Users with hearing impairments may benefit from the use of the following ATs:

Users with mobility impairments may benefit from the use of the following ATs:

Users with cognitive disabilities may benefit from the use of the following ATs:

Some of these assistive technologies can be designed into the product lines themselves; others must be used externally to the device. There is an ongoing debate regarding the role of AT in universal design. At the core of the issue is whether the capabilities of AT should be built into mainstream products (those designed for the general public) or whether they should be separate products that can be used with mainstream products by those who need them. There are three schools of thought regarding the use of AT:

1. AT should be the primary solution to providing people with disabilities access to E&IT.

2. E&IT manufacturers should enhance the accessibility of their products to extents that are technically possible and economically feasible. Beyond this, AT should be used.

3. E&IT manufacturers should make all their products accessible by everyone, under all circumstances, in any situation.

While it is clear that a single design cannot accommodate all individuals in all contexts (Stephanidis, 2001; Vanderheiden, 1990), an inclusive design can accommodate a larger number of people than one designed for the “average” user. In addition, ATs themselves cannot readily accommodate the needs of all users, and it is burdensome and costly for AT to keep up with changing mainstream technologies. On the other hand, AT developers have detailed knowledge about the needs of users with various functional limitations, and they can develop better products if they can focus on the needs of their target users.

Some believe that the solution is for AT developers to develop better products rather than mainstream developers trying to design products that are useful to everyone. However, with this approach, people who need assistive technology are required to purchase AT products in addition to the mainstream products. They must also carry their AT device around so that they always have the capability to use a product. The best solution is, perhaps, a middle ground, keeping in mind that part of UD is ensuring compatibility with some types of AT (e.g., touchsticks), but UD doesn’t have to require the use of AT.

…[U]niversal design in [information technology and telecommunications] IT&T products should not be conceived as an effort to advance a single solution for everybody, but as a user-centered approach to providing products that can automatically address the possible range of human abilities, skills, requirements, and preferences (Stephanidis, 2001).

Assistive technology development, whether or not it is integrated in mainstream products, is critical. The Assistive Technology Act of 1998 (P.L. 105-394) provides federal support for research and promotion of AT; Title II specifically relates to coordinating research for assistive technology and universal design (U.S. Department of Commerce, 2003).

There are a number of arguments against the design of AT as separate products:

• AT requires added cost on top of the mainstream products and is affected, in part, by insurance reimbursement policies (U.S. Department of Commerce, 2003).

• AT is sometimes prohibitively expensive, even without the cost of the mainstream products.

• It is not always possible for a person to carry around all necessary AT products.

• AT is focused on a limited audience.

• Different AT is needed to accommodate different functional limitations.

• The economics of ATs are such that the limited market and limited purchasing power of the market will likely limit the abilities of AT companies to keep up with the pace of mainstream technologies.

• Often when an innovation in mainstream technology takes place, an update in the AT is required; this results in extra cost for the person requiring AT or, at the very least, introduces risk. For example, installation of a new software product may interfere with the operation of existing AT. Technology is changing so rapidly that once an access problem is solved, it is common for a new access problem to surface (Stephanidis, 2001; Emiliani, 2001).

• While ATs can be portable, security concerns may prohibit their use; for example, a library may prohibit the installation of a screen magnifier on a public computer.

• AT companies do not have the resources needed to work closely with companies to ensure compatibilities with their products or to do product testing (U.S. Department of Commerce, 2003).

• AT companies often do not share the features they have planned for their products with other companies until the AT is released. While industry would like to have the data sooner, AT companies are reluctant to promise technologies that they might not be able to deliver.

Arguments favoring the design of ATs as separate products include the following:

• AT allows companies to focus on the development of their specialized products, thus resulting in a better job of handling the accessibility issues to meet the needs of people with disabilities.

• It is possible for AT to become so mainstream that it is no longer considered AT. Eyeglasses, for example, are no longer thought of as assistive technology, and closed-captioning and voice recognition software are becoming more commonplace.

• AT is better equipped to handle specialized or rare needs of people with disabilities, and there will likely always be a need for some forms of assistive technology. In addition, AT can be tailored to address unique needs (U.S. Department of Commerce, 2003).

Arguments for integrated AT and UD include the following (Vanderheiden, 1990; Winograd, 1997):

• Many product adaptations necessary to accommodate some functional limitations can be implemented in mainstream products at little or no extra cost.

• Many product adaptations necessary to accommodate some functional limitations can also facilitate use by the general population (e.g., the curb cut). Some benefits of implementing accessibility features that have a more global benefit include lower fatigue, increased speed, and lower error rates.

• AT cannot accommodate the needs of the many individual subgroups that have special needs (e.g., mild versus severe hearing loss).

• Special features can be integrated into mainstream products so they are transparent to users who don’t need them (e.g., “sticky keys”).

Regardless of how people with disabilities use the technology, it will have a large impact on their independence and ability to fully participate in society, resulting in an added cost benefit to society as a whole (Vanderheiden, 1990). The population of people who may require some sort of accommodation is ever-growing with the increase of the elderly population, so much so that the term “general population” possibly should be redefined in the minds of designers. Although the market potential for products is great, the limited population for any given AT creates financial constraints for small companies that focus on AT development. Large companies typically have the finances but not the expertise to address a wide range of needs (AAATE, 2003). Complications stem not only from the wide variety of functional limitations but also from the ever-increasing need for rapid configuration of technologies to accommodate environmental and other contextual needs. The increasingly mobile society, for example, may mean that individuals need specialized accommodation over a period of a day or even hours, while a more fixed environment may require little variation in configuration. “…[I]n the context of the emerging distributed and communication-intensive information society, users are not only the computer-literate, skilled, and able-bodied workers driven by performance-oriented motives, nor do users constitute a homogeneous mass of information-seeking actors with standard abilities, similar interests, and common preferences with regard to information access and use” (Stephanidis, 2001, p. 6). The AT industry alone cannot address the variable contexts that create a need for more customized situational technologies.

If products are not going to be designed with AT built in, they need to be designed from the ground up to be fully compatible with AT, and AT needs to be designed so well that people with disabilities no longer have accessibility issues with products. If products are designed with UD principles in mind, they will likely be accessible to a large number of people with disabilities without the use of AT. Regardless of the resolution to this debate, if any, AT and mainstream developers must work together to achieve the greatest accommodation possible and to develop adaptors, when necessary. “The use of an adaptor is appropriate when two systems cannot otherwise accommodate each other; this is the case when accessibility problems are alleviated by the choice of alternative input/output devices or by communication via an alternative modality” (Benyon, Crerar, and Wilkinson, 2001). Thus, there is a place in society for both integrated AT and UD, as well as for separate AT products.

Research Process

An extensive research program was conducted to complete each of the research activities documented in this report. This research program was conducted by examining the roles and perspectives of industry, Federal Government, and consumers with respect to the six product lines that are important to people with disabilities. The six product lines studied were automated teller machines (ATMs), cellular phones, distance learning software, personal digital assistants (PDAs), televisions, and voice recognition technologies. For more information about the research process undertaken in preparing this report and additional information, please consult the online version of the report at http://www.ncd.gov.

II. Market Definition and Research

Electronic and information technology is driving the creation of new communities that are forever changing the way people live, learn, work, and play. Companies are increasingly expanding their presence in emerging markets. Businesses are serving populations they have never served before. Every consumer is different. No two people have the same set of characteristics, learning styles, abilities, experiences, or educational backgrounds. Developing products that accommodate the wants, needs, and preferences of as many individual consumers as is technically possible and economically feasible can greatly enhance a company’s competitive advantage.

Designing with access in mind can significantly increase the size of E&IT markets on a global basis. Good business practices dictate that designers and engineers avoid excluding large groups of consumers from accessing and using E&IT. Groups at the highest risk of unintentional exclusion are—

• People with disabilities

• Individuals 65+ years old

• Consumers living within low-bandwidth information infrastructures

• Users of English as a Second Language (ESL)

• Tourists traveling to nonnative language destinations

• Consumers living in high-density populations

This market analysis examined many aspects of manufacturing “more accessibly designed” E&IT. This analysis was intended to help answer questions such as the following:

• Is there a market for more accessibly designed products?

• Does the capacity exist to develop more accessibly designed products in each of the presented product lines?

• What factors influence the market for more accessibly designed products for each of the product lines presented?

All the product lines reviewed in this report are manufactured by members of the E&IT industry. Naturally, in order for these products to be manufactured, the E&IT industry must exist. In order to exist, it must be profitable. A question often asked by the disability community is, “How can we ensure that the E&IT products and services being manufactured are accessible to people with disabilities?” E&IT manufacturers pose a similar question. They ask, “How can we ensure that the E&IT products and services we manufacture are accessible and usable by as many people as is technically possible and economically feasible without the need for customization?” The questions are different. The motivations are different. The market drivers are different. The solutions can be remarkably similar.

Definition of the Market Environment

Historically, the primary forces driving the manufacture of more accessible E&IT products and services have been legal, moral, social, and ethical. The assumption was that if legal, moral, social, and ethical issues no longer existed, the motivation to manufacture more accessible E&IT would all but disappear. The next two sections discuss the reasons why nothing could be further from the truth.

In contrast to the historical notion of what the primary forces driving the manufacture of accessible E&IT are, in actuality a majority of the forces driving demand for more accessibly designed E&IT fall into the following five categories:

• Market forces

• Local environment

• Human condition

• Legal framework

• Standards and guidelines

Market Forces

Market forces consistently drive the demand for more accessibly designed E&IT. Market forces include the need to respond to consumer behavior, the work of federal agencies, legislation mandating developments in the accessibility of E&IT, changing marketing philosophies (from mass marketing to a one-on-one marketing philosophy), competition within the market, emerging technology trends, and economic expansion. These market forces are discussed below in terms of how they drive the markets for more accessibly designed E&IT products.

Consumer Behavior

E&IT is prevalent in schools, libraries, individuals’ homes, work environments, places of recreation, banks, and even supermarkets. It is because of this widespread presence that consumers are more technically literate than they were five years ago. Devices such as cell phones, PDAs, voice recognition systems, and the wireless Web enable us to carry our offices with us when we travel. We are more mobile now than ever before. Consumers have become accustomed to getting the information they need when they need it and where they want it. This has created an expectation of immediacy. When consumers don’t get what they want quickly, they become impatient. E&IT designers need to respond to consumer behavior by providing products and services that not only meet but exceed the high expectations of a technically literate, mobile consumer base. Increasing the accessibility of information services and mobile technologies increases access to the information demanded by consumers with high expectations.

Federal Government

The Federal Government serves as a catalyst for more accessibly designed E&IT products through its buying power, the development of legislation, and the support of AT accommodation labs. Section 508 of the Rehabilitation Act amendments of 1998 mandates the purchase of accessibly designed E&IT. As a result, all federal agencies appointed section 508 coordinators (Section 508, 2003). Those coordinators are responsible for organizing and supporting the implementation of section 508 in their respective departments and agencies, and they serve as the central point of contact for information concerning accessibility issues and solutions. In addition to section 508, other legislation provides guidelines for designing more accessible E&IT. The Architectural and Transportation Barriers Compliance Board (Access Board) developed the ADA Accessibility Guidelines for Buildings and Facilities (ADAAG), and the Telecommunications Act Accessibility Guidelines (section 255) mandates the design of more accessible E&IT products and services. There are also presidential initiatives driving the design of more accessible E&IT. These initiatives include the President’s New Freedom Initiative (White House, 2001), the No Child Left Behind Initiative (U.S. House of Representatives, 2002), and the disabilityinfo.gov Web site (DisabilityInfo.gov, 2003).

In addition to these acts and initiatives, many federal agencies have created AT accommodation labs. These labs serve as focal points for information regarding accommodations, disabilities, and assistive technology. These resources include the following:

• Department of Agriculture’s TARGET Center
  http://www.usda.gov/oo/target

• Department of Education’s Assistive Technology Program
  http://www.ed.gov/offices/OCIO/programs_services/assistive_technology/index.html

• Department of the Interior’s Accessible Technology Program
  http://www.doi.gov/atc

• Department of Transportation’s Disability Resource Center
  http://www.drc.dot.gov

• Department of Labor’s Job Accommodation Network
  http://www.jan.wvu.edu

• The National Institute on Disability and Rehabilitation Research, U.S. Department of Education’s ABLEDATA database of assistive technologies
  http://www.abledata.com

• Department of Veterans’ Affairs Adaptive Training Program
  http://www.va.gov/oirm/itss/itc/brochsb.htm

• General Services Administration’s Center for Information Technology Accommodations (CITA)
  http://www.gsa.gov/Portal/gsa/ep/contentView.do?contentId=9815&contentType=GSA_OVERVIEW

Clearly, the Federal Government is an important market force for driving accessibility requirements.

Marketing Philosophies

Marketing philosophies have changed radically over the past 35 years. The marketing philosophy of the 1960s was mass marketing (Mass Marketing Definition, 2003), in which the seller views the market as a homogeneous whole and, therefore, has only one marketing program (the same product, the same price, the same promotion, and the same distribution system) for everyone in the population. This type of marketing is also referred to as unsegmented or undifferentiated marketing.

Marketing philosophies of the 1970s included product line extension (Product Line Stretching Definition, 2003) and market segmentation (Market Segmentation Definition, 2003). Product line extension adds depth to an existing product line by introducing new products in the same product category. Market segmentation is the division of a totally heterogeneous market into groups or sectors with relatively homogeneous needs and wants.

In the 1980s, the marketing philosophy shifted to one of niche marketing (Niche Marketing Definition, 2003). Niche marketing or concentrated marketing is a marketing segmentation strategy in which the firm focuses all its efforts and resources on serving one segment of the market.

In the 1990s, value-added marketing became popular. Value-added marketing is a strategy in which a company buys products, customizes them for a particular application, and then resells them. There was also a shift toward marketing to individual customers rather than to the larger mass. Don Peppers and Martha Rogers invented the phrase “one-to-one” marketing (Peppers and Rogers, 1997) to illustrate the revolutionary concept of treating different customers differently. One-to-one marketing supports the establishment of permanent relationships with your customers. One-to-one subscribes to providing products and services to customers according to their individual wants, needs, and preferences. “Share of customer” replaces market share. The marketing focus shifts from institutions to individual consumers.

Once a company acquires the knowledge and experience required to manufacture more accessibly designed E&IT, it can take an asset marketing approach (Asset-Based Marketing Definition, 2003) to providing its E&IT products globally. Asset marketing uses the knowledge and skills a company has already developed as the basis for growth. For example, a company that is skilled in developing kiosks that are accessible to people who are blind can market kiosks designed in a similar manner to countries that have high populations of people who have never learned to read. This global marketing (Global Marketing Definition, 2003) philosophy enables companies to sell the same, or very similar, products to world markets with essentially the same promotion. This marketing approach is also commonly referred to as international marketing.

Competition

Competition in the E&IT industry is fierce. The industry is constantly looking for ways to increase efficiency, competitive advantage, sales, market shares, and profitability. It is also looking to cut costs. Businesses are constantly developing new and innovative products and services with the hope of achieving these objectives, and adding functionality that enhances the accessibility and usability of a product can be very beneficial. In extremely competitive markets, several companies have correctly identified UD as a potential market discriminator. When highly similar product lines are all competing for the same customer, a product designed with access in mind may have the needed advantage required to outbid the competitors.

Technology Trends

A variety of rising mainstream technology trends fuels the need for more accessibly designed E&IT. The functionalities of multiple individual devices are now being integrated into a single device, including pagers, cell phones, PDAs, palmtop computers, smart phones, MP3 players, and so on. This trend is creating a dependence on one device to accomplish multiple functions. Thus, if not more accessibly designed, this multiple functionality precludes the use of such devices by certain segments of the population, for example, people 65+ years of age. Developing and manufacturing an accessible interface for a device that provides multiple functions is less expensive than developing and manufacturing an accessible interface for multiple single-function devices.

Decreasing costs are making E&IT devices more affordable to emerging markets, which have the greatest concentration of individuals with low income and a greater concentration of individuals who are unable to read and write. E&IT manufacturers need to move into emerging markets in order to increase sales and gain competitive price advantage through economies of scale.

Increasing processing power, disk storage, memory capacity, and battery life are enabling developers to integrate advanced access technologies (speech recognition, text-to-speech synthesis, projected displays, etc.) into devices where it had not previously been technically possible to do so. In addition, the Internet and the World Wide Web are now being used as a primary infrastructure for education, government services, news, and business. Customers’ technical knowledge and expectations are constantly increasing, along with the use of wireless Internet appliances and wireless infrastructures. Legal mandates to manufacture more accessibly designed E&IT in support of people with disabilities are a driving force behind these technological trends.

Economic Expansion

The strength of our global economy is, to a great extent, the result of the investment in and application of new technologies by governments, businesses, and individuals. Technology is the foundation upon which developing countries can build thriving, financially independent, self-sufficient economies. The technologies that build this foundation include computers, networks, ATMs, wired and wireless information infrastructures, wireless handheld Internet appliances, and cellular telephones, to name a few. Applications include online banking, distance learning, e-government, and e-commerce (World Information Technology, 2003).

Local Environment

Another force that drives the market for accessibly designed E&IT is local environments. The following is a discussion of two environmental factors: variances in bandwidth and tourism.

Bandwidth

As of May 2004, more than half (51.39 percent) of home Internet users in the United States relied on dial-up modems of 56Kbps or less. Of all U.S. home Internet users, 42.53 percent used 56Kbps modems, 6.52 percent used 28/33.3Kbps modems, and 2.34 percent used 14.4Kbps modems (Nielsen/NetRatings, 2004).

Computers using dial-up connections cannot handle graphics as quickly and efficiently as computers connected via broadband. It is for this reason that dial-up users surf the Internet with graphics turned off. They do this to speed up downloads. Low-bandwidth connections do not lend themselves to a lot of graphic images, video-based information, or streaming audio. Multimedia content can be problematic for users with slower connections. Wireless devices communicating with the Internet at slow connect speeds can also be a source of accessibility and usability problems.

There are solutions to these problems. Some companies have the ability to control the settings on the browsers used on their employees’ PCs. When available corporate Intranet bandwidth is at a premium, these companies can simply issue a central command to turn off graphics on all client PC browsers. This can immediately free up as much as 80 percent of available bandwidth. Designing Web sites for low-bandwidth access tends to increase accessibility for users with disabilities. For example, a graphics- or animation-intensive site often requires high bandwidth and is inaccessible to those who are blind. In contrast, a text-based site loads quickly and is accessible to screen readers. Dial-up environments will continue to drive the development of more accessible E&IT in the foreseeable future.

Tourism

During the first quarter of 2004, the United States welcomed 8 million international visitors. This was an increase of 12 percent compared to the first quarter of 2003.

Visiting tourists often make use of ATMs, self-service kiosks, ticketing kiosks, and other tourism-related information technologies. Many tourists use English only as a second language. Content written in simplified English is more understandable to users of ESL. Simplified English content has other significant benefits. For example—

• It reduces the cost of language translation.
• It reduces ambiguity.
• It speeds reading.
• It reduces liability associated with misunderstandings.

The use of simplified content was originally included in various accessibility design guidelines in support of people with cognitive reading disabilities. Using simplified language has now evolved into a market force driving the design of more accessible E&IT.

Human Condition

Aside from forces stemming from the market and the environment, many of the forces driving the accessible design of E&IT fall under aspects of the human condition. E&IT products must be designed with people of different disabilities, various age groups, various levels of literacy, various languages, different learning styles, and different experience levels with activities such as using the Internet in mind. These aspects of the human condition bring with them the demand for accessible E&IT products that cater not just to one category but to many different types of users. Below is a summary of the forces that drive the demand for E&IT that is accessible to a wide range of users.

Disability

Census 2000 counted 54 million people in the United States with some type of long-lasting condition or disability (NCD, 2004). These individuals represented 19.3 percent—nearly one in five people—of the 257.2 million people age five and older in the civilian, noninstitutionalized population. Their conditions included a wide range of disabilities, not all of which precluded the use of E&IT. Within this population, Census 2000 found—

• 9.3 million (3.6 percent) with a sensory disability involving sight or hearing
• 21.2 million (8.2 percent) with a condition limiting basic physical activities, such as walking, climbing stairs, reaching, lifting, or carrying
• 12.4 million (4.8 percent) with a physical, mental, or emotional condition causing difficulty in learning, remembering, or concentrating
• 6.8 million (2.6 percent) with a physical, mental, or emotional condition causing difficulty in dressing, bathing, or getting around inside the home
• 18.2 million of those age 16 and older with a condition that made it difficult to go outside the home to shop or visit a doctor (8.6 percent of the 212.0 million people this age)
• 21.3 million of those ages 16 to 64 with a condition that affected their ability to work at a job or business (11.9 percent of the 178.7 million people in this age group)

E&IT products and services that are accessible to people with disabilities appeal to the wider population as well. Accessible design can significantly enhance the sales of a product. For example, all of the following products were first developed in support of people with disabilities and are now used by the wider population:

• Auto-dialers
• Flatbed scanners
• Microphones
• Speech recognition
• Speech synthesis
• Talking ATMs
• Talking caller ID
• Vibrating pagers

Age

There are 36 million consumers 65 years of age and older living in the United States (Population, 2003). People 65+ years of age are often not able to see, hear, think, or move about as easily as they did when they were younger. In order to enable people 65+ years of age to access and use E&IT, these differences must be accommodated. In addition, 52 percent of people 65+ years of age have some type of disability. Thirty-three percent of persons 65+ years of age have a severe disability.

By 2030, there will be about 70 million older persons, more than twice the number in 2000. People 65+ represented 12.4 percent of the population in the year 2000, but are expected to grow to 20 percent of the population by 2030 (Administration on Aging, 2002). Furthermore, individuals who are accustomed to operating E&IT will demand accessible E&IT as their functional capabilities diminish.

Language

Language is certainly a driving force in today’s market for more accessible E&IT. According to Global Reach, there are 262 million English-speaking people online. Non-English-speaking populations online are 474 million. By the end of 2005, the ratio of English-speaking to non-English-speaking users will decrease significantly (Global Reach, 2003).

Sixty-four percent of people who visit the Internet seek sites in languages other than English (Global Reach, 2003). In a world where International Data Corporation (IDC) predicted that Internet spending outside the United States will have exceeded $914 billion in 2003, effective Web site globalization is the next imperative of Internet enterprises (IDC, 2000). Despite the vast international opportunities projected, few U.S. companies appear poised to take advantage of them. More than half (55 percent) of U.S. companies do nothing to customize their Web sites for foreign visitors; less than one-quarter even allow a choice of language, according to recent IDC Internet Executive ePanel research. With such minor globalization efforts, it is not surprising that 72 percent of U.S. companies that are online currently draw only 10 percent or less of their e-commerce revenue from outside the United States. To increase their e-commerce revenue, companies must strive to design Web sites that are accessible to the non-English-speaking population.

Learning Style

There are three major types of learning styles (Live Text, 2000). They are visual, auditory, and kinesthetic. Visual learners need to see a person’s body language and facial expression to fully understand the content of what is being said. They tend to prefer sitting at the front of a classroom, play, or lecture hall to avoid visual obstructions (e.g., people’s heads). They may think in pictures and learn best from visual displays, including diagrams, illustrated textbooks, overhead transparencies, videos, flipcharts, and handouts. During a lecture or classroom discussion, visual learners often prefer to take detailed notes to absorb the information. Auditory learners learn best through verbal lectures, discussions, talking things through, and listening to what others have to say. Auditory learners interpret the underlying meanings of speech through listening to tone of voice, pitch, speed, and other nuances. Written information may have little meaning until it is heard. These learners often benefit from reading text aloud and using a tape recorder. Tactile/kinesthetic learners learn best through a hands-on approach, actively exploring the physical world around them. They may find it hard to sit still for long periods and may become distracted by their need for activity and exploration. Enabling people to acquire information in the manner most appropriate to their learning style(s) enhances the effectiveness of E&IT and accommodates users with sensory disabilities.

Experience Level

Many people who are learning to use an application on the Web for the first time want all the help they can get. There will come a time, however, when the extra help is no longer needed or desired. One of the benefits of accessible design practices is having the ability to customize user interfaces based on the wants, needs, and preferences of individual users.

Legal Framework

The following is a summary of key laws, statutes, and standards that have improved accessibility for individuals with disabilities in this country. Each law is summarized, followed by a discussion of who is primarily affected by the law and the law’s approach toward addressing accessibility issues. These laws and standards are a driving force in the market for accessibly designed products, as they set the standards and guidelines for what must be done by the government and industry to accommodate the needs of individuals with disabilities.

Section 508 of the Rehabilitation Act

Section 508 of the Rehabilitation Act of 1973 requires that when federal agencies develop, procure, maintain, or use E&IT, they must ensure that individuals with disabilities have access to and use of information that is comparable to the access and use by federal employees who do not have disabilities, unless an undue burden (significant expenses or difficulties) is imposed on the agency. The law also requires that individuals with disabilities in the general public seeking information or services from a federal agency have access to information and services comparable to that provided to individuals without disabilities, unless undue burden is imposed on the agency. When compliance does impose an undue burden, agencies must still provide disabled individuals with the information and data by allowing them to use it by an alternative means of access (e.g., captioning, audio description).

Section 508 covers E&IT such as computer hardware, software, networks, ancillary equipment, firmware, technology services, telecommunications products, information kiosks and transaction machines, World Wide Web sites, multimedia, and office equipment such as copiers and fax machines. Section 508 does not cover equipment that contains embedded information technology that is used as an integral part of the product but the principal function of which is not the acquisition, storage, manipulation, management, movement, control, display, switching, interchange, transmission, or reception of data or information (e.g., HVAC equipment and medical equipment). As a guideline, E&IT systems can be considered to be accessible to individuals with disabilities if they can be used in a variety of ways that do not depend on a single sense or ability.

Section 508 has the potential to greatly improve accessibility to E&IT for individuals with disabilities. The Federal Government will likely become a better employer to the many people with disabilities who work for it, as well as a model employer for industry. In addition, members of the public with disabilities will have greater accessibility to government information and services related to technology.

Those affected directly by section 508 include federal departments and agencies and vendors that serve the Federal Government. The initial impact is at the procurement stage. Section 508 must be integrated into the procurement process by determ