Profile: jbjordan
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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.
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.
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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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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 »
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.”
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.