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Subject Product - Disability Access Analysis

3.2. 1194.31 – Functional Performance Criteria

3.2.1. Quote from Applicable Sections of CFR 1194.31

(a) At least one mode of operation and information retrieval that does not require user vision shall be provided, or support for assistive technology used by people who are blind or visually impaired shall be provided.

(b) At least one mode of operation and information retrieval that does not require visual acuity greater than 20/70 shall be provided in audio and enlarged print output working together or independently, or support for assistive technology used by people who are visually impaired shall be provided.

(c) At least one mode of operation and information retrieval that does not require user hearing shall be provided, or support for assistive technology used by people who are deaf or hard of hearing shall be provided.

(d) Where audio information is important for the use of a product, at least one mode of operation and information retrieval shall be provided in an enhanced auditory fashion, or support for assistive hearing devices shall be provided.

(e) At least one mode of operation and information retrieval that does not require user speech shall be provided, or support for assistive technology used by people with disabilities shall be provided.

(f) At least one mode of operation and information retrieval that does not require fine motor control or simultaneous actions and that is operable with limited reach and strength shall be provided.

3.2.2. Analysis of the Application of CFR 1194.31

The Functional Performance Criteria, CFR 1194.31, follows the same logic used in the Capabilities Analysis.  CFR 1194.31 sets forth the general performance requirements that at least mode of access be provided for six major categories of function loss:

No Vision

Low Vision

No Hearing

Limited Hearing

No Speech

Limited reach, strength or fine motor control

The capabilities analysis differs only in that it starts with the specific product, the Subject Product product.  An analysis is made of the user capabilities required to operate, transmit and obtain information using the product.  Then accommodations and alternative modes are explored for the capabilities required.  Accordingly the requirements of this section are contained in the Capabilities Analysis.

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