMs and fare machines. In the proposed rule, the Board sought comment on whether this section should be extended to cover other types of interactive transaction machines (ITMs), such as point-of-sale machines and information kiosks, among others (Question 31). Information was requested on any possible design conflicts between the requirements of this section and any specific types of interactive transaction machines. Comments from disability groups and individuals with disabilities generally supported coverage of ITMs and point-of-sale machines. Most industry commenters opposed such an expansion since, in their opinion, such devices differ in structure and use from ATMs. Comments noted that computers used in point-of-sale machines rarely have the capacity for added functions, especially for speech. Commenters were particularly concerned that manufacturers, installers, and property owners would be held responsible for the content of web-based dynamic information. Several suggested that unlike ATMs, which are considered primarily single-purpose devices, information kiosks are multi-purpose devices that cannot produce audio files anticipating the content of the video display.

Response. The Board has elected not to broaden the scope of the rule to address all types of interactive transaction machines at this time. However, the Board has issued standards covering various types of electronic and information technology purchased by the Federal government under section 508 of the Rehabilitation Act. These standards encompass various types of interactive transaction machines that are procured by the Federal government. The Board intends to monitor the application of the performance-based section 508 standards to ITMs in the Federal sector for its consideration in future updates of these guidelines.

Revisions made to this section include:

• revising exceptions for drive-up ATMs to also cover drive-up fare machines (707.2, 707.3, and 707.7)

• modifying specifications for operable parts (707.3)

• limiting privacy requirements to ATMs (707.4)

• revamping and clarifying speech output capabilities and specifications (707.5)

• modifying specifications for input controls (707.6)

• adding a requirement for braille instructions (707.8)