Voluntary Product Accessibility Template (VPAT) Review

Criteria 1194.25 - Self-Contained, Closed Products

This critera section covers all hardware that does not fit within the other sections, and in many instances should be completed in conjunction with other sections on the VPAT.

The CSU reviews this section in relation to functionality regardless of that the product or service. The subsections below will contain the following:

  • The text of the section 508 criterion
  • Explanation of what the criterion is asking along with resource links if available
  • Cross reference information if applicable
  • Verification notes we give our campuses for reviewing VPAT's
  • Information on how this looks like it will overlay into the Section 508 Refresh
Criteria Resources

Criteria 1194.25(a)

Self-contained products shall be usable by people with disabilities without requiring an end-user to attach Assistive Technology to the product. Personal headsets for private listening are not Assistive Technology

Clarification:

  • The product must provide someone with a vision, hearing, mobility (including dexterity), or speech etc. disability access to all functionality and features without the use of AT.
  • Section 508 refresh
    • 402.2 Closed Functionality - Speech-Output Enabled

Verification Notes:

  • When Supports with Exceptions is chosen look for the following information in Remarks and Explanation column:
    • What is the impact of the user’s inability to complete any core functions of the application due to the exception or lack of support for this criterion.
  • Note that for responses that include Supports with Exceptions and Not Supported drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement.

Criteria 1194.25(b)

When a timed response is required, the user shall be alerted and given sufficient time to indicate more time is required.

Clarification:

  • This is frequently seen on secure sites when the user is warned that they will be logged off.
  • Further technical explanation of timed response criteria
  • Section 508 refresh
    • 407.5 Operable Parts - Timed Response
    • WCAG 2.2.1 Timing Adjustable

Cross References:

  • Section 508 - 1194.22(p)

Verification Notes:

  • When Supports with Exceptions is chosen look for the following information in Remarks and Explanation column:
    • What is the impact of the user’s inability to complete any core functions of the application due to the exception or lack of support for this criterion.
  • Note that for responses that include Supports with Exceptions and Not Supported drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement.

Criteria 1194.25(c)

Where a product utilizes touchscreens or contact-sensitive controls, an input method shall be provided that complies with Û1194.23 (k) (1) through (4).

Clarification:

  • Touch screens must contain feedback methods for all users to access. 
  • See section 1194.23(k) for specific requirements.
  • Section 508 refresh
    • 407.3 Operable Parts - Tactilely Discernible
    • 407.4 Operable Parts - Key Repeat
    • 407.6 Operable Parts - Status Indicators
    • 407.9 Operable Parts - Operation

Cross References:

  • Section 508 - 1194.23(k)(1), 1194.23(k)(2), 1194.23(k)(3) and 1194.23(k)(4)

Verification Notes:

  • When Supports with Exceptions is chosen look for the following information in Remarks and Explanation column:
    • What is the impact of the user’s inability to complete any core functions of the application due to the exception or lack of support for this criterion.
  • Note that for responses that include Supports with Exceptions and Not Supported drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement.

Criteria 1194.25(d)

When biometric forms of user identification or control are used, an alternative form of identification or activation, which does not require the user to possess particular biological characteristics, shall also be provided.

Clarification:

  • Biometric is a physical feature requirement for security. An alternative must be provide that does not require a user to have the physical aspect. 
  • Examples of biometrics: finger for fingerprints or an eyeball for rental scans.
  • Section 508 refresh
    • 403.1 Biometrics - General

Cross References:

  • Section 508 - 1194.26(c)

Verification Notes:

  • When Supports with Exceptions is chosen look for the following information in Remarks and Explanation column:
    • What is the impact of the user’s inability to complete any core functions of the application due to the exception or lack of support for this criterion.
  • Note that for responses that include Supports with Exceptions and Not Supported drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement.

Criteria 1194.25(e)

When products provide auditory output, the audio signal shall be provided at a standard signal level through an industry standard connector that will allow for private listening. The product must provide the ability to interrupt, pause, and restart the audio at anytime.

Clarification:

  • This standard is similar to the multimedia pause, stop, etc.
  • Section 508 refresh
    • 402.2.1 Closed Functionality - Speech-Output Enabled - User Control

Verification Notes:

  • When Supports with Exceptions is chosen look for the following information in Remarks and Explanation column:
    • What is the impact of the user’s inability to complete any core functions of the application due to the exception or lack of support for this criterion.
  • Note that for responses that include Supports with Exceptions and Not Supported drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement.

Criteria 1194.25(f)

When products deliver voice output in a public area, incremental volume control shall be provided with output amplification up to a level of at least 65 dB. Where the ambient noise level of the environment is above 45 dB, a volume gain of at least 20 dB above the ambient level shall be user selectable. A function shall be provided to automatically reset the volume to the default level after every use.

Clarification:

  • Look for how text for audio is addressed within the standards.
  • Section 508 refresh
    • 402.3.2 Closed Functionality - Volumne - Non-private Listening

Verification Notes:

  • When Supports with Exceptions is chosen look for the following information in Remarks and Explanation column:
    • What is the impact of the user’s inability to complete any core functions of the application due to the exception or lack of support for this criterion.
  • Note that for responses that include Supports with Exceptions and Not Supported drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement.

Criteria 1194.25(g)

Color coding shall not be used as the only means of conveying information, indicating an action, prompting a response, or distinguishing a visual element.

Clarification:

  • Whenever an element such as a control is distinguished by a color, is another method must be used to visually denote the element.
  • Section 508 refresh
    • 302.3 Functional Performance - Without Perception of Color
    • 407.7 Operable Parts - Color
    • 407.8 Operable Parts - Audio Signaling
    • WCAG 1.4.1 Use of Color

Cross References:

  • Section 508 - 1194.21(i) and 1194.22(c)

Verification Notes:

  • When Supports with Exceptions is chosen look for the following information in Remarks and Explanation column:
    • What is the impact of the user’s inability to complete any core functions of the application due to the exception or lack of support for this criterion.
  • Note that for responses that include Supports with Exceptions and Not Supported drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement.

Criteria 1194.25(h)

When a product permits a user to adjust color and contrast settings, a range of color selections capable of producing a variety of contrast levels shall be provided.

Clarification:

When a product provides built in color adjustment, is there enough color contrast?

Cross References:

  • Section 508 - 1194.21(j)

Verification Notes:

  • When Supports with Exceptions is chosen look for the following information in Remarks and Explanation column:
    • What is the impact of the user’s inability to complete any core functions of the application due to the exception or lack of support for this criterion.
  • Note that for responses that include Supports with Exceptions and Not Supported drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement.

Criteria 1194.25(i)

Products shall be designed to avoid causing the screen to flicker with a frequency greater than 2 Hz and lower than 55 Hz.

Clarification:

  • Look for the screen to flicker similar to transitioning to one slide to another.
  • When the flicker is unexpected, unintended, and noticeable the frequency rate can trigger seizers, migraines, and be distracting to the end user.
  • Section 508 refresh
    • 405.1 Flashing - General
    • WCAG 2.3.1 Three Flashes or Below Threshold

Cross References:

  • Section 508 - 1194.21(k)

Verification Notes:

  • When Supports with Exceptions is chosen look for the following information in Remarks and Explanation column:
    • What is the impact of the user’s inability to complete any core functions of the application due to the exception or lack of support for this criterion.
  • Note that for responses that include Supports with Exceptions and Not Supported drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement

Criteria 1194.25(j)(1)

Products which are freestanding, non-portable, and intended to be used in one location and which have operable controls shall comply with the following: The position of any operable control shall be determined with respect to a vertical plane, which is 48 inches in length, centered on the operable control, and at the maximum protrusion of the product within the 48 inch length on products which are freestanding, non-portable, and intended to be used in one location and which have operable controls.

Clarification:

  • Product is in a permanent location, can the controls be reached by everyone?  Including on and off switch, and operations.
  • Product may have controls in more than one location it does refer to all controls.
  • Section 508 refresh
    • 407.12.1 Operable Parts - Reach Height - Vertical Reference Plane
    • 407.12.1.1 Operable Parts - Reach Height- Vertical Plane for Side Reach

Verification Notes:

  • When Supports with Exceptions is chosen look for the following information in Remarks and Explanation column:
    • What is the impact of the user’s inability to complete any core functions of the application due to the exception or lack of support for this criterion.
  • Note that for responses that include Supports with Exceptions and Not Supported drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement.

Criteria 1194.25(j)(2)

Products which are freestanding, non-portable, and intended to be used in one location and which have operable controls shall comply with the following: Where any operable control is 10 inches or less behind the reference plane, the height shall be 54 inches maximum and 15 inches minimum above the floor.

Clarification:

  • Can a person in a wheel chair or who is of shorter stature reach all of the controls even when close to the front of the product.
  • Section 508 refresh
    • 407.12.1 Operable Parts - Reach Height - Vertical Reference Plane

Verification Notes:

  • When Supports with Exceptions is chosen look for the following information in Remarks and Explanation column:
    • What is the impact of the user’s inability to complete any core functions of the application due to the exception or lack of support for this criterion.
  • Note that for responses that include Supports with Exceptions and Not Supported drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement.

Criteria 1194.25(j)(3)

Products which are freestanding, non-portable, and intended to be used in one location and which have operable controls shall comply with the following: Where any operable control is more than 10 inches and not more than 24 inches behind the reference plane, the height shall be 46 inches maximum and 15 inches minimum above the floor.

Clarification:

  • Can a person in a wheel chair or who is of shorter stature reach all of the controls even when the controls are more than 10 inches in setback, the height must be no higher than 46 inches.
  • Section 508 refresh
    • 407.12.2.2 Operable Parts - Reach Height - Side Reach - Obstructed Side Reach

Verification Notes:

  • When Supports with Exceptions is chosen look for the following information in Remarks and Explanation column:
    • What is the impact of the user’s inability to complete any core functions of the application due to the exception or lack of support for this criterion.
  • Note that for responses that include Supports with Exceptions and Not Supported drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement.

Criteria 1194.25(j)(4)

Products which are freestanding, non-portable, and intended to be used in one location and which have operable controls shall comply with the following: Operable controls shall not be more than 24 inches behind the reference plane.

Clarification:

  • Can a person in a wheel chair or who is of shorter stature reach all of the controls even when the controls are closer to 24 inches in setback.
  • Section 508 refresh
    • 407.12.2.2 Operable Parts - Reach Height - Side Reach - Obstructed Side Reach

Verification Notes:

Note that for responses that include Supports with Exceptions and Not Supported drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement.