#1 Digital Multi-function CopiersA study of accessibility issues and potential design solutions for designers, procurement officials, and consumers.

W. Bradley Fain, Ph.D.

August 2006

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This monograph documents the results of research conducted in the Accessibility Evaluation Facility (AEF) of the Georgia Tech Research Institute. The AEF has performed a series of accessibility evaluations for both industry and government customers. Although information about the outcome of specific evaluations has been withheld, the data presented in this monograph is based upon general outcomes and lessons learned stemming from research conducted at the Georgia Tech Research Institute.

For additional information about this monograph please contact:

Dr. Brad FainGeorgia Tech Research Institute

ELSYS/HSID/HSEB Mail Code 0840Atlanta, GA 30332-0840

Voice (404) 407-7261Fax (404) 407-9261

brad.fain@gtri.gatech.edu

Table of Contents

Table of Contents......................................................................................................................................3List of Tables.............................................................................................................................................5List of Figures...........................................................................................................................................6Introduction...............................................................................................................................................7Introduction...............................................................................................................................................7

What is a digital multi-function copier?................................................................................................7Why produce an accessible digital multi-function copier?...................................................................7What types of assistive technologies (AT) are commonly used with digital multi-function copiers?..8Which Section 508 standards apply to digital multi-function copiers?...............................................12

Evaluation Methodologies.......................................................................................................................16How do I define the goals of the evaluation?......................................................................................17How do I perform a task analysis?......................................................................................................18How do I develop a Method of Test?..................................................................................................20Which evaluation techniques should I use?........................................................................................20How should I document the results of the evaluation?.......................................................................26

Accessibility Issues and Potential Solutions...........................................................................................28What are the common issues associated with alerts, error messages, and status indicators?.............29

Error messages are often unclear or enunciated inadequately........................................................29Color coding is sometimes used as the sole means of conveying information...............................31Sometimes the state of a status indicator can only be determined visually....................................33Redundant sensory feedback is unavailable or inaccessible...........................................................35

What are the common issues associated with control panel buttons?.................................................36Buttons mounted flush with the panel are difficult for those without vision or with low vision to detect...............................................................................................................................................36Buttons that do not have sufficient contrast with the panel are difficult for users with low vision to detect...............................................................................................................................................39Buttons that are small and close together may be difficult to differentiate or activate without activating adjacent controls.............................................................................................................40Buttons that are all shaped the same or that do not have shapes corresponding to their functions are more difficult for the blind to memorize and for the cognitively impaired to understand........42Control panel buttons may not provide a surface that facilitates button activation........................44Buttons requiring very little force to activate can increase the number of accidental activations.. 46Chorded button operations can be difficult for users with upper mobility impairments................47

What are the common issues associated with control panel keypads?................................................48Keypads may lack nibs on the “5”, “F”, and “J” keys....................................................................48Non-standard numeric keypads pose a problem for some users.....................................................49The common methods of cursor advancement for numeric keypad text entry cause problems for some users.......................................................................................................................................51

What are the common issues associated with control panel screens and displays?............................52Wheelchair users may have difficulty reading LCD screens..........................................................52Small icons and text are difficult for low vision users to perceive.................................................56Complex menus and inconsistent display elements may be difficult for users with limited cognitive abilities to understand......................................................................................................58

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Control panels are often out of reach of seated users......................................................................59Status is not discernible through either touch or sound...................................................................60

What are the common issues associated with touchscreen interfaces?...............................................61Touchscreen controls are not tactilely differentiable......................................................................61Touchscreen controls typically utilize small text labels..................................................................63Touchscreen controls are easily activated, often resulting in unintentional control activations.....65

What are the common issues associated with the document feeder?..................................................66Platen glass cover may be too heavy for users with limited upper body strength to operate..........66Users in a seated position may not be able to lower the platen glass once it is in a raised position..........................................................................................................................................................67Users may have difficulty placing and retrieving documents.........................................................69

What are the common issues associated with product documentation?..............................................70Documentation is often not available in alternate formats, such as Braille or audio instructions.. 70Documentation available electronically or on a manufacturer's website is not accessible.............71

What are the common issues associated with product labeling?.........................................................72Raised or recessed lettering is often are the same color as the background, providing no contrast, and making it difficult for low vision users to perceive the lettering..............................................72

What are the common issues associated with maintenance panels?...................................................74Access to maintenance areas to perform routine maintenance tasks, such as replenishing toner or the clearing paper jams, is inhibited by maintenance panels that open downward.........................74Routine maintenance tasks, such as replenishing toner or clearing paper jams, are inhibited by maintenance panels, levers, and supply cartridges that mobility impaired users find difficult to operate.............................................................................................................................................76Maintenance instructions and warning labels may be difficult for some users to read, due to placement and/or font size...............................................................................................................77

What are the common issues associated with paper trays?.................................................................79Paper trays are sometimes positioned too low for wheelchair users to access................................79Adding paper sometimes requires fine motor control, and reconfiguring the paper size within a paper tray often requires excessive strength and fine motor control...............................................81Paper trays that require reaching under the tray (palms up) to pull the tray out may be problematic for users in wheelchairs and users with upper mobility impairments.............................................82

References...............................................................................................................................................84Appendix A: Checklist Evaluation..........................................................................................................85

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List of Tables

Table 1: Potentially Applicable Section 508 Standards.........................................................................13

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List of Figures

Figure 1: Digital multi-function copier.....................................................................................................7Figure 2: Reaching aid............................................................................................................................10Figure 3: Screen magnifier in use............................................................................................................11Figure 4: An unclear error message........................................................................................................29Figure 5: A clear error message..............................................................................................................30Figure 6: A dual color state light.............................................................................................................31Figure 7: Redundant coding....................................................................................................................32Figure 8: A visual-only user interface element status indicator..............................................................33Figure 9: A visual and tactile user interface element status indicator.....................................................34Figure 10: Flush mounted control panel buttons.....................................................................................36Figure 11: Raised control panel buttons..................................................................................................37Figure 12: Braille labels on control panel buttons..................................................................................37Figure 13: A control panel button with a contrasting color....................................................................39Figure 14: A control panel with small, tightly-spaced buttons...............................................................40Figure 15: A control panel with large, adequately spaced buttons.........................................................41Figure 16: Identically shaped buttons for controlling unrelated functions.............................................42Figure 17: Button shape coding and distinguishing features..................................................................43Figure 18: Control panel buttons with slick, convex surfaces................................................................44Figure 19: Control panel buttons with concave surfaces........................................................................45Figure 20: A numeric keypad with a non-standard key arrangement.....................................................49Figure 21: A keypad with a standard key arrangement...........................................................................50Figure 22: LCD viewing angle problems for a seated user.....................................................................52Figure 23: A tiltable control panel..........................................................................................................53Figure 24: A detachable control panel....................................................................................................53Figure 25: A remote user interface..........................................................................................................54Figure 26: A detachable document feeder assembly positioned on a wheelchair accessible table.........54Figure 27: A manual display contrast adjustment control.......................................................................55Figure 28: A control panel with small labels..........................................................................................56Figure 29: A control panel with large labels...........................................................................................57Figure 30: A touchscreen on a digital multi-function copier control panel............................................61Figure 31: A digital multi-function copier control panel in a voice display mode.................................62Figure 32: Use of hardware buttons for critical functions.......................................................................62Figure 33: A user having difficulty lifting a heavy platen glass cover...................................................66Figure 34: A seated user having difficulty reaching a raised platen glass cover....................................67Figure 35: Low contrast control panel labeling.......................................................................................72Figure 36: High contrast control panel labeling......................................................................................73Figure 37: A maintenance panel obstructing access for a user in a seated position................................74Figure 38: A seated user performing maintenance on a digital multi-function copier............................75Figure 39: A caution label incorrectly placed for a seated user..............................................................77Figure 40: A paper tray that is positioned too low for a seated user.......................................................79Figure 41: A paper tray handle that requires users to reach under the handle........................................82Figure 42: An open handle paper tray grip design..................................................................................83

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Introduction

What is a digital multi-function copier?A digital multi-function copier (Figure 1) integrates several

common office appliances into a single device. In addition to making copies, a typical digital multi-function copier supports printing, scanning, faxing, and document storage. Digital multi-function copiers are commonly used in medium to large office environments, and are intended for use by multiple users. When purchasing a digital multi-function copier for use in an office environment, it is important that the copier be accessible to all users who may need to use it, including users with disabilities. Smaller versions of the devices, sometimes referred to as “all-in-one” (AIO) devices, have been designed for use in homes or small businesses. For more information about desktop all-in-one devices, see monograph #2 in the Georgia Tech Research Institute Accessibility Monograph series.

Because of the number of functions typically supported by these devices, a rather complex user interface is often required. The complexity of the user interface, and certain design features necessary to accommodate the complex interface (e.g., small labels and icons, small and numerous controls), pose many accessibility challenges. The physical dimensions of these types of devices, which are typically tall and are designed to be used by users in a standing position, also pose accessibility challenges.

Digital multi-function copiers are often used in conjunction with print driver software that can be installed on computers that print to the devices. Some digital multi-function copiers also provide a web-based software interface as an alternative to the control panel on the device itself. These software applications can pose additional accessibility problems, beyond those associated with the copier’s hardware. However, this monograph focuses on the copier hardware, operating in a stand-alone configuration. For information on software accessibility issues, see the Accessibility Assistant website at http://accessibility.gtri.gatech.edu/assistant.

Why produce an accessible digital multi-function copier?There are three major reasons why a company might be interested in designing an accessible

digital multi-function copier. First, companies may decide to market the accessibility features of the device to help discriminate it from the competition. Accessibility can become a key market discriminator in a group of products with similar features. Furthermore, increased accessibility often leads to increases in the usability of the device for all users, another marketable benefit. Second, companies may produce accessible digital multi-function copiers in order to be in conformance with the standards of Section 508 of the Rehabilitation Act so that they can effectively market their products to the Federal Government. Section 508 of the Rehabilitation Act requires Federal departments and agencies that develop, procure, maintain, or use electronic and information technology to ensure that Federal employees and members of the public with disabilities have access to and use of information and data, comparable to that of the employees and members of the public without disabilities - unless it

Figure 1: Digital multi-function copier.

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is an undue burden to do so. Finally, companies might produce an accessible digital multi-function copier in order to broaden their market to include additional users with functional limitations.

What types of assistive technologies (AT) are commonly used with digital multi-function copiers?

Assistive technologies are pieces of equipment or software that are used to increase the capabilities of people with disabilities. The following is a list of AT that people might use either when interacting with or to aid in interacting with digital multi-function copiers:

Braille/tactile labels - Braille and other tactile labels such as high marks are labels that can be felt and used to identify objects tactilely. Braille is a raised dot alphabet system, with letters and numbers represented by patterns of raised dots called “cells.” Each cell is typically 6 to 7 mm high, and the dots are typically raised 0.5 to 1.0 mm from the background surface. High marks come in various forms. They may be preformed on a sticky surface that can be adhered to the item of interest, they can be stickers that are user generated through a specialized label maker, or they can be user generated with a type of glue which the user “draws” with and which dries as a hard surface.

o Used by: Braille labels are primarily used by people who are blind, although there are also people with low vision who know how to read it. Not all blind people know Braille. Most estimates place the percentage of blind people who read Braille at around 10%, though research shows that more than 90% of blind people who are employed read Braille. Other tactile labels can be used by all people with visual impairments.

o Used for: On a digital multi-function copier, tactile labels are applied to help users identify controls.

o AT impact on digital multi-function copier operation: Aftermarket tactile labels increase the likelihood that a person with visual impairments will be able to use a device that is otherwise not accessible. Tactile labels wear with significant use, and will eventually need to be replaced. Devices do not always have adequate room to add tactile labels. Also, users may not all agree on what the best shorthand label is for a given item; however, accessibility will be enhanced even if the label is not optimal for a given user.

Magnifying glass - A magnifying glass or magnifier is a handheld lens that is used to increase the size of an image. Typical magnification powers range from 2x to 10x. Some magnifying glasses have an integrated light, which may increase visibility for some users.

o Used by: Magnifiers are used by people with low vision, who may require larger text and images to be able to read and understand content.

o Used for: On a digital multi-function copier, magnifiers are used to read labels and displays.

o AT impact on digital multi-function copier operation: Magnifiers allow people with low vision to obtain information that is presented in a text size that is otherwise too small for them to read. The use of a magnifier requires the user to get very close to the object of interest. On a digital multi-function copier, this sometimes requires the user to assume an uncomfortable position. The design of the device and the placement of the item to be viewed may prevent a user from getting close enough with a magnifier to read the information of interest. Also, some spaces in a digital multi-function copier that users wish

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to access with their magnifiers may be too dark for the users to obtain readable images. This is one benefit of having a lighted magnifier.

Manipulation stick - A manipulation stick is a rod, typically a wooden dowel, used as an aid to increase a user's reach or strength. Common end attachments are rubber tips and hooks. Rubber tips are used to press against an object (for example, to close a cupboard door or activate a switch). Hooks are used to pick things up or to pull objects (for example, to open a drawer). It is not uncommon for a manipulation stick to have a rubber tip on one end and a hook on the other. Many people who use manipulation sticks have both a short stick and a long stick.

o Used by: Manipulation sticks are typically used by individuals who have limited strength in their hands or arms, or who have limited reach capability (i.e., people with upper mobility impairments).

o Used for: A manipulation stick can facilitate many tasks associated with use of a digital multi-function copier. Common tasks include activating controls, placing paper in the document feeder, opening or closing a paper drawer, and raising and lowering the platen glass cover.

o AT impact on digital multi-function copier operation: Manipulation sticks increase a user's reach. The manipulation stick can also increase a user's leverage. Manipulation sticks are sometimes used in combination with an electric wheelchair. The user positions the stick, and then uses the force generated by the wheelchair’s motor to apply the necessary pressure to activate a control or open a drawer. Manipulation sticks are only useful when they are available to the user. Users who have both a short stick and a long stick may not carry both, and may find that they need the one they don't have. Someone with a long manipulation stick may find that the stick is too long to use easily. For example, to use the longer stick, the user must often be at a further distance from the object being manipulated, which means that a lot of extra maneuvering may be required. Some environments will not provide enough room for a user to obtain the necessary distance, which may mean the user will be unable to use the stick. A greater degree of fine motor control may also be required to use a longer stick. Additionally, the ends of the stick may not be suitable for use with some devices. For example, the rubber end of the manipulation stick may be too large to activate some controls, or the gap on the hook may be insufficient to grab onto some objects with adequate leverage.

Optical character recognition - Optical character recognition (OCR) systems transcribe images of typewritten text into editable text, typically using a scanner and scanning software. Once the images of text are converted to editable text, a screen reader can convert the text to voice output.

o Used by: OCR systems are typically used by individuals who are blind.o Used for: On a digital multi-function copier, people use OCR systems to verify that they

are placing a piece of paper in the correct orientation on the device. This includes identifying which side of the paper contains text, and determining whether the paper should be oriented as portrait or landscape. Once the paper is scanned, a screen reader can be used to read the text to verify orientation and content.

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o AT impact on digital multi-function copier operation: OCR systems allow individuals who are blind to independently determine the orientation and content of a page to be copied.

Reaching aid - A reaching aid is 1 to 2 foot long device with a trigger handle used to open and close the end for the purpose of grasping objects that are difficult to reach. Figure 2 shows a typical reaching aid.

o Used by: Reaching aids are often used by people who use a wheelchair or who have an upper mobility impairment that limits their reach distance.

o Used for: On a digital multi-function copier, people use reaching aids to place papers on the device for copying, or to retrieve the output of the copy job.

o AT impact on digital multi-function copier operation: Reaching aids facilitate placement and retrieval of papers on feeder trays or output trays that are out of reach.

Figure 2: Reaching aid.

Scooter - A scooter is a motorized mobility device. Unlike a traditional wheelchair, the seat of a scooter can rotate left and right, approximately 90 degrees in either direction, giving the user more flexibility to interact with the environment.

o Used by: A scooter is typically used by individuals who have restricted use of their legs (i.e., people with lower mobility impairments).

o Used for: A scooter is not assistive technology to aid interaction with a device. Rather, a scooter is AT that users of a device may require that may inhibit their access to the device.

o AT impact on digital multi-function copier operation: The same limitations that apply to wheelchairs (described below) apply to scooters; however, scooter users typically have greater physical mobility, and can move forward on their seats or lean forward, which increases their reach capability over that of some wheelchair users. Whereas wheelchairs have a fixed seat, the rotating seat of a scooter allows the user to face the device without having the bulk of the mobility aid between the person and the device. This extra mobility increases the user's reach, and removes barriers created when approaching parallel to a device (see discussion of wheelchair impact, below).

Screen magnifier - A screen magnifier is a software application that presents a portion of a normal computer display in an enlarged fashion to assist users with low vision. Typically, either a portion of the display is dedicated to showing a magnified view of the area around the mouse cursor, or the full display shows a magnified view, with the user selecting the area that is magnified. Figure 3 shows the Windows Magnifier in use.

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o Used by: Screen magnifiers are typically used by people who are visually impaired, but still retain some functional vision.

o Used for: Screen magnifiers are used to enlarge the content displayed on a computer screen, typically up to 16x magnification, so that it can be seen and read by users with low vision.

o AT impact on digital multi-function copier operation: Many digital multi-function copiers have associated print driver software that runs on a computer. Some also provide a web-based interface as an alternate to the device’s control panel interface. A user with low vision can interact with the print driver or web application via the screen magnifier to set up options and operate the device.

Figure 3: Screen magnifier in use.

Screen reader - A screen reader is a software application that attempts to translate textual information displayed on a computer screen into speech or Braille for users with impaired vision. Screen readers can be used with web pages, documents, software applications, and operating system functions. They provide support for navigation, filling in data forms, and manipulating controls. Screen readers function best with software that has been designed with screen reader compatibility as a consideration; for example, a screen reader can convey information presented in images, but only if a textual equivalent to the information contained in the image is provided by the developer. Common screen reader applications include JAWS and Window-Eyes.

o Used by: Screen readers are typically used by people who are blind or who have very little functional vision. People with low vision often use screen magnifiers rather than screen readers.

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o Used for: Screen readers are used to make content displayed on a computer screen accessible to users who cannot see the screen by speaking the textual content aloud or by translating it to Braille for a Braille display.

o AT impact on digital multi-function copier operation: Many digital multi-function copiers have associated print driver software that runs on a computer. Some also provide a web-based interface as an alternative to the device’s control panel interface. A user who is blind can interact with the print driver or web application via the screen reader to set up options and operate the device.

Wheelchair - A wheelchair is a device used for mobility. Both manual and electric models are available. Some electric wheelchairs allow the user to raise and lower the height of the seat. The seat itself is fixed in a forward facing position.

o Used by: A wheelchair is typically used by individuals who have restricted use of their legs (i.e., people with lower mobility impairments).

o Used for: A wheelchair is not assistive technology to aid interaction with a device. Rather, a wheelchair is AT that users of a device may require that may inhibit their access to the device.

o AT impact on digital multi-function copier operation: Digital multi-function copiers are typically designed to be used by an individual of average height standing in front of the device. Wheelchair users are in a seated position, with an eye level considerably lower than that of a standing person. As a result, they may have difficulty seeing the displays, labels and warnings on the device, and may have difficulty reaching some device components. Wheelchair users vary in how they first approach a device like a digital multi-function copier. Many people like the forward approach (with the chair oriented such that they are facing the device), but this approach increases the user’s distance from the device, exacerbating the limitations already in place from being in a seated position. Others prefer to approach parallel to the device, but this approach also has problems. If the user approaches with his non-dominant hand closest to the device, he has to reach further to use his dominant hand. If the user approaches with his dominant hand closest to the device, he may need to put his arm in an awkward position in order to manipulate the controls. In some cases, open panels or drawers on the device may prevent the wheelchair user from approaching the device in certain ways, and may place the user too far away to be able to complete all necessary tasks. Furthermore, many people in wheelchairs are unable to move forward on their seats, and some cannot lean their upper bodies forward, limiting their reach abilities even more.

Which Section 508 standards apply to digital multi-function copiers?The following Section 508 standards are almost always applicable to digital multi-function

copiers:

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.

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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.

1194.31(a) At least one mode of operation and information retrieval that does not require user vision shall be provided, or support for assistive technology used by people who are blind or visually impaired shall be provided.

1194.31(b) At least one mode of operation and information retrieval that does not require visual acuity greater than 20/70 shall be provided in audio and enlarged print output working together or independently, or support for assistive technology used by people who are visually impaired shall be provided.

1194.31(c) At least one mode of operation and information retrieval that does not require user hearing shall be provided, or support for assistive technology used by people who are deaf or hard of hearing shall be provided.

1194.31(e) At least one mode of operation and information retrieval that does not require user speech shall be provided, or support for assistive technology used by people with disabilities shall be provided.

1194.31(f) At least one mode of operation and information retrieval that does not require fine motor control or simultaneous actions and that is operable with limited reach and strength shall be provided.

1194.41(a) Product support documentation provided to end-users shall be made available in alternate formats upon request, at no additional charge.

1194.41(b) End-users shall have access to a description of the accessibility and compatibility features of products in alternate formats or alternate methods upon request, at no additional charge.

1194.41(c) Support services for products shall accommodate the communication needs of end-users with disabilities.

Table 1, below, lists Section 508 standards that may apply to digital multi-function copiers, depending on the design features of the device and the circumstances surrounding its use.

Table 1: Potentially Applicable Section 508 Standards.

508 Standard that may apply Situations in which it could apply1194.25(b) When a timed response is required, the user shall be alerted and given sufficient time to indicate more time is required.

This standard applies if there any instances where the device limits the time allowed for users to perform an action or provide a response.

For example, if a user is setting up the device to send a fax, and the device times

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out and returns to copy mode if the fax is not sent within a certain period of time, this standard would apply.

1194.25(c) Where a product utilizes touchscreens or contact-sensitive controls, an input method shall be provided that complies with 1194.23(k)(1) through (4).

1194.23(k)(1) Controls and keys shall be tactilely discernible without activating the controls or keys.

1194.23(k)(2) Controls and keys shall be operable with one hand and shall not require tight grasping, pinching, or twisting of the wrist. The force required to activate controls and keys shall be 5 lbs. (22.2 N) maximum.

1194.23(k)(3) 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.

1194.23(k)(4) The status of all locking or toggle controls or keys shall be visually discernible, and discernible either through touch or sound.

This standard applies if the device has a touchscreen or other non-mechanical, contact sensitive controls.

Standard 1194.23(k)(3) only applies if key repeat is supported (e.g., keys repeat entry when pressed for a specified period of time).

Note: A best practice would be to apply 1194.23(k) to all mechanically operated controls such as buttons, knobs, and switches, whether or not 1194.25(c) applies. Some believe this approach reflects the true intent of the guidelines.

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.

This standard applies if the device uses biometric forms of user identification, such as a fingerprint scanner or a retinal scanner.

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.

This standard applies if the device provides voice output.

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.

This standard applies if the device provides voice output.

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.

This standard applies if color coding is used to convey information on the device.

1194.25(h) When a product permits a user to adjust color This standard applies if the device’s display

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and contrast settings, a range of color selections capable of producing a variety of contrast levels shall be provided.

uses color and the device permits the user to adjust color and contrast settings.

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.

This standard applies if the device is freestanding, non-portable, and intended to be used in one location and has operable controls.

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.

This standard applies if the device is freestanding, non-portable, and intended to be used in one location and has operable controls.

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.

This standard applies if the device is freestanding, non-portable, and intended to be used in one location and has operable controls.

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.

This standard applies if the device is freestanding, non-portable, and intended to be used in one location and has operable controls.

1194.31(d) Where audio information is important for the use of a product, at least one mode of operation and information retrieval shall be provided in an enhanced auditory fashion, or support for assistive hearing devices shall be provided.

This standard applies if audio information is important for use of the device. For example, audio information (speech output, etc.) for which there is not a redundant visual alternative would be covered by this standard.

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Evaluation MethodologiesThere are two basic methods of acquiring information about human performance: direct

measurement and derived assessments. If your goal is to evaluate the ability of a specific individual to perform in a technological system, then you place that individual in the system, give him or her a representative series of tasks to complete, and observe his or her performance. This direct measurement approach allows you to collect very good data about the ability of a single individual to interact with a given device, although the findings may not generalize to a larger population. More robust direct measurement studies adopt effective sampling strategies. By testing a diverse and representative group of users, the evaluator can generalize findings to a larger population segment with much better accuracy. Effective sampling for accessibility evaluations can be very challenging. Not only are there a variety of disability types to consider, but a variety of functional abilities within each disability type to consider as well.

There are eight major categories of functional limitations that can be addressed in an accessibility evaluation: upper mobility impairments, lower mobility impairments, hardness of hearing, deafness, low vision, blindness, speech impairments, and cognitive impairments. Within each category of functional limitation there are a variety of subtypes and levels of disability. For example, in the upper mobility category, someone may have a hand tremor that impacts fine motor control, a muscular abnormality that impacts strength, or an injury that limits reach. A user’s level of experience may also have a significant impact on the outcome of the evaluation. The accessibility problems experienced by someone who has been blind since birth may be significantly different than the accessibility problems experienced by someone who has recently lost his or her vision.

Derived assessment methods, such as functional assessments, checklist evaluations, or expert inspections, do not seek to measure human performance directly. Instead, such techniques are used to determine the extent to which a device meets formal or informal guidelines that have been associated with desired human performance objectives. A checklist evaluation, also known as a heuristic evaluation, is employed where a considerable body of knowledge about a specific domain of human performance relative to the product of interest exists (Nielsen, 1994). For example, a significant amount of research related to the readability of computer displays under normal lighting conditions has been performed. Researchers have analyzed the existing data and developed design guidance for the selection of a font size for important information on computer displays that applies to users with normal or correctable vision. Instead of performing detailed user-in-the-loop test procedures, evaluators can simply measure the font size and viewing distance, and compare the results to established design guidelines.

Occasionally, our knowledge about a specific domain is either incomplete, or the results of previous research are so ambiguous or conflicting, that the development of useful guidelines is impossible. Also, it may be impossible to formulate design guidelines without knowledge of the operational environment of the device. For example, many studies have expressed the importance of providing sufficient contrast on labels or other display items that must be discernable from the background. However, it is very difficult to specify a minimum contrast ratio without knowing details about the device and the context in which it will be used. The contrast ratio of a label must be greater if the label is to be read outdoors as opposed to a label that will only be read indoors. Also, the size, coloration, and position of the control can impact contrast requirements. Therefore, it may be

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impossible to develop a design guideline that is specific enough to objectively test. In such cases, other methods of evaluating accessibility must be employed or the expertise of the evaluator must be relied upon.

Given the challenges of sampling from a diverse population and our somewhat limited knowledge of designing for people with disabilities, it is necessary to combine data from both direct measurement and derived assessment evaluation techniques to obtain the desired degree of confidence in the evaluation results. Gaps in our knowledge in designing for people with disabilities can be addressed by performing user testing. Similarly, the sampling issues associated with human performance testing for accessibility can be addressed by using the derived assessment results to eliminate the need to test some populations and focus the assessment on others.

A variety of evaluation techniques and methodologies are available to the evaluator interested in measuring accessibility. However, there are five main high-level activities common to all accessibility evaluations:

Define evaluation goals Perform a task analysis Develop a Method of Test Perform the evaluations Document the results

How do I define the goals of the evaluation?It is critical to the success of the evaluation effort to determine the specific goals of the

evaluation and the intended audience of the test data prior to designing the data collection method. Failure to consider the goal of the evaluation may result in incomplete data or wasted efforts. If the goal of the evaluation is to measure conformance with a specific set of requirements, such as the Section 508 standards, then the accessibility evaluation should focus on checklist evaluation techniques supported by user testing when needed. If the evaluation goal is to determine if a particular device is accessible to a particular individual, then the evaluation can focus on user testing supported by a functional assessment.

Evaluators may need to know which device among several similar devices is most accessible. If asked to choose among several different options, evaluators should use empirical evidence of accessibility whenever possible. For example, a variety of different desktop printers are available from a variety of different manufactures. Each device can differ in terms of the accessibility features they provide and the accessibility barriers inherent in the designs of the equipment. An accessibility evaluation can assist someone in choosing a device that is most accessible to a given individual or a class of individuals. In order to measure general accessibility and compare the results among multiple products, both checklist evaluations and user testing are important.

Evaluators may also need to know how well the device conforms to a specific set of guidelines or technical requirements. Commonly, evaluations are performed to measure the conformance with the Section 508 standards for the purpose of preparing a Voluntary Product Accessibility Template (VPAT). A VPAT is used to allow companies to document and communicate the accessibility of a particular product to a potential Federal Government customer. An accessibility evaluation for this

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purpose relies heavily on the checklist evaluation approach; however, user testing may be required to document conformance with some technical requirements.

Accessibility evaluations can also be used to advise design. If conducted as part of an iterative design process, the results of an accessibility evaluation can be used to correct design deficiencies and assist developers in selecting from a list of potential design alternatives. Both the checklist evaluation and user testing play an important role in this type of evaluation.

Once the purpose of the evaluation has been determined, the evaluation goals should be expressed as a desired outcome of the evaluation. Candidate evaluation goals might include the following:

Measuring conformance with applicable standards of Section 508 Comparing the accessibility of product A to product B Selecting a design alternative from among two candidate alternatives by selecting the

alternative that maximizes accessibility to users without vision Determining the functional abilities required to operate the product

Proper evaluation goals formulated in terms of a desired outcome will assist in the selection of accessibility evaluation techniques.

How do I perform a task analysis?Task identification is the first, and most important, step in conducting a task analysis (Sanders

& McCormick, 1993; Drury, Paramore, Van Cott, Grey, & Corlett, 1988). The focus of the assessment is the system comprised of the user and the device that the user is intended to operate. Task identification is a structured analysis of all the user actions that are associated with the usage of a particular device or class of devices (Drury, 1983). There are three potential sources of information that the analyst may use to identify tasks. The first source is to observe users as they operate the device (or a comparable device). Users perform tasks with a device because of the requirements of their jobs - and thus it is beneficial to understand how users interact with devices as part of their everyday routine. By observing how users interact with a device in realistic work environments, researchers can decompose user actions into specific tasks.

The second source of information is technical documentation associated with the device, such as user manuals and training materials. These documents may provide information on tasks that are not readily observed, such as tasks performed only during initial setup of the device or in response to some malfunction. These documents may also provide information on alternative methods of performing tasks, beyond what current users may be observed doing. However, it should be noted that most documentation is centered on the technology, not on the user. Researchers should use caution when relying on technical documentation as the sole source of task analysis information. It is very tempting to derive a list of product features from the technical documents rather than a list of user tasks.

The third source of information about user tasks comes from the development of design reference scenarios that describe how users are envisioned to use the device in various circumstances. This source is particularly important when analyzing a new product or addition of new interfaces to an existing product. In such cases, it is not possible to observe users interacting with the new device, and

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technical documentation may still be immature. A design reference scenario is simply a narrative of the key elements in the work environment, and the usage of the device in that environment. A typical set of design reference scenarios would include perhaps 8-12 scenarios, each differing in the circumstances or aspects of functionality that are used.

After completing the task identification, it is often useful to denote tasks that are associated with maintenance, troubleshooting, or initial setup. Depending on the type of equipment and the complexity of the device, maintenance, troubleshooting, and initial set-up tasks may be performed by someone other than the end user, such as a technician or someone with specialized training.

Next, each task should be assigned a priority level. A prioritization of the task list should be developed based on an estimate of the essential or core features of the device, versus advanced features and features related to device set-up and maintenance (Fain & Folds, 2002). Priority may be divided into three levels. Priority 1 tasks must be able to be successfully completed irrespective of impairment in order for the product to be usable for all users. An inability to perform a priority 1 task because of an impairment would likely severely limit the accessibility of the product under evaluation for users with that impairment. Priority 2 tasks are secondary tasks that may be performed on an occasional basis to access advanced functionality. The inability to perform a priority 2 task because of an impairment, while not critical to the basic use of the product, may negate the value of advanced features of the product. Priority 3 tasks are tertiary tasks that are not necessarily performed by all users of the device, but must be performable by some operator on occasion. These tasks include initial setup tasks that are not ordinarily repeated, major troubleshooting tasks, and major maintenance tasks that users are expected to perform, albeit infrequently. The inability to perform a priority 3 task because of an impairment would not affect the basic accessibility of the product unless the product is to be used by a single user (or group of users all sharing the same impairment). Maintenance tasks may be associated with any priority level. Some routine maintenance tasks that any user might perform, such as loading paper, are judged to be priority level 1. Maintenance tasks that are performed rarely or only by specially-trained users, however, are judged to be priority level 3.

The final step in the process is the development of task scenarios. The basic unit or component of an accessibility test is a task scenario (or task sequence). Task scenarios are operationally realistic arrangements of tasks. A series of scenarios (approximately 8-12) that exercises the tasks identified in the task analysis should be developed. Repetition of key tasks is encouraged. The set of scenarios should fully exercise the user interface components of the device. For simple devices, the set of scenarios may include every single task identified during the task identification stage of the analysis. For more complex devices, it is acceptable to formulate the scenarios so that a representative set of tasks are selected from the full set of tasks.

When developing the scenarios, the evaluator should be mindful that every component of interest on the device is covered. For example, the task scenarios should cover maintenance tasks in addition to the more routine tasks. Some of the task conditions may have to be simulated. For example, when evaluating a printer it is important to evaluate the task of clearing a paper jam. The paper jam task can be simulated by instructing the participant to go through all of the steps involved in clearing a paper jam without actually having to induce a paper jam.

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How do I develop a Method of Test?A Method of Test (MOT) document should be created to establish the plan for addressing the

test objectives. The MOT document serves as a coordination tool amongst evaluators and forces those performing the evaluation to consider the details of the evaluation prior to data collection.

The first section of the MOT should identify the reason for performing the test, and the system that is being tested. Evaluators should pay careful attention to documenting the configuration of the device. Any additional software or other modifications above the baseline configuration of the device should be clearly noted. In addition, each test objective should be described, and a summary of planned test sessions should be outlined. The second section should describe, in considerable detail, the methods that will be used in performing the test. Evaluation goals should be stated clearly. In addition, the MOT should outline how the evaluation will produce an outcome that meets the stated goals.

The number and type of participants that are required by the test should be described. For example, a test objective that involves user-in-the-loop testing should describe the specific functional limitations that are required to participate in the test. Care should be taken to choose participants that represent 1) the user population that is expected to interact with the products and 2) the variety of functional limitations that the test is designed to consider. For example, when studying users with low vision, it is desirable to consider several different levels of general impairment as well as specific impairments, such as central field degeneration, in order to evaluate a more complete range of impairments. In addition to participant requirements, any specialized equipment required for the evaluation, such as force meters or assistive technologies, should be specified. Additional resources, such as personal attendants for participants or sign language interpreters for those without hearing, should be documented.

A step-by-step documentation of the procedure should be included in the MOT. The procedure section should document participant training, the particular tasks that the participant will perform, and any debriefing activities performed as a part of the test. A detailed description of the data that will be recorded should be provided. A performance measure can include task durations, error rates, task completion frequencies, and subjective impressions. Methods of data reduction and analysis should describe how the data will be interpreted. If any statistical analyses are planned, a description of each analysis should be included. The criteria specifying how the evaluator will determine if a test objective has been met should be included as well. For example, the test criteria might be that all of the checklist evaluation items must receive a pass rating, at least sixty percent of the users must be able to operate the device without experiencing difficulty, and no more than ten percent of participants should experience extreme difficulty when operating the device.

Which evaluation techniques should I use?The three main accessibility evaluation techniques are functional assessments, checklist

evaluations, and user testing. The accessibility evaluator will likely combine two or more of the techniques described below to produce results that meet the goals of the evaluation.

Functional Assessment. The goal of a functional assessment is to determine the human abilities needed to interact with the device. The functional assessment should be performed at the task level. Required abilities should be identified for each task.

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For example, selecting a menu item from the control panel of a copier requires vision in order to identify the menu item label, reach in order to select the item, fine motor control in order to select the button associated with the menu item, and strength to press the button. For the vision requirement, the evaluator should identify the font size of the label and determine the position of the operator during normal operation of the device. Based on these observations, the required level of visual acuity can be calculated. The evaluator might determine that in order to complete the menu item selection task, operators should have 20/70 or better visual acuity based on the size of the label and the position of the operator. Similarly, the fine motor control ability can be assessed by measuring the target and the positions of the surrounding controls. The activation of a small button with many closely-arranged surrounding controls will require more fine motor control ability than a large button with fewer surrounding controls. The evaluator might express fine motor control requirements in terms of a user’s ability to select a 0.2 cm button from a grid of buttons arranged 0.5 cm apart. Strength requirements can be measured directly. Using a calibrated force meter, the evaluator can take direct measurements of the force required to activate the button associated with the menu item selection. Reach requirements can also be assessed by direct measurement. Therefore, the evaluator might say that the functional abilities required to perform a menu selection from the control panel are 20/70 or better vision, the ability to select 0.2 cm buttons from a grid of buttons spaced 0.5 cm apart, a reach of 10 cm, and the ability to apply 0.2 lbs of force on a 0.2 cm button. Notice that the task did not require hearing or the ability to speak.

The results of the assessment are used in determining the focus and scope of user testing. If the device does not require hearing to operate, then there is no reason to test users that are deaf or users with limited hearing. Also, if the evaluator identifies a number of instances where a particular ability is exercised, it might be useful to focus user testing on the collection of data relative to that ability. For example, if the functional ability testing identifies instances where reach requirements may exceed the abilities of seated users, it might be useful to test a number of users in a variety of personal mobility aids. However, if the functional ability for a given task clearly exceeds the capabilities of a given user population, there is little reason to proceed with testing of associated tasks. For example, given that the task of selecting a menu item from a control panel requires at least partial vision, there is little reason to test a user without vision on that particular task.

An important exception to this general rule occurs when the goal of the evaluation is to provide design feedback. The evaluator may want to know if the device would be accessible if obvious accessibility problems are removed. In this instance, the evaluator would simply skip or assist the user in the performance of task components that would otherwise be extremely difficult or impossible to perform for a given user group. In the case of an evaluation involving a user who is blind, the evaluator would assist the user by reading the menu label or perhaps directing the user to the position of the associated control. By skipping only the task components associated with obvious accessibility deficiencies, the evaluator can collect data about the remainder of the task components. A designer could use the data to determine if additional accessibility interventions are required beyond the correction of the obvious problems.

In addition, the results of the functional assessment can be used during the checklist evaluation when the evaluation item is based on a human performance measurement. For example, when

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designing for someone with limited strength, an important accessibility guideline is to not require the user to apply more than five pounds of linear force to operate the equipment.

Finally, the functional assessment might be an important point of data in and of itself. By collapsing the requirements of functional ability across all of the tasks, the evaluator can identify the minimum set of abilities required to operate the device. This data might help consumers select products that match their own abilities.

Checklist Evaluation. In order to perform a checklist evaluation, the evaluator must be skilled in using measurement equipment such as calipers, torque meters, and force meters as well as the general operation of the device to be evaluated. Also, the evaluator must be prepared to use sound judgment and apply accepted principles when checklist items are ambiguous or ill-defined. In order to complete the evaluation, the evaluator first selects the requirements, standards, and design guidelines that both meet the evaluation goals and are applicable to the device. For example, if the primary evaluation goal is to test conformance with Section 508, then the checklist evaluation should be comprised of applicable Section 508 standards and related design guidance. If the goal of the evaluation is to measure accessibility in general, then the evaluator should select a broad range of recognized design guidelines, standards and principles. Potential checklist items can be derived from the accessibility literature found in peer reviewed journal articles, standards found in government regulations such as Section 508, and sound human factors design principles.

Once the list of checklist items is defined, the evaluator should define a method of evaluating each checklist item. Methods of evaluation may include direct observation, measurement, or expert inspection. Direct observation may be used when the checklist item evaluation method requires the evaluator to inspect the device for a particular design element or characteristic. For example, a checklist item derived from a guideline that recommends that the use of controls that required pinching be avoided might instruct the evaluator to inspect the device for such controls. The evaluator may determine that the device passes or fails the checklist criteria by simply inspecting the device to see if a control that requires pinching is present. Other checklist items may require the use of a tool in order to obtain some useful measurement. For example, a checklist item related to a guideline that recommends that users not be required to apply more than 5.0 pounds of linear force might instruct the evaluator to measure all linear control actions using a force meter. If any of the control action force requirements exceed 5.0 pounds for proper operation, the evaluator should fail the checklist item. Some checklist items rely on the expertise of the evaluator for proper determination of a pass/fail rating. If the checklist item is ambiguous or ill-defined, the evaluator must make a reasonable interpretation of the guideline based on prior experience and apply domain knowledge in order to make a pass/fail judgment. If a checklist item derived from a guideline requiring sufficient contrast is created, it is up to the evaluator to determine what is sufficient contrast. The adequacy of the contrast will, in part, depend on the operating environment of the equipment and the size and coloration of the user interface elements.

After the evaluation criteria have been defined for each checklist item, the evaluator performs the evaluation by assigning a pass/fail rating to each checklist item. The evaluator should record all measurements and keep a log of observations made during the evaluation. If the evaluation criteria require the judgment of the evaluator, the evaluator should defend his or her judgment by documenting

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the thought process used to arrive at the conclusion. After the evaluation is complete, a second qualified evaluator should review the first evaluator’s findings.

User Testing. In some ways, user testing for accessibility is very similar to user testing for usability. The evaluators should be properly trained in overall evaluation methodology, the specific protocol for a given test, and the special concerns that arise when dealing with users with special needs. The evaluator should be very well acquainted with the device under evaluation and should be able to recognize and if possible rectify unusual problems that may arise, irrespective of whether the problem is a consequence of a participant's behavior. For example, if the device is a copier, the evaluator should know how to clear paper jams, how to restore the system to its proper configuration for the test, and whether the machine is malfunctioning in a way that will render the test invalid.

The evaluation facility should be configured according to the requirements of the device and the intended user population that will be participating in the evaluation. For example, if users are expected to utilize assistive technologies during the course of the test, the device should be configured to facilitate the use of specialized equipment. When testing software or hardware devices in an integrated network environment, assistive technology software, such as screen readers or voice recognition software, should be installed and configured prior to performing the test. In addition, proper accommodations must be provided for participants with disabilities. These accommodations include the physical space and any functional accommodations that are appropriate for the impairments of the user. For example, access to the building and maneuvering space around the device should be considered if the intended user population includes persons who use wheelchairs. If required, space should also be provided for personal assistants or sign language interpreters.

In general, observers should not be present in the evaluation room while accessibility evaluations are taking place, unless such observers are playing a direct role in the evaluation protocol (e.g., watching for certain errors). Customer personnel and other interested parties may be accommodated by allowing them to observe video feeds from the evaluation room. Video cameras should be positioned so as to give a good view of the subject and a good view of the device during the test. An audio recording should be made for the purpose of crosschecking key event reports. The video recording should have a time of day counter, including seconds, that can be used to cross-check task performance times.

Accessibility evaluations should be conducted using participants who are properly trained and representative of the user population of interest. Although ease of access to users is always a consideration, care should be taken to ensure that the "user population of interest" is not defined based on the types of impairments that happen to be conveniently present. A typical accessibility evaluation might include representatives from the following user populations:

Users with upper mobility limitations, including users with limited strength, limited reach, and limited fine motor control

Users with lower mobility limitations, including users who use a manual wheelchair, a powered wheelchair, and users who use personal mobility aids such as scooters

Users who are hard of hearing Users who are deaf

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Users who have visual limitations including users who are color blind, users with poor visual acuity, and users with central field obstructions

Users who are blind Users who have speech limitations

Users with cognitive limitations should also be tested, if possible. In general, it is best to test each participant separately. Evaluation sessions should be scheduled so that the pace of the session is not hurried, allowing participants to take breaks as desired.

Proper informed consent must be obtained before proceeding with any aspect of the test. The participants' rights to discontinue participation at any time should be respected. Care should be given to ensure that each participant is fully capable of providing informed consent. Obtaining proper informed consent is especially critical when working with users with certain cognitive impairments. Evaluators should consult with a local research university’s Institute Review Board's guidelines for obtaining informed consent from users with disabilities.

Pilot testing of the test methods and evaluation instruments should be conducted before proceeding with the evaluation. Internal pilot testing is often less formal than external pilot testing, and is generally performed with participants recruited from within the organization performing the testing. Documents, methods, and other materials should be updated as appropriate in accordance with the pilot testing results. Internal pilot testing need not be performed with actual or simulated impairments, although it is beneficial to do so when possible. External pilot testing should be conducted with users who have some impairment of interest and are not part of the evaluation team. Again, documents, methods, and other materials should be refined as appropriate in accordance with the pilot testing results.

A test session should begin with participant orientation and training. The nature of the training is largely determined by the extent to which the device’s learnability or intuitiveness is of interest. If the device’s learnability or intuitiveness is not of interest, participants should be provided detailed training on the use of the device. Most accessibility evaluations will fall into the second category. The evaluator should point out each of the components that will be evaluated during the test session. Training should also include instruction and practice on key event reporting. The evaluator should also inform the participant about the purpose of the test and how the data collected during the test will be used. If an assistant (e.g., a sign-language interpreter), accompanies the participant, the individual giving the assistance should also be properly briefed about the procedures to be followed.

The evaluation should begin with the evaluator telling the participant about the scenario that is going to be performed. For example, if the purpose of the test was to evaluate the keypad of a cellular phone, the evaluator might explain to the participant that they will be retrieving a voice mail message and then returning an urgent phone call. Once the background for the scenario has been described, the evaluator should guide the participant through the scenario as required. There may be a tendency for an evaluator to wish to assist the participant in the completion of a task. Care should be exercised to ensure that any assistance offered by the evaluator does not unduly affect the outcome of the evaluation.

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At the beginning of a task, there is a clear "start" event - which can be generated by the evaluator, by the participant, or by the device. The evaluator or an observer should use a stopwatch to measure task performance time. The end of the task is similarly identified by a clear event, which can be a device outcome, a participant-generated event, or an evaluator-generated event.

The evaluator should be particularly sensitive to the fact that a given device may not be very usable for all users with disabilities, and that this could lead to some degree of frustration on the user's part. Evaluators should be prepared to intervene and move on to the next task to avoid unnecessary frustration. In general, the test session should be conducted with the evaluator directing the participant in the performance of the tasks.

The thinking-aloud approach to usability testing (Rubin, 1994; Dumas & Redish, 1993), while popular, is not particularly well suited to accessibility evaluations because it may create unnatural task performance demands that affect the validity of task performance measures (not to mention that thinking-aloud data is of questionable validity). The thinking-aloud approach also makes it difficult to collect data when testing individuals with speech impairments. As an alternative to continuous thinking aloud, which emphasizes the stream of consciousness of the participant; the key-event reporting method should be used. In this method, certain key events that are of interest to the evaluation are identified in advance. The evaluator should brief the participant about the key events and ask the subject to report them when they occur. Examples of key events that are often of interest are as follows:

1. “I can’t find X”2. “I can’t figure out how to do Y”3. “I didn’t expect that to happen”4. “I see that I have made an error” or “I didn’t mean to do that”5. “I don’t know why that happened”6. “I don’t know what to do next”

When the tasks associated with a given component of the device have been completed (or at whatever time specified by the test procedure), a user rating of accessibility should be collected. The rating should ordinarily be made using a Likert-type scale with an even number of rating points, unless there is a clear need to have a neutral point in the scale. A four-point scale is preferred unless there is a strong reason to use more scale points. Anchors are along the lines of:

1. = Completely unacceptable2. = Marginally unacceptable3. = Marginally acceptable4. = Completely acceptable

The evaluator should record any pertinent observations that are made during the test session. For example, if the participant makes a mistake that is obvious to the evaluator but is not part of a participant comment, then the evaluator should make a note of the occurrence. The evaluator should also make a note of any system malfunction or other event that might influence the interpretation of the test results. For example, if the participant was inadvertently interrupted during the performance of the test, then the evaluator should note the interruption. Important events that are not necessarily

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verbalized should also be recorded. These events might include the beginning and end of task sequences, the number and type of errors, or a record of tasks that are successfully completed.

The final activity in the test session should be a debriefing of the participant. The debriefing should include opportunity for the subject to share any comments on the device and/or the test methods. If possible and appropriate, the debrief should include a quick review of the session, including a summary of the subject's performance (e.g., “You were able to complete 8 of the 10 tasks. The two tasks you did not complete were binding the notebooks and folding the 8 x 14 pullouts”.) This review may help prompt the participant to make insightful comments. All serious comments offered by the participant during this debrief should be fully documented. Ad hoc comments made by the participant in earlier stages of the evaluation session, but not repeated by the participant during the debriefing, should be documented if the evaluator judges them to be important and germane to the accessibility of the product.

Data analysis involves the computation of task durations and the tabulations of user comments and errors. Each error should be documented and categorized. A summary tabulation of errors by error type should be generated. Analysis of data that involves interpretation of user comments should be cross-checked between analysts.

How should I document the results of the evaluation?The final step in the process is to integrate the results of the evaluation and document the

findings. Checklist items should be correlated with user test results when possible. For example, when documenting a problem with the force required to open an document assembly cover on a copier the evaluator might organize the results as follows:

The force required to lift the document assembly cover was 9.5 pounds, which exceeds the recommended maximum force of 5.0 pounds. Seven out of eight users with upper mobility limitations could not lift the cover.

If the purpose of the evaluation is to provide design feedback, the results of the evaluation should be organized by device component. The evaluator should precisely describe accessibility issues for each disability type that are associated with each device component. For example, the evaluator might offer the following feedback to designers:

The control panel is placed 56 inches above the floor, making it difficult for users in a seated position to operate. Control panel buttons are not easily identifiable by touch, making it difficult for visually impaired users to identify key control elements. Users with fine motor control limitations will find the control panel difficult to use because of the size and spacing of the buttons on the panel.

If the purpose of the evaluation is to document the general accessibility of the device, then the results should be reported by disability type and task priority. For example, the evaluator might offer the following observations:

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Blind users, in general, found the device very difficult to use because no alternative to the touch screen was provided. Users without vision were able to complete 20% of the priority 1 tasks, 16% of the priority 2 tasks, and 10% of the priority 3 tasks.

Regardless of how the results are organized, key accessibility issues should be documented in the conclusion of the evaluation report. It is important to clearly describe the accessibility issue and the population that will likely be impacted by the issue. When possible, illustrations should be used to communicate key points.

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Accessibility Issues and Potential SolutionsDigital multi-function copiers have a number of potential accessibility issues related to the

following components: Alerts/error messages/status indicators Control panels - Buttons Control panels - Keypads Control panels - Screens/displays Control panels - Touchscreens Document feeder Documentation Labeling Maintenance panels Paper trays

The following sections contain detailed information about common accessibility issues for each of these digital multi-function copier components. In addition, the populations impacted by the accessibility issues are discussed, and potential solutions are proposed.

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What are the common issues associated with alerts, error messages, and status indicators?

Alerts, error messages, and status indicators consist of visual or auditory information that is typically provided in response to a user action. They are intended to guide the user in correcting an error, performing maintenance, or completing a step in a procedure. On a digital multi-function copier, alerts generally appear as text or graphics on an LCD display. Auditory alerts, such as a beep to indicate an unacceptable action, are also common. Lights, sometimes of different colors, may also be used to indicate a status or identify an error.

Error messages are often unclear or enunciated inadequately.Detailed Description: Sometimes, error messages are expressed in a way that can only be understood by the manufacturer or an expert user trained in diagnosing error messages for the device. For example, the error message might contain only an error code that must be looked up in a service manual, rather than a description of the error that can be understood by a user. Error messages may also contain insufficient detail, or may be output in a form that cannot be adequately perceived by users with disabilities. For users who are hard of hearing, error messages that are not enunciated adequately may be difficult to interpret and understand. For users who are deaf, error messages that are only provided using sound, with no visual component, cannot be perceived. All users may have difficulty interpreting visual error messages if the message is not clear.

Figure 4: An unclear error message.

Populations Impacted: All users, particularly users who are hard of hearing and users who are deaf when dealing with auditory messages.

Potential Solutions: Provide error messages that clearly state the reason for the error and describe the steps needed to correct the error. Every error message should clearly state the reason for the error and provide instructions for how the user can fix the error. Without a clear presentation of this information, the user may not know what to do to correct the error, and may

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not even be able to understand what the error is referring to. For example, an error message that states “Cover open” on a device with multiple covers is not as useful as one that says “Front cover open.”

Figure 5: A clear error message.

When auditory error messages are provided, ensure that they are clearly enunciated. For auditory alerts, it is important that the error message be clearly stated, and that it be loud enough (or that a volume control is available with adequate volume settings for the environment in which the device is used).

When auditory error messages are provided, ensure that they are also provided visually. A redundant visual representation should be provided for all auditory alerts. For example, if a status is indicated by a series of beeps, the status should also be indicated via a message on the display or by a flashing light.

Applicable Section 508 Standards: 1194.31(a), 1194.31(b), 1194.31(c), 1194.31(d)

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Color coding is sometimes used as the sole means of conveying information.Detailed Description: The state of status indicators using red/green color coding as the only method of conveying information may be difficult for color blind and some low vision users to discern. For example, if a two-state light is used, with green representing the ready state and red representing a fault state, a user with red/green color blindness may not be able to determine if the device is ready or is in a fault state.

Figure 6: A dual color state light.

Populations Impacted: Users who are color blind, and users with low vision.

Potential Solutions: Do not use color pairs that are easily confused by color blind users to convey information. Red/green color blindness is most common; however, blue/yellow color blindness occurs occasionally. Total color blindness, where users are not able to perceive color and only see shades of grey, is extremely rare. Using color combinations other than red/green and blue/yellow to represent information will help avoid confusion among most users who are color blind.

Always provide a redundant alternative to color, such as text and/or location, that conveys the same information that the color conveys. Anywhere color coding is used, the message conveyed by that color coding should be conveyed through text as well, in order to ensure that color blind users have access to the same information other users do. For instance, in the example used above, a text indication that says “Ready” when the copier is in the ready state could be provided. The text message would communicate the same information to a color blind user that the green light communicates to a non-color blind user.

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Figure 7: Redundant coding.

Additional Comments: Although the solutions presented above may improve accessibility for those who are color blind (and some with low vision), they in no way solve the problem for users who are blind and cannot see these color cues, and are therefore dependent on tactile or auditory differentiation of status information.

Applicable Section 508 Standard: 1194.25(g)

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Sometimes the state of a status indicator can only be determined visually.Detailed Description: The status of certain common user interface elements can only be discerned visually. For example, a momentary push button may be paired with a light to indicate when the function is active. Since a momentary push button does not indicate its status tactilely, users must determine the status of the element by observing the associated indicator light. Users without vision cannot see the indicator light, and therefore have no way of discerning the status of the user interface element.

Figure 8: A visual-only user interface element status indicator.

Populations Impacted: Users who are blind.

Potential Solution: Always provide a redundant alternative to vision, either touch or sound, that conveys the same information that is conveyed visually. One method is to use a control with tactilely-discernible positions. A toggle power switch is a good example; once the user learns, for example, that left is “off” and right is “on,” he or she can determine by feel whether a device is off or on. Providing voice output is also a good solution. (Non-verbal output, such as beeps, can also be used to indicate status, but the sounds must be recognizable and distinguishable to be effective.)

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Figure 9: A visual and tactile user interface element status indicator.

Applicable Section 508 Standard: 1194.25(c)

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Redundant sensory feedback is unavailable or inaccessible.Detailed Description: If an alert or status indicator relies on a single sensory modality (vision, for example) to convey information to the user, a user with a disability in that particular sensory modality will find the alert difficult or impossible to detect. Users with lower mobility impairments may not be able to see status indicators on the control panel from a seated position. Users with upper mobility impairments may unintentionally activate controls, and may not realize they have done so unless feedback is provided. Redundant feedback, such as visual information supplemented by an auditory display, can greatly increase the accessibility of alerts and status indicators to users with various types of impairments.

Populations Impacted: Users who are blind, users with low vision, users with lower mobility impairments, and users with upper mobility impairments.

Potential Solution: Provide an option to have auditory feedback for key events. Auditory feedback, even feedback as simple as beeps or clicks, when key events such as keypresses or document insertions occur can increase the accessibility of the device. If the device beeps when a key is activated, users will be better able to know when a keypress did not activate the key, when a key was pressed accidentally, or when a key was pressed multiple times. Beeping when documents are correctly loaded into the document feeder provides useful feedback for users with a variety of disabilities.

Applicable Section 508 Standards: 1194.31(a), 1194.31(b)

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What are the common issues associated with control panel buttons?Control panel buttons are mechanically operated push buttons used to interact with the device.

Buttons mounted flush with the panel are difficult for those without vision or with low vision to detect.

Detailed Description: Users with vision impairments may navigate by touch, by moving their hands over the control panel in order to determine where controls are located. Buttons that are mounted flush with the surface of the control panel are difficult for users without vision and users with low vision to feel when they move their hands over the control panel. Furthermore, users without vision typically depend on behaviors such as counting to find a specific control, and this is problematic when there is insufficient tactile differentiation of the controls.

Figure 10: Flush mounted control panel buttons.

Populations Impacted: Users without vision, and users with low vision.

Potential Solutions: Ensure that buttons are sufficiently raised above the control panel so they are tactilely discernable by users without vision. As seen in the image below, buttons should be raised at least 1/32” above the panel so that users can locate the buttons tactilely. This will improve the accessibility of the buttons to users with visual impairments.

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Figure 11: Raised control panel buttons.

Include Braille or raised large text on buttons that are flat to help users without vision determine exactly what each button is. For devices where it is, for some reason, not possible to sufficiently raise the buttons on the control panel, consider providing Braille labels on the buttons so that users without vision will still have access to the buttons. Providing large, raised lettering would have the additional benefit of assisting those with low vision in identifying the functionality of the buttons.

Figure 12: Braille labels on control panel buttons.

Make the texture of the buttons different from that of the control panel to make the buttons more easy to distinguish tactilely. Providing a rougher texture on buttons if the control panel surface is smooth or providing a more rubbery texture on the buttons if the control panel is made of a hard material can help users without vision distinguish buttons from the control panel surface more easily.

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Combining all of these approaches (providing sufficiently raised buttons with accompanying Braille labels or large raised lettering and a distinctive texture) would increase accessibility significantly.

Applicable Section 508 Standards: 1194.25(c), 1194.31(a)

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Buttons that do not have sufficient contrast with the panel are difficult for users with low vision to detect.

Detailed Description: If buttons are the same color as the control panel, they may blend in with the panel, making it difficult for a user with low vision to distinguish the button from the surrounding surface.

Populations Impacted: Users with low vision.

Potential Solution: Ensure that buttons are different in color from the control panel surface. Buttons should be colored differently from the control panel, making them easy for a low vision user to distinguish. Using sufficiently contrasting colors will aid users in distinguishing buttons from one another. For instance, in the image displayed below, the blue “Enter” button is bright and easily distinguishable from the gray color of the control panel (but the other buttons are very close in color to the background and may not be readily identified by users with low vision). Backlighting buttons may also help distinguish them from the surrounding surface.

Figure 13: A control panel button with a contrasting color.

Applicable Section 508 Standard: 1194.31(b)

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Buttons that are small and close together may be difficult to differentiate or activate without activating adjacent controls.

Detailed Description: If control panel buttons are small and are placed too close together, they may be difficult for users without fine motor control to activate without accidentally activating adjacent controls. Small, tightly spaced control panel buttons are also more difficult for users who are blind to differentiate by feel.

Figure 14: A control panel with small, tightly-spaced buttons.

Populations Impacted: Users without fine motor control, and users who are blind.

Potential Solution: Ensure that buttons are large and are spaced far enough apart to minimize the possibility of accidental activation of adjacent buttons and to enhance tactile differentiation. When designing the control panel for a digital multi-function copier, include adequate space between buttons. According to the Human Factors Design Standard (HFDS), minimum spacing of 0.5” (with 2” preferred) is recommended for buttons that are not part of keyboards. Make sure that the diameter of the buttons is large enough (up to a maximum diameter of 1”) that a user who does not have fine motor control is able to activate a button even if he or she does not hit the button directly in the center. Increasing button size and spacing will also aid those who need to differentiate the buttons by feel. Buttons with very little separation can be problematic for those who depend on the tactile quality of the buttons to find the ones they need.

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Figure 15: A control panel with large, adequately spaced buttons.

Applicable Section 508 Standards: 1194.25(c), 1194.31(a), 1194.31(f)

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Buttons that are all shaped the same or that do not have shapes corresponding to their functions are more difficult for the blind to memorize and for the cognitively impaired to understand.

Detailed Description: Button shapes should correspond to their functionality. Commonly used or important controls should be more prominent. Control panel buttons that are logically grouped together, such as on a numeric keypad, should all have the same shape and distinguishing features. Users who are blind rely on memorization to learn where specific keys are located on a device. If all buttons are shaped exactly the same, memorizing the location of the various buttons becomes a difficult task. For users with limited cognitive abilities, it may be difficult to understand the difference between buttons that look exactly the same.

Figure 16: Identically shaped buttons for controlling unrelated functions.

Populations Impacted: Users who are blind, and users with cognitive impairments.

Potential Solution: Include distinguishing features for buttons, including differences in shape. Ensure that buttons with different functions are distinguished from one another in some way. For example, on many digital multi-function copiers the “Start” button is larger than all the other buttons because of its relative importance. It is also a good idea to make all buttons that have similar functions, such as all of the main menu buttons, the same shape. In addition to shape and size coding, color coding and grouping can be used as distinguishing features for controls.

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Figure 17: Button shape coding and distinguishing features.

Applicable Section 508 Standards: 1194.25(c), 1194.31(a)

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Control panel buttons may not provide a surface that facilitates button activation.

Detailed Description: Buttons that are slick or have no concave curvature are more difficult for some users to activate. Users without fine motor control or users that utilize manipulation sticks may have difficulty activating buttons that are slick and not curved inward, because their fingers or manipulation sticks may slip off the button and activate adjacent buttons.

Figure 18: Control panel buttons with slick, convex surfaces.

Populations Impacted: Users without fine motor control, and users that utilize manipulation sticks.

Potential Solutions: The buttons on the device should be concave. Concave buttons help prevent users’ fingers from slipping off the buttons.

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Figure 19: Control panel buttons with concave surfaces.

The buttons on the device should be made from a high friction material. A rubberized coating or other high friction material helps prevent users’ fingers from accidentally slipping off the controls.

Applicable Section 508 Standard: 1194.31(f)

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Buttons requiring very little force to activate can increase the number of accidental activations.

Detailed Description: Buttons that are activated with very light forces are more frequently accidentally activated. This causes problems for users who are blind or who have low vision, because they may rely on touch to locate buttons, and may accidentally activate buttons if the activation force is too low. Users lacking fine motor control may touch buttons unintentionally, and accidentally activate them if the activation force is too low.

Populations Impacted: Users who are blind, users with low vision, and users without fine motor control.

Potential Solution: Buttons should require a sufficient activation force to reduce the number of accidental activations. Button activation forces in the range of 0.22 to 1.8 pounds are recommended (Bullinger, Kern, and Muntzinger, 1988).

Applicable Section 508 Standards: 1194.31(a), 1194.31(f)

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Chorded button operations can be difficult for users with upper mobility impairments.

Detailed Description: Some control panel functions may require that two or more buttons be pressed simultaneously. This can be difficult for users who cannot use both hands simultaneously for various reasons, and for users who use manipulation sticks to activate controls.

Populations Impacted: Users with upper mobility impairments.

Potential Solution: Avoid functions that require simultaneous button presses. If chorded functions cannot be eliminated entirely, consider implementing a “sticky keys” function that will allow the modifier key to be pressed before the action key, eliminating the requirement that both keys be pressed at the same time.

Applicable Section 508 Standard: 1194.31(f)

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What are the common issues associated with control panel keypads?Control panel keypads include both numeric keypads and alphanumeric keyboards. In addition

to the issues listed for buttons, the following issues apply specifically to keypads:

Keypads may lack nibs on the “5”, “F”, and “J” keys.Detailed Description: Users without vision are accustomed to having a small nib on the “5” key on numeric keypads, and on the “F” and “J” keys on alphanumeric keyboards. These nibs assist users to orient themselves to the positions of the various keys. Keypads and keyboards that lack these nibs are difficult for users without vision to use, because they cannot orient themselves to the correct keys and key positions.

Populations Impacted: Users who are blind.

Potential Solution: Include sufficient nibs that can be easily felt on the “5”, “F”, and “J” keys. On numeric keypads, always include a nib on the “5” key that can be easily differentiated by feel. This can be a small raised dot or a dashed line. On alphanumeric keyboards, always include nibs on the “F” and “J” keys so that users can orient themselves to the keyboard layout.

Applicable Section 508 Standards: 1194.25(c), 1194.31(a)

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Non-standard numeric keypads pose a problem for some users.Detailed Description: There are two standard layouts for numeric keypads, the telephone keypad layout (most common for digital multi-function copiers) and the adding machine layout (typical of most computer keyboards). Non-standard numeric keypad layouts create difficulties for users who are blind, who rely on the use of the standard layouts to orient themselves to the keypad, and for individuals with cognitive impairments, who may become confused when faced with a non-standard layout.

Figure 20: A numeric keypad with a non-standard key arrangement.

Populations Impacted: Users who are blind, and users with cognitive impairments.

Potential Solution: Use a standard keypad layout on the control panel for the digital multi-function copier. If a numeric keypad is used on the device, ensure that one of the standard layouts is used. Also, ensure that the keys are tactilely discernable, and provide feedback to the user when a key is pressed.

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Figure 21: A keypad with a standard key arrangement.

Applicable Section 508 Standards: 1194.25(c), 1194.31(a)

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The common methods of cursor advancement for numeric keypad text entry cause problems for some users.

Detailed Description: Some numeric keypad text entry schemes automatically advance the cursor to the next location after a time-out period, and others require the user to manually advance the cursor. Some schemes adopt a semi-automatic approach, where the cursor must be manually advanced to enter consecutive characters using the same number key, but will automatically advance when a different number key is pressed. Each of these approaches has advantages and disadvantages. Manually advancing the cursor requires the user to make additional keystrokes, which may be difficult for users with upper mobility impairments. The user may be required to move his or her hand off of the keypad to advance the cursor, and to subsequently relocate and reorient to the keypad, which may be difficult for users who are blind or who have low vision. Conversely, automatically advancing the cursor may cause problems for users who are unable to press the keys fast enough to select the desired letter before the timeout occurs; this may include users who are blind, users with low vision, users with cognitive impairments, or users with upper mobility impairments.

Populations Impacted: Users who are blind; users with low vision; users with cognitive impairments; users with upper mobility impairments.

Potential Solutions: Make the method of advancing the cursor for numeric keypad text entry a user-configurable option. Allowing users to select the method of cursor advancement (i.e., manual, automatic, semi-automatic) that works best for their particular disabilities increases the accessibility of the device.

Make cursor advancement timeouts adjustable. If the automatic or semi-automatic method is used, allowing users to set the timeout period to a duration appropriate for their personal needs will alleviate timeout problems for those users.

Provide voice output when characters are entered and confirmed. Having the device voice the current character as the user cycles through the available characters on a key would help users with visual impairments select the desired character. Having the device voice each character as it is confirmed (either manually or by a time-out), in a voice distinct from that used to voice the selection of characters, would also help users know when a character has been confirmed and know when the cursor has advanced to the next location.

Applicable Section 508 Standards: 1194.25(b), 1194.25(c), 1194.31(a), 1194.31(f)

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What are the common issues associated with control panel screens and displays?

Control panel screens and displays are typically LCD displays integrated into the control panel, through which information (status information, alerts, error messages, etc.) is provided to the user. Backlit buttons are also included in the category of control panel displays.

Wheelchair users may have difficulty reading LCD screens.Detailed Description: Control panel displays are often positioned at a height and angle that is optimized for standing users. The display may be positioned too high for seated users to see. The viewing angle may also be a problem for seated users. LCD screens have a limited viewing angle; that is, the angle at which a user can clearly view the display is limited. Therefore, a seated user, whose normal line of sight is at an extreme angle with respect to the front of the display, may have difficulty seeing the display clearly.

Figure 22: LCD viewing angle problems for a seated user.

Populations Impacted: Users operating a digital multi-function copier from a wheelchair or other personal mobility device.

Potential Solutions: Provide a tiltable control panel. If the control panel is designed so that it can be easily tilted and locked into multiple positions, the needs of both seated and standing users can be accommodated.

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Figure 23: A tiltable control panel.

Use a detachable control panel. If the control panel is designed so that it can be detached from the device, the detached panel can be operated from a seated user’s lap, or on a wheelchair-accessible work surface.

Figure 24: A detachable control panel.

Provide an alternate interface, such as a secondary control panel, a voice display, or software designed for the remote configuration of the device. Devices that contain LCD displays that are inaccessible (because of their height or angle) to those in a wheelchair may be augmented with an alternative user interface. Three forms of alternative user interfaces are possible. First, control panel functionality could be replicated in a fixed or attached auxiliary control panel that can be accessed from a seated position. Second, a voice display could be integrated with the control panel, so that visual feedback is presented in an auditory fashion as well. For example, using the numeric keypad as an input device, the user could navigate through configuration menus that are voiced, without having to rely on vision to perceive the menus. The voice

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display approach could be combined with voice recognition for hands-free control panel operation. Finally, in a networked environment, the control panel functionality could be replicated in a software application that is compatible with standard assistive technology applications. Therefore, a wheelchair user could configure the digital multi-function copier at his or her workstation or at a workstation located conveniently close to the device.

Figure 25: A remote user interface.

Consider offering a detachable document feeder assembly that can be positioned on a wheelchair accessible work surface. A document feeder assembly that is detachable from the main printer assembly could be positioned in such a way as to be usable by both standing or seated users.

Figure 26: A detachable document feeder assembly positioned on a wheelchair accessible table.

Use a cathode ray tube (CRT) screen rather than an LCD screen, or use an LCD panel with extended viewing angles. In the past, CRT displays offered higher contrast and wider viewing angles than LCD displays. In recent years, advances in LCD display technology have closed

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the gap between LCDs and CRTs. If an LCD display is used, ensure that the display provides adequate contrast, and that its horizontal and vertical viewing angles accommodate both seated and standing users.

Include backlighting on LCD displays. Adding a backlight to an LCD display makes the display more readable by users with low vision and users viewing the display from a wheelchair.

Include a way to manually adjust the contrast of the display. Many displays do not have a contrast adjustment, or provide contrast adjustment controls on the display itself. However, if a user in a seated position is unable to see the display because of insufficient contrast, he or she will be unable to use controls on the display to adjust the contrast. If there is a manual control, such as a dial on the side of the display, users can adjust the contrast without having to read the display. If the range of contrast adjustment and the viewing angle of the display are sufficient, seated users may be able to find a setting that will allow them to use the display.

Figure 27: A manual display contrast adjustment control.

Applicable Section 508 Standards: 1194.25(j)(2), 1194.25(j)(3), 1194.31(f)

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Small icons and text are difficult for low vision users to perceive.Detailed Description: Control panel button labels and display screen labels and symbols may be difficult to read if the text or graphics are too small.

Figure 28: A control panel with small labels.

Populations Impacted: Users with low vision.

Potential Solutions: Ensure that the font size of the text is large enough for low vision users to see. For 20/20 vision, the Human Factors Design Standard (HFDS) recommends that the height of characters occupy a visual angle of 16 to 24 minutes of arc. To compute the character height, use the following formula:

h = 2dTan(x/2)

where h is the character height, d is the viewing distance, and x is the desired angle in radians. (One radian equals 3437.747 arc minutes, or 57.296 arc degrees.)

1194.31(b) of Section 508 states that a mode that does not require visual acuity greater than 20/70 must be provided. Multiplying the character height (h) calculated for 20/20 vision by 3.5 (70/20) yields the recommended character height for 20/70 vision for the specified viewing distance.

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Figure 29: A control panel with large labels.

Ensure that icons are large enough for low vision users to see. The largest dimension (height or width) of icons should be at least as large as the character height calculated above. Icons should be made as large as possible, given the space provided. Often, a control is fairly large, but the icon on the button is only a small fraction of the size of the control. If a control will support the same icon in a larger size, the larger size should be used to enhance visibility for those with low vision.

Applicable Section 508 Standards: 1194.25(c), 1194.25(g), 1194.25(h), 1194.31(b)

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Complex menus and inconsistent display elements may be difficult for users with limited cognitive abilities to understand.

Detailed Description: Menu structures with multiple levels of nested menus can be difficult for users with cognitive impairments to navigate. Inconsistent use of terminology can also be confusing to users with cognitive impairments. For example, if the function for making double sided copies is labeled “two sided” in some places and “duplex” in others, it could be confusing for a user with a cognitive impairment. Similarly, inconsistent or excessive use of abbreviations can decrease reading comprehension for users with cognitive impairments. Ensuring consistency and keeping the interface as simple as possible are important usability considerations, and will improve the accessibility of the device to all users.

Populations Impacted: Users with cognitive impairments.

Potential Solutions: Reduce the complexity of menu structures where possible. Consider providing shortcuts to frequently used menu items, so that users do not have to work through a complex menu structure to get to a frequently used item.

Use consistent terminology and abbreviations throughout the user interface. Ensure that names and abbreviations are applied consistently throughout the user interface. When possible, avoid using abbreviations, as these may be difficult for users with limited cognitive abilities to understand.

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Control panels are often out of reach of seated users.Detailed Description: Users of wheelchairs or other personal mobility devices may have limited reach capabilities. Some users have power wheelchairs that allow them to raise and lower their seats to access items located on the top of a device; however, many users have manual wheelchairs that do not allow for these sorts of adjustments. Some wheelchair users are unable to shift their upper bodies, limiting their access to only controls within arm’s length. Thus, it is important that the control panel of a digital multi-function copier be operable from a seated position, without requiring excessive leaning or reaching.

Populations Impacted: Users operating a digital multi-function copier from a wheelchair or other personal mobility device.

Potential Solutions: Follow the ergonomic standards to determine where to position the controls on a digital multi-function copier to ensure easy access by all users.

The position of any operable control should be determined with respect to a vertical plane that is 48 inches in length, centered on the operable control, and at the maximum protrusion of the product within the 48 inch length.

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.

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.

Operable controls shall not be more than 24 inches behind the reference plane.

Provide a control panel that can be controlled remotely, through use of either a PDA or a cell phone. Digital multi-function copier control panels are inaccessible to many wheelchair users. Some, but not all, wheelchair users can access a few of the controls and have enough mobility place a document on the device, but are seated too low to see enough of the touchscreen display for extensive interaction. One way to enhance accessibility is to provide remote control of the copier, through a PDA, cell phone, or similar device. Users would be able to set up the copier through the PDA or cell phone interface, and then put the items to be copied on the device and press “Start.” A remote control option increases access to controls that require extended interaction and better visual access than major controls like the “Start” button.

Applicable Section 508 Standards: 1194.25(j), 1194.31(f)

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Status is not discernible through either touch or sound.Detailed Description: Users who are blind can only get information through their tactile or auditory senses, yet status information is typically presented only visually. This also decreases the chances of a user who has low vision readily perceiving the status of various items. Users who are in wheelchairs may also obtaining information that is presented visually, because the height or viewing angle makes the controls and displays difficult to see from a seated position.

Populations Impacted: Users who are blind or have low vision, and users who are in wheelchairs and are unable to position themselves to adequately see controls and displays.

Potential Solution: Provide status information in an aural or tactile format. If status information is provided in an aural or tactile format in addition to a visual format, users with visual impairments can access the information more readily. An example of an aural format is the use of a voice display that announces the state of controls. An example of a tactile format is a physical toggle; the state of the switch is indicated by the position of the switch, which can be determined by touch.

Applicable Section 508 Standards: 1194.25(c), 1194.31(a), 1194.31(b)

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What are the common issues associated with touchscreen interfaces?Touchscreens are commonly used as the primary user interface on digital multi-function

copiers. A touchscreen interface allows the designer to accommodate a wide variety of controls and functions in a relatively small area on the control panel.

Touchscreen controls are not tactilely differentiable.Detailed Description: Users without vision, and some users with low vision, navigate by touch, moving their hands over the control panel to determine where various controls are located. Touchscreens are inaccessible to users without vision, because controls displayed on touchscreens are not tactilely discernable - they are merely graphical controls, displayed on a screen.

Figure 30: A touchscreen on a digital multi-function copier control panel.

Populations Impacted: Users who are blind and users with low vision.

Potential Solutions: Provide an alternate interface, such as a secondary control panel, a voice display, or software designed for the remote configuration of the device. Devices that contain touchscreens that are inaccessible to those without vision may be augmented with an alternative user interface. Touchscreen functionality could be replicated in a fixed or attached auxiliary control panel using control elements with functionality, position, and status that are easily discernible by touch. A voice display could be integrated with the control panel, so that visual feedback is presented in an auditory fashion as well. For example, using the numeric keypad as an input device, the user could navigate through configuration menus that are voiced, without having to rely on vision to perceive the menus. The voice display approach could be combined with voice recognition for hands-free control panel operation. In a networked environment, the control panel functionality could be replicated in a software application that is compatible with standard assistive technology applications. Therefore, a user without vision could configure the device at his or her workstation or at a workstation located conveniently close to the device.

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Figure 31: A digital multi-function copier control panel in a voice display mode.

Avoid using touchscreen displays for primary functions on digital multi-function copiers. The complexity of digital multi-function copiers often requires control interfaces capable of presenting multiple pages of control options. The number of functions associated with modern devices simply exceeds the available control panel space, making dedicated physical controls impractical. However, accessible, dedicated physical controls could be used for important functions, with less accessible visual controls used for less frequently used configuration items and maintenance activities.

Figure 32: Use of hardware buttons for critical functions.

Applicable Section 508 Standards: 1194.25(c), 1194.31(a)

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Touchscreen controls typically utilize small text labels.Detailed Description: Because of the limited space that is typically available on touchscreen displays, and the requirement to accommodate a large number of controls on the display, many touchscreen interfaces use very small text labels.

Populations Impacted: Users with low vision.

Potential Solutions: Make the font as large as possible for the size of the button. For 20/20 vision, the Human Factors Design Standard (HFDS) recommends that the height of characters occupy a visual angle of 16 to 24 minutes of arc. To compute the character height, use the following formula

h = 2dTan(x/2)

where h is the character height, d is the viewing distance, and x is the desired angle in radians. (One radian equals 3437.747 arc minutes, or 57.296 arc degrees.)

1194.31(b) of Section 508 states that a mode that does not require visual acuity greater than 20/70 must be provided. Multiplying the character height (h) calculated for 20/20 vision by 3.5 (70/20) yields the recommended character height for 20/70 vision for the specified viewing distance.

While this font size may not be possible for all touch controls, making the text as large as possible for each individual control will increase the chance that users with low vision will able to read the labels.

Provide contrast adjustment for the display. Although users with low vision prefer and generally require larger fonts, they may be able to read smaller fonts if the contrast is sufficient. Provide a range of contrast settings for the user to adjust through a hardware control. (Software controls are problematic because if the contrast is insufficient for a user, the user may not be able to read the display in order to find the contrast adjustment controls.)

Provide an alternate display mode with larger fonts and high contrast options. An alternate display mode that uses larger fonts and provides high contrast options, even if it contains only the most frequently used controls, will be useful for users with low vision.

Provide alternatives to the touchscreen to facilitate interaction by users with low vision. A voice display could be integrated into the device, so that visual content is presented in an auditory fashion as well. For example, using the numeric keypad as an input device, the user could navigate through configuration menus that are voiced, without having to read the menus on the display. The voice display approach could be combined with voice recognition for hands-free control panel operation. In a networked environment, the touchscreen functionality could be replicated in a software application that is compatible with standard assistive technology applications, such as screen magnifiers. Therefore, a user with low vision could configure the device at his or her workstation or at a workstation located conveniently close to the device.

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Applicable Section 508 Standard: 1194.31(b)

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Touchscreen controls are easily activated, often resulting in unintentional control activations.

Detailed Description: A touchscreen interface requires very little pressure to activate controls. The low strength requirement is beneficial to users with limited upper body strength, but can cause problems for other users, especially if the user interface is designed with very small active areas surrounding the interface elements. When controls are small and closely spaced, users who have upper mobility impairments or lack fine motor control will have difficulty activating specific controls without also activating adjacent controls. Users without vision may inadvertently activate touchscreen controls while moving their hands over the control panel to locate hardware controls. If redundant auditory feedback is not provided when controls are activated, these accidental activations may go unnoticed.

Populations Impacted: Users who are blind, users with limited upper body strength, and users lacking fine motor control.

Potential Solutions: Ensure that buttons are large and are spaced far enough apart to minimize the possibility of accidental activation of adjacent buttons. When designing a touchscreen interface, include adequate space between buttons. According to the Human Factors Design Standard (HFDS), minimum spacing of 0.5” (with 2” preferred) is recommended for buttons that are not part of keyboards. Make sure that the diameter of the buttons is large enough (up to a maximum diameter of 1”) that a user who does not have fine motor control is able to activate a button even if he or she does not hit the button directly in the center.

Provide an alternate display mode with larger controls. An alternate display mode that provides larger controls, even if it contains only the most frequently used controls, will be useful for users who lack fine motor control.

Provide alternatives to the touchscreen to facilitate interaction by users with disabilities. For example, voice output could be combined with voice recognition for hands-free control panel operation. In a networked environment, the touchscreen functionality could be replicated in a software application that is compatible with standard assistive technology applications. A user could configure the device at his or her workstation or at a workstation located conveniently close to the device, and avoid having to interact with the touchscreen controls.

Applicable Section 508 Standards: 1194.25(c), 1194.31(a), 1194.31(f)

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What are the common issues associated with the document feeder?The document feeder is the top part of a digital multi-function copier where pages are placed on

the platen glass or in the automatic document feeder (ADF) tray.

Platen glass cover may be too heavy for users with limited upper body strength to operate.

Detailed Description: In order to manually place originals on the platen glass, users must lift a hinged platen glass cover. The platen glass cover is often integrated into an automatic document feeder, which increases the weight of the cover. The cover can be hard to lift without springs or pistons to counteract the weight of the cover.

Figure 33: A user having difficulty lifting a heavy platen glass cover.

Populations Impacted: Users with limited upper body strength.

Potential Solution: Ensure that the force required to lift and lower the platen glass cover does not exceed 5 pounds.

Applicable Section 508 Standards: 1194.25(c), 1194.31(f)

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Users in a seated position may not be able to lower the platen glass once it is in a raised position.

Detailed Description: The platen glass cover may be out of reach for people who use wheelchairs or other personal mobility devices. If the platen glass cover is left in a raised position by a previous user, or if the user allows the cover to open fully, a user without extended reach may not be able to reach the cover to close it.

Figure 34: A seated user having difficulty reaching a raised platen glass cover.

Populations Impacted: Users who use wheelchairs or other personal mobility devices, and therefore have limited reach.

Potential Solutions: Ensure that, when raised, the document feeder is still within the recommended range for operable controls. Follow these standards to determine where to position the controls on a digital multi-function copier:

The position of any operable control should 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.

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.

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.

Operable controls shall not be more than 24 inches behind the reference plane.

Provide a grasp point that remains in the accessible range when the cover is fully raised. An add-on strap or handle that remains within reach for users in a seated position when the platen

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glass cover is fully raised will improve the accessibility of the device for users who use wheelchairs or other personal mobility devices.

Include stops at cover angles other than 90 degrees. It is often unnecessary to open the platen glass cover to its fully open (90 degree) position to place or retrieve a document from the platen glass. However, the cover may not be designed to stay open at any position other than the 90 degree position. Providing stops at other angles (e.g., 30, 45, or 60 degrees) allows users to open the cover enough to place a document, while keeping the cover within easy reach. Additional stops also make one-handed operation of the device easier, because the user can place the document without having to simultaneously hold the platen glass cover open.

Applicable Section 508 Standards: 1194.25(j), 1194.31(f)

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Users may have difficulty placing and retrieving documents.Detailed Description: Users operating a digital multi-function copier from a wheelchair may have difficulty placing documents on or retrieving documents from the document feeder if it is located above shoulder height. If seated users are able to reach to place the document on the glass or the feeder, they may be too low to verify the orientation (e.g., landscape vs. portrait) and alignment of the document. Adjusting the paper guides from a seated position may also be difficult. Users who are blind cannot visually verify the alignment and orientation of the paper on the platen glass or in the document feeder. Users who lack fine motor control may have difficulty precisely aligning documents on the platen glass.

Populations Impacted: Users who use wheelchairs or other personal mobility devices, and therefore have limited reach; users who are blind; users who lack fine motor control.

Potential Solutions: Ensure that the document feeder and paper guides are not positioned above the maximum height range for operable controls. Follow these standards to determine where to position the controls on a digital multi-function copier:

The position of any operable control should 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.

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.

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.

Operable controls shall not be more than 24 inches behind the reference plane.

Provide a hard stop to assist in document placement on the platen glass. Some digital multi-function copiers require users to place documents on the platen glass between two marks, or to place the document with a small offset from the edges of the glass. This causes problem for users who cannot see the platen glass, either due to visual impairment or viewing angle. It also causes problems for users lacking fine motor control. Providing at least one edge, and preferably two, against which documents can be placed on the platen glass reduces the problems that these users have with aligning documents on the glass.

Applicable Section 508 Standards: 1194.25(j), 1194.31(f)

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What are the common issues associated with product documentation?Documentation refers to any setup instructions, user manuals, or quick reference guides

provided with a product, regardless of the format in which they are provided (printed manual, CD, etc.). Documentation is used to assist the user in learning how to set up and use the device.

Documentation is often not available in alternate formats, such as Braille or audio instructions.

Detailed Description: It is important that product documentation be made available to all users, so that they may obtain answers to their questions, have a thorough understanding of all the features of the product and how it operates, and determine what product’s error messages mean and how to fix them. Providing accessible forms of documentation is essential for a product to be accessible to users with disabilities.

Populations Impacted: Users who are blind and users with low vision.

Potential Solution: Provide an accessible form of documentation, or provide an option for the user to request a copy of the documentation in an accessible format. When possible, an accessible form of documentation should be included along with the standard form of documentation. This could be in the form of Braille instructions or audio documentation. If it is not practical or cost-effective to include an accessible form of documentation with the product, provide a phone number that a user can call to request a copy of the manual in an accessible format.

Applicable Section 508 Standards: 1194.31(a), 1194.31(b), 1194.41(a)

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Documentation available electronically or on a manufacturer's website is not accessible.

Detailed Description: Documentation necessary to use the product and perform routine maintenance of the product should be accessible to all users. For example, technical support websites and documentation distributed electronically on installation media should be made accessible. Adhering to the Section 508 standards and the World Wide Web Consortium’s Web Content Accessibility Guidelines (WCAG) is important to ensure that the documentation for the device is accessible to users with visual impairments. Problems with electronic documentation may include incompatibility with screen reader software, cluttered display of information, low contrast, small fonts, etc.

Populations Impacted: Users who are blind and users with low vision.

Potential Solution: Ensure that electronic documentation is accessible to screen readers. The Section 508 1194.22 technical standards and the W3C’s Web Content Accessibility Guidelines should be consulted and adhered to when creating electronic documentation for a digital multi-function copier. All documentation should reviewed using a screen reader to make sure that the documentation is accessible when using such technology.

Applicable Section 508 Standards: 1194.31(a), 1194.31(b), 1194.41(a)

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What are the common issues associated with product labeling?Labeling refers to the text or graphics used to identify controls. Labeling also includes warning

messages or notices typically applied to the device as stickers; these notices may also be presented as either raised or recessed lettering or graphics.

Raised or recessed lettering is often are the same color as the background, providing no contrast, and making it difficult for low vision users to perceive the lettering.

Detailed Description: Raised or recessed lettering is often the same color as the control panel surface, so the contrast between the lettering and the background is insufficient. The lack of contrast makes it difficult for users with low vision or low contrast sensitivity to distinguish the lettering from the background surface.

Figure 35: Low contrast control panel labeling.

Populations Impacted: Users with low vision or low contrast sensitivity.

Potential Solution: Ensure that raised or recessed lettering is different in color from the control panel surface. The contrast between the lettering and the control panel surface should be at least 3:1. If the device is to be used in very bright lighting or outdoors, then a contrast ratio of at least 10:1 may be more appropriate. Using sufficiently contrasting colors will help users with low vision or low contrast sensitivity perceive and read the lettering.

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Figure 36: High contrast control panel labeling.

Applicable Section 508 Standard: 1194.31(b)

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What are the common issues associated with maintenance panels?Maintenance panels are the doors used to obtain access to the interior of a device, generally for

the purpose of performing a maintenance task, such as clearing a paper jam or replenishing supplies.

Access to maintenance areas to perform routine maintenance tasks, such as replenishing toner or the clearing paper jams, is inhibited by maintenance panels that open downward.

Detailed Description: If a maintenance panel door is designed such that it opens downward (i.e., if the door is hinged on the bottom), the door can become an obstruction for a user in a wheelchair or other personal mobility device. Users with limited reach or limited upper body strength may also have difficulty performing maintenance tasks when close access to the machine is prevented by a maintenance panel.

Figure 37: A maintenance panel obstructing access for a user in a seated position.

Populations Impacted: Users with limited reach, users with limited upper body strength, and users of personal mobility devices.

Potential Solution: Ensure that maintenance panel doors do not restrict access to the maintenance area when in the open position. Maintenance panels that open downward and are retained at a 90 degree angle to the device prevent users in a wheelchair from approaching the device in order to access the maintenance area, and require longer reaches to access the maintenance area, causing problems for users with limited reach or upper body strength. Panels that either fold flat or open to the side reduce these problems.

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Figure 38: A seated user performing maintenance on a digital multi-function copier.

Applicable Section 508 Standards: This issue is maintenance-related and therefore not directly covered under Section 508. If users (as opposed to maintenance technicians) are expected to perform these types of tasks, maintenance issues should be considered when designing the device.

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Routine maintenance tasks, such as replenishing toner or clearing paper jams, are inhibited by maintenance panels, levers, and supply cartridges that mobility impaired users find difficult to operate.

Detailed Description: Users with limited upper body strength and movement often have difficulty raising covers and maintenance panels to access device components. Levers also pose difficulties for this user group because of the amount of force that is sometimes required to operate them. Removing and replacing components such as ink cartridges may also be problematic if fine motor control is required.

Populations Impacted: Users with limited reach or limited upper body strength, and users lacking fine motor control.

Potential Solutions: Ensure that excessive force is not required to perform any routine maintenance tasks. The force required to lift covers, open maintenance panels, remove and replace toner or ink cartridges, operate levers, etc. should not exceed 5 pounds of linear force.

Ensure that maintenance does not require fine motor movements. Users should be able to perform routine maintenance tasks without having to perform simultaneous actions or make fine motor movements such as pinching or grasping. Also, internal components that must be manipulated to perform routine maintenance tasks should not be located in places that are difficult to reach.

Provide feedback when maintenance tasks are successfully completed, where possible. Users may be unsure if a toner cartridge is fully inserted or if a maintenance panel is completely closed. The device should provide some form of feedback (a beep, a mechanical click, etc.) to help users determine when an action has been successfully completed.

Applicable Section 508 Standards: This issue is maintenance-related and therefore not directly covered under Section 508. If users (as opposed to maintenance technicians) are expected to perform these types of tasks, maintenance issues should be considered when designing the device.

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Maintenance instructions and warning labels may be difficult for some users to read, due to placement and/or font size.

Detailed Description: Labels containing maintenance instructions or warnings may be placed in a position that is optimized for someone standing. Users in wheelchairs may not notice these labels, or may not be able to read them, because of the placement and orientation of the labels. Labels placed on the rear of the device or within the device may also be difficult for users in wheelchairs to read. Users with low vision may have difficulty reading labels that are printed in a small font size or that are located in a position that prevents the users from approaching the labels for a closer view.

Figure 39: A caution label incorrectly placed for a seated user.

Populations Impacted: Users of personal mobility devices and users with low vision.

Potential Solutions: Place labels on the front of the device when possible. The needs of seated users should be considered when placing warning or instruction labels. Labels should be oriented toward the front of the device when possible. Avoid placing labels inside covers or deep inside the device where they are difficult to access.

Ensure that the font size of the text is large enough for low vision users to see. For 20/20 vision, the Human Factors Design Standard (HFDS) recommends that the height of characters occupy a visual angle of 16 to 24 minutes of arc. To compute the character height, use the following formula:

h = 2dTan(x/2)

where h is the character height, d is the viewing distance, and x is the desired angle in radians. (One radian equals 3437.747 arc minutes, or 57.296 arc degrees.)

1194.31(b) of Section 508 states that a mode that does not require visual acuity greater than 20/70 must be provided. Multiplying the character height (h) calculated for 20/20 vision by 3.5

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(70/20) yields the recommended character height for 20/70 vision for the specified viewing distance.

Applicable Section 508 Standards: 1194.31(b), 1194.31(f)

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What are the common issues associated with paper trays?Paper trays are the drawers into which the blank paper supply for the device is placed. Some

devices do not have a drawer, but instead have a tray with an adjustable support; frequently, a panel needs to be opened to access the tray.

Paper trays are sometimes positioned too low for wheelchair users to access.Detailed Description: Users operating a digital multi-function copier while seated in a wheelchair may have difficulty opening, closing, and loading paper into paper trays that are positioned low on the copier. It is difficult for many wheelchair users to lean over close to the floor, and impossible for some who do not have reach capability.

Figure 40: A paper tray that is positioned too low for a seated user.

Populations Impacted: Users operating the device from a wheelchair or other personal mobility device.

Potential Solution: All paper trays should be positioned high enough from the floor that excessive leaning is not required for access. Follow these standards to determine where to position the controls on a digital multi-function copier:

The position of any operable control should 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.

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.

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.

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Operable controls shall not be more than 24 inches behind the reference plane.

Applicable Section 508 Standards: 1194.25(j), 1194.31(f)

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Adding paper sometimes requires fine motor control, and reconfiguring the paper size within a paper tray often requires excessive strength and fine motor control.

Detailed Description: Precisely positioning paper in a paper tray sometimes requires fine motor control. If users need to reconfigure paper tray to change the paper size, they must often manipulate controls that can be difficult to use. Paper trays can also be too heavy for users with limited upper body strength.

Populations Impacted: Users with upper mobility impairments with limited strength or fine motor control.

Potential Solutions: Ensure that the force required to pull out a paper tray is not excessive. The forces required to open and close the paper tray should be less than 5 pounds.

Provide paper guides to assist users in inserting and aligning paper. Design paper trays in such a way that it is easy to correctly insert paper into the tray in the proper alignment by providing paper guides and stops.

Ensure that reconfiguring the tray for different paper sizes does not require excessive force, fine motor control, pinching, or simultaneous actions. Paper guides and stops within the paper tray that must be reconfigured to accommodate different paper sizes should not require linear forces in excess of 5 pounds. Controls intended to be rotated with the fingertips should not require torque in excess of 10 inch-pounds. Fine motor control (use of tools, manipulation of small parts) should not be required to reconfigure the paper size. Pinching motions or simultaneous actions (press down and turn, pinch and pull) should not be required to reconfigure the paper size.

Ensure that fine motor control is not required to reinsert paper trays. Users lacking strength or fine motor control may find it difficult to reinsert a paper tray if the tolerance for insertion is very small. Consider providing a guiding mechanism that is wide at the insertion point and tapers as the tray is inserted, to “funnel” the paper tray into the device correctly without requiring very fine alignment by the user. A paper tray design that eliminates the requirement for the user to simultaneously support the weight of the tray and align the tray (for example, allowing the paper tray to be rested on a lip on the front of the device before being pushed into the device) is also beneficial.

Applicable Section 508 Standards: 1194.25(c), 1194.31(f)

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Paper trays that require reaching under the tray (palms up) to pull the tray out may be problematic for users in wheelchairs and users with upper mobility impairments.

Detailed Description: If paper trays are low and require a palms up hand orientation to open, the additional reach distance (compared to reaching with a palms down hand orientation) may make it difficult for users in wheelchairs to open the paper trays. Users with upper mobility impairments may have difficulty orienting their hand palms up and having enough strength to pull a paper tray open; this type of handle grasp may also interfere with the use of assistive devices.

Figure 41: A paper tray handle that requires users to reach under the handle.

Populations Impacted: Users of personal mobility devices, users with limited reach, users with limited strength, or users with limited motor control.

Potential Solutions: Provide a handle that can be grasped from either the top or the bottom. Providing a handle design that can be used in more than one way may shorten the required reach, and increases the chances of any user being able to operate it; it also provides for more effective use of some assistive devices.

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Figure 42: An open handle paper tray grip design.

Provide a mechanically operated tray that is controlled with a button. Providing a paper tray that can be opened at the push of a button that requires minimal force to operate would make the task of opening the paper drawer easier for many users. It would also remove the barrier created by requiring users to turn their hands in an awkward manner, which may in turn reduce the amount of force they can apply. In addition, paper drawers typically require greater than 5 pounds of force to open; this could be resolved with a button control that requires a minimal amount of force.

Applicable Section 508 Standard: 1194.25(c), 1194.31(f)

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References1. Ahlstrom, V., and Longo, K., Human Factors Design Standard (HFDS), Washington, D.C.:

Federal Aviation Administration, 2003.2. Bullinger, H., Kern, P., and Muntzinger, W.F., Design of Controls. In Salvendy, G. (ed)

Handbook of Human Factors, John Wiley & Sons, New York, NY, 1988.3. Drury, C. G., Task analysis methods in industry, Applied Ergonomics, 14.1 (1983), 19-28.4. Drury, C. G., Paramore, B., Van Cott, H. P., Grey, S. M. and Corlett, E. N., Task analysis. In

Salvendy, G. (ed) Handbook of Human Factors, John Wiley & Sons, New York, NY, 1988.5. Dumas, J. S., and Redish, J., A Practical Guide to Usability Testing, Ablex, Norwood, NJ,

1993.6. Fain, W. B., & Folds, D. J., An approach to measuring accessibility of office automation

equipment. In Proceedings of the Human Factors and Ergonomics Society 46th Annual Meeting. Santa Monica, CA: Human Factors and Ergonomics Society, 2002.

7. Mercinelli, M., Accessibility Requirements for New Telecommunications Equipment, A COST 219bis Guidebook, COST 219bis, European Commission, 1999.

8. Microsoft, Microsoft Windows guidelines for accessible software design, 1999. (No longer available.)

9. MIL-HDBK-46855a, Human Engineering Program Process and Procedures, Washington, D.C.: Department of Defense, 1999.

10. National Council on Disabilities, Design for Inclusion: Creating a New Marketplace. Washington, D.C, 2004.

11. Nielsen, J., Usability Engineering, Morgan Kaufmann, San Francisco, CA, 1994.12. Nielsen, J., and Mack, R. L. (eds), Usability Inspection Methods, John Wiley & Sons, New

York, NY, 1994.13. Pierce, B. (ed), U.S. House Passes Braille Commemorative Coin Bill, Braille Monitor, 49.5

(2006).14. Rubin, J, Handbook of Usability Testing, John Wiley and Sons, New York, NY, 1994.15. Sanders, M.S., McCormick, E.J., Human factors in engineering and design, McGraw-Hill, New

York, NY, 1993.16. United States Access Board, Americans with Disabilities Act Accessibility Guidelines for

Buildings and Facilities (ADAAG), Washington, D.C., 2002.17. United States Access Board, Electronic and Information Technology Access Advisory

Committee (EITAAC), Recommendations for Accessibility Standards: Electronic and Information Technology, Washington, D.C., 1999.

18. United States Access Board, Electronic and Information Technology Accessibility Standards; Final Rule, 36 CFR Part 1194, Federal Register, 65.246 (2000).

19. United States Access Board, Telecommunications Act Accessibility Guidelines; Final Rule, 36 CFR Part 1193, Federal Register, 63.22 (1998).

20. Vanderheiden, G. C., Design for people with functional limitations. In Salvendy, G. (ed), Handbook of Human Factors and Ergonomics, John Wiley & Sons, New York, NY, 1997.

21. World Confederation for Physical Therapy, Evidence Based Practice – An International Perspective, London, UK, 2002.

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Appendix A: Checklist Evaluation

Disability Evaluator Instructions Guideline SourceOperable with limited cognitive skills or language facility

Set an account code up which requires user access before use. Where possible, verify user settings are individually customized (where settings are activated by a user control card or sign-in procedure) such that the system can be autoconfigured to match different user preferences.

Section 2551193.41(i)(2)(d) - Advisory Guidance

Operable with limited cognitive skills or language facility

Verify that optional voice control is provided. Section 2551193.41(f)(2)(b) - Advisory Guidance

Operable from a seated position

Determine whether forward reach is unobstructed. If so, verify that the high forward reach is a maximum of 48 inches and the low forward reach is a minimum of 15 inches.

ADAAG Revised308.2.1

Operable from a seated position

Determine whether forward reach is obstructed. If so, verify that the clear floor space extends beneath the element for a distance not less than the required reach depth over the obstruction. Determine the reach depth. If the reach depth is 20 inches (510 mm) or less, verify that the high forward reach does not exceed 48 inches (1220 mm). If the reach depth is greater than 20 inches (510 mm), verify that it is no greater than 25 inches (635 mm) and that the high forward reach does not exceed 44 inches (1120 mm).

ADAAG Revised308.2.2

Operable from a seated position

Determine whether side reach is unobstructed and whether a parallel approach is allowed. If so, verify that the high side reach is a maximum of 48 inches (1220 mm) and a minimum of 15 inches.

ADAAG Revised308.3.1

Operable from a seated position

Determine whether side reach is obstructed and a parallel approach is allowed. Determine the reach depth. If the reach depth is 10 inches (255 mm) or less, verify that the high side reach does not exceed 48 inches (1220 mm). If the reach depth is greater than 10 inches (255 mm), verify that it is no greater than 24 inches (610 mm) and that the high side reach does not exceed 46 (1170 mm) inches.

ADAAG Revised308.3.2

Operable with all disability types

Verify that this self-contained product is usable by people with disabilities, without requiring the use of assistive technologies. Verify that the product does not require the end-user to attach assistive technology to the product.

Section 5081194.25(a)

Operable with all disability types

Identify any time-out situations. Verify that if a timed response is required, the user is alerted and given sufficient time (adjusted by the user over a range equal to at least 5 times the average user setting with a value of at least 5 seconds) to indicate that more time is required. Verify that response times can be adjusted or that a non-timed alternative is available.

Section 5081194.22(p)1194.23 (d)1194.25(b)

Section 2551193.41(g)(2)(a)1193.41(g)(2)(b) - Advisory Guidance

EITAAC5.2.1.7.1

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Disability Evaluator Instructions Guideline Source5.3.4.3

Operable with complete blindness

Operable with some vision loss

For all controls, verify that controls and keys are tactilely discernible without activating the controls or keys.

Section 5081194.23(k1)1194.25(c)1194.26(a)1194.26(b)

Operable with complete blindness

For all controls, identify any locking or toggle controls or keys. Verify that the status of any locking or toggle control keys is visually discernible, and discernible either through touch or sound.

Section 5081194.23(k)(4)1194.25(c)1194.26(a)1194.26(b)

Operable with all disability types

Identify whether the device uses biometric forms of user identification or control. Verify that when biometric forms of user identification or control are used, an alternative form of identification or activation is available, which does not require the user to possess particular biological characteristics. Assumption: Providing a password capability is an acceptable alternative.

Section 5081194.25(d)1194.26(c)

EITAAC5.2.1.13

Operable from a seated position

Determine whether the device has operable controls, is freestanding, non-portable, and intended to be used in one location. Identify any operable controls, and measure their distance from the reference plane (defined in 1194.25(j)(1) and the associated figure). If the control is 10 inches or less behind the reference plane, verify that the height of the control is a maximum of 54 inches, and a minimum of 15 inches above the floor. Assumption: Operable controls do not include voice operated controls.

Section 5081194.25(j)(2)

Operable from a seated position

Determine whether the device has operable controls, is freestanding, non-portable, and intended to be used in one location. Identify any operable controls, and measure their distance from the reference plane (defined in 1194.25(j)(1) and the associated figure). If the control is more than 10 inches, and not more than 24 inches behind the reference plane, verify that the height of the control is a maximum of 46 inches, and a minimum of 15 inches above the floor. Assumption: Operable controls do not include voice operated controls.

Section 5081194.25(j)(3)

Operable from a seated position

Determine whether the device has operable controls, is freestanding, non-portable, and intended to be used in one location. Identify any operable controls, and measure their distance from the reference plane (defined in 1194.25(j)(1) and the associated figure). Verify that there are no operable controls more than 24 inches behind the reference plane. Assumption: Operable controls do not include voice operated controls.

Section 5081194.25(j)(4)

Operable with all disability types

Identify all accessibility features. Verify that an option exists to switch each accessibility feature ON/OFF (such that multiple features could be on at once or only one feature could be on at a given time, depending on user needs).

Section 2551193.35(3)(c) - Advisory Guidance

Operable with all disability types

Identify display options. Verify that information (things the display presents to us) is presented in as many redundant

Section 2551193.35(1)

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Disability Evaluator Instructions Guideline Sourceforms as possible (i.e., allows the use of visual, aural, and tactile strategies). When audio information is important for the use of the product, verify that the information is also provided visually, and, where appropriate, tactilely. Verify that multiple modes are available for controls as well.

EITAAC5.2.1.4.2

Vanderheiden, 1997Operable with all disability types

Verify that systems and equipment have standardized terminology, look, and feel (e.g., use established layouts for keyboards and keypads).

HFDS2.4.5

Vanderheiden, 1997Operable with all disability types

Identify error conditions. Verify that systems are tolerant of human errors.

HFDS2.5.4

Operable with all disability types

Identify documentation of unsafe operating states and actions. Verify that systems and equipment clearly identify safe and unsafe operating states and actions.

HFDS2.5.6

Operable with all disability types

Identify all warning labels. Verify that design, location, procedural guidance, and suitable warning labels are provided to prevent damage to equipment while it is being handled, installed, operated, or maintained.

HFDS2.5.10

Operable with all disability types

Identify situations which require mounting or alignment. Verify that equipment includes physical features that prevent improper mounting or alignment, or at least has labels or codes to identify proper mounting and alignment.

HFDS2.5.11

Operable with all disability types

Identify any user feedback. Verify that systems and equipment provide timely and informative feedback to user actions to keep the users informed about what is happening.

HFDS2.6.1

Operable with all disability types

Identify and implement control actions and observe the outcome of each control action. Verify that user actions cause predictable results.

HFDS2.6.2

Operable with all disability types

Identify all labeling and instructions on the device. Verify that systems and equipment use terms and images familiar to the user.

HFDS2.6.3

Operable with all disability types

Identify all control actions. Verify that systems and equipment are designed to minimize hand and eye movements, thus maximizing efficiency.

HFDS2.6.8

Operable with all disability types

Determine whether help information is provided. Verify that help is available in the event that the user has difficulty operating or maintaining software, systems or equipment.

HFDS2.7.1

Operable with all disability types

Identify controls used solely for maintenance and adjustment. Verify that, in general, controls used solely for maintenance and adjustment are covered during normal equipment operation, but are readily accessible and visible to a user when required.

HFDS6.1.1.3.7

Operable with all disability types

Identify all controls. Verify that controls are designed and located so that they are not susceptible to being moved accidentally or inadvertently, particularly critical controls where such operation might cause equipment damage, personnel injury, or system performance degradation.

HFDS6.1.1.6.1

Operable with all disability types

Identify all labels. Verify that the characters identifying controls and displays are larger than the characters

HFDS6.1.2.1.4

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Disability Evaluator Instructions Guideline Sourceidentifying control positions.

Operable with all disability types

Identify all labels. Verify that labels are not located where they obscure other information needed by the user or where a control or user’s normal hand or arm position will obscure the label.

HFDS6.1.2.2.2

Operable with all disability types

Identify all labels. Verify that labels are placed very near the control that they identify.

HFDS6.1.2.2.3

Operable with all disability types

Identify all labels. Verify that labels are placed above the control they describe, or when located above eye level, may be located below the control if label visibility will be enhanced.

HFDS6.1.2.2.4

Operable with all disability types

Identify all labels. Verify that labels are oriented so that alphanumeric characters are read horizontally from left to right.

HFDS6.1.2.2.138.2.11.4.13

Operable with all disability types

Identify any use of abbreviations. Verify that abbreviations are used in labels only if they are familiar to the users.

HFDS6.1.2.4.5

Operable with all disability types

Identify any use of labels and compare the wording to that used in documentation. Verify that designations and terms used on labels are consistent with designations and terms in user documentation and parts catalogs.

HFDS6.1.2.4.6

Operable with complete blindness

Operable with some vision loss

Verify that instructional/user documentation is available in alternate formats or modes (e.g., electronic, large print, audiotape, or Braille), upon request, at no additional charge. Contact the manufacturer to ask if these alternate formats are available, and if they can be provided. Look at any electronic format and determine if it is accessible to someone using a screen reader, whether font size can be increased for low vision users, and whether large print can be generated from the electronic format.

Section 5081194.41(a)

Section 2551193.33(a)(2)

EITAAC5.2.3.2

Operable with all disability types

Contact technical support. Verify that a description of accessibility and compatibility features of products is available in alternate formats or methods, upon request, at no additional charge.

Section 5081194.41(b)

Section 2551193.33(a)(1)

EITAAC5.2.3.1

Operable with all disability types

Contact technical support. Verify that support services can accommodate the communication needs of end-users with disabilities (i.e., email, TTY, and other forms of communication are available).

Section 5081194.41(c)

Section 2551193.33(a)(3)

Operable with all disability types

Identify whether the device provides voice output. Verify whether the audio signal is provided at a standard signal level through an industry standard connector that will allow for private listening. Verify that the product provides the ability to interrupt, pause, and restart the audio at any time. Assumption: 2.5 mm or 3.5 mm jack are the industry standard audio connectors.

Section 5081194.25(e)

EITAAC5.2.1.11

Operable with Verify that at least one mode of operation and information Section 508

89

Disability Evaluator Instructions Guideline Sourcecomplete blindness

Operable with some vision loss

retrieval is provided which does not require user vision; or, alternatively, that support for assistive technology used by people who are blind or visually impaired is provided.

1194.31(a)

Section 2551193.41(a)

EITAAC5.2.1.1

Operable with complete blindness

Operable with some vision loss

Inspect the machine and verify that an optional remote audiovisual indicator of display information has been provided (and is tactile, if appropriate).

Vanderheiden, 1997

Operable with complete blindness

Determine whether voice output is available. If so, turn the feature on, and interact with the controls to test the use of voice. Verify that voice output (turned on/off as needed) is available to “speak” the names of keys or buttons (but does not activate them) as they are encountered. Determine whether voice output is descriptive.

Section 2551193.41(a)(3)(c) - Advisory Guidance

Operable with complete blindness

Identify all controls and their shape. Verify that the shapes of controls are associated with their functions.

Vanderheiden, 1997

Operable with complete blindness

Operable with some vision loss

Verify that sufficient space for easy tactile location, identification, and labeling (e.g., large print (~ 18 point) or Braille) has been provided on all sides of controls. NOTE: Georgia Tech has determined that a more practical evaluation is to verify that there is room on the control itself or on at least one side of the control.

Vanderheiden, 1997

Operable with complete blindness

Operable with some vision loss

Inspect each control. Verify that Braille labels or raised lettering are used to identify controls.

Section 2551193.43(a)(2)(b&c) - Advisory Guidance

Operable with complete blindness

Press each key type. Verify that snap action feedback (“a gradual increase followed by a sharp decrease in force required to actuate the key, and a subsequent increase in force beyond this point for cushioning” –Force 0.25 to 1.5 N or 28g to 142g (.06 lbs to .34 lbs)) is provided for key presses. Measure the pressure required to activate the function.

Mercinelli 2.4

Operable with complete blindness

Note whether membrane or zero travel keys have been used (they should be avoided). Identify keys which are not membrane or zero travel keys. Measure travel distance for each and verify that it is between 1.3 to 6.4 mm.

Mercinelli 2.4

Operable with complete blindness

Identify buttons that are not part of the touch screen display. Verify that buttons are discrete, and can be felt and located by touch by inspecting the controls without vision. Flat panel buttons should have a raised lip or edge around each. Inspect the keypad and keyboard and verify that tactile landmarks (“nibs”) have been placed on the “F” and “J” keys on a keyboard, and on the “5” key on a numeric keypad. (GT comment - diameter changes (gap between buttons) of at least 3/8” and thickness changes of at least 1/32” are the

Section 2551193.41(a)(3)(a) - Advisory Guidance

90

Disability Evaluator Instructions Guideline Sourcemost readily detectable.)

Operable with complete blindness

Test the control panel mapping under different conditions (modes) and verify that it does not change unless adjusted by the user.

EITAAC5.3.1.9

Operable with all disability types

Inspect each key and verify that matte, anti-glare, rubbery material is used for keys.

Mercinelli 2.4

Operable with complete blindness

Operable with limited manual dexterity

Inspect each key and measure and verify that keys used for typing tasks have tops of 1.27 sq cm.

Mercinelli 2.4

Operable with complete blindness

Inspect each key and verify that keycaps are easily interchangeable.

Vanderheiden, 1997

Operable with limited strength and reach

Inspect each control function and verify that direct keypad input is possible, particularly if controls are located on different parts of the product.

Section 2551193.41(f)(2)(a) - Advisory Guidance

Operable with complete blindness

Inspect each control and verify that buttons which are activated by the first touch are avoided, and where they cannot be avoided, include a “confirm” function.

Section 2551193.41(a)(3)(e)1193.41(e)(2)(e) - Advisory Guidance

Operable with complete blindness

Identify tactile and auditory cues for key activation. For keypads, provide clear tactile and auditory feedback. If a touch screen is used, verify that auditory cues are available to aid navigation.

Mercinelli 2.4

Operable with complete blindness

If a flat membrane panel cannot be avoided, verify that a stick-on tactile overlay providing tactile demarcation of key locations and functions has been provided or that some type of audio or tactile feedback is available.

Vanderheiden, 1997

Operable with complete blindness

Operable with some vision loss

Identify insertable objects. Verify that insertable objects that are not self-orienting have tactile indicators that show the proper insertion orientation. Verify that there is visual contrast between the insertion point and the rest of the device.

Section 2551193.41(a)(3)(d) - Advisory Guidance

Vanderheiden, 1997Operable with complete blindness

Attach external connectors. Verify that additional tactile and acoustic (click) feedback is provided from equipment when external connectors or cards or drawers are properly connected or inserted.

Mercinelli 2.7

Operable with complete blindness

Operable with some vision loss

Determine whether the equipment is intended to be accessible to the visually impaired. Verify that there is a nonvisual means for differentiating controls such as by correlating size, shape, or texture with importance or function.

HFDS6.4.1.19

Section 2551193.41(a)(3)(b) - Advisory Guidance

Vanderheiden, 1997Operable with complete blindness

Operable with some

Determine whether the equipment is intended to be accessible to the visually impaired. Verify that there is adequate space for tactile localization and identification and labeling with large print or Braille.

HFDS6.4.1.20

91

Disability Evaluator Instructions Guideline Sourcevision lossOperable with complete blindness

Operable with some vision loss

Identify controls that are not accessible to the visually impaired. Verify that there is an alternative means of manipulation such as a redundant speech recognition input option.

HFDS6.4.1.24

Operable with complete blindness

Identify controls and their functions. Verify that controls are arranged in groups that facilitate tactile identification.

HFDS6.4.1.30

Operable with some vision loss

Operable with little or no color perception

Identify whether the product permits the user to adjust color and contrast settings. Verify that a range of color selections for producing a variety of contrast levels is available; in particular, that there are at least three color combinations that will provide a high contrast color scheme, and that there is a combination that will provide a soft background, low contrast color scheme.

Section 5081194.21(j)1194.22(m)1194.25(h)

Operable with some vision loss

Verify that at least one mode of operation and information retrieval that does not require visual acuity greater than 20/70 is provided in audio and/or enlarged print output; or, alternatively, that support for assistive technology used by people who are visually impaired is provided.

Section 5081194.31(b)

Section 2551193.41(b)

EITAAC5.2.1.2.15.2.1.2.2

Operable with some vision loss

Verify that sufficient illumination of controls and instructions has been provided.

Vanderheiden, 1997

Operable with some vision loss

Verify that a video jack has been provided for attaching larger-image displays or assistive devices.

Vanderheiden, 1997

Operable with some vision loss

Inspect the control space and verify that the space between letters of words (1/16 of uppercase letters), lines of text, and differing topics is uniform and maximizes contrast.

Section 2551193.41(b)(2)(b) - Advisory Guidance

Operable with some vision loss

Inspect each aspect of the display and verify that the use of lightweight, extra bold, and condensed typefaces has been avoided or minimized.

Mercinelli 2.1

Operable with some vision loss

Inspect each aspect of the display and verify that high contrast (contrast must be greater than 70%) between text or graphics and background has been used. Also verify that text and symbols are as simple and large as possible.

Section 2551193.43(b)(2)(a) - Advisory Guidance

EITAAC5.2.1.2.4

Operable with some vision loss

Operable with from a seated position

If the display is an LCD, verify that the viewing angle is adjustable.

Vanderheiden, 1997

Operable with little or no color perception

Identify colors that are used. Verify that there is at least one mode that does not require user color perception. Verify that colors with low luminance are not used.

Section 2551193.41(c)(2)(d) - Advisory Guidance

EITAAC

92

Disability Evaluator Instructions Guideline Source5.2.1.3

Operable with some vision loss

Inspect each display and output format (including control labels) to verify that color-coding is not used as a primary coding technique (i.e., redundant color-coding has been used).

Section 2551193.41(b)(2)(d) - Advisory Guidance

EITAAC5.3.2.8

Operable with little or no color perception

Inspect each display and output format to verify that the color blue, green, or violet is not used to convey information.

Vanderheiden, 1997

Operable with little or no color perception

Inspect each display and output format to verify that multicolor combinations red/green, yellow/blue, red/brown, blue/green, white/light green are not used.

Section 2551193.41(c)(2)(b) - Advisory Guidance

Operable with little or no color perception

Inspect each control label to verify that an alternative to seeing color is provided. For example, verify that control identification is coded by relative shape or position, or graphic labels, in addition to color-coding.

Section 2551193.41(c)(2)(a) - Advisory Guidance

EITAAC5.3.2.8

Prevention of visually induced seizures

Measure screen flicker. Verify that screen flicker does not occur between 2 Hz and 55 Hz (or is adjustable outside this range).

Section 5081194.25(i)

Prevention of visually induced seizures

Verify that bright flashes which occupy a large part of the visual field are avoided to minimize the impact on the visual cortex.

Section 2551193.43(f)(3) - Advisory Guidance

Operable with complete deafness

Operable with some hearing loss

Verify that at least one mode of operation and information retrieval that does not require user hearing is provided; or, alternatively, that support for assistive technology used by people who are deaf or hard of hearing is provided.

Section 5081194.31(c)

Section 2551193.41(b)

EITAAC5.2.1.4.1

Operable with complete deafness

Operable with some hearing loss

Identify any lights that are used (LED or other stand-alone types of illumination). Determine when/if they flash or are steady. Verify that when lights are used as prominent visual indicators that a steady light represents a continuous condition and a flashing light represents a new condition.

Mercinelli 2.4

Operable with complete deafness

Operable with some hearing loss

Identify any use of flash, and measure the rate of flash. Verify that flash rate is between 3-10 flashes/sec with equal intervals of light and dark.

Mercinelli 2.4

Operable with complete deafness

Operable with some hearing loss

Identify text versions of auditory information. Verify that all text versions of auditory information are easily visible and preserved intact (GT comment - all styles and exact timing and synchronization commands are maintained and there is zero introduction of errors or garbling of data; that is, message is either all numbers or the message is mixed numbers with text).

Section 2551193.43(d)(2)(d) - Advisory Guidance

Operable with Identify all auditory cues that are used. Verify that Section 255

93

Disability Evaluator Instructions Guideline Sourcecomplete deafness

Operable with some hearing loss

additional visual or tactile cues are used when auditory cues are used to attract a users attention to product alerts/messages.

1193.43(d)(2)(a) - Advisory Guidance

Operable with complete deafness

Operable with some hearing loss

Determine whether flashing lights are used. If a flashing light is used to indicate different system modes, verify that no more than 3 different flash rates are used.

Mercinelli 2.4

Operable with complete deafness

Operable with some hearing loss

For portable products, if a built-in tactile cue is not readily achievable, verify that an auxiliary vibrating signaler has been provided (e.g., vibrating pager).

Section 2551193.43(d)(2)(b) - Advisory Guidance

Operable with some hearing loss

Identify whether audio information is important for the use of the product. Verify that at least one mode of operation and information retrieval is provided in an enhanced fashion (with increased amplification); or, alternatively, that support for assistive hearing devices is provided.

Section 5081194.31(d)

Section 2551193.41(b)1193.43(e)

EITAAC5.2.1.5.1

Operable with some hearing loss

Identify whether the device will deliver voice output in a public area. Measure the voice output level. Verify that incremental volume control is available with output amplification up to a level of at least 65 dB. Measure the ambient noise level of the environment. If the ambient noise level is above 45 dB, verify that a volume gain of at least 20 dB above the ambient level is user selectable. Verify that a function is provided to automatically reset the volume to the default level after every use.

Section 5081194.23(g)1194.25(f)

EITAAC5.2.1.5.4

Operable with all disability types

Verify that, when a product delivers audio output through an external speaker, an industry standard connector for headphones or personal listening devices (e.g., phone-like handset or ear cup) is provided which cuts off the speaker when used; an exception is simple auditory information that is also provided visually. Verify that the headphones have a separate volume control.

Section 2551193.43(g)(2) - Advisory Guidance

EITAAC5.2.2.3

Operable with some hearing loss

Determine whether there are any connection points for external devices. Verify that existing connection points for external audio processing devices have industry standard connectors.

Section 2551193.51(b)

Operable with some hearing loss

Operable with limited cognitive skills or language facility

Verify that auditory information is presented continuously or periodically until the desired message is confirmed or acted upon by testing device response when messages are not acted upon immediately. If spoken messages do not automatically repeat, verify that the hardware has a mechanism for requesting their repetition.

Section 2551193.43(e)(2)(d) - Advisory Guidance

Vanderheiden, 1997

Operable with some hearing loss

Test sound quality throughout the range of volume and inspect the coupling (speaker output) between the signal

Section 2551193.43(e)(2)(a) - Advisory

94

Disability Evaluator Instructions Guideline Sourcesource and the user in order to verify that sound is intelligible at all volumes. Verify that hardware volume can be adjusted (dynamic range is 18-25 dB) (GT comment - and that the volume indicator is visual and easily located). Verify that at least one mode of operation enhances auditory functioning via increased amplification or increased signal-to-noise ratio or combination.

Guidance

EITAAC5.2.1.5.4.2

Vanderheiden, 1997

Operable with all disability types

Modify volume settings. Turn off main power and restart the machine. Review volume settings after restarting the hardware and verify that volume settings are maintained after the machine has been shut down (for items intended for individual use).

Mercinelli 2.3

Operable with some hearing loss

Inspect the impact of hardware noise on the acquisition of auditory information and verify that it has been minimized.

Vanderheiden, 1997

Operable with some hearing loss

If a headphone is provided, inspect each side of the device and verify that a headphone jack is provided and efficiently located (GT comment - a 9-mm miniature plug-in jack is recommended).

Section 2551193.43(e)(2)(f) - Advisory Guidance

Operable with some hearing loss

If a headphone jack is not possible, verify that sound sources are placed in front of the device and away from loud mechanisms.

Section 2551193.43(e)(2)(e) - Advisory Guidance

Operable with some hearing loss

Identify when alerting tones occur. Verify that alerting tones contrast with expected environmental sounds.

Section 2551193.43(e)(2)(b) - Advisory Guidance

Operable with some hearing loss

Identify all types of audio output and measure pitch for each. If pitch cannot be selected by the user, verify that high pitch sounds ( > 4,500 Hz) are not used.

Mercinelli 2.3

Vanderheiden, 1997Operable with some hearing loss

Verify that a gain adjustable up to a minimum of 20 dB is provided for transmitted voice signals, with incremental volume control of at least one intermediate step of 12 dB of gain.

Section 5081194.23(f)

EITAAC5.2.1.5.3

Operable with all disability types

Verify that microphones have a muting function. Mercinelli 2.8

Operable with all disability types

Test microphone sensitivity and verify that it is adjustable within a range of ± 9-10 dB.

Mercinelli 2.8

Operable with all disability types

Inspect the mounting of microphones and verify that the effects of the echo, sound, and reverberation from the expected usage environment have been minimized.

Mercinelli 2.8

Operable without speech

Verify that at least one mode of operation and information retrieval that does not require speech is provided; or, alternatively, that support for assistive technology used by people with speech disabilities is provided.

Section 5081194.31(e)

Section 2551193.41(h)

EITAAC5.2.1.8.1

Operable without speech

Verify that input options do not require speech and that where speech is an input option alternatives are provided

Section 2551193.41(h)

95

Disability Evaluator Instructions Guideline Source

Operable with limited cognitive skills or language facility

(e.g., keyboard access).

Operable with some vision loss

Operable with limited cognitive skills or language facility

Where softkeys (physical keys with variable labels) are used, inspect each softkey label and verify that each is self-explanatory and does not use abbreviations.

Mercinelli 2.4

Operable with complete blindness

Operable with limited cognitive skills or language facility

Where softkeys (physical keys with variable labels) are used, inspect each softkey and verify that each is used consistently across applications.

Mercinelli 2.4

Operable with some vision loss

Operable with limited cognitive skills or language facility

Where softkeys (physical keys with variable labels) are used, inspect each softkey and its label to verify that softkey positions correspond to softkey label positions.

Mercinelli 2.4

Operable with some vision loss

Operable with limited cognitive skills or language facility

Where softkeys (physical keys with variable labels) are used, inspect each phase of the display and verify that softkey labels always appear at the same position on the display.

Mercinelli 2.4

Operable with all disability types

Identify long command sequences. Determine if they can be programmed. Verify that long command sequences can be programmed with a short code (or with a few, simple steps).

Vanderheiden, 1997

Microsoft 1999

Operable with complete blindness

Operable with some vision loss

Identify all controls and their sensory modes. Inspect all controls and verify that there is multisensory indication of the separate divisions, positions, and levels of each, and of each control’s status. Verify that rotational or linear stops and tactile or audio detents are provided.

Section 2551193.41(a)(3)(f)1193.41(a)(3)(g) - Advisory Guidance

Operable with limited cognitive skills or language facility

Test all system actions and verify that a progress, or “busy” indicator is provided when the product cannot take further input or when there is a delay before requested actions are taken.

Vanderheiden, 1997

Operable with limited cognitive skills or language facility

Inspect the wording of each output format and display to verify that language is simple, and that no passive voice or negative phrasing is used.

Vanderheiden, 1997

Operable with limited cognitive skills or language facility

Inspect the system and identify any programmable keys or the ability to modify default settings. Inspect the required commands for common system functions and verify that programmable function keys or system “default” modes are provided for each.

Vanderheiden, 1997

Operable with limited Inspect the control space and verify that, where appropriate, Vanderheiden, 1997

96

Disability Evaluator Instructions Guideline Sourcecognitive skills or language facility

absolute reference controls (e.g., pointers) are used instead of relative controls (e.g., unmarked knobs).

Operable with limited cognitive skills or language facility

Inspect the control space and verify that, where appropriate, moving pointers with stationary scales are used.

Vanderheiden, 1997

Operable with limited cognitive skills or language facility

Inspect the control space and verify that the number of control choices (for a particular action key) and dual-purpose controls are limited.

Vanderheiden, 1997

Operable with limited cognitive skills or language facility

Inspect the control space and determine the controls available at various layers. Verify that controls are layered such that only the most frequent or necessary controls or commands are visible unless requested.

Vanderheiden, 1997

Microsoft 1999

Operable with limited cognitive skills or language facility

Inspect the control space. Verify that controls are arranged to indicate sequence of operation.

Vanderheiden, 1997

Operable with limited cognitive skills or language facility

Inspect the control space and verify that common layouts or patterns for controls are used (within the device).

Vanderheiden, 1997

Operable with limited cognitive skills or language facility

Inspect the control space and verify that common color-coding conventions are provided in addition to textual or graphic labeling.

Vanderheiden, 1997

Operable with limited cognitive skills or language facility

Inspect system responses to all commands and identify any lags. Verify that product lag or response times to commands are minimized.

Vanderheiden, 1997

Operable with limited cognitive skills or language facility

Inspect each setting control and verify that concrete (rather than abstract) indications of product settings are used.

Vanderheiden, 1997

Operable with limited cognitive skills or language facility

Inspect each screen layout and verify that they are simple, and the user has the option to view one thing at a time.

Vanderheiden, 1997

Operable with limited cognitive skills or language facility

Inspect each output of the display and verify that digital readouts for product generated numbers are provided when a numeric or precise value is important. Verify that dials or bar graphs are provided when qualitative information is more important.

Vanderheiden, 1997

Operable with limited cognitive skills or language facility

Inspect each output format and display, including all button labels, to verify that pictures or icons are used to accompany words.

Vanderheiden, 1997

Operable with limited cognitive skills or language facility

Inspect each output format and display to identify any important information and any grouped information. Examine any coding techniques that are used. Verify that key information and grouped information are highlighted using attention-attracting and grouping techniques.

Vanderheiden, 1997

Operable with limited cognitive skills or language facility

Inspect each output format and display and verify that Arabic notation is used for numerals.

Vanderheiden, 1997

Microsoft, 1999Operable with limited cognitive skills or

Inspect each aspect of the interface and verify that shape, color, icons, and labels for controls sharing functions or

Vanderheiden, 1997

97

Disability Evaluator Instructions Guideline Sourcelanguage facility actions are standardized according to other products and

manufacturers. Verify that the use of images is consistent throughout the application.

EITAAC5.3.2.5

Operable with limited cognitive skills or language facility

Identify actions requiring a sequence of operations. Inspect each aspect of the interface and verify that memory cues or simple operating instructions for required sequences of action are provided. Test all command sequences, and verify that an easy method for undoing or exiting out of each is provided and apparent.

Section 2551193.41(i)(2)(e) - Advisory Guidance

Vanderheiden, 1997

Operable with limited cognitive skills or language facility

Inspect each aspect of the device and verify that instructions for product assembly and use are provided directly on the device.

Vanderheiden, 1997

Operable with limited cognitive skills or language facility

Identify all icons and graphical objects. Try to identify the metaphor associated with each. Inspect all screen object controls and verify that each is represented by common, recognizable metaphors.

Mercinelli 2.5

Operable with limited cognitive skills or language facility

Inspect all labels and verify that each is placed on or immediately adjacent to their corresponding control. Identify labels not placed directly on a control. Inspect all labels and verify that when one must be placed adjacent to a control, the connection between the label and corresponding control is made apparent.

Vanderheiden, 1997

Operable with limited cognitive skills or language facility

Identify and inspect all labels and verify that simple concise language is used for each while abbreviations are avoided.

Section 2551193.41(i)(2)(f) - Advisory Guidance

Operable with limited cognitive skills or language facility

Identify any aurally presented information and verify that audio presentations are short, and that key information is provided at the end. Verify that important information is provided at the beginning of written text.

Vanderheiden, 1997

Operable with limited cognitive skills or language facility

Identify any aurally presented information and verify that attention-getting sounds or words are used before the audio presentation of information.

Vanderheiden, 1997

Operable with limited cognitive skills or language facility

Verify that there is automatic, timed shut-off for devices that present a hazard if left on.

Vanderheiden, 1997

Operable with limited cognitive skills or language facility

Identify any use of lists. Test all lists and verify that clear feedback indicates the end of lists.

Microsoft, 1999

Operable with limited manual dexterity

Operable with limited reach and strength

For all controls, verify that controls and keys are operable with one hand; and do not require tight grasping, pinching, or twisting of the wrist. Measure the force required to activate controls. Verify that the force required to activate controls and keys, insert and retrieve items (cards, connectors, drawers) is a maximum of 5lbs (22.2N).

Section 5081194.23(k2)1194.25(c)1194.26(a)1194.26(b)

Vanderheiden, 1997Operable with limited manual dexterity

For all controls, identify whether key repeat is supported. Measure the delay for key repeat. Verify that if key repeat is supported, the delay before repeat is adjustable to at least 2 seconds.

Section 5081194.23(k3)1194.25(c)1194.26(a)1194.26(b)

98

Disability Evaluator Instructions Guideline Source

Vanderheiden, 1997Operable with limited manual dexterity

Operable with limited reach and strength

Verify that at least one mode of operation and information retrieval does not require fine motor control or simultaneous actions. Verify that at least one mode of operation and information retrieval is available and operable with limited reach and strength.

Section 5081194.31(f)

Section 2551193.41(e)1193.41(f)

EITAAC5.2.1.6.1

HFDS8.18.2.1

Operable with limited manual dexterity

Identify any actions that require simultaneous button presses. Verify that where two buttons must be depressed simultaneously, an option is provided to allow them to be activated sequentially, or an alternative method of control is provided.

Section 2551193.41(e)(2)(d) - Advisory Guidance

Vanderheiden, 1997

Microsoft, 1999Operable with complete blindness

Determine whether optional voice control and speech output are provided. If optional voice is available, verify that a query mode is also available which allows the user to determine (through speech output) the function or state of the control without activating it.

Section 2551193.41(a)(3)(h) - Advisory Guidance

Operable with limited manual dexterity

Inspect insertable objects and verify that objects to be inserted are rugged and able to take rough handling (nothing is apparently delicate).

Vanderheiden, 1997

Operable with limited manual dexterity

Verify that latches are operable with a closed fist. Vanderheiden, 1997

Operable with limited manual dexterity

Verify that knobs are not required for opening the product. Vanderheiden, 1997

Operable with limited manual dexterity

Inspect each control mechanism. Verify that controls requiring simultaneous activation of two or more buttons or latches are avoided. Also verify that small controls and controls requiring rotation of the wrist or pinching and twisting are avoided.

Section 2551193.41(e)(2)(f) - Advisory Guidance

Operable with limited manual dexterity

Use a pen or eraser tip to activate controls. Verify that controls are operable/compatible with prosthetics, and do not require human touch.

Section 2551193.51(c)

EITAAC5.2.1.14

Operable with limited manual dexterity

Verify that cards, external connectors, and drawers can be inserted and retrieved with a single hand.

Mercinelli 2.4

Operable with limited manual dexterity

Verify that an optional mode is provided where buttons must be depressed for a long period of time before input is accepted (to help separate inadvertent keypresses from desired activation), or that the delay before acceptance of input can be preset and adjusted.

Section 2551193.41(e)(2)(c) - Advisory Guidance

Vanderheiden, 1997

99

Disability Evaluator Instructions Guideline SourceOperable with limited manual dexterity

Verify that guard bars are available between or near buttons to help prevent accidental activation.

Section 2551193.41(e)(2)(b) - Advisory Guidance

Operable with complete blindness

Operable with limited manual dexterity

Verify that a standard connection point for applicable assistive input devices (e.g., screen keyboards, predictive dictionaries, and speech recognition technologies) is provided.

Vanderheiden, 1997

Microsoft, 1999

Operable with limited cognitive skills or language facility

Inspect the required actions to execute command sequences and verify that required command sequences are simple, requiring minimal steps, or can be programmed with a short code.

Vanderheiden, 1997

Operable with limited manual dexterity

Inspect the control space to verify that controls are spaced, positioned, and sized to facilitate manipulation.

Section 2551193.41(e)(2)(a) - Advisory Guidance

Operable with limited manual dexterity

Inspect each key or button to verify that concave and/or non-slip buttons (rubbery texture is preferred by most) have been used, or that a ridge is provided around flat keypad buttons. Verify that controls are shaped to minimize the need for pinching or bending the wrist or body, and can be operated using the side of the hand, an elbow, or a pencil.

Section 2551193.41(e)(2)(g) - Advisory Guidance

HFDS6.4.1.7

Vanderheiden, 1997Operable with limited manual dexterity

Inspect each insertable object and verify that it has a high-friction surface (to ease the grip necessary to maintain hold of the object).

Vanderheiden, 1997

Operable with limited manual dexterity

If controls require fine motor control, verify that alternative methods of control are provided.

Vanderheiden, 1997

Microsoft, 1999Operable with limited manual dexterity

If cards, connectors, or drawers must be inserted, verify that a bevel is provided around the slot/connection area, and/or that the slot/connector is located on the front and near a ledge or open space for easy insertion/connection.

Section 2551193.41(e)(2)(h) - Advisory Guidance

Operable with limited manual dexterity

If a touch screen is used, measure each object to verify that it is 2.6 sq cm or larger, and that on screen “keys” are 2.27 sq cm or larger. Also verify that on-screen "keyboard" keys are separated by +0.41 to 0.54 cm.

Mercinelli 2.5

Operable with limited manual dexterity

If a touch screen is used, inspect each key to verify that last key selection algorithms (the system accepts selection from the last valid key touched prior to finger raising; if finger is raised outside a screen "sensible" area no selection should be made) are used.

Mercinelli 2.5

Operable with complete blindness

If a flat membrane keypad cannot be avoided, verify that a ridge around each button has been provided (thickness changes of at least 1/32” the most readily detectable).

Vanderheiden, 1997

Operable with limited manual dexterity

Verify that tilt angle for screen typing is between 30-45°. Mercinelli 2.5

Operable with limited manual dexterity

Verify that keyboards are adjustable from the horizontal (0-15°).

Vanderheiden, 1997

100

Disability Evaluator Instructions Guideline SourceOperable with limited manual dexterity

Identify controls and verify that they can be operated with either the right or the left hand.

HFDS6.4.1.6

Operable with limited manual dexterity

Identify all controls and verify that there are no obstructions that would interfere with a user’s ability to manipulate a control.

HFDS6.4.1.12

Operable with limited manual dexterity

Determine how all controls function and verify that no control requires the user to continuously hold it down in order to activate it unless safety requirements dictate otherwise.

HFDS6.4.1.13

Operable with limited manual dexterity

Identify all controls and determine how they can be manipulated. Verify that controls are designed to permit users great flexibility in how the control is manipulated, whether by using the fingers, the full hand, or both hands.

HFDS6.4.1.14

Operable from a seated position

Operable with limited strength and reach

When the obstruction projects 20 to 25 inches (510 mm to 635 mm), verify that the maximum high forward reach is 44 inches (1120 mm) (compliant with American Disabilities Act Accessibility Guidelines).

Section 2551193.41(f)(2)(f) - Advisory Guidance

EITAAC5.2.1.16

HFDS6.4.1.15

Operable from a seated position

Operable with limited strength and reach

When the obstruction is less than 20 inches (510 mm) deep, verify that the maximum high forward reach is 48 inches (1220 mm) (compliant with American Disabilities Act Accessibility Guidelines).

Section 2551193.41(f)(2)(f) - Advisory Guidance

EITAAC5.2.1.16

HFDS6.4.1.15

Operable with limited manual dexterity

Operable with limited strength and reach

Verify that the requirement for constant, uninterrupted actions is minimized by investigating the required actions for each control.

Vanderheiden, 1997

Operable from a seated position

Operable with limited strength and reach

Verify that the maximum level forward reach over an obstruction with knee space below is 25 inches (635 mm) (compliant with American Disabilities Act Accessibility Guidelines).

Section 2551193.41(f)(2)(f) - Advisory Guidance

EITAAC5.2.1.16

HFDS6.4.1.15

Operable with limited strength and reach

Verify that the manipulation of printouts by “reaching and grasping” aids is facilitated by product design.

Vanderheiden, 1997

Operable with limited strength and reach

Verify that the force required to operate mechanical controls is adjustable or minimized, and that the need for sustained pressure or activity is minimized.

Section 2551193.41(f)(2)(d) - Advisory Guidance

101

Disability Evaluator Instructions Guideline SourceOperable from a seated position

Operable with limited strength and reach

Verify that an optional remote control is provided such that the controls can be positioned optimally for each individual.

Section 2551193.41(f)(2)(c) - Advisory Guidance

HFDS6.4.1.17

Operable with limited manual dexterity

Operable with limited strength and reach

Determine actions required to insert and remove objects. Verify that objects can be inserted and removed with minimal user reach and dexterity by inspecting the insertion and removal of each object.

Vanderheiden, 1997

Operable from a seated position

Verify that multiple displays or auditory output are provided when information cannot be within reach of those who are small or in a wheelchair or other personal mobility device.

Vanderheiden, 1997

Operable from a seated position

Verify that important labels or instructions are placed on the front or other easily accessible side of large or stationary devices.

Vanderheiden, 1997

HFDS6.4.1.27

Operable with limited strength and reach

Verify, by attempting each operation with a single hand, that frequently performed control operations do not require long reaches by people using one hand.

Microsoft, 1999

Operable with limited strength and reach

Verify that devices with covers or lids are hinged, have sliding covers, or are electronically operated. Verify that lids, covers, and other loose objects are hinged or tethered with a cord or wire.

Vanderheiden, 1997

Operable with limited manual dexterity

Verify that device doors with open handles, levers, or spring-loaded doors are used.

Vanderheiden, 1997

Operable with limited strength and reach

Verify that force requirements are minimized or that force required for mechanical controls can be adjusted.

Vanderheiden, 1997

Operable from a seated position

Verify that controls and printed output are within easy reach of those who are small or in a wheelchair or other personal mobility device, and a required change in body position is minimized: Accessible forward reach is between 15”and 48” from the floor. Accessible side reach is between 9” and 54” from the floor.

EITAAC5.2.1.16

HFDS6.4.1.15

Vanderheiden, 1997Operable with limited strength and reach

Verify that bearings for drawers or heavy objects that must be moved are provided.

Vanderheiden, 1997

Operable with limited strength and reach

Identify all controls that will be used frequently. Verify that they are placed in positions that are most easily reached with the minimum change of body position and that arm/wrist rests or supports are provided near controls. Alternatively, verify that short cuts are available to minimize the number of actions needed to perform a given function.

Section 2551193.41(f)(2)(e) - Advisory Guidance

HFDS6.4.1.16

Vanderheiden, 1997Operable with limited manual dexterity

Verify that ample ejection distance of objects (e.g., printouts) facilitates easy gripping and removal (recommended distance is 1 inch but 2 inches is preferred).

Vanderheiden, 1997

102

Disability Evaluator Instructions Guideline SourceOperable from a seated position

Operable with limited strength and reach

Inspect each receptacle and verify that object receptacles can be repositioned or re-angled to be more reachable.

Vanderheiden, 1997

Operable from a seated position

Operable with limited strength and reach

Verify that controls are within easy reach of those who are small or in a wheelchair or other personal mobility device, and a required change in body position is minimized: If the side reach is over an obstruction with a depth of 24 inches (610 mm), verify that the maximum height of the obstruction is 34 inches (865 mm) and that the maximum high side reach over the obstruction is 46 inches (1170) (compliant with American Disabilities Act Accessibility Guidelines).

Section 2551193.41(f)(2)(f) - Advisory Guidance

EITAAC5.2.1.16

HFDS6.4.1.15

Operable from a seated position

Operable with limited strength and reach

Verify that controls are within easy reach of those who are small or in a wheelchair or other personal mobility device, and a required change in body position is minimized: If the clear floor space only allows forward approach to the product, verify that the maximum high forward reach (height) allowed is 48 in (1220 mm) (compliant with American Disabilities Act Accessibility Guidelines).

Section 2551193.41(f)(2)(f) - Advisory Guidance

EITAAC5.2.1.16

HFDS6.4.1.15

Vanderheiden, 1997Operable from a seated position

Operable with limited strength and reach

Verify that controls are within easy reach of those who are small or in a wheelchair or other personal mobility device, and a required change in body position is minimized: If the clear floor space only allows forward approach to the product, verify that the minimum low forward reach is 15 in (380 mm) (compliant with American Disabilities Act Accessibility Guidelines).

Section 2551193.41(f)(2)(f) - Advisory Guidance

EITAAC5.2.1.16

HFDS6.4.1.15

Vanderheiden, 1997Operable from a seated position

Operable with limited strength and reach

Verify that controls are within easy reach of those who are small or in a wheelchair or other personal mobility device, and a required change in body position is minimized: If the clear floor space allows parallel approach by a person in a wheelchair, verify that the maximum high side reach allowed is 54 in (1370 mm) and the low side reach is no less than 9 in (230 mm) above the floor (compliant with American Disabilities Act Accessibility Guidelines).

Section 2551193.41(f)(2)(f) - Advisory Guidance

EITAAC5.2.1.16

HFDS6.4.1.15

Vanderheiden, 1997Operable with limited manual dexterity

Determine the type of grasp required for each knob. As appropriate, measure the height, diameter, and length of each knob. If it is a finger tip grasp, verify that the height of the knob is no less than 13 mm (0.5 in) and no more than 25 mm (1.0 in). The diameter should be a minimum of 10

HFDS6.1.5.4.1

103

Disability Evaluator Instructions Guideline Sourcemm (0.4 in) and a maximum of 100 mm (4.0 in). If the knob requires the thumb and forefinger encircled, verify that the diameter of the knob is no less than 25 mm (1.0 in) and no more than 75 mm (3.0 in). If the knob uses palm grasp, verify that the diameter is no less than 38 mm (1.5 in) and no more than 75 mm (3.0 in). The length should be a minimum of 75 mm (3.0 in).

Operable with limited manual dexterity

Determine if there are adjacent knobs. Verify that separation between adjacent edges of knobs is as follows: For one handed operation, the minimum is 25 mm (1.0 in) and the optimum is 50 mm (2.0 in). When 2 hands are required simultaneously, the minimum separation should be 50 mm (2.0 in) and the optimum is 125 mm (5.0 in).

HFDS6.1.5.4.1

Operable with limited manual dexterity

Determine the type of grasp required for each lever. If the lever uses finger grasp, verify that the minimum diameter is 13 mm (0.5 in) and the maximum is 38 mm (1.5 in). If hand grasp is required, verify that the minimum diameter is 38 mm (1.5 in) and the maximum is 75 mm (3.0 in).

HFDS6.1.5.15.1

Operable with limited strength and reach

Determine whether the motion of the lever is forward or lateral. If forward, verify that resistance for one handed operation is a minimum of 9 N (2.0 lb) and a maximum of 135 N (30.0 lb). For two handed operation, verify that resistance is a minimum of 9 N (2.0 lb) and a maximum of 220 N (50.0 lb). For lateral motion with one handed operation, verify that the resistance is a minimum of 9 N (2.0 lb) and a maximum of 90 N (20.0 lb). For lateral motion with two handed operation, verify that the minimum resistance is 9 N (2.0 lb) and the maximum 135 N (30.0 lb).

HFDS6.1.5.15.1

Operable with limited strength and reach

Determine whether the lever requires forward or lateral motion and measure the displacement. If the lever requires forward motion, verify that the maximum displacement is 360 mm (14.0 in). If the lever requires lateral motion, verify that the minimum displacement is 50 mm (2.0 in) and the maximum is 970 mm (38.0 in) (preferred is 100 mm (4.0 in)).

HFDS6.1.5.15.1

Operable with limited manual dexterity

Measure separation between adjacent levers. Verify that for one handed operation, the minimum separation is 50 mm (3.0 in) (preferred is 100 mm (5.0 in)). For two handed simultaneous operation, verify that the minimum separation is 75 mm (3.0 in) (preferred is 125 mm (5.0 in).

HFDS6.1.5.15.1

Operable with limited strength and reach

Identify all levers and determine whether they are to be used for fine or continuous adjustments. Verify that when a lever will be used to make fine or continuous adjustments, a support for the appropriate limb is provided as follows: a. For large hand movements, a support for the elbow.; b. For small hand movements, a support for the forearm; c. For finger movements, a support for the wrist.

HFDS6.1.5.15.5

Operable with some vision loss

Operable with limited

Determine if animation is displayed. Verify that the information is displayable in at least one non-animated presentation mode at the option of the user. Options include freezing the text, making it scrollable, or providing it

Section 5081194.21(h)1194.22(m)

104

Disability Evaluator Instructions Guideline Sourcecognitive skills or language facility

Prevention of visually induced seizures

in an alternate format that does not move. Section 2551193.43(c) - Advisory Guidance

EITAAC5.2.1.7.2

HFDS8.18.1.7

Operable with some vision loss

Operable with little or no color perception

Identify any use of color coding. Verify that color coding is not used as the only means of conveying information, indicating an action, prompting a response, or distinguishing a visual element.

Section 5081194.21(i)1194.22(m)1194.25(g)

EITAAC5.3.2.85.2.1.3

HFDS8.6.2.1.5

Operable with some vision loss

Verify that the information density (the amount of information per unit area) of a screen is minimized, meaning that only information that is essential to a user at any given time is presented.

HFDS8.1.1.2

Operable with some vision loss

Inspect the screens/web site pages and verify that mixed case is used for text and that standard capitalization rules are used.

HFDS8.2.5.8.1

Vanderheiden, 1997Operable with limited cognitive skills or language facility

Verify that there is at least one mode that minimizes the cognitive, memory, language, and learning skills required of the user.

Section 2551193.41(i)

EITAAC5.2.1.9.15.2.1.10.1

105