9-1.2 Summary

9-1.2.1 Technology

The term “self–contained” is used to define a class of information technology. Unlike personal computers, which can have assistive technology installed, closed products can be accessible only if they have been designed to be accessible by people with limited vision, mobility, or hearing.

The requirements in this chapter cover the following:

  • Any products or systems that do not permit end–user–installed assistive technologies. Such products often involve input and output interactions that present accessibility challenges (e.g., touch screens, physical layout/positioning). Unlike personal, customizable devices, many products in this class of technology (kiosks, shared printers) are used by the general public.
  • Since they cannot be customized, such closed products must be designed with the needed accessibility features for all users.
  • Given the functional disabilities of mobility, hearing, speech, and vision, Subpart C (Functional Performance Criteria) defines the general goal for all closed products as follows: At least one mode of operation and information retrieval must be usable by a user with a disability.
  • For self–contained, closed products to be accessible to blind people, the law specifies audio output will be provided to an external headset jack. Provision (a) clarifies that “personal headsets for private listening are not assistive technology.”
  • The following types of devices are named in the law:
    • Information kiosks and information transaction machines: Equipment used by the public to transact business without personal interaction. The classic example of an information transaction machine is an ATM (automated [bank] teller machine). Banks have made considerable progress, resulting from ADA legislation and consequent lawsuits, in making ATM machines reasonably accessible.
    • Copiers: Although early designs of copiers were primarily devices without electronic sophistication, newer designs often contain higher degrees of functionality, such as the ability to interface with desktop computers that can be made universally accessible.
    • Printers: Like copiers, printers have extensive functions - many of which can be accessed by standard control panels displayed and updated from personal computers. To the extent that the control panels follow the standards described in Chapter 5, Software Applications and Operating Systems, these devices may be fully compliant.
    • Calculators: Although most calculator functions are an integral part of PC application software and governed by the standards described in Chapter 5, Software Applications and Operating Systems, accessible calculators usable by people with disabilities can be acquired. Specialized procurement for a specific accommodation of an employee is a 504 solution rather than a 508 compliance decision. Information on possible alternate formats or modes can be noted when a non–accessible EIT purchase is made. For more information, see the FAQ on accessible calculators at Tech Connections (http://www.techconnections.org/resources/guides/ Calculators.cfm).
    • Fax machines: Like copiers, fax machines have extensive functions - many of which can be accessed from standard control panels displayed and updated from personal computers. To the extent that the control panels follow the standards described in Chapter 5, Software Applications and Operating Systems, these devices may be fully compliant. It should be noted that many fax machines also support of telecommunications functions - that is, the ability to use an attached handset for a traditional voice call. When this functionality is present, the requirements in chapter 5 also apply.
    • Similar types of electronic office equipment: The law states that this standard applies to, but is not limited to, the above listed devices. At the time of the drafting of the 508 standards, Personal Data Assistants (PDA devices) were, functionally, closed products - and were included in many discussions of the provisions in this chapter. According the questions and answers page on the GSA's Section 508 Web site: “This technology is ‘electronic and information technology' covered by Section 508 and the Access Board's standards. Most hand held devices currently fall in the category of ‘self contained closed products.' As technology advances, hand held devices may fall into other categories as well.”
      PDA devices: These devices, if they do not permit additional functions to be added, are closed products. PDA devices that can be modified (software development kit utilities enable the creation of new applications that run under a defined operating system), come under the standard for software applications and operating systems discussed in chapter 5. To the extent that a PDA has telecommunications functions, it comes under the standard discussed in Chapter 7, Telecommunications Products.

This standard in this chapter, 1194.25, covers a single class of technology: technology that is closed to the installation of software that can enable access. The provisions in this standard apply to a single device, devices that represent the convergence of multiple standards (e.g., a fax machine that supports voice communications), or to self–contained devices within a complex systems.

9-1.2.2 Audience

This chapter applies to anyone who buys or develops self–contained, closed products or systems for the Postal Service (i.e., Postal Service employees, suppliers, contractors, and business partners).