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Subject Product - Disability Access Analysis

(h) Where a telecommunications product delivers output by an audio transducer which is normally held up to the ear, a means for effective magnetic wireless coupling to hearing technologies shall be provided.

(i) Interference to hearing technologies (including hearing aids, cochlear implants, and assistive listening devices) shall be reduced to the lowest possible level that allows a user of hearing technologies to utilize the telecommunications product.

(j) Products that transmit or conduct information or communication, shall pass through cross-manufacturer, non-proprietary, industry-standard codes, translation protocols, formats or other information necessary to provide the information or communication in a usable format. Technologies which use encoding, signal compression, format transformation, or similar techniques shall not remove information needed for access or shall restore it upon delivery.

(k) Products which have mechanically operated controls or keys, shall comply with the following:

(1) Controls and keys shall be tactilely discernible without activating the controls or keys.

(2) Controls and keys shall be operable with one hand and shall not require tight grasping, pinching, or twisting of the wrist. The force required to activate controls and keys shall be 5 lbs. (22.2 N) maximum.

(3) If key repeat is supported, the delay before repeat shall be adjustable to at least 2 seconds. Key repeat rate shall be adjustable to 2 seconds per character.

(4) The status of all locking or toggle controls or keys shall be visually discernible, and discernible either through touch or sound.

3.1.2. Analysis of the Application of CFR 1194.23

Items (a) through (c) deal with TTY support.  This underscores the importance of TTY support to the Access Board.  Similar concern is to be found in corresponding FCC documents in dealing with Section 255.  These requirements underscore the desirability of determining if the Subject Product can be configured with a TTY to support VCO and HCO.

Section (d) requires that user response times be adjustable according to a user’s need.  This flexibility of user response is found in other sections of the standards, which apply to software and other kinds of equipment.

Section (f) gives the requirement for 20 dB range of volume adjustment.  However, this section is technically flawed in that the document never states the nominal setting from which this range is measured.  Help may be gained from the EITAAC report, where it states:

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