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Subject Product - Disability Access Analysis

and a category system, which rate wireless devices for use with hearing aids.  For a wireless device, tests for RF interference potential and telecoil compatibility are required.  The use of ANSI C63.19 will add clarity to the exact requirement intended in Section B.Y.Z, “Hearing aid compatible with telecoil”

Recommended Action: It is recommended that the final product be tested to the ANSI C63.19 standard and the resulting category be provided in the user literature.  Given the nature of the product, this is the single most important accessibility provision for this product.

2.4.2. Accessibility for Deafness

The accommodation for deafness in telephony is provided by the use of two-way text messaging, commonly referred to as TTY.  A deaf user would not use the Subject Product but rather connect their TTY device directly to the telephone.  However, some users use the TTY to accommodate their hearing or speech disability but use their corresponding capability for communication in the other direction.  So a deaf user who can speak may only use the TTY to receive communication but speak the reply.  Alternately, a person with normal hearing but a speech disability may listen to a conversation but use the TTY to send their reply.  This kind of use is known as Voice Carry Over (VCO) or Hearing Carry Over (HCO).  In this scenario the Subject Product could be used to carry one portion of the conversation and a TTY connected to the AG would carry the other.  

Recommended Action: An analysis should be performed to determine if the Subject Product would support such use and if so what instructions are required to guide a user in establishing a VCO or HCO communication.  It may be that this analysis or testing may be most effectively done in partnership with a trusted client company since the ability to establish the desired configuration is likely to require correct configuration of the Subject Product product, its host device and the TTY equipment.

2.4.3. Accessibility for Speech Limitations

The Subject Product is intended to take information from the user primarily through speech.  Through the use of voice recognition, speech control is supported.  However, since the voice recognition software is not provided with the product, its ability to adapt to variation in speech ability cannot be evaluated as part of the Subject Product.  The only accommodation for speech disabilities that the Subject Product can make is to provide quality audio transmission.

People with sever speech limitations commonly use TTY devices or speech synthesizers to communicate. The use of the Subject Product would not apply directly to these situations.  However, the Subject Product potentially could be used to support a VCO/HCO TTY call, as discussed in the previous section.

2.4.4. Accessibility for Vision Loss & Blindness

Vision is only relevant to the donning or doffing of this product and to check the battery charge status.  The requirement that the product meet the don/doff “eyes-closed” test is a positive accommodation for issues of vision and blindness.  It appears that connecting Thunder, the battery charger, can also be easily achieved without vision.  This product presents few vision

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