tion of their network architecture (i.e., hardware, software, and databases associated with the routing of telecommunications services) complies with the FCC’s accessibility rules.

FCC Regulations

FCC rules on Section 255, effective since January 28, 2000, require telecommunications manufacturers and service providers to evaluate the accessibility, usability, and compatibility of equipment and services, as early and consistently as possible throughout their design, development, and fabrication. All basic and advanced telephone services including call waiting, speed dialing, call forwarding, computer-provided directory assistance, call monitoring, caller identification, call tracing and repeat dialing, interactive voice response systems, and voice menus are covered under the rules. In addition, under a ruling that came out in June 2007, services provided by interconnected voice-over Internet protocol providers are covered because of their functional similarity to traditional telephone services.91

The customer premises equipment covered by the rules includes all equipment used on an individual’s premises to originate, route, or terminate telecommunications, as well as software integral to the operation of the telecommunications functions of the equipment, whether or not it is sold separately. Examples are wireline and wireless telephones, pagers, and fax machines.

Accessibility In determining whether a product is accessible, a manufacturer must evaluate the extent to which the product’s various input, control, and mechanical functions, as well as its output, display, and control functions, are operable without vision, hearing, manual dexterity, speech, cognitive skills, and other functionalities.92 All information needed to operate the product, including “text, static or dynamic images, icons, labels, sounds, or incidental operating cues,” must also be made accessible to people with various types of disabilities.93 Some of the access features that companies have already started to incorporate to meet the accessibility requirement include nibs or capital letters on keypads; vibrating features and volume control on telephones; jacks for TTYs; accessible telephone intercept mes-


Implementation of Section 255 and 251(a)(2) of the Communications Act of 1934, as Enacted by the Telecommunications Act of 1996, Access to Telecommunications Services, Telecommunications Equipment, and Customer Premises Equipment by Persons with Disabilities, Report and Order and Further Notice of Inquiry, WT Dkt No. 96-198, FCC 99-181, 16 FCC Rcd 6417 (September 29, 1999), codified at 47 C.F.R. Parts 6 and 7.


47 C.F.R. §6.3(a)(1).


47 C.F.R. §6.3(a)(2).

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