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Subject Product - Disability Access Analysis

(a) External electronic access to all information and control mechanisms. Information needed for the operation of products (including output, alerts, icons, on-line help, and documentation) shall be available in a standard electronic text format on a cross-industry standard port and all input to and control of a product shall allow for real time operation by electronic text input into a cross-industry standard external port and in cross-industry standard format. The cross-industry standard port shall not require manipulation of a connector by the user.

(b) Connection point for external audio processing devices. Products providing auditory output shall provide the auditory signal at a standard signal level through an industry standard connector.

(c) Compatibility of controls with prosthetics. Touchscreen and touch-operated controls shall be operable without requiring body contact or close body proximity.

(d) TTY connectability. Products 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. It shall also be possible for the user to easily turn any microphone on and off to allow the user to intermix speech with TTY use.

(e) TTY signal compatibility. Products, including those providing voice communication functionality, shall support use of all cross-manufacturer non-proprietary standard signals used by TTYs.

4.4.2. Analysis of the Application of CFR 1193.51

The requirements for compatibility focus on two types of adaptive technology, hearing aids and other assistive listening devices and support for VCO/HCO in conjunction with the use of TTY’s.  Both of these recommendations have been made in previous sections.

5. Recommended Actions

Recommended Actions
Product Specifications


Test the product for hearing aid compatibility, including telecoil compatibility per ANSI C63.19.  Make the resulting category classification available to users in the user documentation.


Determine if additional volume adjustment range, over the +12 dB specified is possible.  If reasonably achievable +20 dB is desirable due to the Section 508 standard.


Investigate the effectiveness of the acoustic coupling to the ear, compare that to competing products and determine if improvement is necessary and if so, achievable.


Determine if the Subject Product product can be used with a TTY to support VCO or HCO.  If so provide user instructions to customer service on what is required to establish such a configuration.


Confirm that the controls meet the 5 lbs. Maximum force requirement and the key repeat, 2 sec. Minimum requirements of 1194.23 (k) (2) and (3).

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