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Subject Product - Disability Access Analysis

(g) Operable without time-dependent controls. Provide at least one mode that does not require a response time. Alternatively, a response time may be required if it can be by-passed or adjusted by the user over a wide range.

(h) Operable without speech. Provide at least one mode that does not require user speech.

(i) Operable with limited cognitive skills. Provide at least one mode that minimizes the cognitive, memory, language, and learning skills required of the user.

4.2.2. Analysis of the Application of CFR 1193.41

The organization and logic used in this section and in 1193.43 are very similar to that used in 1194.31 and in the Capabilities Analysis earlier in this report.  However, it is interesting that the Access Board utilized nine categories in these guidelines, written several years before the Section 508 standards, and only six in the newly released standards for 508.  The following table illustrates the differences:

Section 255 Guidelines 36 CFR 1194.31

Section 508 Standards

36 CFR 1193.41 & 1193.43

No Vision

No Vision

Low Vision

Low Vision & Limited or No Hearing

No Color Perception

No Hearing

No Hearing

Limited Hearing

No Speech

No Speech

Limited reach, strength or fine motor control

Limited Manual Dexterity

Limited Reach and Strength

No Time-Dependent Controls

Limited Cognitive Skills

The differences in categories show the developing understanding at the Access Board as they transition from dealing with architectural barriers in the built environment, their traditional role, to dealing with telecommunications and information technology.  The requirements are becoming more specific, objective and defined and this trend is likely to continue over time.

Because the fundamental logic of sections 1193.41, 1193.43 and the Capabilities Analysis are the same, the recommendations developed in that section cover the requirements of sections 1193.41 and 1193.43.

4.3. CFR 1193.43 – Output, Display, and Control Functions

4.3.1. Quote from Applicable Sections of CFR 1193.43

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