2004 Conference Proceedings

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TELECOMMUNICATIONS PRODUCT ACCESSIBILITY IN LIGHT OF SECTIONS 255 AND 508

Presenters
By David Baquis
Accessibility Specialist,
U.S. Access Board
1331 F Street, NW
Suite 1000
Washington, DC 20004
Telephone: 202 272 0013 (voice)
Email: baquis@access-board.gov

Background

Telecommunications refers to a wide variety of products and services. It includes simple consumer products to complex systems for organizations and businesses. Examples include wireless and wireline telephones; interactive voice response systems (IVRs), local and long distance phone services and pagers.

In addition, the field is increasingly complex because of convergence, which is a term that refers to the blended design of more than one category of technology. For example, a handheld PDA (personal digital assistant) might possibly function as a cellular phone depending upon its features, but until recent years, people did not normally think of PDAs as possible telecommunications products.

The field can be especially perplexing to new stakeholders learning about relationships between computers, office networks and telephone systems because much of that technology happens "behind the scenes" and seems transparent amd "too technical" to the average user. However, if one of those "invisible" products poses an accessibility barrier to a user with a disability, then the product is often brought to light for better understanding by all affected parties. Those are the types of stories which have driven the need to develop government regulations for accessibility.

Often when the subject of telecommunications for people with disabilities arises, people think of products such as TTYs and amplification telephones for people with communication disabilities; handset rests for people with poor strength in their arms; voice dialers for people with cognitive disabilities; special transmission handsets for people with weak speech, and a hundred other products that we would call "assistive or adaptive telecommunications technologies". Those products are also known as "accommodations".

Accommodations interoperate with accessible mainstream telecommunications products but are generally thought of as a separate subject. This is an area of frequent confusion and often missed in training programs. However, accommodation products and accessible mainstream products complement one another. A direct connect TTY, for example, would be an accommodation. The phone system jack, whether it is located in the wall, computer or phone, would be the accessibility feature. The problem in the past was that a user might receive a direct-connect TTY from his or her employer only to later discover that there was no phone jack to plug the TTY into. Accessibility and accommodations are both important and work together just as wheelchairs and wheelchair ramps can be designed to operate compatibly.

This presentation focuses on accessibility requirements, which are often overlooked. Accessibility Guidelines for telecommunication products were issued by the Access Board and incorporated (with some exceptions) into an FCC (Federal Telecommunications Commission) rule, thus making the requirement enforceable under Section 255 of the Telecommunications Act. A different law, Section 508 of the Rehabilitation Act, requires federal agencies to consider Standards issued by the Access Board when procuring, developing, using or maintaining electronic and information technology (E&IT), including telecommunications items.

These two laws work in concert to promote accessible design. In economic terms, it is thought of as a push/pull phenomenon. Section 255 is a requirement of telecommunications manufacturers and service providers to design products to be accessible, when readily achievable to do so. So Section 255 helps "push" accessible telecommunications products into the marketplace. Section 508 requires federal agencies to consider the Section 508 Standard when procuring telecommunications products (among other types of E&IT). So Section 508 serves as a "pull" to provide the telecommunications industry an incentive to design their products accessibly in order to meet the requirements for accessibility that Federal agencies put out in their RFPs (Requests for Proposals). The Federal government spends billions of dollars on E&IT each year and telecommunications vendors want to remain competitive.

Examples of Accessible Design

Designing telecommunications products to be accessible (as well as usable) benefits people with a wide variety of disabilities. The following are some examples:

Telecommunications Company Process Requirements

One important distinction to understand between 255 and 508 is the requirements for specific company processes under Section 255. The 255 requirements extend beyond guidelines for accessible product design. The FCC rule also requires telecommunications manufacturers and service providers to communicate with disability organizations, consider accessibility in all phases of their product design processes, and to include people with disabilities in both the testing and marketing of their products.

Where To Go From Here?

A major outreach thrust is necessary to raise awareness about accessibility to end users. At this point, consumers seem primarily focused on accommodations and do not understand many of the features designed in mainstream technologies for their benefit. They might not know, for example, that they have a right to accessible text font size on the screen of their cellular phone. First, consumers should be educated on accessibility features already available in the marketplace because sometimes they make poor selections among their choices at the time of purchase. These buyers, of course, include private businesses, educational institutions and governments - just to name a few, not just end- users. Second, end users with disabilities need to know their rights and the procedures for filing complaints. Both 255 and 508 are consumer driven. If consumers don't file complaints, then some products may not receive a degree of attention that is sufficient for developing an accessible solution.

It is important that all stakeholders get involved with planning accessibility. Industry awareness is greater now than ever in the past. Nevertheless, it is not unusual for new technologies to be released into the marketplace that were not designed with full accessibility. One well known example is voicemail that was in general use for years before manufacturers implemented TTY accessibility solutions. A more recent example is VoIP (Voice over Internet Protocol) communication systems that are unable to transmit TTY tones reliably. Fortunately, the industry is rapidly working toward a solution for that problem.


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