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Subject Product - Disability Access Analysis

1. Introduction

This report analyzes the Subject Product for accessibility and disability access issues.  The Subject Product is assumed to be a telephone accessory device, such as a headset or handsfree accessory.  

The report is divided into three sections.  The first, and most important, section presents a Capabilities Analysis of the Subject Product product.  It asks the question, “What capabilities must a user have to effectively use this product?”  It then analyzes the possibility of alternative means should a user be limited in one or more of these capacities.  The second and third sections provide a compliance analysis against the specific requirements of Section 508 and 255.  These sections ask and answer the question, “How would this product be evaluated against the specific requirements of Section 508 or Section 255?”1    

2. Capabilities Analysis

2.1. Product Control & User Interface

The Subject Product is controlled entirely through manual manipulation.  To use the product the user must be able to locate the product, access the receiver, locate and control the keypad.  All information is auditory.  To effective use this product issues of locating controls and manipulation will be of primary interest.

2.2. Information Delivery

The Subject Product is intended to receive and deliver auditory information.  Its single purpose is to receive and deliver speech.  Accordingly it primarily relies upon the user’s ability to hear and speak.  It follows that the primary accessibility issues for the Subject Product deal with accommodations for people with hearing loss or deafness and speech limitations.

2.3. Setup, Use and Maintenance

Some manipulation is required to setup the product for use.  Once in use, with volume set to the user’s preference, further manipulation of the product is not required.  Thus user-initiated actions are infrequent and are generally associated with power up/call initiation and call termination/power down.  Additional manipulation is required to connect the battery charger and to change batteries in the product.  Issues of manipulation will be analyzed in connection with donning and doffing the product and charging the batteries.

A single LED for the battery charging state is the only visual indication on the product.  Thus issues of vision loss are minimal with this product.

1 There is other legislation dealing with disability access.  As the focus of this report is the Subject Product only those regulations that are most relevant are discussed.  Perhaps the most obvious omission is that the requirements of the 1988 Hearing Aid Compatibility Act (HAC Act) are not mentioned.  The HAC Act is the basis for the FCC’s requirements of volume control and telecoil compatibility.  However, these requirements as they apply are dealt with more specifically in ANSI C63.19 and the Section 255 and 508 regulations.  So a separate discussion of the HAC Act is not presented but is subsumed in the discussion of those requirements.

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