Voluntary Product Accessibility Template (VPAT) Review

Criteria 1194.23

This category addresses communication devices used by people who are deaf, hard of hearing, visually impaired, or speech impaired to communicate over networks designed to carry voice. Whenever a device transmits and receives voice over a telecommunications network, it must then be able to support the hookup and successful interoperation of TTY AT. This category includes telecommunications devices such as digital, analog, wire, wireless, and Internet-based products and devices such as PBX and telephone answering machines.

Due to the technical nature of the standards in this category, many of the evaluation statements and tests for compliance require specialized tools and expertise in telecommunication products. While this could be daunting, there is an easy solution and that is to contact the manufacturer of the product for information.

Sub Criteria:

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
Criterion Resources

Criteria 1194.23(a)

Telecommunications products or systems which provide a function allowing voice communication and which do not themselves provide a TTY functionality shall provide a standard non-acoustic connection point for TTYs. Microphones shall be capable of being turned on and off to allow the user to intermix speech with TTY use.

Clarification:

  • Telecommunication products (e.g., telephones, voice over IP) or systems that provide voice communication must also have the capability to provide standard non-acoustic connection points for TTY. Microphones must be capable of being turned on and off to allow user to intermix speech with TTY use.
  • From http://www.uspto.gov/about/offices/cio/section508/04telecom.jsp
  • Section 508 Refresh
    • 410.6.5 ITC with Two-Way Voice Communication - Real-Time Text Functionality - HCO and VCO Support

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 1194.23(b)

Telecommunications products which include voice communication functionality shall support all commonly used cross-manufacturer non-proprietary standard TTY signal protocols.

Clarification:

  • Voice telecommunication products must support commonly used protocols such as 45.5 baud Baudot and 300 baud ASCII. From USPTO
  • Does the product support both 45.5 baud Baudot and 300 baud ASCII, which are the commonly used cross-manufacturer non-proprietary standard TTY signal protocols in the United States?
  • Voice mail, auto-attendant, and interactive voice response telecommunications systems shall be usable by TTY users with their TTYs.
  • Does the system transmit TTY signals for its prompts and greetings and accept TTY signals for inter activity and messages?

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 1194.23(c)

Voice mail, auto-attendant, and interactive voice response telecommunications systems shall be usable by TTY users with their TTYs

Clarification:

  • Automated telecommunication services (e.g. voice mailboxes) must support TTY interaction.
  • From USPTO
  • Section 508 Refresh
    • 410.6.4 ITC with Two-Way Voice Communication - Real-Time Text Functionality - Voice Mail, Auto-Attendant, and IVR Compatibility

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 1194.23(d)

Voice mail, messaging, auto-attendant, and interactive voice response telecommunications systems that require a response from a user within a time interval, shall give an alert when the time interval is about to run out, and shall provide sufficient time for the user to indicate more time is required.

Clarification:

  • The user should be alerted when any time-dependent function is about to timeout. The user must be given enough time to extend the response time. From USPTO
  • Does the system give an alert when the time interval for a required response is about to run out?
  • Does the system allow the user to indicate that more time is required?
  • Section 508 Refresh
    • 410.6.4 ITC with Two-Way Voice Communication - Real-Time Text Functionality - Voice Mail, Auto-Attendant, and IVR Compatibility

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 1194.23(e)

Where provided, caller identification and similar telecommunications functions shall also be available for users of TTYs, and for users who cannot see displays

Clarification:

  • Caller identification and similar functions of a telecommunication device must be accessible to TTY users and those who cannot see the device's display. From USPTO
  • Are features that may appear on telephone LCD displays, such as notification of voice mail messages, which line is ringing, Caller ID and the number of callers on hold, available for users who cannot see such displays?
  • Are these features available to users of TTYs, who might otherwise be disadvantaged because they are given an analog telephone line while others in the workplace use a digital telephone system?
  • Section 508 Refresh
    • 410.6.4 ITC with Two-Way Voice Communication - Real-Time Text Functionality - Voice Mail, Auto-Attendant, and IVR Compatibility
    • 410.7 ITC with Two-Way Voice Communication - Real-Time Text Functionality - Caller ID

    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 1194.23(f)

For transmitted voice signals, telecommunications products shall provide a gain adjustable up to a minimum of 20 Db. For incremental volume control, at least one intermediate step of 12 Db of gain shall be provided.

Clarification:

  • Telecommunications products that transmit voice communications must have the ability to amplify the volume and have an intermediary setting. From USPTO
  • Does the product provide a gain adjustable up to at least 20 dB? If the gain is incremental, is there at least one intermediate step of 12 dB of gain?
  • Section 508 Refresh
    • 410.2.3 ITC with Two-Way Voice Communication - Closed Functionality - Volume Gain

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 1194.23(g)

If the telecommunications product allows a user to adjust the receive volume, a function shall be provided to automatically reset the volume to the default level after every use.

Clarification:

  • On telecommunication products that have adjustable volume, there must be an automatic volume reset function that sets the volume back to the default level.
  • Note: Assume that this standard refers to products that have a handset, headset, earphone, or other transducer near the ear. Assume that the default volume level is safe, clear, and audible for fully able users. From USPTO
  • Is a function provided to automatically reset the volume to the default level?

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 1194.23(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.

Clarification:

  • When using a telecommunication product such as a telephone, there must be a means to effectively use magnetic wireless coupling devices such as hearing aids. Note: Assume that effective magnetic wireless coupling to hearing aids with a telecoil and cochlear implants is applicable to this requirement. From USPTO
  • Is a means provided for magnetic wireless coupling to hearing devices such as hearing aids or cochlear implants?
  • Section 508 Refresh
    • 410.3 ITC with Two-Way Voice Communication - Magnetic Coupling

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 1194.23(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.

Clarification:

  • Interference to hearing technologies (e.g., hearing aids, cochlear implants, assistive listening systems) should be reduced to the lowest possible level. From USPTO.  
  • Is interference to hearing technologies reduced to a level that allows the user of hearing technologies to use the product?
  • Section 508 Refresh
    • 410.4 ITC with Two-Way Voice Communication - Minimize Interference
    • 411.1.1 Closed Caption Processing Technologies - General - Decoding of Closed Captions
    • 411.1.2 Closed Caption Processing Technologies - General - Pass-Through of Closed Caption Data

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 1194.23(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.

Clarification:

  • Any telecommunication product must have the ability to process information in a usable format. Products shall not remove information required for access. Note: This requirement applies to the transmission of TTY signals over voice-based telecommunications systems, including VoIP. The requirement was written broadly to ensure that it would apply to evolving technologies. From USPTO
  • Does the product pass accessibility information and codes, such as TTY signals, in a usable format?
  • Section 508 Refresh
    • 404.1 Preservation of Information Provided for Accessibility - General
    • 411.1 Closed Caption Processing Technologies - General
    • 504.2.1 Authoring Tools - Content Creation or Editing - Preservation of Accessibility Information in Format Conversion

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 1194.23(k)(1)

Products which have mechanically operated controls or keys shall comply with the following: Controls and Keys shall be tactilely discernible without activating the controls or keys.

Clarification:

  • Keypad have standard, tactilely discernible markings such as the f and j on a standard keyboard.
  • Section 508 Refresh
    • 407.3 Operable Parts - Tactilely Discernible
    • 407.3.1 Operable Parts - Tactilely Discernible - Identification
    • 407.3.2 Operable Parts - Tactilely Discernible - Alphabetic Keys
    • 407.3.3 Operable Parts - Tactilely Discernible - Numeric Keys

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 1194.23(k)(2)

Products which have mechanically operated controls or keys shall comply with the following: Controls and Keys shall be operable with one hand and shall not require tight grasping, pinching, twisting of the wrist. The force required to activate controls and keys shall be 5 lbs. (22.2N) maximum.

Clarification:

  • Think of this in relation to can a person with a mobility issue such as arthritis and their ability to operate the control.
  • Section 508 Refresh
    • 407.9 Operable Parts - Operation

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 1194.23(k)(3)

Products which have mechanically operated controls or keys shall comply with the following: 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.

Clarification:

  • By having a delay in the key repeat allows for the accidental hitting of the same key twice. 
  • This provision is specifically related to fine motor skills.
  • Section 508 Refresh
    • 407.4 Operable Parts - Key Repeat

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 1194.23(k)(4)

Products which have mechanically operated controls or keys shall comply with the following: The status of all locking or toggle controls or keys shall be visually discernible, and discernible either through touch or sound.

Clarification:

  • All locking or toggle controls or keys must be discernible visually, and through touch or sound.
  • Note: Assume that more than one person would reliably determine (from USPTO):
    • The type and severity of low vision to which a control or key must be discernible (e.g., a good heuristic is to procure for people with 20/70 vision; meaning what most people see at 70 feet, they would see at 20 feet away).
    • The level of sound that is adequate to discern the status of locking or toggle controls (see requirements (f), (g) and (h)).
    • The amount of force required for the status of a control or key to be tactilely discernible without activating a key (e.g., lightly running your fingers over the F and J keys of a standard keyboard to locate the navigational bumps without actually typing the F or J key).
    • Is the status of all locking or toggle controls or keys discernible either visually and audibly or visually and tactilely?
  • Section 508 Refresh
    • 407.6 Operable Parts - Status Indicators

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.