sages; the ability to change the color, font, or lighting on keypads and screens; and the provision of speech output on cell phones.94


Usability Telecommunications service providers and manufacturers must also evaluate whether their products and services are “usable by” individuals with disabilities.95 This mandate requires functionally equivalent access to the full operation of and the documentation for the product, including instructions, product information, technical support hotlines and databases, customer support call centers, repair services, and billing departments. Among other things, companies must provide end-user product documentation in alternate formats (such as braille and large print) and access to services in alternate modes (TTY, e-mail, etc.) at no additional charge to the consumer requesting these accommodations.

The FCC has also stated that “usable by” requires manufacturers and service providers to include consumers with disabilities in market research projects, focus groups, pilot demonstrations, and product trials when a company otherwise engages in these activities. Similarly, companies must make reasonable efforts to validate unproven access solutions with people with disabilities or disability-related organizations.


Compatibility The FCC’s rules explain that the Section 255 requirement to make mainstream equipment compatible with peripheral devices applies to peripheral devices employed in connection with telecommunications equipment or customer premises equipment used to translate, enhance, or otherwise transform telecommunications into a form that is accessible to individuals with disabilities, such as TTYs, visual signaling devices, and amplifiers.96 The requirement to achieve compatibility with SCPE covers equipment commonly used by individuals with disabilities to originate, route, or terminate telecommunications, such as direct-connect TTYs.97 Assistive technology devices, such as hearing aids or eyeglasses, which have a broad application outside the telecommunications context, are not SCPE or peripheral equipment even if they are used in conjunction with telecommunications devices. In addition to its overall mandate to provide compatibility, FCC rules have four very specific requirements for telecommunications compatibility:

94

The last accommodation was the product of a formal complaint under Section 255 against Verizon Wireless and Audiotext for their failure to make an accessible wireless phone for people who are blind or who have vision disabilities. The cell phone with speech output was produced after a settlement was reached between the parties.

95

47 C.F.R. §6.3(k).

96

47 C.F.R. §§6.3(b), (f).

97

47 C.F.R. §§6.3(h).



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