PsL Monthly 1993 December/PSL Monthly Shareware CD-ROM (December 1993).iso/prgmming/dos/tools/vi_soft.exe/SOFTWARE.TXT

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                   Making Software More Accessible

                     for People with Disabilities



     A White Paper on the Design of Software Application Programs
     to Increase Their Accessibility for People with Disabilities






                             Prepared by
                     Gregg C. Vanderheiden Ph.D.
                           Trace R&D Center
                   University of Wisconsin-Madison
        in conjunction with Information Technology Foundation
                     (formerly ADAPSO Foundation)

       as a resource document to software developers interested
    in increasing the accessibility of their application programs



                             Release 1.2
                              June, 1992




       This White Paper is designed to stimulate discussion on
         the design of more accessible application software,
      leading to the development of design guidelines for use by
      industry.  Comments, corrections, input, ideas, and issues
            are solicited.  Address comments to: Gregg C.
                         Vanderheiden, Ph.D.,
         Trace R & D Center, Dept of Industrial Engineering,
          University of Wisconsin-Madison, Madison, WI 53705


                 (c) Copyright 1991 Board of Regents
                    University of Wisconsin System

       NOTE: To facilitate this document's review and use, you are
       free to duplicate and disseminate it freely.  You may also
       excerpt ideas and materials from it freely.  Acknowledgement is
       appreciated but not required.

       However, some of the charts and concepts in this document are
       taken from other authors and publications.  These are so
       marked, and separate permission must be sought directly from
       those authors or publications before use (apart from copying
       this whole document).





              Support for this work has been provided by
       the Information Technology Foundation (formerly ADAPSO )
                                and by
  the National Institute for Disability and Rehabilitation Research
                               (NIDRR)
      of the US Department of Education under Grant #G00850036.





       The opinions expressed in this document are those of the author
       and do not necessarily reflect the opinions of the Information
       Technology Foundation, the General Services Administration
       (GSA) or the National Institute for Disability and
       Rehabilitation Research (NIDRR).

                          Table of Contents

.Begin Table C.


Introduction...............................................1
  What Is Meant by Accessibility?..........................1
  The Purpose of This White Paper..........................1

Part I: Why Make Application Software More Accessible?.....3

Part II: What Problems Do People
  with Disabilities Have?  and Why?........................7
  Disability has many facets...............................7
  Visual Impairments.......................................8
     Background............................................8
     Functional Limitations Caused by Visual Impairments...8
     Difficulties Using Computers and Software.............8
     Access to Documentation...............................8
  Hearing Impairments......................................9
     Background............................................9
     Functional Limitations Caused by Hearing Impairments..9
     Access to Support Services............................9
  Physical Impairments....................................10
     Background...........................................10
     Functional Limitations Caused by Physical Impairments10
  Cognitive/Language Impairments..........................11
     Background...........................................11
     Functional Limitations Caused by Cognitive Impairments
       11
  Seizure Disorders.......................................12
  Multiple Impairments....................................12

Part III: What is the Role of Standard Application
  Software Manufacturers in Computer Accessibility?.......13
  Computer Accessibility: A Cooperative Undertaking.......13
     The Role of the Hardware and Operating System
       Manufacturers......................................13
     Role of Third-Party Access Manufacturers.............14
     Role of Application Software Manufacturers...........15
     Role of Systems Integrators..........................16
       Selection of the Hardware / Operating System
          Platform........................................16
       Selection of Standard Application Software.........17
       Accessibility of Training Programs and Materials...17
       Ability of Integrators to Set Up
          and Provide Maintenance for Their Systems.......17

Part IV: What Are Others Doing that
  Application Software Manufacturers Can Take Advantage Of?
  19
  Access Strategies for Individuals with Visual Impairments
     (Available via Platform or Third-party Manufacturers)19
     Low Vision...........................................19
     Blind Access (also used by individuals with low
       vision)............................................20
     Advanced Graphic Access Techniques (for GUIs)........20
     Braille..............................................20
     Input and Control Systems for People with Low
       Vision/Blindness...................................21
  Access Strategies for Individuals with Hearing Impairments
     (Available via Platform or Third-party Manufacturers)21
  Access Strategies for Individuals with Physical                                          i
     Impairments
     (Available via Platform or Third-party Manufacturers)22

     Modification to Standard Keyboard Devices............22
     Alternate Input Techniques...........................24

Part V: What Should Application Software Manufacturers Do?
  -- Overview --..........................................25
     1) Using an Open Systems Approach....................25
     2) Cooperation with Access Utilities
       and Access Features in the Operating System........25
       Using System Tools and Conventions/Standards.......25
       Provide Software Access to Commands................25
     3) Designing Software to Minimize the Skills
       and Abilities Needed to Operate It.................26
     4) Providing More Accessible Documentation and
       Training...........................................26
       Electronic Documentation...........................26
       Print Documentation................................27
       Training...........................................27
     5) Product Testing with Access Software and Hardware.28
     6) Provision of Special Customer Support Lines or
       Specialists........................................28
     7) Provision of Special Developer Support Lines or
       Contact People for Third-Party Manufacturers of
       Access Software and Hardware.......................29

Appendix A
  Initial Listing of Specific Techniques
  for Increasing the Accessibility of Application Software31

Appendix B
  Resources Available to Help.............................41

Appendix C
  A Collection of General Notes on Accessibility
  (with specific comments in relation to
  Computers and Application Software).....................45
.End Table C.



























                                          ii



                           .c.Introduction




A variety of federal and state legislative actions, not the least of
which is the Americans with Disabilities Act, have combined with
public sentiment resulting in increasing emphasis on accessibility.
In concert with this movement, the software industry has been asked to
make its products more accessible to people with disabilities.  This
has raised questions among the members of this industry as to what
exactly the problems are, and what specific types of steps they can
take to help make their products more accessible.  This paper is a
first step in an effort sponsored by the software industry to create
materials for themselves which will help to address these questions.
Since the industry contains both advocates and skeptics, and
individuals who are knowledgeable in this area and those to whom this
is entirely new, this document serves several purposes.  First, it is
a mechanism for those who have knowledge to collect and present that
information which is known.  Second, it is a mechanism to document the
rationale and importance of software accessibility.  Third and most
important, it is a means to disseminate information to and among
designers and policy makers within industry to help them better
understand the problem and what they can do to help ensure that their
products are more accessible.


.c.:What Is Meant by Accessibility?

Accessibility refers to the ability of products and environments to be
used by people.  In this particular context, accessibility is used to
refer to the ability of standard application software to be accessed
and used by people with disabilities.  Although the way people access
the software may vary, a program is accessible to an individual if the
individual is able to use it to carry out all of the same functions
and to achieve the same results as individuals with similar skills and
training who do not have a disability.  (For a further discussion of
accessibility, see Appendix C.)


.c.:The Purpose of This White Paper

This particular document is targeted toward application software
developers.  However, it is not possible to make applications more
accessible unless the basic hardware platforms on which they are
running also include accessibility features.  Thus, understanding
"application software accessibility issues" requires an understanding
of the roles that computer manufacturers, operating system
manufacturers, and third-party accessibility developers all play in
making computer systems more accessible.  A key point of this
document, therefore, is to examine the overall accessibility issue,
and separate those aspects which must be addressed by others (hardware
manufacturers or third-party assistive device manufacturers) from
those issues which must be addressed by the application software
manufacturers, so that application software manufacturers can more
clearly understand their role in this area.

To achieve these objectives, this overall paper is organized into five
sections, centered around the following questions:

       I. Why make application software more accessible?
                                          1
       II. What problems do people with disabilities have? and why?

       III. What is the role of manufacturers of standard application
       software?  How does it relate to the role of computer
       manufacturers; of operating system manufacturers; and of third-
       party assistive device manufacturers?

       IV. What are manufacturers of computers, operating system and
       special devices doing that application software manufacturers
       can take advantage of?

       V. What could application software manufacturers be doing
       (overview)?

These are followed by four appendices:

       Appendix A: Specific guidelines for the design of standard
       application software that would increase its accessibility

       Appendix B: Resources are available to help

       Appendix C: A Collection of General Notes on Accessibility

       Appendix D: Section 508 Procurement Guidelines

This paper represents the beginning of a process to compile a document
(a software design guideline) to address these and related questions.
Input to this industry/researcher/consumer cooperative effort is
sought from all interested parties.  Anyone can participate in the
process by marking up and returning a copy of this paper or submitting
additional comments, problems, or ideas.

This cooperative effort is sponsored by the Information Technology
Foundation, a non-profit foundation of the Information Technology
Association of America (formerly ADAPSO), a trade association which
includes software manufacturers, and by the National Institute on
Disability and Rehabilitation Research (NIDRR) of the U.S. Office of
Education.  The effort is headquartered at the Trace Research and
Development Center of the Waisman Center and Industrial Engineering
Department at the University of Wisconsin-Madison.

NOTE:  The opinions expressed in this document are those of the author
and do not necessarily reflect an official position of the Information
Technology Foundation, the General Services Administration (GSA) or
the National Institute for Disability and Rehabilitation Research
(NIDRR).



















                                          2



      .c."Part I: Why Make Application Software More Accessible?




There are many reasons for a company to consider making their
applications more accessible.  They include:

    1) One in ten citizens has a disability of some type.  It is
       estimated that seven to nine out of every ten major
       corporations employ individuals with disabilities who may need
       to access software as a part of their job.

       There are between thirty and forty million people in the United
       States who have disabilities which affect their ability to use
       computers and application software.  At the same time,
       computers are becoming integral parts of our living,
       educational and working environments.  As a result, there is a
       growing concern that if computers, operating systems and
       application software are not accessible to this fairly large
       portion of our population, they will be unable to participate
       effectively in these environments.

    2) Our population is rapidly aging.  The number of individuals
       with disabilities or who have functional limitations is
       continually growing.  Every year, this population includes more
       and more computer users.

       The population is steadily growing older.  As we age, most of
       us lose some of our physical, sensory, or mental abilities.  By
       age 55, 25% of us will experience functional limitations (see
       Figure 1).  By age 65, this percentage will rise to 50%.  For
       the growing number of us who will live to be 70 years old or
       older, 75% will experience functional impairments.  In fifty
       years, it is estimated that more than a third of the population
       will be over age 55 and a sixth will be over 70 (based on US
       Congress Office of Technology Assessment OTA-BA-264).

                      .G.FIGURE1.TIF;3.75";3.088";TIFF

       Figure 1 shows a series of 8 pie charts, each representing an
       age group and the percentage having functional limitations or
       severe functional limitations:
          15-24 years:  1% with functional limitations; minimal with
          severe limitations
          25-34 years:  7.5% with functional limitations, 2% with
          severe limitations
          35-44 years:  13.4% with functional limitations, 3% with
          severe limitations
          45-54 years:  23% with functional limitations, 6% with
          severe limitations
          55-64 years:  34.2% with functional limitations, 12% with
          severe limitations
          65-69 years:  45.4% with functional limitations, 18.5% with
          severe limitations
          70-74 years:  55.3% with functional limitations, 22% with
          severe limitations
          75+ years:  72.5% with functional limitations, 41% with
          severe limitations

    3) Standard software which is designed to be usable by individuals
       with performance limitations is also usually easier to use by                                          3
       everyone else.

       Curbcuts were put into sidewalk street corners for people in
       wheelchairs, but for every one person in a wheelchair who use
       these curbcuts, there are ten individuals with bicycles, carts,
       baby strollers, etc. who use the curbcut.  Similarly, the
       adaptations to software for people with disabilities that make
       the software easier to see on the screen, operate from the
       keyboard, understand, etc., also make the software easier to
       use quickly, efficiently, and without errors for individuals
       who do not have disabilities.  One example is MouseKeys, a
       feature that was added to operating systems to allow people who
       cannot use a mouse to move the mouse cursor from the keyboard.
       This feature is also commonly used by people doing graphics
       layout to make fine adjustments in graphic positioning, because
       it allows precise, pixel-by-pixel movement from the keyboard
       which is not possible using the standard mouse.

    4) Software compatible with accessibility software is usually also
       more compatible with software extensions and to cross-program
       scripting utilities.

       Some of the principle strategies for making application
       software more compatible with disability access software
       include:

         -  doing things in the standard fashion (i.e., following user
            interface guidelines),
         -  using system tools,
         -  supporting inter-application communications and other
            means for one piece of software to issue commands to, and
            extract information from, another application program.

       These also make the program more compatible with other
       nondisability-related system extensions and inter-application
       macro and scripting utilities.

    5) The Federal government is interested in software applications
       that are more accessible and "accessibility aid friendly."
       Some of this interest is backed by legislation.

       Among the legislative efforts is Section 508 of the
       Rehabilitation Act.  This mandates the General Services
       Administration of the U.S. Government to work with the National
       Institute on Disability and Rehabilitation Research to develop
       guidelines for the purchase of computers and other electronic
       office equipment in order to ensure that the equipment
       purchased by the Government is accessible to its employees with
       disabilities.  The text of Section 508 is provided in Figure 2.
       A copy of the 508 related regulations and guidelines is
       included in appendix D. At the present time, the GSA Guidelines
       describe features that would be desirable in computers and
       operating systems.  Discussions are underway, however,
       regarding an extension of the GSA Guidelines to include
       application software, to make sure that applications cooperate
       with access features being built into the operating systems as
       well as lending themselves to access and use by people with
       disabilities.  This White Paper reflects these discussions, and
       provides industry with a mechanism for participating in the
       exploration and discussion of these topics as well.  Review,
       comment, and feedback on this White Paper and subsequent
       cooperative Industry Design Guidelines can help provide
       guidance to others in industry interested in this area.  Also,
       in that interested people within the government also receive
       and review this document it can act as a means of communication
       and input to government processes and deliberations on this                                          4
       topic as well.

       The recently enacted Americans with Disabilities Act requires
       that companies make their work environments more accessible to
       individuals with disabilities.  As a result, not only the
       Federal government but the public sector and private companies
       will be increasingly interested in software application
       programs which are more accessible and work well with existing
       and future special access features and accessories.


                              Figure 2
                Section 508 of the Rehabilitation Act

    Sect. 508. Electronic Equipment Accessibility
    (a)   (1)  The Secretary, through the National Institute on
           Disability and Rehabilitation Research and the
           Administration of the General Services, in consultation
           with the electronics industry, shall develop and
           establish guidelines for electronic office equipment
           accessibility designed to insure that handicapped
           individuals may use electronic office equipment with or
           without special peripherals.
       (2)     The guidelines established pursuant to
           paragraph (1) shall be applicable with respect to
           electronic equipment, whether purchased or leased.
       (3)     The initial guidelines shall be established not
           later than October 1, 1987, and shall be periodically
           revised as technologies advance or change.

    (b) Beginning after September 30, 1988, the Administrator of
     General Services shall adopt guidelines for electronic
     equipment accessibility established under subsection (a) for
     Federal procurement of electronic equipment.  Each agency
     shall comply with the guidelines adopted under this
     subsection.
       (c) For the purpose of this section, the term special
     peripherals means a special needs aid that provides access to
     electronic equipment that is otherwise inaccessible to a
     handicapped individual.



    6) It usually adds little and sometimes nothing to manufacturing
       costs for a product.

       The bulk of all accessibility design features cost little or
       nothing once they are included in the basic design of the
       product.  For software products the difference in manufacturing
       costs is often zero.  In exchange, the products are usually
       easier for everyone to use and the products are applicable to a
       wider market.

    7) It's the appropriate thing to do.

       The ability of people with disabilities to work, receive an
       education, or even access information and other services from
       their homes, is rapidly becoming dependent upon their ability
       to access and use computers.  If computers and application
       programs are not accessible, then individuals with disabilities
       will not be able to participate in education, employment, or
       daily living.  It isn't appropriate to design software that
       cuts off that many people from such an important area when more
       accessible software costs no more to manufacturer and is
       generally faster, easier, less fatiguing, and less error-prone
       to use for everyone.               5


   In summary:
      If properly done, making software more accessible:
        - usually adds little or nothing to the cost to manufacture
        - provides new insights into improved human interface design
        - increases the market for the product
        - brings products into compliance with current and
      anticipated
          government purchasing requirements
        - allows most people to access and use the software in
      employment,
          education, and home.



















































                                          6

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                                          7



.c."Part II: What Problems Do People with Disabilities Have?  and Why?





.c.:Disability has many facets

First, it is important to understand that there are many different
types and severities of impairment which lead to disabilities.  Some
types of impairment are:

            visual impairment

            hearing impairment

            movement impairment

            cognitive/language impairment

            seizure disorders

Within each of these major types, there are many variations and
degrees of impairment.  Each of these may present different barriers
and need to be addressed with different strategies.

    -  Someone with a moderate visual impairment may need some
       mechanism to enlarge the image on the screen.

    -  Someone with a severe visual impairment or who is blind would
       find screen enlargement to be of no value and would need
       mechanisms to translate the contents of the screen to speech or
       braille.

    -  An individual with a mild hearing impairment may just need a
       mechanism to increase the volume.

    -  An individual with a severe hearing impairment or who is deaf
       may need to have auditory information presented in some visual
       form.

    -  An individual with a mild physical impairment may just need to
       have the behavior of the keyboard and mouse changed slightly in
       order for them to be able to effectively use the computer.

    -  An individual with a more severe physical impairment may need
       to have a special keyboard that can be operated by speech,
       headpointing or eyegaze.

The following pages provide a brief overview of the major types of
impairments, along with a brief discussion of the implications of
these impairments on computer use.





  PLEASE NOTE:  It is not up to the application software
   developer/ manufacturer to directly meet all of these needs.
   Part III will discuss the role of application program
   manufacturers versus the role of others in providing
   accessibility.  It is important, however, for everyone to                                          8
   understand the basic problems faced by people with different

   types or degrees of impairment and their resulting
   disabilities.





























































                                          9


                        .c.:Visual Impairments



.c.::Background
Visual impairment represents a continuum, from very poor vision, to
people who can see light but no shapes, to people who have no
perception of light at all.  However, for general discussion it is
useful to think of this population as representing two broad groups:
those with low vision and those who are legally blind.  The National
Society for the Prevention of Blindness estimates that there are 11
million people in the U.S. who have visual impairments.  This includes
both people with low vision and those who are blind.

Low vision is defined as vision that is between 20/40 and 20/200 after
correction.  (20/200 means that something at 20 feet would be just as
visible as something at 200 feet would be to someone with normal 20/20
vision)  There are 9-10 million people with low vision.  Some of these
can read print if it is large and held close (or viewed through a
magnifier).  Others can only use their sight to detect large shapes,
colors or contrasts.  There are approximately 1.2 million people with
severe visual impairments who are not legally blind.

A person is termed legally blind when their visual acuity (sharpness
of vision) is 20/200 or worse after correction, or when their field of
vision is less than 20 degrees.  There are approximately half a
million people in the U.S. who are legally blind.

Blindness can be present at birth, acquired through illness or
accident, or associated with aging (glaucoma, cataracts, macular
degeneration, optic nerve atrophy, diabetic retinopathy).  According
to the American Foundation for the Blind, almost 1 person in every
1,000 under age 45 has a visual impairment of some type, while 1 in
every 13 individuals older than 65 has a visual impairment which
cannot be corrected with glasses.  With current demographic trends
toward a larger proportion of elderly, the prevalence of visual
impairments will certainly increase.

.c.::Functional Limitations Caused by Visual Impairments
Functional limitations of people with visual impairments include
increased sensitivity to glare, viewing the world as through a
yellowed lens, no central vision, no peripheral vision, loss of visual
acuity or focus, poor night vision, reduced color distinction ability
or a general hazing of all vision.  Those who are legally blind may
still retain some perception of shape and contrast or of light vs.
dark (the ability to locate a light source), or they may be totally
blind (having no awareness of environmental light).

.c.::Difficulties Using Computers and Software
As would be expected, people with visual impairments have the greatest
problem with information displayed on the screen.  However, mandatory
use of a mouse or other pointing device requiring eye-hand
coordination is also a problem.  Special programs exist to provide
individuals with the ability to magnify the screen image.  There are
also programs which allow the individual to have the content of the
screen read aloud.  However, application programs sometimes do things
in ways that make it difficult or impossible for these special
programs to work well or at all.  Individuals with low vision may also
miss messages which pop up at different points on the screen, since
their attention is usually focused on only a small area of the screen
at any time.

.c.::Access to Documentation              10
Written operating instructions and other documentation may also be
inaccessible if they are not provided in electronic or alternate form

(e.g., audio tape or braille) and even then people may have difficulty
accessing graphic or pictorial information included in documentation.
Because many people with visual impairments still have some visual
capability, many of them can read with the assistance of magnifiers,
bright lighting (for printed text), and glare reducers.  Many are
helped immensely by use of larger lettering, sans-serif typefaces, and
high contrast coloring.

Key coping strategies for those who are blind or have severe visual
impairments include the use of braille, large raised lettering or
raised line drawings, braille and audio tape.  Note, however, that
braille is preferred by only about 10% of people who are blind
(normally those blind from early in life).  Those who use braille,
however, usually have strong preferences for it, especially for
shorter documents.  Raised lettering must be large and is therefore
better for providing simple labels on raised line drawings than for
extensive text.














































                                          11


                       .c.:Hearing Impairments



.c.::Background
Hearing impairments are among the most prevalent chronic disabilities
in the U.S.  More than 15 million people have some form of hearing
impairment.  Almost two million are deaf.

Hearing impairments are classified into degrees based on the average
hearing level for various frequencies (pitches) by decibels (volume)
required to hear, and also by the ability to understand speech.
Loudness of normal conversation is usually 40-60 decibels.  A person
is considered deaf when sound must reach at least 90 decibels (5-10
times louder than normal speech) to be heard, and even amplified
speech cannot be understood, even with a hearing aid.

Hearing impairments can be found in all age groups, but loss of
hearing acuity is part of the natural aging process.  Of those aged 65
to 74, 23% have hearing impairments, while almost 40% over age 75 have
hearing impairments. The number of individuals with hearing
impairments will increase with the increasing age of the population
and the increase in the severity of noise exposure.

Hearing impairment may be sensorineural or conductive.  Sensorineural
involves damage to the nerves used in hearing (i.e., the problem is in
transfer from ear to brain).  Causes include aging, exposure to noise,
trauma, infection, tumors and other disease.  Conductive hearing loss
is caused by damage to the ear canal and mechanical parts of the inner
ear.  Causes include birth defects, trauma, foreign bodies or tumors.

.c.::Functional Limitations Caused by Hearing Impairments
The functional limitations faced by people with hearing impairment
fall into four categories.

First, individuals may not be able to hear auditory information if it
is not presented loudly enough as compared to the background noise.
The ability to control volume or to plug headphones or other devices
into a headphone jack are the primary strategies for dealing with this
problem.

Second, individuals who are deaf or who have more severe hearing
impairments will not receive any information which is presented only
in auditory form.  Beeps which are accompanied by an on-screen visual
indication prevent this problem.  They also avoid the problem of the
sound output being too quiet, since the auditory information is also
provided visually.  With newer systems which include voice output,
presentation of the text on-screen or the ability to turn on captions
may be necessary.

Third, as voice input becomes more prevalent, it too will present a
problem for many deaf individuals.  While many have some residual
speech, which they work to maintain, those who are deaf from birth or
a very early age often are unable to learn to speak or have very poor
speech.  Thus, alternatives to voice input will be necessary for these
individuals to access products which require voice input.

Fourth, many individuals who are deaf communicate primarily through
ASL (American Sign Language).  It should be noted, however, that this
is a completely different language from English.  Thus, deaf people
who primarily use ASL may understand English only as a second language
(and may therefore not be as proficient with English as native
speakers).                                12

.c.::Access to Support Services
Because individuals who are deaf cannot hear and sometimes cannot
speak, they have difficulty using telephone support services.  Special
telecommunication devices for the deaf (TDDs) have been developed,
however, which allow individuals to communicate over the phone using
text and a modem.  In order for these users to access phone-in support
services, software companies would need to have TDD-equipped support
personnel.  Individuals who are deaf are also be unable to take
advantage of support systems that use touch-tone input and recorded
voice output.





















































                                          13


                       .c.:Physical Impairments



.c.::Background
Physical impairments vary greatly.  They include paralysis (complete
or partial), severe weakness, interference with control, missing
limbs, and speech impairment.  Causes include cerebral palsy, spinal
cord injury, traumatic head injury (includes stroke), injuries or
diseases resulting in amputation, or various diseases such as
arthritis, ALS (Lou Gehrig's Disease), multiple sclerosis or muscular
dystrophy.

Cerebral Palsy (CP).  CP is defined as damage to the motor areas of
the brain prior to brain maturity (in most cases, this occurs before,
during or shortly after birth).  There are 400,000-700,000 individuals
in the U.S. with CP.  The most common types are spastic, where the
muscles are tense and contracted and voluntary movement is very
difficult, and athetoid, where there is constant, uncontrolled motion.
Most cases are combinations of the two types.

Spinal Cord Injury.  Spinal cord injury can result in paralysis or
paresis (weakening).  The extent of paralysis/paresis and the parts of
the body effected are determined by how high or low on the spine the
damage occurs and the type of damage to the cord.  Quadriplegia
involves all four limbs and is caused by injury to the cervical
(upper) region of the spine; paraplegia involves only the lower
extremities.  There are 150,000 to 175,000 people with spinal cord
injuries in the U.S.

Head Injury and Stroke.  The term "head injury" is used to describe a
huge array of injuries, including concussion, brain stem injury,
closed head injury, cerebral hemorrhage, depressed skull fracture,
foreign object (e.g., bullet), anoxia, and post-operative infections.
Like spinal cord injuries, head injury and also stroke often results
in paralysis and paresis, but there can be a variety of other effects
as well.  Currently about 1,000,000 Americans (1 in 250) suffer from
effects of head injuries, and over 2,000,000 people in the U.S. have
suffered strokes.  However, many of these do not have permanent or
severe disabilities.

Arthritis.  Arthritis is defined as pain in joints, usually reducing
range of motion and causing weakness.  Rheumatoid arthritis is a
chronic syndrome.  Osteoarthritis is a degenerative joint disease.
About 1% of the U.S. population (or 2.4 million people) are affected
by arthritis.

ALS (Lou Gehrig's Disease).  ALS is a fatal degenerative disease of
the central nervous system characterized by slowly progressive
paralysis of the voluntary muscles.  The major symptom is progressive
muscle weakness involving the limbs, trunk, breathing muscles, throat
and tongue, leading to partial paralysis and severe speech diffi-
culties.  This is not a rare disease.  About 2 out of 125,000 people
will develop ALS each year.  It strikes mostly those between age 40
and 70, and men twice as often as women.

Multiple Sclerosis (MS).  MS is defined as a progressive disease of
the central nervous system characterized by the destruction of the
insulating material covering nerve fibers.  The problems these
individuals experience include poor muscle control, weakness and
fatigue, difficulty walking, talking, seeing, sensing or grasping
objects.  It is estimated that about 300,000 in the U.S. suffer from
this disease.                             14

Muscular Dystrophy (MD).  MD is a hereditary, progressive condition
resulting in muscular weakness and loss of control, contractions and
difficulty in walking and breathing.  About 10,000 new cases are
reported per year.

.c.::Functional Limitations Caused by Physical Impairments
Problems faced by individuals with physical impairments include poor
muscle control, weakness and fatigue, difficulty talking, seeing,
sensing or grasping (due to pain or weakness), difficulty reaching
things, and difficulty doing complex or compound manipulations (push
and turn).  Individuals with spinal cord injuries may be unable to use
their limbs and may use "mouthsticks" for most manipulations.

Individuals with movement impairments may have difficulty with
programs which require a response in a specified period of time,
especially if it is short.  Individuals with impaired movement or who
must use a mouthstick or headstick have difficulty in using pointing
devices.  Programs which require the use of a mouse or pointing
devices and have no option for keyboard control of the program present
problems.  Individuals who can use only one hand or who use a
headstick or mouthstick to operate the keyboard have difficulty
pressing two keys at the same time.









































                                          15


                  .c.:Cognitive/Language Impairments



.c.::Background
This category contains a wide range of impairments including
impairments of thinking, memory, language, learning and perception.
Causes include birth defects, head injuries, stroke, diseases and
aging-related conditions.  Some commonly known types and causes of
cognitive/language impairment are:

Mental Retardation.  A person is considered mentally retarded if they
have an IQ below 70 (average IQ is 100) and if they have difficulty
functioning independently.  An estimated 1% of Americans (2.4 million)
are mentally retarded.  For most, the cause is unknown, although
infections, Down's Syndrome, premature birth, birth trauma, or lack of
oxygen may all cause retardation.  Those considered mildly retarded
(80-85%) have an IQ between 55 and 69 and achieve 4th to 7th grade
levels.  They usually function well in the community and can hold down
semi-skilled and unskilled jobs.

Language and Learning Disabilities.  This is a general term referring
to a wide range of disorders manifested by significant difficulties in
listening, speaking, reading, writing, reasoning, and
calculating/integrating perceptual/cognitive information.  These
disorders are presumed to be due to central nervous system
dysfunction.  It is estimated that over 43% of children in special
education programs in the U.S. (1.9 million) have some type of
language and learning disability.

Head Injury and Stroke.  This group includes individuals with closed
and open head injuries as well as those suffering strokes.  These
injuries usually result in physical impairments, cognitive impairments
or both.  There are approximately 400,000 to 600,000 people with head
injuries and approximately 2 million people who have suffered a
stroke.

Alzheimer's Disease.  This is a degenerative disease that leads to
progressive intellectual decline, confusion and disorientation.  5% of
Americans over 65 have Alzheimer's; 20% of those above 80 have it.

Dementia.  This is a brain disease that results in the progressive
loss of mental functions, often beginning with memory, learning,
attention and judgment deficits.  The underlying cause is obstruction
of blood flow to the brain.  Some kinds of dementia are curable, while
others are not.  5% of the population over 65 has severe dementia,
with 10% having mild or moderate impairment.  30% of those over 85 are
affected.

.c.::Functional Limitations Caused by Cognitive Impairments
Cognitive impairments are varied, but may be categorized as memory,
perception, problem-solving, and conceptualizing disabilities.  Memory
problems include difficulty getting information from short-term
storage (20-40 seconds, 5-10 items), long term and remote memory.
This includes difficulty recognizing and retrieving information.
Perception problems include difficulty taking in, attending to, and
discriminating sensory information.  Difficulties in problem solving
include recognizing the problem, identifying, choosing and
implementing solutions, and evaluation of outcome.  Conceptual
difficulties can include problems in sequencing, generalizing
previously learned information, categorizing, cause and effect,
abstract concepts, comprehension and skill development.  Language im-
pairments can cause difficulty in comprehension and/or expression of                                          16
written and/or spoken language.  Problems can occur both in the use of

software and in understanding manuals written at too high a
technical/comprehension level.

Approximately 1 million U.S. workers (age 18-69) report impaired
abilities to read, reason and/or understand spoken or written
information as a result of a chronic disabling condition.

There are few assistive devices for people with cognitive impairments.
Simple cuing aids or memory aids are sometimes used.  As a rule, these
individuals benefit from use of simple displays, low language loading,
use of patterns, simple, obvious sequences and cued sequences.




















































                                          17








                        .c.:Seizure Disorders



A number of injuries or conditions can result in seizure disorders.
Seizures can vary from momentary loss of attention to grand mal
seizures which result in the severe loss of motor control and
awareness.

Seizures can be triggered in people with photosensitive epilepsy by
rapidly flashing light, particularly in the 10-25 hz range.  This can
be caused by screen refresh or by rapidly flashing different images on
the screen.  The brighter the flash, and the larger the portion of the
screen involved, the more significant the visual stimulation.
Somewhere between 1 in 25,000 and 1 in 10,000 people in the US have
seizure disorders.










                       .c.:Multiple Impairments



It is all too common to find that whatever caused a single type of
impairment also caused others.  This is particularly true where
disease or trauma is severe, or in the case of impairments caused by
aging.

Diabetes, which can cause blindness, also often causes loss of
sensation in the fingers.  Unfortunately, this makes braille or raised
lettering impossible to read.  Cerebral palsy is accompanied by visual
impairments in 40% of cases, by hearing and language disorders in 20%
of cases, and by cognitive impairments in 60% of cases.  Individuals
who have hearing impairments caused by aging also often have visual
impairments.














                                          18


        .c."Part III: What is the Role of Standard Application
          Software Manufacturers in Computer Accessibility?


              And how does it relate to the roles of...
                 computer manufacturers?
                 operating system manufacturers?
                 third-party assistive device manufacturers?
                 systems integrators?





.c.:"Computer Accessibility: A Cooperative Undertaking

As discussed in Part II, making computers and software more accessible
is not the sole responsibility of application software vendors.  Many
aspects of computer access are best addressed by others, such as
hardware vendors, operating system manufacturers, or third-party
access product manufacturers.  However, there are some components of
accessibility that can only be addressed at the application software
level.

To understand the role of application software manufacturers, it is
important to examine the roles of all parties involved in making
computers accessible.

Each party has its own unique role, and must work together to achieve
computer accessibility:

    1) Hardware and operating system manufacturers,

    2) Third-party assistive device manufacturers,

    3) Standard application software manufacturers, and

    4) Systems integrators.








                  .c.::The Role of the Hardware and
                    Operating System Manufacturers



As much as possible, the computer platform itself should be made
directly accessible by people with disabilities.  The computer
"platform" is defined here as:

    a) the input, output, and media hardware (keyboards, monitors,
       disk drives)

    b) the input and output drivers which control behavior of the
       input/output devices

    c) the system software tools used by the applications for input,
       output, and program control        19

The hardware and operating system components may be produced by a
single vendor or by separate companies.  These components work
together, however, to give the computer its basic operating
characteristics and requirements.  There are some accessibility
features that can only be implemented at this level, and those that
are will benefit all application software manufacturers by reducing
the need to build these features over again in each application
program.  It is also of benefit to users in that there is a standard
user interface and operating characteristics across programs.  (See
Part IV.)

In many cases, particularly for individuals with mild or moderate
disabilities, slight changes in the hardware or operating systems can
make the computers directly and completely accessible without any
further modification.  Once these modifications are incorporated into
the design of the hardware or software drivers, there is little or no
additional manufacturing cost.  This type of accessibility is called
"direct accessibility," since it allows individuals with disabilities
to use the computers directly as they come "from the box."  This is
the most cost-effective type of accessibility, and the most desirable,
since it allows individuals who have disabilities to access and use
the computers in the same fashion as anyone else.  It also allows them
to access and use the computers as they find them in educational,
employment, or public environments without having to bring along and
install special access software or hardware in order to use them
(which is often difficult or impossible in public and some other
environments).

A second role for standard hardware and operating system manufacturers
is to design the computer platform to facilitate the connection and
use of special access tools (software and hardware) for individuals
with more severe impairments where direct access is not possible (see
next section).




            .c.::Role of Third-Party Access Manufacturers



Although direct accessibility of computers is by far the best
situation, the type or severity of some impairments precludes the
ability to use computers "off the shelf" (even if the computers have
been designed to include as many direct access features as practical).
In these cases, special interfaces, software programs, or other
accessories are required in order to allow the individuals to access
and use the computers.  The role of third-party or "special access"
manufacturers is to develop the special hardware and software tools,
and to make them available to people who require them.  As noted
above, standard hardware and operating system manufacturers can
greatly facilitate this process by designing their hardware and
operating system platforms to be compatible with the connection and
use of such special access tools.

While the use of special access products to access a computer is not
as desirable as being able to directly access and use the computers,
there is a need for and advantages to using third-party access
products for some people, especially those with more severe
disabilities.  On one hand, individuals who have to rely on third-
party access devices do not have the ability to just approach and use
computers in libraries, laboratories, or employment situations.  They
must carry their special interfaces with them and be able to connect
them to or load them onto these computers before they can use the                                          20
computers.  On the other hand, third-party products which are targeted
toward a particular disability can sometimes provide more powerful and

efficient interfaces than could be efficiently built into a standard
hardware/operating system.  It is also sometimes necessary to
incorporate additional hardware into the interface (e.g., a dynamic
braille display) which would be impractical to incorporate into a
standard computers design.  Third-party access products are therefore
important components in system accessibility, and the only practical
approach for some individuals with severe or multiple impairments.

Thus, both direct accessibility (wherever possible) and third-party
access products (where built-in accessibility is not possible or is
not efficient enough) are necessary to meet the broad range of needs
of people with mild to severe disabilities.




           .c.::Role of Application Software Manufacturers



The first two parties discussed (the standard platform manufacturers
and the third-party special access manufacturers) can work together to
overcome most of the access problems faced by people with
disabilities.  However, access to the computer and its operating
system does not guarantee full access to application software, and
running application programs is the only use of a computer for most
people.  Some aspects of the computer's behavior are completely in the
control of the application software.  Therefore, effective access to
computers includes cooperation by the developers of application
software.  There are three general ways that manufacturers of
application software can improve access to and usability of their
programs.

    1) Cooperate with other access features and utilities
       Not all information needed to operate the program is available
       at the system level.  Cooperation by the application program is
       therefore necessary in order for standard or special access
       features to be effective.

            For example, most programs running on graphics operating
            system use the system tools to display their menus.
            Access features can thus be designed which attach
            themselves to the system tools and provide access to all
            of these menus.  Occasionally, however, an application
            will create a custom menu or palette without using the
            standard system menu tools, or by using them for only part
            of the menu function.  In this case, the special access
            features attached to the operating system would be unable
            to determine what the items in the special palette were in
            order to present them to the individual with the
            disability (e.g., if they were blind) and to allow the
            individual with a disability to choose from among them.

    2) Tune the user interface to allow efficient use by people with
       different strengths
       In some cases, the standard access features built into the
       operating system may allow the person with a disability to use
       a program, but only in some round-about or inefficient manner.
       A slight change or option in the application program could
       substantially increase the efficiency with which individuals
       with disabilities could operate the program.  Since the person
       with a disability has to compete with their able-bodied
       colleagues, the ability to operate the program efficiently can
       be important to their maintaining comparative productivity to                                          21
       their colleagues.

            For example, dialog boxes and many interactive programs
            may have numerous buttons in them.  An individual who can
            tab between the various buttons and fields would have
            access to the dialog box.  However, this type of operation
            would be much slower than that of other users, who could
            simply click on the desired buttons to access them rather
            than having to tab around.  Having the ability to type a
            command key to activate any button directly would greatly
            increase the speed with which a person with a disability
            (and anyone else whose hands were on the keyboard) could
            access and use these programs.

    3) Make sure your program doesn't break or interfere with existing
       access features or utilities
       Application programs can unknowingly include features which
       cause standard or third-party access features to break, or just
       not work with that program or function of the program.
       Understanding what accessibility features exist and how they
       function can help to prevent this problem.  It also makes the
       program generally more robust and compatible with other
       nondisability-related third-party add-on programs.

            For example, using nonstandard techniques for reading the
            keyboard, writing to the screen, or showing a cursor may
            be done for performance or other reasons, but could
            circumvent or break access software.  Several major
            application programs now do this.

    4) Testing your program for compatibility with 3rd party
       manufacturers of accessibility hardware and software
       In many cases they best means for providing access to persons
       with disabilities is through the use of 3rd party access
       devices or software.  However the design or improvements to a
       program can cause incompatibility problems for these 3rd party
       access products leaving a person who depends on them without
       access to the computer or your software.  Testing of your
       software for compatibility with major access software and
       hardware can prevent this problem.  Providing advance copies of
       the software to 3rd party manufacturers for testing can also
       help avoid this problem if it is done early enough in the
       design cycle to allow for changes in the design to overcome
       incompatibilities

            For example, screen reading software programs used by
            people who are blind can be made partially or completely
            ineffective depending on how new features, menubars,
            toolbars, etc., are implemented.




                   .c.::Role of Systems Integrators



In addition to the three major players, there is sometimes a fourth
player, the systems integrator, particularly in federal acquisitions.
Since systems integrators do not usually create software or hardware,
their role has not been well explored.  However, for federal
acquisitions, system integrators are often the individuals who select
the hardware and software offered, and the individuals who provide the
follow-up support.  Their role in overall accessibility for offerings
to the federal government is therefore substantial.  Three key areas
where systems integrators can have a major effect are:                                          22

    a) the accessibility of the hardware and operating system
       platforms they select to use in their offerings,

    b) the accessibility of the application software they select to
       use in their offering (that is,

         -  the software's compatibility with disability access;

         -  the accessibility of software documentation;

         -  support services provided by the software vendor for users
            with disabilities),

    c) the accessibility of their training programs and materials to
       government employees who have disabilities, and

    d) the ability of integrators to both set up and provide
       maintenance support for federal employees with disabilities who
       are using the hardware/software packages offered by the systems
       integrator.

.c.:::Selection of the Hardware / Operating System Platform
In the past, there have been many compatible hardware platforms, and
system integrators could choose between different vendors in putting
their packages together.  This has not generally been true for
operating systems.  However, there is an increasing compatibility and
inter-operability between operating systems.  For example, there are
three vendors who sell versions of DOS (Microsoft, IBM, and Digital
Research), as well as other operating systems which allow DOS programs
to be run within them (e.g., OS/2).  Windows applications can be run
within Windows, but can also be run within OS/2.  This, combined with
the increasing cross-platform compatibility of applications, is
leading to a situation where systems integrators can begin to choose
between both different hardware and different operating system vendors
in putting together their packages.  Since these different hardware
platforms and, especially, different operating systems are beginning
to differ in terms of their built-in accessibility features, system
integrators can put together more or less accessible offerings to the
government or other purchasers by selecting more (or less) accessible
versions of the hardware and operating systems.

.c.:::Selection of Standard Application Software
Similarly, the increasing compatibility between applications, either
directly or via translators, is providing much greater choice.  Again,
system integrators can provide a much more accessible package by
selecting application software which is itself more accessible and
compatible with the access strategies or aids.  Selecting software
which is more accessible will also greatly reduce the problems faced
by systems integrators when trying to provide support to federal (and
other) employees with disabilities who are using the systems
integrator's package.  It would both reduce the number of
compatibility problems that would arise and, if the original
application software vendors provided disability access support,
provide the systems integrator with a better and lower-cost mechanism
for addressing any compatibility problems that did arise.

.c.:::Accessibility of Training Programs and Materials
In addition to delivering the software and hardware, many systems
integrators also provide training for the client's employees in the
use of their products.  Since the employees they will be training may
have disabilities, the training materials and documentation used by
the systems integrators would need to be accessible to these employees
as well.  Again, choosing hardware and software which already has
accessible forms of documentation can greatly simplify the systems                                          23
integrator's work in this area.

.c.:::Ability of Integrators to Set Up and Provide Maintenance for
  Their Systems
In addition to the training they provide, systems integrators often
provide continued support and maintenance for their systems after
delivery.  If some of their client's employees have disabilities, the
systems integrators may need to provide support for these individuals
as well (both those employed at the time of the bid and individuals
with disabilities who are hired later).  This may involve trouble-
shooting systems provided by the system integrators or compatibility
issues between existing access software and the package sold by the
integrators.



As previously discussed, the role of the systems integrator is not
well understood, and points discussed here are therefore preliminary
in nature.  However, it is clear that the systems integrators will
play a key role in determining the actual access that federal
employees with disabilities will have to their computers and
information processing environments.  It is also clear that system
integrators have major impact on which software packages are offered
to the federal government for most of their packaged buys.  Finally,
it is clear that systems integrators cannot make the hardware and
software in their packages more accessible or compatible with special
access products from third-party vendors.  They will have to rely upon
selecting those hardware, operating system, and application software
products which are most accessible and compatible with third-party
access systems.











NOTE: This White Paper is directed toward the accessibility issues as
they relate to application software developers.  There is a separate
document, titled Considerations in the Design of Computers and
Operating Systems to Increase Their Accessibility to Persons with
Disabilities, which has been developed by and for hardware and
operating system manufacturers.  At present, there is no document
tailored to the needs of systems integrators.  Because of their key
role in federal acquisitions, and the fact that they face different
problems and questions in making the systems they offer more
accessible, a separate tailored document should be developed to
address their needs.













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                                          25



               .c."Part IV: What Are Others Doing that
      Application Software Manufacturers Can Take Advantage Of?




In the previous section, the roles of standard platform manufacturers
and third-party special access manufacturers were described.  The
purpose of this section is to provide an overview of the access work
of these two groups and how application software manufacturers can
take advantage of this work to solve most of the access issues for
their programs.  A thorough understanding of this section is necessary
in order for application software manufacturers to avoid duplicating
effort and solving problems which are best solved at these other
levels.  It is also important for application software manufacturers
to understand these strategies in order to be compatible with them and
to understand the aspects of accessibility that are not covered by
them.

For the purposes of this discussion, the solution strategies which are
provided both by the standard platform manufacturers and by third-
party manufacturers are grouped together and presented by impairment
area.




              .c.:Access Strategies for Individuals with
                          Visual Impairments
                (Available via Platform or Third-party
                            Manufacturers)



The access strategies used by people with visual impairments fall into
two major categories: enlargement of the image on the screen, and
presentation of visual information in some other form (e.g., speech or
braille).  People with low vision generally use both strategies, while
people who are completely blind must rely on the second approach.

   (Please note: The strategies described below and on the following
   pages in this section are already provided (or will be) by computer
   manufacturers, operating systems, or third-party assistive device
   manufacturers.  They are not features that application software
   designers need to add to their software; only things that they need
   to be aware of and to facilitate rather than obstruct.)

.c.::Low Vision
For individuals with mild to moderate visual impairments, the ability
to enlarge the fonts (only) used on the screen may be all that is
necessary.  Within text-only documents, using "large type" is very
straightforward, since most graphics-based programs allow the
individual to select the font size to be used on-screen.  Utilities
also exist which allow one to use a slightly larger font in the system
menus.  This concept could be expanded to include larger cursors,
scroll bars, etc.

Simply enlarging the font used on the screen, however, only works for
individuals needing moderate character enlargement.  For individuals
with low vision, the image on the screen must often be magnified 4-16
times.  Also, the entire image on the screen needs to be enlarged, not
just the alphanumeric characters.  To do this, some type of overall                                          26
screen enlargement utility or program is required.  These utilities or
programs create a virtual image which is much bigger than the actual

monitor screen.  The monitor screen itself then becomes a "viewport"
which can be moved about over the virtual screen.  Using this
technique, the individual can only see a small portion of overall
screen at a time.  (As a result, the effect is similar to a normally
sighted person trying to use a computer while looking down a cardboard
tube such as that found in a roll of paper towels.)  Such screen
enlargement utilities allow the individual to enlarge the text as much
as they like (up to one character filling the entire screen).  They
usually also have a mechanism built in to allow the "viewport" to
automatically follow the movement of the mouse or cursors as the
individual types.

Application developers should note that it is important for screen
reading or enlargement access software to be able to identify events
which occur in different areas of the screen.  This is necessary so
that the access software can automatically move the "viewport" to that
point on the screen in order to avoid the user missing important
events occurring outside of the viewport.  It is also important to
maintain a consistent screen layout.  The user will then know where to
find things such as prompts, status indicators, menus, etc.

.c.::Blind Access (also used by individuals with low vision)
For individuals who cannot read the image on the screen even when
enlarged, some mechanism for presenting the information in nonvisual
form is necessary.  The two most common forms for doing this are
speech and braille.

Screen reading programs allow the individual to move about on the
screen and have any text read aloud to them.  In graphical
environments with multiple windows, screen readers must also be able
to allow the individual to navigate around between windows and among
the different elements of a window (scroll bars, zoom boxes, window
sizing controls, etc.).  They must also provide the individual with a
means to deal with icons and other graphic information.  For
stereotypic images which always appear the same, such as scroll bars
and icons, names or labels can be given to each object or icon.  When
the icons are encountered, their names or labels can be read aloud.

Application programs can facilitate or inhibit screen reading
programs' ability to do this, however.  For example, a tool bar which
is drawn as a single graphic element cannot be easily deciphered by an
access program.  A tool bar where each tool is drawn using a separate
draw command can be easily dissected, and the individual tool images
extracted and named.

.c.::Advanced Graphic Access Techniques (for GUIs)
Screen reading programs which currently exist on the Macintosh and are
being developed for OS/2 and Microsoft Windows are capable of
providing full access to the basic operating system constructs
(windows, menu bars, dialog boxes, etc.) as well as providing access
to text within application program documents (as long as the text
drawing tools of the operating system are used to create the text
image).  In order to access information which is drawing or picture-
based (line drawings, charts and diagrams, floor plans, etc.), several
advanced strategies are being explored.

One approach involves the use of a virtual tactile tablet with a
tactile puck/mouse.  A vibrating tactile array of 100 pins is mounted
on a special puck/mouse.  As the mouse is moved about on the tablet,
the tactile representation of the information on the screen is
provided to the individual's fingertip.  In this fashion, the
individual can actually feel the information on the screen.  Coupled
with voice output screen reading features, this system allows the
individual to feel the image on the screen and to have any words on                                          27
the screen read aloud.

Other experimental techniques being examined are routines which would
automatically recognize and describe verbally stereotypic information
presentations formats (bar charts, pie charts, etc.) and routines
which would provide special image enhancement (edge
detection/enhancement, etc.) to make complex graphics simpler to
tactually explore.

.c.::Braille
In addition to speech output, braille can also be used.  Since braille
is essentially a tactile alphabet, it can be used instead of speech to
present the information to the user.  Special displays of 20 or 40
braille cells with electromechanical moving pins can provide
refreshable or dynamic braille displays that can be continually
changed by the computer.  As a result, anything that is printed in
alphanumerics or which can be described in speech can be presented on
a dynamic braille display.  This is an effective and preferred means
for accessing text by some people who are blind.  For individuals who
are deaf-blind, and can neither read the text on the screen nor hear
spoken output, braille is essential for access.

.c.::Input and Control Systems for People with Low Vision/Blindness
In addition to problems in accessing the screen, individuals who are
blind also have difficulty in using input devices which require
vision.  For example, some keyboards have electronically locking keys,
such as the Num Lock, Scroll Lock, and Caps Lock keys on an IBM PC or
compatible.  Small lights are provided on the keyboard to allow people
who can see to determine whether these keys are in their locked or
unlocked mode.  Individuals who are blind are unable to determine the
status of these keys unless there is some visual indication provided
on the screen where their screenreaders can access it.  Some
application programs provide this.  In addition, some software
utilities and most screen reading software provide some auditory cues
to allow the individual who is blind to know whether these particular
keys are in locked or unlocked mode.  It is important for application
software to use the status flags in the system and ensure that these
flags and lights are set to agree with the program's use of these
keys.

A more serious problem for individuals who are blind is applications
which require use of the mouse.  The mouse by its very nature requires
some type of eye-hand coordination.  For individuals who are blind,
this type of eye-hand coordination is impossible.  Some blind access
software packages provide mechanisms which automatically move the
mouse cursor about the screen as they read or move between window
elements.  Another strategy which can provide some access to mouse-
like operations is the use of the tactile mouse discussed above.  For
these access techniques to work within the application windows
themselves, however, they may require some cooperation from the
application program.




              .c.:Access Strategies for Individuals with
                         Hearing Impairments
                (Available via Platform or Third-party
                            Manufacturers)



Individuals with hearing impairments currently have little difficulty
in using computers.  Some computers, such as the Macintosh computers
and the IBM PS/1, have volume controls and headphone jacks which allow
the connection of headphones or amplifiers/speakers to facilitate                                          28
their use by individuals who have mild hearing impairments.  For
individuals who cannot hear, onscreen indication of beeps and other

sounds can be provided.  Currently, the Macintosh has a feature where
the menu bar will flash whenever a sound is emitted if the volume
control is turned to zero.  IBM's new L40 SX laptop computer has a
small LCD display which flashes a symbol of a speaker whenever a tone
is emitted from the computer, thus providing a visual indication of
the auditory sound.  The AccessDOS package distributed by IBM also
includes a feature called "ShowSounds" which provides a screen flash
whenever the speaker on the computer is used.  There are also other
third-party products, such as SeeBeep, which provide visual
indications on the screen when a sound is emitted from a PC.

In addition, a system-wide "ShowSounds" switch is currently being
advocated for all operating systems.  By implementing the "ShowSounds"
switch at the system level, the switch could be used by all
application programs to determine if the user would like visual
indication of any sounds made by the application programs.  If an
individual was in a noisy environment (such as an airplane or a
factory) or had difficulty hearing, they could set the ShowSounds
switch.  The operating system and all applications which emitted
sounds could then check that switch.  If it were turned on, they would
accompany any auditory sounds with some type of visual indication.
Some applications already provide some type of visual indication to
accompany many (but not all) sounds.  If the ShowSounds switch were
set, however, it would be an indication that all sound output should
be accompanied by some type of visual indication.

Implementation of the ShowSounds switch would also allow application
programs to have closed captioning.  That is, newer programs which
include speech output could check for the ShowSounds switch and, if it
were set, pop up a small window with the same text that was being
spoken.  Because this caption would only appear when the ShowSounds
switch was set, it would be called a "closed caption."  Similarly, if
other auditory information were presented which was necessary for the
operation of the program, a small indicator or caption describing the
sound could be presented if the ShowSounds switch were set.  This
descriptor of the sound should preferably be text rather than an icon,
in order to facilitate access by individuals who are deaf-blind and
using a screen reading program (using braille) to present the
information to them.

As software packages move toward more multi-media presentations, the
ability of application software to provide closed-captioning will
increase in importance.

NOTES:

    -  The ShowSounds switch does not currently exist within standard
       operating systems.  However, discussions are ongoing with the
       major operating system manufacturers to include the switch in
       future releases of their operating systems.

    -  The ShowSounds switch should not be tied to the volume control.
       In many cases, the ShowSounds feature would be used in addition
       to sound output.

    -  The ShowSounds switch when implemented on a systems level
       should not automatically cause all sound events to trigger a
       visual event (as is true for the rudimentary ShowSounds in
       AccessDOS).  The software or system emitting the sound should
       check the status of the switch and create a visual effect only
       if appropriate (e.g., not if just playing background music),
       and only in an appropriate form (e.g., don't just keep
       flickering the screen if the program is talking; put up text
       instead).                          29


              .c.:Access Strategies for Individuals with
                         Physical Impairments
                (Available via Platform or Third-party
                            Manufacturers)



Problems faced by individuals with physical impairments vary widely.
Some individuals are very weak, and have limited range of motion.
Other individuals, such as those with cerebral palsy, have erratic
motor control.  Some individuals have missing or paralyzed limbs,
while others, such as those with arthritis, have limited manipulative
and grasping ability.  People with physical impairments can have
difficulty manipulating media, carrying out quick actions, operating
input devices requiring fine motor control, and pressing multiple keys
or buttons at the same time.

Access strategies can be broken down into roughly three categories:

    1) Modifications to the way the standard input devices (e.g.,
       keyboard and mouse) work

    2) Alternate input techniques which replace the standard input
       devices

    3) Modifications to facilitate manipulation of controls and media
       (disks, etc.)


.c.::Modification to Standard Keyboard Devices

Some individuals are unable to use the standard keyboard, but could
use it if it behaved slightly differently.  A number of standard
modifications are now available which allow the user to modify the way
a standard keyboard works in order for it to function better for
people with disabilities.  Four examples of keyboards modifications
are StickyKeys, SlowKeys, BounceKeys and RepeatKeys.  Many of these
features (and others) are now distributed by the major computer
companies as standard parts of, or extensions to, their standard
operating systems.

                   .G.FIGURE3.TIF;3.75";2.639";TIFF

Figure 3 shows the availability of StickyKeys, RepeatKeys, SlowKeys,
BounceKeys, MouseKeys, ToggleKeys, SerialKeys, and ShowSounds on
Macintosh and IBM computers.  The Macintosh has all but BounceKeys and
SerialKeys built directly into the operating system.  IBM distributes
(free) a package called AccessDOS which contains all of the features.
The Access Utility for Windows 3.1 also contains all of these
features, and is distributed as a part of the third-party drivers
package available from Microsoft, as well as being available on
several bulletin boards.

StickyKeys is a feature which eliminates the need to press several
keys simultaneously.  For individuals who type with only one hand,
finger, or a head- or mouthstick, it is difficult or impossible to
press a modifier key (such as Shift, Control, or Alt) and another key
at the same time.  When invoked, StickyKeys allows the individual to
type modifier keys in sequence with other keys--for example, they can
press the Control key and then the H key to get a Control-H.

RepeatKeys is a feature which allows the repeat rate on the keyboard
to be adjusted.  Some individuals get unwanted multiple characters                                          30
because the key repeat rate is faster than their reaction time.

RepeatKeys allows them to change the speed of the repeat function
and/or to turn it off.

SlowKeys is a feature which facilitates use of the keyboard by
individuals who have poor motor control which causes them to
accidentally bump keys as they move around between desired keys on the
keyboard.  The SlowKeys feature allows the user to add a delay to the
keyboard so that the key must be held down for a moment or two before
it is accepted.  In this fashion, the keyboard would only accept keys
which were pressed deliberately for a moment, and would ignore keys
which were bumped.

BounceKeys is a feature to facilitate keyboard use by individuals with
tremor or other conditions which cause them to accidentally double-
press a key when attempting to press or release it.  BounceKeys does
not slow down the operation of the keyboard, but does prevent the
keyboard from accepting two very quick presses of the same key.  Thus,
with BounceKeys on, individuals who "bounce" when either pressing or
releasing a key would only get a single character.  To type double
characters, the user would simply have to pause a moment between
typing the key two successive times.

In addition to these software modifications to the keyboard, the use
of a keyguard is also common.  A keyguard is a flat plate which fits
over the top of a keyboard and has holes corresponding to each key.
The individual can then rest their hand on the keyguard and poke a
finger down through the hole to type.  The keyguard both helps prevent
the typing of unwanted characters and provides a stable platform which
the individual can use to brace their hand for additional control in
typing.

Many individuals with physical impairments are unable to control the
standard mouse.  In some cases, mouse alternates such as trackballs
can be used.  One software approach which allows the mouse to be
controlled from the keyboard is called MouseKeys.  When MouseKeys is
invoked, the number keypad on the computer switches into a mouse-
control mode.  The keys can then be used to move the mouse cursor
around on the screen.  Keys on the keypad also allow the mouse button
to be "clicked" or to be locked and released to facilitate dragging.
The MouseKeys feature works at the same time as a standard mouse or
trackball; it is therefore possible to use these other pointing
devices to move about on the screen, and then switch to the keypad for
fine movement of the mouse.  Single-pixel of the mouse is very easy
using MouseKeys.  In fact, it is often used by nondisabled graphic
software users for precise pixel movements which are difficult or
impossible with the standard mouse.  For individuals who have good
head control, there are also head-operated mice which allow the
individual to essentially use their head to point and to use a puff on
a straw to act as mouse button.


.c.::Alternate Input Techniques

While modification to the standard keyboard allows input by some
individuals, alternate "special" keyboards or input devices work
better for others.  These alternate keyboards take many different
forms, including expanded keyboards, miniature keyboards, headpointing
keyboards, eyegaze-operated keyboards, Morse code input, scanning
keyboards which require operation of only a single switch (operated by
hand, head, or eyeblink), and voice operated keyboards.  Some of these
keyboards connect to the computer in place of or along with the
standard computer keyboard.  Other alternate keyboards connect to the
serial or parallel port on the computer, and use special software to
cause their input to be injected into the operating system and treated                                          31
as keystrokes from the standard keyboard.  In still other cases, the
"keyboard" may appear onscreen in a special window.  The individual

then selects keys on that video keyboard using a headpointer, a single
switch scanning technique, Morse code, or other special input
technique.  The keys selected on the video keyboards are then fed
through the operating system so that they appear to application
programs as if they had come from the standard keyboard.

For programs which provide mouse support, these alternate input
devices can often also create simulated mouse activity in order to the
user to access drawing, dragging, and other mouse-based functions of
the application programs.





















































                                          32



    .c."Part V: What Should Application Software Manufacturers Do?
                            -- Overview --




Six basic ways for making application software more accessible are:

    1) Using an open systems approach

    2) Cooperation with access utilities and access features in the
       operating system

    3) Designing software to minimize the skills and abilities needed
       to operate it

    4) Providing more accessible documentation and training

    5) Inclusion of access software and hardware in the alpha and beta
       testing stages of product development (to ensure their
       compatibility)

    6) Provision of special customer support lines or specialists
       within your customer support structure who are familiar with
       disability access software and hardware, as well as any
       compatibility issues and solutions for your software

    7) Provision of special developer support lines or contact people
       for third-party manufacturers of access software and hardware


.c.::1) Using an Open Systems Approach

Providing access to people who have disabilities is in many ways just
a natural extension of the open systems approach to software design.
Support of the open systems through GOSIP, POSIX, and the applications
portability profile facilitates compatibility with special access
software and hardware within these environments.  With the rapid
advance of technologies and operating systems, software that is based
upon open systems concepts and which retains a stable or similar
interface format across platforms greatly facilitates the efforts of
third-party accessibility developers in keeping up and adapting their
products.


.c.::2) Cooperation with Access Utilities and Access Features in the
  Operating System

.c.:::Using System Tools and Conventions/Standards
The most important and easiest mechanism for ensuring greater
compatibility with access software is to use the tools and conventions
which have been established for the operating system.  Most access
software works through modifications to the system tools, or bases its
operation on assumptions that the standard conventions for the system
will be followed.  As long as application software programs use the
system tools and conventions, there is generally little problem.  For
example, programs that do not use the BIOS or toolbox to write to
screen, that do not use system cursors, that get keystrokes from the
keyboard in unusual or nonstandard fashion, or that write directly to
the screen rather than using standard screen drawing tools can cause
problems for special access software.  Use the system tools for all
screen drawing/writing activities (many screen readers for users who                                          33
are blind depend on it, especially in the GUI environment).

.c.:::Provide Software Access to Commands

When commands are all executed through the menus, access software has
very little trouble in both accessing listings of the available
commands and activating the commands.  Program commands which are
issued in other fashions--such as tool bars, special palettes, etc.--
present problems.  It is difficult to get a listing of all of the
commands (for example, to present to somebody who is blind).  It is
also difficult to directly activate the various commands (for example,
by an alternate access routine for someone with a severe physical
disability).  Where all of the palette and tool bar commands are
available via the standard menus, this is not a problem.  When these
commands, however, are not otherwise available, it is important that
access somehow be achieved.

Access to commands in a program consists of four parts.  Fortunately,
the movement toward inter-application control is making the commands
in a program more accessible electronically.  Features like balloon
help are also useful for providing descriptions of the commands and
buttons on the screen.  Eventually, it would be nice to be able to:

    a) Obtain a listing of all of the possible commands

    b) Obtain help text for each of the commands

    c) Be able to execute all of the commands from an external program

    d) Be able to read the status of user-settable parameters (and be
       able to set all such parameters) from an external program

When these capabilities are all available in a standardized format, it
will make the process of developing access programs much simpler and
more complete.  In the meantime, programs which have most of their
commands available for inter-program control may consider making the
rest of the program commands available as well.


.c.::3) Designing Software to Minimize the Skills and Abilities Needed
  to Operate It

The best way to view people who have disabilities is to think of them
simply as individuals with reduced abilities rather than as people
without an ability.  The reduction in their abilities may vary from
slight to severe.  The more you can reduce the sensory, physical, or
cognitive skills necessary to operate the program, the more people
will be able to directly use the program.  It also makes it easier for
everyone else to use the program.  Some examples: using a slightly
larger or clearer type, using menus which can be scanned rather than
commands which must be memorized, keeping menus short and dialog boxes
uncluttered, reducing or eliminating the need for fine motor control.

It is also helpful to provide multiple ways of accomplishing functions
in order to adapt to different needs or weaknesses.  For example,
having pull-down menus reduces the cognitive load and makes it easier
to operate computers.  While providing hot keys reduces the motor load
and makes it easier and faster for individuals with physical
disabilities to use computers, providing both addresses the needs of
both groups and gives all users more options to meet their
preferences.  A second example would be the ability to use either the
scroll bar or the keyboard to select position within a document.

The third general strategy is to provide layering to reduce visual and
cognitive complexity.  One example of this are programs which provide
both short and long forms of their menus.  The use of option buttons                                          34
in dialog boxes or other techniques for nesting complexity would be a
second example of this.

.c.::4) Providing More Accessible Documentation and Training

.c.:::Electronic Documentation
An important component to the accessibility of any software is the
ability of the user to access the documentation.  Documentation can be
made available in a number of formats, including standard print, large
print, braille, audio tape, and electronic form.  The most universal
of these is the electronic format.  In order to be really accessible
for people who are blind, the information should be available as an
ASCII text file.  This would involve converting photographs and
diagrams into descriptions, and identifying other techniques for
providing emphasis to particular words other than the use of different
fonts and highlights.  Once a file is available in a pure ASCII form,
it can be easily accessed using screen readers as well as translated
and printed out as braille or recorded in audio tape format.

Although individuals who are blind will find an ASCII text file to be
the most useful form, individuals who have severe physical
disabilities may find that an electronic copy of your manual which
also provided pictures and diagrams will be the most useful form.  The
electronic form of the manual would allow people with physical
disabilities to have access that they would not normally have, because
of the difficulty in manipulating books.  Having a full graphic
version of the manual would provide them with the maximum amount of
information.

Someday, when "electronic paper" is common, having the manual in both
ASCII and "electronic paper" would be optimal.  In the meantime, the
ASCII version is the most universally accessible format.


.c.:::Print Documentation

Even the design of standard print manuals can be done to better
facilitate their direct use by individuals with visual and other
impairments.  Some things which can be done to improve the
accessibility of standard print documents are:

    -  Using a binding which allows a book to open and lie flat.  (Try
       turning the pages of your documentation using the eraser end of
       a pencil.)

    -  Avoiding the use of very light colors which might not be easily
       reproduced by copy machines, especially for important
       information.  (Individuals with low vision will often make a
       "large print" copy of a manual by running it through an
       enlarging copy machine.)

    -  Avoiding color coding, or making it redundant with pattern or
       some other type of coding.  (This helps avoid problems for
       individuals having color blindness, and facilitates the making
       of large print versions of manuals using enlarging copier
       machines.)

    -  Using a sans serif font for non-running text.

    -  Information that is presented in charts or diagrams should also
       be presented redundantly in text.  (This facilitates the
       scanning of documents into ASCII text files using optical
       character recognition technologies.)

One form of electronic documentation which is becoming increasingly
more prevalent is on-line help.  As long as the help is presented
using standard screen-writing routines, access should be no problem.                                          35
If pictures are used within the on-line help, then text should

accompany the picture and provide enough information that the picture
or diagram is a redundant visual aid.

Translating documentation from its standard print form into an ASCII
text file which is effectively formatted can take some effort.
However, there are programs set up in the United States which can
provide technical assistance in the translation process.  (See
Appendix B, Resources Available to Help.)


.c.:::Training

In addition to the printed and on-line documentation, many programs
have videotapes or other multi-media training materials available for
them.  In addition, some companies provide training courses, either in
the direct use of their product or for programmers or other
professionals wishing to use or extend their product.

Having access to the training materials for a program can be as or
more important than access to the basic documentation.  As software
becomes more and more complicated, the ability to access and use the
training materials becomes essential.  Videotapes with closed (or
open) captions, provision of equivalent training materials which do
not require the ability to see, and the use of descriptive video
(where the actions taking place on the screen are described as a
narrative on a separate audio track) are examples of some strategies
which can be used here.  Providing more accessible training does not
mean that videotapes cannot be used because there are people who are
blind, however.  It could mean that the same information provided in
the videotapes is also available in a form that does not require
sight.

In addition to the training materials themselves, it is also important
that training sessions be as accessible as possible.  Some strategies
for doing this include holding the training sessions in facilities
which meet ADA accessibility standards, and may include the provision
of interpreting or other services to meet the needs of specific
attenders.


.c.::5) Product Testing with Access Software and Hardware

It is difficult to ensure that new application software will not cause
problems for any of the many different types of special access and
adaptive hardware and software.  Often, the only way to tell whether a
product or new features in a product will cause problems is to
actually try it out with the different access products.  As a first
pass, companies may have people with disabilities on site who can test
new programs for general usability.  However, there are literally
hundreds of different adaptive aids.  As a result, it is difficult for
each application software manufacturer to have all of the adaptations
on-site to try with their new software or new features.  Two alternate
strategies are therefore suggested.

The first strategy is to include individuals from the various adaptive
hardware manufacturers and software developers as a part of the early
beta testing of a product.  This will take a concerted effort on the
part of application software developers, since these adaptive product
manufacturers themselves do not represent a large enough market to
normally qualify for early beta release of application software
programs.

A second strategy would be to contract with a third-party testing lab
that is familiar with a) the different types of hardware and software                                          36
adaptations available and b) the problems usually encountered by these
access products with application software.  This would involve a

financial investment on the part of the application software
developer.  On the other hand, it may provide for a better mechanism
to get a relatively high confidence evaluation of the compatibility of
the application software.  It would also allow testing with a range of
different hardware and software adaptations without requiring the
application manufacturers to release their software to a large number
of different manufacturers.  The early testing of software (pre-beta)
is important, since problems with accessibility are likely to occur at
a level that is difficult to address at the beta stages of an
application.  A major difficulty with this approach is that there are
no known testing labs with the broad cross-sectional base of
information that would be needed to carry out such testing at the
present time.

The best approach at this time therefore appears to be involving the
developers of the adaptive hardware and software as early as possible
in the testing of a product or update.


.c.::6) Provision of Special Customer Support Lines or Specialists

Another key to having software which is more accessible is the
provision of specialized customer support.  Often, an application
program will seem to be incompatible with various adaptive hardware or
software products, when in fact it will work with them if certain
parameters are properly set.  In other cases, it may be incompatible
with one particular adaptation, but be easily accessed using others.
Such information is important to users who have disabilities, and
generally cannot be obtained by calling the standard customer support
lines.  In fact, a number of companies have built-in accessibility
features in their products which are unknown to their own customer
support teams.

While it would be nice to have all of the customer support personnel
fully aware of all types of disabilities, adaptations, and
compatibility issues, this is unrealistic.  There is simply too much
specialized information.  Even with a specialized hot line,
application companies may find that they identify different
individuals with expertise on how to use or adapt their software for
users with different disabilities.

A two-tiered approach to support for users with disabilities is
therefore suggested.  First is the inclusion of basic disability
access issues and information across all of the customer support
personnel.  This would include both a TDD (telecommunication device
for the deaf) line and a voice line.  It would also include an
awareness of the efforts by the company to make their products more
accessible, and the existence of the specialized customer support
line.  All customers, including those with disabilities, could then
use the standard support lines to handle standard product use
questions.  When specialized questions arose, such as compatibility of
the product with special disability access utilities, the calls could
be forwarded to a disability/technical support team.

The second tier would be the creation of a customer support line
specifically for individuals who have disabilities.  If your company
provides an electronic customer assistance mechanism, a special forum
or section for disability access should also be provided.  The purpose
of these mechanisms would be to provide specialized and in-depth
information and support regarding disability access and compatibility
issues or fixes for different access utilities.

For some small companies, it may be difficult to develop a depth of
expertise in each of the disability areas.  In that case, rather than                                          37
trying to hire someone with expertise in the different disability
areas as well as expertise in the technical support aspects, the

company might contract with an outside agency who does have this
expertise and give them the training on the company's software and
technical support information.

The existence of the special customer support, as well as the phone
numbers, should be prominently listed in the documentation.  Specific
services and disability access features of products should also be
plainly documented in manuals.


.c.::7) Provision of Special Developer Support Lines or Contact People
  for Third-Party Manufacturers of Access Software and Hardware

Another key area in ensuring the accessibility of application software
is support for companies developing disability access software.
Again, these companies are usually small enough that they do not
qualify for the types of support generally provided to other, larger
developers and operating system manufacturers.  As a result, it is
often difficult or impossible for them to qualify for access to
technical support in the same manner as other larger third-party
manufacturers.  In addition, the types of problems they have sometimes
differ.  It is often therefore helpful to have individuals within the
technical support team who specialize in these issues, and who can
work with developers to both a) identify strategies for those
developers to effectively access your application, and b) identify
ways in which your application or future editions of it can be made
more user-friendly.

This latter point is essential in the development of new versions of
application programs.  As mentioned above, discovering an
incompatibility with access software at the beta testing stage is too
late.  Typically, the types of inconsistencies that occur with access
software occur at a rather fundamental architectural or structural
level in the application.  Thus, it is usually too late by the time
the beta test occurs to do anything about accessibility problems.  On
the other hand, software is usually not available for testing until it
is substantially completed.  Ensuring the future accessibility of
software products is therefore highly dependent upon interchange and
communication between the software development team at the application
manufacturer and the third-party access product developers.  Through
this interaction, as well as through documents such as this,
application software developers can begin to identify the kinds of
things that do or might cause accessibility problems.  They can then
get in contact with the third-party assistive device manufacturers and
explore ways to circumvent these problems.


















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                                          39

                            .c."Appendix A
                Initial Listing of Specific Techniques
       for Increasing the Accessibility of Application Software

                              Appendix A
                          Table of Contents

.Begin Table A.

  Character-Based Programs--Writing to the Screen.........33
     - Use Full-Width Text Wherever Possible..............33
     - Avoid Use of --- or *****..........................33
     - Avoid Alphabetic Characters to Draw Pictures, Boxes,
       etc................................................33
     - Provide/Retain Character Mode for Your DOS Software33
  Graphics-Based Programs--Writing to Screen..............34
     - Use the System Tools...............................34
     - Use the Text-Drawing Tools to Erase Text As Well...34
     - Minimize Use of Painted Text.......................34
  Cursors, Pointers and Highlighting......................34
     - Use System Cursors.................................34
     - Drag the System Cursor With You....................34
     - Allow the Substitution of Larger or Heavier-Line
       Cursors and Pointers...............................35
     - Carry a Character With You When Moving a Highlight
       Down a List........................................35
  Screen Format and Color.................................35
     - Use Consistent and Expected Screen Layouts.........35
     - Use Care When Transmitting Information With Color..36
     - Provide a Monochrome Option........................36
     - Make Sure that Warnings, Alerts, and Help Balloons
       Are Sufficiently Stable To Be Read Before They
       Disappear..........................................36
  Menus...................................................36
     - Use the System Tools...............................36
     - Avoid Non-Text Menu Items (Unless Redundant).......37
     - Provide Keyboard Access to All Menus...............37
     - Provide Alternate Mechanisms to Access Commands....37
     - Direct Access to Palettes and Toolbars.............37
     - Draw Toolbar Icons Individually....................37
  Buttons and Dialog Boxes................................37
     - Give Buttons Logical Names.........................37
     - Order Buttons in the Dialog Box Definition in a
       Logical Screen Order...............................37
     - Use Standard Relationships Between Buttons and Their
       Captions...........................................38
     - Allow Direct Keyboard Access to All Aspects of the
       Dialog.............................................38
  Sound...................................................38
     - Provide All Auditory Information in a Visual Format
       As Well............................................38
     - Provide ShowSounds Support for All Sounds..........38
     - Ensure that Visual Cues Are Noticeable.............38
     - Provide Captions for Synthetic or Recorded Speech..38
  Keyboard................................................39
     - Update System and Keyboard Flags/Lights for Locking
       Keys...............................................39
     - Provide Full Access to All Aspects of the Program
       from the Keyboard..................................39
     - Do Not Interfere with Key Latching and Other
       StickyKey Functions................................39
  Documentation...........................................39
  Packaging...............................................39
  General.................................................40
     - Making All Program Settings Software-Queriable and
       Settable...........................................40
.End Table A.                             41



                              Appendix A
                Initial Listing of Specific Techniques
       for Increasing the Accessibility of Application Software




This appendix contains an initial list of specific guidelines.  This
list is only a collection of items submitted so far; it is not meant
to be comprehensive.  Once this document has been circulated for
comment, a more complete list will be compiled and published.  Please
consider this list open-ended:  feel free to comment on any item or
add as many items as you wish.

The lists are organized by aspects of software design--menus, cursors,
writing to screen, etc.--rather than by disability.  This has been
done so that the significance to design is made more clear.


.a.:Character-Based Programs--Writing to the Screen

  1)  Use Full-Width Text Wherever Possible

       Text-based screen readers default to reading left to right.
       Text which is positioned in columns is often read as if it were
       continuous text; that is, the text in the first column is read,
       and then the screen reader jumps to the next column and
       continues reading.  Many screen readers can be programmed to
       deal with text in columns.  Where possible, however, continuous
       text is easier to deal with.


  2)  Avoid Use of --- or *****

       Where possible, use extended ASCII character graphics rather
       than standard ASCII characters (such as "***") for drawing
       lines, making boxes, etc.  When screen readers hit such text,
       they may read it as "asterisk, asterisk, asterisk,"
       unnecessarily slowing down the process.  A particular nuisance
       is text buried in a string of asterisks.  In order to read the
       text, the individual must sit while the screen reader reads off
       the punctuation or other characters.  Screen reading programs
       can be programmed to skip nonalphabetic characters; however,
       this can cause the individual to miss important information on
       the screen.


  3)  Avoid Alphabetic Characters to Draw Pictures, Boxes, etc.

       A similar problem appears when alphabetic characters are used
       to draw boxes.  Using 1's (the digit one) or l's (lower case L)
       to draw a vertical line is obvious to somebody looking at the
       overall screen.  When reading a single line of text using a
       screen reader, however, these do not look like a vertical line
       but are read aloud as the characters "L" or "One."


  4)  Provide/Retain Character Mode for Your DOS Software

       Software that presents information in a color graphics mode
       often uses different strategies to highlight or select text.
       Providing an optional character mode in your software greatly                                          42
       facilitates access software, particularly cursor finding.

.a.:Graphics-Based Programs--Writing to Screen

  1)  Use the System Tools

       Wherever possible, applications should use the standard text-
       drawing tools included in the system.  Most screen access
       software programs for graphics-based computers figure out what
       is on the screen by watching the use of these tools.  Even when
       the tools are used to draw characters in other (nonscreen)
       locations of memory and then copy the information to the
       screen, it is still possible for access software to track its
       use.  In this fashion, the access software can keep track of
       which characters with which attributes appear in each location
       on the screen without having to attempt to do optical character
       recognition directly on the bit-mapped fonts on the screen.
       (Direct OCR of pixel image of the characters on the screen has
       been proposed.  However, when small point italic characters are
       used, they are generally so distorted as to be unrecognizable.
       In addition, underlining, shading, outlining, and other
       attributes to the text can make it difficult to recognize.  As
       a result, tracking the use of the text-drawing tools is the
       only currently available technique.)


  2)  Use the Text-Drawing Tools to Erase Text As Well

       Occasionally, applications will draw the text characters in a
       different portion of memory, and then copy the block of text
       onto the screen.  As mentioned above, as long as the text-
       drawing routines are used, this does not pose a problem.
       However, when the applications are done with this text and they
       want to re-use the area, they will often directly zero the
       space in memory where they were drawing the characters rather
       than using the text-drawing tools to erase this area.  This
       makes it more difficult for the screen reading software to keep
       track of which characters are or are not still drawn in that
       portion of memory.


  3)  Minimize Use of Painted Text

       Occasionally, applications will use text which has been
       predrawn and stored in the program as a bit image.  Such
       painted text cannot be read by many screen reading routines.
       When this text is purely decorative, as on a start-up screen,
       it does not pose a problem.  If it contains important
       information or information necessary to use or understand the
       program, it should be created in real time using the text-
       drawing tools in order to be accessible by screen reading
       programs.


.a.:Cursors, Pointers and Highlighting

The problems surrounding cursors and pointers generally fall into two
categories: being able to substitute the cursor/pointer with a larger,
fatter cursor so that it can be seen with poor vision, and being able
to electronically locate the cursor so that the screen reading or
enlargement programs can follow text entry.  Eventually, some standard
mechanism for allowing electronic cursor/pointer location may be
devised.  In the meantime, the following strategies may be used.


                                          43

  1)  Use System Cursors

       Whether using text-based or graphics-based screens, using the
       system cursors and pointers wherever possible facilitates their
       location.  Again, most screen reading programs can easily
       locate the system cursor and pointer.  However, if the
       application software creates its own cursor (by highlighting
       text, by creating a box, etc.), there is no way for the access
       software to easily tell where the cursor is.


  2)  Drag the System Cursor With You

       If the application software does use some special nonsystem
       cursor, one strategy is to drag the system cursor along with
       the special cursor.  In this fashion, the access software can
       easily follow the custom cursor.  Screen reading software
       frequently provides a capability to automatically locate the
       system cursor.  If the system cursor follows any specialized
       cursor, then the blind user will be able to locate both.  For
       individuals with low vision, the screen enlargement software
       will generally follow the cursor automatically, so that as they
       type, the enlarged image on the screen tracks the typing.


  3)  Allow the Substitution of Larger or Heavier-Line Cursors and
     Pointers

       Some individuals with low vision are able to use computers
       without screen enlargement software, either by using the
       standard font or a slightly larger font.  The text cursor (and
       some mouse cursors), however, sometime consists of a single
       thin line which easily disappears from the user's view.  As the
       user enlarges the fonts, the cursor line usually gets taller,
       but it does not necessarily get any thicker or easier to see.
       If an application is using a system cursor, then there
       shouldn't be a problem (since the system should already support
       an alternate system cursor which would be heavier and easier
       for individuals to see.)  If the application software is
       providing its own cursors, however, then provision of an
       alternate cursor with a heavier line width should be
       considered.  Alternately, a special control which would make
       the cursor stand out in some fashion, to make it easy to
       locate, could be provided.  Some strategies for making the
       cursor easy to locate include:

              -  Having the cursor momentarily change into some large
                 dark shape which is easy to locate when a particular
                 key combination is pressed;

              -  Providing a larger thick cross-hair which covers some
                 or all of the screen momentarily while a particular
                 key combination is pressed.


  4)  Carry a Character With You When Moving a Highlight Down a List

       A common strategy for selecting items from a list is to use the
       arrow keys to move a highlighted bar up and down the list.  A
       highlighted bar is much harder for screen reading software to
       detect than is a character.  If a small character is also moved
       up and down a list (along with the highlight) or in some other
       way change the characters on the line that is selected in the
       list, it greatly facilitates access by screen reading programs.                                          44
       Two examples are shown below.

         Example 1:                  Example 2:
               Item 1                    1   Item
            >  Item 2                    2   Item
               Item 3                   [3]  Item
               Item 4                    4   Item


.a.:Screen Format and Color

  1)  Use Consistent and Expected Screen Layouts

       For individuals who have low vision, consistency of screen
       layout is important.  As discussed earlier, individuals with
       low vision often use screen enlargement software to access the
       screen.  As a result, they are only able to view a small
       portion of the screen, similar to looking down a paper tube.
       Similarly, individuals who are blind must use screen reading
       software to locate items on the screen, searching one letter or
       word at a time.  Thus, programs that have a consistent location
       for menus, feedback messages, etc., are much easier to use.
       Where operating systems specify standard procedures and
       locations for things, it is very helpful for application
       programs to follow these standards.


  2)  Use Care When Transmitting Information With Color

       For individuals who are color blind, the ability to select the
       colors used for all aspects of the screen is helpful.  In
       general, most displays use light characters on a dark
       background or dark characters on a light background.  As a
       result, they are generally visible no matter what their color
       is, simply because of the difference in their intensity.
       However, the ability to adjust colors to increase contrast is
       helpful for some individuals.

       When using color to encode information, using colors having
       much different intensities makes the colors easier to
       differentiate.  A light yellow and a dark green, for example,
       could be distinguished even if the screen were displayed in
       gray-scale mode because of the difference in their intensity.


  3)  Provide a Monochrome Option

       One mechanism to circumvent problems with color is simply to
       provide a monochrome or gray-scale option for the program.
       Individuals having difficulty with colors can then use the
       program in the monochrome or gray-scale mode.


  4)  Make Sure that Warnings, Alerts, and Help Balloons Are
     Sufficiently Stable To Be Read Before They Disappear

       Alert messages that pop up and disappear quickly may be missed
       by some individuals, depending on their screen access tools.
       To avoid this problem, alert messages should remain on screen
       until dismissed by the user.

       Some other applications have text which appears when the mouse
       cursor touches some point on the screen.  If the mouse cursor
       moves off of that point, the text disappears.  This provides a
       particular problem for screen access software, if it moves the
       mouse pointer along as it reads the text.                                          45

       A typical scenario of this problem would occur follows.  The
       user moves the cursor to a point on the screen, causing the
       text to pop up.  The user then tries to read the text, but as
       the screen reader begins to read the text, it moves the mouse
       cursor to move along with the reading.  As soon as the cursor
       moves to the first word, it has left the original trigger point
       on the screen, and the text that the user is trying to read
       disappears.  At the present time, the balloon help on the
       Macintosh suffers from such a problem.  A mechanism which would
       allow triggered text to be locked on, so that the individual
       can move the cursor over the text to read it, would be helpful.

       Individuals with learning disabilities may experience similar
       problems.  For example, there is now a special utility program
       on the market which allows people with learning disabilities to
       get reading assistance: the user points the mouse cursor at a
       word, and the program reads the word aloud.  Such a program
       would be unable to read words in pop-up messages such as those
       described above.  As soon as the user moved the cursor to tell
       the special utility which word to read, the message would
       disappear.


.a.:Menus

  1)  Use the System Tools

       As discussed earlier, most access software works by attaching
       itself to the operating system.  When application software uses
       standard system menu tools, access software is able to read the
       list of available commands and can provide the individual with
       the ability to directly maneuver through and activate the
       commands.


  2)  Avoid Non-Text Menu Items (Unless Redundant)

       Menu items that are not text-based and are not accompanied by
       text are difficult for screen reading programs to access.


  3)  Provide Keyboard Access to All Menus

       Application programs which provide the ability to access all of
       the menus by using the keyboard greatly facilitate access by
       individuals who cannot use the standard mouse.  This access may
       be provided either by use of the arrow keys to move around
       through the menu structure, or through use of keyboard
       equivalents for the menu items.


  4)  Provide Alternate Mechanisms to Access Commands

       Application programs which provide multiple mechanisms for
       accessing commands better accommodate the differing needs of
       users.  Access via menus and layered dialogs provide easier
       access for individuals with lower cognitive abilities.  Direct
       access with key combinations provides better access for
       individuals with physical impairments and for individuals who
       are blind.


  5)  Direct Access to Palettes and Toolbars
                                          46
       As with menus, application programs which provide direct access
       to palettes and toolbars greatly facilitate access by

       individuals with different disabilities.  If the toolbar is
       only a shortcut method to accessing items in the menu, and the
       menu is accessible, then access to the toolbar would not be
       necessary.  When the toolbar commands are not available in the
       menu, however, direct access might be provided, or the items
       might be provided redundantly as an optional menu.


  6)  Draw Toolbar Icons Individually

       Screen access software for individuals who are blind works by
       monitoring the operating system's screen drawing routines.
       When individual icons are drawn separately, they can be
       individually identified, named, and accessed.  If a toolbar or
       palette is drawn as a single bit image, the individual tools
       within that palette are not individually identifiable or
       accessible using standard techniques.


.a.:Buttons and Dialog Boxes


  1)  Give Buttons Logical Names

       When naming the buttons within a dialog box (whose names do not
       appear on the buttons in the dialog definition), be sure that
       clear, logical, descriptive names which match the words printed
       on the screen near them.  Screen reading software accesses
       these names in helping the person who is blind to decipher the
       information within the dialog box.


  2)  Order Buttons in the Dialog Box Definition in a Logical Screen
     Order

       In some operating systems, buttons within a dialog box are not
       normally accessible directly from the keyboard.  Access
       utilities exist which allow individuals to tab through the
       buttons until they reach the desired button, after which they
       can select it from the keyboard.  The order in which the tab
       moves through the buttons is dependent upon the order in which
       the buttons are defined in the dialog.  If the button
       definitions are not in logical order, the tabbing key will jump
       the highlight in what appears to be a random pattern around the
       dialog, highlighting the buttons in their definition order.
       Although this does not prevent access, it is disorienting.


  3)  Use Standard Relationships Between Buttons and Their Captions

       If the caption is not a part of the button itself, use some
       standardized spatial relationship so that the location of a
       label for a button (or a button for a label) is predictable for
       individuals using screen readers to explore/use a dialog box.


  4)  Allow Direct Keyboard Access to All Aspects of the Dialog

       Again, the best solution is to provide direct keyboard access
       to all aspects of the dialog, including buttons, scroll
       windows, text entry fields, and pop-up menus.


                                          47

.a.:Sound


  1)  Provide All Auditory Information in a Visual Format As Well

       A general solution which solves the access problems for both
       individuals who are hard of hearing and individuals who are
       deaf is the provision of all auditory information in a visual
       form as well.  Auditory warning beeps can be accompanied by a
       visual indicator.  Beeps and other sounds would described in
       text, both to differentiate the sounds and to allow access by
       individuals who are deaf-blind (and would be using a braille
       screen reading program to access all of the information from
       the computer).  Speech output (in cases where it is important
       for understanding and using the program) can be accompanied by
       text on the screen (either as a normal part of the program, or
       in a caption box).  This presentation of information visually
       can be programmed to happen at all times, or can be invoked if
       a special operating system flag is set indicating that the user
       would like all auditory information presented visually.  If the
       system software provides a "ShowSounds" switch, the setting of
       this switch could then trigger the visual display feature.


  2)  Provide ShowSounds Support for All Sounds

       For beeps or other sounds which are not normally accompanied by
       a visual indication, application software should check for a
       system "ShowSounds" switch.  At the present time, the
       "ShowSounds" switch is not a standard feature.  In the future,
       however, it should be appearing as a standard system switch
       which can be accessed by software.  Users who are in noisy
       environments or who cannot hear well would then be able to set
       the "ShowSounds" switch.  Application programs could then check
       that switch and provide a visual indication to accompany any
       auditory sounds.


  3)  Ensure that Visual Cues Are Noticeable

       When providing a visual cue to what would otherwise be an
       auditory alert, it is important to ensure that the cue is
       sufficient to attract the user's attention when viewed out of
       the corner of the eye.  An individual who is looking at the
       keyboard and typing, for example, is not going to notice a
       small icon that appears and disappears momentarily in the
       corner of the display.  A flickering menu bar or area at the
       bottom of the screen will stand a better chance of attracting
       attention.


  4)  Provide Captions for Synthetic or Recorded Speech

       As programs incorporate the use of synthetic or recorded
       speech, closed captioning should be considered.  Again, in
       those cases where the information being presented via speech is
       already presented in text on the screen, there is no need to
       present the information visually in any other fashion.  In
       those cases where information is being presented via speech
       which is not otherwise displayed on the screen, application
       programs might check for the "ShowSounds" switch.  If the
       switch is set, a small box containing the text being spoken
       could be displayed on screen.  Music or other sounds being
       provided for adornment would not have to be presented in                                          48
       caption form, if they are not important to the operation of the
       program.  Where the tune or sound is important to the operation

       of the program, then some description to that effect could
       appear in the caption box.

       NOTE: In addition to providing a "ShowSounds" switch as a part
       of the operating system, manufacturers of modern operating
       systems are also being encouraged to build captioning tools
       directly into the operating system to facilitate the
       implementation of closed captioning by application programs.


.a.:Keyboard


  1)  Update System and Keyboard Flags/Lights for Locking Keys

       Some application programs provide their own on-screen
       indication as to whether the CapsLock, ScrollLock, and NumLock
       keys have been depressed.  In some cases, this feedback is
       independent of (and therefore sometimes contradictory to) the
       flags in the system or the status of the lights on the
       keyboard.  This can cause inconsistent feedback to people who
       are using access programs which check the status of these
       indicators.  Applications programs should either use the status
       flags in the system and keyboard or update them to agree with
       the program.


  2)  Provide Full Access to All Aspects of the Program from the
     Keyboard

       Making all aspects of the program, including menus, dialogs,
       palettes, etc., accessible from the keyboard significantly
       increases accessibility for some users.  Although a MouseKeys
       feature (which allows the user to use the keypad to drive the
       mouse around the screen) could be used to provide access to
       toolbars, for example, this is a very slow and ineffective
       mechanism.  Even if the individual is using MouseKeys for
       drawing, rapid access to the tools via the keyboard can greatly
       facilitate the use of the application software by individuals
       with disabilities (and other users as well).


  3)  Do Not Interfere with Key Latching and Other StickyKey Functions

       One problem faced by individuals with disabilities is the
       inability to hold down two keys simultaneously.  "StickyKey"
       programs which provide electronic latching for the Shift,
       Control, Alternate, Option, and Command keys on the different
       computer platforms already exist, and are being made available
       by operating system manufacturers.  As a result, it is not
       necessary to build this type of feature into your application
       program.  In fact, this is an example of an accessibility
       feature which is best handled at the system level.  Moreover,
       implementing it in an application can cause a conflict with and
       therefore interfere with the feature in the system software.


.a.:Documentation

       See discussion in Part IV.


.a.:Packaging
                                          49
       Some packaging techniques make it difficult or impossible for
       people with manipulation problems to open the package.  Where

       products are sealed for warranty or virus protection, some
       means for easily opening the package should be provided.


.a.:General


  1)  Making All Program Settings Software-Queriable and Settable

       In order to facilitate access to programs by individuals using
       their access software, it is useful to have all user-settable
       parameters both readable and settable via external software.
       This might be accomplished in a number of fashions, including
       providing an optional menu which could be enabled (since the
       access software would already have access to the menus.)  This
       technique would allow the software both to easily get a list of
       the externally available commands and to execute them.
       Commands can be provided for reading and for setting
       parameters, either directly or via dialogs.












































                                          50

                            .c.Appendix B
                     Resources Available to Help





























































                                          51

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copying.





























































                                          52



               Appendix B: Resources Available to Help




For comprehensive listings of third-party computer access hardware and
software....


Online:

    ABLEDATA is a comprehensive database of over 17,000 rehabilitation
       and assistive device products.  The full range of technology is
       included, from wheelchairs to sensory aids to communication
       devices.  Low-tech devices, such as typing sticks and
       communication boards, are also included.  ABLEDATA is
       maintained by Macro Systems, 8630 Fenton Street, Suite 300,
       Silver Spring, MD  20910, 301/588-5484.  ABLEDATA is also
       currently available on-line via BRS, Bibliographic Retrieval
       Service, which is subscribed to by most libraries.


On Disk:

    Hyper-ABLEDATA is a desktop version of the ABLEDATA database.
       Hyper-ABLEDATA allows the full 17,000-item database to be
       searched by company name, product name, type of product, or
       Boolean logic searching.  It is available on CD-ROM, and
       contains pictures of about 1,000 products, and sound samples
       for 50 different synthesized voices.  The Hyper-ABLEDATA CD is
       available from the Trace R&D Center, S-151 Waisman Center, 1500
       Highland Avenue, Madison WI  53705; price (1992) is $50.00 for
       two issues of the CD.


On Paper:

    Trace ResourceBook: Assistive Technologies for Communication,
       Control, and Computer Access (1991-92 Edition) is a
       comprehensive guide to software, hardware, and augmentative
       communication equipment.  Updated information is included on
       over 1,000 products and 400 manufacturers.  Products covered
       range from assistive devices for communication, such as
       headsticks, to computer software for speech therapy.  Each
       product entry features basic product and manufacturer
       information, a picture of the product (if relevant), and a one-
       or two-paragraph description.  The ResourceBook is available
       from the Trace R&D Center, S-151 Waisman Center, 1500 Highland
       Avenue, Madison WI  53705; price (1991) is $50.00.


For assistance in translating and formatting documentation into
  accessible ASCII text files, contact:

       George Kersher, Director
       R&D Division
       Recording for the Blind
       PO Box 7068
       Missoula, MT  59802
       406/243-2899

                                          53

For information on efforts of other application software companies
  working on accessibility issues, contact:

       Information Technology Foundation
       (formerly ADAPSO)
       1616 N. Fort Myer Drive, Suite 1300
       Arlington, VA  22209-9998
       703/522-5055 (voice)
       703/525-2279 (fax)


For general information on the Federal regulations regarding computer
  accessibility, contact:

       Frank McDonough, Assistant Commissioner
       Office of Federal Information Resources Management
       General Services Administration
       18th and F Streets NW, Room 2239, KA
       Washington, DC  20405


For general information on Federal computer accessibility, contact:

       Clearinghouse on Computer Accommodation (COCA)
       General Services Administration
       18th and F Streets NW, Room 2022, KGDO
       Washington, DC  20405


For information on the latest application software design
  guidelines...

For information on the latest application software design guidelines,
as well as the latest versions of design guidelines for computer
hardware and operating systems, contact:

       Gregg Vanderheiden, Ph.D., Director
       Trace R&D Center
       S-151 Waisman Center
       1500 Highland Avenue
       Madison, WI  53705-2280
       608/262-6966 (voice)
       608/263-5408 (TDD)
       608/262-8848 (fax)


For information on disability statistics, contact:

       Mitchell Laplante, Ph.D.
       Disability Statistics Program Inventory
       Institute of Health and Aging
       University of California - San Francisco
       3rd and Paranassus Avenue, Room N631
       San Francisco, CA  94143
       415/476-9485








                                          54

                            .c.Appendix C
            A Collection of General Notes on Accessibility
                (with specific comments in relation to
                 Computers and Application Software)



























































                                          55
































































                                          56



                              Appendix C
            A Collection of General Notes on Accessibility
                (with specific comments in relation to
                 Computers and Application Software)





What Is Meant by Accessibility?

Accessibility refers to the ability of products and environments to be
used by people.  In this particular context, accessibility is used to
refer to the ability of standard application software to be accessed
and used by people with disabilities.  Although the way people access
the software may vary, the program is accessible to an individual if
the individual is able to use it to carry out all of the same
functions and to achieve the same results as individuals with similar
skills and training who do not have a disability.

Similarly, with software and operating systems, accessibility refers
to the ability of an individual to access and use the product in an
effective and efficient manner.  It does not have to be identical to
the manner in which somebody without a disability would use it, but it
should provide equivalent and efficient access.





Four Types of Strategies that Standard Product Manufacturers Can Use
  to Make Their Products More Accessible

In looking at product accessibility, it is important to note that
there are different approaches to making products more accessible.  In
any one product, it may be necessary to use one or a combination of
these approaches to achieve the desired level of accessibility across
all of the types of disability.  Each of these approaches has
advantages and disadvantages.  All other things being equal, however,
wherever possible, the first type, direct accessibility, is the most
advantageous.  These four approaches, in order of desirability, are:

    1) Direct Accessibility

    2) Accessibility via Standard Options or Accessories (available
       separately from the manufacturer)

    3) Compatibility with Third-Party Assistive Devices

    4) Facilitation of Custom Modification











                                          57


                       1) Direct Accessibility




Description

For most types or degrees of impairment, there are simple and low cost
(or no cost) adaptations to product designs which can significantly
increase their accessibility and usefulness to individuals with
functional impairments.  By incorporating these design modifications
into the initial product design, the standard product can be more
accessible directly "out of the box."  Direct accessibility features
can allow large numbers of people with mild to moderate disabilities
to directly use products as their colleagues without disabilities do.
As mentioned previously, they also provide options or make a product
easier to use by all.


Advantages

    1) Pre-Installed
       Always there; no need to find, buy, or install.

    2) Public Shared Products
       Will be present on products used in public or shared locations.

    3) Compatible
       If accessibility features are built directly into a standard
       product the access features will be automatically tested by
       third-party software or accessory manufacturers for
       compatibility with their products when they do their testing.

    4) No Additional Cost to User
       Product costs same for users with disabilities as those
       without.

    5) Less Stigma
       Particularly for older users, built in accessibility is much
       more acceptable than special aids or modifications and may be
       unnoticed.

    6) Easier to Use by All
       Products designed for people with reduced abilities are
       generally easier for everyone else to understand and use.


Disadvantages

    1) Feasibility for Some Disabilities
       It is not practical or feasible to make some products directly
       accessible for people with some disabilities.  (e.g. not
       practical to build a braille display into every computer to
       allow access by deaf-blind users)


Notes

For application software manufacturers, a good part of maximizing the
accessibility of their software will be in being sure it is compatible
with the built-in or third-party accessibility features and aids.
This compatibility includes not interfering with the invocation and
operation of the access features as well as cooperating with them by                                          58
making key information available only to the application program
available to the access features.

Examples

A "MouseKeys" feature is now a standard part of all Apple Macintosh
computers shipped.  This feature, which can be invoked directly from
the keyboard, allows the user to move the cursor across the screen via
the numeric keypad rather than the mouse.  Individuals who do not have
the motor control necessary to operate a mouse can use this feature
(which is built into all Macintoshes) to access the Macintosh.
Because the feature is implemented as an extension to the computer's
operating system, it costs nothing to include as part of the product.
Since "MouseKeys" became available, many able-bodied users have found
it useful as well because of its capability for precise one-pixel
positioning, which was not previously available.  (The MouseKeys
feature is now available for IBM computers running DOS, through a
package called "AccessDOS," available from IBM, and for Windows 3.0
and 3.1 through a package called "Windows Access Utility," available
from Microsoft.  (However, in these cases, the access features are
available as a separate package from the standard operating system,
and would therefore be examples of Type 2 accessibility, accessibility
via standard option or accessory.)

Other, noncomputer examples of direct accessibility include
MacDonald's, who embossed braille characters on the tops of its soft
drink cup covers along with the letters labelling the pushdown buttons
on the lid that indicate whether the drink is diet, etc., and Proctor-
Silex, who embossed braille characters on the bottom of some of its
bowls indicating the size (quarts) of the bowl.




































                                          59


               2) Accessibility via Standard Options or
                             Accessories
             (available separately from the manufacturer)




Description

Sometimes it is not possible to design the standard product to make it
directly accessible for some disability populations.  Alternatives to
standard design may be identified, but offering all of them may not be
practical due to some alternatives being mutually exclusive, too
expensive, or awkward as a direct part of a standard product.

When this occurs, a strategy that manufacturers might use would be to
make these adaptations or alternatives available as standard options
or accessories from the manufacturer.  These may be special order
items, or preferably, items packed with the product.  These special
features or accessories should be listed and described in the standard
documentation that comes with the product.  They could also be listed
in advertising for the product.  (If the options or accessories are
sold as separate products by the manufacturer, the listing below would
not apply, and the product would more closely resemble the
advantages/disadvantages list for third-party compatibility found on
the next page.)


Advantages

    1) No Additional Cost to User
       If the manufacturer provides it free, the product would cost
       the same for users with disabilities as those without.

    2) Possible Compatibility Testing
       If the features are packaged directly with the standard
       product, they may be tested by third-party software or
       accessory manufacturers for compatibility with their products
       when they do their testing.

    3) Easier Implementation of Some Features
       Some features, such as braille overlays or software extensions
       that require substantial memory, may be easier to implement as
       options or accessories to the standard product.


Disadvantages

    1) Must Be Installed
       No need to find or buy the feature, but it would have to be
       installed.

    2) Public Shared Products
       May or may not be installed and therefore available on public
       use products.

    3) Possibly No Compatibility Testing
       If the features are not packaged directly with the standard
       product, they may very will not be known to or tested by third-
       party software or accessory manufacturers for compatibility
       with their products when they do their testing.

                                          60

Notes

One reason that this approach is sometimes taken is because of
incompatibilities between various access features.  It may, in fact,
not be possible to have all of them co-reside simultaneously.  In this
case, an effective approach, particularly in the computer industry,
would be to package the various options as separate but included
components in the product when it is shipped.

If the access products/accessories are sold as separate products by a
manufacturer, they would be similar to a third-party product from the
point of view of the purchaser/user.  There may be some compatibility
advantage to the standard manufacturer's offering, since they have
more detailed and inside information on their product and product
plans.  There may also be more of a tendency for other software
developers to test their software with the standard manufacturer's
offering.  On the other hand, third-party access device manufacturers
specialize in the design of aids for people with disabilities or with
particular disabilities, and may be able to design access products
with better functionality and compatibility with other devices or
strategies used by the person with a disability.  As a result, no
preference between access products marketed by the standard product
manufacturers and those marketed by third-party manufacturers can be
drawn on a general basis. Similarly, no preference between large and
small third-party manufacturers can be drawn.  Decisions in this area
must be made on a product-by-product basis.


Examples

Apple currently ships a screen enlargement utility called CloseView as
a standard part of its operating system package.  Because CloseView
consumes a fair amount of memory when loaded, it is not automatically
installed in the system when the computer is purchased (as the other
disability access features are).  It is, however, included as a part
of the standard system disks (along with a number of other optional
system extensions which are not disability-related).  Because it is
packaged with the standard operating system when it is sold, it has a
much better chance of being compatible.  AccessDOS and the Windows
Access Utilities cited above are also examples of Type 2 accessibility
features.  They are not, however, currently packaged with the standard
product.





















                                          61


             3) Compatibility with Third-Party Assistive
                               Devices




Description

This involves designing the standard product in a manner that
facilitates the connection of third-party adaptive interfaces or
assistive devices.  No matter how sincere a manufacturer is about
increasing the accessibility of their products, there will always be
individuals with severe or multiple disabilities who will require
special accessories in order to operate the product.  Individuals who
are deaf-blind, for example,  who require dynamic braille displays
(costing thousands of dollars) cannot be directly accommodated when
building a computer which itself costs under a thousand dollars.
While many accessibility options can be implemented in software, such
that they cause no significant increase in the product manufacturing
cost, the inclusion of a multi-thousand dollar braille display in
every computer in order to accommodate a small number of users is not
efficient or reasonable.  Similarly, an individual who can only use an
eyegaze operated keyboard, again costing a significant amount of
money, could not reasonably be accommodated by adding such an
interface to standard product design.  In these and other cases where
substantial hardware or other manufacturing costs would be involved,
the most appropriate mechanism for providing accessibility is through
third-party special assistive devices.  In these cases, the best
strategy for standard product manufacturers is to maximize the
compatibility of their product with these assistive devices.


Advantages

    1) Better Tailored Solutions
       Use of third-party access aids or special access software
       products which can be selected by a user to meet their
       particular needs and preferences can provide better access than
       a general built-in utility, especially for people with more
       severe disabilities.

    2) Familiar Interface
       Users who already have a communication or interface aid that
       they require for other purposes (and are familiar with) can use
       it to operate products which are compatible with it.

    3) Only Practical Approach for Some
       For some access strategies which involve expensive hardware,
       such as a dynamic Braille display or eye gaze keyboard, the use
       of third-party assistive devices (rather than building
       interfaces into each product) is the only practical approach.


Disadvantages

    1) Must be Installed
       User must find, buy and install/attach the access interface.

    2) Additional Cost to User
       This approach requires that the user purchase the access
       interface or device separately.  However, if they have a severe
       disability, they may already have a general purpose interface
       device.                            62

    3) Public Shared Products
       It is rarely possible to open up public access products
       (computers, information terminals, etc.) to install software or
       hardware needed by a user to access the product.  (An exception
       to this would be products which have a standard external port
       for connecting access aids.)

    4) Usually No Compatibility Testing
       Features that are not part of a standard product are usually
       not known to, much less tested for compatibility by, most
       third-party software or accessory manufacturers.


Notes

Built-in and third-party access approaches are not exclusive of each
other.  It may well be appropriate for an individual to use built-in
access features for occasional use or basic access to public and
shared products (computers or information systems for example) that
the individual runs across in daily life yet use a more optimum access
system from a third-party manufacturer when they must work at a device
for extended periods of time.

Assistive devices/interfaces from third-party manufacturers generally
take one of two forms.  They are usually either:

    a) programs, or accessories that are made specifically for
       interfacing or using the standard product or products like it
       (e.g., an eye gaze keyboard or screen reading program), or

    b) stand-alone aids (such as communication aids or writing
       systems) which can also function as interfaces to other
       devices.

The use of third-party access products can be facilitated in a number
of ways including (but not limited to) :

      -   providing a standard external connection point where the
       product can be controlled from and where information sent to
       the display can also be found. by third-party products

      -   providing hooks or connection points in the operating system
       where third-party access software can tap into the information
       and control flow.

      -   not using display or control formats that are inaccessible
       to third-party access products without providing the
       information/control in an accessible format as well

      -   developing and documenting access strategies for new control
       or display formats which are currently inaccessible to third-
       party products.


Examples

Many people with physical disabilities cannot use standard computer
keyboards.  Some of these people would require more extensive
modifications than would be possible using the first two accessibility
approaches discussed.  Currently, there are assistive device
manufacturers who make alternative input devices to fit people with a
variety of severe physical disabilities.  However, the manufacturers
of these assistive devices have always had problems ensuring that the
devices would work with standard, commercially available computers.                                          63
As part of the effort by the computer industry to cooperate with
manufacturers of assistive devices, both IBM and Microsoft Corporation

now distribute an extension to their operating systems (DOS and
Windows) called "SerialKeys."  This extension allows people to connect
alternative input devices to the serial port of the standard personal
computer in a way which makes input to the serial port look like it is
coming directly from the standard keyboard and mouse.  In this
fashion, the user with a disability can completely access and control
the computer and all of its software from an alternate input system
without touching the standard keyboard or mouse.























































                                          64


                4) Facilitation of Custom Modification




Description

There are some cases where special circumstances require the custom
modifications of the product, either by the product manufacturer or a
third-party.  Standard product manufacturers can facilitate this
process.


Advantages

    1) Allows Custom Fitting of Solution
       Since this approach involves custom modification of products
       for a specific individual the solution can be designed to
       better meet their needs then either third-party or built-in
       access features.


Disadvantages

    1) Must Be Installed
       User must find, buy and install/attach the access interface.

    2) Very High Cost
       This approach is the most expensive.  Unless it only involves
       relatively minor mechanical, electronic or programming
       modifications, the cost can be extremely high.

    3) Public Shared Products
       This approach does not help at all for access to public or
       shared products.

    4) No Compatibility Testing
       Testing for compatibility by third-party software or accessory
       manufacturers is not possible.


Examples

Leaving room for special attachments or labels, documenting hooks or
places to patch into hardware or software, publishing information on
safe or effective ways to modify products, or honoring warrantees for
products which have been modified for accessibility but where the
modification did not result in the problem.














                                          65



The Best Approach

Of the four approaches to Accessible Design, the first type, direct
accessibility "from the box," is the best where it is possible.  It
allows the greatest access to products by persons with disabilities at
the lowest cost.  It also allows them to access products in public
places where they could not otherwise modify the products to meet
their particular needs.  It also removes the stigma of "special" aids
or modifications.  This is especially important for older users who do
not want to be labeled "disabled" even though their abilities are
weakening.

It should also be noted that most of us become temporarily "disabled"
in a number of ways throughout our lives.  Sometimes it is by
accident, such as a broken arm or eye injury.  Sometimes it is by
circumstance, such as operating things in the dark where we can't see
well, in loud environments (vacuuming or teenagers) where we can't
hear well, with things in our arms where we can't reach well, when
we're tired or on cold medication and can't think well, etc.   Only
those products which were designed to be more easily used directly
"from the box" (#1 above) will be of use to us then.  As mentioned
above, more accessible designs are also usually easier to use by
everyone all the time.  But only if the ease of use is directly built
in.







There Are No "Accessible" Products

In all of the discussions above, you will note that nowhere was a
product described as being "accessible."  Products are more accessible
or less accessible.  We can also talk about the accessibility of a
product.  However, it is impossible or inaccurate to ever make the
flat statement or judgement that a product is "accessible" implying
that it is accessible to all.  There will always be individuals with
severe and multiple physical, sensory, and cognitive impairments who
will not be able to use the product.

The corollary of this, of course, is that there is no set of measures
that someone can take that will make their product "accessible."  This
is a difficult concept and unwelcome news for those manufacturers who
sincerely want to make their products "accessible."  Manufacturers can
make their products more accessible or less accessible, but they
cannot make them "accessible" on an absolute scale.

In order to provide accessibility targets for manufacturers, however,
a number of "minimum accessibility standards" have been developed.
These generally take the form of building codes or other regulations.
These are the minimum levels of accessibility that must be achieved in
order to be acceptable according to some law or agency.
Manufacturers, however, should view these as minimum accessibility
standards, and strive to surpass them where they can.  Individuals in
the federal government who are interested in purchasing accessible
products may establish minimum accessibility standards.  However,
their end goal is products that are as accessible as possible.
Manufacturers should therefore not view minimum accessibility
standards as Descriptions of accessibility.  Products that met the
standards would not be accessible.  They could be said to "meet XYZ                                          66
accessibility standards," or they may "meet or exceed all XYZ
accessibility standards."

Thus, there are no totally accessible products.  The use of the term
accessible as a lone descriptor is misleading and confusing to those
who try to practice accessible (or universal) design.  Unfortunately,
it is commonly used this way today.  (Some suggested substitute words
or usage might be: more accessible, less accessible, minimal
accessibility standard, minimally acceptable accessibility, meets or
meets and exceeds XYZ accessibility standards, ADA accessible, GSA
Guideline Accessible, accessible to an individual, etc.)



Partial versus Complete Access
  for an Individual or Type of Disability

In designing products to be accessible, it is important to be sure
that the whole product is accessible.  Often, initial attempts at
accessible design are done piecemeal.  Accessible features are added
where they are obvious rather than as a result of looking at the
product's overall accessibility.  The result can be a design which has
accessible parts, but which is not as a whole accessible or usable.
Access to half a product when the rest is inaccessible is of little
practical use.  In some cases, inspired by a desire to address the
needs of people with different disabilities, it is even possible to
design some parts of a device (such as the controls) to be more
accessible to one population and design another part of the product
with another disability in mind.  Unless the whole product is
accessible to at least one of these populations no-one is served. This
is referred to as Solomon's Trap*.

In most cases, it is possible with careful design to create products
which are simultaneously accessible to people with different
impairments.  However, where this is not possible, care should be
taken to be sure that the entire product is accessible to those
disability populations that you are able to address.





Efficient Access

An important component of the Description of accessibility is that the
individual be able to use the product in a "similar yet efficient"
fashion.  Because the individual with a disability may have different
abilities from someone without a disability, they will undoubtedly
have to do things somewhat differently.  In fact, someone who is deaf
and someone who is blind have differing abilities, and would have to
access software in different ways from each other.  Thus, the term
similar does not imply that the person must access in exactly the same
manner.  They should, however, be able to access the product in as
similar and efficient a manner as possible.  The more similar and
efficient the access, the more accessible an environment or product
is.

Sometimes efficiency and similarity must be played off against each
other.  In this case, efficiency is usually more important if the
product requires frequent and continual use.   Similarity is more
important with products that are infrequently used or only used for
very short periods of time and where there is not time pressure.




                                          67



Accessibility Is a Continuous Function

Accessibility is not a yes/no proposition.  Even buildings or products
which meet accessibility codes vary in their accessibility.  The goal
of accessible design would not be to meet minimum accessibility
measures, but to create a product which is as accessible as possible
and practical.





* Vanderheiden, G., and Vanderheiden, K.  (1991).  Accessible Design
  of Computer Products: Guidelines for the Design of Consumer Products
  to Increase Their Accessibility to People with Disabilities or Who
  Are Aging, page 17.  Madison, WI: Trace R&D Center, S-151 Waisman
  Center, 1500 Highland Avenue, ZIP 53705.












































                                          68

                            .d.Appendix D
                  Section 508 Procurement Guidelines




                    Federal Information Resources
                    Management Regulations (FIRMR)
                      Excerpts on Accessibility




       Selected excerpts from the new FIRMR, 41 CFR Chapter 201,
       related to access to information technology by people with
       disabilities.

       This regulation uses the umbrella term, Federal Information
       Processing (FIP) resources, to identify automatic data
       processing and telecommunications resources that are subject to
       GSA's exclusive procurement authority.

       All text that is both bold and enclosed in square brackets
       represents emphasis that is our own.  All text that is in bold
       without also being enclosed in square brackets reflects the
       printing emphasis in the original document.

       For readers unfamiliar with the FIRMR, a brief excerpt
       concerning FIRMR applicability and scope has been included on
       the last page of this section.

       Copies of the FIRMR may be purchased from the Government
       Printing Office (GPO) Bookstore, Washington, DC 20402,
       telephone [phone].





























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                                          70


                            FIRMR Excerpts


SUBCHAPTER C--MANAGEMENT AND USE OF FEDERAL INFORMATION PROCESSING
  (FIP) RESOURCES

201-17.001 Predominant Considerations

The policies prescribed in subchapter C are designed to promote
success in the acquisition, management, and use of Federal information
processing (FIP) resources by emphasizing the importance for agencies
to--

(a) Develop and annually revise, in coordination with budget
   activities, a 5-year plan to meet the agency's information
   technology needs;

(b) Base requirements for FIP resources on agency mission, programs,
   and related information needs;

(c) Consider the potential for deploying projected technological
   advances of FIP resources to enhance future performance of programs
   and operations in support of the agency mission;

(d) Acquire FIP resources that result in the most advantageous
   alternative to the Government after consideration of--

    (l) Sharing and reuse of existing FIP resources,

    (2) Use of General Services Administration (GSA) services, and

    (3) Acquisition of agency resources by contracting;

(e) Establish responsibility through a designated senior official
   (DSO) when contracting for FIP resources under a delegation of
   GSA's exclusive procurement authority;

(f) Assign an individual (such as a Trail Boss) responsible for
   coordinating programmatic, technical, and contracting functions
   when acquiring FIP resources;

(g) Achieve full and open competition to the maximum extent
   practicable;

(h) Acquire resources that comply with Federal standards;

(i) Provide for security of resources, protection of information about
   individuals, continuity of operations, and national security and
   emergency preparedness;

[j) Provide individuals with disabilities (employees and others who
   use the agency's electronic office equipment) equivalent access to
   electronic office equipment;]

(k) Provide telecommunications access to hearing and speech impaired
   individuals;]

(l) Review and evaluate existing resources and related management and
   acquisition activities on an ongoing basis; and

(m) Replace outdated resources that are no longer the most
   advantageous alternative for satisfying the agency's requirements.
                                          71

                            FIRMR EXCERPTS


PART 201-18--PLANNING AND BUDGETING

201-18.001 General.

(a) 44 U.S.C. 3506(c)(8) (the Paperwork Reduction Reauthorization Act
   of 1986) requires executive agencies to develop and annually revise
   a 5-year plan for meeting the agency's information technology
   needs.

(b) Office of Management and Budget (OMB) Circular No. A-130 requires
   executive agencies to establish multiyear strategic planning
   processes for acquiring and operating information technology that
   meet program and mission needs, reflect budget constraints, and
   form the basis for their budget requests.

(c) OMB Circular No. A-ll requires executive agencies to prepare and
   submit annual agency-wide "Major Information Technology Acquisition
   Plans."

(d) The Computer Security Act of 1987 (Pub. L. 100-235, 40 U.S.C. 759
   Note) requires agencies to identify each FIP system that contains
   sensitive information and prepare a plan for the security and
   privacy of each such system.

[(e) Section 50s of the Rehabilitation Act Amendments of 19s6 (Public
   Law 99-506) requires the Federal Government to adopt guidelines for
   electronic equipment accessibility designed to ensure that
   individuals with disabilities may use electronic office equipment.
   This Act requires that agencies comply with such guidelines. FIRMR
   Bulletin C-8 provides guidance on planning for the FIP resources
   accommodation needs of individuals with disabilities.]

(f) The General Services Administration (GSA) helps agencies with
   their IRM planning by issuing handbooks, bulletins, and other
   guidance documents. IRM planning services are available, on a cost-
   reimbursable basis, through GSA's Office of Technical Assistance.

(g) GSA reviews agency IRM plans and the planning process as part of
   the Information Resources Procurement and Management Review Program
   described in part 201-22. Agencies' IRM planning is a factor in
   delegating procurement authority for FIP resources.



















                                          72

                            FIRMR Excerpts

201-18.002 Policies.

(a) Agencies shall develop a 5-year plan for meeting the agency's
   information technology needs. This plan shall--

    (l) Reflect current and future program and mission needs;

    (2) Consider the potential for deploying projected technological
       advances of FIP resources to enhance future performance of
       programs and operations in support of the agency mission;

    (3) Consider FIP resources needed to meet the national security
       and emergency preparedness needs of the agency;

    (4) Reflect budget constraints;

    (5) Form the basis for the agency's budget requests to OMB;

    (6) Serve as the foundation for requirements analyses; and

    (7) Be updated as needed, but at least annually.

(b) Agencies shall ensure that the IRM planning process includes the
   participation of each of the agency's program areas, as well as
   those organizations responsible for IRM (including records
   management), contracting, and budget preparation.

[(c) Agencies shall adopt electronic equipment accessibility
   guidelines similar to those described in FIRMR Bulletin C-8 and C-
   10 in their planning process.]

(d) Agencies shall ensure that acquisition of FIP resources is in
   accordance with the updated 5-year plan.


201-20--ACQUISITION


201-20.103-7 Accessibility requirements for individuals with
  disabilities.

[(a) Agencies shall provide equivalent access to electronic office
   equipment for individuals with disabilities (employees and others
   who use the agency's electronic office equipment) to the extent
   both present and future needs for such access are determined by the
   agency.

(b) Agencies shall provide telecommunications access to hearing and
   speech-impaired individuals to the extent both present and future
   needs for such access are identified in the requirements analysis.
   Telecommunications access for hearing and speech impaired
   individuals shall include education and training on the services
   and features of the GSA relay service.]

    (l) Agencies shall publish access numbers for TDD and TDD-related
       devices in telephone directories and provide such agency
       numbers to GSA for inclusion in the Federal TDD Directory.

    (2) Agencies shall display in their buildings or offices the
       standard logo specified by GSA for indicating the presence of
       TDD or TDD-related equipment.
                                          73

(c) Agencies shall consider the guidance contained in FIRMR Bulletins
   C-8 and C-10 on the subject of accessibility requirements for
   individuals with disabilities.]




























































                                          74

                            FIRMR Excerpts

Due to the importance of the timely provision of equipment for persons
with disabilities, the FIRMR contains an exception to the policy on
deviations from the FIRMR as follows:


201-3.401 Policy.

Deviations from the FIRMR shall be kept to a minimum consistent with
the specific needs and statutory authorities of each agency.
Individual and class deviations may be authorized by GSA's
Commissioner, Information Resources Management Service, or the
officials designated by the Commissioner for this purpose.


201-3.402 Exception.

[(a) For an acquisition limited solely to providing electronic office
   equipment accessibility for employees with disabilities, an
   individual deviation from the FIRMR may be authorized by the
   agency's DSO or the DSO's authorized representatives. This
   deviation authority is limited to those FIRMR provisions that--

    (1) Are not specifically prescribed by statute or executive order;

    (2) Do not change the level of procurement authority delegated
       from GSA to the agency; and

    (3) Impede or obstruct the acquisition of technology for employees
       with disabilities.

(b) A deviation authorized under paragraph (a) of this section may be
   granted immediately upon a written determination by the agency,
   identifying those FIRMR provisions impeding or obstructing the
   acquisition of technology for employees with disabilities. Agencies
   shall promptly provide a copy of each determination and deviation
   to: General Services Administration, Policy and Regulations
   Division (RMP), 18th & F Streets, NW, Washington, DC 20405.]


201-3.403 Procedures.

(a) The agency head or designee shall prescribe an agency procedure
   for the control of requests for deviations from the FIRMR. The
   procedure should include coordination with the agency DSO as
   appropriate. Agencies shall provide a copy of this procedure upon
   request to the address in 201-3.402(b).

(b) Each request shall explain the nature of and the reasons for the
   deviation.

(c) Agencies shall forward requests for deviations to the address in
   201-3.402(b).









                                          75

                            FIRMR Excerpts

For readers unfamiliar with the FIRMR, the following excerpt
concerning FIRMR applicability follows:


201-1.000 scope of part.

This part prescribes the extent to which the Federal Information
Resources Management Regulation (FIRMR) applies to the creation,
maintenance, and use of Federal records and the acquisition,
management, and use of Federal information processing (FIP) resources
by Federal agencies. It also discusses the basic authority for the
FIRMR.


201-1.002-1 Policy.

The FIRMR applies to--

(a) The acquisition, management, and use of FIP resources by Federal
   agencies.

(b) Any Federal agency solicitation or contract when either paragraph
   (b)(l), (b)(2), or (b)(3) applies:

    (l) The solicitation or contract requires the delivery of FIP
       resources for use by a Federal agency or users designated by
       the agency.

    (2) The solicitation or contract explicitly requires the use by
       the contractor of FIP resources that are not incidental to the
       performance of the contract. FIP resources acquired by a
       contractor are incidental to the performance of a contract
       when:

              (i) None of the principal tasks of the contract depend
                 directly on the use of the FIP resources; or

              (ii) The requirements of the contract do not have the
                 effect of substantially restricting the contractor's
                 discretion in the acquisition and management of FIP
                 resources, whether the use of FIP resources is or is
                 not specifically stated in the contract.

         (3) The solicitation or contract requires the performance of
            a service or the furnishing of a product that is performed
            or produced making significant use of FIP resources that
            are not incidental to the performance of the contract.
            Significant use of FIP resources means:

              (i) The service or product of the contract could not
                 reasonably be produced or performed without the use
                 of FIP resources; and

              (ii) The dollar value of FIP resources expended by the
                 contractor to perform the service or furnish the
                 product is expected to exceed $500,000 or 20 percent
                 of the estimated cost of the contract, whichever
                 amount is lower.

(c) The creation, maintenance, and use of records by Federal agencies.

                                          76

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                                          77

GENERAL SERVICES ADMINISTRATION
Washington, DC 20405                             January 30, 1991


                          FIRMR BULLETIN C-8

TO: Heads of Federal agencies

SUBJECT: Information accessibility for employees with disabilities

1.  Purpose.  This bulletin provides information and guidance
regarding agencies' responsibility to meet the special Federal
information processing (FIP) resource accommodation needs of
individuals with disabilities.

2.  Expiration date.  This bulletin contains information of a
continuing nature and will remain in effect until canceled.

3.  Contents.

Topic                                                   Paraqraph

Related material................................................4
Information and assistance......................................5
Definitions.....................................................6
Acronyms........................................................7
Public Law 99-506...............................................8
COCA............................................................9
General........................................................10
Agency responsibilities........................................ll
COCA services..................................................12
Cancellation...................................................13
Functional Specifications............................Attachment A

4.  Related material.

    a.  FIRMR 201-18.001

    b.  FIRMR 201-20.103-7

    c.  GSA handbook, "Managing End User Computing for Users with
       Disabilities"

    d.  FIRMR Bulletin C-10 "Telecommunications Accessibility for
       Hearing and Speech Impaired Individuals"

TC 90-1                                                Attachment

         FEDERAL INFORMATION RESOURCES MANAGEMENT REGULATION
                              APPENDIX B













                                          78

            FIRMR BULLETIN C-8
             POTENTIAL SOURCES FOR ADP RESOURCES SHARING
                                  By
                     Manufacturer and System Type

This attachment lists, by manufacturer and system type, ADP systems
that are available within the Federal government to make computer time
available for use by other Federal agencies.  Attachment B lists the
information alphabetically by geographic location.

For information and assistance or to effect changes to this
attachment, contact:

       General Services Administration
       Authorizations Branch (KMAS)
       18th and F Streets, NW
       Washington, DC 20405
       Telephone [phone] or FTS 241-1566.


Key to symbols:

* Indicates the installation has a substantial amount of computer time
available to support other agencies' requirements.  The installation
is considered to be among the best known potential Government sources
for sharing.

@ Indicates a Federal Data Processing Center (FDPC).  (Although
outside the scope of the sharing program, FDPC listings are provided
for the convenience of the reader.)

# Indicates Amdahl, ITEL, or Magnuson systems that are compatible with
equivalent IBM systems.

     Manufacturer/              Location and
     System                     Point of Contact

     #Amdahl                    U. S. Geological Survey
     5890                       Reston National Center
                                Reston, VA
                                Elaine Stout
                                [phone] or FTS 959-7157

     Amdahl                     Dept. of Transportation
     470/V7A                    Transportation System Center
                                Cambridge, MA
                                Chuck Pandil
                                [phone] or FTS 837-2217


5.  Information and assistance.

a.  Technical
       General Services Administration
       Clearinghouse on Computer Accommodation (KGDO)
       18th and F Streets, NW
       Washington, DC 20405
       Voice or TDD: FTS 241-4906 or 202-501-4906.


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            FIRMR BULLETIN C-8
b.  Policy

       General Services Administration
       Regulations Branch (KMPR)
       18th and F Streets, NW
       Washington, DC 20405
       Telephone: FTS 241-3194 or [phone].


6.  Definitions.

"Computer accommodation" means the acquisition or modification of FIP
resources to minimize the functional limitations of employees in order
to promote productivity and to ensure access to work-related
information resources.

"Information accessibility" means the application or configuration of
FIP resources in a manner that accommodates the functional limitations
of individuals with disabilities so as to promote productivity and
provide access to work-related or public information resources.

"Handicapped individuals" or "individuals with disabilities" means
qualified individuals with impairments, as cited in 29 CFR
1613.702(f), who can benefit from electronic office equipment
accessibility.

"Special peripheral" is defined in Section 508 of Pub.  L.  99506 as
"a special needs aid that provides access to electronic equipment that
is otherwise inaccessible to a handicapped individual."


7.  Acronyms.

COCA Clearinghouse on Computer Accommodation

DSO  Designated Senior Official

FIP  Federal Information Processing


8.  Public Law 99-506.

In 1986, Congress reauthorized the Rehabilitation Act of 1973, as
amended (Pub.  L.  99-506, 29 U.S.C.  794d).  Section 508, as
incorporated into the Act, mandates that guidelines be established to
ensure that handicapped individuals may use electronic office
equipment with or without special peripherals and that agencies comply
with these guidelines in acquiring electronic equipment.


9.  COCA.

In 1985, GSA's Information Resources Management Service (IRMS)
established an information resource center called COCA, to assist
Federal agencies in providing information accessibility to individuals
with disabilities.


10.  General.
                                          80
a.  Accessibility.  Workstations for Federal employees with sensory,
   cognitive, or mobility impairments may be equipped with special

            FIRMR BULLETIN C-8
   peripherals or software that provide access to computer technology,
   primarily microcomputers.  This accessibility is a necessary link
   that enables handicapped employees to function efficiently and
   effectively on the job.

b.  Equivalent access.  Disabled individuals and nondisabled
   individuals should be provided equivalent access to electronic
   office equipment.  FIP resources, particularly microcomputers,
   provide enhancement features, such as text enlarging and speech
   input and output, allowing disabled individuals to accomplish tasks
   previously impossible for them.  For example, the inherent
   flexibility of microcomputers permits their adaptation to meet the
   specific needs of disabled individuals through the use of braille
   printers, spoken screen review, and keyboard replacement devices.

c.  Functional specifications.  Attachment A presents specifications
   that are organized by functional requirement into three categories:
   input, output and documentation.  These specifications reflect the
   major areas that need to be considered during planning and
   acquisition.

d.  Accessibility alternatives.  Accessibility solutions range from
   third-party hardware and software add-ons, such as "layered"
   solutions, to hardware "built-ins" and operating system
   enhancements.  Agencies should attempt to provide the same
   equipment to all of their employees, whether or not they are
   disabled.  For that reason, "built-in" accessibility solutions are
   preferable to "layered" solutions.  Layering involves adding layers
   of software between the end-user and the operating system or
   application software.  While this often complex solution may have
   advantages, such as increased function and performance, it can also
   have serious disadvantages.  Disadvantages include increased costs,
   greater difficulty in maintaining software updates at the operating
   system level, and increased costs to train employees to utilize
   dissimilar equipment at different sites within the agency.  For
   these reasons, layering should be selected as an accessibility
   solution only after careful analysis of its merits relative to that
   of "built-in" solutions.


11.  Agency responsibilities.

a.  DSO.  The agency DSO for Federal information processing resources
   is the individual primarily responsible for ensuring electronic
   office equipment accessibility for current or prospective employees
   with disabilities.  This responsibility also includes providing
   access to Federal public information resources for individuals with
   disabilities.  The DSO or an authorized representative should
   monitor progress toward achieving electronic equipment
   accessibility goals.  The Federal Information Resources Management
   Review Program is one means of monitoring this progress.

b.  FIRMR requirement.  The FIRMR requires that agencies shall provide
   FIP resource accessibility to individuals with disabilities and
   that agencies consider the guidance contained in FIRMR bulletins
   concerning this subject.  This action is essential to enable
   handicapped employees to perform as productive employees.

c.  Coordinated effort required.  Agency management and technical
   personnel need to work closely with contracting officials when                                          81
   contracting for new or additional FIP resources to ensure

            FIRMR BULLETIN C-8
   accessibility to FIP resources by individuals with disabilities.
   Acquisition, management and technical personnel should:

    (l) Provide to contracting officials, for inclusion in the
       solicitation, an inventory and description of any accommodation
       hardware or software currently-being used with the resources
       scheduled for replacement or modification.

    (2) Specify the need for a plan from prospective offerers that
       ensures functionally equivalent or better access to and use of
       proposed replacement resources.

    (3) Specify the need for technical assistance in resolving
       problems in providing computer accommodation resources.

    (4) Specify the need for the Government to be permitted to install
       additional accommodation devices, peripherals, or software that
       may be acquired from a third party, without voiding the
       maintenance and warranty agreements of the contract, provided
       such devices or peripherals conform to the electrical
       specifications of the system and can be connected through
       standard expansion slots or peripheral ports.

    (5) Develop functional specifications to meet the access needs of
       individuals with disabilities (see Attachment A).

d.  Consult GSA handbook.  Agency managers determining accommodation
   strategies for FIP resource accessibility should consult the GSA
   handbook "Managing End User Computing for Users with Disabilities"
   for guidance.  This handbook is available from COCA.


12.  COCA services.

Upon request for assistance, COCA will:

    a.  Respond to requests for general information on frequently used
       hardware/software and workstation furnishings to accommodate
       individuals with disabilities.

    b.  Assist agencies with researching specific hardware, software
       and communications problems associated with an employee's
       computer accommodation requirements.

    c.  Provide on-going consultative/technical assistance to agencies
       during planning, acquisition, and installation of individual
       and agency wide office automation systems; and

    d.  Conduct workshops on computer accommodation procedures.


13.  Cancellation.


FIRMR Bulletins 42, 48, and 56 are canceled.

Thomas J. Buckholtz
Commissioner
Information Resources
Management Service                        82

            FIRMR BULLETIN C-8
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                          FIRMR Bulletin C-8
                             Attachment A
                      FUNCTIONAL SPECIFICATIONS

These specifications are organized by functional requirement into
three categories: input, output and documentation.  This organization
reflects the major areas that need to be considered during planning
and acquisition.  The capabilities set forth in these specifications
are currently available from industry in various degrees of functional
adequacy, except for access to screen memory for translating bit-
mapped graphic images.

GSA will update this attachment to keep pace with technological
advances and to address other types of FIP resources.

    1.  Input alternatives.  Access problems concerning the input
       interface to a microcomputer differ according to the type and
       severity of an employee's functional limitation.  Some users
       with disabilities are capable of using a keyboard, if it can be
       modified slightly.  Others require an alternative input
       strategy.  The following is an overview of common input
       alternatives and other input functional requirements that
       should be considered:

         a.  Multiple simultaneous operation.  Microcomputers have
            many commonly used functions that require simultaneous
            striking of multiple keys or buttons.  Sequential
            activation control provides an alternative method of
            operation by enabling a user to depress keys or buttons
            one at a time to execute the same function.

         b.  Input redundancy.  Some programs require a "mouse" or
            other fine motor control device for input.  Some users
            with motor disabilities cannot operate these devices.  An
            input redundancy feature permits the functions of these
            devices to be performed by the keyboard or other suitable
            alternative such as voice input.

         c.  Alternative input devices.  The capability to connect an
            alternative input device can be made available to a user
            who is not able to use a modified standard keyboard.  This
            feature supplements the keyboard and any other standard
            input system used.  The alternative input capability
            consists of a port (serial, parallel, etc.) or connection
            capability allowing an accommodation aid to be connected
            to the system to augment or replace the keyboard.  For
            example, an alternative input device, such as a switch,
            eye scan, or headtracking system, may be customized to
            provide the most effective method of input for a user
            while supporting transparent hardware emulation for
            standard input devices, such as the keyboard and the
            mouse.

         d.  Key Repeat.  A typical microcomputer generates
            repetitions of a character if the key for that character
            remains depressed.  This is a problem for users without
            sufficient motor control.  A key repeat feature can give a
            user control over the repeat start time and rate by
            allowing the timing parameters to be extended or the
            repeat function to be turned off.

         e.  Toggle key status control.  Microcomputer toggle keys
            provide visual indications of whether they are on or off.                                          84
            A toggle key status feature provides an alternative, non-

            FIRMR BULLETIN C-8: ATTACHMENT A
            visual means of showing the on or off status of a toggle
            key.

         f.  Keyboard orientation aids.  To orient a visually impaired
            user to a particular keyboard, a set of tactile overlays
            should be available to identify the most important keys.
            The tactile overlays can be in the form of keycap
            replacements or transparent sticky tape with unique
            symbols to identify the various keys.

         g.  Keyguards.  To assist a motor-disabled user, a keyguard
            should be available to stabilize movements and help ensure
            that the correct keys are depressed.  A keyguard is a
            keyboard template with holes corresponding to the location
            of the keys.

    2.  Output alternatives.  Some users with disabilities need an
       alternative output to be able to functionally use FIP
       resources.  The following is an overview of common output
       alternatives, and other output functional requirements, that
       should be considered:

         a.  Auditory output.  The auditory output capability on
            current microcomputers is sufficient to beep and play
            music.  However, some users with disabilities may require
            a speech capability.  A speech synthesizer is required to
            generate speech on today's computers.  The capability to
            support a speech synthesizer should continue to be
            available in future generations of computers, or this
            capability may be internalized through an upgrade of the
            computer's internal speaker.  The speech capability should
            include user-adjustable volume control and a headset jack.

         b.  Information redundancy.  Currently, several programs
            activate a speaker on the microcomputer to provide
            information to the user.  Some programs do not have the
            capability to present this information visually to the
            hearing-impaired user.  An information redundancy feature
            presents a visual equivalent of the auditory information
            provided.

         c.  Monitor display.  The requirement to enhance text size,
            reproduce text orally or in braille, or modify display
            characteristics is crucial for some users with visual
            disabilities.  To ensure that this access continues, the
            following capabilities are required:

              (l) Large Print display.  There should be a means for
                 enlarging a portion of the screen for a low-vision
                 user.  This process uses a window or similar
                 mechanism allowing magnification to be controlled by
                 a user.  A user can invoke the large-print display
                 capability from the keyboard or control pad for use
                 in conjunction with any work-related applications
                 software.  If applications software includes
                 graphics, enlargement of graphic displays should also
                 be available.

              (2) Access to visually displayed information.  The
                 capability to access the screen is necessary to                                          85
                 support the speech or braille output requirement of
                 many blind users.  Currently, blind users are able to

            FIRMR BULLETIN C-8: ATTACHMENT A
                 select and review the spoken or braille equivalent of
                 text from any portion of the screen while using
                 standard applications software.  Third-party vendors
                 should have access to the screen contents in a manner
                 that can be translated and directed to any internal
                 speech chip, a speech synthesizer on a serial or
                 parallel port, or a braille display device.
                 Information presented pictorially also needs to be
                 available in such a manner that, as software
                 sophistication improves, it may eventually be
                 translated using alternative display systems.

         (3) Color presentation.  When colors must be distinguished in
            order to understand information on the display, color-
            blind end users should be provided with a means of
            selecting the colors to be displayed.

    3.  Documentation.  Access to documentation for computer
       technology in a usable format should be provided for Federal
       employees with disabilities.  Braille, large print, or ASCII
       disk equivalents of standard manuals are options to be
       considered.





































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