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Telephone terminals and accessibility with special reference to visual disabilities

A report prepared for

Canadian Radio-Television and Telecommunications Commission (CRTC)

by

Acuity Research Group Inc.

April 2005

Table of contents

1 Executive summary

1.1 Objectives
1.2 Definitions and scope
1.2.1 Definition of "basic service"
1.2.2 Evolution of technology
1.2.3 Definition of disability
1.3 Analysis by jurisdiction
1.3.1 Legislation
1.4 Task-based matrix
1.5 Accessible telephones
1.6 Accessibility of Canadian telco information on accessibility
1.7 Appendices
1.7.1 Appendix A
1.7.2 Appendix A.1
1.7.3 Appendix B
1.8 Conclusions
1.8.1 Availability of information about accessible telecom terminals on the websites of Canadian telephone companies
1.8.2 Accessible wireline equipment available from Canadian telcos
1.8.3 Availability of accessible cellular equipment from Canadian wireless service providers

2 Introduction

2.1 Objectives
2.2 Overview of the report
2.2.1 The approach followed
2.2.2 Organisation of the report
2.3 Challenges addressed
2.3.1 Defining basic versus enhanced services
2.3.2 The evolution of technology
2.3.3 The definition of disability
2.4 Equipment design considerations
2.4.1 Adaptation vs. accommodation
2.4.2 Universal Design, inclusive design, etc.

3 Analysis by jurisdiction

3.1 Australia
3.1.1 Overview
3.1.2 Legislation
3.1.3 Key cases
3.1.4 "Next generation" issues
3.1.5 Standards, etc.
3.1.6 Corporate information
3.2 Japan
3.2.1 Overview
3.2.2 Legislation
3.2.3 Key cases
3.2.4 "Next generation" issues
3.2.5 Standards
3.2.6 Corporate information
3.3 United Kingdom (UK)
3.3.1 Overview
3.3.2 Legislation
3.3.3 Key cases
3.3.4 "Next generation" issues
3.3.5 Standards
3.3.6 Corporate information
3.4 European Union (EU)
3.4.1 Overview
3.4.2 Legislation
3.4.3 Key cases
3.4.4 "Next generation" issues
3.4.5 Standards
3.5 United States (US)
3.5.1 Overview
3.5.2 Legislation
3.5.3 Key cases
3.5.4 "Next generation" issues
3.5.5 Standards
3.5.6 Corporate information
3.6 Canada
3.6.1 Overview
3.6.2 Legislation
3.6.3 Key cases
3.6.4 "Next generation" issues
3.6.5 Standards
3.6.6 Corporate information

4 The task-based matrix: background

4.1 An example
4.2 General tasks
4.3 Specific tasks
4.3.1 Receiving a call
4.3.2 Making a call
4.3.3 Phone management
4.3.4 Call management
4.3.5 Voice mail
4.3.6 Account management
4.3.7 User support

5 Accessible telephones

5.1 "Buyer’s guides"
5.1.1 American Foundation for the Blind (AFB)
5.1.2 BT (British Telecom)
5.1.3 Royal National Institute of the Blind (RNIB)
5.1.4 Tiresias / COST 219bis
5.1.5 Tiresias / COST 219ter
5.2 Business telephones: proprietary telephone systems
5.2.1 Section 255 of the (US) Telecommunications Act
5.2.2 Section 508 of the (US) Rehabilitation Act and the VPAT
5.2.3 Manufacturer statements of compliance
5.2.4 Accessibility Forum
5.3 Identifying accessible telephones: a "buyer’s guide"
5.3.1 Features for each disability category
5.3.2 Matching accessibility features to equipment

6 Accessibility of Canadian telco information on accessible telecom equipment

6.1 Objective
6.2 Method
6.2.1 Sampling
6.2.2 Procedure
6.3 Results
6.4 Conclusions

7 References

7.1 Legislation and related documents
7.1.1 Australia
7.1.2 Japan
7.1.3 United Kingdom
7.1.4 European Union
7.1.5 United States
7.1.6 Canada
7.2 Key legal decisions
7.2.1 Australia
7.2.2 United Kingdom
7.2.3 United States
7.3 Standards and Guidelines
7.4 Definitions of disability
7.5 Advocacy bodies: legal
7.6 Major policy papers (telecom and accessibility)
7.6.1 Australia
7.6.2 Europe
7.7 Design and other comment

1 Executive summary

1.1 Objectives

The present report was commissioned to provide a status report on the accessibility of telecommunications terminals to Canadians with a visual disability. Four deliverables were associated with this project:

1.2 Definitions and scope

The present report is intended to shed some light on the accessibility of telecom terminals, with special reference to persons with a visual disability. In addressing this general issue, we chose to begin by noting that this area deals with "moving targets". For example, the definition of "basic telephone service" has changed, as has the definition of "disability". Moreover, as technology continues to advance we can expect to see newer capabilities in the marketplace. Thus, the introduction to the report (Section 2) addresses these issues, which are summarised below.

1.2.1 Definition of "basic service"

A key component of telecom legislation is the specification of the requirement to provide basic telephone service, often characterised as the Universal Service Obligation. Typically, the relevant legislation defines what is meant by "basic service" and specifies the basis on which it must be provided. For example, is "basic service" simply voice service, or does it include the capability of handling data? Is "basic service" only dial tone, or does it also include features? These issues are addressed in Section 2.3.1.

The definition of "basic telephone service" has changed with time, and will likely continue to change.

1.2.2 Evolution of technology

The evolution of technology is relevant to accessibility in two ways touched upon here.

First, the current status of terminal design implies user interface issues in delivering functionality to the end-user via a telephone; in some cases, these issues may be addressed if the terminal includes an operating system capable of running the appropriate software, such as a screen reader. Such a development could occur via computer-telephony integration (CTI), but should also be possible in a telephone itself (such as a cell phone) as the intelligence of the device increases.

Second, the evolution of the network itself will create new opportunities and challenges with respect to accessibility. As an example, Voice-over-Internet-Protocol (VOIP) will achieve greater penetration in coming years, and care must be taken to ensure that its proliferation does not impose new barriers to telecom access.

1.2.3 Definition of disability

Prior to the World Health Organization’s development of the International Classification of Impairments, Disabilities and Handicaps version 2 (ICIDH-2) in the late 1990’s, the concept of disability was typically seen as an unidirectional process resulting from a disease or health impairment. Policies, research, and services were constructed and conducted using approaches such as the International Classification of Disease (ICD) that defined a disability from a highly medicalized perspective. Such models implicitly assumed that a congenital or acquired disorder within an individual led to pathological changes (signs and symptoms) that could result in a diagnosable impairment. These impairments, in turn, were seen to affect an individual’s ability to perform activities, resulting in a disability.

Recent models of disability, such as the current International Classification of Functioning, Disability and Health (ICF), view the process of disablement (the dynamic process of acquiring and living with a disability) as a complex interaction between health conditions and contextual factors, both personal and environmental. In 2001, the World Health Assembly adopted the International Classification of Functioning, Disability and Health (ICF; www.un.org/esa/socdev/enable/faqs.htm), which evolved from ICIDH-2.

The ICF defines disability as the outcome of the interaction between a person with an impairment and the environmental and attitudinal barriers. Impairments in ICF can be:

‘Functioning’ and ‘disability’ are the key concepts of the ICF classification—the more a person perceives his or her activities to be limited, or participation to be restricted, either in a work, leisure or self care situation, the more they may describe themselves as having a disability. In addition to classifying a disability at an individual level, the ICF also enables one to classify services, policies, and legislation as whether these facilitate an individual’s participation or establish barriers, resulting in a disability.

1.3 Analysis by jurisdiction

Section 3 of the report considers several jurisdictions, chosen to include those countries and organisations (such as the European Union) where the topic of accessibility has been addressed specifically in law. Using this as a criterion, the following jurisdictions are included in the present report, each in its own "chapter":

These chapters follow a similar outline:

In each chapter, the section on legislation covers existing laws. In the rare cases where there is a case that bears on accessibility and telecommunications, it is presented in a follow-up section. In both of these sections, the material is objective in the sense that it is documented and verifiable; that is, the laws and the court decisions are in the public domain and, with the exception of (for example) reversal on appeal, are enduring.

The next section in each chapter is more inferential, in that it concerns groups and issues that we have labelled "next generation" material. Relevant government organisations are described briefly, as are advocacy groups; both of these sets of organisations may become involved in future legislation or litigation. In presenting these, the intent is not to be exhaustive, but rather to identify some organisations that we believe will be worth watching for future developments in the area of telecom accessibility.

Next, major policy papers (if any) are identified. These are papers that we believe may influence advocacy in the future.

The two closing sections in each chapter concern (a) relevant telecom standards and guidelines (typically from a standards agency) and (b) information on the websites of telephone service providers that addresses accessibility. We see both of these, but especially the latter, as an indication of the immediacy of telecom accessibility in each jurisdiction.

1.3.1 Legislation

1.3.1.1 Overview

With the goal of describing the legislative landscape related to the accessibility of telecommunications, the present report looked at legislation in two areas:

A substantial literature exists in the general area of accessibility of telecom terminals for persons with visual disabilities. Thirty years ago this would not have been the case, and even 10 years ago there would have been considerably less legislation and design effort in place. However, major jurisdictions – including the United States, Australia, the UK, the European Union, and others – have taken legislative action in recognition of the fact that, without this, technological advances threaten to deny a sizeable portion of the population access benefits enjoyed by others. Whether this disenfranchising takes place through inattentive design, neglect, or other mechanisms is irrelevant; the presence of enforceable legislation appears to be the remedy.

In each jurisdiction, there has been an effort made to define the term "disability" in legislation. Subsequently, telecom legislation has been enacted that prohibits discrimination on the basis of disability (among other criteria).

Australia
1995 Disability Discrimination Act
1997 Telecommunications Act
1998 Telecommunications (Equipment for the Disabled) Regulations
1999 Telecommunications (Consumer Protection and Service Standards) Act

United Kingdom
1995 Disability Discrimination Act
1995 Disability Rights Commission Act
2003 Communications Act
2003 Electronic Communications (Universal Service) Act

United States
1990 Americans with Disabilities Act
1996 Telecommunications Act
1998 Section 508 of the Rehabilitation Act
2000 Section 255 of the Telecommunications Act

1.3.1.2 Key legal cases

Despite the existence of legislation prohibiting discrimination, we were only able to identify three cases relevant to the present report:

In Scott vs. Telstra, Scott – who has a hearing impairment – charged that Telstra discriminated against him, both directly and indirectly, by not supplying him with a teletypewriter (TTY) on the same basis that it provides a standard telephone to customers who are not hearing-impaired. Scott vs. Telstra is a landmark case in that it broadened the concept of service beyond that of switches, conduits, and telephones.

In Maguire vs. SOCOG, Bruce Maguire, who has a visual disability, made a human rights complaint against the Sydney Organizing Committee for the Olympic Games (SOCOG) because the Sydney Olympic Games website was not accessible to him. The impact of Maguire vs. SOCOG is likely to be widespread, for it establishes a precedent that a website may reasonably be considered a service, and therefore be subject to non-discrimination laws. Moreover, the case itself clearly demonstrated that, at least in this particular jurisdiction, defences based on an argument of "unjustifiable hardship" will not be taken at face value, but will be analysed in detail.

In February 2003, Dr. Bonnie O’Day filed a formal complaint with the Federal Communications Commission (FCC, under Section 255) on the grounds that mobile telephone equipment made by Audiovox Corporation was not accessible to persons with a visual disability; Verizon Wireless was also named in the complaint as the service provider. Both complaints were resolved privately (December 2003 and August 2004, respectively), and so were dismissed by the FCC. The complaint against both parties was eventually dismissed by the FCC because the parties settled privately, although the terms of the settlement were confidential. No further details were available from the FCC, and few details were provided in subsequent press releases.

1.4 Task-based matrix

Rather than looking at accessibility solely as a "global" attribute, we have broken telephone usage into several functionally defined steps and have looked at the accessibility of each of these steps. To do this, we first defined 6 general tasks, as follows:

Each of these general tasks was then broken down into specific tasks that are components of the general task. As an example, "receiving a call" was broken down into the following specific tasks:

Next, the mechanism for addressing each of these tasks was considered. For example, an incoming call can be detected by means of:

Each of these mechanisms may or may not be accessible to someone, depending on a variety of factors (telephone-based, user-based, or environment-based). The task-based matrix articulates each of these steps, comments on the accessibility for persons with a visual impairment, and where appropriate mentions a specific product implementation or regulatory requirement.

1.5 Accessible telephones

In anticipation of a need to identify characteristics of telephones that are valuable for persons with a visual disability, Section 5 of the report presents several "buyer’s guides" on accessible telephones.

In Section 5.2, "buyer’s guides" are presented from a variety of sources, including the British telco BT, the (UK) Royal National Institute of the Blind (RNIB), and the pan-European effort Tiresias (COST 219bis and COST 219ter). For business telephones, guidelines include Section 255 of the (US) Telecom Act and Section 508 of the (US) Rehabilitation Act, and especially the Voluntary Product Accessibility Template (VPAT) forms, and finally the (US) Accessibility Forum.

Using the Tiresias list of 8 "essential" features for blind users as criteria for accessibility, Section 5.3 examines 7 telephones to determine the accessibility of each. Two telephones were selected from manufacturer data, two from (US) distributor data, and three from the websites of Canadian telcos.

The results of this analysis showed that none of the telephones "scored" more than 4 of the 8 features identified by Tiresias as essential for blind users. All of the telephones "tested" met the criterion of "standard key layouts" for the dialpad.

The two telephones scoring highest (4 out of 8) were the Ameriphone JV-35 (available from a US distributor for US$79) and a pre-release telephone (KX-TG2386B) from Panasonic. The Ameriphone JV-35 offers Braille labelling on the dialpad and an announcement of each number as it is dialled. The Panasonic pre-release telephone offers Talking Caller ID and spoken feedback for several functions, as well as dial-out buffer memory.

All 5 of the other telephones scored 2 out of 8. The telephones offered on the Canadian telco websites were scored for having enlarged keys on the dialpad. By contrast, one "manufacturer" phone (Panasonic KX-TG2336S, US$190) and one distributor phone (AT&T 1818, US$30) offer Talking Caller ID.

1.6 Accessibility of Canadian telco information on accessibility

Section 6 of the report describes a small on-line research effort in which we looked at the websites of five Canadian telephone companies (telcos) to find information about accessible telephones for persons with a visual disability, trying to simulate the actions of an independent person doing such an on-line search. The objective of this small study was to determine how "far" from the telco’s home page such information would be found. As a control condition, we also searched for information about "mainstream" telephones. As a second control condition, we undertook a similar search on the websites of three US telcos providing local service.

The results of this survey showed that, in keeping with accepted guidelines for presentation of important information on a website, the US telcos and two of the Canadian telcos (MTS, SaskTel) provided information about accessible telephones within a small number of steps (clicks) from the home page. Moreover, this "distance" was non-discriminatory in that approximately the same number of steps was required for both mainstream phones and accessible phones.

For the other three Canadian telcos (Aliant, Bell Canada, Telus), although the distance to information about mainstream telephones was similar to that of the other telcos, we could find no information on their websites about telephones that were accessible to persons with a visual disability. Although the Bell Canada website contains information about telephones with features designed for persons with a visual disability, we could find no "signposts" leading us to this information, and simply had to browse the on-line catalogue. Neither Aliant nor Telus had any information about accessible telephones on their websites, as far as we could determine.

1.7 Appendices

Three appendices are attached to the report.

1.7.1 Appendix A

Appendix A reports the results of an on-line search for telephones accessible to persons with a visual disability. The search was conducted on the websites of telephone companies (telcos) in Australia, the United Kingdom, the United States, and Canada. In each jurisdiction, results are presented in three areas:

1.7.2 Appendix A.1

Appendix A.1 reports the results of an on-line search for telephones accessible to persons with a visual disability. However, this search was limited to the websites of selected manufacturers and distributors of residential telephones and adjunct equipment in the United States and Canada.

1.7.3 Appendix B

Appendix B provides information related to advances in making wireless terminals accessible to persons with a visual disability.

1.8 Conclusions

1.8.1 Availability of information about accessible telecom terminals on the websites of Canadian telephone companies

Question: On the websites of Canadian telephone companies (telcos), is there information about wireline telephones that are accessible to persons with a visual impairment?

Answer: In the United States, such information exists on the websites of telcos, and it can be accessed as easily as information about "mainstream" telephones on these websites. In Canada, the same is true of the websites of some telcos (MTS and SaskTel). However, the websites of larger Canadian telcos (Aliant, Bell Canada, Telus) either have no information about accessible telephones or do not identify such telephones as having features that make them accessible to persons with a visual disability.

1.8.2 Accessible wireline equipment available from Canadian telcos

Question: In cases where accessible telephones are identified on the websites of Canadian telcos, how do these telephones compare to other commercially available telephones in North America in terms of accessibility features for persons with visual disabilities?

Answer: The telephones and adjunct equipment described on the websites of Canadian telcos generally have fewer accessibility features for visually impaired users than do other commercially available telephones. By this standard, Canadian telcos are not offering visually impaired users the best equipment available.

1.8.3 Availability of accessible cellular equipment from Canadian wireless service providers

Question: What are the barriers to obtaining a cell phone in Canada that is accessible to users who are blind?

Answer: Through their own ingenuity and persistence, it is possible for knowledgeable blind persons in Canada to obtain suitable cell phones from non-Canadian suppliers, install the appropriate software to make the cell phone accessible, and have the phones activated on Canadian cellular networks. Thus, there are no obvious technology barriers to making an accessible cell phone available to blind persons in Canada; rather, the major barriers to the availability of a cell phone accessible to blind persons in Canada appear to be the equipment procurement and marketing practices of the wireless service providers in Canada. By contrast, in other markets blind users are able to benefit from advances in the design of cell phones, operating systems, and screen reading software.

2 Introduction

2.1 Objectives

The present report was commissioned to provide a status report on the accessibility of telecommunications terminals to Canadians with a visual disability. Four deliverables were associated with this project:

In addressing these objectives, we have completed a task analysis of telephone usage, breaking down each task (such as making a call) into elemental tasks. Working from this base, we have created a matrix to match the tasks with existing or possible technology solutions. This matrix, which embodies the work addressing Objectives 1 (needs) and 2 (elemental tasks), is contained in Section 4.

The details pertaining to Objective 3 (identification of terminal equipment) are contained in Appendix A, Appendix A.1, and (for wireless terminals) Appendix B. As well, supplementary material in Section 5 is presented in the form of "buyer’s guides" for accessible telephones.

Objective 4 (legislation, key decisions, etc.) is addressed in Section 3 of the report, where different jurisdictions are considered in detail.

2.2 Overview of the report

2.2.1 The approach followed

In preparing this report, we have been mindful of the fact that accessibility is a moving target. Specifically, we have been aware of challenges in three areas:

One possible approach to the present project was to freeze time and prepare the report "time-stamped" for a particular date. However, we saw this as providing limited value in the context of an on-going discussion concerning telecommunications and accessibility. Accordingly, our approach has been to develop a framework that accepts changes in these areas and provides a platform that can evolve along with them.

Throughout, we have taken the approach that the information we provide should, to the extent possible, represent the information available to persons with a visual disability who are looking for resources electronically. Within the constraints of the present project, it was not possible to exhaustively sample the alternative-format materials available from equipment manufacturers, service providers, advocacy organisations, and other groups in all locations in Canada. For this reason, we chose the Internet as the "common denominator", and made the assumption that a search for resources would include the Web, even if it did not rely on the Web entirely. In this sense, the present report is equally applicable to all communities across Canada.

2.2.2 Organisation of the report

Following the present section, the introduction of the report begins (Section 2.3) with a somewhat detailed evaluation of the types of challenges we faced in addressing the issue of non-visual accessibility and telecom terminals. As will be seen below, we have considered three separate challenges:

Section 2.4 looks at some issues related to the design of equipment in general, with some specific examples provided for the design of telecom equipment. Section 2.4 includes:

Section 3 examines the general issue of telecom accessibility in several different countries, which – depending on one’s approach – may also be seen as jurisdictions or markets. Specifically, Section 3 considers the following jurisdictions:

For each of these jurisdictions, the description includes the following sections:

In the next major section of the report (Section 4), we present a task-based analysis of the use of a telephone terminal to complete each of several telephony tasks that are generally included in the category of "basic service" (see Section 2.3.1, plus relevant sections in each jurisdiction, for the definition of "basic service"). Each task is broken down into component actions, with equipment implications where appropriate. At the elemental level, the accessibility of each of these actions is described.

Section 5 of the report is styled as a "Buyer’s guide" to telephones accessible to users with a visual disability.

2.3 Challenges addressed

2.3.1 Defining basic versus enhanced services

Fifty years ago the provision of dial tone was, in effect, the "feature set" offered by telephone companies (telcos), which at that time were also responsible for distributing and installing rotary-dial telephone terminals in residences (the telephone known as "the 500 set"). In 1964, the advent of the dual-tone, multi-frequency (DTMF) dialpad made Touch-tone™ dialling (www.bell.ca/en/about/history/timeline/1960c.asp) possible in Canada. Later, with the "unbundling" of the service and equipment sides of the telecom business, consumers enjoyed a greater selection in the choice of terminals.

Whereas fifty years ago it might have been possible to argue that dial tone delivered over a party line was "basic" telephone service, and that a private line was an "enhanced" service for which the consumer would pay more, today party lines are much less common, and a private line is taken for granted as a key component of "basic" service. In addition, it is now common for consumers to have access to a range of telephone features, either via the telephone terminal itself (e.g., a "Hold" button or a "Redial" button) or via the telco (in either the switch or the network).

Thus, the baseline for what constitutes "basic" telephone service has shifted over time, and will likely continue to do so. This situation has presented the challenge of defining "basic telephone service" in a way that will not become obsolete in the near future.

2.3.1.1 Defining "basic service"

Given the shifting baseline for "basic service", it is easier to ask what constitutes "basic service" than to provide an answer that will enjoy longevity. Below, we discuss the concept of basic service in today’s legislative environments in Australia and in the United States – jurisdictions where telephony and accessibility have been the subject of considerable legislative effort – as well as in Canada. While it is certainly possible that the definition of basic service will change over time, the text below provides both a "time stamp" and examples of the logic used to define basic telephone service.

In these jurisdictions, there is a common framework for the definition of basic service. Although telecom deregulation has occurred to some extent, it is still the case that "traditional" telephone service providers, who typically have a large market share, have the status of being "universal service providers" and hence have regulatory pressure to meet the "universal service obligation" (Basic Service Objective in Canada). In part, the definition of "basic service" is tied to this obligation, at least for these traditional telephone companies (telcos).

2.3.1.1.1 Australia

Australia has enshrined the definition of Standard Telephone Service (STS) in legislation. Section 6 of the Telecommunications (Consumer Protection and Service Standards) Act 1999 (Act No. 50 of 1999 as amended, up to and including Act No. 114 of 2003) defines STS as voice telephony or the equivalent, with the wording as follows:

(1) A reference in a particular provision of this Act to a standard telephone service is a reference to a carriage service for each of the following purposes:

where:

(2) A service passes the connectivity test if an end-user supplied with the service for a purpose mentioned in paragraph (1)(a), (b) or (c) is ordinarily able to communicate, by means of the service, with each other end-user who is supplied with the same service for the same purpose, whether or not the end-users are connected to the same telecommunications network.

(3) The following are examples of purposes that could be declared by regulations made for the purposes of paragraph (1)(c):

(a) the purpose of the carriage of data;
(b) the purpose of tone signalling.

(4) In making a recommendation to the Governor-General at a particular time about the making of regulations for the purposes of paragraph (1)(c), the Minister must have regard to the following matters:

(a) whether a carriage service for the purpose proposed to be declared by the regulations can be supplied using the same infrastructure as is, at that time, being used by universal service providers to supply a standard telephone service for the purpose referred to in paragraph (1)(a);
(b) such other matters (if any) as the Minister considers relevant.

(5) This section does not prevent a characteristic declared by regulations made for the purposes of paragraph (1)(e), (f) or (g) from being a performance characteristic.

(6) In this section:

this Act includes the Telecommunications Act 1997.

2.3.1.1.2 United States

In Section 254(c), the Telecommunications Act of 1996 defines Universal Service (www.fcc.gov/Reports/tcom1996.txt) as:

Moreover, the Federal Communications Commission (FCC) tried to address the issue of "basic" and "enhanced" services in Section 255 of the Telecom Act of 1996 ("Section 255", hereafter). The approach adopted by the FCC was to mandate that "basic" and "adjunct-to-basic" services be accessible to persons with disabilities. (We will consider this topic more fully below.)

According to Section 255, the term "adjunct-to-basic" is defined as:

"services which literally meet the definition of enhanced services, now called information services, established under the Commission's rules, but which the Commission has determined facilitate the completion of calls through utilization of basic telephone service facilities and are included in the term "telecommunications services." Adjunct-to-basic services include such services as call waiting, speed dialing, call forwarding, computer-provided directory assistance, call monitoring, caller identification, call tracing, and repeat dialing" (Section 255, Section D: SERVICES AND EQUIPMENT COVERED BY THE RULES, paragraph 77).

Thus, legislation in the United States recognises the evolution of telephony service, and has incorporated into basic service not only dial tone, but also a set of services, defined as "adjunct to basic", which are an expected component of the residential telecom environment.

2.3.1.1.3 Canada

In Canada, section 7 of the Telecommunications Act (1993, c.38) sets out objectives for telecom services in Canada (laws.justice.gc.ca/en/T-3.4/101939.html):

7. It is hereby affirmed that telecommunications performs an essential role in the maintenance of Canada's identity and sovereignty and that the Canadian telecommunications policy has as its objectives

(a) to facilitate the orderly development throughout Canada of a telecommunications system that serves to safeguard, enrich and strengthen the social and economic fabric of Canada and its regions;

(b) to render reliable and affordable telecommunications services of high quality accessible to Canadians in both urban and rural areas in all regions of Canada;

(c) to enhance the efficiency and competitiveness, at the national and international levels, of Canadian telecommunications;

(d) to promote the ownership and control of Canadian carriers by Canadians;

(e) to promote the use of Canadian transmission facilities for telecommunications within Canada and between Canada and points outside Canada;

(f) to foster increased reliance on market forces for the provision of telecommunications services and to ensure that regulation, where required, is efficient and effective;

(g) to stimulate research and development in Canada in the field of telecommunications and to encourage innovation in the provision of telecommunications services;

(h) to respond to the economic and social requirements of users of telecommunications services; and

(i) to contribute to the protection of the privacy of persons.

However, the text of the Telecommunications Act does not set a benchmark for basic telecom service. The CRTC tackled the issue of defining "basic service" in the Basic Service Objective in Telecom Decision 99-16. As part of the background for this decision, the Commission noted:

12. Based on the record of this proceeding, it is estimated that over 18 million telephone lines are connected to the public switched telephone network. Over 99 per cent of these lines represent "single line" service. More than 97 per cent are connected to a digital switch, provide touch-tone telephone service, and can connect, via low speed data transmission, to the Internet without incurring long distance charges. Some telephone companies offer this level of service in 100 per cent of their lines. These figures indicate the success of Canadian telecommunications, which has grown steadily over the last century, in providing millions of Canadian residences and businesses with high quality service.

This characterisation provides the backdrop for the definition of "basic service" developed by the Commission:

24. The Commission considers that the level of service now available to the vast majority of Canadians should be extended to as many Canadians as feasible in all regions of the country. Accordingly, the Commission is hereby establishing the following basic service objective for local exchange carriers:

*Individual line local service with touch-tone dialling, provided by a digital switch with capability to connect via low speed data transmission to the Internet at local rates;
*Enhanced calling features, including access to emergency services, Voice Message Relay service, and privacy protection features;
*Access to operator and directory assistance services;
*Access to the long distance network; and
*A copy of a current local telephone directory.

Immediately following this definition, the Commission noted:

25. The basic service objective is independent of the technology used to provide service, and may change over time as service expectations evolve.

Moreover, the Telecommunications Act (1993, c.38, section 27) stipulates that unjust discrimination against persons must not be practiced by telecom carriers:

(2) No Canadian carrier shall, in relation to the provision of a telecommunications service or the charging of a rate for it, unjustly discriminate or give an undue or unreasonable preference toward any person, including itself, or subject any person to an undue or unreasonable disadvantage.

2.3.1.2 Basic service: summary

The definition of "basic telephone service" has changed with time, and will likely continue to do so.

2.3.2 The evolution of technology

As technology evolves, more and more products and services will become available. The evolution of the telephone terminal itself from the rotary-dial telephone (the classic "500 set") to the basic push-button telephone ("2500 set"), and on from there, is an indication of the way in which the advance of technology has enabled the delivery of increased functionality to the user. In this instance, the baseline for what constitutes a telephone terminal has changed over time.

Unfortunately, history shows that progress does not mean that greater accessibility is a given. Some products will become more accessible, while others will be developed that may present new challenges for accessibility. As an example, printed material used to be inaccessible to a blind reader unless the material was available in Braille or audiotape. With the increased penetration of personal computers, as well as the development of screen readers, the amount of text-based material available to blind readers has increased enormously. More recently, personal digital assistants (PDAs) have become popular for reading e-mail and other text-based items, yet these can present accessibility challenges in their own right, as can display-based cell phones.

Until recently, it was the case that, as each new generation of products and services was introduced, it was necessary to ensure accessibility post hoc. However, recent legislative changes in some markets (e.g., Section 508 of the Rehabilitation Act in the United States; see Section 3.5.2 below) have improved this situation somewhat. Unfortunately, though, it appears that accessibility is not likely to be a "mainstream" design criterion until it has become a core part of the training of product designers as well as a cornerstone of the legislative environment. This sentiment was expressed well by William Jolley in When the Tide Comes In: Towards Accessible Telecommunications for People with Disabilities in Australia (2003, pp. xii-xiii):

Without inclusive design embedded in the product development cycle, people with disabilities must engage in a never-ending process of ‘catch-up’. As assistive technology is released that provides access, the relentless march of new technology soon means that a new inaccessible product is released; and the cycle of access denied, adaptation and retrofitting begins again.

As the portal to the network, the terminal can also support access to increased functionality either in the (class 5) telephone switch to which the subscriber is connected, or to the network as a whole. In the following paragraphs, we consider briefly some examples of these different domains. A detailed examination of these areas is beyond the scope of the present report, but they are mentioned because these topics may acquire greater prominence in the area of accessibility and telecom as time goes by.

2.3.2.1 Terminal design: evolution

Fifty years ago, the standard residential telephone was a rotary-dial terminal (the "500 set"). Lifting the handset permitted the user to access the telephone line, and hanging up the handset terminated the call. There were no telephone features in the residential market, and every Canadian household with a telephone had the same model, which was connected to an analog switch in the public switched telephone network (PSTN).

With the deregulation of the telecom market, the telephone service provider (telco) was no longer the sole source of telephone terminals, and the consumer was given a wider choice of equipment that could be attached to the PSTN. Several companies designed and manufactured different models of terminals, and the uniformity of design largely disappeared. Moreover, the PSTN itself was changing, analog switches being replaced by digital switches, supporting the delivery of greater functionality to the subscriber.

Today, it is common for "standard" residential telephones to have a display, several feature buttons (such as Hold, Link, Redial), some autodial buttons (for one-button dialling of frequently called or important numbers), and perhaps speakerphone capability. However, although increases in terminal-based sophistication can deliver greater functionality to the end-user, added functionality can also come from other sources.

2.3.2.1.1 Computer-telephony integration

In the mid-1980s, it was not uncommon to see articles in the trade press (e.g., magazines such as Byte and Teleconnect) that referred to "the battle for the desktop", asking whether, in the business environment, the telecom manager or the management information systems (MIS) manager would become dominant in the organisational structure. This era also saw the early days of computer-telephone integration (CTI), in which a link between an employee’s desk telephone and the desktop computer (or terminal) enabled the employee to view information on the computer screen related to the incoming or outgoing call.

The birth of CTI has been long and difficult. Today, CTI is now well entrenched in specialised environments such as telemarketing and customer care organisations. However, CTI is still not used widely in the general business environment, and hardly at all in the residential environment. For this reason, CTI is not considered explicitly in the present report. Nevertheless, it is worth noting parenthetically that CTI is relevant to the accessibility of telephony functions, especially for users with a visual disability, because many of the telephone’s functions appear on a computer screen, where they can presumably be addressed by a screen reader.

2.3.2.2 Network technology: evolution
2.3.2.2.1 Voice and data

Historically, there have been two "camps" in the general area of information technology: voice and data. Traditionally, voice communication has been analog, at least in the local loop (from the residence to the class 5 switch). Until about 1980, switches in the voice network also used analog technology, but by the mid-1980s analog switches were rapidly being replaced by digital switches, and today telecom networks are largely digital. However, to this day most of the local loops connecting the residence to the network use analog circuits.

Despite the fact that both voice and data can appear as digital signals, they are not equivalent and so have to be treated differently. Voice is traditionally transmitted as circuit-switched information, whereas data is typically treated as packets, and is packet-switched. In transmitting data, packets may be dropped or delayed and may be retransmitted without serious consequence; however, should the same thing happen with voice "packets", the listener would hear a voice signal that might be unintelligible at worst, and choppy at best. As a result, voice is usually circuit-switched, where the integrity of the voice signal is maintained to a greater degree than has been possible in a packet-switched environment.

2.3.2.2.2 Voice-over-Internet-Protocol (VOIP) technology

The rapid growth in Internet usage over the past decade has posed a major challenge to telephone operating companies (telcos). Until data transmission from residences became common (with the Internet), telcos engineered their class 5 switches according to voice traffic characteristics: so many calls per day, so many minutes per call, etc. Once modems became popular, enabling Internet connection over voice lines, the average holding time (length of a call) changed considerably, from a few minutes per call to tens of minutes. By implication, the class 5 switches, to which residences are connected, became "clogged".

Telcos sought ways of separating data and voice communications occurring on the same telephone line, splitting off data communications to handle data separately from the class 5 switch; in effect, this forced telcos to implement parallel channels, one for voice and one for data.

IP is the industry acronym for "Internet protocol", a transmission protocol used to manage data traffic on the Internet. To the extent that voice signals can be packetized and treated similarly to data, the telcos could streamline their networks and remove the "dual path" they have been pushed to. For this reason, several telcos have begun adopting voice-over-IP (VOIP) technology in their networks. At present, packetized voice quality is still not at the level of circuit-switched voice quality. Nevertheless, potential economies in running a single network have spurred advances in VOIP technology, with great effort expended to solve the problem of the quality of VOIP signals.

As VOIP technology continues to develop, it may be expected to find its way into the networks of operating companies, into corporate networks, and perhaps eventually into residences. Because VOIP does not yet enjoy a large penetration into the residential environment, it has not been considered explicitly in the present report, but future activities will likely need to examine the relevance of VOIP technology to accessibility. In a paper published in 2003, Gregg Vanderheiden (head of the Trace Research Institute at the University of Wisconsin) commented,

The wonderful thing about voice-over-IP is that this transmission format, and the types of telecommunications technologies used to implement it, will make it easier to implement accessibility than in any technology before.

For example, one technology company called Avaya has just released a phone program that, when loaded onto the phone server, immediately allows much of the phone functionality on all of the phones to be accessible to those that are blind. And these don’t require any change to the phones. With small changes to the phone software, full access could be gained to the phones without any hardware changes. …

There is nothing about voice-over-IP that makes accessibility harder than with PSTN. VoIP does present some new issues, but solutions for them are already known. We are hearing from those in industry that they cannot move forward with access implementations until it is clear that their companies will either have some advantage, or at least not be at a disadvantage, for implementing access while competitors are doing something else.

It is both important and necessary to carry disability access forward into voice-over-IP. It is technically feasible and, as the regulations are enforced so that there is a level playing field, it is commercially feasible and practical to implement VoIP technologies – with great effect for those with disabilities and for those who are older.1Footnote 1

2.3.2.2.3 Advanced Intelligent Network (AIN)

In the public switched telephone network (PSTN), intelligence in the switches permits calls to be handled in different ways. For example, it is possible to subscribe to a Call Forwarding service. This feature is used if the subscriber will be away from home and wants calls re-routed (forwarded) to another number. When the feature is enabled and a call comes in to the subscriber’s "home switch", the switch re-routes the call to the new destination number. This is an example of a switch-based feature.

The Advanced Intelligent Network (AIN) is, in simple terms, a signalling network that is parallel to the PSTN. AIN permits subscribers (usually business customers, rather than residential customers) to design and implement services based on AIN service elements. In this way, it is possible to build intelligence into the network – not just a into single switch – to handle call traffic better.

As an example, suppose you own a chain of pizza restaurants in a city. During the working hours of weekdays, your downtown branches receive many orders, and the residential branches receive very few. At dinnertime, in the evenings, and on weekends, the opposite is true. It is inefficient to try to juggle staff and supplies among the branches, so you may turn to AIN as a solution.

With AIN, you can have a single phone number for the customer to call (which means it is not necessary for the customer to know different numbers for different branches). When the customer calls this number (typically a 310-series number, such as 310-5555), it is recognised as an AIN number and treated differently than a "regular" number. The calling number (i.e., the customer) is identified and located geographically, and the call is routed to the nearest branch. However, because you know that "nearest" may not be defined by distance but by driving time, you have set up your AIN programme to send calls to the branch that will be able to make and deliver a pizza in the fastest time, given the traditional number of orders based on time of day and day of the week. Thus, it is possible that a customer dialling your AIN number at noon on Tuesday will reach one branch, but the same customer calling the same number from the same location on Wednesday evening will reach another branch. In this way, intelligence in the network is able to customise the operation of the network to meet the needs of the subscriber.

The present report is not the place to go into great detail about the potential of AIN in the area of accessibility. However, it is possible that network-based intelligence (as opposed to switch-based or terminal-based) will have a role to play in the delivery of greater telecom accessibility in the future.

2.3.2.3 Evolution of technology: summary

The evolution of technology is relevant to accessibility in two ways touched upon here.

First, the current status of terminal design implies user interface issues in delivering functionality to the end-user via a telephone; in some cases, these issues may be addressed if the terminal includes an operating system capable of running the appropriate software, such as a screen reader. Such a development could occur via computer-telephony integration (CTI), but should also be possible in a telephone itself (such as a cell phone) as the intelligence of the device increases.

Second, the evolution of the network itself will create new opportunities and challenges with respect to accessibility. As an example, Voice-over-Internet-Protocol (VOIP) will achieve greater penetration in coming years, and care must be taken to ensure that its proliferation does not impose new barriers to telecom access.

2.3.3 The definition of disability

Defining the term "disability" is not an objective of the present document. However, to inform the discussion concerning this definition, we have opted to include in Section 3 a variety of definitions from Canadian and other jurisdictions. In the present section, we provide a high-level overview of the definition from the United Nations, which is likely to emerge as the standard.

2.3.3.1 Background

Prior to the World Health Organization’s development of the International Classification of Impairments, Disabilities and Handicaps version 2 (ICIDH-2) in the late 1990’s, the concept of disability was typically seen as an unidirectional process resulting from a disease or health impairment. Policies, research, and services were constructed and conducted using approaches such as the International Classification of Disease (ICD) that defined a disability from a highly medicalized perspective. Such models implicitly assumed that a congenital or acquired disorder within an individual led to pathological changes (signs and symptoms) that could result in a diagnosable impairment. These impairments, in turn, were seen to affect an individual’s ability to perform activities, resulting in a disability.

In the 1990’s, stakeholders (consumers, researchers, and policy makers alike) in the area of disability began to agree that such impairment-based conceptual models of disability had many shortcomings, some of the major ones being:

2.3.3.2 Progress

Recent models of disability, such as the current International Classification of Functioning, Disability and Health (ICF), view the process of disablement (the dynamic process of acquiring and living with a disability) as a complex interaction between health conditions and contextual factors, both personal and environmental.

As shown in Figure 1, both environmental and personal factors mediate the level and extent of a person’s ability to participate in his or her surroundings. Participation can either involve personal activities or engagement in larger societal activities; these could be work-related or non-work-related.

Figure 1 - Health Condition (disorder/disease)
Figure 1 - Health Condition (disorder/disease)
Long description

Figure 1 Illustrates the ICF model of disability, showing the influence of environmental and personal factors on the person’s ability to participate in activities. Modified from ICF Handbook (2001).

Environmental factors are extrinsic to the individual and include physical and non-physical elements that can either facilitate a person’s participation or restrict it. Some examples of environmental factors are:

Personal factors have an effect on how an individual or group experiences disablement. They include a myriad of factors that play a significant role in a person’s perception and understanding of their disability and the limitations being imposed on her or his ability to participate in society at all of its levels (e.g., personal relationships to work settings to policy planning and development). Some examples of personal factors are:

2.3.3.3 ICF: the United Nations

In 2001, the World Health Assembly adopted the International Classification of Functioning, Disability and Health (ICF) (www.un.org/esa/socdev/enable/faqs.htm), which evolved from the ICIDH-2. (The following material, from this source, has had minor typographical errors corrected.):

There is no universally agreed definition of disability.

The World Programme of Action for Disabled Persons and the Standard Rules on the Equalization of Opportunities for Persons with Disabilities emphasizes that disability is a socially created problem and not an attribute of an individual. Disablement results from a dynamic interaction between health conditions and other personal factors (such as age, sex, personality or level of education) on the one hand, and social and physical / environmental factors on the other hand. It, therefore, is important to distinguish between

Impairment: Any loss or abnormality of psychological, physiological, or anatomical structure or function;
Disability: Any restriction or lack (resulting from an impairment) of ability to perform an activity in the manner or within the range considered normal for a human being and;
Handicap: A disadvantage for a given individual, resulting from an impairment or disability, that, limits or prevents the fulfilment of a role that is normal, depending on age, sex, social and cultural factors, for that individual.

This social perspective on disability is reflected in the International Classification of Functioning, Disability and Health (ICF), adopted by the World Health Assembly in 2001. The ICF further recognizes that disability is a universal human experience and not a concern to a minority of humanity: every human being can suffer from a decrement in health and, thereby, experience some disability.

Earlier models viewed disability as a static condition based upon medical diseases and impairments. Challenging this view is the International Classification of Functioning (ICF) developed by the World Health Organization and adopted by Canada, the United States and many other countries. The ICF complements ICD-10 , The International Statistical Classification of Diseases and Related Health Problems and therefore looks beyond mortality and disease.

The ICF defines disability as the outcome of the interaction between a person with an impairment and the environmental and attitudinal barriers. Impairments in ICF can be:

‘Functioning’ and ‘disability’ are the key concepts of the ICF classification—the more a person perceives his or her activities to be limited, or participation to be restricted, either in a work, leisure or self care situation, the more they may describe themselves as having a disability. In addition to classifying a disability at an individual level, the ICF also enables one to classify services, policies, and legislation as whether these facilitate an individual’s participation or establish barriers, resulting in a disability.

Although the ICF definition is becoming accepted more widely, it is instructive to see how the term "disability" has been defined by other jurisdictions, and in other contexts. Section 3 provides more detailed information on this topic for each jurisdiction considered.

2.3.3.4 Market sizing

In Canada, several national population-based surveys have been used to estimate the extent of disability among Canadians and the self reported effects of the limitations imposed by the disability upon the individual. Two currently in use are the Participation and Activity Limitation Survey (PALS) and the National Population Health Survey (NHPS).

2.3.3.4.1 Participation and Activity Limitation Survey (PALS)

The Participation and Activity Limitation Survey (PALS) uses the World Health Organization’s (WHO) framework of disability provided by the International Classification of Functioning (ICF). This framework defines disability as the relationship between body structures and functions, daily activities and social participation, while recognizing the role of environmental factors. Prior to 2001, the Healthy Activity Limitation Survey (HALS) had been used to determine rates of disability among the Canadian population and the effects of those disability on person, social and work-related activities. Due to the shift towards the ICF model employed in PALS, the use of the HALS database has declined as no reliable comparisons can be made between it and the PALS.

For the purpose of PALS, persons with disabilities are those who reported difficulties with daily living activities, or who indicated that a physical, mental condition or health problem reduced the kind or amount of activities they could do.

The respondents’ answers to the disability questions represent their perception of the situation and are therefore subjective.

2.3.3.4.2 National Population Health Survey (NPHS)

The National Population Health Survey (NPHS) used the Labour Force Survey sampling frame to draw a sample of 22,000 households. Persons of all ages across all provinces in Canada were randomly selected to participate in the survey. By contrast, PALS utilized the 2001 Census as a sampling frame that included age, geography and participants’ responses to two questions on activity limitations. Telephone interviews were first conducted in 1994 and have been repeated every two years with the same respondents in order to create a longitudinal database on health, social, and economic indicators. Data were also collected on children (age 12 and younger) based on perceptions of their parents as well as from a limited number of institutionalized individuals.

The survey includes information related to health status, use of health services, determinants of health and a range of demographic and economic information. The use of health services is probed through questions on accessing of traditional and non-traditional care providers and service, and the use of drugs and other medications. The demographic and economic information includes age, sex, education, ethnicity, household income and labour force status.

Whereas the PALS samples directly on disability, the NPHS is a general health survey based primarily upon a sampling frame that considers age, gender, and geographical location. As such, PALS and NPHS provide slightly different perspectives on the question of the prevalence of disability in Canada and the limitation imposed on the activities and participation of such individuals. Comparisons are also difficult to make across the two surveys as how disability was defined varied between the two. Nevertheless, the general findings from the two provide a snapshot of the magnitude of disability within Canada.

From the PALS survey conducted in 2001, it is estimated that 3.6 million Canadians experience an activity limitation, representing a disability rate of 12.4% overall. Here, a person was defined as "disabled" if she or he reported any limitation on everyday activities or indicated that a physical, mental condition or health problem(s) reduced the kind or amount of activities she or he could do.

The PALS rate of disability, as shown in Table 1, is 9.9% among people 15 to 64 years of age, but increases to 40.5% among Canadians 65 and older. More than half of Canadians 75 years or older report being disabled.

TABLE 1

Rate of Non-Disability and Disability by Age

Total population Population without disabilities Population with disabilities Percentage of population with disabilities
Total population 28,991,770 25,390,510 3,601,270 12.4
Age groups
0 to 14 5,546,020 5,365,090 180,930 3.3
0 to 4 1,641,680 1,615,480 26,210 1.6
5 to 14 3,904,330 3,749,610 154,720 4.0
5 to 9 1,914,220 1,843,850 70,370 3.7
10 to 14 1,990,110 1,905,760 84,350 4.2
15 and over 23,445,760 20,025,420 3,420,340 14.6
15 to 64 19,858,350 17,889,850 1,968,490 9.9
15 to 24 3,883,690 3,732,670 151,030 3.9
25 to 44 8,849,090 8,222,480 626,610 7.1
45 to 64 7,125,570 5,934,710 1,190,850 16.7
65 and over 3,587,410 2,135,560 1,451,840 40.5
65 to 74 2,082,750 1,433,570 649,180 31.2
75 and over 1,504,660 701,990 802,670 53.3

1. The Canada total excludes the Yukon, Northwest Territories and Nunavut. The sum of the values for each category may differ from the total due to rounding.

Source: Statistics Canada, Participation and Activity Limitation Survey, 2001.

The most frequent types of self-reported disability among adult Canadians (15 years of age and older) are shown in Table 2 (below).

The prevalence of the type of reported disabilities among persons with disabilities reveals the magnitude of the limitation experienced by this section of the Canadian population. As an example, of those adult Canadians self-reporting a disability, 71.7% report problems in mobility, 69.5% state they have pain in one form or another, 66.6% report problems with their agility, 30.4% with hearing, 17.4% with vision, 12.3% with memory, and 10.6% with speech. Moreover, many have more than one reported disability. Approximately, 64.5% of adults with a disability report having three or more disabilities. Only 18.2% report having only one disability, with another 17.4% reporting two disabilities.

TABLE 2

Incidence of type of disability

Type of disability Percentage of population Number of people
Mobility 10.5 2,451,570
Pain 10.1 2,376,730
Agility 9.7 2,276,980
Hearing 4.4 1,038,140
Seeing 2.5 594,350
Psychological 2.2 522,850
Learning 1.9 451,420
Memory 1.8 420,750
Speech 1.5 362,720
Developmental 0.5 120,140
Unknown 0.4 96,180

Among the participants reporting disabilities, 34.1% report that their disability is mild, whereas 25% classify it as moderate. Severe disability is reported by 26.9% of adults with disabilities, and another 14% say their disability is very severe.

These results stress that individuals with disabilities cannot easily be separated into independent, discrete categories, for disablement is a complex process involving, as stated earlier, complex interactions between personal and environmental factors and the limitations that these factors impose within a context.

Research on short-term disabilities, defined in the NPHS/Ontario Health Survey of 1996-1997 as any limitation in activity resulting from an illness over a 14-day period, indicates that in Ontario 11.1% of individuals report having some type of short-term loss in everyday functioning (Health Status Report, 1999). Moreover, the incidence of short-term disabilities increases with advancing age (10.5% for 25-44 year olds, 11.4% for 45-64, and 13.1% of people 65 and older). It is estimated that Canadians will, on average, experience 4.4 years of disability prior to death (Literature Review of Care Trends for Seniors, Veterans Affairs Canada, 1997). Although not all of the limitations that will be experienced by an individual over the lifetime will necessarily affect telephony use, it is important to realize that disability per se is not necessarily a constant, chronic condition but one that can fluctuate over a person’s lifetime.

2.3.3.5 Definition of disability: summary

The definition of the term "disability" varies from jurisdiction to jurisdiction (see Section 3). The UN definition is a common standard. It is crucial to realise that disability is not a fixed, permanent, unchanging condition; many people experience temporary disability, which may be a result of a physical condition (e.g., broken arm) or an environmental effect (e.g., heavy snowfall).

As a result, the size of the "disabled market" depends on the definition of "disability"; the aggregate may include most Canadians. There exists a market justification to design and manufacture products whose "user specification" is not based solely on young, able-bodied individuals.

2.4 Equipment design considerations

The present report examines the accessibility of telecom terminals. In considering telecom equipment itself, we have inventoried two categories separately:

It is appropriate to include here a short section on equipment design to provide some context for this type of analysis.

Historically, products are designed for "mainstream" users, who by definition do not have "special needs". This product may serve its target market very well. However, because of certain aspects of its design, the product may not be usable by other people, such as those with a permanent or temporary disability, those who are experiencing the normal effects of aging, or those who are using the product in an environment other than the one for which it was designed.

2.4.1 Adaptation vs. accommodation

As an example, suppose that a particular telephone has black buttons with grey letters and numbers on them. The "design intent" is that this low-contrast lettering provides a touch of style. This telephone will be usable by persons with normal vision who are using the telephone in good lighting. However, it may not be usable by someone with impaired vision, even if this impairment is sub-clinical, such as in the case of a typical 60-year-old person. Also, the telephone may not be usable by the normally sighted person who tries to use the telephone in dim light, for example without turning on a light in a room where others are sleeping. Thus, although this telephone may be more stylish than others, there is a price paid for the style in terms of a reduction in the size of its available market.

A customer who wants to be able to see the letters and numbers on the telephone has two choices: to acquire add-on labels that are of higher contrast than the original labels, or to acquire a different telephone. In the inventory later in the report (and in Appendices A, A.1, and B), the first solution would fall into the "Adjunct" category, whereas the second would be in the "Telephones" category.

In the world of accessibility, the first solution – adding a component to make a product more accessible – is often referred to as "adaptation", because it adapts the product to make it usable by a wider range of people under a broader range of circumstances. By contrast, the second solution – producing a telephone that has taken this broader "user specification" into consideration during the design process, rather than as an afterthought – is referred to as "accommodation", because the product accommodates a wider range of users and circumstances. Both solutions make the product more accessible.

2.4.2 Universal Design, inclusive design, etc.

It is not an objective of the present report to provide an extensive description of different schools of design. However, it may be helpful to note that the past few decades have seen movements which carry titles such as "barrier-free design", "inclusive design", "design for accessibility", and "universal design".

All of these approaches recognise the value of designing products, user interfaces, and built environments (such as buildings and landscapes) in such a way that fewer people are excluded from using them than has traditionally been the case with "mainstream" design. Without favouring any of these approaches, we note here two definitions of Universal Design:

Universal design can be defined as the design or products and environments to be usable to the greatest extent possible by people of all ages and abilities.2

Universal design is the process of creating products (devices, environments, systems, and processes) which are usable by people with the widest possible range of abilities, operating within the widest possible range of situations (environments, conditions, and circumstances), as is commercially practical.3

The logic underlying universal design is that a product designed "universally" will not only meet the needs of users with disabilities, but will have benefits for other populations and in other circumstances. An example often cited is the curb cut (sloped curb at intersections). Originally designed for wheelchair access, curb cuts are now used everyday by parents with strollers, people pushing shopping carts, kids on skateboards or rollerblades, bicyclists, and others. Thus, by including the needs of a "special needs" group (wheelchair users) in the "design specification", the needs of other groups have been met as well. Many other examples can be found in the literature (e.g., The Universal Design File).

Although there may be a higher cost implied in creating a "universally designed" product, it is possible that this product will not only address the needs of a larger segment of the market than would a "mainstream" product, but may also enjoy a competitive advantage among "mainstream" users. Moreover, the incremental cost of providing one universally designed solution may well be less than the aggregate costs of retrofitting products to include a broader section of the population, or of designing an entire portfolio of niche solutions.

2.4.2.1 Equipment design: summary

To make products more accessible, they can either be adapted to meet the needs of users, or can be designed to accommodate a wide range of needs. Disciplines such as Universal Design stimulate the designer to broaden the "user specification" of a product, so that, compared to "mainstream" design, the product is usable by persons who are older (and perhaps younger), by persons with a disability, and in sub-optimal conditions (e.g., noisy environment, low light). As Universal Design becomes better known and is incorporated into the curricula of future product designers, the number of inaccessible products, and the need to retrofit products to make them accessible, may be expected to decrease.

3 Analysis by jurisdiction

The jurisdictions considered in the present report have been selected to include those countries and organisations (such as the European Union) where the topic of accessibility has been addressed specifically in law. Using this as a criterion, the following jurisdictions are included in the present report, each in its own "chapter":

These chapters follow a similar outline:

In each chapter, the section on legislation covers existing laws. In the rare cases where there is a case that bears on accessibility and telecommunications, it is presented in a follow-up section. In both of these sections, the material is objective in the sense that it is documented and verifiable; that is, the laws and the court decisions are in the public domain and, with the exception of (for example) reversal on appeal, are enduring.

The next section in each chapter is more inferential, in that it concerns groups and issues that we have labelled "next generation" material. Relevant government organisations are described briefly, as are advocacy groups; both of these sets of organisations may become involved in future legislation or litigation. In presenting these, the intent is not to be exhaustive, but rather to identify some organisations that we believe will be worth watching for future developments in the area of telecom accessibility.

Next, major policy papers (if any) are identified. These are papers that we believe may influence advocacy in the future.

The two closing sections in each chapter concern (a) relevant telecom standards and guidelines (typically from a standards agency) and (b) information on the websites of telephone service providers that addresses accessibility. We see both of these, but especially the latter, as an indication of the immediacy of telecom accessibility in each jurisdiction.

3.1 Australia

3.1.1 Overview

General comments. No review of telecommunications accessibility in Australia would be complete without reference to the wonderfully comprehensive document When the Tide Comes In: Towards Accessible Communications for People with Disabilities in Australia, written by William Jolley and issued by the Human Rights and Equal Opportunities Commission in 2003. The present summary refers repeatedly to this source, and the reader is directed to it for a detailed treatment of the subject; certainly it would be impractical to attempt to reproduce it here.

Disability legislation. Disability Discrimination Act (1992).

Telecom legislation. Telecommunications Act 1997, Telecommunications (Equipment for the Disabled) Regulations 1998, and Telecommunications (Consumer Protection and Service Standards) Act 1999. The 1998 Regulations are remarkable because they provide specific examples of equipment which will help satisfy the definition of accessibility.

As part of meeting the requirements of its Universal Service Obligation (USO), Telstra is required to implement a Disability Equipment Program (DEP).

Key cases. Scott vs. Telstra (1995) broadened the concept of service beyond equipment to include the accessing of a telephone-based service as the responsibility of a telecommunication provider.

Maguire vs. Sydney Organising Committee for the Olympic Games (2000) struck down the argument of "unjustifiable hardship" advanced by the Olympic Games Committee as a defence for not making its website accessible.

Government organisations. Australian Communications Authority (ACA) and Human Rights and Equal Opportunity Commission (HREOC).

Advocacy groups. Consumers’ Telecommunications Network (CTN), Blind Citizens Australia (BCA).

Other initiatives. Australian Communications Industry Forum (ACIF).

Major policy papers. When the Tide Comes In: Towards Accessible Communications for People with Disabilities in Australia (June 2003, HREOC) and follow-on discussion papers from HREOC. Also from HREOC: Telecommunications equipment and the Disability Discrimination Act.

Standards. Australian Communications Industry Forum (ACIF) (and its Disability Advisory Body) creates standards. AS/ACIF S040:2001 Requirements for Customer Equipment for use with the Standard Telephone Service - Features for special needs.

3.1.2 Legislation

Information about Australian legislation dealing with telecommunications and disability can be found on the website of the Australian Communications Authority (ACA), at www.aca.gov.au/consumer_info/disability_services/about_disability_services/ .

Below, two types of legislation are considered in turn:

3.1.2.1 Disability legislation: Disability Discrimination Act 1992

The key piece of Australian legislation dealing with disabilities is the Disability Discrimination Act 1992 (DDA). According to Section 24 of this Act:

(1) It is unlawful for a person who, whether for payment or not, provides goods or services, or makes facilities available, to discriminate against another person on the ground of the other person's disability or a disability of any of that other person's associates:

Section 50 (1&2) of the DDA, which deals with telecommunications, specifies that neither a carrier or supplier of an eligible service can "discriminate against another person on the ground of the other person's disability in the provision of telecommunications services through payphones and public payphones."

The DDA also encourages both governmental agencies and corporations to develop a Disability Action Plan, an approach taken to reduce the likelihood of discrimination lawsuits. Both Telstra (Australia’s Standard Telephone Service provider, (www.telstra.com.au/disability/action_plan.htm) and Optus (Australia’s second carrier, www.optus.com.au/Vign/ViewMgmt/display/0,2627,1031_29744-3_31347--View_303,00.html) have filed such action plans with the Human Rights and Equal Opportunity Commission (HREOC); progress reports are also available.

3.1.2.1.1 Definition of disability

The Disability Discrimination Act (1992) of Australia defines "disability", in relation to a person, as (Preliminary Part 1, Section 4, Disability Discrimination Act 1992 5):

(a) total or partial loss of the person’s bodily or mental functions; or
(b) total or partial loss of a part of the body; or
(c) the presence in the body of organisms causing disease or illness; or
(d) the presence in the body of organisms capable of causing disease or illness; or
(e) the malfunction, malformation or disfigurement of a part of the person’s body; or
(f) a disorder or malfunction that results in the person learning differently from a person without the disorder or malfunction; or
(g) a disorder, illness or disease that affects a person’s thought processes, perception of reality, emotions or judgment or that results in disturbed behaviour; and includes a disability that:
(h) presently exists; or
(i) previously existed but no longer exists; or
(j) may exist in the future; or
(k) is imputed to a person.

3.1.2.2 Telecommunications legislation

In Australia, the Australian Communications Authority (ACA) "is responsible for regulating telecommunications and radiocommunications, including promoting industry self-regulation and managing the radiofrequency spectrum. The ACA also has significant consumer protection responsibilities." Established in 1997, the ACA is analogous to the CRTC in Canada. Organisationally, it is part of the Department of Communications, Information Technology and the Arts (DCITA). The website is www.aca.gov.au .

Australia has three pieces of telecom legislation that also regulate accessibility. Considered in turn below, they are:

3.1.2.2.1 Telecommunications Act 1997

The Telecommunications Act 1997 is the key telecom act in Australia. It sets up definitions of carriers and service providers, specifies the oversight role of the Australian Communications Authority (ACA), discusses the need to comply with standards, and addresses other issues. (Telecommunications Act 1997 was last amended 07 January 2004, incorporating some of the provisions of the TCPSS 1999 (see below).)

Apart from the omnibus intent of the Act on regulating the telecom industry within Australia, the Act also ensures (Part 1, Section 3 (Objects)) "that standard telephone services, payphones and other carriage services of social importance are: (i) reasonably accessible to all people in Australia on an equitable basis, wherever they reside or carry on business…".

3.1.2.2.1.1 Disability standards

Part 21, Division 4 of the Telecommunications Act 1997 is entitled "Disability standards", and includes Sections 380 to 383. (This Act specifies that "disability has the same meaning as in the Disability Discrimination Act 1992" (Section 380(6)).) With respect to customer telecom equipment, Section 380 states:

(1) The ACA may, by written instrument, make a standard relating to specified customer equipment if:

(a) the customer equipment is for use in connection with the standard telephone service; and

(b) the customer equipment is for use primarily by persons who do not have a disability; and

(c) the standard relates to the features of the equipment that are designed to cater for any or all of the special needs of persons with disabilities.

(2) The following are examples of features mentioned in paragraph (1)(c):

(a) an induction loop that is designed to assist in the operation of a hearing aid;

(b) a raised dot on the button labelled "5" on a telephone.

Section 383 (Effect of compliance with disability standards) of the Act specifically states that:

(1) In determining whether a person has infringed section 24 of the Disability Discrimination Act 1992 in relation to the supply or provision of customer equipment, regard must be had to whether the customer equipment complies with a standard in force under section 380.

(2) Subsection (1) does not, by implication, limit the matters to which regard may be had.

In conjunction with Section 380, sections 381 and 382 provide guidance on the adoption of standards by ACA and procedures for the making of such standards. In particular, Section 382 specifies that, in the making of standards, "interested persons are taken not to have had an adequate opportunity to make representations unless there was a period of at least 60 days during which the representations could be made" (Section 382(5)), reinforcing the provision (Section 382(1)) that "interested persons have had an adequate opportunity to make representations about the proposed standard" and that such representations be given "due consideration".

3.1.2.2.1.2 Industry development plan requirements

Schedule 1 of the Act concerns "Standard carrier licence conditions". Part 2 of Schedule 1 specifies (4(2)) that a "carrier must at all times have a current industry development plan", without which a licence will not be granted.

In terms of the contents of the industry development plan (Item 6(2e)) states:

The plan must include any relevant particulars of the carrier’s strategic commercial relationships, including (but not limited to) … the carrier’s relationships in connection with the production and supply of equipment for use by people with disabilities.

Moreover, with respect to research and development, Item 6(3e) states:

The plan must include any relevant particulars of the carrier’s activities in relation to research and development, including (but not limited to) matters in connection with … research and development to address the needs of people with disabilities.

Finally, Item 6(4) states:

The plan must include any relevant particulars of the carrier’s export development plans, including (but not limited to) export development plans relating to equipment for use by people with disabilities.

3.1.2.2.2 Telecommunications (Equipment for the Disabled) Regulations 1998

In 1998, the Australian Attorney General’s office issued Statutory Rules 1998 No. 133, which deals with telecom equipment for persons with disabilities. This legislation is remarkable because it not only identifies a legislative intent (accessibility), but also provides specific examples (in Part 3) of equipment which will help ensure that the intended accessibility is provided.

Part 2(4) of this document considers the Universal Service Obligation, and refers to the provisions of the Telecommunications Act 1997, specifically those ensuring the accessibility of standard telephone services, payphones, and prescribed carriage services "to all people in Australia on an equitable basis, wherever they reside or carry on business."

Part 3 of these regulations deals with customer equipment. Paragraph 7 deals with equipment for customers using the National Relay Service, and paragraph 8 deals with "Other customer equipment". It is reproduced below for completeness:

8. (1)For paragraph 142 (2) (a) of the Act, the following customer equipment, that allows a person with a disability to have access to a standard telephone service, to communicate effectively with a person without a disability, and in spite of the disability, is specified:

(2) However, the kinds of equipment are specified only for circumstances where it is possible to supply an item of the equipment without imposing unjustifiable hardship on the person that would otherwise be required to supply the item.

3.1.2.2.3 Telecommunications (Consumer Protection and Service Standards) Act 1999

The Telecommunications (Consumer Protection and Service Standards) Act 1999 (TCPSS) goes beyond the Telecommunications Act 1997 in several ways. (As mentioned above, Telecommunications Act 1997 was last amended on 07 January 2004, incorporating some provisions of TCPSS.)

3.1.2.2.3.1 Standard telephone service

TCPSS provides a definition of standard telephone service (Section 6). The Act defines standard telephone service (STS) as voice telephony or the equivalent, with the wording as follows:

(1) A reference in a particular provision of this Act to a standard telephone service is a reference to a carriage service for each of the following purposes:

3.1.2.2.3.2 Universal Service Obligation

Division 2 of TCPSS deals with the Universal Service Obligation. In this Division, Section 9 of TCPSS considers accessibility of telephone service in the broader sense, including access to payphones. Specifically, Section 9 states:

(1) For the purposes of this Act, the universal service obligation is the obligation:

(a) to ensure that standard telephone services are reasonably accessible to all people in Australia on an equitable basis, wherever they reside or carry on business; and

(b) to ensure that payphones are reasonably accessible to all people in Australia on an equitable basis, wherever they reside or carry on business; and

(c) to ensure that prescribed carriage services are reasonably accessible to all people in Australia on an equitable basis, wherever they reside or carry on business.

(2) To the extent necessary to achieve the obligation mentioned in subsection (1), the universal service obligation includes:

(a) the supply of standard telephone services to people in Australia on request; and

(b) the supply, installation and maintenance of payphones in Australia; and

(c) the supply of prescribed carriage services to people in Australia on request. …

The Act goes on to define specific terms:

9A Determinations of what is necessary to ensure reasonable accessibility

9B What is a service obligation?

9C Payphones

9D Prescribed carriage services

9E Supply of standard telephone services

9F Supply of prescribed carriage services

As part of meeting the requirements of its Universal Service Obligation (USO), Telstra is required to implement a Disability Equipment Program (DEP). The Telecommunications (Equipment for the Disabled) Regs 1998 specifies some of the characteristics of this equipment (see Section 3.1.2.2.2, above).

3.1.2.2.3.3 Policy statement and Standard marketing plan

TCPSS also requires (Section 12H) that a primary universal service provider (in this case, Telstra) must submit a draft policy statement and a draft standard marketing plan to the Australian Communications Authority (ACA). The ACA must either approve or refuse to approve the draft policy statement (Section 12K(1)); grounds for refusing to approve the draft policy statement are specified (Section 12K(2) as:

(2) The ACA must not approve the draft unless it is satisfied that the draft adequately deals with the supply of appropriate equipment, goods or services to:

A similar requirement exists for approving a draft digital service plan (Section 15(1aa)).

3.1.3 Key cases

There are two cases in Australia that are relevant to disabilities and telecommunications products and services, both today and in the near future. These cases are described below.

3.1.3.1 Scott vs. Telstra

In the review of Australian literature, the only case identified as relevant to telecom equipment is that of Scott vs. Telstra in 1995.

In Scott vs. Telstra, Scott – who has a hearing impairment – charged that Telstra discriminated against him, both directly and indirectly, by not supplying him with a teletypewriter (TTY) on the same basis that it provides a standard telephone to customers who are not hearing-impaired. Telstra countered that their decision was not discriminatory because the provision of a TTY should be considered a new service that was not part of their existing services. In addition, Telstra argued that such a new service was a "non-profitable enterprise" peripheral to their standard service, which was voice-operated.

Telstra’s claim was rejected by the Commissioner presiding over the case, Sir Ron Wilson, President of the Human Rights and Equal Opportunity Commission (HREOC) (www.humanrights.gov.au/disability_rights/comdec/1995/DD000060.htm). In his response, Wilson stated that the restricted definition of a service was too narrow:

This submission is only intelligible in the context of the respondent's (Telstra’s) fundamental proposition that the only services it provides consists of products, namely a telephone network and a T200 handset. It was not in the business of supplying services described as access to a telecommunications service. Once that fundamental proposition is not accepted and it is found that the service is appropriately defined as access to a telecommunications service, it follows that the service is provided subject to a requirement that the subscribers access that service through the medium of a T200 handset, because that handset is the only means of access provided (HREOC, 1995, 15).

Scott vs. Telstra is a landmark case in that it broadened the concept of service beyond that of switches, conduits, and telephones. In effect, at least in Australia, the accessing of a telephone-based service was also the responsibility of a telecommunication provider. And, when coupled with disability legislation such as the Disability Discrimination Act (DDA), any provider-created barrier to that access which creates a handicap in a person is determined to be discriminatory. Although such legal actions have not yet occurred in Canada or the United States, current relevant acts and legislation such as the Canadian Charter of Rights or the (US) Americans with Disabilities Act (ADA) increase the likelihood that similar legal decisions could arise.

3.1.3.2 Maguire vs. Sydney Organising Committee for the Olympic Games

A second case which has gained prominence in Australia deals with accessibility to websites by persons with a visual disability. Bruce Maguire, who has a visual disability, made a human rights complaint against the Sydney Organizing Committee for the Olympic Games (SOCOG) in 1999 because the Sydney Olympic Games website was not accessible to him (www.hreoc.gov.au/disability_rights/comdec/2000/DD000120.htm).

The history of the case is remarkable in several respects, not least of which is the extent to which SOCOG went to avoid complying with a request to make the website accessible, apparently choosing instead to argue that the nature of Mr. Maguire’s complaint changed across time and that making the website accessible would be prohibitively expensive and time-consuming, thereby invoking the "unjustifiable hardship" clause of the Disability Discrimination Act (DDA).

In its decision, the Human Rights and Equal Opportunity Commission (HREOC) stated,

The firm view of the Commission in this respect is that the complaint in respect of the web site was always that it was inaccessible to a blind person and that it did not comply with the W3C Guidelines for accessibility.

Section 24 of the DDA stipulates that access to services must not discriminate on the basis of disability. In its defence, SOCOG argued that its website was not providing a service, but instead was merely means of presenting "promotional" material. The Commission’s judgment stated,

It is submitted that the site is merely a "promotional" website which publishes "promotional" material. That description is in part valid but the site is much more. It is intended to provide a source of information concerning a large body of variable content which can be distributed to and accessed by persons across the world. The provision of information by the respondent via its web site is, in the Commission's view, a service relating to the entertainment which the respondent will provide to the world in the course of the Sydney Olympic Games. It is in the Commission's view comprehended by section 24 of the DDA.

In its decision, the Commission stated,

At the time of the making of the complaint and at the time of his statement of 29 April 2000, the complainant was clearly the recipient of less favourable treatment by the respondent in that he was unable to access the services offered by the respondent by means of its web site or at best he was offered imperfect or limited access only because of the manner in which the services were made available and this less favourable treatment was because of his disability. … In the Commission's view, the respondent has discriminated against the complainant in breach of section 24 of the DDA in that the web site does not include ALT text on all images and image maps links, the Index to Sports cannot be accessed from the Schedule page and the Results Tables provided during the Games on the web site will remain inaccessible.

The "unjustifiable hardship" clause of the DDA permits discrimination under certain circumstances. However, the expert witnesses summoned by SOCOG, who were apparently briefed incompletely and at the last minute, were unable to convince the Commission of the substance of SOCOG’s arguments relating to "unjustifiable hardship". Some of the arguments documented in the decision included:

* There are 37 sports web page templates each with approximately 35 result templates - in total 1,295 templates for results alone.

* One person working 8 hour business days would require 368 days to complete the task properly.

* $2.2 million of additional infrastructure would be required to separately host the additional designs necessary to an accessible Table of Results.

Expert witnesses – including Dr. Jutta Treviranus, director of the Adaptive Technology Resource Centre (ATRC) at the University of Toronto (www.utoronto.ca/atrc/) – for the complainant carried greater credibility and demolished SOCOG’s argument for unjustifiable hardship. As examples:

* The number of templates is significantly less than 1295 and the reformatting of the templates will take considerably less than the 2 hours for each alleged by the respondent. A more realistic estimate for the minor changes required is 10 minutes each; nor is there the need for unique manually generated formats.

* No new infrastructure will be required because it is allegedly in place.

* A team of one experienced developer with a group of 5-10 assistants could provide an accessible site to Level A compliance in 4 weeks.

Moreover,

if accessibility had been considered by the respondent when the site was being developed it could have been totally achieved in less than 1 percent of the time consumed in the site's development. … In respect of the Schedule page, which in her view is completely inaccessible, it could be corrected by a very simple change which would take less than 1 ½ hours. … What the respondent suggested would take 25 business days could be effectively completed within a few hours.

The Commission concluded,

Rather, the clear inference can be drawn from the facts and circumstances that the respondent never seriously considered the issue and only when the hearing was imminent did it attempt to support its rejection of the complainant's complaint by resort to a process which was both inadequate and unconvincing. … In the view of the Commission, the respondent cannot avoid liability for its breach of section 24 of the DDA by its claim of unjustifiable hardship.

The Commission’s determination states,

1.  A declaration that the respondent has engaged in conduct that is unlawful under section 24 of the DDA in that it has provided for the use of the complainant a web site which because of his blindness is to a significant extent inaccessible.

2.  A declaration that the respondent do all that is necessary to render its web site accessible to the complainant by 15 September 2000 by:

(i)       including ALT text on all images and image map links on its web site;
(ii)       providing access to the Index of Sports from the Schedule page; and
(iii)       providing access to the Results Tables to be used on the web site during the Sydney Olympic Games.

Finally, in the decision dated 24 August 2000, the Commission encouraged Mr. Maguire to pursue this matter should SOCOG’s website not be accessible at the time of the Sydney Games, which were due to open on 15 September 2000, three weeks later.

The impact of Maguire vs. SOCOG is likely to be widespread, for it establishes a precedent that a website may reasonably be considered a service, and therefore be subject to non-discrimination laws. Moreover, the case itself clearly demonstrated that, at least in this particular jurisdiction, defences based on an argument of "unjustifiable hardship" will not be taken at face value, but will be analysed in detail.

3.1.4 "Next generation" issues

We have provided an overview of Australia’s telecom and disability legislation, as well as key cases. In a subsequent section (Section 3.1.5), we consider standards that apply to accessibility and telecom. All of these consider "established" initiatives.

The purpose of the present section is to look at the activities of other groups, where activities are taking place that may eventually result in legislation, but which are not at that stage yet. In other words, the present section is an attempt to "peer over the horizon" to see what might be coming in the near future. Given this context, the material in Section 3.1.4 should be seen as suggestive rather than definitive.

Topics covered include:

3.1.4.1 Government organisations
3.1.4.1.1 Australian Communications Authority (ACA)

The Australian Communications Authority is a government agency charged with regulating telecommunications and radio communications. It also is charged with consumer protection, handled by its Consumer & Universal Service Obligation Group. Organisationally, the ACA is in the Department of Communications, Information Technology and the Arts (DCITA).

As part of its activities, the ACA has a Futures Panel, which is "an internal strategic foresight body established to monitor, analyse and report on trends in communications technology and services that may fall within or affect the ACA’s responsibilities" (www.aca.gov.au/aca_home/about_aca/futures_panel/overview.htm).

The ACA website is a good source for information about Australian activities related to telecom and accessibility. See, for example, www.aca.gov.au/consumer_info/disability_services/about_disability_services/index.htm .

The Australian Communications Exchange (ACE) is the provider of the National Relay Service, designed for persons with hearing or speech impairments. As part of its mandate to obtain customer feedback, the ACA conducts regular customer satisfaction surveys. It also formed a National Relay Service Consultative Committee (NRSCC) to obtain feedback on this service.

3.1.4.1.2 Human Rights and Equal Opportunity Commission (HREOC)

The Australian Human Rights and Equal Opportunity Commission is a government body whose mandate is to ensure the protection of rights, including the rights of persons with disabilities in the area of telecommunications.

The Human Rights and Equal Opportunity Commission (HREOC, website located at www.hreoc.gov.au) is "an independent statutory organisation and report(s) to the federal Parliament through the Attorney-General." HREOC looks at telecom issues from the human rights standpoint. Citizens can file complaints with the HREOC. As well, HREOC can initiate research into various topic areas.

The HREOC commissioned the paper When the Tide Comes In: Towards Accessible Communications for People with Disabilities in Australia, issued in June 2003 (see also Section 3.1.4.4, below). The foreword to When the Tide Comes In identifies "three major issues facing people with disabilities in telecommunications"; two of these three concern visual impairment and so are relevant to the present project:

3.1.4.2 Advocacy groups

Other advocacy groups include the Consumers’ Telecommunications Network, which is funded under Section 593 of Telecommunications Act 1997 (Funding of consumer representation, and of research, in relation to telecommunications). TEDICORE (Telecommunications and Disability Consumer Representation) is a project also funded in this manner.

3.1.4.2.1 Consumers’ Telecommunications Network (CTN)

The (Australian) Consumers’ Telecommunications Network (CTN) is a consumer- and community-based advocacy organisation (www.ctn.org.au/content/index.cfm). The website states,

CTN is a member of the Australian Communications Authority (ACA) Consumer Consultative Forum and ACIF Consumer Advisory Council. In addition CTN holds positions on the Standards Australia Council and the Telecommunications Industry Ombudsman Council.

3.1.4.2.2 Blind Citizens Australia (BCA)

The home page of Blind Citizens Australia (www.bca.org.au) describes the organisation as, "The united voice of blind and vision-impaired Australians. Our mission is to achieve equity and equality by our empowerment, by promoting positive community attitudes, and by striving for high quality and accessible services which meet our needs." BCA hosts a weekly radio programme ("Horizons"), provides employment counselling, issues publications, and otherwise maintains a high profile. A list of projects may be viewed at www.bca.org.au/projects.htm. BCA is one of the groups involved with TEDICORE (Telecommunications and Disability Consumer Representation).

Blind Citizens Australia (BCA), through TEDICORE, has produced a position paper on the Disability Equipment Program (DEP), described more fully below ("Major policy papers", Section 3.1.4.4) (www.bca.org.au/tedicore/DEP2002.htm).

3.1.4.2.3 Telecommunications and Disability Consumer Representation (TEDICORE)

TEDICORE is not a group, but rather is a project which is funded under Section 593 of Telecommunications Act 1997, and involves both Blind Citizens Australia (see above) and the Australian Association of the Deaf. The TEDICORE Submission to the Government Review of the Operation of the Universal Service Obligation and Customer Service Guarantee was issued in February 2004, and can be downloaded from www.dcita.gov.au/Article/0,,0_1-2_3-4_117807,00.html.

The DCITA website (www.dcita.gov.au/Article/0,,0_1-2_1-4_111495,00.html) contains testimony from Gunela Astbrink (TEDICORE) describing a new initiative related to accessible products:

The Australian Telecommunications Industry Association's Disability-Industry Partnership was formed as a result of TEDICORE's representations. This Partnership is now working on the development of an online database and web site for companies to list products which comply with the AS/ACIF Disability Standard S040:1999 as well as meeting other accessibility guidelines.

3.1.4.3 Other initiatives
3.1.4.3.1 Australian Communications Industry Forum

The Australian Communications Industry Forum (ACIF) is an industry association concerned with communications in Australia (www.acif.org.au/home). ACIF members include consumer groups and user groups in addition to carriers and carriage service providers. The ACIF may also develop standards, perhaps at the request of the ACA.

The ACIF maintains a Disability Advisory Body (DAB), which "provides advice to ACIF regarding the implications for disabled consumers of ACIF's proposed Codes and Standards" (www.acif.org.au/current_activities/consumer_liaison/dab).

In 2001, ACIF issued a report entitled ACIF G586: 2001 Access to Telecommunications for People with Disabilities—Industry Guideline, a guideline designed to inform various telecom groups about the needs of persons with disabilities (see Section 3.1.5.2 below).

3.1.4.4 Major policy papers

The Human Rights and Equal Opportunity Commission (HREOC) commissioned a study which produced a comprehensive document entitled When the Tide Comes In: Towards Accessible Communications for People with Disabilities in Australia, issued in June 2003. In November 2003, the HREOC hosted a Telecommunications Forum that followed up the major discussion paper When the Tide Comes in, commissioned by HREOC. The record of the key points of discussion of this forum can be found at www.hreoc.gov.au/disability_rights/communications/forum/record.htm.

Also, at the request of ACIF, HREOC produced a paper (August 2001) entitled Telecommunications equipment and the Disability Discrimination Act. This paper (www.humanrights.gov.au/disability_rights/communications/equipment.htm), which includes summaries of both Australian and US legislation, attempts to clarify some of the issues surrounding disability and access to telecom equipment.

Telecommunications and Disability Consumer Representation (TEDICORE) has produced a position paper on The Development of a New Telecommunications Disability Program (www.bca.org.au/tedicore/DEP2002htm); this paper is a response to the Disability Equipment Program of Telstra, mandated under Telstra’s Universal Service Obligations (USO). This position paper lists the following "key principles":

Because of the above issues set out above, TEDICORE believes that a new Program is required. Below is a set of key principles which forms the essence of a new Program.

(Parenthetically, it is worth commenting that the webpage containing this position paper is also a good reference site for legislation bearing on this issue.)

3.1.5 Standards, etc.

The Australian Communications Industry Forum (ACIF) is a telecom industry association based in Australia. The ACIF develops and issues Codes, Guidelines, Standards, and Specifications, and has a Disability Advisory Body which provides advice to ACIF on disability-related issues (www.acif.org.au/current_activities/consumer_liaison/dab).

The Working Committee of the Customer Equipment and Cabling Reference Panel (CECRP 19) of ACIF deals with accessibility information. Its terms of reference are described as follows (www.acif.org.au/panels_and_committees/cecrp_wc19):

This Committee is to develop:

a) An Industry Code to specify obligations on customer equipment importers and manufacturers to provide product information on the functional characteristics of their customer equipment used with a Standard Telephone Service (STS) as defined in the Telecommunications (Consumer Protection and Service Standards) Act 1999 (which covers services that deliver voice telephony whether delivered by fixed or mobile services) that would be beneficial to people with a disability.
This information is to be provided to carriage service providers (CSPs) that provide an STS. Consideration should also be given to the provision of information to other parts of the market in addition to CSPs.

b) An Industry Guideline to provide guidance for customer equipment importers and manufacturers on features of customer equipment used for the STS to assist consumers with disabilities.

In developing both the Code and Guideline, the Working Committee is to:

3.1.5.1 Standards

On 19 March 2002 the ACIF issued the standard AS/ACIF S040:2001 Requirements for Customer Equipment for use with the Standard Telephone Service - Features for special needs (www.acif.org.au/publications/standards). This standard (p.5) "applies to certain Customer Equipment (CE) that uses a telephone handset or keypad, that is manufactured in, or imported into Australia for use with the Standard Telephone Service."

The standard refers to a "customer switching system" (CSS) – which may be a PBX or key system, but is not limited to these examples – and which is defined as "a switching system for use on the customer side of the boundary of a Telecommunications Network that can switch voice, digital data, images, video or any other information. The standard "includes fax machines with a handset and system integral equipment". System integral equipment is later (p. 10) defined as "(a)nalogue or digital equipment which is intended to operate in association with a CSS and functions as part of the CSS."

The requirements specified in this Australian Standard S040:2001 include only two areas: Hearing aid coupling (5.1) and Tactile indicators on keypads (5.2). Of these two, only the latter applies to visual disabilities. The text of 5.2 reads:

5.2.1 The requirements of Clause 5.2 shall only apply to CE with a keypad, that has keys that can be differentiated by touch, where the keypad has the primary function of dialling for the purposes of call set-up for the Standard Telephone Service.

5.2.3 From 1 July 2003, all CE except cellular mobile telephones and cordless telephones shall have a raised pip as a tactile indication on the key associated with digit ‘5’ on keypads.

5.2.4 From 1 July 2003, all cellular mobile telephones and cordless telephones shall have a raised pip as a tactile indication on or in the vicinity of the key associated with digit ‘5’ on the keypad.

5.2.5 The pip specified in Clause 5.2.3 and Clause 5.2.4 shall be at least 0.4 mm above the face of the key.

Note: This does not prevent other additional indicators to be located in the vicinity of the key associated with the digit ‘5’.

3.1.5.2 Guidelines

The industry guideline ACIF 586 Access to telecommunications for people with disabilities (www.acif.org.au/publications/guidelines) was issued by ACIF in September 2001. The introduction, written by the Chair of ACIF’s Disability Advisory Body, states that "The Guideline should be applied in the development of all ACIF Codes and Standards."

The text of the Guideline begins by noting that

The Disability Advisory Body (DAB) endorses the Telecommunications Charter (COST219bis, 1999) set out below as a statement of principles which will improve the access and equity in telecommunications for people with disabilities and as a basis for the more specific provisions of this Guideline.

Item 1.1.2 of the Guideline states (quoting from the Telecommunications Charter):

The needs of older people and people with disabilities should be taken into account in the design of any new telecommunications equipment or service. Terminal equipment should be designed for the widest possible market. Network services should adequately support relevant special terminal functions so that all users experience equivalent end-to-end service.

3.1.6 Corporate information

In an attempt to identify the accessibility-related information available on the websites of major telecom service providers, we examined the websites of Telstra and Optus.

3.1.6.1 Telstra

The homepage of Telstra (telstra.com/index.jsp) has no link to disability. It is necessary to select, under "Home & family", the "Home users" link. This takes the reader to a page (www.telstra.com.au/services/homefamily.htm) where there are links to "Access for everyone" and "Telstra disability services".

On the home page, entering "disability" (07 June 2004) into the Search field returns many links, almost all of which are relevant to disability products and services. Searching for "accessibility" also returns several 20 links, some of which concern access in the general sense (that is, not related to disabilities), but others of which deal with Telstra’s Centre for Accessibility.

3.1.6.2 Optus

The homepage of Optus (www.optus.com.au) has no link to disability or accessibility, and no search function.

3.2 Japan

3.2.1 Overview

General comments. Much of the information about Japan was available only in Japanese.

Disability legislation. Several laws are relevant, including the Constitution. The Disabled Persons’ Fundamental Law (1993) defines disability, including the phrase "substantially limited over the long term". Other laws: Law for the Welfare of Physically Disabled Persons (1949, Law No. 283).

Telecom legislation. Telecommunication Service Law (1984). Law for Promoting Businesses that Facilitate the Use of Communications and Broadcast Services by the Physically Disabled Persons (1993).

Key cases. No cases found.

Government organisations. Ministry of Public Management, Home Affairs, Posts and Telecommunications. National Institute on Information and Communications Technology (NICT).

Advocacy groups. Japanese Society for Rehabilitation of Persons with Disabilities.

Major policy papers. None found.

Standards. Japanese Standards Association (JSA). Also, Japan belongs to the major international telecommunications standards organisations.

3.2.2 Legislation

3.2.2.1 Definition of disability

Article 2 of Japan’s Disabled Persons’ Fundamental Law, which came into effect on 03 December 1993, defines "disabled persons" as "persons whose daily life or life in society is substantially limited over the long term due to a physical disability, mental retardation or mental disability (hereinafter referred to as ‘disability/ies’)." The use of the phrase "over the long term" differentiates this legislation from others, such as the (US) Americans with Disabilities Act (ADA), which do not use duration as a criterion for defining disability.

Below, information available in English about Japanese legislation is summarised. Much of this information has been drawn from The 30 Selected Japanese Laws Related to Persons with Disabilities (www.dinf.ne.jp/doc/japanese/law/etc/z00003.htm), published by the Japanese Society for Rehabilitation of Disabled Persons.

3.2.2.2 Constitution

Article 11 of the Japanese Constitution states, in part, "The people shall not be prevented from enjoying any of the fundamental human rights". Article 13 makes it clear that all individuals are entitled to these fundamental rights:

All of the people shall be respected as individuals. Their right to life, liberty, and the pursuit of happiness shall, to the extent that it does not interfere with the public welfare, be the supreme consideration in legislation and in other governmental affairs.

Article 25 concerns daily living, and may perhaps be construed to address a person’s potential need to access telecommunications services and products:

All people shall have the right to maintain the minimum standards of wholesome and culture living. In all spheres of life, the State shall use its endeavor for the promotion and extension of social welfare and security, and of public health.

Likewise, Article 27 applies to the work environment, and might be taken to include telecommunications services and products as part of this environment:

All people shall have the right and the obligation to work. Standards for wages, hours, rest and other working conditions shall be fixed by law.

3.2.2.3 Disabled Persons’ Fundamental Law

Japan has the Disabled Persons’ Fundamental Law (Law No. 84 of 21 May 1970). This law was amended in 1983 (Law No. 80), 1986 (Law No. 93), and 1993 (Law No. 94), and came into effect on 03 December 1993.

Chapter II of this law is entitled "Fundamental Measures for the Welfare of Disabled Persons". In this chapter, Article 10-2, paragraph 3 states,

The State and local public entities shall take the necessary measures to provide prosthetic appliances and other devices needed by disabled persons to compensate for their disabilities.

It is not clear from this brief text whether assistive technologies for vision are implied here.

Chapter II also includes Article 22-3, concerning the use of information. It reads,

The State and local public entities shall, in order to enable disabled persons to use information easily and express their will, take the necessary measures to facilitate the use of telecommunications and broadcast services by disabled persons and to improve facilities providing information to them.

It goes on to say (paragraph 2),

Providers of telecommunications and broadcast services shall, on the basis of the principle of social solidarity, endeavour to facilitate their use by disabled persons when providing the said services.

3.2.2.4 Law for the Welfare of Physically Disabled Persons

The Law for the Welfare of Physically Disabled Persons (1949, Law No. 283) is designed "to promote independence and participation in society of physically disabled persons." Part of this mandate includes (emphasis added) the "provision of technical aids for living such as bathtubs, toilet facility, beds and communication aids (e.g., talking machines and word processors)." It is not clear to what extent this stipulation implies accessible communications devices that are typically seen as mainstream products.

3.2.2.5 Law for Promoting Businesses that Facilitate the Use of Communications and Broadcast Services by the Physically Disabled Persons

The Law for Promoting Businesses that Facilitate the Use of Communications and Broadcast Services by the Physically Disabled Persons (1993, Law No. 54) "promotes services to make media like telecommunications and broadcast accessible to people with disabilities."

3.2.2.6 Telecommunication Service Law

Under the Telecommunication Service Law (1984, Law No. 86), directory service is provided to disabled persons free. Also, provisions are made for reducing the charges for the use of public telephones by persons with a speech disorder.

3.2.3 Key cases

We found no information on key legal cases regarding telecom and disabilities in Japan. It is interesting, however, that in commentary on the complaint brought to the (US) FCC by Dr. Bonnie O’Day against Verizon and Audiovox regarding the lack of accessible cell phones, the statement was attributed to Charlie Crawford of the American Council of the Blind (HearingLoss.org, www.shhh.org/html/fcc_push.html) that:

It is ludicrous for Audiovox and Verizon even to imply that it is not readily achievable for them to make their menus accessible to use with voice output. We know that blind people living in Japan are already enjoying text-to-speech capability on their cell phones.

3.2.4 "Next generation" issues

3.2.4.1 Government organisations

In Japan, telecommunications was handled by the Ministry of Posts and Telecommunications until January 2001, when it became Ministry of Public Management, Home Affairs, Posts and Telecommunications.

On 01 April 2004, the Communications Research Laboratory (CRL) and the Telecommunications Advancement Organization (TAO) were reorganised into the National Institute on Information and Communications Technology (NICT; www.nict.go.jp/overview/index.html). Historically, CRL "carried out both basic and applied research in the field of information and communications", and TAO "conducted practical research and development cooperatively with industry and academia for the practical application of information and communications technologies, provided various forms of assistance to researchers in the private and academic sectors, and gave various subsidies to enterprises in the communications and broadcasting field".

Several departments of NICT seem to be involved in areas that touch on accessibility:

Unfortunately, we were unable to locate more information in English or French.

3.2.4.2 Advocacy groups
3.2.4.2.1 Japanese Society for the Rehabilitation of Persons with Disabilities

The Japanese Society for the Rehabilitation of Persons with Disabilities (JSRDP) represented Japan at the World Summit on the Information Society (WSIS, Geneva, December 2003). Founded in 1964, the society’s goal is "to promote the activities of persons with disabilities in every way possible both within and outside Japan" (www.jsrpd.jp/english/out.html). News about WSIS can be found at www.dinf.ne.jp/doc/english/other/wz_wsis_e.htm.

3.2.4.2.2 Japan National Assembly of Disabled Peoples’ International

Disabled Peoples’ International (DPI) is, as its name suggests, an international organisation for disabled persons. The report of the Japanese branch in 1999 (www.disabilityworld.org/Aug-Sept2000/IL/dpijapan.htm) touches on several accessibility issues, such as transportation and housing, but there is no mention of telecom issues.

3.2.4.3 Major policy papers

We found no major policy papers concerning telecom terminals and accessibility for persons with a visual disability.

An article appeared in the 29 September 2003 issue of ng Japan (Next Generation Japan: Mobile in Japan and Asia, volume 2 issue 9) entitled "Mobile phone services for the disabled in Japan" (www.icr.co.jp/nG/backissues.html).

3.2.5 Standards

Information about Japanese technical standards can be found on the website of JSA, the Japanese Standards Association (www.webstore.jsa.or.jp/webstore/Top/indexEn.jsp).

The Ministry of Public Management, Home Affairs, Posts and Telecommunications (MPHPT) has authorised two organisations to approve telecom and radio equipment. These organisations are JATE (Japan Approvals Institute for Telecommunications Equipment) and TELEC (Telecommunications Engineering Center, formerly MKK). JATE approves wired (Wireline) equipment, and TELEC approves radio equipment.

3.2.6 Corporate information

We found no corporate information on Japanese telcos that was related to accessibility. However, it is worth mentioning that many of the world’s telephones are designed and manufactured by Japanese companies (e.g., Panasonic, Sony). Panasonic in particular has shown a strong commitment to accessibility (See Appendix A).

3.3 United Kingdom (UK)

3.3.1 Overview

General comments. The UK has legislation that appears to be strong, as well as a progressive and well deregulated telecom sector and a well established advocacy sector.

Disability legislation. Disability Discrimination Act (1995). Disability Rights Commission Act (1999).

Telecom legislation. Communications Act 2003. Electronic Communications (Universal Service) Order 2003.

Key cases. No key cases were found related to blindness. However, the Disability Rights Commission lists one case in which a deaf customer complained of paying for mobile services (short message service) which, in her view, should have been included in the "free minutes" available to a hearing customer.

Government organisations. Directgov for on-line information. Disability Rights Commission. OFCOM (Office of Communication) is the telecom regulator in the UK.

Advocacy groups. HumanITy. The Royal National Institute of the Blind (RNIB). Telephones for the Blind Fund.

Major policy papers. No major policy papers were found.

Standards. British Approvals Board of Telecommunications (BABT). Also, Britain uses many European Telecommunications Standards Institute (ETSI) standards.

3.3.2 Legislation

3.3.2.1 Disability legislation: Definition of disability

Within the Disability Discrimination Act (1995) Chapter 50, "disability" is broadly defined in Section I, Part I (http://www.hmso.gov.uk/acts/acts1995/1995050.htm) as,

a person has a disability for the purposes of this Act if he has a physical or mental impairment which has a substantial and long-term adverse effect on his ability to carry out normal day-to-day activities.

The DDA specifically outlines, amongst many others, what constitutes discrimination against persons with disabilities with respect to services and service provision such as communication, information access and use of trades and professions. A service provider is defined in the Act as a person or persons "concerned with the provision, in the United Kingdom, of services to the public or to a section of the public; and … it is irrelevant whether a service is provided on payment or without payment."

The Disability Rights Commission Act (1999) established the Disability Rights Commission. Section 2 of the Act says,

2. - (1) The Commission shall have the following duties-

3.3.2.2 Telecommunications legislation

Two legislative acts are pertinent to the review of telecommunications and accessibility thereof for people with disabilities: the Disability Discrimination Act (Section 50) and the Communications Regulation Act (2003).

3.3.2.2.1 Disability Discrimination Act 1995 (Chapter 50)

In the DDA, telecommunication is dealt with under Section III (19) where the legal responsibility of a service provider is specified (www.hmso.gov.uk/acts/acts1995/95050--c.htm#19):

(1) It is unlawful for a provider of services to discriminate against a disabled person-

Section 19 (2) of the DDA also specifies that:

(2) For the purposes of this section and sections 20 and 21-

The scope of what is to be considered a service includes telecommunication, and is defined in Section 19 (3b and 3c) as:

(b) access to and use of means of communication;
(c) access to and use of information services;

3.3.2.2.2 Communications Act 2003

The Communications Act 2003 outlines in detail the functions, general powers and responsibilities of the Office of Communication (OFCOM). In general, the Act covers all aspects of electronic communication, including radio, television, Web and telecommunications, from regulation and competition to service provision and stakeholder consultation (www.legislation.hmso.gov.uk/acts/acts2003/30021--b.htm).

With respect to disability, Section 3 of "General duties of OFCOM" specifically states that it must perform its duties in regard of all cases to:

(4:i ) the needs of persons with disabilities, of the elderly and of those on low incomes.

Two provisions of the Act are of special interest:

the Act specifically identifies the requirement that OFCOM conduct consumer research (Section 14) and both publish it and take it into account (Section 15) in its operations; and

the Act requires that OFCOM "establish and maintain a committee to provide the advice" related to elderly and disabled persons (Section 21(1)). The Act specifically identifies the need to consult with advocacy groups for people with disabilities (www.legislation.hmso.gov.uk/acts/acts2003/20030021.htm).

The other relevant section of the Act, Section 10 "Duty to encourage availability of easily usable apparatus", states that:

(10) It shall be the duty of OFCOM to take such steps, and to enter into such arrangements, as appear to them calculated to encourage other to secure -

3.3.2.2.3 Electronic Communications (Universal Service) Order 2003

The Electronic Communications (Universal Service) Order 2003 (Statutory Instrument 2003 No. 1904) defines "publicly available telephone service", and specifically mentions disabilities, as follows:

"publicly available telephone service" means a service available to the public for originating and receiving national and international calls and access to emergency services through a telephone number or numbers in a national or international telephone numbering plan, and may, where relevant, also include one or more of the following - 

(a) the provision of operator assistance,
(b) directory enquiry facilities,
(c) directories,
(d) the provision of public pay telephones,
(e) the provision of service under special terms,
(f) the provision of specific facilities for end-users with a disability or with special social needs, and
(g) the provision of non-geographic services

Article 3, Section 6 of the Electronic Communications (Universal Service) Order 2003 addresses disabilities specifically:

Special measures for end-users with a disability

6. - (1) Special measures shall be taken to ensure access to and affordability of publicly available telephone services for end-users with a disability equivalent to those enjoyed by other end-users.

    (2) The measures to be taken for the purposes of sub-paragraph (1) shall include:

(a) provision of access to the directory information facilities provided for the purposes of paragraph 3 in a form appropriate to meet the needs of end-users with a disability who are unable to use a telephone directory in a form in which it is generally available to other end-users;

(b) provision of priority fault repair services to end-users with a disability as is necessary to ensure access to publicly available telephone services by such end-users;

(c) provision of, and the provision of access to, relay services for end-users with a disability where required to ensure access to publicly available telephone services by such end-users;

(d) methods of billing and methods of accepting payment for publicly available telephone services in an appropriate format for subscribers with a disability, including provision for such subscribers to nominate a third party to handle their billing issues; and

(e) accessibility and functionality of the public pay telephones to be provided for the purposes of paragraph 4 for use by end-users with a disability, including the adequate provision of textphone facilities.

3.3.3 Key cases

The only case identified on the website of the Disability Rights Commission (see below) is called "Mobile phone company treat deaf customer less favourably with regard to the provision of charges for text messaging in a mobile phone contract - DRC/01/030." The summary of the case is as follows:

Summary: The client, who is deaf, signed a contract with the Defendants for the provision of a mobile telephone service. At the time of the sale, the client understood that the service would include 200 minutes per month of 'free time', during which she would not be charged for using the service. The client understood that text messaging would form part of this free time. This has proved not to be the case, and the client believes she is being treated less favourably for a reason related to her disability.

Interest: The case highlights adjustments that can be made to improve accessibility of mobile phone services for deaf people, which could, in turn, provide benefit to a whole category of disabled people.

Outcome: Settled for financial compensation for damages and the issue to be discussed with the Commission.

3.3.4 "Next generation" issues

3.3.4.1 Government organisations
3.3.4.1.1 Directgov

Directgov (www.direct.gov.uk/Homepage/fs/en) is a website billed as "The place to turn to for the latest and widest range of public service information".

The website provides information from Directgov itself, and also provides links to the websites of 21 associations for persons with a visual disability, including:

3.3.4.1.2 Disability Rights Commission

According to the entry in the Directgov website (www.direct.gov.uk/Homepage/fs/en), the "The Disability Rights Commission (DRC; www.drc-gb.org/whatwedo/index.asp) is the statutory body set up by the government to help secure civil rights for disabled people."

The DRC’s website lists its functions as:

Although the Disability Rights Commission website lists "Successful legal cases", we could find no cases listed that related to the design of telephones or to accessibility and telephones.

3.3.4.1.3 OFCOM

In the UK, Ofcom (Office of Communication) has replaced Oftel (Office of Telecommunications) as the regulatory body for telecom. Ofcom has responsibility "for the UK communications industries, with responsibilities across television, radio, telecommunications and wireless communications services" (www.ofcom.org.uk).

Ofcom has an Advisory Committee on Older and Disabled People, which has the following mandate:

3.3.4.2 Advocacy groups
3.3.4.2.1 British Wireless for the Blind Fund (BWBF)

The British Wireless for the Blind Fund (www.blind.org.uk/) is a registered charity whose mission is "keeping blind people in touch with the world". Here, the term "wireless" refers to the older British term for radio; this charity distributes radios to blind people to help them keep in touch with the world.

3.3.4.2.2 HumanITy

According to its website (www.humanity.org.uk), HumanITy "was established in 1997 to draw attention to the problem of social exclusion caused by the increased use of information technology". HumanITy has established the HUBS (Help Us Be Successful) brand, and is an advisor to:

HumanITy’s mission statement is (www.humanity.org.uk/about/mission.shtml):

humanITy is based on the simple idea that commercial companies can best expand their markets by engineering steady market growth through helping an increasing number of people to recognise and enjoy the potential of the IT revolution.

3.3.4.2.3 RNIB

The Royal National Institute of the Blind (RNIB; www.rnib.org) is the largest charitable organisation in the UK, which has – according to the RNIB website – two million persons with a visual disability. Aside from meeting the needs of its members on an ad hoc basis, the RNIB is also proactive in terms of attempting to ensure that future products are accessible.

To this end, RNIB has an internal consultancy called Sensory Design Services (www.sds-uk.org), which provides services to product developers, including:

One intent of the Sensory Design Services group is to help ensure, by verifying design during development, that the product is accessible to persons who are visually impaired.

The RNIB has issued Access-Ability: Making technology more useable by people with disabilities, a "booklet on accessibility of information and communication technologies which (Dr. John Gill, Chief Scientist, RNIB) wrote for senior managers in local government in the UK"4. Chapter 12 of this booklet deals with telecommunications, and is considered more fully in Section 5 of the present report (Accessible telephones).

3.3.4.2.4 Telephones for the Blind Fund

Telephones for the Blind Fund "(p)rovides full telephone installation costs and a large proportion of the line rental charge for people who are registered blind who live alone or cannot meet these costs."

3.3.5 Standards

The British Approvals Board of Telecommunications (BABT; www.babt.co.uk/) certifies telecom products and services in the UK. Products must be BABT-approved for connection to a public network in the UK, but some of the types of approval are now under the control of European bodies

ICSTIS (www.icstis.org.uk) is the Independent Committee on the Standards of Telephone Information Services, an "industry-funded regulatory body for all premium rate charged telecommunications services". Premium-rate services are defined by ICSTIS as offering "information and entertainment via phone, fax, PC (e-mail, Internet, bulletin board), mobile (SMS/WAP) or interactive digital TV. Services range from sports, voting and sex lines to competition, directory enquiry, chat and business information services, and currently vary in cost from 10 pence per call to £1.50 per minute."

3.3.6 Corporate information

3.3.6.1 British Telecom (BT)

The homepage of BT’s website (www.bt.co.uk) contains a link to "Disability Services" (www.btplc.com/age_disability).

Searching for "disability" returns three hits, all related to disabilities:

Searching for "accessibility" returns the second and third items in the list above.

3.4 European Union(EU)

3.4.1 Overview

General comments. Until the formation of the European Union, Europe was a patchwork of countries, each with their own currency, legislation, and goals. The emergence of a more cooperative economic union has had implications for legislation, as well. Now, although member countries retain their own legal structure, there is a supra-national layer of legislation overlaying the national boundaries. The present section ignores national differences and takes a more pan-European view.

Disability legislation. Definitions of Disability in Europe: a Comparative Analysis (2002). Article 13 of the EC Treaty. Also, Towards a barrier free Europe for people with disabilities (COM(2000) 284).

Telecom legislation. Directive 2002/22/EC is the Universal Service directive. Directive 1999/5/EC of the European Parliament and of the Council of 9 March 1999 on radio equipment and telecommunications terminal equipment and the mutual recognition of their conformity deals, among other things, with terminal equipment.

Key cases. We could find no key cases in the EU.

Advocacy groups. Tiresias (www.tiresias.org) is the authoritative research effort and information clearinghouse for issues related to telecommunications and accessibility.

Major policy papers. Tiresias publications, as well as publications of its member groups.

Standards. Several international standards bodies are headquartered in Europe, including the International Telecommunications Union (ITU) and the International Standardization Organization (ISO). However, the true European standards organisations are the Comité Européen de Normalisation / European Committee for Standardisation. and the European Telecommunications Standards Institute (ETSI).

3.4.2 Legislation

3.4.2.1 Definition of disability

Within the European Union, there is no commonly used standard definition of what constitutes a disability. As pointed out in the 2002 European Commission report on Definitions of Disability in Europe: a Comparative Analysis, legislative acts on disability are typically found in member states’ social policies and anti-discrimination laws; and, therefore, reflect the civic and legal atmosphere of the member state (for details, see www.europa.eu.int/comm/employment_social/index/complete_report_en.pdf ).

The definitions themselves vary from impairment-based to socially-based models of participation and tend to be quite broad; for example, a disability may be a long-term chronic condition or include minor, temporary limitation as well. There has been, however, a move within the EC to discard medically-based definitions of disability in favour of a more socially-based model5. The proposed social model emphasizes "the full participation in society of people with disabilities by breaking down the barriers that prevent the realisation of equal opportunity, full participation, and respect for difference." (COM(2003) 16 final, p.7). This proposed shift in how legislation defines both disability and discriminatory acts against people with disabilities reflects the increasing influence of the International Classification of Functioning, Disability and Health (ICF) of the World Health Organisation (WHO).

With respect to telecommunication accessibility, there does not appear to be any specific Act that has been developed or enacted to outline or guide the private and public sector. Instead, the combined issue of telephone accessibility and the question of disability tends to fall under general clauses that ensure the rights of persons with disabilities to equal access of services, and more recently, access to information (see below).

Disability is dealt with in general, as are other forms of potential discrimination, in modified Article 6a of the Amsterdam Treaty (1997). The Article states that:

Without prejudice to the other provisions of this Treaty and within the limits of the powers conferred by it upon the Community, the Council, acting unanimously on a proposal from the Commission and after consulting the European Parliament, may take appropriate action to combat discrimination based on sex, racial or ethnic origin, religion or belief, disability, age or sexual orientation.

The Act, in and of itself, is not legally binding on member states. Although it recognizes disability as a human rights concern, it only gives the EC community permission to take action if and when it wishes against acts of discrimination. In effect, the Treat of Amsterdam does not supersede an individual member’s own legislative acts on disability.

Equal rights for people with disabilities have also been enshrined in Article 13 of the EC Treaty (http://europa.eu.int/comm/employment_social/equ_opp/treaty_en.html); this is the Treaty Establishing the European Communities, under the Employment and Social Affairs division of the European Commission. The text reads:

Without prejudice of the other provisions of this Treaty and within the limits of the powers conferred by it upon the Community, the Council, acting unanimously on a proposal from the Commission and after consulting the European Parliament, may take appropriate action to combat discrimination based on sex, racial or ethnic origin, religion or belief, disability, age of sexual orientation.

According to the website of the Non-discrimination European Commission (http://europa.eu.int/comm/justice_home/fsj/rights/discrimination/fsj_rights_discrim_en.htm):

The most recent reinforcement of fundamental rights and non-discrimination in the EU came with the proclamation of the Charter of Fundamental Rights of the European Union at the Nice European Council on 7 December 2000. Article 21 of the charter prohibits discrimination on any ground such as sex, race, colour, ethnic or social origin, genetic features, language, religion or belief, political or any other opinion, membership of a national minority, property, birth, disability, age or sexual orientation and also discrimination on the grounds of nationality.

Finally, Towards a barrier free Europe for people with disabilities (COM(2000) 284), a communication to the European Parliament (among other bodies) from the Commission of European Communities, addressed the definition of disability as follows (http://europa.eu.int/comm/employment_social/news/2001/jul/2000284_en.html):

Environmental barriers are a greater impediment to participation in society than functional limitations and barrier removal through legislation, universal design, provision of accommodations and other means, has been identified as the key to equalisation of opportunities for people with disabilities.

3.4.2.2 Telecommunications legislation
3.4.2.2.1 Directive 2002/22/EC

Directive 2002/22/EC is the Universal Service directive from the European Parliament and the Council of the European Union, passed on 07 March 2002 (europa.eu.int/information_society/topics/telecoms/regulatory/new_rf/documents/l_10820020424en00510077.pdf).

As a Universal Service directive, this document concerns the definition of Universal Service, its accessibility to all members of society, and the transparency of processes related to Universal Service delivery. However, for the most part the Directive simply defers to the member state, using phrases such as "in the light of national conditions".

In Chapter 1, Article 1 of the Directive, clause 2 reads, in part:

With regard to ensuring provision of universal service within an environment of open and competitive markets, this Directive defines the minimum set of services of specified quality to which all end-users have access, at an affordable price in the light of national conditions, without distorting competition.

Article 6 of the Directive deals with payphones. Clause 1 reads:

Member states shall ensure that national regulatory authorities can impose obligations on undertakings in order to endure that public pay telephones are provided to meet the reasonable needs of end-users in terms of the geographical coverage, the number of telephones, the accessibility of such telephones to disables users and the quality of services.

Article 7 of the Directive is entitled "Special measures for disabled users", and consists of two clauses:

1. Member States shall, where appropriate, take specific measures for disabled end-users in order to ensure access to and affordability of publicly available telephone services, including access to emergency services, directory enquiry services and directories, equivalent to that enjoyed by other end-users.

2. Member States may take specific measures, in the light of national conditions, to ensure that disabled end-users can also take advantage of the choice of undertakings and service providers available to the majority of end-users.

Clause 2 of Article 11 ("Quality of service of designated undertakings") refers to persons with disabilities:

National regulatory authorities may specify, inter alia, additional quality of service standards, where relevant parameters have been developed, to assess the performance of undertakings in the provision of services to disabled end-users and disabled consumers. National regulatory authorities shall ensure that information concerning the performance of undertakings in relation to these parameters is also published and made available to the national regulatory authority.

Finally, Clause 1 of Article 33 ("Consultation with interested parties") stipulates a mechanism for evolution of service offerings:

Member States shall ensure as far as appropriate that national regulatory authorities take account of the views of end-users, and consumers (including, in particular, disabled users), manufacturers, undertakings that provide electronic communications networks and/or services on issues related to all end-user and consumer rights concerning publicly available electronic communications services, in particular where they have a significant impact on the market.

3.4.2.2.2 Directive 1999/5/EC

Directive 1999/5/EC of the European Parliament and of the Council of 9 March 1999 on radio equipment and telecommunications terminal equipment and the mutual recognition of their conformity (http://europa.eu.int/comm/enterprise/rtte/dir99-5.htm) deals with, among other things, the design of telecom terminals.

The introduction to this Directive reads, in part:

15. Whereas telecommunications are important to the well-being and employment of people with disabilities who represent a substantial and growing proportion of the population of Europe; whereas radio equipment and telecommunications terminal equipment should therefore in appropriate cases be designed in such a way that disabled people may use it without or with only minimal adaptation

and

19. Whereas it should therefore be possible to identify and add specific essential requirements on user privacy, features for users with a disability, features for emergency services and/or features for avoidance of fraud;

Article 3 of this Directive describes "Essential requirements"; clause 3 reads (in part):

3. In accordance with the procedure laid down in Article 15, the Commission may decide that apparatus within certain equipment classes or apparatus of particular types shall be so constructed that:

…

f) it supports certain features in order to facilitate its use by users with a disability.

3.4.2.2.3 COM(2000) 284: Towards a Barrier Free Europe for People with Disabilities

COM(2000) 284 is a communication from the European Commission to (among others) the European Parliament and the European Council. It notes that targets established to improve access by persons with disabilities to the benefits of the "information age" include (http://europa.eu.int/comm/employment_social/news/2001/jul/2000284_en.html):

The Commission will prepare a Communication on how public procurement instruments can positively take account of the needs of people with disabilities in the public procurement of information and communication technology products and services.

and

The Commission will set up a European network to optimise the interaction among national centres of excellence (either physical or virtual) and encourage the development of curricula in design for all for designers and engineers.

The first of these is reminiscent of Section 508 of the US Rehabilitation Act (see Section 3.5 of the present report). Along these lines, on 19-21 October 2004 CENORM (the standards organisation) will hold an "International Workshop on Accessibility Requirements for Public Procurement in the ICT domain" in Brussels as part of the e-Accessibility Policy Implementation work of the European Commission (http://europa.eu.int/information_society/topics/citizens/accessibility/regulation/pubproc_ws_2004/index_en.htm).

3.4.3 Key cases

We could find no court cases in the EU relating to telecommunications access and disability.

3.4.4 "Next generation" issues

3.4.4.1 Advocacy groups

It is impossible to talk about telecom accessibility in Europe without mentioning Tiresias, a Euro-headed effort that is the clearinghouse for information on this topic in Europe and other places. The Tiresias effort includes the European Co-Operation in the field of Scientific and Technical Research (COST) initiatives, including COST 219bis and COST219ter. The general website for these efforts is www.tiresias.org. They are described in greater detail in Section 5 of the present report (Accessible telephones).

There are several national advocacy groups in the member countries of the European Union. Because a list of these (by country) can be found on the Tiresias website (www.tiresias.org/agencies/index.htm), they are not listed here.

3.4.4.2 Major policy papers

The Tiresias (COST 219bis) website, with PhoneAbility (its UK branch), contains a list of key publications from Europe that relate to the general area of telecom and accessibility (www.tiresias.org/phoneability/telephones/links.htm); it is summarised briefly below. As can be seen, the Tiresias / PhoneAbility effort has been very productive.

3.4.4.2.1 COST 219bis publications

Gill J M The Forgotten Millions: Access to Telecommunications for People with Disabilities. The European Commission, COST 219, ISBN 92 826 7399 5, March 1994, 16 pp. Also at: www.stakes.fi/cost219/forgmi94.doc

Gill J M Telecommunications: The Missing Links for People with Disabilities. The European Commission, COST 219, ISBN 92 827 5115 5, February 1996, 16 pp. Also at: www.trace.wisc.edu/docs/missing_links/mlhome.htm 

Gill J M Access Prohibited? Information for Designers of Public Access Terminals. ISBN 1 86048 014 4, May 1997, revised March 1998. Also at: www.tiresias.org/pats

Roe P R W (ed) Telecommunications for All. The European Commission, COST 219, October 1995. Also at: www.stakes.fi/cost219/Telall96.doc

von Tetzchner S (ed) Issues in Telecommunications for People with Disabilities. The European Commission, COST 219, ISBN 92 826 3128 1, 1991. Also at: www.stakes.fi/cost219/isscon91.doc 

3.4.4.2.2 Other publications

Cullen K & Robinson S Telecommunications for Older People and Disabled People in Europe. IOS Press, ISBN 90 5199 346 3, 1997.

Gill J M (ed) Guidelines for the Design of Screen and Web Phones to be Accessible by Visually Disabled Persons. ISBN 1 86048 018 7, December 1998, 28 pp. Also at: www.rnib.org.uk/wedo/research/sru/phones.htm 

Telephones for All: Nordic Design Guidelines. The Nordic Committee on Disability, Stockholm, ISBN 91 86954 26 1, 1995.

Vanderheiden G C & Vanderheiden K R Guidelines for the Design of Consumer Products to Increase their Accessibility to People with Disabilities or who are Ageing. Trace Center, 1992. Also at: tracecenter.org/docs/consumer_product_guidelines/consumer.htm

3.4.5 Standards

3.4.5.1 Non-EU organisations

The International Standardization Organization (ISO), based in Geneva, is described on its website (www.iso.ch)  as "network of national standards institutes from 148 countries working in partnership with international organizations, governments, industry, business and consumer representatives". As such, it is a supra-national organisation which happens to be based in Europe.

The International Telecommunications Union (ITU) is an intergovernmental organisation based in Switzerland that issues recommendations and standards (www.itu.int); as such, it is not a European organisation (that is, under the EU), but simply happens to be based in Europe. The ITU is the parent body of the previous standards organisation known as CCITT (Comité Consultatif International Téléphonique et Télégraphique), which was disbanded in 1992. A list of ITU standards, several of which apply to persons with disabilities or older persons, can be found on the ITU website www.itu.int/rec/recommendation.asp?type=products&lang=e&parent=T-REC-E.

ITU standards that relate to accessibility issues include:

3.4.5.2 EU-affiliated organisations

The European Committee for Standardisation, or Comité Européen de Normalisation (CEN), based in Belgium, is a European Union organisation (www.cenorm.be). It was founded in 1961 by national standards bodies, such as those in the European Economic Community, and works for harmonisation of standards across Europe.

The relevant standards body in Europe is ETSI, the European Telecommunications Standards Institute (www.etsi.org). ETSI has jurisdiction over the entire European Union, although several countries also have their own standards bodies.

Links to all these standards bodies (and others), plus a list of relevant standards, can be found on the Tiresias website (www.tiresias.org/guidelines/standards.htm).

3.4.5.3 ETSI standards and other documents

ETSI has done considerable work in the human factors aspects of telecommunications. An annotated bibliography of ETSI documents on this topic (ETSI SR 001 996 v2.1.1 (2003-10)) is entitled Human factors (HF); An annotated bibliography of documents dealing with Human Factors and disability. This document is a good starting point for human factors issues in telecom equipment design, but only some of the documents listed in this publication relate to disabilities.

ETSI standard ES 201 381 V1.1.1 (1998-12) is entitled Human factors (HF); Telecommunications keypads and keyboards; Tactile identifiers. This standard sets out its scope as follows:

The present document specifies the form, dimension and location of tactile identifiers on telecommunications keypads and keyboards. Only the "5", "F" and "J" keys are within the scope of the present document.

Briefly, this standard specifies that the "5" button on telephone keypads must contain a "pip" that can be perceived tactually. This pip can then be used as a reference to locate other buttons on the dialpad. Section 5.1 states:

The numeric keypad shall be marked with a tactile identifier on the "5" key.

Section 5.2 goes on to say that:

The preferred locations for the tactile identifier on the numeric keypad are:

However – and perhaps especially in the case of cell phones, where the size of the dialpad as a whole is reduced – there is an "opt-out" clause (5.2) in the standard, which reads:

If none of these locations can be used, e.g. on small keys, then alternative positions and forms of the tactile identifier may be acceptable.

This standard was developed with reference to the existing ITU-T Recommendation E.161 (Arrangement of digits, letters and symbols on telephones and other devices that can be used for gaining access to a telephone network), the scope of which is world-wide, applying to all ITU member states.

Another recent ETSI document deals with the lettering on telephone dialpads in different languages. This issue could affect the use of a telephone keypad by any user, but particularly by persons with a visual disability. The document is entitled ES 202 130 v1.1.1 (2003-10). Human factors (HF); User interfaces; Character repertoires, ordering rules and assignments to the 12-key telephone keypad.

3.5 United States (US)

3.5.1 Overview

General comments. A populous country with a strong economy, a constitution dedicated to equality of persons, and a tradition of litigation, the United States (US) is well poised to be a leader in accessibility of telecommunications. Over the past 15 years, there has been a burst of federal legislation in the US that has made it a model for other countries, such as Australia.

Disability legislation. The Americans with Disabilities Act (ADA), enacted in 1990, is the key disability rights legislation.

Telecom legislation. The Telecommunications Act of 1996 (Telecom Act) is the most recent major revision of telecom legislation in the US. Section 255 of the Telecom Act addresses the obligations of telecom equipment manufacturers and service providers to make their products and services accessible to persons with disabilities, where readily achievable. Section 508 of the Rehabilitation Act of 1973 requires that telecom and datacom equipment and services acquired by the US federal government be accessible to persons with disabilities. The Architectural and Transportation Barriers Compliance Board published (21 December 2000) the Electronic and Information Technology Accessibility Standards.

Key cases. Dr. Bonnie O’Day filed a formal Section 255 complaint with the FCC against Audiovox Corporation and Verizon alleging that basic telephone features on the respondent’s wireless telephones (such as Caller ID and one-touch dialling) were not accessible to people who are blind. The complaint against both parties was eventually dismissed by the FCC because the parties settled privately, although the terms of the settlement were confidential. No further details were available from the FCC, and few details were provided in subsequent press releases.

Government organisations. Key government resources are Access Board, DisabilityInfo.com, Federal Communications Commission (FCC), National Council on Disability, RERC network (Rehabilitation Engineering Research Centers).

Advocacy groups. Assistive Technology Industry Association (ATIA), American Foundation for the Blind (AFB), National Federation of the Blind (NFB), American Council of the Blind (ACB), National Task Force on Technology and Disability (NTFTD), Rehabilitation Engineering and Assistive Technology Society of North America (RESNA), as well as many other groups.

Other initiatives. An example of other initiatives is the annual conference entitled Technology and Persons with Disabilities, organised by the Center on Disabilities at California State University at Northridge (CSUN).

Standards. American National Standards Institute (ANSI).

3.5.2 Legislation

The United States has the most definitive legislation related to disabilities in general and to telecommunications and disabilities in particular. Here, we review three acts that are directly relevant to the issue of the accessibility of telecommunications equipment:

3.5.2.1 Definition of disability

In 1990, the United States passed the Americans with Disabilities Act, Public Law 336 of the 101st Congress, enacted July 26, 1990 (www.usdoj.gov/crt/ada/adahom1.htm). Section 3, clause (2) of the ADA defines "disability", with respect to an individual, as:

(A) a physical or mental impairment that substantially limits one or more of the major life activities of such individual;
(B) a record of such an impairment; or
(C) being regarded as having such an impairment.

3.5.2.2 Telecommunications legislation

Following the passage into law of the ADA in 1990, there was a movement to define the relation between electronic and information technology (EIT) on the one hand and accessibility on the other.

As described below, the ADA only dealt with telecom in passing. The two most relevant pieces of legislation – in the US at first, but increasingly on a more international scale – are Section 508 of the Rehabilitation Act and Section 255 of the Telecom Act. These are considered below in some detail.

3.5.2.2.1 Americans with Disabilities Act (ADA)

The ADA only mentions telecommunications in passing. However, because Section 255 has been described as "the marriage of the Telecom Act with the ADA", the relevant ADA passage is cited here. It reads (www.usdoj.gov/crt/ada/cguide.htm) :

"The ADA prohibits discrimination on the basis of disability in employment, State and local government, public accommodations, commercial facilities, transportation, and telecommunications".

Title IV of the ADA deals with telecommunications, but is restricted to two areas:

3.5.2.2.2 Section 508 of the Rehabilitation Act of 1973

Section 508 of the Rehabilitation Act became law in 1998. The opening text of Section 508 (www.usdoj.gov/crt/508/508law.html) makes it clear that accessibility is a key procurement criterion for the United States federal government:

(a) REQUIREMENTS FOR FEDERAL DEPARTMENTS AND AGENCIES.--

(1) ACCESSIBILITY.--

(A) DEVELOPMENT, PROCUREMENT, MAINTENANCE, OR USE OF ELECTRONIC AND INFORMATION TECHNOLOGY.--When developing, procuring, maintaining, or using electronic and information technology, each Federal department or agency, including the United States Postal Service, shall ensure, unless an undue burden would be imposed on the department or agency, that the electronic and information technology allows, regardless of the type of medium of the technology--

(i) individuals with disabilities who are Federal employees to have access to and use of information and data that is comparable to the access to and use of the information and data by Federal employees who are not individuals with disabilities; and

(ii) individuals with disabilities who are members of the public seeking information or services from a Federal department or agency to have access to and use of information and data that is comparable to the access to and use of the information and data by such members of the public who are not individuals with disabilities.

(B) ALTERNATIVE MEANS EFFORTS.--When development, procurement, maintenance, or use of electronic and information technology that meets the standards published by the Access Board under paragraph (2) would impose an undue burden, the Federal department or agency shall provide individuals with disabilities covered by paragraph (1) with the information and data involved by an alternative means of access that allows the individual to use the information and data.

The United States federal government is the largest purchaser in the world. Thus, for companies manufacturing products or providing services, to the extent that they intend to sell to the US government, they must comply with the US government’s procurement policies. Since the implementation of Section 508, these policies include accessibility.

For this reason, the implementation of Section 508 has had an enormous impact on ensuring that EIT products and services (electronic and information technology, or telecom and datacom) are accessible. Section 508 mandates that all telecom and datacom products and services procured by the US government must be accessible to persons with disabilities. Although there are exceptions to this rule (see below), the vast majority of acquisitions must meet the accessibility criterion.

There is some "wiggle room" in Section 508. Some micropurchases are excluded, and section (a)(5) makes exception for national security systems:

This section shall not apply to national security systems, as that term is defined in section 5142 of the Clinger-Cohen Act of 1996 (40 U.S.C. 1452).

Moreover, the Act contains the "undue burden" exemption. However, it is incumbent on the federal department to demonstrate that an undue burden prevents the procurement of accessible products and services. Also, "any individual with a disability may file a complaint alleging that a Federal department or agency fails to comply with subsection (a)(1) in providing electronic and information technology" (section (f)(1)(a)), and the citizen is entitled to pursue a civil suit (section (f)(3)).

Section 508 has had an enormous impact on the EIT industry supplying the US federal government, and its impact has attracted legislative interest in other jurisdictions, such as Australia. Moreover, some states in the US have begun implementing 508-like state laws, further reducing the size of the available market for non-accessible EIT equipment and services. Here, we cite two examples:

IC 4-23-16-12
Accessibility standards; appointment of group to develop standards
     Sec. 12. (a) The commission shall appoint a group to develop standards that are compatible with principles and goals contained in the electronic and information technology accessibility standards adopted by the architectural and transportation barriers compliance board under Section 508 of the federal Rehabilitation Act of 1973 (29 U.S.C. 794d), as amended. The commission shall adopt rules under IC 4-22-2 concerning the standards developed under this section. Those standards must conform with the requirements of Section 508 of the federal Rehabilitation Act of 1973 (29 U.S.C. 794d), as amended.

3.5.2.2.3 Section 255 of the Telecommunications Act of 1996

Section 255 of the Telecommunications Act of 1996 adopted a different tack than Section 508. Whereas Section 508 addresses both telecom and datacom, Section 255 specifically excludes datacom equipment and services. However, where Section 508 deals only with US federal government procurements, Section 255 addresses the entire telecom industry in the US.

Analogous to Section 508, Section 255 mandates that equipment manufacturers and service providers ensure that their products and services be accessible to persons with disabilities, where readily achievable (www.fcc.gov/Reports/tcom1996.txt; emphasis added):

(b) MANUFACTURING- A manufacturer of telecommunications equipment or customer premises equipment shall ensure that the equipment is designed, developed, and fabricated to be accessible to and usable by individuals with disabilities, if readily achievable.

(c) TELECOMMUNICATIONS SERVICES- A provider of telecommunications service shall ensure that the service is accessible to and usable by individuals with disabilities, if readily achievable.

(d) COMPATIBILITY- Whenever the requirements of subsections (b) and (c) are not readily achievable, such a manufacturer or provider shall ensure that the equipment or service is compatible with existing peripheral devices or specialized customer premises equipment commonly used by individuals with disabilities to achieve access, if readily achievable.

(e) GUIDELINES- Within 18 months after the date of enactment of the Telecommunications Act of 1996, the Architectural and Transportation Barriers Compliance Board shall develop guidelines for accessibility of telecommunications equipment and customer premises equipment in conjunction with the Commission. The Board shall review and update the guidelines periodically.

The Guidelines referred to in the preceding paragraph are considered in Section 3.5.2.2.4 (below).

Although the phrase "where readily achievable" wording may be taken to imply an opt-out provision, the FCC’s interpretation of this phrase has been addressed specifically (www.fcc.gov/cgb/consumerfacts/section255.html):

The "readily achievable" standard requires companies to incorporate access features that are easily accomplishable without much difficulty or expense. In determining what is readily achievable, companies must balance the costs and nature of the access required with their available resources. Companies that have great resources will need to do more to achieve access than will companies with smaller budgets. The FCC will make readily achievable determinations on a case-by-case basis. A company may not need to provide access when the access feature would so fundamentally alter the product that it would substantially reduce the functionality of the product, make some features unusable, substantially impede or deter use of the product by other individuals, or substantially and materially alter the shape, size or weight of the product. Similarly, a company does not have to incorporate an access feature that is not technically possible. Companies wishing to use these defenses, however, must provide evidence to back up their positions.

The FCC’s website for Section 255 includes a page listing manufacturers of telecommunications equipment (www.fcc.gov/cgb/dro/section255_manu.html), and a page listing telecom service providers (www.fcc.gov/cgb/dro/service_providers.html).

3.5.2.2.4 Electronic and Information Technology Accessibility Standards

On 21 December 2000, the Architectural and Transportation Barriers Compliance Board published, in the Federal Register (36 CFR Part 1194 [Docket No. 2000-01] RIN 3014-AA25, www.access-board.gov/sec508/508standards.htm), the Electronic and Information Technology Accessibility Standards. These standards provide the structure for the Voluntary Product Accessibility Template (VPAT) used by telecom equipment manufacturers to indicate the manner in which their products conform to the standards. The VPATs are described more fully in Section 5.2.2 of the present report.

3.5.2.3 Legislation: summary

Table 3 (below) summarises the areas of jurisdiction of Sections 255 and 508. US federal government procurement for both telecom and datacom equipment and services is covered by Section 508 of the Rehabilitation Act, which does not directly affect state government procurement or the private sector. By contrast, Section 255 of the Telecom Act affects telecom equipment and services at the manufacturer and service provider level, but does not have jurisdiction over datacom equipment and services.

TABLE 3

Areas of jurisdiction of Sections 255 and 508

  Telecom equipment and services Datacom equipment and services
Federal government Section 255, Section 508 Section 508
All other areas Section 255  

From this analysis, it may appear that datacom equipment and services outside the federal government are essentially unregulated in terms of accessibility. Although this may be true in principle, and to some extent in practice, two factors limit the truth of this statement in practice:

Thus, EIT equipment and service providers are subject to both market and legislative pressure to make their goods accessible. It is expected that, over time, this pressure will increase as the size of the domestic US market available to inaccessible EIT products shrinks.

3.5.3 Key cases

A search of the US Federal and State legal cases (LEXIS), using the keywords "disability" and "telecommunication", yielded no cases relevant to the question of service accessibility. The only cases identified fell into one of two main categories: (1) job discrimination (the largest); and (2) provision of broadcasting licenses. Job discrimination referred either to loss of a job or unequal hiring practices due to the presence of a disability and not lack of telephony access.

The sole case concerning telecom terminals and visual disability is a Section 255 complaint brought to the Federal Communications Commission (FCC) by Dr. Bonnie O’Day against a wireless handset manufacturer (Audiovox Corporation) and a wireless service provider (Verizon). The complaint against both parties was eventually dismissed by the FCC because the parties settled privately, although the terms of the settlement were confidential. No further details were available from the FCC, and few details were provided in subsequent press releases.

3.5.3.1 Dr. Bonnie O’Day vs. Audiovox Corporation

In February 2003, Dr. Bonnie O’Day filed a formal complaint with the Federal Communications Commission on the grounds that mobile telephone equipment made by Audiovox Corporation was not accessible to persons with a visual disability (www.fcc.gov/eb/2003/DA-03-767A1.html).

On February 21, 2003, Dr. Bonnie O'Day … filed a formal complaint alleging, among other things, that many of the features of a wireless telephone developed by Audiovox Communications Corporation and Cellco Parnership d/b/a Verizon Wireless ("Defendants") are inaccessible to blind or visually-impaired users. In a Notice of Formal Complaint issued on February 28, 2003, the Telecommunications Consumers Division ("Division") set forth a pleading cycle for the O'Day formal complaint proceeding.

In December 2003, the complaint against Audiovox was dismissed with prejudice following a private settlement (http://www.fcc.gov/eb/2003/DA-03-4116A1.html). Because this complaint had widely been seen as a test case for the Section 255 complaints process, both the withdrawal and the conditions of secrecy surrounding the settlement provided an air of mystery and disappointment.

On February 21, 2003, pursuant to Section 255 of the Act and the Commission's implementing rules and orders, Dr. Bonnie O'Day filed a formal complaint against defendant Audiovox Communications Corporation ("Audiovox"). In her complaint, O'Day contends that Audiovox violated Section 255 of the Act by, among other things, failing to make features of the wireless telephone handset that Audiovox manufactured accessible to O'Day, a visually-impaired user. O'Day requests that the Commission require Audiovox to make available for downloading into O'Day's wireless telephone the software needed to deploy "text to speech" capability. O'Day contends that such software would allow the essential functions and services available through a wireless telephone's visual menu to be accessible to her through audio prompts.

The text of a news item announcing the settlement is shown below:

Dr. Bonnie O'Day and Audiovox Announce Settlement in Section 255 Formal Complaint Proceeding

HAUPPAUGE, N.Y., Dec. 18 (2003) /PRNewswire-FirstCall/ -- Audiovox Communications Corp., a majority owned subsidiary of Audiovox Corporation (Nasdaq: VOXX), and a leading provider of mobile phones, announced today that it has reached a settlement of litigation with Dr. Bonnie O'Day concerning the accessibility features of Audiovox mobile telephone equipment. In a formal complaint filed with the FCC last February, Dr. O'Day, who has impaired vision, had contended that Audiovox mobile telephone equipment was not accessible to people with visual disabilities to the extent required by the Telecommunications Act of 1996. As a result of the settlement, in which Audiovox does not admit any violation of law, the parties have moved to have the complaint dismissed. The specific terms of the settlement are confidential. The parties did disclose, however, that Audiovox is making a number of significant improvements. For example, Audiovox's 9900 series, which is to be released during December, provides a more accessible keypad and audible announcement of certain visually displayed information, such as dialed and incoming phone numbers battery power, and roaming status. In addition, the company will make instruction manuals and other information more user friendly for blind and low vision individuals, will develop an accessibility plan for its website, and will undertake additional employee training on disability issues. The company is currently assessing additional, more advanced speech output capabilities. For its mobile handsets with a view toward incorporating these capabilities in the future. Dr. O'Day hailed the settlement, stating, "I filed the complaint because blind and low vision people were frustrated with the pace of progress achieved by the wireless industry. Audiovox's commitment in this settlement, however, makes them a leader in providing wireless access to blind and visually impaired consumers." Audiovox's President and CEO, Philip Christopher, added that "As wireless technology evolves and our industry provides enhanced communications capability to 150 million wireless subscribers in North America, it is important to improve wireless access for the 10 million Americans who have visual impairments. That's why Audiovox is taking seriously its commitment to implementation of Section 255 of the Telecommunications Act and our efforts to add value to these subscribers' wireless experience."

The aftermath of the agreement with Audiovox is interesting, because within 6 months of this agreement being announced – with Audiovox making pronouncements about its commitment "to improve wireless access for the 10 million Americans who have visual impairments" – Audiovox abandoned the mobile handset business. Audiovox had been a manufacturer of wireless telephones until 15 June 2004, when the following news item appeared (Globe & Mail, 15 June 2004, page B12):

Audiovox Corp., a consumer electronics and communications company, agreed to sell its wireless telephone division to UTStarcom Inc. for $165.1-million (U.S.). Audiovox said it is exting the wireless handset business because it no longer has "the capabilities to be a major player in that market."

3.5.3.2 Dr. Bonnie O’Day vs. Verizon Wireless

Dr. O’Day’s complaint (referenced above) was against both Audiovox as the equipment manufacturer and Verizon Wireless as the service provider. The Audiovox complaint was dismissed first, and then on 27 August 2004, the FCC issued an Order granting a joint motion to dismiss the formal complaint filed by Dr. O’Day against Verizon Wireless (www.fcc.gov/eb/2004/DA-04-2870A1.html). The text of the news release is included below:

Dr. Bonnie O'Day and Verizon Wireless Settle Section 255 Formal Complaint Proceeding
August 27, 2004: 8:30 a.m. EST

WASHINGTON (PRNewswire) - WASHINGTON, Aug. 27 /PRNewswire/ -- Verizon Wireless and Dr. Bonnie O'Day announced today that they have reached a settlement agreement resolving a complaint before the Federal Communications Commission concerning the accessibility of Verizon Wireless' wireless products and services. In a complaint filed with the FCC in February 2003, Dr. O'Day, who has impaired vision, contended that Verizon Wireless was violating Section 255 of the Telecommunications Act of 1996 by failing to make its wireless telephones and services accessible to people with visual disabilities. Verizon Wireless answered the complaint asserting that its products and services are accessible to and usable by persons with disabilities consistent with the requirements of Section 255. The parties entered discussions that resulted in the settlement of this dispute. Dr. O'Day and Verizon Wireless have moved the FCC to dismiss the complaint.

Dr. O'Day praised the settlement, stating: "I filed the complaint because blind and low vision people were frustrated with the pace of progress achieved by the wireless industry. Verizon Wireless' commitment in this settlement to breaking down the barriers to accessibility, however, makes them a leader in providing wireless access to blind and visually impaired consumers."

Terms of the settlement are not being released. The parties did, however, disclose that later this year Verizon Wireless intends to introduce a moderately priced wireless handset with new accessibility features to address some of the concerns raised by Dr. O'Day. Verizon Wireless has also taken additional steps to provide people with disabilities easier access to user information such as bills, manuals, and product information in accessible formats; to modify its Web site to be more user friendly for blind and low vision individuals; and to modify employee training on disability issues. Verizon Wireless is currently assessing additional, more advanced speech output capabilities for mobile handsets carried on its network with a view toward incorporating these capabilities in future models.

3.5.4 "Next generation" issues

3.5.4.1 Government organisations

The US federal government is such a huge organisation that there are many offices associated with disability issues, and many of these touch on telecom. In this section, we have tried to identify those which may be most relevant to this topic on an on-going basis.

3.5.4.1.1 Access Board

The Access Board is "an independent Federal agency that develops and maintains accessibility guidelines and standards. This includes not only the guidelines issued under the Telecommunications Act, but guidelines for the built environment and transit vehicles developed under other laws such as the Americans with Disabilities Act, as well as standards for electronic and information technology. The Board provides technical assistance and training on its guidelines and standards, but does not have any enforcement authority under the Telecommunications Act" (www.access-board.gov/publications/bulletins/telecomm.htm).

The website of the Access Board describes what types of products are covered by Section 255 (www.access-board.gov/publications/bulletins/telecomm.htm):

Telecommunications products covered include:

The possible functions of a product are key in determining coverage. If a product can provide telecommunication services, then that portion is covered. For example, televisions generally are not covered by section 255, except where a set-top-box enables e-mail communication or Internet access, and then only that device is covered.

3.5.4.1.2 DisabilityInfo.gov

DisabilityInfo.gov is described as "your gateway to the federal government's disability-related information and resources." The website provides information on employment, education, housing, transportation, health, income support, technology, independent living, and civil rights, and is located at www.disabilityinfo.gov/digov-public/public/DisplayPage.do?parentFolderId=500.

3.5.4.1.3 Federal Communications Commission (FCC)

The FCC is the organisation responsible for telecommunications policy in the United States. According to the FCC’s website (www.fcc.gov):

The Federal Communications Commission (FCC) is an independent United States government agency, directly responsible to Congress. The FCC was established by the Communications Act of 1934 and is charged with regulating interstate and international communications by radio, television, wire, satellite and cable. The FCC's jurisdiction covers the 50 states, the District of Columbia, and U.S. possessions.

The Consumer and Governmental Affairs Bureau (CGB) of the FCC "educates and informs consumers about telecommunications goods and services and engages their input to help guide the work of the Commission. CGB coordinates telecommunications policy efforts with industry and with other governmental agencies — federal, tribal, state and local — in serving the public interest."

Within CGB is the Disability Rights Office (DRO; www.fcc.gov/cgb/dro/). The CGB also has a Consumer Advisory Committee, whose mission is

… to make recommendations to the Federal Communications Commission regarding consumer issues within the jurisdiction of the Commission and to facilitate the participation of consumers (including people with disabilities and underserved populations, such as Native Americans and persons living in rural areas) in proceedings before the Commission.

CGB also has a Technology Advisory Council, which maintains a focus group "charged with analyses of technology and accessibility for persons with disabilities"; the focus group (http://trace.wisc.edu/docs/fccadv/disability.htm) is moderated by Gregg Vanderheiden of the Trace Institute. The mission statement of the focus group is described (www.fcc.gov/cgb/dro/tac.html) as:

… assess and report to the TAC the current technical trends in telecommunications services; suggest any changes that might decrease, rather than increase, the accessibility of telecommunications services by persons with disabilities; and suggest how the FCC might best communicate to designers of emerging telecommunications network architectures, the requirements for accessibility.

3.5.4.1.4 National Council on Disability

The National Council on Disability (NCD; www.ncd.gov/) "is an independent federal agency making recommendations to the President and Congress on issues affecting Americans with disabilities." Its mission statement is described as:

… to promote policies, programs, practices, and procedures that guarantee equal opportunity for all individuals with disabilities, regardless of the nature or severity of the disability; and to empower individuals with disabilities to achieve economic self-sufficiency, independent living, and inclusion and integration into all aspects of society.

3.5.4.1.5 Rehabilitation Engineering and Research Center (RERC) network

The US federal government agency NIDRR (National Institute on Disability and Rehabilitation Research) supports a network of 21 RERCs (Rehabilitation Engineering and Research Centers). Each RERC is affiliated with a university or research institute. Two RERCs are of direct relevance to the present project; their websites should be viewed as resources for emerging information. These two RERCs are:

Information about the RERCs is disseminated by the NCDDR, which stands for the National Center for the Dissemination of Disability Research; the website is located at www.ncddr.org/rpp/techaf/techdfdw/rerc/.

3.5.4.1.5.1 ITTATC

The Information Technology Technical Assistance and Training Center (ITTATC) "is charged with providing accessibility training and technical assistance related to Section 508 of the Rehabilitation Act and Section 255 of the Telecommunications Act. We want to help our audiences - industry, state officials, trainers, and consumers - to understand the requirements of Sections 508 and 255 and to achieve success in their efforts to develop, market, and buy accessible E&IT" (www.ittatc.org). ITTATC is funded by the (US) National Institute on Disability and Rehabilitation Research (NIDRR), and is based at the Georgia Institute of Technology in Atlanta.

3.5.4.1.5.2 Trace Research Center

The Trace Research Center (www.trace.wisc.edu) is currently headed by Gregg Vanderheiden, a major voice in the area of accessibility and Universal Design. Trace has a long history of research in the area of accessibility, including the accessibility of telecommunications.

3.5.4.2 Advocacy groups

There are numerous advocacy groups in the United States. The list below is not comprehensive, but has been designed to include influential advocacy groups and industry associations which, because of their focus, activities, and reputation, are key to the telecom accessibility movement in the US.

3.5.4.2.1 Assistive Technology Industry Association (ATIA)

The mission of ATIA (www.atia.org) is "to serve as the collective voice of the Assistive Technology industry so that the best products and services are delivered to people with disabilities". ATIA has an annual conference in January.

3.5.4.2.2 Associations of and for individuals with visual disabilities

There are three major organisations of and for the blind:

Examination of the websites of these groups, and knowledge of at least some of their activities, supports the conclusion that the AFB may produce the most lasting work – especially in research and product testing – and do so without creating a lot of fanfare. The NFB probably comes second in terms of influence.

3.5.4.2.2.1 American Foundation for the Blind (AFB)

The American Foundation for the Blind (www.afb.org), with which Helen Keller was affiliated, is a major advocacy group based in the United States. Its mission is "to ensure that the ten million Americans who are blind or visually impaired enjoy the same rights and opportunities as other citizens" (www.afb.org/Section.asp?SectionID=42).

In addition to its many other activities, AFB puts out a publication entitled AccessWorld: Technology and People with Visual Impairments. The May 2004 issue of AccessWorld includes a review of three cellphones with built-in speech capability; these are considered in more detail in Appendix B. The July 2004 issue contains a review of three more cellphones, two equipped with text-to-speech software and one designed to be usable by blind individuals; this is also considered in Appendix B.

3.5.4.2.2.2 National Federation of the Blind (NFB)

The National Federation of the Blind (www.nfb.org) was founded in 1940 and claims to be the "largest and most influential membership organization of blind persons" (www.nfb.org/aboutnfb.htm). The NFB website states that NFB’s objective is two-fold: "to help blind persons achieve self-confidence and self-respect and to act as a vehicle for collective self-expression by the blind".

3.5.4.2.2.3 American Council of the Blind (ACB)

The American Council of the Blind (www.acb.org) was founded in 1961 and claims to be the "the nation's leading membership organization of blind and visually impaired people" (www.acb.org/profile.html). The ACB’s stated purpose is "to improve the well-being of all blind and visually impaired people by: serving as a representative national organization of blind people; elevating the social, economic and cultural levels of blind people; improving educational and rehabilitation facilities and opportunities; cooperating with the public and private institutions and organizations concerned with blind services; encouraging and assisting all blind persons to develop their abilities and conducting a public education program to promote greater understanding of blindness and the capabilities of blind people."

3.5.4.2.3 National Task Force on Technology and Disability

The mission statement of the National Task Force on Technology and Disability (www.ntftd.org) is presented as:

The Task Force was established in 2001 to create recommendations on increasing the access to and usability of accessible technologies for people with disabilities. This blue ribbon panel of private industry, technology experts, disability advocates, education and government is funded by a grant from the CS Mott Foundation.

NTFTD has issued a report entitled "Within Our Reach" that looks at the status of accessible technologies in the US (www.ntftd.org/report/tableofcontents.htm).

3.5.4.2.4 Rehabilitation Engineering and Assistive Technology Society of North America (RESNA)

The mission statement of RESNA (www.resna.org) states:

We are an interdisciplinary association of people with a common interest in technology and disability. Our purpose is to improve the potential of people with disabilities to achieve their goals through the use of technology. We serve that purpose by promoting research, development, education, advocacy and provision of technology; and by supporting the people engaged in these activities.

RESNA holds an annual conference in June, and issues a journal entitled Assistive Technology.

3.5.4.3 Other initiatives
3.5.4.3.1 California State University at Northridge (CSUN) Center on Disabilities

The Center on Disabilities at California State University at Northridge (CSUN; www.csun.edu/cod) is perhaps best known for its annual conference in Los Angeles in March, entitled "Technology and Persons with Disabilities". The CSUN conference (as it is commonly known) is the major event that brings together the worlds of technology and disabilities. The url for the conference is www.csun.edu/cod/conf/index.htm.

3.5.5 Standards

In the United States, standards are developed by the American National Standards Institute (ANSI). The industry has input to the standards through industry associations; several US industry associations involved with telecommunications standards, including:

3.5.5.1 Industry associations

The industry associations which feed into standards development in the US are described briefly below.

3.5.5.1.1 Cellular Telecommunications and Internet Association (CTIA)

According to its website (www.wow-com.com), "CTIA is the international organization that represents all sectors of wireless communications-cellular, personal communication services and enhanced specialized mobile radio. We serve the interests of service providers, manufacturers, wireless data and Internet companies and other contributors to the wireless universe."

CTIA’s website describes its purpose as "the voice of the wireless industry - representing its members in a constant dialogue with policy makers in the Executive Branch, in the Federal Communications Commission, and in Congress, CTIA's industry committees provide leadership in the area of taxation, roaming, safety, regulations, fraud and technology."

As part of its "consumer issues" focus, CTIA maintains a website entitled AccessWireless, "dedicated to making wireless telecommunications available to the greatest number of people possible" (www.accesswireless.org). This site provides an on-line Consumer Guide in 5 sections:

The section (www.accesswireless.org/product/Users_with_Visual_Impairments.htm) on "blind and visually impaired" has two principal sections:

The features identified on this website include the following:

The manufacturers listed on this site as of 29 August 2004 included:

3.5.5.1.2 Telecommunications Industry Association (TIA)

The Telecommunications Industry Association (TIA; www.tiaonline.org/) is "the leading U.S. non-profit trade association serving the communications and information technology industry". Its mission is described on the website as representing "providers of communications and information technology products and services for the global marketplace through its core competencies in standards development, domestic and international advocacy, as well as market development and trade promotion programs".

In terms of standards development,

TIA is accredited by the American National Standards Institute (ANSI) to develop voluntary industry standards for a wide variety of telecommunications products. … To ensure representation for the positions of U.S. telecommunications equipment producers in the international arena, TIA also participates in international standards-setting activities, such as the International Telecommunication Union (ITU), the Inter-American Telecommunication Commission (CITEL) and the International Electrotechnical Commission (IEC).

The TIA’s only reference to disabilities related to the accessibility of emergency services for persons with disabilities, especially hearing impairments.

However, TIA, in association with the Electronic Industries Foundation (EIF), has a website (TIA Access; www.tiaonline.org/access/) which

serves as a clearinghouse for important industry and consumer information on accessible telecommunications technology. TIA uses technology as an essential tool for developing individual potential and leads the industry in promoting the application of telecommunications technology to help people with disabilities.

3.5.5.1.3 United States Telecom Association (USTA)

The USTA website (www.usta.org) links its business organisation to its four main goals, described as:

Searching the USTA website for the term "disability" yielded one hit, a reference to the employees’ disability insurance provisions.

3.5.5.2 American National Standards Institute (ANSI)

The American National Standards Institute (ANSI; www.ansi.org) has been in existence since 1918. The website describes ANSI’s mission as

The American National Standards Institute (ANSI) is a private, non-profit organization (501(c)3) that administers and coordinates the U.S. voluntary standardization and conformity assessment system.

The Institute's mission is to enhance both the global competitiveness of U.S. business and the U.S. quality of life by promoting and facilitating voluntary consensus standards and conformity assessment systems, and safeguarding their integrity.

ANSI standard T1.703-1995 (R1999) deals with the "Allocation of Letters to the Keys of Numeric Keypads for Telecommunications".

3.5.6 Corporate information

In Appendix A, we have presented in detail the results of an on-line search for information about accessible products and services on the websites of major telcos in the US. Information about specific products can be found in Appendix A; below, we have duplicated the results of the search, leaving out information about the products.

3.5.6.1 BellSouth

The homepage of BellSouth (www.bellsouth.com) has a link to "special needs", which takes the user to the "Special needs" site. Also, selecting "Residential services" opens a pull-down menu with "Special needs" as a choice. Selecting this option takes the reader to a page where 4 options are offered:

Choosing "Visually impaired" takes the reader to a page which lists 11 assistive products, each with a link to more information. Relevant telephones are described in Appendix A.

3.5.6.2 Qwest

As in the case of BellSouth, the homepage of Qwest (www.qwest.com) has a direct link to "disability" (icon), which takes the user to the "Center for Customers with Disabilities" page (www.qwest.com/residential/disabled/index.html). At this page, the customer is given 8 choices:

Although selecting "Other adaptive equipment vendors" provides a list of company names and contact information, we were unable to find an on-line catalogue of assistive equipment on the Qwest website itself. Despite the promising start, it seems to be the case that the user must follow the links to state equipment programmes or to the assistive technology vendors to identify specific equipment.

3.5.6.3 SBC

The homepage of SBC Communications (www.sbc.com) does not have a direct link to "disability". However, the SBC homepage features a "Search" function. Entering "disability" into the search field and selecting (as an example) "Texas", a total of 14 hits are returned, including "Vision solutions". Selecting this option produces the following information:

A second hit from "disability" is "SBC – Accessibility resources – Texas". Selecting this item, the user is presented with 7 options:

Selecting "Special Needs Equipment" takes the user to an on-line catalogue of 8 products. Most of these products, which can be seen at www.hitec.com/cgi-bin/hitec.storefront/en/Catalog/1925?BannerCode=1070549849&site=SBC, deal with hearing disability.

A third hit that is returned is "SBC Universal Design Policy – Texas". In Appendix A, we have reproduced the text in its entirety because it is a good example of the positioning of a major telco with respect to the accessibility of telecom equipment and services. It is perhaps especially noteworthy that SBC mentions explicitly that it will not use the "if readily achievable" option in Section 255 as "an excuse to avoid full, good faith compliance with its commitment to universal design principles or the law" (www01.sbc.com/Products_Services/Residential/1,,19--6-3-19,00.html).

3.5.6.4 Sprint

The homepage of Sprint (www.sprint.com) does not have a link to "disability". The user can access information about disabilities and accessibility by ignoring the product-related choices (Personal, Business) and selecting "About Sprint". From there, one selects "Consumer information". From here, "Technology for all abilities" opens a window that provides accessibility-related information with the following titles:

However, we could not find anything resembling a catalogue of accessible products.

3.5.6.5 Verizon

In Spring 2004, the homepage of Verizon (www22.verizon.com) had a link "Customers with disabilities". (By 10 September 2004, this link had disappeared from the homepage, but the link to "Solutions for customers with disabilities" appeared by selecting "More" under "Residential" on the home page.) Selecting this item takes the reader to a page with the following text:

Verizon is committed to providing the greatest range of communication capabilities to all of our customers. Our mission is to provide the highest quality of service and sensitivity to our customers with disabilities by empowering them with accessible telecommunications products and services.

In order to show you products and services, you may be asked to select a state. If you have previously selected a state, you will be taken to a listing of the product/categories for that state. To view these products in other states, you will need to select a category.

This page also features a navbar at right with the following choices (selected):

Selecting "Adaptive equipment", the reader is presented with a catalogue of 11 products; items relevant to visual disabilities are shown in Appendix A.

3.6 Canada

3.6.1 Overview

General comments. The telecom equipment market in Canada is heavily influenced by the market in the United States, with which it shares standards. However, the legislative environment in Canada is at a different stage with respect to explicit description of the relation between telecom and disabilities.

Disability legislation. Canadian Human Rights Act.

Telecom legislation. Telecommunications Act 1993.

Key cases. We know of no court cases regarding accessibility and telecommunications in Canada.

Government organisations. There are several initiatives. Examples include: Accessible Procurement Toolkit, Assistive Devices Industry Office, Office for Disability Issues, Persons with Disabilities Online, Web-4-All.

Advocacy groups. ARCH: Legal Resource Centre for Persons with Disabilities, Canadian Centre on Disability Studies, Canadian National Institute for the Blind, Council of Canadians with Disabilities, National Federation of the Blind: Advocates for Equality.

Other initiatives. Adaptive Technology Resource Centre, Neil Squire Foundation.

Major policy papers. We did not identify any major policy papers related to telecom accessibility in Canada.

Standards. T516-2: Requirements for pay telephone keypads and function keys with particular regard to use by persons with disabilities.

3.6.2 Legislation

3.6.2.1 Definition of disability

At the present time, there is no encompassing Canadian federal legislation similar to the Disability Discrimination Act (DDA) in the UK nor the Americans with Disabilities Act (ADA) in the United States. The Canadian Human Rights Act was amended to ensure "that federal employers and service providers are supportive of, and accessible to, persons with disabilities" (Future Directions to Address Disability Issues for the Government of Canada, 1999, p.5). With the development (by the World Health Organisation) of the International Classification of Functioning, Disability and Health (ICF), Statistics Canada and other federal organizations have adopted ICF’s operational definition of disability in surveys and policy development papers.

Section 25 of the Canadian Human Rights Act (laws.justice.gc.ca/en/H-6/30599.html) defines "disability" as:

"disability" means any previous or existing mental or physical disability and includes disfigurement and previous or existing dependence on alcohol or a drug;

With special reference to employment, Section 3 of the Employment Equity Act (laws.justice.gc.ca/en/E-5.401/49263.html) provides the following definition:

"persons with disabilities" means persons who have a long-term or recurring physical, mental, sensory, psychiatric or learning impairment and who

(a) consider themselves to be disadvantaged in employment by reason of that impairment, or
(b) believe that a employer or potential employer is likely to consider them to be disadvantaged in employment by reason of that impairment,

and includes persons whose functional limitations owing to their impairment have been accommodated in their current job or workplace(.)

Although provincial legislation is beneath the scope of the present document, we have included here some text from the recent Ontarians with Disabilities Act to illustrate how other definitions of "disability" may develop.

Province of Ontario

The Ontarians with Disabilities Act was passed into law in December 2001. Section 2 of this law (www.e-laws.gov.on.ca/DBLaws/Statutes/English/01o32_e.htm) defines "disability" as:

(a) any degree of physical disability, infirmity, malformation or disfigurement that is caused by bodily injury, birth defect or illness and, without limiting the generality of the foregoing, includes diabetes mellitus, epilepsy, a brain injury, any degree of paralysis, amputation, lack of physical co-ordination, blindness or visual impediment, deafness or hearing impediment, muteness or speech impediment, or physical reliance on a guide dog or other animal or on a wheelchair or other remedial appliance or device,
(b) a condition of mental impairment or a developmental disability,
(c) a learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language,
(d) a mental disorder, or
(e) an injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997; ("handicap").

3.6.2.2 Telecommunications legislation

Canada’s Telecommunications Act 1993 c.38 came into power in 1993. The provisions of the Act with respect to basic service have been covered in the Introduction to the present report (Section 2.3.1.1.3), and are not duplicated here.

3.6.3 Key cases

We know of no key court cases in Canada concerning telecom accessibility for persons with visual disabilities.

3.6.4 "Next generation" issues

3.6.4.1 Government organisations

Here, we cite a few examples of federal government initiatives concerning the accessibility of communications.

3.6.4.1.1 Accessible Procurement Toolkit

The Government of Canada provides (on-line) an Accessible Procurement Toolkit (www.apt.gc.ca), designed to help people who are procuring "electronic and information technologies, training and services." The site supports the user by permitting a choice of type of product or type of disability.

3.6.4.1.2 Assistive Devices Industry Office

Industry Canada maintains an Assistive Devices Industry Office (ADIO) which "was created to provide a window into the Federal Government for the Assistive Technology (AT) and Rehabilitation Engineering Research Sectors. It also works to ensure that the Industry Portfolio programmes and services are accessible to Canadians with disabilities" (http://strategis.ic.gc.ca/sc_mangb/asstdev/burst.html).

3.6.4.1.3 Office for Disability Issues

The Government of Canada has an Office for Disability Issues, which "is the focal point within the Government of Canada for key partners working to promote the full participation of Canadians with disabilities in learning, work and community life" (www.sdc.gc.ca/en/gateways/nav/top_nav/program/odi.shtml). The ODI is part of Social Development Canada.

3.6.4.1.4 Persons with Disabilities Online

The Government of Canada maintains this on-line information site to provide assistance to persons with disabilities (www.pwd-online.ca/).

3.6.4.1.5 Web-4-All

Industry Canada’s Web-4-All programme uses a smart-card based solution with Community Access Points across Canada to help ensure that access to computers and the Internet is accessible to all (http://web-4-all.ca).

3.6.4.2 Advocacy groups

Until 30 April 2003, Tiresias (based in Europe) maintained a list of "Main agencies serving blind people". The entries tend to be service organisations; Canadian entries can be found at www.tiresias.org/agencies/countries_c/canada.htm#canada. Below, we have identified some Canadian organisations which have touched the issue of telecom and non-visual accessibility.

3.6.4.2.1 ARCH Legal Resource Centre for Persons with Disabilities

Originally known as Advocacy Resource Centre for the Handicapped, "ARCH is a not-for-profit charitable organization with a provincial mandate". According to its website (www.archlegalclinic.ca/index.asp):

ARCH: A Legal Resource Centre for Persons with Disabilities is a specialty legal aid clinic dedicated to defending and advancing the equality-rights of persons with disabilities.

ARCH has made submissions to the CRTC on several topics, including:

In addition, ARCH maintains an on-line database of links to issues and organisations (www.archlegalclinic.ca/search/searchResults.asp?resourceType=webSite&linkNote=yes) that may be of interest. At the time of this writing (10 September 2004), the list contained 120 items, and included many other Canadian organisations. For brevity, the reader is referred to the ARCH website.

3.6.4.2.2 Canadian Centre on Disability Studies (CCDS)

The Canadian Centre on Disability Studies (www.disabilitystudies.ca) is "a consumer-directed, university-affiliated centre dedicated to research, education and information dissemination on disability issues." As such, CCDS funds research and has educational initiatives.

3.6.4.2.3 Canadian National Institute for the Blind (CNIB)

In terms of membership, the Canadian National Institute for the Blind (CNIB; www.cnib.ca) is a large service organisation for Canadians with visual impairments. The CNIB operates a "technical aids" service, but the organisation is not specifically involved in advocacy for telecom accessibility. Their website describes the mission statement as:

The Canadian National Institute for the Blind (CNIB) is a national voluntary agency providing services to individuals across Canada to whom loss of vision is a central problem in personal and social adjustments. The CNIB also acts as a consultant and resource agency to the helping professions, government departments and private industry.

The basic aim of the CNIB is to help blind and visually impaired people find ways to lead satisfying lives. Underlying all CNIB services and actions is the belief that blind or visually impaired individuals can be integrated into the mainstream of community life, according to their ability to function within that community.

The specific objectives of the CNIB are:

The CNIB is committed to helping anyone with a vision problem that cannot be corrected using ordinary lenses and that significantly affects the person's ability to function normally. The CNIB uses a team approach to which staff, volunteers and clients work together towards a set of common goals. Our purpose is to help blind and visually impaired persons achieve the lifestyle they want, both at home and in the community.

3.6.4.2.4 Council of Canadians with Disabilities

The website of the Council of Canadians with Disabilities (www.ccdonline.ca) describes its mission:

The Council of Canadians with Disabilities advocates at the federal level to improve the lives of men and women with disabilities in Canada, by eliminating inequality and discrimination. Our members include national, regional and local advocacy organizations that are controlled by persons with disabilities. 

CCD is a team of people with disabilities, deeply committed to the principles of self-help and consumer advocacy. We work for the personal empowerment of all people with disabilities in Canada and around the globe. CCD works at the international level through its participation in the activities of Disabled Peoples' International (DPI) and through development projects initiated by the CCD International Committee. 

One of the CCD’s core values is "Consumer Control: We must be centrally involved in the decision making processes that affect our lives." We could find nothing on the CCD website related to telecom issues.

3.6.4.2.5 National Federation of the Blind: Advocates for Equality (NFB:AE)

The NFB:AE is "a not-for profit consumer group of blind, partially sighted and deaf-blind adults, parents of blind, partially sighted and deaf-blind children, and other interested individuals, who have joined together for the purposes of preserving and enhancing the rights of blind, partially sighted and deaf-blind people in Canada".

The website of the NFB:AE (www.nfbae.ca) describes its mission:

To increase awareness of rights and responsibilities, so blind, deaf-blind and partially sighted individuals can have equal access to the benefits and opportunities of society.

NFB:AE publishes "The Canadian Blind Monitor".

NFB:AE has made two representations to the Canadian Radio-Television and Communications Commission (CRTC):

3.6.4.3 Other initiatives
3.6.4.3.1 Adaptive Technology Resource Centre, University of Toronto

The Adaptive Technology Resource Centre (ATRC; www.utoronto.ca/atrc/) of the University of Toronto is a well respected centre for helping ensure that advances in technology do not leave behind persons with disabilities.

The Adaptive Technology Resource Centre advances information technology that is accessible to all; through research, development, education, proactive design consultation and direct service.

A large part of the ATRC’s work is research, the goal of which is described below:

The goal of Research and Development at the ATRC is to insure that the design of emerging information technology is inclusive of people with disabilities.

This is achieved by:

The reputation of ATRC is exemplified by its on-going participation in industry conferences (e.g., the CSUN conference on "Technology and Persons with Disabilities") and its expert testimony delivered in a landmark Australian accessibility case (Maguire vs. Sydney Organizing Committee for the Olympic Games (SOCOG); www.hreoc.gov.au/disability_rights/comdec/2000/DD000120.htm).

3.6.4.3.2 Neil Squire Foundation

The Neil Squire Foundation is a Canadian non-profit organisation "committed to providing education, technology and career development for people with physical disabilities" (www.neilsquire.ca/section.asp?catid=121). The website describes the vision as:

The Neil Squire Foundation is driven by the hopes, wants, needs and dreams of people with disabilities. These people are using our services to achieve social, educational, political, technological, and financial equality. This is accomplished by using appropriate technology to provide innovative programs that are client and participant driven. We exceed the expectations of persons with disabilities and we help them to surpass their own. To help facilitate this we have reached a level of self sufficiency through excellence in resource generation that allows us to deliver services on an effective basis.

3.6.4.4 Major policy papers

We know of no major policy papers on telecom accessibility in Canada.

3.6.5 Standards

The Canadian Standards Association (CSA) is described on the website (www.csa.ca) as "not-for-profit membership-based association serving business, industry, government and consumers in Canada and the global marketplace." As its name implies, the CSA develops standards.

Canadian standard T516-2 (Telecommunications – Telephone terminal equipment – Requirements for pay telephone keypads and function keys with particular regard to use by persons with disabilities. November 2002.) deals with, among other issues, the "pip" on the 5 button of a payphone dialpad (for copyright reasons, the standard cannot be quoted verbatim).

As a member of the International Telecommunications Union (ITU), Canada benefits from international standards, such as ITU-T Recommendation E.161 (Arrangement of digits, letters and symbols on telephones and other devices that can be used for gaining access to a telephone network).

3.6.6 Corporate information

3.6.6.1 Aliant

The homepage of Aliant (www.aliant.ca/english/index.asp) had no links to "disability". Selecting "Aliant products & services" takes the reader to the "Products and service for your home" page, where the reader must select a province. Selecting (as an example) New Brunswick, the reader is taken to a page which has, in the navbar at left, 6 categories containing 12 sub-categories. Selecting "Phones", one is given a choice between "Rental" and "Retail", as well as a Phone Care maintenance plan. Selecting "Retail" takes the reader to another page which provides two lists, without images or explanatory notes, of cordless (n=14) and corded (n=2) phones. We could not find any information related to disabilities searching in this manner.

Searching the Aliant site (as a whole) for "disability" resulted in no website hits, but did retrieve a news story (from 2002). A search for "accessibility" returned no websites but three news stories related to network access.

However, once New Brunswick had been selected, a keyword search window was offered. Entering "disability" yielded one hit ("Special needs services"). Selecting this item led to a description of special needs services, TTY contact information, relay service information, information about long distance discounts and Directory Assistance exemptions, and, finally, this item:

Specialized Equipment for Customers with Disabilities
There are a number of dealer locations which can provide you with special telephones and accessories to assist those customers with disabilities. Contact our Special Needs representative at 1-888-683-0222 to discuss any particular situation.

Based on this brief trial, it seems to be the case that a customer with disabilities will not be able to search the Aliant site successfully for telephones by him- or herself.

3.6.6.2 Bell Canada

Bell Canada’s home page (www.bell.ca/shop/application/commercewf) contains no link to "disability". Clicking on "Phone services" leads to the "Telephones and services" page. Clicking on "Telephones & accessories" takes the reader to the "Browse for phones" page, where 5 categories are presented:

Clicking (as an example) "Corded phones" takes the reader to an on-line catalogue of corded telephones. Without reading the descriptions of each telephone – by scrolling to the phone, selecting the "More" button and accessing another page – it was not possible to determine which phones had accessibility functions.

Entering "disability" into the Search field returns no hits related to disabilities. The only hit returned in our brief test was for the case for the Palm V; following this link leads to text containing no reference to "disability", but containing the word "durability". Searching for "accessibility" returned 44 hits, none of them obviously related to disability and several relating to accessing e-mail or voice mail messages.

3.6.6.3 Manitoba Telephone Service (MTS)

The homepage of Manitoba Telephone Service (MTS) (www.mts.ca) has no link to "disability".

Searching for "disability" returned no hits; "accessibility" returned unrelated hits, and "special needs" returned hits for 7 TTY products and two network connectivity packages (MegaLink, MicroLink).

3.6.6.4 SaskTel

The homepage of SaskTel (www.sasktel.com) does not have a direct link to "disability", but it features a search function. Clicking in the "I’m looking for …" window and scrolling down, "Special needs" appears as an option. Executing this search takes the reader to the Special Needs page, which features the following text:

Telephones and accessories specially suited to customers who have sight, hearing, motion or speech limitations. 

Selecting the link to the catalogue, one is presented with these 4 choices (by disability). Selecting "sight" opens a window that has a catalogue of items, as follows:

3.6.6.5 Telus

Telus’s homepage (www.telus.ca/cgi-ebs/jsp/homepage.jsp) contains no direct link to "disability". To locate accessible telephones, the reader selects "Personal users", then clicks "personal products & services". Next, one is asked to select a region. Selecting (as an example of where Telus provides fixed-line service) "British Columbia", one is presented with 6 lists containing a total of 32 items, none related directly to "disability". Selecting "telephones" under the "Products" banner brings up 4 choices8:

Selecting "corded" brings up a catalogue of 5 telephones. None of the descriptions relates to "disability".

We could not find a "Search" function on the Telus site. Selecting "Sitemap" brings up a list of 46 topics, none related to "disability" or "accessibility", in 8 categories. Selecting "Frequently asked questions" yields nothing related to "disability".

4 The task-based matrix: background

The purpose of the present section is to describe the organisation of a task-based taxonomy for the usage of a telephone, where the tasks are organised in a hierarchical fashion. The hierarchy starts with a broad category known as "General tasks"; one such example is "Making a call". At the next level, this overall category is broken down into "Specific tasks". Finally, specific product solutions are identified, where possible. The reader is referred to Appendix A for details about specific product solutions mentioned here; comparisons of some specific telephones are shown in Table 4 in Section 5.

In reviewing the matrix, it is important to keep in mind that the primary focus of the present report is on wireline terminals and visual disabilities. With respect to the type of terminals, where appropriate we have also added some comments about cell phones. With respect to accessibility for persons with a visual impairment, we have also occasionally made note of solutions (such as a teletypewriter, or TTY) that address other types of disabilities. Overall, though, the focus has been on wireline solutions for persons with a visual disability. Finally, where the solution is widely available (e.g., a telephone handset), it has been noted without additional comment.

As the reader works through this matrix, it should become obvious that, in many cases, telephone designers have implemented different solutions to address a particular need in different ways. This situation emphasises that, although certain aspects of telephone design are dictated by standards, in general designers are mostly unregulated when designing the user interface, such as (for example) the location and size of non-dialpad buttons.

4.1 An example

Consider an example. Under the general task "Receiving a call", one of the specific tasks is "Detecting an incoming call". How this detection is achieved will depend on the design of the telephone, the capabilities of the user, and the environmental conditions.

For example, the telephone may be equipped with a ringer that has a volume control. This volume control may be implemented in the telephone itself, either as a hardware control (e.g., a slider or a three-position switch) or as a software control (e.g., a toggle switch). However, volume control could also be a system feature (e.g., in the case of a key system or PBX), or it may be a network-resident feature (for example, a scheduling function that is part of an Advanced Intelligent Network feature). In other cases (such as a manufacturing floor), the telephone may be linked to a loud bell (similar to a fire-alarm bell) designed to be noticeable above high ambient noise. In each of these cases, the ability of the user to adjust the volume control may vary.

Thus, even a task as basic as detecting an incoming call will depend on many factors. If the telephone is a "normal" residential telephone not attached to a key system or PBX, we can ignore (for this example) system-based functionality. Nevertheless, it is still the case that the user may not hear the ringer, for one (or more) of several reasons:

4.2 General tasks

We have identified 6 general tasks, as follows:

  1. Receiving a call;
  2. Making a call;
  3. Phone management;
  4. Call management;
  5. Voice mail; and
  6. Account management.

In addition, as a seventh category, we have identified:

  1. User support.

In Section 4.3, each of these general tasks constitutes a sub-section. Within each such sub-section, the specific tasks making up the general task are listed.

The General tasks and Specific tasks constitute the "backbone" of the matrix. In developing this matrix of functional tasks, the intent is to articulate the operational definition of each specific task, and then to identify particular solutions that exist as relevant to an end-user who is visually impaired. A similar analysis could be performed for other disabilities (e.g., speech, hearing, mobility); because the tasks themselves exist independently of any disability, the matrix can also be viewed as a template for describing telephone usage in its most general sense.

4.3 Specific tasks

4.3.1 Receiving a call

We have identified 6 specific tasks related to receiving a call:

  1. detect an incoming call;
  2. get information about the call
  3. accept the call;
  4. communicate with the caller;
  5. detect the Call Waiting signal; and
  6. toggle to the waiting call.
4.3.1.1 Detecting an incoming call

The industry has implemented three ways of signalling incoming calls:

4.3.1.1.1 Ringer

All business and residential telephones are equipped with a ringer. On many of these, the volume (amplitude) of the ringer can be modified by adjusting a toggle switch up or down, or by turning a knob. Once the mechanism has been located, it is accessible to persons with a visual disability.

4.3.1.1.2 Visual ringer

In addition, many business and residential telephones are equipped with a light that indicates an incoming call. An example of this in a residential telephone is the Vista 350. The visual ringer may not be accessible to persons with a visual disability.

4.3.1.1.3 Vibrating alerter

The AT&T Model 5870 is the only example we could find of a residential (cordless) telephone that has a vibrating alerter (see Appendix A.1, page A.1-3). This solution is also used widely in cellular telephones, the newer models of which have a "silent mode" feature in which the ringer is silenced and a vibrator used to signal an incoming call, missed call, or presence of a voice message. Vibrating alerters are also sold as adjuncts to wireline sets at incremental cost (see Appendix A).

The vibrating alerter is accessible to persons with a visual disability.

4.3.1.2 Getting information about the incoming call

Two types of information are commonly available concerning an incoming call

These types of information may be delivered in two ways:

4.3.1.2.1 Display

For the residential subscriber to receive either type of information, it is necessary to subscribe to a Call Display feature and to have telephone with a display that supports this feature. An example of a residential telephone that can support these features is the Vista 350.

In a business environment, these features may be delivered to the end-user’s telephone if the telephone system (PBX, key system) serving the business supports the feature(s) and if the end-user’s telephone supports the feature(s). Most modern display-based business telephones meet this criterion. Display-based interfaces may be inaccessible to persons with a visual disability.

4.3.1.2.2 Spoken output

For residential users with a visual impairment, a few terminals, such as the Panasonic KX-TG2336S and the AT&T model 1818 (both available in the US; see Appendix A), offer Talking Caller ID.

Also, some manufacturers (e.g., ClassCo) produce adjunct devices that speak the name and/or number associated with the calling number (see Appendix A). ClassCo has a portfolio of "Talking Caller ID" devices designed for this purpose. Of course, the visually impaired user must purchase such a device, so the cost of the solution is greater than that for a sighted person.

We are unaware of any similar device designed for proprietary telephone systems (PBX, key system) found in a multi-line business environment. In this case, it is probably necessary to provide the user with an analog line, and analog telephone, to which a ClassCo (or similar) device can be connected. However, this solution may be counterproductive in that providing an analog line "parallel to" the PBX may eliminate caller information and compromise the user’s ability to use system-based features.

4.3.1.3 Accepting a call

There are three common ways to accept an incoming call:

A fourth, less common, mechanism to accept an incoming call is the Auto-answer feature. Also, some telephones permit users to accept an incoming call on a teletypewriter (TTY), but as this mechanism is not relevant to visual disabilities, it is not considered here.

4.3.1.3.1 Handset

Virtually all telephones are provided with a handset. We are not aware of any issues related to the handset for persons with a visual disability.

Parenthetically, we note that lifting a handset may be impossible or inadvisable in certain circumstances; for example, a person with a motor impairment may not be able to lift or hold the handset, and medical staff in the middle of a sterile procedure may choose not to touch a handset.

4.3.1.3.2 Handsfree function

Many residential and business telephones are equipped with a handsfree function, which is usually turned on and off by means of pressing a button. Again, the Vista 350 is an example of a residential telephone with this functionality, although there are many others.

For someone with a visual disability, the colour-coding or labelling on the handsfree button will not be accessible. In this case, an add-on tactile label or other distinctive marker may be required.

4.3.1.3.3 Headset

Many business telephones, some residential telephones, and some cell phones are equipped with a jack that accepts a headset. When the user is wearing a headset, it is often only necessary to hit a distinctive button to accept a call.

4.3.1.3.4 Auto-answer feature

Some business telephones are equipped with an Auto-answer feature. With this feature, an incoming call is announced with a single ring, after which the receiving telephone answers the call in handsfree mode, so the recipient can simply begin to speak to the calling party without taking any other action.

While this feature may be useful for persons with a mobility impairment, we are not aware of its existence in residential telephones. The feature is used in special business environments (such as operating rooms), where it is not practical for the recipient of the call to touch the handset or a button.

One of the reasons this feature has limited use is that it has privacy implications, where the caller can hear what is happening at the recipient’s location even if the recipient is not aware that he or she is connected on a call. However, other than this privacy concern the Auto-answer feature seems to pose no accessibility challenge for a user with a visual disability.

4.3.1.4 Communicating

The whole point of a telephone call is to exchange information by communicating. Leaving aside a text-based device (e.g., TTY), communication can be received in three ways:

Also, voice communication is transmitted by means of a microphone.

For brevity, we simply note here that the relevance of these mechanisms to persons with a visual disability is the same as noted for "Accepting a call" in Section 4.2.1.3, and will not repeat the details here.

4.3.1.5 Detecting a Call Waiting signal

The Call Waiting feature is designed to alert a person on an existing call that another call to his or her telephone number is arriving. To make use of the Call Waiting feature, the person must subscribe to the feature. This feature can be delivered over any touch-tone telephone.

There are two mechanisms for detecting a Call Waiting signal:

The Call Waiting tone presents no obstacle to the user with a visual disability, and is not considered further here. We note parenthetically that this tone may be problematic for a user with a hearing impairment.

However, information presented on the display may not be accessible to a person with a visual disability. It is possible to acquire (at incremental cost) a Talking Caller ID adjunct device (e.g., from ClassCo) which speaks the name and number of the calling party. This adjunct may be connected to any analog telephone, but to the best of our knowledge no such device is available for use on proprietary business systems (see Section 4.2.1.2.2, above).

4.3.1.6 Toggle to the waiting call

There are two ways to toggle to the waiting call:

Not all telephones are equipped with a dedicated button ("Link" or "Flash"); the Vista 350 is an example of a residential telephone with this button. Use of this button requires that the user be able to orient to the button.

By contrast, the hookswitch (the "switch" that the handset depresses when it is replaced in the cradle) is present on virtually all telephones. Anyone who is able to retrieve the handset from the cradle to answer a call should be able, with minimal difficulty, to briefly depress and release the hookswitch to toggle between the existing call and the new incoming call.

4.3.2 Making a call

We have identified 7 specific tasks related to making a call:

  1. obtain the phone number to be called;
  2. verify the status of the line / extension;
  3. select a line;
  4. orient to the dial mechanism;
  5. dial the number;
  6. verify the number selected;
  7. verify the number dialled.
4.3.2.1 Obtaining the phone number to be called

Before someone can initiate a phone call, it is necessary to have the telephone number to be called. There are three "flavours" of this task:

4.3.2.1.1 Obtaining a number that is new to the caller

Other than speaking to a friend or acquaintance, there are three sources for a number that is new to the caller:

Unless the printed source is published in Braille and/or large print, it will likely be inaccessible to many users with a visual impairment. By contrast, the on-line source should be accessible to visually impaired users equipped with a computer and screen reader. Finally, depending on the legislative environment, Directory Assistance is available at reduced cost (or no cost) to users who are visually disabled.

Thus, although the printed source is likely inaccessible, accessible solutions are available to visually impaired users.

4.3.2.1.2 Accessing a number stored by the user

Telephone numbers can be stored in the telephone by the user in two forms:

In addition, some telcos (telephone operating companies) make Speed Dial available as a subscription feature at a monthly cost. However, since the operation is basically the same as the terminal-based Speed Dial, we consider them together here.

Autodial buttons. Autodial buttons are typically not labelled in a manner that is accessible to persons with a visual disability, although it may be possible to add Braille or tactile labels. To our knowledge, there is no telephone that announces the stored contents of an autodial button.

Speed Dial. Speed Dial codes are programmed by the user, as well. However, instead of having a dedicated button, the user must dial a code followed by a number. It is common for people to joke – but they are usually correct – that "home" is code 1 in everyone’s Speed Dial list.

The drawback with a Speed Dial list is that, unless the numbers are dialled frequently or unless the user has a reminder of the contents of the Speed Dial list, numbers further down the list may be forgotten or their places on the list confused. This problem applies to both sighted and visually impaired users; showing a Speed Dial list (or entry) on a display, as is common on cell phones, is helpful for sighted users, but may be of no benefit for users with a visual impairment.

Some wireline phones are appearing (such as the Panasonic KX-TG2386B) which speak the contents associated with a Speed Dial number. This feature will benefit both sighted and visually impaired users.

4.3.2.1.3 Accessing a number stored automatically

Depending on the features to which the customer has subscribed, and on the type of telephone, it is possible that information about people who have called will be stored in a Callers List (e.g., Vista 350).

Most phones with a Callers List use a display-based interface to access the list; this solution is not accessible to many people with a visual impairment. Some newer phones (e.g., the Panasonic KX-TG2386B) may offer a "Phone Book voice announcement (that) will ‘speak’ names stored in memory when you review this memory bank," and "Caller ID voice announcement (that) will ‘speak’ Caller ID names received when you review Caller ID information."9

4.3.2.2 Verifying the status of the line / extension

A user wishing to dial out may use a single-line phone or a multi-line phone. These are considered separately below.

4.3.2.2.1 Single-line phones

In single-line phones, there is no choice to be made; the user simply lifts the handset (or equivalent) and the line is selected automatically. The only potential complication is that the line may already be occupied by someone else using an extension.

Some telephones (e.g., Vista 350) have a visual indicator that shows that an extension is in use. Such an indicator may be inaccessible to someone with a visual impairment. For phones such as the Vista 350, the visually impaired user is at a disadvantage relative to the sighted user. However, the penetration of phones that indicate that an extension is in use is sufficiently small that, for all intents and purposes, neither sighted nor visually impaired users can tell without lifting the handset.

4.3.2.2.2 Multi-line phones

In contrast to the situation with single-line phones, multi-line phones always use visual indicators to indicate line status. Because line status indicators are usually visual in nature (e.g., light-emitting diodes, or LEDs), they may be inaccessible to a visually impaired user, who will be at a disadvantage relative to sighted users on this task. This situation may be a job barrier for a visual impaired person who wishes to become a receptionist, for example.

4.3.2.3 Selecting a line

Selection of a line in a single-line phone is achieved by lifting the handset (or equivalent). This task is equivalent for sighted and visually impaired users. However, with cordless handsets the user is typically required to locate and press a button to "turn on" the handset and obtain dial tone. If this button is not located or identified distinctively in a non-visual manner, this task may be inaccessible to some persons with a visual disability.

In multi-line sets, which tend to be more common in a business environment than in a residence, the user may have to select which line to use to make the call. In this case, the user must be able to orient to the line keys, detect which lines are in use, and select one which is not in use. Because the line keys are labelled (if labelled at all) in a manner that may be inaccessible to a visually impaired user, and because line status indicators are usually visual in nature (e.g., light-emitting diodes, or LEDs), visually impaired users are at a disadvantage relative to sighted users on this task.

4.3.2.4 Orienting to the dial mechanism

Some cell phones have a voice dialling feature, where the user can speak the name or number of the person to be called. Where this feature is present, there may be accessibility implications in the display-based prompts, which may not be detectable by a user with a visual impairment. Thus, this feature is not considered further here.

On most residential and business telephones, there is no voice dialling feature, and so the caller can call someone in two ways:

For the moment, we ignore the Redial feature, which implies that the user has already called the number stored there. Redial is addressed in Section 4.2.2.5.

4.3.2.4.1 Using the telephone’s dialpad

The vast majority of calls are initiated by the caller using the dialpad to dial the number. In the case of someone with a visual disability, there is a standard found around the world which requires that a tactile "pip" be present on the "5" key of the dialpad (or next to it; see Section 3.4.5.3). The presence of this "pip" orients the user; once the "5" button has been located, the locations of the other numerals may be deduced assuming a standard dialpad layout.

The international standard for dialpads is ITU E.161. In Europe, this standard is ETSI ES 201 381 v1.1.1. In the US, it is ANSI standard T1.703-1995 (R1999). Canada is harmonised with the ITU (International Telecommunications Union) on this issue. Additionally, in Canada CSA standard T516-2 specifies the "pip" on the dialpad of payphones.

Several residential phones are available that provide "jumbo" or large buttons on the dialpad, some with Braille labels. See Appendix A for details.

4.3.2.4.2 Using a pre-programmed autodial button

Many business and residential telephones also have autodial buttons. Storing information in an autodial button is considered below (Section 4.2.3.4), whereas here we are concerned with retrieving information that has been stored.

There are various ways of labelling autodial buttons. On some phones, the user can write the name on a template that surrounds an array of autodial buttons; on some others, each button is labelled individually; on yet others, the autodials may be labelled and displayed in software by means of a display. In all of these cases, the labels will be inaccessible to a person who is blind, and may be inaccessible to others with a visual impairment.

4.3.2.5 Dialling the number

On a wireline residential or business telephone, the user can dial a number in one of two ways:

4.3.2.5.1 Composing the number on the dialpad

As long as the user can orient to the dialpad (see Section 4.2.2.2.1, above), it may appear that there is no general accessibility issue here for persons with a visual impairment. However, it is possible that a user with a visual impairment (or, less relevant in the present report, a user with a motor impairment) may take longer to dial a number than a sighted user, or may take longer to initiate dialling once the handset has been lifted. In the United States, Section 1193.41 (Input, control, and mechanical functions) of the Telecommunications Act Accessibility Guidelines issued by the US Access Board (www.access-board.gov/telecomm/html/telfinl2.htm) addresses the user response issue with the following wording:

Input, control, and mechanical functions shall be locatable, identifiable, and operable in accordance with each of the following, assessed independently: …

(g) Operable without time-dependent controls. Provide at least one mode that does not require a response time. Alternatively, a response time may be required if it can be by-passed or adjusted by the user over a wide range.

This issue relates to the ability of the telephone network (PSTN) to accommodate the needs of users who need extra time to initiate dialling and to dial sequential digits, and the issue may be especially relevant to pay telephones. For example, in Canada it is common for a payphone user to hear a prompt within a few seconds of lifting a payphone’s handset. If no user response is recorded (for example, inserting coins or a calling card), dial tone service to the payphone is terminated, and the user must hang up and start over. A user with a motor impairment, or perhaps one with a visual impairment, may be unable to satisfy the timing demands of the network, and so will effectively be blocked from making a telephone call. Under Section 255 of the US Telecommunications Act of 1996, this situation is prohibited, as noted in the guideline quoted above; however, no such protection exists in Canada, to our knowledge.

Some telephones (such as the Ameriphone JV-35; see Appendix A) have Braille labels on jumbo-size buttons, which may be useful for users proficient in Braille. Others (such as the Panasonic KX-TG2386B) speak individual digits as they are being dialled, either directly or via a pre-dial function.

As a general design comment, we note that telephones with a pre-dial capability enable the user to dial the number in its entirety before sending the digit stream to the network for processing. This solution is effective for avoiding "lock-out" by the network, but as far as we know it has not been implemented in pay telephones in Canada.

4.3.2.5.2 Selecting the "Redial" button

Unless the visually impaired user knows where the "Redial" button is located on each telephone that he or she uses, this function is likely inaccessible to persons with a visual disability.

The Panasonic KX-TG2386B offers a redial function that speaks the digits of the number being re-dialled.

Cell phones that offer voice dialling may seem to offer greater accessibility. However, prompts that are display-based may be inaccessible to someone with a visual impairment.

4.3.2.6 Verifying the number selected

On some residential (e.g., Vista 350) and business phones, the display shows the number selected before the number is dialled. If this information is only display-based, it will be inaccessible to many people with visual impairments.

The Panasonic KX-TG2386B speaks individual digits in a pre-dial function, verifying the digits before they are sent to the network.

4.3.2.7 Verifying the number dialled

On some residential (e.g., Vista 350) and business phones, the display shows the number dialled. Obviously, if this information is only display-based, it will be inaccessible to many people with visual impairments.

The Panasonic KX-TG2386B, available in the US, provides voice announcements that "speak" the name associated with various dialling functions (see Appendix A).

4.3.3 Phone management

The topic "Phone Management" deals with management of features on the telephone itself, as opposed to those resident in the switch or the network. It is possible, and in some cases perhaps likely, that the end-user may not know where the feature resides. However, for this category we are concerned with functionality accessible to the user, and specifically with functionality under the design control of the terminal manufacturer.

We have identified 10 specific tasks related to phone management:

  1. verify the alert mode (e.g., light, ringer);
  2. adjust the alerter (intensity, cadence);
  3. terminate a call;
  4. save (store) call information;
  5. manipulate stored information;
  6. locate the telephone itself;
  7. orient to non-dialpad buttons;
  8. programme autodial buttons;
  9. adjust the receive volume (either speakerphone, handset, or headset); and
  10. verify the status of the phone (on/off).
4.3.3.1 Verifying the alert mode

Most business and residential telephones have an audible ringer, which may or may not be accompanied by a visual ringer (light) or a vibrating alerter. In some cases it may be desirable to turn off one mode or the other (for example, setting a cell phone to "Silent" (or vibrate) mode when in a meeting).

To our knowledge, all phones that permit one or more modes of alerter to be turned on and off inform the user of this status through a display-based interface, which may be inaccessible to persons with a visual disability. An example of this is the AT&T 5870.

4.3.3.2 Adjusting the alerter

On many telephones, the alerter can be adjusted in volume (amplitude) or cadence, or both. On telephones such as the Vista 350, adjustment of the cadence and volume is achieved through a display-driven interface, which will be inaccessible to many persons with a visual impairment. However, for the ring volume there is also a hardware-based toggle switch that can be used to adjust the ring volume, or the handset volume or speakerphone volume, while the phone is in that particular mode. Once this switch is located, it is equally accessible to sighted and visually impaired persons.

Other than hardware-based solutions such as this, or the ringer knob on older telephones, we know of no telephone that provides an alerter solution that is accessible to persons with a visual disability.

4.3.3.3 Terminating a call

When using a handset, a call may be terminated by replacing the handset in the cradle. This solution is accessible to sighted users as well as to those with a visual disability.

If the user is on a handsfree call, the call can be terminated by pressing a button on the telephone, either "Release", "Goodbye", or some other button. Because it may be difficult to locate the button, especially for users with a visual impairment, an alternative mechanism for terminating the call is to lift the handset from the cradle (which switches the call to the handset), then replace the handset in the cradle.

In the case of a cordless handset, the user must press a button to turn the handset on and off. If this button is not labelled or located distinctively in a non-visual manner, this task could be inaccessible to some persons with a visual disability.

4.3.3.4 Saving (storing) call information

Different models of telephone have different mechanisms for storing call information. In some cases, information is stored automatically (e.g., in a Callers List) without user involvement; in other cases, the user can add information to a Phone Book stored in the phone. It is possible that some phones provide display-based prompts, which may not be accessible to users with a visual disability; in other cases, the user must learn the procedure from a manual.

We know of no telephone that provides audible prompts to guide the user through this operation.

4.3.3.5 Manipulating stored information

Different models of telephone have different mechanisms for editing stored information (e.g., modifying or deleting an entry). It is possible that some phones provide display-based prompts, which may not be accessible to users with a visual disability; in other cases, the user must learn the procedure from a manual.

We know of no telephone that provides audible prompts to guide the user through this operation.

4.3.3.6 Locating the telephone itself

For the user to be able to make use of the telephone, it is necessary to locate it. If the user is locating the phone to answer a call, the ringer provides guidance to its location. If the user is trying to locate the phone to initiate a call, we know of no mechanism to help locate the phone.

It is common for residential subscribers with cordless phones to misplace the cordless handset. Cordless telephones are typically equipped with a "locator" function; pressing a button on the base of the phone causes the handset to beep. Once the button has been located on the base, this function is equally accessible to sighted and visually impaired users.

4.3.3.7 Orienting to non-dialpad buttons

Although various international standards specify the presence of a "pip" on the 5 button of the dialpad, we know of no standard that specifies the configuration of any non-dialpad buttons on a telephone. A telephone faceplate may consist of a dialpad, dedicated feature buttons, autodial buttons, and perhaps other buttons. Moreover, different manufacturers and different models will use different button sizes, shapes, colours, and layout configurations.

In the absence of a specialised labelling scheme, non-dialpad buttons may be inaccessible to users with visual disabilities. We know of no telephone that provides tactile or spoken labels for non-dialpad buttons.

4.3.3.8 Programming autodial buttons

Different models of telephone have different mechanisms for programming autodial buttons. Some models of telephone provide display-based prompts, which may not be accessible to users with a visual disability.

To our knowledge, most models provide no feedback to the user during this operation; rather, the user must learn the method from a manual or from a help line. If the manuals are paper-based, they are likely inaccessible to some users with a visual disability. Although we are not aware of manuals provided on CD-ROM or in an accessible format, they may exist.

We know of no telephone that provides audible prompts to guide the user through this operation.

4.3.3.9 Adjusting the receive volume

Many telephones (e.g., Vista 350 and many others) provide a context-sensitive mechanism for adjusting the receive volume of the signal. That is, while the user is on a call, it is possible to use a hardware-based toggle switch to adjust the volume up or down. If the user is using the handset, the handset receive volume is adjusted; if the user is on a handsfree call, the handsfree receive volume is adjusted. Once the toggle switch has been located, this solution is equally accessible to sighted and visually impaired users.

Several phones exist which provide strong amplification of the receive signal for persons with a hearing impairment. Some of these phones are listed in Appendix A; many are manufactured by Clarity / Ameriphone.

4.3.3.10 Verifying the status of the phone

Most telephones are always "on", in the sense that they are always ready to receive a call or to be used to initiate a call by (say) lifting the handset. However, to keep the line free it is common for cordless handsets to be "off". That is, to make a call with a cordless handset the user must first press a button on the handset. This button is typically labelled in a way that may not be accessible to users with a visual disability.

Cell phones may be in "off", "locked" or "on" mode. If the cell phone is "on", pressing a button on the cell phone to initiate a call may provide audible feedback. However, if the phone is "off", no feedback is given. If the cell phone is in "locked" mode, there may also be no audible feedback, although a display-based prompt will tell the user how to unlock the phone. Obviously, the display-based prompt may be inaccessible to users with a visual impairment. Moreover, the absence of audible feedback when the cell phone is "off" and when it is "locked" implies that a visually disabled user may not know whether or not the phone is powered up.

Many phones also provide an audible indication of a low battery charge.

4.3.4 Call management

We have identified 3 specific tasks related to call management. These tasks occur during an existing call, and so are separate from receiving a call. (Note that, as with the other categories, other specific tasks may be added to this category as time goes by.)

The case of Call Waiting straddles these two categories, and so deserves special mention. Because Call Waiting can only occur during an existing call, it could be seen as falling into the category of "Call Management". However, we have opted to include Call Waiting in the category of "Receiving a Call", because it implies the acquisition of information related to a new call, as well as actions to accept the new call.

However, we accept that there may be differing points of view. In any case, the intent here is to ensure that all the potential specific tasks are included; where they fall in the matrix is of secondary importance.

The specific tasks included here are:

  1. accessing and using features where the user interface is a dedicated button (such as "Hold");
  2. accessing and using features where the user interface is a software code (or series of button-presses, such as *69); and
  3. accessing and using features where the user interface is a softkey, a physical button associated with a label on the display that can change depending on the context.

In choosing this categorisation scheme, we have deliberately chosen to use operational definitions of the tasks rather than consider a long list of features individually. We believe that all features can be utilised via one of the three options listed above.

4.3.4.1 Accessing and using features via a dedicated button

The layout of non-dialpad buttons on a telephone is not determined by standards, and so will vary from model to model. In the absence of tactile or spoken labels for feature buttons, these buttons may largely be inaccessible to persons with a visual disability. While it is possible for a user to learn the location of specific buttons, this learning will not transfer if they change phone models.

4.3.4.2 Accessing and using features via a software code

The use of software codes (such as *69) to access features requires that the user be able to locate the digits on the dialpad and remember the code. Because the layout of buttons on the dialpad is determined by standards (orienting to the "pip" on the 5 button), locating the correct buttons is feasible for users with a visual disability. Remembering the codes is a task of comparable difficulty for sighted users and users with a visual disability.

4.3.4.3 Accessing and using features via a softkey

A softkey is a physical button (or key) whose label appears on a display next to the button. By definition, the label of the softkey – and the softkey’s function – differs depending on the status of the telephone, so although the physical button remains the same, its display-based label, and its function, vary from condition to condition.

To our knowledge, all softkey-based telephones (e.g., Norstar 7310, Vista 350) rely on a display to label the softkeys, and none provide audible feedback to the user. By definition, it is not possible to label softkeys with a tactile label, because the label changes depending on the context. Therefore, in the absence of audible labels, the softkey solution may not be accessible to persons with a visual disability.

4.3.5 Voice mail

We have identified 7 specific tasks related to voice mail. In some cases (2 tasks), the task involves leaving a voice message for another person; in the other 5 cases, it involves retrieving messages from one’s own voice mail account, or otherwise managing the voice mail account.

In the case of accessing one’s own account, it is necessary for the user to make a telephone call first. The specific tasks related to this call are included in the general category "Making a call". Following this initial call, the 2 specific tasks related to leaving a voice message for another person are:

  1. leave a voice message; and
  2. manipulate the message you have left.

The 5 specific tasks related to accessing one’s own voice mail account are:

   c.    detect an incoming message;
   d.    retrieve the message;
   e.    obtain information about the message;
   f.     manipulate the incoming message; and
   g.    administrative function (set greeting, change password).

In the United States, Section 255 of the Telecommunications Act of 1996 has recognised the possibility that certain voice mail systems may "time out" someone who cannot process information or provide responses quickly enough. Specifically, Paragraph 102 of Section 255 states, in part,

The time allowed for a person to input the necessary numbers to retrieve voicemail messages, select an option from a list of choices or control the other functions may be too short for people with motor disabilities, or people who are blind. In these instances, although the phone call may be completed in the technical sense of terminating the call, the call is not accessible to the person.

This concern has been addressed in the Accessibility Guidelines issued by the (US) Access Board. Specifically, paragraph (d) of Section 1194.23 states:

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

In the present section, we have made the assumption that voice mail systems operable in Canada will be identical to those in the US, where these products are subject to sanctions under Section 255. However, we acknowledge the possibility that this assumption may be flawed and note that, to the extent that it is flawed, the possibility exists that voice mail systems may be generally inaccessible to persons with a visual disability.

4.3.5.1 Leaving a voice message

When a user calls another person and the call is answered by a voice mail system, the system provides a greeting that advises the caller how to leave a message (e.g., "At the tone, please leave a message."). There are two potential tasks here:

4.3.5.1.1 Leaving a message

The task requirements for leaving a message are simply to wait for the tone, then speak the message, hanging up when the message is complete. We see no accessibility issue here for a person with a visual disability.

4.3.5.1.2 Skipping the greeting

It is possible that the user does not want to wait for the voice-mail greeting, for example if the call is a long-distance call or if the caller is in a hurry. Some voice mail systems (but not all) permit the user to press a key (such as #, the pound sign) to bypass the greeting and go straight into voice mail. This hint is not part of the prompt delivered by the system, and as far as we know it is no more discoverable for a sighted person than it is for a person with a visual disability.

As long as the user can orient to the dialpad (see Section 4.2.2.2.1, above) and can hear the prompts delivered by the voice mail system, we see no accessibility issue here for persons with a visual impairment.

4.3.5.2 Manipulating the message you have left

Sometimes when a user has left a voice message for someone, the system presents the user with options for manipulating the message; these options may include:

In each case, these tasks are performed using the dialpad. Thus, as long as the user can orient to the dialpad (see Section 4.2.2.2.1, above) and can hear the prompts delivered by the voice mail system, we see no accessibility issue here for persons with a visual impairment.

4.3.5.3 Detecting an incoming message

The remaining 5 specific tasks in this section deal with use of one’s own voice mail account.

The first task, detecting an incoming message, may be completed in several ways:

Although a person with a visual impairment may not be able to see the flashing light (depending on the type and severity of the impairment), the other two alerting mechanisms are equally accessible to persons with and without a visual impairment. Hence, we see no evidence of a general lack of accessibility related to this task.

4.3.5.4 Retrieving the message

Once the user has detected that there is a message waiting, it is necessary to follow the correct steps to retrieve the message. Typically, these steps are prompted by the voice mail system itself, using a prompt such as, "You have 2 new messages. Check unheard messages, press 11. Listen, press 1," and so on.

As long as the user can orient to the dialpad (see Section 4.2.2.2.1, above) and can hear the prompts delivered by the voice mail system, we see no accessibility issues for persons with a visual impairment.

4.3.5.5 Obtaining information about the message

Typically, the voice mail system provided by telcos for residential subscribers provides information to the user about the call at the time that the message is received, using a prompt such as, "The following message was received from an external number at 3:15 p.m. on Thursday 15 July." This information can be repeated by pressing the 5 button (or equivalent).

As long as the user can orient to the dialpad, we see no accessibility issue here for persons with a visual impairment.

4.3.5.6 Manipulating the incoming message

The user may perform various actions related to a voice message, including replaying it, deleting it, forwarding it, and re-saving it. For residential subscribers, the voice mail system typically delivers prompts, such as:

As long as the user can orient to the dialpad (see Section 4.2.2.2.1, above) and can hear the prompts delivered by the voice mail system, we see no accessibility issues for persons with a visual impairment.

4.3.5.7 Handling administrative functions

Anyone with a voice mail account will know that there are several administrative options, such as determining the number of rings before the call goes to voice mail, setting a password, changing the password, and so on. The subscriber is greeted with a prompt such as, "Listen, press 1. Send, press 2. Check receipt, press 3. Personal options, press 4. To disconnect, press star."

Pressing "4" leads the subscriber into another menu equipped with prompts. As with other voice mail functions, as long as the user can orient to the dialpad (see Section 4.2.2.2.1, above) and can hear the prompts delivered by the voice mail system, we see no accessibility issues for persons with a visual impairment.

However, it may possible that a subscriber would want to choose a password based on a name or another word, rather than a number; for example, the user may want the password to be his or her mother’s maiden name. Because the letters on the dialpad would normally be inaccessible to a person with a visual disability, this could be considered an example of an inaccessible function.

Clause 4.5.5 of TIA/EIA TR41.3.5 specifies that if "the telephone dial or keypad is provided with alpha characters, they shall be assigned" in a specified fashion. CSA standard T510-95, which concerns lettering on the dialpad, has been harmonised with ANSI/TIA/-470-B-1997.

4.3.6 Account management

The general domain of account management has traditionally been paper-based. More recently, it has become possible to perform some of these functions electronically, using either a computer or telephone to access the functionality (or "intermediate" devices, such as a personal digital assistant, or PDA).

We have identified 2 specific tasks related to account management. They are:

  1. receive billing information; and
  2. receive promotional information.

It is not the intent of the present document to specify the particular means of accessing these types of account-based information, except to note that CRTC orders have directed that both types of information be available in alternative format. Specifically, the following Orders are relevant:

4.3.7 User support

As implied in the introduction to this section (Section 4.1), there could be several reasons why a user may not be able to complete a task related to use of the telephone network. For example:

Consumer electronic goods, including telephones, are rarely sold without some form of material to help the user understand how the product can be used successfully. This additional material, often called a "manual" or "user guide", can take several forms.

4.3.7.1 Types of support

There are several options for delivering support to the prospective user of the product. These options include:

For a consumer product such as a telephone, a paper manual provided in the box may be the most common delivery mechanism for user support. Although provision of a CD-ROM is possible, we do not know of any example of this being done for a consumer telephone. Likewise, we do not know of vendors providing audiocassettes.

Telephone vendors may provide a customer-service or help line which customers can phone for assistance. However, vendor training, because of its cost and logistical requirements, is typically done only for business telephone systems, if at all.

The web provides a good medium for delivering support, either through web pages dedicated to this purpose or through a means for requesting a user guide.

4.3.7.2 The accessibility of different support mechanisms

In this section, we briefly consider different means of providing support for the use of a telephone in terms of accessibility for persons with a visual disability.

4.3.7.2.1 "In the box" materials

Paper manuals will be inaccessible to many persons with a visual disability. For reasons of cost and bulk, it is unlikely that "the box" would include alternate-format printed materials (large print, Braille). Thus, a "default" paper user guide delivered with the telephone is unlikely to be accessible to all persons.

Information on a CD-ROM would be accessible to anyone with access to a suitably equipped computer, providing the files were in a format that could be accessed by a screen reader.

Information on audiocassettes would be accessible to anyone with a cassette player. However, for reasons of cost and bulk, audiocassettes are unlikely to be shipped with all telephones.

4.3.7.2.2 Requestable "hard-copy" materials

Although requesting support materials places a burden on the purchaser, manufacturers or vendors may make hard-copy support materials available on request. Obviously, the degree to which they are accessible to a person with a visual impairment will depend on the format of the manual.

4.3.7.2.3 Live help

Acknowledging that vendor training is unlikely to be provided, the delivery option for live help is a customer support line. Assuming that information about the number to be called is itself accessible to a person with a visual disability, the delivery of help via telephone should be accessible to this person, also.

4.3.7.2.4 Web-based support

Web-based support will only be accessible to someone who has access to a computer. In addition, for persons with a visual disability, the computer must be equipped with a screen reader or other accessibility features. Such a computer could be the user’s own machine, a publicly available machine (such as a Web-4-All terminal; see ), or some other machine.

Assuming that the consumer can use a computer to access the website, the format of the support material can also affect its accessibility, as described briefly below:

5 Accessible telephones

The previous sections have looked at the legislative environment in different jurisdictions (Section 3) and a task-based functional analysis of telephone usage (Section 4). The present section looks at accessible telephone terminals in two ways that have not been considered earlier.

The first analysis (Section 5.1, "Buyer’s guides") looks at material from a variety of organisations that are concerned with accessibility and telecom. Each of the organisations selected has prepared, in some form, what might be considered a "buyer’s guide" which, in principle, helps persons choose an accessible telephone. These "buyer’s guides" are summarised in Section 5.1.

Almost all of the analysis in the earlier sections of the report deals with residential telephones. By contrast, Section 5.2 focuses on business telephones, in recognition of the fact that many persons with visual disabilities may have, or be looking for, jobs in companies that use proprietary telephone systems (i.e., key systems or PBXs).

5.1 "Buyer’s guides"

It is not the role of the present report to evaluate products in terms to their compliance to particular design standards. However, we take the opportunity here to identify sources from diverse backgrounds, each of which can be seen as a sort of "buyer’s guide" to help consumers select telephones in terms of their accessibility.

5.1.1 American Foundation for the Blind (AFB)

On its website (www.afb.org/info_document_view.asp?documentid=1536), the American Foundation for the Blind (AFB) has placed a document entitled "How to get an accessible telephone". This document opens with the following wording:

Section 255 for People Who Are Blind or Visually Impaired

Telephones and telephone services must be accessible. It's the law.

The AFB also maintains, on its website, a page with links to the Section 255 pages of telephone manufacturers (www.afb.org/info_document_view.asp?DocumentID=1702). At the time of writing, the only manufacturers listed on this page were Motorola, Nokia, Panasonic, Sony-Ericsson, and Toshiba.

With respect to cell phones (addressed in Appendix B of the present report), the AFB TECH group reported (www.afb.org/afbpress/pub.asp?DocID=AW040302) that:

we first surveyed 20 cell phone users who are blind or visually impaired to determine which features they would most like to have made accessible. The survey used a questionnaire that asked respondents about cell phone use and their opinions of their current telephones. The questionnaire listed 40 cell phone features, which respondents were asked to rate from 1 to 5. A low number indicated that the feature had little or no importance to the respondent, and a high number meant that it would be extremely important for that feature to be accessible. The 16 highest-rated features, representing 40% of the features surveyed, all scored an average rating of 4.0 or higher.

This effort "resulted in the "Sweet 16," a list of 16 features that were rated the highest by the respondents" (www.afb.org/Section.asp?DocumentID=2419). The list is shown below; the top three features were tied for first place.

  1. Keys that are easily identifiable by touch
  2. Voice output
  3. Accessible documentation
  4. Battery-level indicator
  5. Roaming indicator
  6. Message indicator
  7. Phone book
  8. Phone lock mode
  9. Keypad lock mode
  10. Power indicator
  11. Ringing or vibrating mode indicator
  12. GPS feature
  13. Signal strength indicator
  14. Ringer volume control
  15. Caller identification
  16. Speed dialing

Although somewhat inferential, in the absence of primary evidence to the contrary it seems sensible to argue that a similar set of features would be tied for first place for wireline phones, as well.

5.1.2 BT (British Telecom)

To help guide persons with visual disabilities in making a choice of telephone, BT (www.btplc.com/age_disability/AccessibleProducts/ClearerCommunication/Features/Indexv1.htm) suggests features to look for:

5.1.3 Royal National Institute of the Blind (RNIB)

In 2004, the RNIB issued a booklet entitled Access-Ability: Making technology more useable by people with disabilities. Chapter 12 of this booklet, entitled "Telecommunications", looks at several aspects of telecommunications in the modern world, including the implications for persons with disabilities.

The guidelines, taken from the Tiresias effort (www.tiresias.org/guidelines), cover 8 topics:

Rather than being a detailed technical treatment of these issues, the booklet uses well chosen photographs and brief textual descriptions to illustrate some of the guidelines, and their implications for accessibility, related to:

5.1.4 Tiresias / COST 219bis

Tiresias is an organisation, centred in Europe but extending beyond it, which is dedicated to making telecommunications more accessible. The objectives and membership (which includes the US, but not Canada) are described (www.tiresias.org/telecoms/glo.htm):

The main objective of COST 219bis is to increase the availability of telecommunication services and equipment so that they are accessible to disabled and elderly people. These services and equipment should be designed so that the special needs are taken into account, but if this is not possible they could also be made more adaptable to meet the required needs. In cases where neither of these can be achieved, the action will propose appropriate supplementary services and equipment. The aim is therefore to make sure that the universal design concept in one form or another is taken into account when dealing with telecommunications and Telematics.

The Action also seeks to promote research into the field of telecommunications and Teleinformatics with the aim of proposing solutions to the problems related to the needs of disabled and elderly people in providing access to new telecommunication and Teleinformatic services.

The signatory members in COST 219bis are Australia (GSA), Austria, Belgium, Denmark, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Netherlands, Norway, Portugal, Slovenia, Spain, Sweden, Switzerland, United Kingdom and United States of America (TRACE).

Tiresias / COST219bis is an excellent source for locating standards and guidelines from a wide variety of jurisdictions (www.tiresias.org/guidelines/standards.htm). (COST is an acronym for Co-Operation in the field of Scientific and Technical Research.)

The Tiresias / COST219 website has several sections:

Below, we look at "telephones" and "public telephones".

5.1.4.1 Telephones

The webpage dedicated to telephones (www.tiresias.org/telecoms/tel.htm) provides a graphic illustration of an accessible telephone, with design guidelines positioned appropriately. As noted on this webpage, more detailed guidelines can be found at www.tiresias.org/phoneAbility/telephones. Briefly, the guidelines include:

The PhoneAbility website is a very valuable source of information about the types of telephone features that will help make telephones more accessible. (One of the driving forces behind PhoneAbility is Dr. John Gill, Chief scientist of the Royal National Institute of the Blind in the UK.)

5.1.4.2 Public telephones

Consistent with the format of the "Telephones" model, the Public telephones page has a schematic of an accessible pay telephone, with design guidelines arranged around the graphic. Accessibility features extend to smart cards or payment cards, which have a notch in one side to help orient the card correctly.

Components include:

Detailed guidelines can be found at www.stakes.fi/cost219/payphones.htm, which contains a COST 219bis guidebook entitled Payphones with immediate public access.

5.1.5 Tiresias / COST 219ter

COST 219ter is, like the COST 219bis effort, focused on accessibility of technology. However, whereas COST 219bis is concerned with more traditional telecom, COST 219ter looks at "services and terminals for next generation networks" (www.tiresias.org/cost219ter/).

The mission statement on the website reads:

The main objective of the Action is to increase the accessibility of next generation telecommunication network services and equipment to elderly people and people with disabilities by design or, alternatively, by adaptation when required.

In cases where this cannot be achieved, the Action will aim at promoting the establishment of appropriate supplementary assistive services and equipment.

Taking always into account the "Design for All" concept in telecommunications and teleinformatics, especially in the mobile field, the objectives of the Action can be specified in operational terms as follows:

so that

The COST 219ter site contains the guidelines for a pay phone, but that has already been considered above (COST 219bis), and will not be repeated here. However, the COST 219ter site has an excellent list of references not just for telecom, but also for parallel technologies, such as smart cards, smart housing, and other devices and systems.

5.2 Business telephones: proprietary telephone systems

Most of the material presented in the earlier parts of this report focus primarily on residential telephones, which are connected directly to a telephone line from a central office switch. By contrast, many business environments – and especially larger businesses, with 10 or more employees – use telephones that are part of a proprietary telephone system, either a key system or a private branch exchange (PBX).

5.2.1 Section 255 of the (US) Telecommunications Act

It may be recalled that Section 255 of the (US) Telecommunications Act of 1996 requires that telecom equipment be accessible to persons with disabilities. The Section 255 website (www.fcc.gov/cgb/dro/section255.html, part of the website of the US Federal Communications Commission) contains a list of equipment manufacturers wishing to sell telecom equipment in the United States (www.fcc.gov/cgb/dro/section255_manu.html), providing the Section 255 contact information for each company.

There are many manufacturers of proprietary business telephone systems. In North America, major manufacturers include Avaya, Cisco Systems, Nortel Networks, and Siemens, among others. Because it may be expected that the products offered by these companies will change across time, rather than considering their product portfolios we have opted to note that telecom equipment manufacturers must comply with Section 255.

5.2.2 Section 508 of the (US) Rehabilitation Act and the VPAT

In addition, any manufacturer wishing to sell telecom equipment to the US federal government must comply with Section 508 of the (US) Rehabilitation Act. As noted earlier, Section 508, "effective June 21, 2001, requires Federal departments and agencies that develop, procure, maintain, or use electronic and information technology to assure that these technologies provide access to information and data for people with disabilities."10 Our approach here is to describe the tools used to determine accessibility.

For equipment manufacturers to report consistency with Section 508 guidelines, the Information Technology Industry Council (ITIC) makes available a form called the Voluntary Product Accessibility Template, or VPAT (version 1.1, 8/3/01). Version 1.1 (8/3/01) of this form can be viewed on-line at www.itic.org/policy/vpat.html. The VPAT contains several sections, each related to a particular type of product or (in the case of Section 1194.31) to the functional performance criteria overall:

Each of the sections listed above includes a number of specific evaluation criteria. Below, we have provided the wording (from ITIC) on the VPAT forms for two sections which have a direct relevance to traditional telecom equipment. The specific criteria are described below for each of these sections:

5.2.2.1 Section 1194.23: Telecommunications Products

The evaluation criteria listed for Telecommunications Products include:

(a) Telecommunications products or systems which provide a function allowing voice communication and which do not themselves provide a TTY functionality shall provide a standard non-acoustic connection point for TTYs. Microphones shall be capable of being turned on and off to allow the user to intermix speech with TTY use.
(b) Telecommunications products which include voice communication functionality shall support all commonly used cross-manufacturer non-proprietary standard TTY signal protocols.
(c) Voice mail, auto-attendant, and interactive voice response telecommunications systems shall be usable by TTY users with their TTYs.
(d) Voice mail, messaging, auto-attendant, and interactive voice response telecommunications systems that require a response from a user within a time interval, shall give an alert when the time interval is about to run out, and shall provide sufficient time for the user to indicate more time is required.
(e) Where provided, caller identification and similar telecommunications functions shall also be available for users of TTYs, and for users who cannot see displays.
(f) For transmitted voice signals, telecommunications products shall provide a gain adjustable up to a minimum of 20 dB. For incremental volume control, at least one intermediate step of 12 dB of gain shall be provided.
(g) If the telecommunications product allows a user to adjust the receive volume, a function shall be provided to automatically reset the volume to the default level after every use.
(h) Where a telecommunications product delivers output by an audio transducer which is normally held up to the ear, a means for effective magnetic wireless coupling to hearing technologies shall be provided.
(i) Interference to hearing technologies (including hearing aids, cochlear implants, and assistive listening devices) shall be reduced to the lowest possible level that allows a user of hearing technologies to utilize the telecommunications product.
(j) Products that transmit or conduct information or communication, shall pass through cross-manufacturer, non-proprietary, industry-standard codes, translation protocols, formats or other information necessary to provide the information or communication in a usable format. Technologies which use encoding, signal compression, format transformation, or similar techniques shall not remove information needed for access or shall restore it upon delivery.
(k) (1) Products which have mechanically operated controls or keys shall comply with the following: Controls and Keys shall be tactilely discernible without activating the controls or keys. (2) Products which have mechanically operated controls or keys shall comply with the following: Controls and Keys shall be operable with one hand and shall not require tight grasping, pinching, twisting of the wrist. The force required to activate controls and keys shall be 5 lbs. (22.2N) maximum. (3) Products which have mechanically operated controls or keys shall comply with the following: If key repeat is supported, the delay before repeat shall be adjustable to at least 2 seconds. Key repeat rate shall be adjustable to 2 seconds per character. (4) Products which have mechanically operated controls or keys shall comply with the following: The status of all locking or toggle controls or keys shall be visually discernible, and discernible either through touch or sound.

5.2.2.2 Section 1194.31: Functional Performance Criteria

The evaluation criteria listed for Functional Performance Criteria include:

(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.
(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.
(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.
(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.
(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.
(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.

The United States federal government provides a "buyer’s guide" in relation to Section 508 acquisitions. This guide is available on-line, and (as at the time of writing this report) features such items as:

The guide can be found at www.section508.gov/index.cfm?FuseAction=Content&ID=87.

5.2.3 Manufacturer statements of compliance

Each telecom equipment manufacturer hoping to sell equipment to the federal government is required to complete the VPATs for their equipment. These VPATs are usually posted on the manufacturer’s website.

The VPATs listed below are available for review. Note that we have chosen these as examples, and that others are available on these manufacturers’ websites.

5.2.4 Accessibility Forum

As described on its website (www.accessibilityforum.org), the Accessibility Forum "began in May of 2001 as an ongoing collaboration among stakeholders affected by Section 508 including user, industry, government, and other communities. The Forum membership includes over 640 organizations from industry (electronics, information technology, and assistive technology), associations for people with disabilities, the research community (academia, research institutions, and standards groups), and government agencies. The General Services Administration (GSA) has been the initial sponsor for the Forum."

In February 2004, the Accessibility Forum announced the availability of a new tool (the "Buy Accessible Wizard") designed "to assist procurement decision makers to determine the relevance of Section 508 and the applicability of the specific sections of the Standard to each acquisition". At the time of writing, this Wizard is undergoing beta testing.

5.3 Identifying accessible telephones: a "buyer’s guide"

The Tiresias website (http://www.tiresias.org/phoneability/telephones/blindness.htm), in combination with the UK-based PhoneAbility effort, identifies "essential features" and "desirable features" of telephones for use by persons with three types of visual impairment:

The features are listed below. Following this list, we have drawn on the material in Appendix A as well as the Tiresias / PhoneAbility features to create a matrix indicating which telephones available in North America meet particular accessibility criteria.

5.3.1 Features for each disability category

The material presented below is taken from the Tiresias website.

5.3.1.1 Features for users who are blind

The Tiresias website lists the following 8 features as essential for persons who are blind. The definitions that follow each term are also from the Tiresias website.

In addition, the following 2 features are listed as desirable for persons who are blind:

5.3.1.2 Features for users with a severe visual impairment

The Tiresias website lists the following 9 features as essential for persons with a severe visual impairment. Here, definitions (from Tiresias website) are provided for those terms not defined above.

In addition, the following 4 features are listed as desirable for persons with a severe visual impairment:

5.3.1.3 Features for users with a moderate visual impairment

The Tiresias website lists the following 6 features as essential for persons with a moderate visual impairment (all items have been defined above):

In addition, the following 4 features are listed as desirable for persons with a moderate visual impairment:

5.3.2 Matching accessibility features to equipment

In the present section, we have attempted to determine the accessibility of telephones that are currently available to Canadian users. This analysis required that we select a set of telephones and match their features against an "accessibility template" to determine how accessible each telephone truly is. Thus, it was necessary to establish criteria for selection of telephones; equally important, it was crucial to use accepted criteria for accessibility. Both of these tasks are described below.

The "buyer’s guide" that resulted from this effort is obviously dependent on the amount and detail of information available on the websites which served as the sources for information about telephones, and so the present guide should be taken to be indicative of the availability of descriptions of accessible telephones rather than as a definitive guide to accessible telephones, which in any case would change as new models are introduced.

5.3.2.1 Accessibility criteria

For the present exercise, we have used as a template the Tiresias list of "essential" telephone features for blind persons. As noted above, Tiresias publishes separate lists of "essential" and "desirable" features for persons who are blind, who have a severe visual impairment, and who have a moderate visual impairment. Because the present exercise looks only at "essential" features for blind users, it is obviously a subset of a more complete analysis which could be performed.

The 8 features listed by Tiresias as "essential" for blind users are:

5.3.2.2 Identifying the telephones

For this analysis, we selected telephones that are listed as accessible equipment on the websites of major Canadian telephone operating companies (telcos; see Appendix A), as well as some telephones available in North America from one manufacturer (Panasonic) and three US distributors of assistive equipment. Below, we list the telephones, and the sources of the information about them.

5.3.2.2.1 Manufacturer data: Panasonic

We obtained information from www.panasonic.ca concerning two cordless telephones11:

For simplicity, we have included only one of these in the analysis, selecting the phone without the answering machine.

However, as an indication of future developments from this manufacturer, and perhaps others, we have also included data on the KX-TG2386B, a pre-release model shown at the CSUN conference12 in March 2004.

5.3.2.2.2 Distributor data

We obtained data from the US distributor Independent Living Aids, whose products are presented in more detail in Appendix A.1. Independent Living Aids distributes Panasonic telephones identical (or similar) to those identified in Section 5.3.2.2.1 (above), which are not considered here.

Here, we include data from two telephones:

5.3.2.2.3 Telco data13
5.3.2.2.3.1 Aliant

We could not find any information about accessible telephones on the Aliant website (www.aliant.ca), including searches for Nova Scotia and New Brunswick.

5.3.2.2.3.2 Bell Canada

We found two relevant telephones on the Bell Canada site (www.bell.ca):

5.3.2.2.3.3 MTS

The MTS website (www.mts.ca) contains one non-TTY telephone which has relevant accessibility features: the Dialogue XL-40. This telephone is available as a rental for $8.95 per month.

5.3.2.2.3.4 SaskTel

The SaskTel website (www.sasktel.com) lists one telephone for persons with a visual disability, the Big Button Telephone (GE2-9268) ($39.95).

5.3.2.2.3.5 Telus

We could not find any information about accessible telephones on the Telus website (www.telus.ca).

5.3.2.3 The analysis

Below, we present the results of this comparative analysis in two forms: in a table (Table 4), and in narrative form. Table 4 is constructed in such a way that each of the telephones is a row of the table and each "essential" attribute from Tiresias is one column. Thus, one can scan across each row to see how well each telephone meets the Tiresias criteria, and by scanning down each column it is possible to determine, based on the descriptions available, which telephones offer each feature.

In total, there are two "manufacturer" telephones (Panasonic KX-TG2386B, which is not yet released, and KX-TG2336S), two "distributor" telephones (AT&T corded phone with Talking Caller ID, Ameriphone JV-35), and a total of 3 accessible telephones from 5 Canadian telcos (Ameriphone P-300 Photo Phone, Ameriphone Dialogue XL-40, Big Button Telephone GE2-9268), for a total of 7 telephones in this analysis.

To prevent redundancy, we note here that all telephones included in the analysis have standard key layouts on the dialpad, meeting one of the Tiresias criteria. However, none of the phones has a tactile display or a plug-in display.

5.3.2.3.1 Scoring the telephones

Panasonic’s pre-release model KX-TG2386G does not have enlarged keys or tactile key markers. However, it does have synthetic speech display for Caller ID, a phone book, the dialpad, and speed dial and redial functions. There is also dial-out buffer memory for both pre-dial and redial. Finally, there is audible key feedback for the dialpad and for the redial and pre-dial functions. Thus, this phone has a score of 4 out of a possible 8.

The Panasonic KX-TG2336S, available in Canada, offers Talking Call Display in addition to the standard key layout on the dialpad, for a score of 2 out of a possible 8.

The AT&T model 1818 corded phone, available from a US distributor, has Talking Caller ID in addition to the standard key layout on the dialpad, for a score of 2 out of a possible 8.

The Ameriphone JV-35, available from a US distributor, has enlarged dialpad keys, Braille labels on the dialpad, and audible key feedback on the dialpad. Combined with standard key layout on the dialpad, this phone has a score of 4 out of a possible 8.

The three phones available from Canadian telcos – the Ameriphone P-300 Photo Phone, the Ameriphone Dialogue XL-40, and the GE9268 Big Button Telephone – each have standard key layout on the dialpad, plus enlarged dialpad keys. Thus each of these phones has a score of 2 out of a possible 8. (It should be noted here that these and other phones available from Canadian telcos offer other accessibility features, for example for persons who are hard of hearing. However, the present analysis examines only those features for persons who are blind.)

5.3.2.3.2 Summary

No phone included in the present analysis has more than 4 out of the 8 features identified by Tiresias as "essential" for blind users.

Of the commercially available phones, the Ameriphone JV-35, available from a US distributor for US$79, has the most "essential" features, including Braille markers on the dialpad and audible key feedback on the dialpad.

The pre-release Panasonic KX-TG2386B also has 4 "essential" features, including several implementations of audible key feedback, several implementations of synthetic speech display (such as for Caller ID), and a dial-out buffer memory. Unlike Ameriphone’s JV-35, this phone does not have enlarged dialpad keys.

The remaining 5 phones in the present analysis each had 2 "essential" features. The three phones available from Canadian telcos each have standard dialpad layouts and enlarged dialpad keys. By contrast, the two remaining phones in the analysis (Panasonic KX-TG2336S and the AT&T model 1818 corded phone) do not have enlarged dialpad buttons, but do offer Talking Caller ID.

Without primary data from blind users indicating the relative value of these different accessibility features, we cannot conclude that one feature is of more value than another, and so we are forced to the default conclusion that a score of 4 is equally good regardless which 4 features were present. However, it would be valuable to conduct primary research to verify the relative value of these features among persons with visual impairments. The conclusions of a study which employs a defensible sampling plan and research methodology will be of great value in helping suggest design directions to ensure that visually impaired users of telecom terminals in Canada will enjoy access to functionality equivalent to that enjoyed by sighted users.

TABLE 4

Comparison of accessibility features of various telephones available to Canadian consumers.

Telephone Source Enlarged keys Tactile key markers Standard key layouts Synthetic speech display Dial-out buffer memory Tactile display Plug-in display Audible key feedback
Panasonic KX-TG2386B mfr. (pre-release) no no yes, dialpad Caller ID, phone book, speed dial, dialpad, redial pre-dial, redial no no dialpad, redial, pre-dial
Panasonic KX-TG2336S mfr. no no yes, dialpad Talking Call Display no no no no
AT&T 1818 corded phone dist. no no yes, dialpad Talking Caller ID no no no no
Ameriphone JV-35 dist. yes, dialpad Braille on dialpad yes, dialpad no no no no yes, dialpad
Ameriphone P-300 Photo Phone telco yes, dialpad no yes, dialpad no no no no no
Ameriphone Dialogue XL-40 telco yes, dialpad no yes, dialpad no no no no no
GE2-9268 Big Button Phone telco yes, dialpad >no yes, dialpad no no no no no

6 Accessibility of Canadian telco information on accessible telecom equipment

6.1 Objective

In the Introduction to the present report, we noted (Section 2.2.1) that:

we have taken the approach that the information we provide should, to the extent possible, represent the information available to persons with a visual disability who are looking for resources electronically. … For this reason, we chose the Internet as the "common denominator", and made the assumption that a search for resources would include the web, even if it did not rely on the web entirely.

Given this context, we have scanned the websites of Canadian telephone companies (telcos) to determine the availability to blind users of information concerning telephones.

6.2 Method

6.2.1 Sampling

We sampled the websites of 5 local service providers in Canada:

In addition, as another condition for comparison we sampled the websites of three local service providers in the US, where the regulatory environment is somewhat different. The companies sampled were:

6.2.2 Procedure

In keeping with the spirit of independent living that is a goal for most citizens, including persons with disabilities, we sampled the websites of companies that provide local telephone service to determine how readily one could locate information about telecom products that are accessible to persons with disabilities. As a "control" condition, we also looked on these websites for information about "mainstream" telephones.

To determine the accessibility of information about accessible products, we followed the guideline to "put critical information near the top of the website" (Guideline 16:2 of Koyani et al., 2003; http://usability.gov/pdfs/chap.html). This guideline, which rates in the highest category in terms of importance, has the following comments associated with it:

Critical information should be provided as close to the homepage as possible. This reduces the need for users to click deep into the site and make additional decisions on intervening pages. The more steps (or clicks) users must take to find the desired information, the greater the likelihood they will make an incorrect choice. Important information should be available within two or three clicks of the homepage.

Therefore, throughout the present analysis the measure of interest was the number of steps (clicks) required to locate information on the telco’s website.

6.3 Results

Figure 2 (below) summarises the results of this exercise. In this figure, the solid lines show the number of steps required to access information about mainstream phones. The number of steps (clicks) required varied from 2 to 3 for the US telcos and from 3 to 5 for the Canadian telcos. Although the Canadian websites required, on average, 3.6 clicks vs. 2.5 for the US telcos, these figures are in the same ballpark.

The picture changes when one examines the number of steps required to get information about accessible telephones. The websites of US telcos required an average of 2.7 steps, nearly identical to the number of steps the US telco websites required for mainstream phones. Two Canadian prairie telcos (MTS and SaskTel) required 3 steps to get information about accessible equipment, equal to or fewer than the number of steps required to get information about mainstream phones from their websites.

However, we were unable to find information about accessible products on the websites of the other three Canadian telcos sampled (Aliant, Bell Canada, Telus). In Figure 2, the absence of a firm count for the number of steps is represented on the graph by bars fading out between 8-10 steps. Note that this result does not mean that the information does not exist, but simply that we were unable to find such information on the websites. By extrapolation, we assume that users with a visual impairment will have the same experience.

In some cases, the telco’s website offers connection to a live agent. However, if one adheres to the assumption that the customer wishes to be able to view and select accessible equipment by him- or herself – that is, without having to rely on another person – then the results of this brief survey suggest that the websites of MTS and SaskTel support this activity. We were not able to locate an on-line catalogue of assistive equipment for Aliant, Bell Canada, or Telus.

Figure 2 - Accessibility of Information about Accessible Products
Figure 2 - Accessibility of Information about Accessible Products
Long description

Accessibility of information about accessible products. The figure shows, for the website of each of the telcos identified at bottom, the number of steps required to access information for "mainstream" telephones (red line) and accessible equipment (blue bars). A score of 10 was arbitrarily assigned where no information could be found. The figure shows that, for the US telcos sampled, details about accessible equipment were only 2 or 3 "steps" away from the telco’s homepage, equal to or fewer than the number of steps required to access details of mainstream phones. In Canada, information about accessible equipment was 3 steps away from the homepage for MTS and SaskTel (equal to or fewer than clicks required for mainstream phones). However, for Bell Canada, Telus, and Aliant, information about accessible equipment could not be found on their websites.

6.4 Conclusions

Taking into account the constraints of the method used and the small number of telco websites sampled, the evidence suggests that US telcos do not discriminate between accessible and mainstream equipment in terms of the degree of difficulty required for a customer to access information about these products.

The same conclusion may be drawn for two Canadian telcos (MTS and SaskTel). However, within the constraints of the present study, we conclude that a self-reliant user searching the websites of Aliant, Bell Canada, and Telus to find information about accessible products would not be successful, although information about mainstream products is readily available. We contrast this result with commonly accepted guidelines on Web accessibility (e.g., Koyani, S.J., Bailey, R.W., and Nall, J.R. Research-based Web Design and Usability Guidelines. Communication Technologies Branch , National Cancer Institute, U.S. Department of Health and Human Services, 2003.).

7 References

In this section, the references are divided into several categories:

7.1 Legislation and related documents

7.1.1 Australia

Australian Communications Authority Act 1997. Act No. 52 of 1997 as amended. scaleplus.law.gov.au/cgi-bin/download.pl?/scale/data/pasteact/2/3016

Disability Discrimination Act 1992: Act No. 135 of 1992 as amended. scaleplus.law.gov.au/html/pasteact/0/311/top.htm

Telecommunications (Consumer Protection and Service Standards) Act 1999: Act No. 50 of 1999 as amended (compilation was prepared on 3 December 2003 taking into account amendments up to Act No. 114 of 2003). scaleplus.law.gov.au/cgi-bin/download.pl?/scale/data/pasteact/3/3267

Telecommunications Act 1997: Act No. 47 of 1997 as amended (compilation was prepared on 7 January 2004 taking into account amendments up to Act No. 148 of 2003). scaleplus.law.gov.au/cgi-bin/download.pl?/scale/data/pasteact/2/3021

Trade Practices Amendment (Telecommunications) Act 1997, Number 58 of 1997. scaleplus.law.gov.au/cgi-bin/download.pl?/scale/data/comact/9/5624

Telecommunications (Transitional Provisions and Consequential Amendments) Act 1997. Act No. 59 of 1997 as amended. scaleplus.law.gov.au/cgi-bin/download.pl?/scale/data/pasteact/2/3020

Telecommunications (Equipment for the Disabled) Regs: Statutory Rules 1998 No. 133. http://frli.law.gov.au/s97.vts?VdkVgwKey=1998B00123&ViewTemplate=frliview.hts&action=View

7.1.2 Japan

Disabled Persons' Fundamental Law (Law No. 84 of May 21, 1970). Amendments: (1) Law No. 80 of 1983; (2) Law No.93 of 1986; (3) Law No. 94 of 1993 (To Come into Effect on December 3, 1993) www.dinf.ne.jp/doc/japanese/law/etc/z00003.htm#living

Japanese Society for Rehabilitation of Disabled Persons. The 30 Selected Japanese Laws Related to Persons with Disabilities. www.dinf.ne.jp/doc/japanese/law/etc/z00003.htm

Law for the Welfare of Physically Disabled Persons (1949, Law No. 283).

Law for Promoting Businesses that Facilitate the Use of Communications and Broadcast Services by the Physically Disabled Persons (1993, Law No. 54).

Telecommunication Service Law (1984, Law No. 86).

7.1.3 United Kingdom

Communications Act 2003. 2003 Chapter 21. www.legislation.hmso.gov.uk/acts/acts2003/20030021.htm

Disability Discrimination Act 1995. 1995 Chapter 50. www.hmso.gov.uk/acts/acts1995/1995050.htm

Disability Rights Commission Act 1999. 1999 Chapter c.17. www.legislation.hmso.gov.uk/acts/acts1999/19990017.htm

Statutory Instrument 2003 No. 1904: The Electronic Communications (Universal Service) Order 2003
www.legislation.hmso.gov.uk/si/si2003/20031904.htm

7.1.4 European Union

COM(2000) 284 final of 12 May 2000. Communication from the Commission to the Council, the European Parliament, the Economic and Social Committee and the Committee of the regions. Towards a Barrier Free Europe for People with Disabilities. http://europa.eu.int/comm/employment_social/news/2001/jul/2000284_en.html

Directive 2002/22/EC of the European Parliament and of the Council, of 7 March 2002, on universal service and users’ rights relating to electronic communications networks and services (Universal Service Directive).

europa.eu.int/information_society/topics/telecoms/regulatory/new_rf/documents/l_10820020424en00510077.pdf

EC Treaty (Treaty Establishing the European Communities), Article 13. http://europa.eu.int/comm/employment_social/equ_opp/treaty_en.html

Non-discrimination European Commission. Charter of Fundamental Rights of the European Union at the Nice European Council on 7 December 2000. Article 21. http://europa.eu.int/comm/justice_home/fsj/rights/discrimination/fsj_rights_discrim_en.htm

7.1.5 United States

Americans with Disabilities Act of 1990, S.933. 23 January 1990. Especially Title IV: Telecommunications. www.usdoj.gov/crt/ada/pubs/ada.txt

Architectural and Transportation Barriers Compliance Board. Electronic and Information Technology Accessibility Standards. Federal Register (36 CFR Part 1194 [Docket No. 2000-01] RIN 3014-AA25. 21 December 2000.
www.access-board.gov/sec508/508standards.htm

Federal Communications Commission. Section 255 of the Telecommunications Act of 1996. Access to Telecommunications Service, Telecommunications Equipment and Customer Premises Equipment by Persons with Disabilities. WT Docket No. 96-198, 1999. www.fcc.gov/Bureaus/Common_Carrier/1999/fcc99181.pdf

Section 508 of the Rehabilitation Act of 1973, as amended 29 U.S.C. § 794 (d). www.access-board.gov/sec508/guide/act.htm. See also Quick Reference Guide to Section 508 Documents (version 1.0, 15 September 2003), issued by the Accessibility Forum.

Telecommunications Act of 1996. www.fcc.gov/Reports/tcom1996.txt

U.S. Access Board. Telecommunications Act Accessibility Guidelines: Part 1193. www.access-board.gov/telecomm/html/telfinl2.htm#D

7.1.6 Canada

Canadian Human Rights Act. laws.justice.gc.ca/en/H-6/30599.html.

Canadian Radio-television and Telecommunications Commission. Telecom order CRTC 95-1172, 31 October 1995. www.crtc.gc.ca/eng/archive/1995/O95-1172.HTM.

Canadian Radio-television and Telecommunications Commission. Telecom order CRTC 96-1191, 29 October 1996. www.crtc.gc.ca/eng/archive/1996/O96-1191.HTM.

Canadian Radio-television and Telecommunications Commission. Telecom order CRTC 98-626, 26 June 1998. Alternative-format billing, etc. www.crtc.gc.ca/eng/archive/1998/O98-626.HTM.

Canadian Radio-television and Telecommunications Commission. Telecom decision CRTC 99-16. 19 October 1999. Telephone service to high-cost serving areas. www.crtc.gc.ca/eng/archive/1999/DT99-16.HTM.

Canadian Radio-television and Telecommunications Commission. Telecom order CRTC 2001-163, 26 February 2001. Access to Microcell’s Fido-related service by persons who are blind. www.crtc.gc.ca/eng/archive/2001/O2001-163.htm.

Canadian Radio-television and Telecommunications Commission. Telecom order CRTC 2001-164, 26 February 2001. Access to Bell Canada’s SimplyOne by persons who are blind. www.crtc.gc.ca/eng/archive/2001/O2001-164.htm.

Canadian Radio-television and Telecommunications Commission. Telecom order CRTC 2001-690. 31 August 2001. Alternative formats for a person who is blind. www.crtc.gc.ca/eng/archive/2001/O2001-690.htm.

Canadian Radio-television and Telecommunications Commission. Telecom decision CRTC 2002-13. 8 March 2002. Extending the availability of alternative formats to consumers who are blind. www.crtc.gc.ca/eng/archive/2002/dt2002-13.htm.

Employment Equity Act. laws.justice.gc.ca/en/E-5.401/49263.html

Telecommunications Act (1993, c.38). laws.justice.gc.ca/en/T-3.4/101939.html

7.2 Key legal decisions

7.2.1 Australia

Bruce Lindsay Maguire v Sydney Organising Committee for the Olympic Games. No. H 99/115. www.hreoc.gov.au/disability_rights/comdec/2000/DD000120.htm

Geoffrey Scott V Telstra Corporation Limited. Disabled People’s International (Australia) Limited V Telstra Corporation Limited. Nos. H95/34, H95/5. www.humanrights.gov.au/disability_rights/comdec/1995/DD000060.htm

7.2.2 United Kingdom

Disability Rights Commission (DRC). DRC legal cases.
www.drc-gb.org/law/caseslist.asp

7.2.3 United States

Federal Communications Commission, In the Matter of Dr. Bonnie O'Day, File No. EB-03-TC-F-004, Complainant, v. Audiovox Communications Corporation, Defendant. ORDER. Adopted: December 30, 2003, Released: January 5, 2004. www.fcc.gov/eb/2003/DA-03-4116A1.html

Federal Communications Commission, In the Matter of Dr. Bonnie O'Day, File No. EB-03-TC-F-001, Complainant, v. Cellco Partnership d/b/a Verizon Wireless, Defendant. ORDER. Adopted: September 2, 2004, Released: September 3, 2004.
www.fcc.gov/eb/2004/DA-04-2870A1.html

7.3 Standards and Guidelines

American National Standards Institute (ANSI). ANSI T1.703-1995 (R1999), Allocation of Letters to the Keys of Numeric Keypads for Telecommunications.

Australian Communications Authority (ACA). AS/ACIF S040:2001 Requirements for Customer Equipment for use with the Standard Telephone Service - Features for special needs of persons with disabilities Application (as described in the s.380 instrument). www.aca.gov.au/telcomm/stds/s040/s040.htm

Australian Communications Industry Forum (ACIF). Industry guideline ACIF G586 September 2001. Access to Telecommunications for People with Disabilities. www.acif.org.au/__data/page/278/G586_2001.pdf, www.acif.org.au/publications/guidelines

Australian Communications Industry Forum (ACIF). Industry guideline ACIF G505 (Version 1.0), January 1998. Development of Telecommunications Industry Working Codes.
www.acif.org.au/__data/page/3243/G505_1998.pdf, www.acif.org.au/publications/guidelines

Canadian Standards Association. T510-95 (R2003): Performance and Compatibility Requirements for Telephone Sets. Revised 2003.

Canadian Standards Association. T516-2: Telecommunications – Telephone terminal equipment – Requirements for pay telephone keypads and function keys with particular regard to use by persons with disabilities. November 2002.

ETSI (European Standards Telecommunications Institute). ES 201 381 v1.1.1 (1998-12). Human factors (HF); Telecommunications keypads and keyboards; Tactile identifiers.

ETSI (European Standards Telecommunications Institute). SR 001 996 v2.1.1 (2003-10). Human factors (HF); An annotated bibliography of documents dealing with Human Factors and disability.

ETSI (European Standards Telecommunications Institute). ES 202 130 v1.1.1 (2003-10). Human factors (HF); User interfaces; Character repertoires, ordering rules and assignments to the 12-key telephone keypad.

European Committee for Standardisation (CEN). CEN/TC 293: Technical aids for disabled persons. (Note that communications devices are in the "ad hoc" category.) www.cenorm.be/cenorm/businessdomains/businessdomains/healthcare/workprogramme.asp

International Telecommunications Union (ITU). E.161: Arrangement of digits, letters and symbols on telephones and other devices that can be used for gaining access to a telephone network. 2001-2002.
www.itu.int/rec/recommendation.asp?type=items&lang=e&parent=T-REC-E.161-200102-I

TIA/EIA. Telecommunications - Telephone Terminal Equipment - Performance and Compatibility Requirements for Telephone Sets with Loop Signaling (ANSI/TIA/EIA-470-B-97). http://ftp.tiaonline.org/tr-41/tr4135/Public/TR41.3.5-ArchivesForContibutionsAndDocuments/TR41.3.5-99-05-03%20PN-4350%20(470C%201st%20draft).pdf

Tiresias, www.tiresias.org/telecoms/pre.htm

7.4 Definitions of disability

(Canadian) Employment Equity Act. laws.justice.gc.ca/en/E-5.401/49263.html.

Canadian Human Rights Act. laws.justice.gc.ca/en/H-6/30599.html.

European Commission. Definitions of Disability in Europe: a Comparative Analysis. 2002. www.europa.eu.int/comm/employment_social/index/complete_report_en.pdf

Statistics Canada. Health and Activity Limitation Survey (HALS). www.statcan.ca/english/sdds/3252.htm

Statistics Canada. Participation and Activity Limitation Survey (PALS). www.statcan.ca/english/sdds/3251.htm

World Health Assembly. International Classification of Functioning, Disability, and Health. Fifty-fourth World Health Assembly. A54/18. 09 April 2001. www.who.int/gb/ebwha/pdf_files/WHA54/ea5418.pdf, and www.un.org/esa/socdev/enable/faqs.htm

World Health Organisation. ICD-10. The International Statistical Classification of Diseases and Related Health Problems, tenth revision. www.who.int/whosis/icd10/

Veterans Affairs Canada. Literature review of care trends for seniors. 1997.

7.5 Advocacy bodies: legal

Disability Rights Education and Defense Fund (DREDF). www.dredf.org/index.html See especially the Directory of National Non-Discrimination Laws at www.dredf.org/international/lawindex.html.Canadian National Institute for the Blind (CNIB). www.cnib.ca.

Royal National Institute of the Blind (RNIB). www.rnib.org.uk.

American Foundation for the Blind (AFB). www.afb.org.

National Federation of the Blind (NCB). www.nfb.org.

7.6 Major policy papers (telecom and accessibility)

7.6.1 Australia

Human Rights and Equal Opportunity Commission. Telecommunications equipment and the Disability Discrimination Act. August 2001. www.humanrights.gov.au/disability_rights/communications/equipment.htm

Jolley William & Associates. When the Tide Comes In: Towards Accessible Telecommunications for People with Disabilities in Australia. A discussion paper commissioned by the Human Rights and Equal Opportunity Commission (2003).

Telecommunications and Disability Consumer Representation (TEDICORE). The Development of a New Telecommunications Disability Program. 2002. www.bca.org.au/tedicore/DEP2002htm

Telecommunications and Disability Consumer Representation (TEDICORE). TEDICORE Submission to the Government Review of the Operation of the Universal Service Obligation and Customer Service Guarantee. February 2004.
www.dcita.gov.au/Article/0,,0_1-2_3-4_117807,00.html

7.6.2 Europe

The references listed below have been copied from the Tiresias / PhoneAbility website (www.tiresias.org/phoneability/telephones/links.htm).

Cullen K & Robinson S Telecommunications for Older People and Disabled People in Europe. IOS Press, ISBN 90 5199 346 3, 1997.

Gill J M The Forgotten Millions: Access to Telecommunications for People with Disabilities. The European Commission, COST 219, ISBN 92 826 7399 5, March 1994, 16 pp. Also at: www.stakes.fi/cost219/forgmi94.doc

Gill J M Telecommunications: The Missing Links for People with Disabilities. The European Commission, COST 219, ISBN 92 827 5115 5, February 1996, 16 pp. Also at: www.trace.wisc.edu/docs/missing_links/mlhome.htm

Gill J M Access Prohibited? Information for Designers of Public Access Terminals. ISBN 1 86048 014 4, May 1997, revised March 1998. Also at: www.tiresias.org/pats

Gill J M (ed) Guidelines for the Design of Screen and Web Phones to be Accessible by Visually Disabled Persons. ISBN 1 86048 018 7, December 1998, 28 pp. Also at: www.rnib.org.uk/wedo/research/sru/phones.htm

Roe P R W (ed) Telecommunications for All. The European Commission, COST 219, October 1995. Also at: www.stakes.fi/cost219/Telall96.doc

Telephones for All: Nordic Design Guidelines. The Nordic Committee on Disability, Stockholm, ISBN 91 86954 26 1, 1995.

Vanderheiden G C & Vanderheiden K R Guidelines for the Design of Consumer Products to Increase their Accessibility to People with Disabilities or who are Ageing. Trace Center, 1992. Also at: tracecenter.org/docs/consumer_product_guidelines/consumer.htm

von Tetzchner S (ed) Issues in Telecommunications for People with Disabilities. The European Commission, COST 219, ISBN 92 826 3128 1, 1991. Also at: www.stakes.fi/cost219/isscon91.doc

7.7 Design and other comment

(US) Access Board. Telecommunications Act Accessibility Guidelines.

www.access-board.gov/telecomm/html/telfinl2.htm.

Bell Canada. History of the dual-tone multi-frequency (DTMF) dialpad. www.bell.ca/en/about/history/timeline/1960c.asp

Burton, D., and Uslan, M. Answering the call: Top-of-the-line cell phones, Part 1. AccessWorld, May 2003, 4(3). www.afb.org/afbpress/pub.asp?DocID=AW040302

Burton, D., and Uslan, M. We think they hear us now: Cell phones with speech. AccessWorld, May 2004, 5(3). www.afb.org/afbpress/pub.asp?DocID=aw050306

Burton, D. You get to choose: An overview of accessible cellphones. AccessWorld, March 2005, 6(2). www.afb.org/afbpress/pub.asp?DocID=aw060206.

Koyani, S.J., Bailey, R.W., and Nall, J.R. Research-based Web Design and Usability Guidelines. Communication Technologies Branch , National Cancer Institute, U.S. Department of Health and Human Services, 2003.

Story, M.F, Mueller, J.L., and Mace, R.L. The Universal Design File: Designing for People of All Ages and Abilities. North Carolina State University, The Center for Universal Design. 1998.

Vanderheiden, G. The future of Internet phone calling: regulatory imperatives to protect the promise of VoIP for industry and consumers. New Millennium Research Council, December 2003. www.fcc.gov/voip/presentation/vanderheiden.doc

Vanderheiden, G., & Tobias, J. (2000). Universal design of consumer products: Current industry practice and perceptions. Proceedings of the XIVth Triennial Congress of the International Ergonomics Association and 44th Annual Meeting of the Human Factors and Ergonomics Society, 6, 19-22. http://trace.wisc.edu/docs/ud_consumer_products_hfes2000/index.htm

Footnotes

1 Vanderheiden, G. The future of Internet phone calling: regulatory imperatives to protect the promise of VoIP for industry and consumers. New Millennium Research Council, December 2003. www.fcc.gov/voip/, document at
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-248634A11.doc.

2 Page 2 in Story, M.F, Mueller, J.L., and Mace, R.L. The Universal Design File: Designing for People of All Ages and Abilities. North Carolina State University, The Center for Universal Design. 1998. www.design.ncsu.edu/cud/pubs/center/books/ud_file/toc3b14.htm.

3 Vanderheiden, G., & Tobias, J. (2000). Universal design of consumer products: Current industry practice and perceptions. Proceedings of the XIVth Triennial Congress of the International Ergonomics Association and 44th Annual Meeting of the Human Factors and Ergonomics Society, 6, 19-22. http://trace.wisc.edu/docs/ud_consumer_products_hfes2000/index.htm

4 Personal correspondence from Dr. John Gill, Chief Scientist, RNIB, 20 May 2004.

5 Towards a United Nations legally binding instrument to promote and protect rights and dignity of persons with disabilities. Communication from the Commission of the European Communities to the Council and the European Parliament. COM (2003) 16 final.

6 The European Commission produces different types of documents; these are explained in a PDF document on the website http://europa.eu.int/comm/secretariat_general/sgc/acc_doc/docs/en.pdf. Briefly, a Communication is described as follows: “COM documents (sometimes SEC documents) … contain the Commissions legislative proposals and other communications of general interest that are due to be transmitted to the other institutions. … COM documents also contain proposals for directives, regulations or decisions of the Council and/or the European Parliament, Green Papers, White Papers, political communications, reports and working documents of the Commission”.

7 Thanks to the ITTATC website (www.ittatc.org) for these links. ITTATC is the Information Technology Technical Assistance and Training Center, located at Georgia Tech.

8 11 October 2004.

9 Brochure obtained at the Panasonic booth at CSUN 2004.

10 Quick Reference Guide to Section 508 Documents (version 1.0, 15 September 2003), issued by the Accessibility Forum. Page iii.

11 www.panasonic.ca/English/telecom/telephones/24GHz/kxtg2336.asp, and www.panasonic.ca/English/telecom/telephones/24GHz/kxtg2356.asp (04 October 2004).

12 Conference on Technology and Persons with Disabilities, California State University at Northridge (CSUN) Center for Disabilities.

13 04 October 2004.

14 Koyani, S.J., Bailey, R.W., and Nall, J.R. Research-based Web Design and Usability Guidelines. Communication Technologies Branch , National Cancer Institute, U.S. Department of Health and Human Services, 2003.

Telephone terminals and accessibility with special reference to visual disabilities

Appendix A:

Residential wireline equipment and services, including payphones, from telephone service providers (telcos)

Adjunct to a report prepared for
Canadian Radio-Television and Telecommunications Commission (CRTC)

by

Acuity Research Group Inc.

April 2005

Table of contents

Introductory comments and organisation of Appendix A

1 Australia

1.1 Wireline equipment
1.1.1 Telephones
1.1.2 Adjunct equipment
1.2 Wireline services
1.2.1 Telephone features
1.2.2 Account management material
1.3 Payphones

2 United Kingdom (UK)

2.1 Wireline equipment
2.1.1 Telephones
2.1.2 Adjunct equipment
2.2 Wireline services
2.2.1 Telephone features
2.2.2 Account management material
2.3 Payphones

3 United States

3.1 Wireline equipment
3.1.1 Telephones
3.1.2 Adjunct equipment
3.2 Wireline services
3.2.1 Telephone features
3.2.2 Account management material
3.3 Payphones

4 Canada

4.1 Wireline equipment
4.1.1 Telephones
4.1.2 Adjunct equipment
4.2 Wireline services
4.2.1 Telephone features
4.2.2 Account management material
4.3 Payphones

5 References: telephone companies

5.1 Australia
5.2 Canada
5.3 UK
5.4 United States

Introductory comments and organisation of Appendix A

One of the objectives of the present project was to characterise the availability of accessible telephone terminals. To address this issue, we have opted to conduct a search on the Internet, looking at the websites of telephone service providers (telcos).

In following this approach, we have, in effect, opted to play the role of a person with a visual disability who wants to obtain information from telco websites about accessible residential telephone terminals, adjunct equipment, and services. Because the specific information available from these sources should be expected to change on an on-going basis, the material in Appendix A should be regarded as a "time stamped" example of the results of such a search conducted in Spring 2004, except where otherwise noted, and should not be taken as definitive for other times.

The following jurisdictions are included in the present report:

For each jurisdiction included here, the material is organised into different sections, as follows:

Throughout this Appendix, the material has been quoted from telco websites, and is referenced as such.

Business telephone systems not covered here

Note that, with the exception of single-line businesses in which residential terminals may be used, Appendix A does not cover business telephone systems. Business telephone systems would typically be found in a key system, PBX (private branch exchange), or Centrex environment.

1 Australia

1.1 Wireline equipment

In Australia, the Department of Communications, Information Technology and the Arts (DCITA) maintains a webpage concerning the availability of telephone equipment to persons with disabilities (www.dcita.gov.au/Article/0,,0_1-2_3-4_115594,00.html). As explained in the consultation paper When the Tide Comes In (July 2003), there are two major telephone companies (telcos) in Australia: Telstra and Optus. Information from both companies is presented below; note that prices were not readily available.

1.1.1 Telephones

The telephones below are listed as available on the Telstra website. (This material has been quoted from the Telstra website.)

1.1.1.1 Telstra

Telstra is the major telephone company in Australia, and as such is the designated Universal Service Provider. Telstra maintains a Disability Equipment Program and provides an on-line catalogue of equipment for persons with a visual disability (www.telstra.com.au/disability/catalogue/vision.htm).

Telstra Standard Rental Phone (T1000S)

The description of this phone reads, "The new design T1000S has a number of features that make it easy to use for people with vision impairment and with impaired dexterity. New improved adjustable ring volume and new adjustable volume control features for incoming calls now also make this phone accessible for people with hearing impairment." Features listed include:

Voice Aid Phone

This phone is described as having been designed to make outgoing speech louder. Features listed include:

Volume Control Phone

This phone is described as having been designed to make incoming speech louder. Features listed include:

Big Button Phone

A Big Button Phone is available for purchase from Telstra Shops and, with its larger keypad buttons, may make dialling easier for people with a vision or dexterity impairment. A volume control feature for incoming speech and visual ring indicator may also make this phone useful for people with a hearing impairment. Features include:

Telstra also provides some equipment for customers who are deaf-blind.

Large visual display TTY (teletypewriter)

Includes the same features as the Superprint 4425, and has a large visual display for Deafblind customers with some residual vision. Features include:

Braille TTY

For Deafblind customers, this TTY outputs conversations in Braille as well as on a standard TTY fluorescent display. Features include:

1.1.1.2 Optus

The website of Optus, major competitive carrier in Australia, has a "Disability services" page (www.optus.com.au/Vign/ViewMgmt/display/0,2627,1020_3867-3_32151--View_203,00.html). Although this page mentions that "One of the major initiatives within the Action Plan is to develop a Disability Equipment Program for its telephony customers," the programme is apparently just starting, and the only disability mentioned is hearing-related; the only product mentioned is a TTY.

1.1.2 Adjunct equipment

Telstra also makes available adjunct equipment for persons with visual disabilities.

EasyRead stickers

These stickers have large numerals, which can be stuck on to the keys on your telephone keypad. Features: large print numerals on high contrast background; easy-peel; can be applied to most telephone keypads.

EasyRead Memory Store sheet

This A4 size card allows you to record the numbers stored in your telephone’s directory in a large format – making it easier to read.

1.2 Wireline services

The Telstra website (www.telstra.com.au/disability/catalogue/vision.htm) contains information about telephone-related services (all material quoted from the Telstra website). Below, the information is presented separately for telephone features and account management material.

1.2.1 Telephone features

Directory Assistance Helpline

Telstra's Directory Assistance Helpline offers a live, operator assisted service that includes telephone number information as well as address information for people who are unable to read, use or hold White Pages™ or Yellow Pages™ directories and are unable to satisfactorily use the standard Directory Assistance service (12455/1223) service. Contact the Disability Enquiry Hotline on FREECALL™ 1800 068 424* (Voice) or FREECALL™ 1800 808 981* (TTY) or email DisabilityEnquiryHotline@team.telstra.com to apply.

*A free call from most fixed phones.

Abbreviated Dialling**

You can choose to store up to 60 of your most frequently used telephone numbers in the telephone exchange memory, including long distance numbers. Then you can dial these numbers using a simple one or two digit code. This product can be very helpful for people with a mobility impairment who have difficulty dialling numbers.

**Monthly rental charges apply.

Telstra Call Connect™ - 12456

Telstra Call Connect™ is a live, operator-assisted, premium service that finds and connects the customer to the number being sought. Customers who are unable, or find it extremely difficult, to dial numbers on a telephone and therefore are prevented from using an ordinary telephone may be eligible to receive access to the Telstra Call Connect (12456) service for free (call charges still apply).

1.2.2 Account management material

Bill Options

Telstra offers a range of billing options for customers with a disability, at no additional cost.

Braille Bill

Customers who are blind have the option of receiving their Telstra standard and mobile telephone bills in Braille. Features include:

Braille bills can be ordered by calling the Disability Enquiry Hotline on FREECALL™ 1800 068 424* (Voice) or FREECALL™ 1800 808 981* (TTY) or email DisabilityEnquiryHotline@team.telstra.com.

*A free call from most fixed phones.

Big Print Bill

If you have a vision impairment that means you can't easily read your Telstra bill, you may prefer to receive your standard telephone and mobile bills printed in a large font - the Big Print Bill. Features include:

1.3 Payphones

In Australia, most payphones (42,000 as of June 2003) are privately owned; telecom regulations concerning accessibility do not seem to apply in this case. The remaining payphones (36,000) are owned by Telstra, and as the Universal Service Provider, Telstra is subject to the Universal Service Obligation, which requires that payphones be accessible.

According to the website (www.dcita.gov.au/Article/0,,0_1-2_3-4_102275,00.html) of the (Australian) Department of Communications, Information Technology, and the Arts, or DCITA:

Telstra consults with, and takes into account the needs of people with a disability in providing payphones. This is reflected in Telstra's approach to siting payphones, equipment and booth design and installation standards. Telstra provides TTY payphones for the speech and/or hearing impaired. Telstra operated 161 TTY payphones at 30 June 2001.

The DCITA website (www.dcita.gov.au/Article/0,,0_1-2_3-4_115594,00.html) mentions that Telstra has about 170 payphones that include TTY capability. However, we could find no information about accessibility with respect to visual disabilities.

The Telstra website (www.telstra.com.au/universalservice/payequipment.htm) notes that more than 95% of Telstra payphones have been upgraded to "Smart" payphones, which include accessibility features. Smart payphone features include

2 United Kingdom (UK)

2.1 Wireline equipment

The principal source for information about accessible telecom products in the UK is BT’s website entitled "BT Age & Disability Action". This website provides a page for accessible products (www.btplc.com/age_disability/AccessibleProducts/Indexv1.htm) provided by BT. The material is broken down by the type of need: visual impairment, dexterity impairment, and so on.

On the page "BT accessible products", there are 8 categories of products and services (www.btplc.com/age_disability/AccessibleProducts/ClearerCommunication/Products/Indexv1.htm):

Also on this page, there is a link to "BT Shop", where one is invited to buy accessible products. Selecting this link takes the user to the BT eShop. (The material below is quoted from the BT and eShop sites.)

2.1.1 Telephones

The BT site classifies accessible equipment as "corded telephones", "analogue cordless telephones", and "digital cordless telephones". We have included the category "handsfree telephone" in the "corded telephone" category.

2.1.1.1 Corded telephones

BT Big button+ corded phone

Phone with extra large buttons and special features ideal for anyone who has difficulty operating a standard telephone. Price £19.99 (approximately CDN$50).

Relate 3000

Our latest 'Design for all' phone, the Relate 3000 features include large, contrasting keys; raised dot on '5' button; memory buttons; large, adjustable display; handsfree; headset option; 1471/ 1571 buttons; pre-dialling and voice prompts. Also, a keypad lock. Price £49.99 (approximately CDN$125)

Converse 225

Our 20 number memory phone includes raised dot on '5' button, headset option and wall mounting. Price £39.99 (approximately CDN$100).

Duet Mini

Our one-piece corded with illuminated keypad. Price £9.99 (approximately CDN$25).

Converse 325 (handsfree phone)

Our hands-free phone includes raised dot on '5' button, memory buttons, last number  redial, repeat dial and wall mounting. Price £49.99 (approximately CDN$125).

2.1.1.2 Analogue cordless telephones

Freestyle 60

Our large button cordless phone includes raised dot on '5' button, memory buttons, contrasting keypad and wall mounting. Larger than average buttons. Inductive coupler. Adjustable ringer tones. Price £29.99 (approximately CDN$75).

Freestyle 65

Our large button cordless phone with digital answering machine includes raised dot on '5' button, contrasting keypad and voice prompts. 10 memory dials, not with dedicated buttons. Price £44.99 (approximately CDN$112).

Quartet 3100

Our cordless phone with larger than average keys includes raised dot on '5' button, contrasting keypad and memory buttons. This colorful analogue cordless shows you when a 1571 message is waiting. Price £23.49 (approximately CDN$58).

Quartet 3500

Our cordless phone with digital answering phone includes larger than average buttons, raised dot on '5' button, contrasting keypad, memory buttons and voice prompts. Price £29.99 (approximately CDN$75)

2.1.1.3 Digital cordless telephones

Verve 3010 Executive

Our digital cordless includes raised dot on the '5' button, hands-free dialling, headset option, memory buttons and wall mounting. Price £54.99 (approximately CDN$137).

2.1.2 Adjunct equipment

The BT site lists two Caller ID products and headsets.

CD 1500

Our large display Caller Display unit, which can be wall-mounted.

Duet 700

Our Caller Display phone includes raised dot on '5' button, memory buttons and adjustable LCD (liquid crystal display).

Headsets (Free rental for disabled customers)

We supply the Converse 4 headset rent free to disabled customers who rent our Converse 225 or 325 phones. To order our rent free headset call Freefone 0800 150 111 or  180111 0800 150 111 for text users. Headsets are also available for a wide range of corded, cordless or mobile phones.

2.2 Wireline services

2.2.1 Telephone features

The BT website lists the following features for users with a visual impairment1:

Ring Back

Re-dials busy numbers for you at the touch of 1 button.

1471

Lets you hear the number and details of the last person who called you.

BT Answer 1571

An answering service with voice prompts allows you play back messages via any phone e.g. the BT Big Button+.

Call Sign

Lets you know when a call is for you by ringing in a different way.

2.2.2 Account management material

As discussed (www.btplc.com/age_disability/ClearerInformation/alternativemedia.htm), BT provides phone bills in alternative media, including audio, Braille, e-information, and large print.

2.3 Payphones

On its webpage entitled "BT Age and Disability Action: Textphone communication", it is noted that BT has almost 1800 e-mail and text payphones across the UK (www.btplc.com/age_disability/TextCommunications/TextPayphones/TextPayphones.htm). We could not find information related to accessibility features for visual disabilities.

3 United States

Information about accessible telecom equipment in the United States comes primarily from three sources: manufacturers, distributors, and telcos. In the present section, only information from telcos is presented. Information about equipment from manufacturers and distributors is presented in Appendix A.1, a supplement to Appendix A.

3.1 Wireline equipment

In keeping with the spirit of independent living that is a goal for most citizens, including persons with disabilities, we sampled the websites of companies that provide local telephone service (telcos) to determine how readily one could locate information about telecom products that are accessible to persons with disabilities. The sections below summarise the results of this search for 5 local service providers in the United States:

If one adheres to the assumption that the customer wishes to be able to view and select accessible equipment by him- or herself – that is, without having to rely on another person – then the results of this brief survey suggest that the websites of BellSouth, SBC, and Verizon support this activity. We were not able to locate an on-line catalogue of assistive equipment for Qwest or Sprint.

3.1.1 Telephones

3.1.1.1 BellSouth

The homepage of BellSouth (www.bellsouth.com) has a link to "special needs", which takes the user to the "Special needs" site. Also, selecting "Residential services" opens a pull-down menu with "Special needs" as a choice. Selecting this option takes the reader to a page where 4 options are offered:

Choosing "Visually impaired" takes the reader to a page which lists 11 assistive products, each with a link to more information. The relevant telephones are described below.

Walker Clarity telephone

The Walker Clarity telephone is helpful to people with high frequency hearing loss. The Clarity Control® sliding bar helps you hear sounds like "ch" and "st." Other features include a visual ringer, ringer volume control, large number dialing pad, 13-number programmable memory, pulse/tone selection, last-number redial, mute button, desk or wall mountings, and a Braille dot on the five key. Price US$118.00, lease US$3.80/month.

TeleTalker telephone (from Williams Sound Corp.)

The TeleTalker telephone features two adjustment controls: one that amplifies the sound coming into the receiver and another that eliminates background noise. Together, the controls provide clearer sounds without distortion or electronic feedback. TeleTalker is a product of Williams Sound Corp. (Although not mentioned in the description, this phone has big buttons with high-contrast labels.) Price US$99.50, lease US$2.15/month.

3.1.1.2 Qwest

Like BellSouth, the homepage of Qwest (www.qwest.com) has a direct link to "disability" (icon), which takes the user to the "Center for Customers with Disabilities" page (www.qwest.com/residential/disabled/index.html). At this page, the customer is given 8 choices:

Although selecting "Other adaptive equipment vendors" provides a list of company names and contact information, we were unable to find an on-line catalogue of assistive equipment on the Qwest website itself. Despite the promising start, it seems to be the case that the user must follow the links to state equipment programmes or to the assistive technology vendors to identify specific equipment.

3.1.1.3 SBC

The homepage of SBC Communications (www.sbc.com) does not have a direct link to "disability". However, the SBC homepage features a "Search" function. Entering "disability" into the search field and selecting (as an example) "Texas", a total of 14 hits are returned, including "Vision solutions". Selecting this option produces the following information:

A second hit from "disability" is "SBC – Accessibility resources – Texas". Selecting this item, the user is presented with 7 options:

Selecting "Special Needs Equipment" takes the user to an on-line catalogue of 8 products. Most of these products deal with hearing disability, and can be seen at www.hitec.com/cgi-bin/hitec.storefront/en/Catalog/1925?BannerCode=1070549849&site=SBC.

A third hit that is returned is "SBC Universal Design Policy – Texas". Here, we have reproduced the text in its entirety because it is a good example of the positioning of a major telco with respect to the accessibility of telecom equipment and services. It is perhaps especially noteworthy that SBC mentions explicitly that it will not use the "if readily achievable" option in Section 255 as "an excuse to avoid full, good faith compliance with its commitment to universal design principles or the law" (www01.sbc.com/Products_Services/Residential/1,,19--6-3-19,00.html):

Preface

Universal design is critical to millions of Americans who depend on telecommunications accessibility for employment, education, social interaction, recreation, and other life activities. Access to telecommunications allows persons with disabilities greater participation in society.

Policy Summary

SBC supports universal design to make new telecommunications products and services accessible to and usable by individuals with disabilities, consistent with Section 255 of the Telecommunications Act of 1996 (the Act) and the Americans with Disabilities Act of 1990 (ADA).

Policy Application:

SBC Universal Design Policy Adopted in 1998 Background:

3.1.1.4 Sprint

The homepage of Sprint (www.sprint.com) does not have a link to "disability". The user can access information about disabilities and accessibility by ignoring the product-related choices (Personal, Business) and selecting "About Sprint". From there, one selects "Consumer information". From here, "Technology for all abilities" opens a window that provides accessibility-related information with the following titles:

However, we could not find anything resembling a catalogue of accessible products.

3.1.1.5 Verizon

The homepage of Verizon (www22.verizon.com) has a link "Customers with disabilities". Selecting this item takes the reader to a page with the following text:

Verizon is committed to providing the greatest range of communication capabilities to all of our customers. Our mission is to provide the highest quality of service and sensitivity to our customers with disabilities by empowering them with accessible telecommunications products and services.

In order to show you products and services, you may be asked to select a state. If you have previously selected a state, you will be taken to a listing of the product/categories for that state. To view these products in other states, you will need to select a category.

This page also features a navbar at right with the following choices (selected):

Selecting "Adaptive equipment", the reader is presented with a catalogue of 11 products; items relevant to visual disabilities are shown below.

Ameriphone Dialogue CL40

Manufactured by Ameriphone, the Dialogue CL40 is an amplified cordless phone that offers 900 MHz technology for extended operating range and static-free transmissions. Features include a powerful amplifier that can increase incoming sounds up to 43 dB. (Price US$129.95)

Ameriphone Dialogue JV35

Jumbo-size buttons with Braille characters. Electronic voice announce announces each number as you dial. 10 programmable memory buttons. 3 one-touch emergency buttons with Braille characters. (Price US$119.99)

Clarity big button amplified telephone W500

Large display and buttons: Easy to see both day and night which is very useful for those who may have vision limitations. Back-lit keypad. (Price US$199.99)

3.1.2 Adjunct equipment

This section lists adjunct equipment designed for persons with a visual disability, either low vision or blindness. We looked for two types of products: those requiring electrical power (electronic aids), and those which do not (mechanical).

We were able to find only one product from a telco (Verizon) that required electrical power, and one product set from a telco (BellSouth) that was mechanical.

3.1.2.1 BellSouth (telephone company)

Large number plates and magnifying cards

Customers who have difficulty seeing numbers on telephone dials or in phone books may find large number plates for either rotary or touch-tone dials, or a magnifying card useful. BellSouth provides these at no charge.

3.1.2.2 SBC (telephone company)

Backlite Caller ID

This Model G99M uses a large 3-line LCD2 to display calling time, calling number and calling name on a single screen. Supports Caller ID on Call Waiting services and voice mailbox services by local telephone companies. G99M receives Visual Message Waiting Indication (VMWI) signal and detects stutter tone automatically. It flashes LED3 and LCD icons to inform user of waiting voice message(s). (Price US$35.00)

3.1.2.3 Verizon (telephone company)

On the Verizon website, the single electronic adaptive aid for visual disabilities is a ClassCo talking Caller ID unit (CV9900CW), selling for US$89.99. See Appendix A.1 for details.

3.2 Wireline services

3.2.1 Telephone features

3.2.1.1 BellSouth

Local directory assistance

(The following material is quoted from the BellSouth website)

Customers who cannot look up telephone numbers in the phone book because of sight or motion impairment can get BellSouth local directory assistance at no charge. To qualify for this free service, customers should simply call the TCCD for a copy of a application. Please complete and return the application along with a certification letter from your doctor to the TCCD.

DACC - Directory Assistance Call Completion (calls dialed by automated directory assistance) is available at no charge in the following states; Georgia, North Carolina, Kentucky and Alabama. All other states (Mississippi, Florida, South Carolina, Tennessee and Louisiana) DACC will be charged.

National Directory Assistance (any city that is not listed locally in your local phone book) is not covered by Directory Assistance exemption. Please contact your long distance carrier (company) to discuss exemption for long distance Directory assistance.

Local operator assistance

(The following material is quoted from the BellSouth website)

Suppose you want to make a local phone call but have difficulty dialing the complete number because of sight or motion impairment. Dial "0" and explain to the operator that you need assistance dialing a local number because of a disability. The BellSouth operator will be happy to help you free of charge. If "Operator Assistance" charges appear on your bill after using this service, please call the TCCD at 1-888-390-7770 or if out of BellSouth calling area 1-800-982-2891. We will be happy to adjust these charges.

The Customer Guide, which precedes the white pages of your local telephone book, explains Calling Zones, or the "0" operator can help you.

3.2.1.2 Qwest

Qwest offers exemptions from Directory Assistance and other charges upon certification of a visual disability unless the customer can obtain this information from another person, a Braille resource, or a device. By implication, a visually impaired person who has access to a sighted person is apparently unable to be recognised as independent.

The Qwest website (www.qwest.com/residential/disabled/da_os.html) is the source for the material below.

Exemptions from Directory Assistance and Operator-Handling Charges

Qwest residential customers and employees of Qwest business customers are eligible for an exemption from directory assistance and operator handling charges under the following conditions. They must have certified vision or motion impediments AND must be unable to obtain directory listing information from another person, a resource such as Braille directory or a device such as an automatic dialer.

Customers who request exemptions must be certified as having a motion or vision disability. The Qwest Center for Customers with Disabilities must receive certification, signed by an authorized person or agency, prior to granting the exemption.

Qwest Wireless™ customers with disabilities also may be eligible for a directory assistance exemption. Qwest Wireless customers must include their wireless telephone number on their exemption application.

3.2.1.3 SBC

The SBC website requires that the customer select a state (or area code) to determine what services are available. Selecting (arbitrarily) "Texas" leads to a webpage (www01.sbc.com/Products_Services/Residential/1,,15--6-6-0,00.html) that lists features and capabilities in several categories, including:

Under "Discounts and exemptions", the site provides the following information:

Discounts and Exemptions

If a disability makes it difficult for you to use the telephone directory, you may not have to pay for calls to Local Directory Assistance. To see if you qualify and to find out more details, call 1-800-464-7928:

Qualified customers may be exempt from:
Local Directory Assistance Charges when dialing 1 +411.
Local Directory Assistance Call Completion when dialing 1 +411

If you are making a Local Directory Assistance call from another location you may use your calling card and ask the operator to bill your call to your exempt telephone number.

National Directory Assistance

By dialing 1+411, you can also reach National Directory Assistance and receive phone listings anywhere in the country at just $0.95 per request. Exemptions do not apply to requests for National Directory Assistance.

3.2.1.4 Sprint

It is difficult to find information concerning disabilities on the Sprint website. The information below (www2.sprint.com/as_scope/values/consumer_info/home.do), quoted from the Sprint website, provides information related to visual disabilities. (There is considerably more information, not included here, about auditory disabilities.)

As Sprint Project ConnectSM exemplifies, Sprint is committed to improving the lifestyle of individuals with disabilities. As a technology innovator, Sprint understands that technology provides an excellent opportunity to assist and enhance the lives of people with disabilities. As a result, Sprint is working to increase the accessibility and usability of our products and services to make it easier for everyone to communicate more effectively. We continually strive to enhance our products and services in order to create opportunities for Americans with disabilities to learn, develop, and engage in all aspects of everyday life.

Below is information on the various products and services that Sprint offers that may be helpful to individuals with disabilities.

Handset Accessibility

Sprint is committed to making its handsets user-friendly and accessible to customers with disabilities. Sprint works with manufacturers to design easy-to-use handsets that incorporate a host of features and functions that help hard-of-hearing, deaf, visually-impaired, speech-impaired, blind, and cognitively disabled customers.

Examples of accessibility features include tactile marking of the "5" key, large font display, vibrating ringer, one-touch dialing, etc.

To learn more about the features and functions of specific handsets, please visit a Sprint Store or SprintPCS.com.

Voice Activated Dialing and Sprint PCS Voice CommandSM

Sprint is well on its way to building speech recognition into its handsets and network. Today, many PCS Phones have voice activated dialing software that allows a user to enter a list of names and numbers that can be dialed by speaking into the microphone.

Sprint also offers Sprint PCS Voice Command - a much more expansive network-based voice activated dialing platform employing second generation speech technology. Sprint PCS Voice Command service can greatly benefit blind or visually impaired customers because it eliminates much of the key punching otherwise required to make calls. Please visit the Sprint PCS Voice Command site to learn more about this service.

3.2.1.5 Verizon

Selecting "visual disability" and "New Jersey", the Verizon offers 5 features, as follows (material quoted from www22.verizon.com/foryourhome/sas/res_fam_Visual.asp).

*69(US$4.00 per month, $0.75 per use.)

*69 provides either (1) information regarding your last incoming call and the option to dial the caller back, or (2) the ability to return the last incoming call.  Call information is not available for all incoming calls and certain calls cannot be returned by this service.

Busy Redial (US$2.00 per month, $0.75 per use)

Automatically dials a busy number for you, for up to 30 minutes. Once the line is free, a distinctive ring alerts you that the call is connected.

Speed Dialing 30 (US$4.00 per month)

Allows you easy access to 30 specified telephone numbers, local and/or long distance, that you can dial using two digits instead of seven or 10.

Speed Dialing 8 (US$2.30 per month)

Allows you easy access to eight specified telephone numbers, local and/or long distance, that you can dial using one digit instead of seven or 10.

Talking Call Waiting (US$2.50 per month)

With special equipment, this service audibly announces an incoming caller's telephone number when you are already on the phone so you can decide whether to take the call. For more information on special Caller ID equipment, call 800-822-0409 or visit www22.verizon.com/pages/phones. You must also subscribe to Call Waiting to have this service.

3.2.2 Account management material

3.2.2.1 BellSouth

The BellSouth website (www.bellsouth.com) describes the Telecommunications Center for Customers with Disabilities (TCDD). The following description is provided:

Telecommunications Center for Customers with Disabilities (TCDD)

The BellSouth TCCD is a service center for customers who have disabilities. You can call either the voice or the text telephone (TTY) number at the times listed.

Representatives at the TCCD can help you:

RightTouch® service

(The following material is quoted from the BellSouth website)

RightTouch service allows customers to do business with BellSouth 24 hours a day, seven days a week. RightTouch is a "free" service. All that's needed is a touch-tone telephone and a Personal Access Code (PAC). The PAC is a four-digit code that's included monthly in the "Messages" portion of your bill.

Customers calling RightTouch service are greeted by a friendly-recorded voice and given instructions on using the service. Customers respond to the questions by touching certain numbers on the touch-tone keypad to take advantage of the following options:

To use RightTouch service, customers call: 1.888.764.2500.

RightTouch service is popular with all residence customers, and is especially helpful to customers who are visually impaired.

3.2.2.2 Qwest

As noted on their website (www.qwest.com/residential/disabled/billingformat.html), "Qwest offers Braille billing, billing in large print format, billing on audio tape, and billing via email upon request".

3.2.2.3 SBC, Sprint, and Verizon

SBC, Sprint, and Verizon provide large print and Braille bills upon request.

3.3 Payphones

We visited the website of the Federal Communications Commission (www.fcc.gov) and conducted an advanced search for the terms "payphone+disability" and "payphone+accessibility". Many of the hits returned concerned access to the TRS (Telecommunications Relay Service) from payphones, which is not related to visual disabilities.

However, on 30 June 1998 the American Public Communications Council (APCC) submitted comments to the FCC concerning Section 255 implementation and payphones (ftp.fcc.gov/Bureaus/Wireless/Comments/fcc98055/ampubcom.txt). In the comments (Docket 96-198), it is noted that "APCC is a national trade association made up of almost 2,000 manufacturers and independent (non-local exchange carrier (LEC)) payphone service providers." Briefly, the commenters note that, "the Commission must permit manufacturers and service providers to make individual business decisions on what is readily achievable, or compliance with Section 255 will be retarded." In part, this argument is based on the observation that "APCC’s membership is made up primarily of small companies with limited resources."

4 Canada

The present section focuses on information available through the websites of Canada’s major local service providers: Aliant, Bell Canada, Manitoba Telephone Service, SaskTel, and Telus. As above, we have conducted the Web-based search from the perspective of a person with a visual disability who wishes to obtain information about accessible telephone equipment and services for residential use.

4.1 Wireline equipment

4.1.1 Telephones

Information that is available from telephone company websites concerning accessible wireline telephones is presented here.

4.1.1.1 Aliant website

The homepage of Aliant (www.aliant.ca/english/index.asp) had no links to "disability". Selecting "Aliant products & services" takes the reader to the "Products and service for your home" page, where the reader must select a province. Selecting (as an example) New Brunswick, the reader is taken to a page which has, in the navbar at left, 6 categories containing 12 sub-categories. Selecting "Phones", one is given a choice between "Rental" and "Retail", as well as a Phone Care maintenance plan. Selecting "Retail" takes the reader to another page which provides two lists, without images or explanatory notes, of cordless (n=14) and corded (n=2) phones. We could not find any information related to disabilities searching in this manner.

Searching the Aliant site (as a whole) for "disability" resulted in no website hits, but did retrieve a news story (from 2002). A search for "accessibility" returned no websites but three news stories related to network access.

However, once New Brunswick had been selected, a keyword search window was offered. Entering "disability" yielded one hit ("Special needs services"). Selecting this item led to a description of special needs services, TTY contact information, relay service information, information about long distance discounts and Directory Assistance exemptions, and, finally, this item:

Specialized Equipment for Customers with Disabilities


There are a number of dealer locations which can provide you with special telephones and accessories to assist those customers with disabilities. Contact our Special Needs representative at 1-888-683-0222 to discuss any particular situation.

Based on this brief trial, it seems to be the case that a customer with disabilities will not be able to search the Aliant site successfully for telephones by him- or herself.

4.1.1.2 Bell Canada website

Bell Canada’s home page (www.bell.ca/shop/application/commercewf) contains no link to "disability".4 Clicking on "Phone services" leads to the "Telephones and services" page. Clicking on "Telephones & accessories" provides the reader with three choices:

Clicking (as an example) "Other phones" presents the reader with a catalogue of 20 phones and accessories (such as a headset system). Without reading the descriptions of each telephone – that is, by scrolling to the phone, selecting the "More" button and accessing another page – it was not possible to determine which phones had accessibility features.

Some phones listed here do have accessibility features. The Ameriphone P-300 Photo Phone and the Ameriphone Dialogue XL-40 both have oversized dialpad buttons with high-contrast labels (see below). However, unless the reader knew this in advance or was familiar with the accessibility profile of Ameriphone products, there would be no way of identifying these phones as useful for someone with a visual disability.

We also conducted searches for several terms:

Searching the Bell Canada website (www.bell.ca/shop/application/), we were able to obtain information about the terminals listed below. (Source for the text is the Bell Canada website.)

Ameriphone P-300 Photo Phone ($89.95)

Last Number Redial makes calling speedy and convenient

Dialogue XL-40 ($189.95)

Adjustable Tone Control, Powerful amplifier increases incoming sounds up to 100 times (43+ dB) louder for extra loud and clear conversations

4.1.1.3 Manitoba Telephone Service (MTS) website

The homepage of Manitoba Telephone Service (MTS) (www.mts.ca) has no link to "disability".

From the homepage, Selecting "home", and then "Product catalogue" revealed a "Special needs" section. The Special Needs section contains information about 7 TTY products and the Dialogue XL-40, which, although described below, are primarily for customers with a hearing disability (http://ebusiness.mts.mb.ca/mtsapplications/css/home.nsf/CatalogueForm?readform&hm~Special%20Needs~).

Alternatively, searching for "disability" on the homepage returned no hits; "accessibility" returned unrelated hits, and "special needs" returned hits for the 7 TTY products and two network connectivity packages (MegaLink, MicroLink).5

Dialogue XL-40 (Rental only. $6.95 to $8.95 per month)

The Dialogue XL-40 gives you even more amplification and clarity. It increases the incoming sound up to 100 times louder! You will hear every word loud and clear! It's (sic) lighted keypad makes it easy to dial. Talking on the telephone has never been so enjoyable! (Also has lighted dialpad and large, high contrast buttons.)

4.1.1.4 SaskTel website

The homepage of SaskTel (www.sasktel.com) does not have a direct link to "disability".6 However, in the section marked "Personal", clicking on the last item "More" leads to a page of products and services for personal use. One item on this page is "Special Needs Services", described as "Telephones and accessories specially suited to customers who have sight, hearing, motion or speech limitations." Selecting this link takes the reader to a page where the only choice is to select "More info". Doing so takes the reader to another page where the following text appears: "Telephones and accessories specially suited to customers who have sight, hearing, motion or speech limitations." Selecting "sight" opens a window with the following items:

On the homepage, entering "disability" in the "Search" window produces about 23 hits, some of which are relevant to persons with functional impairments. A search for "accessibility" produced 14 hits, but none of the top 10 was related to disabilities. Searching for "special needs" produced 20 hits, most of which were relevant to disability / accessibility.

The SaskTel website (www.sasktel.com) contains a description of one telephone and one adjunct device, as quoted below.

Big Button Telephone (GE2-9268) ($39.95)

This telephone has extra large buttons for easier dialing for people with limited mobility or vision. Volume control will adjust receiver and ringer volume. Has 8 speed call keys.

4.1.1.5 Telus website

Telus’s homepage (www.telus.ca/cgi-ebs/jsp/homepage.jsp) contains no direct link to "disability". To locate accessible telephones, the reader selects "Personal users", then clicks "personal products & services". Next, one is presented with 6 lists containing a total of 32 items, none related directly to "disability". Selecting "telephones" under the "Products" banner brings up 4 choices:

Selecting "corded" brings up a catalogue of 5 telephones. None of the descriptions relates to "disability".

We could not find a "Search" function on the Telus site. Selecting "Sitemap" brings up a list of 13 categories, with a total of 40 sub-topics, none related to "disability" or "accessibility"; 16 of these sub-topics have further sub-topics, but we did not explore these. Selecting "Frequently asked questions" yields nothing related to "disability".7

4.1.2 Adjunct equipment

We were able to locate only one "add-on" item (adjunct equipment), which we located on the SaskTel website. Our inability to find adjunct items on other websites does not mean that these items are not offered; it simply means that, using the parameters defined for our search, we were unable to locate them.

Magnifying sheet ($7.95)

This framed sheet of plastic material (lens size is about 6" by 9") is held over the printed material to provide 2 times magnification to the image.

4.2 Wireline services

4.2.1 Telephone features

The SaskTel website was the only website where we were able to locate information about telephone features targeted to persons with a visual disability. As noted above, our inability to find similar items on other websites does not mean that these items are not offered; it simply means that, using the parameters defined for our search, we were unable to locate them.

4.2.1.1 SaskTel website

The SaskTel website identifies the following telephone features for customers with a visual disability (material quoted from website):

Directory Assistance

Provided to approved customers at no charge.

Speed Call lets you store 8 or 30 different phone numbers in memory. To make calls from any phone in your home, dial a 1 or 2 digit code instead of a phone number.

4.2.1.2 Aliant, Bell Canada, MTS, and Telus websites

We were unable to locate any information on any of these websites about services which are targeted to persons with a visual disability, or which may benefit them.

It is worthy of mention that the Bell Canada site has a "special needs" section (www.bell.ca/shop/application/commercewf?origin=noorigin.jsp&event=link(goto)&content=/jsp/content/contact/spe_relay.jsp). However, this section is targeted to TTY users, and we could find no information relating to persons with a visual disability.

4.2.2 Account management material

4.2.2.1 SaskTel website

The SaskTel website identifies the following account management materials for customers with a visual disability (material quoted from website):

Alternative format phone bill and bill inserts

Available in Braille, large print, or diskette.

4.2.2.2 Aliant, Bell Canada, MTS, and Telus websites

We were unable to locate any information on any of these websites about account management material targeted to persons with a visual disability, or which may benefit them.

4.3 Payphones

Canadian standard T516-02 (Telecommunications - Telephone Terminal Equipment - Requirements for Pay Telephone Keypads and Function Keys with Particular Regard to Use by Persons with Disabilities) addresses issues related to payphones and accessibility. This standard considers the following aspects of payphone design:

In conformity with comparable standards in other jurisdictions, this Canadian standard also specifies a tactile "pip" on the "5" button.

5 References: telephone companies

5.1 Australia

Optus (www.optus.com.au). For customers with disabilities, www.optus.com.au/Vign/ViewMgmt/display/0,2627,1020_3867-3_6818--View_254,FF.html

Telstra (telstra.com/index.jsp). For customers with visual disabilities, www.telstra.com.au/disability/catalogue/vision.htm

5.2 Canada

Aliant (www.aliant.com). We could not find any location, or search result, on the Aliant website that provided information about customers with disabilities.

Bell Canada (www.bell.ca). We could not find any location, or search result, on the Bell Canada website that provided information about customers with disabilities.

Manitoba Telephone Service (www.mts.ca). For customers with disabilities, http://ebusiness.mts.mb.ca/mtsapplications/css/home.nsf/CatalogueForm?readform&hm~Special%20Needs~.

SaskTel (www.sasktel.com) . For customers with disabilities, https://commerce.sasktel.com/eSales

Telus (www.telus.ca). We could not find any location, or search result, on the Telus website that provided information about customers with disabilities.

5.3 UK

BT (www.btplc.com). For customers with disabilities, www.btplc.com/Siteservices/Servicesforolderanddisabledcustomers/index.htm

5.4 United States

BellSouth (www.bellsouth.com). For customers with disabilities, www.bellsouth.com/specialneeds/index.html?gnav=sneeds

Qwest (www.qwest.com). For customers with disabilities, www.qwest.com/residential/disabled/index.html

SBC (www.sbc.com). For customers with disabilities, www.sbc.com/gen/general?pid=1080&cdvn=localize&prod-snip=res_with_disabilities

Sprint (www.sprint.com). For customers with disabilities, www2.sprint.com/as_scope/values/consumer_info/home.do and select "Technology for all abilities", or go directly to http://144.226.116.21/as_scope/values/consumer_info/feature.do?article=1111510

Verizon (www.verizon.com). For customers with disabilities, www22.verizon.com/foryourhome/SAS/res_family_servfordis.asp

Footnotes

1 11 October 2004.

2 LCD is an acronym for liquid crystal display.

3 LED is an acronym for light-emitting diode.

4 04 October 2004.

5 04 October 2004.

6 04 October 2004.

7 04 October 2004.

Telephone terminals and accessibility with special reference to visual disabilities

Appendix A.1:

Residential wireline equipment: information from US manufacturers and distributors

Adjunct to a report prepared for
Canadian Radio-Television and Telecommunications Commission (CRTC)

by
Acuity Research Group Inc.

April 2005

Table of contents

Introductory comments

1 United States

1.1 Telephones
1.1.1 Manufacturers
1.1.2 Distributors
1.2 Adjunct equipment
1.2.1 Electronic aids
1.2.2 Mechanical aids

2 References

2.1 Manufacturers
2.2 Distributors

Introductory comments

One of the objectives of the present project was to characterise the availability of accessible telephone terminals. Appendix A examined the availability from telephone companies of telephones and adjunct equipment accessible to persons with a visual disability, looking at four jurisdictions:

Because of distance and the use of different telecommunications standards, the relevance to Canadian consumers of accessible telecom equipment in Australia and the UK is marginal, although its design and relative abundance can be instructive. By contrast, the United States shares telecommunications standards with Canada, and North America may be considered a unified market in this regard.

By implication, it is possible that Canadian consumers will acquire telecom equipment from US sources. While it is unlikely that they would acquire equipment from telephone service providers (telcos), they may acquire equipment from manufacturers or distributors. For this reason, we have prepared Appendix A.1 as a supplement to Appendix A. Whereas Appendix A focused on accessible equipment available from telcos, Appendix A.1 looks at a selection of accessible equipment available in the US from manufacturers and distributors.

Two types of products are considered in Appendix A.1:

1 United States

Appendix A.1 presents information about telecom equipment which is accessible to persons with a visual disability, and which is available from manufacturers and / or distributors. Telephones and adjunct equipment are described separately below.

1.1 Telephones

1.1.1 Manufacturers

Below, we present selected equipment from three equipment manufacturers. These manufacturers are AT&T, Clarity Products (formerly Walker-Ameriphone), and Panasonic.

1.1.1.1 AT&T

In the early 1980s, before the telecom industry in the United States underwent divestiture, AT&T was the telephone company in the US, providing local and long distance service and selling telecom equipment. With divestiture, AT&T ceased to exist as a local service provider, and Lucent became the equipment manufacturing company (later spinning off Avaya).

The AT&T identified here should not be confused with this former telecom monopoly. The AT&T website (http://telephones.att.com/attui/about/index.cfm?NavID=4.0) states1,

We are Advanced American Telephones. We design and produce the AT&T telephone products that you are viewing on this site -- the products that millions of people enjoy every day. Our voice quality, product selection, and reliability make AT&T telephone products your best choice.

AT&T telephone products reflect a long and distinguished history of product excellence dating back over 100 years. Today, our product line is one of the most extensive in the industry, including corded and cordless phones, answering systems, and phone-related accessories.

This website contains two telephones with Talking Caller ID, a low-price corded phone (Model 1818) and a 5.8 GHz cordless phone (Model 5870).

Model 1818 Digital answering system speakerphone

Feature list:

Price: US$29.95.

Model 5870 Cordless 5.8 GHz phone with Talking Caller ID

Feature list:

Price: US$169.95.

1.1.1.2 Clarity Products

Clarity Products (www.clarityproducts.com) is the new name for the company formerly known as Walker-Ameriphone. Clarity’s products are typically intended for users with a hearing impairment. (Searching the Clarity site by need reveals only three categories: hard of hearing, deaf, and limited mobility.)

In the present section we identify products that also contain accessibility features for persons with a visual disability. Some of the products identified below are still known as Ameriphone or Walker products. They are distributed through Radio Shack, as well as through other distributors (see below).

JB35 Amplified telephone with Braille characters

Eases phone use for persons with both low vision and hearing loss. Features:

Price: US$139.95.

W300 single-line phone

Single-line phone with Clarity® PowerTM technology amplifies incoming sound.

Keypad lighted, oversized for dialing ease.

Price: US$99.95.

JB20 Amplified Big Button phone

Designed for persons with low vision and mild hearing loss. Features:

Price: US$69.95.

W425 amplified cordless phone

Price: US$129.95.

1.1.1.3 Panasonic

Panasonic has a history of involvement in accessible communications. For example, Panasonic is one of the few telephone manufacturers to display products and collect feedback at conferences such as CSUN2 ("Technology and Persons with Disabilities").

For example, Panasonic has a portfolio of 6 telephones that offer Talking Caller ID3 (http://catalog2.panasonic.com/webapp/wcs/stores/servlet/ModelList?storeId=11251&catalogId=11005&catGroupId=20551). These are described more fully below.

Panasonic KX-TG5240M

5.8 GHz FHSS (frequency-hopping spread spectrum) GigaRange® Supreme Expandable Digital Cordless Phone System with Talking Caller ID and Digital Answering System. Features:

Price: US$149.95.

Panasonic KX-TG2357B

2.4 GHz FHSS (frequency-hopping spread spectrum) GigaRange® Dual-Handset Cordless Phone System with Digital Answering System and Talking Caller ID. Features:

Price: US$129.95.

Panasonic KX-TG5230M

5.8 GHz FHSS (frequency-hopping spread spectrum) GigaRange® Supreme Expandable Digital Cordless Phone System with Talking Caller ID. Features:

Price: US$129.95.

Panasonic KX-TG2356S

2.4 GHz FHSS (frequency-hopping spread spectrum) GigaRange® Digital Cordless Phone with Digital Answering System, Talking Caller ID, and Dual Keypad. Features:

Price: US$99.95.

Panasonic KX-TG2346S

2.4 GHz FHSS (frequency-hopping spread spectrum) GigaRange® Digital Cordless Phone with Digital Answering System and Talking Caller ID. Features:

Price: US$89.95.

Panasonic KX-TG2336S

2.4 GHz FHSS (frequency-hopping spread spectrum) GigaRange® Digital Cordless Phone with Talking Caller ID and Caller IQ4. Features:

Price: US$79.95.

The final telephone from Panasonic is the KX-TG2386B, a pre-release model on display at the CSUN conference in March 2004. Details are provided on the following page.

Panasonic KX-TG2386B

Panasonic’s model KX-TG2386B telephone (viewed at CSUN 2004) is described as having "all-new features for aiding the hearing- and visually-impaired". The phone is described as having "bolder font, higher contrast" than other phones. It retails in the U.S. for US$169 (price obtained from Panasonic).

The description identifies the following features (all material below is quoted from Panasonic’s product handout, with minor grammatical modifications):

The voice announcements are described as follows:

Features other than voice announcements are described as follows:

1.1.2 Distributors

At the CSUN conference in 2004, we obtained product catalogues from three distributors:

Their products are described below.

1.1.2.1 Independent Living Aids Inc.

Panasonic cordless phone with talking Caller ID and answering machine

Independent Living Aids Inc. catalogue (p. 43) provides the following description of this telephone (US$179.95):

Manufactured by Panasonic, it’s the one phone that offers all the features you may now have in separate units. It is a digital 2.4 GHz cordless phone with a 15 minute digital answering machine and caller ID that actually says the name even for call waiting. Other features include a visual 30 number caller ID memory, dual digital duplex speaker phone on base and handset, visual 50 number phone directory and dialer, illuminated keypad, back lit LCD5 on handset, headset jack, belt clip and is wall mountable.

Panasonic 2.4 GHz big button cordless phone

Independent Living Aids Inc. catalogue (p. 43) provides the following description of this cordless telephone (available in black or white, US$64.95):

Not only does it have large, lighted keypad buttons, but this phone includes Panasonic’s Voice Enhancer technology that analyzes incoming speech signals and recreates the lower and upper frequency bands that are often lost during transmission. Plus, it has a handset speaker phone, handset locator, headset jack, and visual ring indicator.

900 MHz Clarity amplified cordless phone with large numbers

Independent Living Aids Inc. catalogue (p. 43) provides the following description of this cordless telephone (US$139.95):

The Clarity® PowerTM enhances high frequency sounds that are difficult to distinguish on the phone and the handset amplifies incoming sound up to 30dB. To help the user hear or notice the ring, the tone can be customized and a bright light flashes in the base. It also has a large, lighted dial pad and 10 quick-dial memory buttons.

Large number 900 MHz cordless phone

Independent Living Aids Inc. catalogue (p. 43) provides the following description of this cordless telephone (US$59.95):

The large black numbers on the white pads make it easy to dial the right number, but if you have several people who you call regularly, you can put their numbers into memory and just press 2 buttons to dial them. Other useful features include its volume control, hearing aid compatibility, 40 channel auto scan, last number redial and base to handset page.

Ameriphone’s JV-35: Amplifier phone with jumbo-size buttons and Braille

Independent Living Aids Inc. catalogue (p. 44) provides the following description of this telephone (US$139.95):

An outstanding telephone that satisfies the needs of both the hearing and visually impaired.

Large number 900 MHz cordless phone with sound enhancement and lighted keypad

Independent Living Aids Inc. catalogue (p. 43) provides the following description of this cordless telephone (US$145.95):

Its powerful amplifier increases incoming sounds up to 100 times (40+dB) for extra loud and clear conversations. An adjustable tone control customizes the amplifier so you can understand similar sounding words. Has programmable 10 speed-dial memory, an extra loud ringer and is desk or wall mountable.

Brailled large number speakerphone

Independent Living Aids Inc. catalogue (p. 44) provides the following description of this telephone (US$39.95):

The large numbers on the keypad are raised, and have accompanying symbols in Braille. Besides these unique features, the phone has an adjustable ringer, a volume control, 13-number memory, visual ring indicator, a speakerphone, and re-dial and hold button.

AT&T corded phone with talking Caller ID and answering machine

Independent Living Aids Inc. catalogue (p. 44) provides the following description of this telephone (US$59.95):

A phone with large, widely spaced keys, 12 number memory, 3 emergency or priority one-touch keys PLUS a 19 minute digital answering machine and talking Caller ID. Additional features include, remote access with toll saver, call screening talking Caller ID that announces the phone number, variable speed playback, audible message alert, number block on/off, speaker phone, memory monitor, audible time/date stamp. Measures 7"x8". Comes with cassette instructions.

Giant button speakerphone with flashing ringer

Independent Living Aids Inc. catalogue (p. 45) provides the following description of this telephone (US$19.95):

In addition to 10 two-touch speed dialing, 3 programmable one-touch speed dials, hold button and last number redial, it is a two-way speakerphone with volume control. Measures 8.5" x 5.75" and has 1" x 1.25" buttons with large bold numbers.

1.1.2.2 LS&S

Big button speakerphone

The LS&S catalogue (p. 72) provides the following description of this phone:

Features: large, distinct numbers, speaker phone with volume control, 10 number speed dialing, flashing ringer light, ringer on/off, mute, and last number redial. US$19.95.

(There is a separate model which includes a digital answering machine. US$34.95)

Big button, visual ring indicator, Braille keypad, speakerphone

The LS&S catalogue (p. 72) describes this phone. Features:

US$35.95.

"Big button plus" 905

The LS&S catalogue (p. 73) describes this phone. Features:

US$29.95

Slimline big button phone

The LS&S catalogue (p. 72) provides the following description of this phone:

This slim, desktop phone features big buttons on the handset, enabling you to raise the phone closer to your face to read the numbers for easier dialing. Also features hearing aid compatibility, last number redial, and desk or wall mounting. US$14.95.

LS&S Inc. also distributes the Ameriphone (Clarity) JB20 (described in the Clarity Products section above) and the Ameriphone CL40 (cordless phone with a large, illuminated keypad).

1.1.2.3 TeleDynamics

Ameriphone AME-XL-30

The TeleDynamics catalogue (p. 57) provides the following description of this phone:

Extra large buttons with maximum contrast graphics for optimum visibility, amplified handset can also be set for outgoing voice for those with weak speech, 85dB tone ringer, ring flasher, 12# memory, redial, hold, wall mountable.

Ameriphone AME-XL-50

The TeleDynamics catalogue (p. 57) provides the following description of this phone:

Increases incoming sound up to 48+dB for severe hearing loss, adjustable tone control, audio output jack, extra bright ring flasher, super loud ringer (95+dB), bright voice mail indicator, hearing aid T-coil compatible, 12# memory, redial, hold, flash, wall mountable.

Ameriphone AME-JV-35

Jumbo-size buttons with Braille help you dial quickly and correctly. Phone also announces the numbers as you dial. When using a memory button, the phone will announce the name of the person you are calling, 10# memory, 37+dB amplification of calls, super-loud adjustable ringer up to 100 dB, extra bright ring flasher.

TeleDynamics Inc. also distributes the Ameriphone (Clarity) JB20 (described in the Clarity Products section above) and the Ameriphone CL40 (cordless phone with a large, illuminated keypad). As well, TeleDynamics distributes the voice carry-over VCO phone, which also has an oversized keypad.

1.2 Adjunct equipment

This section lists adjunct equipment designed for persons with a visual disability, either low vision or blindness. The products are presented in two sections: those requiring electrical power (electronic aids), and those which do not (mechanical).

1.2.1 Electronic aids

In this section, we describe products that require electrical power. For each product, the source is identified, whether manufacturer or distributor.

1.2.1.1 ClassCo (manufacturer)

Several devices are available that provide an audible announcement of information about incoming callers. One of the companies manufacturing these devices is ClassCo, of Concord, New Hampshire. Information about their products has been copied (with permission) from their website, and is shown below. All prices are in US dollars.

Background material: VoiceAnnounce® Caller ID and Internet Call Waiting Products

In the future, all telephones will announce the caller's identity instead of ringing.  You don't have to wait...  VoiceAnnounce® Caller ID products identify incoming calls and call waiting calls by announcing the caller’s name or telephone number.  You’ll know who’s calling when the phone rings.  You’ll know if the call is for you or for someone else.  You’ll know if the call is personal or business-related.  And you’ll know if it’s the type of call not worth your time – all without interrupting what you are doing.

VoiceAnnounce Caller ID products identify incoming calls by announcing the caller’s name or telephone number over a built-in speaker.  Calls can also be announced over existing corded and cordless telephone handsets, speakerphones, and handsets.  The identity of each call-waiting caller is privately "whispered" through your telephone handset or can be broadcast over the built-in speaker, alerting others to the presence of the call-waiting call.  Only the VoiceAnnounce product line delivers the convenience and security promised by Caller ID service.  Universal design makes VoiceAnnounce the Caller ID for everyone.

InTouch™ Internet call waiting products let you surf the net without missing important calls.  Most Internet users share a single phone line for Internet and telephone activities.  During Internet sessions, incoming calls are missed.  InTouch is the cost-effective way to create a "virtual" second line.  Using call waiting and/or call waiting ID telephone company services, InTouch identifies the presence of an incoming call.  InTouch models with integrated VoiceAnnounce Caller ID even announce the caller's identity.  All InTouch models let you answer the call using your existing telephones.  Now you can stay in touch while you're on-line.

VoiceAnnounce® Caller ID Model 9900CW

Lets you record names for up to 50 frequent callers.  Announces and displays caller’s NAME or 10-digit telephone number when the phone rings, and for call waiting calls.  Alerts other household members to a call waiting call.  Announces "Number Unknown" (usually telemarketers) and "Number Blocked" when people block their caller ID.  Stores 99 calls for review.  Dial back.  New call and message waiting light.  Operates on 9VAC adapter included. Price US$79.99.

VoiceAnnounce® Caller ID Model 560CW

Announces and displays caller’s 10-digit telephone number and displays caller’s name when the phone rings, and for call waiting calls.  Alerts other household members to a call waiting call.  Announces "Number Unknown" (usually telemarketers) and "Number Blocked" when people block their caller ID.  Stores 99 calls for review.  Dial back.  New call and message waiting light.  Operates on 6VDC adapter included. Price US$59.99.

VoiceAnnounce® Caller ID Model 500

Announces caller’s 10-digit telephone number when the phone rings.  Announces "Number Unknown" (usually telemarketers) and "Number Blocked" when people block their caller ID.  Stores 10 calls for audible review.  Operates on 3 AAA batteries included, or an optional 6VDC adapter. Price US$24.99.

InTouch™  Internet Call Waiting Model 5000

Internet call waiting with VoiceAnnounce® caller ID.  Detects the presence of a call-waiting call while on-line, and ANNOUNCES and displays the caller’s identity.  The called party can answer the call automatically using any standard telephone set, or play a short message to the caller indicating they will be called back later.  AC adapter included.  Call Waiting ID service is required. Price US$79.99.

InTouch™  Internet Call Waiting Model 510

Never miss another call while surfing the Internet!  Detects the presence of a call-waiting call while on-line and beeps and flashes to alert the user.   Disconnects the modem and connects the call automatically when the telephone is answered.  Or ignore the call and continue surfing.  AC adapter included.  Call Waiting service is required. Price US$49.99.

1.2.1.2 LS&S (distributor)

LED large number Caller ID

The LS&S catalogue provides (p. 74) the following description of this product (US$126.50).

This bright red, LED (light-emitting diode) display with 1" high numbers gives you an easy way to read your Caller ID. Unit can display either the caller name or number, or alternate between both. With a viewing screen over 8 inches long, it is easy to see who is calling you. When no one is calling, display shows you time and date. Stores the number and date of up to 99 calls so you can go back and review who has called you. Does not require batteries or additional power.

1.2.2 Mechanical aids

1.2.2.1 Independent Living Aids Inc. (distributor)

The Independent Living Aids catalogue offers two "mechanical" assistive devices.

Cell phone magnifying lens

The Independent Living Aids catalogue provides (p. 45) the following description of this product (US$6.95):

A 2X lens is framed by a rubber frame and flexible band that fits around just about any size cell phone and even portable phones.

Bold number overlays for cell phones

The Independent Living Aids catalogue provides (p. 45) the following description of this product (US$11.95):

Four flexible, heavy gauge, film bands that are silk screened in 4 combinations of colors – white or yellow of black, black on white or yellow. Bands are scored and die cut for easy positioning over the key pad of cell phones. Included is a bonus page of 150 stick-ons of symbols, words and numbers.

1.2.2.2 LS&S (distributor)

Of the 11 adjunct products described in the 2003 catalogues, 3 are mechanical products.

Easy to read push button phone attachment

The LS&S catalogue (p. 73) provides the following description of this product (US$9.45), which is shown on a standard 2500-type telephone set:

Large numerals – widely spaced on plastic cover to fit directly over standard desk type push button phones. White numbers on black background make dialing easier. Tape supplied for attaching to phone.

Bright and bold cell phone labels

The LS&S catalogue provides (p. 74) the following description of this product (US$11.95):

Finding small cell phone buttons can be so difficult, but with these clever labels, the task becomes much easier. Each kit provides 4 distinct sheets with different color combinations. Sheets wrap the cell phone keypad and fit most standard cell phones.

Cell phone magnifier

The LS&S catalogue provides (p. 74) the following description of this product (US$6.95):

Magnify your cell phone display 1.5X. Sticks directly onto the face of the phone and enlarges the whole viewing area. Fits most Nokia, Ericsson, AudioVox, and QualComm phones.

2 References

2.1 Manufacturers

AT&T Telephones (http://telephones.att.com/attui/index.cfm).

Clarity Products (www.clarityproducts.com).

4289 Bonny Oaks Drive
Chattanooga, TN, USA 37406
Phone: 800-552-3368
Fax: 800-325-8871

ClassCo Inc. (www.classco.com).

99 Airport Road
Concord, NH 03302, USA
Phone: 603-225-2990
Fax: 603-225-2998

Panasonic (www.panasonic.com).

2.2 Distributors

Independent Living Aids, Inc. (www.independentliving.com).

P.O. Box 9022
Hicksville, NY, USA 11802-9022
Phone: 800-537-2118
Fax: 516-937-3906

LS&S, LLC (www.lssproducts.com).

P.O. Box 673
Northbrook, IL, USA 60065
Phone: 800-468-4789
Fax: 847-468-1482
TTY: 866-317-8533

TeleDynamics, L.L.P. (www.teledynamics.com).

2200 Wheless Lane
Austin, TX, USA 78723-2097
Phone: 800-847-5629
Fax: 800-847-5675

Footnotes

1 17 October 2004.
2 CSUN is the acronym for California State University at Northridge, whose Center on Disabilities holds an annual conference in March entitled “Technology and Persons with Disabilities”.
3 17 October 2004.
4 Caller IQ is a free service available from www.ablecomm.com/calleriq.html.
5 LCD is an acronym for liquid crystal display.

Telephone terminals and accessibility with special reference to visual disabilities

Appendix B:

Wireless equipment and services

A report prepared for
Canadian Radio-Television and Telecommunications Commission (CRTC)

by
Acuity Research Group Inc.

April 2005

Table of contents

Introduction

1 Wireless telephones

1.1 UK

1.1.1 Vodafone UK

1.2 European Union (EU)

1.2.1 ALVA B.V.

1.2.2 Nokia

1.2.3 Owasys

1.3 Japan

1.3.1 NTT DoCoMo

1.4 United States

1.4.1 Audiovox

1.4.2 Motorola

1.4.3 PDA-type devices

1.5 Specifications for accessible wireless telephones

1.5.1 American Foundation for the Blind

1.5.2 Tiresias

2 Adjunct equipment for wireless products

2.1 ClassCo wireless products

3 Wireless services

3.1 Vodafone UK

3.2 Sprint

4 Procuring an accessible cell phone in Canada: a case study of a user with a visual disability

4.1 Background

4.2 Obtaining an accessible cell phone in Canada

4.3 Conclusions

Introduction

The main body of the report and Appendices A and A.1 are organised in terms of jurisdiction (e.g., country). In the case of wireless telephone terminals (such as cell phones), there is both more excitement and fewer products.

There is more excitement because cell phones, which were accessible to persons with a visual disability until they became display-based, are once again becoming accessible. This development is coming at a time when many subscribers are forsaking a wireline telephone altogether and using the cell phone as their primary or only telephone.

The reasons why there are fewer accessible cell products than wireline terminals is a topic for discussion, and should be considered in detail in a separate report dedicated to this issue. The area of accessibility and cell phones, as well as other wireless devices such as personal digital assistants (PDAs) and two-way pagers (such as the BlackBerry), should form a large part of such a report.

In the case of Appendix B, our goal is simply to point to areas where progress is being made in the exciting and fast-moving area of accessibility of wireless terminals.

1 Wireless telephones

1.1 UK

1.1.1 Vodafone UK

On 18 February 2003, Vodafone UK (www.vodafone.co.uk) issued the following press release:

VODAFONE LAUNCHES THE VODAFONE SPEAKING PHONE

From 18th February 2003 blind and visually impaired consumers for the first time will have use of text-messaging, electronic contacts and network information on a mobile phone with the new Vodafone Speaking Phone. The news comes as Vodafone UK continues to celebrate its new partnership with The Royal National Institute of the Blind (RNIB).

The specially adapted Nokia 9210i is capable of an "audible display" which also makes it possible to use text-based subscription services such as news, sports and weather alerts. Because the Vodafone Speaking Phone is a complete personal digital assistant, other features such as memo pad, document software, calendar and email are also available. Linking software allows synchronization of documents, address and calendar information with a personal computer via data cable.

"Vodafone is committed to providing the best solution for the visually impaired," commented Gavin Darby, UK Chief Executive Officer for Vodafone. "The Vodafone Speaking Phone is part of the company's commitment to ensuring customers with special needs are equal members of the Vodafone Community."

In December 2002, Vodafone UK and the RNIB announced a new partnership, which will open up the world of mobile phones to the visually impaired. Activities include Vodafone providing customer care staff at RNIB with training and demonstrations on all Vodafone products and services which may be beneficial to RNIB customers. The Vodafone Speaking Phone will be available from selected Vodafone stores, by contacting Vodafone on 0800 10 11 12 or by contacting the Royal National Institute of the Blind at RNIB Customer Services on 0845 766 99 99

On its home page, Vodafone UK has a direct link to "Special Needs". The "Special needs" page has three choices:

Selecting "sight problems", one is given two choices:

Selecting "Advice on handsets", one finds the following text (02 December 2004):

There is no 'ideal' mobile phone for anyone, regardless of any disability. However, if you're blind or partially sighted, you may want to look for some of the following features on your new mobile:

Keypad

A keypad with large, well spaced keys

A raised dot on the number '5' to help you find your way around the keypad

Back-lit keys that are easier to see

Tones

Tones that sound when you press a key

The ability to choose different ringtones for different people

A warning 'beep' when the battery is running low

Screen

A large, clear display screen

A contrast or brightness control

The option to change the size of characters on the screen

Control

Voice activated calling, so that you can call someone's number by speaking their name

There is also a link to a Vodafone speaking phone with screen reader, which offers the following description:

It's here! The first mobile phone with built in screen reader. Available on a range of pay monthly price plans. The Vodafone Speaking Phone, Nokia 9210i Communicator costs just £499.99 including pre-loaded software, audio CD guide to using the screen reader, and back up CD in as well as standard battery, charger, data suite and serial port cable, for connecting to your PC.

What is it?

The Vodafone Speaking Phone is a Nokia 9210i Communicator with in-built text-to-speech software that reads the screen.

Where can I get it

The first Vodafone Speaking Phone is available to handle at the following Vodafone Stores as well as the RNIB Resource Centre in Judd Street, London. If you can't get to a store and want to order one on the 'phone call Vodafone on 0800 10 11 12 or RNIB customer services on 0845 766 99 99.

Welcome to the text revolution! For the first time blind and visually impaired customers will be able to send & receive text messages. Not only will this mean simple silent communication with seeing friends and family, it will also open up the world of text-based services such as news, sports and weather alerts.

Users can also check network coverage and battery strength, vital information previously inaccessible to blind or visually impaired users. The Nokia 9210i Communicator is a multi-tasking tool, so users will not only have use of a mobile phone, but also an address book, memo pad, calendar document software and email. All of this in a standard handset, this Vodafone Speaking Phone doesn't look like an assistive device and with headphones, it can be used in complete privacy so it doesn't sound like one either.

1.2 European Union (EU)

The present section considers advances from two companies which are relatively new entrants to the field of cellular accessibility (Alva, Owasys) as well as Nokia, a world leader in cell phone design and sales.

1.2.1 ALVA B.V.

The Dutch company Alva B.V. has developed a product line called the Mobile Phone Organizer (MPO) (www.alvampo.com/). This is a hand-held device about the size of a No. 10 envelope (24 cm long x 10.5 cm "high") and is about 4.5 cm thick.

The MPO 5500 provides Braille input (8-dot) and output (20 Braille cells of 8 dots each). It weighs 775 g, and supports the following functions:

The MPO 5500 has a list price of about US$4,295.

The MPO 5200 is still in prototype stage. It supports Braille input, but has no Braille output. It weighs 620 g, and supports the following functions:

The manufacturer is working on pricing for the MPO 5200, but expects it to be about US$2,800.

1.2.2 Nokia

The website of the Finnish cell phone designer Nokia has a large section devoted to accessibility (www.nokiaaccessibility.com/resources.html). The section of this website that concerns vision (www.nokiaaccessibility.com/vision.html) has several sub-sections, described briefly below.

1.2.2.1 Text-to-speech software

The Nokia website notes that some "9200-series Communicator models are compatible with text-to-speech software that provides audible feedback by reading the text on the screen out loud". (See, for example, the Vodafone section above.) In addition, "A Braille keyboard is also available for some Nokia Communicator models".

One type of text-to-speech software that is receiving good acceptance in the market is TALKS (formerly TALX), produced in Germany. This software is supported by the Symbian operating system.

1.2.2.2 Other accessibility features

The Nokia accessibility site also describes other accessibility features for users with a visual impairment.

Voice Control

Phones like the Nokia 6620 let you control popular functions by repeating pre-recorded voice commands. And many Nokia phones allow you to dial a number simply by speaking a name out loud.

Audio Feedback

Nokia phones like the Nokia 3595 have distinct sounds to alert you to the strength of the wireless signal and the level of the battery.

Screens

Large, high-resolution displays and backlit displays offer better visibility. Color displays -- like the screen on the Nokia 6100 -- offer brightness controls and even a choice of text and background colors. And the Nokia 3650 offers adjustable fonts, so you can choose the text style and size you prefer.

Keys

Raised nibs help you indentify keys by touch. Distinctive shapes help you easily tell the difference between number keys and function keys. And many phones -- like the Nokia 3650 -- have backlit buttons for better visibility in low light. Nokia phones also offer convenient keypad shortcuts like one-touch dialing, so you can dial a complete phone number by pressing just one number key from 2 to 9. And you can answer the phone by pressing any key.

PC Suite

PC Suite lets people with vision or mobility impairments use a personal computer to share information with their Nokia phone. You can take advantage of the large screen and full-sized keyboard of your PC, using it to install software on the phone, configure phone settings, and make backups of phone files. You can also synchronize calendars, contacts and tasks with Microsoft and Lotus applications, copy and move images on your PC and phone, and copy contacts and calendar information from another Nokia phone or a Palm device.

PC Suite requires a compatible PC running Windows 98 SE, Windows ME, Windows 2000 with Service Pack 2, or Windows XP, along with at least 110 megabytes of free disk space.

1.2.3 Owasys

Owasys is a Spanish company that is in the process of producing cellphones compatible for persons with a visual disability. Two models were shown at the CSUN conference in 2004: the owasys 22c and the owasys 112c. Neither phone has a display.

On 31 March 2004, the on-line industry journal PhoneContent.com reported (www.phonecontent.com/bm/news/gnews/244.shtml):

In what it said was a first for Europe, Spanish telecommunications operator Telefonica has unveiled a voice-activated mobile telephone for blind people.

The phone is the fruit of cooperation between Spanish computer terminals producer Owasys and Spanish organisation for the blind ONCE, which has 65,000 members, the companies said in a joint statement on Wednesday.

The phone has no screen and whereas it comprises a conventional keyboard for actual dialling, other functions such as messaging will be voice activated.

1.2.3.1 Owasys 22c

Information about Owasys 22c, an accessible cellphone, can be obtained at the website (www.owasys.com/accesible_en/products.php?PHPSESSID=2abfc61ebeee268f8ab235ec333834b0), from which a product description may be downloaded in pdf format. Specifications on the website include the following information:

Features

PHONE FEATURES

SPECIFICATIONS

Size

Phonebook

Call Management

Messaging

Power Management

1.2.3.2 Owasys 112c

According to the website (www.owasys.com/index_en.php), the 112c is "designed for elderly and people with disabilities". Information about Owasys 112c can be obtained at the website www.owasys.com/index_en.php, from which a product description may be downloaded in pdf format.

1.3 Japan

1.3.1 NTT DoCoMo

In October 2002, the on-line journal Disability Information Resources published an article (www.dinf.ne.jp/doc/english/other/wz_mobile_e.htm)  on mobile phone developments in Japan1. In part, the article read:

For blind users, the advent of the mobile phone or the TV phone that reads incoming e-mail aloud will probably have a great impact on their lives. Sadao Hasegawa, representative of TeleSupport NET, has introduced a new support system that utilizes the 3G TV mobile phone "FOMA" system launched in October 2001 by NTT DoCoMo, the largest company in the mobile phone industry in Japan.

With this system, a person with visual impairments communicates with a supporter who is in a different location through the use of a TV and mobile phone. The blind person directs the camera toward whatever needs explanation while he/she is out or at home, and sends the image to the supporter. Acting as the eyes of the user, the supporter explains the received image, and the user hears the explanation through an earphone which is connected to the mobile phone. Using this device the user can walk safely and avoid obstacles.

1.4 United States

1.4.1 Audiovox

Audiovox was a manufacturer of wireless telephones until 15 June 2004, at which point it "agreed to sell its wireless telephone division to UTStarcom Inc."; it said that "it is exiting the wireless handset business because it no longer has ‘the capabilities to be a major player in that market’" (Globe & Mail, 15 June 2004, page B12).

On the Audiovox website (www.audiovox.com), one selects "Find a product", then "Communications", then "Wireless telephones", and is presented with 6 options:

There is no "accessibility" information evident on the website, nor is there a Search function. Thus, the user must search each category separately. We were unable to find any accessibility-related information on the Audiovox website.

1.4.2 Motorola

Motorola (www.motorola.com) is one of the world’s leading manufacturers of wireless equipment. Navigating the Motorola website to "consumer products" and selecting the United States as the territory of interest, entering "accessibility" into the Search field returns

1.4.3 PDA-type devices

An article entitled "New handhelds target the blind" recently appeared in PocketPCCity (01 July 2004; www.pocketpccity.com/articles/2004/7/2004-7-1-New-Handhelds-Target.html). This article reviewed the BrailleNote PK from PulseData International and the Maestro from VisuAide and HP. The reader is referred to this article for reviews; of interest here is that the BrailleNote PK has a target price of US$4,995, and the price of the Maestro was not disclosed.

1.5 Specifications for accessible wireless telephones

1.5.1 American Foundation for the Blind

The American Foundation for the Blind (AFB, www.afb.org) has a division that is charged with testing devices to determine their accessibility for persons with a visual disability. AFB TECH, as this division is known, began testing cell phones for accessibility in 2003 and publishing the results in the AFB publication AccessWorld. The opening paragraph of the March 2005 article (www.afb.org/afbpress/pub.asp?DocID=aw060206) reads:

Since May 2003, AccessWorld has published a groundbreaking series of seven articles that have evaluated the accessibility and usability of several cellular telephones and add-on software applications. In this article, in response to readers' suggestions, we at AFB TECH (the American Foundation for the Blind Technology and Employment Center at Huntington, West Virginia), have put together a summary of the options that are currently available to cell phone users who are blind or have low vision. So, this is not a traditional product-evaluation article in which we compare the relative merits of particular products. Instead, it is a summary of the information available at this time, designed to help readers make informed choices for purchasing a cell phone and a service plan and to clear up any remaining confusion.

This article provides an excellent status report of the accessibility of cell phones in the United States; these findings can be extended to Canada in terms of cell phone functionality, although not necessarily with respect to service provider support.

The reader is referred to the original article for a comprehensive analysis. Briefly, the article notes that cell phones only became inaccessible to persons with visual disabilities when the functionality became display-driven. Thus, a key challenge is to make the display "visible" by means of screen reader software or built-in accessibility features.

Screen reader software is available for phones running the Symbian operating system, including Symbian series 60 cell phones and Symbian series 80 cell phones, which include larger devices such as personal digital assistants (PDAs) and communicators. The actual accessibility software is manufactured by ScanSoft (TALKS software, now called SpeechPAK TALKS) and Code Factory (Mobile Speak, Mobile Accessibility, Mobile Magnifier).

Built-in accessibility features are currently included on fewer phones. Examples include the Toshiba VM4050 and the LG VX4500 (also known as the VX5500).

In addition, AFB TECH has generated a list of the "sweet 16" features that blind cell phone users most want to be made accessible (www.afb.org/Section.asp?DocumentID=2419). This list is presented in Section 5.1.1 of the body of the present report; the top 3 items are reproduced below:

  1. Keys that are easily identifiable by touch
  2. Voice output
  3. Accessible documentation

1.5.2 Tiresias

As discussed in Section 5.3 of the body of this report, the (European-centred) Tiresias website (http://www.tiresias.org/phoneability/telephones/blindness.htm), in combination with UK-based PhoneAbility, has identified several design considerations that are "essential" or "desirable" for persons who are blind, who have a severe visual impairment, or who have a moderate visual impairment. The reader is referred to Section 5.3 of the body of the report for details.

2 Adjunct equipment for wireless products

2.1 ClassCo wireless products

As well as adjuncts for wireline terminals, ClassCo (www.classco.com) also offers products for use with wireless devices. In this case, the spoken-identification feature enables drivers (for example) to keep their hands on the wheel when receiving a call on their mobile phone.

Extends CID and CIDCW services to users of wireless Bluetooth™ telephones and headsets.

Reduces driver distraction by allowing drivers to keep their eyes on the road

3 Wireless services

3.1 Vodafone UK

Vodafone UK (www.vodafone.co.uk) offers a "Vocalise 1471" service, which provides audible information about the last number that called.

Just dial 1471 to hear the telephone number of the person that last called you. You will also be given the time they called and the date. Especially useful if you are blind or partially sighted. Click here to find out more about Vodafone Vocalise 1471 and other ways of finding out who last called you.

The service is further described as follows:

Vodafone Vocalise 1471 will tell you who last called your Vodafone mobile phone. It will also tell you the time and date that the call was made. All numbers including landline or international numbers will work, so it doesn't matter if the person called you from a landline or another mobile phone. Dialling 1471 will tell you the last caller whether or not you answered it.

Selecting "Advice on services", one finds the following text:

Services that may be of interest to customers who have problems with their sight.

Your last caller
If you miss a call and discover that your caller hasn't left a message, it's easy to find out who it was. When you call 1471 from your mobile, you'll hear an announcement telling you the number of the last person that phoned you. This service is currently free of charge.

Voicemail
Vodafone Voicemail is an answering service for your mobile phone. If someone calls and you don't answer - even if your mobile is switched off - Voicemail takes a message and lets you know. You can also return the call from within Voicemail by pressing 5 twice, so there's no need to remember your caller's number and fewer keys to press to get back in touch.

Simply call 121 to start using the service. There's no extra monthly charge for using it, you just pay for the phone call when you're listening to messages and setting the service up. Most of our 'pay monthly' price plans include a fixed amount of calls with the monthly charge, which means that you can listen to your Voicemail messages and make calls at no extra cost.

Vodafone Mail
Vodafone Mail lets you use email on your mobile phone by putting it in the same convenient 'mailbox' as your voice messages. It lets you receive messages in two different ways: voice email speaks your email messages to you, whilst internet email lets you read and reply to messages by using the web.

Vodafone Mail is compatible with almost all email services except AOL, Hotmail and some company email systems. Please click on the www.vodafone.net link below to get set up then call 242, or simply call our special needs customer service team on 33222 from your Vodafone mobile phone and we’ll be happy to help you set this service up.  

Directory Assistance
Customers who are unable to use a phonebook can register to receive FREE access to the Vodafone Directory Assistance service. To do this, you first need to have a special PIN code from BT, which can be obtained and registered by calling 195 from a BT phone (not from your mobile phone). You'll then be able to use the Vodafone Directory Assistance service by calling 195 whenever you need someone's number.

When we've found the number you need, we can connect you to the person we've found. Calls to 195 are FREE for the first 75 seconds and then cost just 15p per minute.

If you're not registered to use 195, you can call our regular Directory Assistance service on 11 88 88 (11 88 88 is the new telephone number for the 'old' 192 service and the 197 Through Connect service). They can also search through UK or international telephone numbers to help you find the person you want. They'll text or read you the number you need and can connect you so you don't have to hang up and dial again.

Calls to 11 88 88 cost 55p for the first minute, then 25p per minute thereafter; the minimum call charge is one minute, with no extra charge for text messaging. The text message and connection facility are available for UK numbers only. All prices include VAT at the current rate and apply within the UK.  

3.2 Sprint

Sprint’s website (www2.sprint.com/as_scope/values/consumer_info/home.do) provides information on various corporate initiatives designed to make its products and services more accessible. The information below is taken from the Sprint website and was selected because it relates to visual disabilities. Other material, not included here, concerns hearing and speech disabilities.

Sprint is committed to making its handsets user-friendly and accessible to customers with disabilities. Sprint works with manufacturers to design easy-to-use handsets that incorporate a host of features and functions that help hard-of-hearing, deaf, visually-impaired, speech-impaired, blind, and cognitively disabled customers.

Examples of accessibility features include tactile marking of the "5" key, large font display, vibrating ringer, one-touch dialing, etc.

To learn more about the features and functions of specific handsets, please visit a Sprint Store or SprintPCS.com.

Sprint is well on its way to building speech recognition into its handsets and network. Today, many PCS Phones have voice activated dialing software that allows a user to enter a list of names and numbers that can be dialed by speaking into the microphone.

Sprint also offers Sprint PCS Voice Command - a much more expansive network-based voice activated dialing platform employing second generation speech technology. Sprint PCS Voice Command service can greatly benefit blind or visually impaired customers because it eliminates much of the key punching otherwise required to make calls. Please visit the Sprint PCS Voice Command site to learn more about this service.

Sprint is happy to provide its wireless customers with billing statements in Braille or large print formats. Please contact Customer Solutions to obtain this service. Please note, you will receive your billing statement in Braille or large print approximately two weeks after the initial bill.

Wireless handset manufacturers are required to offer handset user guides in alternate formats. Please contact the manufacturer.

4 Procuring an accessible cell phone in Canada: a case study of a user with a visual disability

As noted above, there have been advances in making cell phones accessible for persons with a visual disability. However, it is still the case that sighted users have a much wider choice of products, a wider choice of service providers, and more moderate costs to cope with than do users with a visual disability. Moreover, the potential availability of such accessible cell phones in other markets does not address the situation faced by the Canadian user with a visual disability.

The purpose of the present section is to relate, in case study form, the steps followed by a blind Canadian consumer (who we will call Mr. C, for "consumer") in his quest to acquire a cell phone that is accessible to him.

4.1 Background

Mr. C is an IT professional who has a comprehensive knowledge of telecommunications and data communications, has good software skills, and has a consuming interest in accessibility. Despite his visual disability, his technical knowledge and skills far exceed those of "average" Canadian consumers regardless of their disability status.

Because he follows the accessibility literature, Mr. C had learned about advances in cell phone accessibility from a number of sources. One of these sources is AccessWorld, a publication of the American Foundation for the Blind (AFB; www.afb.org). Four articles have appeared recently in this publication that are relevant to this topic:

4.2 Obtaining an accessible cell phone in Canada

In late June 2004, Mr. C looked on the Web to see what was available. From the articles in AccessWorld, he knew about the Nokia 6620, a cell phone that supports the TALKS (formerly TALX) screen reader, which had previously been developed in Germany and which is supported by the Symbian operating system.

Mr. C’s research led him to identify several cell phones which could support the TALKS software; these are listed on the TALKS website (www.talx.de/index_e.shtml), and include several which are not available in Canada. Two Canadian TALKS dealers are listed on this website: Frontier Computing in Toronto (www.frontiercomputing.on.ca), and Aroga (www.aroga.com/), headquartered in Vancouver.

The following shopping list was required to obtain a cell phone accessible to blind users in Canada:

Via eBay, Mr. C obtained an unlocked Nokia 6620 from Romulus Communications (in the US) for US$259 (US$302 including shipping). He ordered it on 25 October 2004, and it arrived on 29 October 2004. This phone did not include the TALKS screen-reading software, which he obtained from Frontier Computing (Toronto), loading the software onto the cell phone himself. Finally, with the help of an industry contact, he obtained the appropriate SIM card.

His telephone was activated, and he is now the owner of a cell phone that works on the Canadian network and is accessible to blind users.

4.3 Conclusions

Currently, wireless service providers in Canada do not have, in their portfolio of cell phones, a product that is accessible to blind users. There could be several reasons for this, including technical barriers, equipment availability, software availability, compatibility of the software with the equipment and the equipment with the network.

Through the efforts of one determined and knowledgeable blind Canadian, it is clear that none of the potential barriers identified above is relevant:

The case study described here makes it clear that, with incredible persistence, a good knowledge base, relatively deep pockets (in terms of disposable income), and a network of contacts able and willing to help, it is possible for a Canadian user to obtain a cell phone that is accessible to persons who are blind.

By implication, the major barriers to the availability of a cell phone accessible to blind Canadians appear to be the equipment procurement and marketing practices of the wireless service providers in Canada. In other markets, blind users are able to benefit from advances in the design of cell phones, operating systems, and screen reading software. It would be regrettable for this discrepancy to persist, for such persistence could be interpreted as neglect of this user group by Canadian wireless service providers, and could be interpreted as discriminatory.

Whether this perceived discrimination be rooted in disinterest or lack of awareness is irrelevant; either root cause is easily addressable. Moreover, it should be addressed in such a way that visually impaired Canadians who wish to appreciate the benefits of technology not be placed in a position where doing so incurs a greater financial penalty than that experienced by sighted Canadians.

Finally, it must be mentioned that, while the Nokia cell phones which support the TALKS software may be suitable for blind users who can benefit from the screen reader, they are less than optimal for other users, including those with a moderate visual impairment. Unfortunately, the buttons on these cell phones are not readily discriminable by touch (as pointed out in AccessWorld of November 2004). Ironically, blind users who are accustomed to a screen reader – which speaks the button name – may find this handset more accessible than sighted users attempting to use the dialpad in the dark, and almost certainly will find it more accessible than a user with a moderate visual impairment who can neither read the labels nor discriminate by touch, and who will not have installed the TALKS software.

Footnote

1 Japan: Myriad of Developments for Mobile Phone Users. Disability Information Resources, October 2002.

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