Transcript Slide 1

Accessible Telecommunication Systems
Paul R. Michaelis, Ph.D., C.P.E.
[email protected]
July 2006
Copyright © 2006 Avaya Inc. All rights reserved
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The goals of this presentation
• Describe three assistive technologies that are
commonly used in conjunction with telecom systems.
• Review disability access laws and regulations that
apply to the telecom industry and to telecom
customers.
• Demonstrate accessible solutions that have been
developed by Avaya.
• Describe how these products work, thereby allowing
you to see for yourself that accessible solutions don’t
have to be expensive, complicated, or hard to
administer.
• Solicit your feedback about the products we have built,
and about the products you want us to build.
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Avaya’s accessibility philosophy
• Many of the people in Avaya who are working on accessible
solutions have personal reasons for regarding it as important.
• We will not achieve our personal objectives if our solutions are
adopted solely by organizations for whom Section 508 is
mandatory. (Only about 5% of Avaya’s revenue comes from sales to
the Federal government.)
• In the private sector, the incremental costs and perceived
complexity of accessible solutions are disincentives to the hiring of
a qualified person with a disability.
• For these reasons, whenever it is possible to do so, we embed our
accessibility solutions within our mainstream products, and provide
these solutions at no additional charge.
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A quick review of
assistive technologies:
(1) What is a TTY?
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What is a TTY?
A TTY (also known as a TDD) is a special text terminal
that lets people who are deaf, hard of hearing, or
speech-impaired use a telephone to communicate.
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Some TTY basics
• How US TTYs work:
– FSK “Baudot” tones. Half duplex. No error correction; no
“handshake”; no carrier tone. (TTYs are silent when not
transmitting.) There is no ability to interrupt the other person.
– 45.45 baud. (Each “bit” is a 22ms tone, either 1400 or 1800Hz.)
– Each character consists of seven tones: a start bit at 1800Hz,
five tones at 1400 or 1800Hz that specify the character, and 1.5
stop bits at 1400Hz.
• Not all TTY users transmit and receive with their TTYs.
In fact, roughly half have hearing deficits, but still speak
clearly; these users often prefer to receive via TTY but
then speak in response. This is commonly referred to
as Voice Carry Over or VCO.
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(2) What is inductive
coupling ?
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Inductive coupling
•
If an object gets within a few inches of most hearing aids, the aids
often emit a loud howling sound. This is simple acoustic feedback,
similar to the feedback you can get with an auditorium P.A. system.
•
To prevent this when a phone is being used, the microphone in the
aid must be turned off. (Note: The microphone is turned off, but
not the hearing aid itself.)
•
The voice signal from the phone handset is transmitted to the aid
via electro-magnetic inductive coupling.
•
All Avaya handsets have primary inductive coils (commonly
referred to as tele-coils or T-coils) that permit the phones to be
used with inductively coupled assistive listening devices, such as
traditional hearing aids and cochlear implants.
•
A big problem, not yet solved: The electro-magnetic “noise”
produced by many wireless devices makes it impossible to use
inductively coupled assistive listening devices.
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(3) What are JAWS and
Window-Eyes?
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What are JAWS And Window-Eyes?
Computer users who are blind often rely on sophisticated
text-to-speech screen-reading software adjuncts. Two
commonly used packages are JAWS and Window-Eyes.
Many of the GUI and web standards are oriented toward
allowing JAWS and Window-Eyes to work properly.
Windows 2000 and XP include a primitive version of these
products. Try using this MS software to do your job:
Start > Programs > Accessories > Accessibility > Narrator
JAWS (“Java Access With Speech”) is a product of Freedom Scientific
http://www.freedomscientific.com/
Window-Eyes is a product of GW Micro http://www.gwmicro.com/
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Relevant US laws
and regulations
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First generation of disability access laws
Architectural Barriers Act of 1968
 First accessibility law; governed physical barriers (doors, stairs,
etc.) in transportation facilities and Federal buildings.
Hearing Aid Compatibility Act of 1988
 Requires the Federal Communications Commission (FCC) to ensure
that all telephones manufactured or imported for use in the United
States after August 1989 are hearing aid compatible.
Americans with Disabilities Act of 1990
 Permits people with disabilities to file civil lawsuits in order to
obtain “reasonable accommodation.”
These lawsuits can be
expensive for individuals to pursue, which is why many ADA cases
are class actions. Within the ADA, there are very few explicit
requirements for telecom equipment.
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Examples of recent telecom-specific laws
Section 255,Telecommunications Act of 1996
Empowers the Federal Communications Commission
to require disability access provisions in telecom
equipment and services.
Section 508, Rehabilitation Act of 1973
(As amended in 1998)
Adds specific accessibility requirements to Federal
procurement regulations.
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Section 255, Telecommunications Act of 1996
GOAL: Ensure that telecom equipment and services are usable by
people with disabilities.
REQUIREMENTS:
The US Access Board identified specific types of
disability (e.g., complete or partial deafness, blindness, paralysis, cognitive
impairments) and specific assistive devices (e.g., TTYs, inductively coupled
hearing aids, cochlear implants); FCC rules require telecom manufacturers
and service providers to take these disabilities and devices into account.
ENFORCEMENT:
 The FCC is empowered to require compliance in all telecom products
designed, built, or modified after February, 1996 if readily achievable.
 Possible penalties for noncompliance include fines, loss of FCC product
certification, and required retrofitting of the entire product line (not just the
product that generated the original complaint).
 The FCC determines whether compliance is achievable. There is no right of
private action, i.e., the FCC’s decisions cannot be challenged in court.
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What about Section 255 and VoIP?
CAVEAT EMPTOR
>>> Read the fine print! <<<
• The FCC regulates communication systems. It does not have the
authority to regulate “information systems.”
• Under current law, the Internet is treated as an information system.
• The FCC therefore considers Voice over Internet Protocol to be
exempt from their jurisdiction. This exemption makes it possible for
VoIP manufacturers and service providers to claim that they are not
out of compliance with Section 255, even if they fail to address any
of Section 255’s accessibility objectives.
• A recommendation: Don’t achieve “compliance” with Section 255
by relying on legal loop-holes.
• My presentation to the FCC, asking them to remove VoIP’s S-255
exemption: http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-248634A8.pdf
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Section 508, Rehabilitation Act Amendments
GOALS:
Ensure that the government’s internal electronic communication
and information systems are accessible to government employees with
disabilities. Ensure also that the government’s public-access systems are
accessible to people with disabilities in the general population.
REQUIREMENTS:
Specific accessibility features must be present in
telecom and information systems developed, procured, leased, or used by
the government. (Note the difference in regulatory style: Section 508
imposes specific engineering design requirements, while the FCC’s
guidelines under Section 255 say, “We expect manufacturers to find
solutions for the disability access problems we’ve identified.”)
ENFORCEMENT:
Unless they can demonstrate undue hardship,
departments and agencies are barred from acquiring systems that do not
conform with Section 508’s requirements if a compliant system is available.
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Code Of Federal Regulations,
36 CFR Part 1194
The “Section 508 standards” were authored by the US Access Board
and are in the Code of Federal Regulations, 36 CFR Part 1194:
• Subpart A - General Scope (1194.1)
• Subpart B - Technical Standards
- Software Applications and Operating Systems (1194.21)
-
Web-based Intranet and Internet Information and Applications (1194.22)
Telecommunications Products (1194.23)
Video and Multimedia Products (1194.24)
Self Contained, Closed Products (1194.25)
Desktop and Portable Computers (1194.26)
• Subpart C - Functional Performance Criteria (1194.31)
• Subpart D - Information, Documentation, and Support (1194.41)
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Problems
and
Solutions
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A closer look at three Avaya products
 TTY-on-VoIP
 TTY Messaging
 Universal Access Phone Status
In all three cases, we did the following:
 Identify the users’ needs.
 Identify capabilities that already existed within the
“plain vanilla” versions of the products, that we could
leverage in order to build the accessibility adjuncts.
 Because we were able to piggyback onto other
solutions that already existed, we have been able to
provide these accessibility adjuncts for free.
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TTY-on-VoIP
 Problem: The voice channels on VoIP systems may be unable to
transport TTY tones reliably.
 Users’ needs: People must be able to use standard TTYs. It must
be possible to intermix text and voice on the same call.
 Key capability that already existed: VoIP systems use a non-audio
mechanism (“RFC-2833”) to transport “touch tone” signals.
 The solution:
 Detect automatically when a TTY is in use.
 Use RFC-2833 protocol to transmit a description of the tones
(rather than the tones themselves). Command the receiving
system to reconstruct those tones for the TTY at the far end.
 Transmit each RFC-2833 packet many times. (Unless packet
loss is especially severe, at least one of them will get through.)
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TTY messaging
 Problem: If someone calls you, and you don’t answer your phone,
the call gets forwarded to voicemail. What if it’s a TTY user?
 Users’ needs: Callers must be able to choose whether they wish to
be prompted by voice or in TTY format. Regardless of the
prompting style they choose, they must be able to leave a voice or
TTY message.
 Key capabilities that already existed: (1) The ability to let callers
choose the spoken language for prompting; (2) the ability to record
and play back TTY tones reliably.
 The solution:
 Create a TTY “announcement set” in exactly the same way that
spoken announcement sets are created, i.e., by generating
audio recordings of the prompts and menus that must be
presented to users.
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Universal Access Phone Status
 Problem: Business phones use LCDs and LEDs to provide info.
 Users’ needs: People with visual impairments cannot get important
info, such as caller ID, whether the phone is forwarded, which lines
are in use, and whether someone on hold has disconnected.
 Key capability that already existed: Specific changes that occur in
a telephone’s display can only mean one thing. For example,
 Only one thing can cause the LED associated with button #1 to
go from steady-on to flashing: “Line 1 on hold.”
 Only one thing can cause the LED associated with button #3 to
go from flashing to off: “Caller on Line 3 has disconnected.”
 The solution: PC-based software that
 Monitors changes that occur in the telephone’s displays.
 Provides by voice output a description of what those changes
mean.
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Useful web pages
Access Board guidance for manufacturers and service providers:
• Section 255: http://www.access-board.gov/telecomm/index.htm
• Section 508: http://www.access-board.gov/sec508/guide/index.htm
Avaya information:
• Accessible solutions brochure: http://www.avaya.com/master-usa/enus/resource/assets/brochures/accessibility-brochure.pdf
• Section 508 home page:
http://www1.avaya.com/enterprise/gov/508/index.html
Other resources:
• The FCC Disabilities Rights Office: http://www.fcc.gov/cgb/dro
• Section 255 home page: http://www.fcc.gov/cgb/dro/section255.html
• Section 508 home page: http://www.section508.gov/
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