Agency Proposal
Kiosks: Accessibility standards
Skip to issueThe discussion is now closed. The final summary is available.
§1. Using standards for similar machines
Now, there is no accessibility standard specifically for check-in kiosks. The Department of Justice has ADA Standards for Accessible Design (2010) for automated teller machines (ATMs) and fare machines. The U.S. Access Board has standards for machines like copiers, printers, and information kiosks. Both DOJ and the Access Board are currently involved in rulemaking to update their standards and include machines like check-in kiosks. (See the DOJ Proposal; the Access Board Proposal). But, these rulemakings are still in the early stages and won’t be effective for several years — and won’t apply to all check-in kiosks anyway.
DOT has been working with DOJ and the Access Board to come up with appropriate accessibility standards for all these machines. DOT is now proposing to base its kiosk accessibility standard on DOJ’s current ATM standard, adding certain parts of the Access Board’s current standard. DOT expects its standard to be compatible with the standards eventually adopted by the other agencies.
The goal is to make kiosks accessible for people with visual, mobility, tactile and hearing disabilities. DOT notes that IBM has already developed an accessible kiosk equipped with an industry-standard audio connector, accessible hardware controls, and text-to-speech output; testing shows it allows independent check-in by people with vision and mobility impairments. DOT estimates that in the first 10 years after the new regulations become effective, travelers with disabilities will check in using an accessible kiosk more than 12.4 million times. The details of the proposed standard are explained in the next Sections.
See what DOT said: SNPRM: Kiosk Current Proposal, SNPRM: Kiosk Technical Criteria; RIA §5.1: Current Industry Kiosk Practices
Proposed new §382.57(c) (carriers); Proposed new §27.71(k) (airports)
§2. ”Self-contained”; privacy
Kiosks must be “self-contained,” meaning the traveler does not need any assistive technology to use them other than a personal headset or audio loop. The kiosk must enable travelers with disabilities to receive and input information with the same degree of privacy available to other travelers.
- What are the costs associated with providing a handset or industry-standard headset connector?
- Instead of the kiosk itself having a headset connector or handset, is wireless technology available for people to use smart phones or other portable devices and Bluetooth to communicate with the kiosk? If so, should DOT require use of this technology?
- What about only requiring amplification control for the kiosk’s speaker, without also requiring a handset or headset connector? (See Section 6 of this post.) What are the costs and benefits of this alternative? Are there privacy issues?
See what DOT said: SNPRM: Kiosk Current Proposal, SNPRM: Kiosk Technical Criteria
Proposed new §382.57(c)(1) (carriers); Proposed new §27.71(k)(1) (airports)
§3. Height; clear floor space
Kiosks must be installed in a way that meets the DOJ 2010 ADA Clear Floor or Ground Space Standards. In general, these require clear space of 30” x 48” minimum, with requirements for knee and toe clearance and additional requirements for machines in alcoves or other partially enclosed spaces.
Height also must comply with the DOJ 2010 ADA Reach Standards. In general, all operable parts must be placed no more than 48 inches and no less than 15 inches from the floor. There are additional requirements for machines with partial obstructions. And, based on the DOJ 2010 ADA Display Screen Visibility Standard, the kiosk screen must be visible from a location 40” above the floor.
- Is there any aspect of physical layout that isn’t covered here?
Proposed new §382.57(c)(2),(7) (carriers); Proposed new §27.71(k)(2),(7) (airports)
§4. Operating parts; input controls
Kiosks would have to comply with the DOJ 2010 ADA Operable Parts Standards. Specifically, travelers must be able to operate all kiosk parts with one hand, without tight grasping, pinching, or twisting the wrist. No more than 5 pounds of force can be required. Beyond the ADA standards, DOT’s proposed standards would require:
- All operable parts must be designed so that users can discern them by touch without accidentally activating something.
- At least one tactilely discernible input control must be provided for each function.
- Any key surfaces not on active areas of the display screen must be raised above surrounding surfaces. Where touch keys are the only method of input, each must be tactilely discernable from surrounding surfaces and adjacent keys.
- Status indicators (including the status of all locking or toggle controls or keys) must be discernible both visually and through either touch or sound.
- When a timed response is needed, the unit must alert the user by sound or touch and give him/her a way to request more time.
- Numeric keys must be arranged in a 12-key ascending or descending telephone keypad layout. The central number 5 key must be tactilely distinct to allow the user to orient him/herself on the keypad by touch. Function keys must visually contrast from background surfaces. The following function key surfaces must have these tactile symbols:
Enter or Proceed – raised circle
Clear or Correct – raised left arrow
Cancel – raised letter “x”
Add Value – raised plus sign
Decrease Value – raised minus sign
- How costly will it be to make the various usable parts of kiosks perceptible by touch? DOT notes that software is now available to give people with vision impairments access to touchscreen-based technology. Recent versions of Apple’s iPhone, iPod Touch and iPad, and mobile devices with Google’s Android platform, are equipped with screen-reading technology that uses built-in voiceover software and a touch-sensitive track pad to give a spoken description of what is on the display as the user drags a finger over the track pad. Should the proposed requirement that input controls be tactilely discernible be revised to allow for this kind of input mechanism? Do most users who are blind or have low vision know how to use such touchscreens?
- Is it necessary to require that the status of all locking or toggle controls be visually and either audibly or tactilely discernible?
- Are time-outs really an accessibility barrier? What technical or other problems would be involved in requiring audible or tactile timeout alerts?
- Is the proposed standard for the numeric keypad the best arrangement to require?
- Should DOT specify the arrangement of alphabetic keys?
- Are there other function keys that should have a corresponding required tactile symbol? What should the symbol(s) be?
See what DOT said: SNPRM: Kiosk Technical Criteria (2), SNPRM: Kiosk Technical Critera (6)
Proposed new §382.57(c)(3),(6) (carriers); Proposed new §27.71(k)(3),(6) (airports)
§5. Speech-enabled; captioned
The kiosk must be speech-enabled. Operating instructions, visible transaction prompts, user input verification, error messages, and all other displayed information necessary for full use must be independently accessible to travelers who are vision-impaired. Audible tones can be used instead of speech to represent visual output not displayed for security purposes, like asterisks for PINs. Also, advertisements that don’t convey information used in the transaction don’t have to be audible.
The audible output must be coordinated with the visual output on the display. (Coordination allows users with low vision or cognitive disabilities to get information simultaneously by sight and hearing.) It must automatically stop when a transaction is selected, and the user must be able to pause it and to repeat it. The speech output must be delivered through a mechanism that is readily available to all users—e.g., an industry-standard connector for personal headphones or a telephone handset.
When receipts, tickets, etc. are the result of a transaction, audible output must be provided for all information the traveler needs to complete or verify the transaction. What this information is will depend on the particular transaction and on how the automated kiosk works. But the following information would specifically be required:
- For boarding passes and similar documents, concourse, gate number, seat number and boarding group must be provided audibly
- Boarding passes, receipts, tickets, or similar output delivered to a smart phone or PDA must be accompanied by the same audio information as if they were printed
- Is there other information that DOT should require to be audible?
The following information is specifically excluded from the audio requirement:
- The location of the kiosk; date and time of the transaction; customer account number; kiosk identifier
- Information that duplicates information audibly presented earlier in the transaction
- The contract of carriage, fare rules, itineraries or other “supplemental information” that may come with a boarding pass
- Are these exclusions reasonable?
- Is there other information that could be excluded without creating problems for travelers with disabilities?
Multimedia content containing speech or other audio information (e.g., beeps or other tones) necessary to understand the content must be open-captioned or closed-captioned. Advertisements, etc. that don’t convey information that can be used in the transaction do not have to be captioned.
- Are there any other aspects of audible output and captioning that DOT should cover?
See what DOT said: SNPRM: Kiosk Technical Criteria (3), SNPRM: Kiosk Technical Criteria (5)
Proposed new §382.57(c)(5) (carriers); Proposed new §27.71(k)(5) (airports)
§6. Volume control
If audible content is delivered through a handset or headset connector for private listening, there must be some way for the user to control the volume. If sound is delivered through speakers on the kiosk, users must be able to increase volume to at least 65 dB SPL. If the surrounding noise level is more than 45 dB SPL, users must be able to increase volume by at least 20 dB above the background noise level. The kiosk must automatically reset the volume to the default level after every user.
- If both volume control and the ability to use a personal audio loop are required, can the same industry-standard connector be used for both speech navigation and the kiosk’s audio output? If so, how would users select the function that meets their particular disability-related needs?
- Would volume controls similar to those provided in speech-enabled ATMs be useful in the airport environment?
- Should the dB amplification gain for the volume control for private listening be specified?
- Is the proposed 65 dB amplification gain for voice output in public areas sufficient to address the needs of travelers who are hard of hearing?
- Is the proposed 20 dB additional amplification requirement for nosier environments sufficient to address the needs of travelers who are hard of hearing?
- Should different amplification gains be specified for outputs from public speakers vs. personal assistive listening devices?
See what DOT said: SPRNM Kiosk Technical Criteria (4)
Proposed new §382.57(c)(5) (carriers); Proposed new §27.71(k)(5) (airports)
§7. Display characteristics; Braille
Characters displayed on the screen must be in a sans serif font, at least 3/16th inch high (measured by an uppercase I). They must contrast with the background (either light on dark, or dark on light). Color coding cannot be used as the only means of conveying information.
Braille instructions for how to turn on the speech mode must be provided. The Braille has to comply with the DOJ 2010 ADA Standard for Signs.
Proposed new §382.57(c)(6),(8) (carriers); Proposed new §27.71(k)(6),(8) (airports)
§8. Biometric authentication
Kiosks may not use biometric identification (e.g., fingerprint, palm print, iris recognition) as the only method of user identification unless a least two biometric options using different biological characteristics are provided. For example, a person without arms could not use fingerprint authentication but could use an iris scan alternative. This provision does not require kiosks to add biometric features; if and when such features are used, this would be the standard.
- How important it is to have a provision like this–and what would it cost?
See what DOT said: SNPRM: Kiosk Technical Criteria (7)
Proposed new §382.57(c)(9) (carriers); Proposed new §27.71(k)(9) (airports)
I think that if the kiosk is going to tell people information through speakers, the rules must be very clear about what can and cannot be sent through the speakers. They have to protect people’s privacy.
I guess you are referring to the HIPPA and privacy laws. The one thing that blind people do, especially myself when I use an ATM or other accessible device when I am out is carry earphones, and all ATMS and other machines, have the standard sockets, and we just listen and follow the instructions. So that is the way blind people do these things for a very long time. Again, the only thing these business have to do is ask, we know what is out there that we can use, and how to do it to protect our privacy as well.
Hi Cherylchevarria! Thank you for your comments. It sounds like you think travelers who use earphones have enough privacy. DOT is also considering allowing kiosks to have loudspeakers. Do you think they should? What about other users: are there additional privacy issues with loudspeakers on airport kiosks?
Machines such as atms and others out there that have capability, usually has an up or down mechaniam that allows us to control thisl. This is basically standard stuff.
Do you think that making airport kiosks work basically like ATMs would be enough? One of the things DOT is considering is whether airports are different from other places where people use kiosks, they are especially concerned that airports might be too noisy. Do you think the proposed volume levels are high enough?
Are you sure the DOT and DOJ are the best people to propose such a standard?
For someone who is a travel agent who is blind, it is hard for me or my clients to book or access there books online or at the Kiosks, more and more people are becoming print disabled whether from being blind by birth, disease, accidents, o…r from being veterans. I am also part of the NFB and we brought cases against certain airports for doing this, and it was thrown out of court because ADA doesn’t have any jurisidiction at the airports or the websites in this matter, only on the actual airlines themselves, we can travel on the but we can’t book them or access our tickets, that is not right.
Hello, cherylechevarria. Welcome to RegulationRoom and thanks for sharing your experiences! What do think about the standards DOT is suggesting for airport kiosks? Mencik suggested a priority lane for travelers with disabilities to get assisted service, what do you think? See Mencik’s comment below.
Hi, Natpotter, welcome back to RegulationRoom! Can you explain a little more about why you think DOT isn’t right to propose the standard? Which agency would be better?
Instead of revamping all the kiosks, why not require a priority lane for disabled people to get personal assisted service instead? The same goal is achieved at at very much reduced cost.
mencik, you’ve made several comments proposing personal service instead of DOT’s proposed changes. Currently airlines and airports (CFR Part 382) are required to “provide equivalent service to passengers with disabilities when automated airport kiosks are inaccessible.” In the SNPRM, DOT has noted that, “Many passengers with disabilities consider these solutions inadequate because they do not allow for independent access and call attention to a passenger’s disability.” Do you feel the current regulations are adequate? If not, what changes would you suggest?
Why, just make the kiosks more accessible. There are laws out there in place for this. I know we had them passed into law. If they need to revamp them so be it, we want independence and not special treatment, the same with the websites, more and more websites are not accessible. It would save me a lot of time and aggrevation if I could book my clients some place without have to wait on the phone for a minimum of 30 minutes for a rep to get on the phone and book something for me, instead of me doing it myself.
Segregating people with disabilities into a separate line is a stigmatizing. People with disabilities are normal people who do not require special treatment, just equal treatment. That means equally accessible benefits like kiosks and websites.
Hello, gregory.p.care, and welcome to Regulation Room. What do you think of the standards that DOT is proposing for kiosk accessibility? Are they enough, or are they missing something?
FYI, with someone who is blind, they might not have access to this type of service or cell phones. I am the President of the Travel and Tourism Division of the National Federation of the Blind, many people already carry headphones with them, especially if they use them at the banks and other avenues. The airlines are not being fair to anyone, and they have to change there scripting on their websites to be accessible to all. The NFB had a law put through congress and passed into law that all websites much be made accessible to all.
The information and knowledge you can provide based on your personal experience and position at NFB will be valuable for DOT. You mention that many travelers who are blind may not have access to a certain type of service or cell phones. Could you say more about this? Do you support the “self-contained” kiosk proposal?
This comes from the National Federation of the Blind Directly.
New proposal seeks improved access for disabled fliers
9/20/2011
News Outlet: USA TODAY
The Transportation Department wants to require airlines to make their websites and airport kiosks more accessible to the disabled.
The proposed regulation — made Monday following years of complaints by travelers with disabilities about getting tickets on flights — is similar to a proposal made in 2004 that airlines and travel agents resisted because of the cost and complexity of the changes.
The new proposal calls for the airlines to make their websites accessible to blind people for reservations and check-ins within a year. The airlines would have two years to make the rest of their websites more accessible.
Websites… more »
Under the proposed rule, airlines would also have to upgrade airport kiosks that print boarding passes or baggage tags with braille, audio messages and screens visible 40 inches off the floor. The upgrades to kiosks would apply as airlines replace machines during the next decade.
“I strongly believe that airline passengers with disabilities should have equal access to the same services as all other travelers,” Transportation Secretary Ray LaHood said in announcing the proposed regulation.
More than 15 million adults have disabilities with vision, hearing or mobility, according to the Census Bureau, and nearly one-third travel by air.
The advocacy group Paralyzed Veterans of America welcomed the kiosk proposal, saying people with vision and physical impairments have been unable to read screens too high off the ground or use touch-screen functions.
Marc Maurer, president of the National Federation of the Blind, argued that airlines are “openly discriminating” when not using the most accessible technology.
“It is critical for blind people to be able to buy tickets, check in, print boarding passes and select seats independently,” Maurer said.
A rule that took effect in May 2008 required airlines to discount tickets for disabled passengers who had to make reservations by phone or in person. Airlines had to provide assistance to disabled passengers who couldn’t use their kiosks.
Parts of that rulemaking were hotly debated for years, with 1,300 comments. The Air Transport Association, an airline industry group, argued at the time it would cost each airline at least $200,000 to upgrade their website, plus tens of thousands more each year in maintenance.
Steve Lott, an association spokesman, said the group is still reviewing the newest proposal.
The administration estimates that tens of millions of dollars spent upgrading websites and kiosks would be offset by having more disabled customers buy tickets and saving the time of airline employees.
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This regulation is another example of government trying to implement an inefficient and costly requirement on taxpaying travelers. Look what requirements on tarmac delays have done – increased flight cancellations. Look at what the airlines did to find other revenues – they added exorbitant fees onto travelers if they couldn’t fit all their travel gear into a small bag. The airlines won’t pay for this requirement if it get enacted – everyone who travels will. I find it very difficult to believe that there is not a more reasonable cost way to achieve the same end goal.
Many people are responding to this, I don’t know if any of you are blind at all; but I am, again, the airlines didn’t take any of this into consideration when the put these into place at all. If we need assistance we will ask for it but at the same time, if someone cannot use something that everyone else can that is down right discrimination.
The DOT and the DOJ are the ones who need to get into this with the help of the ADA Laws.
By the way, this website isn’t the most accessible one either. You want to hear from us on this, but I use Magnification, others that I have posted this information to, to post in reference to this cannot because it is not accessible.
Also this particular case was thrown out of court due to the judge that said, ADA has no laws over this type of situation.
United Airlines Discriminates Against Blind Passengers
National Federation of the Blind Files Suit Over Inaccessible Kiosks
San Francisco, California (October 25, 2010): The National Federation of the Blind, the nation’s oldest and largest organization of blind people and the leading advocate for accessible technology, and three blind individuals—Michael Hingson, Mike May, and Tina Thomas—who reside in California and frequently fly United, filed a class-action lawsuit today in the United States District Court for the Northern District of California against United Airlines. United uses airport kiosks that employ touchscreen technology in a manner such that they… more »
Dr. Marc Maurer, President of the National Federation of the Blind, said: “The airline industry has an unfortunate history of discriminating against blind passengers, and now United Airlines is repeating that history by deploying inaccessible technology that we cannot use. United is engaging in this blatant discrimination even though the technology to make its kiosks accessible is readily available, has been deployed by others, and will involve little cost to the company. Instead of enjoying the features and convenience of these kiosks, including a quicker and more convenient check-in process, blind passengers must wait in long lines at the ticket counter, even when they have already purchased their tickets and checked in online. We will not tolerate a separate and unequal experience for blind passengers and demand that United cease its discrimination against us as soon as practicable.”
Michael Hingson, a blind motivational speaker and president and owner of a technology sales company, said: “I have traveled throughout the United States and the world for my public speaking engagements and as a technology sales representative, yet I cannot independently check in at the airport. It frustrates me, as a frequent traveler and United passenger, that I must wait for a United employee to assist me with the kiosk, seek help from a sighted passenger (in which case I must share sensitive private information with a total stranger), or else stand in a long line in order to complete the airport check-in process. I hope that this lawsuit will serve as a wake-up call to United and that the airline will swiftly make its kiosks accessible.”
Mike May, CEO of the Sendero Group, a leading manufacturer of technology for the blind, said: “I have been working in the adaptive technology field for twenty years, and I know well that it is easy and practical for United to make its kiosks accessible. There is simply no excuse for the long wait and inconvenience that other blind United passengers and I continue to experience at airports.”
Tina Thomas, a member of the United States Paralympic Judo Team, said: “I find it extremely ironic that United, which touts itself as the official airline of the U.S. Paralympic Team, discriminates against me as a member of that team and as a blind person. I sincerely hope that United will make a more serious and tangible commitment to treating passengers with disabilities equally.”
Plaintiffs are represented in this matter by Daniel F. Goldstein and Gregory P. Care of the Baltimore firm Brown, Goldstein, and Levy; and Laurence W. Paradis, Karla Gilbride, and Kevin Knestrick of the Berkeley firm Disability Rights Advocates.
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Generally speaking, I don’t think there should be government regulations on accessibility standards for check-in kiosks. Instead, let competition between airlines create similar accessibility standards. If implementing these standards helps a lot of people and is cost effective, chances are an airline will set them in place, and many other airlines will likely follow suit to stay competitive. The DOT setting accessibility standards would only increase the cost of traveling for millions of Americans. There needs to be a cost-benefit analysis in these situations to determine if the benefit is really worth the cost of what is being proposed.
Hi Chandler2, welcome to Regulation Room. DOT is proposing these regulations now because it believes that inaccessible kiosks are a violation of the Air Carrier Access Act. In addition, DOT has estimated that the benefits of this proposal will outweigh the costs. You can read more about its estimates the Kiosks: Benefits and Costs of Accessibility post. Do you think that DOT has taken everything into account in its estimation?
Another standard worth looking at is the Election Assistance Commission’s Voluntary Voting System Guidelines (VVSG).
This is an interesting suggestion, whitneyq, thanks. Could you provide a little bit more information on the guidelines, and perhaps a link to them, so that others can see what you mean? Also, what might make these better than the guidelines DOT is suggesting here?
Chapter 3 of the VVSG is only interesting because it specifically addresses kiosk-type systems, with no personal assistive technology. It draws on 508 and WCAG along with AADAG.
You can find it here: http://www.eac.gov/testing_and_certification/voluntary_voting_system_guidelines.aspx
Thanks for the link, whitneyq. Can you explain a little bit about what you think of the VVSG standard compared to DOT’s proposal? Or do you just see this as a source of standards DOT hasn’t addressed?
I applaud the inclusion of a standard set of symbols for common functions. Unlike a personal computer, we use many different airlines. It will help if they all have the same tactile symbols.
Hello whitneyq. Since it would help to have a standard set of symbols, do you think that DOT should specify how the alphabetic keys are arranged so that the layout there is standard too?
Private listening / Headphone jack:
Because financial transactions are being conducted on such kiosks, a private listening option must be provided through an industry-standard headset connector. A headset/headphone jack is better than a handset, because people may not have two hands free to simultaneously hold the handset and operate the device (for example, because they are holding luggage or have a physical limitation).
In addition, a headset jack is required to allow users to connect their own neckloops or other hearing technologies to the device besides just headphones. Because different headphones and other hearing technologies will result in different volumes when plugged in, a volume control must be also be provided.
Headphone jacks are typically the most inexpensive option available… more »
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HI jbjordan and thank you for contributing such excellent comments.
In DOT’s past rule makings, airlines pushed back hard on DOT’s cost-benefit analysis and succeeded in convincing DOT not to issue the proposed rule. From what you’ve written it looks like you have some experience in accessibility design; DOT would benefit from any input you or others might have on their cost estimates or how long it will take airlines to implement the new rules. You can comment on those issues on the Kiosk cost/benefit post and Kiosk which/when post.
Wireless technology:
It is possible to wirelessly pair a Bluetooth headset or headphones to a device to provide audio to the user. The biggest problem with Bluetooth audio is that a user must pair the device. Typically there are pairing settings in a visual menu on a Bluetooth enabled device, but a person who is blind cannot see to make the pairing and they cannot yet hear because the Bluetooth headset is not yet paired! Also, Bluetooth is likely of limited utility because not everyone who might use such wireless headsets at a kiosk owns a wireless headset or has them available when they need them. Today, a headphone jack is a better choice to use because more people carry around personal headphones for private listening. Airlines buy inexpensive headphones in bulk and could potentially make… more »
Tactile Controls:
Tactile controls that meet the specifications in Section 508 [36 CFR 1194.23(k) & .25(c)] are good to include. Having tactilely discernible controls is good for people who must explore the device and find controls by touch. It is necessary to be able to find the controls without activating them or surrounding controls by simply touching them. Similarly, providing the status of toggle/locking controls audibly or tactilely is good for people who cannot see so that they can determine the status. It is best if they do not need to change the status in order to discover it; however, since it is easily reversed, this is not necessary.
Timed Response / Timeouts:
Timeouts that cannot be extended present an accessibility barrier to people who cannot see and who must slowly navigate through items on the screen and then listen to them. Timeouts are also an accessibility barrier to people who have slow movement, those who need to plan movement in advance, those who need time to digest information they had just heard or read, and to people who may lock up or freeze when they realize they are under a perceived short deadline to get something done.
Certainly, unattended kiosks often need to have an inactivity timeout that resets the kiosk if the user leaves in the middle of a transaction. However, a kiosk can have short timeouts and still provide sufficient time for those who need it. It can also have short timeouts and still… more »
jbjordan’s suggestion is a good one.
Tactile icons / symbols:
The tactile markings are taken from the ADA Accessibility Guidelines for ATM keys on a numeric keypad. Those exact markings should not be required for *all* other types of keypads, keyboards, or controls because they are not appropriate in all circumstances–for example, the Enter key on a keyboard is discernible by location and size (and shape in many cases) and should not be required to also have a raised circular tactile icon on it. As another example, a different device with right and left keys for navigation might be marked with raised right and left arrows, which would conflict with the Clear/Correct labeling of ATMs. It might be best for the ATM conventions to apply if an ATM-like interface and keypad is used, but it is too limiting for other circumstances and approaches to making kiosks accessible.
Keypad & keyboard arrangement:
Numeric keys on a physical, hardware input device must be available in a standard arrangement for people who touch type and cannot see. Number keys may be provided in a 3×4 numeric keypad in (1) an ascending (telephone-style) or (2) descending (10-key computer style) arrangement of keys or (3) in a line at the top of a touch-type-able QWERTY keyboard. These three arrangements are common and recognized by users.
It would be good to specify a QWERTY arrangement for physical, hardware keyboards on which users can touch type if they are included on kiosk. Many people who are blind can touch type.
A biometrics provision like this is very important to include per-emptively so that equivalent provisions do not need to be added later if/when biometrics become more widely used. Retrofitting a kiosk later to include a biometric alternative would certainly be very expensive. This gives vendors and airlines clear guidelines for biometrics and allows them to calculate the cost of inclusion.
Having two biometric identification or control systems is usable by more people than only having one. However, there are some people, such as some veterans, who might have difficulty with both a fingerprint and iris scanner for example. A system with a non-biometric alternative would be usable by more people than a two-biometric system.
Display height:
This is a useful provision for people in wheelchairs and people with short stature. The intent of the provision is that people can read the display from a point 40 inches high, not simply view it. Revising the provision slightly, using the word “readable” instead of “visible” would make the intent clear.
Contrast ratio for screens:
A value for the contrast ratio between text and its background should be specified so that designers have guidance about how much contrast is necessary. In order to harmonize with other standards, a value of 3:1 should be used (using the formula in the web content accessibility guidelines (WCAG 2). For enhanced contrast, a ratio of 1:4.5 or even of 1:7 might be specified.
Usable without body/skin contact:
Some people cannot easily use a touchscreen or other controls if that touchscreen requires body or skin contact. For example, a person with prosthetic hands would not be able to use a capacitive touchscreen. While it would be preferable if they could use the touchscreen directly, the person should at least be able to use alternative controls to access the device.
A new provision might read: “Usable without body contact. A least one mode of operation for all functionality shall be provided that does not require body contact or close contact.”
Usable without speech:
Some people cannot speak clearly enough or at all to use speech recognition systems. For example, a speech recognition system may be unable to understand the speech of a person who became deaf early in life. While speech recognition is not generally included as an option in today’s kiosks it is technology that is being used more widely in consumer electronics now, and a provision should be added to future-proof the legislation.
A new provision might read: “Usable without speech. At least one mode of operation for all functionality shall be provided that does not require user speech.”
I agree with jbjordan, I have epilepsy so any flashing lights are out of the question. I also can not speak loudly or clearly enough due to an implant to control my seizures. So any devices would have to be without the flashing lights, and no verbal recognition. A provision for another person to be with us would be very helpful. Some of us (a good number) get confused easily and need that extra help.
I am also in a wheelchair or have a walker a lot of the time, especially for long distances. So allowing someone to escort us to the gate, and through the check-ins would be wonderful.
Hi, joanneread, and thanks for your input about avoiding flashing lights and verbal recognition. One suggestion that DOT is considering is having kiosks equipped with a telephone-style handset attached to them. Do you think that this might be a potential work-around for travelers who have difficulty speaking loudly?
Hello again, Joanneread. The team at Regulation Room looked into your concern about needing additional assistance, and we think we’ve found something helpful. TSA, the agency in charge of airport security, maintains a list of Tips For the Screening Process for travelers who may need extra assistance. Specifically, they say “”Your companion, assistant, or family member may accompany you and assist you during a private or public screening. After providing this assistance, the companion, assistant, or family member will need to be rescreened.” Hope this helps.
Flashing & seizures:
People with photosensitive epilepsy may have seizures if there is fast, bright flashing from lights or a display. As an easy rule of thumb, fewer than three flashes per second is generally considered safe. Flashing faster than that rate may be safe, but depends on the intensity and size of the flashing area. The web content accessiblity guidelines (WCAG 2) has a standard for flashing that is useful.
Visual & Speech interfaces coordinate:
It is very good that the provision requires that the speech output be coordinated with visual output for the very reasons mentioned. It should also be noted that many people who are legally blind can see, and the visual display can be helpful for them even if the text is too small to be read. A headphone jack would be better than a handset because a person might not be able to use two hands (e.g., holding luggage or because of disability) to both control the device and hold the handset.
Speech output:
The provision references being “speech enabled.” People reading the provision may initially assume the phrase means “speech recognition,” because of increasing consumer familiarity with that technology. Instead, the phrase “speech output” should be used because it is more accurate.
Importance of volume control:
It is important that a system have volume control for all forms of audio output. This includes both the standard output and any assistive audio output. People plugging in headphones or hearing technologies into headphone jacks need to have control over the audio because the volumes vary widely for different headphones. What might be a fine volume for one person with one set of headphones might be painfully loud to another person with a different set of headphones. With speakers, the user may need to adjust the volume to account for ambient noise or their own ability to hear.
Volume gain:
Note that specifying an absolute volume level for headphones cannot be done because of differences between headphones. The audio signal should be provided at a standard output level for the jack with volume control. People who need significant amplification beyond what is usually provided at the audio jack of a computer or kiosk may carry a personal audio amplifier or amplified headphones.
It is important that the method of changing the volume does not require the person to initially hear the audio. For example, a person who is blind and has difficulty hearing at the default level would not be able to adjust the volume if the only means for doing so were to navigate through audio menus on the system.
Finally, since some users who are hard of hearing may set the volume very high, it is important that the volume be reset after each user.
Captioning:
The captioning provision is a good provision and should be kept. Besides being helpful to travelers who cannot hear well, captions are helpful for all people when the airport environment is too loud. It also helps those travelers for whom English is a second language because they can both read and listen.
It seems to me that a review of currently available technology and the experience of people with disabilities in its use, should be helpful in developing kiosks that can be adequately used by most people with most disabilities. I don’t see why most kiosks can’t be accessible by the time the rules are effective.
Hi aews175. Can you explain a little more about your comment? Do you mean that you think that if DOT consults with people with disabilities and looks at currently available technologies, developing kiosk standards should be straightforward? What do you think about the standards DOT is proposing?
there needs to be more mobile and hands on devices to provide access to information aat the kissok nadn information boards. Possible links to i phones to list curret information or EM alerts. At present screen readers are not owrkable on webliinks and the touch screens at data terminals are not usable
Hi timniles and welcome to regulation room. It sounds like you’re pointing out a problem with both kiosks and websites: that airline kiosks are not accessible and even though the information is online and available to travelers through personal mobile devices, those websites are also not accessible. Is that right?
Are you suggesting that connecting personal mobile devices, such as iPhones, to kiosks would help make the information accessible?
It is essential to have multiple methods of biometric identification. Eye disease can prevent adequate imaging of the iris or retina, or an inability to hold the eye still.
Hi lhare, thank you for sharing your knowledge. Since you see biometric identification technologies as a potential barrier to accessibility, what do you think of jbjordan’s comment that DOT should propose accessibility regulations for biometric readers even though they aren’t widely used right now?
I agree that regulations should be established before biometrics are in common use. Designing a feature to be accessible from the ground up is cheaper and takes less work than retrofitting. If regulations don’t appear until biometrics are already required to fly or in wide use, there will be a delay and some kind of burdensome process for people who cannot use the technology. If equipment manufacturers know the rules before they design technologies, they can incorporate it. People with disabilities are often left behind with technology upgrades and putting regulations into effect now would prevent that.
Not all blind people are knowledgeable about operating touch screens. The learning curve is too steep for the airline check-in process.
Do you have any suggestions for how DOT can resolve this problem? Cherylechevarria has suggested that airport kiosks should be more like ATMs. Would that help?
Yes, a keypad with distinct keys as described on this page for ATMs or mass transit ticket machines is much more readily accessible.
I know that there have been a lot of innovations and research done to create accessible machines for voting (for President etc.). The DOT might want to look at some of these innovations when designing kiosks that are accessible.
As a person with a visual and mobility disability I find it difficult to use kiosks because it is very hard to put in credit cards etc. because there is no guide (something tactile to put my credit card in before it is loaded). I know that most airlines are going to a kiosk only check in and no human person to assist and it is frustrating because I can’t see or feel where to put in information and/or get information out such as boarding passes etc.
I have had to use strangers to help me put in credit cards etc. when using a kiosk and this is very concerning to me. I am hopeful that when designing a new kiosk system there would be some privacy guidelines and/or shell so that a person can put in there ID and Credit Card for charges without having to be totally in the open.
Hi jalexander. Thank you for your comments. Privacy is certainly a major concern of these regulations. Can you give us an idea of what kind of changes or guidelines would help make credit card use more private at these kiosks?
I am wondering if there would be a way of auditorily accessing information on the display screens (that are high above and give information about whether or not flights are on time and when they will be flying). At this time it is very frustrating because even if you are at a gate and knew the initial departure of your plane the gate display does not neccesarily tell you about changes to that departure time or to the gate. I have run into situations where the gate and departure times have changed and because there was not human interaction it was hard to dealing with the situation. I also have a mobility disability and need airport assistance to get from check in to the gate and had no way to access airport assistance if my gate changed. The people that provide assistance with getting me wheelchair… more »
Chrisa and Jalexander, at this point the proposal is limited to interactive kiosks. However, DOT recently issued a clarification of some parts of the proposal. They explained that an “automated kiosk” is “a self-service transaction machine…available at a U.S. airport to enable customers to independently obtain flight related services.” So these regulations would cover more than just check-in kiosks, in particular it would cover self-service kiosks that are past security check-points.
Perhaps these kiosks would be able to perform the scheduling functions you asked about?
That clarification is available in several forms on the agency documents page. The relevant section is on pages 16 and 17 of the PDF.
please work toward making schedule signage accessible to people who are visually impaired
Chrisa and Jalexander, at this point the proposal is limited to interactive kiosks. However, DOT recently issued a clarification of some parts of the proposal. They explained that an “automated kiosk” is “a self-service transaction machine…available at a U.S. airport to enable customers to independently obtain flight related services.” So these regulations would cover more than just check-in kiosks, in particular it would cover self-service kiosks that are past security check-points.
Perhaps these kiosks would be able to perform the scheduling functions you asked about?
That clarification is available in several forms on the agency documents page. The relevant section is on pages 16 and 17 of the PDF.
Regarding that DOT notes that software is now available to give people with vision impairments access to touchscreen-based technology: the recent software is useful for many users but will likely not be useful for all of them. DOT should consider testing this software with a wide range of potential users so that a proper cost-benefit analysis can be completed before making a revision to allow this software as an alternative to tactile keys.
Time-outs are an accessibility barrier. Especially when using a new kiosk, it takes additional time for other users and me to learn how to conduct a transaction. For example, Amtrak has accessible kiosks, which are very useful for printing a ticket already purchased (equivalent to just getting a boarding pass for a flight), but it may take significantly… more »
Regarding time-outs, do you think jbjordan’s suggestion would work? Do users with disabilities need more time?
Do other commenters have experience with the Amtrak kiosks? Do they work well? Should DOT consider these as a model?
If closed-captioned, the trigger (whether icon, button, key, etc.) to activate captions should be clearly visible and easy to find. Perhaps a standardized location.
Welcome to RegulationRoom and thank you for your comment. Do you think requiring open-captioning would be a better/easier solution?