Nonvisual Access Guidance: Regulation .08 Self contained, closed products

(a) Accessible Without Attachments

This guidance has been excerpted from federal implementation guidelines for Section 508 Standards. http://www.access-board.gov/sec508/guide/1194.25.htm. Minor changes to the federal guidelines may have been made in order to comply with Maryland regulations.

What are self contained, closed products?
Self contained closed products generally have embedded software and are commonly designed in such a fashion that a user cannot easily attach or install assistive technology. For example, one could attach a screen reader to a computer to meet the standard but one would not be expected to attach a screen reader to a copier machine. A copier machine is an example of a self-contained, closed product. Other examples include, calculators, fax machines, information transaction machines, and information kiosks. Unlike other provisions which allow a product to meet the standards by being compatible with assistive technology, this provision requires self contained, closed products to contain built-in accessibility.

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(b) Touch Screens or Contact-Sensitive Controls

Note: The referenced COMAR is:

  1. Controls and keys are tactilely discernable without activating the controls or keys; and
  2. The status of all locking or toggle controls or keys is discernible either through touch or sound in addition to being visually discernable.
This guidance has been excerpted from federal implementation guidelines for Section 508 Standards. http://www.access-board.gov/sec508/guide/1194.25.htm. Minor changes to the federal guidelines may have been made in order to comply with Maryland regulations.

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. Because touch is necessary to discern tactile features, this provision requires touch-screens and contact-sensitive controls to enable touch that does not automatically activate a function based on mere contact. One method of ensuring compliance with the regulation is to equip the touch-screen keypad or contact-sensitive controls 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.

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(c) Non-Ocular Biometric Identifiers

This guidance has been excerpted from federal implementation guidelines for Section 508 Standards. http://www.access-board.gov/sec508/guide/1194.25.htm. Minor changes to the federal guidelines may have been made in order to comply with Maryland regulations.

What is an ocular form of user identification or control?
Ocular identification is a biometric control activated only if a particular biological eye feature of the user exists and matches specific criteria. An example includes retinal scans that may become common practice for allowing an individual to gain access to personal data from an information transaction type of machine. Biometric controls provide a high level of security. However, when a system needs to be accessed by a person with a visual disability, a non-biometric alternative should be provided that does not compromise security.

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(d) Auditory Output

This guidance has been excerpted from federal implementation guidelines for Section 508 Standards. http://www.access-board.gov/sec508/guide/1194.25.htm. Minor changes to the federal guidelines may have been made in order to comply with Maryland regulations.

Does this provision apply to "beeps and tones" or to voice signals only?
This provision applies only to voice output. For example, it could apply to a device that is providing voice output for a person who is unable to see a visual display.

What is meant by a standard connector?
People who regularly use information transaction kiosks may plan to carry a portable headset (or other listening coupler) with them. Examples of common plugs on headsets include those that fit 2.5 mm jacks (such as those in most cellular phones) and 3.5 mm plugs (such as those in most portable stereos). There have been problems in the past when manufacturers made proprietary plugs that were flat with multiple pins and were compatible only with their own products.

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(e) Volume Controls

This guidance has been excerpted from federal implementation guidelines for Section 508 Standards. http://www.access-board.gov/sec508/guide/1194.25.htm. Minor changes to the federal guidelines may have been made in order to comply with Maryland regulations.

How was the level of 65 dB determined?
According to the Occupational Safety and Health Administration, and the American Speech, Language, and Hearing Association, 65 dB is the volume level for normal speech. This provision requires that audio output from a kiosk type product have a minimum level of 65 dB. A feature has been required to automatically reset the volume to the default level after every use.

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(f) Color Coding in Self Contained, Closed Products

This guidance has been excerpted from federal implementation guidelines for Section 508 Standards. http://www.access-board.gov/sec508/guide/1194.25.htm. Minor changes to the federal guidelines may have been made in order to comply with Maryland regulations.

How can color coding create accessibility difficulties?
A software program that requires a user to distinguish between otherwise identical red and blue squares for different functions (e.g., printing a document versus saving a file) would pose problems for anyone who is visually disabled and would generally be very difficult to run with assistive technology. Screen reading software can announce color changes. However, this is an "on/off" feature. This means that if a user had to identify a specific color, they would have to have all colors announce which would greatly reduce the usability of the software for that person.

Does the provision prohibit the use of colors?
No. This provision does not prohibit the use of color to enhance identification of important features. It does, however, require that some other method of identification, such as text labels, be combined with the use of color.

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(g) Color Contrast Levels in Self Contained, Closed Products

This guidance has been excerpted from federal implementation guidelines for Section 508 Standards. http://www.access-board.gov/sec508/guide/1194.25.htm. Minor changes to the federal guidelines may have been made in order to comply with Maryland regulations.

Do all products have to provide color selections?
No. This provision is applied to those products that already allow a user to adjust screen colors.

What is the desired outcome of this requirement?
This provision requires more than just providing color choices. The available choices must also allow for different levels of contrast. Many people experience a high degree of sensitivity to bright displays. People with this condition cannot focus on a bright screen for long because they will soon be unable to distinguish individual letters. An overly bright background causes a visual "white-out". To alleviate this problem, the user must be able to select a softer background and appropriate foreground colors. On the other hand, many people with low vision can work most efficiently when the screen is set with very sharp contrast settings. Because there is such a variance in individual needs it is necessary for a program to have a variety of color and contrast settings.

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(h) Screen Flicker Frequency in Self Contained, Closed Products

Why are flashing or blinking displays limited by this provision? The 2 Hz limit was chosen to be consistent with proposed revisions to the ADA Accessibility Guidelines which, in turn, are being harmonized with the International Code Council (ICC)/ANSI A117 standard, "Accessible and Usable Buildings and Facilities", ICC/ANSI A117.1-1998 which references a 2 Hz limit. An upper limit was identified at 55 Hz.

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