Nonvisual Access Guidance: Regulation .06 Telecommunications and interconnected network equipment and services

(a) Integrated for Visual Information by Nonvisual Means

"Telecommunications" means the transmission of information, images, pictures, voice or data by radio, video or other electronic or impulse means. "Interconnected network services" means the support of direct or indirect facilities for telecommunication and computer connections such that telecommunications operate in a reliable and secure manner.

The intent of the regulation is to ensure that State telecommunications and networks used by individuals who are not blind or visually impaired are compatible with, and capable of receiving, recovering and distributing graphics, forms and other visual information by means specified in, nonvisual accessibility features of State information technologies.

back to top

(b) PDAs and Mobile Phone Systems

"Mobile phone systems" means analog or digital telephonic transmission hardware and software.

The intent of the regulation is to ensure that mobile telecommunications devices and systems deliver text to end-user devices and that the end-user devices convert the delivered text to good quality synthesized speech. Good quality synthesized speech, utilizing either concatenative synthesis or parameterized modeling, includes:

  • Accurate spectral voice properties;
  • Reasonable dynamic range;
  • Constant volume;
  • Filtered side-effects of speech (such as pops); and
  • Accurate segmentation and voice definition.

Paper presented at IEE Seminar "State-Of-The-Art In Speech Synthesis". London, April 2000. FLEXVOICE: A PARAMETRIC APPROACH TO HIGH-QUALITY SPEECH SYNTHESIS. György Balogh, Ervin Dobler, Tamás Grőbler, Béla Smodics, Csaba Szepesvári (* Mindmaker Ltd., Budapest, Hungary; Email:

back to top

(c) Information Delivery

This provision prohibits products from stripping out nonvisual accessibility information or requires the information to be restored at the end point. The provision was written broadly enough to ensure that it will apply to evolving technologies.

back to top

(d) Mechanically Operated Controls or Keys

This guidance has been excerpted from federal implementation guidelines for Section 508 Standards. Minor changes to the federal guidelines may have been made in order to comply with Maryland regulations.

What products are generally covered under this provision?
This provision only applies to products that have mechanically operated controls or keys, such as standard telephone keypads and computer keyboards. It is not intended to apply to touch-screens.

What is meant by 'tactilely discernible'?
Individual keys must be identifiable and distinguishable from adjacent keys by touch. Compliance with this provision can be accomplished by using various shapes, spacing, or tactile markings. The normal desktop computer keyboard, for example, would meet this provision because the tactile marks on the "j" and "f" keys permit a user to locate all other keys tactilely. Many phones also have a raised dot on the number 5 button, enabling them to orient their fingers around the 12 keys. In addition, the physical spacing of the function, "numpad" and cursor keys make them easy to locate by touch.

Because touch is necessary to discern tactile features, this provision requires keyboards to enable touch that does not automatically activate a function based on mere contact. Fortunately most keyboards require some pressure on individual keys in order to enable a keystroke.

However, "capacitance" keyboards would not meet this provision because they react as soon as they are touched and have no raised marks or actual keys. A "membrane" keypad with keys that must be pressed can be made tactilely discernible by separating keys with raised ridges so that individual keys can be distinguished by touch.

What is meant by "status of controls" and why do people need that information?
This provision requires the status of toggle controls, such as the "caps lock" or "scroll lock" keys to be identifiable by either touch or sound, in addition to visual means. For example, adding audio patterns, such as ascending and descending pitch tones that indicate when a control is turned on or off, would alleviate the problem of a person who is blind inadvertently pressing the locking or toggle controls. Also, buttons which remain depressed when activated and switched with distinct positions may meet this provision.

back to top