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Subject Product - Disability Access Analysis

For voice output from devices, provide incremental volume control with output amplification up to a level of at least 97 dB SPL with at least one intermediate step of 89 dB SPL.

From this citation it can be seen that a normal output in the range of 77 dB SPL is anticipated.  Adjusting upward by 12 dB provides a stop at 89 dB SPL.  The 20 dB requirement gives a maximum output at 97 dB SPL.  It is unstated whether this is measured in an open ear or sealed ear condition.

Section (g) requires that the volume automatically reset to nominal after use.  This is intended to protect other users from very high volume levels set by users with hearing loss.  It is unclear that this requirement applies to a personal use device such as Subject Product.

The requirements of (h) and (i) are met by compliance with ANSI C63.19.  In its discussion of the rules the Access Board stated:

Paragraph (i) requires that interference to hearing technologies be reduced to the lowest possible level that allows a user of hearing technologies to utilize a telecommunications product. Individuals who are hard of hearing use hearing aids and other assistive listening devices, but they cannot be used if products introduce noise into the listening aids because of electromagnetic interference. (See §1194.23(d)(9) in the NPRM.)

Comment. The American National Standards Institutes (ANSI) is developing methods of measurement and defining the limits for hearing aid compatibility and accessibility to wireless telecommunications. At the time of the proposed rule, the ANSI C63.19 ANSI/IEEE Standard for Hearing Aid Compatibility with Wireless Devices was not completed. The NPRM noted that the Board may ultimately incorporate the standard when it is completed. Several commenters recommended referencing the work of the ANSI committee.

Response. The ANSI committee has recently completed its work. No changes have been made to this provision in the final rule and the provision continues to be a performance standard rather than a specific design standard. However, compliance with the ANSI C63.19 ANSI/IEEE Standard for Hearing Aid Compatibility with Wireless Devices would meet this provision.

ANSI C63.19 provides tests and criteria for both the issues of RF interference and telecoil compatibility for wireless devices.

Section (j) does not apply to this product.

Section (k) requirements of controls are judged to be met by the Subject Product product.  

Recommended Action: It appears that the product meets the force requirement of item (2) and the response time, item (3).  However, this needs to be confirmed.

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