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Telecommunications Products
(1194.23)
Updated: June 21, 2001
How does section 508 relate to the Telecommunications
Act?
Section 255 of the Telecommunications Act of
1996 requires phone manufacturers and telecommunications service
providers to make their products accessible when readily achievable
to do so. A TTY, for example, is considered customer premises equipment,
subject to section 255 provisions. The Access Board wrote guidelines
for section 255 known as the Telecommunications
Act Accessibility Guidelines (36 CFR, Part 1193). The FCC
(Federal Communications Commission) used the guidelines as a basis
for developing a report
and order under section 255. The Access Board also incorporated
the guidelineâs language in the 508 standard. Using consistent language
in both documents enables companies to develop products that satisfy
manufactureâs design requirements as well as Federal agenciesâ procurement
requirements.
(a) Telecommunications
products or systems which provide a function allowing voice communication
and which do not themselves provide a TTY functionality shall provide
a standard non-acoustic connection point for TTYs. Microphones shall
be capable of being turned on and off to allow the user to intermix
speech with TTY use.
What is a TTY?
A TTY (Teletypewriter) is a data terminal that allows a person
with a communication disability to use the telephone. TTYs traditionally
have been stand-alone devices with a keyboard and an electronic display
for reading text. TTYs send and receive tones which are converted
to text. TTYs transmit and receive baudot code at a rate of 45.5 baud.
Baudot refers to the code made from bits of electronic information.
Baudot is considered to be an antiquated code. Baud refers to the
speed at which data can be transmitted. Some TTYs may transmit at
a faster speed using proprietary protocols or ASCII. ASCII (American
Standard Code for Information Interchange) is a more conventional
code, commonly used by computers and other devices that transmit data.
It is possible to enable some computers to function as TTYs if appropriate
communication software (and sometimes a different modem) is installed.
Some TTYs can connect directly to the phone or phone line, thus reducing
the possibility of noise interfering with the data. Depending on the
type of phone, a TTY might connect via a standard RJ-11 phone jack
or a 2.5 mm audio jack. A variety of TTY styles exist that include
models without acoustic coupling ability and models without keyboards.
People select and use TTYs differently depending on their communication
preferences and the nature of their disabilities. Basic information
on how to use a TTY can be obtained here.
What is VCO and HCO?
VCO is "voice carry over" and HCO is "hearing carry over". These
terms refer to strategies for using TTYs. VCO allows people who are
hard of hearing or oral deaf (deaf with intelligible speech) to use
a TTY without typing. They only use the TTY for reading during the
inbound direction of the call. They talk to their party by speaking
into a microphone. Similarly, HCO allows a person with a speech disability
to hear a response from their party directly. These options are often
used in conjunction with a relay service.
 What
is a relay service?
A telecommunications relay service (TRS) is essentially a telephone
interpreting service for people with communication disabilities. It
enables a TTY user to converse with a non-TTY user. Relay service
operators are called Communication Assistants (CAs) and serve as third
parties to facilitate conversations - by typing or speaking information
as appropriate. Relay services are available without charge 24 hours
per day. These and other TRS provisions are mandated under Title IV
of the Americans with Disabilities Act. An FCC report
and order mandates 7-1-1 as a toll-free number to use in accessing
a relay service. The Federal Relay Service
is one of several relay services available throughout the country.
Why is a non-acoustic connection point needed for TTYs?
Traditionally, people with communication disabilities used a TTY
by placing a telephone handset in an acoustic modem on top of the
TTY. Some manufacturers reduced the size of their TTY by removing
the acoustic modem, thus requiring the TTY to connect directly to
a telephone or wall jack. Therefore, if a new phone system has hardwired
cords with no port for direct connection, then a direct connect TTY
cannot be used at that phone and the phone will be considered non-conforming
with this section 508 provision.
Why must phone systems be capable of intermixing speech and TTY tones
and why must users be able to turn microphones on and off?
This provision supports VCO and HCO. People with communication
disabilities have reported instances in which they connected a TTY
to a cellular phone, which resulted in a deactivation of the telephoneâs
microphone. In those cases, there was no way to talk into the phone
(no way to turn the microphone on). This is frustrating to people
with a hearing disability and intelligible speech who prefer to talk
instead of type.
People who are deaf and use the TTY for both typing as well as reading
would have less of a problem with a connection that disables the microphone.
However, even they would be concerned if the phone was disabled to
a point where it was unable to transmit tones for responding to interactive
telephone response systems. TTY signals are not the same as "touch
tone" sounds, and some TTYs may not readily make the necessary tones.
On the other extreme, some TTY-phone set-ups keep a microphone on
throughout the entire conversation (never toggling it off). This can
cause a problem if the microphone picks up extraneous noise during
the data reception mode and results in errors.
Do TTYs work with digital phones?
At this time, TTYs do not work reliably
with most digital cellular phones. The industry is working
toward a solution on this matter through an FCC
order which set a deadline of June 30, 2002 for wireless providers
to be able to transmit 911 calls made from TTYs.
 With regard to landline phones, most digital phones from offices or hotels
will transmit TTY signals. If a TTY is use in an acoustic mode, then
it does not matter whether it is being used with analog or digital
phones. However, direct-connect TTYs should only be connected to analog
phones to prevent damage to the TTYs. TTYs use analog plugs. Users
may experience some confusion in determining whether a phone is analog
or digital because of variances in the jacks. Digital jacks are often
larger than standard RJ-11 analog plugs, but sometimes they are the
same size. Finally, it is important that digital systems enable TTY
signals to come out of the system undistorted if signals are compressed
along the way.
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(b) Telecommunications products which include voice
communication functionality shall support all commonly used cross-manufacturer
non-proprietary standard TTY signal protocols.
How might telephone systems affect TTY signals?
Some systems compress or alter transmissions, including TTY audio
signals, in such a manner that the signals are not decoded properly.
This provision is consistent with language in the Telecommunications
Act Accessibility Guidelines.
What communication protocols are used by TTYs?
TTYs transmit in Baudot code at a rate of 45.5 baud. Products
would need to match this protocol to be considered "TTY compatible."
A standard was published for TTYs on June 23, 2000, which is available
from the Telecommunications
Industry Association. Under 508, this is the protocol
which must be retained as TTY signals pass through phone systems.
Some TTYs also include the optional ability to connect at a rate of
300 baud ASCII, which enables them to communicate with some computers
or other TTYs with the same protocol. These two codes (300 baud ASCII
and 45.5 baud Baudot) are considered non-proprietary. Equipment that
contains a v.18 chip will enable transmission in many protocols including
these two. That chip is based on an international
standard.
Some TTY manufacturers developed proprietary protocols that enable
TTYs to communicate in Baudot at a higher rate. TTY users will see
a benefit in using proprietary protocols only when communicating with
other users who have products with the same protocol. The 508 standard
does not require support for proprietary protocols.
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(c) Voice mail, auto-attendant, and interactive
voice response telecommunications systems shall be usable by TTY users
with their TTYs.
 What difficulties have TTY experienced with interactive voice
response systems (IVRSs)?
IVRSs include a variety of systems such as voice mail, recordings
that require selecting a department you wish to connect to and job
line announcements. Due to a hearing disability, many TTY users cannot
understand prompts indicating which phone buttons to push when encountering
IVRSs. Often when calling through relay services, TTY users are not
given enough time to respond and get timed-out by the IVRS. Auditory
information when typed to a TTY user via relay may not include necessary
spacing or punctuation to help a consumer understand sections of what
is being conveyed. TTY users have discovered that some voice mail
systems corrupt TTY data left in voice mail boxes.
What does this provision require?
This provision is a performance requirement. It does not require
phone systems to provide voice to text conversion capabilities. IVRS
products have been available for over a decade which provide TTY users
all of the same functions and information as non-TTY users, such as
reading streaming text, leaving messages, and managing personal voice
mail. This software should not be confused with other software on
the market that is designed to allow computers to transmit and receive
TTY code for live communication.
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(d) Voice mail, messaging, auto-attendant, and
interactive voice response telecommunications systems that require
a response from a user within a time interval, shall give an alert
when the time interval is about to run out, and shall provide sufficient
time for the user to indicate more time is required.
Why is an alert necessary?
This provision was included to serve the needs of people, such
as those with cognitive or dexterity disabilities, who may require
additional time to respond to the prompts of an interactive telephone
response system in order to avoid getting disconnected prematurely.
The provision does not specify what the alert could sound like or
exactly how much additional time would be sufficient, as those factors
vary. This provision is identical to section 1194.22(p).
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(e) Where provided, caller identification
and similar telecommunications functions shall also be available for
users of TTYs, and for users who cannot see displays.
 What types of challenges have people with disabilities experienced
with information displayed on phones?
Some phones have an LCD (liquid crystal display) window that shows
Caller ID or other functions of the phone. People with visual or other
disabilities may be unable to read the display. Talking Caller ID
would be one means of making that information available in an alternate
format.
Receiving this information has been a problem in the past for TTY
users who were forced to use an analog phone and line that bypassed
the office digital system. This will no longer be a problem with new
508 compliant systems that will support TTY requirements.
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(f) For transmitted voice signals, telecommunications
products shall provide a gain adjustable up to a minimum of 20 dB.
For incremental volume control, at least one intermediate step of
12 dB of gain shall be provided.
How are volume controls affected by this provision?
If a volume control (usually a calibrated wheel or slide) is provided
that allows a user to set the level anywhere from 0 to the upper requirement
of 20 dB, there is no need to specify an intermediate level. If a
stepped volume control is provided (usually through pressing a button
repeatedly), one of the intermediate levels must provide 12 dB of
gain.
How is this provision related to ANSI standards and ADA Accessibility
Guidelines?
This provision is consistent with the 1998 American National Standards Institute (ANSI)
A117.1 document, "Accessible and Usable Buildings and Facilities."
ANSI is a voluntary standard-setting body which issues accessibility
standards that become incorporated into the nation's model building
codes. This standard is consistent with the Telecommunications Act
Accessibility Guidelines and proposed revisions to the ADA and Architectural
Barriers Act Accessibility Revised Guidelines.
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(g) If the telecommunications product allows a
user to adjust the receive volume, a function shall be provided to
automatically reset the volume to the default level after every use.
Why is this provision necessary?
This is a safety feature to protect people from damaging their
hearing, which might occur if they answer a telephone with the amplification
accidentally turned too high.
How does it relate to other accessibility guidelines and rules?
The provision is adopted from the ADA Accessibility Guidelines
(ADAAG), where it applies to public phones used by many people. The
FCC's Part 68 rules requires an automatic reset when the phone is
hung up if the volume exceeds 18 dB gain. To provide the ability to
override the reset function would require a waiver from the FCC.
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(h) Where a telecommunications product delivers
output by an audio transducer which is normally held up to the ear,
a means for effective magnetic wireless coupling to hearing technologies
shall be provided.
 What is hearing aid compatibility (HAC)?
HAC commonly refers to magnetic leakage around a telephone receiver.
Hearing aid users desire a phone that emits such a magnetic field
because it enables them to listen through a phone handset held up
to their ear without getting an annoying squealing sound (acoustic
feedback). They accomplish this by turning off their hearing aid microphone
and listening "inductively" (via magnetism).
Who benefits from products with wireless magnetic coupling?
Hearing aid users (and their representative associations) have
been the primary advocates for hearing aid compatibility and are the
most common beneficiaries. However, only hearing aids with a telecoil,
also known as a t-coil or telephone switch, can pick-up sound inductively.
In addition, cochlear implant users, who have an optional t-coil inserted
in an ear-level speech processor, can listen inductively.
What types of products can be made hearing aid compatible?
In addition to HAC telephone handsets, HAC telephone headsets
are now available. Note that this provision does not require a product
to fit comfortably, nor does it address the problem of interference
to hearing aids. (People with over-the-ear hearing aids often find
that headsets do not direct sound into their hearing aid very well,
even if the headset is HAC.)
How does this 508 provision relate to other public policies?
This standard is consistent with language in the Telecommunications Act
Accessibility Guidelines.
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(i) Interference to hearing technologies (including
hearing aids, cochlear implants, and assistive listening devices)
shall be reduced to the lowest possible level that allows a user of
hearing technologies to utilize the telecommunications product.
Why is this provision necessary?
This provision largely grew out of complaints about digital cellular
phones by hearing aid users. Some hearing aid users heard a humming
sound coming from the phone and this interfered with the ability to
hear the conversation. This problem existed for both hearing aid users
with t-coils as well as those without t-coils. See discussion of provision
(h) (previous) for an explanation of a t-coil.
Who and what does the provision apply to?
This provision was carefully worded so that it could apply to
listening technologies other than hearing aids, such as cochlear implants
and assistive listening systems. In addition, although digital cellular
phones were identified as one source of interference, there may be
other electronic and information technologies that cause interference.
How can interference be determined?
The ANSI/IEEE C63.19 Standard, available from the American National Standards Institute, can
be used to assess electromagnetic characteristics of hearing aids
and wireless phones for the purpose of determining compatibility.
The FCC, consumer groups and the telecommunications industry are now
discussing plans for educating the public about this cell phone/hearing
aid compatibility standard.
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(j) Products that transmit or conduct information
or communication, shall pass through cross-manufacturer, non-proprietary,
industry-standard codes, translation protocols, formats or other information
necessary to provide the information or communication in a usable
format. Technologies which use encoding, signal compression, format
transformation, or similar techniques shall not remove information
needed for access or shall restore it upon delivery.
What types of products does this provision apply to?
This provision applies to any technologies involved with the transmission
of information, such as televisions and DVD players. People who depend
on closed captioning discovered that sometimes they would miss captions
if they saw a show on cable as opposed to receiving the same show
through other broadcast modes. Closed captioned information is usually
included in portions of a video signal not seen by users without decoders
or who have turned off or disabled the captioning. This issue applies
to retaining audio description information as well. This provision
prohibits products from stripping out such information or requires
the information to be restored at the end point. The provision was
written broadly enough to ensure that it will apply to evolving technologies.
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(k) Products which have mechanically operated controls
or keys, shall comply with the following:
(1) Controls and keys shall be tactilely discernible without
activating the controls or keys.
(2) Controls and keys shall be operable with one hand and shall
not require tight grasping, pinching, or twisting of the wrist.
The force required to activate controls and keys shall be 5 lbs.
(22.2 N) maximum.
(3) If key repeat is supported, the delay before repeat shall be
adjustable to at least 2 seconds. Key repeat rate shall be adjustable
to 2 seconds per character.
(4) The status of all locking or toggle controls or keys shall be
visually discernible, and discernible either through touch or sound.
What products are generally covered under this provision?
This provision only applies to products that have mechanically
operated controls or keys, such as standard telephone keypads and
computer keyboards. It is not intended to apply to touchscreens.
What is meant by 'tactilely discernible'?
Individual keys must be identifiable and distinguishable from
adjacent keys by touch. Compliance with this provision can be accomplished
by using various shapes, spacing, or tactile markings. The normal
desktop computer keyboard, for example, would meet this provision
because the tactile marks on the "j" and "f" keys permit a user to
locate all other keys tactilely. Many phones also have a raised dot
on the number 5 button, enabling them to orient their fingers around
the 12 keys. In addition, the physical spacing of the function, "numpad"
and cursor keys make them easy to locate by touch.
Because touch is necessary to discern tactile features, this provision
requires keyboards to enable touch that does not automatically activate
a function based on mere contact. Fortunately most keyboards require
some pressure on individual keys in order to enable a keystroke.
However, "capacitance" keyboards would not meet this provision because
they react as soon as they are touched and have no raised marks or
actual keys. They may not react at all when touched by persons with
prostheses. A "membrane" keypad with keys that must be pressed can
be made tactilely discernible by separating keys with raised ridges
so that individual keys can be distinguished by touch.
What is meant by "status of controls" and why do people need that
information?
This provision requires the status of toggle controls, such as
the "caps lock" or "scroll lock" keys to be identifiable by either
touch or sound, in addition to visual means. For example, adding audio
patterns, such as ascending and descending pitch tones that indicate
when a control is turned on or off, would alleviate the problem of
a person who is blind inadvertently pressing the locking or toggle
controls. Also, buttons which remain depressed when activated and
switched with distinct positions may meet this provision.
What does "key repeat" mean?
This provision addresses a challenge encountered by some people
with fine motor coordination difficulty. Sometimes they accidentally
press a key several times when intending to hit it only once. This
could potentially result in the same character displaying several
times on the screen. Some systems do not support key repeat. However,
where key repeat is provided, this provision requires the repeat to
be adjustable. Specifically, the delay must be adjustable for a length
of time that is no greater than 2 seconds between repeats.
How will individuals with disabilities benefit from the requirement
enabling operability without tight grasping, pinching, twisting or
pressure?
Individuals with tremor, cerebral palsy, or other disabilities
may have difficulty operating systems which require fine motor control,
a steady hand, or two hands to be used simultaneously for operation.
Individuals with high spinal cord injuries, arthritis, and other conditions
may have difficulty operating controls which require significant strength.
The standard limits the force required to five pounds and is based
on section 4.27.4 of the ADA Accessibility Guidelines,
codified as the ADA Standards for Accessible
Design as part of the Department of Justiceâs regulation implementing
title III of the ADA at 28 C.F.R. pt. 36, Appendix A. This provision
is also consistent with the Telecommunications
Act Accessibility Guidelines.
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